The regulatory limits for the project include those prescribed via the Imperial County municipal code.

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4 August 18, 2015 Dear Sharyn Del Rosario, HDR evaluated potential impacts from construction noise associated with the SEPV Dixieland East and West Solar Farm Projects (Project) and this letter memo provides the results of the construction noise analysis. Operational noise is anticipated to be minimal from the Project since there will be no onsite substation and operation of the Project will be completed remotely. Maintenance of the Project would include a couple of people once or twice a year to clean the photovoltaic modules. Therefore, operational and maintenance noise is anticipated to be negligible from the Project and not evaluated further. Regulatory Limits The regulatory limits for the project include those prescribed via the Imperial County municipal code. Imperial County General Plan Noise Element and Municipal Code Imperial County has adopted specific Noise/Land Use Compatibility Criteria in its Noise Element. The criteria provides levels of acceptable noise exposure based on the sensitivity of specific land uses via Imperial County Code, Title 9, Division 7: Noise Abatement and Control, section Sound Level Limits (Imperial County 1998). These limits are presented in Table 1. Depending on the ambient environment of a particular community, these basic guidelines may be tailored to reflect existing noise and land use characteristics. Table 1. Imperial County Exterior Noise Standards Land Use Zone Time Period Noise Level, L eq 1-hour R-1 Residential Night (10 p.m. to 7 a.m.) 45 dba Day (7 a.m. to 10 p.m.) 50 dba R-2 Residential Night (10 p.m. to 7 a.m.) Day (7 a.m. to 10 p.m.) R-3, R-4, & other Residential Commercial Manufacturing, other industrial, agricultural, and extraction industry Night (10 p.m. to 7 a.m.) Day (7 a.m. to 10 p.m.) Night (10 p.m. to 7 a.m.) Day (7 a.m. to 10 p.m.) Anytime 50 dba 55 dba 50 dba 55 dba 55 dba 60 dba 70 dba Industrial Anytime 75 dba Source: Imperial County Municipal Code Section hdrinc.com 8690 Balboa Avenue, Suite 200, San Diego, CA (858)

5 The Noise Element of the County s Genera Plan (Imperial County 1993) stipulates that the County s municipal code noise limits do not apply to construction activities. Environmental Setting Land uses surrounding the Project are mostly vacant desert land; however, there are a total of 31 residences located within one mile radius of the project areas. The nearest residence (a mobile home) is located approximately 175 feet from either of the project site boundaries where construction equipment would be used. Eight residences (four houses and four mobile homes) are located east of the Project across the Westside Main Canal with the closest construction noise approximately 350 feet from the nearest residence. Two residences are located approximately 350 feet south of the project area. The Imperial Lakes Water Ski Community is located west of DWSF. This development includes 20 residences (mobile homes). The eastern boundary of the Imperial Lakes Water Ski Community is approximately 1,500 feet from the DWSF western boundary. No residences are located immediately to the north. All of the residences are located on tax lots (i.e., parcels) zoned A2 (Agricultural) except for the Imperial Lakes Water Ski Community which is zoned Recreational (F) under the conditions of the SPA, which allows for mobile homes. This zoning designation does not have a specific noise requirement but is assumed to be other residential in Table 1. For the purposes of assigning noise level limits based on zones the limit for A2 is 70 dba L eq 1- hour at all times and the limits for SPA are 55 dba L eq 1-hour during the daytime and 50 dba L eq 1- hour at night; however, these limits do not apply to construction noise. Construction of the Project would take place over the course of 36 weeks. Construction Noise Impact Analysis Construction of the project would be conducted during daytime hours only and in compliance with the County s noise ordinance. Construction noise, although temporary, can be a source of concern for sensitive receptors, such as nearby residences. Heavy equipment will be used to construct the project and may be periodically audible at offsite locations. Received sound levels will fluctuate, depending on the construction activity, equipment type, and distance between noise source and receiver. The variation in power and usage imposes complexity in characterizing construction noise levels. Expected equipment types for each phase of construction are presented in Table 2 and were used to screen for potential construction noise impacts. The estimated composite site noise level is based on the assumption that all equipment would operate at a given usage load factor, for a given hour, to calculate the composite average daytime hourly L eq. The load factor accounts for the fraction of time that the equipment is in use over the specified time period. The composite noise level from several pieces of equipment operating is obtained from decibel addition of the L eq of each individual unit. Although it is not possible for all the construction equipment to operate at one point simultaneously, the screening level analysis conservatively assumes that this is the case.

