Banning City Council
February 26, 2026

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by the City’s development review process, any such development would be evaluated for wildfire safety when a proposed for physical development of VHDR units is proposed to the City.

Future proposals for development within the MSJC Site would be subject to adopted federal, State, and local development guidelines in existence at that time that govern wildfire, emergency services, and emergency access, including Chapter 8.16 of the City’s Municipal Code (which, as amended by the City, incorporates the current California Building and Fire Codes). Furthermore, the City adopted the Multi‐Hazard Functional Guidance document in 1996 and the Emergency Operations Plan in July 2007 (updated in 2012) both of which provide guidance for residents, City emergency responders, and businesses in the event a man‐made or natural emergency occurs within the City or threatensthe City.

Future development within the RSG project located directly south of the MSJC Site, may alter the nature of fuel and wildland fire potential, fire behavior, and the potential for exposure to wildfire pollutants on the MSJC Site. Should development on the RSG project proceed in advance of MSJC Site development, fuel modification zones stipulated in the RSG project would provide buffer any future MSJC Site development. To address the specific wildland impacts to the MSJC Site, a development specific Fire Protection Plan (FPP) will be required to identify the condition and wildland fire potential at the time MSJC Site development occurs. Such a FPP Plan would conform to City and RCFD21 requirements. This requirement is detailed in MSJC Site MM WLD‐1. Furthermore, MSJC Site MM WLD‐2 requires the submittal of evidence that the protective features and preventative measures are fully and appropriately implemented into the design and construction of any development occurring on the MSJC Site prior to the issuance of construction permits. Adherence to these measures will ensure potential wildfire impacts related to potential future VHDR development on the MSJC Site are reduced to a less than significant level. Because adoption of the proposed MSJC Entitlements will not result in any physical changes on the site, no impact related to this issue will occur (Draft EIR Section

5.4.20.2).

Adoption of the proposed MSJC Entitlements will not result in any construction of residential units or the installation of infrastructure that would exacerbate wildfire risk. Utility and infrastructure improvements required to facilitate residential development of the MSJC Site would include water, wastewater, drainage, roadway, and electrical transmission features. A new circulation system internal to the MSJC Site and connectionsto adjacent roadways would be provided. Utilities, including waterfacilities,sewerfacilities,storm drain lines, and powerlines would be modified and/or extended throughout the MSJC Site. All utility lines, pipes, utility junction boxes, and transformers would be located underground and would not exacerbate fire risk. Design and implementation of utility and roadway improvements on the MSJC Site would be reviewed and approved by the City’s Public Works Department as part of the development review, ensuring any proposed uses are compliant with all applicable fire codes, design standards, and regulations. Compliance with these standards would ensure a less than significant impact would occur. (Draft EIR Section 5.4.20.2). 21   To include compliance with applicable portions of the Riverside County Fire Code (Chapter 8.32 of County’s Code of Ordinances) and Ordinances No. 460 and No. 787‐9, and the City of Banning’s Fire Protection Code (Chapter 8.16 of the City’s Municipal Code). where the Riverside County Fire Code and Banning Fire Protection Code differ, the most restrictive requirements are typically implemented. 638

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Adoption of the proposed MSJC Entitlements will not result in any exposure of people or structures to post‐fire risks, including downslope or downstream flooding or landslides, slope instability, or drainage changes. Design and implementation of improvements on the MSJC Site would be reviewed and approved by the City’s Public Works Department as part of the development review, ensuring any proposed uses are compliant with all applicable fire codes, design standards, and regulations.

Compliance with these standards would ensure a less than significant impact would occur.

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9.0 FINDINGS REGARDING CUMULATIVE IMPACTS
The cumulative impacts of the Project are analyzed in Chapter 6.0 of the Draft EIR. Asstated in Chapter

6.0, the Project is comprised of the following components:
a. The Development Project, consisting of the proposed commercial and industrial development of a 533.8‐acre property (Development Site) located in part in the City of Banning (City) and in part in the City’s Sphere of Influence (SOI) in unincorporated Riverside County (County), California, which is proposed to be entitled through, among other things, adoption of the Sunset Crossroads Specific Plan (Specific Plan) and a City project for a reverse osmosis facility on the Development Site that is analyzed in this EIR; and
b. The Mt. San Jacinto College (MSJC) Entitlements, pursuant to which the City proposes to rezone an approximately 41 ‐acre property located adjacent to the Development Site, east of Sunset Avenue and south of Westward Avenue and owned by the Mt. San Jacinto Community College District22 (MSJCCD) (MSJC Site) to very high‐density residential development, creating capacity for up to 1,181 housing units to ensure no net loss of residential capacity asrequired under State law.

Because the MSJC Entitlements propose no development and would not result in physical changes to the environment and would only allow for the potential future development of the MSJC Site, no physical environmental impacts, and thus no cumulative impacts, would result from the MSJC Entitlements action. However, buildout is anticipated by 2045, and the cumulative impacts, if any, that could occur with future physical development of the MSJC Site are considered in this chapter.

The impacts associated with the construction and operation of the Project are addressed in Chapter

4.0 (Development Project) and Chapter 5.0 (MSJC Entitlements) of the Draft EIR. The Development Project and the MSJC Entitlements are referred to collectively in the EIR as the Project, and the Development Site and MSJC Site are collectively referred to as the Project Sites. The cumulative impact analysis considered development of the Project in conjunction with other development projects and planned development as detailed in Table 6.B and Figure 6‐1 of the Draft EIR, including a number of planned developments in the cities of Banning and Beaumont that have been identified as cumulative projects. The list of cumulative projects was developed through consultation with planning and engineering staff from the City of Banning and the City of Beaumont which shares a common street network with the City of Banning and would generate traffic and contribute traffic to the study area intersections.

9.1 AESTHETICS
Impact Statement: The Project would not result in cumulatively considerable impacts related to aesthetics.
22   In collaboration with the Beaumont Unified School District, MSJC is housing the Beaumont Middle College High School at the San Gorgonio Pass Campus. The middle college high school is designed to raise graduation rates, prepares students for transfer to a 4‐year institution or an associate degree, and serves underrepresented students.
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Finding
Potential cumulative impacts of the Project related to aesthetics are discussed in detail in Section

6.5.1 of the Draft EIR. The City finds that the development the Project would not result in significant cumulative impacts related to aesthetics; therefore, no mitigation is required.

Substantial Evidence
The Project’s potential to result in cumulatively considerable visual quality impacts would be limited locally to the City of Banning and immediate adjacent areas of unincorporated Riverside County. The Project and related public facility projects (i.e., the SLB Extension) would occur in the same general area as the Project and are not likely to be separately discernable. Other construction activities associated with the cumulative projects would be of limited duration and scale; would be dispersed throughout the City or in the City of Beaumont, and would likely not occur simultaneously; therefore, it is reasonable that construction activity itself would not result in cumulative aesthetic impacts.

With respect to scenic resources in the viewshed of the Project and the cumulative projects, the Caltrans Scenic Highway Program identifies State Route 243 (SR‐243) (approximately 2 miles east of the Development Project) between I‐10 and State Route 74 as both an Eligible and Officially Designated State Scenic Highway.23 At lower elevations, views of the Project Sites and the cumulative projects are either limited or obscured from SR‐243. From higher elevations along SR‐243, expansive views of the cumulative area would be visible. While cumulative development would be visible, the extent of other projects relative to viewshed available from SR‐243 is limited; therefore, impacts would not be cumulatively considerable.

Due to the topography, the intervening presence of existing development and landscaping, and the visual barrier of I‐10, views of the cumulative project area are generally limited. The City has not designated any portion of the Development Site or the MSJC Site as a scenic resource. Future development within the viewshed of I‐10 will continue to expand as structures, infrastructure, and lighting associated with the Project and cumulative projects are installed and occupied. The City’s General Plan EIR recognizes development activity will result in changes to the visual character throughout the City resulting from modifications to existing vegetation and topography, and the development of new structures/facilities. Any development in the City and the cumulative area would adhere to the applicable General Plan, zoning, and specific plan regulations and development standards, including those related to the design and orientation of buildings, amenities, landscaping, signage, and lighting, which would ensure the specific aesthetic impacts from cumulative projects are appropriately addressed. Cumulative projects located in the City of Beaumont would likewise be required to adhere to the City of Beaumont’s applicable General Plan, zoning, and specific plan regulations and development standards to ensure the specific aesthetic impacts from cumulative projects are appropriately addressed. Future development within the viewshed of I‐10 will continue to expand as structures, infrastructure, and lighting associated with the Project and cumulative projects are installed and occupied. In addition, future development, including at the MSJC Site, would be required to undergo its own review pursuant to CEQA, which may require mitigation measures to 23   California Department of Transportation (Caltrans). n.d. Scenic Highways. Website: https://dot.ca.gov/ programs/design/lap‐landscape‐architecture‐and‐community‐livability/lap‐liv‐i‐scenic‐highways (accessed August 31, 2023).
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reduce aesthetic impacts. The General Plan and City Municipal Code would regulate design of the anticipated development of the Project and the cumulative projects within the respective cities; therefore, the Project would result in a less than significant impact to aesthetics when measured cumulatively with future development of cumulative projects. Additionally, the Specific Plan would regulate the design of the Project to be consistent with the guidelines and standards established in the General Plan and Municipal Code; therefore, the Project would not result in a significant aesthetic impact and its aesthetic effect is not cumulatively considerable. It is reasonable to anticipate that any development in the cumulative area would adhere to the applicable General Plan,zoning, and specific plan regulations and development standards, including those related to the design and orientation of buildings, amenities, landscaping, signage, and lighting, which would ensure the specific aesthetic impacts from individual projects are appropriately addressed.

To contribute to cumulative light or glare impacts, cumulative projects must be located in the same field of view as the Project. As such, impacts with respect to light and glare are typically localized. To the extent of the Project’s proximity to the cumulative projects or with respect to proximity of the Development Site and MSJC Site, there exists the possibility for the Project to result in a cumulative light and glare impact. As a project design feature, lighting on the Development Site would follow the standardsidentified in the Specific Plan (see Draft EIR, Appendix B, Sections 3.1 and 4.3.9). Any cumulative development would be required to comply with existing lighting regulations under the City’s Municipal Code Sections 17.12.170 and 17.24.100, or the provisions of their respective Specific Plans, which encourage the minimum amount of lighting required for safety and security, appropriate shielding of all lighting, the integration of lighting into buildings where possible, and the incorporation of features to confine light spread to the boundaries of a development site. As with the Project, potential light or glare generated by cumulative projects would also be regulated by City Municipal Code and design requirements and would not be anticipated to occur, and no cumulatively considerable impact would result.

As detailed in Sections 4.1 and 5.4.1.2 of the Draft EIR, the Project’s potential visualresource/aesthetic impacts would be less than significant. Section 6.0 of the Draft EIR identifies other planned developments in the City, including the Rancho San Gorgonio Specific Plan (RSG), Sun Lakes Village North (e.g., Banning Pointe) project (SLVN), and Butterfield Specific Plan (e.g., Atwell) (BSP. These cumulative projects are subject to the siting and design guidelines enshrined in their respective Specific Plans and/or the City code. The implementation of City design, siting, and development standards at a project‐level basis would ensure the incremental aesthetic effect of other projects would not be cumulatively considerable. The related public facilities are typical of public improvements in an existing urban environment, and development of these facilities would not directly or cumulatively adversely affect the visual character or obstruct view to, from or through the Sites.

9.2 AGRICULTURAL AND FORESTRY RESOURCES
Impact Statement: The Project would not result in cumulatively considerable impacts related to agricultural and forestry resources.
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Finding
Potential cumulative impacts of the Project related to agricultural and forestry resources are addressed in Section 6.5.2 of the Draft EIR. The City finds that the development of the Project would not result in significant cumulative impacts related to agricultural or forestry resources; therefore, no mitigation is required.

Substantial Evidence
The Project’s potential to result in a cumulatively considerable impact to agricultural and forestry resources is limited to the City of Banning and Riverside County. No Prime, Unique, or Statewide Important Farmland (collectively Important Farmland), which CEQA identifies asthe types of farmland to assess in the Appendix G threshold of significance 1a, is located within the City of Banning or within adjacent areas of unincorporated Riverside County, or on the Project Sites, including within the alignment of the SLB Extension. Therefore, the Project would not contribute to the cumulative loss or conversion of Important Farmland to non‐agricultural use.

Neither the Development Site nor the MSJC Site are zoned for agricultural uses, or subject to the Williamson Act; therefore, the Project has no impact related to changes in agricultural zoning or Williamson Act designation. Accordingly, the Project would not have a significant cumulative effect on existing agricultural zoning/use and would not cumulatively effect Williamson Act lands.

