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V RU* Tracy Rural County Fire Protection District R (209)834-7269 793 S.Tracy Blvd.#298 www.tracyruralfire.org u� Tracy,CA 95376 Study of All Alternative Technologies. The NOP states that"(i)individual" lithium-ion, or similar technology, battery cells from the core of the energy storage system."We expect that the EIR will study the environmental impacts and fire service requirements of each different battery/energy storage technology that could be a part of the "core of the energy storage system." Different technologies (i.e., other than lithium-ion batteries) could have different fire hazard and environmental impacts and different mitigation requirements. Study of Fire Hazards Associated with Battery/Storage Technologies and Mitigation. Determinations of levels of fire hazards of battery/energy storage technologies still are in the early stages. There have been catastrophic fires associated with such facilities using lithium-ion batteries, such as a major 2019 incident in Surprise, Arizona. Since we have limited information and details about the technology proposed for the project, it is difficult at this point to identify all potential fire hazards and risks. As an example of the seriousness of the fire hazard posed by Energy Storage Systems, enclosed for your reference is a bulletin from the International Association of Fire Chiefs (IAFC Bulletin, "Recommended Fire Department Responses to Energy Storage Systems (ESS) Part 1" dated August 1, 2022). The bulletin suggests that battery fires should be allowed to burn themselves out while applying water spray to neighboring battery enclosures and exposures in efforts to limit the spread of the fire. The environmental impacts of such an approach should be addressed. It is obviously vital that the County actually identify the precise fire hazards associated with the various technologies in order to properly mitigate fire risk. The facility will require an appropriate fire suppression plan. The facility will require an adequate and reliable water supply to fight fires as well as roads for fire apparatus to reach the facility. Since addressing fire risk in ESS is a still-evolving matter, the County should build in requirements that state-of-the-art conditions and mitigation measures can be imposed on an ongoing basis to properly address the significant health and safety risks. Wildfires. The new map of the State Responsibility Area Fire Hazard Severity Zones for San Joaquin County dated November 21, 2022 (copy attached) states the project location is in the High Fire Hazard Severity Zone. The hazard severity seems to have increased from the previous hazard ranking of"Moderate"which still appears on the San Joaquin County parcel data information when using the information at the www.sjmap.org/DistrictViewer/website. The EIR should study wildland fire issues as delineated in Section IX of Appendix G of the state's CEQA Guidelines and also whether introduction of the proposed battery storage use in the High Fire Hazard Zone functionally transforms it into a Very High Fire Hazard Zone requiring additional study under Section XX of Appendix G. The dry nature of the terrain in the summer with its flammable vegetation and high winds should be part of the analysis. Page 12