6 Table 2. Construction Equipment Noise Levels Equipment Noise Level, L max at 50 feet Composite Noise Level (L eq 1-hour ) at 50 feet Vibratory Post driver 85 Crawler/Tractor/Dozer 82 Dump, Concrete, Tender Truck 79 Forklift/aerial lift/boom 81 Generator/Compressor 81 Grader/Scraper 85 Roller/Compactor 80 Tractor/Loader/Backhoe 79 Vibratory Plate (handheld) 83 Flatbed Truck 74 Water Truck 79 Source: Federal Highway Administration Roadway Construction Noise Model, FHWA Construction sound will attenuate with increased distance from the sound sources. Composite L eq 1-hour sound levels at distances out to a distance of 1,000 feet were calculated assuming spherical free-field spreading, see Table 3. Other factors, such as vegetation, ground effects, terrain and obstacles, such as buildings, will act to limit the impact of construction noise levels, but were not considered in the evaluation. Actual received sound levels will fluctuate, depending on the construction activity, equipment type, and separation distances between source and receiver. As a general construction practice, functional mufflers will be maintained on all equipment to maintain noise levels as low as reasonably achievable. Table 3. Construction Noise Levels at Distance Distance from Project Construction (feet) Noise Level, L eq 1-hour at 50 feet 175* ** Notes: * Distance to nearest sensitive receptor. **Distance to second closest sensitive receptor. Conclusions Construction noise from the Project was analyzed at the nearest sensitive receptors. Although the County s noise limits do not apply to construction noise, they do provide some context against which conclusions can be drawn. For the nearest sensitive receptors, the highest

7 construction noise levels would be experienced when construction is nearest, identified as the mobile home residence located 175 feet east of the DESF site. At this distance the received sound level would be 73 dba L eq 1-hour. ; however, this sound level would only be experienced for a day or two at most since the construction is not stationary and will move throughout the Project area. The sound level calculated at the Project centroid would be considered an average for the duration of construction and would be approximately 1,300 feet from the nearest residential area. At this distance the received sound level would be 49 dba L eq 1-hour. Because construction would be restricted to daytime hours over a period of 36 weeks for the entire project, the use of muffled equipment shall be kept in good working order, and would not exceed applicable regulatory limits. The associated construction noise impacts would be considered less than significant. Sincerely, HDR Scott Noel, AICP GISP INCE Sr. Acoustics Specialist

8 Equipment Composite Sound Level (L eq ) at Distance 3 Variable Nearest 402 W Cocupa Ave., Seeley, CA (enter below) Residences East of Dixie Canal Closest Residence at Imperial Lakes Development 50' SEELEY CA, Type Quantity L Closest (175') East Centroid (1300') West Centroid (1300') Closest (460') East Centroid (1000') West Centroid (3600') Closest (1680') East Centroid (5000') West Centroid (3400') Vibratory Post driver Crawler/Tractor/Dozer Dump, Concrete, Tender Truck Forlift/aerial lift/boom Generator/Compressor Grader/Scraper Roller/Compactor Tractor/Loader/Backhoe Vibratory Plate (handheld) Flatbed Truck Water Truck Source

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10 Estimated sound levels at sensitive receptor locations. Filename: Engr: NOISE SENSITIVE LOCATION: A Total Soft OPERATION 7 RCNM Number of Ref EL 1 UF 2 Dist 3 Dist 4 Barrier/Terrain Ground 6 Lmax Leq Equipment Equipment Dist Lmax percent feet feet Sheilding Effects dba dba Vibratory Post driver Crawler/Tractor/Dozer Dozer Dump, Concrete, Tender Truck Concrete Mixer Truck Forlift/aerial lift/boom Crane Generator/Compressor Generator Grader/Scraper Grader Roller/Compactor Roller Tractor/Loader/Backhoe Front End Loader Vibratory Plate (handheld) Compactor (ground) Flatbed Truck Flat Bed Truck Water Truck Concrete Mixer Truck Total Project Operational Sound Level: EL, Measured given reference distance. 2. UF, Percenatge of time noise source is operating (for 1-hour Leq calculation). 3. Distance factor determined by the inverse square law defined as 6 dba per doubling of distance as sound travels away from an idealized point. 4. Unpaved of soft ground distance from source to receptor (per FTA/FHWA guidance manual). 5. Topographic effects calculated per Maekawa (FHWA method) for sheilding by berm or barrier (only where appropriate). 6. Ground effects were calculated using FTA and FHWA Construction Noise Assessment Guidelines. 7. Equipment from Table 8 of Air Emissions and Greenhouse Gas Analysis.

