1 Arvin - Bear Mountain Blvd. Site Replacement Request This request provides documentation that the Arvin

- Di Giorgio ( U.S. EPA A ir Q uality S ystem Site ID 060295002) monitoring site is the replacement for the Arvin

- Bear Mountain Blvd. ( Site ID 060295001) monitoring site. Detailed site information for Arvin

- Bear Mountain Blvd. and Arvin

- Di Giorgio can be found in the San Joaquin Valley Air Pollution Control District’s 2010 and 2015 Air Moni toring Network Plans, respectively. History of the Arvin - Bear Mountain Blvd. Monitoring Site Arvin

- Bear Mountain Blvd. began collecting ozone data in June of 1989. The site was located at 20401 East Bear Mountain Blvd., approximately 2.5 miles east of th e town of Arvin. The inten ded purpose was as a high site for the Bakersfield M etropolitan S tatistical A rea

. Figure 1 : Ozone Monitoring Sites in the Bakersfield M etropolitan S tatistical A rea 1

Arvin

- Bear Mountain Blvd. operated continuously for 21 years. During that time, the highest 8

- hour and 1

- hour ozone design values and number of exceedance days in the Bakersfield Metropolitan Statistical Area generally occurred at either Arvin

- Bear Mountain Blvd. or one of its neighboring sites, Edison ( Site ID 060290007).

1 Exclusive of the Mojave

- 923 Poole Street site, which is 55 miles east

- southeast of Bakersfield in the Eastern Kern Nonattainment Area

.2

Arvin

- Bear Mountain Blvd. was designated a State/Local Air Monitoring Station (SLAMS) site. Throughout its existence, in addition to hourly ozone data, the site collected hourly nitrogen dioxide, hourly nitric oxide, and hourly oxides of n itrogen data. Starting in July of 1995, Arvin

- Bear Mountain Blvd. also collected canister

- based 3

- hour non - methane organic compounds (every 12 days)

. Arvin - Bear Mountain Blvd. Characteristics Arvin

- Bear Mountain Blvd. was located in a rural

- agricultural area at the Arvin

- Edison Water Storage District facilities at 20401 East Bear Mountain Blvd. (see Figure 2 below). Other than these facilities, there is no urban development nearby. Local land use is agriculture, with vineyards to the south and east, orc hards to the north , and vacant land to the west . Local topography is flat, with rising foothills approximately 1.5 miles to the southeast. The ozone monitor at Arvin

- Bear Mountain Blvd. was designated as a " neighborhood scale" monitor. Under Appendix D to 40 CFR §58, a neighborhood scale monitor “ D efines concentrations within some extended area of the city that has relatively uniform land use with dimensions in the 0.5 to 4.0 kilometers range. The neighborhood and urban scales

. . . have the potential to overlap in applications that concern secondarily formed or homogeneously distributed air pollutants. ” Figure 2 : Arvin - Bear Mountain Blvd. Monitor Location3

Lease Termination In July of 2009, the Arvin

- Edison Water Storage District notified the A ir R esources B oard that it was letting the lease that allowed ARB to operate Arvin

- Bear Mountain Blvd. on the Water Storage District's property expire on August 31, 2009. The Water Sto rage District directed ARB to remove its equipment from the site by that date. ARB immediately began a search for a replacement site. 40 CFR §58.14(c)(6) states, " A SLAMS monitor not eligible for removal under any of the criteria in paragraphs (c)(1) through (c)(5) of this section may be moved to a nearby location with the same scale of representation if logistical problems beyond the State's control make it impossible to continue operation at its current site. " As a result, ARB staff initiated a syst ematic and intensive search for potential replacement site locations that were as nearby as practical considerations allowed and had the same spatial scale of representat i on

. ARB also communicated with the Water Storage District with the goal of keeping A rvin

- Bear Mountain Blvd. in operation. Despite these efforts, the Water Storage District chose to terminate the lease and have the monitoring equipment removed from their property. Officials from the San Joaquin Valley Air Pollution Control District succ essfully negotiated with the Water Storage District to allow Arvin

- Bear Mountain Blvd. to remain in operation for another year to allow parallel monitoring with the replacement site. By mid