While the Development Project will convert land designated as Farmland of Local Importance to a non‐agricultural use, the Development Site has notsupported agricultural uses, apart from occasional livestock grazing, since the early 1900s. Within the City there are 4,382 acres designated as Farmland of Local Importance, and the Farmland of Local Importance that will be developed as part of the Project is a small percentage of this total. Additionally, Riverside County contains approximately 221,201 acres of Farmland of Local Importance. Even if all of the cumulative projects were located on designated Farmland of Local Importance, loss of that acreage would be a small portion (1.9 percent) of the overall land designated as Farmland of Local Importance in the County. As detailed in the CEQA documents for the RSG, BSP, SLB Extension, SLVN, and other projects, those cumulative projects identified no impact related to agricultural and forestry resources or such impact has been determined to be less than significant; therefore, the incremental effects of the Project, when considered with the other projects cited in Table 6.A, would not result in a cumulatively considerable impact on Important Farmland.

The Project would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). No land in the City is zoned for forestry uses or used for forestry/timberland production; therefore, no change to or conflict with such uses/zones would result from cumulative development in the City. In absence of any conflict or change, no cumulative impact would occur.

The Project would not involve other changes to the existing environment which, due to location or nature, could result in conversion of Important Farmland to non‐agricultural use or conversion of forest land to non‐forest use. Therefore, the Project would not result in the indirect conversion of 644

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agricultural land to non‐agricultural use as a result of land use incompatibilities with adjacent land uses and no cumulative impact would occur.

9.3 AIR QUALITY
Impact Statement: The Project would result in cumulatively considerable air quality impacts for construction (VOCs) and operational regional emissions for VOC, NOX, CO, PM10, and PM2.5.

Finding
Under applicable SCAQMD standards, a project that individually has a significant air quality impact by exceeding regional emissions thresholds would also be considered to have a cumulatively considerable contribution to cumulative significant regional air quality impact. The potential cumulative impacts of the Project related to air quality are addressed in Section 6.5.3 of the Draft EIR.

The City finds that the development of the Project would result in cumulatively considerable air quality impacts due to an exceedance of pollutants in excess of established SCAQMD standards for VOC (both construction and operations), and NOX, CO, PM10, and PM2.5 (collectively, for operations), and inconsistency with the 2022 Air Quality Management Plan (AQMP). The City finds that project‐ related odors would be less than significant and there would not be a cumulatively considerable impact. With the implementation of Regulatory Compliance Measures (RCMs) AIR 1 through AIR‐4 and Mitigation Measures AIR‐1 and Air‐2, the City finds that the Project would have a less than significant cumulative impact related to exposure of sensitive receptors to concentrations of localized pollutants during construction and operations, and emissions during Project construction and operations would not exceed the cancer risk and chronic hazard index thresholds with implementation of the above‐referenced mitigation.24 For these two impact areas, because the Project does not have a significant impact under the relevant SCAQMD guidance, it would not contribute to a cumulatively significant impact.

Consistency with the AQMP is based on two criteria: (1) whether a project is consistent with the SCAG growth forecasts, which is based, in part, on the planned land uses in general plans of cities located within the SCAG region; and (2) whether a project would increase the frequency orseverity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. The Project requires General Plan amendments for the Development Project. Therefore, the City finds that the Project is not consistent with SCAG’s growth forecasts, and is not consistent with the first criterion. Asidentified in Section 4.3 of the Draft EIR, the Development Project’sregional construction emissions would result in an exceedance of volatile organic compounds(VOCs) after the implementation of mitigation. Under a conservative analysis assuming concurrent construction and operation of each phase of the Development Project (Final EIR, Revised Table 4.3.M), emissions would exceed the SCAQMD thresholds for all criteria pollutants except for sulfur oxides (SOx). Because the Development Project exceeds the regional thresholds of significance for VOC, NOX, CO, PM10, and PM2.5, the City finds that the Project is inconsistent with the AQMP and has a significant cumulative air quality impact. The City finds that the Project is required to comply with Mitigation Measures AIR‐1 AND AIR‐2, as revised in 24   A project specific air quality analysis for the MSJC Site would be required to confirm that SCAQMD RCMs would likely reduce potential impacts from construction and development of the VHRD uses to a less than significant impact.
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Final EIR, which are feasible, adopted, and will reduce cumulative air quality impacts attributable to the Project to the extent feasible. The City also finds that no further feasible mitigation to reduce these emissions has been identified; therefore, a significant and unavoidable cumulative impact would result from construction and operation of the Project. The City finds that implementation of mitigation measures, compliance with RCMs, the Project’s emissions‐reducing design features and operational programs are consistent with and support overall AQMP air pollution reduction strategies.

Project support of these strategies would globally promote timely attainment of AQMP air quality standards and would bring the Project into conformance with the AQMP to the extent feasible.

However, the City finds that impacts would remain significant and unavoidable. Relative to AQMP consistency, the City finds that exceedance of regional thresholds by the Project would result in a cumulatively considerable and significant impact.

Several comments on the Draft EIR identified new or modified mitigation to further address the Project’s significant air quality impacts. These measures were evaluated in the Final EIR and were:
1) already required through regulatory requirements, project design features, or mitigation; 2) added as mitigation and included, herein; or 3) determined to be infeasible. Mitigation Measures AIR‐1 and AIR‐2 (Draft EIR, pages 4.3‐35) have been revised, which reduced (to the extent feasible) the air quality impacts of the Project. See the Final EIR (Section 3.0, responses to Comments, D‐3‐56 and D‐6‐4).

Public comments also identified measures that were determined by the City to be infeasible; for example, the recommendation to restrict all trucks used on‐site to zero‐emission vehicles. While zero‐ emission heavy‐duty trucks are commercially available, the City finds that these vehicles are not available on a large enough scale to totally support Project operations; therefore, requiring exclusive zero‐emission vehicles is currently economically and technologically infeasible. Please see Findings, Section 5.1; Final EIR (Section 3.0, responses to Comment D‐6‐13).

The City finds that Mitigation Measures AIR‐1 and AIR‐2, as revised in the Final EIR, are feasible, adopted, and will reduce cumulative air quality impacts attributable to the Project to the extent feasible. The City also finds that no further feasible mitigation to reduce these emissions has been identified; therefore, a significant and unavoidable cumulative impact would result from operation of the Project. The City further finds that mobile source emissions that contribute to exceedance of thresholds ofsignificance are subject to regulationsthat control heavy‐duty truck emissions which are the responsibility of the State and outside of the responsibility and control of the City. See Final EIR, Section 3.0, Response to Comments. Pursuant to Section 21081(a)(3) of the California Public Resources Code, as described below, the City has determined that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or alternatives identified in the EIR.

Substantial Evidence
The Project’s potential to result in cumulatively considerable air quality impacts extends to the South Coast Air Basin (Basin) under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The nonattainment status of a project with respect to regional pollutants for which the region is in nonattainment is a result of past and present development, and the SCAQMD develops and implements plans for future attainment of ambient air quality standards. To facilitate attainment of those standards, the SCAQMD has developed a South Coast Air Basin plan based on planned development and regional, basin‐wide thresholds of significance for criteria pollutants which are 646

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needed to attain the Clean Air Act air quality standards. Non‐compliance with either is considered non‐compliance with an applicable plan and a significant project level impact. Project‐level thresholds of significance for criteria pollutants also determine whether a project’s individual emissions would have a cumulatively significant impact on air quality. Under the applicable standards established by SCAQMD, a project that individually triggers a significant air quality impact by exceeding regional emissions thresholds would also be considered to have a cumulatively considerable contribution to the cumulative regional air quality impact.

As detailed in Draft EIR, Section 4.3, with the implementation of Regulatory Compliance Measures (RCMs) AIR 1 through AIR‐4 and Mitigation Measure AIR‐1, the Project was determined to have less than significant impacts related to exposure of sensitive receptors to concentrations of localized pollutants during construction (see Draft EIR, Tables 4.3.O and 4.3.P). Based on public comments received on the Draft EIR, a supplemental HRA (Final EIR, Appendix C‐4) was prepared assess the additional potential health risks from resulting from revised truck trip lengths and the operation of TRUs. As with the original HRA, the supplemental HRA determined that health risk impacts at the nearest sensitive receptor while higher, would still be substantially lower than SCAQMD health risk thresholds (see Final EIR, revised Table 4.3.Q). Construction and operation of the Project would not result in odors that would adversely affect a substantial number of people, and accordingly, Project‐ related impacts associated with odors would be less than significant, and no mitigation measures are required (see Draft EIR, Section 4.3.6.4). For localized health risk impacts, because the Project does not have a significant impact under the relevant SCAQMD guidance, the Project would not contribute to a cumulatively significant impact.

The Development Project’s regional construction emissions would result in an exceedance of volatile organic compounds (VOCs), NOX and particulate matter less than 2.5 microns in diameter (PM2.5) before mitigation. With the exception of VOCs, construction emissions associated with the Development Project would be reduced to a less than significant level with implementation of revised Mitigation Measure AIR‐1 (see Draft EIR, Table 4.3.I); therefore, during construction, a significant and unavoidable regional cumulative air quality impact would occur. Other projects in the area, including the City’s Sun Lakes Boulevard Extension (SLB Extension), the electric substation, reserve osmosis facility, potable water reservoir, and/or Sunset Avenue Bridge may be under construction at the same time as the Development Project. However, construction of the SLB Extension and electrical substation would not result in the emission of pollutants in excess of regional or localized thresholds.

Such concurrent development would generate fugitive dust and equipment emissions that could result in substantial short‐term increases in air pollutants in the local area without mitigation. A standard requirement during construction is adherence to applicable SCAQMD rules governing the control of fugitive dust, the application of architectural coatings, and operation of construction equipment. These rules seek to eliminate project‐specific significant impacts resulting from emissions generated during development and would apply equally to the Project and the cumulative projects; therefore, the uniform implementation of these rules during construction would ensure construction impacts are not cumulatively considerable, with the exception of VOCs.

Under a conservative analysis where concurrent construction and operation of each phase of the proposed Development Project (Draft EIR, Tables 4.3.J through 4.3.M) occurs, emissions would exceed the SCAQMD thresholds for all pollutants except for sulfur oxides (SOx). Despite implementation of 647

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the planned Project Design Features (PDFs) and revised Mitigation Measure AIR‐2 (which requires the implementation of all feasible measures to reduce operational impacts associated with the Development Project), emissions associated with operation of the Development Project would remain significant and unavoidable (see Final EIR, revised Table 4.3.N). Emissions from future operations of the MSJC Site cannot be calculated at this time, and therefore any contribution to cumulative air quality impacts is speculative. Because the MSJC Entitlements are part of the Project, the combined Project emissions also would be significant and unavoidable, and therefore cumulatively considerable.

Similar to the Development Project, despite the identification of mitigation and project design features, the RSG, SLVN, BSP, and BPSP projects each identified significant and unavoidable impacts related to AQMP consistency and exceedance of pollutant thresholds for reactive organic gas (ROG), NOx, carbon monoxide (CO), PM10 and PM2.5 during project operations.25,26,27,28 Forthe SLVN project, though the level of other emissions were reduced through implementation of mitigation, emissions of NOx emissions remained in excess of the SCAQMD threshold; therefore, the operational air quality impact of that project remained significant and unavoidable. Even with the implementation of Development Project mitigation, emissions of VOCs, NOX, CO, PM10, and PM2.5 pollutants would still exceed SCAQMD standards, prompting a significant and unavoidable project level and cumulative impact (see Table 4.3.N). Due to the Project’s exceedance of SCAQMD thresholds, the infeasibility of mitigation to reduce operational air quality impacts to below SCAQMD significance standards, and in combination with other inability to show that other cumulative projects could implement feasible mitigation to reduce their similar impacts, air quality impacts would cumulatively and significantly contribute to the nonattainment designation in the South Coast Air Basin.

In response to public comment on the Draft EIR, a supplemental air quality assessment (Final EIR, Appendix C‐5) was prepared assess the additional potential air quality impacts resulting from revised truck trip lengths and the operation of TRUs. Public comment received on the Draft EIR requested implementation of additional mitigation measures. These measures were evaluated in the Final EIR (see Section 3.0, Responses to Comments) and were either, 1) already required through regulatory requirements, project design features, or mitigation, 2) added to mitigation, or 3) determined to be infeasible (see Final EIR, Section 3.0, responses to Comments A‐3‐25 and A‐3‐ 58, B‐2‐15 and B‐2‐6, D‐3‐56 through D‐3‐93, and D‐6‐10 through D‐6‐13. Additional measures have been added to revised Mitigation Measures AIR‐1 and AIR‐2 to further reduce, to the extent feasible, the emission of pollutants during the construction and operation of the Development Project. Examples include electrification of construction activities to the extent feasible (see Final EIR, Section 3.0, responses to Comments A‐3‐49, A‐3‐54, and D‐3‐45) and a requirement to ensure 90 percent of TRUs at cold storage uses be zero‐emission (response to Comment A‐3‐64).

