<<

DRAFT

April 2021 Denmar Natural Soda Ash Export Terminal and Remedial Activities

Addendum to the West Complex Development Plan Environmental Impact Report

Prepared for the State Clearinghouse Number: 2002032048

April 2021 Denmar Natural Soda Ash Export Terminal and Remedial Activities

Addendum to the West Complex Development Plan Environmental Impact Report

Prepared for Prepared by Port of Stockton Anchor QEA, LLC 2201 West Washington Street 130 Battery Street, Suite 400 Stockton, California 95203 , California 94111

Project Number: 160377-01.16

TABLE OF CONTENTS

1 Introduction ...... 1 1.1 West Complex Development Plan ...... 1 1.1.1 2004 Draft Environmental Impact Report...... 1 1.1.2 2007 Settlement Agreement ...... 4 1.1.3 Existing (2020) West Complex Conditions...... 4 1.1.4 Changes to the California Environmental Quality Act Since the West Complex Development Plan Environmental Impact Report...... 4 1.2 Addendum to the West Complex Development Plan Environmental Impact Report ...... 6 1.2.1 California Environmental Quality Act Requirements ...... 6 1.2.2 Project Modifications ...... 6 1.2.3 Incorporation of the West Complex Development Plan Environmental Impact Report and Settlement Agreement ...... 8 1.2.4 Conclusion ...... 9 1.3 Incorporation by Reference ...... 9 1.3.1 City of Stockton 2040 General Plan...... 9 1.3.2 City of Stockton Municipal Code ...... 10 1.3.3 City of Stockton Climate Actio n Plan ...... 10 1.4 Port Environmental Programs ...... 10 1.4.1 Water Quality ...... 10 1.4.2 Air Quality ...... 11 1.4.3 Habitat and Species ...... 12 1.4.4 Community Outreach and Support ...... 12

2 Project Description ...... 14 2.1 Environmental Setting ...... 14 2.2 Proposed Project Overview...... 14 2.3 Proposed Project Construction...... 19 2.3.1 Initial Remediation...... 19 2.3.2 Phase 1 Denmar Terminal Construction ...... 20 2.3.3 Future Remediation...... 26 2.3.4 Phase 2 Denmar Terminal Construction ...... 28 2.3.5 Environmental Management During Construction...... 28 2.4 Proposed Denmar Operations ...... 31 2.4.1 Phase 1 Operation ...... 31 2.4.2 Phase 2 Operation ...... 32

Denmar Addendum to the WCDP EIR i April 2021

2.4.3 Project Throughput ...... 32

3 Environmental Analysis ...... 34 3.1 Land Use and Agriculture ...... 34 3.1.1 Environmental Setting ...... 34 3.1.2 Regulatory Setting ...... 34 3.1.3 Mitigation Measures ...... 36 3.1.4 Methods/Approach ...... 36 3.1.5 Impact Assessment...... 36 3.2 Transportation and Circulation ...... 37 3.2.1 Environmental Setting ...... 38 3.2.2 Regulatory Setting ...... 39 3.2.3 Mitigation Measures ...... 42 3.2.4 Methods/Approach ...... 42 3.2.5 Impact Assessment...... 43 3.3 Air Quality ...... 48 3.3.1 Environmental Setting ...... 48 3.3.2 Regulatory Setting ...... 48 3.3.3 Mitigation Measures ...... 52 3.3.4 Methods/Approach ...... 52 3.3.5 Impact Assessment...... 53 3.4 Noise...... 59 3.4.1 Environmental Setting ...... 60 3.4.2 Regulatory Setting ...... 60 3.4.3 Mitigation Measures ...... 63 3.4.4 Methods/Approach ...... 63 3.4.5 Impact Assessment...... 64 3.5 Geology, Soils, and Seismicity...... 69 3.5.1 Environmental Setting ...... 69 3.5.2 Regulatory Setting ...... 71 3.5.3 Mitigation Measures ...... 72 3.5.4 Methods/Approach ...... 72 3.5.5 Impact Assessment...... 73 3.6 Hydrology and Water Quality ...... 76 3.6.1 Environmental Setting ...... 77 3.6.2 Regulatory Setting ...... 80

Denmar Addendum to the WCDP EIR ii April 2021

3.6.3 Mitigation Measures ...... 82 3.6.4 Methods/Approach ...... 82 3.6.5 Impact Assessment...... 82 3.7 Biological Resources ...... 90 3.7.1 Environmental Setting ...... 91 3.7.2 Regulatory Setting ...... 98 3.7.3 Mitigation Measures ...... 100 3.7.4 Methods/Approach ...... 100 3.7.5 Impact Assessment...... 101 3.8 Cultural Resources ...... 113 3.8.1 Environmental Setting ...... 113 3.8.2 Regulatory Setting ...... 117 3.8.3 Mitigation Measures ...... 117 3.8.4 Methods/Approach ...... 117 3.8.5 Impact Assessment...... 118 3.9 Visual Resources...... 119 3.9.1 Environmental Setting ...... 119 3.9.2 Regulatory Setting ...... 120 3.9.3 Mitigation Measures ...... 121 3.9.4 Methods/Approach ...... 121 3.9.5 Impact Assessment...... 121 3.10 Hazardous Materials and Public Health ...... 124 3.10.1 Environmental Setting ...... 124 3.10.2 Regulatory Setting ...... 126 3.10.3 Mitigation Measures ...... 129 3.10.4 Methods/Approach ...... 129 3.10.5 Impact Assessment...... 130 3.11 Public Services and Utilities ...... 135 3.11.1 Environmental Setting ...... 135 3.11.2 Regulatory Setting ...... 136 3.11.3 Mitigation Measures ...... 137 3.11.4 Methods/Approach ...... 137 3.11.5 Impact Assessment...... 138 3.12 Population, Employment, and Housing...... 141 3.12.1 Environmental Setting ...... 141

Denmar Addendum to the WCDP EIR iii April 2021

3.12.2 Regulatory Setting ...... 142 3.12.3 Mitigation Measures ...... 142 3.12.4 Methods/Approach ...... 143 3.12.5 Impact Assessment...... 143 3.13 Resource Areas and CEQA Considerations Not Considered in the WCDP EIR ...... 143 3.13.1 Transportation Analysis Using the Vehicle Miles Traveled Metric...... 144 3.13.2 Greenhouse Gases ...... 145 3.13.3 Energy ...... 147 3.13.4 Wildfire...... 148 3.13.5 Tribal Cultural Resources ...... 148 3.14 Cumulative Impacts Analysis ...... 149 3.14.1 Land Use ...... 150 3.14.2 Transportation and Circulation ...... 150 3.14.3 Air Quality ...... 150 3.14.4 Noise...... 151 3.14.5 Geology and Soils ...... 151 3.14.6 Hydrology and Water Quality ...... 152 3.14.7 Biological Resources ...... 152 3.14.8 Cultural Resources ...... 153 3.14.9 Visual Resources...... 153 3.14.10 Hazardous Materials and Public Health ...... 153 3.14.11 Public Services and Utilities ...... 154 3.14.12 Population, Employment, and Housing...... 154 3.14.13 Summary ...... 155

4 References ...... 156

TABLES Table 1 Transportation Mode Numbers (Annual Calls) ...... 7 Table 2 Construction Schedule ...... 19 Table 3 Proposed Denmar Terminal Annual Throughput ...... 32 Table 4 Comparison of Transportation Mode Mix...... 42 Table 5 Construction Trips Associated with Remediation and Terminal Development ...... 43 Table 6 San Joaquin Valley Control District Criteria Pollutant Thresholds ...... 51 Table 7 Proposed Project Construction Emissions (tons per year) ...... 54

Denmar Addendum to the WCDP EIR iv April 2021

Table 8 Proposed Project Construction Emissions with Modified Mitigation Measure (tons per year) ...... 55 Table 9 Operational Emissions, Non-Permitted Sources (tons per year) ...... 56 Table 10 Operational Emissions, Permitted Sources (tons per year) ...... 57 Table 11 Comparison of Operational Emissions of West Complex Development Plan and Denmar Terminal (tons per year)...... 58 Table 12 Maximum Allowable Noise Exposure by Land Use Per City of Stockton 2040 General Plan (Ldn) ...... 62 Table 13 Potentially Present California Native Plant Society List Rare Plants...... 96 Table 14 Area of Impact and Fill Volumes for Jurisdictional Wetlands and Waters of the United States or State...... 102 Table 15 Heritage Trees within the Project Area...... 111 Table 16 Rough and Ready Island Landfill Cell Contents ...... 115 Table 17 Greenhouse Gas Emissions from Rail Versus Trucks ...... 146

FIGURES Figure 1 Study Area and Vicinity ...... 2 Figure 2 West Complex Development Plan Land Use Types ...... 3 Figure 3 Denmar Terminal Overview...... 16 Figure 4 Initial Remediation...... 17 Figure 5 Future Remediation...... 18 Figure 6 Impacts to Jurisdictional Wetlands ...... 103 Figure 7 Impacts to San Joaquin County Multi-Species Habitat Conservation and Open Space Plan Land Categories...... 107 Figure 8 Stockton Municipal Code Heritage Trees...... 112 Figure 9 Historic Maps ...... 116

APPENDICES Appendix A West Complex Development Plan Environmental Impact Report and Settlement Agreement Mitigation Measures Appendix B Air Quality Study Appendix C Noise Study Appendix D Jurisdictional Waters and Wetlands Figures

Denmar Addendum to the WCDP EIR v April 2021

ABBREVIATIONS 2040 General Plan Envision Stockton 2040 General Plan (City 2018) AB Assembly Bill ARB Air Resources Board bgs below ground surface BMP best management practice BNSF BNSF Railway CAAQS California Ambient Air Quality Standards Cal/OSHA California Division of Occupational Safety and Health CalARP California Accidental Release Prevention CalEPA California Environmental Protection Agency Caltrans California Department of Transportation CAP Climate Action Plan CBPR Center for Business & Policy Research CCR California Code of Regulations CCT Central California Traction Company CDFW California Department of Fish and Wildlife CEQA California Environmental Quality Act CERCLA Comprehensive Environmental Response, Compensation and Liability Act CESA California Endangered Species Act CFR Code of Federal Regulations CGS California Geological Survey CHSC California Health and Safety Code City City of Stockton CNDDB California Natural Diversity Database CNEL community noise equivalent level CNPS California Native Plant Society CO carbon monoxide

CO2e carbon dioxide equivalent COC contaminant of concern County San Joaquin County CPUC California Public Utilities Commission CUPA Certified Unified Program Agency CVRWQCB Central Valley Regional Water Quality Control Board CWA Clean Water Act dB decibel dBA decibel, A-weighted

Denmar Addendum to the WCDP EIR vi April 2021

DDD dichloro-diphenyl-dichloroethylene DDE dichloro-diphenyl-dichloroethane DDT dichloro-diphenyl-trichloroethane DEIR Draft Environmental Impact Report Delta Sacramento- Delta Denmar Denmar US LLC DOT Department of Transportation DPM diesel particulate matter DPS distinct population segment DSM deep soil mixing DSP Development Standards Plan DTSC Department of Toxic Substance Control DWSC Deep Water Ship Channel EA exposure area EFH essential fish habitat EIR Environmental Impact Report EOP Emergency Operations Plan EPCRA Emergency Planning and Community Right-to-Know Act ESA Endangered Species Act ESU evolutionarily significant unit FEMA Federal Emergency Management Agency FGC California Fish and Game Code FHWA Federal Highway Administration FIRM Flood Insurance Rate Map FMP Fisheries Management Plans FMWT Fall Midwater Trawl GHG greenhouse gas GSA General Services Administration HMMP Hazardous Materials Management Plan HRA Health Risk Assessment I-5 Interstate 5 ITMM incidental take minimization measure

Ldn day/night average sound level Leq equivalent continuous noise level LOS Level of Service LUC Land Use Covenant MHHW mean higher high water

Denmar Addendum to the WCDP EIR vii April 2021

NAAQS National Ambient Air Quality Standards Navy U.S. Department of the Navy NMFS National Marine Fisheries Service

NOX nitrogen oxides NPDES National Pollution Discharge Elimination System NRCS Natural Resources Conservation Service OPR Office of Planning and Research OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyl PM particulate matter

PM10 particulate matter less than 10 microns in diameter

PM2.5 particulate matter less than 2.5 microns in diameter Port Port of Stockton ppm parts per million PPV peak particle velocity PRC Public Resources Code RAP Remedial Action Plan RCRA Resource Conservation and Recovery Act RDIP Remedial Design Report/Implementation Plan ROG reactive organic gases RTP Regional Transportation Plan RWQCB Regional Water Quality Control Board SB Senate Bill Settlement West Complex Development Program EIR Settlement Agreement Agreement (Port 2007) SIP State Implementation Plan SJCEHD San Joaquin County Public Health Services, Environmental Health Division SJCGIS San Joaquin County Geographic Information Systems SJCOES San Joaquin County Office of Emergency Services SJCOG San Joaquin Council of Governments SJMSCP San Joaquin County Multi-Species Habitat Conservation and Open Space Plan SJVAPCD San Joaquin Valley Air Pollution Control District

SO2 sulfur dioxide

SOX sulfur oxides SPCCP Spill Prevention Control and Countermeasures Plan SWPPP Stormwater Pollution Prevention Plan SWRCB State Water Resources Control Board

Denmar Addendum to the WCDP EIR viii April 2021

TAC toxic air contaminant Technical Advisory Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018) TIA Transportation Impact Analysis TMDL Total Maximum Daily Load TPA metric tons per annum UP Union Pacific USACE U.S. Army Corps of Engineers USC United States Code USEPA US Environmental Protection Agency USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey VMT Vehicle Miles Traveled WCDP West Complex Development Plan WCDP EIR West Complex Development Plan Environmental Impact Report (Port 2004)

Denmar Addendum to the WCDP EIR ix April 2021

1 Introduction This document is an addendum to the West Complex Development Plan (WCDP) Environmental Impact Report (EIR) prepared by the Port of Stockton (Port) and certified in 2004 (hereafter referred to as the WCDP EIR; Port 2004). The 2004 WCDP EIR analyzed the long-term implementation of the Port’s WCDP and the City of Stockton (City) Redevelopment Agency’s Rough and Ready Island Redevelopment Plan; dredging of the West Complex docks; and the McCloy Avenue, Daggett Road, and Daggett Road Bridge Project. This addendum supports the development of a new bulk cargo marine terminal in the Port’s West Complex for the purpose of exporting soda ash (Figure 1). As part of the Proposed Project, the Port would conduct remediation on the former military landfill lands located in the western areas of the West Complex pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Following the initial phase of remediation, Denmar US LLC (Denmar) would construct and operate Phase 1 of a bulk natural soda ash export facility. Future remediation would occur concurrent with and/or after Phase 2 of the Denmar terminal construction. Both phases of the Denmar terminal construction and both the initial and future remedial activities constitute the Proposed Project analyzed in this environmental document.

1.1 West Complex Development Plan

1.1.1 2004 Draft Environmental Impact Report In 2004, the Port approved the WCDP EIR to support future development of the approximately 1,459-acre West Complex, commonly known as Rough and Ready Island, after the U.S. Department of the Navy (Navy) transferred its interest and use to the Port. When the WCDP EIR was prepared, the entire West Complex was owned by the Port, with the exception of 23 acres of private property on the northeastern portion and a 60-acre area at the southwest corner of Rough and Ready Island that had been set aside by the Navy for the Immigration and Naturalization Service Northern California Service Processing Center (Figure 2; areas 3 and 11). The Port subsequently acquired the 60-acre Navy parcel (area 11) in 2009.

As part of long-term planning for the West Complex, the Port identified and considered the types of development and operations that could occur based on existing infrastructure, approved land uses, and future regional consumer demand. The WCDP EIR assumed that commercial and industrial parks and other diversified land uses and infrastructure that support Port activities would be located on the undeveloped portion of Rough and Ready Island, while marine terminals would be developed on the remaining 500-acre area. The WCDP EIR then identified the following types of Port-related land uses that would most likely be developed: rail to dock; break-bulk; petroleum plant; commercial/industrial park; automobile facility and wharf upgrade; container shipping facility; expanded break-bulk, roll-on/roll-off, and project cargo; container expansion/intermodal transfer; water-related future expansion area; diversified land use; and a future Immigration and Naturalization Service facility.

Denmar Addendum to the WCDP EIR 1 April 2021 CALIFORNIA

Sacramento Stockton

San Francisco Project Site Study Area

5

San Joaquin River

Rough and Ready Island NAVY DR Port of Stockton

WASHINGTON ST DAGGETT RD DAGGETT

0 2,000 Figure 1

Feet Study Area and Vicinity Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report Figure 2 West Complex Development Plan Land Use Types Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

Using this mix of development, the WCDP EIR forecast the level of infrastructure needs and resulting operations associated with full build-out of the West Complex. Accordingly, the WCDP EIR generated forecasts for and analyzed the full amount of throughput that was predicted to occur based upon the types of Port operations that were included in the development plan, as well as the construction elements that would be required to build such facilities. Infrastructure improvements to support these development activities were programmatically assessed, including water-related development, demolition and soil remediation, construction of rail facilities and warehouse and transit shed facilities, and utility upgrades. Operations analyzed included increased vehicle and truck trips (1.3 million annual trips), rail trips (240 annual trips), and vessel trips (150 annual calls).

1.1.2 2007 Settlement Agreement In July 2004, several groups challenged the Port’s certification of the WCDP EIR. The challenge was settled in 2007 through the West Complex Development Program EIR Settlement Agreement (Settlement Agreement; Port 2007). The only lawsuit challenging the legal sufficiency of the WCDP EIR was dismissed after the applicable statute of limitations had run. Accordingly, the WCDP EIR is conclusively presumed to satisfy the requirements of the California Environmental Quality Act (CEQA). Together, the WCDP EIR and Settlement Agreement provide the development provisions for the West Complex.

The Settlement Agreement restricted the Port’s use of the WCDP EIR to develop container terminal operations in the West Complex. Therefore, the land uses that remain within the scope of the WCDP EIR are: rail to dock; break-bulk; petroleum plant, commercial/industrial park; automobile facility and wharf upgrade; expanded break-bulk, roll-on/roll-off, and project cargo; intermodal transfer; water-related future expansion area; diversified land use; and a future Immigration and Naturalization Service facility (Figure 2). The Settlement Agreement also established several air quality and water quality mitigation programs. This addendum considers the requirements of the 2007 Settlement Agreement as well as the WCDP EIR.

1.1.3 Existing (2020) West Complex Conditions As of early 2020, approximately 75 facilities or businesses currently operate in the West Complex. Consistent with the WCDP EIR, all facilities or businesses are Port-dependent bulk, commercial, industrial, and/or warehousing operations. The total leased area comprises approximately 300 acres of the 1,459-acre West Complex, leaving substantial area available for development.

1.1.4 Changes to the California Environmental Quality Act Since the West Complex Development Plan Environmental Impact Report Since the certification of the WCDP EIR, there have been several notable changes to CEQA and the CEQA Guidelines, as described in the following paragraphs. These changes do not, in and of

Denmar Addendum to the WCDP EIR 4 April 2021

themselves, constitute new information requiring a subsequent or supplemental EIR for the WCDP (Citizens Against Airport Pollution v. City of San Jose, 227 Cal. App. 4th 788 [2014]).

Senate Bill (SB) 97, enacted in 2007, directed the Governor’s Office of Planning and Research (OPR) to develop CEQA Guidelines “for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions.” New CEQA Guidelines addressing analysis and mitigation of greenhouse gas (GHG) emissions took effect on March 18, 2010. These updates included amendments to Appendix G of the CEQA Guidelines (Environmental Checklist), which created a new resource section for GHG emissions and indicated criteria that may be used to establish the significance of GHG emissions. The CEQA Guidelines addressing GHG emissions were updated effective December 28, 2018. The California Court of Appeal has held that new CEQA Guidelines addressing analysis of GHG emissions do not constitute new information requiring a subsequent or supplemental EIR because the potential impacts of GHG emissions have been known since the 1970s. (Citizens Against Airport Pollution v. City of San Jose, 227 Cal. App. 4th 788 [Cal. 2014]; Citizens for Responsible Equitable Environmental Development v. City of San Diego, 196 Cal. App. 4th 515, pages 531–532 [Cal. 2011]) Because the WCDP EIR could have included an analysis of the effect of GHG emissions on climate change, the new CEQA Guidelines on this topic do not constitute new information requiring a subsequent or supplemental EIR.

Assembly Bill (AB) 52, which became effective on July 1, 2015, requires lead agencies to consider the effects of projects on tribal cultural resources and to conduct early notification and consultation with federally and non-federally recognized Native American tribes and the Native American Heritage Commission (NAHC). The CEQA Guidelines were updated in 2016 to include Tribal Cultural Resources as a new resource area in Appendix G. AB 52 applies only to a project for which a notice of preparation or a notice of negative declaration or mitigated negative declaration is filed on or after July 1, 2015. The notice of preparation for the WCDP EIR was filed before that date; therefore, AB 52 does not apply to the Proposed Project. However, the Port elected to conduct voluntary consultations for the Proposed Project with five tribes identified by the NAHC. Consultation letters were sent to the Buena Vista Rancheria of Me-Wuk Indians, Confederated Villages of Lisjan, North Valley Yokuts Tribe, and Wilton Rancheria Tribe on January 6, 2021, and to the Tule River Indian Tribe on January 21, 2021. To date, responses have been received from the North Valley Yokuts Tribe and Confederated Villages of Lisjan requesting more information on the Proposed Project. On March 3, 2021, the Port provided response letters to both tribes.

SB 743, enacted in 2013, directed OPR to develop CEQA Guidelines for determining the significance of transportation impacts, which must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” The law also provided that upon certification of the new CEQA Guidelines implementing SB 743, “automobile delay, as described solely by Level of Service (LOS) or similar measures of vehicular capacity or traffic

Denmar Addendum to the WCDP EIR 5 April 2021

congestion shall not be considered a significant impact on the environment” except in locations specifically identified in the Guidelines.

The state of California revised the CEQA Guidelines on December 28, 2018. The 2018 CEQA Guidelines Update provides direction on numerous issues, including streamlining, tiering, complex environmental document preparation, and climate change/GHG emissions impact assessments. Updated exemptions were included for transit-centered residential and mixed-use development, along with clarifications to CEQA exemptions for existing facilities and emergencies. Changes were also made to implement SB 743 into CEQA transportation impact analyses, including guidance on Vehicle Miles Traveled (VMT) screening thresholds, mitigation, and reduction. The 2018 revised CEQA Guidelines also include two additional resource areas in Appendix G: Energy and Wildfire.

1.2 Addendum to the West Complex Development Plan Environmental Impact Report

1.2.1 California Environmental Quality Act Requirements Section 15164 of the CEQA Guidelines provides that, when an EIR has been certified for a project, the lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. Per Section 15164, this addendum provides a brief explanation, supported by substantial evidence, of the decision not to prepare a subsequent EIR. Based on the analysis presented in this addendum, no proposed changes to the project description, changes in circumstances, or new information would cause the Proposed Project to result in a new or substantially more significant environmental impact than identified in the WCDP EIR, no mitigation measures or alternatives previously found to be infeasible would in fact be feasible and would substantially reduce significant impacts as identified in the WCDP EIR, and no mitigation measures or alternatives that are considerably different from those analyzed in the WCDP EIR would substantially reduce one or more significant effects on the environment.

1.2.2 Project Modifications While the remediation and construction and operation of the Denmar terminal is consistent with the type and scale of projects analyzed as part of the WCDP EIR and consistent with the uses that can be approved in reliance upon the WCDP EIR under the Settlement Agreement, several project elements would be considered a change from the specific descriptions evaluated in the WCDP EIR and require further analysis in this addendum to determine the level of required review under CEQA. These elements are described in the following paragraphs, and this addendum evaluates the environmental effects of these elements in Section 3.

Denmar Addendum to the WCDP EIR 6 April 2021

Remediation was identified and programmatically analyzed in the WCDP EIR, but details of the remedial activities were not available because a remedy had not been selected for the Landfill Area at that time. This addendum analyzes the proposed initial and future remedial activities that are being developed in coordination with the Department of Toxic Substance Control (DTSC) and the Central Valley Regional Water Quality Control Board (CVRWQCB).

Denmar’s proposed mix of rail, truck, and ship calls is different than the mix described in the WCDP EIR. The WCDP EIR assumed a predominant use of truck transport, while the Denmar terminal would entail a predominant use of unit trains, as well as increased ships. Table 1 presents the different mode mix, comparing the WCDP EIR projections to existing and Proposed Project conditions. As discussed further in Section 3, the change in mix does not result in new findings of significance and is consistent with the environmental analysis presented in the WCDP EIR. Specifically, as detailed in Sections 3.3.5 and 3.4.5, this addendum includes project-specific air quality and noise evaluations that support the conclusion that the Proposed Project’s change in transportation modes would not result in any new or substantially more severe impacts compared to the impacts disclosed by the WCDP EIR.

Table 1 Transportation Mode Numbers (Annual Calls)

Existing West Proposed Denmar Terminal Calls Mode WCDP EIR Projected Calls Complex Calls (2019) Phase 1 Phase 22 Trucks 1,327,350 274,343 0 0 Ships 150 43 137 200 Trains1 240 188 249 363 Note: 1. The WCDP EIR assumed manifest trains. The Denmar terminal would use unit trains. 2. Phase 2 calls represent the total calls to the terminal inclusive of (not additive to) Phase 1 calls.

The WCDP EIR identified a 409-acre “Diversified Land Use Area” on the western portion of Rough and Ready Island and disclosed that mapped wetlands occur in that area, but the WCDP EIR stated that these wetlands and habitats were not specifically within the area that was proposed for development. Diversified land uses were further described in the WCDP EIR as uses that would be developed on a market-driven basis to support Port activities. Nonetheless, the WCDP EIR considered impacts on wetlands to be significant, and implementation of mitigation, as identified in Appendix A, was required to reduce impacts to less-than-significant levels. The WCDP EIR also required that all development activities obtain coverage under the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan (SJMSCP) for habitat impacts. Portions of the Proposed Project would be constructed and operated within the Diversified Land Use Area; accordingly, this

Denmar Addendum to the WCDP EIR 7 April 2021

addendum analyzes the wetland and habitat impacts that would result from construction of the Proposed Project in detail in Section 3.7.5.

The WCDP EIR also described that structures would not be placed in, under, or over navigable waters. Nonetheless, the WCDP EIR considered impacts on waters to be significant, and implementation of mitigation as identified in Appendix A, including obtaining required permits, implementing avoidance measures, and completing compensatory mitigation for impacts, was required to reduce impacts to less-than-significant levels. The Proposed Project would result in a minor amount of overwater coverage and fill in the San Joaquin River associated with the fendering system at Berth 18 and 19. Accordingly, this addendum analyzes the fill impacts to waters that would result from the Proposed Project in Section 3.7.5.

The tallest building described in the WCDP EIR was assumed to be 75 feet tall. Each of two storage buildings proposed by Denmar would be approximately 107 feet tall and 200 feet wide by 1,050 feet long. The south building would be constructed during Phase 1 and the north building would be constructed during Phase 2 to support the Denmar terminal’s full build-out, as determined by market conditions. This addendum evaluates the visual effects of the taller buildings in Section 3.9.5. It concludes that the increased building heights would not present a new or substantially more severe visual effect because they would not alter the visual character of the project area and would be consistent with the industrial appearance of the site and its surroundings, and they would replace blighted buildings with new, more visually appealing structures.

The analysis presented in Section 2 evaluates the proposed modifications in the context of the WCDP EIR. This evaluation describes the findings of the WCDP EIR and determines whether there would be a new or substantially more severe impact not disclosed in the WCDP EIR.

1.2.3 Incorporation of the West Complex Development Plan Environmental Impact Report and Settlement Agreement As an addendum to the WCDP EIR, this document incorporates sections of the 2004 EIR as well as provisions of the Settlement Agreement. Specifically, the 2004 EIR sections incorporated into this document include but are not limited to the Environmental and Regulatory Settings, Baseline, Alternatives, Impact Findings, and Cumulative Projects sections. Section 3 of this document provides updates to the Environmental and Regulatory Settings where relevant. Consistent with the requirements of the WCDP EIR, the Proposed Project would be subject to relevant mitigation measures approved by the Port as part of the WCDP EIR. Appendix A provides the full list of mitigation measures and identifies those relevant to the Proposed Project.

Denmar Addendum to the WCDP EIR 8 April 2021

1.2.4 Conclusion As presented in Section 2, for all resource areas, there would be no proposed changes to the project description, changes in circumstances, or new information that would cause the Proposed Project to result in a new or substantially more significant environmental impact than identified in the WCDP EIR, no mitigation measures or alternatives previously found to be infeasible would in fact be feasible and would substantially reduce significant impacts as identified in the WCDP EIR, and no mitigation measures or alternatives that are considerably different from those analyzed in the WCDP EIR would substantially reduce one or more significant effects on the environment. The Port has determined that construction related to remediation and development of the Denmar terminal, as well as the operation of the Denmar terminal, is consistent with the WCDP EIR because it is consistent with the remediation presented in the WCDP EIR, as well as the types of Port operations, specifically bulk cargo activities, analyzed in the WCDP EIR and for which the WCDP EIR may be relied upon under the Settlement Agreement. Therefore, an addendum is the appropriate CEQA documentation. An addendum need not be circulated for public review. In accordance with Section 15164 of the CEQA Guidelines, the decision-making body shall consider the addendum with the WCDP EIR before making a decision on the proposed activity.

1.3 Incorporation by Reference As permitted in Section 15150 of the CEQA Guidelines, an EIR may reference all or portions of another document that is a matter of public record or is generally available to the public. Information from the documents that have been incorporated by reference has been briefly summarized in the appropriate sections of this EIR, along with a description of how the public may obtain and review these documents. The documents that are incorporated by reference are available for review at the internet links provided in the following sections or during working hours from 8:00 AM to 5:00 PM, Monday through Friday at the Port of Stockton at 2201 West Washington Street, Stockton, California, 95201. Documents incorporated by reference are included as follows.

1.3.1 City of Stockton 2040 General Plan The City’s Envision Stockton 2040 General Plan (2040 General Plan), which is available online at http://www.stocktongov.com/files/Adopted_Plan.pdf, is appropriate to incorporate by reference because it establishes the land use designations for the project site with which the Proposed Project is consistent. The 2040 General Plan also guides the maintenance, design, and operation of transportation resources in the City, including streets and highways, within the project area, and sets regional noise standards based on land use designations.

Denmar Addendum to the WCDP EIR 9 April 2021

1.3.2 City of Stockton Municipal Code This document, which is available online at https://qcode.us/codes/stockton/, is appropriate to incorporate by reference because the City designates Landmarks and Historic Sites under the City Municipal Code, Title 16, Division 7, Chapter 16.220. Landmarks are artifacts, natural features, or structures notable for one or more of the following: archaeological interest; architectural craftsmanship, style, or type; association with a historic event or person; association with the heritage of the City, state, or nation; visual characteristics; relationship to another landmark; or integrity as a natural environment. Port resources have been identified as having significant historical or cultural significance. Title 16, Division 5, Chapter 16.130 of the City Municipal Code provides protection for heritage in the City.

1.3.3 City of Stockton Climate Action Plan This document, which is available online at: http://www.stocktonca.gov/files/Climate_Action_ Plan_August_2014.pdf, was approved in August 2014. It is appropriate to incorporate by reference because the City’s Climate Action Plan (CAP) provides goals and associated measures in the sectors of energy use, transportation, land use, water, solid waste, and off-road equipment. Consistent with the San Joaquin Valley Air Pollution Control District’s (SJVAPCD’s) goals, the CAP relies on a goal of 29% reduction in GHG emissions from business-as-usual by 2020. As described in the CAP, the City will revisit this plan in the future to examine whether there exist additional options to further reduce GHG emissions, and whether such options might be feasible in improved economic conditions beyond 2020. An update is not currently available.

1.4 Port Environmental Programs Since preparation of the WCDP EIR in 2004 and in cooperation with numerous agencies, the City, and the surrounding community, the Port has implemented a variety of plans and programs to identify and reduce environmental impacts from Port operations and promote community engagement and education. These programs are being implemented in areas throughout the Port—on both the West Complex and East Complex—and include measures to reduce emissions, protect habitat, improve water quality, and engage with the community. While not specifically limited to the footprint of the Proposed Project, all of these efforts ultimately reduce cumulative environmental effects and will continue to do so into the future.

1.4.1 Water Quality The Port makes considerable efforts to prevent pollutants potentially produced by industrial and maritime activities at the Port from reaching the surrounding waterways. Over the past 5 years, the Port spent more than $5 million on stormwater programs, including the following: • The Port labeled 100% of the storm drains on Port property with “No Discharge.”

Denmar Addendum to the WCDP EIR 10 April 2021

• The Port upgraded the wash pad to significantly reduce the chance of overspray and potential stormwater contamination. • The Port installed three “Safe Drains” near the Port fueling station. In the event of a spill, these will allow for the quick closure of nearby storm drains, thereby preventing a release to the aquatic environment. • The Port installs and maintains sediment traps in storm drains at key locations that are most susceptible to pollution. The Port upgraded the stormwater conveyance system on the East Complex by installing several checkdams. These dams are designed to reduce the velocity of the stormwater runoff, which dissipates some of the energy and allows solid pollutants to drop out of suspension before the water is discharged to a waterway. • The Port maintains and operates an aeration facility in the Stockton Deep Water Ship Channel (DWSC; which is within the San Joaquin River) to help alleviate the problems associated with low dissolved oxygen concentrations. • The Port maintains and operates a detention pond on the Port’s East Complex that collects stormwater and allows for settling and removal of contaminants before the water is released into the San Joaquin River.

1.4.2 Air Quality The Port is developing longer-term plans and strategies to better understand and reduce air emissions related to Port development and projects. As part of this effort, the Port is conducting a Port-wide criteria pollutant and GHG emissions inventory. The Technical Working Group for the emissions inventory includes Port representatives and technical experts, including stakeholder agency representatives from the U.S. Environmental Protection Agency (USEPA), California Air Resources Board (ARB), and SJVAPCD.

The Port is also working with tenants and the SJVAPCD to repower and/or retrofit their existing cargo handling equipment with lower emissions engines for improved air quality. Projects that have resulted in direct emissions reductions, demonstrating the beginning of the Port’s longer-term emissions plans and strategies, include the following: • Replacing four older gasoline powered trucks with new zero-emission electric vehicles for use on docks and implementing more than 30 electrical vehicle charging stations • Acquiring two zero-emission, multi-use DANNAR mobile power sources fitted with forklift, scissor lift, and dump capabilities • Working in tandem with the Ports of Long Beach and Oakland, the Port was awarded grant funding as part of ARB’s Zero- and Near-Zero Emission Freight Facilities Program to receive 34 forklifts from XL Lifts, a company specializing in zero- and near-zero-emissions forklifts ‒ In addition to these units, a zero-emissions railcar mover has been ordered and is scheduled to arrive in late 2020.

Denmar Addendum to the WCDP EIR 11 April 2021

1.4.3 Habitat and Species The Port has implemented habitat and species programs that use innovative approaches towards invasive species mitigation, while protecting and providing habitat for special-status species. Several of the Port’s programs are discussed below.

The Port is a key contributor to implementation of the Antioch Dunes Restoration Project. The U.S. Army Corps of Engineers (USACE) conducts annual dredging of the Stockton DWSC to improve navigability, and since 2013, the Port has worked with USACE and the U.S. Fish and Wildlife Service to deliver dredged sand to the refuge to replenish habitat for endangered plant and insect species, including the Antioch Dunes Evening Primrose. The Port and its partners have completed the first cell of the restoration, holding approximately 40,000 cubic yards of sand material. The Antioch Dunes Evening Primrose has voluntarily revegetated the area, and its population has come back to its highest level since the 1970s.

The Port has installed barn owl nest boxes throughout the East and West complexes to provide nesting habitat for barn owls. The Port currently has 15 barn owl nesting boxes, which have housed over 200 new owls. The nest boxes provide valuable and safe habitat, natural rodent control, and two boxes are outfitted with streaming cameras, which allow the public to learn more about Port wildlife. To accommodate construction of the Proposed Project, the Port may relocate certain owl boxes to other areas on the West Complex. The Port also maintains a number of bat roosting boxes, which provide bat habitat and natural insect control; none of these are in the project area.

Arundo is an invasive giant reed that has spread throughout the Sacramento-San Joaquin River Delta (Delta). In the past, arundo has been controlled with heavy use of herbicides. However, the Port has begun an eradication program based on two more environmentally friendly approaches: first, cutting and tarping the arundo, based on research conducted at the University of the Pacific, and second, introduction of arundo wasps, a tiny 1-centimeter-long black insect that is harmless to humans. These wasps feed and reproduce only on arundo, laying eggs in their chutes, which usually leads to the death of the plant.

1.4.4 Community Outreach and Support The Port is in the process of forming two stakeholder engagement groups. The first group will comprise representatives from the Port, the Port’s community outreach experts, and environmental managers from the Port’s business partners and tenants. The purpose of this group is to improve communication between the Port, business partners, and tenants; identify information gaps; facilitate opportunities for collaboration, cooperation, and problem solving; and define key strategies to reduce emissions and improve air quality through advancing technologies at the Port.

Denmar Addendum to the WCDP EIR 12 April 2021

The second engagement group, the Environmental Justice Task Force, is being formed to amplify local voices. It will comprise representatives from the Port, the Port’s community outreach experts, members of the community, environmental justice groups, and local organizations. The Catholic Charities of the Diocese of Stockton, STRIVE Giving, and PUENTES have already expressed interest in joining this group, and the Port will reach out to a wide range of other community groups, including the Stockton community AB 617 Steering Committee, to ensure this task force has a diverse representation of the Stockton community. The purpose of this group is to create a communication channel between concerned citizens, community groups, environmental justice organizations, and the Port, thus establishing a strategic network with opportunities for enhanced communication, cooperation, collaboration, and transparency.

Denmar Addendum to the WCDP EIR 13 April 2021

2 Project Description This addendum evaluates the development of the Denmar Natural Soda Ash Export Terminal in the Port’s West Complex. Concurrent to construction of the terminal, the Port would conduct remediation in the western undeveloped areas of the West Complex pursuant to CERCLA. The two components—the Denmar terminal and the remedial activities—constitute the Proposed Project analyzed in this addendum.

2.1 Environmental Setting The Proposed Project is located at the West Complex on Rough and Ready Island. The Denmar terminal would be located at Berths 18 and 19 along the San Joaquin River and in western undeveloped areas within the West Complex (Figure 1). Remedial activities would occur in western undeveloped areas. The current setting and conditions in the surrounding area are generally consistent with those described in Section 2.6 of the WCDP EIR (Port 2004). The WCDP EIR designated the northern marine terminal areas for water-related expansion, and the western undeveloped areas of the West Complex for diversified land uses (Figure 2). The WCDP EIR defined water-related expansion as break-bulk activities and other uses including “continued low price leasing of the existing buildings; development of a precast concrete factory with its own batch plant; and other related uses” (Port 2004).

2.2 Proposed Project Overview Denmar is proposing to construct and operate a bulk terminal to receive and export natural soda ash. The Soda ash, or sodium carbonate, is a chemical marine terminal would be located at existing Berths 18 refined from the mineral trona or sodium- carbonate-bearing brines (both of which are and 19, with a new rail depot proposed for the referred to as "natural soda ash") or undeveloped areas of the West Complex. The manufactured from one of several chemical processes (referred to as "synthetic soda ash"). Denmar terminal would include new shiploaders at Soda ash is used in a wide range of industries Berths 18 and 19; parking and quarters buildings for crew; and products, including baking soda, administration/maintenance support buildings; sweetened soft drinks, green cleaning products, personal care products, and as a pH conveyors, towers, and storage facilities on warehouse adjuster. sites 705, 706, 805, 806, 905, and 906; and a rail loop and railcar unloading building in the westernmost portion of the West Complex (Figure 3).

The Denmar terminal would be constructed in two phases (Sections 2.3.2 and 2.3.4). Phase 1 would include construction of the rail loop, rail infrastructure, and railcar unloading building; berth improvements and installation of a shiploader at Berth 18; a single storage building (south storage building) and stacker reclaimer; conveyors; towers; crew quarters; support, administration, and maintenance buildings; and ground improvements, access roads, and parking infrastructure. Full build-out of the facility (Phase 2) would include installation of an additional rail track on the existing rail loop; a second storage building (north storage building) and stacker reclaimer; associated

Denmar Addendum to the WCDP EIR 14 April 2021

conveyors and towers; and berth improvements and installation of a shiploader at Berth 19. The Denmar terminal would be designed to receive bulk deliveries of soda ash by rail. The soda ash is anticipated to come from the central United States. Soda ash would be offloaded from unit trains for export by marine vessels. The Port would issue a long-term lease to Denmar to operate the terminal.

Several sites on the West Complex contain hazardous substances in soil and groundwater as a result of past Navy activities, including “Landfill Cells” in which the Navy disposed of solid waste, and other “Remedial Sites of Interest” in which hazardous chemicals were reportedly released (together referred to as “Remediation Sites” within the “Landfill Area”). Concurrent with design and construction of the Denmar terminal, the Port is working with DTSC and CVRWQCB to identify remedial actions to be taken to address soil contamination at the Remediation Sites within the Landfill Area pursuant to CERCLA.

Remedial activities encompass a larger area than the proposed Denmar construction footprint. Portions of the Denmar construction footprint overlap with some of the Landfill Cells and Remedial Sites of Interest. Remedial activities would be implemented in several stages, with initial remediation focused on excavation and consolidation of solid waste and contaminated soils in the sites on or near the proposed Denmar construction areas, prior to or during construction of the Denmar terminal (Figure 4). As described in detail in Sections 2.3.1 and 2.3.2, initial remediation activities would include the following:

• Steps designed to remediate portions of Remediation Sites intersecting the footprint of the Denmar terminal construction, along with a 20-foot offset area • Actions and protective measures to protect the health and safety of workers performing the Denmar terminal excavation and construction work • Steps to ensure continued access to and monitoring of the remainder of the Remediation Sites pending implementation of future remediation stages

Future remediation, which is described in Section 2.3.3, would address soil contamination at the remaining Landfill Cells and Remedial Sites within the Landfill Area. The Port, DTSC, and CVRWQCB are preparing a Remedial Action Plan (RAP) and Remedial Design Report/Implementation Plan (RDIP) to identify the steps to be taken to complete future remediation. Figure 5 summarizes the areas that may be addressed in future remediation.

Denmar Addendum to the WCDP EIR 15 April 2021 LEGEND: Shiploader

Railcar Unloading Utility Lines Building and Enclosed Conveyor System Crew Quarters Rail Culverts Rail Line Area Administration/Maintenance Wastewater Treatment Plant Electrical Room

Berth 19 Stormwater Pond Buildings Storage Buildings Berth 18 Parking Building Demolition CROMWELL AV Construction Staging Stockpile Area Deck Crew

Quarters ELLSBERG DR

HUMPHREYS DR

FYFFE AV 0 1,000

Feet

Figure 3 Denmar Terminal Overview Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

Figure 4 Initial Remediation Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

Figure 5 Future Remediation Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

2.3 Proposed Project Construction This section provides details on construction including remedial activities and Denmar terminal construction. Construction would occur over approximately 4 years, as shown in Table 2. The periods shown in Table 2 reflect the earliest anticipated commencement dates at the time that the analysis supporting this addendum was prepared; the actual time periods will commence only after necessary permits for specific construction elements are obtained.

Table 2 Construction Schedule

Approximate Schedule Construction Element Start End Initial Remediation 2021 2021 Excavation and consolidation of waste and select areas with contaminated soil (within 20 feet of rail line); install liner and soil 72 work days cover at IAS-11 Consolidation Area Phase 1 Denmar Terminal Construction 2021 20221 Staging and site preparation; rail infrastructure; facility buildings 700 work days and infrastructure; berth improvements

Future Remediation 2023 20292 Excavation and consolidation of remaining areas with known or 256 work days potentially contaminated soil; install liners and soil covers Phase 2 Denmar Terminal Construction 2024 2025 Ground improvements; facility buildings and infrastructure 700 work days Note: 1. The construction schedule is likely to shift but would be the same length regardless of when it occurs. 2. Future remediation would occur over an estimated period of 256 work days between 2023 and 2029.

2.3.1 Initial Remediation Denmar terminal construction for the rail loop and railcar unloading building in the westernmost portion of the West Complex traverses 15 Remediation Sites that are known to contain hazardous substances and are subject to activity restrictions pursuant to the 2003 Consent Agreement (State of California 2003). A total of approximately 20,860 cubic yards of contaminated soil, sediment, waste, and adjacent material would be excavated from 4 acres of these areas during initial remediation activities and consolidated on site at a portion of Site IAS-11 (referred to as the “IAS-11 Consolidation Area”) located outside the Denmar terminal construction footprint (Figure 4). Initial

Denmar Addendum to the WCDP EIR 19 April 2021

remediation would take about 5 months and would involve excavation and on-site consolidation of material from the following areas, as shown in Figure 4:

• Waste Cell Excavation Areas shown in Figure 4 indicate the portions of the Landfill Cells in the area of the rail line that intersect with the Denmar terminal construction footprint and a 20-foot surrounding offset area. In these select locations, the portions of the Landfill Cells that overlap Denmar terminal construction areas would be excavated to the full depth of the Landfill Cell (estimated at 6.5 to 9 feet deep) and offset into the cell horizontally approximately 20 feet from the edge of the rail track embankment, to provide working clearance from the embankment after construction. • Areas of Known Contamination shown in Figure 4 indicate the portions of these areas that intersect with the Denmar terminal construction footprint and an approximate 20-foot surrounding offset area. These areas would be excavated to the full depth of contamination (estimated at 0.5 to 3.5 feet deep).

The IAS-11 Consolidation Area would then be permanently closed with installation of a foundation layer, a low-permeability liner and an 18-inch-thick cover of imported soil from an off-site source, covering approximately 2.3 acres and seeded with native, non-invasive grasses. To support drainage and site preparation for construction of Phase 1 of the Denmar terminal, approximately 4 acres of areas that were excavated would be backfilled with imported soil from an off-site source to reach required elevations. An estimated total of 23,800 cubic yards of clean material would be imported from sources on Roberts Island and/or elsewhere on Rough and Ready Island for backfill and soil cover to support the initial remediation activities.

The excavation, placement, and material handling activities would be conducted using standard construction equipment such as excavators, dump trucks, dozers, and grading and compacting equipment. Construction would occur approximately 8 hours per day, during daylight hours.

2.3.2 Phase 1 Denmar Terminal Construction Phase 1 of Denmar terminal construction would take approximately 23 months and would include construction of the rail loop, rail infrastructure, and railcar unloading building; berth improvements and installation of a shiploader on Berth 18; a single storage building (south storage building) and stacker reclaimer; conveyors; towers; crew quarters; support, administration, and maintenance buildings; and ground improvements, access roads, and parking infrastructure. Construction would occur over approximately 10 hours per day (between the hours of 7:00 am and 7:00 pm) and typically 5 days per week.

Denmar Addendum to the WCDP EIR 20 April 2021

Phase 1 construction activities would include the following elements, which are described further in Sections 2.3.2.1 through 2.3.2.4: • Staging and site preparation activities, coordinated with initial remediation as required • Construction of rail infrastructure and the railcar unloading building • Construction of facility buildings and infrastructure, including towers, conveyors, the south storage building, administration/maintenance buildings, crew quarters, utilities, and the wastewater treatment plant • Improvements to Berth 18, including shiploading equipment, pile cap replacements, a new fender system, and wharf improvements

2.3.2.1 Staging and Site Preparation Site preparation activities would include clearing and grading, and excavation for the railcar unloading building, conveyor tunnel, associated crew building, storage buildings, administration/maintenance building, dock crew quarters building and associated parking area, wastewater treatment plant, temporary construction and permanent access roads, and track construction. Excavation in the rail loop area would not be deeper than 2 feet, except in the limited areas described for initial remediation in Section 2.3.1, a 6-foot-deep area in the northern part of the rail loop, and an area for the railcar unloading building. Outside of the rail loop area, excavation is expected to be minimal and to consist of minor clearing and grubbing.

Aboveground vegetation (e.g., trees and shrubs with no associated soil) removed during site preparation would be disposed of off site. Following vegetation removal, approximately 143,700 cubic yards of material (e.g., surface soil and organic material) is expected to be excavated during the clearing, grading, and excavation portion of Phase 1 of Denmar terminal construction. The total surface area that would be prepared in this portion of Phase 1 is approximately 64 acres, of which 42 acres are for the rail infrastructure and railcar unloading building components, 14 acres are for construction laydown space, and an additional 8 acres of disturbance are in existing developed (gravel or paved) areas. The materials excavated from locations within the Landfill Area would remain within the Landfill Area and be placed in a combination of the following locations: • A designated stockpile area in the southern loop of the rail line area, where it would be reused by the Port in the future to provide a foundation layer for capping and closure of Landfill Cells in the Landfill Area outside the Denmar terminal construction areas • On top of Landfill Cell M outside the Denmar terminal construction areas, where it would be reused to provide a foundation layer for Landfill Cell M capping and closure

Materials excavated from locations outside the Landfill Area would be placed as follows: • Surface soils and organic material excavated (to a depth of 6 inches) for clearing and grubbing of support facilities would be placed in a designated stockpile area in the southern

Denmar Addendum to the WCDP EIR 21 April 2021

loop of the rail area and would be reused by the Port in the future to provide a foundation layer for capping and closure of Landfill Cells in the Landfill Area outside the Denmar construction areas. • Other excavated soils would be kept outside the Landfill Area and would be reincorporated into the finished grading at proposed structures outside the Landfill Area.

If required in areas of the rail loop, after clearing and organics removal to a depth of 6 inches, unsuitable soils would be stabilized to an additional depth of approximately 18 inches with in situ lime treatment and backfilled to reach the required rail embankment elevations. Some localized areas where peat, very soft organic soil, and/or debris are present would need to be excavated and replaced with fabric and imported soil. Once clearing and grubbing is complete, grading would be conducted to provide an even surface for construction. Clean imported fill would be placed as needed to level the site for subsequent construction activities. The primary source of fill material for construction would be dredging spoil borrow sites on Rough and Ready Island or Roberts Island. Subballast and ballast material for construction of the rail line would be imported, clean granular material from an off-site source.

Outside the rail loop area, warehouse site 806 and the transit shed at Berth 18 would be demolished. Any demolition materials would be stockpiled temporarily in an upland location and disposed of off- site at an approved disposal site to be determined by the contractor.

Three areas—currently undeveloped or existing gravel parking lots—would be prepared for construction staging and material storage. One of these areas would require shallow excavation and grading, then would be overlain with gravel to prepare the site. The three areas would be used for: 1) equipment and materials storage; 2) contractor trailers and construction parking; and 3) pre-assembly of the stacker reclaimer that would be moved into the south storage building once complete.

Minimal changes would be made to existing vehicular access roads at the Port. To maintain access for existing tenants through the south storage building and conveyor area, Ellsburg Drive would be permanently rerouted to the east, run alongside the conveyor path, and then turn south again when clearance under the conveyor can be achieved. Additional gravel and paved temporary construction roads and permanent roads for employees, maintenance, and emergency access would also be prepared throughout the site during Phase 1 construction.

Areas where the storage buildings, conveyor bents, railcar unloading building, and towers are proposed would require deep soil mixing (DSM) and/or stone column methods of ground improvement prior to construction of foundations. The DSM method consists of in situ mixing of existing soils with a cement slurry and a special auger tool to create interconnected soil-cement columns. The stone column method uses a rig and vibratory tool to add crushed stone or

Denmar Addendum to the WCDP EIR 22 April 2021

recycled concrete to voids created in the existing soils. Further geotechnical investigation is ongoing; ground improvements may include the following: • Based on the preliminary geotechnical findings, the railcar unloading building would use a combination of a DSM shear wall around the perimeter of the structure and a DSM grid under the footprint to control groundwater and resist liquefaction and uplift. Both the shear wall and the DSM grid would be to a total depth of approximately 50 feet with overlapping cylindrical columns 36 to 60 inches in diameter. The shear pile wall would also include intermittently spaced, full depth wide flange beams typically on 4-foot centers throughout the wall. • If the geotechnical investigations show that measures are needed to address seismic slope deformation and kinematic loads on the existing piles of Berths 18 and 19, a DSM buttress would be constructed landward of the dock. The buttress would be approximately 50 feet wide, would run the entire length of Berths 18 and 19, and would extend approximately 60 feet deep. The conveyor support bents and towers would require a triangular stone column grid or DSM to provide additional support to spread or mat foundations. The stone column grid would horizontally offset structure foundations by 10 feet and consist of 24-inch- diameter columns that are drilled to a depth of 60 feet with columns in the grid roughly on 6-foot centers.

2.3.2.2 Rail Infrastructure and Railcar Unloading Building After the completion of site preparation activities, construction of the rail lines would commence. In areas that are not already at the required elevation, excavation, grading, and resurfacing would level the site and prepare it for track placement. Fill material consisting of import borrow and crushed surfacing base course (subballast) would be placed—approximately 2 to 6 feet high, depending on the location—followed by installation of the rail and ties. A specialized piece of construction equipment called a tamper would be used to raise the track through the ballast, and the ballast would be compacted under the crossties. The ballast would then be shaped to form a uniform ballast section. Tracks would be tested and aligned prior to use. Some of the staging in the rail loop would feature buried compressed air lines and electrical conduit to facilitate switching operations, air testing trains, and inspection of trains prior to departing the facility.

A 202-foot-long by 60-foot-wide railcar unloading building would be constructed inside the rail loop track area. The unloading pit within the 9,400--foot railcar unloading building would extend approximately 35 feet below ground. Standard and heavy earthmoving and grading equipment would be used to construct the railcar unloading building. The lined unloading pit and conveyor tunnel associated with the railcar unloading building would require ground improvements (Section 2.3.2.1) and hold-down anchors to counteract buoyancy loads and prevent groundwater incursion. Air emissions controls for particulate matter (e.g., soda ash dust) would be incorporated into the design of the railcar unloading building.

Denmar Addendum to the WCDP EIR 23 April 2021

Rail infrastructure would additionally include gravel access roads between the rail lines for train inspection and to serve as access to the Remediation Sites located within the new rail loop. The rail infrastructure access roads would connect to other proposed features, including the railcar unloading building paved access road, western tower dirt access road, and an upland access road connecting to Fyffe Avenue.

Adjacent to the rail infrastructure, an access road would be constructed to provide access to Remediation Sites southeast of the rail loop. The crossing would include installation of three 72-inch-diameter corrugated metal pipe culverts and clean soil or ballast backfill to construct a crossing for one stormwater conveyance channel. Temporary water diversion or dewatering may be required for construction of the stormwater channel crossing, and may include a cofferdam system and diversion pipelines, or similar, as determined by the contractor.

2.3.2.3 Facility Buildings and Infrastructure A conveyor system would be constructed from the railcar unloading building to the storage building and shiploader. The south storage building would be constructed, to be approximately 107 feet tall and a total of 187,000 square feet, comprising a 205-foot-wide, 857-foot-long main storage area and a 54-foot by 198-foot tripper house at the west end. The storage building would be outfitted with dust collectors and solar panels on its roof. The associated stacker reclaimer would be brought to the site on a single ship and assembled on site. An industrial wastewater treatment plant would be constructed to the west of the south storage building.

A single-story, 26-foot-tall, approximately 12,100-square-foot administration and maintenance building would be constructed to the east of the location of the future north storage building. Two crew quarters buildings would be constructed, one for the dock facility labor force and one for the railcar unloading facility labor force. Each would be a single-story, 13-foot-tall, approximately 2,000-square-foot building. The dock crew quarters would be located near Berth 18 and the railcar unloading crew quarters would be along the eastern wall of the railcar unloading building. Crew buildings are expected to be of modular construction. The administration and maintenance and crew quarter buildings would each have adjacent parking areas.

Upland existing utilities and infrastructure would either be abandoned, relocated, or connected to the project facilities, depending on the final proposed Denmar terminal design, including electrical, sanitary sewer, water, stormwater lines, catch basins, manholes, communications, and power distribution. Utility work would include a combination of horizontal directional drilling and open cutting of trenches to access and remove existing utilities, and installation of new utilities.

Existing catch basin and pipe systems, swales, roadside ditches, culverts, hydraulic control structures, and wet ponds are located throughout the Port to manage stormwater runoff. The proposed facility would require minor conveyance modifications to maintain flow paths. Stormwater runoff from

Denmar Addendum to the WCDP EIR 24 April 2021

paved areas near the railcar unloading building would be directed to pervious areas via a bioswale on the east side of the parking area and allowed to infiltrate. Stormwater runoff from the paved access road between Fyffe Avenue and the railcar unloading building area would be directed to pervious areas and allowed to infiltrate.

Multiple contractors would be working at the same time to excavate foundations, prepare cast-in- place concrete, install ground improvement systems, and erect elements of the various structures, utilities, mechanical, dust control, or electrical equipment. Construction equipment, facility components, and pre-assembled modules would be delivered by truck, rail, or marine vessel to laydown areas. Standard and heavy earthmoving and grading equipment would be used to construct the facility buildings and infrastructure. The south storage building, conveyor bents, and towers also would require ground improvements (Section 2.3.2.1). Concrete would be sourced from concrete suppliers; no on-site production of concrete is anticipated.

2.3.2.4 Berth 18 Improvements Phase 1 construction at Berth 18 would include improvements to the mooring and fender systems to accommodate the type and size of expected vessels, and improvements to the existing wharf structure to improve the structural and seismic capacity to support new shiploader operations. After berth improvements are completed, a new shiploader and associated tower would be installed. All new work, except for the fender panels, would occur on the existing berth above mean higher high water (MHHW), including overwater demolition and concrete work; no in-water work would be required. The fender panels, although physically attached to the wharf deck, would extend into the water below MHHW by a few feet.

Proposed wharf improvements include localized strengthening of the concrete deck along the entire length of the berth, by thickening, replacing existing pile caps, and adding new concrete deck beams. Pile caps would be replaced with cast-in-place concrete pile caps, which would include pumping concrete into forms attached to the piles. In addition, the top of existing piles just below the deck soffit would be wrapped with carbon fiber sleeves to improve concrete confinement and shear capacity.

The new fender system includes the installation of new fender batteries at five locations along the length of Berth 18. Each battery consists of a steel-framed reaction panel attached to the face of the existing wharf with steel bracing elements, and supports a foam-filled pneumatic fender unit held in place with chains. The new Berth 18 fender system is expected to add approximately 0.02 acre of overwater coverage and includes 68 cubic feet of fill below MHHW for each battery (340 cubic feet in total for the Berth 18 batteries). Mooring improvements include the installation of new bollards or quick-release hook units to accommodate the mooring lines for expected vessels. Mooring points would be anchored to the existing wharf deck, founded on new mat foundations.

Denmar Addendum to the WCDP EIR 25 April 2021

The existing dock structures contain stormwater drainage holes, which would be modified to contain any stormwater that comes into contact with soda ash. Contact stormwater would then be conveyed to a new stormwater retention pond and pre-treatment system prior to discharge to the existing stormwater system.

Wharf improvements would be installed from shore or from the water, depending on access. Water-based equipment may include a spud barge supporting a marine crane, storage and layout barges, and small work barges. The spud barge would be anchored with two to four steel spuds that would not be driven but rather would be pushed into the substrate to hold the barge in place along with mooring lines. The sizes of the spuds would depend on the contractor’s specific barge but are anticipated to be between 24 and 36 inches in diameter. The spud barge would be unable to provide access to the underside of the berth; falsework would be constructed under the deck to allow for the pile cap and deck strengthening installations. Overwater work would not require any temporary piles. Other storage and work barges would be conventionally moored at the berth during construction.

The shiploader would be brought to Berth 18 on a single ship and assembled on site.

2.3.3 Future Remediation Agency discussions are ongoing to further define future remediation; the RAP and RDIP would identify the specific steps that the Port would take to complete the Remediation Project and specific areas to be remediated. In future remediation, soil and waste from select areas would be excavated and consolidated within on-site waste cells, which would then be closed with an engineered soil cover. Expanded soil cover is also anticipated at several areas adjacent to waste cells that contain disperse soil contamination.

Areas and related actions may include the following, as summarized in Figure 5:

• Areas of Known Contamination that are not addressed during the initial remediation, and are located outside of the Consolidated Landfill Cells, would be excavated to the full depth of contamination (estimated at 1.5 to 6 feet deep) along their entire extents. Approximately 24,400 cubic yards of contaminated soil would be excavated from these areas and placed on site in the Consolidated Landfill Cells outside the Denmar terminal construction areas. • Areas of Potential Contamination and Contingency Excavation areas may require additional excavation or other actions to be determined in the future. Additional soil data from Areas of Potential Contamination will be evaluated to determine the appropriate response actions, which may include localized additional excavation and/or permanent capping. Contingency Excavation areas are included in the event shallow soil contamination is found to extend beyond the Areas of Known Contamination and Areas of Potential Contamination.

Denmar Addendum to the WCDP EIR 26 April 2021

• Consolidated Landfill Cells are the Landfill Cells outside the Denmar terminal construction areas (Figure 5), in which any material excavated during future remediation would be consolidated. The excavated soil and waste would be used to construct the foundation layer for the engineered cover at each consolidated waste cell in accordance with CCR Title 27 requirements. The Consolidated Landfill Cells would be closed during future remediation with an engineered cover, which consists of a foundation layer, a low-permeability liner, and an 18-inch vegetative soil layer seeded with native, non-invasive grasses. The engineered cover is a well-established technology to cap landfills in a manner that prevents contact with waste and limits infiltration from precipitation. • Soil Cover Areas are the areas adjacent to Consolidated Landfill Cells that are anticipated to receive expanded soil cover during future remediation as an additional protective measure. The soil cover would be tied into the engineered covers constructed over the Consolidated Landfill Cells. The soil cover would be 2 feet thick and would consist of clean imported soil, placed in a manner to promote plant growth following seeding with native, non-invasive grasses. Following vegetation establishment, this layer would resist erosion and provide a durable barrier from the underlying soil contamination.

This addendum uses a conservative estimate of the total future remediation, including excavation and on-site consolidation of up to 223,200 cubic yards of contaminated soil. This estimate includes materials from Areas of Known Contamination, Areas of Potential Contamination, and Contingency Excavation areas that are not addressed in the initial remediation. This estimate is expected to be extremely high; this is to allow this analysis to consider all possible remediation effects. The remedial design will be refined through ongoing investigations, data evaluation, and agency discussions. An estimated 74,000 cubic yards of clean material would be imported from sources on Roberts Island and/or elsewhere on Rough and Ready Island for soil cover and capping during future remediation.

The excavation, placement, and material handling activities would be conducted on the site using standard construction equipment such as excavators, dump trucks, dozers, and grading and compacting equipment. Construction would occur approximately 8 hours per day, during daylight hours. Future remediation is anticipated to occur concurrently with Denmar terminal operations (summarized in Section 2.4).

The soil cover and engineered cover areas would be inspected and maintained regularly, including groundwater monitoring and landfill gas control. Access roads are included in the Denmar terminal embankment design to facilitate access for future remediation activities, including monitoring and inspection activities. Denmar terminal operations will include procedures for this future access.

Denmar Addendum to the WCDP EIR 27 April 2021

2.3.4 Phase 2 Denmar Terminal Construction Phase 2 of Denmar terminal construction is anticipated to be completed 3 to 5 years following completion of Phase 1; however, the timeline for reaching full build-out would ultimately depend on market conditions. Phase 2 construction may include some or all of the following: installation of an additional rail track on the existing rail loop; a second storage building (north storage building) and stacker reclaimer; associated conveyors and towers; and berth improvements and installation of a shiploader on Berth 19. Construction timing for these remaining elements is to be determined, but is anticipated to occur concurrently with Denmar terminal operations (summarized in Section 2.4) and may occur concurrently with future remediation (Section 2.3.3).

2.3.4.1 Additional Rail Loop Staging Track All grading and subsurface work for track embankments would be performed as part of the Phase 1 construction. Phase 2 construction would add placement of final subballast, track, and ties alongside the tracks constructed in Phase 1, using methods similar to those described for Phase 1 track construction.

2.3.4.2 Second Storage Building Warehouse 805 would be demolished, and the north storage building would be constructed. This storage building would be built to the same dimensions and using the same methods as the south storage building constructed during Phase 1.

2.3.4.3 Berth 19 Improvements The transit shed at Berth 19 would be demolished. Improvements on Berth 19 would be constructed similarly to those on Berth 18 during Phase 1, including improvements to the mooring and fender systems to accommodate the type and size of expected vessels, improvements to the existing wharf structure to improve the structural and seismic capacity to support the shiploader operations, and installation of a shiploader. All new work, except for the fender panels, would occur on the existing berth, above MHHW, involving overwater demolition and concrete work; no in-water work would be required. The fender panels, although attached to the wharf deck, would extend into the water below MHHW by a few feet. The new Berth 19 fender system is expected to add approximately 0.02 acre of overwater coverage and includes 68 cubic feet of fill below MHHW for each battery (340 cubic feet in total for the Berth 19 batteries).

2.3.5 Environmental Management During Construction As described further in Section 3, construction and remediation would require compliance with several standard permits and regulatory oversight plans. Environmental management measures and procedures would be implemented as part of construction as required by these permits and plans. This section includes a summary of standard compliance plans and the environmental management

Denmar Addendum to the WCDP EIR 28 April 2021

measures and procedures that would be implemented to avoid and minimize any potential impacts. These measures and procedures are described in the following bullets: • City building permits and the Stormwater Pollution Prevention Plan (SWPPP) and Erosion Control Plan prepared in compliance with the NPDES Construction Stormwater General Permit require implementation of erosion control measures. Appropriate erosion control measures would be implemented prior to clearing, grading, or excavation activities to minimize erosion of sediments due to rainfall runoff at remediation or construction sites and to reduce, eliminate, and prevent the pollution of stormwater during remediation or construction. These control measures would be identified in the project plans and construction specifications and implemented as required by the building permit and SWPPP. • A Spill Prevention Control and Countermeasures Plan (SPCCP) to manage toxic materials associated with construction activities (e.g., equipment leakage, disposal of oily wastes, cleanup of any spills, storage of petroleum products and chemicals in contained areas away from streams and wetlands) would be developed, implemented, and maintained. The SPCCP would outline best management practices (BMPs), responsive actions in the event of a spill or release, and notification and reporting procedures. The plan also would outline management elements such as personnel responsibilities, project site security, site inspections, and training. A communication protocol for handling spills would be established. Applicable spill response equipment and material designated in the SPCCP would be maintained at the job site. • All remedial activities would be required to comply with all stipulations in the RAP and RDIP, potentially including but not limited to the need to prepare and comply with the following: ‒ Health and Safety Plan ‒ Construction Quality Assurance Plan ‒ Operation and Maintenance Plan ‒ Community Air Monitoring Plan

The following list presents an overview of expected environmental measures and BMPs that would be implemented before, during, and following remediation and construction to adhere to environmental requirements; references to these measures are included in Section 3. Additional measures may be required through permit conditions and would be included in applicable construction plans and contracts. • Filter fabric fences would be installed around disturbed areas. • Silt traps would be installed in storm drain inlets. • Gravel construction entrances would be installed, appropriate means to minimize tracking sediment onto public roadways by construction vehicles would be used, and regular street cleaning would be conducted for mud and dust control. • All staging areas would be delineated on plans. Staging and temporary stockpiling of materials would be prohibited within waters of the United States and state.

Denmar Addendum to the WCDP EIR 29 April 2021

• Temporary soil stockpiles and exposed soils would be stabilized. Stockpiles that are to remain on site through the wet season (October 15 to April 15) would be covered or otherwise protected to prevent erosion. Permanent stabilization of disturbed areas would occur after construction is completed. Temporarily disturbed areas would be restored by establishing grass or other vegetative cover on the construction site as soon as possible after disturbance. At a minimum, vegetative application would be done by September 15 to allow for plant establishment. No disturbed surfaces would be left without erosion control measures in place during the wet season. • Construction equipment and vehicles would be refueled away from surface waters whenever practical. • Equipment and vehicle wash water associated with construction would be contained and prevented from draining to surface waters. • Fuels and other potential contaminants would be stored away from excavation sites and surface waters in secured containment areas. No oil, fuels, or chemicals would be discharged to surface waters or onto land where there is a potential for entry into surface waters. • Regular inspections, maintenance, and repairs of fuel hoses, hydraulically operated equipment, lubrication equipment, and chemical and petroleum storage containers would be conducted. • No construction debris or fluids would be allowed to enter the San Joaquin River. Concrete process water would not be allowed to enter the San Joaquin River. Any process water or contact water would be captured in water-tight forms or chutes and routed to a contained area for treatment and disposal at a permitted upland location to be determined by the contractor. • Equipment would be checked for leaks and other problems that could result in the discharge of petroleum-based products or other material into the San Joaquin River. • Netting or a similar system would be used to prevent berth work construction materials from falling below the deck into the San Joaquin River. • Excess or waste materials would not be stored, disposed of, or abandoned waterside of MHHW or allowed to enter waters. • Waste materials would be disposed of in an appropriate manner consistent with applicable local, state, and federal regulations. • Construction materials would not be stored where wave action or upland runoff can cause materials to enter surface waters. • Oil-absorbent materials would be present on site for use in the event of a spill or if any oil product is observed in the water. • Prefabricated steel fender panels would be used where practicable to avoid working with wet concrete in areas over water. • Forms for any concrete structure would be constructed to prevent leakage of wet concrete.

Denmar Addendum to the WCDP EIR 30 April 2021

• Groundwater extracted during construction would be containerized and analyzed for contaminants. Based on the results, the groundwater would be disposed of by discharging to the surface to infiltrate, conveyed to the stormwater system or the sanitary system, or disposed of at an approved off-site facility.

2.4 Proposed Denmar Operations Denmar would operate the terminal to export natural soda ash. Soda ash would be transported to the Port by unit trains and exported via ocean-going ships. There would be no truck transport associated with either operational phase of the Denmar terminal. Ongoing facility operations would include the following: • The receipt, storage, and shipment of soda ash • Maintenance, repair, and operation of the tenant improvements • Access to the licensed and leased areas as well as Port common areas • Lawful ancillary uses related to rail and terminal operations, including but not limited to installation and replacement of tenant improvements such as solar panels, electrical vehicle charging stations, signage, and other on-site amenities and improvements incidental to terminal operation

2.4.1 Phase 1 Operation As noted above, the facility would be constructed in two phases; Phase 1 operations would begin after Phase 1 construction. Soda ash would be transported by unit trains to the Port along existing main line tracks. After entering the West Complex, unit trains would access the Denmar terminal rail loop via existing track infrastructure. As the trains move through the loop, the soda ash would be transferred using bottom-dump hopper railcars. As each railcar passes through the railcar unloading building, the bottom of the hopper car would open, and contents would be deposited in a hopper and feed conveyor system in an unloading pit. The rail loop would have enough capacity to support an entire train. A centralized dust collection system would collect dust from the conveyor transfer points and create a downdraft within the hopper to capture dust generated by falling material.

During Phase 1, soda ash would be transferred through a series of enclosed conveyors from the railcar unloading building up to the west end of the storage building. Because soda ash is highly soluble in water, the facility would limit the exposure of soda ash to the elements. After the soda ash is deposited, it would be transported from the rail unloading building onto a series of fully enclosed conveyors to a storage building, or if a vessel is available, directly to the berth. When a vessel arrives at Berth 18 during Phase 1 operations, soda ash from the outbound conveyor would pass through a tower adjacent to the dock, be conveyed onto an enclosed conveyor, and be transferred onto the shiploader. The shiploader would be capable of a range of motion enabling it to reach all of the holds on the ship, and equipped with dust minimization and containment and collection features.

Denmar Addendum to the WCDP EIR 31 April 2021

2.4.2 Phase 2 Operation After addition of the north storage building in Phase 2 construction, soda ash would be stored temporarily in one of the two storage buildings prior to loading onto ships. A short conveyor would allow for directing soda ash from the southern storage building tower to the northern storage building.

After construction of the second shiploader, when a vessel arrives at either berth, soda ash would travel on the enclosed outbound conveyors on the east end of a storage building, to the tower near the berths, to the final enclosed conveyor, and be transferred onto the shiploader at either Berths 18 or 19. Each shiploader would be capable of a range of motion enabling them to reach all of the holds on the anticipated ship sizes (i.e., handysize, handymax, and Ultramax), and equipped with dust minimization, containment, and collection features.

Full build-out is assumed to be achieved within 5 years of completing Phase 1 construction; however, the timeline for reaching full build-out would ultimately depend on market conditions and would be subject to permitting. At full build-out, the facility would require 71 full-time employees per day.

2.4.3 Project Throughput The facility would operate 24 hours per day, and would be open 365 days per year, but would be subject to holidays, maintenance, and potential weather delays that would result in a typical 336-day operating year. As shown in Table 3, during Phase 1, the facility is anticipated to handle approximately 4.8 million metric tons per annum (TPA) of soda ash and support approximately 137 annual vessel calls (two to three per week) and approximately 249 annual unit trains (approximately five per week). At full build-out, the facility would be anticipated to handle a total of approximately 7 million TPA of soda ash and support 200 annual vessel calls (approximately four per week) and 363 annual unit trains (approximately one per day).

Table 3 Proposed Denmar Terminal Annual Throughput

Proposed Denmar Terminal Annual Calls Material or Method Phase 1 Operation Phase 2 Operation (Full Build-out) Soda Ash (tons) 4.8 million 7 million Trucks 0 0 Ships 137 200 Trains1 249 363 Note: 1. The WCDP EIR assumed manifest trains. The Denmar terminal would use unit trains.

Denmar Addendum to the WCDP EIR 32 April 2021

As noted above, the WCDP EIR projected a total increase of 1.3 million annual truck trips, 150 annual ship calls, and 240 rail trips. Currently, facilities in the West Complex generate approximately 270,000 annual truck trips, 40 annual ship calls, and 180 annual rail trips. Table 1 presents a comparison of Denmar’s operation with the levels assumed in the WCDP EIR and existing conditions (defined as 2019, the last full year of operations and prior to any reductions associated with the COVID-19 pandemic).

Denmar Addendum to the WCDP EIR 33 April 2021

3 Environmental Analysis The Notice of Preparation for the WCDP EIR identified several potentially significant impacts that could result from implementation of the WCDP, leading to the Port’s decision to prepare an EIR. Based on preliminary analysis, the Port determined that the WCDP EIR should address the full range of environmental issues identified in CEQA. Therefore, the analysis in this section considers the Proposed Project, including the proposed modifications (transportation mode changes and taller storage buildings), and the full range of environmental resource areas assessed in the WCDP EIR.

3.1 Land Use and Agriculture Proposed Project- Significance Threshold WCDP EIR Findings Related Findings a. The Proposed Project will not conflict with applicable land Less-than-Significant Less-than- use designations and adopted plans and policies. Impact Significant Impact b. Implementation of the Proposed Project will result in the Significant and No Impact conversion of 272 acres of Prime Farmland. Unavoidable Impact

3.1.1 Environmental Setting The WCDP EIR provided a framework for considering the land use and agriculture effects of the Proposed Project. The land use and agriculture setting of the Port and its environs are described in the WCDP EIR (Section 4.2 of the Draft EIR [DEIR]) and updated in this section. The following text summarizes context information for land use and agriculture relevant to the Proposed Project.

The City’s 2040 General Plan (City 2018) designates the project site as “Institutional,” and the zoning designation of the project area is “Port” (City 2020a). Port areas are designated for the operation of port facilities, including wharves, dockage, warehousing, and related port facilities. The nearby properties across Burns Cut are currently zoned for agricultural purposes (County 2020).

The project site does not support forestry resources. There are no timberland zoned properties within San Joaquin County (County) as of 2001 (CAL FIRE 2002). The nearest forest area is the Stanislaus Forest, which is more than 50 miles away.

3.1.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• City General Plan (City 1990), 2035 General Plan (City 2007), and 2040 General Plan (City 2018). The General Plan and its successors, the 2035 General Plan and 2040 General Plan, are the documents that are used by the City as the primary documents governing land use and development. The 2040 General Plan designates the project site as “Institutional.” This

Denmar Addendum to the WCDP EIR 34 April 2021

designation allows for public and quasi-public uses such as schools, libraries, colleges, water treatment facilities, airports, some governmental offices, federal installations, and other similar and compatible uses; residential uses are prohibited. The maximum floor area ratio (FAR) for institutional uses outside the downtown area is 0.5. The following 2040 General Plan goals and policies are relevant to the land use and agriculture analysis of the Proposed Project: ‒ Goal LU-4: High-Quality Jobs, Attract and retain companies that offer high-quality jobs with wages that are competitive with the region and state. • Policy LU-4.2: Attract employment- and tax-generating businesses that support the economic diversity of the city. ‒ Goal LU-5: Protected Resources, Protect, maintain, and restore natural and cultural resources • Policy LU-5.2: Protect natural resource areas, fish and wildlife habitat, scenic areas, open space areas, agricultural lands, parks, and other cultural/historic resources from encroachment or destruction by incompatible development. ‒ Goal LU-6: Effective Planning, Provide for orderly, well-planned, and balanced development. • Policy LU-6.1: Carefully plan for future development and proactively mitigate potential impacts. • Policy LU-6.2: Prioritize development and redevelopment of vacant, underutilized, and blighted infill areas. ‒ Goal TR-1: Mobile Community, Provide an integrated transportation system that enables safe and efficient movement of people and goods for all modes of travel. • Policy TR-1.3: Facilitate expanded port and airport operations, service, and development as travel and goods movement assets to the community and sources of employment growth. • SJMSCP (County 2000). The SJMSCP is a voluntary program that allows participants (including the City and County) to issue Incidental Take Permits or mitigate for impacts to certain special-status species. • Stockton Municipal Code. The City Municipal Code implements the land use and zoning designations in the 2040 General Plan (City 2018), including development standards addressing building location (setbacks) and size, building design and coverage, parking requirements, provision of open space, and identification of allowed land uses. The zoning for the project site is PT (Port District), which is characterized as areas operated by port districts for the operation of port facilities, including wharves, dockage, warehousing, and related port facilities. Pursuant to Municipal Code section 16.24.200, there is no height limit for development in the PT zone.