- November 2009, Arvin

- Di Giorgio (the chosen replacement site) beg an operation. Arvin

- Bear Mountain Blvd. sh ut down on November 1, 2010, allowing for almost a year of parallel ozone monitoring at the two Arvin sites. Replacements Considered As part of the site replacement evaluation process, ARB staff reviewed ARB siti ng criteria (see http://www.arb.ca.gov/airwebmanual/aqsbdocs1/V2/v2sec2.0.4.pdf , section 2.0.4.4), generated meteorological and air quality statistics, reviewed topographical and satellite image maps to characterize Arvin

- Bear Mountain Blvd

. and the surrou nding area . ARB staff considered the local topography and land uses, emissions sources, nearby traffic counts, and the predominant wind direction coinciding with high ozone concentrations. Staff compared 1

- hour ozone data and wind direction at Arvin

- Bear Mountain Blvd. for the most recent complete (2008) ozone season (May through October) to determine predominant wind direction during 1

- hour ozone exceedances , shown below in Figure 3. The unshaded portion of Figure 3 represents those 1

- hour concentrations that exceeded the 1

- hour ozone standard (i.e., they were above 0.124 ppm). With the exception of two outliers that were just above the standard, all the exceedance days fell between about 260 degrees ± 30 degrees. In other words, the predo minant wind during exceeding 1

- hour ozone concentrations was coming from slightly south of west, with a small spread around that direction. The highest 8

- hour averages would occur under similar wind conditions as the highest 8

- hour averages will always in clude the highest 1

- hour measurements.4 Figure 3 : 1 - Hour Ozone Concentration vs. Wind Direction at Arvin - Bear Mountain Blvd. , 2008 Ozone Season

Staff did an initial search for possible replacement sites using these criteria: 1. The site was within five miles of Arvin

- Bear Mountain Blvd. , 2. The site had, at a minimum, electricity potentially available without the additional delay of adding new power poles, and 3. The site had space where a monitoring structure could be set up. Accordi ng to the aforementioned regulations, it was imperative that a replacement monitor be placed in a nearby location. A RB performed the extensive search for a replacement site within a five mile radius of the Arvin

- Bear Mountain Blvd. monitor. ARB staff initially identified 31 possible replacement sites, which included businesses, schools, farm structures , farm outbuildings, and irrigation infrastructure , as shown in Figure 4

.5

Figure 4 : Locations of the 31 Possible Replacement Sites Considered

The yellow circle in this figure defines a five

- mile radius around Arvin

- Bear Mountain Blvd.

Arvin

- Di Giorgio , the selected replacement, is Site 20 in this F igure. ARB staff then further reviewed each possible site for compliance with the following crite ria: 1. The potential site was located on public property (i.e., land controlled by a Federal, State, County, City, or Municipal entity) 2

. 2. A long

- term lease was likely to be achieved. 3. The monitoring equipment could be put into operation quickly (no long delays from developing site infrastructure, such as adding new power poles, for example). 4. The surrounding land use and topography was similar to that at Arvin

- Bear Mountain Blvd. 5. There was a lack of impact from local NOx (oxides of nitrogen) sources 3

. 6. Ther e was a lack of impact from urban Arvin sources 3

. Due to the lease termination at Arvin

- Bear Mountain Blvd. which resulted in a forced shutdown and the fact that Arvin

- Bear Mountain Blvd. was a maximum concentration site, the most important features of a nearby replacement site were that it have a similar scale of representation, it be located on public property , and that a long

- term lease was

2 The Arvin

- Edison Water Storage District is recognized as a “special district , ” or a separate local government that delivers public services to a particular area. Special districts primarily rely on local revenues and are only accountable to the voters or landowners they serve. See the Special Districts Annual Report from the State Controller’s Office for more information. 3 These criteria addressed concerns that NOx scavenging effects could potentially lower ozone concen trations.6

feasible. The same scale of representation means that the replacement site should not only have similar land use and surface characteristics, but also that it measure concentrations from similar sources to those near Arvin