As stated in Section 4.3,6.1 of the Draft EIR, the Development Project was determined to be inconsistent with the AQMP, which is based on, 1) whether a project is consistent with the SCAG growth forecasts, which is based, in part, on the planned land uses in general plans of cities located 25   RBF Consulting. 2011. Draft Butterfield Specific Plan Subsequent Environmental Impact Report. June 3.   26   Placeworks. 2016. Rancho San Gorgonio Specific Plan Final Environmental Impact Report. October.   27   Romo Planning Group. 2020. Sun Lakes Village North Specific Plan, Amendment No. 5, Draft Environmental Impact Report SCH No. 202002907. September 9. 28   T&B Planning, Inc. 2022. Draft Environmental Impact Report, Beaumont Pointe Specific Plan, City of Beaumont, California. December.
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within the SCAG region; and, 2) whether a project would increase the frequency orseverity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. The Development Project29 along with many of the projects on the cumulative project list entail a General Plan amendment and/orzone change and therefore would not be consistent with SCAG’s growth forecasts, and the impact is cumulatively considerable. The Development Project also contributes to a cumulatively considerable impact under the second criterion because the regional operational‐source emissions are anticipated to exceed the regional thresholds of significance for VOC, NOX, CO, PM10, and PM2.5 emissions. The RSG, BSP, SLVN, and BPSP projects also each exceed regional emission thresholds and were determined to be inconsistent with the AQMP; therefore, the Project would have a cumulatively considerable and significant air quality impact.

9.4 BIOLOGICAL RESOURCES
Impact Statement: The Project could have a significant cumulative impact on biological resources without the implementation of mitigation measures.

Finding
A cumulatively considerable effect would occur if the Project, in conjunction with the cumulative projects, resulted in a significant impact on candidate, sensitive, or special‐status species or their habitats, protected wetlands/riparian resources, wildlife movement or nursery sites, or conflicted with local policies or adopted conservation plans/programsintended to protect protected species and habitats. Potential cumulative impacts of the Project related to biological resources are discussed in detail in Draft Section 6.5.4. The City finds that the Development Project would not significantly impact protected wetlands, wildlife movement, or wildlife nursery sites; therefore, implementation of the Development Project would not result in impacts that are cumulatively significant related to these issues. One pair of burrowing owls was detected at the Development Site. The on‐site burrowing owls and most, if not all, other burrows, if any are identified on the Development Site through future surveys, would be permanently impacted by implementation of the Development Project, and they would need to be relocated. The on‐site burrowing owls may suffer indirect effects as a result of their forced relocation. The Los Angeles pocket mouse (LAPM) was detected at drainages within the Development Site during the 2002 and 2005 surveys, and again during surveys conducted in 2020 in limited upland areas of the Development Site; therefore, the on‐site drainages and portions of the upland areas are assumed to be occupied by LAPM based on these survey results. Per the Draft EIR (pg 4.4‐33), while approximately 7.92 of the approximately 8.99 acres of riparian habitat present on‐ site and a buffer of approximately 32.58 acres of upland area would be preserved, assome permanent impact to drainages would result from the Development Project, there is a potential to impact the LAPM. A wide variety of bird species, including many criteria, sensitive, or special‐status species, have potential to occur on the Development Site, particularly while passing through during migration.

These species are all protected under the MBTA as discussed in Section 4.4.4.1 of the Draft EIR. The 29   Because the MSJC Entitlements would not result in a significant increase in the inventory of residential units or population growth in the City and only changes the location of the development of the units, the MSJC Entitlements would be consistent with SCAG forecasts and the first criterion identified in the SCAQMD’s CEQA Handbook, and the future development of residential units on the MSJC Site would not add to cumulative impacts under this criterion.
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MSJC Site islocated in an area that potentially hosts MSHCP‐protected biological resources; therefore, removal of vegetation, ground disturbance, landform modification, or other activities associated with subsequent development residential uses, has the potential to adversely impact protected biological resources on site.

The City finds that impacts on candidate, sensitive, or special‐status species from development of the MSJC Site would be substantially similar to those on the Development Site and accordingly would be mitigated to a lessthan significant level by imposition of MSJC Site Mitigation Measures BIO‐1 through BIO‐5 identified in Section 5.4.4.2 of the Draft EIR. Additionally, the City finds that Mitigation Measures BIO‐1 through BIO‐16 (see Section 4.1.1 of these Findings), revised as appropriate in response to public comments, and MSJC Mitigation Measures BIO‐1 through BIO‐5 (see Section 8.1.4 of these Findings) would minimize and mitigate impacts to biological resources to less than significant through the protection, conservation, and/or restoration of on‐site biological resources. The City finds that the identified mitigation measures are feasible, required, and appropriate to reduce impacts to biological resources to a less than significant level, and therefore would not contribute to a cumulatively considerable impact. The City further finds that changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the Draft EIR.

The City also finds that significant cumulative effects of the Project on MSHCP‐covered plants and wildlife, wildlife movement, riparian/riverine areas, and habitat connectivity and covered species are fully mitigated due to the City’s status as a MSHCP permittee and the applicable provisions of the City’s Municipal Code, which impose MSHCP compliance on discretionary projects that have or may be developed in the City. See Draft EIR Section 6.5.4. The cities of Banning and Beaumont and the County of Riverside are each permitteesto the MSHCP. The cumulative area for jurisdictional features and sediment transport is the Whitewater River watershed. As with the Project, the cumulative projects may result in the modification of existing landforms, vegetation, habitats, and jurisdictional features, and may alter the volume and/or intensity ofsediment transport. Depending on the location and design of each cumulative project and the avoidance measures implemented to avoid these impacts, impacts to sensitive biological resources, habitats, and jurisdictional waters will occur, but the City finds that Project compliance with identified mitigation measures that are feasible, required, and appropriate to reduce impactsto biologicalresourcesto a lessthan significant level, and therefore would not contribute to a cumulatively considerable impact.

Substantial Evidence
As discussed in Section 4.4 of the Draft EIR, the Development Project would not significantly impact protected wetlands (Draft EIR Section 4.4.3.5), wildlife movement (Draft EIR Section 4.4.6.4), or wildlife nursery sites (Draft EIR Section 4.4.6.4); therefore, implementation of the Development Project would not result in impacts that are cumulatively significant related to these issues. The Project’s potential to result in cumulatively considerable impacts to biological resources extends to the Western Riverside County Multi‐Species Habitat Conservation Plan (MSHCP) Area and the Whitewater River watershed (for impacts related to jurisdictional features). The cumulative impact analysis considers development of the Project, including the MSJC Site, in conjunction with other development projects and planned development in the vicinity of the Project Sites. 650

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The MSHCP setsforth conservation goalsfor each covered species. A development project must either demonstrate that the conservation goals for each covered species identified within the development site have been met or prepare a Determination of Biologically Equivalent or Superior Preservation (DBESP) Report enumerating mitigation measures to achieve equivalent or superior preservation for each not conserved covered species through deed restriction, conservation easement, or other appropriate method. The City of Banning was a party to the Implementing Agreement for the MSHCP and is a member of the Regional Conservation Authority (RCA).

Implementation of Mitigation Measures BIO‐1 through BIO‐16 would reduce potential impacts to candidate, sensitive, or special‐status species present on the Development Site through habitat preservation or enhancement, active or passive relocation. Along with these mitigation measures, impacts to burrowing owl and LAPM would be further reduced through the permanent conservation of riparian/riverine lands on site (7.92 of 8.99 acres) as well as a surrounding upland area buffer of approximately 32.58 acres. To mitigate for the permanent impacts to 1.07 acres of riparian/riverine areas on the Development Site, 3.21 acres of on‐site riparian habitat would be enhanced or restored (a 3:1 ratio). The MSJC Entitlements themselves would not result in a physical disturbance; therefore, the impactsto biological resourcesfrom adoption of these entitlements would be lessthan significant.

While subsequent development of the MSJC Site with residential uses could potentially significantly impact biological resources; implementation of the MSJC Site Mitigation Measures BIO‐1 through BIO‐ 5 would reduce impacts to biological resources resulting from subsequent development on the MSJC Site to a less than significant level.

The City’s Municipal Code, Chapter 15.72.050, details the purpose and procedures for adherence to applicable provisions of the MSHCP including habitat evaluation, implementation requirements for protection of riparian/riverine areas and narrow endemic species, conduct of required focused biologicalspecies, and compliance with MSHCP guidelinesfor urban/wildland interface. Chapter 15.72 requires the imposition of conditions or mitigation to ensure each project complies with the applicable biological resource protection polices detailed in the MSHCP. Additionally, as required under the MSHCP, each permittee has established a fee program to collect required MSHCP mitigation fees. Banning Municipal Code Chapter 15.72.060 identifies the requirements for payment of MSHCP fees. The fees collected are to be used to finance the acquisition and perpetual conservation of the natural ecosystems and certain improvements necessary to implement the goals and objectives of the MSHCP. The mitigation fee must be paid no later than at the issuance of a building permit. Currently, MSHCP fees(effective July 1, 2023) range from $781 per residential unit (greater than 14.1 units/acre) to $19,066/acre for commercial and industrial development. Significant cumulative effects of the Project on MSHCP‐covered plants and wildlife, wildlife movement, riparian/riverine areas, and habitat connectivity and covered species are fully mitigated due to the City’s status as a MSHCP permittee and the applicable provisions of the City’s Municipal Code, which impose MSHCP compliance on discretionary projects that have or may be developed in the City.

As with the Project, the cumulative projects in the cities of Banning and Beaumont and in unincorporated areas of Riverside County, may result in the modification of existing landforms, vegetation, habitats, and jurisdictional features, and may alter the volume and/or intensity of sediment transport. Depending on the location and design of each cumulative project and the avoidance measures implemented to avoid these impacts, impacts to sensitive biological resources, 651

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habitats, and jurisdictional waters will occur. While the Project and the cumulative projects may conserve a portion of their property by protecting areas within local drainages, development on these sites represents a cumulative loss of habitat. For each cumulative project, it is anticipated the project‐ specific effects to jurisdictional features and sediment transport will be assessed during the project‐ specific permitting process and mitigation will be imposed consistent with the requirements of the MSHCPs.

The Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) Plan Area lies downstream of the Development Site. The CVMSHCP was designed, in part, to conserve species which depend specifically on the preservation of their respective sand dune or sand sheet habitats in CVMSHCP Conservation Area(s). As stated in Section 4.10 of the Draft EIR, while the city is not located within the boundaries of the CVMSHCP or a party to its requirements, much of the sand for the sand dune and sand sheet habitats in the CVMSHCP is supplied by ephemeral streams flowing out of the San Bernardino Mountains through the City and then onward to the San Gorgonio River. Mitigation Measures HYD‐1, HYD‐2 and BIO‐16 have been identified to address and mitigate potential Project impacts related to the transport of sediment (Final EIR Section 4.4.6.1, Final EIR Section 4.10.6.3, and Draft EIR Section 6.5.10) (see also Final EIR, Section 3.0, response to Comment A‐4‐7). Cumulative development, such as the Rancho San Gorgonio (RSG) project, Butterfield Specific Plan (BSP), and Sun Lakes Boulevard (SLB) Extension projects, have or are currently addressing thisissue in theirrespective environmental clearance and/or permitting actions. Adherence to the project‐level measures would ensure no cumulatively considerable sediment transport would result from cumulative development activity. Similarly, the Project would be required to comply with respective permit requirements such that the impactsto jurisdictional features and sediment transport are reduced to a lessthan significant level. The collective adherence of permit requirements will ensure the regional (watershed) cumulative impacts on jurisdictional features and sediment transport remain less than significant.

Significant cumulative effects of the Project on MSHCP‐covered plants and wildlife, wildlife movement, riparian/riverine areas, and habitat connectivity and covered species are fully mitigated due to the City’s status as a MSHCP permittee and the applicable provisions of the City’s Municipal Code, which impose MSHCP compliance on discretionary projects that have or may be developed in the City. The Project, including the identified Mitigation Measures, are in compliance with the conservation goals and guidelines of the MSHCP. Other cumulative projects in the City or MSHCP would be equally required to implement measures to achieve compliance with the MSHCP; therefore, no significant adverse cumulative effect to biological resources would occur.

9.5 CULTURAL RESOURCES
Impact Statement: The Project would not result in significant cumulative cultural resources impacts.

Finding
The potential cumulative impacts of the Project related to cultural resources are discussed in detail in Draft EIR, Section 6.5.5. The culturalresourcesrecord search identified 68 previously recorded cultural resources within one mile of the Project Sites, with only one, an isolate, determined to be prehistoric.