Denmar Addendum to the WCDP EIR 35 April 2021

3.1.3 Mitigation Measures No mitigation measures from the WCDP EIR apply to land use and agriculture, and no new or modified mitigation measures are proposed for this resource area.

3.1.4 Methods/Approach Impacts to or associated with land use and agriculture were qualitatively evaluated based on the potential for the Proposed Project to alter land uses, designations, and zoning of land in and around the project area, including agricultural and forest land. Relevant findings from the WCDP EIR pertaining to land use and agriculture are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.1.5 Impact Assessment

3.1.5.1 The Proposed Project will not conflict with applicable land use designations and adopted plans and policies. The WCDP EIR concluded that development of the West Complex is consistent with the City of Stockton General Plan (General Plan; City 1990), the City Planning and Zoning Code (City 2020b), and the SJMSCP (County 2000). Development of the land uses and types of Port-related terminals and uses described in the WCDP EIR were found to be consistent with the zoning designations and goals and policies contained within the General Plan, and impacts were considered less than significant.

The Proposed Project, which consists of remedial activities and development of a marine bulk cargo terminal, entails construction and operations consistent with the land uses evaluated in the WCDP EIR, and is therefore also consistent with applicable land use plans. Although the City updated the General Plan in 2018 with the 2040 General Plan (City 2018), this update does not affect the land use analyses provided in the WCDP EIR. Zoning designations in the West Complex are unchanged, and both the WCDP and Proposed Project remain consistent with the updated 2040 General Plan goals and policies. The taller storage buildings are consistent with land use provisions in the 2040 General Plan and the Stockton Municipal Code because they would constitute permitted port-related uses and there is no height limit applicable to the project site. The Proposed Project would be consistent with the 2040 General Plan’s maximum FAR of 0.5 for institutional land uses. While the transportation mode mix would change, the types of transport would be unchanged (rail, truck, and ship calls), and there are no General Plan policies or zoning regulations that restrict transportation mode mix. Therefore, the Proposed Project would neither create new or additional impacts related to land use designations and adopted plans and policies, nor conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and the findings would be the same as those described in the WCDP EIR. In addition, because there are no communities on

Denmar Addendum to the WCDP EIR 36 April 2021

or adjacent to the project site, construction and operation of the Proposed Project would not result in the division of a community.

Because none of the project area is designated as forest land or timberland, and the nearest forest area is over 50 miles away from the project area, the Proposed Project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code [PRC] 12220[g]), timberland (as defined by PRC 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104[g]), result in the loss of forest land or conversion of forest land to non-forest use, or involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use, and there would be no impact to land designated as forest land or timberland.

Based on the analysis presented above, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.1.5.2 Implementation of the Proposed Project will result in the conversion of 272 acres of Prime Farmland. The WCDP EIR identified 272 acres of Prime Farmland within the 1,459-acre area that would be impacted by the WCDP. This was considered a significant and unavoidable impact in the WCDP EIR.

The project site does not currently support agricultural use and is zoned for non-agricultural uses, which precludes the lease area from qualifying for Williamson Act contracts. The Proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. Similarly, because there is no land in the project area zoned for agricultural use or eligible for Williamson Act contracts, the Proposed Project would neither conflict with existing zoning for agricultural use, or a Williamson Act contract, nor involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland to non-agricultural use. Therefore, there would be no impact to Prime Farmland as a result of the Proposed Project and no new or additional impacts to farmland beyond that described in the WCDP EIR.

3.2 Transportation and Circulation Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Significant and Trip Generation rates which result in a substantial number of Significant and a. Unavoidable new vehicle trips. Unavoidable Impact Impact Less-than-Significant Less-than- Trip Generation rates which result in substantial amounts of b. Impact with Significant Impact additional truck traffic. Mitigation with Mitigation

Denmar Addendum to the WCDP EIR 37 April 2021

Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Two intersections within the Project Area would continue to operate at acceptable levels of service with implementation Less-than-Significant Less-than- c. of the Proposed Project under the Cumulative (2020) Plus Impact Significant Impact Project Condition. Increased traffic associated with implementation of the Significant and Proposed Project under the Cumulative (2020) Plus Project Significant and d. Unavoidable Condition would contribute to unacceptable levels of service Unavoidable Impact Impact at eighteen intersections within the Project Area. Eighteen freeway facilities would continue to operate at acceptable levels of service with implementation of the Less-than-Significant Less-than- e. Proposed Project under the Cumulative (2020) Plus Project Impact Significant Impact Condition. Increased traffic associated with implementation of the Significant and Proposed Project under the Cumulative (2020) Plus Project Significant and f. Unavoidable Condition would contribute to unacceptable levels of service Unavoidable Impact Impact at thirty-three freeway facilities.

3.2.1 Environmental Setting The WCDP EIR provides a framework for considering the transportation and circulation effects of the Proposed Project, including on-road vehicles used during construction related to remediation and construction and operation of the Denmar terminal. The roadway setting of the Port and its environs are described in the WCDP EIR (Section 4.3 of the DEIR) and updated in this section. The following text summarizes context information for transportation and circulation relevant to the Proposed Project, including the street and rail network that serves the area, maritime navigation, and a summary of current conditions.

The Port is served by several regional freeways and highways, namely Interstate 5 (I-5), SR-4, and SR-99, with local roads serving the terminals and wharves. I-5, Fresno Avenue, Center Street, and El Dorado Street serve the major north-south movements of traffic in the project area, and Washington Street, Navy Drive, and Charter Way serve the east-west flow of traffic in the project area.

California’s freight railroad system consists of Class I railroads (BNSF Railway [BNSF] and Union Pacific Railroad [UP]), which transport freight to and from the state over state lines and Class III railroads, referred to as shortline railroads, which provide local rail movements. Both UP and BNSF lines serve the Port. In northern California, the Martinez Subdivision, Feather River Canyon, and Donner Pass routes serve the ports of Oakland and Stockton, and are owned and dispatched by UP but serve BNSF through trackage right agreements. BNSF operates the Stockton Intermodal Facility on the southeast edge of the City, and UP operates a major intermodal facility and other terminal operations in Lathrop, California. Several shortline railroads also operate in Stockton. The Central California Traction Company (CCT), jointly owned by BNSF and UP, operates 52 miles of freight

Denmar Addendum to the WCDP EIR 38 April 2021

service between Stockton and Lodi and is the shortline operator for the Port. CCT connections are made with BNSF, UP, and the Stockton Terminal and Eastern Railroads, which run from Stockton to Linden (City 2018). The Port has its own internal railway system and CCT provides all switching and local movements within the Port.

The Port is served by the Stockton DWSC within the San Joaquin River, which provides access to the Port from the San Francisco Bay. Vessel traffic in the study area includes commercial shipping and recreational vessels, as well as vessels to support periodic maintenance dredging operations. All commercial deep draft vessels calling on the Port pick up a bar pilot at the offshore sea buoy before entering the San Francisco Bay through the Main Ship Channel.

3.2.2 Regulatory Setting Several changes to regulations governing traffic analyses have been made since the WCDP EIR. The regulatory setting has been included in full with updates as follows.

3.2.2.1 California Department of Transportation Policies Traffic analyses in the state of California are guided by policies and standards set at the state level by the California Department of Transportation (Caltrans) and local jurisdictions. Caltrans policies are applicable to the Proposed Project and are summarized in Caltrans’s Vehicle Miles Traveled-Focused Transportation Impact Study Guide, which provides a summary of goals and policies (Caltrans 2020a).

3.2.2.2 California Public Utilities Commission Authority The California Public Utilities Commission (CPUC) has legal regulatory authority over rail safety within California, including operations and grade crossings throughout the state. However, rail operations under the Proposed Project would not be subject to approval or modification by CPUC because no grade crossings at public roads would be added or modified.

3.2.2.3 California Department of Boating and Waterways Authority The California Harbors and Navigation Code vests authority with the California Department of Boating and Waterways to regulate matters of navigational safety for the state’s boating public. The code establishes laws and regulations governing the equipment and operation of vessels on waters of the state, including within the project area.

3.2.2.4 San Joaquin Council of Governments Plans and Programs SJCOG has developed a Regional Transportation Plan (RTP), which guides the region’s transportation development over a 20-year period and covers all modes of transportation. The RTP is updated every 3 years to reflect changes in available funding, economic activity, and population, and to incorporate findings from corridor studies and major infrastructure investments. The projects included in the RTP are also assessed as to their effect on air quality because the RTP is used in the State Implementation

Denmar Addendum to the WCDP EIR 39 April 2021

Plan (SIP) to ensure states are meeting federal conformity standards. If a project is included in the RTP, its effect on regional conformity goals has been accounted for. The current 2018 RTP was adopted by the SJCOG Board in June 2018. The City is responsible for coordination with RTPs.

3.2.2.5 City of Stockton Policies

3.2.2.5.1 City of Stockton 2040 General Plan The City’s 2040 General Plan (City 2018) guides the maintenance, design, and operation of transportation, including streets and highways, within the project area. The following General Plan goals, policies, and actions applicable to the Port and Proposed Project are provided for transportation:

• GOAL TR-1: Mobile Community, Provide an integrated transportation system that enables safe and efficient movement of people and goods for all modes of travel. ‒ Policy TR-1.1: Ensure that roadways safely and efficiently accommodate all modes and users, including private, commercial, and transit vehicles, as well as bicycles and pedestrians and vehicles for disabled travelers. • Action TR-1.1A: Direct truck traffic to designated truck routes that facilitate efficient goods movement and minimize risk to areas with concentrations of sensitive receptors, such as schools, for example by disallowing any new truck routes to pass directly on streets where schools are located, and vulnerable road users, like pedestrians and bicyclists. • Action TR-1.1B: Maintain and periodically update a schedule for synchronizing traffic signals along arterial streets and freeway interchanges to facilitate the safe and efficient movement of people and goods and to provide signal priority for transit vehicles at intersections. • Action TR-1.1C: Require roadways in new development areas to be designed with multiple points of access and to address barriers, including waterways and railroads, in order to maximize connectivity for all modes of transportation • Action TR-1.1D: Update existing Precise Road Plans to reflect the 2040 General Plan, including changes in land use and LOS requirements, and a shift in priority from vehicular travel to travel by all modes through complete streets. ‒ Policy TR-1.2: Enhance the use and convenience of rail service for both passenger and freight movement. • Action TR-1.2C: Provide grade separations at railroad crossings on arterial streets where feasible to ensure public safety and minimize traffic delay. ‒ Policy TR-1.3: Facilitate expanded port and airport operations, service, and development as travel and goods movement assets to the community and sources of employment growth.

Denmar Addendum to the WCDP EIR 40 April 2021

• Goal TR-4: Effective Transportation Assessments, Ensure that traffic-related impacts of proposed land uses are evaluated and mitigated. ‒ Policy TR-4.1: Utilize LOS information to aid understanding of potential major increases to vehicle delay at key signalized intersections. • Action TR-4.1A: Strive for LOS D or better for both daily roadway segment and peak-hour intersection operations, except when doing so would conflict with other land use, environmental, or economic development priorities, and with the following additional exceptions: ‒ In the Greater Downtown, strive for LOS E or better, but LOS F may be acceptable after consideration of physical or environmental constraints and other City goals and policies. ‒ Strive for different LOS standards along roadway segments determined to be operating at deficient LOS by SJCOG in the Regional Congestion Management Program (RCMP) ‒ Accept worse than adopted-standard LOS at intersections where widening the intersection would reduce bicycle and pedestrian safety and/or increase pedestrian crossing times such that they would create longer traffic delays due to signal timing. • Action TR-4.1B: Amend the City’s Transportation Impact Analysis Guidelines to reflect the updated LOS goals under Action TR-4.1.A and to refine the threshold at which a project needs to evaluate LOS impacts. ‒ Policy TR-4.2: Replace LOS with: 1) VMT per capita; and 2) impacts to non-automobile travel modes, as the metrics to analyze impacts related to land use proposals under CEQA, in accordance with SB 743. • Action TR-4.2A: To evaluate the effects of new development and determine mitigation measures and impact fees, require projects to evaluate per capita VMT and impacts to transit, bicycle, and pedestrian modes. ‒ Policy TR-4.3: Use the threshold recommended by OPR for determining whether VMT impacts associated with land uses are considered significant under state environmental analysis requirements.

3.2.2.5.2 City Transportation Impact Analysis Guidelines While the General Plan policies call for amending the City’s Transportation Impact Analysis (TIA) Guidelines, new guidelines from the City are not yet available. The City’s TIA Guidelines require transportation impact analyses for projects generating 100 or more vehicle trips during the AM or PM peak hours. The TIA Guidelines identify the minimum acceptable operations criteria for roadway segments and signalized intersections to be LOS D.

Denmar Addendum to the WCDP EIR 41 April 2021

3.2.3 Mitigation Measures The following mitigation measure from the WCDP EIR remains applicable to the Proposed Project: • Mitigation Measure 4.3.1 – Implement Feasible Travel Demand Measures

Details on this mitigation measure can be found in Appendix A.

3.2.4 Methods/Approach The WCDP EIR’s analysis of transportation and circulation impacts considered whether implementation of the WCDP would increase traffic volumes by at least 5%, would degrade LOS from an acceptable level (defined as LOS A through D for intersections, and LOS A through E for freeway facilities) to an unacceptable level, or would increase traffic volumes by at least 5% on a facility operating at unacceptable LOS under existing conditions. As noted above, automobile delay, as described solely by LOS or similar measures of vehicular capacity or traffic congestion, is no longer considered a significant impact on the environment under CEQA (PRC 21099[b][2]). While not required under CEQA, this addendum includes an analysis of LOS impacts for informational purposes and to compare to the WCDP EIR findings.

The WCDP EIR completed a trip generation assessment of vehicle (defined as vehicles other than heavy-duty trucks) and truck trips to determine daily trips. The trip generation table projected that the WCDP at full build-out in 2020 would result in 51,319 daily vehicle and truck trips, with 8,307 new AM trips and 8,116 PM trips.

Because some development projects have occurred on the West Complex since the WCDP EIR was prepared (Section 1.1.3), and the Proposed Project includes modifications to the transportation mode mix (Section 1.2.2), a comparison of transportation modes at the WCDP EIR’s baseline conditions, as projected by the WCDP EIR, and existing conditions is presented in Table 4. The WCDP EIR assumed a mix of annual, monthly, and daily calls. Table 4 converts all calls to annual numbers assuming 300 working days per year, consistent with the WCDP EIR. As shown in Table 4, existing traffic levels in 2019 are below the WCDP EIR projections.

Table 4 Comparison of Transportation Mode Mix

5 Existing Proposed Denmar Terminal Operations WCDP EIR Full Traffic Maximum Levels WCDP EIR Build-Out Levels Maximum Phase 2 Mode Baseline (2020) (2019) Levels Phase 1 (full build-out) Trucks (daily trips)1 850 8,849 1,093 0 0 Trucks (annual) 127,500 1,327,350 274,343 0 0 Trains (month)2 12 20 164 20 30

Denmar Addendum to the WCDP EIR 42 April 2021

5 Existing Proposed Denmar Terminal Operations WCDP EIR Full Traffic Maximum Levels WCDP EIR Build-Out Levels Maximum Phase 2 Mode Baseline (2020) (2019) Levels Phase 1 (full build-out) Trains (annual)2 144 240 188 249 363 Vehicles (daily trips)1,3 2,704 42,470 10,000 152 152 Ships (annual calls) 20 150 43 137 200 Notes: 1. Trips are one-way trips (i.e., one vehicle visit to terminal would result in two one-way trips). 2. The WCDP EIR assumed manifest trains; the Denmar terminal would operate unit trains. 3. “Vehicles” is cars and light-duty trucks; it does not include heavy-duty on-road trucks. 4. Average monthly manifest trains 5. Phase 2 throughout represents the total throughput to the terminal inclusive of (not additive to) Phase 1 throughput.

Table 5 presents the truck and vehicle trips associated with construction. During the period of overlap between initial remediation and Phase 1 of the terminal construction, there would be a maximum of 157 workers on site. Once initial remediation work concludes, the maximum number of on-site workers would be 142.

Table 5 Construction Trips Associated with Remediation and Terminal Development

Transportation Mode Trips Haul Trucks (daily trips) 305 Vehicles (daily trips) 314 Notes: Trips are one-way trips (i.e., one vehicle visit to the terminal would result in two one-way trips). Construction includes remediation and terminal construction

3.2.5 Impact Assessment

3.2.5.1 Trip generation rates which result in a substantial number of new vehicle trips. The WCDP EIR found that implementation of the WCDP at full build-out would generate 42,470 new off-site vehicle trips on roadways serving the West Complex (vehicle trips do not include truck trips, which are addressed in Section 3.2.5.2). Vehicle trips would mainly be generated from high-density employment land uses identified in the WCDP EIR (such as “Office – Industrial” and “High Tech – Research & Development”). The WCDP EIR found these impacts to be significant and implementation of mitigation as identified in Appendix A, requiring implementation of feasible travel demand measures, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation. As described in Section 1.1.3 and noted in Table 4, substantial area

Denmar Addendum to the WCDP EIR 43 April 2021

within the West Complex remains undeveloped and the current developments are Port-dependent bulk, commercial, industrial, and/or warehousing operations, which have generated lower volumes of vehicle trips than anticipated in the WCDP EIR. As shown in Table 4, the WCDP EIR analyzed the addition of 40,000 new daily vehicle trips. As of 2019, there were 10,000 daily vehicle trips.

At full build-out, the Denmar terminal would require 71 full-time employees per day. An additional five daily roundtrips are assumed to account for visitors and deliveries. As such, the Denmar terminal would generate 76 new vehicle roundtrips (or 152 one-way trips) to the West Complex through employee commuting and visitor trips. As shown in Table 4, these levels would not exceed the volumes analyzed in the WCDP EIR.

Construction activities would also involve daily vehicle trips and have the potential to affect traffic levels during the estimated 4-year construction period. Remediation and construction of the Denmar terminal would temporarily generate new vehicle trips from construction employee commutes to and from the construction site. The majority of these trips would be during the 4-month period when initial remediation and Phase 1 of the Denmar terminal construction overlap, which would involve up to 157 round trips per day or 314 one-way trips per day. Following initial remediation, Phase 1 of terminal construction would result in up to 142 round trips or 284 on-way trips per day over a 2-year period. While construction-related vehicle trips were not quantified in the WCDP EIR, the volume of construction- and remediation-related vehicle trips for the Proposed Project would be temporary and would not exceed the daily volumes analyzed in the WCDP EIR.

While vehicle trips would increase as part of construction and operation, the trips can be accommodated within the larger Port network which is designed for Port and industrial operations. Vehicular access to and from the West Complex site is currently provided from Navy Drive or from the Port of Stockton Expressway, such that if one route was blocked, there are alternate routes to access the site. The Port has developed an emergency response plan to address emergency needs Port-wide and maintains its own Police Department, which is responsible for providing security protection of Port tenants on a 24-hour basis. Additionally, the closest fire station to the project site is approximately 3.5 miles to the east of the site at 110 West Sonora Street.

Because the vehicle trips are within the numbers assumed and analyzed in the WCDP EIR, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.2.5.2 Trip generation rates which result in substantial amounts of additional truck traffic. The WCDP EIR found that full build-out of the WCDP would increase the number of truck trips on local and regional roadways up to an additional 8,849 truck trips per day over existing conditions (Port 2004; Table 4.3-13 of the Draft EIR). These impacts were considered significant and implementation of

Denmar Addendum to the WCDP EIR 44 April 2021

mitigation as identified in Appendix A, requiring development and implementation of a truck travel control plan, was required to reduce impacts to less-than-significant levels.

As discussed in Section 2.4, the Denmar terminal’s operations would not include any new truck trips; rail would be used for product transport and trains would use the existing rail lines in and out of the Port consistent with the assumptions in the WCDP EIR. Therefore, there would be no new or additional operational impacts associated with truck trips, and the findings would be the same as those described in the WCDP EIR. These existing rail lines do not intersect with any of the intersections found to have significant LOS delays in the WCDP EIR.

Construction activities would involve daily truck trips that could have the potential to affect traffic levels on a temporary basis. While the WCDP EIR assumed up to an additional 8,849 daily truck trips, on-road truck trips associated with construction were not included in this total or quantified in the WCDP EIR. The Proposed Project construction-related truck traffic would include the initial movement of construction equipment to the site at the start of construction and eventual movement from the site at the end of construction. In addition, the Proposed Project includes haul truck trips to import clean fill, rock base, and construction materials, and to export construction debris. All excavated material associated with remediation would be used for consolidation on site; therefore, there would be no export truck trips associated with remediation. The largest number of truck hauling trips would occur during the time period when initial remediation and Phase 1 Denmar terminal construction activities overlap, when up to 305 truck trips per day would be used to haul material on and off site. The majority of these trips would be between the project site at the Port and the Rough and Ready Island or Roberts Island soil borrow sites (2 miles to the east and 5 miles to the west, respectively), and between the Port and George Reed Jackson Valley rock quarry (35 miles to the northeast).

While the WCDP EIR did not quantify construction-related truck trips, as discussed above, the existing level of truck trips in 2019 is well under what was assumed in the WCDP EIR (1,093 daily truck trips in 2019, versus a maximum of 8,849 daily truck trips as projected by the WCDP EIR at full build-out). While the truck trips projected in the WCDP EIR were associated with operations, construction trucks share the same characteristics as heavy-duty operational trucks. Truck trips associated with construction and remediation for the Proposed Project (305 trips per day), when combined with existing (2019) truck trips (1,093), would still be well below truck trip volumes projected at full build-out in the WCDP EIR (8,849).

Because construction haul trips would need to be staged throughout the day to allow for access on the construction site, haul traffic is assumed to be distributed fairly evenly throughout the day. Assuming a maximum of 305 trips a day spread throughout 10 hours of construction per day (for example, 7:00 AM to 5:00 PM), there would be only 30.5 truck trips per hour.

Denmar Addendum to the WCDP EIR 45 April 2021

The truck trips would travel on local Port roads with the majority using SR-4 to access Roberts Island and I-5 to access the rock quarry by way of six access ramps, four serving northbound and southbound I-5 and two serving eastbound and westbound SR-4. A review of Google Maps midweek (typical Wednesday) traffic flow during the AM and PM peak hours shows that neither I-5 or SR-4 freeway-to-freeway ramp connections experience slow or forced traffic flow conditions in the Port area (Google Maps 2019). Therefore, the affected highways do not operate at LOS E or F. In addition, the Proposed Project would not cause changes in local circulation networks that impact a state highway facility, and there are no identified areas of increased risk for traffic incidents.

Based on the analysis presented above, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.2.5.3 Two intersections within the Project Area would continue to operate at acceptable levels of service with implementation of the Proposed Project under the Cumulative (2020) Plus Project Condition. The WCDP EIR found that two study intersections would continue to operate at an acceptable LOS with implementation of the WCDP, and impacts were considered less than significant.

As discussed above, the Denmar terminal operations would include a limited amount of new vehicle trips and no truck trips, which would be within the levels analyzed in the WCDP EIR and therefore would not cause any new intersection impacts. Construction (remediation and Denmar terminal construction) would generate new vehicle and truck trips that also would be within the levels analyzed in the WCDP EIR, and therefore would not cause any new intersection impacts. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.2.5.4 Increased traffic associated with implementation of the Proposed Project under the Cumulative (2020) Plus Project Condition would contribute to unacceptable levels of service at eighteen intersections within the Project Area. The WCDP EIR found that 18 intersections would operate at an unacceptable LOS during the morning and evening peak hours when considering the cumulative impact of WCDP implementation and other past, present, and reasonably foreseeable future projects. These impacts were considered significant and implementation of Mitigation Measure 4.3.4 identified in Appendix A, requiring fair share contribution to intersection/roadway improvements, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation for three of the 18 intersections.

As previously discussed, the Denmar terminal’s operations would include a limited amount of new vehicle trips (up to 76 roundtrips or 152 one-way trips per day) and no truck trips, which would be

Denmar Addendum to the WCDP EIR 46 April 2021

within the levels analyzed in the WCDP EIR and therefore would not cause new or more severe impacts at the 18 intersections.

Vehicle trips and truck trips associated with construction would be within the projections analyzed in the WCDP EIR and therefore would not cause any new or more severe intersection impacts at the 18 intersections identified in the WCDP EIR.

The increased rail transit would not cause intersection delays; the existing mainline rail tracks do not intersect with any of the intersections found to have significant LOS delays. In addition, several area grade separations preclude traffic delays from passing trains.

Based on the analysis above, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.2.5.5 Eighteen freeway facilities would continue to operate at acceptable levels of service with implementation of the Proposed Project under the Cumulative (2020) Plus Project Condition. The WCDP EIR found that traffic associated with the WCDP would not substantially increase vehicle traffic on any freeway facilities, and impacts were considered less than significant.

As previously discussed, the Denmar terminal’s operations would include a limited amount of new vehicle trips (up to 76 new vehicle roundtrips or 152 one-way trips) and no truck trips. Vehicle trips would be well within the projections analyzed in the WCDP EIR and therefore would not cause any new freeway capacity impacts. Vehicle trips and truck trips associated with construction would be within the projections analyzed in the WCDP EIR, and therefore would not cause any new intersection impacts. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.2.5.6 Increased traffic associated with implementation of the Proposed Project under the Cumulative (2020) Plus Project Condition would contribute to unacceptable levels of service at thirty-three freeway facilities. The WCDP EIR found that eight freeway facilities would operate at an unacceptable LOS during the morning and evening peak hours when considering the cumulative impact of WCDP implementation and other past, present, and reasonably foreseeable future projects. These impacts were considered significant and unavoidable.

As previously discussed, the Denmar terminal’s operations would include a limited amount of new vehicle trips (up to 76 new vehicle roundtrips or 152 one-way trips) and no truck trips. Vehicle trips would be well within the projections analyzed in the WCDP EIR and therefore would not cause any new freeway capacity impacts. Vehicle trips and truck trips associated with construction would be within the projections analyzed in the WCDP EIR. Therefore, the vehicle and truck trips associated

Denmar Addendum to the WCDP EIR 47 April 2021

with the Proposed Project would not cause new or more severe impacts on freeway facilities, and the findings would be the same as those described in the WCDP EIR.

3.3 Air Quality Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Construction-related activities associated with the Proposed Project would temporarily and intermittently increase fugitive Less-than-Significant Less-than- dust and combustion emissions that could violate state air a. Impact with Significant Impact quality standards if the air district’s standard dust control Mitigation with Mitigation measures were not implemented. The increase in fugitive dust is considered a potentially significant impact. Implementation of the Proposed Project would result in an Significant and Significant and b. increase in operational emissions of criteria air pollutants Unavoidable Unavoidable Impact (ROG, NOX and PM10). Impact Mobile emissions generated by the Proposed Project would increase CO concentrations at intersections in the area Less-than-Significant Less-than- c. surrounding the Project Area, but not to a level exceeding the Impact Significant Impact national or state standards. Implementation of the Proposed Project could result in Less-than-Significant Less-than- d. exposure of nearby sensitive receptors to certain toxic air Impact Significant Impact contaminants from various stationary and mobile sources.

3.3.1 Environmental Setting The WCDP EIR provides a framework for considering the effects of the Proposed Project on air quality, including construction equipment used during remediation and construction of the Denmar terminal as well as mobile and stationary sources used during operation of the Denmar terminal. The setting of the Port and its environs are described in the WCDP EIR (Section 4.4 of the DEIR) and updated in this section.

The air pollutants of concern in the project area are ozone, nitrogen oxides (NOX), carbon monoxide

(CO), sulfur oxides (SOX), and particulate matter equal to or less than 10 microns (PM10) and

2.5 microns (PM2.5). For the purposes of the air quality analysis, the study area is defined as the project site and the surrounding area, including roadways, railways, and the San Joaquin River/Stockton DWSC. The closest sensitive receptor to the project site is a residential area located approximately 700 feet to the north.

3.3.2 Regulatory Setting Several regulations related to air quality have been modified or issued since the WCDP EIR. This section presents a summary of the most recent regulatory requirements pertaining to air quality.

Denmar Addendum to the WCDP EIR 48 April 2021

3.3.2.1 Federal and State Policies

3.3.2.1.1 Emission Standards for Non-Road Diesel Engines USEPA has established a series of progressively cleaner emission standards for new non-road (off-road) diesel engines. Tier 1 standards were phased in from 1996 to 2000; Tier 2 standards were phased in from 2001 to 2006; Tier 3 standards were phased in from 2006 to 2008; and Tier 4 standards, which may require add-on emission control equipment, were phased in from 2008 to 2015. For each tier, the phase-in schedule is driven by engine size. To enable sulfur-sensitive control technologies in Tier 4 engines, USEPA mandated reductions in the sulfur content of non-road diesel fuels to 15 parts per million (ppm; also known as ultra-low-sulfur diesel), effective 2010 (DieselNet 2017). The federal fuel standard is preempted by the California standard, which took effect in 2006. These standards would apply primarily to construction equipment associated with the Proposed Project.

3.3.2.1.2 California Diesel Fuel Regulation ARB has set sulfur limitations for diesel fuel sold in California for use in on- and off-road motor vehicles and to fulfill ARB’s 2000 Diesel Risk Reduction Plan. Diesel fuel used in harbor craft in the SJVAPCD’s boundaries was limited to 500 ppm sulfur starting January 1, 2006, and 15-ppm sulfur starting September 1, 2006. Diesel fuel used in intrastate locomotives has been limited to 15 ppm sulfur since January 1, 2007.

3.3.2.1.3 California Air Resources Board Heavy-Duty Truck Idling Regulation This ARB rule became effective in 2005 and prohibits heavy-duty diesel trucks from idling for longer than 5 minutes at a time, unless they are queueing, provided the queue is located beyond 100 feet from homes or schools.

3.3.2.1.4 California Air Resources Board Cargo Handling Equipment at Ports and Intermodal Rail Yards This rule became effective in December 2005 when ARB approved the Regulation for Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards (13 California Code of Regulations [CCR] 79), which was designed to use best available control technology to reduce diesel PM and NOX emissions from mobile cargo handling equipment at ports and intermodal rail yards. Since January 1, 2007, the regulation has imposed emission performance standards on new and in-use terminal equipment that vary by equipment type. In October 2012, the Office of Administrative Law approved amendments to the regulation to provide additional flexibility for cargo handling equipment owners/operators in an effort to reduce compliance costs while continuing to reduce emissions.

Denmar Addendum to the WCDP EIR 49 April 2021

3.3.2.1.5 California Air Resources Board In-Use Off-Road Diesel Vehicle Rule In July 2007, ARB adopted a rule that requires owners of off-road mobile equipment powered by diesel engines 25 horsepower or larger to meet the fleet average or best available control technology requirements for NOX and PM emissions by March 1 of each year. The rule is structured by fleet size: large, medium, and small. Medium-sized fleets receive deferred compliance, and small fleets are exempt from NOX requirements and receive deferred compliance. The regulation was adopted in April 2008 and amended in 2011, delaying the initial compliance date for all fleets by 4 years.

3.3.2.1.6 California Air Resources Board Statewide Bus and Truck Regulation This regulation, adopted in 2008, requires the installation of PM retrofits on all heavy-duty trucks beginning in 2012 and replacement of older trucks starting in 2015. All vehicles must have 2010 model year engines or equivalent by 2023.

3.3.2.1.7 California Air Resources Board Regulation to Reduce Emissions from Diesel Engines on Commercial Harbor Craft

In November 2007, ARB adopted a regulation to reduce diesel particulate matter and NOX emissions from new and in-use commercial harbor craft. Under ARB’s definition, commercial harbor craft include tugboats, tow boats, ferries, excursion vessels, work boats, crew boats, and fishing vessels. The regulation implemented stringent emission limits on harbor craft auxiliary and propulsion engines. In 2010, ARB amended the regulation to add specific in-use requirements for barges, dredges, and crew/supply vessels.

3.3.2.1.8 California Air Resources Board Regulations for Fuel Sulfur and Other Operational Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Coast In 2008, ARB adopted a clean fuel regulation for ocean-going vessels within 24 nautical miles of the California coast to further reduce emissions from shipping. Since then, the permitted sulfur content of marine gas oil and marine diesel oil has been progressively lowered and since 2014 may not exceed 0.1%. ARB passed a rule in 2014 that allows marine vessels to be considered in compliance with the California ocean-going fuel regulation when they are complying with the North American Emission Control Area using alternative emission control technologies or non-distillate low sulfur (less than or equal to 0.1% sulfur) marine fuels.

3.3.2.2 San Joaquin Valley Air Pollution Control District Regulations SJVAPCD is responsible for implementing federal and state regulations at the local level in the project area, permitting stationary sources of air pollution, and developing the local elements of the SIP. Air quality management at the local level is also accomplished through development of regional CEQA significance thresholds and mitigation measures. SJVAPCD’s thresholds of significance,

Denmar Addendum to the WCDP EIR 50 April 2021

presented in Table 6, are based on the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS) and represent a regional approach to meeting CAAQS and NAAQS recognizing the air districts attainment status, emission sources, and regional geography. SJVAPCD’s CEQA significance thresholds are applicable to the Proposed Project.

Table 6 San Joaquin Valley Air Pollution Control District Criteria Pollutant Thresholds

Operations Non-Permitted Permitted Construction Equipment and Equipment and NAAQS/CAAQS Emission Thresholds Activity Threshold Activity Threshold Screening Level Pollutant (tons per year) (tons per year) (tons per year) (pounds per day)

NOX 100 100 100 100 ROG 10 10 10 100 CO 100 100 100 100

PM10 15 15 15 100

PM2.5 15 15 15 100

SO2 27 27 27 100 Note: Source: SJVAPCD 2015a

In addition to CEQA thresholds, SJVAPCD is responsible for permitting and rule compliance. The Denmar terminal would require a SJVAPCD Authority to Construct permit and would be required to adhere to all permit restrictions. Specific regulations applicable to the Proposed Project include the following: • SJVAPCD Rule 4101 – Visible Emissions: SJVAPCD Rule 4101 prohibits a single source to discharge any air contaminant, other than uncombined water vapor, which exceeds the standards set forth in Section 5 of this Rule. • SJVAPCD Rule 4102 – Nuisance: SJVAPCD Rule 4102-4 prohibits the discharge any air contaminants, which would cause injury, detriment, nuisance, or annoyance to the public. • SJVAPCD Rule 4201 – Particulate Matter Concentration: SJVAPCD Rule 4201-3 prohibits a single source to discharge dust, fumes, or suspended PM in excess of 0.1 grains per dry standard cubic foot under dry conditions. • SJVAPCD Rule 4202 – Particulate Matter Emission Rate: SJVAPCD Rule 4202-4 prohibits the discharge of PM into the atmosphere at a rate which exceeds the limitations determined by the process weight as defined and detailed in SJVAPCD Rule 4202. • SJVAPCD Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities: SJVAPCD Rule 8021 provides fugitive dust control requirements for any construction, demolition, excavation, extraction, and other earthmoving activities.

Denmar Addendum to the WCDP EIR 51 April 2021

• SJVAPCD Rule 8061 – Paved and Unpaved Roads: SJVAPCD Rule 8061 limits fugitive dust emissions from paved and unpaved roads by implementing control measures and design criteria. This rule applies to any new or existing public or private paved or unpaved road, road construction project, or road modification project. • SJVAPCD Rule 8041 – Carryout and Track Out: SJVAPCD Rule 8041 limits fugitive dust emissions from carryout and track out. Under this rule, the owner/operator shall remove all visible carry out and trackout at the end of each workday.

3.3.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Construction ‒ Mitigation Measure 4.4.1a – Retain an Air Quality Monitor During Periods of Construction-Related Activity ‒ Mitigation Measure 4.4.1b – Further Reduction of Emissions of Construction- related Fugitive Dust ‒ Mitigation Measure 4.4.1c – Minimization of Construction Equipment Emissions ‒ Mitigation Measure 4.4.1d – Further Reduction of Exhaust Emissions from Construction Equipment ‒ Mitigation Measure 4.4.2d – Reduction in Emissions from All Off-Road Equipment • Operations ‒ Mitigation Measure 4.3.1 – Implement Feasible Travel Demand Measures. ‒ Mitigation Measure 4.4.2b – Reduction of Emissions from Heavy-Duty Yard Equipment

Details on these mitigation measures can be found in Appendix A.

3.3.4 Methods/Approach SJVAPCD has developed quantitative criteria to evaluate the significance of criteria air pollutant emissions under CEQA. Specifically, a significant impact would occur if implementation of a project would result in emissions that exceed the SJVAPCD-established thresholds shown in Table 6. SJVAPCD’s CEQA thresholds represent the criteria air pollutant emission levels that would result in a direct or indirect project impact, as well as impacts resulting in a cumulatively considerable net increase in criteria air pollutants. SJVAPCD applies the CEQA thresholds separately to three emission categories: 1) construction emissions; 2) operational non-exempt equipment emissions; and 3) operational exempt emissions.

Denmar Addendum to the WCDP EIR 52 April 2021

In addition, SJVAPCD has developed thresholds related to the potential for health risk impacts for air pollutants. A significant impact would occur if a project would emit toxic air contaminants (TACs) that could cause a significant increase in health risks, including both carcinogenic and non-carcinogenic risks. A project is considered to have a significant TAC impact if it would: • Result in ground-level concentrations of carcinogenic TACs that would increase the probability of contracting cancer for the maximally exposed individual by 20 in 1 million or more (SJVAPCD 2015b) • Increase ground-level concentrations of non-carcinogenic TACs that would result in an acute or chronic hazard index exceeding 1 for the maximally exposed individual receptor (SJVAPCD 2015b)

To determine whether the Proposed Project would result in similar findings as those described in the WCDP EIR, an air quality study was completed. Complete details, as well as modeling results related to the air quality analysis, are included in Appendix B.

3.3.5 Impact Assessment

3.3.5.1 Construction-related activities associated with the Proposed Project would temporarily and intermittently increase fugitive dust and combustion emissions that could violate state air quality standards if the air district’s standard dust control measures were not implemented. The increase in fugitive dust is considered a potentially significant impact. The WCDP EIR assumed that development of the West Complex would include construction commensurate with full build-out of the 1,459-acre area with a mix of land uses. Construction- related air quality impacts from a variety of activities were considered, including grading, excavation, road building, and other earth moving activities; travel by construction equipment, especially on unpaved surfaces; exhaust from construction equipment; and asphalt paving. The WCDP EIR found that construction-related activities would temporarily and intermittently increase fugitive dust and combustion emissions that could violate state air quality standards if SJVAPCD’s standard dust control measures were not implemented. The WCDP EIR considered this impact to be significant and implementation of mitigation as identified in Appendix A, including air quality monitoring and construction fugitive dust and exhaust reduction measures, were required to reduce construction air quality impacts to less-than-significant levels.

The WCDP EIR did not quantify criteria air pollutant emissions from construction activities, such as those related to remedial activities and the Denmar terminal. Therefore, these project-specific emissions were quantified and the potential impacts from construction emissions were analyzed as part of the air quality study (Appendix B).

Denmar Addendum to the WCDP EIR 53 April 2021

Consistent with the WCDP EIR, the following mitigation measures would be implemented as part of the Proposed Project: • Mitigation Measure 4.4.1a – Retain an Air Quality Monitor During Periods of Construction-Related Activity • Mitigation Measure 4.4.1b – Further Reduction of Emissions of Construction-related Fugitive Dust • Mitigation Measure 4.4.1c – Minimization of Construction Equipment Emissions • Mitigation Measure 4.4.1d – Further Reduction of Exhaust Emissions from Construction Equipment

As shown in Table 7 and detailed in Appendix B, combined construction emissions associated with the remediation and terminal development elements of the Proposed Project would exceed SJVAPCD

NOX thresholds in 2021 and 2022 with incorporation of the WCDP EIR-identified mitigation measures.

Table 7 Proposed Project Construction Emissions (tons per year)

ROG NOX CO SOX PM10 PM2.5 2021 2.7 18 12 0.039 2.6 1.4 2022 1.9 12 9.4 0.030 1.6 0.87 2023 0.80 6.8 5.6 0.014 1.0 0.60 2024 1.6 7.6 7.0 0.019 1.5 0.80 2025 1.1 4.8 4.8 0.014 0.83 0.42 Threshold 10 10 100 27 15 15 Exceeds Threshold? N Y N N N N

Because project-specific construction emissions would exceed thresholds for NOx in years 2021 and 2022, when both initial remediation and Phase 1 Denmar terminal construction would occur, Mitigation Measure 4.4.1b – Further Reduction of Exhaust Emissions of Construction-related Fugitive Dust is proposed to be modified as follows (underlines represent new text):

Mitigation Measure 4.4.1b: When the Port approves a project component implementing the West Complex Development Plan, the Port will require compliance with any feasible and appropriate SJVAPCD Enhanced and Additional Control Measures applicable to the particular project component.

Denmar Addendum to the WCDP EIR 54 April 2021

In addition, the Port would further require compliance with its current standard idling and construction equipment requirements, which would supersede Mitigation Measure 4.4.1c. These include the following:

• Idling Restrictions. Denmar will require construction contractors to minimize heavy-duty construction idling time to 2 minutes where feasible. Exceptions include vehicles that need to idle to perform work, vehicles being serviced, or vehicles in a queue waiting for work. • Use of Tier 4 Engines During Construction. All off-road diesel- powered heavy equipment exceeding 50 horsepower used to construct the Proposed Project will be equipped with Tier 4 engines, except for specialized equipment or when Tier 4 engines are not available. The combined ratings of all non-Tier 4 diesel engines in use at any time during project construction shall not exceed 200 horsepower.

Table 8 presents the Proposed Project’s impacts with incorporation of the modified Mitigation Measure 4.4.1b – Further Reduction of Exhaust Emissions of Construction-related Fugitive Dust. As shown, impacts would be less than significant for all years.

Table 8 Proposed Project Construction Emissions with Modified Mitigation Measure (tons per year)

ROG NOX CO SOX PM10 PM2.5 2021 1.5 7.4 11 0.039 2.1 0.92 2022 1.1 5.4 9.1 0.030 1.3 0.54 2023 0.18 1.9 4.4 0.014 0.78 0.39 2024 1.0 2.8 6.3 0.019 1.3 0.59 2025 0.79 2.4 4.7 0.014 0.71 0.31 Threshold 10 10 100 27 15 15 Exceeds Threshold? N N N N N N

Therefore, there would be no new or additional impacts as a result of the Proposed Project and the findings would be consistent with those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 55 April 2021

3.3.5.2 Implementation of the Proposed Project would result in an increase in

operational emissions of criteria air pollutants (ROG, NOX, and PM10). The WCDP EIR found that implementation of the WCDP would result in an increase in operations- related criteria pollutant emissions, primarily from mobile sources. Stationary sources, such as on-site space heating and landscaping activities, would result in smaller quantities of pollutants. The WCDP

EIR found that operational emissions of reactive organic gases (ROGs) and NOX would exceed SJVAPCD’s thresholds. The WCDP EIR also found that implementation of the WCDP would result in substantial increases in PM10. Per these findings, impacts were considered significant and implementation of mitigation as identified in Appendix A, including implementing feasible travel demand measures and reducing truck and heavy-duty yard equipment and off-road equipment emissions, providing a heavy-duty vehicle education program, and evaluating the feasibility of implementing a diesel engine retrofit program, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation.

As discussed in Sections 1.2.2 and 2.4, operations associated with the Denmar terminal would include changes to the mode mix as compared to the WCDP EIR. Operations associated with the Denmar terminal would increase rail and vessel calls, but would not include truck calls. To determine whether the proposed changes would increase air emissions over what was assessed in the WCDP EIR, an air quality study was completed. As detailed in Appendix B and presented in Table 9, operational emissions would exceed SJVAPCD non-permitted thresholds for NOX and CO during Phase 1 of the Denmar terminal’s operations and ROG, NOX, and CO for operations associated with Phase 2 (full build-out).

Table 9 Operational Emissions, Non-Permitted Sources (tons per year)

ROG NOx PM10 PM2.5 CO SOx Phase 1 Architectural Coating 1.5 ------On-Road Fugitive Dust -- -- 0.10 0.014 -- -- Trucks 0.051 0.048 0.030 0.013 0.61 0.0019 Rail 1.2 36 0.58 0.54 14 0.052 Ships 4.3 55 1.5 1.4 4.0 12 Tugboats 0.37 2.4 0.095 0.095 1.8 0.0023 Total 8.1 93.4 2.3 2.0 21 12.1 SJVAPCD Thresholds 10.0 10.0 15.0 15.0 100.0 27.0 Exceeds Significance? N Y N N N N Final Build-Out Architectural Coating 2.8 ------On-Road Fugitive Dust -- -- 0.13 0.019 -- --

Denmar Addendum to the WCDP EIR 56 April 2021

ROG NOx PM10 PM2.5 CO SOx Trucks 0.059 0.051 0.041 0.017 0.7 0.0024 Rail 1.5 43 0.68 0.63 21 0.076 Ships 6.3 80 2.2 2.0 5.8 18 Tugboats 0.55 3.6 0.14 0.14 2.6 0.0033 Total 12 127 3.1 2.8 30 18.1 SJVAPCD Thresholds 10.0 10.0 15.0 15.0 100.0 27.0 Exceeds Significance? Y Y N N N N

Permitted stationary sources would be less than SJVAPCD significance thresholds for all pollutants for all years, as summarized in Table 10.

Table 10 Operational Emissions, Permitted Sources (tons per year)

ROG NOx PM10 PM2.5 CO SOx Phase 1 Ship Loading -- -- 3.0 0.70 -- -- Dust Collectors -- -- 3.6 1.4 -- -- Total 0.0 0 6.6 2.1 0 0 SJVAPCD Thresholds 10.0 10.0 15.0 15.0 100.0 27.0 Exceeds Significance? N N N N N N Final Build-Out Ship Loading -- -- 6.1 1.4 -- -- Dust Collectors -- -- 4.8 1.8 -- -- Total 0 0 10.9 3.2 0 0 SJVAPCD Thresholds 10.0 10.0 15.0 15.0 100.0 27.0 Exceeds Significance? N N N N N N

Table 11 presents the total emissions from operation of the Denmar terminal and full build-out of the WCDP for comparison. As shown in Table 11, the emissions from operation of the Denmar terminal would be less than the total emissions identified in the WCDP EIR.

Denmar Addendum to the WCDP EIR 57 April 2021

Table 11 Comparison of Operational Emissions of West Complex Development Plan and Denmar Terminal (tons per year)

ROG NOx PM Full Build-out of WCDP 39.1 391 33.6 Full Build-out of Denmar Terminal 11.2 126.7 14.1

Consistent with the WCDP EIR, the following mitigation measures would be applicable to the Proposed Project: • Mitigation Measure 4.3.1 – Implement Feasible Travel Demand Measures • Mitigation Measure 4.4.2b – Reduction of Emissions from Heavy-Duty Yard Equipment • Mitigation Measure 4.4.2d – Reduction in Emissions from All Off-Road Equipment

However, impacts would remain significant. While impacts would exceed significance, there would be no new or additional impacts as a result of the Proposed Project and the findings would be consistent with those described in the WCDP EIR.

3.3.5.3 Mobile emissions generated by the Proposed Project would increase CO concentrations at intersections in the area surrounding the Project Area, but not to a level exceeding the national or state standards. This is considered a less-than-significant impact. The WCDP EIR found that traffic generated by the WCDP would have a less-than-significant potential to affect CO concentrations along surface streets and near stagnation points such as major highways and heavily traveled and congested roadways.

As discussed in Sections 1.2.2 and 2.4, operations associated with the Denmar terminal would include changes to the mode mix as compared to the WCDP EIR. Operations associated with the Denmar terminal would increase rail and vessel calls, but would not include truck calls. While there would be vehicle trips associated with operations and both vehicle and truck trips associated with construction, the levels generated by the Proposed Project would be considerably less than projected by the WCDP EIR, as detailed in Sections 3.2.5.1 and 3.2.5.1. Therefore, there would be no new or additional impacts as a result of the Proposed Project and the findings would be the same as those described in the WCDP EIR.

3.3.5.4 Implementation of the Proposed Project could result in exposure of nearby sensitive receptors to certain toxic air contaminants from various stationary and mobile sources. The WCDP EIR found that development would expose nearby sensitive receptors to TAC emissions, including diesel particulate matter, but not to levels considered significant for either construction or

Denmar Addendum to the WCDP EIR 58 April 2021

operation. The health risk assessment (HRA) found that operation consistent with full build-out of the West Complex would result in an increased cancer risk of 8.3 in 1 million.

As discussed in Sections 3.3.5.1 and 3.3.5.2, construction emissions were not quantified or modeled in the WCDP EIR. In addition, operations associated with the Denmar terminal would include changes to the mode mix as compared to the WCDP EIR. To determine whether the proposed changes would increase the potential for health risks, an HRA was completed for the Proposed Project (Appendix B).

As detailed in Appendix B, operation of the Denmar terminal would result in an increased cancer risk of 19 in 1 million, which would be less than the 20 in 1 million risk threshold, as modified by the SJVAPCD in 2015. Chronic impacts were found to be 0.014, which is less than the SJVAPCD threshold of 1. The maximum risk exposure period is the first year of operation, which overlaps with construction. Therefore, impacts are considered less than significant; however, overall health risks have increased as compared to those presented in the WCDP EIR.

In 2015, the Office of Environmental Health Hazard Assessment (OEHHA) released a Revised Risk Assessment Guidelines document (OEHHA 2015). This document introduced more conservative exposure parameters for receptors, updating health effects values and exposure pathway variates (e.g., breathing rates), and continuing to use a tiered approach for performing HRAs based on current science and policy assessment. In response, SJVAPCD released a Notice of Exemption on June 4, 2015, that stated, "the update incorporates District Governing Board direction to implement the revisions to OEHHA's risk assessment guidelines without relaxing current health protections, while also preventing unreasonable restrictions on permitting" (SJVAPCD 2015c, 2015d). SJVAPCD recognized the conservative nature of the revised OEHHA guidance, and increased their cancer risk significance threshold from 10 in a million to 20 in a million to account for the expected increase in calculated cancer risk. The expected increase in calculated cancer risk would not be because of any project-related inputs, but rather the exposure parameter inputs, over which the project has no control. As a result, cancer risk estimates that were calculated prior to the 2015 OEHHA Revised Risk Assessment Guidance Document (OEHHA 2015) should not be directly compared to cancer risk estimates calculated after the revised guidance was published.

3.4 Noise Proposed WCDP EIR Project-Related Significance Threshold Findings Findings Construction-related activities associated with Less-than- Less-than- the Proposed Project would temporarily and a. Significant Impact Significant Impact intermittently increase noise levels at nearby with Mitigation with Mitigation sensitive receptor locations.

Denmar Addendum to the WCDP EIR 59 April 2021

Proposed WCDP EIR Project-Related Significance Threshold Findings Findings Operation of the Proposed Project would Significant and Significant and generate increased ambient noise levels and b. Unavoidable Unavoidable affect the noise environment of nearby sensitive Impact Impact land uses. Project operations would generate increased Significant and Significant and traffic on roads leading to the Project Area and c. Unavoidable Unavoidable would affect noise levels of sensitive receptors on Impact Impact some of the heavily traveled roads. Project operations would generate increased Significant and Significant and d. levels of low-frequency noise that would likely Unavoidable Unavoidable produce vibrations in lightweight structures. Impact Impact

3.4.1 Environmental Setting The WCDP EIR provided a framework for considering the effects from noise associated with the Proposed Project, including construction equipment used during remediation and construction of the Denmar terminal, and equipment and activities related to the Denmar terminal’s operations. The noise setting of the Port and its environs are described in the WCDP EIR (Section 4.5 of the DEIR and Section 4.5 of the Final EIR) and were updated as part of a noise study completed for the Proposed Project (Appendix C).

Existing noise in the project area can be attributed to various stationary and mobile sources, including ship traffic, tractor-trailer truck traffic, rail activity, and terminal equipment. Other sources that contribute to the existing noise environment in the general site vicinity include recreational boating along the San Joaquin River (reduced during fall and winter months), landscaping activities (e.g., leaf blowing and lawn mowing), and local and regional roadway traffic on nearby local roads and highways (i.e., I-5, SR-4, and SR-99). Noise monitoring previously conducted for the WCDP EIR concluded that the equivalent continuous noise level (Leq) on Rough and Ready Island generally ranges between 60 and 84 decibels (A-weighted; dBA), with higher levels from short-term increases in noise levels 85 dBA or higher.

3.4.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• Noise Limits for Heavy-Duty Trucks. Federal regulations establish noise limits for medium and heavy trucks (more than 4.5 tons, gross vehicle weight rating) under 40 Code of Federal Regulations (CFR), Part 205, Subpart B. These controls are implemented through regulatory controls on truck manufacturers.

Denmar Addendum to the WCDP EIR 60 April 2021

• General Plan Guidelines. The City has developed community noise control regulations and standards which are consistent with or exceed the guidelines of the State Office of Noise Control and the standards adopted by the Federal Highway Administration, Caltrans, and other government and regulatory agencies (City Municipal Code Title 16, Division 3, Chapter 16.60). Regarding construction, the City prohibits “operating or causing the operation of tools or equipment on private property used in alteration, construction, demolition, drilling, or repair work between the hours of 10:00 PM and 7:00 AM, so that the sound creates a noise disturbance across a residential property line, except for emergency work of public service utilities.” State law requires general plans to use the community noise equivalent level (CNEL)

or the day/night average sound level (Ldn) to describe the community noise environment (in dBA) and its effects on the population.

The City’s General Plan was updated in 2018; the following changes pertain to noise. The City’s 2040 General Plan (City 2018) establishes goals, policies, and criteria for determining land use compatibility with major noise sources within the community. The 2040 General Plan includes Policy SAF-2.5, which protects the community from health hazards and annoyance associated with excessive noise levels. Policy SAF-2.5 includes the following standards: ‒ Action SAF-2.5A: Prohibit new commercial, industrial, or other noise-generating land uses adjacent to existing sensitive noise receptors, such as residential uses, schools, health care facilities, libraries, and churches, if noise levels are expected to exceed 70 dBA CNEL when measured at the property line of the noise-sensitive land use. ‒ Action SAF-2.5B: Require projects that would locate noise-sensitive land uses where the projected ambient noise level is greater than the "normally acceptable" noise levels listed in Table 5-1 (included below as Table 12) to conduct an acoustical analysis. (As noted in Table 5-1 of the 2040 General Plan, if existing noise standards are exceeded, a proposed project shall not incrementally increase noise levels by more than 3 dBA.) ‒ Action SAF-2.5C: Require noise produced by commercial uses to not exceed 75 dBA

Ldn/CNEL at the nearest property line. ‒ Action SAF-2.5D: Grant exceptions to the noise standards for commercial and industrial uses only if a recorded noise easement is conveyed by the affected property owners. ‒ Action SAF-2.5E: Require all new habitable structures to be set back from railroad tracks to protect residents from noise, vibration, and safety impacts.

Denmar Addendum to the WCDP EIR 61 April 2021

Table 12 Maximum Allowable Noise Exposure by Land Use Per City of Stockton 2040 General Plan (Ldn)

Noise Level, Ldn (dBA) Land Use 0-55 56-60 61-65 66-70 71-75 75-80 >81 Residential Urban Residential Infill Hotels, Motels

Schools, Libraries, Churches, Hospitals, Extended Care Facility Auditoriums, Concert Halls, Amphitheaters Sports Arenas, Outdoor Spectator Sports Playgrounds, Neighborhood Parks

Golf Courses, Riding Stables, Water Recreation, Cemeteries

Office Buildings, Business Commercial and Professional

Mining, Industrial, Manufacturing, Utilities, Agriculture Notes: Source: City 2018 Normally Acceptable Conditionally Acceptable Unacceptable

Additional regulations, plans, and policies applicable to the Proposed Project and pertaining to noise include the following:

• Occupational Safety and Health Administration Regulations (29 CFR 1910.95). The Occupational Safety and Health Administration (OSHA) has established acceptable occupational noise exposure levels. These regulations state that employees shall not be exposed to occupational noise levels greater than 90 dB without adequate hearing protection. If occupational noise levels exceed 85 dB, the employer must establish a hearing conservation program as described under 29 CFR 1910.95(c–o). For occupational noise exposure levels greater than 90 dB, the daily period of noise exposure must be decreased from 8 hours, as described under 29 CFR 1910.95(b). • State of California General Plan Guidelines. Published by OPR, the guidelines provide guidance for the acceptability of projects within areas that are exposed to specific noise levels. For areas zoned for industrial, manufacturing, utilities, and agricultural land uses, the normally acceptable level of community noise exposure is less than 75 dBA CNEL with 70 to 80 dBA CNEL considered conditionally acceptable (OPR 2017).

Denmar Addendum to the WCDP EIR 62 April 2021

• Groundborne Vibration. For the protection of fragile, historic, and residential structures from groundborne vibration, Caltrans recommends a threshold of 0.2 inch per second peak particle velocity (PPV) for normal residential buildings and 0.08 inch per second PPV for old or historically significant structures (Caltrans 2020b).

3.4.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.5.1a – Limit Construction Activities to Between 7:00am and 7:00pm • Mitigation Measure 4.5.1b – Minimize Construction Equipment Noise • Mitigation Measure 4.5.1c – Position Staging Areas Furthest from Residences • Mitigation Measure 4.5.2a – Direct Ships to Berths Furthest Away from Sensitive Receptor Locations • Mitigation Measure 4.5.2b – Implement Noise-Reducing Treatments at Sensitive Receptor Locations • Mitigation Measure 4.5.2c – Baffle Stationary Land-based Generators

Details on these mitigation measures can be found in Appendix A.

3.4.4 Methods/Approach The WCDP EIR addressed the construction-phase noise impacts based on possible infrastructure improvements and potential future operational noise using typical construction equipment noise levels and vehicular traffic to estimate corresponding noise levels at the nearest sensitive receptor locations. Long-term noise measurements were conducted at various locations to estimate baseline noise conditions within the West Complex and surrounding areas in October 2002. The WCDP EIR established noise criteria based on changes in ambient noise levels and construction noise associated with implementation of the WCDP. Significant ambient noise level increases were defined as 3 dBA for land uses that already exceed the “normally acceptable” ranges, 5 dBA for land uses that are within “normally acceptable” ranges but would exceed these ranges with additional project noise, and 10 dBA for land uses that would remain within the “normally acceptable” range of noise.

Construction noise was considered significant if it would exceed 65 dBA Lmax at the property line of nearest residence between 9 PM and 6 AM.

The WCDP EIR recognized the presence of sensitive receptors and used the following upper limits of the “normally acceptable” range for daytime (7:00 AM to 7:00 PM) in determining the significance of noise impacts:

• Residential: 60 dBA Ldn/CNEL (45 dBA Ldn/CNEL interior)

• Neighborhood Parks: 70 dBA Ldn/CNEL

Denmar Addendum to the WCDP EIR 63 April 2021

• Golf Courses: 75 dBA Ldn/CNEL

To determine whether the Proposed Project would result in similar findings as those described in the WCDP EIR, a noise study was completed and is included as Appendix C. To document the current conditions at the closest noise-sensitive receptors to the Proposed Project, a noise measurement survey was conducted in in the vicinity of the residential and recreational uses opposite from the project site along the northeastern bank of the San Joaquin River. The existing noise levels within these residential and recreational areas result from ship traffic, operations associated with current Port activities, recreational boating along the San Joaquin River, parkland and landscaping activities, and local roadway traffic.

3.4.5 Impact Assessment

3.4.5.1 Construction-related activities associated with the Proposed Project would temporarily and intermittently increase noise levels at nearby sensitive receptor locations. The WCDP EIR assumed that WCDP implementation would include construction commensurate with full build-out of the West Complex. The WCDP EIR assumed that construction activities would involve excavation, grading, and construction of foundations and structures, as well as construction vehicle travel to and from Rough and Ready Island. It was assumed that pile-driving activities would not occur along the berths, but that a limited amount of pile driving could be associated with construction-related activities occurring within the central portion of the island. The WCDP EIR found that construction-related noise would be significant and implementation of mitigation as identified in Appendix A, including limiting construction activities to between 7:00 AM and 7:00 PM, minimizing construction noise, and positioning staging areas away from residences, were required to reduce impacts to less-than-significant levels.

Remediation and construction of the Denmar terminal would require excavation, grading, and construction of foundations and structures, as well as construction vehicle travel to and from the site consistent with the WCDP EIR. As detailed in Appendix C, remedial activities and terminal construction would occur over approximately 4 years and would result in an increase in noise levels on the project site and surrounding areas during this period. The closest construction and remediation areas would be 600 and 2,500 feet, respectively, from the closest noise-sensitive uses. These distances and the type, quantity, and usage factors of the proposed construction equipment for the remediation and construction phases were input into the Federal Highway Administration Roadway Construction Noise Model (RCNM). The RCNM model provides a means to determine composite noise levels from multiple construction noise sources. To conduct a conservative analysis of construction and remediation noise at the sensitive uses on the north side of the San Joaquin River, construction was assumed to occur at the closest distances to these noise-sensitive uses (between 550 and 2,900 feet depending on the

Denmar Addendum to the WCDP EIR 64 April 2021

remediation and construction phase elements). The results of modeling indicate that noise levels at the closest noise-sensitive receptors to the remediation and construction activities would be less than 55 dBA Leq and 75 dBA Lmax. These levels are less than the daytime limits in the City’s General Plan and Noise Ordinance limits and the significance levels outlined in the WCDP EIR for residential areas. However, if construction were to occur at night, the resulting maximum noise levels could exceed the WCDP EIR nighttime significance criteria and the average or maximum nighttime Noise Ordinance limits at these nearest sensitive receptors.

Consistent with the WCDP EIR, the following mitigation measures would be implemented as part of the Proposed Project: • Mitigation Measure 4.5.1.a – Limit Construction Activities to Between 7:00am and 7:00pm • Mitigation Measure 4.5.1b – Minimize Construction Equipment Noise • Mitigation Measure 4.5.1c – Position Staging Areas Furthest from Residences

Incorporation of these mitigation measures would ensure noise levels would not be exceeded at night, consistent with the findings of the WCDP EIR. Therefore, there would be no new or additional impacts as a result of the Proposed Project and the findings would be consistent with those described in the WCDP EIR.

3.4.5.2 Operation of the Proposed Project would generate increased ambient noise levels and affect the noise environment of nearby sensitive land uses. The WCDP EIR found that noise levels associated with Port operations at the West Complex would increase and assumed that future land uses, including a combination of industrial, commercial, manufacturing, maritime, and break-bulk land uses, would incrementally add to the existing ambient noise environment. As part of the analysis, detailed noise modeling was performed assuming a mixture of Port uses on the backlands from operations, noises associated with truck and rail trips, and noise associated with ship calls. Depending on the locations and intensity of stationary source noise from new industrial land uses at the West Complex, the WCDP EIR found that operations in the West Complex could have significant impacts on noise-sensitive residential land uses across the river from Rough and Ready Island. Less-sensitive land uses, including a park and golf course on the north side of the San Joaquin River, were also considered. These impacts were considered significant and implementation of mitigation as identified in Appendix A, including directing ships to berths furthest away from sensitive receptor, implementing noise-reducing treatments at sensitive receptor locations, and baffling stationary land-based generators were required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation.

Operation of the Denmar terminal would require ship calls and berth operations consistent with those evaluated in the WCDP EIR. However, the Denmar terminal would also include rail operations

Denmar Addendum to the WCDP EIR 65 April 2021

in the western corner of the West Complex, which was not specifically considered in the WCDP EIR. Therefore, noise modeling was performed for the Proposed Project.

Consistent with the WCDP EIR, the following mitigation measures would be implemented as part of the Proposed Project: • Mitigation Measure 4.5.2a – Direct Ships to Berths Furthest Away from Sensitive Receptor Locations • Mitigation Measure 4.5.2b – Implement Noise-Reducing Treatments at Sensitive Receptor Locations • Mitigation Measure 4.5.2c – Baffle Stationary Land-based Generators

As detailed in Appendix C, operational noise generated by the Proposed Project can be broken down into the following categories:

• On-site rail noise: noise generated by unit train operations accessing the Denmar terminal via the rail loop • Material offloading noise: noise emitted during railcar unloading and from use of vibratory railcar shakers • Material transfer noise: noise generated during material transfers via the conveyor system from the railcar unloading building to the material storage building and ship loaders • Ship loading and operations noise: noise generated from ship activities, including loading and unloading

The noise analysis considered the resulting noise levels from each of these activities, how they compare to the significance findings presented in the WCDP EIR, and how they compare to the City’s General Plan and Noise Ordinance limits. The following paragraphs summarize the findings detailed in Appendix C.

On-Site Rail Noise. The closest rail tracks would be 2,500 feet or more from the noise-sensitive uses on the north side of the San Joaquin River. Freight train engines can produce maximum noise levels of up to 85 dBA at 100 feet from the track centerlines, resulting in an hourly average level of 66 to 72 dBA at 100 feet from the track centerline, depending on the number of cars and locomotives per train. At a distance of 2,500 feet, the average noise levels would be less than 45 dBA and maximum noise levels would be less than 60 dBA. With one or possibly two trains per day delivering soda ash, the resulting average daily noise level would be less than 45 dBA Ldn/CNEL at the closest noise- sensitive uses on the north side of the San Joaquin River.

Material Offloading Noise. The railcar unloading building would be located 2,900 feet or more from the noise-sensitive uses on the north side of the San Joaquin River. Though the actual noise levels produced during railcar unloading is unknown, measurements of the offloading of a heavier

Denmar Addendum to the WCDP EIR 66 April 2021

material (1-inch rock aggregate) into a hopper produced an average sound level of 76 dBA Leq at 145 feet. Considering only a minimal building sound attenuation factor of 6 dBA and distance attenuation with no other intervening barriers, the noise study found that the offloading of this heavier and inherently much louder material would be less than 45 dBA Leq at the closest noise- sensitive receptors. Based on this very conservative analysis, the average daily noise level due to railcar unloading would be less than 45 dBA Leq. With one or possibly two trains per day delivering soda ash, the resulting average daily noise level due to material offloading would be less than

50 dBA Ldn/CNEL at the closest noise-sensitive uses on the north side of the San Joaquin River.

Material Transfer Noise. The conveyors and storage buildings would be located 700 feet from the Stockton Golf and Country Club and about 1,400 feet from the closest residential use on the north side of the San Joaquin River. Considering these distances and distance attenuation only, the fans associated with the dust collection system could produce levels of up to 48 dBA at the Stockton Golf and Country Club and up to 42 dBA at the residential use opposite the San Joaquin River.

Shiploading Noise. When a vessel arrives at Berth 18 (Phase 1) or at either Berths 18 or 19 (Phase 2), soda ash would travel on the enclosed outbound conveyors on the east end of either storage building to the tower near the berths, to the final enclosed conveyor, and be transferred onto the ships at either Berths 18 or 19 via shiploaders. Each shiploader would be able to be moved along each berth, capable of a range of motion enabling them to reach all of the holds on a ship and equipped with dust minimization and containment and collection features. Though the noise generated by this operation is unknown, based on measurements of gantry crane movement operations, which are judged to be similar to shiploader operations, shiploading is expected to produce maximum noise levels of 72 to 73 dBA at 50 feet. Shiploading activities would occur as close as 600 feet from the Stockton Golf and Country Club and about 1,200 feet from the closest residential use on the north side of the San Joaquin River. Considering these distances and distance attenuation only, shiploading noise could produce maximum levels of up to 51 dBA at the Stockton Golf and Country Club and up to 46 dBA at the residential use on the north side of the San Joaquin River.

Ship Operational Noise. The WCDP EIR contained a discussion and analysis of the noise produced by ships in port on residences on the north side of the San Joaquin River. This analysis, which used measurements of noise from the operations of several ships in port, found that the typical measured sound level produced by a ship in port, along with related operations was about 61 dBA at distance 150 yards from the ship, which is the distance ships at Berths 18 and 19 would be located from the Stockton Golf and Country Club. Ships at Berths 18 and 19 would be about 1,000 feet from the closest residential use on the north side of the San Joaquin River. Assuming constant operation

24 hours per day, this corresponds to a sound level of about 67 dBA Ldn/CNEL at the Country Club and 60 dBA Ldn/CNEL at the closest residences.

Denmar Addendum to the WCDP EIR 67 April 2021

Based on the above discussions, project operations would comply with the City’s General Plan and Noise Ordinance and be consistent with the findings of the WCDP EIR. Therefore, there would be no new or additional impacts as a result of the Proposed Project.

3.4.5.3 Project operations would contribute to increased traffic on roads leading to the Project Area and would affect noise levels of sensitive receptors on some of the heavily traveled roads. The WCDP EIR found that traffic-related noise along roadways leading to the West Complex would increase noise levels to the extent that they could affect sensitive receptors. These impacts were considered significant and implementation of mitigation as identified in Appendix A, including building a sound wall and implementing additional noise-reducing measures at sensitive receptor locations impacted by trucks, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation.

Because the Proposed Project would not include operations resulting in new truck trips, it would not contribute to such noise levels. Therefore, there would be no new or additional impacts as a result of the Proposed Project and the findings would be less than those described in the WCDP EIR.

3.4.5.4 Project operations would generate increased levels of low-frequency noise that would likely produce vibrations in lightweight structures. As discussed in Section 2.1.4.2, the levels of low-frequency noise and infrasound measured for most ships analyzed was in the range of approximately 65 to 70 dBA at residential receptors. The WCDP EIR used a significance threshold of 70 dBA at low frequencies and a change of 3 dBA. When levels of low-frequency noise or infrasound exceed 75 decibels, studies indicate that there is a high probability that noise-induced vibration in lightweight wall and ceiling construction would be clearly felt and that audible rattles in light fixtures, doors, and windows would be anticipated. While low-frequency project-related noise is not expected to exceed 75 dBA, there is a reasonable probability that increased ship activity at the Port would result in low-frequency noise exceeding 70 dBA and at least a 3-dBA increase in low-frequency noise. These impacts were considered by the WCDP EIR to be significant and implementation of mitigation as identified in Appendix A, directing ships to berths furthest away from sensitive receptors, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation.

Because the Proposed Project would include operations consistent with the levels analyzed in the WCDP EIR, impacts would also be considered significant, consistent with the WCDP EIR. The Proposed Project is designed to comply with Mitigation Measure 4.5.2a – Direct Ships to Berths Furthest Away from Sensitive Receptor Locations to minimize impacts. Operation of the Denmar terminal would require ship calls and berth operations consistent with those evaluated in the WCDP EIR. However, the Denmar terminal would also include rail operations in the western corner of the

Denmar Addendum to the WCDP EIR 68 April 2021

West Complex, which was not specifically considered in the WCDP EIR. Therefore, noise modeling, including a vibration assessment, was performed for the Proposed Project.

As detailed in Appendix C, the Federal Transit Administration (FTA) has established vibration impact assessment criteria for use in evaluating groundborne vibration impacts associated with developments in proximity to rail lines. The FTA vibration impact criteria are based on maximum overall levels for a single event. Based on measurements of rail operations, freight operations are typically considered to be limited to groundborne vibration levels of 70 to 75 dBA at 100 feet from the railroad centerline depending on ground motility (vibration transfer conditions). All vibration sensitive uses on the project site and vicinity are well beyond 100 feet from the rail lines. Therefore, groundborne vibration produced by the Proposed Project is expected to comply with FTA vibration impact criteria.

Based on the above discussions, Proposed Project rail operations are not expected to result in any groundborne or airborne vibration impacts. Proposed Project ship operations would result in airborne vibration impacts that would be consistent with those identified in the WCDP EIR. Therefore, there would be no new or additional impacts as a result of the Proposed Project and findings would be consistent with those described in the WCDP EIR.

3.5 Geology, Soils, and Seismicity Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Implementation of the Proposed Project could expose people and/or structures to potential adverse effects of seismically- Less-than-Significant Less-than- a. induced groundshaking; however local ordinances require Impact Significant Impact implementation of measures that will reduce this risk. Structures constructed under the Proposed Project could be located on expansive soils, as defined in Table 18- 1-B of the Less-than-Significant Less-than- b. Uniform Building Code (1994); however local ordinances Impact Significant Impact require implementation of measures that will reduce this risk. Throughout implementation of the Proposed Project, new and existing structures and the perimeter levee could be Less-than-Significant Less-than- subjected to geologic hazards, including liquefaction, c. Impact with Significant Impact differential settlement, and total settlement. Failure of the Mitigation with Mitigation levee could result in significant damage to properties from flooding and loss of life. Less-than-Significant Less-than- Implementation of the Proposed Project has the potential to d. Impact with Significant Impact result in levee bank and surface erosion. Mitigation with Mitigation

3.5.1 Environmental Setting The WCDP EIR provides a framework for considering the geology and soils effects of the Proposed Project. The geology, soils, and seismicity setting of the Port and its environs are described in the

Denmar Addendum to the WCDP EIR 69 April 2021

WCDP EIR (Section 4.6 of the DEIR) and updated in this section. The geology, soils, and seismicity setting conditions identified in the WCDP EIR remain largely applicable to the Proposed Project. New or revised data available since publication of the WCDP EIR provide updated details relevant to the Proposed Project setting, which are summarized as follows.

The latest Natural Resources Conservation Service maps identify the project site as predominantly containing the following soil map units (NRCS 2019): dumps; Egbert Mucky clay loam (partially drained, 0% to 2% slopes); Egbert-Urban land complex (partially drained, 0% to 2% slopes); and Urban Land. The characteristics for these soil map units are consistent with the description in the WCDP EIR and generally include exhibiting slow runoff and slow permeability, poor drainage, high percentage of organic materials, and a naturally high seasonal water table.

No known active faults (defined by the state of California as faults that show evidence of movement during the past 10,000 years) occur within 25 miles of the project area (Caltrans and Port 2013), and the project site is not located within a currently designated Alquist-Priolo Earthquake Fault Zone (CGS 2019). Numerous active and potentially active faults, however, are identified east and west of the project site. The closest significant earthquake fault to the City is the Greenville Fault, which is located roughly 22 miles southwest (City 2018).

The estimated likelihood of a magnitude 6.7 or greater earthquake in the greater San Francisco Bay area before 2036 is 63%. For individual faults in proximity to the project site, forecasted probabilities include 31% for the Hayward Fault, 7% for the Calaveras Fault, and 3% for the Greenville Fault (22 miles from the City; the closest earthquake fault to the project site). The project site’s significant distance from active earthquake faults would help reduce impacts related to ground shaking. For other similar industrial sites at the Port in proximity to the project site, the estimated Maximum Considered Earthquake peak ground acceleration adjusted for site class effects was determined to be 0.393g (based on both probabilistic and deterministic seismic ground motion; SEG 2018). Nonetheless, regional seismic activity could cause accelerations severe enough to cause major damage to structures and foundations not designed to resist the forces generated by earthquakes. Underground utility lines are also susceptible where they lack sufficient flexibility to accommodate the seismic ground motion (City 2018).

The California Geological Survey (CGS) and U.S. Geological Survey (USGS) have not mapped any seismically-induced liquefaction hazard zones at the project site or within the City (City 2018). However, as described in the WCDP EIR, the possibility of soil liquefaction exists within the West Complex and should be considered when planning and designing levees and structures in areas of potential liquefaction, as would be identified in subsequent geotechnical investigations.

Expansive soils are high in clay content and increase and decrease in volume upon wetting and drying, respectively. The change in volume exerts stress on buildings and other loads placed on these

Denmar Addendum to the WCDP EIR 70 April 2021

soils. Expansive soils are common throughout California and can cause damage to foundations and slabs unless properly treated during construction. Grading, site preparations, and backfill operations associated with subsurface structures can often eliminate the potential for expansion. The Natural Resources Conservation Service (NRCS) identifies the eastern portion of the project site as containing expansive soils (County GIS 1999), and expansive materials could be encountered in portions of the project site mapped as containing Egbert mucky clay loam (NRCS 2019).

The WCDP EIR identifies the transition zone between urban land and artificial fill occurring in the northeastern portion of Rough and Ready Island as an area likely to experience differential settlement. These conditions are consistent with the most recent NRCS soil maps (NRCS 2019). Although the WCDP EIR describes Rough and Ready Island as unlikely to suffer the direct effects of regional subsidence, potentially expansive soils noted in NRCS maps (County GIS 1999; NRCS 2019) within the project site may be susceptible to subsidence.

The erosion, landslide, and slope failure conditions identified in the WCDP EIR largely remain relevant to the Proposed Project. Consistent with the WCDP EIR description, the project area is essentially level and slope failure is not considered a substantial limitation to development. The project site remains surrounded by a perimeter levee which the WCDP EIR identifies as potentially susceptible to erosion. Since publication of the WCDP EIR, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring of the West Complex levees, including those in the northwestern portion of Rough and Ready Island. Shoreline areas, such as those in the vicinity of Berths 18 and 19, may also be susceptible to water-induced erosion.

3.5.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• Alquist-Priolo Geologic Hazards Zone Act. The Alquist-Priolo Earthquake Fault Zoning Act as described in the WCDP EIR remains applicable to the Proposed Project. The project site is not traversed by or in proximity to any USGS mapped quaternary faults or any CGS mapped regulatory zones (fault rupture, soil liquefaction, or earthquake landslides). This includes faults and regulatory zones identified since publication of the WCDP EIR (USGS 2020; CGS 2019). • Seismic Hazards Mapping Act. The Seismic Hazards Mapping Act, described in the WCDP EIR, remains applicable to the Proposed Project. The project site remains outside of any mapped seismic hazard areas, including any CGS mapped regulatory zones (CGS 2019). • California Uniform Building Code. The California Uniform Building Code or California Building Code as described in the WCDP EIR remains applicable to the Proposed Project. New editions of the California Building Standards Code are published every 3 years with supplemental information published during other years. This includes revisions to seismic

Denmar Addendum to the WCDP EIR 71 April 2021

hazard standards. These California Uniform Building Code revisions do not substantively change the analysis provided in the WCDP EIR. • City of Stockton General Plan. The WCDP EIR identifies safety goals and policies from the 1990 City of Stockton General Plan, which have since been updated or replaced within policies from the 2040 General Plan (City 2018). New or updated policies relevant to geology, soils, and seismicity include the following: ‒ Policy SAF-2.1: Ensure that community members are adequately prepared for natural disasters and emergencies through education and training. ‒ Policy SAF-2.2: Prepare sufficiently for major events to enable quick and effective response.