- Bear Mountain Blvd. The need for the same scale of representation at the replacement site was met by the last three criteria listed above. Staff evaluated each of the possible sites against the criteria stated above . Many of the 31 sites failed to meet all the criteria and were eliminated. Some sites met most of the criteria and received further evaluation. ARB staff determined that only Sites 19 and 20 met all the criteria. The following list describes each of the sites and the outcome of each evaluation

. Site 1: Irrigation Equipment approximately 0.3 miles east of Arvin

- Bear Mountain Blvd. on East Bear Mountain Blvd

. (Latitude: 35.209 587, Longitude:

- 118.771 ) . The site was eliminated because it was not on public property and concern s about the long

- term viability of the site. Site 2: Farm Structures approximately three

- quarters of a mile east

- northeast of Arvin

- Bear Mountain Blvd. , no rth of East Bear Mountain Blvd. on a farm road (35.211685,

- 118.76203) . The site was eliminated because it was not on public property and concern s about property access and the ability to obtain a long

term lease. Site 3: Farm Structures on Richardson Road, 0.1 miles west of Rockpile Road (35.216284,

- 118.7898) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 4: Farm Structures on Richardson Roa d halfway between Tower Line Road and Rockpile Road (35.216396,

- 118.797449) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 5: Farm Structures, on Sunset Blvd. halfway betwee n Tower Line Road and Rockpile Road (35.223558,

- 118.796953) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 6: Farm Storage Yard at the southwest corner of Russell Street and Tower Line Road (35.230073,

- 118.807527) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease and the difficulty of obtaining electricity. Site 7: Farm Structures on Russell Street, 0.2 miles west of Rockpile Road (35.230873,

- 118.79177) . The site was eliminated because it was thought not to be on public property and concern s about the ability to obtain a long

- term lease. Site 8: Farm Structures on Russell Street, one

- half mile east of Rockpile Road (35.224096,

- 118.778986) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 9: Farm Structures on Sunset Blvd., one

- half mile east of Rockpile Road (35.230108,

- 118 .779772) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease.7

Site 10: Farm Structures on Sunset Blvd., one mile east of General Beale Road (35.224311,

- 118.735217) . The site was elimi nated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 11: Irrigation Facility at the southwest corner of Russell Street and General Beale Road (35.23118,

- 118.753273) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 12: Irrigation Facility on Russell Street, one

- half mile east of General Beale Road (35.23121,

- 118.744222) . The site was eliminated because it was not on publi c property and concern s about the ability to obtain a long

- term lease. Site 13: Irrigation Facility on Russell Street, one mile east of General Beale Road (35.231257,

- 118.735693) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 14: Farm Storage Yard at the northeast corner of Buena Vista Blvd. and General Beale Road (35.238549,

- 118.752283) . The site was eliminated because it was not on public property and concern s about the a bility to obtain a long

- term lease and the difficulty of obtaining electricity. Site 15: Farm Structure on Buena Vista Blvd., one

- half mile west of General Beale Road (35.238305,

- 118.756952) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 16: Farm Structure on farm road, one

- quarter mile south of Buena Vista Blvd. and one - half mile west of General Beale Road (35. 235888,

- 118.761756) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 17: Farm Structures on farm road, one

- quarter mile south of Russell Street and one - half mile west of Gener al Beale Road (35.227603,

- 118.761236) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 18: Irrigation Facility on Russell Street at irrigation canal crossing (35.231308,

- 118. 774048) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 19: Di Giorgio Elementary School property at the southeast corner of Buena Vista Blvd. and Rockpile Road (35.23707,

- 11 8.787349) . This site met all criteria, al though there was concern about the potential for vehicular emissions from the school's parking lot and student drop

- off area, which could lead to reduced ozone levels due to NOx scavenging. This site is approximat ely 2.1 miles northwest of Arvin

- Bear Mountain Blvd. Adjacent land uses are the school facilities directly to the north, orchards north of that, vineyards to the west and northwest, and unused land to the south. T he t opography is flat. Site 20: Di Giorgio Elementary School property at the northwest corner of Buena Vista Blvd. and Rockpile Road (35.239197,

- 118.788637) . This site met all criteria. The site is approximately 2.2 miles northwest of Arvin