The remaining are historic sites, buildings, and features, including 39 single‐family residences, three multifamily residential properties, eight commercial buildings, one ranch complex, two remnantranch 652

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foundations/features, one motel, two industrial building complexes, one transmission line, one road, one railroad alignment, six erosion control features/water conveyance systems, and two trash scatters. Two of the previously recorded resources (P‐33‐013778 Historic Ranch Foundations/Features and RIV‐7544 Historical erosion control feature[s]/water conveyance system) are located within the Development Site and the SLB Extension. Within the MSJC Site, one resource (P‐33‐009176) containing historic buildings associated with a ranch complex tied to Barker Ranch was previously recorded. The standing structures associated with this resource were demolished in 2010 for the construction of the MSJC campus buildings. Six previously recorded and 12 new cultural resource/sites were identified during the cultural assessment of the RSG project site, located directly east and south of the Development Sites.

The City finds that Mitigation Measures CUL‐1 through CUL‐6 Implementation of these measures would ensure that if any historic or archaeological resources are identified during excavation, these resources would be evaluated, documented, and studied in accordance with standard historic or archaeological practice, and these resources (including human remains) would be treated in accordance with appropriate State codes and regulations which would minimize and mitigate Project impacts to cultural resources to less than significant. The City also finds that the cumulative projects have, are, or will be required to complete project‐specific cultural resource assessments and be subject to the same resource protection requirements and CEQA process as the Development Project that would reduce those impacts to less than significant, and that therefore cumulative impacts to historic and archaeological resources would be less than significant. The City further finds that the identified Project mitigation measures are feasible, required, and appropriate to reduce Project and cumulative impacts to cultural resources to a less than significant level, and that changes or alterations have been required in, or incorporated into, the Project which avoid orsubstantially lessen the significant environmental effect as identified in the Draft EIR.

Substantial Evidence
The cumulative area for cultural resources is the City and its Sphere of Influence (SOI). The cultural resources survey areas and the survey reports for the Development Site encompass the area planned for the eventual development of the related public facility projects including the SLB extension; therefore, for those projects, the cumulative effect is accounted for in the impacts identified for the Development Site.

A cultural resources assessment was conducted for the Development Site (see Section 4.5). Mitigation Measures CUL‐1 through CUL‐6 have been identified to: (1) require the retention of a qualified archaeologist during all ground disturbance activities and pre‐construction archaeological sensitivity training; (2) mandate development of an archaeological monitoring treatment plan; (3) establish a Native American monitoring agreement detailing the presence, extent, and authority of Native American monitoring during ground disturbance activities; (4) identify the notification processrelated to human burials; (5) establish a process for the treatment and disposition of archaeological or Native American cultural material (including human remains); and (6) ensure disclosure of all project‐related cultural data to consulting Native American parties. Implementation of these measures would ensure that if any historic or archaeological resources are identified during excavation, these resources would be evaluated, documented, and studied in accordance with standard historic or archaeological 653

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practice, and these resources (including human remains) would be treated in accordance with appropriate State codes and regulations.

One historic‐period archaeological resource, Site 33‐013779 (CA‐RIV‐7544), and one built environment resource, 33‐013778, are located within the limits of the SLB Extension. Eighteen cultural resources were found on the RSG site (Draft EIR Section 6.5.5. Ground disturbance associated with the Project and cumulative projects could potentially affect previously unidentified archaeological sites and/or associated human remains. The City’s General Plan EIR states, “…All development or land use proposals, which have the potential to disturb or destroy sensitive cultural resources shall be evaluated by a qualified professional and, if necessary, comprehensive Phase 1 studies and appropriate mitigation measures shall be incorporated into project approvals.” Mandatory compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097 et seq., would assure that the Project and all cumulative Projects treat human remains that may be uncovered during development activities in accordance with prescribed, respectful, and appropriate practices, thereby avoiding significant cumulative impacts. In addition, as with the Project, the cumulative projects have, are, or will be required to complete project‐specific cultural resource assessments required under the City’s General Plan and similar to the Project, impacts on known or previously unknown cultural resources on adjacent sites would be required to be mitigated to less than significant levels with appropriate mitigation measures adopted as part of the respective approvals of those projects. Other development projects would be required to undergo discretionary review and be subject to the same resource protection requirements and CEQA process as the Development Project that would reduce those impacts to less than significant. Therefore, with implementation of appropriate project‐specific mitigation, cumulative impacts to historic and archaeological resources would be rendered less than significant.

9.6 ENERGY
Impact Statement: The Project would not result in cumulatively significant impact related to energy.

Finding
The potential cumulative impacts of the Project related to energy are discussed in detail in Section

6.5.6 of the Draft EIR. The City finds that the construction and operation of the Project would not result in significant cumulative impacts related to energy; therefore, no mitigation is required.

Substantial Evidence
Cumulative energy impacts would result if the Project, along with cumulative projects, taken together could result in wasteful, inefficient, or unnecessary use of energy. The cumulative projects are subject to CEQA and required to conduct an energy analysis, consistency with existing plans and policies for renewable energy and energy efficiency, and implementation of control measures and mitigation if necessary to avoid wasteful, inefficient, or unnecessary consumption of energy resources.

The cumulative area for electricity and natural gas energy resources is the service areas of the utility providers. The Project Sites are within the service territory of the Banning Electric Utility (BEU). BEU is a not‐for‐profit, publicly owned retail electrical energy distribution utility. Southern California Gas 654

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Company (SoCalGas) provides natural gas to approximately 21.8 million people in a 24,000‐square‐ mile service area throughout Central and Southern California, from Visalia to the Mexican border.

As with the Project, the largest energy use during construction of the cumulative projects would likely occur from the transport and use of construction equipment, delivery vehicles and haul trucks, construction worker vehicles, and use of on‐site equipment that would use petroleum fuels (e.g., diesel fuel and/or gasoline). Fuel consumption from transportation uses depends on the type and number of trips, VMT, the fuel efficiency of the vehicles, and the travel mode. While it would be speculative to precisely identify the fleet mix used by persons working on cumulative development sites, it must be noted that updated Corporate Average Fuel Economy (CAFE) regulations establish fuel efficiency standards for model years 2024 through 2026, requiring an industry‐wide fleet average of approximately 49 miles per gallon (mpg) for passenger cars and light trucks in model year 2026.

The updated standards require fuel efficiency increases of 8 percent annually for model years 2024 and 2025, and 10 percent annually for model year 2026. It is anticipated that these updated standards avoid the consumption of about 234 billion gallons of gasoline between model years 2030 to 2050.30 As cumulative development occurs, construction vehicles would collectively and appropriately adhere to the fuel efficiency standards enshrined in the CAFE regulations. The cumulative projects would be required to comply with the California Air Resources Board’s(CARB) Airborne Toxics Control Measure, which restricts heavy‐duty diesel vehicle idling time to 5 minutes, CARB’s Truck and Bus Regulation, and federal fuel efficiency requirements, which would minimize fuel consumption, and other regulatory requirements designed to increase fuel efficiency. In addition, because petroleum use during construction would be temporary and relatively minimal in comparison to overall usage, it would not be wasteful or inefficient. It is reasonable to anticipate (as with the Project) that such fuel use would have a negligible effect on the amount or availability of fuel resources during cumulative development (see Draft EIR, Section 4.6.6.1); therefore, no cumulatively significant conflict or obstruction with an energy efficiency program would occur.

The Project and other cumulative projects would result in an increased services demand in electricity and natural gas. As discussed in the Draft EIR, Section 4.6, the total annual electricity consumption in the BEU service area in 2022 was 151.5 gigawatt‐hours(GWh). The BEU hasincluded the energy usage by this Development Project as well as other large commercial and residential developments or industrial projects in itsfuture planning, which has enabled it to enter into long‐term contractsfor the purchase of renewable sources of electricity as required by State law. The Project, in combination with cumulative projects, is well within BEU’ssystem‐wide net increase in electricity supplies annually over the 2018 to 2030 period and, with construction of the electrical substation, there are sufficient planned electricity supplies in the region for estimated net increases in energy demands and the increases are not significant.
30   It should be further noted that approval of any one cumulative project does not ensure that development will occur. The timing and/or certainty of development is in part based on economic conditions, market demand, legal/regulatory, and/or community factors. For example: The RSG project (2016) anticipated building out of a Master Planned residential community over a 20‐year period. Currently, no development has yet occurred on the RSG site. It is uncertain if the projects identified in Table 6.B of the Draft EIR will be developed at the time and in the manner outlined in their respective approvals. 655

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Similarly, additional natural gas infrastructure is not anticipated due to cumulative development.

Total natural gas consumption in the Southern California Gas Company (SoCalGas)service area in 2022 was 5,026.5 million therms. Total natural gas consumption in SoCalGas’s service area is forecast to remain steady between 2018 and 2035 for the low‐ and mid‐demand scenarios and to increase by approximately 650 million therms in the high‐demand scenario due to intense energy efficiency efforts.31 It is anticipated that SoCalGas would be able to meet the natural gas demand of the Project and cumulative projects without additional facilities. In addition, both BEU and SoCalGas’s demand forecasts include the growth contemplated by the Project and the related projects. BEU and SoCalGas plan to continue to provide reliable service to their customers and upgrade their distribution systems as necessary to meet future demand.

As stated in Sections 4.6 and 5.4.6.2 of the Draft EIR, future use of the Project Sites would incorporate the most current energy efficient/energy conserving designs; adhere to vehicle fuel efficiency requirements; and install the fixtures, features and facilities meeting the energy efficiency requirements in effect at the time of development. The California Energy Code is a building code for Building Energy Efficiency Standards for Residential and Nonresidential Buildings that imposes building standards to reduce energy consumption through efficient lighting and heating standards among other requirements. Increased building energy efficiency will reduce energy consumption on a per square foot basis. The 2022 Energy Code establishes specifications related to electric‐ready requirements for new homes, expands solar photovoltaic and battery storage standards, requires solar roofs on multifamily residential units of 3 stories or less, and strengthens ventilation standards.

Since January 1, 2023, projects that apply for building permits must comply with the 2022 Energy Code. Based on its mix of generation sources, BEU currently has a renewable portfolio of 81.3 percent (2022), far exceeding the State’s target of 50% by 2030. This satisfies Renewable Portfolio Standard (RPS) targets for 2030 mandated under Senate Bill 100.

The Project and cumulative projects are required to comply with various federal and State government legislation to improve energy efficiency in buildings, equipment, and appliances and reduce vehicle milestraveled. The State of California provides a minimum standard for building design and construction standards through Title 24 of the California Code of Regulations (CCR), known as the California Building Code (CBC). The CBC is updated every 3 years, and the current 2022 CBC went into effect in January 2023 and is applicable to the Development Project. The California Building Standards Commission adopted Part 6 of the Title 24 Building Energy Efficiency Standards and adopted Part 11 (referred to as the California Green Building Standards Code, or CALGreen) as part of the State’s efforts to reduce greenhouse gas emissions and energy consumption from residential and non‐ residential buildings. CALGreen covers the following five categories: (1) planning and design; (2) energy efficiency; (3) water efficiency and conservation; (4) material conservation and resource efficiency; and (5) indoor environmental quality. As the cumulative projects are developed, it is reasonable to assume that provisions of the applicable energy and/or building codes would be implemented, furthering the efficient use of energy resources. Regulatory Compliance Measure ENG‐ 1 is a regulatory requirement imposed on all projects by the City to ensure the incorporation of required features to meet code requirements and ensure efficient use of energy for building operations. Accordingly, as cumulative projects are developed, they would comply with the applicable 31   Ibid.
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CALGreen Code requirements and Title 24 efficiency standards, so they would not significantly obstruct or conflict with adopted plansforrenewable energy and energy efficiency, and no cumulative impacts would result.

Based on fuel consumption obtained from the CARB California Emissions Factor Model, Version 2021 (EMFAC2021), approximately 915.5 million gallons of gasoline and approximately 321.6 million gallons of diesel fuel will be consumed from vehicle trips in Riverside County in 2023. Based on estimated VMT, the Development Project would use approximately 1.423 and 6.667 million gallons of gasoline and diesel fuel, respectively (approximately 1.5 percent of Countywide gasoline fuel usage and 2.01 percent of Countywide diesel fuel usage). While the size and nature of the cumulative projects vary, it is reasonable to conclude that each will require the use of vehicle fuels. The amount of fuel used will vary, but even collectively and due to the incremental percentage of fuel used, the operation of the cumulative projects regarding the amount of fuel required does not represent a meaningfully significant percentage of the total fuel used in Riverside County. As stated previously, the fuel standards established under the CAFE regulations require an industry‐wide fleet average of approximately 49 mpg for passenger cars and light trucksin model year 2026. It isreasonable that use of vehicles adhering to updated CAFE standards and the increasing use of electric vehicles will exert a downward pressure on total vehicle fuel usage.