11 Equipment Description Impact Device? Acoustical Usage Factor (%) Spec L 50 feet (dba, slow) Actual Measured L 50 feet (dba, slow) (Samples Averaged) Number of Actual Data Samples (Count) All Other Equipment > 5 HP No N/A 0 Auger Drill Rig No Backhoe No Bar Bender No N/A 0 Blasting Yes N/A 94 N/A 0 Boring Jack Power Unit No Chain Saw No Clam Shovel (dropping) Yes Compactor (ground) No Compressor (air) No Concrete Batch Plant No N/A 0 Concrete Mixer Truck No Concrete Pump Truck No Concrete Saw No Crane No Dozer No Drill Rig Truck No Drum Mixer No Dump Truck No Excavator No Flat Bed Truck No Front End Loader No Generator No Generator (<25KVA, VMS Signs) No Gradall No Grader No N/A 0 Grapple (on backhoe) No Horizontal Boring Hydraulic Jack No Hydra Break Ram Yes N/A 0 Impact Pile Driver Yes Jackhammer Yes Man Lift No Mounted Impact Hammer (hoe Yes Pavement Scarifier No Paver No Pickup Truck No Pneumatic Tools No Pumps No Refrigerator Unit No Rivit Buster/Chipping Gun Yes Rock Drill No Roller No Sand Blasting (single nozzle) No Scraper No Sheers (on backhoe) No Slurry Plant No Slurry Trenching Machine No Soil Mix Drill Rig No N/A 0 Tractor No N/A 0 Vacuum Excavator (Vac-Truck) No Vacuum Street Sweeper No Ventilation Fan No Vibrating Hopper No Vibratory Concrete Mixer No Vibratory Pile Driver No Warning Horn No Welder/Torch No

12 Traffic Assessment for: Project No. 1 SEPV Dixieland East 2MW Solar Photovoltaic Electricity Generating Facility Project No. 2 - SEPV Dixieland West 3MW Solar Photovoltaic Electricity Generating Facility Imperial County, California October 19, 2015 Prepared for: Michael Stern SEPV Imperial, LLC San Vicente Blvd, Suite 414 Los Angeles, CA Telephone: Cell Telephone: Prepared by: 1941 Paseo Pelota Palm Springs, California Telephone: (760) FAX: (815) Job Number PA15005

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14 Table of Contents 1. INTRODUCTION PROJECT DESCRIPTIONS SEPV DIXIELAND EAST PROJECT DESCRIPTION SEPV DIXIELAND WEST PROJECT DESCRIPTION FORECAST PROJECT TRIP GENERATION Construction Phasing and Duration Construction Workforce Estimates for the Projects Construction Truck Trip Estimates for the Projects Peak Hour Trip Generation Forecast Employee Trips Truck Trips Additional Work Related Trips FACILITY OPERATIONS AFTER CONSTRUCTION ROADWAY CAPACITY ANALYSIS CONCLUSIONS List of Figures FIGURE 1 SEPV DIXIELAND EAST PROJECT LOCATION... 2 FIGURE 2 SEPV DIXIELAND WEST PROJECT LOCATION... 3 FIGURE 3 SEPV DIXIELAND EAST PROJECT SITE PLAN... 4 FIGURE 4 SEPV DIXIELAND WEST PROJECT SITE PLAN... 6 FIGURE 5 AREA TRAFFIC VOLUMES (FORECAST YEAR 2015) List of Tables TABLE 1 - PROJECT TRAFFIC GENERATION... 9 Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering i