These revisions do not substantively affect the applicability of geology, soils, and seismicity impact analyses from the WCDP EIR. Additional regulations, plans, and policies applicable to the Proposed Project and pertaining to geology and soils include the following:

• Stockton Municipal Code. City Municipal Code Section 15.48.050, “Construction and Application,” includes a requirement that seeks to mitigate hazards associated with erosion: “During construction, construction activities shall be designed and conducted to minimize runoff of sediment and all other pollutants onto public properties, other private properties and into the waters of the United States.” Section 15.48.110, “Erosion Control Requirements,” contains specific provisions for erosion control for those construction projects where a grading permit is not required. Section 15.48.070 includes requirements for a grading permit that apply to most construction projects. Such permits require implementation of erosion control measures, often referred to as BMPs.

3.5.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.7.1 – Require Erosion and Sediment Control BMPs for All Construction Activities • Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures

Details on these mitigation measures can be found in Appendix A.

3.5.4 Methods/Approach Impacts to or associated with geological, soil, and seismic conditions were qualitatively evaluated based on the potential for the Proposed Project to temporarily or permanently alter the geology of the project area. In addition, because geological hazards such as earthquakes happen independently of the Proposed Project, the potential for damage to proposed structures or increased risk of injury due to geologic and seismic hazards were also qualitatively evaluated. The measurement index for

Denmar Addendum to the WCDP EIR 72 April 2021

evaluating impacts associated with geology, soils, or seismicity is risk to the public or the environment from geologic processes. Relevant findings from the WCDP EIR pertaining to geology and soils are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.5.5 Impact Assessment

3.5.5.1 Implementation of the Proposed Project could expose people and/or structures to potential adverse effects of seismically-induced groundshaking; however local ordinances require implementation of measures that will reduce this risk. The WCDP EIR concluded that the West Complex is potentially susceptible to ground shaking, liquefaction, differential settlement, and other seismic related hazards. Potentially expansive soils were identified as occurring within the central portion of Rough and Ready Island, including within the project area. Potential impacts associated with these hazards were determined to be less than significant when considering California Building Code seismic requirements; General Plan policies, including future revisions; City ordinances requiring site-specific geotechnical investigations for construction projects; and implementation of recommendations from required geotechnical investigations.

Most of the project site lacks steep slopes that would be potentially susceptible to slope failure or landslide hazards, with the possible exception of the shoreline at Berths 18 and 19 and the Rough and Ready Island perimeter levee. The Rough and Ready Island perimeter levee geologic and soil conditions would be unaffected by the Proposed Project, and levee failure hazards are comprehensively addressed in the WCDP EIR (Section 3.5.5.3). In addition, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring of the West Complex levees. Proposed Project-related improvements may also be susceptible to seismic hazards, and would be subject to the same regulations and policies pertaining to seismic hazards and soil conditions as the WCDP, including compliance with updated or revised policies, such as the 2040 General Plan and California Building Code revisions. These measures would apply to all of the Denmar terminal structures, including the taller storage buildings described in Section 2.

The Proposed Project would include ground improvements to address potential susceptibility of new structures to seismic liquefaction, kinematic loading, and settlement and geotechnical investigations are ongoing. Ground improvements are anticipated to include a combination of DSM (in situ mixing of the existing native soils with a cement slurry to create interconnected soil-cement columns), stone columns, ground anchors, or equivalent design and construction elements.

Denmar Addendum to the WCDP EIR 73 April 2021

The project area is not located within a currently designated Alquist-Priolo Earthquake Fault Zone, and no known surface expression of active faults is believed to cross the project site (USGS 2020); therefore, fault rupture through the site is not anticipated. The Proposed Project would have no effect related to septic tanks or alternative wastewater disposal because these systems are not proposed.

Based on the analysis presented above, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.5.5.2 Structures constructed under the Proposed Project could be located on expansive soils, as defined in Table 18- 1-B of the Uniform Building Code (1994); however local ordinances require implementation of measures that will reduce this risk. Potential impacts associated with expansive soils identified in the WCDP EIR are described in Section 3.5.5.1. Impacts were found to be less than significant.

The Proposed Project would be subject to the same regulations and policies pertaining to soil conditions as the WCDP, including compliance with updated or revised policies, such as the 2040 General Plan and California Building Code revisions. These measures would apply to all of the Denmar terminal structures, including the taller storage buildings described in Section 2. The Proposed Project includes specific design and construction methods to address seismic hazards. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.5.5.3 Throughout implementation of the Proposed Project, new and existing structures and the perimeter levee could be subjected to geologic hazards, including liquefaction, differential settlement, and total settlement. Failure of the levee could result in significant damage to properties from flooding and loss of life. The WCDP EIR concluded that there is a high potential for ground motion-induced liquefaction within the West Complex. Similar to ground shaking, liquefaction hazards would be partially addressed through California Building Code requirements, project-specific geotechnical investigations, and City ordinances and policies. Liquefaction also has the potential to result in levee failure and inundation of Rough and Ready Island, which was considered a potentially significant impact in the WCDP EIR. As described in the WCDP EIR, this hazard is addressed through the Port’s past implementation of required mitigation, including establishing a levee monitoring program, as described in Appendix A. In consideration of this program being in place, impacts would be reduced to less-than-significant levels.

The Denmar terminal may also be susceptible to geologic hazards, and would be subject to the same regulations and policies pertaining to geologic hazards as the WCDP. As described in Section 3.5.5.1,

Denmar Addendum to the WCDP EIR 74 April 2021

the Proposed Project includes design and construction methods specifically addressing potential susceptibility of new structures to liquefaction, which would be modified as needed to address subsequent geotechnical investigations and consultations. Because the Proposed Project would not affect West Complex levees, it would not present additional risks to the levees. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.5.5.4 Implementation of the Proposed Project has the potential to result in levee bank and surface erosion. The WCDP EIR concluded that construction activities involving soil disturbance, excavation, cutting/filling, and grading activities could result in increased erosion and sedimentation to surface waters. Surface erosion impacts would be partially addressed through compliance with the City’s stormwater management requirements and BMPs for the reduction of pollutants in runoff, as well as National Pollutant Discharge Elimination System (NPDES) Construction General Permit requirements. The WCDP EIR additionally considered the effects of ship wake on the shoreline, and concluded that increased tugboat traffic could erode the levees along the northwest portion of Rough and Ready Island. Impacts were considered significant, and implementation of mitigation as identified in Appendix A, including specific levee monitoring considerations, implementing erosion, sediment control, and stormwater quality measures, street sweeping, and implementing spill control and countermeasures plans, was required to reduce impacts to less-than-significant levels.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR, and therefore could also result in erosion and sedimentation to surface waters. A NPDES Construction General Permit would be required and obtained for the Proposed Project. Consistent with the findings of the WCDP EIR, the Port would require implementation of Mitigation Measure 4.7.1 – Require Erosion and Sediment Control BMPs for All Construction Activities and Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures as part of project approval. In consideration of these requirements, the Proposed Project includes implementing standard BMPs pertaining to erosion, spills, and water quality, as detailed in Section 2.3.5. These mitigation measures and BMPs would also ensure compliance with City Municipal Code Section 15.48.050. Topsoil that would be removed during grading, other surface preparation, or remediation does not serve agricultural purposes or other valuable functions. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 75 April 2021

3.6 Hydrology and Water Quality Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Water Quality – Construction of the project facilities could result in increased erosion and sedimentation, with Less-than-Significant Less-than- subsequent impacts to water quality and/or storm drain a. Impact with Significant Impact capacity during construction. Additionally, release of fuels or Mitigation with Mitigation other hazardous materials associated with construction equipment could impact water quality. Drainage – Development of the project site could increase drainage flows as a result of the introduction of increased Less-than-Significant Less-than- amounts of impervious surfaces, which could exceed the b. Impact with Significant Impact capacity of on-site drainage systems, create localized Mitigation with Mitigation flooding, or contribute to a cumulative flooding impact downstream. Water Quality – The Proposed Project could increase both Less-than-Significant Less-than- c. non-storm and stormwater runoff, transporting contaminants Impact with Significant Impact to adjacent receiving waters. Mitigation with Mitigation Water Quality – As discussed in Section 4.12, Public Services and Utilities, the wastewater conveyance system on the Less-than-Significant Less-than- project site is known to suffer from an inflow and infiltration d. Impact with Significant Impact (I&I) problem. This could result in sewage leaks reaching Mitigation with Mitigation groundwater and/or surface waters, potentially impairing beneficial uses and violating water quality standards. Water Quality – The Proposed Project has the potential to increase the trade of bulk materials that may increase the Less-than-Significant Less-than- likelihood of contaminated runoff during wet weather events. e. Impact with Significant Impact In addition, fuel spills, releases of hazardous materials, and Mitigation with Mitigation other contaminant-laden runoff generated in the warehouse and dock area could result in impacts to water quality. Water Quality – The Proposed Project will lead to increases in the frequency and number of ships traveling in the DWSC. Ship traffic has been shown to resuspend sediment in the Less-than-Significant Less-than- f. water column, leading to decreases in water quality. Impacts Impact with Significant Impact to dissolved oxygen in the DWSC are of particular concern Mitigation with Mitigation due to a pre-existing impairment for this constituent in this waterbody. Water Quality – The wakes created by the additional ship Less-than-Significant Less-than- traffic associated with the Proposed Project could lead to g. Impact with Significant Impact increased rates of bank erosion, with subsequent impacts to Mitigation with Mitigation water quality. Groundwater – As discussed in Section 4.12, Public Services and Utilities, at build-out, the Proposed Project is anticipated generate a domestic water demand impact of approximately Less-than-Significant Less-than- h. 1633 AF/year. Because the water supplier, Cal Water, relies on Impact with Significant Impact groundwater to support demand, this water demand has Mitigation with Mitigation potential to substantially deplete groundwater supplies in a basin that is already in overdraft.

Denmar Addendum to the WCDP EIR 76 April 2021

Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Flooding – The Project Area is protected from 100-year flood events by levees. Although the levees currently provide adequate protection within the Project Area from a 100-year Less-than-Significant Less-than- flood event, flood hazards in the long term could result from i. Impact with Significant Impact inadequate levee maintenance, rising sea level, and regional Mitigation with Mitigation land subsidence. This could potentially lead to flooding of project facilities, causing loss of property or expose people to risk of injury and/or death. Flooding – Many dams are located upstream of the project site. The Project Area could be subject to flooding if one of Less-than-Significant Less-than- j. these dams were to fail. However, the risk of flooding from Impact Significant Impact dam failure is considered very low because the likelihood of dam failure is low (City 1990). Seiche, Tsunami, or Mudflow – Tsunamis originating in the Pacific Ocean would dissipate in the San Francisco Bay, and therefore pose a negligible hazard to the project site (City 1990). Seiches, while having no occurrences in San Joaquin County in the historic record, could occur in the San Joaquin River, DWSC, or Burns Cutoff, and therefore pose a slightly higher risk to the Project Area as they could overtop levees or Less-than-Significant Less-than- k. lead to levee failure. However, because the outboard side of Impact Significant Impact the levees on the Project Area are reinforced with riprap, the risk of levee failure as a result of a seiche is considered low. Further, the risk of a seiche of sufficient magnitude to overtop the levees is low enough to be considered to be below significance thresholds. Finally, the Project Area is nearly level, with little risk of mudflow.

3.6.1 Environmental Setting The WCDP EIR provides a framework for considering the hydrology and water quality effects of the Proposed Project. The hydrology and water quality setting of the Port and its environs are described in the WCDP EIR (Section 4.7 of the DEIR) and updated in this section. The hydrology and water quality setting described in the WCDP remains substantively unchanged and applicable to the Proposed Project. However, since publication of the WCDP EIR, there have been new developments, Port plans, and new or revised environmental assessments (e.g., flood and inundation risk assessments) that pertain to hydrological conditions on Rough and Ready Island and within the project site. New or revised setting information is presented in the following sections.

3.6.1.1 Hydrology Hydrology conditions specific to the project site were documented in a 2020 jurisdictional delineation report (Anchor QEA 2020a). The project area includes approximately 65.38 acres of potentially jurisdictional waters and wetlands (60.62 acres of wetlands, 4.76 acres of waters), portions

Denmar Addendum to the WCDP EIR 77 April 2021

of which occur within the immediate footprint of the Proposed Project. Appendix D includes the 2020 jurisdictional delineation report figures depicting these potentially jurisdictional waters and wetlands. Wetlands occur on the undeveloped but disturbed western side of the project area, west of the existing industrialized and developed waterfront. Portions of the irrigation and drainage ditch system described in the WCDP EIR occur within the project area, including a drainage channel that extends east to west along the southwestern portion of the project site, and a drainage channel that extends north to south along the center portion of the project site.

Consistent with the WCDP EIR description, runoff from most of Rough and Ready Island continues to be collected in a series of culverts and ditches and conveyed to a single outfall on the western side of the island. As noted, this includes two conveyance channels within the immediate project footprint. Since publication of the WCDP EIR, there have been several development projects associated with the WCDP that have created impervious surfaces or otherwise affected the stormwater drainage system. These developments have occurred outside the footprint of the project site, and have been constructed in compliance with the Port’s Storm Water Development Standards Plan (DSP; Port 2009) as applicable to avoid significant surface water impacts.

Groundwater levels at the project site are shallow, consistent with the description provided in the WCDP EIR. While the WCDP EIR describes Rough and Ready Island as outside of any substantial groundwater recharge area, overdraft conditions have existed in the County Basin since the 1920s, although elevations have recovered and stayed relatively constant since 1999 (Port 2012).

The Federal Emergency Management Agency (FEMA) maintains an interactive online National Flood Hazard Layer viewer, which indicates the potential of flooding for various locations. The majority of the project site is located in a “Zone X Area with Reduced Flood Risk due to Levee,” which indicates an area where an accredited levee, dike, or other flood control structure has reduced the flood risk from the 1% annual chance flood. The Rough and Ready Island series of stormwater conveyance ditches and channels are within “Zone A” with a 1% annual chance of flood hazard, including the two conveyance channels within the immediate project footprint where rail, utility, or road crossings are proposed. FEMA “Zone A” mapped areas are also present on the margins of the conveyance channels and within a small area identified as a seasonal wetland near the western terminus of the conveyance channel system (Anchor QEA 2020a); portions of the proposed rail alignment and some remediation areas would be located within or abutting these features (FEMA 2009). Berths 18 and 19 are located within or above the San Joaquin River, which is within the floodway (FEMA 2009). These conditions are generally consistent with the flood hazards description provided in the WCDP EIR using lower-detail FEMA maps from 1988 (FEMA 1988a, 1988b); although the WCDP EIR identifies the site as outside of the 100-year flood hazard zone, it concedes that the area is protected by levees, identifies the presence of conveyance channels throughout the island, and also describes potential presence of seasonal wetlands.

Denmar Addendum to the WCDP EIR 78 April 2021

As described in the WCDP EIR, the project site and Rough and Ready Island remain vulnerable to flooding in the event of levee failure. However, since publication of the WCDP EIR, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring the West Complex levees, including those in the northwestern portion of the island. Upstream dam failures could cause flooding in the project area, which is within the dam inundation zone of the New Malones, San Luis, Lake McClure, Camanche, and New Hogan dams (SJCOES 2019a). California SB 92 (2017) requires emergency action plans for all dams, except those classified as “low hazard.” Tsunamis and seiches are also not considered to be significant threats in the Stockton area (City 2007).

3.6.1.2 Water Quality Surface water quality remains affected by former or current land uses on the island and in surrounding areas, including institutional (military), urban/industrial, agricultural, resource extraction, maritime commerce, and recreation. Relevant to the Proposed Project, surface waters are affected by current industrial waterfront uses on the eastern portion of the project site and former military uses on the disturbed but undeveloped western portion of the project site. As noted in Section 2, sites on the West Complex contain hazardous substances in soil and groundwater as a result of the former Navy activities (Remediation Sites), including sites in which the Navy disposed of waste (Landfill Cells), and Remedial Sites of Interest. This includes contamination within the project site, which may affect surface water quality. Plans and consultations between the Port, DTSC, and CVRWQCB to remediate these areas are ongoing, and are a component of the Proposed Project.

Waterbodies in the vicinity of the project site continue to exhibit impairment as described in the WCDP EIR, though Clean Water Act (CWA) Section 303(d) list impairments have been updated since 2004. San Joaquin River channel substrate in the project area contains mud and silt, and water quality is characterized by low dissolved oxygen levels and high water temperatures during the late summer and early fall. The Delta is a California 303(d) List Category 5 waterbody, defined as a water segment where water quality standards are not met and one or more Total Maximum Daily Load programs (TMDLs) are required but have not yet been completed. Noted pollutants in the Delta include chlordane, dichlorodiphenyltrichloroethane, dieldrin, dioxin compounds, furan compounds, invasive species, mercury, polychlorinated biphenyls (PCBs), and selenium (USEPA 2011). However, water quality monitoring and elutriate toxicity testing results from past Port maintenance dredging sediment characterization efforts have not indicated toxicity concerns (ERS 2012, 2013; Anchor QEA 2017) for sediments within the project area.

Denmar Addendum to the WCDP EIR 79 April 2021

3.6.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• Clean Water Act. The CWA, described in the WCDP EIR, remains applicable to the Proposed Project, although recent updates may affect implementation of CWA Section 404 and Section 401 regulations. On April 21, 2020, USEPA and USACE published in the Federal Register the Navigable Waters Protection Rule (the Final Rule), which took effect on June 22, 2020 (85 Federal Register 22250). The Final Rule departs from the “significant nexus” standard previously articulated in the Rapanos decision. Under the Final Rule, waters of the United States encompass “the territorial seas and traditional navigable waters; perennial and intermittent tributaries that contribute surface water flow to such waters; certain lakes, ponds, and impoundments of jurisdictional waters; and wetlands adjacent to other jurisdictional waters.” The Final Rule also specifically clarifies that waters of the United States do not include certain features such as groundwater, ephemeral features that flow only in direct response to precipitation, certain ditches, certain artificial features, and other exemptions. • Porter-Cologne Water Quality Control Act. The Porter-Cologne Water Quality Control Act remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. Under the act, the State Water Resources Control Board (SWRCB) has the ultimate authority over water rights and water quality policy in the state and nine Regional Water Quality Control Boards (RWQCBs) oversee water quality on a day-to-day basis at the regional level. The SWRCB and RWQCBs regulate all pollutant or nuisance discharges that may affect either surface water or groundwater. The study area is under the jurisdiction of CVRWQCB. Under oversight by USEPA, SWRCB and CVRWQCB are responsible for establishing regulatory standards and objectives for water quality in the Bay, developing TMDLs for impaired waterbodies, and issuing NPDES permits and Waste Discharge Requirements/401 Water Quality Certifications. • California Fish and Game Code Section 1600–1607. The California Fish and Game Code (FGC), Section 1600–1607, remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • City of Stockton General Plan. The WCDP identifies safety goals and policies from the 1990 City of Stockton General Plan, which have since been updated or replaced within policies from the 2040 General Plan (City 2018). New or updated policies relevant to hydrology and water quality include the following: ‒ Policy SAF-2.3. Protect the community from potential flood events. • Action SAF-2.3C. Require new public and private waterfront development to be oriented to waterways and provide setbacks and easements along levees and channels to provide space for levee widening, flood fighting, roadway and

Denmar Addendum to the WCDP EIR 80 April 2021

maintenance access, open space and trail amenities, and appropriate landscaping. • Action SAF-2.3D. Prepare and maintain a map of evacuation routes for major flood events. ‒ Policy SAF-2.4. Minimize risks to the community from flooding through appropriate siting and protection of structures and occupants. • Action SAF-2.4D. Consider the best available flood hazard information and mapping from regional, State, and federal agencies to inform land use and public facilities investment decisions.

Additional regulations, plans, and policies applicable to the Proposed Project and pertaining to hydrology and water quality include the following:

• Rivers and Harbors Act. The Rivers and Harbors Act of 1899 prohibits discharge of refuse matter into navigable waters or tributaries thereof of the United States without a permit. Permits are also required for any activities that excavate, fill, or alter the course, condition, or capacity of any port, harbor, channel, or other areas covered by the act. Many of these activities are additionally regulated by the CWA. • National Flood Insurance Program. The National Flood Insurance Program, administered by FEMA, requires that local governments covered by federal flood insurance pass and enforce a floodplain management ordinance that specifies minimum requirements for any construction within the 100-year flood zone. FEMA is responsible for preparing maps delineating these areas. • California Fish and Game Code. FGC 5650 prohibits discharge of harmful materials to waters of the state. It is unlawful to deposit in, permit to pass into, or place where it can pass into California waters, any petroleum, acid, coal or oil tar, lampblack, aniline, asphalt, bitumen, or residuary product of petroleum; any carbonaceous material or substance; any refuse, liquid or solid, from a refinery, gas house, tannery, distillery, chemical works, mill, or factory of any kind; any , shavings, slabs, or edgings; any factory refuse, lime, or slag; any cocculus indicus; or any substance or material deleterious to fish, plant, mammal, or bird life. FGC 5655 requires that parties responsible for polluting waters of the state pay for removal costs and environmental damages. • California Senate Bill 92. SB 92 requires dam owners to prepare emergency action plans in accordance with Federal Energy Regulatory Commission guidelines. • Port of Stockton Storm Water Development Standards Plan. The Port’s DSP establishes stormwater development standards and review process for Port tenants. The DSP covers new and substantial redevelopments of properties within three subareas to ensure compatibility with the SWRCB-issued Municipal Separate Storm Sewer System NPDES Permit. The Port’s review process under the DSP includes assessment of technical stormwater submittals from project proponents. DSP objectives also include protecting the quality of stormwater runoff

Denmar Addendum to the WCDP EIR 81 April 2021

and the receiving waters that surround the Port. This plan supersedes the Storm Drainage Study and Master Plan identified in the WCDP EIR (Port 2004).

3.6.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.7.1 – Require Erosion and Sediment Control BMPs for All Construction Activities • Mitigation Measure 4.7.5b – Cover Bulk Stockpiles During the Rainy Season • Mitigation Measure 4.7.5c – Immediately Address Releases of Hazardous Materials • Mitigation Measure 4.7.9 – Ensure a Setback from Existing Levees and Maintain Levees • Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures • Mitigation Measure 4.12.6 – Assess and Manage Potable Water Demands • Mitigation Measure 4.12.7 – Upgrade Potable Water System

Details on these mitigation measures can be found in Appendix A.

3.6.4 Methods/Approach Impacts to or associated with hydrology and water quality were qualitatively evaluated based on the potential for the Proposed Project to temporarily or permanently alter the hydrology of the project area or impact water quality. Potential damage to structures and increased risk of injury due to flood risks independent of the Proposed Project are also qualitatively assessed. Relevant findings from the WCDP EIR pertaining to hydrology and water quality are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.6.5 Impact Assessment

3.6.5.1 Water Quality – Construction of the project facilities could result in increased erosion and sedimentation, with subsequent impacts to water quality and/or storm drain capacity during construction. Additionally, release of fuels or other hazardous materials associated with construction equipment could impact water quality. The WCDP EIR concluded that construction activities could result in increased erosion and sedimentation to surface waters, as well as accidental spills, both of which could adversely affect water quality. These potential impacts are partially addressed through required compliance with the Port’s municipal NPDES permit and the NPDES Construction General Permit. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including

Denmar Addendum to the WCDP EIR 82 April 2021

requiring erosion and sediment control BMPs during construction and spill containment and countermeasures plans, was required to reduce impacts to less-than-significant levels.

Construction activities associated with the Proposed Project would directly disturb soils within the project area, including excavation or ground disturbance required for grading, consolidation, and construction of the project elements described in Section 2. In-water work within the Port’s drainage channel system would be limited to remediation, installation of the culverted railway and access road crossing, and installation of utilities. In-water work within the San Joaquin River would be limited to installation of fender panels at Berths 18 and 19. Both upland and in-water work have the potential to result in water quality degradation, including through erosion or inputs of common industrial pollutants to the waterbody. Remediation procedures have been designed to avoid water quality impacts during construction, including but not limited to consolidating excavated contaminated materials in suitable areas. Remediation is anticipated to result in a long-term benefit to water quality. Potential water quality impacts during construction of the Denmar terminal and remediation would be further addressed through adherence to the construction BMPs described in Section 2.3.5. This includes obtaining a NPDES Construction General Permit for the Proposed Project. Consistent with the findings of the WCDP EIR, the Port would require implementation of Mitigation Measure 4.7.1 – Require Erosion and Sediment Control BMPs for All Construction Activities and Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures as part of project approval. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.2 Drainage – Development of the project site could increase drainage flows as a result of the introduction of increased amounts of impervious surfaces, which could exceed the capacity of on-site drainage systems, create localized flooding, or contribute to a cumulative flooding impact downstream. The WCDP EIR found that development may increase the area of impermeable surfaces, which could result in increased runoff and potentially contribute to flood hazards. Impacts were considered significant and implementation of mitigation as identified in Appendix A, requiring the development of a master drainage plan for the West Complex, was required to reduce impacts to less-than- significant levels. Since publication of the WCDP EIR, the Port has prepared and implemented the DSP (Port 2009).

New impervious surfaces would be required associated with construction of the Proposed Project, including from landfill cover liners, roads, and the railcar unloading building, over an area of approximately 1,079,406 square feet (24.78 acres). Stormwater runoff from the railcar unloading building’s paved parking area would be directed to pervious areas via a bioswale on the east side of the parking area and allowed to infiltrate. Existing catch basin and pipe systems, swales, roadside

Denmar Addendum to the WCDP EIR 83 April 2021

ditches, culverts, hydraulic control structures, and wet ponds are located throughout the Port to manage stormwater runoff. The Proposed Project would require minor conveyance modifications to maintain flow paths. Stormwater runoff from the paved access road between Fyffe Avenue and the railcar unloading building area would be directed to pervious areas and allowed to infiltrate.

Development of impervious or low-permeability surfaces and other drainage modifications would occur in compliance with the Port’s DSP. Any associated increase in stormwater runoff would have no effect on upland or shoreline flood risk or erosion. To accommodate operational wastewater and stormwater runoff, the Proposed Project would include construction of a wastewater treatment plant and stormwater retention pond. With these improvements, the minor conveyance modifications described above, and the Port’s DSP, the Proposed Project would neither exceed the capacity of nor increase erosion within the Port’s existing stormwater conveyance system.

Flood hazard risk within the project site is relatively low because the majority of the project site is not within a 100-year flood zone, and existing infrastructure and management actions address potential levee failure risk and flooding within the Port’s stormwater conveyance system. The proposed conveyance channel rail or road crossings would include culvert or overcrossing designs to accommodate anticipated water elevations, and utility crossings would occur underground or elevated on utility poles. Water levels in the conveyance channel system would still be able to be controlled via the existing pump station. Rail infrastructure in or near the FEMA “Zone A” mapped areas, including the small seasonal wetland feature and areas adjacent to the conveyance channel, would be elevated above the elevation of adjoining areas outside of the 100-year flood zone. Remediation activities in 100-year flood zone areas would have no effect on flood risk or exposure to flood risk. Potential flood hazards from levee failure are addressed through Port and Reclamation District 403 monitoring of West Complex levees, which would be unaffected by the Proposed Project. Stormwater would continue to be conveyed to the Port’s drainage system and pumped as needed into the Burns Cutoff.

Based on the analyses presented above, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.3 Water Quality – The Proposed Project could increase both non-storm and stormwater runoff, transporting contaminants to adjacent receiving waters. The WCDP EIR found that development may increase the area of impermeable surfaces, which could result in increased runoff and potentially introduce contaminants into adjacent receiving waters such as the San Joaquin River. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including conducting street sweeping and including BMPs that maximize stormwater quality in drainage plans, was required to reduce impacts to less-than-significant levels.

Development of impervious surfaces and drainage conveyance improvements would need to occur in compliance with the Port’s DSP, which is implemented to maximize stormwater quality in the West

Denmar Addendum to the WCDP EIR 84 April 2021

Complex. As noted in Section 3.6.5.2, any project-related increase in stormwater runoff from construction of new impervious surfaces is unlikely to affect flooding or exceed the capacity of the Port’s existing stormwater conveyance system, and the Proposed Project includes a wastewater treatment plant and stormwater retention pond to accommodate operations. Water quality impacts during construction would be avoided or minimized with implementation of the WCDP EIR-identified mitigation measures identified in Appendix A and the BMPs identified in Section 2.3.5, as detailed in Section 3.6.5.1. This would include development and implementation of a Stormwater Pollution Prevention Plan by a qualified stormwater professional, which would include BMPs that address the management and sampling of stormwater during remediation activities.

Several of the construction water quality control measures would also apply to operation of the Denmar terminal, including but not limited to compliance with the Port’s municipal NPDES permit. Storage and transportation of soda ash would be performed in a fully enclosed fashion, and soda ash is not classified as being toxic by OSHA. As described in Section 3.6.5.2, remediation procedures have been designed to avoid environmental impacts during construction and would likely provide a long-term benefit to water quality. Operation of the Proposed Project would not generate any significant new sources of runoff. The existing dock structures contain stormwater drainage holes, which would be modified to contain any stormwater that comes into contact with soda ash. Contact stormwater would then be conveyed to the new stormwater retention pond and pre-treatment system prior to discharge to the existing stormwater system. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.4 Water Quality – As discussed in Section 4.12, Public Services and Utilities, the wastewater conveyance system on the project site is known to suffer from an inflow and infiltration (I&I) problem. This could result in sewage leaks reaching groundwater and/or surface waters, potentially impairing beneficial uses and violating water quality standards. The WCDP EIR concluded that increased development could generate additional wastewater and exacerbate existing inflow and infiltration impairments. Impacts were considered significant and implementation of mitigation as identified in Appendix A, which requires the Port to assess the wastewater conveyance system, was required to reduce impacts to less-than-significant levels.

The Proposed Project would result in an incremental contribution to the wastewater conveyance demand analyzed in the WCDP EIR. Facility demands on wastewater would be accommodated through the wastewater treatment plant. The stormwater retention pond would be designed in compliance with the Port’s DSP to avoid adverse water quality impacts. Although the Delta is a California 303(d) List Category 5 waterbody for multiple pollutants, construction and operation of the Proposed Project would not substantially degrade water quality when considering the enclosed nature of soda ash transport and the implementation of BMPs and mitigation measures previously

Denmar Addendum to the WCDP EIR 85 April 2021

described. As described in Section 3.6.5.2, remediation procedures have been designed to avoid environmental impacts during construction and would likely provide a long-term benefit to surface water and groundwater quality. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.5 Water Quality – The Proposed Project has the potential to increase the trade of bulk materials that may increase the likelihood of contaminated runoff during wet weather events. In addition, fuel spills, releases of hazardous materials, and other contaminant-laden runoff generated in the warehouse and dock area could result in impacts to water quality. The WCDP EIR concluded that untreated runoff from the warehouse and dock area located along the shoreline could potentially contaminate the San Joaquin River, other surface water features, and groundwater. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including directing all stormwater runoff to the storm drain system, covering bulk stockpiles during rains, immediately addressing hazardous materials releases, and implementing spill containment and countermeasures plans, was required to reduce impacts to less-than-significant levels.

As noted in Section 2.2, soda ash is not a hazardous material, but is extremely water soluble. Therefore, soda ash would be stored and transferred in an enclosed system, which would minimize the potential for water quality impacts from handling of this commodity. The Proposed Project also includes modifying stormwater drainage holes on the existing dock in order to contain any stormwater that comes into contact with soda ash, which would be conveyed to the stormwater retention pond and pre-treatment system prior to discharge to the existing stormwater system. The Proposed Project would comply with the Port’s DSP, which reflects the latest stormwater drainage conditions throughout the Port. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.7.5b – Cover Bulk Stockpiles During the Rainy Season; Mitigation Measure 4.7.5c – Immediately Address Releases of Hazardous Materials; and Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures as part of project approval. Therefore, there would be no additional impacts, and the findings would be the same as those described in the WCDP EIR.

3.6.5.6 Water Quality – The Proposed Project will lead to increases in the frequency and number of ships traveling in the DWSC. Ship traffic has been shown to resuspend sediment in the water column, leading to decreases in water quality. Impacts to dissolved oxygen in the DWSC are of particular concern due to a pre-existing impairment for this constituent in this waterbody. The WCDP EIR concluded that existing dissolved oxygen impairment in the San Joaquin River may be exacerbated by ship movement. Impacts were considered significant and implementation of mitigation as identified in Appendix A, which requires the Port to take ownership and operational

Denmar Addendum to the WCDP EIR 86 April 2021

responsibility of the aeration device currently owned and operated by USACE, was required to reduce impacts to less-than-significant levels. Since publication of the WCDP EIR, the Port has taken over operation of the aeration device in accordance with the conditions described in Appendix A.

The Proposed Project entails operations consistent with the evaluation in the WCDP EIR, including incremental increases in vessel traffic. The aeration device is already being implemented to ensure dissolved oxygen levels are in compliance with regulations. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.7 Water Quality – The wakes created by the additional ship traffic associated with the Proposed Project could lead to increased rates of bank erosion, with subsequent impacts to water quality. The WCDP EIR considered the effects of ship wake on the shoreline and concluded that increased ship traffic could erode the levees along the northwest portion of Rough and Ready Island, leading to potential water quality impacts. Impacts were considered significant and implementation of mitigation as identified in Appendix A, requiring specific levee monitoring considerations, was required to reduce impacts to less-than-significant levels.

Consistent with requirements of the WCDP EIR, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring of the West Complex levees, including those in the northwestern portion of the island. As part of regular operations, the Port and Reclamation District 403 complete regular inspections and any necessary repairs. No levee erosion issues have been observed by the Port or Reclamation District 403 on the western portion of the West Complex. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.8 Groundwater – As discussed in Section 4.12, Public Services and Utilities, at build-out, the Proposed Project is anticipated generate a domestic water demand impact of approximately 1633 AF/year. Because the water supplier, Cal Water, relies on groundwater to support demand, this water demand has potential to substantially deplete groundwater supplies in a basin that is already in overdraft. The WCDP EIR concluded that existing groundwater overdraft conditions represent a potentially significant impact on the availability of potable water supply. In consideration of these overdraft conditions and the WCDP’s anticipated domestic water demand of approximately 1,633 acre-feet per year, impacts were considered significant and implementation of mitigation as identified in Appendix A, including managing and accessing potable water demands on the West Complex and

Denmar Addendum to the WCDP EIR 87 April 2021

upgrading the potable water supply system if demands are anticipated to exceed system capacity, was required to reduce impacts to less-than-significant levels.

As described in Section 3.6.5.2, several of the proposed minor conveyance modifications would still allow infiltration of stormwater into the groundwater table. This includes use of grading and bioswales to convey water away from new impervious features and allow groundwater infiltration to occur. Furthermore, while groundwater overdraft conditions have existed in the County Basin since the 1920s, elevations have recovered and stayed relatively constant since 1999 (Port 2012). The Denmar terminal’s incremental demand on domestic water supply (approximately 41 million gallons annually) would be addressed through the Port’s ongoing implementation of Mitigation Measure 4.12.6 – Assess and Manage Potable Water Demands and Mitigation Measure 4.12.7 – Upgrade Potable Water System. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.9 Flooding – The Project Area is protected from 100-year flood events by levees. Although the levees currently provide adequate protection within the Project Area from a 100-year flood event, flood hazards in the long term could result from inadequate levee maintenance, rising sea level, and regional land subsidence. This could potentially lead to flooding of project facilities, causing loss of property or expose people to risk of injury and/or death. The WCDP EIR concluded that, although the West Complex levees provided adequate protection from a 100-year flood event, there could be long-term flood risks associated with the WCDP. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including requiring development projects to maintain a 50-feet setback from existing levees and to actively maintain levees, was required to reduce impacts to less-than-significant levels.

Based on input from Reclamation District 403 specific to the project area, the Proposed Project has been designed to comply with a modified version of Mitigation Measure 4.7.9 – Ensure a Setback from Existing Levees and Maintain Levees, proposed to be modified as follows (underlines represent new text):

Mitigation Measure 4.7.9: Any new Port structural development shall allow a Reclamation District 403-approved 20 50-foot) setback from existing levees to permit continued levee maintenance and improvements as necessary for protection from major floods. The Port shall conduct regular levee maintenance to FEMA standards that are adequate to protect people and property from the 100-year flood event.

The Proposed Project would not include any new structures within 20 feet of existing levees and would not impede levee maintenance. The Proposed Project would include construction of a

Denmar Addendum to the WCDP EIR 88 April 2021

roadway atop the existing levee road, but this would not preclude access for levee maintenance and has been reviewed and supported by Reclamation District 403.

Since publication of the WCDP EIR, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring of the West Complex levees, thereby minimizing the risk of flooding because of levee failure. The effects of unstable soil conditions on proposed structures would be addressed through construction methods such as DSM and use of stone columns or ground anchors, and through adherence with applicable regulations including the California Building Code. While potentially expansive soils noted in NRCS maps (County GIS 1999; NRCS 2019) within the project site may be susceptible to subsidence, the Proposed Project would not exacerbate these conditions. Similarly, construction and operation of the Proposed Project would not substantially affect sea level rise. The proposed Berth 18 and 19 improvements, including concrete reinforcement and stormwater drainage holes, would provide additional shoreline protection from and resiliency to flooding, and would not impede or redirect flood flows. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.6.5.10 Flooding – Many dams are located upstream of the project site. The Project Area could be subject to flooding if one of these dams were to fail. However, the risk of flooding from dam failure is considered very low because the likelihood of dam failure is low (City 1990). The WCDP EIR concluded that the risk of flooding in the West Complex from upstream dam failure was low. Impacts were considered less than significant.

The Proposed Project would not affect the potential for flooding due to failure of an upstream dam. It would comply with all requirements associated with levee maintenance and the modified setback Mitigation Measure 4.7.9, which has been approved by Reclamation District 403. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 89 April 2021

3.6.5.11 Seiche, Tsunami, or Mudflow – Tsunamis originating in the Pacific Ocean would dissipate in the San Francisco Bay, and therefore pose a negligible hazard to the project site (City 1990). Seiches, while having no occurrences in San Joaquin County in the historic record, could occur in the San Joaquin River, DWSC, or Burns Cutoff, and therefore pose a slightly higher risk to the Project Area as they could overtop levees or lead to levee failure. However, because the outboard side of the levees on the Project Area are reinforced with riprap, the risk of levee failure as a result of a seiche is considered low. Further, the risk of a seiche of sufficient magnitude to overtop the levees is low enough to be considered to be below significance thresholds. Finally, the Project Area is nearly level, with little risk of mudflow. The WCDP EIR concluded that the level elevation, inland location, and existing levees of the West Complex would protect it from risks associated with seiche, tsunamis, or mudflow. Impacts were considered less than significant.

The Proposed Project would not affect any of these conditions. It would comply with all requirements associated with levee maintenance and the modified setback Mitigation Measure 4.7.9, which has been approved by Reclamation District 403. The project site is not within any designated tsunami or seiche zones that would pose significant risk of inundation or associated release of pollutants. Inputs of pollutants from shoreline areas potentially vulnerable to inundation would be avoided through compliance with BMPs described in Section 2.3.5, WCDP EIR mitigation measures, compliance with the Port’s municipal NPDES permit, and by performing operational soda ash transfer within an enclosed system. Therefore, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.7 Biological Resources Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Construction activities in the Project Area could potentially Less-than-Significant Less-than- a. result in direct and indirect impacts to “waters of the United Impact with Significant Impact States,” including wetlands. Mitigation with Mitigation Construction activities and project operations in the Project Less-than-Significant Less-than- b. Area could result in adverse impacts to special-status species Impact with Significant Impact covered under the SJMSCP. Mitigation with Mitigation Future development activities resulting from the Proposed Project could result in direct or indirect impacts to habitat for special-status species not covered under the SJMSCP (soft Less-than-Significant Less-than- c. bird’s beak, roundleaved filaree, Sacramento perch, river Impact with Significant Impact lamprey, Kern Brook lamprey, Pacific lamprey, Central Valley Mitigation with Mitigation fall/late fall-run and spring-run Chinook salmon, Central Valley steelhead, and salt-marsh harvest mouse).

Denmar Addendum to the WCDP EIR 90 April 2021

Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Future development activities resulting from the Proposed Project may result in the alteration of, or disturbance to Significant and Significant and d. sensitive natural communities within the Sacramento San Unavoidable Unavoidable Impact Joaquin Delta associated with an increased release of non- Impact native aquatic organisms from ships. The Proposed Project may result in impacts to heritage trees Less-than-Significant Less-than- e. as defined in the Stockton Municipal Code. Impact Significant Impact Less-than-Significant Less-than- Construction activities in the Project Area could conflict with f. Impact with Significant Impact the SJMSCP. Mitigation with Mitigation

3.7.1 Environmental Setting The WCDP EIR provides a framework for considering the biological resource effects of the Proposed Project. The biological resources setting of the Port and its environs is described in the WCDP EIR (Section 4.8 of the DEIR) and updated in this section to reflect existing conditions at the project site. The setting description provided in the WCDP remains largely unchanged, although new or revised biological resource investigations, Endangered Species Act (ESA) listings, and regulatory updates are available. Therefore, the environmental setting has been updated to include new information obtained during multiple site visits occurring in 2014, 2019, and 2020 conducted in support of the project’s jurisdictional delineation report, Biological Assessment, and general Port planning (Anchor QEA 2020a, 2020b). The following text summarizes pertinent and updated context information for biological resources relevant to the Proposed Project.

3.7.1.1 Habitats and Vegetation Communities Consistent with the WCDP EIR description, the project area is located in the northern San Joaquin Valley within the City and the Delta. Rough and Ready Island is protected from surrounding high water by a perimeter levee, and includes industrial developments, grasslands, a golf course, stormwater conveyance channels, and fallow agricultural fields. The project site is located in the northwestern portion of the island, within the area containing industrial developments and grasslands described in the WCDP EIR. Additional upland habitat conditions were observed during site visits in support of the jurisdictional delineation report (Anchor QEA 2020a), as described in the following paragraphs. All portions of the project area that were not delineated as waters or wetlands (Figures 4 and 5; Appendix D) are considered upland.

The eastern portion of the project site occurs within a developed portion of the island characterized by warehouses, parking lots, roadways, and associated infrastructure to support shiploading operations. These areas have very limited vegetation which mostly occurs at the margins of developments, and largely consists of ornamental landscaping or ruderal weeds.

Denmar Addendum to the WCDP EIR 91 April 2021

Upland habitats in the western undeveloped but disturbed portion of the project site proposed for soil remediation activities and rail infrastructure construction are composed of ruderal and grassland communities, including all areas that were not mapped as waters or wetlands (Figure 4). Ruderal plants consisting of weedy broadleaves vary in height between 1 and 3 feet and are prevalent on the inland side of the levee slopes and across the uplands. Surface grading in recent times likely disturbed the soils in some locations, as observed in the field and viewed in aerial photographs. Vegetation on the levee slopes and on the disturbed soil areas consists of ruderal weeds common to the Central Valley, and the dominant species include milk thistle (Silybum marianum), summer mustard (Hirshfeldia incana), Italian thistle (Carduus pychnocephalus), prickly lettuce (Lactuca serriola), Menzie’s fiddleneck (Amsinckia menziesii), black mustard (Brassica nigra), wild radish (Raphanus sativa), and hedge parsley (Torilis arvensis). Non-native perennial grasslands dominated by tall wheat grass (Elymus ponticus) also occur as observed on the west side of the project site intermixed with the ruderal areas. Ruderal and non-native annual grass species occur among the 3- to 4-foot-tall bunch grass clusters.

In the vicinity of the proposed conveyor system is an undeveloped but disturbed parcel bound by rail lines and developed areas. Apart from the wetland habitats shown in Figures 4 and 5 and Appendix D, habitat in this area is composed of ruderal vegetation dominated by milk thistle, yellow starthistle (Centaurea solstitialis), poison hemlock, wild fennel (Foeniculum vulgare), black mustard, wild radish, churlock (Raphanus raphanistrum), Italian thistle, alkali mallow (Malvella leprosa), and stinkwort (Dittrichia graveolens). This area also includes thick swaths of Himalayan blackberry.

3.7.1.2 Waters and Wetland Habitats The jurisdictional delineation report prepared for the Proposed Project updates the 1996 delineation described in the WCDP EIR. Jurisdictional waters and wetlands were observed during site visits in 2014, 2019, and 2020. Per the 2020 delineation, the project site includes 65.38 acres of potentially jurisdictional waters and wetlands (60.62 acres of wetlands and 4.76 acres of waters). Appendix D includes figures from the 2020 jurisdictional delineation depicting these potentially jurisdictional waters and wetlands. These findings are preliminary until verified by USACE. Wetland areas occur on the undeveloped but disturbed western portion of the project site, and relatively permanent waters consist of the two drainage channels that traverse the project site. The Proposed Project includes remediation and construction of rail, tower, and access road infrastructure within wetland areas, and installation of a culverted crossing within the drainage channel that extends east to west in the project area. Figures 4 and 5 depict the location of potentially jurisdictional waters and wetlands relative to the Proposed Project activities. A description of wetland features identified during the 2020 delineation is provided as follows.

Riparian scrub meeting USACE wetland criteria occurs on the northwest side of the project site interspersed with upland ruderal and grassland communities and poison hemlock or pepperweed

Denmar Addendum to the WCDP EIR 92 April 2021

patches wetlands. Vegetation in these riparian scrub areas is characterized by thick growth paired with hydrophytic associates in the understory. Arroyo willow and black willow (Salix gooddingii) are the dominant species and reach as high as 30 to 40 feet in some locations. Cottonwood ( sp.), giant reed (Arundo donax), and black walnut ( hindsii) are found in this low-lying region as secondary species. The shorter-growing sandbar willow (Salix exigua) is found filling the middle to low positions in the riparian scrub canopy, and commonly occurs on the edges of the taller arroyo and black willow vegetation. Cumulatively, the assemblage of riparian scrub tree species forms a very dense cover over portions of the project site. The understory species found among the riparian scrub consists of poison hemlock, stinging nettle (Urtica dioica), water smartweed (Persicaria amphibia), and pepperweed. Areas likely to experience the longest period of inundation within the riparian scrub were observed to support the growth of marsh baccharis and western goldenrod (Euthamia occidentalis). Riparian habitat in this area may occur because of a long inundation period associated with lake-like conditions, although there may also be connectivity to stream, creek, or river areas in the vicinity (specifically the drainage ditch system).

Also within the northwest side of the project site, east of the riparian scrub areas described above, is a mosaic of poison hemlock or pepperweed patches, quailbush scrub, and arroyo willow thicket wetlands. Poison hemlock patches formed a low canopy over the ground surface with multiple plants overlapping each other completely covering the soil. The secondary species that competes with poison hemlock is pepperweed, a perennial herbaceous plant which spreads by rhizomes. The poison hemlock and pepperweed form or nearly form a monoculture over the ground surface with little competition from any other herbaceous species. Within the poison hemlock or pepperweed patch wetlands is a smaller polygon of arroyo willow wetlands, which include dense stands of 15- to 20-foot-tall arroyo willow trees with dense branches starting at the base of willow trunks. Little or no vegetation was observed in the understory; dead limbs of various sizes and leaves form the ground cover beneath the live willow trees. East of the poison hemlock or pepperweed patches and arroyo willow thickets is a linear row of quailbush scrub immediately west of the stormwater conveyance channel that extends north to south across the project site. Quailbush scrub forms similarly dense growth as arroyo willow thickets, punctuated by sharper limbs beneath the live growth of the 10-foot-tall shrubs. No vegetation is found beneath the quailbush shrubbery. Each of these wetland features are adjacent to and likely dependent upon the north to south stormwater conveyance channel.

Two seasonal wetland polygons were identified in the western side of the project site, within or near the southern portion of the proposed rail loop. These wetlands were distinguished from the uplands by the thick growth of creeping wild rye (Leymus triticoides) which spreads across the two low, shallow basins. At the topographic low point of the basins, water smartweed grows where the inundation period is the longest. At the upper periphery of the creeping wild rye, clusters of Indian hemp (Apocynum cannabinum) are found near the ordinary high water mark within these seasonal wetland features. A third seasonal wetland occurs in the same area, with predominant vegetation of

Denmar Addendum to the WCDP EIR 93 April 2021

bristly oxtongue (Helminthotheca echioides). During typical annual storm events, runoff from these seasonal wetlands may sheetflow to adjacent drainage or irrigation ditches.

Wetland riparian scrub habitat also occurs in the proposed conveyor system area, in the undeveloped but disturbed area bound to the west by rail lines and other sides by developed areas. This riparian scrub area is characterized by dense willow growth paired with associated hydrophytic understory vegetation. Black willow, arroyo willow, and Fremont’s cottonwood (Populus fremontii) are the dominant species, reaching 30 to 40 feet tall in some locations throughout the basin. Black walnut is found in this low-lying region as a secondary species. Areas where the overstory produces dense shade do not support understory vegetation. Herbaceous annual and perennial species are found in the overstory gaps within the riparian scrub. Other species observed include California blackberry (Rubus ursinus), water smartweed, sunflower (Helianthus bolanderi), cocklebur, stinging nettle, and alkali mallow. The source of wetland hydrology or connection to relatively permanent waters in this area is not immediately apparent; they appear to have formed through a long duration of saturation or inundation from rainwater and/or the presence of standing water through a high water table, and may sheetflow to or be otherwise influenced by the drainage channel to the south.

An additional three seasonal wetland polygons were observed in the proposed conveyor system area, in the undeveloped but disturbed area bound to the west by rail lines and other sides by developed areas. In some seasonal wetland areas, fat hen (Atriplex prostrata) is the dominant species, covering more than 50% of the ground. The dominant fat hen vegetation grows in late summer and has formed a layer over early germinating wild radish, a secondary species that accounted for approximately 20% of the vegetation. The presence and growth of the later germinating fat hen may indicate a very long inundation period, long duration of saturation, or possibly a rise in the water table in the summer months, which saturates the subsurface and promotes this species’ dominance over early germinating wild radish. Apart from fat hen areas, other dominant or secondary vegetation include poison hemlock, cocklebur (Xanthium strumarium), stinging nettle, and western goldenrod. Similar to riparian scrub habitat in this area, wetland conditions may be the result of accumulated precipitation or the high water table, and seasonal wetlands may sheetflow or be dependent upon the nearby drainage ditch during a typical year.

The western portion of the project site also includes freshwater emergent wetlands on the slopes of or within the irrigation and drainage ditches that extend east to west and north to south. Freshwater emergent marsh vegetation is found in the linear drainage/irrigation ditches where bulrush (Scirpus sp.), chairmaker’s bulrush (Schoenoplectus americanus), and broad leaf cattail (Typha latifolia) occur in various densities. Generally, the emergent marsh vegetation forms bands along the channel edges. A small polygon of freshwater emergent marsh is also found supporting marsh baccharis within the drainage ditch on the northwestern corner of the island. In total, freshwater wetlands comprise an approximate area of 1.7 acres in the project site.

Denmar Addendum to the WCDP EIR 94 April 2021

The irrigation and drainage ditch system on Rough and Ready Island likely qualifies as a relatively permanent water per the USACE definition, and likely has connectivity to traditionally navigable waters (Burns Cutoff). This includes the two drainage ditch channels that extend north to south and east to west across the project site, over an area of approximately 4.32 acres. The drainage and irrigation ditches exhibit defined beds and banks. These features connect and eventually terminate at a pump station on the western side of the island. There is also a relatively small drainage ditch with a defined bed and bank in the center of the western portion of the project site, which terminates in a culvert and likely conveys stormwater from adjacent areas during storm events.

3.7.1.3 Special-Status Species In order to identify special-status species that could be present within the project area, the following sources were reviewed: • Species observation records in the California Natural Diversity Database (CNDDB) for the 7.5-minute USGS quadrangle for the project area and adjacent quadrangles, including Stockton West, Terminous, Lodi South, Waterloo, Stockton East, Manteca, Lathrop, Union Island, and Holt (CDFW 2020) • California Department of Fish and Wildlife (CDFW) Fall Midwater Trawl survey results (FMWT; CDFW 2019) • USACE entrainment and community monitoring performed during annual Stockton and Sacramento DWSCs maintenance dredging since 2005 (USACE 2015a; ICF 2019) • SJMSCP species lists (County 2000) and draft incidental take minimization measures (ITMMs; SJCOG 2021) • WCDP EIR (Port 2004) • Site visits by Anchor QEA biologists (Anchor QEA 2020c), including focused plant surveys during the summer blooming period (August and September)

The following federally or state listed special-status species and habitats may be present in the project’s area of effect (Anchor QEA 2020b, 2020c; CDFW 2020; CDFW 2019; ICF 2019; County 2000; Port 2004; SJCOG 2021): • Southern distinct population segment (DPS) green sturgeon (Acipenser medirostris): federal threatened and state species of special concern • Delta smelt (Hypomesus transpacificus): federal threatened and state endangered • Central Valley spring-run evolutionarily significant unit (ESU) Chinook salmon (Oncorhynchus tshawytscha): federal and state threatened • Central Valley DPS steelhead (O. mykiss irideus): federal threatened • Longfin smelt (Spirinchus thaleichthys): federal candidate and state threatened • Critical habitat for delta smelt, Central Valley DPS steelhead, and Southern DPS green sturgeon

Denmar Addendum to the WCDP EIR 95 April 2021

• Essential fish habitat (EFH) for the Pacific Coast salmon and Pacific Groundfish fishery management plans (FMPs) • Valley elderberry longhorn beetle (Desmocerus californicus dimorphus): federal threatened • Giant garter snake (Thamnophis gigas): federal and state threatened • Riparian brush rabbit (Sylvilagus bachmani riparius): federal and state endangered • Western pond turtle (Emys marmorata): state species of special concern • Central Valley fall-run Chinook salmon (O. tshawytscha): state species of special concern • Swainson’s hawk (Buteo swainsoni): state threatened • Tricolored blackbird (Agelaius tricolor); state threatened • California black rail (Laterallus jamaicensis coturniculus): state threatened • Short-eared owl (Asio flammeus): state species of special concern • Burrowing owl (Athene cunicularia): state species of special concern • Northern harrier (Circus hudsonius): state species of special concern • Loggerhead shrike (Lanius ludovicianus): state species of special concern • Yellow warbler (Setophaga petechia): state species of special concern • Migratory Bird Treaty Act-protected birds and raptors • Marine mammals (harbor seals)

In addition to the above noted federally or state listed special-status species, the following SJMSCP-covered species may be present at the project site: moestan and molestan blister beetles (Lytta moesta and Lytta molesta) and bats. Table 13 identifies California Native Plant Society list rare plants determined potentially present based on recorded occurrences and habitat conditions.

Table 13 Potentially Present California Native Plant Society List Rare Plants

Species California Native Plant Society Rank Bloom Period Suisun Marsh aster (Aster lentus) 1B.2 Late May – November Bristly sedge (Carex comosa) 2B.1 May – September Slough thistle (Cirsium crassicaule) 1B.1 May – August California hibiscus (Hibiscus lasiocarpus) 1B.2 August – September Delta tule pea (Lathyrus jepsonsii var. jepsonii) 1B.2 May – September Mason's lilaeopsis (Lilaeopsis masonii) 1B.1 April – October Delta mudwort (Limosella subulata) 2B.1 May – August Sanford's arrowhead (Sagittaria sanfordii) 1B.2 May – October Notes: Bloom periods obtained from the SJMSCP. 1B.1 and 1B.2: Plants with a California Rare Plant Rank of 1B are rare throughout their range with the majority of them endemic to California. 2B.1: Except for being common beyond the boundaries of California, plants with a California Rare Plant Rank of 2B would have been ranked 1B.

Denmar Addendum to the WCDP EIR 96 April 2021

Special-status plant surveys (including for rare plants) were conducted on August 26 and 27, and September 3, 2020, coinciding with the bloom periods of each of the species listed in Table 13. No special-status plant species were observed during these site visits.

The potentially present special-status species and habitats identified above are consistent with those described as potentially present in the WCDP EIR, with the exception of riparian brush rabbit, moestan and molestan blister beetles, California black rail, and yellow warbler, EFH, and marine mammals. These special-status biological resources are briefly described in the following paragraphs.

The riparian brush rabbit occupies riparian forests within the natural floodplains, which have an ample brushy understory in association with the forest, plus suitable upland areas for cover and retreat from annual floods. The historic range of the riparian brush rabbit is believed to have extended along the San Joaquin River from Stanislaus County to the Delta. One of two presently known populations is found on the lower Stanislaus River in Caswell State Park. Pursuant to recent studies, a second population has been identified near Stewart Tract along the San Joaquin River and its tributaries. The habitat for this species is the dense brush and nearby openings associated with the banks of the Stanislaus and San Joaquin rivers (County 2000). Recorded occurrences of the riparian brush rabbit within the nine-quadrangle CNDDB search area are all located within the Lathrop and Union Island quadrangles south and southwest of the project quadrangle. Occurrences are clustered around Stewart Tract. The nearest recorded occurrence is approximately 8.75 miles southeast of the project site, observed in 2004 (CDFW 2020). Because suitable habitat exists in portions of the project site, the Port conducted surveys for riparian brush rabbit. The surveys documented jack rabbit (Lepus californicus) and desert cottontail (Sylvilagus audubonii) on site, but riparian brush rabbit were not observed (Sapere 2021).

There are no known occurrences of either the moestan or molestan blister beetles in San Joaquin County (County 2000), and these species do not have any CESA or ESA listings. Nonetheless, the draft ITMMs identified by the SJCOG for the proposed project include avoidance measures for these species. Habitat for both beetle species includes annual grassland, foothill woodland, and atriplex scrub. Atriplex scrub (specifically quailbush) occurs within the proposed eastern rail loop portion of the project site immediately west of the existing north to south drainage channel (Appendix D).

The California black rail inhabits salt and freshwater marshes, and the nearest CNDDB recorded occurrence of this species was made approximately 6.5 miles northwest of the project site along the San Joaquin River in 2010 (CDFW 2020). Per the SJMSCP, the California black rail is only found where there are marshes that are 20 acres or larger, and nesting habitat includes dense herbaceous canopy at the water’s edge (County 2000). These habitat types are absent from the project area, although some marsh vegetation is present at the margins of the drainage channels and San Joaquin River within the project area.

Denmar Addendum to the WCDP EIR 97 April 2021

The yellow warbler was once a common to locally abundant summer resident throughout cismontane California, and the SJMSCP identifies four observational records of this species from San Joaquin County (County 2000). Yellow warblers inhabit willow thickets at the edges of permanent waters. Arroyo willow thickets occur on the northeastern portion of the proposed rail loop area (Appendix D).

The project site is within EFH for Pacific salmon and Pacific groundfish. The Pacific salmon FMP includes Chinook salmon and coho salmon (O. kisutch) and occasionally includes pink salmon (O. gorbuscha), sockeye salmon (O. nerka), and chum salmon (O. keta). The Pacific groundfish FMP is designed to protect habitat for more than 90 species of fish, including rockfish, flatfish, groundfish, some sharks and skates, and other species that associate with the underwater substrate (e.g., rocky and soft substrates). There exists a low likelihood for transitory presence of Pacific salmon and Pacific groundfish FMP species within the area that would be affected by the Proposed Project. No Chinook salmon have been encountered since 2010 at observations stations near the project site during the FMWT, and no Chinook salmon have been encountered during entrainment and community monitoring by USACE. No other Pacific salmon FMP species have been encountered during entrainment and community monitoring by USACE or during the FMWT. Similarly, no Pacific groundfish FMP species were encountered during entrainment and community monitoring by USACE within the Stockton DWSC adjacent to Rough and Ready Island or within the turning basin southeast of the project site.

Harbor seals (Phoca vitulina) are known to occur in the San Joaquin River near the project site. Their presence is largely transitory because there are no rookeries or suitable haul-out sites at or near Berths 18 and 19. Habitat for harbor seals within the area that would be affected by the Proposed Project is generally low quality relative to the greater Bay-Delta because of the high level of vessel traffic in the Stockton DWSC and turning basin and the disturbed condition of the San Joaquin River.

3.7.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• Clean Water Act. The CWA, as described in the WCDP EIR, remains applicable to the Proposed Project, although the recent updates described in Section 3.6.2 may affect implementation of CWA Section 404 and Section 401 regulations. • Migratory Bird Treaty Act. The Migratory Bird Treaty Act remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • Bald and Golden Eagle Protection Act. The Bald and Golden Eagle Protection Act remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • Endangered Species Act. The ESA remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR, with the exception

Denmar Addendum to the WCDP EIR 98 April 2021

of updated species listings and recorded occurrences. The ESA designations presented in Section 3.7.1 reflect the current federal ESA designations. • California Endangered Species Act. The California Endangered Species Act (CESA) remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR, with the exception of updated species listings and recorded occurrences. The CESA designations presented in Section 3.7.1 reflect the current CESA designations. • State of California Marine Invasive Species Act. The State of California Marine Invasive Species Act remains applicable to the Proposed Project. It was amended through AB 912 on January 1, 2020, to include additional definitions, standards, and adoption dates for regulations pertaining to ballast water discharge (CSLC 2019). These revisions do not substantively change the regulatory conditions described in the WCDP EIR. • Port of Stockton Ballast Water Management Program. The Port’s Ballast Water Management Program remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • San Joaquin County Multi-species Conservation and Open Space Plan. The SJMSCP remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • Stockton Municipal Code Heritage Tree Protections. Heritage tree protection regulations and procedures remain applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR.

Additional regulations, plans, and policies applicable to the Proposed Project and pertaining to biological resources include the following:

• Marine Mammal Protection Act (MMPA). The MMPA was enacted on October 21, 1972, and was reauthorized by the MMPA amendments of 1994 (Public Law 103-238). Under the MMPA, all species of marine mammals are protected. The MMPA prohibits, with certain exceptions, the "take" of marine mammals. Under the MMPA, take is defined as the means, "to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or kill." Harassment is defined as, "any act of pursuit, torment, or annoyance which has the potential to injure a marine mammal or marine mammal stock in the wild; or has the potential to disturb a marine mammal or marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not limited to migration, breathing, nursing, breeding, feeding, sheltering." Sections 101(a)(5)(A) and (D) of the MMPA (16 United States Code [USC] 1361 et seq.) allow incidental take of marine mammals during specified activities under authorization of the Secretary if the total take would have negligible impacts on the species. • California Native Plant Protection Act. The California Native Plant Protection Act (FGC 1900–1913), Natural Communities Conservation Planning Act, and CESA provide guidance on the preservation of plant resources. Vascular plants listed as rare or endangered

Denmar Addendum to the WCDP EIR 99 April 2021

by the California Native Plant Society (CNPS), but which may have no designated status or protection under federal or state endangered species legislation, are defined as follows (in general, plants listed as CNPS Ranks 1A, 1B, 2A, or 2B also meet the definition of FGC 1901, Chapter 10 of the Native Plant Protection Act, and FGC 2062 and 2067): ‒ Rank 1A: Plants presumed to be extirpated in California and either rare or extinct elsewhere. ‒ Rank 1B: Plants rare, threatened, or endangered in California and elsewhere. ‒ Rank 2A: Plants presumed to be extirpated in California, but more common elsewhere. ‒ Rank 2B: Plants rare, threatened, or endangered in California, but more common elsewhere. ‒ Rank 3: Plants about which more information is needed—a review list. ‒ Rank 4: Plants of limited distribution—a watch list.

3.7.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.7.5b – Cover Bulk Stockpiles During the Rainy Season • Mitigation Measure 4.8.1a – Obtain and Comply with USACE Permit, Including Mitigation Requirements • Mitigation Measure 4.8.1b – Site Staging Areas Away from Waters • Mitigation Measure 4.8.1c – Use Standard BMPs to Avoid Accidental Fill of Waters • Mitigation Measure 4.8.1d – Use Standard BMPs to Prevent Hazardous Releases • Mitigation Measure 4.8.2a – Comply with the SJMSCP • Mitigation Measure 4.8.2b – Conduct Special-Status Species and Habitat Avoidance and Mitigation • Mitigation Measure 4.8.3 – Conduct Pre-Construction Rare Plant Surveys • Mitigation Measure 4.8.4 – Continued Ballast Water Management Plan Implementation

Details on these mitigation measures can be found in Appendix A.

3.7.4 Methods/Approach Potential impacts on biological resources were qualitatively evaluated based on the habitat preferences for various species known or suspected to be in the project area, as well as the quantity and quality of existing habitat. Potential impacts were analyzed using recent data on special-status species with the potential to inhabit the study area, local observations, and professional expertise and judgment in evaluating how the Proposed Project could interact with biological resources. Impacts to jurisdictional waters and wetlands were quantified using the 2020 jurisdictional delineation report findings (Anchor QEA 2020a) and GIS overlays of the Proposed Project footprint. The measurement indices used to evaluate impacts on biological resources include impacts on special-status species or habitats. Relevant findings from the WCDP EIR pertaining to biological

Denmar Addendum to the WCDP EIR 100 April 2021

resources are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.7.5 Impact Assessment

3.7.5.1 Construction activities in the Project Area could potentially result in direct and indirect impacts to “waters of the United States,” including wetlands. The WCDP EIR determined that implementation of the WCDP could result in direct and indirect impacts to waters of the United States, including wetlands. The WCDP EIR identified many of the mapped wetlands as occurring within a designated 409-acre “Diversified Land Use Area,” which was described in the WCDP EIR as an area not proposed for specific development. Diversified land uses were further described in the WCDP EIR as uses that would be developed on a market-driven basis to support Port activities. The WCDP EIR also described that structures would not be placed in, under, or over navigable waters. Nonetheless, the WCDP EIR considered impacts on wetlands and waters to be significant and implementation of mitigation as identified in Appendix A, including obtaining required permits and completing compensatory mitigation for impacts, siting staging areas away from waters, and implementing avoidance measures to avoid impacts, was required to reduce impacts to less-than-significant levels.

Portions of the Proposed Project would be constructed and operated within the Diversified Land Use Area and are the impetus for addressing the Port’s longstanding need to remediate a portion of the historically contaminated areas within the project site. Several wetland areas are located in or near contaminated areas, including Landfill Cells, that would have likely required excavation or capping even absent the proposed Denmar terminal. As summarized in Table 14, approximately 0.94 acre of jurisdictional wetlands and 0.499 acre of waters of the United States would be impacted by initial remediation activities, and up to 29.146 acres of jurisdictional wetlands and 0.448 acre of waters of the United States could be impacted by future remediation activities associated with the Proposed Project. Overall, the Proposed Project would result in the permanent fill of up to approximately 51.219 acres of jurisdictional wetlands and 1.047 acre of waters of the United States and state within the Diversified Land Use Area. Ultimately, remediation of hazardous substances in soils by the Port as part of the Proposed Project represents an environmental benefit. The existing disturbed conditions and location within both an industrialized Port and on an isolated island limit the habitat value of the wetlands that would be affected by the Proposed Project.

The Proposed Project was designed to avoid temporary or indirect impacts to wetlands and waters. Direct permanent loss of wetlands is not anticipated to result in additional temporary or indirect wetland impacts because: 1) the primary source of hydrology for wetlands at the project site is

Denmar Addendum to the WCDP EIR 101 April 2021

groundwater, which would not be impacted by the Proposed Project; and 2) no riparian vegetation trimming or root removal would occur outside of the Proposed Project footprint.

The Proposed Project would also add approximately 0.04 acre of overwater coverage and 0.01 acre of in-water fill below MHHW associated with the fendering system at Berth 18 and 19. While this nominal fill was not contemplated in the WCDP EIR, the fenders would be installed along the existing berths, would not affect the mudline of the San Joaquin River, and would be the minimum size necessary to support shipping operations. These nominal impacts to waters would not result in substantial adverse effects to special-status species or habitats, as detailed in Sections 3.7.5.2 and 3.7.5.3.

A summary of the total anticipated impacts to jurisdictional wetlands and waters from the Proposed Project components is provided in Table 14. Impacts to jurisdictional wetlands are shown in Figure 6.

Table 14 Area of Impact and Fill Volumes for Jurisdictional Wetlands and Waters of the United States or State

Permanent or Impact Areas Cut and Fill Volumes (Cubic Yards) Project Element Causing Impact Temporary Impact (Acres) Cut Fill Net Fill Wetlands Initial Remediation1 Permanent 0.94 3,942 2,969 -973 Rail Infrastructure Permanent 18.28 68,549 149,649 +81,100 Railcar Unloading Building Permanent 0.416 14,611 0 -14,611 Conveyor and Towers Permanent 0.78 619 101 -518 Tower Access Roads Permanent 0.84 1,367 3,606 +2,239 Utilities Permanent 0.817 4,048 3,259 -789 Future Remediation2 Permanent 29.146 42,662 85,525 -42,863 Total Permanent Impacts 51.219 135,798 245,109 +109,311 Non-Wetland Waters Initial Remediation1 Permanent 0.499 1,993 2,346 +353 Rail Infrastructure Permanent 0.10 554 1,474 +920 Berth Improvements Permanent 0.01 0 25 +25 Future Remediation2 Permanent 0.448 0 2,530 +2,530 Total Permanent Impacts 1.057 2,547 6,375 +3,828 Overall Permanent Impacts Total 52.276 138,345 251,484 +113,139 Notes: Impact values for all project elements include any preceding site preparation activities. 1. Initial remediation values include only initial remediation areas that do not overlap with proposed Denmar terminal elements. This includes remediation areas within the 20-foot buffer offset and within the IAS-11 Consolidation Area that overlap with jurisdictional features. 2. Future remediation values include all definite, potential, and contingency actions identified.

Denmar Addendum to the WCDP EIR 102 April 2021

Figure 6 Impacts to San Joaquin County Multi-Species Habitat Conservation and Open Space Plan Land Categories Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

Consistent with the WCDP EIR, the following wetlands and waters-related mitigation measures would be implemented as part of the Proposed Project: Mitigation Measure 4.8.1b – Site Staging Areas Away from Waters and Mitigation Measure 4.8.1c – Use Standard BMPs to Avoid Accidental Fill of Waters. Pending regulatory agency approval, the Proposed Project would also comply with a modified Mitigation Measure 4.8.1a – Obtain and Comply with USACE Permit, Including Mitigation Requirements. The Port has coordinated with USACE and CVRWQCB on the anticipated mitigation ratio to be considered appropriate for the Proposed Project, and agency input suggests reducing the mitigation ratio from 1:1 as described in the WCDP EIR to 0.5:1 may be approved. Pending regulatory agency approval, the rationale for the reduction would be to: 1) account for the habitat benefits from remediation; and 2) in consideration of the relative low quality of affected waters and wetlands as compared to the relative high quality of wetland mitigation bank wetland creation areas for which credits are for sale. Mitigation Measure 4.8.1a is proposed to be modified as follows (underlines represent new text):

Mitigation Measure 4.8.1a: The Port shall apply for a Department of the Army permit for all impacts to “waters of the U.S.,” and shall comply with all conditions of permits received. Permanent impacts to waters of the U.S. covered under this permit will be mitigated at a minimum 0.51:1 ratio through the purchase of mitigation credits at an approved mitigation bank, or through other habitat restoration or compensation measures proposed by the Port and approved by the USACE, CVRWQCB, and CDFW.

Portions of the wetlands that would be impacted by the Proposed Project were characterized as riparian scrub in the 2020 jurisdictional delineation report (Anchor QEA 2020a). Other non-wetland riparian vegetation may also be present on the western portion of Rough and Ready Island and could be impacted by the Proposed Project. Similar to the wetland conditions described above, the habitat value of riparian scrub and non-wetland riparian vegetation is compromised by the island’s former uses, existing contamination, existing Port uses, and isolated nature.

Non-wetland waters of the United States and state that would be impacted by the Proposed Project include portions of the stormwater conveyance system. These impacts would occur as a result of remediation, utility connections, and the culverted railway crossing. Hydrological connectivity between the stormwater conveyance system and nearby waters, including the Burns Cutoff and San Joaquin River, is via a pump station on the western end of the island. This lack of connectivity limits the habitat value of these waters because they lack the conditions required for anadromous fish or other special-status aquatic species. Water quality in the channel is also affected by Port land uses and existing contamination. Furthermore, the conveyance system is composed of drainage channels with marginal shoreline habitat; the system lacks the natural meanders, riparian canopy, and understory conditions that typify high quality waters in the Delta.

Denmar Addendum to the WCDP EIR 104 April 2021

With implementation of the WCDP EIR-identified and proposed modified mitigation measures, there would be no new or substantially more significant impacts to wetlands, waters, or riparian resources as a result of the Proposed Project, and the findings would be consistent with those described in the WCDP EIR.

3.7.5.2 Construction activities and project operations in the Project Area could result in adverse impacts to special-status species covered under the SJMSCP. The WCDP EIR concluded that construction and operation in the West Complex could result in adverse impacts to SJMSCP-managed species. Potential impacts to these species from implementation of the WCDP could include direct impacts from construction and habitat conversion. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including compliance with the SJMSCP and avoiding and mitigating impacts to other special-status species and habitats, was required to reduce impacts to less-than-significant levels.

A variety of urban, grassland, riparian, wetland, and other habitat types occur within the project site, and habitat may therefore be suitable for some SJMSCP-managed species identified in the WCDP EIR as potentially present at the West Complex, which includes numerous terrestrial and avian species. Potentially present SJMSCP-managed species include valley elderberry longhorn beetle, giant garter snake, riparian brush rabbit, western pond turtle, moestan and molestan blister beetles, and CESA or Migratory Bird Treaty Act-protected birds and raptors. Pre-construction special-status plant surveys were completed on August 26, August 27, and September 3, 2020, concurrent with the blooming period for potentially present plant species addressed in the SJMSCP (Anchor QEA 2020c). No SJMSCP-covered or other special-status plant species were encountered during these surveys; therefore, SJMSCP-covered plant species are not anticipated to be affected by the Proposed Project.

Potentially present SJMSCP-covered species may be directly or indirectly impacted by construction and operation of the Proposed Project, constituting a significant impact consistent with the findings presented in the WCDP EIR. Consistent with the requirements of the WCDP EIR, the Port would require implementation of Mitigation Measure 4.8.2a – Comply with the SJMSCP, Mitigation Measure 4.8.2b – Conduct Special-Status Species and Habitat Avoidance and Mitigation, and Mitigation Measure 4.8.3 – Conduct Pre-Construction Rare Plant Surveys as part of project approval. Denmar is seeking SJMSCP coverage for the Denmar terminal and the Port is seeking SJMSCP coverage for the remediation footprint. Figure 7 provides an overview of the Proposed Project’s impacts to the land categories identified in the SJMSCP. The SJMSCP process includes identifying all potentially present special-status species covered by the plan, complying with SJMSCP-set ITMMs, and mitigating for all impacts to natural or agricultural lands, which could provide habitat to SJMSCP-covered species. The Port and Denmar submitted an application for coverage to SJCOG in October 2020. SJCOG reviewed the project, prepared a staff report, and submitted the report to the SJMSCP Habitat Technical Advisory Committee. The Proposed Project

Denmar Addendum to the WCDP EIR 105 April 2021

was approved for coverage, and SJCOG biologists conducted a site visit in early 2021 to determine which ITMMs included in the SJMSCP are applicable to the Proposed Project. SJCOG issued a draft summary of applicable ITMMS for the Proposed Project on March 5, 2021, and a final summary is expected in mid-2021. ITMMs include surveys, monitoring, and applying temporary construction buffers, among other measures. The Port and Denmar would implement all required ITMMs identified by SJCOG. Ground disturbance would not occur until the ITMMs have been satisfied.

With implementation of the WCDP EIR-identified mitigation measures, there would be no new impacts to special-status species as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 106 April 2021

Figure 7 Historic Maps Denmar Natural Soda Ash Export Terminal at the Port of Stockton Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

3.7.5.3 Future development activities resulting from the Proposed Project could result in direct or indirect impacts to habitat for special-status species not covered under the SJMSCP (soft bird’s beak, roundleaved filaree, Sacramento perch, river lamprey, Kern Brook lamprey, Pacific lamprey, Central Valley fall/late fall-run and spring-run Chinook salmon, Central Valley steelhead, and salt-marsh harvest mouse). The WCDP EIR concluded that construction and operation in the West Complex could result in adverse impacts to special-status aquatic and plant species that are not managed by the SJMSCP. Potential impacts to aquatic species from implementation of the WCDP could occur from indirect effects associated with increased maritime traffic or water quality impacts from stormwater runoff or accidental spills. Potential impacts to plant species from implementation of the WCDP include direct impacts from construction or habitat conversion. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including directing all stormwater runoff to the storm drainage system, obtaining and complying with USACE permit and mitigation requirements, covering bulk stockpiles during the rainy season, siting staging areas away from waters, using standard BMPs to avoid accidental fill of waters and to prevent hazardous releases, and conducting pre-construction rare plant surveys, was required to reduce impacts to less-than-significant levels.

Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.8.1a – Obtain and Comply with USACE Permit, Including Mitigation Requirements as part of the Proposed Project, which would address potential impacts to federally listed special-status species and critical habitat not covered under the SJMSCP, including aquatic resources. USACE would consult with the U.S. Fish and Wildlife Service and National Marine Fisheries Service to identify and address potential impacts to federally listed species, critical habitats, and EFH. Additional measures that would be implemented to avoid impacts to aquatic resources or other non-SJMSCP-managed special-status species and habitats include Mitigation Measure 4.7.5b – Cover Bulk Stockpiles During the Rainy Season; Mitigation Measure 4.8.1a – Obtain and Comply with USACE Permit, Including Mitigation Requirements; Mitigation Measure 4.8.1b – Site Staging Areas Away from Waters; Mitigation Measure 4.8.1c – Use Standard BMPs to Avoid Accidental Fill of Waters; and Mitigation Measure 4.8.1d – Use Standard BMPs to Prevent Hazardous Releases.

The Proposed Project would involve operations along the shoreline and within the San Joaquin River, where special-status aquatic fish species not covered under the SJMSCP are known to occur, including southern DPS green sturgeon, delta smelt, Central Valley spring-run ESU Chinook salmon, Central Valley DPS steelhead, and longfin smelt. The project area additionally includes critical habitat for southern DPS green sturgeon, delta smelt, and Central Valley DPS steelhead and EFH for the Pacific Coast Salmon and Pacific Groundfish FMPs. The project area does not include any spawning habitat for these species or species associated with these FMPs, and their presence in the project area would likely be transitory. The WCDP EIR identifies potential impacts to aquatic species as

Denmar Addendum to the WCDP EIR 108 April 2021

including direct impacts from construction, habitat loss, increased maritime traffic, and water quality impacts from increased suspended sediment. These impacts may also occur as a result of the Proposed Project. Specific to special-status aquatic species habitat loss, the Proposed Project would result in only negligible loss from installation of the proposed fender system. Additional potential impacts from the Proposed Project not addressed in the WCDP EIR include water quality impacts from accidental spills and underwater noise effects of additional vessel traffic.