The Development Project and, if developed, the VHDR on the MSJC Site, will increase energy use; however, it will be used efficiently and therefore would not result in a significant impact. Construction and operation of the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and impacts from wasteful, inefficient, or unnecessary energy consumption would be less than significant. Mitigation is not required. While development of the Project and other cumulative projects would increase the demand for vehicle fuels, electricity and natural gas over current use, it is anticipated that the fuel efficiency of vehicles and energy efficiency in buildings will increase over the lifetime of these projects. Further, compliance with the existing and future regulatory requirements would ensure that the Project and the cumulative projects do not result in an inefficient, wasteful, and unnecessary consumption of energy. Therefore, the Project’s contribution to impacts related to the inefficient, wasteful, and unnecessary consumption of energy would not be cumulatively considerable, and no mitigation is required.

9.7 GEOLOGY AND SOILS
Impact Statement: The Project would not result in a cumulatively considerable impact related to geology and soils (risk of loss due to earthquakes, substantial soil erosion/loss of topsoil, risks due to unstable geologic unit/soil, expansive soil, erosion, or septic tanks).

In the absence of mitigation measures, the Project has the potential to directly or indirectly impact a paleontological resource and contribute to cumulative considerable impacts.

Finding
The potential cumulative geology and soils impacts of the Project related to risk of loss due to fault rupture, seismic shaking, ground failure, erosion, unstable soil, expansive soil, landslides and septic tanks are discussed in detail in Section 6.5.7 of the Draft EIR. The cumulative projects would be required to comply with the Regulatory Compliance Measures (RCMs) or the equivalent applicable to 657

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the Project. The City findsthat with application of the RCMs, which require site development to follow the recommendations detailed in the development of the proposed Project, no significant cumulative impacts related to geology and soils would result; therefore, no mitigation is required.

The potential Project impacts related to paleontological resources is addressed in Section 4.7.6.9 and

6.5.7 of the Draft EIR. While the Quaternary sediments on the Project Sites have an “Undetermined” paleontological sensitivity, typically in western Riverside County, these sediments are assigned a High (High A or High B) paleontological sensitivity based on the well documented record of yielding important Ice Age fossils, such as large terrestrial vertebrates (e.g., bison, mammoth, mastodon, horse, camel, giant ground sloth, short‐faced bear, saber‐toothed cat, and others). The Project could result in direct impacts to paleontological resources within the Project Sites should such resources be discovered during Project‐related construction activities. The City finds that Project compliance with Mitigation Measures GEO‐1 and MSJC Site GEO‐1 and GEO‐2, would reduce impactsto paleontological resources to less than significant. The City further finds that the cumulative projects, as appropriate, would be required to comply with comparable measures. The City finds that these measures are feasible, adopted, and will reduce impacts to paleontological resources attributable to the Project to less than significant. Therefore, the Project will not contribute to a cumulatively considerable impact, and its cumulative impact is less than significant.

Substantial Evidence
Typically, geology and soils impacts are specific to a particularsite and there islittle, if any, cumulative relationship between the development of a proposed project and development within a larger cumulative area; therefore, the geographic scope of the cumulative impact analysis for geology, soils, and seismicity includes the Development Site and the MSJC Site. The area included in the geologic assessment (Draft EIR, Appendix F‐1) prepared for the Development Site encompasses the area planned for the eventual development of the related public facility projects; therefore, the cumulative effects associated with those projects are accounted for in the impactsidentified for the Development Site.

Issues including fault rupture, seismic ground shaking, liquefaction, landslides, and expansive soils would involve effects to (and not from) a proposed development project, are specific to conditions on the Project Sites, and are not influenced or exacerbated by the geologic and/or soils hazards that may occur at the location(s) of other cumulative projects. Construction activities associated with the MSJC Site and cumulative projects would include some level of earthmoving, trenching, and/or temporary stockpiling, which could contribute to cumulative soil erosion effects. A standard development requirement is compliance with relevant federal, State, and local laws, which require preparation of Storm Water Pollution Prevention Plans (SWPPPs) to identify, evaluate, and minimize erosion and sedimentation from construction sites. The SWPPPs generally identify the project‐specific Best Management Practices (BMPs) and erosion control features that would be implemented to prevent soil erosion that may result from construction activities. For the Development Project, RCM WQ‐1 requires preparation of a SWPPP, and construction BMPs detailed in the SWPPP would be implemented during construction. Additionally, as specified in RCM WQ‐2, an Erosion and Sediment Control Plan would be prepared and submitted to the City’s Public Works Department prior to issuance of any grading permit in compliance with the City’s Municipal Code. Regulatory compliance would be required for the MSJC Site and all other related projects as well. 658

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The project‐specific geotechnical investigation prepared for the SLB Extension did not identify significant geotechnical or soil‐related issues. While seismic events may affect a broad region, implementation of the Development Project would not increase the intensity, frequency, or duration of seismic events or the properties of off‐site geology or soils. The CBC (adopted by reference in Chapter 15.08 [Construction Codes] of the City’s Municipal Code) contains provisions to safeguard against major structural failures or loss of life caused by earthquakes or other geologic hazards.

In addition, the California Building Code (adopted by reference in Chapter 15.08 [Construction Codes] of the City’s Municipal Code) contains provisions to safeguard against major structural failures or loss of life caused by earthquakes or other geologic hazards. Regulatory Compliance Measure (RCM) CM GEO‐1 requires all structures to be designed in accordance with the seismic parameters presented in the Geotechnical Assessment prepared for this Development Project. RCM GEO‐2 further requires that the recommendations detailed in the Geotechnical Assessment are appropriately incorporated/ implemented during design, grading, and construction activities on the Development Sites. Adherence to applicable sections of the most current CBC and the site‐specific recommendationsidentified in the Geotechnical Investigation would effectively minimize the potential effects of liquefaction, ground shaking, landslides, and other seismically induced hazards. MSJC Site RCM GEO‐1 similarly requires the preparation of a site‐specific geotechnical assessment and adherence to the recommendations related to design, grading, construction, and/or development on the MSJC Site. It is reasonable to expect similar measures would be implemented on cumulative projects. Furthermore, because potential geologic hazards are generally site‐specific, there would be no direct or indirect cumulative effect when considered with other projects; therefore, the Project’s impact relative to geology and soils would not be cumulatively considerable.

Sediments mapped as Quaternary older and younger alluvial fan sediments in western Riverside County are assigned a High (High A or High B) paleontological sensitivity based on the well documented record of yielding important Ice Age fossils, such as large terrestrial vertebrates (e.g., bison, mammoth, mastodon, horse, camel, giant ground sloth, short‐faced bear, saber‐toothed cat, etc.). Combined with other past, present, and reasonably foreseeable projects in the City of Banning, the Project could contribute to a cumulatively significant impact due to the overall loss of paleontological remains unique to the region. The Development Project and MSJC Entitlements each identify (Mitigation Measures GEO‐1 and MSJC Site GEO‐1 and GEO‐2) to reduce the level of impact to paleontological resources at each of these sitesto a lessthan significant level. See Draft EIR Sections

4.7 and 5.4.7.2. The SLB Extension and RSG Project require similar mitigation to reduce the project‐ level paleontological resource impacts on those sites to a less significant level.

There are no unique geologic features in the Project vicinity. Cumulative development in the City, would be required to undergo environmental review pursuant to CEQA. The potential for significant impactsto paleontological resources or unique geologic features would be identified in a project‐level investigation to determine the nature and extent of the impacts and/or resources and to identify appropriate mitigation measures. The implementation of project‐level mitigation, tailored to the specific nature of each cumulative site, would ensure that the development of cumulative projects in the City would not result in significant cumulative impacts to unique paleontological resources or unique geologic features.
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9.8 GREENHOUSE GAS EMISSIONS
Impact Statement: The Project would result in a cumulatively considerable impact replated to GHG emissions.

Finding
Under CEQA Guidelines Section 15064.4, greenhouse gas (GHG) and climate change‐related impacts are inherently cumulative, and any project level GHG emissions above an applicable threshold of significance – here 3,000 MT CO2e ‐ would have a cumulative impact. The unmitigated emission of 62,844.96 MT CO2e and mitigated emissions of 44,313 MT CO2e (see Final EIR, Tables 4.8.F‐1 and

4.9.J‐1, respectively). Accordingly, the City adopts the findings for GHG emissions in Section 5.2.1 as though fully set forth. The cumulative impacts of the Project related GHG emissions are discussed in detail in Section 6.5.8 of the Draft EIR with additional, supplemental analysis provided in Section 4.0 and Appendix C‐6 of the Final EIR.

In addition, because the MSJC Entitlements are not a physical project, no GHG emissions would result from the entitlement actions themselves. The GHG emissions that may result from the subsequent residential development of the MSJC Site cannot be determined until such a project is proposed.

Because the Project is comprised of both the MSJC Entitlements and Development Project, the City findsthat Project‐related GHG emissions would exceed the City’s 3,000 MT CO2e per yearsignificance threshold, and Project impacts are cumulatively significant.

The Development Project is generally consistent with and/or would not conflict with applicable GHG reducing plans or policies. These plans and policies are the GHG emission reduction policies, measures, goals, orstrategiesidentified in the City’s General Plan, applicable Scoping Plan(s) including the CARB 2022 Scoping Plan, and Riverside County CAP, Regional Transportation Plan (Connect SoCal), or the 2022 Air Quality Management Plan. However, due to the annual volume of CO2e emitted in excess of the City’s 3,000 MT CO2e per year threshold, and the infeasibility of additional mitigation measuresto reduce the impacts of the Development Project to lessthan significant, the City findsthat Development Project’s contribution of GHG is cumulatively considerable. In addition, because the Project is comprised of both the MSJC Entitlements and Development Project, the City finds that Project‐related GHG emissions would exceed the City’s 3,000 MT CO2e per year significance threshold, and Project impacts are cumulatively significant concerning applicable GHG reducing plans or policies.

The City finds that the revised mitigation measures identified in Final EIR are feasible, are adopted, and will reduce GHG impacts attributable to the Project to the extent feasible, and that additional, suggested mitigation measures are infeasible for the reasons stated in the Final EIR and responses to comments. The City further finds that regulations that control heavy‐duty truck emissions are the responsibility of the State and outside of the responsibility and control of the City. Pursuant to Section 21081(a)(3) of the California Public Resources Code, as described below, the City has determined that specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or alternatives identified in the EIR.
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Substantial Evidence
Under CEQA Guidelines Section 15064.4, greenhouse gas (GHG) and climate change‐related impacts are inherently cumulative, and any project level GHG emissions above an applicable threshold of significance would have a cumulative impact.

Based on comments received during public review of the Draft EIR, a supplemental greenhouse analysis was conducted to account for emissions from updated truck trip lengths trucks by axle type which conform to SCAQMD WAIRE Guidelines and emissions from transport refrigeration units (TRUs) (see Final EIR, Appendices C‐5 and C‐6). These additional emissions were added to those previously identified for the Project. This additional analysis identified, at buildout, with the incorporation of project design features, the Development Project’s unmitigated emissions with incorporation of the PDFs would be approximately 62,844.96 MT CO2e annually from both construction and operations32 (see Final EIR, Table 4.8.F‐1). Comments received during public review of the Draft EIR identified a variety of potential measures that could reduce the volume of criteria pollutants and greenhouse gases emitted during the construction and operation of the Development Project. For example, the suggestion that all truck traffic related to the Development Project utilize zero‐emission vehicles.

Currently, and for the foreseeable future, requiring the Project to use all zero‐emission trucks is economically and technologically infeasible, as such trucks are not commercially available on a large enough scale to serve the Project. Imposing mandatory requirements on the Project based on an emerging, not yet established technology when the technological advances and timeframesforreadily available quantities of such trucks are not known with any certainty, is not a feasible mitigation measure. (See Final EIR, Section 3.0, responses to Comments A‐3‐25, A‐3‐26, and A‐3‐27). Another suggestion was the installation of roof‐top solar panels to the extent feasible. While the City will require Project buildings be to designed and constructed to include solar‐ready roof and solar facilities required for commercial and office space in the industrial buildings, the installation of solar panels beyond those required by law is not anticipated at this time as the City prefers that new commercial and industrial uses refrain from installing solar roofs and purchase electricity from BEU to facilitate and support the utility’s long‐term renewable energy contracts (see Final EIR, Section 3.0, response to Comment A‐3‐64). Other measures suggested by commenters were either, (1) already included in the Draft EIR, (2) incorporated into the Final EIR through the revision of the mitigation measures previously identified in the Draft EIR, and/or (3) determined by the City to be infeasible. The discussion of mitigation measures suggested during public review to reduce the emission of criteria pollutants and greenhouse gases is provided in the Final EIR, Section 3.0, including (but not limited to) the responses to Comments A‐3‐28, A‐3‐58, A‐3‐60, B‐2‐15, B‐2‐16, D‐3‐8, D‐3‐53 and D‐3‐56 through D‐ 3‐93, and D‐6‐4.