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16 1. INTRODUCTION This report was prepared to assess the project trip generation for the following two independent projects: Project No. 1 SEPV Dixieland East 2MW Solar Photovoltaic Electricity Generating Facility Project No. 2 - SEPV Dixieland West 3MW Solar Photovoltaic Electricity Generating Facility The projects will be shown to have negligible trip generation upon completion of the construction phase of the projects. The projects will generation the most traffic during construction. Since these project are in close proximity to one another, and since the project construction schedules will overlap, the traffic assessment for both projects is being provided in a single document. This report will develop a trip generation forecast for the projects and determine if a formal traffic study is required under Imperial County CMP guidelines. 2. PROJECT DESCRIPTIONS The proposed projects are located approximately 5 miles west of the community of Seeley, near the Westside Main canal. It is anticipated that most trips will have origins and destinations from El Centro and those trips will utilize S80/West Evan Hewes Highway (a county roadway) to access the project site. Figure 1 shows the location of the SEPV Dixieland East Project. Figure 2 shows the location of the SEPV Dixieland West Project. 2.1 SEPV Dixieland East Project Description SEPV Imperial, LLC is seeking to construct and operate a 2MWac, solar photovoltaic ( PV ) electricity generating facility called SEPV Dixieland East on an approximately 24-acre site located north of Potrero Avenue along Brown Road and in an unincorporated area of Imperial County known as Dixieland. The site is approximately 5 miles west of the community of Seeley, south of the Centinela State Prison and east of the Dixieland Substation. The site is to the west of the Westside Main canal. The project will utilize solar photovoltaic ( PV ) modules mounted on single-axis sun tracking support structures to generate 2 megawatts (MWac) of renewable electrical energy. The project fence line will be located approximately 400 feet north S80/West Evan Hewes Highway to minimize any visual impacts. Figure 3 shows the SEPV Dixieland East Project site plan. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 1

17 FIGURE 1 SEPV DIXIELAND EAST PROJECT LOCATION Traffic Assessment for the Proposed (EPV Dixieland East West Prepared for SEPV Imperial, LLC George Dunn Engineering 2

18 FIGURE 2 SEPV DIXIELAND WEST PROJECT LOCATION Traffic Assessment for the Proposed (EPV Dixieland East West Prepared for SEPV Imperial, LLC George Dunn Engineering 3

19 FIGURE 3 SEPV DIXIELAND EAST PROJECT SITE PLAN Traffic Assessment for the Proposed (EPV Dixieland East West Prepared for SEPV Imperial, LLC George Dunn Engineering 4

20 2.2 SEPV Dixieland West Project Description SEPV Imperial, LLC is seeking to construct and operate a 3MWac, solar photovoltaic ( PV ) electricity generating facility called SEPV Dixieland West on an approximately 29-acre site located at the northwest corner of West Evan Hews Hwy and Carriso Avenue in an unincorporated area of Imperial County known as Dixieland. The site is approximately 5 miles west of the community of Seeley, and is to the west of the Westside Main canal. The project will utilize solar photovoltaic ( PV ) modules mounted on single-axis sun tracking support structures to generate 3 megawatts (MWac) of renewable electrical energy. The project fence line and the project components will be set back at least 240 feet from Evan Hewes highway to minimize visual impacts. Figure 4 shows the SEPV Dixieland West Project site plan. 3. FORECAST PROJECT TRIP GENERATION Since there is no specific land use in the ITE Trip Generation manual, trip generation for the construction and operational phases of the project were developed as outlined below. 3.1 Construction Construction Phasing and Duration A PV solar energy based electricity generating facility is highly modular and as such, is very straightforward to construct. The construction activities for the project generally fall into three main phases: (1) site preparation; (2) system installation; and (3) facility commissioning. SEPV Dixieland East Project Schedule The entire process is estimated to take up to 22 weeks. Construction is anticipated to begin in early 2016, with operations beginning in mid Construction would primarily occur during daylight hours, Monday through Saturday. SEPV Dixieland West Project Schedule The entire process is estimated to take up to 26 weeks. Construction is anticipated to begin in early 2016, with operations beginning in mid Construction would primarily occur during daylight hours, Monday through Saturday. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 5