- Bear Mountain Blvd. , 0.1 miles northwest of Di Giorgio Elementary School, but still on school

- owned property. Adjacent land uses are vineyards to the west and north, orchards to the east and southwest, and the school to the southeast. T he t opography is flat.8

Site 21: Farm Structures off of Buena Vista Blvd. , one - quarter mile west of Tower Line Road, adjacent to the irrigation canal (35.237504,

- 118.809467) . The site was eliminated because it was not on public property and concern s about property access and the ability to obtain a long

- term lease. Site 22: W inery Buildings at the southeast corner of Bear Mountain Winery Road and Palmora Drive (35.257592,

- 118.833353) . The site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Site 23: Arvin High School at the northwest corner of Varsity Road and Campus Drive (35.218487,

- 118.835225) . This site is approximately 3.4 miles west

- northwest of Arvin

- Bear Mountain Blvd. near the northern urbanized edge of Arvin. Adjacent land uses are urbanized develop ment to the south and agriculture to the west, north, and east. As a school

- owned property, there was the possibility for a long

- term lease. In addition, infrastructure (electricity and security) were present. This site met most criteria, except for a c oncern of being impacted by urban emissions from the city of Arvin and by local vehicular emissions. Site 24: Golf Course, directly east of the intersection of Kenmar Lane and Frick Road (35.165317,

- 118.812206) . This site is approximately 3.4 miles south west of Arvin

- Bear Mountain Blvd. on the grounds of a privately owned golf course. It was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. The golf course is no longer in operation. Site 25: Sch ool in Arvin at 1501 Hood Street in Arvin (Bear Mountain Elementary School) (35.202614,

- 118.839284) . This site is approximately 3.6 miles west of Arvin

- Bear Mountain Blvd. within the urbanized area of Arvin. It was eliminated because adjacent land use i s urbanized development in all directions , with parking areas near the proposed site. Local automotive emissions were likely to negatively impact an ozone monitor located there due to NOx scavenging. Site 26: Office Complex at 1305 Bear Mountain Boulevard (35.208802,

- 118.839314)

. This site is approximately 3.6 miles west of Arvin

- Bear Mountain Blvd. at the western urbanized edge of Arvin. It was eliminated because adjacent land uses are urbanized development in all directions, specifically residential use to the north and south, and light commercial uses (stores and offices) to the east and west. The site is located on the area's major east

- west thoroughfare. Local automotive emissions were likely to negati vely impact an ozone monitor located there due to NOx scavenging. Site 27: U.S. EPA Superfund Site at 600 South Derby Street in the city of Arvin (35.203117,

- 118.822618) . This site is approximately 2.7 miles west of Arvin

- Bear Mountain Blvd. on the groun ds of a former agricultural chemical manufacturer. The site was eliminated because of concerns about contamination, disruptions during remediation, and the ability to obtain a long

term lease. It is also notable that adjacent land use

— manufacturing and u rban development

— was significantly different from that at Arvin

- Bear Mountain Blvd. Site 28: El Camino Real Elementary School at 911 El Camino Real in the city of Arvin (35.185437,

- 118.835039) . This site is approximately 3.7 miles west

- southwest of Arvin

- Bear Mountain Blvd. on Arvin city

- owned property. This site was9

eliminated because nearby dirt fields caused concerns about it not meeting U.S. EPA siting criteria for particulate matter (at the time ARB staff was considering placing a PM monitor at the replacement site, but that did not come to fruition). In addition, the area was scheduled for development, raising concerns about ongoing suitability of the site. Adjacent land uses were the school to the east, vacant land to the west and south, and urba n development to the north. Site 29: South Arvin at approximated 4000 Blue Loop Lane (35.173944,

- 118.829969)

. This site is approximately 4 miles to the southwest of Arvin

- Bear Mountain Blvd. in a private, gated community between two artificially created skiing lakes. The site was eliminated because it was not located on public property, concerns about the ability to obtain a long

- term lease, and the need for the community board's continuing approval for occupying the property. Site 30: Corner Lot at the northwest corner of El Camino Real and Tejon Highway (35.187408,