Project design features(PDFs) to reduce the emission of GHGs have been previously identified in Draft EIR, Draft EIR, Section 4.8.5.1, (pg 4.8‐23) and Appendix C‐3 (pg 31). The Specific Plan has been revised to require compliance with California Building Code Title 24, Part 6 solar requirements which have been continuously evolving. Previously, consistent with the CALGreen requirement, only solar ready 32   This includes total construction emissions amortized over 30 years per 2008 SCAQMD Interim CEQA GHG Significance Thresholds for Stationary Sources, Rules, and Plans. 661

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roofs were required for non‐residential development. The revised GHG analysis includes the updated CALGreen solar roof requirements for non‐residential analysis:

All Commercial and Industrial buildings within the Development Project will have solar ready roofs, that includes roof vents and skylights spaced in a manner that allows the south facing roof areas sufficient space to install PV solar panels. In addition, all Commercial buildingsshall install PV solar panels with the capacity to generate at least 20 percent of the Commercial buildings’ expected electricity consumption. All Industrial buildingsshall install PV solar panels with the capacity to generate the expected electricity consumption of the office space of the warehouses and otherwise comply with Title 24, Part 6. Electric conduit leading from the roof area to the electric control panelsshall be installed and include electrical panels with sufficient capacity to accommodate PV solar.

This has been incorporated into the Final EIR (Final EIR Section 4.6.4.2 and Section 6.5.6.2).

Quantifiable greenhouse gas reducing practices have been identified in revised Mitigation Measures AIR‐1 and AIR‐2 and GHG‐1 through GHG‐7, along with previously identified and new PDFs, would reduce emissions to 44,313.0 MT CO2e per year at Project buildout (see Final EIR, Table 4.8.J‐1), which would still exceed the City’s threshold of 3,000 MT CO2e. Again, the majority of these are generated from mobile sources that are regulated by the State and not the City. Therefore, the Project’s GHG emissions are significant and would be cumulatively considerable.

The County of Riverside Climate Action (CAP) determined a baseline GHG emissions inventory, and calculated percentage reductions needed to meet 2020, 2030, and 2050 reduction goals. See Draft EIR, Sections 4.3 and 4.8. Consistency with the CAP is demonstrated as the Development Project greatly exceeds the 100‐points (+586 points) needed to show consistency with the CAP. See Draft EIR Table 4.8.K. Through the incorporation of project design features(PDFs) and Mitigation Measures AIR‐ 2, and GHG‐1 through GHG‐7 (including the addition of GHG‐7 expressly verifying implementation of the total number of CAP points (see the response to Comment D‐3‐8) the Development Project implements actions required for consistency with the CAP (and therefore 2030/2050 GHG reduction goals). See also response to Comment D‐3‐13 and D‐3‐32. Furthermore, as demonstrated in Tables 4.8.K through 4.8.O of the Draft EIR, the Development Project is consistent with and/or would not conflict with the GHG emission reduction policies, measures, goals, or strategies identified in the City’s General Plan (Draft EIR, Table 4.8.L, pg 4.8‐33), the Riverside County CAP (Draft EIR, Table 4.8.K, pg 4.8‐323), applicable Scoping Plan(s) (the 2022 CARB Scoping Plan) (Draft EIR, Table 4.8.M, pg 4.8‐ 35), Regional Transportation Plan (Connect SoCal) (Draft EIR, Table 4.8.N, pg 4.8‐37 and ‐38), and the 2022 Air Quality Management Plan (Draft EIR, Table 4.8.O, pg 4.8‐38). As previously stated, discussion of mitigation measures suggested during public review to reduce the emission of criteria pollutants and greenhouse gases is provided in the Final EIR, Section 3.0, Where feasible, revisions to mitigation and the incorporation of new PDFs have been identified to reduce GHG emissions. As established in the previously cited responses to public comments, due to the annual volume of MT CO2e emitted in excess of the City’s 3,000 MT CO2e per year threshold, and the infeasibility of additional mitigation measures to reduce the impacts of the Development Project to less than significant, the Project’s contribution of GHG is cumulatively considerable. The GHG analyses conducted for various cumulative 662

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projects33 each identified significant and unavoidable emissions of GHGs in excess of established thresholds and concluded the projects’ contribution of GHG emissions would be cumulatively significant.

GHG emissions from development of the MSJC Site cannot be determined until a project is proposed, and approval of the MSJC Entitlements will not result in GHG emissions. Because the Project is comprised of both the MSJC Entitlements and Development Project, Project‐related GHG emissions would exceed the City’s 3,000 MT CO2e per year threshold. The majority of the GHG emissions are associated with non‐construction related mobile sources. Emissions of motor vehicles are controlled by State and federal standards over which the City has no control.

9.9 HAZARDS AND HAZARDOUS MATERIALS
Impact Statement: The Project would not result in a cumulatively considerable impact related to hazards and hazardous materials.

Finding
The potential cumulative impacts of the Project related to hazards and hazardous materials are discussed in detail in Section 6.5.9 of the Draft EIR. The City finds that with the application of mandatory RCMs, the development of the proposed Project would not result in significant cumulative impacts related to hazards and hazardous materials; therefore, no mitigation for cumulative impacts is required.

Substantial Evidence
Cumulative impacts with respect to hazards and hazardous materials would occur when the Project and cumulative projects, taken as a whole, would result in accidental spills or inadvertent releases of hazardous substances, create an increased wildfire impact, emit hazardous substances within

0.25 mile of a school, or create a public safety hazard relative to airport safety. The cumulative areas for this issue are the Project Sites and immediately adjacent areas.

The Project Sites are not included on any of the queried databases of hazardous materials sites that could create a significant hazard to the public or the environment. A search of the California Office of Environmental Health Hazard Assessment database and Cleanup Sites Map indicated no active cleanup sites within the vicinity of the Project Sites. Two inactive sites are located approximately

0.5 mile north of the Development Site, north of Interstate 10 (I‐10).

Construction within the Project Sites, and at the cumulative projects would increase the regional transport, use, and disposal of hazardous materials and petroleum products (e.g., diesel fuel, lubricants, paints and solvents, and cement products containing strong basic or acidic chemicals).

These materials are commonly used during construction operation of various land uses. It is reasonable to anticipate that applicable State and federal regulations for the proper transport, use, storage, and disposal of hazardous materials and hazardous would be. Additionally, RCMs WQ‐1, 33   For example, ‘mitigated’ GHG emissions from the selected cumulative projects include Butterfield Specific Plan (124,025 MT CO2e), Rancho San Gorgonio Specific Plan (46,000 MT CO2e), Sun Lakes Village North (11,966 MT CO2e), and Beaumont Pointe Specific Plan (60,638 MT CO2e). 663

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WQ‐2, and WQ‐3 require compliance with the waste discharge permitrequirementsto avoid potential impacts to water quality due to spills or runoff from hazardous materials used during construction, thus ensuring cumulative impacts during construction remain less than significant (Draft EIR, pg 6‐37).

As established in Section 4.9, the Phase I Environmental Site Assessment prepared for the Development Site identified several listings for off‐site adjacent or nearby properties on databases potentially indicative of a contamination concern. However, none of these listings are considered as a “recognized environmental condition.” RCM HAZ‐1 requires the preparation of a Hazardous Materials Business Plan that includes (at a minimum) an inventory of hazardous materials used and stored on site, a site map, an emergency plan, and a training program for employees. Compliance with all applicable regulations presented in Section 4.9.4 would reduce potential impacts from the transport, use, storage, and disposal of hazardous materials to a less than significant level. These regulatory requirements would apply to the cumulative projects which therefore would also have a less than significant impact. The MSJC Site was evaluated via regional and State hazardous materials databases (see Section 5.4.9.1). Based on this review, there are no known conditions on the MSJC Site that would represent a significant risk to public health or safety (e.g., on‐site storage, leaking tanks, approaching groundwater contamination plume) on the MSJC Site. At the time of development occurs, MSJC Mitigation Measures HAZ‐1 and HAZ‐2 require the preparation of a site‐specific Phase I Environmental Site Assessment and submittal of evidence that any required site‐specific compliance measures identified have been appropriately implemented and/or incorporated into MSJC Site design. No significant hazardous material related to construction of the SLB Extension has been identified in the project‐specific investigation prepared for that roadway improvement effort. The area included in the hazard materials assessment prepared for the Development Site encompasses the area planned for the eventual development of the electrical substation and water reservoir; therefore, it is reasonable the less than significant cumulative effect is accounted for in the impacts identified. Once constructed, these public facilities may require the incremental use of hazardous substances, but it is anticipated any such use would comply with accepted use, storage, and disposal requirements, and their operation would not contribute to a significant cumulative impact.

The geographic scope of impacts associated with hazardous materials generated or released on the any site generally encompasses that site and areas immediately adjacent to or within a 0.25‐mile radius. Construction and operation/occupation within the Project Sites, and at the cumulative projects would increase the regional transport, use, and disposal of hazardous materials and petroleum products (e.g., diesel fuel, lubricants, paints and solvents, and cement products containing strong basic or acidic chemicals). These materials are commonly used during construction and operation of various land uses. It is reasonable to anticipate that applicable State and federal regulations for the proper transport, use, storage, and disposal of hazardous materials and hazardous would be followed by the owners, tenants, occupants, and/or employees at the cumulative projects’ sites; therefore, the potential to generate, release, or increase the risk of impacts related to hazardous materials, either through accidents or due to routine transport, use, or disposal during construction would be similarly addressed and mitigated and would not result in a cumulatively considerable impact. RCMs WQ‐1, WQ‐2, and WQ‐3 require compliance with waste discharge permit requirements to avoid potential impacts to water quality due to spills or runoff from hazardous materials used during construction.

While the cumulative projects listed in Table 6.B also have the potential to generate or increase the risk of impacts related to hazardous materials, these uses include residential, industrial, and 664

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commercial development, and like the Development Project, would be required to comply with these orsimilar regulatory requirements which would avoid potential impactsto water quality, and any such impacts likely would be confined to the limits of their respective sites.

Because the MSJC Site is proposed to be developed with residential uses, the limited use of household hazardous materials would occur subsequent to any subsequent development of the site. Similar to the Development Project, cumulative projects, including the RSG, Sun Lakes Village North (SLVN), and Butterfield Specific Plan (BSP) projects either identified impacts related to hazardous materials as less than significant through implementation ofstandard hazardous materialstransport, use,storage, and disposal regulations and/or the incorporation of project‐specific mitigation. The applicants of future cumulative projects would be required to comply with regulating agencies as well as the County to implement the applicable and appropriate measures to reduce the risk associated with the use and transport, storage, and disposal of hazardous materials. Therefore, no cumulatively significant hazardous materials impacts would occur.

While the Project Sites are located adjacent to the MSJC campus, as stated in Section 4.9, compliance with RCM HAZ‐1 and adherence to applicable regulations related to the transport, storage, use, and/or disposal of hazardous substances would ensure Project impacts remain less than significant.

Schools within 0.25 mile of cumulative projects also include Banning High School, Hoeffner Elementary School, and Hemmering Elementary School. It should be noted that the RSG and BSP projects themselves include the construction of schools within their respective Specific Plans. As with the Project, it is reasonable that adherence to these applicable regulations mitigate hazardous material impacts associated with other cumulative projects. Therefore, cumulative impacts related to the release of hazardous materials within 0.25 mile of a school would not be cumulatively considerable.

The Project Sites are located outside the influence area of Banning Municipal Airport and as a result would not have a cumulatively considerable impact on development within the Airport Influence Area established for this facility; therefore, the Project would not result a safety hazard or air excessive airport noise for people residing or working on the Project Sites and would not contribute to a cumulatively considerable airport hazard impact.