The Proposed Project would result in negligible impacts from riverine habitat loss, which would be consistent with or less than the impact conclusion presented in the WCDP EIR. Riverine habitat loss would be minimal, occurring only as a result of the very small fill impacts from the new fender system (approximately 0.01 acre). Construction does not entail bottom-disturbing activities (e.g., dredging or pile driving); therefore, short-term construction impacts from increased turbidity or suspended sediment would not occur. In addition to the water quality impacts considered in the WCDP EIR, construction of the Proposed Project has the potential to result in accidental spills, if improperly managed. Various contaminants, such as fuel oils, grease, and other petroleum products used in construction activities, could be introduced into aquatic environments either directly or through surface runoff. Contaminants in soils or groundwater could also potentially be introduced to the waterbody during remediation activities. Contaminants may be toxic to fish or cause altered oxygen diffusion rates and acute and chronic toxicity to aquatic organisms, thereby reducing growth and survival. To ensure that contaminants are not accidentally introduced into the waterway, the Proposed Project includes implementation of avoidance and minimization measures described in Appendix A, including but not limited to development and implementation of a Spill Prevention, Control, and Countermeasure Plan.

The Proposed Project would result in up to 200 additional annual vessel calls to Berths 18 and 19, which potentially could contribute to risks to listed aquatic special-status species occupying the action area waters through increased noise. Underwater noise source levels for container ships can range from less than 150 decibels (dB; referenced to 1 µPa2) at 1 meter to over 190 dB for the largest commercial vessels (USACE 2015b). These sound levels decrease with increasing distance from the source. Ship calls to the proposed Denmar facility would be bulk carriers with cargo capacities averaging 35,000 metric tons. Bulk carriers are anticipated to generate noise levels on the lower end of the spectrum identified for container ships, because of their smaller size and relatively low speed moving through the San Joaquin River. It is therefore unlikely that underwater sound from vessels calls to the proposed Denmar facility would result in physical injury to fish species. Fish would likely respond to vessel traffic by avoiding the area where noise effects (and increased suspended sediments and other temporary water quality changes) may occur. In the action area, the San Joaquin River measures 500 to 800 feet wide, providing sufficient area for any fish species to disperse from vessels calling on Berths 18 and 19. In consideration of the analysis of above and the associated

Denmar Addendum to the WCDP EIR 109 April 2021

WCDP analysis pertaining to special-status aquatic species, the Proposed Project would not adversely affect special-status fish species, critical habitats, or EFH.

Negligible effects to harbor seals could also occur as a result of the Proposed Project. In-water work and resultant fill in the San Joaquin River would be minimal, and avoidance and minimization measures would be implemented to avoid water quality impacts. Operational changes, including increases in vessel traffic, would not substantially alter conditions in the San Joaquin River, which already serves as a primary shipping corridor. Similar to fish species, it is anticipated that marine mammals would avoid areas of increased noise or suspended sediment caused by vessel traffic, and the San Joaquin River has enough space to accommodate this displacement. Therefore, impacts to marine mammals from the Proposed Project are not anticipated.

The above-described potential impacts are unlikely to result in adverse effects on any special-status species or habitats present or potentially present in the project area. As noted, the Proposed Project is anticipated to result in no more than negligible to minor short-term construction water quality impacts and long-term habitat loss or impacts from increased maritime traffic. These potential impacts are not among the primary threats identified for southern DPS green sturgeon, delta smelt, Central Valley spring-run ESU Chinook salmon, Central Valley DPS steelhead, or longfin smelt (Anchor QEA 2020b). Impacts to EFH for the Pacific Coast Salmon and Pacific Groundfish FMPs would similarly be minimal. As noted, impacts to marine mammals would also be negligible, and are not anticipated to result in any take as defined by the MMPA.

With implementation of the WCDP EIR-identified mitigation measures, there would be no new impacts to special-status species as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.7.5.4 Future development activities resulting from the Proposed Project may result in the alteration of, or disturbance to sensitive natural communities within the Sacramento San Joaquin Delta associated with an increased release of non-native aquatic organisms from ships. The WCDP EIR concluded that increased vessel traffic may result in ballast water releases that could carry non-native aquatic organisms. Impacts were considered significant and implementation of mitigation as identified in Appendix A, requiring continued implementation of the Ballast Water Management Plan, was required. Impacts were considered to remain significant and unavoidable after incorporation of mitigation.

Because the Proposed Project includes additional vessel calls to the West Complex, consistent with the WCDP EIR, there is the potential for release of non-native aquatic organisms from ballast water exchange. However, since the issuance of the WCDP EIR, the state has implemented new ballast water management requirements. The Marine Invasive Species Act, including the amendments

Denmar Addendum to the WCDP EIR 110 April 2021

effective January 1, 2020, applies to vessels that are 300 gross registered tons or more and capable of carrying ballast water. Vessels that would call on the Port as part of the Proposed Project would comply with these updated regulations, which are consistent with Mitigation Measure 4.8.4 – Continued Ballast Water Management Plan Implementation. Therefore, there would be no new impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.7.5.5 The Proposed Project may result in impacts to heritage trees as defined in the Stockton Municipal Code. The WCDP EIR concluded that compliance with the required Stockton Municipal Code Heritage Tree Ordinance would ensure impacts associated with removing heritage trees are less than significant.

Consistent with the WCDP EIR, heritage tree removal required as part of the Proposed Project would occur in compliance with the Stockton Municipal Code. Tree surveys identified 14 potential heritage oak trees (including trees with multiple leaders) within the project area (Anchor QEA 2020c), as shown in Figure 8 and detailed in Table 15.

Table 15 Heritage Oak Trees within the Project Area

Tree Diameter at Breast Height (Inches) Number Heritage Oak Tree Species (Single or Multiple Leaders) 1 Quercus lobata 31.5 2 Quercus agrifolia 14.3, 18.7 3 Quercus lobata 15.9,17.5, 14.1 4 Quercus lobata 8, 7 5 Quercus lobata 5 6 Quercus lobata 7.5 7 Quercus lobata 6 8 Quercus lobata 9 9 Quercus lobata 4, 5, 6 10 Quercus lobata 3 11 Quercus lobata 8, 6 12 Quercus lobata 8 13 Quercus lobata 9, 10, 11 14 Quercus lobata 6

Denmar Addendum to the WCDP EIR 111 April 2021 LEGEND: HT-4 through 14 Stockton Municipal Code Heritage Tree (See Table 1 for Details) Project Area

HUMPHREYS DR

CROMWELL AV

Table 1 Stockton M unicipal Code Heritage Trees in Study Area NOTE: Stockton Municipal Code heritage Diameter at Breast Height in Inches Figure Label Heritage Tree Species (Single or M ultiple Leaders) tree symbols are not to scale. The tree symbols for HT-1, HT-2, and HT-1 Valley oak (Quercus lobata) 31.5 HT-3 represent single Stockton HT-1 HT-3 HT-2 Coast live oak (Quercus agrifolia) 14.3, 18.7 Municipal Code heritage trees. The HT-3 Valley oak (Quercus lobata) 15.9, 17.5, 14.1 tree symbol for HT-4 through 14 HT-2 represents ten Stockton Municipal HT-4 Valley oak (Quercus lobate) 8, 7 Code heritage trees occurring in HT-5 Valley oak (Quercus lobate) 5 dense assemblage of multiple trees and tree species with thick HT-6 Valley oak 7.5 (Quercus lobate) understory. HT-7 Valley oak (Quercus lobate) 6 HT-8 Valley oak (Quercus lobate) 9 HT-9 Valley oak (Quercus lobate) 4, 5, 6 HT-10 Valley oak (Quercus lobate) 3 HT-11 Valley oak (Quercus lobate) 8, 6 HT-12 Valley oak (Quercus lobate) 8 0 1,000 FYFFE AV HT-13 Valley oak (Quercus lobate) 9, 10, 11 HT-14 Valley oak 6 (Quercus lobate) Feet

Figure 8 Stockton Municipal Code Heritage Trees Denmar Natural Soda Ash Export Terminal and Remedial Activities Addendum to the Port of Stockton West Complex Development Plan Environmental Impact Report

This analysis assumes that all of the 14 identified heritage trees would require removal as part of the Proposed Project. Compliance with the Stockton Municipal Code would include inspection of any potential heritage trees within the construction area by a certified arborist, and replacement of any heritage trees removed at a 1:1 ratio. Therefore, the Proposed Project would create no new or additional impact related to heritage trees, and the findings would be the same as those described in the WCDP EIR.

3.7.5.6 Construction activities in the Project Area could conflict with the SJMSCP. The WCDP EIR concluded that, to the extent that construction activities would not avoid, minimize, or mitigate impacts to special-status species, riparian habitat, or other sensitive natural communities, development of the West Complex would conflict with the conservation and protection goals of the SJMSCP. This would constitute a significant impact and implementation of mitigation as identified in Appendix A, including complying with the SJMSCP and avoiding and mitigating special-status species and habitat impacts, was required to reduce impacts to less-than-significant levels.

Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.8.2a – Comply with the SJMSCP, Mitigation Measure 4.8.2b – Conduct Special-Status Species and Habitat Avoidance and Mitigation, and Mitigation Measure 4.8.3 – Conduct Pre- Construction Rare Plant Surveys as part of project approval to avoid conflicting with the SJMSCP. As previously noted, Denmar would seek SJMSCP coverage for the Denmar terminal and the Port would seek SJMSCP coverage for the remediation footprint. Preliminary discussions with SJCOG have already occurred; and pre-construction plant surveys did not identify any potentially affected special- status plant species. Therefore, there would be no new impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.8 Cultural Resources Proposed Project- Significance Threshold WCDP EIR Findings Related Finding Less-than-Significant Less-than- Implementation of the Proposed Project may affect unknown, a. Impact with Significant Impact potentially significant prehistoric and historic resources. Mitigation with Mitigation The demolition of existing structures on Rough & Ready Significant and Island and development of new facilities within the Significant and b. Unavoidable potentially eligible historic district will substantially affect a Unavoidable Impact Impact historic resource.

3.8.1 Environmental Setting The WCDP EIR provides a framework for considering the impacts of the Proposed Project on sensitive cultural resources. The cultural and historical setting of the Port and its environs are

Denmar Addendum to the WCDP EIR 113 April 2021

described in the WCDP EIR (Section 4.9 of the DEIR). The following text provides updates to the environmental setting relevant to the Proposed Project.

Prior to historic land-making, the project site would have been seasonally inundated. Levees were constructed on Rough and Ready Island beginning in 1850, and the island was originally agricultural and residential; a 1917 journal article describes construction and testing of irrigation infrastructure for cattle ranching on the Island (JOE 1917). Rough and Ready Island became a Navy property in 1944 to serve the expanding needs of the Pacific theater in World War II. At some point prior to becoming a naval base, some industrial development took place on the island. A naval history indicated that:

The original plan called for the purchase and development of 824 acres, but by the end of the first year, 1419 acres were included in the station, and the remainder of the island – some 79 acres – was to be turned over to the Navy as soon as two oil companies, already established there, were able to develop facilities elsewhere (Navy 1947:306).

Neither the location of the oil companies on Rough and Ready Island nor the extent of their facilities is clear. Between 1943 and 1946, the northern boundary of the island was straightened to its current configuration (Figure 9). This was likely done by the Navy, though the process could have been started by the aforementioned oil companies. Various developments occurred across the island while the base was operated by the Navy. Facilities still present in the project area include steel warehouses 805 and 806, and transit sheds 803 and 704, Cromwell Avenue, and a rail line. The base was transferred to the Port between 2000 and 2010, and is now part of the Port’s West Complex.

The Navy constructed a landfill area on Rough and Ready Island in 1962, which is located in the western portion of the project site. The landfill area was used for construction and demolition debris, dredge spoils, fuels, medical waste, electronic waste, batteries, drummed waste, and municipal solid waste (presumably garbage collected from residences and administrative buildings on the island). The landfill area is divided into a Northern Landfill, used between 1968 and 1977; a Central Landfill, used between 1962 and 1979; and a Southern Landfill, used between 1940 and 1983. Each area of the landfill is further divided into areas and each area contains several cells where waste was contained. The Proposed Project includes excavation within (or within 20 feet of) the following cells: • Northern Landfill: Area IAS-11, Cells D, E, and F; Area IAS-12, Cell A; Area Site 37, Cell C • Southern Landfill: Area IAS-07, Cells P and Q; Area IAS-16, Cell M; Area Site 39, Cell N; Area IAS-03/04, Cell South

Table 16 shows the contents of the Landfill Cells where excavation would occur.

Denmar Addendum to the WCDP EIR 114 April 2021

Table 16 Rough and Ready Island Landfill Cell Contents

Approximate Depth Investigation Site Waste Types (feet bgs) Northern Landfill Areas (1968-1977) Disposal trenches containing primarily municipal solid waste IAS-11 2 to 8 and fuels IAS-12 Construction and demolition debris 2 to 5.5 Dredge spoils, fuels, construction and demolition debris, Site 37 2 to 7 burned debris Southern Landfill Areas (1940-1983) Municipal solid waste, construction and demolition debris, IAS-07 (Cells P and Q) 7 to 8 drum fragments, burned debris IAS-16 (Cell M) Medical supply waste, electronic debris, batteries 7 to 8 Site 39 (Cell N) Construction and demolition debris, drum fragments 7 to 8 IAS-03/04 Burned debris, demolition debris, electronic debris 3.5 to 5

Denmar Addendum to the WCDP EIR 115 April 2021

Figure 9 Historic Maps

Rough and Ready Island

Denmar Addendum to the WCDP EIR 116 April 2021

One cultural resource, the Naval Supply Annex Stockton National Historic District, has been identified in the study area. The district consists of 93 contributing historic structures and 13 non-contributing historic structures. Contributing structures include 38 warehouses and nine transit sheds, in addition to administrative structures, utilities, storage structures, and the Daggett Road Bridge. One archaeological site has been recorded within 1 mile of the project site. Site P-39-005178 is an isolated cobble tool located approximately 1 mile southwest of the project site on the mainland. Two archaeological surveys have occurred on Rough and Ready Island; both were outside the project site and neither located archaeological resources (BRAI 1996; Gross 2007). A 1996 evaluation of archaeological potential concluded that the island has “very low to low sensitivity for subsurface prehistoric archaeological resources” and “the potential for significant historical archaeological resources appears low” due to the landform setting and history (Uribe & Associates 1996:A-5-6). However, some potential for archaeological resources remains.

3.8.2 Regulatory Setting CEQA requires that lead agencies determine whether projects may have a significant effect on cultural resources. Cultural resources are defined as archaeological sites, elements of the historic built environment (e.g., buildings, structures, bridges, or other built features), and places of traditional cultural importance that meet one of the following criteria (14 CCR 15064.5): • Listed in or eligible for listing in the California Register of Historical Resources • Listed in a local preservation register • Identified as significant in a historical resource survey (unless the preponderance of evidence demonstrates that it is not historically or culturally significant) • Determined to be significant by the CEQA lead agency, provided the determination is supported by substantial evidence considering the whole record

CEQA emphasizes avoidance as the preferred means of reducing potential significant impacts. If avoidance is not feasible, mitigation must be developed.

3.8.3 Mitigation Measures The following mitigation measure from the WCDP EIR remains applicable to the Proposed Project: • Mitigation Measure 4.9.1: Inadvertent Discovery of Archaeological Resources

Details on this mitigation measure can be found in Appendix A.

3.8.4 Methods/Approach The cultural resources impact assessment references and updates the evaluation provided in the WCDP EIR. Because impacts to historic structures (and specifically the Naval Supply Annex Stockton National Historic District) and within the project site outside of the remediation area are within those

Denmar Addendum to the WCDP EIR 117 April 2021

described in the WCDP EIR, only potential impacts related to ground disturbance in the remediation area were considered in the updated evaluation. Potential impacts on archaeological resources were evaluated based on determining the potential for intact, significant archaeological resources in areas outside those analyzed in the WCDP EIR, and comparing that potential to the horizontal and vertical limits of ground disturbance.

3.8.5 Impact Assessment

3.8.5.1 Implementation of the Proposed Project may affect unknown, potentially significant prehistoric and historic resources. The WCDP EIR concluded that development that includes alterations of structures or subsurface excavations could impact previously unidentified prehistoric or historic cultural resources. Impacts were considered significant and implementation of mitigation as identified in Appendix A, requiring provisions for inadvertent discovery of prehistoric or historic cultural resources during construction, was required to reduce impacts to less-than-significant levels.

The Proposed Project would include construction-related ground disturbance throughout the project footprint. While construction-related ground disturbance was contemplated by the WCDP EIR, some of this activity, including construction of the rail line and associated structures and excavation of soils to support remediation activities, would occur in areas not specifically considered in the WCDP EIR. Ground disturbance in waste cell excavation areas would occur mostly within existing waste deposits. Native soils may be encountered beneath waste deposits, but are low-lying and unlikely to contain archaeological materials. Items older than 50 years may be encountered during excavation, though most items are likely more recent, especially in the Northern Landfill. The history of mixing industrial and municipal waste, as well as the practice of burning, indicates that intact significant archaeological deposits are unlikely.

Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.9.1: Inadvertent Discovery of Archaeological Resources as part of project approval to avoid impacts on potentially significant prehistoric and historic resources. Therefore, there would be no new impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.8.5.2 The demolition of existing structures on Rough & Ready Island and development of new facilities within the Naval Supply Annex Stockton National Historic District will substantially affect a historic resource. The WCDP EIR concluded that historic properties are present throughout Rough and Ready Island, and that removal or reuse of historic properties incidental to continued Port development constitutes a significant and unavoidable impact. It was determined that no further mitigation is feasible because

Denmar Addendum to the WCDP EIR 118 April 2021

the WCDP has been designed to make efficient use of all developed areas of the island, and restoration and reuse of historic structures would not result in an efficient configuration for future use. Furthermore, mitigation for the loss of the Naval Supply Annex Stockton National Historic District (consisting of Historic American Buildings Survey recordation) was completed by the Department of Defense under Section 106 of the National Historic Preservation Act prior to the transfer of the property to the Port.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR. Components of the Proposed Project, including demolition of the existing steel warehouses 805 and 806, and transit sheds 803 and 704, would result in significant and unavoidable impacts to historic resources, but the severity of these impacts would not exceed the analysis in the WCDP EIR. Therefore, the Proposed Project would create no new or additional impact related historic properties, and the findings would be the same as those described in the WCDP EIR.

3.9 Visual Resources Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Implementation of the Proposed Project will not affect scenic Less-than-Significant Less-than- a. vistas and scenic resources. Impact Significant Impact Implementation of the Proposed Project does not conflict Less-than-Significant Less-than- b. with adopted Plans and Policies relating to visual resources. Impact Significant Impact The Proposed Project has the potential to alter the existing Less-than-Significant Less-than- c. visual character of the site and its surroundings. Impact Significant Impact The Proposed Project could increase sources of light and Significant and Significant and d. glare that would adversely affect day or nighttime views in Unavoidable Unavoidable Impact the area. Impact

3.9.1 Environmental Setting The WCDP EIR provided a framework for considering the visual resource effects of the Proposed Project. The visual resources setting of the Port and its environs are described in the WCDP EIR (Section 4.10 of the DEIR) and remain largely unchanged. Visual receptors most sensitive to visual changes at the project site (or on the West Complex in general) are the local residents located directly across the Stockton DWSC, as identified in the WCDP EIR. Residents would be considered sensitive because of the duration of their exposure to any visual change, their familiarity with the existing landscape, and their ability to detect change. Other sensitive receptors would include visitors to Louis Park and the Stockton Country Club. There are no scenic vistas or significant visual resources within the project area.

Denmar Addendum to the WCDP EIR 119 April 2021

3.9.2 Regulatory Setting The City of Stockton General Plan was identified in the WCDP EIR, and remains applicable to the Proposed Project, but was updated in 2018. The 2040 General Plan (City 2018) establishes policies in the land use chapter that address visual quality, including urban design and aesthetics issues. The following policies and actions under the 2040 General Plan land use chapter may be applicable to the Proposed Project and visual resources:

• Policy LU-1.3: Improve the visual quality of the urban environment to be more welcoming and inviting at key gateways and travel corridors into the city. ‒ Action LU-1.3C: Require the incorporation of scenic views, including open space features like waterways, wetlands, natural landscapes, and parks, into design of the built environment. • Policy LU-5.1: Integrate nature into the city and maintain Stockton’s urban forest. ‒ Action LU-5.1A: Require renovated and new projects to provide open spaces that create gateways, act as collectors for pedestrian systems, and/or provide a social focal point for a project and the surrounding community and corridor, as appropriate. ‒ Action LU-5.1C: Require landscape plans to incorporate native and drought-tolerant plants in order to preserve the visual integrity of the landscape, conserve water, provide habitat conditions suitable for native vegetation, and ensure that a maximum number and variety of well-adapted plants are maintained. • Policy LU-5.3: Define discrete and clear city edges that preserve agriculture, open space, and scenic views. ‒ Action LU-5.3A: At the interface between development and rural landscapes, use landscaping and other attractive edging instead of soundwalls and similar utilitarian edges of developments to maintain the visual integrity of open space. • Policy LU-6.3: Ensure that all neighborhoods have access to well-maintained public facilities and utilities that meet community service needs. ‒ Action LU-6.3D: Design public facilities and infrastructure to maintain and improve the visual quality of the urban environment, including through the following approaches: • Designing buildings and infrastructure to fit into and complement their ultimate surroundings. • Buffering buildings and infrastructure from their surroundings as appropriate to shield unsightly areas from public view. • Providing appropriate landscaping.

Denmar Addendum to the WCDP EIR 120 April 2021

3.9.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.10.4a – Stationary overhead light fixtures shall be shaded and directed away from adjacent residential areas • Mitigation Measure 4.10.4b – Exterior lighting shall only be used where necessary for safety and security purposes

Details on these mitigation measures can be found in Appendix A.

3.9.4 Methods/Approach Impacts to visual resources were qualitatively evaluated based on the potential for the Proposed Project to temporarily or permanently alter the visual quality of the project area. To determine whether the Proposed Project would result in similar findings as those described in the WCDP EIR, physical changes associated with the Proposed Project were considered relative to both the development contemplated in the WCDP EIR and the regulatory setting changes since publication of the WCDP EIR. Relevant findings from the WCDP EIR pertaining to visual resources are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.9.5 Impact Assessment

3.9.5.1 Implementation of the Proposed Project will not affect scenic vistas and scenic resources. The WCDP EIR concluded that implementation of the WCDP would result in less-than-significant impacts from degradation of scenic vistas or scenic resources, based on the lack of scenic resources within or in proximity to the West Complex.

The most visible components of the Proposed Project would occur in the same area analyzed in the WCDP EIR, and scenic resources are still absent. There are no state scenic highways in the area, and thus scenic resources related to scenic highways would also not be damaged. Therefore, there would be no new impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.9.5.2 Implementation of the Proposed Project does not conflict with adopted Plans and Policies relating to visual resources. The WCDP EIR concluded that implementation of the WCDP does not conflict with any of the City’s General Plan goals and policies and would be visually compatible with the general concept of land use designations in the General Plan (City 1990). The WCDP EIR noted that any developments would

Denmar Addendum to the WCDP EIR 121 April 2021

be required to demonstrate consistency with General Plan policies for institutional land use. Impacts were considered less than significant.

The Proposed Project would entail construction and operations consistent with the findings in the WCDP EIR and would also be subject to local plans and policies. Although the 2040 General Plan update (City 2018) has been adopted since publication of the WCDP EIR, the land use designations at the West Complex remain unchanged, and updated policies for institutional land use do not affect the analysis or impact conclusion presented in the WCDP EIR. The Proposed Project is in an urbanized area and is consistent with applicable zoning.

The WCDP EIR assumed the area would include industrial and commercial structures that may reach five stories (or up to 75 feet) in height. While the Proposed Project includes construction of taller storage buildings (approximately 107 feet tall), the buildings would not conflict with land use designations or 2040 General Plan policies. Therefore, the Proposed Project would create no new or additional conflict with adopted plans and policies related to visual resources, and the findings would be the same as those described in the WCDP EIR.

3.9.5.3 The Proposed Project has the potential to alter the existing visual character of the site and its surroundings. The WCDP EIR evaluated impacts to visual and aesthetic resources within the project area and on views from Louis Park, Stockton Country Club, and residences located across the Stockton DWSC. It concluded that adherence with land use polices, design guidelines, and other provisions set forth in the General Plan and Stockton Municipal Code would ensure that implementation of the WCDP does not result in significant impacts to the visual character of the site and views from surrounding areas. Impacts were considered less than significant.

Views of the project site from adjacent areas on the West Complex would be consistent with changes described in the WCDP EIR, including the potential for conversion of open space area to commercial and industrial uses, upgrades to wharf facilities, and development of marine terminal and intermodal transfer facilities. Views of the project site from other areas on the West Complex would not affect the general public.

Views from surrounding areas are evaluated relative to the same receptors identified in the WCDP EIR. The Proposed Project would include construction of two storage buildings (Section 2.3) that would be taller than buildings contemplated in the WCDP EIR. While the two storage buildings are taller than the buildings identified in the WCDP EIR, building height was not the defining visual characteristic of the project area. The defining visual character of the area was Port-related industrial development uses. Although these taller buildings, the shiploaders, and other facilities constructed in the project site would be visible from residences, the Stockton Country Club, Louis Park, and other areas across the Stockton DWSC, these views are not currently considered scenic and the storage

Denmar Addendum to the WCDP EIR 122 April 2021

buildings would be consistent with the visual character of the area as identified in the WCDP. As noted in the WCDP EIR, in many cases these changes could be beneficial to the overall appearance of the area because blighted buildings would be replaced by modern facilities.

Shoreline areas adjacent to the project site are currently used for mooring and loading/offloading of vessels at the Port, and views of operations of the Proposed Project would be consistent with the current visual character of these adjacent areas. As a result of implementation of the Proposed Project, there would likely be a localized increase in loading and unloading ships, but these transitory activities would not change the existing industrial character of the waterfront or significantly alter off-site views toward the Port. This change is consistent with the changes contemplated in the WCDP EIR.

Small portions of the rail infrastructure constructed in the West Complex may also be periodically visible from workers in agricultural fields or local drivers along Burns Cutoff Road (which is not a through street)—both located to the east of Burns Cutoff. Rail infrastructure developed for the Proposed Project would be a visual change from the current undeveloped and open conditions in that area, but these views are largely obstructed by the levees along both sides of Burns Cutoff and adjacent trees and vegetation. The rail facilities would be lower and would mostly still be obstructed from view across Burns Cutoff.

The most visible portions of the Proposed Project would occur in the area analyzed in the WCDP EIR, and would also comply with General Plan policies and portions of the Stockton Municipal Code pertaining to visual character, including compliance with plans and policies that have been updated since release of the WCDP EIR. Therefore, there would be no new impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.9.5.4 The Proposed Project could increase sources of light and glare that would adversely affect day or nighttime views in the area. The WCDP EIR concluded that the projected increase in number of berthed vessels and number of days annually when vessels are berthed could result in a commensurate increase in light emissions from vessel exterior lights. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including minimizing exterior lighting, shading lighting, and directing lighting away from residences, was required. Impacts were considered to remain significant and unavoidable.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR, including incremental increases in vessel traffic and berth activities which may generate light emissions. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.10.4a – Shade and Direct New Lighting Away from Residences and Mitigation Measure 4.10.4b – Minimize Exterior Lighting as part of project approval. The changes described in Section 2.3, including the taller storage buildings and changes in the transportation mode mix, would not change the WCDP EIR analyses pertaining to light and glare. Therefore, the Proposed

Denmar Addendum to the WCDP EIR 123 April 2021

Project would create no new or additional impacts pertaining to light and glare, and the findings would be consistent with those described in the WCDP EIR.

3.10 Hazardous Materials and Public Health Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Construction activities in the Project Area or other facility Less-than-Significant Less-than- a. improvements could result in the disturbance of Impact with Significant Impact contaminated soil and/or groundwater. Mitigation with Mitigation Construction activities in the Project Area could result in Less-than-Significant Less-than- b. potential interference with properties undergoing soil and/or Impact with Significant Impact groundwater contamination clean-up activities. Mitigation with Mitigation Construction and renovation activities would involve the use and storage of hazardous materials such as gasoline and diesel fuels, oils, and solvents. The potential for an accidental Less-than-Significant Less-than- release exists during handling and transfer from one c. Impact with Significant Impact container to another. Depending on the relative hazard of the Mitigation with Mitigation hazardous material, if a spill were to occur of significant quantity, the accidental release could pose both a hazard to construction employees and the environment. Less-than-Significant Less-than- d. Risk of damage to overhead and underground utilities. Impact with Significant Impact Mitigation with Mitigation Exposure of individuals to the existing and/or potential future Less-than-Significant Less-than- e. use of hazardous materials and generation of hazardous Impact Significant Impact wastes. Implementation of the Proposed Project could result in Less-than-Significant Less-than- f. exposure of individuals to asbestos-containing dust and lead- Impact with Significant Impact based . Mitigation with Mitigation Implementation of the Proposed Project will not result in the Less-than-Significant Less-than- g. exposure of individuals to PCBs. Impact Significant Impact

3.10.1 Environmental Setting The WCDP EIR provides a framework for considering the hazardous materials and public health effects of the Proposed Project. The hazardous materials and public health setting of the Port and its environs is described in the WCDP EIR (Section 4.11 of the DEIR) and updated in this section. The setting description provided in the WCDP remains largely unchanged, although additional planning and data collection pertaining to contamination in the project area has occurred. Emergency response plans and other plans or regulations pertaining to hazards and hazardous materials have also been updated. The following text summarizes pertinent and updated context information for hazardous materials and public health relevant to the Proposed Project.

Denmar Addendum to the WCDP EIR 124 April 2021

The Port has been in coordination with DTSC and CVRWQCB to identify remedial actions within the western portion of Rough and Ready Island, including within the project area. Soil and groundwater contamination conditions are associated with past uses of the island, including farming and bulk petroleum storage and Navy use prior to Port transfer. As detailed in Section 2, portions of the project site are located within Remediation Sites within the Landfill Area. The Final Focused Feasibility Study, Landfill Area (Geosyntec 2021) documented the theoretical health and environmental risks from possible exposures to contaminants of concern (COCs) in soils, which were evaluated in a two- step process. First, the Preliminary Risk Assessment identified COCs based on the historical soil dataset for the Landfill Area and determined that further investigation was warranted to address spatial data gaps and more accurately assess risks. Following completion of a 2020 investigation, a second step, referred to as the Supplemental Risk Evaluation, was performed to determine if additional areas of the Landfill Area warranted remedial actions. These risk evaluations identified the following COCs:

• Future industrial worker – lead, Aroclor-1260, dioxins, and the congeners of dichloro- diphenyl-dichloroethylene (DDD), dichloro-diphenyl-dichloroethane (DDE), and dichloro- diphenyl-trichloroethane (DDT) • Wildlife receptors – four metals (i.e., copper, lead, mercury, and zinc), Aroclor-1260, dioxins, and the congeners of DDD, DDE, and DDT

The Supplemental Risk Evaluation identified areas where COC concentrations required remedial actions (i.e., areas of known contamination), which are described in Sections 2.3.1 and 2.3.3.

Concurrent to design and construction of the Denmar terminal, the Port is working with DTSC and CVRWQCB to identify remedial actions to be taken to address Remediation Sites as part of the Proposed Project pursuant to CERCLA. This includes initial remediation focused on solid waste and contaminated soils in the sites on or near the Denmar terminal areas; and future remediation to address the remaining Landfill Cells and Remedial Sites. As described in Sections 2.3.1 and 2.3.3, remediation involves excavation and consolidation of contaminated material and installation of soil covers.

Potential hazardous material sites occurring within or around the project site were also identified through a search of the DTSC EnviroStor and SWRCB GeoTracker database websites (DTSC 2020; SWRCB 2020). Within a 1.5-mile radius of the project site (center point at intersection of Humphrey Street and Embarcadero), the EnviroStor database lists four cleanup sites and the GeoTracker database identifies 42 cleanup sites with active, open, or unidentified statuses. The GeoTracker database additionally identifies three permitted underground storage tanks within the 1.5-mile radius. Consistent with the previously described site conditions, the project area includes several GeoTracker cleanup sites identified as Military Privatized Sites.

Denmar Addendum to the WCDP EIR 125 April 2021

Portions of the project site are within the Former Naval Computer and Telecommunications Station Land Use Covenant (LUC) area, which encompasses approximately 500 acres of Rough and Ready Island (Port, DTSC, and CVRWQCB 2003). Within its coverage area, the LUC prohibits land uses including residences, hospitals, schools for persons under 18 years of age, daycare centers for children, uses that cover or prevent access to groundwater monitoring wells, uses that would restrict remedial investigations or actions, and activities that would affect groundwater or soils without appropriate state or federal approvals.

In addition, under existing operating conditions on the West Complex, the Port and Port tenants continue to store and use potentially hazardous materials including but not limited to adhesives, lubricants, , solvents, oils, and fuels in underground storage tanks, as described in the WCDP EIR. Older buildings located on the island could contain asbestos or lead-based paints. This may include the warehouses and transit sheds that would be demolished as part of the Proposed Project.

3.10.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• Resource Conservation and Recovery Act (RCRA). The RCRA remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • Hazardous Materials Transportation Act. The Hazardous Materials Transportation Act remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • State Hazardous Waste Control Law. The State Hazardous Waste Control Law remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • California Hazardous Materials Release Response Plans and Inventory Law. The California Hazardous Materials Release Response Plans and Inventory Law remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. This state right-to-know law requires businesses to develop a Hazardous Materials Management Plan (HMMP) or a business plan for hazardous materials emergencies if they handle more than 500 pounds, 55 gallons, or 200 cubic feet of hazardous materials. The HMMP or business plan must be submitted to the Certified Unified Program Agency (CUPA), in this case, the County Public Health Services, Environmental Health Division (SJCEHD). • California Hazardous Materials Release Response Plans and Inventory Law. The California Hazardous Materials Release Response Plans and Inventory Law remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. As detailed in the WCDP EIR, Hazardous Materials Business Plans are required to

Denmar Addendum to the WCDP EIR 126 April 2021

inventory hazardous materials stored and used on site, disclose the location of storage and use on site, maintain an emergency response plan, and contain provisions specifying employee training in safety and emergency response procedures. • Occupational Health and Safety, including 29 CFR. Consistent with the WCDP EIR, the California Division of Occupational Safety and Health (Cal/OSHA) and OSHA remain responsible for assuring worker safety in the handling and use of chemicals in the workplace. Under its federally approved OSHA program, Cal/OSHA has adopted regulations that are equal or more stringent than federal regulations. OSHA and Cal/OSHA regulations have been regularly updated since publication of the WCDP EIR, although revisions do not substantively change the analyses provided in that document. Cal/OSHA regulations concerning the use of hazardous materials in the workplace, as detailed in 8 CCR, include requirements for safety training, availability of safety equipment, accident and illness prevention programs, hazardous substance exposure warnings, and emergency action and fire prevention plan preparation. Cal/OSHA enforces hazard communication program regulations that contain training and information requirements, including procedures for identifying and labeling hazardous substances, communicating hazard information related to hazardous substances and their handling, and preparation of health and safety plans to protect workers and employees at hazardous waste sites. The hazard communication program requires that Material Safety Data Sheets be available to employees and that employee information and training programs be documented. • California Accidental Release Prevention (CalARP) Program. The CalARP program remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP EIR. • California Health and Safety Code (CHSC) Section 25500. CHSC Section 25500 remains applicable to the Proposed Project and substantively unchanged from the description provided in the WCDP.

Additional regulations, plans, and policies applicable to the Proposed Project and pertaining to hazardous materials and public health include the following:

• CHSC Chapter 13 (Standards Applicable to Transporters of Hazardous Waste) (22 CCR 66263.10–66263.50). These regulations establish standards that apply to persons transporting hazardous waste within, into, out of, or through the state if the transportation requires a manifest under the CHSC Section 25160. “Transporter” means a person engaged in the off-site transportation (or movement) of hazardous waste by air, rail, highway, or water. This hazardous waste regulation applies to carriers transporting hazardous waste when that waste is subject to the manifesting requirements of CHSC Chapter 12. In general, transporters of hazardous waste must comply with these requirements and statutory requirements in CHSC, Division 20, Chapter 6.5, Articles 6 and 6.5, as well as the specific U.S. Department of Transportation requirements referenced throughout the transporter regulations.

Denmar Addendum to the WCDP EIR 127 April 2021

• Emergency Planning and Community Right-to-Know Act (42 USC 11001 et seq.). Also known as Title III of the Superfund Amendments and Reauthorization Act, the Emergency Planning and Community Right-to-Know Act (EPCRA) was enacted by Congress as the national legislation on community safety. This law was designated to help local communities protect public health, safety, and the environment from chemical hazards. To implement EPCRA, Congress required each state to appoint a State Emergency Response Commission. These commissions were required to divide their states into Emergency Planning Districts and to name a Local Emergency Planning Committee for each district. EPCRA provides requirements for emergency release notification, chemical inventory reporting, and toxic release inventories for facilities that handle chemicals. • City of Stockton General Plan. The City updated and adopted its 2040 General Plan (City 2018) on December 4, 2018, which includes the following policies specific to hazardous materials: ‒ Policy SAF-2.6. Minimize the risk to City residents and property associated with the transport, distribution, use, and storage of hazardous materials. • Action SAF-2.6A. Restrict transport of hazardous materials within the City to routes that have been designated for such transport. • Action SAF-2.6B. When appropriate, require new development to prepare a hazardous materials inventory and/or prepare Phase I or Phase II hazardous materials studies, including any required cleanup measures. • Action SAF-2.6C. Educate the public regarding the types of household hazardous wastes and the proper methods of disposal. • Unified Hazardous Waste and Hazardous Management Regulatory Program (SB 1082, 1993) and County Public Health Services. The Unified Hazardous Waste and Hazardous Management Regulatory Program (SB 1082, 1993) is a state and local effort to consolidate, coordinate, and make consistent existing programs regulating hazardous waste and hazardous materials management. The California Environmental Protection Agency adopted implementing regulations for the Unified Program (27 CCR, Division 1, Subdivision 4, Chapter 1) in January 1996. The Unified Program is implemented at the local level by CUPAs.

SJCEHD is the CUPA for all cities and unincorporated areas within the County. The concept of a CUPA was created by the California legislature to minimize the number of inspections and different fees for businesses. SJCEHD provides the management and recordkeeping of hazardous materials and underground storage tank sites for the County, including the City. Through the Hazardous Materials Program, SJCEHD inspects businesses for compliance with the Hazardous Waste Control Act. Hazardous waste is subject to storage time limits, disposal requirements, and container labeling requirements.

Denmar Addendum to the WCDP EIR 128 April 2021

• San Joaquin County Emergency Operations Plan. Regional plans pertaining to hazardous materials have been updated since publication of the WCDP EIR. The County Office of Emergency Services authored the 2019 San Joaquin County Emergency Operations Plan (2019 EOP; SJCOES 2019b), which addresses the County’s response to all hazards, including incident management structure, compliance with relevant legal statutes and other relevant guidelines, whole community engagement, continuity of government focus, and critical components of the incident management structure. The 2019 EOP includes response protocol specific to hazards and hazardous materials.

3.10.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.11.1a – Review of Past and Current Uses, Records of Known Contamination and Hazardous Materials Usage, and Hazardous Waste Generation • Mitigation Measure 4.11.1b – Halt Work if Unidentified Contaminated Soil or Groundwater Are Encountered • Mitigation Measure 4.11.2 – Ensure Site Access for Remediation Activities • Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures During Construction • Mitigation Measure 4.11.4a – Ensure Precautions to Avoid Contact with Aerial Lines • Mitigation Measure 4.11.4b – Identify and Avoid Utilities During Construction • Mitigation Measure 4.11.5 – Comply with Asbestos and Lead Requirements • Mitigation Measure 4.11.6 – Additional Compliance with Asbestos and Lead Requirements

Details on these mitigation measures can be found in Appendix A.

3.10.4 Methods/Approach Impacts pertaining to hazards and hazardous materials were assessed based on the potential for the Proposed Project to affect existing hazardous material conditions recorded on and off site; existing and planned emergency action plans; and siting relative to schools, residents, airports, or other sensitive receptors. Relevant findings from the WCDP EIR pertaining to hazardous materials and public health are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

Denmar Addendum to the WCDP EIR 129 April 2021

3.10.5 Impact Assessment

3.10.5.1 Construction activities in the Project Area or other facility improvements could result in the disturbance of contaminated soil and/or groundwater. The WCDP EIR concluded that ground-disturbing construction activities may encounter contaminated soil and groundwater, which could result in adverse health effects from worker exposure. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including characterizing and remediating hazardous sites and requirements for hazardous materials encountered during construction, was required to reduce impacts to less-than- significant levels.

The Proposed Project would entail construction consistent with the evaluation in the WCDP EIR. The Proposed Project includes ground disturbance within Remediation Sites, which could expose individuals or the environment to contaminants if improperly managed. Construction activities could also potentially uncover currently unknown conditions of contamination. Consistent with the findings of the WCDP EIR, the Port would require implementation of Mitigation Measure 4.11.1a – Review of Past and Current Uses, Records of Known Contamination and Hazardous Materials Usage, and Hazardous Waste Generation and Mitigation Measure 4.11.1b – Halt Work if Unidentified Contaminated Soil or Groundwater Are Encountered as part of project approval.

The Port is working with DTSC and CVRWQCB to identify remedial actions to be taken to address Remediation Sites consistent with CERCLA and pursuant to Chapter 6.8 of the CHSC, which would further consider and address the potential for disturbance of contaminated soil or groundwater through appropriate construction procedures. This would include adherence to OSHA and Cal/OSHA regulations pertaining to hazardous materials, including but not limited to safety training, availability of safety equipment, accident and illness prevention programs, hazardous substance exposure warnings, and emergency actions. All remediation contractors would be required to have completed 40-hour HAZWOPER training. A Health and Safety Plan would be developed and implemented to address potential hazards associated with the remedy implementation. Remedial actions would provide a long-term benefit to the environment and would minimize the potential for future exposure of individuals and the environment to contaminated soil or groundwater.

In accordance with the 2003 Consent Agreement, a RAP and RDIP would be prepared presenting the regulatory framework and technical basis for the selected remedy. The RDIP would include a schedule for remedy implementation, including preparation, review, and approval of documents, construction activities, and an initial schedule of post-remedy maintenance. State review and approval of the RAP would be required, including a period for public comment.

Denmar Addendum to the WCDP EIR 130 April 2021

Based on the analysis presented above, and with implementation of appropriate mitigation measures, there would be no additional impacts as a result of the Proposed Project, and the findings would be the same as those described in the WCDP EIR.

3.10.5.2 Construction activities in the Project Area could result in potential interference with properties undergoing soil and/or groundwater contamination clean-up activities. The WCDP EIR concluded that development activities could potentially interfere with remediation investigations or actions within the West Complex. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including project-specific evaluations and coordination to ensure that easements or accesses for operation of investigative or remedial systems are maintained, was required to reduce impacts to less-than-significant levels.

Remediation sites are present throughout the western portion of the project area, and remediation of soils at these sites is a component of the Proposed Project. The EnviroStor (DTSC 2020) and GeoTracker (SWRCB 2020) databases also identify several cleanup sites near the project site. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.11.2 – Ensure Site Access for Remediation Activities as part of project approval. The Landfill Area is subject to the Former Naval Computer and Telecommunications Station LUC, which specifies that the site is not allowed to have “…any use that would restrict investigation activities, remedial actions, or long-term maintenance and operations” (Port, DTSC, and CVRWQCB 2003). To ensure compliance with the LUC, the Denmar terminal was designed to include roads that would provide access to the rail line and throughout the Landfill Area, and terminal operations would include procedures to ensure continued access for remediation purposes. The presence of rail lines and other facilities can complicate groundwater investigation and remediation activities. To ensure the site’s use does not restrict such activities, rail operations would accommodate installation of soil borings, wells, and other investigation activities and would enable remedial activities as required. If the area of interest is located under the rail line footprint or other facilities, investigatory drilling activities and well installation may be conducted using slant drilling techniques at locations outside the rail line footprint or at locations within access roads between the rail lines.

The Proposed Project’s soil remediation activities would be completed in coordination with DTSC and CVRWQCB, further ensuring that any other ongoing or future remediation projects would not be adversely affected. Therefore, the Proposed Project would create no new or additional impact related to interference with remediation activities, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 131 April 2021

3.10.5.3 Construction and renovation activities would involve the use and storage of hazardous materials such as gasoline and diesel fuels, oils, and solvents. The potential for an accidental release exists during handling and transfer from one container to another. Depending on the relative hazard of the hazardous material, if a spill were to occur of significant quantity, the accidental release could pose both a hazard to construction employees and the environment. The WCDP EIR concluded that construction would require the use of potentially hazardous substances (e.g., gasoline, diesel fuel, oils, solvents, and hydraulic fluid), which if improperly maintained could result in adverse impacts. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including implementing spill containment and countermeasures during construction, was required to reduce impacts to less-than-significant levels.

The Proposed Project would include construction activities requiring the use of hazardous materials. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.11.3 – Implement Spill Containment and Countermeasures During Construction as part of project approval. The 2019 EOP provides additional response protocol specific to hazards and hazardous materials, and the Proposed Project would not interfere with this or other emergency response plans. There are no airports or airfields in the vicinity of the project site, and the nearest school is located approximately 1.15 miles northeast of Berths 18 and 19; therefore, these potential receptors would be unaffected in the event of a construction accident. Based on this analysis, the Proposed Project would create no new or additional impact related to accidental release of hazardous substances during construction, and the findings would be the same as those described in the WCDP EIR.

3.10.5.4 Risk of damage to overhead and underground utilities. The WCDP EIR concluded that construction could damage above and below-ground utilities, which may endanger individuals or interrupt essential public services. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including ensuring precautions to avoid contact with aerial lines and utilities during construction, was required to reduce impacts to less-than-significant levels.

The Proposed Project would involve construction that could potentially damage utilities in the vicinity of planned improvements. As part of the Proposed Project, upland existing utilities and infrastructure would either be abandoned or relocated depending on final Denmar terminal design, including electrical, sanitary sewer, water, stormwater lines, catch basins, manholes, communications and power distribution. Utility work would include a combination of horizontal directional drilling and open cutting of trenches to access and remove existing utilities, and installation of new utilities. Utility poles would also be installed to convey electricity, and possible telecommunications, which would tie into existing systems. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.11.4a – Ensure

Denmar Addendum to the WCDP EIR 132 April 2021

Precautions to Avoid Contact with Aerial Lines and Mitigation Measure 4.11.4b – Identify and Avoid Utilities During Construction as part of project approval. Therefore, the Proposed Project would create no new or additional impact related to damage of utilities, and the findings would be the same as those described in the WCDP EIR.

3.10.5.5 Exposure of individuals to the existing and/or potential future use of hazardous materials and generation of hazardous wastes. The WCDP EIR concluded that existing and future businesses operating in the West Complex may use or generate hazardous materials during operations. Potential adverse impacts associated with management of such materials would be avoided through adherence with federal, state, and local regulations, including but not limited to maintaining hazardous waste inventories, complying with building and fire codes, and providing storage and shipment of potentially hazardous materials per regulatory requirements. The WCDP EIR also identifies City and County provisions for emergency response for accidental release of hazardous materials. Impacts were considered less than significant.

The Denmar terminal would receive, store, and transfer soda ash. Soda ash is not classified as being flammable, combustible, explosive, or toxic by OSHA, and it is categorized as a generally recognized as safe substance for use in foods by the U.S. Food and Drug Administration. Limited quantities of potentially hazardous materials may be used on site (e.g., gasoline, diesel fuel, oils, solvents, and hydraulic fluid). Under the Proposed Project, management of these materials would comply with all applicable federal, state, and local regulations. Local and regional emergency response procedures would continue to apply to the Denmar terminal and throughout the West Complex, including the 2019 EOP. While there have been minor revisions to regulations and response procedures since publication of the WCDP EIR, these do not substantially change the analysis presented therein. To further minimize potential impacts from soda ash management, stormwater drainage holes on the existing docks would be modified to contain any stormwater that comes into contact with soda ash, which would be conveyed to a new stormwater retention pond and pre-treatment system prior to discharge to the existing stormwater system.

Proposed remediation includes initial remediation activities focused on solid waste and contaminated soils in the sites on or near the Denmar terminal areas and future remediation activities that would address the remaining Landfill Cells and Remedial Sites. As described in Sections 2.3.1 and 2.3.3, remediation involves excavation and consolidation of contaminated material and installation of soil covers. As noted in Section 3.10.5.1, a RAP and RDIP would be prepared presenting the regulatory framework and technical basis for the selected remedy. The RDIP would include a schedule for remedy implementation, including preparation, review, and approval of documents; construction activities; and an initial schedule of post-remedy maintenance. Among other documents, a Health and Safety Plan would be developed and implemented to address

Denmar Addendum to the WCDP EIR 133 April 2021

potential hazards associated with the remedy implementation. Remediation would provide a long- term benefit by reducing the potential for release of hazardous materials.

The project site is not in the vicinity of any airports or airfields, and the nearest school is located approximately 1.15 miles northeast of Berths 18 and 19; therefore, these potential receptors would likely be unaffected by hazardous material use at the proposed facility. The project site is not within any fire hazard severity zones (Los Padres ForestWatch 2020), and on-site use of hazardous materials would therefore not exacerbate any wildfire hazards.

Based on the analysis presented above, the Proposed Project would create no new or additional impact related to use of hazardous materials and generation of hazardous waste, and the findings would be the same as those described in the WCDP EIR.

3.10.5.6 Implementation of the Proposed Project could result in exposure of individuals to asbestos-containing dust and lead-based paint. The WCDP EIR concluded that indiscriminate and unmitigated renovation or demolition of structures on the West Complex could expose workers or the surrounding public to asbestos-containing dust and lead-based paint. Impacts were considered significant and implementation of mitigation as identified in Appendix A was required to reduce impacts to less-than-significant levels. These measures include complying with National Emission Standards for Hazardous Air Pollutants and SJVAPCD requirements regarding the handling and disposal of asbestos-containing materials as well as complying with Cal/OSHA requirements regarding lead-related construction activities.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR. Proposed demolition of the warehouses and transit sheds or other construction activities could expose individuals to asbestos or lead paint. Consistent with the WCDP EIR, the Port would require implementation of Mitigation Measure 4.11.5 – Comply with Asbestos and Lead Requirements and Mitigation Measure 4.11.6 – Additional Compliance with Asbestos and Lead Requirements as part of project approval. Therefore, the Proposed Project would create no new or additional impact related to asbestos or lead exposure, and the findings would be the same as those described in the WCDP EIR.

3.10.5.7 Implementation of the Proposed Project will not result in the exposure of individuals to PCBs. The WCDP EIR concluded that the risk of PCB exposure is minimal because all PCB equipment or contaminated equipment containing PCB levels of 50 parts per million or greater were removed from the West Complex in 1990 during Naval Communications Station Stockton ownership and management. Impacts were considered less than significant.

Denmar Addendum to the WCDP EIR 134 April 2021

Although the Proposed Project would occur within the area analyzed in the WCDP EIR, the PCB compound Aroclor-1260 is potentially present in soils and would be addressed as part of the proposed remediation (Geosyntec 2021). Aroclor-1260 is potentially hazardous to humans and wildlife. As described in Section 3.10.5.1, human exposure would be controlled during remediation through implementation of safety protocols. Remediation activities would reduce hazards from Aroclor-1260 to below established thresholds. Therefore, the Proposed Project would create no new or additional impact related to PCB exposure, and the findings would be the same as those described in the WCDP EIR.

3.11 Public Services and Utilities Proposed Project- Significance Threshold WCDP EIR Findings Related Findings Implementation of the Proposed Project would not Less-than-Significant Less-than- necessitate a new or expanded fire station; however, the a. Impact with Significant Impact Proposed Project may necessitate upgrades to the existing Mitigation with Mitigation non-potable water system. Implementation of the Proposed Project would not substantially affect law enforcement services and would not Less-than-Significant Less-than- b. necessitate new or expanded governmental facilities for Impact Significant Impact provision of police services. Implementation of the Proposed Project would not Less-than-Significant Less-than- c. substantially affect parks. Impact Significant Impact Implementation of the Proposed Project would not Less-than-Significant Less-than- d. substantially affect schools. Impact Significant Impact Implementation of the Proposed Project has the potential to Less-than-Significant Less-than- e. impact wastewater service. Impact Significant Impact Less-than-Significant Less-than- Implementation of the Proposed Project has the potential to f. Impact with Significant Impact result in impacts to the potable water supply. Mitigation with Mitigation Less-than-Significant Less-than- Implementation of the Proposed Project could result in g. Impact with Significant Impact impacts to the water distribution infrastructure system. Mitigation with Mitigation Implementation of the Proposed Project would not result in Less-than-Significant Less-than- h. insufficient capacity at an existing landfill. Impact Significant Impact

3.11.1 Environmental Setting The WCDP EIR provided a framework for considering the public services and utilities effects of the Proposed Project. The public services and utilities setting of the Port and its environs are described in the WCDP EIR (Section 4.12 of the DEIR) and updated in this section. The following text summarizes context information for public services and utilities relevant to the Proposed Project.

Denmar Addendum to the WCDP EIR 135 April 2021

As described in the WCDP EIR, the Port and the project site continue to be adequately served by existing public services and utilities. The WCDP EIR describes several planned or in-progress projects and actions relevant to public services and utilities that have now been completed, including testing and upgrades to the West Complex non-potable water system and fire protection system and wastewater system. The City’s Delta Water Supply Project, one of the actions described under Future Water Supplies in the WCDP EIR, was also completed in 2012, providing the City with a reliable water supply to meet both current and future water needs (City 2020c).

Additionally, the Lyons Golf Course, described in the WCDP EIR, closed in 2009 because of low usage (Highfill 2010). However, the parks and other recreational facilities in the City and surrounding area continue to provide adequate recreational capacity.

3.11.2 Regulatory Setting The following regulations, plans, and policies identified in the WCDP EIR remain applicable to the Proposed Project, with minor revisions noted:

• City General Plan (City 1990), 2035 General Plan (City 2007), and 2040 General Plan (City 2018). The General Plan and its successors, the 2035 General Plan and 2040 General Plan, are the documents that used by the City as the primary documents governing policy for provision of public services and utilities. The following 2040 General Plan goals and policies are relevant to the public services and utilities analysis of the Proposed Project: ‒ Goal LU-5: Protected Resources, Protect, maintain, and restore natural and cultural resources • Policy LU-5.2: Protect natural resource areas, fish and wildlife habitat, scenic areas, open space areas, agricultural lands, parks, and other cultural/historic resources from encroachment or destruction by incompatible development. ‒ Goal LU-6: Effective Planning, Provide for orderly, well-planned, and balanced development. • Policy LU-6.1: Carefully plan for future development and proactively mitigate potential impacts. ‒ Action LU-6.1D: Require that all utility connections outside the city limit be for land uses that are consistent with the General Plan. ‒ Action LU-6.1E: Do not approve new development unless there is infrastructure in place or planned and funded to support the growth. ‒ Action LU-6.1G: Maintain adequate staffing levels to support achieving the City’s service level goals for police and fire protection. • Policy LU-6.3: Ensure that all neighborhoods have access to well-maintained public facilities and utilities that meet community service needs.

Denmar Addendum to the WCDP EIR 136 April 2021

‒ Action LU-6.3A: Require development to mitigate any impacts to existing sewer, water, stormwater, street, fire station, park, or library infrastructure that would reduce service levels. ‒ Goal SAF-3: Clean Water, Sustain clean and adequate water supplies. • Policy SAF-3.1: Secure long-term renewable contracts and related agreements to ensure that surface water rights will be available to meet projected demand. ‒ Action SAF-3.1A: Actively participate in appropriate forums designed to discuss and solve regional water supply and quality issues. • Policy SAF-3.2: Protect the availability of clean potable water from groundwater sources. ‒ Action SAF-3.2A: Continue to cooperate with San Joaquin County, Stockton East Water District, and CalWater to monitor groundwater withdrawals and ensure that they fall within the target yield for the drinking water aquifer. • Policy SAF-3.4: Ensure adequate collection, treatment, and safe disposal of wastewater. ‒ Action SAF-3.4A: Require all new urban development to be served by an adequate wastewater collection system to avoid possible contamination of groundwater from on-site wastewater disposal systems. ‒ Action SAF-3.4C: Continue to discharge treated effluent to the Delta and reuse that water through the City’s California Water Code Section 1485 water right. ‒ Goal CH-1: Healthy People, Support the ability of the entire community to maintain healthy lifestyles. • Policy CH-3.4: Foster innovation through access to quality community education and library services.

3.11.3 Mitigation Measures The following mitigation measures from the WCDP EIR remain applicable to the Proposed Project: • Mitigation Measure 4.12.6 – Assess and Manage Potable Water Demands • Mitigation Measure 4.12.7 – Upgrade Potable Water System

Details on the mitigation measures can be found in Appendix A.

3.11.4 Methods/Approach Impacts to or associated with public services and utilities were qualitatively evaluated based on the potential for the Proposed Project to require new construction, modification, or expansion of facilities for provision of public services and utilities. Relevant findings from the WCDP EIR pertaining

Denmar Addendum to the WCDP EIR 137 April 2021

to public services and utilities are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.11.5 Impact Assessment

3.11.5.1 Implementation of the Proposed Project would not necessitate a new or expanded fire station; however, the Proposed Project may necessitate upgrades to the existing non-potable water system. The WCDP EIR concluded that, while existing fire response capacity was sufficient, there could potentially be adverse impacts related to flow restrictions in the non-potable water system. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including requiring the Port to perform an assessment and as-needed upgrades to the non-potable water system on a project-by-project basis or as part of a master plan, as well as to meet fire protection needs, was required to reduce impacts to less-than-significant levels.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR, would not generate fire system demand beyond the analysis presented therein, and would therefore not result in a need for new or physically altered governmental facilities. Existing non-potable water system flows are sufficient to provide fire service for the Proposed Project, and new water hookups would be added as part of the Proposed Project for firefighting access to non-potable water at the project site. In consideration of the WCDP EIR mitigation measures already implemented by the Port and the Proposed Project’s consistency with the WCDP EIR analysis, there would be no new or additional impact related to non-potable water system flows, and the findings would be the same as those described in the WCDP EIR.

3.11.5.2 Implementation of the Proposed Project would not substantially affect law enforcement services and would not necessitate new or expanded governmental facilities for provision of police services. The WCDP EIR concluded that development activities could result in incremental increase in demand for law enforcement but would not require new or expanded police facilities. Impacts were considered less than significant.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR and would generate nominal incremental demand on police service, and would not result in a need for new or physically altered governmental facilities. Therefore, the Proposed Project would result in no new or additional impacts related to police service, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 138 April 2021

3.11.5.3 Implementation of the Proposed Project would not substantially affect parks. The WCDP EIR concluded that development activities could result in incremental increase in demand for parks, but that General Plan policies include measures pertaining to park development to accommodate the City’s needs. Impacts were considered less than significant.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR, would generate nominal incremental demand on parks, and would therefore neither result in a need for new, physically altered, or expanded parks or other recreational facilities nor cause or accelerate substantial physical deterioration of existing parks or other recreational facilities. Although policies have been updated with adoption of the 2040 General Plan (City 2018), measures pertaining to park development remain in place and the analysis presented in the WCDP EIR remains relevant. Therefore, the Proposed Project would result in no new or additional impacts related to parks, and the findings would be the same as those described in the WCDP EIR.

3.11.5.4 Implementation of the Proposed Project would not substantially affect schools. The WCDP EIR concluded that development activities could result in incremental increase in demand for schools, but that General Plan policies include measures pertaining to the development of new schools to accommodate the City’s needs. Impacts were considered less than significant.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR, would generate nominal incremental demand on schools, and would therefore not result in a need for new or physically altered governmental facilities. Although policies have been updated with adoption of the 2040 General Plan (City 2018), measures pertaining to the development of new schools remain in place and the analysis presented in the WCDP EIR remains relevant. Therefore, the Proposed Project would result in no new or additional impacts related to schools, and the findings would be the same as those described in the WCDP EIR.

3.11.5.5 Implementation of the Proposed Project has the potential to impact wastewater service. The WCDP EIR concluded that the City’s Regional Wastewater Control Facility has sufficient capacity to accommodate the wastewater demands from implementation of the WCDP. Impacts were considered less than significant.

This analysis remains applicable to the Proposed Project, which would generate nominal incremental demand on wastewater service consistent with the evaluation in the WCDP EIR. Therefore, the Proposed Project would result in no new or additional impacts related to wastewater service, and would neither require relocation or construction of new or expanded facilities nor result in a determination by the wastewater treatment provider which serves or may serve the project that it

Denmar Addendum to the WCDP EIR 139 April 2021

does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. Therefore, the Proposed Project would result in no new or additional impacts, and the findings would be the same as those described in the WCDP EIR.

3.11.5.6 Implementation of the Proposed Project has the potential to result in impacts to the potable water supply. The WCDP EIR concluded that existing groundwater overdraft conditions represent a potentially significant impact on the availability of potable water. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including requiring the Port to assess and manage potable water demands, was required to reduce impacts to less-than-significant levels.

The Proposed Project would entail operations consistent with the evaluation in the WCDP EIR and would generate nominal incremental demand on potable water. The Proposed Project’s incremental demand on potable water would be addressed through the Port’s ongoing implementation of Mitigation Measure 4.12.6 – Assess and Manage Potable Water Demands and Mitigation Measure 4.12.7 – Upgrade Potable Water System. Therefore, there would be no additional impacts, the Proposed Project would not require relocation or construction of new or expanded facilities beyond Port facilities already considered in the WCDP EIR, and the findings would be the same as those described in the WCDP EIR.

3.11.5.7 Implementation of the Proposed Project could result in impacts to the water distribution infrastructure system. The WCDP EIR concluded that the water distribution infrastructure may not be sufficient to support development of the West Complex. Impacts were considered significant and implementation of mitigation as identified in Appendix A, including requiring the Port to assess and manage potable water demands and upgrade the potable water system, was required to reduce impacts to less-than- significant levels.

The Proposed Project would entail operations consistent with the evaluation in the WCDP EIR and would generate nominal incremental demand on potable water. The Proposed Project’s incremental demand on potable water would be addressed through the Port’s ongoing implementation of Mitigation Measure 4.12.6 – Assess and Manage Potable Water Demands and Mitigation Measure 4.12.7 – Upgrade Potable Water System. Therefore, there would be no additional impacts, sufficient water supplies would be available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years, and the findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 140 April 2021

3.11.5.8 Implementation of the Proposed Project would not result in insufficient capacity at an existing landfill. The WCDP EIR concluded that existing solid waste collection services and local landfills could accommodate development of the West Complex. Impacts were considered less than significant.

The Proposed Project would entail construction and operations, including waste generation, consistent with the evaluation in the WCDP EIR. The Proposed Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste, and would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Existing source reduction measures at the Port would remain in place. Therefore, the Proposed Project would result in no new or additional impacts related to landfill or solid waste management infrastructure, and the findings would be the same as those described in the WCDP EIR.

3.12 Population, Employment, and Housing Proposed Project- Significance Threshold WCDP EIR Findings Related Findings a. Implementation of the Proposed Project has the potential to result in an increase in both temporary construction-related Beneficial Impact Beneficial Impact and permanent operations-related employment for the City of Stockton and surrounding area.

3.12.1 Environmental Setting The WCDP EIR provided a framework for considering the population, employment, and housing effects of the Proposed Project. The population, employment, and housing setting of the Port and its environs are described in the WCDP EIR (Section 4.13 of the DEIR) and updated in this section. The following text provides updates relevant to the Proposed Project.

The population growth projected through 2015 in the WCDP EIR for the County and City was slightly greater than the rate of actual growth in both areas. As of 2018, the County population reached 752,660 and the City population was 311,189 (ACS 2019a, 2019b). The WCDP EIR noted that the unemployment rate for the City was 14.4% in 1995, and 10.4% in 2000 and was projected to decrease. Prior to the reductions in employment associated with the COVID-19 pandemic, employment in the County was 307,900 employees, with an unemployment rate of 5.9% for the County. The WCDP EIR projected the number of direct jobs generated would range from 15,000 to 20,000 jobs, with additional indirect and induced jobs in supporting employment sectors including local construction, retail, and services. In August 2010, the Port and the Navy completed transferring more than 1,400 acres of property to the Port, and employment on Rough and Ready Island has continued to transition over time from reliance on the federal government, to employment through a

Denmar Addendum to the WCDP EIR 141 April 2021

variety of Port tenants and supporting industries. As of 2017, the Port as a whole supported more than 5,500 jobs and $220 million in annual salaries and benefits (Port 2017). The WCDP EIR projected the number of direct jobs generated would range from 15,000 to 20,000 jobs, with additional indirect and induced jobs in supporting employment sectors including local construction, retail, and services.

SJCOG conducts an assessment every 8 years to determine the number of new housing units that need to be built in each jurisdiction in the County to ensure housing remains accessible and affordable for the growing population. As an update to the future housing projections in the WCDP EIR, for the most recent assessment (covering 2014 to 2023), SJCOG determined that 40,360 new housing units should be constructed, but as of 2017, only 6,881 were built (SJCOG 2020). At the current building rate, SJCOG projects there will be a housing supply gap in the County of more than 20,000 homes by 2023.

3.12.2 Regulatory Setting Several changes to plans and policies governing population, employment, and housing analyses have been made since the WCDP EIR. The regulatory setting is updated to incorporate the following policies and actions under the land use and transportation chapters of the City’s 2040 General Plan (City 2018) that address population, employment, and housing and may be applicable to the Proposed Project:

• Policy LU-4.1: Encourage large-scale development proposals in appropriate locations that include significant numbers of higher-wage jobs and local revenue generation. • Policy LU-4.2: Attract employment-and tax-generating businesses that support the economic diversity of the city. • Policy LU-6.4: Ensure that land use decisions balance travel origins and destinations in as close proximity as possible and reduce VMT. ‒ Action LU-6.4A: Maintain a reasonable balance between potential job generation and local workforce availability with a goal of one job for each employed resident. ‒ Action LU-6.4B: Maintain a reasonable proximity and balance (i.e., magnitude) between job-generating uses, housing opportunities, and resident services and amenities, including transit and active transportation. • Policy TR-1.3: Facilitate expanded port and airport operations, service, and development as travel and goods movement assets to the community and sources of employment growth.

3.12.3 Mitigation Measures No mitigation measures from the WCDP EIR apply to population and land use, and no new or modified mitigation measures are proposed for this resource area.

Denmar Addendum to the WCDP EIR 142 April 2021

3.12.4 Methods/Approach Impacts to population, employment, and housing were evaluated based on the potential for the Proposed Project for temporary or permanent local or regional change. To determine whether the Proposed Project would result in similar findings as those described in the WCDP EIR, physical changes associated with the Proposed Project were considered relative to both the development contemplated in the WCDP EIR and the regulatory setting changes since publication of the WCDP EIR. Relevant findings from the WCDP EIR pertaining to population, employment, and housing are briefly summarized in this section. Additional information is provided specific to the Proposed Project and in consideration of environmental or regulatory setting changes since publication of the WCDP EIR.

3.12.5 Impact Assessment

3.12.5.1 Implementation of the Proposed Project has the potential to result in an increase in both temporary construction-related and permanent operations-related employment for the City of Stockton and surrounding area. The WCDP EIR concluded that implementation of the WCDP would increase both temporary construction-related and permanent operations-related employment opportunities for the City and the surrounding area, which would be a beneficial impact.

The Proposed Project would entail construction and operations consistent with the evaluation in the WCDP EIR and would consequently also result in beneficial employment opportunities. It is anticipated that these new employment opportunities would be filled by local residents because of the large number of workers that already reside within the area, the County’s complementary workforce profile, and the currently high rate of unemployment. There are no housing units in the project area. The increase in employment opportunities is not expected to induce unplanned population growth in the area or result in an additional need for housing in the area, and this growth was previously analyzed in the WCDP EIR. Therefore, the Proposed Project would create no new or additional impact related to population, employment, and housing, and the findings would be the same as those described in the WCDP EIR.

3.13 Resource Areas and CEQA Considerations Not Considered in the WCDP EIR As noted in Section 1.1.4, CEQA and the CEQA Guidelines have been amended since certification of the WCDP EIR. This section discusses resource areas that were not specifically included in the WCDP EIR but which are currently required to be analyzed under CEQA and the CEQA Guidelines.

Denmar Addendum to the WCDP EIR 143 April 2021

3.13.1 Transportation Analysis Using the Vehicle Miles Traveled Metric SB 743, signed by Governor Brown in 2013, was intended to balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of GHG emissions. SB 743 set the stage for moving away from LOS, which measures delay to motorists, to VMT (defined as the amount and distance of automobile travel attributable to a project) as the metric to evaluate transportation network performance and land use and transportation planning decisions through CEQA. Specifically, SB 743 required OPR to develop revisions to the CEQA Guidelines to establish criteria for evaluating transportation impacts that promote the reduction of GHG emissions, the development of multimodal transportation networks, and a diversity of land uses (PRC 21099[b][1]). SB 743 provided that, upon certification of the updated guidelines by the Secretary of the California Natural Resources Agency, automobile delay, as described solely by LOS or similar measures of vehicular capacity or traffic congestion, is no longer considered a significant impact on the environment under CEQA, except in locations specifically identified in the guidelines, if any (PRC 21099[b][2]).

In December 2018, the California Natural Resources Agency certified and adopted updated CEQA Guidelines, including guidelines implementing SB 743. Under Section 15064.3 of the updated CEQA Guidelines, VMT generally is the most appropriate measure of transportation impacts. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Transportation impacts related to air quality, noise, and safety must still be analyzed under CEQA where appropriate (PRC 21099[b][3]). The new transportation guidelines took effect statewide on July 1, 2020, and apply prospectively to steps in the CEQA process not yet undertaken by that date (CEQA Guidelines Sections 15064.3[c] and 15007).

OPR issued a Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory; OPR 2018), which provides general guidance on VMT analyses in the absence of regional guidance and defines automobiles as on-road passenger vehicles, specifically cars and light trucks. Under the Technical Advisory, absent substantial evidence indicating that a project would generate a potentially significant level of VMT, or inconsistency with a Sustainable Communities Strategy or general plan, small projects that generate or attract fewer than 110 automobile trips per day generally may be assumed to cause a less-than-significant transportation impact.

At the time that the WCDP EIR was developed, there was little existing development in the West Complex. The WCDP EIR assumed full build-out would result in 51,319 daily vehicle and truck trips, with 8,307 new AM trips and 8,116 PM trips (Section 3.2.5). This volume of vehicle trips is over the screening level in OPR’s Technical Advisory, and it is assumed that the increase in VMT caused by implementation of the WCDP would have been considered significant if the WCDP EIR had analyzed VMT.

Denmar Addendum to the WCDP EIR 144 April 2021

Construction (remediation and Denmar terminal construction) would generate up to 284 daily vehicle trips and up to 305 daily truck trips. As shown in Table 4 in Section 3.2.4, these trip volumes would be within the full build-out levels analyzed in the WCDP EIR. Construction traffic would be temporary and is not expected to affect regional VMT levels. Most construction vehicle trips would be for construction employee commutes to and from the construction site. Truck trip lengths have been minimized by sourcing most of the imported fill material from areas at and near the Port. The majority of construction truck trips would be between the project site at the Port and the Rough and Ready Island or Roberts Island soil borrow sites (2 and 5 miles one-way from the site, respectively) or between the Port and George Reed Jackson Valley rock quarry (35 miles one-way).

At full build-out, the Denmar terminal would require 71 employees. An additional five daily roundtrips are assumed to account for visitors or deliveries. As such, the Denmar terminal would generate 76 new vehicle roundtrips (or 152 one-way trips) to the West Complex through employee commuting and visitor trips. The Denmar terminal would not involve trucks during operations. As described in Section 3.2.5, vehicle trips resulting from the Proposed Project would not exceed the full build-out volumes analyzed in the WCDP EIR, and vehicle trip distance is assumed to be the same because most trips would be related to employee commutes from the surrounding area in both analyses. Further, the Proposed Project’s permanent increase in vehicle trips would be below the Technical Advisory’s screening level of 110 automobile trips per day.

Therefore, there would be no additional transportation impacts as a result of the Proposed Project compared to the impacts that would be expected to result from the approved WCDP.

3.13.2 Greenhouse Gases SB 97 directed OPR to develop CEQA Guidelines “for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions.” The current CEQA Guidelines provide that a lead agency must make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of GHG emissions resulting from a project (CEQA Guidelines Section 15064.4[a]). In determining the significance of a project’s GHG impacts, the lead agency should consider, among other factors: 1) the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting; 2) whether the project’s GHG emissions exceed a threshold of significance that the lead agency determines applies to the project; and 3) the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. The lead agency may consider a project’s consistency with the state’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is consistent with those plans, goals, or strategies (CEQA Guidelines Section 15064.4[b]).

Denmar Addendum to the WCDP EIR 145 April 2021

As detailed in Appendix B, the proposed operations of the Denmar terminal at full build-out would contribute 14,420 metric tons of carbon dioxide-equivalent (CO2e) per year. The Proposed Project would include new sources of construction and sustained operations consistent with the levels of construction and operation assumed in the WCDP EIR; therefore, GHG emissions from the Proposed Project would be expected to be consistent with the types and quantities GHG emissions resulting from the approved WCDP EIR. Further, the Proposed Project would move goods to the Port by rail, as opposed to moving goods to the Port by truck as was contemplated by the WCDP EIR. The use of rail is generally more efficient than trucks, which translates to GHG savings over a regional basis. As shown in Table 17, trucks produce roughly four times the amount of GHG emissions compared to rail. This finding is conservative, because total rail emissions (on-site and off-site) are being compared to truck emissions generated from off-site travel only. Additional truck emissions would be expected from on-site operations during unloading, which would make rail even more favorable compared to trucks.

Table 17 Greenhouse Gas Emissions from Rail Versus Trucks

GHG Emissions Source (metric tons of CO2e per year) Rail 7,402 Truck 28,524 Notes: The rail source category includes emissions generated from travel between the project site and the SJVAPCD boundary, plus on-site operations. The truck source category includes emissions generated from traveling between the project site and the SJVAPCD boundary only. A default load of 20 tons per truck from CalEEMod was assumed. Based on this default load, a total of 1,148 trucks per day are required to transport 7,000,000 metric tons per year of material (assuming 336 terminal operating days per year).

The Proposed Project would be subject to future state and local requirements imposed by ARB’s 2017 Climate Change Scoping Plan Update (ARB 2017). The Climate Change Scoping Plan Update describes how California will reduce its GHG emissions by 40% below 1990 levels by 2030. The Proposed Project’s emission sources would be mobile sources (ships and rail) that would be captured under state initiatives such as low carbon energy and fuel standards. On-site stationary sources do not produce direct emissions but would produce secondary emissions through the use of electricity. The City’s 2040 General Plan (City 2018) includes several policies that are applicable to the Proposed Project, specifically Policy TR-3.2, which requires new development and transportation projects to reduce GHG emissions, and Policy CH5.2, which expands opportunities for recycling, reuse of materials, and waste reduction. The Denmar terminal would also include terminal efficiency measures such as solar panels on new buildings, efficient lighting, and recycling facilities, thereby complying with applicable GHG reduction plans.

Denmar Addendum to the WCDP EIR 146 April 2021

Because the Proposed Project would not increase GHG emissions compared to the transportation modes and emission sources identified in the WCDP EIR, and because the Proposed Project would be consistent with plans adopted to address climate change, the impacts of the Proposed Project would not differ from the impacts of the approved WCDP.

3.13.3 Energy SB SX1-2 requires the state of California to produce 33% of its electricity from renewable sources by December 31, 2020; SB 350 requires that the state produce 50% of its electricity from renewable sources by December 31, 2030; and SB 100 requires that the state produce all electricity from renewable sources by 2045. Local policies pertaining to energy include 2040 General Plan Policy LU-5.4B, which requires all new development, including major rehabilitation, renovation, and redevelopment, to incorporate feasible and appropriate energy conservation practices.

In order to comply with SB SX1-2 and SB 350 standards, the Port has developed and implemented a Renewable Portfolio Standard Procurement Plan (Port 2016). In the plan’s most recent iteration, the Port determined the most efficient and cost-effective approach to meeting these standards is through continued purchase of sufficient state-approved renewable energy products from the active California market. For the compliance period from 2021 through 2030, the Port will determine and implement the most cost-effective options for complying with newly codified laws (Port 2016).

As of July 2019, the Port additionally offers its tenants financial incentives for the installation of high-efficiency equipment or systems. Incentives are paid on the energy savings and permanent peak demand reduction above and beyond baseline energy performance, which include state-mandated codes, federal-mandated codes, industry-accepted performance standards, or other baseline energy performance standards (Port 2019). Continued implementation of the Port’s Renewable Portfolio Standard Procurement Plan (Port 2016) would ensure that the Proposed Project does not conflict with state regulations pertaining to renewable energy.

The WCDP EIR analyzed utility uses in Section 3.11. The Denmar terminal would obtain energy from the Port, which would obtain it from local providers, including electricity from the Pacific Gas and Electric Company. Proposed Project construction would involve the same types of equipment that consume fossil fuel as was contemplated by the WCDP EIR; the Proposed Project would not require any unusual or excessive construction equipment or practices compared to projects of similar type and size. In addition, the Proposed Project would comply with standard BMPs such as equipment idling restrictions and maintaining equipment according to manufacturer specifications. As such, construction of the Proposed Project would not result in wasteful, inefficient, or unnecessary consumption of energy. Proposed Project operations also would involve the same types of fuels and transportation modes as were identified in the WCDP EIR; however, the Proposed Project involves a larger number of trains and substantially fewer trucks than were identified in the WCDP EIR. As

Denmar Addendum to the WCDP EIR 147 April 2021

explained in Section 3.13.2, goods movement via train is more efficient from an energy usage perspective than goods movement by truck, which translates to fuel savings. Proposed Project operations would use fuel and utilities; however, they would not result in wasteful, inefficient, or unnecessary consumption of energy resources, and the Proposed Project’s use of rail would result in energy savings over the use of trucks.