21 FIGURE 4 SEPV DIXIELAND WEST PROJECT SITE PLAN Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 6

22 3.1.2 Construction Workforce Estimates for the Projects SEPV Dixieland East The on-site construction workforce for the project is expected to peak (overlapping construction activities) at 30 individuals. It is anticipated that the construction workforce would commute to the site each day from local communities. The worker vehicle trips anticipated to be generated from the project assumes 20 employees that would commute alone, and 10 employees that would carpool. Additionally, construction activity trips would include several trucks arriving and departing the site each day to deliver materials, including water for dust suppression, supplies, and equipment. Coordination with sister project Dixieland West will provide logistical synergies which will serve to reduce impacts associated with traffic, dust, and noise. SEPV Dixieland West The on-site construction workforce for the project is expected to peak (overlapping construction activities) at 30 individuals. It is anticipated that the construction workforce would commute to the site each day from local communities. The worker vehicle trips anticipated to be generated from the project assumes 20 employees that would commute alone, and 10 employees that would carpool. Additionally, construction activity trips would include several trucks arriving and departing the site each day to deliver materials, including water for dust suppression, supplies, and equipment. Combined Project Peak Construction The projects will be constructed on a serial basis, meaning the time from construction start to finish will be 36 weeks. The SEPV Dixieland East Project will take 22 weeks to construct and the SEPV Dixieland West Project will take 26 weeks to complete. Peak construction times for each individual project is not expected to occur at the same time. The maximum number of employees working on the two solar project at one time will be 40 employees. For purposes of the trip generation calculations, it is assumed that 28 employees will drive alone and 12 employees will arrive in two-person carpools Construction Truck Trip Estimates for the Projects The SEPV Dixieland East Project will require 120 truck trips over the course of the project, with a maximum of 8 trucks per day. The SEPV Dixieland West Project will require 180 truck trips over the course of the project, with a maximum of 12 trucks per day. The total number of trucks over the 36-week overlapping construction period for the two project will be 300. The maximum number of daily truck trips generated by construction will be 20, assuming each project generated its maximum number of truck trips on a specific day, which is a worst case scenario that is not anticipated. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 7

23 The truck trip calculations below account for the heavier vehicles types such as trucks by converting truck trips to passenger car equivalents. A rate of 2.2 passenger car equivalents (PCEs) per truck trip was used in this analysis. This conversation rate falls within the guidelines set for in the Highway Capacity Manual. Construction of the project will require the periodic use and installation of heavy equipment and associated systems at various times within each construction phase. Heavy equipment will not be hauled to/from the project sites daily; it will be hauled in at the beginning of construction and hauled out upon completion of construction Peak Hour Trip Generation Forecast For purposes of forecasting future peak hour trip generation, it is assumed that the majority of the daily project trips will occur during daylight hours. It is assumed that each employee arrives prior to the start of the work shift and departs just after the work shift. It is also assumed that truck trips will occur randomly during daylight hours, Monday through Saturday. Based on these assumptions, daily and peak hour trip generation calculations are provided below Employee Trips It is estimated that the maximum number of employees working on the SEPV Dixieland East and West projects at one time will be 40 employees. 28 employees will drive alone and 12 employees will carpool (2 to vehicle) = 34 inbound trips in the AM and 34 outbound trips in the PM Due to the remote project location, employees would be expected to stay on-site during the lunch period. Total trips = 34 * 2 = 68 daily employee trips Truck Trips The maximum number of daily truck trips generated by construction will be 20, assuming each project generated its maximum number of truck trips on a specific day. These trips will likely occur randomly during the work day. 20 daily two-way truck trips = 40 one-way truck trips at a PCE of 2.2 = 88 PCE one-way truck trips per day. 88 PCE truck trips / 8-hour days = 11 PCE one-way truck trips during the AM peak hour and 11 PCE one-way truck trips during the PM peak hour. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 8

24 3.1.7 Additional Work Related Trips For the purposes of forecasting, it is assumed that other trips associated with the activities of supervisors, inspectors and vendors would be equal to 20% of the employee trips and would occur randomly over the work day. 68 daily employee trips x 0.20 = 14 ancillary trips (PCEs) daily trips Table 1 shows the forecast traffic generation expected from the project based on the information provided by the project proponent. Table 1 - Project Traffic Generation Land Use Daily AM Peak Hour PM Peak Hour Total In Out Total In Out Employee Trips* Truck Trips (PCEs) Ancillary Trips NET Project Trips (PCEs) During the peak of projects construction, the project sites will generate a total of 170 trips (PCEs) daily, including 47 trips (PCEs) during the traditional AM peak hour and 47 trips (PCEs) during the traditional PM peak hours on the adjacent roadways. 4. FACILITY OPERATIONS AFTER CONSTRUCTION Once the facilities are operational, they will be operated and monitored remotely. Each facility will employ up to three (3) individuals on a part-time basis to provide maintenance, repair, and other services required to ensure the facility continues generating energy over its lifetime. These workers will not be on site on a daily basis, but only as-needed for panel washing and maintenance and repair activities. 5. ROADWAY CAPACITY ANALYSIS The type of traffic analysis required for this project is based on the Imperial County traffic study guidelines since the project access will be provided by S80/West Evan Hewes Highway, Dunaway Road and Interstate 8. Brown Road is a two-lane north-south roadway that has a southern terminus at West Evan Hewes Highway to the south and Centinela State Prison to the north. Brown Road bisects the SEPB Dixieland East Project Site, which has two (2) primary access driveways and two (2) secondary access driveways along Brown Road. The Brown Road/West Evan Hewes Highway intersection is controlled by stop signs on the intersection approaches. Brown Road is classified as a local roadway. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 9