- 118.824544) . This site is one

- half mile east of the El Camino Real Elementary School site on land scheduled for development. It was eliminated because of concerns about unsuitable local la nd use (urban development to the north and west) and its unsuitably as a long

- term site, given that it could be developed at any time. Site 31: Carrot Packing Facility at 830 Sycamore Road (35.196136,

- 118.816887) . This site was eliminated because it was not on public property and concern s about the ability to obtain a long

- term lease. Selected Site After reviewing all 31 possible replacement sites, staff determined that the two Di Giorgio Elementary School sites (Sites 19 and 20) were the only sites that met all of the search criteria. The second Di Giorgio site

— Site 20 in the list above

— was chosen as Arvin

- Bear Mountain Blvd. 's replacement

. ARB staff judged Site 20 to be preferable to Site 19 because it was farther removed from the school's parking and drop

- off lots and thereby would be less impacted by local vehicular emissions. Site 20 was immediately available for lease and had readily available electricity. Land uses adjacent to Site 20 are similar to those at Arvin

- Bear Mountain Blvd. , with both sites (i.e., Arvin

- Bear Mountain Blvd. and Arvin

- Di Giorgio ) being surrounded by agricultural fields and having a light urban use (offices at Arvin

- Bear Mountain Blvd. , a school at Arvin

- Di Giorgio ) nearby in approximately the same relative position. Local topography at Arvin

- Di Giorgio is essentially identical to that at Arvin

- Bear Mountain Blvd. Predominant wind direction and nearby traffic counts are similar at both sites

. Arvin

- Di Giorgio is located on public property and was established to be a long

- term site with the same scale of representation

. Arvin

- Di Giorgio was also the second closest public property site of those considered, being only 2.2 miles (3.5 km) away. ARB therefore pursued a formal lease only for Arvin

- Di Giorgio

.10 Figure 5 : Arvin - Di Giorgio Monitor Location

Given Arvin

- Bear Mountain Blvd. 's and Arvin

- Di Giorgio 's similar adjacent land use s and the sites' proximity to each other, the expected emissions impacts on both sites were similar. Thus, it was anticipated that Arvin

- Di Giorgio would produce similar data to that of Arvin

- Bear Mountain Blvd. B oth ozone monitors are designated as " neighborhood scale" monitors. Arvin

- Di Giorgio started collecting ozone data on November 16, 2009. Arvin

- Di Giorgio and Arvin

- Bear Mountain Blvd. operated in parallel from that date until October 31, 2010 when Arvin

- Bear Mountain Blvd. was permanently shut down. The parallel data show that 1

- hour and 8

- hour ozone daily maxima during the May through October 2010 ozone season were on average 6

- 7 parts per billion lower at Arvin

- Di Giorgio than at Arvin

- Bear Mountain Blvd. Conclusion Based on 2009 Evaluation At the time of relocation, ARB staff concluded that Arvin

- Di Giorgio was the best available site to replace Arvin

- Bear Mountain Blvd. Staff found that Arvin

- Di Giorgio was as similar a site to Arvin

- Bear Mountain Blvd. as was possible to achieve. Arvin

- Di Giorg io met all the criter ia for proximity, permanence (i.e., on public land with a long

- term lease available ), similar land use, existing infrastructure, predominant wind direction, lack of impact from local NOx sources , and topography. Given the similarities between Arvin

- Bear Mountain Blvd. and Arvin

- Di Giorgio , it was also expected they would produce similar ozone data. Additionally, Arvin

- Di Giorgio was located in close proximity to a school. Because children are extremely vulnerable to the adverse effec ts of air pollution, Arvin

- Di Giorgio was seen as a favorable location since it would11

represent this sensitive segment of the population. ARB staff's comprehensive search for an alternative found no other site in the area that would have been a more suitable replacement for Arvin

- Bear Mountain Blvd. Subsequent Actions and Evaluations The information presented above represents what was known and available at the time that ARB staff was performing the initial search for a replacement site for Arvin

- Bear Mountain Blvd. in 2009. Activity surrounding the Arvin

- Bear Mountain Blvd. site did not end in 2010 when the site was shut down and Arvin

- Di Giorgio was established. ARB continued efforts to put an ozone monitor back at Arvin