The Development Site is located in a wildland‐urban interface (WUI) setting, but it is not located in an area statutorily designated as a Moderate, High, or Very High Fire Hazard Severity Zone (FHSZ) by the California Department of Forestry and Fire Protection (CAL FIRE) or Riverside County. The MSJC Site is located within a Local Responsibility Area (LRA) non‐VHFHSZ. Both the Development and MSJC Sites are located within the Wildland Urban Interface (WUI) influence zone. The occupation of the proposed commercial, industrial (and in the case of the MSJC Site, residential) uses would increase the number and concentration of persons within a Wildland Urban Interface zone. A number of cumulative projects in the cities of Beaumont (e.g., Fairway Canyon, Beaumont Pointe, Heartland) and Banning (e.g., RSG) are located within or adjacent to fire hazard severity zones (very high, high, and moderate) designated by the California Department of Forestry and Fire Protection (CAL FIRE).34 Development in 34   California Department of Forestry and Fire Protection (CAL FIRE). 2022. Fire Hazard Severity Zones in State Responsibility Area. November 21. Website https://calfire‐forestry.maps.arcgis.com/apps/webappviewer/ index.html?id=4466cf1d2b9947bea1d4269997e86553 (accessed March 8, 2023). 665

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these areas could increase the risk of property loss or injury from wildfire hazards. All projects approved and developed within fire hazard severity zones would be required to comply with applicable provisions of the California Fire Code, including provisions related to development within zones and the wildland‐urban interfaces. Additionally, adherence to appropriate provisions of the CBC and City requirements related to the type, method, and manner of construction and the establishment and maintenance of fuel management zones would reduce the site‐specific wildfire impacts of each cumulative project. As noted in Sections 4.9, 4.20, and 5.4.20.2 of the Draft EIR, the Project would provide a fire protection plan (and per MSJC Site Mitigation Measure HAZ‐3, the MSJC Site would be required to develop a fire protection plan when development is proposed) that identifies the features/procedures to further offset potential wildland fire impacts. The related SLB Extension would improve circulation within and around the Development Site by improving the road surface and providing additional lanes of traffic that could be used to evacuate in an emergency and allow emergency personnel additional access to the Development Site and adjacent residential communities faster than using the roadways currently available. Upon compliance with existing regulations, including the applicable provisions of any project‐specific fire protection plan, the cumulative impacts with respect to hazards would be less than significant.

9.10 HYDROLOGY AND WATER QUALITY
Impact Statement: The Project would not result in cumulatively considerable impacts related to hydrology and water quality.

Finding
Potential cumulative impacts of the Project related to hydrology and water quality are discussed in detail in Section 6.5.10 of the Draft EIR. The City finds that with the application of RCMs, the Project would not result in significant cumulative impacts related to hydrology and water quality; therefore, no mitigation for cumulative effects is required.

Substantial Evidence
The Project is located within the Coachella Valley Groundwater, San Gorgonio Pass Subbasin and within the Whitewater River Watershed (which is within the jurisdiction of the Colorado River Basin Regional Water Quality Control Board). The Development Site is located within an undeveloped open grassland valley where two main creeks flow: Smith Creek and Pershing Creek, both of which flow in a southeasterly manner across the Development Site. Storm water on the Development Site, under existing conditions, either flows into Smith or Pershing Creek or infiltrates into the ground. Highland Wash, a tributary to Smith Creek, also crosses the Development Site until it meets with Smith Creek.

One such drainage transects the MSJC Site in a northwest to southeast direction joining Pershing Creek on the RSG site. The City of Banning and the Project Sites are located within the boundary of the Coachella Valley Groundwater Basin, San Gorgonio Pass Subbasin.

Cumulative development in the Whitewater River Watershed is a continuation of the existing urban pattern of development that has already resulted in extensive modifications to watercourses in the area  ‐‐ Smith Creek and Pershing Creek, both of which flow in a southeasterly manner across the Development Site, and the Highland Wash is a tributary to Smith Creek. Cumulative development in the Whitewater River Watershed is a continuation of the existing urban pattern of development that 666

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has already resulted in extensive modifications to watercourses in the area. The area’s watercourses have been either channelized or left in natural conditions, and drainage systems have been put into place to respond to the past urbanization that has occurred in this area. Without mitigation or implementation of applicable RCMs, the Project and related public facilities projects would increase impermeable surfaces and increase the volume of storm water runoff and contribute to pollutant loading in storm water runoff reaching the City’s storm drain system, the Coachella Valley Storm Channel, and Whitewater River Watershed, thereby resulting in cumulative impacts to hydrology and surface water quality. A similar result could occur with the cumulative projects without comparable RCMs or mitigation. Section 4.10 of this EIR identifies RCMs WQ‐1 through WQ‐3, construction general permit (CGP) requirements, City erosion control requirements (per Ordinance No. 1388), and water quality management plan(s) satisfying Whitewater River Watershed MS4 Permit requirements which were imposed to achieve a less than significant impact for the Development Project. The proposed public facilities are located within the area studied in the Development Project‐specific hydrologic report and water quality management plan, and it is anticipated that no appreciable decrease in impermeable surface area would or change of drainage pattern would occur. Therefore, the cumulative effect of the public facilitiesis accounted for in the impactsidentified for the Development Site, which will be confirmed by City review of their facility design to ensure the appropriate management of storm runoff that may occur during the construction and operation of the facilities.

Detailed hydrologic analysis of the MSJC Site has not been completed; however MSJC Site RCMs WQ‐ 1 through WQ‐3 identified in Section 5.4.10.2 of the Draft EIR mirror those required for the Development Site which would likewise result is no significant impacts.

The Project would increase impermeable surfaces and increase the volume of storm water runoff and could contribute to pollutant loading in storm water runoff reaching the City’s storm drain system, the Coachella Valley Storm Channel, and Whitewater River Watershed, thereby resulting in cumulative impacts to hydrology and surface water quality. RCMs WQ‐1 through WQ‐3 and MSJC Site RCMs WQ‐1 through WQ‐3 identify construction general permit (CGP) requirements, City erosion control requirements (per Ordinance No. 1388), and water quality management plan(s) satisfying Whitewater River Watershed MS4 Permit requirements. Compliance with these requirements would result in a less than significant Project impact. As with the Project, each cumulative project could also result in increased urban pollutantsin storm water runoff from developmentsitesthat would degrade surface or ground water quality, and also must comply with existing water quality standards and waste discharge requirements, including Whitewater River Watershed MS4 permit requirements. These requirements include preparation of a Final WQMP for all new development that specify the Site Design, Source Control, Low‐Impact Development (LID), and Treatment Control BMPs that would be implemented to capture, treat, and reduce pollutants of concern in storm water runoff. and would implement construction and operational BMPs to reduce pollutants of concern in storm water runoff.

These would include preparation and approval of a SWPPP, erosion and sediment control plans (for construction), and a Water Quality Management Plan (WQMP) (for operation) for each project to minimize water quality impacts. Accordingly, there would not be a significant cumulative impact.

The City is located in the Whitewater River Watershed. The Whitewater River is the major stream in the watershed and extends 54 miles from the San Bernardino Mountains to the Salton Sea, and Smith Creek and Pershing Creek confluence with the San Gorgonio River which ultimately joins the Whitewater River. The SLB Extension crosses Highland Wash, Smith Creek, and Pershing Creek. These 667

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crossings have been sized and will be ultimately designed to mimic downstream flow conditions and to not exacerbate the existing hydrologic and sediment transport condition similar to RCM WQ‐4 which requires preparation of a hydrology and hydraulic analysis consistent with local and regional flood control and water quality requirements. As deemed appropriate by the City, similar studies would be required for cumulative projects. It is reasonable that cumulative development would occur pursuant to the siting, design, and maintenance measures detailed in these project‐specific reports such that the drainage impacts from each site do not exceed existing conditions or result in hydromodification orsoilsedimentation impacts. These studies would be reviewed by the City’s Public Works Department (or as appropriate the Riverside County Public Works Department for projects within the County) on a case‐by‐case basis to ensure that sufficient local and regional drainage capacity is available and that sediment transport conditions are not significantly impacted (Draft EIR, Section 6.5.10).

Each project must consider impacts to impaired receiving waters and Total Maximum Daily Loads (TMDLs) for receiving waters. The TMDL program is designed to identify all constituentsthat adversely affect the beneficial uses of water bodies and then identify appropriate reductions in pollutant loads or concentrationsfrom allsourcesso that the receiving waters can maintain/attain the beneficial uses in the Basin Plan. Thus, by complying with TMDL requirements, a project’s cumulative impacts to overall water quality in the Whitewater River Watershed are taken into account. Regional programs and BMPs, such as TMDL programs and the MS4 Permit Program, have been designed under an assumption that the Whitewater River Watershed would continue its pattern of urbanization. The regional control measures contemplate the cumulative effects of proposed development. Compliance with these regional programs and permits constitutes compliance with programs intended to address cumulative water quality impacts.

Portions of the Whitewater River watershed are located within 100‐year flood zones. No development on the Development Sites would occur in identified 100‐year flood zones. For the cumulative projects that include residential development, those projects will be required to provide evidence their residential improvements are maintained at least one foot above 100‐year‐flood elevations in accordance with National Flood Insurance Program requirements. City of Banning Ordinance No. 1415 Stormwater Code requires compliance with all applicable local, state, and federal regulations and BMPs related to stormwater runoff and catchment basins, and that projects be subject to regular inspection to ensure compliance. Section 13.24.110 of the City of Banning Municipal Code requires that any construction in the City comply with the Stormwater Management Provisions as codified in Chapter 13.24 and the Uniform Building Code, as well as the City of Banning Ordinance 1388.35 Concerning potential groundwater impacts, the City is located within San Gorgonio Pass Subbasin of the Coachella Valley Groundwater Basin, which the California Department of Water Resources designates as a medium priority basin. In 2022, the San Gorgonio Pass Subbasin adopted a Groundwater Sustainability Plan, which identifies projects and management actions to conserve 35   The City is approximately 55 miles northeast of the Pacific Ocean, as such it is not located in a tsunami hazard zone. Seiches are waves that are created in an enclosed body of water such as a bay, lake, or harbor that are triggered by high winds, changes in atmospheric pressure, earthquakes, tsunamis, or tidal influence. The cumulative projects are not adjacent to or near any large, enclosed closed bodies of water.

There would be no significantly cumulative tsunami or seiche hazard. 668

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water, capture stormwater, and recharge imported water into the Subbasin. Project impacts related to depletion of groundwater supplies or interference with groundwater recharge in a manner that may impede sustainable groundwater management would be less than significant, and no mitigation would be required. Similar to the Project, the cumulative projects would each be required to analyze potential impacts and impose mitigation necessary to ensure that the projects do not substantially interfere with groundwater management or recharge that may impede implementation of the Groundwater Sustainability Plan for the San Gorgonio Pass Subbasin.

The cumulative projects would increase impervious surface area, which may alter the amount or duration of local or regional runoff. It is reasonable that as cumulative development occurs, site‐ specific design (through on‐site retention and/or detention of stormwater runoff) and project mitigation will ensure post‐development flows do not result in on‐site or off‐site substantial erosion or siltation, substantially increase surface runoff that would result in on‐site or off‐site flooding, contribute runoff which would exceed existing or planned capacity of stormwater drainage systems or substantially add to polluted runoff, or impede or redirect flood flows. Similar to the Project, the cumulative projects would each be required to control or otherwise limit runoff in accordance with the applicable City regulation and the Whitewater River Watershed MS4 Permit. The implementation of these requirements on a project‐level would ensure no significant cumulative drainage or flooding impacts would occur.

Flows within alluvial channels typically carry sediment, with concentrations that tend to increase with flow rate. The ability of flow to move sediment as it passes downstream is termed its sediment transport capacity. Hydraulic properties, particularly flow velocity, and bed material properties, such as median grain size, determine the sediment transport capacity of a given river reach. The capacity of a flow to transport particles of a given diameter is exponentially related to the flow velocity (above a given incipient or threshold velocity). In channels with similar bed material composition, higher velocities result in increased sediment transport capability. The Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) Plan Area lies downstream of the Development Site. The CVMSHCP was designed, in part, to conserve species which depend specifically on the preservation of their respective sand dune or sand sheet habitats in CVMSHCP Conservation Area(s). As stated in Section 4.10 of this EIR, while the city is not located within the boundaries of the CVMSHCP or a party to its requirements, much of the sand for the sand dune and sand sheet habitats in the CVMSHCP is supplied by ephemeral streams flowing out of the San Bernardino Mountains through the city and then onward to the San Gorgonio River. High winds in the San Gorgonio Pass pick up sand deposited along Smith Creek and the San Gorgonio River during the winter and transport it into the CVMSHCP Conservation Areas located downwind. Features within upstream drainage areas, such as detention basins, and changes in stream flow related to flood control features have the potential to diminish the amount of sediment transported downstream which is then available for aeolian transport.

Cumulative development, such as the RSG, BSP, and SLB Extension projects, have or are currently addressing this issue in their respective environmental clearance and/or permitting actions. Project‐ level adherence to appropriate measures identified during these processes, similar to Mitigation Measures HYD‐1 and HYD‐2, will ensure the maintenance of appropriate sediment transport to support deposition in downstream/downwind conservation areas. 669

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As development within the City must include project‐level provisions related to the management of storm water, maintenance of surface or groundwater water quality, preservation of groundwater, drainage patterns, flood control, consistency with plans drafted for the management of water resources, and Agency requirements related to the appropriate maintenance of sediment transport, the impacts related to these issues would not be cumulatively significant.