25 West Evan Hewes Highway has a classification of Prime Arterial in the Imperial County Circulation and Scenic Highway Element Plan. This roadway is currently constructed as a two (2) lane un-divided roadway. Based on Imperial County guidelines, this roadway has a Level of Service (LOS) C capacity of 7,100 vehicles per day. Level of Service C is considered a good level of service. Dunaway Road in the project vicinity has a classification of Major Collector in the Imperial County Circulation and Scenic Highway Element Plan. Dunaway Road provided the nearest I-8 Freeway interchange to the SEPV Dixieland project sites. This roadway is currently constructed as a two (2) lane un-divided roadway. Based on Imperial County guidelines, this roadway has a Level of Service (LOS) C capacity of 7,100 vehicles per day. Interstate 8 is constructed as a four-lane divided interstate highway in the project vicinity with two lanes in each direction. A four-lane freeway has a LOS C capacity of about 60,000 vehicles per day. Traffic volumes in this area were documented in the Final Environmental Impact Report/Environmental Assessment (Final EIR/EA) for the proposed Imperial Solar Energy Center West project, July This project is currently under construction and will likely be completed before the SEPV Dixieland project begin construction. The Imperial Solar Energy Center West project is located approximately 1.5 miles southwest of the proposed SEPV Dixieland East and West projects. Figure 5 shows the Year 2010 traffic volumes used in assessment of construction impacts for the Imperial Solar Energy West Project. The volumes in boxed are forecast Year 2015 volumes that were developed by factoring Year 2010 volumes from the EIR by increasing for five years by a growth factor of 2.8 percent per year. That same growth rate was used in the approved Final Imperial Solar Energy Center West EIR. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 10

26 FIGURE 5 AREA TRAFFIC VOLUMES (FORECAST YEAR 2015) Note: The striped Project Site in Figure 5 is the location of the Imperial Solar Energy West project. The figure shows that traffic on both Evan Hewes Highway and Dunaway Road is less than 1,000 vehicles per day. Well below the roadway LOS C capacity of 3,100 vehicles per day. Interstate 8 volumes are also well below LOS C capacity. Imperial County Guidelines state that a full traffic study, based on trip generation, is required for: 1. Any project that adds more than 8% of the total existing vehicle trips on the adjacent road system at full build-out of the project. 2. Any project that generates more than 400 daily residential trip ends, 800 commercial or industrial trip ends, or 200 peak hour trip ends as determined by the average trip rates contained in the ITE Trip Generation Informational Report. 6. CONCLUSIONS Both the SEPV Dixieland East and SEPV Dixieland West Project are located in remote areas that do not have congested roadways. Once the projects are completed, they will only intermittently generate a few trips per day. The only time that projects will generate any noticeable traffic is during the 36-week construction period. The construction phase of the project is forecast to generate less than 100 peak hour trips (PCEs) and 170 daily trips (PCEs). Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 11

27 Since the daily volumes (ADT s) on Evan Hewes Highway and Dunaway Road are so low, it is possible that one of these two roadway segments could see an increase of daily trips by more than 8%, depending on how trip paths to and from the project are distributed and how the project is actually staffed and scheduled. Most trips would have origins and destinations to/from the El Centro area to the east. Some trips would use Evan Hewes Highway to travel east while most would likely use Evan Hewes Highway to travel west to Dunaway Road to access Interstate 8. Access to Evan Hewes Highway from the SEPV Dixieland East Project would be provided by Brown Road. Adding 170 daily trips (worst case scenario) on any of the Evan Hewes Highway/Dunaway Road segments, however, would not degrade existing levels of service since both roadways are lightly used and traffic volumes, even during construction of the SEPV Dixieland Projects, would be well below the capacities of the roadways. No capacity-related traffic impacts are anticipated as a result of either the construction phase or build-out and operation of the SEPV Dixieland East and West projects. Traffic Assessment for the Proposed SEPV Dixieland East and West Projects Prepared for SEPV Imperial, LLC George Dunn Engineering 12