3.13.4 Wildfire According to the Fire Hazard Severity Zone Maps, the West Complex, as well as other communities within the County, is not located within one of the zones that present a moderate to very high fire hazard severity risk, and therefore is generally considered to have lower wildfire risk (Los Padres ForestWatch 2020). Soda ash is not flammable and would not present a higher fire risk than other cargo operations analyzed in the WCDP EIR. Fire hazards from additional vessel or rail trips would be addressed through their respective management programs and applicable regulations, and through regional and local emergency response plans and infrastructure. Therefore, impacts from wildfire would have been deemed less than significant had they been included in the WCDP EIR. The Proposed Project would not change this finding.

3.13.5 Tribal Cultural Resources Amendments to the CEQA guidelines in 2016 (commonly known as AB 52) require CEQA lead agencies to consult with Native American tribes who have formally requested consultation. AB 52 applies only to a project for which a notice of preparation or a notice of negative declaration or mitigated negative declaration is filed on or after July 1, 2015. The notice of preparation for the WCDP EIR was filed before that date; therefore, AB 52 does not apply to the Proposed Project. However, the Port elected to conduct voluntary consultations for the Proposed Project with five tribes identified by the NAHC. Consultation letters were sent to the Buena Vista Rancheria of Me- Wuk Indians, Confederated Villages of Lisjan, North Valley Yokuts Tribe, and Wilton Rancheria Tribe on January 6, 2021, and to the Tule River Indian Tribe on January 21, 2021. To date, responses have been received from the North Valley Yokuts Tribe and Confederated Villages of Lisjan requesting more information on the Proposed Project. On March 3, 2021, the Port provided response letters to both tribes. The Port also requested a search of the NAHC’s Sacred Lands file; the NAHC responded on February 2, 2021, and stated that the search was negative (no Sacred Lands are recorded in the project area). No tribal cultural resources have been identified in the project area through the above- described consultation, and the Proposed Project is unlikely to encounter Native American archaeological materials that could constitute previously unidentified tribal cultural resources. Therefore, impacts to tribal cultural resources would have been deemed less than significant had they been included in the WCDP EIR. The Proposed Project would not change this finding.

Denmar Addendum to the WCDP EIR 148 April 2021

3.14 Cumulative Impacts Analysis As discussed in Section 1.1.1, the WCDP EIR forecasted the level of infrastructure needs and resulting operations associated with full build-out of the West Complex assuming a mix of development types. Accordingly, the WCDP EIR analyzed the types of Port operations that were included in the development plan, as well as the construction elements that would be required to build such facilities. The WCDP EIR then considered full build-out of the West Complex in combination with other regional growth, specifically projections contained in the City of Stockton General Plan and the Port’s Industrial Redevelopment Plan and Project Area to determine the potential for cumulative impacts (Port 2004). The WCDP EIR concluded that full implementation of the WCDP in conjunction with past projects, existing conditions, and regional projections would contribute to cumulatively significant impacts related to land use, transportation and circulation, air quality, noise, and public services and utilities. For several of these categories, such as land use, existing baseline conditions were determined to be the primary factor contributing the significant impacts, while development of the WCDP would only incrementally contribute. For the remaining CEQA resource topics, the WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant impacts.

As discussed in Section 1.1.3, as of early 2020, approximately 75 facilities or businesses operate in the West Complex. Consistent with the WCDP EIR, all facilities or businesses are Port-dependent bulk, commercial, industrial, and/or warehousing operations. Development of the East Complex and regional growth has occurred as projected through the City’s General Plan. Therefore, the cumulative environmental setting is consistent with conditions assumed in the WCDP EIR. As discussed in Section 2, the Proposed Project would entail construction and operations of a project consistent with the types of projects evaluated in the WCDP EIR, and, as detailed in Sections 3.1 through 3.12, would not result in any new or substantially greater impacts than those analyzed in the WCDP EIR.

The Port has identified a reasonably foreseeable project on the West Complex, which, if approved, could have overlapping construction schedules with the Proposed Project. This potentially overlapping project (the Trammell Crow Remediation and Warehouse Project) would involve remediation of a 76-acre site impacted by past Navy activities (referred to as Site 47) as well as construction and operation of a warehouse approximately 1 mile to the southeast of the Proposed Project footprint. The Trammell Crow Remediation and Warehouse Project is consistent with the general land use designations and build-out identified in the WCDP EIR but is currently undergoing separate CEQA analysis to address the potential for project-level impacts. Because remediation and development activities associated with the Proposed Project and the Trammell Crow Remediation and Warehouse Project could overlap, the following subsections consider the potential for project- level cumulative impacts.

Denmar Addendum to the WCDP EIR 149 April 2021

3.14.1 Land Use The WCDP EIR concluded that implementation of the WCDP would contribute to cumulatively significant and unavoidable land use impacts. As described in Section 3.1.5, the Proposed Project would neither create new or additional impacts related to land use designations and adopted plans and policies beyond those identified in the WCDP EIR, nor would the Proposed Project conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The impacts of the Proposed Project would be the same as those described in the WCDP EIR. The Trammell Crow Remediation and Warehouse Project, which is subject to the same zoning as the Proposed Project, would not physically divide an established community or conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, as will be documented in the CEQA analysis. Therefore, there would be no additional cumulative contribution to land use impacts.

3.14.2 Transportation and Circulation The WCDP EIR concluded that implementation of the WCDP would contribute to cumulatively significant and unavoidable transportation and circulation impacts. As discussed in Section 3.2.4, the WCDP EIR completed a trip generation assessment of vehicle (defined as vehicles other than heavy- duty trucks) and truck trips to determine daily trips. The trip generation table projected that the WCDP at full build-out in 2020 would result in 51,319 daily vehicle and truck trips. Table 4 shows that existing levels (11,093 daily vehicle and truck trips) are far below these projections and that the Proposed Project would only contribute 152 additional trips. Therefore, the Proposed Project would be within the projections analyzed in the WCDP EIR and the findings would be the same as those described in the WCDP EIR. The Trammell Crow Remediation and Warehouse Project would contribute additional vehicles to the roadway and could contribute to traffic within the general Stockton area. While still undergoing CEQA analysis, based on projected traffic volumes, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts related to transportation and circulation at a project level and would not be expected to exceed the 2020 traffic projections analyzed in the WCDP EIR. Therefore, there would be no additional cumulative contribution to transportation and circulation impacts.

3.14.3 Air Quality The WCDP EIR concluded that implementation of the WCDP would contribute to cumulatively significant and unavoidable air quality impacts. As noted in the WCDP EIR, according to SJVAPCD, any proposed project that would individually have a significant air quality impact would also be considered to have a significant cumulative air quality impact. Impacts of local pollutants (e.g., ROG,

NOX, and TACs) are cumulatively significant when modeling shows that the combined emissions from the project and other existing and planned projects in the area would exceed air quality standards.

Denmar Addendum to the WCDP EIR 150 April 2021

As described in Section 3.3.5, the Proposed Project’s operational emissions would exceed SJVAPCD non-permitted thresholds for NOX and CO during Phase 1 of the Denmar terminal’s operations and ROG,

NOX, and CO for operations associated with Phase 2 (full build-out) and therefore, consistent with the findings of the WCDP EIR, cumulative impacts are considered significant and unavoidable. While still undergoing CEQA analysis, based on the expected construction schedule and operational levels, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts related to air quality with implementation of mitigation measures. Therefore, there would be no additional cumulative contribution to air quality impacts.

3.14.4 Noise The WCDP EIR concluded that implementation of the WCDP would contribute to cumulatively significant and unavoidable noise impacts related to traffic operations. The WCDP EIR found that significant cumulative construction noise impacts are not anticipated because no major construction projects are anticipated to coincide with the Proposed Project and because daytime construction noise is not considered significant. In addition, no projects other than the Proposed Project were anticipated in the vicinity of sensitive receptors on the north shore of the San Joaquin River, and therefore there would be no contribution to operational noise or vibration. As described in Section 3.4.5, the Proposed Project’s noise impacts, including impacts from operations would be within the projections analyzed in the WCDP EIR and the findings would be the same as those described in the WCDP EIR. While the Trammell Crow Remediation and Warehouse Project would be located in the West Complex, it is located south of Navy Drive. Based on the way noise attenuates, operational noise would not likely be heard by receptors on the north shore of the San Joaquin River and therefore would not additionally contribute to cumulative operational noise findings. As noted in Section 3.14.2, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts related to transportation and circulation at a project level and would not be expected to exceed the 2020 traffic projections analyzed in the WCDP EIR. Therefore, there would be no additional cumulative contribution to transportation noise impacts.

3.14.5 Geology and Soils The WCDP EIR concluded because new development would be required to conform to building standards contained within the Uniform Building Code, the WCDP would not pose any substantial cumulative effects to the safety of people and/or structures with regard to local soils and geology. The WCDP EIR further found that for some areas of the levee that are unprotected or eroding under existing wave conditions, there would be the potential for additional levee erosion due to more frequent tugboat traffic. Therefore, mitigation was identified to protect these areas of the levee, and impacts were found to be less than significant. As described in Section 3.5.5, the Proposed Project would be consistent with the type of development assumed in the WCDP EIR and would conform to building standards contained within the Uniform Building Code as well as implement all applicable

Denmar Addendum to the WCDP EIR 151 April 2021

WCDP EIR-identified geology and soils-related mitigation measures. The Proposed Project would include vessel trips (and correspondingly tug trips) that exceed those identified in the WCDP EIR; however, as discussed in Section 3.5, since publication of the WCDP EIR, the Port and Reclamation District 403 have collaborated to conduct ongoing monitoring of the West Complex levees, including those in the northwestern portion of Rough and Ready Island to address the potential for impacts. Therefore, there would be no additional cumulative contribution to impacts on geology and soils from additional vessel traffic as a result of the Proposed Project. While still undergoing CEQA analysis, the Trammell Crow Remediation and Warehouse Project would not include any vessel trips and is not expected to result in significant and unavoidable impacts on geology and soils as development would conform to building standards contained within the Uniform Building Code. Therefore, there would be no additional cumulative contribution to impacts on geology and soils from additional vessel traffic.

3.14.6 Hydrology and Water Quality The WCDP EIR concluded that because of the pre-existing water quality impairment in the DWSC, any adverse impacts to water quality would be considered cumulatively considerable and therefore mitigation was identified. Following implementation of the mitigation, impacts would be reduced to a less-than-significant level and would render the WCDP’s incremental contribution to cumulative impacts less than cumulatively considerable. As described in Section 3.6.5, construction of the Proposed Project would be consistent with the type of development assumed in the WCDP EIR and would implement all applicable WCDP EIR-identified hydrology and water quality-related mitigation measures. Accordingly, the associated impacts of the Proposed Project would be the same as those described in the WCDP EIR. While still undergoing CEQA analysis, based on projected construction and operational impacts and its compliance with the Port’s DSP as well as other applicable state and federal environmental regulations, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts on hydrology and water quality. Therefore, there would be no additional cumulative contribution to impacts on hydrology and water quality.

3.14.7 Biological Resources The WCDP EIR found that increased maritime traffic could result in an increased release of ballast water; however, such increases would not contribute to cumulatively significant biological resources impacts with implementation of mitigation. In addition, the WCDP EIR found that landside construction activities and project operations could potentially result in adverse impacts to special status species. Impacts were determined not to be significant based on participation in the SJMSCP, which covers many of the potentially present species. The WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant biological resources impacts with implementation of mitigation. As described in Section 3.7.5, construction of the Proposed Project would be consistent with the type of development assumed in the WCDP EIR and would implement

Denmar Addendum to the WCDP EIR 152 April 2021

all applicable WCDP EIR-identified biological resources-related mitigation measures. Accordingly, the biological resources impacts of the Proposed Project would be the same as those described in the WCDP EIR. While still undergoing CEQA analysis, based on the existing site conditions, projected construction impacts, and requirements to comply with all applicable state and federal environmental regulations, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable biological resources impacts as it would not include any in-water work or vessel calls. If there are any special status species identified on site, Trammell Crow would obtain coverage under the SJMSCP. Therefore, there would be no additional cumulative contribution to biological resources impacts.

3.14.8 Cultural Resources The WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant cultural resources impacts. As described in Section 3.8.5, construction of the Proposed Project would be consistent with the type of activities assumed in the WCDP EIR. The cultural resources impacts of the Proposed Project, including impacts to the National Historic District from building demolition, would be the same as those described in the WCDP EIR. The Trammell Crow Remediation and Warehouse Project is located within the West Complex in the same footprint of the historic district as identified in the WCDP EIR. However, the Trammell Crow Remediation and Warehouse Project would not contribute to significant and unavoidable cultural resources impacts. Therefore, there would be no additional cumulative contribution to cultural resources impacts.

3.14.9 Visual Resources The WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant visual resources impacts because no other development is planned or proposed within the same viewshed as the WCDP, as viewed from off-site viewers. As described in Section 3.9.5, the Proposed Project would be consistent with the type of development assumed in the WCDP EIR. The visual resources impacts of the Proposed Project, including impacts from construction and facility operations, would be the same as those described in the WCDP EIR. The Trammell Crow Remediation and Warehouse Project, which is subject to the same zoning as the Proposed Project, would involve construction of a warehouse in the southern portion of the West Complex consistent with the viewshed as described in the WCDP EIR. Therefore, there would be no additional cumulative contribution to visual resources impacts.

3.14.10 Hazardous Materials and Public Health The WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant impacts related to hazardous materials and public health. The WCDP EIR found that proposed infrastructure improvements could result in the disturbance of contaminated areas, both identified and unknown, but any areas to be disturbed for the infrastructure improvements would be

Denmar Addendum to the WCDP EIR 153 April 2021

investigated to determine the past and current uses and whether any releases of hazardous materials have occurred. If a release has occurred, the site(s) would be characterized to determine the nature and extent of contamination that is present before construction activities proceed at the site(s) and therefore there would be no significant cumulative impacts. As described in Section 3.10.5, construction of the Proposed Project would be consistent with the type of activities assumed in the WCDP EIR. The hazardous materials and public health-related impacts of the Proposed Project, including impacts from remediation and facility construction and operations, would be the same as those described in the WCDP EIR. The soil remediation components of the Trammell Crow Remediation and Warehouse Project, which is subject to the same Consent Decree as the Proposed Project, is being developed in coordination with DTSC and CVRWQCB. The Trammell Crow Remediation Warehouse Project is subject to the same requirements for proper handling of hazardous materials during construction and operation as the Proposed Project. Accordingly, while still undergoing CEQA analysis, it is not anticipated that the Trammell Crow Remediation Warehouse Project would result in significant impacts related to hazardous materials and public health. Therefore, there would be no additional cumulative contribution to hazardous materials and public health-related impacts.

3.14.11 Public Services and Utilities The WCDP EIR concluded that implementation of the WCDP would contribute to cumulatively significant and unavoidable public services and utilities impacts associated with water supply (groundwater draft), which was recognized as an area-wide impact. As described in Section 3.11.5, the Proposed Project would be consistent with the type of development assumed in the WCDP EIR and would have nominal effect on water supply. The impacts of the Proposed Project would be the same as those described in the WCDP EIR. While still undergoing CEQA analysis, based on projected construction and operations, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts related to public services and utilities, including to water supply. Therefore, there would be no additional cumulative contribution to impacts on public services and utilities.

3.14.12 Population, Employment, and Housing The WCDP EIR concluded that implementation of the WCDP would not contribute to cumulatively significant impacts on population, employment, and housing. As described in Section 3.12.5, the Proposed Project would be consistent with the type of development assumed in the WCDP EIR. The impacts of the Proposed Project would be the same as those described in the WCDP EIR, which are considered beneficial. While still undergoing CEQA analysis, the Trammell Crow Remediation and Warehouse Project is not expected to result in significant and unavoidable impacts related to population, employment, and housing. Therefore, there would be no additional cumulative contribution to impacts on population, employment, and housing.

Denmar Addendum to the WCDP EIR 154 April 2021

3.14.13 Summary For the reasons outlined in the subsections above, there would be no new or new or additional project-level cumulative impacts from overlapping construction and operation of the Proposed Project and the Trammell Crow Remediation and Warehouse Project. Findings would be the same as those described in the WCDP EIR.

Denmar Addendum to the WCDP EIR 155 April 2021

4 References ACS (American Community Survey), 2019a. U.S. Census Bureau 2019 American Community Survey 1-Year Estimates. Stockton city, California entry. Accessed September 30, 2020. Available at: https://data.census.gov/cedsci/table?q=stockton&tid=ACSDP1Y2019.DP05&hid ePreview=true.

ACS, 2019b. U.S. Census Bureau 2019 American Community Survey 1-Year Estimates. San Joaquin County, California entry. Accessed September 30, 2020. Available at: https://data.census.gov/cedsci/table?q=san%20joaquin&tid=ACSDP1Y2019.DP0 5&hidePreview=true.

Anchor QEA (Anchor QEA, LLC), 2017. Port of Stockton 2017-2021 Maintenance Dredging Sediment Characterization Notice of Intent. Accessed October 2, 2020. Available at: https://www.portofstockton.com/wp-content/uploads/2018/06/dock-14-20- dredging/Notice-of-Intent---2017-2021-Maintenance-Dredging-Sediment- Characterization.pdf.

Anchor QEA, 2020a. Draft Jurisdictional Delineation, Denmar Natural Soda Ash Export Terminal at the Port of Stockton. September 2020.

Anchor QEA, 2020b. Denmar Natural Soda Ash Export Terminal Biological Assessment. November 2020.

Anchor QEA, 2020c. Notes from April 17, August 26, August 27, September 3, and September 11, 2020, site visits by Anchor QEA biologists Nicolas Duffort and Julia King.

ARB (California Air Resources Board), 2017. California’s 2017 Climate Change Scoping Plan: The strategy for achieving California’s 2030 greenhouse gas target. November 2017. Available at: https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/scoping_plan_2017.pdf.

BRAI (Basin Research Associates, Inc.), 1996. Archaeological Sensitivity Review; NCS Stockton, San Joaquin County and NRFT Dixon, Solano County. Report on file at the California Historic Resources Information Center, Stanislaus, California.

CAL FIRE (California Department of Forestry and Fire Protection), 2002. Timberland Site Class on Private Lands Zoned for Timber Production. CAL FIRE and Resource Assessment Program (FRAP). Technical Working Paper 1-03-02. Accessed September 30, 2020. Available at: http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.626.4149&rep=rep1&type=pdf.

Denmar Addendum to the WCDP EIR 156 April 2021

Caltrans (California Department of Transportation), 2020a. Vehicle Miles Traveled-Focused Transportation Impact Study Guide. May 20, 2020. Available at: https://dot.ca.gov/- /media/dot-media/programs/transportation-planning/documents/sb-743/2020-05-20- approved-vmt-focused-tisg-a11y.pdf.

Caltrans, 2020b. Transportation and Construction Vibration Guidance Manual. April 2020. Available at: https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf.

Caltrans and Port (Port of Stockton), 2013. Initial Study with Mitigated Negative Declaration/Environmental Assessment and Programmatic Section 4(f) Evaluation with Finding of No Significant Impact. September 2013.

CDFW (California Department of Fish and Wildlife), 2019. Fall Midwater Trawl Monthly Abundance Indices. Accessed June 6, 2020. Available at: http://www.dfg.ca.gov/delta/data/fmwt/indices.asp.

CDFW, 2020. California Native Diversity Database Rarefind 5 Program Search of Stockton West Terminous, Lodi South, Waterloo, Stockton East, Manteca, Lathrop, Union Island, and Holt quadrangles. Accessed September 30, 2020.

CGS (California Geological Survey), 2019. EQ Zapp: California Earthquake Hazards Zone Application. Stockton West. Updated April 4, 2019; accessed October 2, 2020. Available at: https://maps.conservation.ca.gov/cgs/EQZApp/app/.

Citizens Against Airport Pollution v. City of San Jose. 227 Cal. App. 4th 788 (Cal 2014).

Citizens for Responsible Equitable Environmental Development v. City of San Diego. 196 Cal. App. 4th 515, pages 531–532 (Cal. 2011)

City (City of Stockton), 1990. City of Stockton General Plan: Background Document and Policy Document. Stockton, California. Amended through November 3, 1998.

City, 2003. City of Stockton Transportation Impact Analysis Guidelines. July 30, 2003. Available at: http://www.stocktongov.com/files/Appendix%20- %20Transportation%20Impact%20Analysis%20Guidelines.pdf.

City, 2007. Stockton General Plan 2035 Goals & Policies Report. December 2007. Accessed September 14, 2020. Available at: http://www.stocktongov.com/files/GoalPolicyReport.pdf.

City, 2014. City of Stockton Climate Action Plan. Prepared by ICF International for the City of Stockton. August 2014.

Denmar Addendum to the WCDP EIR 157 April 2021

City, 2018. Envision Stockton 2040 General Plan. December 4, 2018. Accessed August 11, 2020. Available at: http://www.stocktongov.com/files/Adopted_Plan.pdf.

City, 2020a. City of Stockton, CA: LandMaster Online. Zoning map overview. Updated September 2, 2020. Accessed September 14, 2020. Available at: https://stocktonca.mapgeo.io/datasets/properties?abuttersDistance=100&latlng=37.947043 %2C-121.35112&zoom=14.

City, 2020b. “Title 16 Development Code.” City of Stockton Municipal Code. Stockton, California. Current through Ordinance 2020-06-09-1501 C.S. and the July 2020 code supplement. Accessed September 21, 2020. Available at: https://qcode.us/codes/stockton/view.php?topic=16&frames=off.

City, 2020c. “City of Stockton Municipal Utility Services – Water.” Last modified April 13, 2020; accessed September 21, 2020. Available at: http://www.stocktongov.com/government/departments/municipalUtilities/utilWater.html.

County, 2000. San Joaquin County Multi-species Habitat Conservation and Open Space Plan. November 14, 2000. Accessed September 14, 2020. Available at: https://ca- sjcog2.civicplus.com/DocumentCenter/View/5/Habitat-Planpdf.

County, 2020. San Joaquin County, CA, USA, District Viewer Map. Parcel Details for Parcel 16203007 (Port of Stockton West Complex). Accessed September 14, 2020. Accessed at: https://www.sjmap.org/DistrictViewer/.

County GIS (San Joaquin County Geographic Information Systems), cartographer, 1999. Expansive Soils 1999 (computer map). Stockton, California: San Joaquin County Geographic Information Systems. Published October 18, 1999. Accessed August 11, 2020. Available at: http://www.sjmap.org/mapdocs/FrontCounter_Expansive_Soils.pdf.

CSLC (California State Lands Commission), 2019. Letter to: Shipping Agents and Interested Parties. Regarding: AB 912. File Reference W9777.234. October 11, 2019. Accessed September 22, 2020. Available at: https://slcprdwordpressstorage.blob.core.windows.net/wordpressdata/ 2019/10/AB912_11October2019_finalletter.pdf.

DieselNet, 2017. Nonroad Diesel Engine Emission Standards. Last updated December 2017. Accessed September 23, 2020. Available at: https://www.dieselnet.com/standards/us/nonroad.php.

DTSC (California Department of Toxic Substances Control), 2020. DTSC EnviroStor Database. Accessed September 30, 2020. Available at: https://www.envirostor.dtsc.ca.gov/public/.

Denmar Addendum to the WCDP EIR 158 April 2021

ERS (Environmental Risk Services Corporation), 2012. Report of Waste Discharge for the Proposed Maintenance Dredging of Docks 14, 15, 19 and 20. Prepared for the Port of Stockton. May 2012.

ERS, 2013. Technical Memorandum, Historical Dredge Depth Study, West Complex, Port of Stockton, California. August 20, 2013.

FEMA (Federal Emergency Management Agency), 1988a. Flood Insurance Rate Map City of Stockton, California, San Joaquin County. Panel 15 of 45. Community Panel Number 060302 0015 D. Revised February 4, 1988.

FEMA, 1988b. Flood Insurance Rate Map for San Joaquin County, California (Unincorporated Areas). Panel 410 of 925. Community Panel Number 060299 0410 B. Revised July 4, 1988.

FEMA, 2009. FEMA’s National Flood Hazard Layer Viewer Search of Project Area. Accessed November 23, 2020. Available at: https://hazards-fema.maps.arcgis.com/apps/webappviewer/index.html.

Geosyntec (Geosyntec Consultants), 2021. Final Focused Feasibility Study, Landfill Area.

Google Maps, 2019. Live traffic overlay for Stockton, California. Mountain View, California: Google LLC. Accessed January 8 and 15, 2019. Available at: https://www.google.com/maps/place/Stockton,+CA/@37.917636,- 121.3340937,12.38z/data=!4m5!3m4!1s0x80900d737b442181:0x5876f5d1044fcbd8!8m2!3d37. 957701.

Gross, C., 2007. Archaeological Area of Potential Effects and Finding of No Historic Properties Affected for the Proposed DWR Delta Emergency Rock and Transfer Facility of the Port of Stockton, San Joaquin County, California. Report on file at the California Historic Resources Information Center, Stanislaus, California.

Highfill, B., 2010. “Lyons GC closure brings sad end to year.” Recordnet. January 1, 2010. Accessed November 23, 2020. Available at: https://www.recordnet.com/article/20100101/A_SPORTS0203/1010312.

ICF (ICF International, Inc.), 2019. Fish Entrainment Monitoring Report for Dredging Operations on the Sacramento and Stockton Deep Water Shipping Channels. April 2019.

JOE (Journal of Electricity), 1917. Irrigation 29(6). July 1, 1917.

Los Padres ForestWatch, 2020. Is Your Home In a Fire Hazard Severity Zone? Updated September 13, 2020. Accessed September 23, 2020. Available at: https://www.arcgis.com/home/item.html? id=5e96315793d445419b6c96f89ce5d153.

Denmar Addendum to the WCDP EIR 159 April 2021

Navy (U.S. Department of the Navy), 1947. Building the Navy’s Bases in World War II: History of the Bureau of Yards and Docks and the Civil Engineer Corps 1940-1946. Washington, DC: Government Printing Office.

NRCS (Natural Resources Conservation Service), 2020. Web Soil Survey. Search of project area. Survey area data updated May 29, 2020. Accessed September 30, 2020. Available at: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.

OEHHA (California Environmental Protection Agency, Office of Environmental Health Hazard Assessment), 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines: The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. February 2015. Accessed November 23, 2020. Available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf.

OPR (Governor’s Office of Planning and Research), 2017. State of California General Plan Guidelines. Accessed September 30, 2020. Available at: http://opr.ca.gov/docs/OPR_COMPLETE_7.31.17.pdf.

OPR, 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Accessed September 30, 2020. Available at: http://opr.ca.gov/docs/20190122- 743_Technical_Advisory.pdf.

Port (Port of Stockton), 2004. Port of Stockton West Complex Development Plan Final Environmental Impact Report. Prepared by Environmental Science Associates. May 2004.

Port, 2007. “West Complex Development Program EIR Settlement Agreement.” In the matter of The Port of Stockton v. Baykeeper, NRDC Friends of Riviera Cliffs, and the Individual Plaintiffs. California Court of Appeals, Third Appellate District, Case No. C050636. August 6, 2007.

Port, 2009. Port of Stockton Storm Water Development Standards Plan. June 1, 2009.

Port, 2012. Targa Stockton Terminal Project Tiered Initial Study and Proposed Mitigated Negative Declaration. January 2012.

Port, 2016. Renewable Portfolio Standard Procurement Plan 2016 Update. August 11, 2016.

Port, 2017. 2017 Annual Report: Port of Stockton, California. Accessed September 30, 2020. Available at: http://online.anyflip.com/vzeli/kcjg/mobile/index.html.

Port, 2019. 2019 Energy Efficiency Program Offering Procedures Manual. July 1, 2019.

Denmar Addendum to the WCDP EIR 160 April 2021

Port, DTSC, and CVRWQCB (Central Valley Regional Water Quality Control Board), 2003. Former Naval Computer and Telecommunications Station Covenant and Agreement To Restrict Use Of Property. September 29, 2003.

Sapere (Sapere Environmental), 2021. Riparian Brush Rabbit Survey Results. April 2021.

SEG (Salem Engineering Group, Inc.), 2018. Geotechnical Engineering Investigation, Proposed Stockton Phase B Expansion, San Joaquin County. November 13, 2018.

SJCOES (San Joaquin County Office of Emergency Services), 2019a. Flood and Dam Failure Hazard Annex. March 2019. Accessed November 23, 2020. Available at: https://www.sjgov.org/uploadedfiles/sjc/departments/oes/content/docs/plans/sj oa%20-%20flood%20and%20dam%20annex.pdf.

SJCOES, 2019b. County of San Joaquin Emergency Operations Plan. January 22, 2019. Accessed November 23, 2020. Available at: https://www.sjgov.org/uploadedfiles/sjc/departments/oes/content/meetings- committees/documents/2019/5- 2%20san%20joaquin%20emergency%20operations%20plan.pdf.

SJCOG (San Joaquin Council of Governments), 2020. “Housing Production.” Accessed September 24, 2020. Available at: https://www.sjcog.org/251/Housing-Production.

SJCOG, 2021. Denmar Terminal Project SJMSCP Incidental Take Minimization Measures (APN: 162- 030-07). March 5, 2021.

SJVAPCD (San Joaquin Valley Unified Air Pollution Control District), 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. Final Draft. February 19, 2015. Accessed November 23, 2020. Available at: http://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT- GAMAQI.PDF.

SJVAPCD, 2015b. Final Staff Report: Update to District’s Risk Management Policy to Address OEHHA’s Revised Risk Assessment Guidance Document. May 28, 2015. Accessed November 23, 2020. Available at: http://www.valleyair.org/busind/pto/staff-report-5-28-15.pdf.

SJVAPCD, 2015c. Notice of Exemption. San Joaquin Unified Air Pollution Control District (District): Proposed Update to District’s Risk Management Policy to Address OEHHA’s Revised Risk Assessment Guidance Document. June 4, 2015. Accessed November 23, 2020. Available at: https://www.valleyair.org/notices/Docs/2015/06-04-15_OEHHA/NOE.pdf.

SJVAPCD, 2015d. Notice of Exemption. San Joaquin Unified Air Pollution Control District (District): Clarification to Recent District Risk Management Policy Update. July 7, 2015.

Denmar Addendum to the WCDP EIR 161 April 2021

Accessed November 23, 2020. Available at: https://www.valleyair.org/notices/Docs/2015/07- 07-15_NOE/NOE.pdf.

State of California, 2003. Consent Agreement between the Port of Stockton, California, and the State of California Environmental Protection Agency, Department of Toxic Substances Control and the Regional Water Quality Control Board, Concerning the Former Naval Computer and Telecommunications Station, San Diego, Detachment Stockton. July 30, 2003.

SWRCB (State Water Resources Control Board), 2020. GeoTracker database search. Accessed September 30, 2020. Available at: https://geotracker.waterboards.ca.gov/.

Uribe & Associates, 1996. Historic and Archeological Resources Protection Plan for the Naval Communication Station Stockton, California. Report on file at the California Historic Resources Information Center, Stanislaus, California.

USACE (U.S. Army Corps of Engineers), 2015a. Stockton and Sacramento Deep Water Ship Channel Maintenance Dredging and Dredge Material Placement Projects 2014 Fish Community, Entrainment and Water Quality Monitoring Report. May 2015.

USACE, 2015b. Charleston Harbor Post 45, Charleston, South Carolina, Final Integrated Feasibility Report and Environmental Impact Statement. Appendix G: Noise Assessment. Prepared by the U.S. Army Corps of Engineers, Charleston District. May 2015. Accessed November 23, 2020. Available at: https://www.sac.usace.army.mil/Portals/43/docs/civilworks/post45/finalreport/3_ Appendix%20G%20-%20Noise%20Assessment.pdf?ver=2015-07-02-134724-100.

USEPA (U.S. Environmental Protection Agency), 2011. 2010 California 303(d) List of Water Quality Limited Segments. Sacramento San Joaquin Delta Entry. Accessed September 24, 2020. Available at: https://www.waterboards.ca.gov/water_issues/programs/tmdl/2010 state_ir_reports/category5_report.shtml

USGS (U.S. Geological Survey), 2020. U.S. Quaternary Faults. Golden, Colorado: USGS Geologic Hazards Science Center. Accessed September 24, 2020. Available at: https://usgs.maps. arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf.

Denmar Addendum to the WCDP EIR 162 April 2021

Appendix A West Complex Development Plan Environmental Impact Report and Settlement Agreement Mitigation Measures

Table A1 WCDP EIR and Settlement Agreement Mitigation Measures

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility While the size of the Proposed Project results in the impact being significant and unavoidable, the size of the project also presents opportunities to implement travel demand management (TDM) measures on a scale not feasible with smaller projects. This is especially the case in the high-density employment “Office – Industrial” and “High Tech – Research & Development” portions of the Proposed Project. The West Complex Development Plan does not describe proposed land uses in sufficient detail to allow the preparation of specific TDM measures. Nor is quantification of the effectiveness of the mitigation measures possible at this time. However, the San Joaquin Valley Air Pollution Control District document, Guide for Assessing and Mitigating Air Quality Impacts, presents a description of the types of measures that may apply to the Proposed Project. To the extent feasible, and as appropriate to the specific use, the Port shall implement or shall ensure that its tenants implement the following air district guide measures: • Encourage the provision of transit enhancing infrastructure that includes: transit shelters, benches, etc.; street lighting; route signs and displays; and / or bus turnouts / bulbs. • Encourage the provision of park and ride lots and/or satellite telecommuting centers. • Implement carpool / vanpool program (e.g., carpool ridematching for employees, assistance with vanpool formation, provision of vanpool vehicles, etc. Transportation Implement Feasible 4.3.1 Yes • Establish mid-day shuttle service from worksite to food service establishments / commercial areas. Port and Circulation Travel Demand Measures • Provide shuttle service to transit stations / multimodal centers. • Provide preferential parking (e.g., near building entrance, sheltered area, etc.) for carpool and vanpool vehicles. • Implement parking fees for single occupancy vehicle commuters. • Implement parking cash-out program for employees (i.e., non-driving employees receive transportation allowance equivalent to value of subsidized parking). • Provide transit incentives. • Implement compressed work week schedule (e.g., 4/40, 9/80). • Implement home-based telecommuting program. As it relates to traffic impacts associated with the Proposed Project, the Port shall develop an overall TDM Plan for the West Complex Development Plan. In developing the TDM Plan, the above measures would be included as components of the plan to be applied as appropriate to the specific uses developed. Additional measures, appropriate to the Project Area, not listed above may also be included in the TDM Plan. As specific high-density employment projects within the Project Area are proposed, additional measures based upon the TDM Plan shall be developed and implemented, and shall be specifically tailored to address the specific characteristics of each project. Until such time that the City, County, SJCOG and Caltrans approve an alternative access plan for the Port that reduces potential conflicts with adjacent residential uses the Port shall develop and implement a truck travel control plan to reduce the effects of project- related truck traffic on local roadways within the vicinity of the Project Area. The plan shall identify feasible methods to manage truck traffic accessing the Project Area, includi ng the following: • As alternative access becomes available from the West Complex (i.e., Daggett and McCloy Roads), the Port will direct truck traffic, in coordination with Transportation Develop and Implement Caltrans and to the extent capacity of Highway 4 allows, to that route; 4.3.2 No N/A and Circulation Truck Travel Control Plan • Additional signage will be provided to direct trucks to only designated truck routes; • Additional signage will be provided to limit truck speeds in residential areas or other areas of potential conflict with pedestrians and/or passenger vehicle traffic; The Port will continue to work with the City, County, and Caltrans on studies of alternative access routes and will coordinate with all agencies in the implementation of the Truck Travel Control Plan.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-1 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility Contribution of Fair The Proposed Project is not the only source of traffic congestion on the roadway facilities that would be affected by implementation of the Proposed Project. Transportation Share for Upon establishment by the City of Stockton, San Joaquin County, or other appropriate public agencies of fair share fee programs to fund construction of 4.3.4 No N/A and Circulation Intersection/Roadway Intersection/ Roadway improvements identified in Appendix D, the Port will contribute its fair share of funding for the cost of improvements that would be Improvements required to improve the levels of service on intersections/roadways affected by the Proposed Project. Retain an Air Quality Port for remediation The Port shall comply with the SJVUAPCD’s Regulation VIII control measures, and shall retain an onsite air quality monitor during periods of construction-related Monitor During Periods activities and Denmar for 4.4.1a Air Quality Yes activity to ensure compliance with the SJVUAPCD’s Regulation VIII control measures. The monitor must be familiar with the SJVUAPCD’s Regulation VIII Fugitive of Construction-Related terminal construction PM10 Prohibitions, including implementation of all feasible control measures specified in the SJVUAPCD’s Guide for Assessing Air Quality Impacts. Activity activities When the Port approves a project component implementing the West Complex Development Plan, the Port will require compliance with any feasible and appropriate SJVAPCD Enhanced and Additional Control Measures applicable to the particular project component. Proposed to be modified as follows (underlines represent new text): When the Port approves a project component implementing the West Complex Development Plan, the Port will require compliance with any feasible and appropriate SJVAPCD Enhanced and Additional Control Measures applicable to the particular project Further Reduction of component. Port for remediation Emissions of In addition, the Port would further require compliance with its current standard idling and construction equipment requirements, which would supersede Mitigation activities and Denmar for 4.4.1b Air Quality Yes Construction-related Measure 4.4.1c. These include the following: terminal construction Fugitive Dust • Idling Restrictions. Denmar will require construction contractors to minimize heavy-duty construction idling time to 2 minutes where feasible. Exceptions include activities vehicles that need to idle to perform work, vehicles being serviced, or vehicles in a queue waiting for work. • Use of Tier 4 Engines During Construction. All off-road diesel-powered heavy equipment exceeding 50 horsepower used to construct the proposed Project will be equipped with Tier 4 engines, except for specialized equipment or when Tier 4 engines are not available. The combined ratings of all non-Tier 4 diesel engines in use at any time during project construction shall not exceed 200 horsepower. Port for remediation Minimization of activities and Denmar for 4.4.1c Air Quality Yes Construction Equipment The Port shall require construction contractors to minimize idling time from heavy duty construction equipment (e.g., scrapers, graders, trenchers, earthmovers. terminal construction Emissions activities Port for remediation Further Reduction of When the Port approves a project component implementing the West Complex Development Plan, the Port will consider the Construction Equipment Mitigation activities and Denmar for 4.4.1d Air Quality Yes Exhaust Emissions from Measures identified by the SJVAPCD, and will implement those Construction Equipment Mitigation Measures that the Port determines are feasible and terminal construction Construction Equipment appropriate for the specific project-component. activities As part of the Proposed Project, the Port has included internal roadway improvements designed to reduce congestion. The Port will monitor roadways within the Reduction of Truck 4.4.2a Air Quality No Project Area and will, to the extent feasible, improve onsite roadways as necessary to reduce congestion and truck idling. The Port also will carry out a truck driver N/A Emissions information program aimed at reducing truck-idle emissions. Reduction of Emissions As equipment is replaced or new equipment is added, the Port shall require that cargo-handling diesel equipment at the West Complex include new engines 4.4.2b Air Quality Yes from Heavy Duty Yard meeting California emission standards for new diesel engines. Orientation of buildings to the north for natural cooling and the use of appropriate landscaping Denmar Equipment that maximize the potential of passive solar design principles. At each time that the Port evaluates a project-specific proposal expected to result in a substantial increase in truck trips, the Port will evaluate the feasibility of adopting a mitigation measure for that project that would implement a program to provide incentives to truck owners to retrofit, repair, or replace diesel engines Evaluate the Feasibility of in trucks which would primarily serve activities within the Port. In addition, on an ongoing basis Port staff will work with regional transportation planning agencies, 4.4.2c Air Quality No Implementing a Diesel N/A local governments, and regional and state air quality agencies to determine whether grant money would be available to the Port to fund an incentive program Engine Retrofit Program pertaining to diesel truck mitigation, to attempt to obtain such grant money to the extent that it is available and feasibly could be applied to Port-related trucking operations, and to use such grant money to reduce emissions from Port-related trucking operations. Reduction in Emissions The Port will require that all off-road and portable diesel-powered equipment, including harbor craft, to use ARB-certified diesel fuel (non-taxed version suitable 4.4.2d Air Quality Yes from All Off-Road Denmar for use off-road). Equipment Heavy Duty Vehicle 4.4.2e Air Quality No The Port will provide all port heavy duty vehicle users information regarding the SJVAPCD Heavy Duty Engine incentive (Carl Moyer) programs. N/A Education Program

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-2 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility Construction activities shall be limited to between 7:00 a.m. and 7:00 p.m. If nighttime construction were required, spot noise monitoring would be required to Limit Construction assure that noise levels from construction activities do not exceed 65 Lmax at the property line of the nearest residence. Measures to reduce nighttime 4.5.1a Noise Yes Activities to Between Denmar construction noise levels may include using noise barriers or reducing the amount of construction activity until noise levels are below the nighttime significance 7:00am and 7:00pm criterion. Construction equipment noise shall be minimized during project construction by muffling and shielding intakes and exhaust on construction equipment (per the Minimize Construction 4.5.1b Noise Yes manufacturers’ specifications) and by shrouding or shielding impact tools. All equipment shall have sound-control devices no less effective than those provided by Denmar Equipment Noise the manufacturer. Position Staging Areas 4.5.1c Noise Yes Material stockpiles and vehicle staging areas shall be located as far as practicable from residences. Denmar Furthest from Residences Direct Ships to Berths Furthest Away from As feasible, maritime vessels shall be directed away from berths located across from residential areas to other available locations. Ships shall be directed to these 4.5.2a Noise Yes Port Sensitive Receptor available locations at the time that a vessel makes its initial call to the Port. Locations At the request of any homeowner where noise from Port operations exceeds 60 DNL, the Port will retain a qualified acoustical consultant to evaluate interior noise levels to determine if Port operations are resulting in interior noise that exceeds 45 DNL. Residences with air-conditioning will be evaluated with windows closed; residences with no air conditioning will be evaluated with windows open if that is the normal operating condition. If it is determined that Port operations are resulting in interior noise levels exceeding 45 DNL, the Port will identify building treatments to reduce interior noise resulting from Port operations to 45 DNL or less. Treatments may include installation of air-conditioning, upgrading windows and doors, and eliminating noise flanking paths. The Port will provide construction Implement Noise- drawings and specifications for the treatments to the homeowner. The homeowner will then be responsible for receiving 3 bids from qualified contractors to Reducing Treatments at implement the treatments. 4.5.2b Noise Yes Port Sensitive Receptor The Port will promptly pay the homeowner for the cost of the lowest bid after treatments are completed and accepted by the homeowner. The Port will pay for normal Locations installation of the treatments but will not pay for any additional work necessary to allow installation of the treatments (e.g., repair of dry rot or termite damage). Although significant ship noise impacts will not occur until the Proposed Project becomes operational, the treatment program for these residences will begin upon issuance of the last permit required for the dredging project to proceed. Depending on the number of requests received for monitoring and the number of residences qualifying for treatment, the Port reserves the right to spread monitoring and treatment over 10 years, using a priority system that addresses the most impacted residences first. Once the program begins, the owner of each impacted residence may select the time at which noise monitoring and, if necessary, treatment, will occur, but the Port will treat each residence no more than once. Baffle Stationary Land- 4.5.2c Noise Yes Stationary land-based generators within the marine terminal shall be baffled to the extent feasible in order to minimize increases in the ambient noise level. Denmar based Generators Unfortunately, most of the residences affected by traffic noise are not located where sound walls could be built to reduce traffic noise. There are too many driveways (cutouts) that would reduce the effectiveness of sound walls. Mitigation Measure 4.5- 3b provides potential mitigation for these receptors. At the time that the project results in a doubling of traffic on Fresno Avenue adjacent to San Joaquin Elementary School, the project shall construct a sound wall to mitigate traffic noise at the school. The sound wall shall be designed to provide at least a 5 dBA noise reduction and constructed with the concurrence of the school. Build a Sound Wall Should the school prefer not to have the sound wall built, noise-reduction measures identified in Mitigation Measure 4.5.3b shall be offered to the school. Adjacent to Fresno Doubling of traffic shall mean a 100% increase in the AM peak hour volume on Fresno Ave adjacent to San Joaquin Elementary School compared to pre-project 4.5.3a Noise No N/A Avenue for San Joaquin conditions. For the purposes of this measure, pre-project conditions shall be determined by a traffic count conducted by the Port prior to operation Elementary School implementation of the first project within the scope of the West Complex Development Plan. After the determination establishment of the pre-project conditions, the Port shall conduct a traffic count at least every two years, or according to another schedule developed in consultation with the City of Stockton or County of San Joaquin, until the earliest of the following dates: the year 2020, or the year when it is determined that a 100% increase over pre-project conditions has occurred. The Port may use traffic counts conducted by another public agency on this road segment including, but not limited to, the City of Stockton, San Joaquin County, SJCOG, or the California Department of Transportation, in place of conducting its own traffic counts.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-3 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility At the time that the project results in a doubling of traffic for the sensitive receptors identified in this impact, the Port will retain a qualified acoustical consultant to evaluate interior noise levels to determine if Port operations are resulting in interior noise that exceeds 45 DNL. Residences with air-conditioning will be evaluated with windows closed; residences with no air conditioning will be evaluated with windows open if that is the normal operating condition. If it is determined that Port operations are resulting in interior noise levels exceeding 45 DNL, the Port will identify building treatments to reduce interior noise resulting from Port operations to 45 DNL or less. Treatments may include installation of air-conditioning, upgrading windows and doors, and eliminating noise flanking paths. The Port will provide construction drawings and specifications for the treatments to the homeowner. The homeowner will then be responsible for receiving 3 bids from qualified contractors to implement the treatments. Implement Additional The Port will promptly pay the homeowner for the cost of the lowest bid after treatments are completed and accepted by the homeowner. The Port will pay for normal Noise-Reducing installation of the treatments but will not pay for any additional work necessary to allow installation of the treatments (e.g., repair of dry rot or termite damage). 4.5.3b Noise No Measures at Sensitive Depending on the number of requests received for monitoring and the number of residences qualifying for treatment, the Port reserves the right to spread N/A Receptor Locations monitoring and treatment over 10 years, using a priority system that addresses the most impacted residences first. Once the program begins, the owner of each Impacted by Trucks impacted residence may select the time at which noise monitoring and, if necessary, treatment, will occur, but the Port will treat each residence no more than once. Doubling of traffic shall mean a 100% increase in the AM peak hour volume on the road segments identified in Impact 4.5.3 compared to pre-project conditions. For purposes of this measure, pre-project conditions shall be determined by a traffic count conducted by the Port prior to implementation of the first project within the scope of the West Complex Development Plan. After the determination establishment of the pre-project conditions, the Port shall conduct a traffic counts once at least every two years, or according to another schedule developed in consultation with the City of Stockton or County of San Joaquin, until the earliest of the following dates: the year 2020, or the year when it is determined that a 100% increase over pre-project conditions has occurred. The Port may use traffic counts conducted by another public agency on those road segments including, but not limited to, the City of Stockton, San Joaquin County, SJCOG, or the California Department of Transportation, in place of conducting its own traffic counts. To ensure the island’s perimeter levee (Rough and Ready Island only) would provide sufficient protection in the event of an earthquake, the Port shall establish an Establish an Annual Geology and annual levee-monitoring and inspection program. The purpose of the program will be to review and, if needed, reinforce the structural integrity of the perimeter 4.6.3 No Levee Monitoring and N/A Soils levee on an annual basis over the lifetime of the Development Plan in accordance with applicable local, state, and federal requirements. A licensed geotechnical or Inspection Program civil engineer shall prepare levee treatments proposed under the program. The annual levee-monitoring and inspection program referred to in mitigation measure 4.6.3 shall include inspection, monitoring, and, where necessary, reinforcement of any segments of shoreline on the north side of the DWSC, across from the West Complex, between the Calaveras River and the eastern leg of the Levee Monitoring Burns Cut-off that is either inadequately protected, unprotected or eroding in order to protect against levee erosion due to increased tug boat traffic during the Geology and Considerations for the 4.6.4 No lifetime of the Development Plan. A licensed geotechnical or civil engineer shall prepare levee treatments proposed under the program in accordance with N/A Soils Northwestern Portion of applicable local, state and federal requirements. the West Complex Where there is an existing levee or shoreline maintenance program in place, such as a Reclamation District levee maintenance program, the Port of Stockton shall work with the existing program. All construction plans and activities shall implement multiple BMPs to provide effective erosion and sediment control. These BMPs shall be selected to achieve maximum sediment removal and represent the best available technology that is economically achievable. BMPs to be implemented as part of this mitigation measure shall include, but are not limited to, the following measures: • Temporary erosion control measures (such as silt fences, staked straw bales/wattles, silt/sediment basins and traps, check dams, geofabric, sandbag dikes, and temporary revegetation or other ground cover) will be employed for disturbed areas. • Protect the storm drain inlets on the site and in downstream off-site areas from sediment with the use of BMPs acceptable to the Port and City of Stockton. • Sweep dirt and debris from paved streets in the construction zone on a regular basis, particularly before predicted rainfall events. Require Erosion and Port for remediation • Hydrology and Sediment Control BMPs Establish grass or other vegetative cover on the construction site as soon as possible after disturbance. At minimum, vegetative application shall be done by activities and Denmar for 4.7.1 Yes Water Quality for All Construction September 15th to allow for plant establishment. No disturbed surfaces will be left without erosion control measures in place during the period of October terminal construction Activities 15th to April 15th. activities While data is scarce regarding the effectiveness of BMPs as erosion and sediment controls, the expected pollutant removal efficiencies given in Table 4.7-1 suggest that multiple BMPs used in combination, properly installed and maintained, can achieve nearly complete sediment removal. Therefore multiple BMPs shall be selected to achieve this result and protect water quality. The final selection and design of erosion and sediment controls shall demonstrate that this result can be achieved. Implementation of this mitigation measure shall be the responsibility of the party carrying out the action, or its contractors. In all cases, these BMPs shall be subject to approval by the Port at its discretion, and the Port and/or tenants shall incorporate into contract specifications the requirement that the contractor(s) comply with and implement these provisions, as well as provisions for monitoring to verify that these standards are met.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-4 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility This mitigation measure may be integrated with other regulatory requirements associated with construction activities, such as compliance with the Port’s municipal NPDES permit, the General Construction Permit, the City of Stockton Storm Water Management and Discharge Control Ordinance, and the City of Stockton Grading and Erosion Control Ordinance. The Port shall prepare a master Drainage Plan for the Project Area. The Drainage Plan will incorporate measures to maintain runoff during peak conditions to pre- construction discharge levels. The Port will implement measures provided in the Drainage Plan. A detailed drainage report shall be prepared by a registered civil engineer prior to site development. The report shall include the following items: • An accurate calculation of pre-development runoff conditions and post-development runoff scenarios shall be conducted using appropriate engineering methods. This analysis will more accurately evaluate potential changes to runoff through specific design criteria. The model will account for increased surface runoff. • An assessment of existing drainage facilities within the Project Area, and an inventory of necessary upgrades, replacements, redesigns, and/or rehabilitation. Prepare a Master • Design specifications for additional retention basins if needed to attenuate peak flows. Retention basins will be sized to result in no net increase in peak Hydrology and 4.7.2 No Drainage Plan for the stormwater discharge from the site, taking into account the volume of permanent water held by the basin as discussed in Mitigation Measure 4.7.3. N/A Water Quality West Complex • A description of the proposed maintenance program for the on-site drainage system. • Standards for drainage systems to be installed on a project-specific basis. • The drainage system shall be designed to meet standards in the Stockton Municipal Code and the City of Stockton Department of Public Works Standard Specifications (current edition). The Drainage Plan shall include, and the Port shall implement, a schedule for identified drainage improvements. In addition, when approving specific developments that may result in increased drainage flows on the project site, the Port shall concurrently implement any necessary drainage improvements such that new development does not exceed the capacity of on-site drainage systems and peak stormwater discharge rates are maintained to pre-project levels. The Port, at its discretion, may require such project-specific drainage improvements to be funded and implemented by the developer (i.e., tenant, developer, and/or contractor). To minimize the amount of pollutants entering the storm drain system, project roadways and parking areas will be cleaned regularly using street sweeping Hydrology and 4.7.3a No Conduct Street Sweeping equipment. Additionally, litter and debris that may accumulate on the project site will be regularly collected and properly disposed. These activities shall be the N/A Water Quality responsibility of the Port. The Drainage Plan described above in Mitigation Measure 4.7.2 will include BMPs to maximize stormwater quality. The Drainage Plan will include both BMPs that will address the project site as a whole, as well as guidance for BMPs to be implemented for specific projects on a project-by-project basis. These BMPs shall be selected to achieve maximum contaminant removal and represent the best available technology that is economically achievable. The BMPs will include a combination of source control, structural improvements, and treatment systems and will be implemented so as to ensure, at minimum no net increase in contaminant releases in comparison with pre-project conditions. Drainage Plan Must BMPs may include but not be limited to the following: Hydrology and Include BMPs to 4.7.3b No • A wet retention basin(s), which holds a volume of stormwater until it is displaced by the next storm event, designed to provide effective water quality control. Wet N/A Water Quality Maximize Stormwater retention basins have been shown to be more effective at contaminant removal than dry detention basins. Basin features shall include the following: Quality 1. Maximize retention time for settling of fine particles. 2. Establish maintenance schedules for periodic removal of sedimentation, excessive vegetation, and debris that may clog basin inlets and outlets. 3. Maximize the retention basin elevation to allow the highest amount of infiltration and settling prior to discharge. Wet retention basins are expected to remove, at a minimum, 50 percent of suspended solids and metals, 30 percent of nitrogen and phosphorus, and up to 30 percent of pathogens (EPA, 1999). Perform an Assessment Hydrology and Prior to major project-specific development, the Port shall perform an assessment of the wastewater conveyance system. This may be performed as part of a 4.7.4 No of Wastewater N/A Water Quality Master Plan for development of the Project Area. Conveyance System Direct All Stormwater Hydrology and As part of the wharf upgrades under Phase I of the Marine Terminal Development, the Port shall install storm drainage facilities that redirect all stormwater runoff 4.7.5a No Runoff to Storm N/A Water Quality from this area into the Project Area’s storm drainage system. Drainage System Hydrology and Cover Bulk Stockpiles Port for remediation 4.7.5b Yes All stockpiles of bulk materials with potential to adversely impact water quality shall be covered or contained during the rainy season (October 15th – April 15th). Water Quality During the Rainy Season activities and Denmar for

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-5 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility terminal construction activities Port for remediation Immediately Address Hydrology and activities and Denmar for 4.7.5c Yes Releases of Hazardous The Port shall ensure the immediate clean-up of any on-site fuel spills or releases of hazardous materials. Water Quality terminal construction Materials activities The Port shall take ownership and operational responsibility of the aeration device currently owned and operated by the USACOE. The USACOE jet aerator was originally installed to mitigate for deepening of the DWSC from -30 feet to -35 feet. The aeration facility was constructed in 1993 and has been operated as Hydrology and Operate the Aeration 4.7.6 No conditions have warranted since then (USACOE, 1999). The USACOE agreed to provide aeration that would attempt to maintain a 0.2 mg/l DO increment above N/A Water Quality Device background conditions, whenever background conditions at any station measured by the City of Stockton dropped below 5.2 mg/L during September 1 through November 30. Consequently, the USACOE requirement depends on the San Joaquin River streamflow and existing background DO levels. Any new Port development shall allow a 50-foot setback from existing levees to permit continued levee maintenance and improvements as necessary for protection from major floods. The Port shall conduct regular levee maintenance to FEMA standards that are adequate to protect people and property from the Ensure a Setback from 100-year flood event. Hydrology and 4.7.9 Yes Existing Levees and Proposed to be modified as follows (underlines represent new text and strikethroughs represent removed text): Any new Port structural development shall allow a Port Water Quality Maintain Levees Reclamation District 403-approved 20 50-foot) setback from existing levees to permit continued levee maintenance and improvements as necessary for protection from major floods. The Port shall conduct regular levee maintenance to FEMA standards that are adequate to protect people and property from the 100-year flood event. The Port shall apply for a Department of the Army permit for all impacts to “waters of the U.S.,” and shall comply with all conditions of permits received. Permanent impacts to waters of the U.S. covered under this permit will be mitigated at a minimum 1:1 ratio through the purchase of mitigation credits at a Port for remediation Obtain and Comply with USACOE approved mitigation bank, or through other habitat restoration or compensation measures proposed by the Port and approved by the USACOE. Biological activities and Denmar for 4.8.1a Yes USACE Permit, Including Proposed to be modified as follows (underlines represent new text): The Port shall apply for a Department of the Army permit for all impacts to “waters of the U.S.,” Resources terminal construction Mitigation Requirements and shall comply with all conditions of permits received. Permanent impacts to waters of the U.S. covered under this permit will be mitigated at a minimum 0.5:1 ratio activities through the purchase of mitigation credits at an approved mitigation bank, or through other habitat restoration or compensation measures proposed by the Port and approved by the USACE, RWQCB, and CDFW. Staging areas for construction activities in the Project Area shall be located in developed areas or disturbed habitat; staging areas will be prohibited within “waters Port for remediation Biological Site Staging Areas Away of the U.S.” All staging areas shall be delineated on detailed plans and reviewed by a qualified biologist. Temporary stockpiling of excavated or imported material activities and Denmar for 4.8.1b Yes Resources from Waters shall occur only in these approved construction staging areas. Excess excavated soil shall be disposed of at a regional landfill or at another approved and/or terminal construction properly permitted location. Stockpiles that are to remain on the site through the wet season shall be covered or otherwise protected to prevent erosion. activities Port for remediation Use Standard BMPs to Biological The Port shall require the use of silt fences and/or straw bales and any other standard and appropriate BMPs by construction contractors in an effort to prevent activities and Denmar for 4.8.1c Yes Avoid Accidental Fill of Resources accidental fill of “waters of the U.S.” because of construction activities. terminal construction Waters activities Port for remediation Use Standard BMPs to Biological Standard precautions will be employed by construction contractors to prevent the accidental release of fuels or other hazardous materials associated with activities and Denmar for 4.8.1d Yes Prevent Hazardous Resources construction equipment. terminal construction Releases activities Port for remediation Biological The proponents of future development activities resulting from the Proposed Project, including an increase in maritime traffic in the DWSC, shall comply with the activities and Denmar for 4.8.2a Yes Comply with the SJMSCP Resources terms of the SJMSCP, or (see 4.8.2.b) terminal construction activities Upon determination of final project configuration and before any construction activities, a qualified biologist shall delineate all SJMSCP-listed special-status Conduct Special-status Port for remediation species habitat occurring within the vicinity of proposed project sites and DWSC. If it is determined that any special-status species may be affected by proposed Biological Species and Habitat activities and Denmar for 4.8.2b Yes construction activities or increased maritime traffic in the DWSC, the proponents of future development activities resulting from the Proposed Project shall Resources Avoidance and terminal construction implement pertinent avoidance and mitigation measures commensurate with those described in Sections 5.2 and 5.3 of the SJMSCP (see Appendix K), subject to Mitigation activities review and approval by the appropriate regulatory agencies. Mitigation measures may include, but are not limited to, the following:

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-6 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility 1. Specified construction timing to avoid impact to migratory or seasonal species. 2. Replacement of habitat at a 1:1 ratio. 3. Transplantation of special-status plant species to protected areas. 4. Purchase of credits from an approved mitigation bank. 5. Maintain buffers from special-status species habitat 6. Construction monitoring by a qualified biologist. 7. Complying with Mitigation Measures 4.7.5a and 4.7.5b. Upon determination of final project configuration and before any construction activities, a qualified biologist shall evaluate proposed construction areas (including rights-of-way and staging areas) for round-leaved filaree and soft bird’s beak habitat. If suitable habitat occurs within proposed construction areas, surveys for these species shall be conducted by a qualified biologist during the appropriate time of year to identify each species (March through May for round-leaved filaree and July to November for soft bird’s beak). Surveys shall conform to “Guidelines for Assessing the Effects of Proposed Projects on Rare, Threatened, and Endangered Plants and Natural Communities” (CDFG, 2000). If either species is detected within construction areas, the project shall buffer with orange fencing and avoid all identified specimens and notify the appropriate regulatory agency (i.e., USFWS for federally listed species, and CDFG for state rare plants and plants Port for remediation Conduct Pre- Biological identified by CNPS). If sensitive plants cannot be avoided by the project, additional measures will be developed in consultation with the appropriate regulatory activities and Denmar for 4.8.3 Yes construction Rare Plant Resources agencies. These measures may include, but are not limited to the following: terminal construction Surveys • Minimize impacts by restricting removal of plants to a few individuals of a relatively large population; activities • Relocating plants to suitable habitat outside the project area; • Monitoring affected populations to document potential project-related impacts; • Restoring or enhancing occupied habitat onsite or at another regional location; and/or • Protecting occupied habitat for the species on-site or at another regional location. Continued Ballast Water Biological 4.8.4 Yes Management Plan Continued Implementation of existing Ballast Water Management Plan Port Resources Implementation Pursuant to CEQA Guidelines 15064.5 (f), “provisions for historical or unique archaeological resources accidentally discovered during construction” should be instituted. Therefore, in the event that any prehistoric or historic subsurface cultural resources are discovered during ground disturbing activities, all work within 50 feet of the resources shall be halted and the Port shall consult with a qualified archaeologist or paleontologist to assess the significance of the find. If any find is determined to be significant, representatives of the Port and the qualified archaeologist and/or paleontologist would meet to determine the appropriate avoidance measures or other appropriate mitigation. All significant cultural materials recovered shall be subject to scientific analysis, professional museum curation, and a report prepared by the qualified archaeologist according to current professional standards. If the discovery includes human remains, CEQA Guidelines 15064.5 (e)(1) shall be followed, which is as follows: • (e) In the event of the accidental discovery or recognition of any human remains in any location other than a dedicated cemetery, the following steps should be taken: Comply with ‒ (1) There shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until: Port for remediation Cultural Requirements for activities and Denmar for 4.9.1 Yes • (A) The coroner of the county in which the remains are discovered must be contacted to determine that no investigation of the cause of death is Resources Accidental Discovery of terminal construction required, and Cultural Resources activities • (B) If the coroner determines the remains to be Native American: ‒ 1. The coroner shall contact the Native American Heritage Commission within 24 hours. ‒ 2. The Native American Heritage Commission shall identify the person or persons it believes to be the most likely descended from the deceased Native American. ‒ 3. The most likely descendent may make recommendations to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code Section 5097.98, or ‒ (2) Where the following conditions occur, the landowner or his authorized representative shall rebury the Native American human remains and associated grave goods with appropriate dignity on the property in a location not subject to further subsurface disturbance.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-7 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility • (A) The Native American Heritage Commission is unable to identify a most likely descendent or the most likely descendent failed to make a recommendation within 24 hours after being notified by the commission; • (B) The descendant identified fails to make a recommendation; or • (C) The landowner or his authorized representative rejects the recommendation of the descendant, and the mediation by the Native American Heritage Commission fails to provide measures acceptable to the landowner. Shade and Direct New Visual 4.10.4a Yes Lighting Away from Stationary overhead light fixtures shall be shaded and directed away from adjacent residential areas. Denmar Resources Residences Visual Minimize Exterior 4.10.4b Yes Exterior lighting shall only be used where necessary for safety and security purposes. Denmar Resources Lighting Detailed information about the past and current uses, records of known contamination and hazardous materials usage and hazardous waste generation of the Review of Past and specific area(s) proposed for development and improvements should be reviewed prior to site preparation and construction activities. If contamination has Current Uses, Records of Hazardous occurred, the site(s) should be characterized to determine the nature and extent of contamination that is present before construction activities proceed at the Known Contamination 4.11.1a Materials and Yes site(s). Should further investigation reveal high levels of hazardous materials in the soil or groundwater beneath the site(s), a qualified professional, in consultation Port and Hazardous Materials Public Health with appropriate regulatory agencies (i.e., DTSC, RWQCB, SJCEHD, and Stockton Fire Department) shall then develop an appropriate method to remediate the Usage, and Hazardous contamination. If necessary and allowed, a remediation plan in conjunction with continued construction shall be implemented. In addition, a contingency plan to Waste Generation dispose of any contaminated soil or groundwater shall be developed through consultation with the DTSC, RWQCB, SJCEHD, and the Stockton Fire Department. If unidentified contaminated soil and/or groundwater is encountered or if suspected contamination is encountered during any construction activities, work shall Halt Work if Unidentified Port for remediation Hazardous be halted in the area, and the type and extent of the contamination shall be identified. A qualified professional, in consultation with appropriate regulatory Contaminated Soil or activities and Denmar for 4.11.1b Materials and Yes agencies (i.e., DTSC, RWQCB, SJCEHD, and Stockton Fire Department) shall then develop an appropriate method to remediate the contamination. If necessary and Groundwater Are terminal construction Public Health allowed, a remediation plan in conjunction with continued construction shall be implemented. In addition, a contingency plan to dispose of any contaminated soil Encountered activities or groundwater shall be developed through consultation with the DTSC, RWQCB, SJCEHD, and the Stockton Fire Department. During project-specific development review, the Port and other appropriate regulatory agencies (i.e., DTSC, RWQCB, SJCEHD, and Stockton Fire Department) Port for remediation Hazardous Ensure Site Access for should evaluate each project to ensure that all easements or accesses for operation of investigative or remedial systems are maintained. At that time a decision activities and Denmar for 4.11.2 Materials and Yes Remediation Activities should be made as to what type of construction activities and development can occur on the sites evaluated. As a result, this impact potential would be reduced terminal construction Public Health to less-than-significant. activities Implement Spill Port for remediation Hazardous The Port shall ensure through its construction permitting process or through enforcement of contractual obligation for its own projects, that all contractors Containment and activities and Denmar for 4.11.3 Materials and Yes immediately control the source of any leak and immediately contain any spill utilizing appropriate spill containment and countermeasures. If required by any Countermeasures During terminal construction Public Health regulatory agency, contaminated media shall be collected and disposed at an off-site facility approved to accept such media. Construction activities Port for remediation Hazardous Ensure Precautions to The Port shall ensure through its construction permitting process or through enforcement of contractual obligation for its own projects, that proper precautions activities and Denmar for 4.11.4a Materials and Yes Avoid Contact with Aerial will be taken (such as keeping a distance of at least 10 feet from aerial lines) in operating heavy equipment, moving long tools and sections of metal pipe, the terminal construction Public Health Lines location of scaffolding, etc. to avoid contact with aerial lines. activities

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-8 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility The Port shall ensure through its construction permitting process or through enforcement of contractual obligation for its own projects, that prior to any Port for remediation Hazardous Identify and Avoid construction activities the areas planned to be disturbed would be marked in white paint and all utility owners contacted so that utilities can be identified and activities and Denmar for 4.11.4b Materials and Yes Utilities During avoided. The utility owners will be responsible for the timely removal or protection of any existing utility facilities located within construction areas This procedure terminal construction Public Health Construction would protect the excavator from personal injury and underground facilities from being damaged. activities Port for remediation Hazardous The Port shall ensure through its construction permitting process or through enforcement of contractual obligation for its own projects, that all SJVUAPCD and Comply with Asbestos activities and Denmar for 4.11.5 Materials and Yes NESHAP regulations for the handling and disposal of asbestos containing materials, and all DHS and Cal/OSHA requirements for lead-related construction will be and Lead Requirements terminal construction Public Health implemented. activities Port for remediation Hazardous Additional Compliance The Port shall ensure through its construction permitting process or through enforcement of contractual obligation for its own projects, that all SJVAPCD and activities and Denmar for 4.11.6 Materials and Yes with Asbestos and Lead NESHAP regulations for the handling and disposal of asbestos-containing materials, and all DHS and Cal/OSHA requirements for lead-related construction will be terminal construction Public Health Requirements implemented. activities Prior to major project-specific development, the Port shall perform an assessment of the non-potable water system, and if deemed necessary complete any needed upgrades to the system. This may be performed on a project-by-project basis or as part of a Master Plan for development of the entire Project Area. The assessment will test for leaks in the non-potable water system, establish the ability of the system to provide sufficient flow for fire-fighting throughout the Assess and Upgrade the Public Services island, and identify any areas where upgrades, replacement, and/or rehabilitation is necessary to provide fire flows which conform to adopted Building Code Fire 4.12.1a No Non-potable Water N/A and Utilities Safety Standards and support the City of Stockton’s existing Class 1 ISO rating. All system improvements shall conform to the City of Stockton Department of System Public Works Standard Specifications and the Stockton Municipal Code. The assessment shall include, and the Port shall implement, a schedule that performs system improvements prior to or concurrent with new development and/or increased intensity of land use such that it does not exceed the capacity of the on-site system, and adequate fire protection flows continue to be provided. Upgrade the Non- After the upgrades performed under Mitigation Measure 4.12.1a have been completed, if it is determined that any subsequent project-level action (e.g., a new Public Services potable Water System to 4.12.1b No land use or development) would require fire flows in excess of the system capacity, the Port shall require an upgrade of the system to accommodate these fire N/A and Utilities Meet Fire Protection flow requirements as a condition of project approval. Needs Prior to approving specific developments associated with the Proposed Project, the Port shall perform a detailed assessment of the water demands associated with these developments. To ensure that water usage from the Proposed project does not exceed baseline water levels. As outlined below, the Port shall implement the following mitigation measures, if applicable: • For project-related water demands that bring the cumulative demand for potable water above the 2001 annual average of 86 AF/year, the Port shall utilize one or more of the following options: 1. Implement water conservation measures that bring cumulative demand within the Project Area at or below 86 AF/year. 2. Supply the development by utilizing any unused portion of the water historically supplied for non-potable uses (i.e., agriculture, fire flows and the golf course), estimated at 868 AF/year. Public Services Assess and Manage This option may be carried out in a variety of ways. For instance, the Port may choose to dual plumb their water system within the Project Area such 4.12.6 Yes Port and Utilities Potable Water Demands that non-potable demands are supplied from these existing surface water diversions and freeflow system. Alternatively, the Port could build a water treatment plant for potable use of such water. 3. For project-related domestic water demands which may not be filled using the above two options, or bring the cumulative demand on the Project Area above the total historic water use of 954 AF/year, the Port shall not approve any development until a firm water supply has been secured, and all agreements and financing for such a supplemental water supply are in place. This supplemental supply shall not contribute to any worsening in the overdraft condition of the aquifer. Options for such a water supply include obtaining new water rights, performing in-lieu and/or direct recharge to the aquifer, entering into contracts for water transfers, and water reclamation/reuse. As discussed in the setting above, under buildout conditions, the Proposed Project could produce approximately 0.7 mgd (788 AF/year) of wastewater that may be available for reuse, assuming it received treatment to Title 22 standards. This could account for a projected shortfall of approximately 679 AF/year at buildout. After the upgrades performed under Mitigation Measure 4.12.6 have been completed, if it is determined that any subsequent project-level action (e.g., a new land Public Services Upgrade Potable Water 4.12.7 Yes use or development) would require water supplies in excess of the system capacity, the Port shall require an upgrade of the system to accommodate these Port and Utilities System supplies as a condition of project approval.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-9 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility In compliance with the California Integrated Waste Management Act (AB 939), the Proposed Project shall implement specific source reduction measures that Public Services Implement Solid Waste require mandatory pre-processing of all solid waste generated within the Project Area. Pre-processing methods would include one or more of the following 4.12.8 No N/A and Utilities Reduction Measures source reduction measures: on-site recycling or reuse programs, composting, and/or funding off-site sorting activities by a private waste management company. Source reduction measures shall be coordinated with the City of Stockton Public Works Department, Division of Solid Waste. Settlement Agreement: PORT REQUIRED MEASURES As further described in sub-Sections 1.1 (a) and (b) and Section 1.2, below, the Port shall establish a fund in the amount of five million dollars ($5,000,000) to be used for air quality mitigation ("Air Quality Mitigation Fund'). The Parties anticipate that, rather than setting aside payments from Port revenues for this fund, much of this fund will be provided in the form of credits for lease restrictions that result in substantially fewer truck trips by older, more polluting trucks than would otherwise occur at the Port absent such lease restrictions. The Port and the NRDC estimate that this Agreement could result in as many as 330 clean trucks at the West Complex. • (a) Calculated Fund Amount. The amount of the fund will be five million dollars ($5,000,000), minus credits for lease restrictions pursuant to Section 1.2, below, and expenditures to wholly or partially subsidize the cost of replacing or retrofitting trucks that operate within the West Complex in order to comply with the most restrictive CARB or EPA on-road heavy duty diesel emission standards for NOx and PM at the time that the replacement or retrofit occurs. The amount of the fund will be calculated within ten (10) years from the Effective Date of this Agreement ("Calculation Period'). • (b) Timing for Establishment and Use of the Air Quality Mitigation Fund. The Port need not set aside, or otherwise reserve funding for, the Air Quality Mitigation Fund until the end of the Calculation Period. At the end of the Calculation Period, the Port will determine the amount, if any, remaining in the Air Establish an Air Quality S1.1 Air Quality No Quality Mitigation Fund ("Remaining Fund Amount') by deducting from five million dollars ($5,000,000) any credits for clean trucks accrued before and during N/A Mitigation Fund the Calculation Period pursuant to Section 1.2, below ("Clean Truck Credits") and any expenditures during the Calculation Period to wholly or partially subsidize the cost of replacing or retrofitting trucks that operate within the West Complex in order to comply with the most restrictive CARB or EPA on-road heavy duty diesel emission standards for NOx and PM at the time that the replacement or retrofit occurs. Within one year of the end of the Calculation Period, the Port shall expend any Remaining Fund Amount for the uses described in Section 1.1(c), below ('"Authorized Fund Uses"). • (c) Authorized Fund Uses. The Port may use Clean Truck Credits to offset all or any portion of the Air Quality Mitigation Fund. In addition, the Port may use all or any portion of the Air Quality Mitigation Fund to wholly or partially subsidize the cost of replacing or retrofitting trucks that operate within the West Complex in order to comply with the most restrictive CARB or EPA on-road heavy duty diesel emission standards for NOx and PM at the time that the replacement or retrofit occurs. Separate from the amount required in Section 1.3, below, if there is a Remaining Fund Amount at the end of the Calculation Period, the Port may use up to twenty-five percent (25%) of the Air Quality Mitigation Fund to wholly or partially subsidize the cost of replacing or retrofitting tugs, harbor craft, and switcher engines that operate at the West Complex in order to comply with the most restrictive CARB or EPA emission standards for NOx and PM at the time that the replacement or retrofit occurs. The Port may enter into a lease or contract with a tenant (" Tenant") to use the Port's facilities ("Port Lease") that restricts some or all of the trucks used in the Tenant's Port operations ("Truck Restriction") to trucks that meet the most restrictive emissions standards for PM and NOx applicable to on-road heavy duty diesel truck engines that have been adopted by CARB or EPA at the time that the Port Lease is executed ("Clean Trucks"). As of July, 2007, the most restrictive on-road heavy duty diesel engine emission standards for NOx and PM are CARB and EPA's emission standards for model year 2007 heavy-duty diesel engines; thus all trucks that are model-year 2007 or newer, or that have been retrofitted to meet or exceed these 2007 model year or newer standards, will be considered Clean Trucks until such time as CARB or EPA adopts more stringent emissions standards for on-road heavy-duty diesel engines. The definition of Clean Truck should not be interpreted as a requirement or preference for diesel trucks. Accordingly, the Port also will receive Clean Truck Credit for on-road heavy duty alternative fuel trucks that meet or exceed the emissions standards described in this paragraph. The value of the Truck Restriction for each Port Lease will be credited against the Air Quality Mitigation Fund according to the following method: Implement a Clean Truck • (a) Size of Truck Fleet. First, the Port will calculate the size of the truck fleet needed to service Tenant's transportation needs at the West Complex ("Truck S1.2 Air Quality No N/A Credit Program Fleet”). To perform this calculation, the Port must receive from Tenant the following information: (a) the average weekly number of truck round trips expected to be needed to serve the Tenant's facility, (b) the average maximum number of round trips per week that any particular truck could visit Tenant's facility (which shall be estimated using the average duration of the Tenant's delivery cycle, a five day work week and a 12 hour work day), and (c) the percentage of time that an average truck is expected to be unavailable for use due to normal maintenance, repairs, accidents or other commercially reasonable factors. The size of the Truck Fleet shall be determined by dividing the average weekly round trips by the average number of round trips per truck multiplied by the sum of one plus the percentage of time a truck is expected to be unavailable, with the result rounded up or down to the nearest whole number of trucks. For example assume that 100 round trips per week are required to service a Tenant's needs, that the Tenant's business is such that the average delivery cycle is 18 hours long and that trucks are unavailable five percent of the time. There are 60 hours available for delivery per week and at 18 hours per delivery, each truck can make 3.33 round trips per week. 100 round trips divided by 3.33 trips per truck per week is 30 trucks. Thirty trucks times 1.05 is 31.5 trucks or rounded to 32 trucks. So in this example the estimated Truck Fleet associated with the Port Lease would be 32 trucks.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-10 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility • (b) Second, the Port will determine the number of trucks that would not meet the most restrictive applicable CARB or EPA standards at the time that the Port Lease is executed ("Noncompliant Trucks") that normally would be expected to be included in the Truck Fleet serving the Tenant at the Port absent the Truck Restriction ("Baseline"). To calculate this Baseline, the Port shall multiply the Truck Fleet by the percentage that is listed for each model year in the EMFAC computer model for the first year of a Tenant's or Subcontractor's full operations under the Port Lease. For purposes of this calculation, the Port shall use the most current version of the EMFAC computer model that is authorized for use by CARB at the time that the Port Lease is executed, and the calculation shall be based on EMFAC's predicted statewide average truck fleet. The estimated percentage of trucks for each model year of Noncompliant Trucks shall be added together and the sum of these percentages shall be multiplied by the Truck Fleet and the product shall be rounded up or down to the closest whole number of trucks in each category. For example assume the Tenant will commence operations in 2010 and the EMFAC computer model shows that 82.82% of trucks in the 2010 statewide average truck fleet normally would be expected to be pre-2007 model year trucks. (The remaining 17.18% of the trucks would be model year 2007 or newer even in the absence of a Lease Restriction.) As in the example above, there are 32 trucks in the Tenant's Truck Fleet. Thirty-two trucks in the Truck Fleet times 82.82 percent is 26.5 trucks, rounded to 27 trucks. Thus, under the Baseline condition absent the Truck Restriction, it would be expected that 27 trucks in the Tenant's Truck Fleet would be Noncompliant Trucks. (The remaining 5 trucks in the Tenant's Truck Fleet would be expected to be model year 2007 or newer trucks under Baseline conditions absent a Truck Restriction.) • (c) Calculate the Number of Clean Trucks Required By The Lease Restriction, Compared to Baseline Conditions. Third, the Port will calculate the number of Clean Trucks required by the Lease, compared to Baseline conditions without the Lease Restriction. For example, assume the Truck Restriction requires that all 32 trucks in the Tenant's Truck Fleet from the example above must be Clean Trucks. Then the lease would result in 27 Clean Trucks that would have been Noncompliant Trucks absent the Lease Restriction. As another example, assume the Truck Restriction requires that 75% of the 32 trucks in the Tenant's Truck Fleet from the example above must be Clean Trucks. Then, the lease would result in 20.25 (.75 X 27 = 20.25 trucks) Clean Trucks, rounded to 20 Clean Trucks, that would have been Noncompliant Trucks under Baseline conditions absent the Lease Restriction • (d) Calculate Clean Truck Credits. For each Clean Truck under the lease that would have been a Noncompliant Truck under Baseline conditions without the Lease Restriction, the credit is $15,152. Under the first example above, the credit would be $15,152 for each of the 27 Clean Trucks that would have been Noncompliant Trucks absent the Lease Restriction. The Clean Truck credit would be $409,104. Under the second example above, the credit would be $15,152 for each of the 20 Clean Trucks that would have been Noncompliant Trucks absent the Lease Restriction. The Clean Truck credit would be $303,040. • (e) Adjustment for Truck Restriction That Phases In Clean Trucks. If a Truck Restriction requires an increase in the number of Clean Trucks over time, then the same basic methodology as described above will be employed in order to calculate the credit for additional Clean Trucks required during ·years after· the first year of full operation under the Lease. For example, if under the second example above, the Truck Restriction requires that 75% of the 32 trucks in the Tenant's Truck Fleet must be Clean Trucks in the first year of full operation, and 100% of the 32 trucks in the Tenant's Truck Fleet must be Clean Trucks within two years of that date, by 2012, then the calculation described in sub-Sections (a) through (d) above would be performed to compare the additional number of Clean Trucks expected in the Tenant's Truck Fleet in years 2011 and 2012 to the Baseline conditions for those years using the EMFAC computer model assumptions for 2011 and 2012. In this case, the credit for the first year of full operation would be calculated as described above. If an additional 10% of the 32 truck fleet would be Clean Trucks in 2011 (3.2 trucks), and if under Baseline conditions in 2011, 78% of trucks would be expected to be Noncompliant Trucks absent a lease restriction, then the lease would result in an additional 2 Clean Trucks in 2011 (3.2 X .78 = 2.49, rounded to 2). If in 2012, the remaining 15% of the 32 truck fleet would be Clean Trucks (4.8 trucks) and if under Baseline conditions in 2012, 75% of trucks would be expected to be Noncompliant Trucks absent a lease restriction, then the lease would result in an additional 4 Clean Trucks (4.8 X .75 = 3.6, rounded to 4). The additional credit would be calculated by multiplying the six additional trucks that would result from phasing in Clean Trucks under the lease (2 additional Clean Trucks in 2011 plus 4 additional Clean Trucks in 2012) by the $15,152 credit for a total of $90,912 additional credit. • (f) Adjustment for Truck Restriction Longer than Average Truck Life. If the term of a Port Lease is longer than the average truck life of eight years, then the credit will be increased by a credit attributable to this later part of the term in excess of eight years following commencement of operations. The same basic methodology will be employed to calculate the additional credit, treating the additional lease term as if it were a new lease for the later part of the term. The calculation shall use the model year distribution assumptions in the EMFAC computer model for the year of the start of the second eight-year period. A similar procedure shall be followed for any additional eight-year periods. If any remaining term is less than eight years, the credit shall be calculated but reduced pro rata based upon the number of remaining years to eight. In our example above where the Truck Fleet under the Lease is 32 trucks, the operations under the lease commence in 2010, and the Lease Restriction requires that all trucks must be Clean Trucks, if the Port Lease had a duration of 15 years, then the credit for the first eight years of operations would be calculated as provided in Sections 1.2 (a) through (d) above. The second eight year period will commence in 2019, and if the EMFAC computer model shows that in 2019 the normally expected percentage of Noncompliant Trucks totals 33.49 percent, then 32 trucks in the Truck Fleet would be multiplied by 33.49 percent for a total of 10.71, rounded to 11 trucks. Thus, under Baseline conditions in 2019, there would be 11 Noncompliant Trucks absent the Lease Restriction. If all trucks under the lease must be Clean Trucks, then the additional credit would calculated by multiplying $15,152 times the 11 Noncompliant Trucks that would be expected absent the Lease Restriction. This equals $166,672. However, the