- Bear Mountain Blvd. in the years following. However , the Water Storage District was not amenable and those attempts were unsuccessful. In 2011, the San Joaquin Valley A ir Pollution Control District contacted the farmer who owned the land north of Bear Mountain Blvd., directly across from the Water Storage District facility and the previous Arvin

- Bear Mountain Blvd. site. The farmer expressed interest in allowing an air monitor on his property. In the 2009 review , ARB staff had considered this property (Site 1 listed above is located on this property )

. However, similar to the 2009 assessment , ARB did not further pursue this location because a site on the farmer's proper ty would not satisfy the first two site selection criteria regarding placement on public property and the potential for a long

- term lease. In 2013, the San Joaquin Valley Air Pollution Control District contracted with Sonoma Technology, Inc. to conduct a “saturation study” in which 23 temporary ozone sensors were deployed in and around the Arvin area for a six

- week period. Two of the main goals of the study were : 1) to examine ozone gradients and behavior around the Arvin area and 2) to provide supporting information to ARB, U.S. EPA, and the San Joaquin Valley Air Pollution Control District for decisi ons related to monitoring in that region

. The study did not identify any potential alternative site locations to Arvin

- Bear Mountain Bl vd. or Arvin

- Di Giorgio that met ARB's site replacement criteria stated above. In 2015, ARB staff again reviewed the possible replacement sites that were considered in 2009. Staff found that all sites were as described in 2009, except that Site 7 was fou nd to be on public property. Site 7 is currently occupied by the California Department of Food and Agriculture Arvin Field Station. Given that Site 7 and Arvin

- Di Giorgio have similar surrounding land uses and are approximately the same distance (1.8 and 2.2 miles , respectively) and direction (north

- northwest) from Arvin

- Bear Mountain Blvd. , ARB staff expect that there would be no difference in ozone measurements taken at Site 7 and Arvin

- Di Giorgio and that any relationship between Arvin

- Bear Mountain Bl vd. and Arvin

- Di Giorgio would also apply to Arvin

- Bear Mountain Blvd. and Site 7. In late 2015, ARB staff became aware of another potential location near Arvin

- Bear Mountain Blvd. for a replacement ozone site

. The Tejon Ranch Conservancy controls proper ty approximately 0.3 miles east of Arvin

- Bear Mountain Blvd. The Tejon Ranch Conservancy , while not a government entity , is an independent non

- profit organization12

formed by an agreement between the Tejon Ranch Company, Audubon California, the Endangered Habitats League, the Natural Resources Defense Council, the Planning and Conservation League, and the Sierra Club

.

Figure 6 : Proposed Tejon Ranch Conservancy Monitor Location

ARB, in consultation with U.S. EPA, pursued the possibility of e stablishing a replacement for Arvin

- Bear Mountain Blvd. on th e Tejon Ranch Conservancy property. In March 2016, ARB's Monitoring and Laboratory Division contacted Tejon Ranch Conservancy formally requesting permission to establish an ozone monitoring site on the property (see A ttachment 1 ). Tejon Ranch Conservancy replied shortly thereafter that it would not be possible to use Tejon Ranch Conservancy land for that purpose ( see A ttachment 2 ). Conclusion In 2009 , given the criteria listed above, ARB staff concluded that Arvin

- Di Giorgio was the best available site to replace Arvin

- Bear Mountain Blvd , in accordance with 40 CFR §58.14(c)(6)

. Since then, staff has re evaluated other possible locations, namely Site 1, Site 7 and the Tejon Ranch Conservancy property. Site 1 continues not to meet replacement site criteria. Site 7 reflects the same conditions as Arvin

- Di Giorgio, so is expected to produce similar ozone measurements as Arvin

- Di Giorgio . The Tejon Ranch Conservancy property proved to be unavailable. ARB staff's conclusion has therefore not changed: the ongoing and comprehensive search for a replacement site meeting the criteria listed above with the same scale of representation as Arvin

- Bear Mountain Blvd. found no other site in t he area that would13

have been a more suitable replacement for Arvin

- Bear Mountain Blvd. than Arvin

- Di Giorgio

.