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-11 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility lease term is 15 years, so there are only five additional years left after the first 8 years of operation. The credit therefore needs to be reduced so that it is 5/8 of the $166,672 amount calculated above, or $104, 170. Within five years of the Effective Date of this Agreement, the Port will work in good faith with the operator of tugs serving its facilities to apply to the San Joaquin Valley Air Quality Control District ("SJVAPCD") for funding under the Carl Moyer Memorial Air Quality Standards Attainment Program (or other similar program administered by the SJVAPCD) to retrofit or replace one tug operating at the Port of Stockton in order to meet or exceed the most restrictive emissions standards S1.3 Air Quality No Clean Harbor Craft applicable to tugs that has been adopted by CARB or EPA ("Tug Retrofit Funds"). If the SJVAPCD provides Tug Retrofit Funds in an amount equal to at least half the N/A cost of retrofitting or replacing one tug operating at the Port of Stockton in order to meet or exceed the most restrictive emissions standards, the Port will pay the remaining amount necessary to retrofit or replace one tug operating at the Port of Stockton. The Port's obligations under this Section 1.3 will be in addition to the obligations under Section 1.1, and the amount expended under the terms of this Section 1.3 will not be deducted from the Air Quality Mitigation Fund. • (a) WCDP EIR. The Port will not rely on the WCDP EIR to develop an area in the West Complex that includes onshore cranes used for loading and unloading containers from Ships ("Ship" is defined as an ocean-going vessel), and that is dedicated to the movement of containers to and from Ships ("Marine Container Terminal”). On the WCDP EIR, the Port will remove the "container" designation from Area Six (Container Facility-105 acres) and Area Eight (Container Expansion / lntermodal Transfer) on Figure 3-4 (Proposed Development Plan - Land Use Types). The Port may (a) continue to handle containers from Ships Additional Environmental with on-Ship cranes, and (b) use Areas Six and Eight shown on Figure 3-4 of the WCDP EIR for marine terminal facilities other than a Marine Container S1.4 Air Quality No N/A Review Terminal without triggering the Port's obligation to prepare a separate CEQA document under Section 1.4(b), below. • (b) Marine Container Terminal CEQA Document. If the Port considers approving a Marine Container Terminal, then the Port will prepare a separate CEQA document analyzing the environmental impacts of the Marine Container Terminal and mitigation measures for that terminal ("Marine Container Terminal CEQA Document”) pursuant to CEQA. The CEQA document for the Marine Container Terminal will include, but not be limited to, an analysis of: (a) wharf electrification feasibility, and (b) the potential for use of electric power by Ships calling at a Marine Container Terminal while at berth at the West Complex. The Port will provide a thirty percent (30%) discount on West Complex dockage fees to Ship owners or operators that use diesel fuels with sulfur content no higher than 2,000 parts per million ("ppm") in the Ships' auxiliary engines while operating within twenty-four (24) nautical miles of the California coastline, including while maneuvering from the San Francisco harbor when the Ship takes on a local pilot, and while at berth at the West Complex ("West Complex West Complex Dockage S1.5 Air Quality No Dockage Discount'). The West Complex Dockage Discount will terminate if: (a) Ship owners or operators calling at the West Complex are required by federal, state, N/A Discount or local law or international treaty to use diesel fuels with sulfur content no higher than 2,000 ppm in their auxiliary engines, or (b) one-third or more of the Ship calls at the West Complex are by Ships utilizing diesel fuels with sulfur content no higher than 2,000 ppm in their auxiliary engines every year for two (2) consecutive years. • (a) Refrigerated Cargo Containers. Before the Port enters into a Port Lease with a Tenant, the Port will inquire as to whether the Tenant intends to bring refrigerated cargo containers to the West Complex Regularly. For purposes of this Section, "Regularly" is defined to mean 20 or more times per month as part of the Tenant's business operations. If the Tenant intends to bring refrigerated cargo containers to the West Complex Regularly, the Port will ensure that electrical hook-ups will be provided for these refrigerated cargo containers at the West Complex. Further, the Port will require in the Port Lease described in the first sentence of this Section that heavy duty diesel trucks bringing refrigerated cargo containers to the West Complex must utilize these electrical hook- ups rather than their auxiliary power units. Electrical Hook-ups; • (b) Harbor Tugs. The Port will provide electrical hook-ups for harbor tugs at a minimum of one dock to be used regularly by harbor tugs ("Harbor Tug Dock''). S1.6 Air Quality No N/A Idling Restrictions The Port will meet with harbor tug operators to explain the importance of turning off engines when they are at the Harbor Tug Dock. Further, the Port will adopt mandatory restrictions that limit the idling of harbor tugs to thirty (30) minutes during engine start-up and fifteen (15) minutes at any other time while at a West Complex Harbor Tug Dock. The Port will locate the Harbor Tug Dock such that start-up idling will not take place at Docks 19 or 20 at the West Complex. • (c) Trucks. The Port will adopt mandatory idling restrictions that limit heavy duty diesel truck idling at the West Complex to fifteen (15) minutes. • (d) Enforcement. The Port will dedicate adequate Port staff to monitor and ensure that the operators of trucks and harbor tugs comply with the provisions set forth above in Sections 1.6(a)-(c). The Port will require that fifty percent (50%) of off-road diesel-powered construction equipment greater than 50 hp used at the West Complex must be equipped Clean Construction with Tier I or cleaner engines, as defined in the U.S. EPA Nonroad Diesel Engine Rule (2004). Equipment not designated Tier 1 by the manufacturer may achieve S1.7 Air Quality Yes Equipment at the West Port the emissions requirement described in this Section by retrofitting the equipment with the highest level of GARB-Verified Diesel Emission Control System (VDECS) Complex that is available. The Port will provide the NRDC with annual reports regarding implementation of the air quality provisions in this Section 1, including the use of the Air Quality S1.8 Air Quality No Air Quality Reporting N/A Mitigation Funds, in accordance with Section 8.4.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-12 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility The provisions in this Section 2 apply for the term of this Agreement as described in Section 6.2 to (1) the initial dredging to the length of all existing wharves at the West Complex ("Docks") to a nominal depth of thirty-five (35) feet below the mean lower low water datum, plus one foot of over-dredge, (2) maintenance S2.1 Water Quality No Dredging Considerations dredging of the Docks (together, the initial dredging and maintenance dredging described in this sentence are referred to as "Dock Dredging"), and (3) the N/A placement and reuse of dredge materials from Dock Dredging. The provisions in this Section 2 do not apply to maintenance dredging of the DWSC or to any other dredging activities other than those specified in this Section 2.1. In future WDRs for Dock Dredging, the Port will agree to: (1) the RWQCB's inclusion of a term that specifies a dredging window from July 1 to December 31 each year ("Dredging Window") and (2) to abide by such Dredging Window regardless of whether RWQCB includes such a term in any future WDRs, unless the Port obtains express authorization from the National Marine Fisheries Service ("NMFS") for a Dredging Window extension ("Dredging Window Extension") based upon biological conditions in the DWSC. The Port will notify Baykeeper of any Port request for Dock Dredging outside the Dredging Window by providing Baykeeper a Compliance with S2.2 Water Quality No copy of a written request to NMFS at the time the Port request is submitted to NMFS in accordance with Section 8.4. If the Port requests a Dredging Window N/A Dredging Window Extension, Plaintiffs/Petitioners may comment upon that request to NMFS, the Port, RWQCB, SWRCB, and the Corps; however, such comments will be limited to the items specified in terms and conditions 1 (b) of the July 7, 2006 Biological Opinion pertaining to the West Complex only and Plaintiffs/Petitioners shall not take any legal action against NMFS, the Port, RWQCB, SWRCB, the Corps or any other entity to challenge any such Dredging Window Extension. Should the Port obtain authorization for a Dredging Window Extension, the Port will undertake all protective measures required for such authorization by NMFS. The Port will not discharge any decant water from the placement at the dredge material placement site of materials dredged from Dock Dredging unless it first obtains a water quality certification from the RWQCB allowing such discharge(s). The Port will discharge decant water, if at all, only in accordance with RWQCB requirements, and to optimize water quality and minimize discharge of pollutants. The Port will monitor decant water at the dredge material placement site by (a) Obtain Approval to visual inspections, and (b) using probes to continuously measure turbidity, ammonia and dissolved oxygen in the decant water as it is discharged. Probes shall be Decant Water from Initial S2.3 Water Quality No placed near the holding pond outlet weir or orifice so as to best represent the quality of decant water as it leaves the holding pond. If, at any time during N/A Dredge Material discharge of decant water, the monitoring shows an exceedance of the RWQCB's requirements for the decant water, the Port will (1) immediately cease Placement Site discharging decant water until such time as the cause of the exceedance has been identified and corrected; (2) notify Baykeeper within twenty-four (24) hours of this exceedance; and (3) provide Baykeeper the monitoring data regarding this exceedance as soon as possible and, in any event, within two weeks of any such exceedance. Specification D (RN1 Site-Soil Limitation & Reuse Specification) in the West Complex Waste Discharge Requirements for Docks 14 and 15 adopted by the RWQCB on August 4, 2006 ("Current WDRs") states in part: "Placement and reuse of dredged sediment will be restricted to use as foundation material beneath engineered covers such as buildings, foundation slabs, parking lots or roadways; and at least two feet above any significant groundwater bearing zone" ("Specification D"). The Port agrees to comply with Specification D for reuse of dredged sediment from Dock Dredging unless an exception is permitted pursuant to this Section 2.4. Obtain Approval to In both the Current WDRs and in future WDRs, the Plaintiffs/Petitioners will support an exception to Specification D for sediments that meet the criteria for S2.4 Water Quality No Reuse Dredge Material "Wetland Surface Material" as such criteria are listed in Table 4, titled "Recommended Sediment Chemistry Screening Guidelines for Beneficial Reuse of Dredged · N/A from Docks 14 and 15 Material" in Draft Staff Report, Beneficial Reuse of Dredged Materials, Sediment Screening and Testing Guidelines (May 2000) prepared by the staff of the San Francisco Bay Regional Water Quality Control Board ("Table 4 Criteria"). To determine whether the sediment quality meets Table 4 Criteria, testing will comply with Corps' Public Notices 99-3 and 99-4 and Corps' Inland Testing Manual. If the sediments to be reused do not meet Table 4 Criteria and the Port requests an exception to Specification D, then Plaintiffs/Petitioners reserve the right to challenge the Port's request before the RWQCB and SWRCB and to seek administrative and judicial review of any decision by the RWQCB or SWRCB on this request and/or of any Port actions in connection with this request. Reuse of Dredge For dredge materials from Dock Dredging that both are subject to Specification D and that do not meet the Table 4 Criteria, the Port will (a) provide Baykeeper S2.5 Water Quality No Material Subject to and the RWQCB with documentation where reused materials will be placed; and (b) require that deed restrictions or other appropriate, and similarly restrictive, N/A Specification D notices are recorded for any sites where the dredge materials are reused to ensure compliance with Specification D. In future WDRs for Dock Dredging, the Port will agree to WDRs that specify quarterly monitoring at the dredge material placement sites, including samples of Monitoring at Dredge ponded water (in addition to groundwater monitoring) for all of the parameters listed in the groundwater monitoring table in the Current WDRs. The Port will S2.6 Water Quality No N/A Material Placement Sites comply with this requirement regardless of whether it is actually contained in such future WDRs. The Port will provide this monitoring data to Baykeeper at the same time as it provides the data to RWQCB. The Current WDRs state in part that the Port shall provide 2,500 lbs of oxygen per day during the months of December through August, up to a maximum of 250,000 lbs per year, whenever background concentrations of dissolved oxygen ("DO") drop below 5.2 mg/L ("DO Triggering Conditions"). Notwithstanding this Dissolved Oxygen S2.7 Water Quality No provision, the Port agrees that it will not cap its annual provision of DO at 250,000 lbs per year and will instead provide 2,500 lbs of oxygen per day whenever the N/A Restrictions DO Triggering Conditions are met. However, if the Port determines that it is necessary for the Port to cap its annual provision of DO, the Port may request that the RWQCB reinstate an annual cap to protect the Port from undue hardship ("DO Cap Request”). If the Port makes a DO Cap Request to the RWQCB,

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-13 April 2021

Applicable Resource to Proposed Reference Topic Project? Measure Summary Mitigation Measure Responsibility Plaintiffs/Petitioners reserve all rights to challenge the DO Cap Request before the RWQCB and SWRCB and to seek administrative and judicial review of any decision by the RWQCB or the SWRCB on the DO Cap Request. For any Current WDRs or future WDRs for Dock Dredging that require the Port to supply oxygen to the DWSC during Dock Dredging when DO levels drop below a stated threshold, the requirement to supply oxygen will be triggered based upon an hourly average DO concentration rather than a daily average DO Interpreting DO S2.8 Water Quality No concentration. For Current WDRs or future WDRs for Dock Dredging that require that the Port provide a specified daily amount of oxygen during dredging (e.g., N/A Requirements in WDRs 500 pounds per day), the Port will provide the full daily amount of oxygen each day that dredging occurs, even if the dredger does not operate during all twenty- four (24) hours of the day. The Port will provide Baykeeper and the RWQCB the results of the Port-commissioned study by Dr. Gary Lytton to evaluate the effectiveness of the Port's S2.9 Water Quality No Provide Lytton's Report introduction of DO into the water column, as soon as the Port receives Dr. Lytton's final report, and, in any event, no later than twelve (12) months from the N/A Effective Date of this Agreement. Plaintiffs/Petitioners may elect to enforce the following WDRs through a private contract right of action or through normally available administrative procedures at the RWQCB or SWRCB: (a) Discharge Prohibition Nos. 8 and 23, Discharge Specifications Nos. 9, 10, and 13, and Provision 14 in the Current WDRs or any similar provisions in future WDRs for Dock Dredging. The Port expressly acknowledges that, among other things, Discharge Prohibition Nos. 8 and 23 prohibit the Port from dredging any time certain specified turbidity requirements are exceeded; (b) The provisions of any future WDRs for the West Complex authorizing discharge of decant water from dredged materials placed at the dredge material placement site from Dock Dredging, but only to the extent that such provisions apply to the discharge of decant water; and (c) The requirement in Provision 4 of the Current WDRs that the Port submit a Sediment Toxicity Assessment/ Remediation Workplan for RWQCB Executive Officer approval within ninety (90) days following notification of a toxic sediment condition. This private right of action does not include any other Provision 4 requirement in the Current WDRs or future WDRs including, but not limited to, enforcing the requirements of WDR Provision 4 Private Right of Action to S2.10 Water Quality No pertaining to the content of the Sediment Toxicity Assessment/Remediation Workplan, the standards by which sufficiency of the Sediment Toxicity N/A Enforce Terms in WDRs Assessment/Remediation Workplan are to be judged, or any other aspect of this provision. Collectively, the requirements subject to a private right of action in subsections (a) through (c), above, are the "Specified WDR Provisions". The Port will comply with the Specified WDR Provisions in all Dock Dredging. Plaintiffs/Petitioners must elect to pursue each alleged violation of a Specified WDR either through (a) proceedings before the RWQCB and the SWRCB, or (b) litigation enforcing Plaintiffs/Petitioners contractual rights brought within one hundred twenty (120) days of the later of the following (i) the alleged violation, or (ii) the date one or more of the Plaintiffs/Petitioners know or should have known of the violation. The contractual remedy for any violation of a Specified WDR will be limited to injunctive relief. Plaintiffs/Petitioners will bear the burden of proving that the Port's interpretation of and compliance with the applicable Specified WDR_ Provision is not supported by substantial evidence. The federal court will not retain jurisdiction over any litigation to determine compliance with the Specified WDR Provisions or any other provision in this Agreement. The Port will provide Baykeeper with access to all Port monitoring data required under the Current WDRs, and any future WDRs or permits issued by the RWQCB or Corps for Dock Dredging, at the same time as this monitoring data is submitted to the RWQCB or Corps. In addition, the Port will provide data from monitoring of water column turbidity during Dock Dredging to Baykeeper by 5 p.m. on the day after dredging operations have occurred. The Port will allow access to Baykeeper to independently measure DO levels and to take periodic groundwater samples at any dredged material placement site. This access is subject to a written protocol attached as Exhibit A to this Agreement, which includes measures designed to ensure safety, security, and reasonable accuracy of these S2.11 Water Quality No Independent Monitoring N/A measurements, and this access is subject to compliance with Homeland Security requirements, as such requirements currently exist or may be imposed or amended in the future. In the event that Homeland Security requirements limit access to the area within 100 feet of the dredging operations, as described in Exhibit A, the Port will act in good faith to take all legally permitted steps reasonably necessary to provide the access described in Exhibit A to Baykeeper, including but not limited to assisting Baykeeper with obtaining necessary permission or clearances, if available. In addition, to the extent allowed by Homeland Security requirements, the Port will provide Baykeeper with one tour of the Port's computer facility used for monitoring the dredging operations. Beginning on January 1, 2008 and four (4) anniversaries thereafter, the Port will provide Baykeeper annually the greater of (a) $25,000, or (b) an amount proportional to the percentage of Dock Dredging that the Port performed in the prior calendar year. The cumulative amount provided by the Port to Baykeeper S2.12 Water Quality No Monitoring Funds will be one hundred thousand dollars ($100,000) and will be used only for water quality purposes, and will not be used to take any judicial or administrative action N/A against the Port other than for purposes of monitoring or enforcing this Agreement. Payment will be made by check made payable to Baykeeper and delivered to Robert Perlmutter at the address identified in Exhibit B on or before January 1 of the applicable calendar year.

Note: All mitigation measures are from the 2004 WCDP Final EIR and 2007 West Complex Development Program EIR Settlement Agreement.

Appendix A: WCDP EIR and Settlement Agreement Mitigation Measures A-14 April 2021

Appendix B Air Quality Study

DRAFT

Appendix C Air Quality Study Table 1 Land Use Summary for Proposed Project Denmar US, LLC Stockton, California

Land Use1 CalEEMod® Land Use Size Units Square Footage

Phase 1 (2023)2 Rail Building General Light Industry 9.4 ksf 9,400 Storage Building Unrefrigerated Warehouse-Rail 187 ksf 187,000 Administrative Building General Office Building 12.1 ksf 12,100 Administrative Building - Adjacent Parking Lot Parking Lot 17 spaces 6,800 Crew Quarters Building (Marine Facility) Health Club 2.0 ksf 2,000 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot Parking Lot 9 spaces 3,600 Crew Quarters Building (Rail Facility) Health Club 2.0 ksf 2,000 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot Parking Lot 14 spaces 5,600 Full Buildout (2025)2 Rail Building General Light Industry 9.4 ksf 9,400 Storage Building Unrefrigerated Warehouse-Rail 374 ksf 374,000 Administrative Building General Office Building 12.1 ksf 12,100 Administrative Building - Adjacent Parking Lot Parking Lot 17 spaces 6,800 Crew Quarters Building (Marine Facility) Health Club 2.0 ksf 2,000 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot Parking Lot 9 spaces 3,600 Crew Quarters Building (Rail Facility) Health Club 2.0 ksf 2,000 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot Parking Lot 14 spaces 5,600

Notes: 1. Land uses analyzed based on information provided by the Project Sponsor. 2. Per the Project Description, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026.

Abbreviations: ksf - 1,000 square feet Table 2 Emissions Calculation Methodology Denmar US, LLC Stockton, California

Type Source Methodology and Formula Reference OFFROAD2017 and 1 Construction Equipment Off-Road Equipment Ec = Σ(EFc * HP * LF * Hr * C) ARB/USEPA Engine Standards

ER = Σ(EFR * VMT * C) , where Construction On-Road Mobile Exhaust – Running VMT = Trip Length * Trip EMFAC2017 Sources2 Number

Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2017

Construction Fugitive Dust 3 Material Movement Shown in Table 10 --

ER = Σ(EFR * VMT * C) , where Operational On-Road Mobile Exhaust - Running VMT = Trip Length * Trip EMFAC2017 Sources2 Number

Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2017

On-Road Fugitive Dust4 On-Road Dust Shown in Table 30 ARB

E = EF * On-Site Running Hours * Number of On-Site Exhaust - Running R-on ARB Locomotives * HP * LF E = EF * On-Site Idling Hours * Number of Rail Sources5 On-Site Exhaust - Idling I-on ARB Locomotives * HP * LF

Off-Site Exhaust - Running ER-off = EF * Σ(Weight * Distance / NAFCI) ARB

Exhaust - Transit ET = EFT * Transit Hours * HP * LF * C ARB

6 Ship Sources Exhaust - Maneuvering EM = EFM * Maneuvering Hours * HP * LF * C ARB

Exhaust - Hoteling EH = EFH * Hoteling Hours * HP * LF * C ARB

ER = EF * (1 + DF * (OY - MY) / UL) * FCF * HP * LF * Tugboat Sources7 Exhaust - Running ARB Operating Hours * C

Notes: 1. Ec: off-road equipment exhaust emissions (lb).

EFc: emission factor (g/hp-hr). CalEEMod 2016.3.2 default emission factors used. HP: equipment horsepower. OFFROAD2017. LF: equipment load factor. OFFROAD2017. Hr: equipment hours. C: unit conversion factor. 2. On-road mobile sources include truck and passenger vehicle trips. Emissions associated with mobile sources were calculated using the following formulas.

ER: running exhaust and running losses emissions (lb).

EFR: running emission factor (g/mile). From EMFAC2017. VMT: vehicle miles traveled C: unit conversion factor The calculation involves the following assumptions: a. All material transporting and soil hauling trucks are heavy-heavy duty trucks. b. Trip Length: The one-way trip length as calculated based on the truck route or the default length from CalEEMod or construction contractor. c. Trip Number: provided by the construction contractor or estimated in CalEEMod.

EI: vehicle idling emissions (lb).

EFI: vehicle idling emission factor (g/hr-trip). From EMFAC2017.

TI: idling time. C: unit conversion factor. 3. The methodology and formulas for Project construction fugitive dust emssions are shown in Table 10. 4. The methodology and formulas for on-road fugitive dust emissions are shown in Table 30. 5. Rail sources include on-site running, on-site idling, and off-site running exhaust. Emissions associated with rail sources were calculated using the following formulas.

ER-on: on-site running exhaust emissions (lb). EF: emission factor (g/bhp-hr). From ARB. HP: horsepower. Provided by Project sponsor. LF: load factor. From USEPA based on throttle notch position provided by Project sponsor. Table 2 Emissions Calculation Methodology Denmar US, LLC Stockton, California

Notes, continued:

EI-on: on-site idling exhaust emissions (lb). EF: emission factor (g/bhp-hr). From ARB. HP: horsepower. Provided by Project sponsor. LF: load factor. From EPA based on throttle notch position provided by Project sponsor.

ER-off: off-site running exhaust emissions (lb). EF: emission factor (g/gal). From ARB. NAFCI: net aggregated fuel consumption index. From ARB. 6. Ship sources include transit, maneuvering, and hoteling exhaust. Emissions associated with ship sources were calculated using the following formulas:

ET: transit exhaust emissions (lb).

EFT: transit emission factor (g/kW-hr). From ARB. HP: horsepower. From ARB. LF: load factor. From ARB. C: unit conversion factor.

EM: maneuvering exhaust emissions (lb).

EFM: maneuvering emission factor (g/kW-hr). From ARB. HP: horsepower. From ARB. LF: load factor. From ARB. C: unit conversion factor.

EH: hoteling exhaust emissions (lb).

EFH: hoteling emission factor (g/kW-hr). From ARB. HP: horsepower. From ARB. LF: load factor. From ARB. C: unit conversion factor. 7. Tugboat sources include running exhaust. Emissions associated with tugboat sources were calculated using the following formulas:

ER: running exhaust emissions (lb). EF: emission factor (g/bhp-hr). From ARB. DF: deterioration factor. From ARB. OY: operating year. MY: manufacturer year. Based on Brusco fleet operating in the Port of Stockton, according to the Port's Daily Vessel Log. UL: useful lifetime. Based on Brusco fleet operating in the Port of Stockton, according to the Port's Daily Vessel Log. FCF: fuel correction factor. From ARB. HP: horsepower. Based on Brusco fleet operating in the Port of Stockton, according to the Port's Daily Vessel Log. LF: load factor. Based on Brusco fleet operating in the Port of Stockton, according to the Port's Daily Vessel Log. C: unit conversion factor.

Abbreviations: ARB: California Air Resources Board EF: emission factor EMFAC: EMission FACtor Model g: gram HP: horsepower lb: pound LF: load factor mi: mile USEPA: United States Environmental Protection Agency VMT: vehicle miles traveled

References: ARB. 2009. Commercial Harbor Craft Inventory Model. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions- inventory/road-documentation/msei-documentation-road ARB. 2011. Emissions Estimation Methodology for Ocean-Going Vessels. Available at: https://ww3.arb.ca.gov/regact/2011/ogv11/ogv11appd.pdf ARB. 2017. Line Haul / Class I Documentation. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions- inventory/road-documentation/msei-documentation-road Table 2 Emissions Calculation Methodology Denmar US, LLC Stockton, California

References, continued: ARB/USEPA. 2017. Table 1: ARB and USEPA Off-Road Compression-Ignition (Diesel) Engine Standards. Available at: https://ww3.arb.ca.gov/msei/ordiesel/ordas_ef_fcf_2017.pdf and https://ww3.arb.ca.gov/msei/ordiesel/ordas_ef_fcf_2017_v7.xlsx.

ARB. 2017. EMission FACtors Model, 2017 (EMFAC2017). Available at: http://www.arb.ca.gov/emfac/2017/

ARB. 2018. Miscellaneous Processes Methodologies - Paved Entrained Road Dust. Available online at: https://www.arb.ca.gov/ei/areasrc/fullpdf/full7-9_2018.pdf California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2016.3.2. Available online at http://www.caleemod.com/ Table 3 Project Construction Phasing Schedule Denmar US, LLC Stockton, California

Construction1 Operations3 1 1 Construction Area Construction Activity Phase Start Phase End Number Days per Hours Start Date Date Date Work Days Week per Day Excavation and Consolidation of Waste and Contaminated Soil 1/1/2021 3/2/2021 43 5 8 Initial Remediation2 Installation of Liner and Soil Cover 3/3/2021 4/12/2021 29 5 8 Rail Buildings 1/1/2021 6/30/2022 390 5 8 Ground Improvements 1/1/2021 5/31/2022 368 5 8 Phase 1 Buildings 4/1/2021 7/31/2022 347 5 8 Operations Track Construction 7/1/2021 3/31/2022 196 5 8 Phase 1 Terminal begin on Infrastructure and Conveyors 7/1/2021 9/30/2022 327 5 8 Construction 1/1/2023 Administration Buildings 8/1/2021 3/31/2022 174 5 8 Waste Water Treatment Plant 2/1/2022 7/31/2022 129 5 8 Terminal Equipment 3/31/2022 9/30/2022 132 5 8 Commissioning 8/1/2022 11/30/2022 88 5 8 Excavation and Consolidation of Waste and Contaminated Soil 6/8/2023 12/5/2023 129 5 8 Future Remediation2 Installation of Liner and Soil Cover 12/6/2023 5/30/2024 127 5 8 Ground Improvements 1/1/2024 5/30/2024 109 5 8 Full Buildout Operations Buildings 4/1/2024 7/30/2025 348 5 8 Phase 2 Terminal begin on Conveyors 7/1/2024 5/31/2025 240 5 8 Construction 12/1/2025 Terminal Equipment 2/1/2025 8/1/2025 130 5 8 Commissioning 8/1/2025 11/30/2025 86 5 8

Notes: 1. All construction phasing information provided by HDR and Geosyntec. 2. Start and End dates for Phase 1 and Phase 2 Remediation not yet available. Start and End dates determined using the year(s) of activity and estimated number of work days. Phase 1 Remediation assumed to start on 1/1/2021, with the two activities occurring consecutively. Phase 2 Remediation assumed to start on 6/8/2023, with the two activities occurring consecutively, such that Phase 2 Remediation ends at the same time as the "Future Storage Building Ground Improvements" activity of Phase 2 Terminal Construction. 3. Per the Project Description provided by HDR, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations assumed to begin at conclusion of Phase 2 Terminal Construction. Table 4 Project Construction Off-Road Equipment List Denmar US, LLC Stockton, California

CalEEMod® Equipment Load Hours per Utilizations for Unmitigated Mitigated Construction Area Construction Activity Equipment Type1,2 Fuel4 Number1 HP1,5 Type3 Factor6 Day1 Duration1 Equipment Tier7 Equipment Tier7

Site-Wide Miscellaneous Site-Wide Miscellaneous Small Tools Other Construction Equipment Diesel 8 25 0.42 8 75% Fleet-Average Tier Tier 2 Diesel-Fueled Tools8

Bull Dozer (small) Rubber Tired Dozers Diesel 2 170 0.4 8 25% Fleet-Average Tier Tier 4 Final Bull Dozer (large) Rubber Tired Dozers Diesel 2 355 0.4 8 100% Fleet-Average Tier Tier 4 Final Excavation and Excavator (large) Excavators Diesel 2 425 0.38 8 25% Fleet-Average Tier Tier 4 Final Consolidation of Waste and Contaminated Soil Excavator (small) Excavators Diesel 2 275 0.38 8 25% Fleet-Average Tier Tier 4 Final Compactor Plate Compactors Diesel 2 405 0.43 8 50% Fleet-Average Tier Tier 4 Final Motorgrader Graders Diesel 1 140 0.41 8 25% Fleet-Average Tier Tier 4 Final Initial Remediation Bull Dozer (small) Rubber Tired Dozers Diesel 1 170 0.4 8 40% Fleet-Average Tier Tier 4 Final Bull Dozer (large) Rubber Tired Dozers Diesel 1 355 0.4 8 50% Fleet-Average Tier Tier 4 Final Excavator (small) Excavators Diesel 1 275 0.38 8 40% Fleet-Average Tier Tier 4 Final Installation of Liner and Forklift/telehandler Forklifts Diesel 1 145 0.2 8 65% Fleet-Average Tier Tier 4 Final Soil Cover Drilling rig Bore/Drill Rigs Diesel 2 350 0.5 8 40% Fleet-Average Tier Tier 4 Final Compactor Plate Compactors Diesel 1 405 0.43 8 65% Fleet-Average Tier Tier 4 Final Motorgrader Graders Diesel 1 140 0.41 8 50% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 1 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dewatering Pumps Pumps Diesel 2 84 0.74 8 10% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 2 247 0.4 8 15% Fleet-Average Tier Tier 4 Final Excavators Excavators Diesel 2 158 0.38 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Rail Buidling Graders Graders Diesel 1 187 0.41 8 15% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 1 84 0.74 8 50% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 2 63 0.31 8 20% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 4 46 0.45 8 30% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Phase 1 Terminal Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 25% Fleet-Average Tier Tier 4 Final Ground Improvements Construction Graders Graders Diesel 1 187 0.41 8 30% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 20% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 1 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 2 231 0.29 8 75% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 4 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 1 247 0.4 8 25% Fleet-Average Tier Tier 4 Final Excavators Excavators Diesel 1 158 0.38 8 50% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Graders Graders Diesel 1 187 0.41 8 25% Fleet-Average Tier Tier 4 Final Building Light Towers Generator Sets Diesel 4 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 4 84 0.74 8 50% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 4 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 8 46 0.45 8 15% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 30% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Table 4 Project Construction Off-Road Equipment List Denmar US, LLC Stockton, California

CalEEMod® Equipment Load Hours per Utilizations for Unmitigated Mitigated Construction Area Construction Activity Equipment Type1,2 Fuel4 Number1 HP1,5 Type3 Factor6 Day1 Duration1 Equipment Tier7 Equipment Tier7

Dozers Rubber Tired Dozers Diesel 2 247 0.4 8 75% Fleet-Average Tier Tier 4 Final Excavators Excavators Diesel 1 158 0.38 8 50% Fleet-Average Tier Tier 4 Final Track Construction Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Graders Graders Diesel 2 187 0.41 8 75% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 1 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 1 247 0.4 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 4 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 2 97 0.37 8 25% Fleet-Average Tier Tier 4 Final Graders Graders Diesel 1 187 0.41 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 4 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Conveyors Misc. Generators Generator Sets Diesel 3 84 0.74 8 50% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 4 63 0.31 8 20% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 8 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 4 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 1 247 0.4 8 75% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Administration Buildings Graders Graders Diesel 1 187 0.41 8 75% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 2 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Phase 1 Terminal Personnel Lifts Aerial Lifts Diesel 1 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Construction Welding Machines Welders Diesel 2 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 1 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Waste Water Treatment Light Towers Generator Sets Diesel 1 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Plant Misc. Generators Generator Sets Diesel 1 84 0.74 8 25% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 1 63 0.31 8 25% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 2 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 1 231 0.29 8 10% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final

Terminal Equipment Misc. Generators Generator Sets Diesel 3 84 0.74 8 50% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 2 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 2 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 30% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 1 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final Commissioning Misc. Generators Generator Sets Diesel 1 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 1 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 1 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 3 231 0.29 8 50% Fleet-Average Tier Tier 4 Final Table 4 Project Construction Off-Road Equipment List Denmar US, LLC Stockton, California

CalEEMod® Equipment Load Hours per Utilizations for Unmitigated Mitigated Construction Area Construction Activity Equipment Type1,2 Fuel4 Number1 HP1,5 Type3 Factor6 Day1 Duration1 Equipment Tier7 Equipment Tier7

Bull Dozer (small) Rubber Tired Dozers Diesel 4 170 0.4 8 65% Fleet-Average Tier Tier 4 Final Bull Dozer (large) Rubber Tired Dozers Diesel 4 355 0.4 8 65% Fleet-Average Tier Tier 4 Final Excavation and Excavator (large) Excavators Diesel 4 425 0.38 8 65% Fleet-Average Tier Tier 4 Final Consolidation of Waste Excavator (small) Excavators Diesel 4 275 0.38 8 65% Fleet-Average Tier Tier 4 Final and Contaminated Soil Scraper Scrapers Diesel 2 290 0.48 8 25% Fleet-Average Tier Tier 4 Final Compactor Plate Compactors Diesel 2 405 0.43 8 65% Fleet-Average Tier Tier 4 Final Motorgrader Graders Diesel 1 140 0.41 8 25% Fleet-Average Tier Tier 4 Final Future Remediation Bull Dozer (small) Rubber Tired Dozers Diesel 1 170 0.4 8 40% Fleet-Average Tier Tier 4 Final Bull Dozer (large) Rubber Tired Dozers Diesel 2 355 0.4 8 75% Fleet-Average Tier Tier 4 Final Excavator (small) Excavators Diesel 1 275 0.38 8 40% Fleet-Average Tier Tier 4 Final Installation of Liner and Forklift/telehandler Forklifts Diesel 2 145 0.2 8 40% Fleet-Average Tier Tier 4 Final Soil Cover Drilling rig Bore/Drill Rigs Diesel 2 350 0.5 8 15% Fleet-Average Tier Tier 4 Final Compactor Plate Compactors Diesel 2 405 0.43 8 65% Fleet-Average Tier Tier 4 Final Motorgrader Graders Diesel 1 140 0.41 8 40% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 1 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Graders Graders Diesel 1 187 0.41 8 75% Fleet-Average Tier Tier 4 Final Ground Improvements Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 1 84 0.74 8 75% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 50% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 4 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 1 247 0.4 8 25% Fleet-Average Tier Tier 4 Final Excavators Excavators Diesel 1 158 0.38 8 50% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 30% Fleet-Average Tier Tier 4 Final Building Graders Graders Diesel 1 187 0.41 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 4 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Phase 2 Terminal Misc. Generators Generator Sets Diesel 4 84 0.74 8 25% Fleet-Average Tier Tier 4 Final Construction Personnel Lifts Aerial Lifts Diesel 3 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 4 46 0.45 8 15% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Dozers Rubber Tired Dozers Diesel 1 247 0.4 8 75% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Front End Loaders Tractors/Loaders/Backhoes Diesel 1 97 0.37 8 50% Fleet-Average Tier Tier 4 Final Graders Graders Diesel 1 187 0.41 8 75% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 4 20 0.74 8 25% Fleet-Average Tier Tier 4 Final Conveyors Misc. Generators Generator Sets Diesel 3 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Personnel Lifts Aerial Lifts Diesel 3 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 6 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 50% Fleet-Average Tier Tier 4 Final Cranes for Ground Improvement Installation Cranes Diesel 1 231 0.29 8 25% Fleet-Average Tier Tier 4 Final Table 4 Project Construction Off-Road Equipment List Denmar US, LLC Stockton, California

CalEEMod® Equipment Load Hours per Utilizations for Unmitigated Mitigated Construction Area Construction Activity Equipment Type1,2 Fuel4 Number1 HP1,5 Type3 Factor6 Day1 Duration1 Equipment Tier7 Equipment Tier7

Air Compressors Air Compressors Diesel 2 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 2 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final Terminal Misc. Generators Generator Sets Diesel 3 84 0.74 8 50% Fleet-Average Tier Tier 4 Final Equipment Personnel Lifts Aerial Lifts Diesel 2 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 2 46 0.45 8 25% Fleet-Average Tier Tier 4 Final Phase 2 Terminal 100 ton cranes Cranes Diesel 2 231 0.29 8 50% Fleet-Average Tier Tier 4 Final Construction Air Compressors Air Compressors Diesel 1 78 0.48 8 25% Fleet-Average Tier Tier 4 Final Forklifts Forklifts Diesel 1 89 0.2 8 25% Fleet-Average Tier Tier 4 Final Light Towers Generator Sets Diesel 2 20 0.74 8 50% Fleet-Average Tier Tier 4 Final Misc. Generators Generator Sets Diesel 1 84 0.74 8 75% Fleet-Average Tier Tier 4 Final Commissioning Personnel Lifts Aerial Lifts Diesel 1 63 0.31 8 50% Fleet-Average Tier Tier 4 Final Welding Machines Welders Diesel 1 46 0.45 8 25% Fleet-Average Tier Tier 4 Final 100 ton cranes Cranes Diesel 2 231 0.29 8 50% Fleet-Average Tier Tier 4 Final

Notes: 1. Equipment list provided by Geosyntec and HDR for the Remediation and Terminal Construction phases, respectively. List included equipment type, number, horsepower, hours per day, and utilization expect as noted in the following footnotes. Note that construction hours would occur between 6AM and 9PM based on the Performance standards in the San Joaquin County Development Title (Section 0-1025.9), available online at https://library.municode.com/ca/san_joaquin_county/codes/development_title?nodeId=TIT9DETI_DIV10DERE_CH9-1025PEST_9-1025.9NO. See Table 3 for phasing information.

2. Note that the equipment lists provided by Geosyntec and HDR also included pieces of equipment not shown in the above table. The emissions associated with these pieces of equipment are accounted for elsewhere. The personnel trucks included in the Remediation equipment lists are accounted for in Table 8 as on-road worker trips. The haul/dump trucks and water trucks included in both the Remediation and Terminal Construction equipment lists are shown in Table 5 and emissions are calculated in Table 6. The emissions for the marine tug/work barge included in the Terminal Construction equipment list for the "Shiploading Equipment" activity are calculated in Table 7. 3. CalEEMod Equipment Types assigned using CalEEMod User's Guide Appendix D. Light Towers are assumed to be diesel powered and modeled as the CalEEMod equipment type Generator Sets. Horsepower assumed based on highest powered model from one potential vendor. 4. All equipment is conservatively assumed to be diesel-fueled. During construction, various small tools that are gasoline-fueled may be used. Since diesel-fueled equipment yields higher cancer risks than gasoline-fueled equipment, the all diesel-fueled equipment approach is conservative. The use of gasoline-fueled equipment would replace the use of diesel-fueled equipment, resulting in lower health impacts. The equipment list presented in this table represents the worst case scenario. 5. Horsepower (HP) for Remediation equipment provided by Geosyntec. For Terminal Construction equipment, the default CalEEMod horsepower was assumed based on the equipment type. See CalEEMod User's Guide Appendix D Table 3.3 for more details. 6. For all equipment, default CalEEMod load factor assumed based on the equipment type. See CalEEMod User's Guide Appendix D Table 3.3 for more details. 7. In order to present the best and worst-case emissions scenarios, the unmitigated tier is assumed to be fleet-average tier and the mitigated tier is assumed to be Tier 4 for all pieces of equipment except as noted in footnote 8. 8. A category for miscellaneous small tools has conservatively been added to the analysis to account for miscellaneous tools used over the duration of construction. Tier 4 engines may not be available for these tools, so this category includes 200 HP of Tier 2 diesel equipment over the entire construction duration. Since the Tier 2 emissions are greater for eight 25 HP pieces of equipment than one 200 HP, this category conservatively includes eight 25 HP pieces of equipment to ensure a conservative estimate of emissions.

Abbreviations: CalEEMod - California Emissions Estimator Model

References: CalEEMod v2016.3.2 Available online at: http://www.caleemod.com/ Table 5 Project Construction Onsite Dump Truck and Water Truck Equipment List Denmar US, LLC Stockton, California

EMFAC Hours Utilization Construction Area Construction Activity Equipment Type1 Vehicle Fuel2 Number1 per Day1 for Duration1 Type2 Excavation and Consolidation of Haul/Dump Truck MHDT Diesel 4 8 25% Waste and Contaminated Soil Water Truck MHDT Diesel 2 8 90% Initial Remediation Haul/Dump Truck MHDT Diesel 1 8 40% Installation of Liner and Soil Cover Water Truck MHDT Diesel 1 8 50% Haul/Dump Truck MHDT Diesel 2 8 25% Rail Building Water Truck MHDT Diesel 1 8 25% Haul/Dump Truck MHDT Diesel 2 8 30% Ground Improvements Water Truck MHDT Diesel 1 8 30% Haul/Dump Truck MHDT Diesel 2 8 25% Building Water Truck MHDT Diesel 1 8 25% Phase 1 Terminal Construction Track Construction Haul/Dump Truck MHDT Diesel 8 8 25% Water Truck MHDT Diesel 2 8 25% Haul/Dump Truck MHDT Diesel 2 8 25% Infrastructure and Conveyors Water Truck MHDT Diesel 1 8 25% Haul/Dump Truck MHDT Diesel 2 8 25% Administration Buildings Water Truck MHDT Diesel 1 8 25% Terminal Equipment Haul/Dump Truck MHDT Diesel 1 8 25% Excavation and Consolidation of Haul/Dump Truck MHDT Diesel 8 8 65% Waste and Contaminated Soil Water Truck MHDT Diesel 2 8 100% Future Remediation Haul/Dump Truck MHDT Diesel 2 8 40% Installation of Liner and Soil Cover Water Truck MHDT Diesel 2 8 75% Haul/Dump Truck MHDT Diesel 2 8 25% Ground Improvements Water Truck MHDT Diesel 1 8 25% Haul/Dump Truck MHDT Diesel 2 8 25% Building Phase 2 Terminal Construction Water Truck MHDT Diesel 1 8 25% Conveyors Haul/Dump Truck MHDT Diesel 2 8 25% Water Truck MHDT Diesel 1 8 25% Terminal Equipment Haul/Dump Truck MHDT Diesel 1 8 25%

Notes: 1. Haul/Dump and Water Truck quantity and utilization by construction activity provided by Geosyntec and HDR for Remediation and Terminal Construction phases, respectively. See Table 3 for phasing information. 2. Haul/Dump and Water Trucks are modeled as diesel-fueled medium-heavy duty trucks (MHDT) using EMFAC2017 emission factors. See Table 6 for emissions calculations.

Abbreviations: EMFAC2017 - Onroad Emission Factor Model MHDT - medium heavy duty truck

References: EMFAC2017. Available online at: https://arb.ca.gov/emfac/ Table 6 Project Construction Onsite Dump Truck and Water Truck Emissions Denmar- Port of Stockton Stockton, California

Onsite Truck Use Data1 Onsite Truck Emissions2,3

Construction Area Construction Activity Year Total ROG NOx CO SOx PM10 PM2.5 CO2 CH4 N O CO e Hours Trips Miles 2 2 Vehicles (lbs) (MT) Excavation and Consolidation of Waste and 2021 963 963 14,448 120 18 189 39 0.50 8.4 3.7 24 3.7E-04 0.0037 25 Initial Remediation Contaminated Soil Installation of Liner and Soil Cover 2021 209 209 3,132 26 3.8 41 8.5 0.11 1.8 0.81 5.2 8.1E-05 8.1E-04 5.2 2021 1,566 1,566 23,490 196 29 307 64 0.81 14 6.1 39 6.0E-04 0.0061 39 Rail Building 2022 774 774 11,610 97 6.1 120 17 0.39 4.8 1.1 19 1.3E-04 0.0029 19 2021 1,879 1,879 28,188 235 34 369 77 1.0 16 7.3 47 7.3E-04 0.0073 47 Ground Improvements 2022 770 770 11,556 96 6.1 119 17 0.39 4.8 1.1 19 1.3E-04 0.0029 19 2021 1,176 1,176 17,640 147 22 231 48 0.61 10 4.6 29 4.5E-04 0.0046 29 Building 2022 906 906 13,590 113 7.2 140 20 0.45 5.6 1.3 22 1.5E-04 0.0034 22 2021 2,640 2,640 39,600 330 48 518 108 1.4 23 10 65 0.0010 0.010 65 Phase 1 Terminal Construction Track Construction 2022 1,280 1,280 19,200 160 10 198 29 0.64 8.0 1.9 31 2.1E-04 0.0048 31 2021 792 792 11,880 99 15 155 32 0.41 6.9 3.1 20 3.1E-04 0.0031 20 Infrastructure and Conveyors 2022 1,170 1,170 17,550 146 9.2 181 26 0.59 7.3 1.7 28 1.9E-04 0.0044 28

2021 660 660 9,900 83 12 130 27 0.34 5.8 2.6 16 2.5E-04 0.0026 16 Administration Buildings 2022 384 384 5,760 48 3.0 59 8.7 0.19 2.4 0.56 9.2 6.4E-05 0.0015 9.2 Terminal Equipment 2022 264 264 3,960 33 2.1 41 6.0 0.13 1.6 0.38 6.3 4.4E-05 0.0010 6.4 Excavation and Consolidation of Waste and 2023 7,430 7,430 111,456 929 5.4 941 71 3.6 36 1.0 173 1.1E-04 0.027 173 Contaminated Soil Future Remediation 2023 350 350 5,244 44 0.26 44 3.4 0.17 1.7 0.049 8.1 5.4E-06 0.0013 8.1 Installation of Liner and Soil Cover 2024 1,987 1,987 29,808 248 1.4 256 19 1.0 10 0.28 46 3.0E-05 0.0072 46

Ground Improvements 2024 654 654 9,810 82 0.48 84 6.4 0.31 3.2 0.091 15 1.0E-05 0.0024 15

2024 1,182 1,182 17,730 148 0.86 152 11 0.57 5.7 0.16 27 1.8E-05 0.0043 27 Building Phase 2 Terminal Construction 2025 906 906 13,590 113 0.65 118 8.9 0.43 4.4 0.12 21 1.4E-05 0.0032 21 2024 792 792 11,880 99 0.58 102 7.7 0.38 3.8 0.11 18 1.2E-05 0.0029 18 Infrastructure and Conveyors 2025 648 648 9,720 81 0.47 85 6.3 0.31 3.1 0.089 15 9.9E-06 0.0023 15 Terminal Equipment 2025 260 260 3,900 33 0.19 34 2.5 0.12 1.3 0.036 5.9 4.0E-06 9.3E-04 5.9

Notes: 1. Dump Truck and Water Truck (MHDT) usage data comes from the following assumptions: - Number of MHDT vehicles and schedule are provided in Table 5. - Hours are calculated as number of equipment * utilization percent * number of construction days * hours/day as provided in Table 5. - Trips are calculated as hours * 1 trip/hour. - Miles are calculated as hours * 15 miles per hour. - Total Vehicles are calculated as number of equipment * utilization percent * number of construction days as provided in Table 5. 2. Onsite Dump Trucks and Water Trucks are assumed to be similar to medium heavy duty trucks (MHDT) as defined in EMFAC2017. Emission factors are from EMFAC2017 ("Emission Rates" mode) for MHDT diesel vehicles (aggregated model year) in San Joaquin County. RUNEX emission factors are specific to vehicle speed of 15 mph. All other emission factor types are for aggregated speed. Emission factors were multiplied by the appropriate usage parameter based on the units. Emission factors in units of g/trip, g/mi, and g/vehicle/day, were multiplied by trips, miles, and total vehicles, respectively, in order to obtain mass emissions.

3. Global warming potentials used in the calculation of CO2e are 1, 25, and 298 for CO2, CH4, and N2O, respectively.

Abbreviations:

CH4 - Methane N2O - nitrous oxide

CO2 - Carbon Dioxide NOx - nitrogen oxides

CO2e - Carbon Dioxide Equivalents PM10 - particulate matter less than 10 microns

lb - pound PM2.5 - particulate matter less than 2.5 microns MT - metric ton ROG - reactive organic gases

References: California Air Resources Board. EMFAC2017. Available online at: https://arb.ca.gov/emfac/emissions-inventory Table 7 Project Construction Tugboat Emissions Denmar US, LLC Stockton, California

Input Parameters - Engine Details Brake-Specific Average Main Average Auxiliary Auxiliary Main Engine Load Auxiliary Engine Manufacturer Main Engine Fuel Construction Area Vessel Type1 Activity2 Engine Size - Engine Size - Tug Engine Useful Factor1 Load Factor1,3 Year1 Useful Life1 Consumption Tug Boat (HP)1 Boat (HP)1 Life1 Rate (g/bhp-hr)1

Transit and Maneuvering 0.31 0.43 (within SJVAPCD) Marine Tug

Hoteling 0.0 0.10 Phase 1 Terminal Construction Transit and Maneuvering 0.31 0.43 (within SJVAPCD) Equipment Delivery 1,800 282 2009 21 23 184.16

Hoteling 0.0 0.10

Transit and Maneuvering 0.31 0.43 (within SJVAPCD) Phase 2 Terminal Construction Equipment Delivery

Hoteling 0.0 0.10

Input Parameters - Trip Rate, Length, and Speed Details Daily One-Way Trip One-Way Total Annual Sub-Phase Duration4 Construction One-Way Trip Construction Area Vessel Type Activity Length6 Speed7 (knots) Transit Time8 % Utilization9 Usage Hours10 (days/year) Hours4 Rate4,5 (trips/yr) (nmi/trip) (hours/trip) (hours/yr) (hours/day) Transit and Maneuvering (within 15 3.0 4.89 -- 9.8 Marine Tug 132 8 2.0 SJVAPCD) Hoteling -- 5% 53 Phase 1 Terminal Construction Transit and Maneuvering (within 15 3.0 4.89 -- 20 Equipment Delivery -- -- 4.0 SJVAPCD) Hoteling -- 100% 192 Transit and Maneuvering (within 15 3.0 4.89 -- 20 Phase 2 Terminal Construction Equipment Delivery -- -- 4.0 SJVAPCD) Hoteling -- 100% 192

Zero-Hour Emission Factors11

ROG NOx CO SOx PM CO2 CH4 N2O Engine Type 12 13 14 15 g/bhp-hr g/bhp-hr g/bhp-hr g/bhp-hr g/bhp-hr g/bhp-hr g/bhp-hr g/bhp-hr Main Engine 0.68 5.529 3.73 0.0055 0.2 587 0.61 0.020 Auxiliary Engine 0.8092 5.1015 3.73 0.0055 0.22 587 0.73 0.020

Deterioration Factors16 Engine Type HC NOx CO SOx PM CO2 CH4 N2O

Main Engine 0.44 0.21 0.25 -- 0.67 ------Auxiliary Engine 0.28 0.14 0.16 -- 0.44 ------

Fuel Correction Factors17 Engine Type HC NOx CO SOx PM CO2 CH4 N2O All 1.0 0.948 1.0 -- 0.8 ------Table 7 Project Construction Tugboat Emissions Denmar US, LLC Stockton, California Tug Emissions18

ROG Emissions NOx Emissions CO Emissions SOx Emissions PM Emissions PM Emissions CO Emissions CH Emissions N O Emissions CO2e Emissions Engine 10 2.5 2 4 2 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (MT/yr) (MT/yr) (MT/yr) (MT/yr)19 Phase 1 Terminal Construction (2022)

Marine Tug - Main 0.0052 0.036 0.026 3.3E-05 0.0014 0.0014 3.2 0.0033 1.1E-04 3.3 Marine Tug - Auxiliary 0.0028 0.015 0.012 1.6E-05 6.5E-04 6.5E-04 1.6 0.0019 5.3E-05 1.6 Equipment Delivery - Main 0.010 0.071 0.052 6.6E-05 0.0027 0.0027 6.4 0.0067 2.2E-04 6.6 Equipment Delivery - Auxiliary 0.0080 0.045 0.035 4.7E-05 0.0019 0.0019 4.6 0.0057 1.6E-04 4.8 Total 0.026 0.17 0.12 1.6E-04 0.0066 0.0066 16 0.018 5.4E-04 16 Phase 2 Terminal Construction (2025) Equipment Delivery - Main 0.011 0.073 0.053 6.6E-05 0.0029 0.0029 6.4 0.0067 2.2E-04 6.6 Equipment Delivery - Auxiliary 0.0083 0.046 0.036 4.7E-05 0.0020 0.0020 4.6 0.0057 1.6E-04 4.8 Total 0.019 0.12 0.089 1.1E-04 0.0049 0.0049 11 0.012 3.7E-04 11

Notes: 1. Tug main and auxiliary engine characteristics are based on the TERRI L BRUSCO tugboat from the Brusco fleet, which operates in the Port of Stockton according to the Port's Daily Vessel Log. 2. Vessels are assumed to only operate within SJVAPCD boundaries. 3. Load factor for auxiliary engines while hoteling assumed to be equal to load factor for bulk carrier while hoteling. See Table 35. 4. Per HDR, the Marine Tug will operate for the entire duration of the Shiploading Equipment activity of Phase 1 Terminal Construction for 8 hours/day at 5% utilization. This is assumed to representative of hoteling. The Marine Tug is also assumed to make two one-way trips - one inbound and one outbound. 5. Equipment Delivery Vessels will deliver two pieces of equipment per Terminal Construction phase. This is equivalent to two round-trips per phase or four one-way trips per phase. 6. One-way trip length within SJVAPCD pulled from Google Earth. 7. Consistent with information provided by HDR in the Project Description, vessels are assumed to travel at 3 knots in the San Joaquin River. 8. One-way trip transit time calculated based on trip length and speed. 9. Utilization for Marine Tug while hoteling provided by HDR. Utilization for Equipment Delivery vessels while hoteling conservatively assumed to be 100%. 10. Total annual transit hours calculated based on transit time and total number of one-way trips. Total annual hoteling hours for the Marine Tug calculated using duration of activity, hours per day, and utilization. Total annual hoteling hours for the Equipment Delivery vessels calculated assuming vessel hotels for four days (24 hours/day) per round-trip, as estimated by HDR. 11. Zero-hour emission factors for ROG, NOx, CO, and PM were derived from the Commercial Harbor Craft (CHC) Inventory Model from CARB for model year 2009 engines ranging from 751 to 1900 horsepower.

12. For the purpose of this analysis, all SOx emissions are assumed to be emitted as SO2. SOx emission factor is estimated assuming sulfur fuel content of 15 ppm per California fuel regulation. 13. CO2 emission factor is calculated using US EPA Port-Related Methodologies, assuming a fuel carbon content of 86.8 percent by weight and a ratio of molecular weights of CO2 and C at 3.667. 14. Methane emission factor is assumed to be 0.9*ROG emission factor, based on EPA's SPECIATE database.

15. N2O emission factor is assumed based on CARB's Marine Emissions Model v2.3L 16. Deterioration factors were obtained from the Commercial Harbor Craft (CHC) Inventory Model from CARB. Note that there are no deterioration factors for SOx or GHGs. 17. Fuel correction factors were obtained from the Commercial Harbor Craft (CHC) Inventory Model from CARB. Note that there are no fuel correction factors for SOx or GHGs.

18. Ship emissions calculated using the following equation from CARB: E = EF0 x F x (1 + D x A/UL) x HP x LF x hr; where EF0 is the zero-hour emission factor, F is the fuel correction factor, D is the deterioration factor, A is the engine age, and UL is the useful life of the engine as shown above. Horsepower (HP), load factor (LF) and transit hours (hr) are shown above.

19. CO2e emissions calculated based on the IPCC AR4 global warming potentials of 1, 25, and 298 for CO2, CH4, and N2O, respectively.

Abbreviations: bhp - brake horsepower g - gram nmi - nautical mile ROG - reactive organic gases

CH4 - methane HC - hydrocarbon N2O - nitrous oxide SJVAPCD - San Joaquin Valley Air Pollution Control District CO - carbon monoxide hp - horsepower NOx - nitrogen oxides SOx - sulfur oxides

CO2 - carbon dioxide hr - hour PM - particulate matter yr - year

CO2e - carbon dioxide equivalent MT - metric ton

References: CARB. Commercial Harbor Craft (CHC) Inventory Model. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/road-documentation/msei-documentation-road CARB. Marine Emissions Model v2.3L. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/road-documentation/msei-documentation-road Port of Stockton Daily Vessel Log. Accessed September 2020. Available online at: http://12.146.29.131/webx/getreport.ashx?CODE=USSCK-HM-1010&FORMAT=PDF US Environmental Protection Agency. 2009. Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories Final Report. Available online at: https://www.epa.gov/sites/production/files/2016-06/documents/2009-port- inventory-guidance.pdf US Environmental Protection Agency. SPECIATE database. Available online at: https://www.epa.gov/air-emissions-modeling/speciate IPCC Greenhouse Gas Protocol. 2014. Global Warming Potential Values, IPCC AR4. https://www.ghgprotocol.org/sites/default/files/ghgp/Global-Warming-Potential-Values%20%28Feb%2016%202016%29_1.pdf Table 8 Project Construction Trip Generation Rates Denmar US, LLC Stockton, California

Hauling3,4,5 Worker1,2 Construction Import Export Total Construction Activity Area one-way one-way one-way one-way trips/day trips/activity trips/activity trips/activity Excavation and Consolidation of 30 2,720 -- 2,720 Initial Waste and Contaminated Soil Remediation Installation of Liner and Soil Cover 24 1,050 -- 1,050

Rail Building -- 2,830 2,194 5,024

Ground Improvements -- 4,050 -- 4,050

Building -- 3,174 4,028 7,202

Track Construction -- 29,994 5,962 35,956

Phase 1 Infrastructure and Conveyors -- 3,100 470 3,570 Terminal Administration Buildings Construction -- 368 192 560

Waste Water Treatment Plant -- 48 164 212

Terminal Equipment -- 6,498 834 7,332

Commissioning ------

Phase 1 Construction Worker Trips 284 ------

Excavation and Consolidation of 60 10,170 -- 10,170 Future Waste and Contaminated Soil Remediation Installation of Liner and Soil Cover 30 13,320 -- 13,320

Ground Improvements -- 4,050 -- 4,050

Building -- 2,548 3,890 6,438

Phase 2 Conveyors -- 1,454 266 1,720 Terminal Construction Terminal Equipment -- 3,722 3,584 7,306

Commissioning ------

Phase 2 Construction Worker Trips 190 ------

Construction EMFAC2017 Trip Length Trip Type Area Fleet Mix6 (mi/one-way)

Worker7 LDA, LDT1, LDT2 16.8 Phase 1 + 2 Remediation Import: 5 Hauling8 HHDT Export: N/A

7 Phase 1 + 2 Worker LDA, LDT1, LDT2 16.8 Terminal Import: 26 Construction Hauling9 HHDT Export: 20 Table 8 Project Construction Trip Generation Rates Denmar US, LLC Stockton, California Notes: 1. Worker trip rates for remediation activities based on number of personnel trucks included in the equipment list provided by Geosyntec. Number of one-way trips calculated as twice the number of personnel trucks onsite. 2. Worker trip rates for construction activities based on number of workers on site per day as estimated by HDR. 142 workers will be employed during Phase 1 Terminal Construction, and 95 workers will be employed during Phase 2 Terminal Construction. Due to the overlapping nature of activities, worker trips per day are not allocated by activity. The one-way trip rate presented in the table is assumed to be constant for the entire duration of the construction phase. One-way trip rates calculated assuming two one-way trips per worker per day.

3. Per CalEEMod methodology, there are only vendor trips associated with building construction phases. Thus, assumed zero vendor trips for remediation activities. For construction activities, any vendor trips are assumed to be accounted for in the hauling trip totals.

4. Hauling trip rates for remediation activities based on soil quantities provided by Geosyntec. Soil quantities were converted from tons to corresponding one-way trips per activity by assuming 20 tons/truck and two one-way trips per truck (note this conservatively assumes the truck is empty in one direction). Note that there are only import trips associated the remediation as the contaminated soil will be stockpiled onsite, thus there are no export trips. It is assumed that all emissions associated with transporting soil within the site are accounted for in Table 6, which includes emissions for onsite haul/dump trucks (modeled as EMFAC medium-heavy duty trucks).

5. Hauling round-trip rates provided by HDR. Total one-way trips per activity calculated assuming two one-way trips per truck (note this conservatively assumes the truck is empty in one direction). 6. Fleet mix assumptions based on CalEEMod Appendix A defaults.

7. Worker trip lengths based on CalEEMod Appendix D defaults for San Joaquin County, rural trip lengths.

8. Remediation hauling trip lengths provided by Geosyntec. Length represents average distance between project site and Roberts Island and Rough and Ready Island soil borrow sites.

9. Construction hauling import trip lengths represents average distance between project site and Roberts Island soil borrow site and George Reed Jackson Valley rock quarry. Export trip length based on CalEEMod Appendix A defaults. Hauling trip distances are subject to change. Table 9 Project Construction Entrained Dust Emission Factor Denmar US, LLC Stockton, California

Silt Loading Factor Derivation1 Entrained Roadway Dust Constants for San Joaquin County Roadway Category Silt Loading (g/m2) Travel Fraction Freeway 0.015 45.6% Major 0.032 35.1% Collector 0.032 11.7% Local 0.32 7.8% Weighted Silt Loading Factor 0.047 100%

Road Dust Equation2 E = k*(sL)^0.91 * (W)^1.02 * (1-P/4N)

Parameter3 Value E = annual average emission factor in the same units as k [calculated] k = particle size multiplier for particle size range and units of interest

PM 10 (lb/VMT) 0.0022

PM 2.5 (lb/VMT) 3.3E-04 sL = road surface silt loading (grams per square meter) (g/m 2 ) 0.047 W = average weight (tons) of all the vehicles traveling the road 2.4 P = number of “wet” days with at least 0.01 in of precipitation during averaging period 4 51 N number of days in the averaging period 365

Scenario Fugitive PM10 Fugitive PM2.5 Units Emission Factor 3.20E-04 4.79E-05 lb/VMT

Notes: 1. Travel fraction by roadway category and silt loading are from the ARB's Entrained Road Travel Emission Inventory Source Methodology, Tables 6 and 7, respectively. 2. The road dust equation for paved roads is from the California Air Resources Board's (ARB) 2018 Miscellaneous Process Methodology 7.9 for Entrained Road Travel, Paved Road Dust. 3. Silt loading emission factor calculated above using roadway travel fractions. Other parameters are from ARB

2016. PM2.5 is assumed to be 15% of PM10 based on paved road dust sampling in California (ARB Speciation Profile #471), which is a more representative fraction than provided in the older AP-42 fugitive dust methodology as discussed in ARB 2018 (page 10). 4. The number of "wet" days for San Joaquin County is from CalEEMod® Appendix D Table 1.1 (51 days).

Abbreviations: ARB - Air Resources Board m - meter CalEEMod® - California Emissions Estimator Model PM - particulate matter g - grams VMT - vehicle miles traveled lb - pounds

References: California ARB. 2018. Miscellaneous Processes Methodologies - Paved Entrained Road Dust. Available online at: https://www.arb.ca.gov/ei/areasrc/fullpdf/full7-9_2018.pdf USEPA. 1996. AP 42. Compilation of Air Pollutant Emission Factors, Volume 1. Fifth Edition. Chapter 13.2.1, Paved Roads. Available online at: http://www3.epa.gov/ttn/chief/ap42/ch13/final/c13s0201.pdf. Accessed January 2016. Table 10 Project Construction Fugitive Dust Emissions Denmar US, LLC Stockton, California

Emission Factors Emission Factor Construction Stage Emission Factor Calculation Methodology1 Units PM2.5 PM10

EFPM10 = 0.051*(S^2)*FPM10

EFPM2.5 = 0.04*(S^2.5)*FPM2.5 Grading S = 7.1 mph (AP-42 default mean vehicle speed) 0.17 1.5 lb/VMT

FPM10 = 0.6 (AP-42 default scaling factor utilized in CalEEMod)

FPM2.5 = 0.031 (AP-42 default scaling factor utilized in CalEEMod)

EFPM2.5 = FPM2.5*(CTSP*(S^1.2))/(M^1.3)

EFPM10 = FPM10*(CPM15*(S^1.5))/(M^1.4)

CTSP = 5.7 (arbitrary coefficient utilized in AP-42 methodology)

CPM15 = 1.0 (arbitrary coefficient utilized in AP-42 methodology) Bulldozing 0.41 0.75 lb/hr M = 7.9% (material moisture content for overburden, the default soil type utilized in CalEEMod) S = 6.9% (material silt factor for overburden, the default soil type utilized in CalEEMod)

FPM10 = 0.75 (AP-42 scaling factor utilized in CalEEMod)

FPM2.5 = 0.105 (AP-42 scaling factor utilized in CalEEMod)

EFPM2.5 = kPM2.5*0.0032*((U/5)^1.3)/((M/2)^1.4)

EFPM10 = kPM10*0.0032*((U/5)^1.3)/((M/2)^1.4) kPM2.5 = 0.053 (AP-42 particle size multiplier utilized in CalEEMod) Truck Loading 0.0000062 0.000041 lb/ton kPM10 = 0.35 (AP-42 particle size multiplier utilized in CalEEMod) U = 2.7 (mean wind speed in m/s for San Joaquin County per CalEEMod Appendix D) M = 12% (moisture content for cover, the default soil type utilized in CalEEMod)

EFPM2.5 = kPM2.5*0.0032*((U/5)^1.3)/((M/2)^1.4)

EFPM10 = kPM10*0.0032*((U/5)^1.3)/((M/2)^1.4) kPM2.5 = 0.053 (AP-42 particle size multiplier utilized in CalEEMod) Demolition 0.000076 0.00050 lb/ton kPM10 = 0.35 (AP-42 particle size multiplier utilized in CalEEMod) U = 2.7 (mean wind speed in m/s for San Joaquin County per CalEEMod Appendix D) M = 2% (moisture content, based on MRI report per CalEEMod methods)

Emissions Grading Bulldozing Truck Loading Demolition Total Emissions Emissions Emissions Emissions Emissions Construction Area Construction Activity Tons Tons of VMT2 PM PM Hours3 PM PM PM PM PM PM PM PM 2.5 10 2.5 10 Hauled4 2.5 10 Material5 2.5 10 2.5 10 lbs lbs lbs lbs lbs/activity Excavation and Consolidation of Waste and Contaminated Soil 22 3.7 34 430 178 324 48,800 0.30 2.0 15,226 1.2 7.7 183 368 Initial Remediation Installation of Liner and Soil Cover 14 2.3 22 209 86 157 10,500 0.065 0.43 ------89 179 Rail Building 40 7 62 0,468 0,194 0,352 50,240 0.31 2.1 ------201 416 Ground Improvements 38 6 59 ------40,500 0.25 1.7 ------6.6 60 Building 60 10 92 0,694 0,287 0,522 72,020 0.45 2.9 ------298 617 Track Construction 101 17 156 1,176 487 0,885 ------503 1,041 Phase 1 Terminal 56 9 87 0,654 0,271 0,492 35,700 0.22 1.5 ------280 580 Construction Infrastructure and Conveyors Administration Buildings 90 15 138 1,044 432 0,786 5,600 0.035 0.23 ------447 925 Waste Water Treatment Plant ------2,120 0.013 0.087 ------0.013 0.087 Terminal Equipment ------73,320 0.45 3.0 ------0.45 3.0 Commissioning ------Excavation and Consolidation of Waste and Contaminated Soil 91 15 140 1,342 555 1,010 440,700 2.7 18 13,662 1.0 6.9 574 1,175 Future Remediation Installation of Liner and Soil Cover 68 11 104 1,168 483 0,880 133,200 0.83 5.5 ------496 989 Ground Improvements 28 4.7 43 ------40,500 0.25 1.7 ------4.9 45 Building 60 10 92 0,696 0,288 0,524 64,380 0.40 2.6 ------298 619 Phase 2 Terminal 124 21 191 1,440 596 1,084 17,200 0.11 0.70 ------617 1,276 Construction Conveyors Terminal Equipment ------73,060 0.45 3.0 ------0.45 3.0 Commissioning ------Table 10 Project Construction Fugitive Dust Emissions Denmar US, LLC Stockton, California Notes: 1. All construction fugitive dust emission factors are calculated per the methodology utilized by CalEEMod and outlined in CalEEMod Appendix A, sections 4.3 and 4.4. Default factors and constants are per CalEEMod guidance. 2. Total grading emissions are the product of the lbs/VMT emission factor and the total VMT for all scrapers, crawler tractors, graders and rubber tired dozers used during project construction. The VMT for all grading equipment is calculated as the total acreage graded divided by 12 feet, the default width for grading equipment blades per CalEEMod methodology. The acreage graded is calculated assuming all crawler tractors, graders and rubber tired dozers can grade 0.5 acres per 8-hr work day and all scrapers can grade 1 acre per 8-hr workday, per CalEEMod methods. The total hours of operation (accounting for percent utilization) for all pieces of grading equipment during each activity are multiplied by these factors in order to obtain the acreage graded per activity. See Table 4 for off-road equipment details.

3. Total bulldozing emissions are the product of the lbs/hr emission factor and the total hours of bulldozing per subphase. Total hours of bulldozing are obtained by multiplying the total number of rubber tired dozers utilized in each activity by the hours per day in which they operate, percent utilization, and the days in the activity. See Table 4 for off-road equipment details. 4. Truck loading emissions are the product of the lbs/ton emission factor and the total tonnage of the soil hauled away or to the site by truck. The total tonnage was provided by Geosyntec and HDR. Note that total tonnage includes all material imported, exported, or stockpiled onsite.

5. Demolition material emission factors are the product of the lbs/ton emission factor and the total tonnage of material demolished. The demolition tonnage is based on the CalEEMod assumption of 0.046 tons of material per square foot demolished and the square footage of buildings to be demolished per phase provided by HDR (331,000 sqft during Phase 1, 297,000 sqft during Phase 2) . All demolition is assumed to occur in the excavation and consolidation of waste and contaminated material activities.

Abbreviations: CalEEMod® - California Emissions Estimator Model hr - hour lb - pound PM - particulate matter VMT - vehicle miles traveled

References: CalEEMod® User's Guide. 2016. Appendix A. Available online at: http://www.aqmd.gov/caleemod/user's-guide Table 11 Project Construction Architectural Coating Emissions Denmar US, LLC Stockton, California

Coating Category Interior1 Exterior1 VOC Content (g/L) 150 150 Emission Factor (lb/sqft) 0.0069 0.0069

Painted Area Land Use Fraction of Surface Area Painted2 (%) Multiplier2 Non-Residential 75% 25% 2 Parking 0% 6% --

3 Painted Areas Building Square Footage ROG Construction Area Construction Activity Building Non-residential Emissions Parking Area Interior Exterior Area sqft sqft sqft sqft lb/activity

Rail Building Rail Building 9,400 -- 14,100 4,700 131

Storage Building Storage Building 187,000 -- 280,500 93,500 2,598

Phase 1 Terminal Administrative/Maintenance 12,100 6,800 18,150 6,458 171 Construction Building Administration Buildings Crew Quarters Building (Marine 2,000 3,600 3,000 1,216 29 Facility) Crew Quarters Building (Rail 2,000 5,600 3,000 1,336 30 Facility) Phase 2 Terminal Future Storage Building Storage Building 187,000 -- 280,500 93,500 2,598 Construction

Notes:

1. VOC content of paint consistent with CalEEMod Appendix D for San Joaquin County. VOC is assumed to be equivalent to ROG for these purposes. VOC content in g/L converted to lb/sqft using CalEEMod assumption that 1 gallon of paint covers 180 square feet.

2. CalEEMod® default architectural coating emissions parameters. Non-residential building surface area assumed to be 2 times the floor area. Parking painted area is assumed to be 6% of the total surface area for surface lots. 3. Project square footage by land use was provided by HDR. See Table 1 for land use details.

Abbreviations: CalEEMod® - California Emissions Estimator MODel lb - pounds g - gram ROG - reactive organic gas gal - gallons sqft - square feet L - liters VOC - volatile organic compound

References: California Air Pollution Control Officers Association (CAPCOA). 2016. Appendix A. Available at: http://www.caleemod.com Table 12 Project Construction Asphalt Paving Off-Gassing Emissions Denmar US, LLC Stockton, California

Asphalt Paving Off- Asphalt- Asphalt Paving Off- Construction Gassing ROG Construction Activity Paved Area Gassing ROG Emission Area Emissions (acre)1 Factor (lb/acre)2 (lb/activity)

Rail Building 0.36 2.62 0.94

Storage Building 1.5 2.62 3.9

Phase 1 Terminal Track Construction 2.4 2.62 6.2 Construction

Administration Buildings 1.2 2.62 3.2

Waste Water Treatment Plant 0.30 2.62 0.78

Notes: 1. Asphalt paving areas provided by HDR. 2. Emission factor from CalEEMod User's Guide, Appendix A.

Abbreviations: lb - pound ROG - reactive organic gas

References: California Air Pollution Control Officers Association (CAPCOA). 2016. Appendix A. Available at: http://www.caleemod.com Table 13 Summary of Unmitigated Project Construction Criteria Air Pollutant Emissions Denmar US, LLC Stockton, California

Unmitigated Construction CAP Emissions1

Construction Area Construction Activity Year ROG NOx CO SOx PM10 PM2.5 lb/year 2021 293 1,422 1,539 1.6 111 102 2022 266 1,370 1,493 1.6 100 92 Site-Wide Miscellaneous Diesel- Site-Wide 2023 250 1,327 1,466 1.6 93 85 Fueled Tools2 2024 241 1,313 1,465 1.6 89 82 2025 200 1,139 1,289 1.4 71 65 Excavation and Consolidation of 2021 261 2,356 1,720 3.9 483 276 Waste and Contaminated Soil Initial Remediation Installation of Liner and Soil Cover 2021 97 839 637 1.7 222 123

2021 600 5,120 3,410 9.3 542 347 Rail Building 2022 260 2,206 1,625 4.5 249 154 Ground Improvements 2021 401 4,588 2,437 8.4 268 182 2022 141 1,646 958 3.4 98 63 Building 2021 2,044 5,677 4,372 11 643 410 2022 1,504 3,838 3,249 8.4 460 284 Track Construction 2021 592 9,749 2,988 24 1,303 665 2022 214 4,006 1,289 12 597 290 2021 371 3,489 2,456 6.1 409 263 Infrastructure and Conveyors Phase 1 Terminal Construction 2022 482 4,582 3,526 8.9 569 355 Administration Buildings 2021 425 2,748 1,697 4.0 714 400 2022 225 1,389 950 2.3 403 221 Waste Water Treatment Plant 2022 65 536 574 1.1 27 25 Terminal Equipment 2022 203 2,854 1,699 8.5 185 103 Commissioning 2022 103 970 712 1.6 43 41 2021 336 268 2,933 8.4 527 114 Phase 1 Construction Worker Trips3 2022 281 212 2,426 7.4 481 104

Phase 1 Construction Marine Vessels4 2022 53 334 249 0.33 13 13

Excavation and Consolidation of 2023 1,246 11,475 8,992 25 1,746 1,017 Waste and Contaminated Soil Future Remediation 2023 96 844 666 1.7 182 102 Installation of Liner and Soil Cover 2024 561 4,870 3,928 10 1,093 609 Ground Improvements 2024 145 2,015 1,088 5.7 163 74

2024 1,794 3,404 3,015 8.6 519 294 Building 2025 1,361 2,458 2,295 6.5 388 216 Conveyors 2024 355 3,488 2,900 7.1 852 470 Phase 2 Terminal Construction 2025 272 2,653 2,348 5.8 685 372 Terminal Equipment 2025 172 2,388 1,703 7.9 157 83 Commissioning 2025 73 628 598 1.3 25 24 2024 177 119 1,509 5.1 355 76 Phase 2 Construction Worker Trips3 2025 150 96 1,273 4.5 322 69

Phase 2 Construction Marine Vessels4 2025 39 238 178 0.23 10 10

Summary of Emissions by Year (ton/yr)5

Year ROG NOx CO SOx PM10 PM2.5 2021 2.7 18 12 0.039 2.6 1.4 2022 1.9 12 9.4 0.030 1.6 0.87 2023 0.80 6.8 5.6 0.014 1.0 0.60 2024 1.6 7.6 7.0 0.019 1.5 0.80 2025 1.1 4.8 4.8 0.014 0.83 0.42 Threshold 10 10 100 27 15 15

Notes: 1. Unmitigated emissions assume Fleet-Average Tier offroad equipment, as shown in Table 4. Emissions from the following sources are summed by activity and year: offroad equipment use as shown in Table 4, onsite medium-heavy duty truck use as shown in Tables 5 and 6, onroad worker trips (remediation only) and onroad hauling trips as shown in Table 8, onroad fugitive dust as show in Table 9, offroad fugitive dust as shown in Table 10, architectural coating off-gassing emissions as shown in Table 11, and asphalt paving off-gassing emissions as shown in Table 12. Emissions from terminal construction onroad worker trips and marine vessel use are accounted for by year and construction area, but not by activity. See footnotes 3 and 4.

2. The miscellaneous small tools category has conservatively been added to the analysis to capture the potential for any miscellaneous diesel-fueled equipment to be used during construction. See Table 4 for more details.

3. Onroad terminal construction worker trips, as shown in Table 8, were calculated on a per-year basis rather than per-activity basis. Thus, emissions are also presented on a per-year basis for each of the terminal construction phases.

4. Marine vessels include those used to deliver equipment and those that assist during construction. See Table 7 for more details. These emissions were calculated on a per-year basis rather than per-activity basis, and are thus shown separately. 5. Annual emissions exceeding SJVAPCD Thresholds of Significance are shown in bold.

Abbreviations:

CAP - Criteria Air Pollutant PM2.5 - particulate matter less than 2.5 microns in diameter CO - carbon monoxide ROG - reactive organic gases lb - pound SJVAPCD - San Joaquin Valley Air Pollution Control District NOx - nitrogen oxides SOx - sulfur oxides

PM10 - particulate matter less than 10 microns in diameter Table 14 Summary of Mitigated Project Construction Criteria Air Pollutant Emissions Denmar US, LLC Stockton, California

Mitigated Construction CAP Emissions

Construction Area Construction Activity Year ROG NOx CO SOx PM10 PM2.5 lb/year 2021 84 1,343 1,189 1.6 81 81 2022 84 1,338 1,184 1.6 81 81 Site-Wide Miscellaneous Diesel- Site-Wide 2023 84 1,327 1,184 1.6 81 81 Fueled Tools2 2024 84 1,313 1,194 1.6 82 82 2025 77 1,139 1,084 1.4 71 65 Excavation and Consolidation of 2021 59 478 1,152 3.9 398 196 Waste and Contaminated Soil Initial Remediation Installation of Liner and Soil Cover 2021 23 163 495 1.7 191 94

2021 217 1,707 3,324 9.3 354 169 Rail Building 2022 95 762 1,594 4.5 171 80 2021 115 1,334 2,436 8.4 117 38 Ground Improvements 2022 36 477 958 3.4 44 12 2021 1,624 1,948 4,309 11 433 208 Building 2022 1,219 1,349 3,214 8.4 324 152 2021 278 6,003 2,947 24 1,134 508 Track Modifications 2022 89 2,495 1,289 12 530 228 2021 83 1,062 2,389 6.1 272 132 Infrastructure and Conveyors Phase 1 Terminal Construction 2022 105 1,447 3,448 8.9 396 189 2021 203 514 1,668 4.0 601 292 Administration Buildings 2022 114 276 944 2.3 348 169 Waste Water Treatment Plant 2022 14 172 561 1.1 4.2 2.2 Terminal Equipment 2022 70 1,757 1,686 8.5 122 42 Facility Commissioning 2022 20 175 708 1.6 2.4 2.4 2021 336 268 2,933 8.4 527 114 Phase 1 Construction Worker Trips3 2022 281 212 2,426 7.4 481 104

Phase 1 Construction Marine Vessels4 2022 53 334 249 0.33 13 13

Excavation and Consolidation of 2023 260 2,336 7,064 25 1,325 624 Waste and Contaminated Soil Future Remediation 2023 16 181 474 1.7 153 74 Installation of Liner and Soil Cover 2024 98 1,080 2,861 10 925 450

Ground Improvements 2024 39 905 1,088 5.7 114 28

2024 1,552 1,287 2,995 8.6 413 192 Building 2025 1,190 984 2,281 6.5 316 147 2024 78 886 2,867 7.1 728 352 Future Conveyors 2025 64 724 2,322 5.8 596 288 Phase 2 Terminal Construction Terminal Equipment 2025 54 1,390 1,693 7.9 108 35 Commissioning 2025 17 156 594 1.3 1.9 1.9 2024 177 119 1,509 5.1 355 76 Phase 2 Construction Worker Trips3 2025 150 96 1,273 4.5 322 69

Phase 2 Construction Marine Vessels4 2025 39 238 178 0.23 10 10

Summary of Emissions by Year (ton/yr)5

Year ROG NOx CO SOx PM10 PM2.5 2021 1.5 7.4 11 0.039 2.1 0.92 2022 1.1 5.4 9.1 0.030 1.3 0.54 2023 0.18 1.9 4.4 0.014 0.78 0.39 2024 1.0 2.8 6.3 0.019 1.3 0.59 2025 0.79 2.4 4.7 0.014 0.71 0.31 Threshold 10 10 100 27 15 15

Notes: 1. Mitigated emissions assume Tier 4 Final offroad equipment, excluding the Site-Wide Miscellaneous Tier 2 Diesel-Fueled Tools category, which conservatively accounts for non-Tier 4 Final offroad equipment, as shown in Table 4. Emissions from the following sources are summed by activity and year: offroad equipment use as shown in Table 4, onsite medium-heavy duty truck use as shown in Tables 5 and 6, onroad worker trips (remediation only) and onroad hauling trips as shown in Table 8, onroad fugitive dust as show in Table 9, offroad fugitive dust as shown in Table 10, architectural coating off-gassing emissions as shown in Table 11, and asphalt paving off-gassing emissions as shown in Table 12. Emissions from terminal construction onroad worker trips and marine vessel use are accounted for by year and construction area, but not by activity. See footnotes 3 and 4.

2. The miscellaneous small tools category has conservatively been added to the analysis to capture the potential for any diesel-fueled equipment to be used during construction. See Table 4 for more details. 3. Onroad terminal construction worker trips, as shown in Table 8, were calculated on a per-year basis rather than per-activity basis. Thus, emissions are also presented on a per-year basis for each of the terminal construction phases. 4. Marine vessels include those used to deliver equipment and those that assist during construction. See Table 7 for more details. These emissions were calculated on a per-year basis rather than per-activity basis, and are thus shown separately. 5. Annual emissions do not exceed SJVAPCD Thresholds of Significance for any CAP.

Abbreviations:

CAP - Criteria Air Pollutant PM2.5 - particulate matter less than 2.5 microns in diameter CO - carbon monoxide ROG - reactive organic gases lb - pound SJVAPCD - San Joaquin Valley Air Pollution Control District NOx - nitrogen oxides SOx - sulfur oxides

PM10 - particulate matter less than 10 microns in diameter Table 15 Summary of Project Construction Greenhouse Gas Emissions Denmar US, LLC Stockton, California

Construction GHG Emissions1 5 Construction Area Construction Activity Year CO2 CH4 N2O CO2e MT/year 2021 69 0.022 0 70 2022 69 0.022 0 70 Site-Wide Miscellaneous Diesel- Site-Wide 2023 69 0.022 0 70 Fueled Tools2 2024 70 0.023 0 70 2025 63 0.021 0 64 Excavation and Consolidation of 2021 164 0.029 0.0076 167 Waste and Contaminated Soil Initial Remediation Installation of Liner and Soil Cover 2021 69 0.013 0.0023 70

2021 412 0.060 0.025 421 Rail Building 2022 202 0.029 0.012 206 2021 378 0.051 0.025 387 Ground Improvements 2022 153 0.020 0.010 157 2021 496 0.061 0.027 505 Building 2022 374 0.046 0.020 381 2021 1,160 0.061 0.15 1,207 Track Construction 2022 550 0.029 0.072 572 2021 265 0.038 0.012 269 Infrastructure and Conveyors Phase 1 Terminal Construction 2022 388 0.054 0.017 394 2021 173 0.029 0.0046 175 Administration Buildings 2022 100 0.017 0.0026 101 Waste Water Treatment Plant 2022 46 0.0072 0.0010 47 Terminal Equipment 2022 394 0.018 0.044 407 Commissioning 2022 69 0.014 0 69 2021 384 0.011 0.011 388 Phase 1 Construction Worker Trips3 2022 340 0.0087 0.0093 343

Phase 1 Construction Marine Vessels4 2022 16 0.018 5.4E-04 16

Excavation and Consolidation of 2023 1,070 0.22 0.041 1,088 Waste and Contaminated Soil Future Remediation 2023 70 0.011 0.0037 72 Installation of Liner and Soil Cover 2024 421 0.064 0.022 429

Ground Improvements 2024 262 0.025 0.025 270

2024 383 0.049 0.022 390 Building 2025 291 0.037 0.017 297 2024 309 0.051 0.0080 313 Conveyors 2025 252 0.041 0.0064 255 Phase 2 Terminal Construction Terminal Equipment 2025 361 0.021 0.037 373 Commissioning 2025 56 0.010 0 56 2024 236 0.0051 0.0058 237 Phase 2 Construction Worker Trips3 2025 208 0.0042 0.0049 209

Phase 2 Construction Marine Vessels4 2025 11 0.012 3.7E-04 11

Summary of Emissions by Year (MT/yr)

Year CO2 CH4 N2O CO2e 2021 3,500 0.35 0.27 3,589 2022 2,632 0.26 0.19 2,695 2023 1,141 0.23 0.045 1,160 2024 1,611 0.19 0.082 1,640 2025 1,180 0.13 0.065 1,202 Total 10,063 1.2 0.65 10,285

Notes: 1. GHG emissions are independent of engine tier, and thus emissions are the same between the unmitigated and mitigated scenarios. Emissions from the following sources are summed by activity and year: offroad equipment use as shown in Table 4, onsite medium-heavy duty truck use as shown in Tables 5 and 6, and onroad worker trips (remediation only) and onroad hauling trips as shown in Table 8. Emissions from terminal construction onroad worker trips and marine vessel use are accounted for by year and construction area, but not by activity. See footnotes 2 and 3. Note that GHG emissions associated with water pumping are not included in this analysis. 2. The miscellaneous small tools category has conservatively been added to the analysis to capture the potential for any miscellaneous diesel-fueled equipment to be used during construction. See Table 4 for more details. 3. Onroad terminal construction worker trips, as shown in Table 8, were calculated on a per-year basis rather than per-activity basis. Thus, emissions are also presented on a per-year basis for each of the terminal construction phases. 4. Marine vessels include those used to deliver equipment and those that assist during construction. See Table 7 for more details. These emissions were calculated on a per-year basis rather than per-activity basis, and are thus shown separately.

5. CO2e emissions are calculated using IPCC AR4 global warming potentials of 1, 25, and 298 for CO2, CH4, and N2O, respectively.

Abbreviations:

CH4 - methane lb - pound

CO2 - carbon dioxide MT - metric ton

CO2e - carbon dioxide equivalents N2O - nitrous oxide GHG - greenhouse gas

References: IPCC. 2007. Fourth Assessment Report. Available at: https://www.ipcc.ch/assessment-report/ar4/ Table 16 Architectural Coating Emissions from Project Operations Denmar US, LLC Stockton, California

Phase 1 Buildout

Floor Area Building Surface Application Indoor Paint Outdoor Paint Architectural Coating Land Use (sq ft) Area1 (sq ft) Rate VOC EF2 (g/L) VOC EF2 (g/L) VOC Emissions3 (lb/yr)

Rail Building 9,400 18,800 100% 150 150 131 Storage Building 187,000 374,000 100% 150 150 2,601 Administrative Building 12,100 24,200 100% 150 150 168 Administrative Building - Adjacent Parking Lot 6,800 408 100% 0 150 0.71 Crew Quarters Building (Marine Facility) 2,000 4,000 100% 150 150 28 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 3,600 216 100% 0 150 0.38 Crew Quarters Building (Rail Facility) 2,000 4,000 100% 150 150 28 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 5,600 336 100% 0 150 0.58 Total Phase 1 Buildout Emissions 2,957

Full Buildout

Floor Area Building Surface Application Indoor Paint Outdoor Paint Architectural Coating Land Use (sq ft) Area1 (sq ft) Rate VOC EF2 (g/L) VOC EF2 (g/L) VOC Emissions3 (lb/yr)

Rail Building 9,400 18,800 100% 150 150 131 Storage Building 374,000 748,000 100% 150 150 5,201 Administrative Building 12,100 24,200 100% 150 150 168 Administrative Building - Adjacent Parking Lot 6,800 408 100% 0 150 0.71 Crew Quarters Building (Marine Facility) 2,000 4,000 100% 150 150 28 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 3,600 216 100% 0 150 0.38 Crew Quarters Building (Rail Facility) 2,000 4,000 100% 150 150 28 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 5,600 336 100% 0 150 0.58 Total Full Buildout Emissions 5,558

Notes: 1. Consistent with CalEEMod®, residential building surface area is assumed to be 2.7 times the floor area, and non-residential 2 times the floor area. Also consistent with CalEEMod®, the parking painted area is assumed to be 6% of the total surface area for surface lots. 2. VOC emission factors consistent with CalEEMod Appendix D for San Joaquin county. Building area is assumed to be 75% indoors and 25% outdoors, consistent with CalEEMod. Parking garages are assumed to have no indoor surfaces. 3. Uses CalEEMod® assumption that 1 gallon of paint covers 180 square feet.

Abbreviations: CalEEMod® - California Emissions Estimator Model lb - pound EF - emission factor sq ft - square feet g - grams VOC - volatile organic compound L - liters yr - year

References: California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2016.3.2. Available online at http://www.caleemod.com/ Table 17 Consumer Product Emissions from Project Operations Denmar US, LLC Stockton, California

Phase 1 Buildout Consumer Products VOC Consumer Products Floor Area1 Land Use EF2 Days per Year VOC emissions3 (sq ft) (lb/sq ft/day) (lb/yr) Rail Building 9,400 1.62E-05 365 56 Storage Building 187,000 1.62E-05 365 1,106 Administrative Building 12,100 1.62E-05 365 72 Administrative Building - Adjacent Parking Lot 6,800 3.54E-07 365 0.88 Crew Quarters Building (Marine Facility) 2,000 1.62E-05 365 12 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 3,600 3.54E-07 365 0.47 Crew Quarters Building (Rail Facility) 2,000 1.62E-05 365 12 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 5,600 3.54E-07 365 0.72 Total Phase 1 Buildout Emissions 1,259

Full Buildout Consumer Products VOC Consumer Products Floor Area1 Land Use EF2 Days per Year VOC emissions3 (sq ft) (lb/sq ft/day) (lb/yr) Rail Building 9,400 1.62E-05 365 56 Storage Building 374,000 1.62E-05 365 2,211 Administrative Building 12,100 1.62E-05 365 72 Administrative Building - Adjacent Parking Lot 6,800 3.54E-07 365 0.88 Crew Quarters Building (Marine Facility) 2,000 1.62E-05 365 12 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 3,600 3.54E-07 365 0.47 Crew Quarters Building (Rail Facility) 2,000 1.62E-05 365 12 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 5,600 3.54E-07 365 0.72 Total Full Buildout Emissions 2,364

Notes: 1. Floor areas are given in Table 1, as provided by the Project sponsor. 2. The consumer products VOC EF for non-parking land uses was derived using methodology consistent with CalEEMod® but with updated statewide parameters. The CalEEMod® default emissions factor assumes 2008 statewide VOC inventory and building square footage. An updated VOC inventory for 2017 was taken from the ARB and 2017 population estimates based on the State of California's Department of Finance demographic projections were used to estimate a statewide VOC EF for 2017. The EFs for the parking land uses were taken as default values from the CalEEMod® User's Guide.

3. For the purposes of this analysis, we assume that VOC is equal to ROG.

Abbreviations: ARB - Air Resources Board sq ft - square feet CalEEMod® - California Emissions Estimator Model VOC - volatile organic compound EF - emission factor yr - year lb - pound

References: California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2016.3.2. Available online at http://www.caleemod.com/ Table 18 Energy Usage Emission Factors Denmar US, LLC Stockton, California

Historical Electricity Intensity - PG&E Annual Electricity Data 2016 2017 2018 Average1 Units 2 CO2 Intensity Factor per Total Energy Delivered 294 210 206 237 lbs CO2/MWh delivered % of Total Energy From RPS-Eligible Renewables3 33% 33% 39% 35% - 4 CO2 Intensity Factor per Total Non-RPS-Eligible Energy 437 314 338 363 lbs CO2/MWh delivered

Estimated Intensity Factor for Total Energy Delivered5 Model Year 2016 2017 2018 Average1 Units

293 210 226 243 lbs CO2/MWh delivered 2020 RPS (33%)6 295 212 228 245 lbs CO2e/MWh delivered 252 181 194 209 lbs CO2/MWh delivered 2023 RPS (42%) 254 183 197 211 lbs CO2e/MWh delivered 230 165 177 191 lbs CO2/MWh delivered 2025 RPS (47%) 232 167 180 193 lbs CO2e/MWh delivered

175 126 135 145 lbs CO2/MWh delivered 2030 RPS (60%) 177 128 137 147 lbs CO2e/MWh delivered

0 0 0 0 lbs CO2/MWh delivered 2045 RPS (100%) 2.0 2.0 2.0 2.0 lbs CO2e/MWh delivered

Greenhouse Gas Energy Emission Factors

Greenhouse Gas CO2 CH4 N2O CO2e Units Global Warming Potential7 1.0 25 298 - - 209 0.033 0.0040 211 lb/MWh 2023 (Phase 1) Electricity Use Emission Factor 0.095 1.5E-05 1.8E-06 0.10 MT/MWh 191 0.033 0.0040 193 lb/MWh 2025 (Full Buildout) Electricity Use Emission Factor 0.087 1.5E-05 1.8E-06 0.087 MT/MWh

Fuel Combustion Emission Factors8 Fuel Combustion Emission Factors (lb/MMBtu) Fuel Type Reference CO2 CH4 N2O CO2e Based on Distillate Fuel Oil No. 2 Diesel 163 0.0066 0.0013 164 emission factor

Notes: 1. This average uses the most recent three years of data. 2. Total CO2 intensity factors from The Climate Registry. Available at: https://www.theclimateregistry.org/our-members/cris-public-reports/. 3. Percent of total energy from eligible renewables is from the PG&E 2017, 2018, and 2019 Corporate Responsibility Report. 4. The emissions metric presented here is calculated based on the total CO2 intensity factor divided by the percent of energy delivered from non-RPS-eligible renewable sources.

This CO2 intensity factor includes both fossil fuel and carbon-free sources of energy, such as largescale hydro and nuclear. Diablo Canyon Nuclear Plant, which accounts for a

portion of the carbon-free energy in this CO2 intensity factor, is planned to be closed by 2024-2025 (https://www.pge.com/en_US/safety/how-the-system-works/diablo- canyon-power-plant/diablo-canyon-power-plant/engagement-panel.page). According to SB 1090 (approved 9/2018), "The [California Public Utilities] commission shall ensure that integrated resource plans are designed to avoid any increase in emissions of greenhouse gases as a result of the retirement of the Diablo Canyon Units 1 and 2

powerplant." This was incorporated into CPUC section 712.7(2)(b). Based on this information, the total Non-RPS-Eligible energy CO2 intensity factor was assumed to remain constant.

5. The intensity factor for total energy delivered is estimated by multiplying the percentage of energy delivered from non-RPS-eligible renewable energy by the CO2 emissions per total non-RPS-eligible renewable energy metric calculated above.

6. The 2020 intensity factor for total energy delivered is calculated by taking a 33% reduction from the CO2 intensity factor per total non-RPS-eligible energy. For this reason, the

2020 intensity factor is slightly higher than the CO2 intensity factor per total energy delivered.

7. Global Warming Potentials (GWP) are based on the IPCC Fourth Assessment Report. CH4 and N2O emission factors are from the CalEEMod® version 2016.3.2 defaults for PG&E, and are conservatively assumed not to change from these estimates. As more renewable energy is integrated into the electricity grid, these intensity factors will also decrease. 8. Emission Factors for fuels are based on the EPA's Emission Factors for Greenhouse Gas Inventories, Table 1. The GWPs applied to these emission factors are based on Intergovernmental Panel on Climate Change (IPCC), Fifth Assessment Report (AR5), 2014.

Abbreviations: CalEEMod® - California Emissions Estimator Model MT - metric ton(s)

CH4 - methane MWh - megawatt-hour

CO2 - carbon dioxide N2O - nitrous oxide

CO2e - carbon dioxide equivalents NOx - nitrogen oxides CPUC - California Public Utilities Commission PG&E - Pacific Gas & Electric

GWP - global warming potential PM10 - particulate matter smaller than 10 microns in diameter IPCC AR4 - Intergovernmental Panel on Climate Change Fourth PM2.5 - particulate matter smaller than 2.5 microns in diameter Assessment Report ROG - reactive organic gases lb - pound(s) RPS - Renewable Portfolio Standard MMBtu - million British Thermal Units SB - Senate Bill

References: California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2016.3.2. Available online at http://www.caleemod.com/ IPCC. 2007. AR4 Climate Change 2007: The Physical Science Basis. Available online at: https://www.ipcc.ch/report/ar4/wg1/ Table 18 Energy Usage Emission Factors Denmar US, LLC Stockton, California References, continued: PG&E 2017 Corporate Responsibility Report. Available at: http://pgecorp.com/corp_responsibility/reports/2017/assets/PGE_CRSR_2017.pdf. PG&E 2018 Corporate Responsibility Report. Available at: http://www.pgecorp.com/corp_responsibility/reports/2018/assets/PGE_CRSR_2018.pdf. PG&E 2019 Corporate Responsibility Report. Available at: http://www.pgecorp.com/corp_responsibility/reports/2019/assets/PGE_CRSR_2019.pdf. The Climate Registry. Available at: https://www.theclimateregistry.org/our-members/cris-public-reports/. SB-100 California Renewables Portfolio Standard Program. Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100. EPA (2020). Emission Factors for Greenhouse Gas Inventories. March 26. Available at: https://www.epa.gov/sites/production/files/2020-04/documents/ghg-emission-factors- hub.pdf Table 19 Energy Usage Emissions from Project Operations Denmar US, LLC Stockton, California

Annual Electricity Use1 Annual Fuel Use1 Phase (MWh/yr) (gal/yr) Phase 1 (2023)2 13,598 23,100 Full Buildout (2025)2 18,074 33,000

Electricity Emissions3 Fuel Consumption Emissions3 Phase CO2e CO2e (MT/yr) (MT/yr) Phase 1 (2023)2 1,301 236 Full Buildout (2025)2 1,580 336

Notes: 1. Energy use rates were provided by the Project sponsor. 2. Per the Project Description, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026. The emissions shown in the table above assume a full year of Full Buildout Operation in 2025. 3. Emissions are calculated based on energy use and energy emission factors, shown in Table 18.

Abbreviations: CalEEMod® - California Emissions Estimator Model

CO2e - carbon dioxide equivalents GHG - Greenhouse Gas MT - metric ton(s) yr - year

References: California Emissions Estimator Model (CalEEMod®). Available online at http://www.caleemod.com/ Table 20 Water Usage and Treatment Emission Factors for Project Operations Denmar US, LLC Stockton, California

Water Usage1

Indoor Water Outdoor Water Phase (million gal/year) (million gal/year) Phase 1 (2023) 26 0 Full Buildout (2025) 26 0

Water Electricity Intensity2 Electricity to Supply Water Electricity to Treat Water Electricity to Distribute Water County (kWh/million gal) (kWh/million gal) (kWh/million gal) San Joaquin 2,117 111 1,272

Notes: 1. Water use was provided by the Project sponsor. 2. Water Electricity Intensity from Table 9.2 of Appendix D of the CalEEMod® User's Guide.

Abbreviations: CalEEMod® - California Emissions Estimator Model gal - gallon kWh - kilowatt-hours

References: CalEEMod® Version 2016.3.2 Available Online at: http://www.caleemod.com Table 21 Wastewater Treatment Emission Factors Denmar US, LLC Stockton, California

Wastewater Electricity Intensity1 Electricity to Treat Wastewater County (kWh/million gal) San Joaquin 1,911

Wastewater Treatment Types2 Anaerobic, Anaerobic, Anaerobic, County Septic Tank Aerobic Facultative Combustion of Cogeneration of Lagoons Gas Gas San Joaquin 10.33% 87.46% 2.21% 100% 0%

Wastewater Treatment Direct Emission Factors3

CO2 Non- CO2 Biogenic CH4 N2O Wastewater Treatment Type Biogenic (ton/gal) (ton/gal) (ton/gal) (ton/gal) Septic 0 0 2.5E-07 8.5E-10 Aerobic 3.9E-07 0 1.3E-09 8.5E-10 Anaerobic Facultative 3.9E-07 0 4.0E-07 8.5E-10 Digester Burn 0 0 0 0 Digester Cogen 0 0 0 0

Notes: 1. Water Electricity Intensity from Table 9.2 of Appendix D of the CalEEMod® User's Guide. 2. Water Treatment Types from Table 9.3 of Appendix D of the CalEEMod® User's Guide. 3. Wastewater Treatment Direct Emission Factors from Table 9.4 of Appendix D of the CalEEMod® User's Guide.

Abbreviations: CalEEMod® - California Emissions Estimator Model

CH4 - methane

CO2 - carbon dioxide gal - gallon kwh - kilowatt

N2O - nitrous oxide

References: CalEEMod® Version 2016.3.2 Available Online at: http://www.caleemod.com Table 22 Water Usage and Wastewater Emissions from Project Operations Denmar US, LLC Stockton, California

Electricity Indirect Septic Tank Direct Aerobic Direct Facultative Lagoon 1 1 1 1 Scenario Emissions Emissions Emissions Direct Emissions

(MT CO2e/yr) (MT CO2e/yr) (MT CO2e/yr) (MT CO2e/yr) Phase 1 (2023)2 13 15 8.6 5.4 Full Buildout (2025)2 12 15 8.6 5.4

Notes: 1. Emissions shown in this table were calculated using default values and methods from CalEEMod® Version 2016.3.2. These calculations were performed using water use rates, shown in Table 20, wastewater emission factors, shown in Table 21, and energy emission factors, shown in Table 18. Indoor water use is assumed to be processed as wastewater. Outdoor water use is assumed to not be processed as wastewater. 2. Per the Project Description, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026. The emissions shown in the table above assume a full year of Full Buildout Operation in 2025.

Abbreviations: CalEEMod® - California Emissions Estimator Model MT - metric ton

CO2e - carbon dioxide equivalents yr - year

References: California Emissions Estimator Model (CalEEMod®). Available online at http://www.caleemod.com/ Table 23 Solid Waste Generation for Project Operations Denmar US, LLC Stockton, California

Solid Waste Generation Solid Waste Solid Waste Land Use CalEEMod Land Use Size Units Disposal Rate1 Disposal Rate (ton/size/year) (ton/year) Phase 1 (2023)2 Rail Building General Light Industry 9.4 ksf 1.2 12 Building Unrefrigerated Warehouse-Rail 187 ksf 0.94 176 Administrative Building General Office Building 12 ksf 0.93 11 Administrative Building - Adjacent Parking Lot Parking Lot 17 spaces 0 0

Crew Quarters Building (Marine Facility) Health Club 2.0 ksf 5.7 11 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 9.0 spaces 0 0 Parking Lot Crew Quarters Building (Rail Facility) Health Club 2.0 ksf 5.7 11 Crew Quarters Building (Rail Facility) - Adjacent Parking Parking Lot 14 spaces 0 0 Lot Full Buildout Conditions (2025)2 Rail Building General Light Industry 9.4 ksf 1.2 12 Building Unrefrigerated Warehouse-Rail 374 ksf 0.94 352 Administrative Building General Office Building 12.1 ksf 0.93 11 Administrative Building - Adjacent Parking Lot Parking Lot 17 spaces 0 0

Crew Quarters Building (Marine Facility) Health Club 2.0 ksf 5.7 11 Crew Quarters Building (Marine Facility) - Adjacent Parking Lot 9 spaces 0 0 Parking Lot Crew Quarters Building (Rail Facility) Health Club 2.0 ksf 5.7 11 Crew Quarters Building (Rail Facility) - Adjacent Parking Parking Lot 14 spaces 0 0 Lot

Sludge Generation from Wastewater Pretreatment Facility3 Number of Annual Truck Trips Number of Weekly Truck Trips (truck/week) Truck Capacity (yd3/truck) Sludge Disposal Rate (ton/year) (trucks/year) 1 52 16 982

Notes 1. Solid Waste Generation Rates from Table 10.1 of Appendix D of the CalEEMod® User's Guide.

2. Per the Project Description, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026. 3. Sludge generation from the wastewater pretreatment facility are based on a conservative estimate of 1 truck trip per week to pick up the sludge. This conservative estimate applies to both Phase 1 and Full Buildout operations.

Abbreviations CalEEMod® - California Emissions Estimator Model ksf - thousand square feet yd3 - cubic yard

References CalEEMod® Version 2016.3.2 Available Online at: http://www.caleemod.com Table 24 Solid Waste Emissions from Project Operations Denmar US, LLC Stockton, California

Solid Waste Landfill Gas (LFG) Treatment Types1 Landfill Gas Landfill Gas Landfill, Capture County Landfill, No Gas Capture Capture Control Gas Flare Efficiency Efficiency San Joaquin 6% 94% 75% 98%

Solid Waste Landfill Gas Emission Factors2

CO2 Emissions CH4 Emissions Description

(ton/ton waste) (ton/ton waste)

No LFG Collection 0.14 0.043 LFG Collect and Combust 0.23 0.011

Solid Waste Emissions3

CO2 CH4 CO2e Land Use CalEEMod Land Use (MT/year) (MT/year) (MT/year)

Phase 1 (2023) Rail Building General Light Industry 2.4 0.14 5.9 Building Unrefrigerated Warehouse-Rail 36 2.1 88 Administrative Building General Office Building 2.3 0.13 5.7 Administrative Building - Adjacent Parking Lot Parking Lot 0 0 0

Crew Quarters Building (Marine Facility) Health Club 2.3 0.14 5.7 Crew Quarters Building (Marine Facility) - Parking Lot 0 0 0 Adjacent Parking Lot Crew Quarters Building (Rail Facility) Health Club 2.3 0.14 5.7 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 0 0 0 Parking Lot Total Phase 1 Buildout Emissions 45 2.7 111 Full Buildout Conditions (2025) Rail Building General Light Industry 2.4 0.14 5.9 Building Unrefrigerated Warehouse-Rail 71 4.2 177 Administrative Building General Office Building 2.3 0.13 5.7 Administrative Building - Adjacent Parking Lot Parking Lot 0 0 0

Crew Quarters Building (Marine Facility) Health Club 2.3 0.14 5.7 Crew Quarters Building (Marine Facility) - Parking Lot 0 0 0 Adjacent Parking Lot Crew Quarters Building (Rail Facility) Health Club 2.3 0.14 5.7 Crew Quarters Building (Rail Facility) - Adjacent Parking Lot 0 0 0 Parking Lot Total Full Buildout Emissions 81 4.8 200

Sludge Disposal Emissions3,4 CO CH CO e Location 2 4 2 (MT/year) (MT/year) (MT/year) Wastewater Pretreatment Facility 199 12 494

Notes: 1. Solid Waste Landfill Gas Treatment Types from Appendices A and D of the CalEEMod® User's Guide. 2. Solid Waste Landfill Gas Emission Factors from Table 10.2 of CalEEMod® User's Guide Appendix D. 3. Emissions are calculated using data provided above and in Table 23. 4. Sludge disposal emissions from the wastewater pretreatment facility are based on a conservative estimate of 1 truck trip per week to collect the sludge. This conservative estimate applies to both Phase 1 and Full Buildout operations.

Abbreviations: CalEEMod® - California Emissions Estimator Model LFG - Landfill Gas

CH4 - methane MT - metric ton

CO2 - carbon dioxide

CO2e - carbon dioxide equivalents

References: California Emissions Estimator Model (CalEEMod®). Available online at http://www.caleemod.com/ Table 25 Trip Rates for Project Operations Denmar US, LLC Stockton, California

Phase 1 Buildout Trip Rate1 Trip Length2 Annual Activity3 Annual Trips Annual VMT Fleet Type trips/day mi/trip days/year (trips/yr) (mi/yr) Passenger4 106 16.8 336 35,616 598,349

Full Buildout Trip Rate1 Trip Length2 Annual Activity3 Annual Trips Annual VMT Fleet Type trips/day mi/trip days/year (trips/yr) (mi/yr) Passenger4 142 16.8 336 47,712 801,562

Notes: 1. Operational trip rates are based on the number of employees working at the facility. Each employee is assumed to make 2 one-way trips per day, to and from the Project site. 2. Operational trip length is based on the CalEEMod default rural trip length from home-to-work for San Joaquin county. 3. Annual activity is based on the number of terminal operating days per year, provided by the Project sponsor.

4. The passenger fleet mix is defined in Table 26.

Abbreviations: CalEEMod® - California Emissions Estimator Model mi - mile(s) VMT - vehicle miles travelled yr - year

References: CalEEMod® Version 2016.3.2 Available Online at: http://www.caleemod.com Table 26 On-Road Fleet Mix for Project Operations Denmar US, LLC Stockton, California

Phase 1 Buildout Fleet Mix Vehicle Percentage of % by Fuel Type2 1 2 Assumption Type Fleet Mix Gas Diesel Natural Gas Electric LDA 61% 97% 0.9% 0% 1.9% LDT1 5.4% 99% 0.034% 0% 0.85% Passenger-Only LDT2 18% 98% 0.68% 0% 0.87% MCY 0.50% 100% 0% 0% 0% MDV 15% 97% 2.5% 0% 0.63%

Full Buildout Fleet Mix Vehicle Percentage of % by Fuel Type2 1 2 Assumption Type Fleet Mix Gas Diesel Natural Gas Electric LDA 62% 96% 1.0% 0% 2.8% LDT1 5.5% 99% 0.028% 0% 1.4% Passenger-Only LDT2 18% 98% 0.76% 0% 1.3% MCY 0.48% 100% 0% 0% 0% MDV 14% 96% 2.7% 0% 1.1%

Notes: 1. Operational on-road mobile trips are only generated by the passenger fleet mix (i.e., workers traveling to and from the site in passenger vehicles). Percentages have been adjusted accordingly. 2. Fleet mixes and percentages by fuel type are calculated based on EMFAC2017 vehicle miles traveled projections for San Joaquin County. EMFAC2017 was run for calendar years 2023 and 2025 in the annual season.

Abbreviations: EMFAC2017 - California Air Resources Board EMission FACtor model

References: California Air Resources Board (ARB) 2017. EMFAC2017. Available at: https://ww2.arb.ca.gov/our- work/programs/mobile-source-emissions-inventory/msei-modeling-tools Table 27 Operational On-Road Emission Factors Denmar US, LLC Stockton, California

Emission Mobile Emission Factors Scenario Factor CAPs GHGs Units Year Fleet ROG NOx PM10 PM2.5 CO SOx CO2 CH4 N2O CO2e g/mi 0.022 0.059 0.046 0.019 0.77 0.0029 290 0.0043 0.0059 292 Phase 1 - 2023 Passenger g/trip 0.92 0.24 0.0019 0.0017 2.5 0.00061 61 0.062 0.029 71 g/mi 0.018 0.046 0.046 0.019 0.66 0.0027 269 0.0036 0.0050 271 Full Buildout 2025 Passenger g/trip 0.81 0.20 0.0017 0.0016 2.3 0.00056 57 0.053 0.026 66

Notes: 1. Emission factors were estimated using EMFAC2017 for San Joaquin County. EMFAC2017 was run in Emission Rates mode for calendar years 2023 and 2025 in the annual season. The following processes have units of g/trip: DIRUN, HOTSOAK, RESTLOSS, STREX, and IDLEX. The following processes have units of g/mile: PMBW, PMTW, RUNEX, and RUNLOSS. Processes with units of g/vehicle/day were converted to g/trip using the population and trip rate values given in the EMFAC2017 run.

2. Emission factors from EMFAC with units of g/vehicle/day were converted to g/trip by scaling by the ratio of the total number of vehicles divided by the total number of trips for each vehicle class, fuel type, and year.

3. Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the IPCC 4th Assessment Report on Climate Change (AR4).

Abbreviations: CAP - Criteria Air Pollutant mi - mile

CH4 - methane N2O - Nitrous oxide

CO - carbon monoxide NOx - nitrogen oxides

CO2 - carbon dioxide PM - particulate matter

CO2e - carbon dioxide equivalent PMBW - break wear particulate matter emissions DIURN - diurnal evaporative hydrocarbon emissions PMTW - tire wear particulate matter emissions EMFAC2017 - California Air Resources Board EMission FACtor model RESTLOSS - resting evaporative losses g - grams ROG - reactive organic gases GHG - greenhouse gas RUNEX - running exhaust emissions HOTSOAK - hot soak evaporative hydrocarbon emissions RUNLOSS - running loss evaporative hydrocarbon emissions IDLEX - idle exhaust emissions STREX - start exhaust tailpipe emissions IPCC - Intergovernmental Panel on Climate Change SOx - sulfur oxides

References: California Air Resources Board (ARB) 2017. EMFAC2017. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/msei-modeling-tools Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report (AR4), 2007. Available at: https://www.ipcc.ch/assessment-report/ar4/ Table 28 Mobile Emissions from Project Operations Denmar US, LLC Stockton, California

Mobile Emissions Emissions from Mobile Sources

Phase Trip Type ROG NOx PM10 PM2.5 CO SOx CO2e [tons/yr] [MT/yr] Phase 1 Passenger 0.051 0.048 0.030 0.013 0.61 0.0019 177 Full Buildout Passenger 0.059 0.051 0.041 0.017 0.71 0.0024 220

Notes: 1. Trip generation rates and emission factors used in emissions calculations are shown in Table 25 and 27, respectively.

Abbreviations: CO - carbon monoxide PM - particulate matter

CO2e - carbon dioxide equivalents ROG - reactive organic gases MT - metric ton(s) SOx - sulfur oxides NOx - nitrogen oxides yr - year Table 29 On-Road Fugitive Dust Emissions from Project Operations Denmar US, LLC Stockton, California

Road Dust Equation1 E = k*(sL)^0.91 * (W)^1.02 * (1-P/4N)

Parameter2 Value E = annual average emission factor in the same units as k [calculated] k = particle size multiplier for particle size range and units of interest

PM 10 (lb/VMT) 0.0022

PM 2.5 (lb/VMT) 3.3E-04 2 sL = road surface silt loading (grams per square meter) (g/m ) 0.047 W = average weight (tons) of all the vehicles traveling the road 2.4 P = number of “wet” days with at least 0.01 in of precipitation during averaging period 3 51 N number of days in the averaging period 365

Phase 1 Buildout Conditions VMT 598,349 miles/year Full Buildout Conditions VMT 801,562 miles/year

Scenario Fugitive PM10 Fugitive PM2.5 Units Emission Factor 3.20E-04 4.79E-05 lb/VMT Phase 1 Buildout Emissions 0.096 0.014 tons/year Full Buildout Emissions 0.13 0.019 tons/year

Notes: 1. The road dust equation for paved roads is from the California Air Resources Board's (ARB) 2018 Miscellaneous Process Methodology 7.9 for Entrained Road Travel, Paved Road Dust. 2. Silt loading emission factor calculated in Table 9 using roadway travel fractions. Other parameters are from ARB

2016. PM2.5 is assumed to be 15% of PM10 based on paved road dust sampling in California (ARB Speciation Profile #471), which is a more representative fraction than provided in the older AP-42 fugitive dust methodology as discussed in ARB 2018 (page 10).

3. The number of "wet" days for San Joaquin County is from CalEEMod® Appendix D Table 1.1 (51 days).

Abbreviations: ARB - Air Resources Board PM - particulate matter CalEEMod® - California Emissions Estimator Model VMT - vehicle miles traveled lb - pounds

References: California ARB. 2018. Miscellaneous Processes Methodologies - Paved Entrained Road Dust. Available online at: https://www.arb.ca.gov/ei/areasrc/fullpdf/full7-9_2018.pdf

USEPA. 1996. AP 42. Compilation of Air Pollutant Emission Factors, Volume 1. Fifth Edition. Chapter 13.2.1, Paved Roads. Available online at: http://www3.epa.gov/ttn/chief/ap42/ch13/final/c13s0201.pdf. . Accessed January 2016. Table 30 Daily and Annual Dust Collector Emissions Denmar US, LLC Stockton, California

Design Outlet Maximum Daily PM10 Maximum Daily PM2.5 Design Operating Annual PM10 Annual PM2.5 Area Category No. Location Airflow Loading Emissions by Source Emissions by Source Hours per Year Emissions Emissions (CFM)1 (gr/CF)1 Group (lb/day) Group (lb/day) (hr/yr)1 (ton/yr) (ton/yr) 2 DC 1 Dumper 52,500 0.005 8.7 3.3 6,570 1.2 0.45 2 DC 2 Transfer Tower 02-TT-01 - Head Chute 4,000 0.005 6,570 0.091 0.034 2 DC 3 Transfer Tower 02-TT-01 - Skirtboard 4,000 0.005 6,570 0.091 0.034 2.7 1.0 2 DC 4 Transfer Tower 02-TT-02 - Head Chute 4,000 0.005 6,570 0.091 0.034 2 DC 5 Transfer Tower 02-TT-02 - Skirtboard 4,000 0.005 6,570 0.091 0.034 3 DC 1 Transfer Tower 03-TT-01 - Head Chute 4,000 0.005 6,570 0.091 0.034 3 DC 2 Transfer Tower 03-TT-01 - Upper Skirtboard 4,000 0.005 3,285 0.046 0.017 2.7 1.0 3 DC 8 Transfer Tower 03-TT-02 - Head Chute 4,000 0.005 7,350 0.102 0.038 3 DC 9 Transfer Tower 03-TT-02 - Skirtboard 4,000 0.005 7,350 0.102 0.038 3 DC 3 Storage Building 03-SB-01 - West 20,000 0.005 7,350 0.51 0.19 6.7 2.5 3 DC 7 Storage Building 03-SB-01 - East 20,000 0.005 7,350 0.51 0.19 3 DC 4 Stacker Reclaimer 03-SR-01 - Tripper Discharge2 4,000 0.005 N/A N/A N/A 3 DC 5 Stacker Reclaimer 03-SR-01 - Stacker Discharge2 4,000 0.005 N/A N/A N/A N/A N/A 3 DC 6 Stacker Reclaimer 03-SR-01 - Rake Discharge2 4,000 0.005 N/A N/A N/A 4 DC 1 Transfer Tower 03-TT-01 - Lower Skirtboard 4,000 0.005 3,285 0.046 0.017 4 DC 2 Transfer Tower 04-TT-01 - Head Chute 4,000 0.005 3,600 0.050 0.019 4 DC 3 Transfer Tower 04-TT-01 - Skirtboard 4,000 0.005 3.3 1.2 3,600 0.050 0.019 4 DC 9 Transfer Tower 04-TT-02 - Head Chute 4,000 0.005 3,600 0.050 0.019 4 DC 10 Transfer Tower 04-TT-02 - Skirtboard 4,000 0.005 3,600 0.050 0.019 4 DC 4 Storage Building 04-SB-01 West 20,000 0.005 3,600 0.25 0.09 6.7 2.5 4 DC 8 Storage Building 04-SB-01 East 20,000 0.005 3,600 0.25 0.09 4 DC 5 Stacker Reclaimer 04-SR-02 - Tripper Discharge2 4,000 0.005 N/A N/A N/A 4 DC 6 Stacker Reclaimer 04-SR-02 - Stacker Discharge2 4,000 0.005 N/A N/A N/A N/A N/A 4 DC 7 Stacker Reclaimer 04-SR-02 - Rake Discharge2 4,000 0.005 N/A N/A N/A 5 DC 1 Transfer Tower 05-TT-01 - 03-CV-02 Head Chute 4,000 0.005 6,570 0.091 0.034 5 DC 2 Transfer Tower 05-TT-01 - 05-CV-01 Skirtboard 1 4,000 0.005 1.995 0.7 6,570 0.091 0.034 5 DC 3 Transfer Tower 05-TT-01 - 05-CV-01 Skirtboard 2 4,000 0.005 6,570 0.091 0.034 5 DC 4 Shiploader 05-SL-01 - Tripper Head Chute 4,000 0.005 6,570 0.091 0.034 5 DC 5 Shiploader 05-SL-01 - Tripper Discharge 4,000 0.005 6,570 0.091 0.034 5 DC 6 Shiploader 05-SL-01 - Stinger Conveyor Discharge 4,000 0.005 3.3 1.2 6,570 0.091 0.034 5 DC 7 Shiploader 05-SL-01 - Telescoping Function 4,000 0.005 6,750 0.093 0.035 5 DC 8 Shiploader 05-SL-01 - Discharge Spout 4,000 0.005 6,750 0.093 0.035 6 DC 1 Transfer Tower 05-TT-01 - 04-CV-03 Head Chute 4,000 0.005 3,750 0.052 0.019 6 DC 2 Transfer Tower 05-TT-01 - 06-CV-01 Skirtboard 2 4,000 0.005 1.995 0.7 3,750 0.052 0.019 6 DC 3 Transfer Tower 05-TT-01 - 06-CV-01 Skirtboard 2 4,000 0.005 3,750 0.052 0.019 6 DC 4 Shiploader 06-SL-01 - Tripper Head Chute 4,000 0.005 3,750 0.052 0.019 6 DC 5 Shiploader 06-SL-01 - Tripper Discharge 4,000 0.005 3,750 0.052 0.019 6 DC 6 Shiploader 06-SL-01 - Stinger Conveyor Discharge 4,000 0.005 3.3 1.2 3,750 0.052 0.019 6 DC 7 Shiploader 06-SL-01 - Telescoping Function 4,000 0.005 3,750 0.052 0.019 6 DC 8 Shiploader 06-SL-01 - Discharge Spout 4,000 0.005 3,750 0.052 0.019 Total Annual Dust Collector Emissions (ton/yr) 4.8 1.8 Table 30 Daily and Annual Dust Collector Emissions Denmar US, LLC Stockton, California Dust Collector Emissions Summary PM PM Scenario 10 2.5 ton/year ton/year Phase 1 Buildout 3.6 1.4 Full Buildout 4.8 1.8

Notes: 1. Baghouse input parameters including design airflow, outlet loading, and design operating hours were provided by the Project sponsor. 2. Process Recapture Sources are dust collectors that exhaust to an enclosure that is controlled by other dust collectors and therefore are not considered emission sources.

Abbreviations: CF - cubic foot lb - pound CFM - cubic feet per minute PM - particulate matter gr - grain(s) yr- year hr - hour Table 31 Daily and Annual Shiploading Emissions Denmar US, LLC Stockton, California

PM10 Fugitive PM2.5 Fugitive Maximum Daily Maximum Daily Annual Annual PM10 Annual PM2.5 1 2 Process Rate PM10 Emission PM2.5 Emission Shiploader Emission Factor Emission Factor PM10 Emissions PM2.5 Emissions Operating Emissions Emissions (ton/hr)3 Rate (lb/hr) Rate (lb/hr) (lb/ton material) (lb/ton material) (lb/day) (lb/day) Hours (hr/yr)3 (ton/yr) (ton/yr)

05-SL-01 1.5 0.34 35 8.1 3.0 0.70 0.0012 0.00028 2,424 4,161 06-SL-02 1.5 0.34 35 8.1 3.0 0.70 Total Annual Shiploading Fugitive Emissions 6.1 1.4

Shiploading Emissions Summary PM PM Scenario 10 2.5 ton/year ton/year Phase 1 Buildout 3.0 0.70 Full Buildout 6.1 1.4

Notes: 1. The PM10 emission factor was developed from the uncontrolled value for Metallic Minerals Processing, material handling and transfer, for low moisture ore. A capture efficiency of 98% percent was applied to the

uncontrolled value to achieve the PM10 fugitive emission factor. 2. The PM2.5 emission factor was developed from the PM10 uncontrolled value for Metallic Minerals Processing, material handling and transfer, for low moisture ore. The PM2.5/PM10 ratio provided in AP-42, Appendix

B.1, for uncontrolled potash (Potassium Chloride) dryer was applied to the PM10 uncontrolled value to obtain a value for PM2.5. A capture efficiency of 98% percent was applied to the uncontrolled value to achieve

the PM2.5 fugitive emission factor.

3. Shiploading input parameters including process rate and annual operating hours were provided by the Project sponsor.

Abbreviations: hr - hour lb - pound PM - particulate matter yr - year

References: USEPA. 1982. AP-42 Metallic Minerals Processing. Available at: https://www3.epa.gov/ttn/chief/ap42/ch11/final/c11s24.pdf Table 32 Vessels, Train and Material Throughput Summary Denmar US, LLC Stockton, California

Description Initial Phase Full Buildout

Annual Throughput (MT/yr) 4,800,000 7,000,000 Trains per Year1 249 363 Trains per Week2 5.2 7.6 Trains per Day3 0.74 1.1 Ships per Year4 137 200 Ships per Week2 2.9 4.2 Ships per Day3 0.41 0.60

Notes 1. Based on 193 cars/unit train and 100 metric tons of product per railcar. Trains that will be diverted as part of the project are limited to 143 cars/unit train and 100 metric tons of product per railcar. 2. Based on 336 terminal operating days per year. 3. Based on 7 terminal operating days per week. 4. Based on 35,000 metric tons of product per ship. 5. Train and ship numbers are calculated as one-way (loaded-only) trips. For number of round-trips (loaded and empty), multiply the train and ship numbers shown above by 2. 6. Train and ship numbers are calculated on a continuous average based on annual throughput and the assumptions listed above. As a result, reverse-calculation of annual throughput from these resultant values may result in variance from the original numbers.

Abbreviations: MT - metric tons yr - year Table 33 Rail Emission Factor Derivation Denmar US, LLC Stockton, California

Line Haul Emission Factors1 U.S. EPA Emission Factors (g/gal) Tier PM10 PM2.5 HC ROG NOx CO Pre-Tier 6.7 6.1 10 12 270 27 Tier 0 6.7 6.1 10 12 179 27 Tier 0+ 4.2 3.8 6.2 7.6 150 27 Tier 1 6.7 6.1 9.8 12 139 27 Tier 1+ 4.2 3.8 6.0 7.3 139 27 Tier 2 3.7 3.4 5.4 6.5 103 27 Tier 2+ 1.7 1.5 2.7 3.3 103 27 Tier 3 1.7 1.5 2.7 3.3 103 27 Tier 4 0.31 0.29 0.83 1.0 21 27

Line Haul Locomotives Tier Distribution2 Year Pre-Tier Tier 0 Tier 0+ Tier 1 Tier 1+ Tier 2 Tier 2+ Tier 3 Tier 4 2020 0% 0% 1.4% 0% 1.5% 0% 36% 33% 28% 2021 0% 0% 0.90% 0% 1.5% 0% 31% 33% 34% 2022 0% 0% 0.45% 0% 1.4% 0% 24% 34% 40% 2023 0% 0% 0% 0% 1.4% 0% 19% 34% 46% 2024 0% 0% 0% 0% 0.94% 0% 13% 32% 53% 2025 0% 0% 0% 0% 0.48% 0% 8.5% 31% 60% 2026 0% 0% 0% 0% 0% 0% 3.3% 30% 67% 2027 0% 0% 0% 0% 0% 0% 2.8% 24% 73% 2028 0% 0% 0% 0% 0% 0% 2.4% 18% 80% 2029 0% 0% 0% 0% 0% 0% 1.8% 13% 86% 2030 0% 0% 0% 0% 0% 0% 1.4% 7.5% 91% 2031 0% 0% 0% 0% 0% 0% 0.88% 2.5% 97% 2032 0% 0% 0% 0% 0% 0% 0.45% 2.4% 97% 2033 0% 0% 0% 0% 0% 0% 0% 2.4% 98% 2034 0% 0% 0% 0% 0% 0% 0% 1.9% 98% 2035 0% 0% 0% 0% 0% 0% 0% 1.4% 99% 2036 0% 0% 0% 0% 0% 0% 0% 0.90% 99% 2037 0% 0% 0% 0% 0% 0% 0% 0.45% 100% 2038 0% 0% 0% 0% 0% 0% 0% 0% 100% 2039 0% 0% 0% 0% 0% 0% 0% 0% 100% 2040 0% 0% 0% 0% 0% 0% 0% 0% 100% 2041 0% 0% 0% 0% 0% 0% 0% 0% 100% 2042 0% 0% 0% 0% 0% 0% 0% 0% 100% 2043 0% 0% 0% 0% 0% 0% 0% 0% 100% 2044 0% 0% 0% 0% 0% 0% 0% 0% 100% 2045 0% 0% 0% 0% 0% 0% 0% 0% 100% 2046 0% 0% 0% 0% 0% 0% 0% 0% 100% 2047 0% 0% 0% 0% 0% 0% 0% 0% 100% 2048 0% 0% 0% 0% 0% 0% 0% 0% 100% 2049 0% 0% 0% 0% 0% 0% 0% 0% 100% 2050 0% 0% 0% 0% 0% 0% 0% 0% 100% Table 33 Rail Emission Factor Derivation Denmar US, LLC Stockton, California Fleet Average Line Haul Project Emission Factors3 Emission Factors (g/gal) Year PM10 PM2.5 ROG NOx CO 2023 1.1 1.0 2.3 66 27 2024 1.0 0.9 2.1 60 27 2025 0.86 0.79 1.9 54 27 2026 0.76 0.70 1.8 48 27 2027 0.67 0.62 1.6 43 27 2028 0.59 0.54 1.5 38 27 2029 0.51 0.47 1.3 33 27 2030 0.43 0.40 1.2 28 27 2031 0.36 0.33 1.1 24 27 2032 0.35 0.32 1.1 23 27 2033 0.34 0.31 1.1 23 27 2034 0.34 0.31 1.0 22 27 2035 0.33 0.30 1.0 22 27 2036 0.32 0.30 1.0 22 27 2037 0.32 0.29 1.0 21 27 2038 0.31 0.29 1.0 21 27 2039 0.31 0.29 1.0 21 27 2040 0.31 0.29 1.0 21 27 2041 0.31 0.29 1.0 21 27 2042 0.31 0.29 1.0 21 27 2043 0.31 0.29 1.0 21 27 2044 0.31 0.29 1.0 21 27 2045 0.31 0.29 1.0 21 27 2046 0.31 0.29 1.0 21 27 2047 0.31 0.29 1.0 21 27 2048 0.31 0.29 1.0 21 27 2049 0.31 0.29 1.0 21 27 2050 0.31 0.29 1.0 21 27

4 Line Haul SO2 Emission Factor Parameter Value Units Fuel Density 3,200 g/gal Fraction of fuel sulfur converted to 100% % SO2 Sulfur content of fuel 15 ppm MW S 32 g/mol

MW SO2 64 g/mol

SO2 Emission Factor 0.10 g/gal

Notes: 1. Line haul emission factors are based on the CARB 2017 Line Haul / Class I Documentation, Table 4-8. The PM2.5 emission factor is 92% of PM10 for locomotive operations, and the emission factor

for PM and PM10 are equivalent. The emission factor for reactive organic gases is estimated as 1.21 times the emission factor for hydrocarbons (HC). 2. Line haul locomotives tier distribution is from the CARB 2017 Emissions Inventory Aggregated at County/Air Basin/State. 3. Fleet average emission factors were calculated by applying CARB Tier distributions to the line haul emission factors for each operational year. 4. The SO2 emission factor was calculated based on the methodology described in the CARB 2017 Line Haul / Class I Documentation, Equation 4.5 5. After calendar year 2038, all engines are Tier 4 and emission factors are assumed to be constant.

Abbreviations: CARB - California Air Resources Board NOx - nitrogen oxides CO - carbon monoxide PM - particulate matter g - gram(s) ppm - parts per million gal - gallon(s) ROG - reactive organic gases

HC - hydrocarbons SO2 - sulfur dioxide MW - molecular weight

References: CARB. 2017 Line Haul / Class I Documentation. Last accessed on 12/2/2019 at: https://www.arb.ca.gov/msei/ordiesel.htm. Table 34 Project Operational Rail Emissions Denmar US, LLC Stockton, California

Rail Emission Factors

Emission Factor1 (g/gal) Emission Factor2 (g/bhp-hr) Pollutant 2023 2025 2023 2025 ROG 2.3 1.9 0.110 0.093 NOx 66 54 3.2 2.6

PM10 1.1 0.86 0.052 0.041

PM2.5 1.0 0.79 0.048 0.038 CO 27 27 1.3 1.3

SO2 0.10 0.10 0.0046 0.0046

CO2 10,210 491

CH4 0.80 0.038

N2O 0.26 0.012

CO2e 10,306 495

Phase 1 Buildout Inputs Parameter Running Idling Units Unit Train Equivalents per Year3 249 # of trains per year Horsepower per Locomotive4 4,390 HP Within Project Site On-Site Drayage Hours/Unit Train5 9 15 hours/unit train On-Site Drayage Hours/Year 2,238 3,731 hours/year Line Locomotives per Train for Offloading6 2 1 # of locomotives Engine Load Factor7 24% 0.35% % Annual On-Site Drayage Locomotive Engine 4,675,604 bhp-hours/yr Power Between Project Site and Air District Boundary Miles Traveled8 26 miles/one-way Net Aggregated Fuel Consumption Index9 868 ton-mile/gal Number of Locomotives per Train6 5 locomotive/train Weight of Locomotive10 213 ton/locomotive Number of Rail Cars per Year 47,999 rail cars/year Number of Rail Cars per Train3 193 rail cars/train Weight of Empty Rail Car11 33 ton/rail car Weight of Product Transported per Year12 5,289,600 ton/yr Fuel Consumption (Roundtrip)13 267,719 gal/yr

ROG NOx PM PM CO SO CO e Location 10 2.5 2 2 (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (MT/year) Within Project Site 0.57 16 0.27 0.24 6.6 0.024 2,317

Between Project Site and Air District Boundary 0.67 19 0.32 0.29 7.9 0.028 2,759

Total 1.2 36 0.58 0.54 14 0.052 5,076 Table 34 Project Operational Rail Emissions Denmar US, LLC Stockton, California Full Buildout Inputs Parameter Running Idling Units Unit Train Equivalents per Year3 363 # of trains per year Horsepower per Locomotive4 4,390 HP Within Project Site On-Site Drayage Hours/Unit Train5 9 15 hours/unit train On-Site Drayage Hours/Year 3,264 5,440 hours/year Line Locomotives per Train for Offloading6 2 1 # of locomotives Engine Load Factor7 24% 0.35% % Annual On-Site Drayage Locomotive Engine 6,818,635 bhp-hours/yr Power Between Project Site and Air District Boundary Miles Traveled8 26 miles/one-way Net Aggregated Fuel Consumption Index9 868 ton-mile/gal Number of Locomotives per Train6 5 locomotive/train Weight of Locomotive10 213 ton/locomotive Number of Rail Cars per Year 69,999 rail cars/year Number of Rail Cars per Train3 193 rail cars/train Weight of Empty Rail Car11 33 ton/rail car Weight of Product Transported per Year12 7,714,000 ton/yr Fuel Consumption (Roundtrip)13 390,425 gal/yr

ROG NOx PM PM CO SO CO e Location 10 2.5 2 2 (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (MT/year) Within Project Site 0.70 19 0.31 0.29 10 0.035 3,378

Between Project Site and Air District Boundary 0.83 23 0.37 0.34 11 0.041 4,024

Total 1.5 43 0.68 0.63 21 0.076 7,402

Brake specific fuel consumption factor2 20.8 bhp-hr/gallon Grams to tons 907185 g/ton Grams to metric tons 1000000 g/MT Grams to pounds 453.59 g/lb

Notes: 1. The ROG, NOx, PM10, PM2.5, CO, and SO2 emission factors are based on the CARB 2017 Line Haul / Class I Documentation, Table 4-8. Fleet average emission factors were calculated by applying CARB Tier

distributions (2017 Emissions Inventory Aggregated at County/Air Basin/State) for each operational year. See Table 35 for details. The CO2, CH4, and N2O emission factors (g/gal) come from Table 2.1 and Table

2.7 of The Climate Registry's 2019 Default Emission Factors. For the purpose of this analysis, all SOx emissions are assumed to be emitted as SO 2.

2. The conversion from g/gal to g/bhp-hr is calculated using the brake specific fuel consumption factor. The brake specific fuel consumtion factor comes from the CARB 2017 Line Haul / Class I Documentation, Section 4.5. 3. The number of trains per year was provided by the Project sponsor, as shown in Table 34. 4. Default locomotive assumed to be 4,390 horsepower, similar to a GE C44AC. 5. The number of on-site drayage hours per train is conservatively estimated to be 9 hours/unit train for running and 15 hours/unit train for idling. 6. Trains will have 5 locomotives in total. It is conservatively assumed that 2 locomotives will be operating while the train is running on-site, and 1 locomotive will be operating during idling on-site. All 5 locomotives will be operating while the train is running off-site. Table 34 Project Operational Rail Emissions Denmar US, LLC Stockton, California Notes, continued: 7. Engine load factor is consistent with the EPA's Locomotive Emission Standards Regulatory Support Document (Locomotive RSD), Document No. EPA-420-R-98-101 Table 5-2 for throttle notch positions N3 and Idle, which represent the on-site running and idling conditions, respectively. Throttle notch positions were provided by the Project sponsor. 8. Miles traveled represent the number of miles from the Project site to the SJVAPCD boundary. Incoming trains will be traveling from Roseville, CA into Stockton, CA during set transit windows. It is anticipated that the trains would turn west at the wye in Stockton and travel along the main line. Trains destined for the proposed facility would enter the port's existing lead in the east complex, cross the existing bridge over the San Joaquin River, travel through the west complex and arrive at the facility. 9. Net aggregated fuel consumption index is calculated based on the methodology described in the CARB 2017 Line Haul / Class I Documentation, Equation 4-2. Estimated grades for Roseville to Fresno and Fresno to Roseville were selected from Table 4-4 of the CARB 2017 Line Haul / Class I Documentation.

10. The weight of the locomotive was obtained from the GE Transportation Evolution Series Tier 4 Locomotive specification sheet (GE 2014). 11. Empty car weight was obtained from BNSF website (BNSF 2016). 12. The annual throughput was provided by the Project sponsor, as shown in Table 34. 13. The roundtrip fuel consumption accounts for a filled train one-way trip and an empty train one-way trip. The train will arive at the site filled with material and exit the site empty.

Abbreviations:

bhp - brake horsepower g - gram(s) N2O - nitrous oxide CARB - California Air Resources Board gal - gallon(s) NOx - nitrogen oxides

CH4 - methane HP - horsepower PM - particulate matter CO - carbon monoxide hr - hour(s) ROG - reactive organic gases

CO2 - carbon dioxide MT - metric ton(s) SO2 - sulfur dioxide

CO2e - carbon dioxide equivalents

References BNSF. 2016. Individual Railcar. Available at: http://www.bnsf.com/customers/how-can-i-ship/individual-railcar/#%23subtabs-3 CARB. 2017 Line Haul / Class I Documentation. Last accessed on 12/2/2019 at: https://www.arb.ca.gov/msei/ordiesel.htm. Climate Registry. 2019 Emission Factors, Table 2.1 and Table 2.7. Available at: https://www.theclimateregistry.org/wp-content/uploads/2019/05/The-Climate-Registry-2019-Default-Emission-Factor- Document.pdf

Environmental Protection Agency (EPA). 1998. Locomotive Emission Standards Regulatory Support Document (Locomotive RSD), Document No. EPA-420-R-98-101, Table 5-2 Typical Power Distribution by Notch.

GE. 2014. Evolution Series Tier 4 Locomotive. Available at: http://media.getransportation.com/sites/default/files/3%20EvoSeries%20Tier%204_locomotives.pdf Table 35 Project Operational Ship Emissions Denmar US, LLC Stockton, California

Input Parameters - Trip Rate, Length, and Speed Details Total Annual Annual Trip Rate2 One-Way Trip One-Way Transit Scenario Activity1 Trip Type Speed4 (knots) Transit Hours6 (trips/yr) Length3 (nmi/trip) Time5 (hours/trip) (hours/yr)

Transit (beyond GGB) Inbound 19 15 1.3 345 Outbound Inbound Transit (within BAAQMD) 62 3.0 21 5,668 Outbound Phase 1 Buildout Inbound 137 Transit (within SJVAPCD) 14 3.0 4.7 1,280 Outbound Inbound 5.1 1.8 252 Maneuvering 3.0 Outbound 0.67 3.0 0.35 48 Hoteling ------36 4,937

Transit (beyond GGB) Inbound 19 15 1.3 503 Outbound Inbound Transit (within BAAQMD) 62 3.0 21 8,267 Outbound Full Buildout Inbound 200 Transit (within SJVAPCD) 14 3.0 4.7 1,867 Outbound Inbound 5.1 1.8 367 Maneuvering 3.0 Outbound 0.67 3.0 0.35 70 Hoteling ------36 7,200

Input Parameters - Engine Details7

Average Auxiliary Average Main Engine Size - Average Boiler Size Main Engine Load Auxiliary Engine Scenario Activity Engine Size - Bulk Boiler Load Factor Bulk Carrier (kW) (kW) Factor Load Factor Carrier (kW)

Transit (beyond GGB) 0.83 0.17 1.0 Transit (within BAAQMD) 0.06 0.17 1.0 Phase 1 Buildout Transit (within SJVAPCD) 0.06 0.17 1.0 Maneuvering 0.02 0.45 1.0 Hoteling N/A 0.10 1.0 7,803 2,459 82 Transit (beyond GGB) 0.83 0.17 1.0 Transit (within BAAQMD) 0.06 0.17 1.0 Full Buildout Transit (within SJVAPCD) 0.06 0.17 1.0 Maneuvering 0.02 0.45 1.0 Hoteling N/A 0.10 1.0

Main Engine Emission Factors8,9,10

CO2 Emission CO2e Emission NOx Emission ROG Emission PM10 Emission PM2.5 Emission CO Emission Factor SOx Emission CH4 Emission Fuel Activity Engine Speed Factor (g/kW- Factor (g/kW- Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) hr) hr)6 Transit (beyond GGB) Medium 13 0.65 0.25 0.23 1.1 0.40 645 0.080 647 Transit (within BAAQMD) Slow 27 3.4 0.51 0.47 1.8 1.6 935 0.305 943 Marine Distillate (0.1% S) Transit (within SJVAPCD) Slow 27 3.4 0.51 0.47 1.8 1.6 935 0.305 943 Maneuvering Slow 79 17 1.8 1.7 3.6 7.6 1929 1.483 1966 Hoteling ------

Auxiliary Engine Emission Factors11

CO2 Emission CO2e Emission NOx Emission ROG Emission PM10 Emission PM2.5 Emission CO Emission Factor SOx Emission CH4 Emission Fuel Activity Engine Speed Factor (g/kW- Factor (g/kW- Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) hr) hr)6 Transit (beyond GGB) Medium 14 0.52 0.25 0.23 1.1 0.40 690 0.090 692 Transit (within BAAQMD) Medium 14 0.52 0.25 0.23 1.1 0.40 690 0.090 692 Marine Distillate (0.1% S) Transit (within SJVAPCD) Medium 14 0.52 0.25 0.23 1.1 0.40 690 0.090 692 Maneuvering Medium 14 0.52 0.25 0.23 1.1 0.40 690 0.090 692 Hoteling Medium 14 0.52 0.25 0.23 1.1 0.40 690 0.090 692

Boiler Emission Factors12

CO2 Emission CO2e Emission NOx Emission ROG Emission PM10 Emission PM2.5 Emission CO Emission Factor SOx Emission CH4 Emission Fuel Activity Engine Speed Factor (g/kW- Factor (g/kW- Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) (g/kW-hr) Factor (g/kW-hr) Factor (g/kW-hr) hr) hr)6 Heavy Fuel Oil All N/A 2.1 0.11 0.80 0.78 0.20 17 970 0.03 971 Table 35 Project Operational Ship Emissions Denmar US, LLC Stockton, California Ship Emissions

NOx Emissions ROG Emissions PM Emissions PM Emissions CO Emissions SOx Emissions CO Emissions CH Emissions CO e Emissions Source Activity 10 2.5 2 4 2 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (MT/yr) (MT/yr) (MT/yr)

Phase 1 Buildout Transit (beyond GGB) 32 1.6 0.61 0.56 2.7 0.98 1,433 0.18 1,437 Transit (within BAAQMD) 80 9.9 1.5 1.4 5.1 4.6 2,481 0.81 2,501 Transit (within SJVAPCD) 18 2.2 0.34 0.31 1.2 1.03 560 0.18 565 Main Engine Maneuvering 4.1 0.85 0.094 0.086 0.19 0.393 90 0.069 92 Hoteling ------Sub-Total 134 14.6 2.5 2.3 9.2 7.0 4,564 1.24 4,595 Transit (beyond GGB) 2.2 0.083 0.040 0.037 0.17 0.064 100 0.013 100 Transit (within BAAQMD) 36 1.4 0.65 0.60 2.9 1.0 1,635 0.21 1,640 Transit (within SJVAPCD) 8.2 0.31 0.15 0.14 0.65 0.24 369 0.048 370 Auxiliary Engine Maneuvering 5.1 0.19 0.091 0.084 0.40 0.15 229 0.030 229 Hoteling 19 0.70 0.33 0.31 1.5 0.54 838 0.11 840 Sub-Total 70 2.6 1.3 1.2 5.6 2.0 3,170 0.41 3,180 Transit (beyond GGB) 0.065 0.0034 0.025 0.024 0.0062 0.51 27 0.00085 27 Transit (within BAAQMD) 1.1 0.056 0.41 0.40 0.10 8.5 451 0.014 451 Transit (within SJVAPCD) 0.24 0.013 0.093 0.090 0.023 1.9 102 0.0031 102 Boiler Maneuvering 0.057 0.0030 0.022 0.021 0.0054 0.45 24 0.00074 24 Hoteling 0.94 0.049 0.36 0.35 0.089 7.4 393 0.012 393 Sub-Total 2.4 0.12 0.91 0.88 0.23 19 997 0.031 997 Total Emissions within SJVAPCD 55 4 1.5 1.4 4.0 12 2,604 0.5 2,616 Total Emissions 207 17 4.7 4.4 15 28 8,731 1.7 8,773 Full Buildout Transit (beyond GGB) 47 2.3 0.9 0.8 3.9 1.4 2,089 0.26 2,096 Transit (within BAAQMD) 116 14 2.2 2.0 7.5 6.7 3,618 1.2 3,648 Transit (within SJVAPCD) 26 3.3 0.49 0.45 1.7 1.51 817 0.27 824 Main Engine Maneuvering 5.9 1.2 0.14 0.13 0.27 0.573 131 0.10 134 Hoteling ------Sub-Total 195 21 3.7 3.4 13 10 6,656 1.80 6,701 Transit (beyond GGB) 3.2 0.12 0.058 0.053 0.26 0.093 145 0.019 146 Transit (within BAAQMD) 53 2.0 0.95 0.88 4.2 1.5 2,384 0.31 2,392 Transit (within SJVAPCD) 12 0.45 0.22 0.20 0.95 0.34 538 0.070 540 Auxiliary Engine Maneuvering 7.4 0.28 0.13 0.12 0.59 0.21 333 0.043 334 Hoteling 27 1.0 0.49 0.45 2.1 0.78 1,222 0.16 1,226 Sub-Total 103 3.8 1.8 1.7 8.1 3.0 4,623 0.60 4,638 Transit (beyond GGB) 0.096 0.0050 0.036 0.035 0.0091 0.75 40 0.0012 40 Transit (within BAAQMD) 1.6 0.082 0.60 0.58 0.15 12 658 0.020 658 Transit (within SJVAPCD) 0.35 0.019 0.135 0.13 0.034 2.8 148 0.0046 149 Boiler Maneuvering 0.083 0.0043 0.032 0.031 0.0079 0.65 35 0.0011 35 Hoteling 1.4 0.072 0.52 0.51 0.13 11 573 0.018 573 Sub-Total 3.5 0.18 1.3 1.3 0.33 27 1,453 0.045 1,455 Total Emissions within SJVAPCD 80 6.3 2.2 2.0 5.8 18 3,798 0.66 3,814 Total Emissions 301 25 6.9 6.4 22 40 12,733 2.5 12,794

Notes: 1. Ship emissions are quantified within a 100 nmi zone of the Project site, as recommended in 2011 CARB Emissions Estimation Methodology for Ocean-Going Vessels. Ships will travel from the Project site, through SJVAPCD, through BAAQMD, and into the Pacific Ocean beyond the Golden Gate Bridge. Emissions estimates have been grouped by activity, including hoteling, maneuvering, and transit. Transit emissions are split out based on the air district in which emissions occur. 2. Annual trip rates were provided by the Project sponsor, as shown in Table 34. 3. Trip lengths were pulled from Google Earth. Maneuvering distance reflects the distance from the Rough & Ready Island (at Burns Cutoff), where tugboats pick up vessels. 4. Vessels will travel at 3 knots within the San Joaquin River and 15 knots in the Pacific Ocean, as provided by the Project sponsor. 5. Transit time is calculated based on the trip length and ship speed. Each vessel will bee moored at the dock for an average of approximately 36 hours, as provided by the Project sponsor. As recommended by CARB, maneuvering time is calculated as the length of time required to travel the maneuvering distance plus an additional 15 minutes for docking and undocking. 6. Total annual transit hours are calculated based on the transit time and annual trip rate, accounting for two one-way trips per roundtrip. 7. Engine characteristics were obtained from the 2011 CARB Emissions Estimation Methodology for Ocean-going Vessels for Bulk Carriers. Average engine sizes for Bulk Carriers are given in Table II-4. Main Engine transit load factor is given in Section 4 for ships traveling at cruise speed. Main Engine transit load factors were adjusted for the legs in which ships will be traveling at slower speeds, consistent with the methodology described in the Lehigh Southwest Stockton Terminal Project DEIR . Auxiliary Engine transit load factors are given in Table II-5. Boilers assumed to operate at full load. 8. Emission factors for main engine transit are based on 2011 CARB Emissions Estimation Methodology for Ocean-going Vessels (Table II-6); for Bulk Carriers operating at slow speed, using Marine Distillate Fuel (0.1% S) while the ships are traveling at 3 knots. Once the ships accelerate to a speed of 15 knots past the Golden Gate Bridge, emission factors are selected for Bulk Carriers operating at medium speed. Maneuvering emission factors are from Table II-7.

9. The CO2e emission factor is calculated based on the IPCC AR4 reporting global warming potentials for CH4 and CO2 emissions. No N2O emission factor is reported in 2011 CARB Emission Estimation Methodology for Ocean-going Vessels (Table II-6). 10. As recommended by CARB, at main engine load factors of less than 20%, engine emissions are multiplied by an adjustment factor which accounts for higher emission rates at lower loads. The adjustment factor is calculated using an exponential equation developed by Sierra Research for the U.S. Environmental Protection Agency (USEPA 2000). Table 35 Project Operational Ship Emissions Denmar US, LLC Stockton, California Notes, continued: 11. Emission factors for auxiliary engine transit are based on 2011 CARB Emissions Estimation Methodology for Ocean-going Vessels (Table II-8); for Bulk Carriers operating at medium speed, using Marine Distillate Fuel (0.1% S). 12. Emission factors for boilers are based on 2011 CARB Emissions Estimation Methodology for Ocean-going Vessels (Table II-9); for Bulk Carriers using heavy fuel oil. Note that boilers are conservatively assumed to operate for the entire duration in which the ship is operating.

Abbreviations: BAAQMD - Bay Area Air Quality Management District GGB - Golden Gate Bridge PM - particulate matter CARB - California Air Resources Board HP - horsepower ROG - reactive organic gases

CH4 - methane hr - hour(s) SJVAPCD - San Joaquin Valley Air Pollution Control District

CO - carbon monoxide MT - metric ton(s) SO2 - sulfur dioxide

CO2 - carbon dioxide N2O - nitrous oxide

CO2e - carbon dioxide equivalents nmi - nautical mile g - gram(s) NOx - nitrogen oxides

References: CARB. 2011. Appendix D: Emissions Estimation Methodology for Ocean-Going Vessels (2011). https://ww3.arb.ca.gov/regact/2011/ogv11/ogv11appd.pdf IPCC Greenhouse Gas Protocol. 2014. Global Warming Potential Values, IPCC AR4. https://www.ghgprotocol.org/sites/default/files/ghgp/Global-Warming-Potential-Values%20%28Feb%2016%202016%29_1.pdf Lehigh Southwest Stockton Terminal Project. Draft Environmental Impact Report. May 2020. https://www.portofstockton.com/wp-content/uploads/2020/05/LehighSWStocktonTerminal_2019100510_DEIR_small.pdf USEPA. 2000. Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data. Table 36 Project Operational Tugboat Emissions Denmar US, LLC Stockton, California

Input Parameters1,2

Total Tug Boats to Trip Length One-way Transit Total Annual Average Main Average Auxiliary Main Engine Auxiliary Engine Average Tugboat Scenario Trip Type Assist Ships (tug (nmi/one-way Time (hours/one- Transit Hours Engine Size - Tug Engine Size - Tug Transit Load Transit Load Speed (knots) boats/yr) trip) way trip) (hours/yr) Boat (HP) Boat (HP) Factor Factor Inbound 274 5.1 1.8 503 Phase 1 Buildout Outbound 137 0.67 0.35 48 3.0 1,800 282 0.31 0.43 Inbound 400 5.1 1.8 734 Full Buildout Outbound 200 0.67 0.35 70

Ship Emissions3 NOx Emissions ROG Emissions CO Emissions SOx Emissions PM Emissions PM Emissions CO Emissions CH Emissions N O Emissions CO e Emissions Engine 10 2.5 2 4 2 2 (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (MT/yr) (MT/yr) (MT/yr) (MT/yr)4 Phase 1 Buildout Main 2.0 0.30 1.5 0.0019 0.08 0.08 0.0061 181 0.19 187 Auxiliary 0.39 0.07 0.30 4.1E-04 0.017 0.017 0.0013 39 0.049 41 Total 2.4 0.37 1.8 0.0023 0.09 0.09 0.007 220 0.24 228 Full Buildout Main 3.0 0.45 2.2 0.0027 0.12 0.12 0.009 263 0.27 273 Auxiliary 0.57 0.10 0.45 5.9E-04 0.025 0.025 0.0019 57 0.07 60 Total 3.6 0.55 2.6 0.0033 0.14 0.14 0.011 321 0.35 332

Notes 1. Tug main and auxiliary engine characteristics are based on the TERRI L BRUSCO tugboat from the Brusco fleet, which currently operates in the Port of Stockton according to the Port's Daily Vessel Log. 2. Total tug boats per year calculated assuming 2 tug boats assist the ship on each inbound trip, while 1 tug boat assists on each outbound trip. Trip length reflects distance from Rough & Ready Island (at Burns Cutoff) where tugboats pick up ships, to project site. Total annual transit hours are calculated based on transit time and trip rates. See Table 37 for more details on ship operations. 3. Tugboat emissions calculated using the following equation from CARB: E = EF0 x F x (1 + D x A/UL) x HP x LF x hr; were EF0 is the zero-hour emission factor, F is the fuel correction factor, D is the deterioration factor, A is the engine age, and UL is the useful life of the engine as shown in Table 7. Horsepower (HP), load factor (LF) and transit hours (hr) are shown above.

4. CO2e emissions calculated based on the IPCC AR4 global warming potentials of 1, 25, and 298 for CO2, CH4, and N2O, respectively.

Abbreviations:

CH4 - methane NOx - nitrogen oxides CO - carbon monoxide PM - particulate matter

CO2 - carbon dioxide ROG - reactive organic gases

CO2e - carbon dioxide equivalents SOx - sulfur oxides HP - horsepower yr - year

N2O - nitrous oxide

References CARB. Commercial Harbor Craft (CHC) Inventory Model. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/road-documentation/msei-documentation-road IPCC Greenhouse Gas Protocol. 2014. Global Warming Potential Values, IPCC AR4. https://www.ghgprotocol.org/sites/default/files/ghgp/Global-Warming-Potential-Values%20%28Feb%2016%202016%29_1.pdf Table 37 Summary of Unmitigated Operational CAP and GHG Emissions Denmar US, LLC Stockton, California

CAP Emissions1 GHG Emissions Source Emissions Source (ton/year) (MT/yr) Designation ROG NOx PM10 PM2.5 CO SOx CO2e Phase 1 (2023)2 Architectural Coating 1.5 ------Consumer Products 0.63 ------Electricity Use ------1,537 Water Use ------42 Non-Permitted Waste Disposed ------605 Sources On-Road Fugitive Dust -- -- 0.10 0.014 ------On-Road Mobile 0.051 0.048 0.030 0.013 0.61 0.0019 177 Rail 1.2 36 0.58 0.54 14 0.052 5,076 Ships 4.3 55 1.5 1.4 4.0 12 2,616 Tugboats 0.37 2.4 0.095 0.095 1.8 0.0023 228 Ship Loading -- -- 3.0 0.70 ------Permitted Sources Dust Collectors -- -- 3.6 1.4 ------Total Permitted Emissions3 -- -- 6.7 2.1 ------Total Non-Permitted Emissions3 8.1 93 2.3 2.0 21 12 10,281 Full Buildout Conditions (2025)2 Architectural Coating 2.8 ------Consumer Products 1.2 ------Electricity Use ------1,916 Water Use ------41 Non-Permitted Waste Disposed ------694 Sources On-Road Fugitive Dust -- -- 0.13 0.019 ------On-Road Mobile 0.059 0.051 0.041 0.017 0.71 0.0024 220 Rail 1.5 43 0.68 0.63 21 0.076 7,402 Ships 6.3 80 2.2 2.0 5.8 18 3,814 Tugboats 0.55 3.6 0.14 0.14 2.6 0.0033 332 Ship Loading -- -- 6.1 1.4 ------Permitted Sources Dust Collectors -- -- 4.8 1.8 ------Total Permitted Emissions3 -- -- 11 3.2 ------Total Non-Permitted Emissions3 12 127 3.1 2.8 30 18 14,420 Table 37 Summary of Unmitigated Operational CAP and GHG Emissions Denmar US, LLC Stockton, California

SJVAPCD Air Quality Thresholds of Significance

ROG NOx PM10 PM2.5 CO SOx Source Designation (tons/year) Permitted Equipment and Activities 10 10 15 15 100 27 Non-Permitted Equipiment and Activities 10 10 15 15 100 27

Notes: 1. Emissions estimated using methods consistent with CalEEMod® version 2016.3.2. 2. Per the Project Description, Phase 1 Operations are expected to begin in January 2021. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026. The emissions shown in the table above assume a full year of Full Buildout Operation in 2025. 3. Emissions that exceed SJVAPCD thresholds of significance are bolded. There are no GHG emissions thresholds in the CEQA Guidelines.

Abbreviations: CalEEMod - California Emissions Estimator Model CAP - Criteria Air Pollutant CO - carbon monoxide

CO2e - carbon dioxide equivalent GHG - greenhouse gas lb - pounds NOx - nitrogen oxides PM - particulate matter ROG - reactive organic gases SJVAPCD - San Joaquin Valley Air Pollution Control District SOx - sulfur oxide

References: CalEEMod Version 2016.3.2 Available Online at: http://www.caleemod.com Table 38 Modeled Operational Emissions Denmar US, LLC Stockton, California

Operational Emissions (g/s)4,5 Phase1 Source2,3 DPM Baghouses -- Fugitive Shiploading -- Phase 1 (2023) Rail 8.33E-03 Ship 2.47E-02 Tugboat 1.85E-03 Baghouses -- Fugitive Shiploading -- Full Buildout (2025) Rail 1.22E-02 Ship 2.56E-02 Tugboat 1.93E-03

Notes: 1. Per the Project Description, Phase 1 Operations are expected to begin in January 2023. Full Buildout Operations are assumed to begin at the conclusion of Phase 2 Terminal Construction, in December 2025. Therefore, the first full year of Full Buildout Operations will be 2026. 2. Operational TAC emissions were estimated from baghouses, fugitive shiploading, rail, ship, and tugboat activity. On-road emissions were not included in the HRA because the traffic volumes do not exceed the screening levels recommended by BAAQMD (i.e., more than 5,000 vehicles per day and 500 trucks per day) and can be considered minor sources (BAAQMD 2011). 3. Operational rail emissions were broken out by year to capture future engine tier distributions. Details are shown in Table 39. 4. Annual emissions in tons per year were converted to grams per second using the following assumptions: 24 hours per day, 365 days per year. 5. For this analysis, DPM is conservatively assumed to equal PM10.

Abbreviations: BAAQMD - Bay Area Air Quality Management District CalEEMod® - California Emissions Estimator Model® CEQA - California Environmental Quality Act DPM - diesel particulate matter

PM10 - particulate matter less than 10 microns TAC - toxic air contaminant Table 38 Modeled Operational Emissions Denmar US, LLC Stockton, California References: California Emissions Estimator Model (CalEEMod). 2016. CAPCOA. Available online at: http://www.caleemod.com California Environmental Quality Act (CEQA) Guidelines. 2017. Bay Area Air Quality Management District (BAAQMD). May. Available online at: http://www.baaqmd.gov/~/media/files/planning-and- research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en Recommended Methods for Screening and Modeling Local Risks and Hazards. 2011. BAAQMD. May. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/baaqmd- modeling-approach.pdf Table 39 Modeled Operational Rail Emissions Denmar US, LLC Stockton, California

Operational Emissions (g/s) Source Group1 Year2,3 DPM 2023 9.4E-05 2024 8.4E-05 2025 7.8E-05 2026 9.6E-05 2027 8.5E-05 2028 7.5E-05 2029 6.4E-05 2030 5.5E-05 On-Site Idling 2031 4.5E-05 2032 4.4E-05 2033 4.4E-05 2034 4.3E-05 2035 4.2E-05 2036 4.1E-05 2037 4.0E-05 2038+ 4.0E-05 2023 7.6E-03 2024 6.8E-03 2025 6.3E-03 2026 7.8E-03 2027 6.9E-03 2028 6.0E-03 2029 5.2E-03 2030 4.4E-03 On-Site Running 2031 3.6E-03 2032 3.6E-03 2033 3.5E-03 2034 3.4E-03 2035 3.4E-03 2036 3.3E-03 2037 3.2E-03 2038+ 3.2E-03 Table 39 Modeled Operational Rail Emissions Denmar US, LLC Stockton, California

Operational Emissions (g/s) Source Group1 Year2,3 DPM 2023 6.7E-04 2024 6.0E-04 2025 5.6E-04 2026 6.9E-04 2027 6.1E-04 2028 5.3E-04 2029 4.6E-04 2030 3.9E-04 Off-SiteOn-Site Running Idling 2031 3.2E-04 2032 3.2E-04 2033 3.1E-04 2034 3.0E-04 2035 3.0E-04 2036 2.9E-04 2037 2.9E-04 2038+ 2.8E-04

Notes: 1. Yearly operational emissions are calculated using the emission factors presented in Table 33, and the same calculation methodology as shown in Table 34.

2. The year 2025 includes Phase 1 and Full Buildout operational emissions, which have been scaled to account for the fraction of the year each phase is operational.

3. As shown in Table 33, tier distributions are expected to be 100% Tier 4 by 2038. Therefore, emission factors do not change after the year 2038.

References CARB. 2017 Line Haul / Class I Documentation. Last accessed on 12/2/2019 at: https://www.ar b.ca.gov/msei/ordiesel.htm. Table 40 Construction Source Parameters Denmar US, LLC Stockton, CA

Initial Vertical Number of Release Height2 Source Source Type Dimension3 Sources1 (m) (m) Construction Equipment Area 13 5 1.16 On-Road Trucks Volume 503 2.6 2.4 Vendor Ships Volume 42 15.2 7.1

Notes: 1. The number of modeled construction equipment sources was based on the number of distinct construction work areas. The number of on-road vehicle sources was based on the geometry of the truck or traffic routes. 2. SJVAPCD does not have guidance on construction modeling, therefore construction equipment parameters used were based on BAAQMD's San Francisco Community Risk Reduction Plan-Health Risk Assessment (CRRP-HRA). According to the CRRP-HRA methodology, release height of a modeled area source representing construction equipment is set to 5 meters. On-road truck release height was based on USEPA haul road guidance, assuming vehicle heights of 3 meters for heavy-duty vehicles and 2 meters for light-duty vehicles. 3. According to USEPA's AERMOD guidance, initial vertical dimension of the modeled construction equipment area sources is the release height divided by 4.3. According to the USEPA Haul Road Guidance, the initial vertical dimension for line sources is the top of plume height divided by 2.15, where the top of the plume is equal to 2*Release Height.

4. Vendor ships were modeled based on tug boats source parameters according to the China Shipping Final Environmental Impact Report (FSEIR). 5 Construction activities are assumed to occur during 6AM to 9PM hours.

Abbreviations: AERMOD - Atmospheric Dispersion MODeling BAAQMD - Bay Area Air Quality Management District m - meter SJVAPCD - San Joaquin Valley Air Pollution Control District USEPA - United States Environmental Protection Agency

References: San Francisco Department of Public Health. February 2020. San Francisco Citywide Health Risk Assessment: Technical Support Documentation. Available online at: https://www.sfdph.org/dph/files/EHSdocs/AirQuality/Air_Pollutant_Exposure_Zone_Technical_Document ation_2020.pdf

BAAQMD. 2017. California Environmental Quality Act: Air Quality Guidelines. May. Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017- pdf.pdf?la=en. Accessed November 2018. Port of Los Angeles. 2019. Berths 97-109 [China Shipping] Container Terminal Project: Final Supplemental Environmental Impact Report. Appendix B2 Air Dispersion Modeling. September. Available online at: https://kentico.portoflosangeles.org/getmedia/477b7424-414b-4a7b-b796- ed8f91decab5/CS_Appendix_B2_Air_Dispersion_Modeling_FSEIR United States Environmental Protection Agency (USEPA). 2012. Haul Road Workgroup Final Report Submission to EPA-OAQPS. U.S. EPA Office of Air Quality and Planning Standards, Research Triangle Park, North Carolina. Available at: https://www3.epa.gov/scram001/reports/Haul_Road_Workgroup- Final_Report_Package-20120302.pdf

USEPA. 2012. Haul Road Workgroup Final Report Submission to EPA-OAQPS. U.S. EPA Office of Air Quality and Planning Standards, Research Triangle Park, North Carolina. Available at: https://www3.epa.gov/scram001/reports/Haul_Road_Workgroup-Final_Report_Package-20120302.pdf

USEPA. 2019. User's Guide for the AMS/EPA Regulatory Model (AERMOD). U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. Available at: https://www3.epa.gov/ttn/scram/models/aermod/aermod_userguide.pdf Table 41 Operational Source Parameters Denmar US, LLC Stockton, CA

Initial Vertical Number of Release Height Exit Temperature Exit Velocity Exit Diameter Source1,2,3 Source Type 3 Sources Dimension (m) (K) (m/s) (m) (m) Dust Collectors4 Point 34 0.3-28.4 298 0.03-25.9 0.4-1.3 -- Shiploading Fugitive Area 2 9.1 ------16 Ship Hoteling Point 2 39.9 559 18.2 0.5 -- Ship Maneuvering Volume 66 59.1 ------27.5 Ship Transit Volume 20 49.1 ------22.8 Tugboat Volume 143 15.2 ------7.1 Rail Running Onsite - Day1,2 Volume 191 5.5 ------2.6 Rail Running Onsite - Night1,2 Volume 191 13.9 ------6.5 Rail Running Offsite - Day1,2 Volume 70 5.5 ------2.6 Rail Running Offsite - Night1,2 Volume 70 13.9 ------6.5 Rail Idling1 Point 1 4.9 364 3.1 0.6 --

Notes: 1. Rail source parameters were derived from the Roseville Rail Yard Study (CARB, 2004). The plume heights vary by day and night due to differences in atmospheric stability conditions. 2. Rail Running – Day are modeled from 6am – 6pm, which corresponds to AERMOD hours 7 - 18. Rail Running – Night are modeled from 6pm – 6am, which corresponds to AERMOD hours 1 - 6 and 19 - 24. 3. Ships and tugboat source parameters are consistent with China Shipping Final Environmental Impact Report (FSEIR). 4. A total of 34 dust collectors were modeled on-site, each with a different release height provided by the Project sponsor. The range of release heights is provided in this table.

Abbreviations: AERMOD - Atmospheric Dispersion MODeling K - Kelvin m - meter s - second USEPA - United States Environmental Protection Agency

References: CARB. 2004. Roseville Rail Yard Study. Available online at: https://ww2.arb.ca.gov/sites/default/files/classic/diesel/documents/rrstudy/rrstudy101404.pdf Port of Los Angeles. 2019. Berths 97-109 [China Shipping] Container Terminal Project: Final Supplemental Environmental Impact Report. Appendix B2 Air Dispersion Modeling. September. Available online at: https://kentico.portoflosangeles.org/getmedia/477b7424-414b-4a7b-b796-ed8f91decab5/CS_Appendix_B2_Air_Dispersion_Modeling_FSEIR

USEPA. 2019. User's Guide for the AMS/EPA Regulatory Model (AERMOD). U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. Available at: https://www3.epa.gov/ttn/scram/models/aermod/aermod_userguide.pdf Table 42 AERMOD Parameters Denmar US, LLC Stockton, CA

Parameter Assumptions Model Control Options Use Regulatory Default Yes Urban or Rural Option Rural Flagpole Receptor Height 0 m for all receptors Source Options Include Building Downwash Yes Receptor Information Classifications Residential, Worker, Recreational Spacing 20 x 20 m grid Meteorological Information Meteorological Station1 Stockton Station Base Elevation 10 Meteorological Data Years 2013-2017 Output Averaging Times Annual

Notes: 1. Five complete years of pre-processed meteorological data for Stockton was obtained from the San Joaquin Valley Air Pollution Control District.

References: San Joaquin Valley Air Pollution Control District. September 2020. Meteorological data for Stockton. Available online at: http://www.valleyair.org/busind/pto/Tox_Resources/Modeling-Sites/stockton.htm Table 43 Exposure Parameters Denmar US, LLC Stockton, CA

ASF-Weighted Daily Breathing Exposure Fraction of Exposure Age Averaging Cumulative Intake Receptor Intake Factor, Phase Year Age Group Rate Duration Time at Home Frequency Sensitivity Time Factor, Inhalation Type Inhalation Factor [L/kg-day] [years] [unitless] [days/year] [days] [m3/kg-day] [m3/kg-day] 2025 3rd trimester 361 0.083 1.0 350 10 25,550 0.0041 0.0041 3rd trimester 361 0.17 1.0 350 10 25,550 0.0082 2026 0.13 0-<2 1,090 0.83 1.0 350 10 25,550 0.12 2027 0-<2 1,090 1.0 1.0 350 10 25,550 0.15 0.15 0-<2 1,090 0.17 1.0 350 10 25,550 0.025 2028 0.044 2-<16 572 0.83 1.0 350 3.0 25,550 0.020 2029 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2030 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 Full Buildout Residential 2031 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 Operations 2032 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2033 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2034 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2035 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2036 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2037 2-<16 572 1.0 1.0 350 3.0 25,550 0.024 0.024 2-<16 572 4.2 1.0 350 3.0 25,550 0.10 2038+ 0.13 16-30 261 14 0.73 350 1.0 25,550 0.037 2025 16-70 230 0.083 -- 250 1.0 25,550 1.9E-04 1.9E-04 2026 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2027 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2028 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2029 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2030 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 Full Buildout 2031 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 Worker Operations 2032 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2033 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2034 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2035 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2036 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2037 16-70 230 1.0 -- 250 1.0 25,550 0.0023 0.0023 2038+ 16-70 230 13 -- 250 1.0 25,550 0.029 0.029 2025 0-<2 900 0.083 -- 52 10 25,550 0.0015 0.0015 2026 0-<2 900 1.0 -- 52 10 25,550 0.018 0.018 0-<2 900 0.92 -- 52 10 25,550 0.017 2027 0.017 2-<16 390 0.083 -- 52 3.0 25,550 2.0E-04 2028 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2029 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2030 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 Full Buildout 2031 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 Recreational Operations 2032 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2033 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2034 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2035 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2036 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2037 2-<16 390 1.0 -- 52 3.0 25,550 0.0024 0.0024 2-<16 390 3.9 -- 52 3.0 25,550 0.009 2038+ 0.014 16-30 180 14 -- 52 1.0 25,550 0.0051

Notes: 1. Daily breathing rates for residents reflect default breathing rates from Cal/EPA 2015 as follows: 95th percentile 24-hour daily breathing rate for age 3rd trimester and 0-<2 years 80th percentile 24-hour daily breathing rate for age 2-<16 years 80th percentile 24-hour daily breathing rate for age 16-30 years 2. Daily breathing rates for workers are based on the OEHHA Risk Assessment Guidelines 2015 as follows: 95th percentile moderate intensity 8-hour daily breathing rate for age 16-70 3. Daily breathing rates for recreational receptors assume 95th Percentile Eight-Hour Breathing Rates for Moderate Intensity Activities, scaled to 6 hours per day. 4. Exposure duration represents the fraction of the year each age bin is exposed to Project emissions. 5. Fraction of time spent at home is conservatively assumed to be 1 (i.e., 24 hours/day) for all age bins except Age 16-30 Years. Fraction of time spent at home is assumed to be 0.73 for Ages 16-30 Years. 6. Exposure frequency was determined as follows: Residents: reflects default residential exposure frequency from Cal/EPA 2015. Workers: reflects default worker exposure frequency from Cal/EPA 2015. Recreational: reflects 52 days per year, assuming recreational receptors play a round of golf or go to the park once a week. 7. Age sensitivity factors account for an “anticipated special sensitivity to carcinogens” of infants and children as recommended in the OEHHA Technical Support Document (Cal/EPA 2009) and current OEHHA guidance (Cal/EPA 2015).

Abbreviations: ASF - age sensitivity factor L - liter Cal/EPA - California Environmental Protection Agency m3 - cubic meters kg - kilogram OEHHA - Office of Environmental Health Hazard Assessment

Reference: Cal/EPA. 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February. Table 44 Toxicity Values Denmar US, LLC Stockton, CA

Chronic Noncancer Cancer Potency Reference Exposure Source Chemical1 CAS Number Factor Level (mg/kg-day)-1 (μg/m3)

PM10 Diesel PM 9-90-1 1.1 5.0

Notes: 1. Toxicity values are taken from ARB's Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values.

Abbreviations: ARB - Air Resources Board Cal/EPA - California Environmental Protection Agency CAS - chemical abstract services mg/kg-day - milligrams per kilogram per day OEHHA - Office of Environmental Health Hazard Assessment µg/m3 - micrograms per cubic meter

Reference: Cal/EPA. 2016. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values. March. Available at: http://www.arb.ca.gov/toxics/healthval/contable.pdf. Table 45 Maximum Project Excess Lifetime Cancer Risk and Chronic HI Denmar US, LLC Stockton, CA

Excess Lifetime Cancer Chronic HI3 Source Category Risk1,2 in a million unitless ratio Construction Sources Off-Road Construction Equipment -- -- Haul Trucks -- -- Marine Tugs -- -- Operational Sources Ships 11 0.00025 Tugboats 5.3 0.00036 Rail 3.2 0.014 Baghouses -- -- Shiploading Fugitive -- -- Total 19 0.014 Significance Threshold4 20 1 Exceeds Threshold? No No Location Year Occurred -- 2025 UTMx 644,830 642,530 UTMy 4,202,470 4,202,350 Receptor Type5 Classification Residential Worker

Notes: 1. Excess lifetime cancer risks were estimated using the following equation:

Riskinh = ΣCi x CF x IFinh x CPFi x ASF Where:

Riskinh = Cancer Risk for the Inahalation Pathway (unitless) 3 Ci = Annual Average Air Concentration for Chemical "i" ug/m CF = Conversion Factor (mg/ug) 3 IFinh = Intake Factor for Inhalantion (m /kg-day) -1 CPFi = Cancer Potency Factor (mg/kg-day) ASF = Age Sensitivity Factor (unitless) 2. Excess lifetime cancer risk was evaluated for three unique exposure scenarios, with the intent of identifying the most conservative scenario. Scenario 1 started exposure at the start of Phase 1 construction, Scenario 2 started exposure at the start of Phase 1 operations, and Scenario 3 started exposure at the start of Full Buildout operations. Scenarios 1 and 2 included overlapping construction and operational emissions, whereas Scenario 3 included operational emissions only. Ultimately, Scenario 3 yielded the highest risk results of the three exposure scenarios, which are shown in the table above. The other two scenarios resulted in lower risks, which are not presented for that reason.

3. Chronic HI for each receptor was estimated using the following equation:

HIinh = ΣCi / cREL Where:

HIinh = Chronic HI for the Inhalation Pathway (unitless) 3 Ci = Annual Average Air Concentration for Chemical "i" (ug/m ) cREL = Chronic Reference Exposure Level (ug/m3) Table 45 Maximum Project Excess Lifetime Cancer Risk and Chronic HI Denmar US, LLC Stockton, CA Notes, continued: 4. Thresholds of significance are based on information from San Joaquin Valley Air Pollution Control District, Air Quality Thresholds of Significance - Toxic Air Contaminants.

5. This table shows the maximum exposed individual receptor, but three different receptor types were analyzed for this analysis: residential, worker, and recreational.

6. Potential MEIR locations were screened to remove any receptors located over roadways or open space. Further, only the subset of off-site receptors located on residential buildings or homes were considered residential receptors.

References: San Joaquin Valley Air Pollution Control District, Air Quality Thresholds of Significance - Toxic Air Contaminants. Available at: http://www.valleyair.org/transportation/0714-GAMAQI-TACs-Thresholds- of-Significance.pdf.

Appendix C Noise Study

DENMAR PROJECT PORT OF STOCKTON WEST COMPLEX

NOISE AND VIBRATION ASSESSMENT

Stockton, California

April 21, 2021

Prepared for:

Lena DeSantis ANCHOR QEA, LLC 123 Tice Blvd #205 Woodcliff Lake, NJ 07677

Prepared by:

Fred M. Svinth, INCE, Assoc. AIA

429 East Cotati Avenue Cotati, CA 94931 (707) 794-0400

Project: 20-123

INTRODUCTION Denmar is proposing to construct and operate a bulk terminal to receive and export natural soda ash. The marine terminal would be located on Berths 18 and 19 in the West Complex of the Port of Stockton, with a new rail depot proposed for the undeveloped areas of the West Complex. The proposed Denmar terminal would include shiploaders at Berths 18 and 19; parking and quarters for crew and support buildings for administration/maintenance; transfer conveyors, towers, and storage facilities on parcels 708, 805, and 806; and a rail loop and railcar unloading building in the westernmost portion of the West Complex. The Denmar terminal would be designed to receive bulk deliveries of soda ash by rail. Soda ash would be offloaded for export either directly onto ocean-going bulk cargo vessels or into the storage buildings where it would be temporarily held prior to transfer onto ocean-going marine vessels. The Denmar terminal would be constructed in two phases, with the first phase including the construction of a single storage building and use of only Berth 18 and the second a second adjacent storage building and the use of Berth 19. This report evaluates the project’s noise and land use compatibility with respect to the significance findings and mitigation measures contained in the 2004 Port of Stockton West Complex EIR, as well as local regulatory requirements established by the City of Stockton. Vibration and land use compatibility were also addressed for the rail usage proposed by the project. The report is divided into three sections: 1) the Setting Section provides a brief description of the fundamentals of environmental noise, summarizes applicable regulatory criteria, and discusses the results of the ambient noise monitoring survey completed to document existing noise conditions; 2) the Noise Assessment Section evaluates noise effects resulting from the project with respect to the West Complex EIR and City of Stockton guidelines; and 3) the Vibration and Land Use Compatibility Section evaluates the vibration levels generated by the rail usage, project construction and project operation with respect to the West Complex EIR, Perceptibility, and Federal Transportation Agency guidelines.

SETTING FUNDAMENTALS OF ENVIRONMENTAL NOISE Noise may be defined as unwanted sound. Noise is usually objectionable because it is disturbing or annoying. The objectionable nature of sound could be caused by its pitch or its loudness. Pitch is the height or depth of a tone or sound, depending on the relative rapidity (frequency) of the vibrations by which it is produced. Higher pitched signals sound louder to humans than sounds with a lower pitch. Loudness is intensity of sound waves combined with the reception characteristics of the ear. Intensity may be compared with the height of an ocean wave in that it is a measure of the amplitude of the sound wave. In addition to the concepts of pitch and loudness, there are several noise measurement scales which are used to describe noise in a particular location. A decibel (dB) is a unit of measurement which indicates the relative amplitude of a sound. The zero on the decibel scale is based on the lowest sound level that the healthy, unimpaired human ear can detect. Sound levels in decibels are calculated on a logarithmic basis. An increase of 10 decibels represents a ten-fold increase in acoustic energy, while 20 decibels is 100 times more intense, 30 decibels is 1,000 times more intense, etc. There is a relationship between the subjective noisiness or loudness of a sound and its intensity. Each 10 decibel increase in sound level is perceived as approximately a doubling of loudness over a fairly wide range of intensities. Technical terms are defined in Table 1.

1

TABLE 1 Definition of Acoustical Terms Used in this Report

Term Definition Decibel, dB A unit describing, the amplitude of sound, equal to 20 times the logarithm to the base 10 of the ratio of the pressure of the sound measured to the reference pressure. The reference pressure for air is 20 micro Pascals. Sound Pressure Level Sound pressure is the sound force per unit area, usually expressed in micro Pascals (or 20 micro Newtons per square meter), where 1 Pascal is the pressure resulting from a force of 1 Newton exerted over an area of 1 square meter. The sound pressure level is expressed in decibels as 20 times the logarithm to the base 10 of the ratio between the pressures exerted by the sound to a reference sound pressure (e. g., 20 micro Pascals). Sound pressure level is the quantity that is directly measured by a sound level meter. Frequency, Hz The number of complete pressure fluctuations per second above and below atmospheric pressure. Normal human hearing is between 20 Hz and 20,000 Hz. Infrasonic sound are below 20 Hz and Ultrasonic sounds are above 20,000 Hz. A-Weighted Sound The sound pressure level in decibels as measured on a sound level meter using the A-weighting filter network. The A-weighting filter de- Level, dBA emphasizes the very low and very high frequency components of the sound in a manner similar to the frequency response of the human ear and correlates well with subjective reactions to noise. Equivalent Noise Level, The average A-weighted noise level during the measurement period. Leq The maximum and minimum A-weighted noise level during the Lmax, Lmin measurement period. The A-weighted noise levels that are exceeded 1%, 10%, 50%, and 90% L01, L10, L50, L90 of the time during the measurement period. The L10 is typically considered the intrusive noise level, the L50 represents the median noise level, and the L90 represents, and is considered, the background, or ambient noise level. Day/Night Noise Level, The average A-weighted noise level during a 24-hour day, obtained after addition of 10 decibels to levels measured in the night between 10:00 pm Ldn or DNL and 7:00 am.

Community Noise The average A-weighted noise level during a 24-hour day, obtained after addition of 5 decibels in the evening from 7:00 pm to 10:00 pm and after Equivalent Level, addition of 10 decibels to sound levels measured in the night between 10:00 CNEL pm and 7:00 am. Ambient Noise Level The composite of noise from all sources near and far. The normal or existing level of environmental noise at a given location.

Intrusive That noise which intrudes over and above the existing ambient noise at a given location. The relative intrusiveness of a sound depends upon its amplitude, duration, frequency, and time of occurrence and tonal or informational content as well as the prevailing ambient noise level.

2

Human hearing is limited in the range of audible frequencies as well as in the way it perceives the sound pressure level in that range. In general, people are most sensitive to the frequency range of 1,000 to 8,000 Hz and perceive sounds within that range better than sounds of the same amplitude in higher or lower frequencies. To approximate the response of the human ear, sound levels of individual frequency bands are weighted, depending on human sensitivity to those frequencies. The A-weighted sound level (expressed in units of dBA) can be computed based on this information. The A-weighting scale approximates the frequency response of the average young ear when listening to most ordinary sounds. When people make judgments regarding the relative loudness or annoyance of a sound, their judgments correlate well with the A-scale sound levels of those sounds. Table 2 describes typical A-weighted sound levels for various noise sources. Because sound levels can vary markedly over a short period of time, a method for describing either the average character of the sound or the statistical behavior of the variations must be utilized. Most commonly, environmental sounds are described in terms of an average level that has the same acoustical energy as the summation of all the time-varying events. This energy- equivalent sound/noise descriptor is called Leq. The most common averaging period is hourly, but Leq can describe any series of noise events of arbitrary duration. The scientific instrument used to measure noise is the sound level meter. Sound level meters can accurately measure environmental noise levels to within about plus or minus 1 dBA. Various computer models are used to predict environmental noise levels from sources, such as roadways and airports. The accuracy of the predicted models depends upon the distance the receptor is from the noise source. Close to the noise source, the models are accurate to within about plus or minus 1 to 2 dBA. Decibel Addition Because decibels are logarithmic units, sound pressure levels cannot be added or subtracted through ordinary arithmetic. On the dB scale, a doubling of sound energy corresponds to a 3 dB increase. In other words, when two identical sources are each producing sound of the same loudness, their combined sound level at a given distance would be 3 dB higher than one source under the same conditions. For example, if one excavator produces a sound pressure level of 80 dBA, two excavators would not produce 160 dBA. Rather, they would combine to produce 83 dBA. The cumulative sound level of any number of sources, such as excavators, can be determined using decibel addition. Environmental Noise Descriptors Since the sensitivity to noise increases during the evening and at night -- because excessive noise interferes with the ability to sleep -- 24-hour descriptors have been developed that incorporate artificial noise penalties added to quiet-time noise events. The Community Noise Equivalent Level (CNEL) is a measure of the cumulative noise exposure in a community, with a 5 dB penalty added to evening (7:00 pm - 10:00 pm) and a 10 dB addition to nocturnal (10:00 pm - 7:00 am) noise levels. The Day/Night Average Sound Level (Ldn or DNL) is essentially the same as CNEL, with the exception that the evening time period is dropped and all occurrences during this three-hour period are grouped into the daytime period.

3

TABLE 2 Typical Noise Levels in the Environment

Common Outdoor Activities Noise Level (dBA) Common Indoor Activities 110 dBA Rock band

Jet fly-over at 1,000 feet

100 dBA

Gas lawn mower at 3 feet 90 dBA Diesel truck at 50 feet at 50 mph Food blender at 3 feet

80 dBA Garbage disposal at 3 feet

Noisy urban area, daytime Gas lawn mower, 100 feet 70 dBA Vacuum cleaner at 10 feet Commercial area Normal speech at 3 feet Heavy traffic at 300 feet 60 dBA Large business office Quiet urban daytime 50 dBA Dishwasher in next room

Quiet urban nighttime 40 dBA Theater, large conference room Quiet suburban nighttime 30 dBA Library Bedroom at night, concert hall Quiet rural nighttime (background) 20 dBA Broadcast/recording studio 10 dBA

0 dBA

Source: Technical Noise Supplement (TeNS), California Department of Transportation, September 2013.

Effects of Noise Studies have shown that under controlled conditions in an acoustics laboratory, a healthy human ear is able to discern changes in sound levels of one dBA. In a quiet environment with average background noise, the healthy human ear can detect changes of about two dB(A). However, it is widely accepted that changes of three dB(A) in the normal environment are considered just noticeable to most people, and that an increase of 3 dB(A) is perceived as approximately a 25 percent increase in noise level. A change of five dB(A) is readily perceptible, and a change of 10

4

dB(A) is perceived as being twice as loud. Accordingly, a doubling of sound energy (e.g., doubling the volume of traffic on a highway) which would result in a three dB increase in sound would generally be barely detectable. Sleep and Speech Interference The thresholds for speech interference indoors are about 45 dBA if the noise is steady and above 55 dBA if the noise is fluctuating. Outdoors the thresholds are about 15 dBA higher. Steady noises of sufficient intensity (above 35 dBA) and fluctuating noise levels above about 45 dBA have been shown to affect sleep. Interior residential standards for multi-family dwellings are set by the State of California at 45 dBA DNL. Typically, the highest steady traffic noise level during the daytime is about equal to the DNL and nighttime levels are 10 dBA lower. The standard is designed for sleep and speech protection and most jurisdictions apply the same criterion for all residential uses. Typical structural attenuation is 12-17 dBA with open windows. With closed windows in good condition, the noise attenuation factor is around 20 dBA for an older structure and 25 dBA for a newer dwelling. Sleep and speech interference is therefore possible when exterior noise levels are about 57-62 dBA DNL with open windows and 65-70 dBA DNL if the windows are closed. Levels of 55-60 dBA are common along collector streets and secondary arterials, while 65-70 dBA is a typical value for a primary/major arterial. Levels of 75-80 dBA are normal noise levels at the first row of development outside a freeway right-of-way. Annoyance Attitude surveys are used for measuring the annoyance felt in a community for noises intruding into homes or affecting outdoor activity areas. In these surveys, it was determined that the causes for annoyance include interference with speech, radio and television, house vibrations, and interference with sleep and rest. The DNL as a measure of noise has been found to provide a valid correlation of noise level and the percentage of people annoyed. People have been asked to judge the annoyance caused by aircraft noise and ground transportation noise. There continues to be disagreement about the relative annoyance of these different sources. When measuring the percentage of the population highly annoyed, the threshold for ground vehicle noise is about 50 dBA DNL. At a DNL of about 60 dBA, approximately 12 percent of the population is highly annoyed. When the DNL increases to 70 dBA, the percentage of the population highly annoyed increases to about 25-30 percent of the population. There is, therefore, an increase of about 2 percent per dBA between a DNL of 60-70 dBA. Between a DNL of 70-80 dBA, each decibel increase results in an increase of 3 percent of the population being highly annoyed. Sound Propagation When sound propagates over a distance, it changes in both level and frequency content. The manner in which noise is reduced with distance depends on the following important factors: Geometric spreading from point sources. Sound from a single source (i.e., a “point” source) radiates uniformly outward as it travels away from the source in a spherical pattern. The sound level attenuates (or drops off) at a rate of six dB(A) for each doubling of distance (intensity drops to one-quarter of the previous level with each doubling of distance). Geometric spreading from line sources. Some sound generators are not point sources. Highway noise, for example, is not a single stationary point source of sound. The movement of vehicles on a highway makes the source of the sound appear to emanate from a line (i.e., a “line” source) rather than from a point. This results in cylindrical spreading rather than the spherical spreading resulting from a point source.

5

The change in sound level from a line source is 3 dB(A) per doubling of distance (intensity drops to one-half of the previous level with each doubling of distance). Ground absorption. Usually the noise path between the source and the observer is very close to the ground. The excess noise attenuation from ground absorption occurs due to acoustic energy losses on sound wave reflection. Traditionally, the excess attenuation has also been expressed in terms of attenuation per doubling of distance. This approximation is done for simplification only; for distances of less than 200 feet, prediction results based on this scheme are sufficiently accurate. For acoustically “hard” sites (i.e., sites with a reflective surface, such as a parking lot or a smooth body of water, between the source and the receptor), no excess ground attenuation is assumed because the sound wave is reflected without energy losses. For acoustically absorptive or “soft” sites (i.e., sites with an absorptive ground surface, such as soft dirt, grass, or scattered bushes and trees), an excess ground attenuation value of 1.5 dBA per doubling of distance is normally assumed. When added to the geometric spreading, the excess ground attenuation results in an overall drop-off rate of 4.5 dBA per doubling of distance for a line source and 7.5 dBA per doubling of distance for a point source. Although some ground attenuation is expected, it is often ignored in a noise analysis, to ensure a conservative analysis and considering that, in any event, it is very difficult to characterize accurately. Atmospheric effects. Research by Caltrans and others has shown that atmospheric conditions can have a major effect on noise levels. Wind has been shown to be the single most important meteorological factor within approximately 500 feet, whereas vertical air temperature gradients are more important over longer distances. Other factors, such as air temperature, humidity, and turbulence, also have major effects. Receptors located downwind from a source can be exposed to increased noise levels relative to calm conditions, whereas locations upwind can have lower noise levels. Increased sound levels can also occur because of temperature inversion conditions (i.e., increasing temperature with elevation) which cause reflection of sound from the inversion layer back to the ground. As with ground absorption, atmospheric effects are often ignored, as here, in the interest of a conservative analysis. Shielding by natural or human-made features. A large object or barrier in the path between a noise source and a receptor can substantially attenuate noise levels at the receptor. The amount of attenuation provided by this shielding depends on the size of the object, proximity to the noise source and receptor, surface weight, solidity, and the frequency content of the noise source. Natural terrain features (such as hills and dense ) and human-made features (such as buildings and walls) can substantially reduce noise levels. Walls are often constructed between a source and a receptor with the specific purpose of reducing noise. A barrier that breaks the line of sight between a source and a receptor will typically result in at least 5 dB of noise reduction. A higher barrier may provide as much as 20 dB of noise reduction. Lightly built barriers provide less attenuation.

FUNDAMENTALS OF GROUNDBORNE VIBRATION Ground vibration consists of rapidly fluctuating motions or waves with an average motion of zero. Several different methods are typically used to quantify vibration amplitude. One method is the Peak Particle Velocity (PPV). The PPV is defined as the maximum instantaneous positive or negative peak of the vibration wave. In this report, a PPV descriptor with units of mm/sec or in/sec is used to evaluate construction generated vibration for building damage and human

6

complaints. Table 3 displays the reactions of people and the effects on buildings that continuous or frequent intermittent vibration levels produce. The guidelines in Table 3 represent syntheses of vibration criteria for human response and potential damage to buildings resulting from construction vibration. Construction activities can cause vibration that varies in intensity depending on several factors. The use of pile driving and vibratory compaction equipment typically generates the highest construction related groundborne vibration levels. Because of the impulsive nature of such activities, the use of the PPV descriptor has been routinely used to measure and assess groundborne vibration and almost exclusively to assess the potential of vibration to cause damage and the degree of annoyance for humans. The two primary concerns with construction-induced vibration, the potential to damage a structure and the potential to interfere with the enjoyment of life, are evaluated against different vibration limits. Human perception to vibration varies with the individual and is a function of physical setting and the type of vibration. Persons exposed to elevated ambient vibration levels, such as people in an urban environment, may tolerate a higher vibration level. TABLE 3 Reaction of People and Damage to Buildings from Continuous or Frequent Intermittent Vibration Levels Velocity Level, PPV (in/sec) Human Reaction Effect on Buildings 0.01 Barely perceptible No effect Vibration unlikely to cause damage of any type to any 0.04 Distinctly perceptible structure Distinctly perceptible to Recommended upper level of the vibration to which 0.08 strongly perceptible ruins and ancient monuments should be subjected Threshold at which there is a risk of damage to fragile 0.1 Strongly perceptible buildings with no risk of damage to most buildings Threshold at which there is a risk of damage to historic 0.25 Strongly perceptible to severe and some old buildings. Threshold at which there is a risk of damage to older 0.3 Strongly perceptible to severe residential structures Severe - Vibrations considered Threshold at which there is a risk of damage to new 0.5 unpleasant residential and modern commercial/industrial structures Source: Transportation and Construction Vibration Guidance Manual, California Department of Transportation, September 2013. Structural damage can be classified as cosmetic only, such as paint flaking or minimal extension of cracks in building surfaces; minor, including limited surface cracking; or major, which may threaten the structural integrity of the building. Safe vibration limits that can be applied to assess the potential for damaging a structure vary by researcher. The damage criteria presented in Table 3 include several categories for ancient, fragile, and historic structures, the types of structures most at risk to damage. Most buildings are included within the categories ranging from “Historic and some old buildings” to “Modern industrial/commercial buildings”. Construction-induced vibration that can be detrimental to the building is very rare and has only been observed in instances where the structure is at a high state of disrepair and the construction activity occurs immediately adjacent to the structure. The annoyance levels shown in Table 3 should be interpreted with care since vibration may be found to be annoying at lower levels than those shown, depending on the level of activity or the sensitivity of the individual. To sensitive individuals, vibrations approaching the threshold of

7

perception can be annoying. Low-level vibrations frequently cause irritating secondary vibration, such as a slight rattling of windows, doors, or stacked dishes. The rattling sound can give rise to exaggerated vibration complaints, even though there is very little risk of actual structural damage. Railroad operations are potential sources of substantial ground vibration depending on distance, the type and the speed of trains, and the type of railroad track. People’s response to ground vibration has been correlated best with the velocity of the ground. The velocity of the ground is expressed on the decibel scale. The reference velocity is 1 x 10-6 in./sec. RMS, which equals 0 VdB, and 1 in./sec. equals 120 VdB. Although not a universally accepted notation, the abbreviation “VdB” is used in this document for vibration decibels to reduce the potential for confusion with sound decibels. Typical background vibration levels in residential areas are usually 50 VdB or lower, well below the threshold of perception for most humans. Table 4 illustrates some common sources of vibration, their VdB levels and their association to human perception or the potential for structural damage. TABLE 4 Typical Levels of Groundborne Vibration Human/Structural Typical Events Response Velocity Level, VdB (50-foot setback) Blasting, pile driving, vibratory Threshold, minor cosmetic damage 100 compaction equipment Heavy tracked vehicles (Bulldozers,

cranes, drill rigs) Difficulty with tasks such as reading a video or computer screen 90 Commuter rail, upper range Residential annoyance, infrequent Rapid transit, upper range events 80 Residential annoyance, occasional Commuter rail, typical Bus or truck events over bump or on rough roads Residential annoyance, frequent Rapid transit, typical events 70 Approximate human threshold of Buses, trucks and heavy street perception to vibration traffic 60 Background vibration in residential

settings in the absence of activity Lower limit for equipment ultra-

sensitive to vibration 50 Source: Transit Noise and Vibration Impact Assessment, US Department of Transportation Federal Transit Administration, May 2006.

8

REGULATORY BACKGROUND West Complex EIR. The project will occur within the West Complex of the Port of Stockton. The 2004 West Complex EIR established noise criteria based on changes in ambient noise levels and construction noise associated with implementation of the West Complex Development Plan. Significant ambient noise level increases were defined as 3 dBA for land uses that already exceed the “normally acceptable” ranges, 5 dBA for land uses that are within “normally acceptable” ranges but would exceed these ranges with additional project noise, and 10 dBA for land uses that would remain within the “normally acceptable” range of noise. Construction noise was considered significant if it would exceed 65 Lmax at the property line of nearest residence between 9 pm and 6 am. The West Complex EIR recognized the presence of sensitive receptors and used the following upper limits of the “Normally Acceptable” range for daytime (7 am to 7 pm) in determining the significance of noise impacts: Residential: 60 dBA Ldn/CNEL (45 dBA Ldn/CNEL interior) Neighborhood Parks: 70 dBA Ldn/CNEL Golf Courses: 75 dBA Ldn/CNEL City of Stockton General Plan The Safety Chapter in the Envision Stockton 2040 General Plan sets forth actions with the goal to Protect the community from health hazards and annoyance associated with excessive noise levels. The following actions are applicable to the proposed project: Action SAF-2.5A Prohibit new commercial, industrial, or other noise generating land uses adjacent to existing sensitive noise receptors such as residential uses, schools, health care facilities, libraries, and churches if noise levels are expected to exceed 70 dBA Community Noise Equivalent (CNEL) (decibels on A-weighted scale CNEL) when measured at the property line of the noise sensitive land use. Action SAF-2.5C Require noise produced by commercial uses to not exceed 75 dB Ldn/CNEL at the nearest property line. Action SAF-2.5D Grant exceptions to the noise standards for commercial and industrial uses only if a recorded noise easement is conveyed by the affected property owners. City of Stockton Noise Ordinance The Section 16.60.040.B.2 of the City of Stockton Noise Ordinance requires that new or expanded Commercial, Industrial, and Other Land Use-Related noise sources comply with performance standards contained in Table 3-7, Part II when they are adjacent to any noise- sensitive land uses. Table 3-7, Part II is summarized as follows: Outdoor Activity Areas Noise Descriptor Day (7am to 10pm) Night (10pm to 7am) Hourly equivalent sound level (Leq), dB 55 45 Maximum sound level (Lmax), dB 75 65 Notes: (1) The noise standard shall be applied at the property line of the receiving land use. When determining the effectiveness of noise mitigation measures, the standards shall be applied on the receiving side of noise barriers or other property line noise mitigation measures (2) Each of the noise level standards specified shall be decreased by five (5) for impulse noise, simple tone noise, or noise consisting primarily of speech or music.

9

Regulatory Background – Vibration While the State of California and the City of Stockton do not have specific vibration regulations, the U.S. Department of Transportation (DOT) Federal Transit Administration (FTA) has established vibration impact assessment criteria1 for use in evaluating vibration impacts associated with developments in close proximity to rail lines. The FTA vibration impact criteria are based on maximum overall levels for a single event. The impact criteria for groundborne vibration are shown in Table 5. Note that there are criteria for frequent events (more than 70 events of the same source per day), occasional events (30 to 70 vibration events of the same source per day), and infrequent events (less than 30 vibration events of the same source per day).

TABLE 5 Groundborne Vibration Impact Criteria Groundborne Vibration Impact Levels (VdB re 1 µinch/sec, RMS) Land Use Category Frequent Events1 Occasional Events2 Infrequent Events3 Category 1 Buildings where vibration 65 VdB4 65 VdB4 65 VdB4 would interfere with interior operations. Category 2 Residences and buildings 72 VdB 75 VdB 80 VdB where people normally sleep. Category 3 Institutional land uses with 75 VdB 78 VdB 83 VdB primarily daytime use. Notes: 1. “Frequent Events” is defined as more than 70 vibration events of the same source per day. Most rapid transit projects fall into this category. 2. “Occasional Events” is defined as between 30 and 70 vibration events of the same source per day. Most commuter trunk lines have this many operations. 3. “Infrequent Events” is defined as fewer than 30 vibration events of the same kind per day. This category includes most commuter rail branch lines. 4. This criterion limit is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes. Vibration sensitive manufacturing or research should always require detailed evaluation to define the acceptable vibration levels. Ensuring low vibration levels in a building requires special design of HVAC systems and stiffened floors.

Existing Noise Environment The Proposed Project is located at the West Complex area of the Port of Stockton on Rough and Ready Island. The proposed Denmar marine terminal will be located at Berths 18 and 19 on the south western bank of the San Joaquin River opposite residential and recreational uses along the northeastern bank of the San Joaquin River and in western undeveloped areas within the West Complex (Figure 1). Remedial activities needed to clean up hazardous substances in soil and groundwater as a result of past U.S. Department of the Navy (Navy) activities, would also occur in western undeveloped areas concurrent to the Denmar terminal development.

1U.S. Department of Transportation, Federal Transit Administration, Transit Noise and Vibration Impact Assessment, May 2006, FTA-VA-90-1003-06. 10

The West Complex EIR described the existing noise environment within the commercial and industrial complex and at the sensitive receptors in the project area. As a part of the West Complex EIR Long-term noise measurements were conducted at various locations to estimate baseline noise conditions within complex and surrounding areas in October of 2002. Baseline measurements in the West Complex EIR closest to the proposed project were made at Dad’s Point and at West Complex Berth 20. At Dad’s Point site sound levels ranged from 57 dBA to 70 dBA DNL on weekdays and from 56 dBA to 60 dBA DNL on weekend days. At the Berth 20 site sound levels ranged from 81 dBA to 84 dBA DNL on weekdays and from 60 dBA to 62 dBA DNL on weekend days. These locations are shown in Figure 1.

To document the current conditions at the closest noise sensitive receptors to the proposed project, a noise measurement survey was conducted in in the vicinity of the residential and recreational uses opposite from the project site along the northeastern bank of the San Joaquin River. This noise monitoring survey included one long-term (LT-1) noise measurement and three short-term (ST-1, ST-2, and ST-3) noise measurement. All measurement locations are shown in Figure 1. The Existing noise levels within these residential and recreational areas result from ship traffic, operation associated with current Port activity, recreational boating along the San Joaquin River, parkland and landscaping activities, and local roadway traffic.

The long-term continuous (101 hour duration) noise measurement (site LT-1 in Figure 1) was conducted between 12pm on Monday, August 10th, 2020 and 5pm on Friday August 14th, 2020 on the lands of the Stockton Golf and Country Club in a tree approximately 30 feet from the northeast bank of the San Joaquin River and 510 feet from the face of Berth 18 on the southwest bank of the River. The hourly average noise levels at this location typically ranged from 52 to 60 dBA Leq during the day, and from 53 to 57 dBA Leq at night. The overall day-night average noise level during the weekday measurement period was determined to be 61 dBA DNL, with a day to day variation of 60 dBA to 61 dBA DNL. The daily trend in noise levels at LT-1 is shown in Chart 1.

11

ST-1

West Complex DEIR ST-2 Berth 20 Measurement Location

LT-1

ST-3 PROJECT STUDY AREA

West Complex DEIR Dad’s Point Measurement Location

Figure 1: DEIR and Current Measurement Locations

12

13

The short-term noise measurements were made over 15-minute periods concurrently with the long-term noise measurement on Friday, August 14, 2020. The first short-term noise measurement (ST-1) was made between 3:45 p.m. and 4:00 p.m. below the levee path parallel with St. Andrews Drive northeast of the confluence of the San Joaquin and the Calaveras Rivers at approximately 30 feet from the bank of the San Joaquin River and 640 feet from the southwest bank of the River. Noise at this location was primarily due to periodic watercraft noise on the adjacent waterways, including jet boats and jet skis which produced sound levels of between 53 and 61 dBA. Other sounds contributing to the noise environment included cars on area roadways at up to 47 dBA, sea lions barking at the Port shipyard across the San Joaquin River at 41 to 45 dBA, gusts of wind in nearby trees at 42 to 44 dBA. The short-term measurement results for ST- 1 are summarized in Table 6.

The second short-term noise measurement (ST-2) was made between 4:30p.m. and 4:45 p.m. near the driveway to 4439 Yacht Harbor Drive in the vicinity of the corner where Yacht Harbor Drive becomes West Riviera Drive. This measurement was approximately 270 feet from the bank of the San Joaquin River and 850 feet from the southwest bank of the River. Noise at this location was primarily due to neighborhood activities and distant watercraft noise on the adjacent waterways, including children at pay in backyard of area homes at 39 to 45 dBA, boats on the San Joaquin River at 40 to 43 dBA. No vehicular traffic passed on roadways during the measurement, however an idling car at about 100 feet produce a sound level of 41 to 42 dBA. Other sounds contributing to the noise environment included birds in trees at 38 to 40 dBA, gusts of wind in nearby trees at 40 to 42 dBA. The loudest noise during the measurement period was produced by a falling tree branch at about 59 dBA. The short-term measurement results for ST- 2 are summarized in Table 6.

The third short-term noise measurement (ST-3) was made between 5:00p.m. and 5:15 p.m. at the end of the parking lot for the Monte Diablo Avenue boat ramp and Louis Park southeast of the confluence of the San Joaquin River and the Smith Canal at approximately 55 feet from the bank of the inlet behind to spit to Dad’s Point, 440 feet to northeast bank of the San Joaquin River and 940 feet from the southwest bank of the River. Noise at this location was primarily due to park and parking lot activities at between 44 to 53 dBA, boats on the river at between 56 and 66 dBA and boat dock activities at between 50 and 52 dBA. The short-term measurement results for ST- 3 are summarized in Table 6.

TABLE 6 Summary of Short-Term Noise Measurements (dBA) Noise Measurement Location Lmax L01 L10 L50 L90 Leq DNL (Date, Time) ST-1: Below the levee path by St. Andrews Dr. 61 60 55 44 39 50 54 (8/14/2020, 3:45 - 4:00 p.m.) ST-2: Near 4439 Yacht Harbor Dr. Driveway 59 45 42 39 37 40 46 (8/14/2020, 3:30 - 4:45 p.m.) ST-3: End of Louis Park boat ramp parking lot 66 65 57 47 43 54 53 (8/14/2020, 5:00 - 5:15 p.m.) Note: The DNL is approximated by correlation to the corresponding measurement period at the long-term site.

14

PROJECT IMPACTS AND MITIGATION MEASURES Significance Criteria Noise The project will occur with the Port of Stockton West Complex, thus the noise criteria established in The West Complex EIR are the primary significance criteria applicable to the proposed project. The West Complex EIR criteria are based on changes in ambient noise levels and construction noise associated with implementation of the West Complex Development Plan. Significant ambient noise level increases were defined as 3 dBA for land uses that already exceed the “normally acceptable” ranges, 5 dBA for land uses that are within “normally acceptable” ranges but would exceed these ranges with additional project noise, and 10 dBA for land uses that would remain within the “normally acceptable” range of noise. Construction noise was considered significant if it would exceed 65 Lmax at the property line of nearest residence between 9 pm and 6 am. The West Complex EIR also recognized the presence of sensitive receptors and used the following upper limits of the “Normally Acceptable” range for daytime (7 am to 7 pm) in determining the significance of noise impacts: Residential: 60 dBA Ldn/CNEL (45 dBA Ldn/CNEL interior) Neighborhood Parks: 70 dBA Ldn/CNEL Golf Courses: 75 dBA Ldn/CNEL The City of Stockton General Plan and Noise Ordinance also set forth noise criteria which can be applied to project generated noise within the City of Stockton. The General Plan standards prohibit noise for new generating land uses adjacent to existing sensitive noise receptors, such as residential uses to a CNEL of 70 dBA when measured at the property line of the noise sensitive land use and require that noise produced by commercial uses to not exceed 75 dBA DNL/CNEL at the nearest property line. The Noise Ordinance requires that new or expanded Commercial, or Industrial noise sources comply with the following hourly average (Leq) and maximum (Lmax) sound level performance standards in the outdoor activity areas of adjacent to any noise-sensitive land uses as follows: Outdoor Activity Areas Noise Descriptor Day (7am to 10pm) Night (10pm to 7am) Hourly equivalent sound level (Leq), dB 55 45 Maximum sound level (Lmax), dB 75 65 Notes: (1) The noise standard shall be applied at the property line of the receiving land use. When determining the effectiveness of noise mitigation measures, the standards shall be applied on the receiving side of noise barriers or other property line noise mitigation measures (2) Each of the noise level standards specified shall be decreased by five (5) for impulse noise, simple tone noise, or noise consisting primarily of speech or music.

15

Vibration The West Complex EIR considered both ground-borne and airborne vibration resulting from projects I this Complex as potential impacts. To assess the significance of groundborne vibration and airborne sound-induced vibration, criteria recommended by the U.S. Department of Transportation were considered. For low frequency airborne sound-induced vibration a threshold of 70 dB has been used because this level is midway between a slight possibility of rattles in light fixtures, doors, windows, etc. (at 65 dB) and a high probability of such effects (at 75 dB). A 3 dB change relative to existing low frequency noise conditions and exceedance of the 70 dB threshold are used to assess significance. Thus, vibration impacts would be considered significant if project-related rail ground-borne vibration is predicted to exceed 80 VdB or project operations related airborne sound-induced vibration would exceed 70 dB at low frequencies and would be at least 3 dB greater than existing conditions at adjacent residential uses

NOISE IMPACTS Noise impacts resulting from the proposed project fall into two major categories: (1) Short-term noise impacts resulting from construction; and (2) Potential increases in noise resulting from project operation

Impact 1: Construction Generated Noise. Project operations and traffic accessing the project would increase noise levels in the surrounding area. This is a potentially significant noise impact. Project construction would occur over approximately 4 years and would result in an increase within noise levels on the project site and surrounding areas during this period. Construction of the project can be broken into two site remediation and two project construction phases as follows: Initial Remediation: (~72 working days) This will involve the excavation and consolidation of waste and select areas with contaminated soil within 20 feet of rail line and the installation of liner and soil cover at IAS-11 Consolidation Area Phase 1: (est. Jan.2021 to Nov. 2022) During this phase the following construction elements of the Denmar Terminal will be undertaken: Railcar unloading building Storage building ground improvements Storage building Rail track construction/modifications Transfer towers and conveyors Administration/maintenance and crew quarters buildings Wastewater treatment plant Shiploading equipment Facility commissioning Future Remediation: (~256 working days) Excavation and consolidation of remaining areas with known or potentially contaminated soil, Install liners and soil covers

16

Phase 2: (est. Jan.2024 to July 2025) Storage building ground improvements Storage building Transfer towers and conveyors Shiploading equipment Facility commissioning Based on a review of the project site plan and proposed remediation elements and a review distances to the nearest noise sensitive uses opposite the San Joaquin River for the project site obtained via the use of Google Earth, we have established that the closest portions of the above construction and remediation elements will be as close as 600 and 2500 feet from the closest noise sensitive uses. These distances, and the type and quantity, along with the usage factors of the proposed construction equipment for each of the remediation and construction phase elements were input into the Federal Highway Administration Roadway Construction Noise Model (RCNM). The RCNM model provides a means to determine composite noise levels from multiple construction noise sources. To conduct a conservative analysis of construction and remediation noise at the sensitive uses opposite the San Joaquin River, construction was assumed to occur at the closest distances to these noise sensitive uses (between 550 and 2900 feet depending on the remediation and construction phase elements undertaken. The results of this modeling in terms of average and (Leq) and maximum (Lmax) noise levels at the closest noise sensitive uses opposite the San Joaquin River are shown in Table 7 (following). A review of Table 7 indicates that the resultant noise levels at the closest noise sensitive receptors to the site remediation and construction activities associated with the development of the Denmar Terminal would be less than 55 dBA Leq and 75 dBA Lmax These levels are less than the daytime limits in the Stockton noise ordinance and the significance levels outlined in the West Complex EIR for residential areas. However, if construction occurs at night, the resulting maximum noise levels could exceed the West Complex EIR nighttime significance criteria and the average or maximum nighttime noise limits in the Stockton noise ordinance at these nearest sensitive receptors. The West Complex EIR contained the following mitigation measures for nighttime construction activity, muffling and shielding construction equipment, and locating stockpile and staging areas away from residential areas, which will be incorporated in the project. 4.5.1a Construction activities shall be limited to between 6:00 a.m. and 9:00 p.m. If nighttime construction were required, spot noise monitoring would be required to assure that noise levels from construction activities do not exceed 65 dBA Lmax at the property line of the nearest residence. Measures to reduce nighttime construction noise levels may include using noise barriers or reducing the amount of construction activity until noise levels are below the nighttime significance criterion. 4.5.1b Construction equipment noise shall be minimized during project construction by muffling and shielding intakes and exhaust on construction equipment (per the manufacturers’ specifications) and by shrouding or shielding impact tools. All equipment shall have sound-control devices no less effective than those provided by the manufacturer. 4.5.1c Material stockpiles and vehicle staging areas shall be located as far as practicable from residences.

17

Through the incorporation of MM 4.5.1.a, 4.5.1.b, and 4.5.1.c, construction generated noise from the Denmar Terminal project would have a less than significant impact on the noise sensitive uses opposite the San Joaquin River from the proposed Denmar Terminal. Table 7: Construction Noise Levels at Closest Noise Sensitive Uses Distance to Construction Sound Levels at Closest Noise Sensitive Uses (dBA) Sensitive Leq Lmax Work Description Uses (feet) Initial Remediation: 2500 41 64 -Excavation & Consolidation Initial Remediation: 2500 38 58 -Install Liner & Cover Phase1: Railcar Unloading Building 2900 35 59 Phase1: Storage Building Ground 1300 42 66 Improvements Phase1: Storage Building 1300 39 66 Phase1: Rail Track 2500 38 58 Construction/Modifications Phase1: Transfer Towers and 700 44 69 Conveyors Phase1: Administration/ Maintenance 1900 39 63 & Crew Quarters Bldgs. Phase1: Wastewater Treatment Plant 2000 28 49

Phase1: Shiploading Equipment 550 46 71

Phase1: Facility Commissioning 700 39 61 Future Remediation: 2500 47 67 -Excavation & Consolidation) Future Remediation: 2500 40 61 -Install Liner & Cover Phase 2: Storage Building Ground 1200 42 67 Improvements Phase 2: Storage Building 1200 43 67 Phase 2: Transfer Towers and 700 48 72 Conveyors Phase 2: Shiploading Equipment 700 44 69

Phase 2: Facility Commissioning 700 44 59

18

Impact 2: Project Generated Noise. Project operations and traffic accessing the project would increase noise levels in the surrounding area. This is a potentially significant noise impact. As proposed, the facility would operate 24 hours per day, 336 terminal operating days per year. During the initial phase, the facility is anticipated to handle approximately 4.8 million tons per annum (TPA) of soda ash and support approximately 137 annual vessel calls (two to three per week) and approximately 249 annual unit trains (approximately five per week). At full build-out, the facility would be anticipated to handle approximately 7 million TPA of soda ash and support 200 annual vessel calls (approximately four per week) and 363 annual unit trains (approximately one per day if the terminal operated 7 days per week). The overall project site plan is shown in Figure 2, following. Noise generated by the project can be broken down into the following categories; 1) On-Site Rail Noise: Noise generated by unit train operations accessing the Denmar terminal via the rail loop, 2) Material Offloading Noise: Noise emitted from the railcar dumper building during unloading and the use of vibratory railcar shakers, 3) Material Transfer Noise: Noise generated during material transfers via the conveyor system from the railcar dumping building to the material storage building and to the ship loaders, and 4) Ship Loading and Operations Noise: Noise generated from ship activities in the deep-water channel, loading and unloading the ships. Considering these activities and the proposed duration and schedule of the proposed operations the resulting noise levels and how they comply with the noise requirements of the West Complex EIR and the resulting sound levels and City of Stockton Noise limits are as follows: On-Site Rail Noise: The proposed project would bring Soda ash to the site on unit trains along existing main line tracks. Once on the West Complex site, unit trains would access the Denmar terminal via a project constructed rail loop. Based on a review of Google Earth distance data the closest rail tracks will be 2500 feet or more from the noise sensitive uses opposite the San Joaquin River. Engines of freight trains can produce maximum noise levels of up to 85 dBA at 100 feet from track centerlines with one train in any given hour resulting in an hourly average level of 66 to 72 dBA at 100 feet from the track centerline depending on the number of cars and locomotives per train. At a distance of 2500 feet, this the average noise levels would be less than 45 dBA and maximum noise levels would be less than 60 dBA, and with one or possibly two trains per day delivering product the resulting average daily noise level less than 45 dBA Ldn/CNEL at the closest the noise sensitive uses opposite the San Joaquin River and comply with the noise requirements of the West Complex EIR and the City General Plan and Noise Ordinance.

19

Figure 2: Overall Project Site Plan

20

Material Offloading Noise: As the trains move through the loop, the soda ash would be transferred using bottom-dump hopper railcars in the railcar unloading building. As the car pass through the building the bottom of the hopper car would open, and contents would be deposited in a lined 35-foot-deep dual unloading pit. Train unloading in the building would be completed using a car-in-motion system where each unit train would proceed through the railcar unloading building at up to 40 feet per minute. Multiple railcars would be unloaded simultaneously within the building as they pass over the unloading hopper. There will also be side-mounted vibratory railcar shakers in the railcar unloading building, as well as two railcar gate opener robots to assist offloading the soda ash through the bottom-dump hopper railcars. A manual railcar opener would be positioned between the two robots to provide redundancy in the event of a robot failure. A centralized dust collection system would collect dust from the conveyor transfer points and create a downdraft within the hopper to capture dust generated by falling material. The offloading of soda ash itself is not expected to result in noise levels greater than that of the moving rail cars, the opening and closing rail car hoppers, or the vibratory shakers. Additionally, because soda ash is highly soluble in water, all of these operations would occur within the railcar building. Based on a review of Google Earth distance data the Rail Car Unloading Building will 2900 feet or more from the noise sensitive uses opposite the San Joaquin River. Though the actual noise levels produced during rail car unloading is unknown, measurements of the off-loading of a heavier material (1-inch rock aggregate) into a hopper produced an average sound level of 76 dBA Leq at 145 feet. Considering only a minimal building sound attenuation factor of 6 dBA and distance attenuation with no other intervening barriers, the offloading of this heavier, and inherently much louder material, would be less than 45 dBA Leq at these closest noise sensitive receptors. Based on this very conservative analysis, the average daily noise level due to rail car unloading would be less than 45 dBA Leq and with one or possibly two trains per day delivering product the resulting average daily noise level due to material offloading would be less than 50 dBA Ldn/CNEL at the closest the noise sensitive uses opposite the San Joaquin River. These noise levels would comply with the noise requirements of the West Complex EIR and the City of Stockton General Plan Noise and Noise Ordinance limits. Material Transfer Noise: Soda ash would be transferred through a series of fully enclosed conveyors from the railcar unloading building up to the top of a transfer tower to the project storage buildings. In direct rail- to-vessel transfers, soda ash would travel straight through the storage building to an enclosed outbound conveyor. If rail and vessel schedules do not allow soda ash to be transferred directly from the train to the vessel, it would be placed in storage buildings until a vessel arrives at the dock, then transferred to the outbound conveyor. Though the noise generated by this operation is unknown, sound from the actual material transfer in enclosed conveyors is expected to be minimal, with the primary noise source from this operation being produced by fans associated with the dust collection system. Depending on the size and enclosures of the fans, it is expected that they could produce noise levels of between 60 dBA and 65 dBA at 100 feet. Based on a review of Google Earth distance data the conveyors and storage buildings will as close as 700 feet from the Stockton Golf and Country Club and about 1400 feet from the closest residential use opposite the San Joaquin River. Considering these distances and distance attenuation only, the fans associated with the dust collection system could produce levels of up to 48 dBA at the Stockton Golf and Country Club and up to 42 dBA at the residential use opposite the San Joaquin River. These noise levels would comply with the noise requirements of the

21

West Complex EIR and the City of Stockton General Plan Noise and Noise Ordinance limits. Ship Loading Noise: When a vessel arrives at Berth 18 (Phase 1) or at either Berths 18 or 19 (Phase 2), soda ash would travel on the enclosed outbound conveyors on the east end of either storage building to the transfer tower near the berths, to the final enclosed conveyor, and be transferred onto the ships at either Berths 18 or 19 via shiploaders. Each shiploader would be able to be moved along each berth, capable of a range of motion enabling them to reach all of the holds on a ship and equipped with dust minimization and containment and collection features. Though the noise generated by this operation is unknown, based on measurements of gantry crane movements operations, which are judged to be similar to shiploader operations, ship loading is expected to produce maximum noise levels of 72 to 73 dBA at 50 feet. Based on a review of Google Earth distance data, shiploading activities will occur as close as 600 feet from the Stockton Golf and Country Club and about 1200 feet from the closest residential use opposite the San Joaquin River. Considering these distances and distance attenuation only, shiploading noise could produce maximum levels of up to 51 dBA at the Stockton Golf and Country Club and up to 46 dBA at the residential use opposite the San Joaquin River. These noise levels would comply with the noise requirements of the West Complex EIR, and the City of Stockton General Plan and Noise Ordinance limits. Ship Operational Noise The West Complex EIR contained a discussion and analysis of the of the noise produced by ships in port on residences opposite the San Joaquin River. This analysis, which used measurements of noise from the operations of several ships in port, found that the typical measured sound level produced by a ship in port, along with related operations was about 61 dBA at distance 150 yards from the ship. Based on a review of Google Earth distance data, ships in Berths 18 and 19 would about this distance from the Stockton Golf and Country Club and about 1000 feet from the closest residential use opposite the San Joaquin River. With constant operation 24-hours a day, this corresponds to a sound level of about 67 dBA Ldn/CNEL at the Country Club and 60 dBA Ldn/CNEL at the closest residences. These average day/night levels would comply with the noise requirements of the West Complex EIR and the City of Stockton General Plan Noise limits. Based on the above discussions, project operations would comply with the noise requirements of the West Complex EIR and the City of Stockton Noise Standards. This is a less than significant noise impact.

VIBRATION AND LAND USE COMPATIBILITY GROUNDBORNE VIBRATION Rail Traffic The FTA has established vibration impact assessment criteria for use in evaluating groundborne vibration impacts associated with developments in proximity to rail lines. The FTA vibration impact criteria are based on maximum overall levels for a single event. The impact criteria for groundborne vibration are shown in Table 5 (see page 10). Note that there are criteria for frequent events (more than 70 events of the same source per day), occasional events (30 to 70 vibration events of the same source per day), and infrequent events (less than 30 vibration events of the same source per day). As proposed, at full buildout 363 annual unit trains (approximately

22

one per day if the terminal operated 7 days per week) would bring product to the site. This frequency of rail usage would fall in the “infrequent” category. The applicable threshold is therefore 80 VdB for residential uses. Based on measurements of rail operations, we typically consider freight operations to be limited to groundborne vibration levels of 70 to 75 dBA at 100 feet from the railroad centerline depending of ground motility (vibration transfer conditions). All vibration sensitive uses on the project site and vicinity are well beyond 100 feet from the rail lines. Therefore, groundborne vibration produced by the project is expected to comply with FTA vibration impact criteria.

Construction Vibration Ground remediation and project construction has the potential to produce high level of ground vibration in close proximity to these activities. Typical Peak Particle Velocity (PPV) ground vibration levels produced by construction equipment range from 0.2 in/sec for large vibratory rollers to 0.003 in/sec for small bull dozers at a distance of 25 feet. Considering a Rayleigh (surface) wave propagation model2 and using factors for ground and damping ratios3 and considering that the closet offsite vibration sensitive receivers are over 500 feet removed and opposite the San Joaquin River, construction vibration levels would be below a PPV level of 0.01in/sec. and likely less than perceptible at these closest sensitive receivers.

AIRBORNE VIBRATION As discussed in the West Complex EIR low frequency noise and infrasound measured for most ships are in the range of about 65 to 70 dB at residential receptors with vibration-inducing noise produced by the main propulsion engines of ships. When levels of low-frequency noise and/or infrasound exceed 75 decibels, studies indicate that there is a high probability that noise-induced vibration in lightweight wall and ceiling construction would be clearly felt and that audible rattles in light fixtures, doors, and windows are to be anticipated. Low frequency project related noise is not expected to exceed 75 dB at residential uses across the San Joaquin River from Berths 18 and 19. It is, however, possible that low frequency airborne noise could cause irritating secondary vibrations, such as rattling of windows, doors, or stacked dishes in these homes. However, with a maximum of two to three ships per week at the Denmar Terminal it is highly unlikely that the project would result in a 3 dB or more increase in low frequency noise at the adjacent residential uses. Based on the above discussions, project operations are not expected to result in any groundborne or airborne vibration impacts. This is a less than significant noise impact.

2 Amick, H., and Gendreau, M., “Construction Vibrations and Their Impact on Vibration Sensitive Facilities”, Presented at the ASCE Construction Congress 6, Orlando, Florida, February 22, 2000. 3 H. Bachmann, et al., Vibration Problems in Structures, Birkhauser Verlag, Berlin, 1995.

23

Appendix D Jurisdictional Waters and Wetlands Figures

CALIFORNIA

Sacramento^ Stockton !

! % San Francisco Study Area Project Site

5

% §¨¦ %

San Joaquin River

Rough and Ready Island NAVY DR Port of Stockton

WASHINGTON ST DAGGETT RD DAGGETT

Publish Date: 2020/09/18, 8:49 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_Fig01_SiteAndVicinityMap.mxd

0 2,000 Figure 1 Vicinity Map [ Feet Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton San Joaquin River

Burns Cut

Rough and Ready Island

LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 580 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:32 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 2 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton Burns Cut

LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 3 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 4 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 5 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 6 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 7 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton LEGEND: NOTE: Labels for each jurisdictional feature include two digits denoting the Study Area jurisdictional delineation year and source when the feature was identified ("19" for the 2019 Draft Jurisdictional Delineation of Rough and Ready Island (North Jurisdictional Features and South Parcels), "14" for the 2014 Draft Jurisdictional Delineation Report Poison hemlock or Pepperweed Patches (Semi-Natural Herbaceous Stands) Rough and Ready Island, and "20" for the 2020 Supplemental Field Investigation). Quailbush Scrub (Shrubland Alliance) Arroyo Willow Thickets (Shrubland Alliance) Riparian Scrub Freshwater Emergent Wetlands Seasonal Wetland 0 200 Relatively Permanent Waters Drainage Ditch [ Feet

Publish Date: 2020/09/18, 10:04 AM | User: alesueur Filepath: \\orcas\gis\Jobs\Port_of_Stockton_0377\Maps\Denmar\WetDel\AQ_Denmar_JurisdictionalFeatures.mxd

Figure 8 Jurisdictional Features Draft Jurisdictional Delineation Denmar Natural Soda Ash Export Terminal at the Port of Stockton