9.11 LAND USE
Impact Statement: The Project would not result in a cumulatively considerable impact related to land use and planning.

Finding
Potential cumulative impacts of the Project related to land use and planning are discussed in detail in Section 6.5.11 of the Draft EIR. The City findsthat the Project would not result in significant cumulative impacts related to land use and planning; therefore, no mitigation is required.

Substantial Evidence
A cumulatively considerable impact would occur if a project, when considered with other cumulative projects, would cause an environmental impact due to conflict with an established land use policy or program adopted to avoid or mitigate an environmental effect or results in a physical division of an established community. As detailed in Draft EIR Sections 4.11 and 5.4.11.2, the Development Project and MSJC Entitlements would have no impact or a less than significant land use/planning impact and no regulatory compliance measures or mitigation measures are required.

The construction and operation of the Project would increase the urban development footprint and improve roadway connections within the City and would not physically divide an established community and therefore would not contribute to cumulative land use impacts with respect to division of an existing community. In addition, the Project Sites are outside of and do not conflict with the Banning Airport Master Plan and therefore would not contribute to cumulative land use impacts with respect to airport uses.

The Sunset Crossroads Specific Plan has been prepared under the provisions of Government Code §65450 through §65454, which establish the authority to adopt a Specific Plan, identify the required content of a Specific Plan, and mandate consistency with city’s General Plan. In addition to standard requirements established by statute, the City may require the inclusion of other material it deems deemed necessary or desirable to implement the General Plan, such as architectural or landscaped design guidelines. Chapter 17.96 (Specific Plans) of the Banning Code of Ordinances establishes uniform procedures for the adoption and implementation of Specific Plans. The Sunset Crossroads Specific Plan has been prepared to provide the essential link to the policies of the City of Banning General Plan. By functioning as a regulatory document, the Sunset Crossroads Specific Plan provides a means of implementing and detailing the City’s General Plan and tailoring its policies to the Development Site. The Sunset Crossroads Specific Plan has been prepared to address site‐specific issues such as building setbacks and visual appearance, as well as community‐wide concerns such as vehicular and non‐vehicular circulation, energy conservation, landscaping, and the provision for 670

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infrastructure improvements, and ensures the Development Project meets or exceeds City land use standards for environmental protection, infrastructure, and aesthetic quality.36 Future development within the City could result in changes to the existing land use environment through the conversion of vacant land to developed uses, or through conversions of existing land uses (e.g., from residential to commercial). As Specific Plans are tailored to implement the General Plan and establish policies and guidelines to address site‐specific issues and community‐wide concerns, cumulative development would not conflict with the General Plan and Zoning Code, or with General Plan policies adopted to avoid or mitigate an environmental effect or result in a physical division of an established community. Other cumulative development would also be reviewed for consistency with adopted land use plans and policies by the City, in accordance with the requirements of CEQA and planning requirements. Development of future projects proposing changes in land use would require project‐specific consistency analysis to ensure such a change would not conflict with the General Plan or City Code.

The City has initiated the General Plan Amendment (GPA) and Zoning Change (ZC) of the MSJC Site to avoid a net loss of residential capacity resulting from implementation of the Development Project.

The proposed MSJC Entitlements will change the current general plan and zoning designation of the MSJC site from Public Facilities to Very High Density Residential, allowing a maximum capacity of not fewer than 1,146 residential units (and a maximum of 1,181 units). The MSJC Entitlements ensure no net loss of residential capacity in the City and provide alternative housing opportunities for a broader segment of the community. Future development of the MSJC Site with a specific plan would include a development framework for detailed land use, circulation, infrastructure including drainage, sewer, and water facilities, and urban design and landscape. Subsequent development on the MSJC Site would be pursuant to the required specific plan, and is required to be consistent with City guidelines and requirements; therefore, no significant inconsistency with this policy would result from implementation of the MSJC Entitlements or subsequent residential development on the MSJC Site.

Construction and operation of the Project (pursuant to its Specific Plan(s)), combined with cumulative development in accordance with the City of Banning’s General Plan or the controlling Specific Plan, would not result in significant land use and planning impacts and would comply with State law requirements related to no net loss of residential units. The Project would be consistent with applicable plans, goals, policies, and regulations of the City of Banning’s General Plan and zoning regulations, and the SCAG RTP/SCS, that have been adopted to avoid or mitigate an environmental effect or results in a physical division of an established community. Therefore, the cumulative impact of the proposed Project with respect to future development would not be cumulatively considerable and would not result in significant land use impact.

9.12 MINERAL RESOURCES
Impact Statement: The Project would not result in a cumulatively considerable impact related to mineral resources.
36   T&B Planning, Inc. 2022. Draft Sunset Crossroads Specific Plan No. 20‐20000002. August. 671

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Finding
The potential cumulative impacts of the Project related to mineral resources are discussed in detail in Section 6.5.12 of the Draft EIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to mineral resources; therefore, no mitigation is required.

Substantial Evidence
Mineral Resource Zone (MRZ)‐3 is the predominant designation throughout most of the City and its Sphere of Influence (SOI). The only mineral extraction site in the City, the Banning Quarry, mines rock, sand, and base materials used for concrete and construction. The quarry is located in the MRZ‐2 zone in the eastern portion of the City approximately 3.3 miles northeast of the Project Sites. The General Plans of the City and Riverside County have not designated the Sites with a land use designation that allows for mineral extraction nor are these areas held in reserve for future mining activity. The proposed sites for the public facilities projects, as well as the alignment of the SLB Extension, like the Project Sites, are located within Mineral Resource Zone 3; therefore, any development of the Project and these public facilities would be expected to have a less than significant mineral resource impact.

As stated in stated in Sections 4.13 and 5.4.13.2 of this EIR, the Development Site and the MSJC Site are designated as MRZ‐3 (areas of known of inferred mineral occurrences of unknown significance.

While the Projects Sites are mapped assuch, over the past 120 years, there has been no evidence that significant mineral resources are located on the Sites, nor has the State, County, or City conducted mineral recovery at these locations.

Of the cumulative projects, only the Hathaway Industrial project (BA7) is located in an MRZ‐2 zone (an area where adequate information indicatesthatsignificant mineral deposits are present, or where it is judged that a high likelihood for their presence exists). The State Mining and Geology Board maps the Hathaway Industrial project site as Sector G‐1, which indicates that the site contains regionally significant Portland‐cement concrete (PCC) grade aggregate resources. However, there are no records that indicate the project site was previously used as a mineral resource recovery site or as a site occupied by mines. Within Sector G‐1, approximately 470.6 acres remain open for mineral extraction including the Banning Quarry. The Hathaway Industrial project site has previously been mass graded.

While the Hathaway Project would preclude any future mineral extraction on the site, the loss of the site represents 0.43 percent of the total remaining areas designated for PCC grade aggregate in the Region. Development of the cumulative projects would not conflict with or interfere with extractive operations at the Banning Quarry. Implementation of the Project would not cumulatively contribute to a significant loss of known mineral resources or the development of a site that has been delineated as a locally important mineral resource recovery area by the City or Riverside County.

Therefore, the Project would not cumulatively contribute to a significant loss of known mineral resources or the development of a site that has been delineated as a locally important mineral resource recovery area or have a cumulatively considerable effect on mineral resources. 672

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9.13 NOISE AND VIBRATION
Impact Statement: The Project would not generate a substantial permanent increase in ambient noise resulting from Project‐related traffic or Project operations in excess of established standards under cumulative conditions.

Finding
The potential cumulative noise impacts of the Project are discussed in Section 6.5.13 of the Draft EIR.

On‐site construction‐related noise impacts are reduced to a less than significant level through the implementation of Mitigation Measure NOI‐1. For activities associated with construction of roadway or utility improvements, it may not be possible to construct the temporary noise attenuation walls required under Mitigation Measure NOI‐1; therefore, the off‐site construction noise resulting from roadway and utility improvement associated with the Development Project was determined to be significant. However, as the roadway work in this location would be completed by the Project applicant and not by cumulative projects, the significant Project impact is not a cumulative impact.

Off‐site traffic noise impacts and operational noise impacts are reduced to below a level of significance through the implementation of Mitigation Measure NOI‐2. The City has determined that these measures, incorporated into the Project, are feasible and reduce the potential significant operations impact identified in the EIR to a less than significant level.

Substantial Evidence
Cumulatively significant noise impacts require multiple sources and noise receptors, each in close proximity to each other. Due to the attenuating characteristics of noise, cumulative noise and vibration impacts are evaluated on the Project Sites and immediately adjacent areas. The only adjacent cumulative projects to the Development Site and MSJC Site are the RSG site, located immediately to the east of the Development Site and south of the MSJC Site, and the SLB Extension, potable water reservoir, reverse osmosisfacility, and electricalsubstation proposed to be constructed and operated by the City within the boundaries of the Development Site. Other cumulative projects would generally not result in cumulative noise impacts on sensitive receptors near the Project Sites due to their scattered locations and distance from the Development Project. The primary noise sources in the Project area for Project operations are transportation facilities/traffic. In order for a cumulative impact to be considered significant, the Project traffic would need to create a noise level increase of 3 dB(A) or greater in the area adjacent to the roadway segments. In addition, the resulting noise level would need to exceed the City’s 65 dB(A) CNEL exterior noise standard.

Construction. As stated in Draft EIR, Section 4.13, implementation of Mitigation Measure NOI‐1 requiring a temporary construction noise barrier when project construction activities are within 100 feet from the nearest residential structure would reduce noise levels from on‐site construction to below the City’s interior construction noise standard of 55 A‐weighted decibel (dBA) for more than 15 minutes per hour; therefore, a significant impact would not occur. For activities associated with construction of roadway or utility improvements, it may not be possible to construct the temporary noise attenuation walls required under Mitigation Measure NOI‐1. While the off‐site construction noise resulting from roadway and utility improvement associated with the Development Project were determined to be significant, cumulatively significant noise impacts require multiple sources and noise receptors, each in close proximity to each other. As roadway and utility improvements are 673

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typically linear projects that do not overlap (either in location or schedule) it is not likely multiple projects would be on‐going at the same time; therefore, construction noise resulting from roadway and utility improvements would not be cumulatively considerable and impacts would be less than significant. In addition, Banning Municipal Code Chapter 8.44.085 states that sound emanating from capital improvement projects of a governmental agency, or the maintenance and repair of public properties by a governmental agency are exempt from City noise standards; therefore, construction of the related public facilities would not contribute to a cumulative considerably noise impact.

The timing of any future development of the MSJC Site is not known at this time, but development may occur in the future concurrently with development of portions of the RSG site. Construction crew commutes and the transport of construction equipment and materials would incrementally increase noise levels on adjoining roadways. Noise generated during site preparation, grading, building construction, paving, and architectural coating phases of construction could, if carried out at the same time, have cumulatively considerable impacts on sensitive receptors in the community. The net increase in noise levels generated by these activities and other sources has been quantitatively estimated and compared to the applicable noise standards and thresholds of significance. If the Development Project and RSG project are developed at the same time, adherence to the City’s Municipal Code (Section 8.44.090[E]) would limit the construction activities to daytime between 7:00 a.m. and 6:00 p.m. As stated in Section 4.13, implementation of Mitigation Measure NOI‐1 requiring a temporary construction noise barrier when project construction activities are within 100 feet from the nearest residential structure would reduce construction noise levels below the City’s interior construction noise standard of 55 A‐weighted decibel (dBA) for more than 15 minutes per hour. Like the Development Project, the RSG project identified a significant construction‐related noise impact at nearby receptors, recommending mitigation to reduce noise levels at nearby receptors. Section 5.4.13.2 of this EIR indicates that a site‐specific noise assessment identifying noise reduction requirements is required prior to any construction on the MSJC Site. As the City’s Municipal Code limits hours of construction, because of the temporary nature of construction noise, and as both the Project and the RSG project will implement necessary mitigation to reduce construction noise levels at nearby receptors, construction noise in the project area would not be cumulatively considerable.

Operation. Noise from Development Project operations has two sources: traffic and onsite operations. With respect to long‐term operational noise primarily caused by traffic, this EIR analyzed the cumulative impacts of the Project Sites, and cumulative projects (see Draft EIR, Table 6.B) as described in Section 4.13 of this EIR (as revised). Specifically, future (2045) cumulative traffic calculations were used to determine the noise levels of all cumulative projects and reflect the cumulative conditions at new and existing land uses in the vicinity of the Project. The Horizon Year (2045) average daily traffic trips were obtained from the Project specific traffic analysis (which estimated traffic volumes and distributions for the cumulative projects added to the projected ambient growth detailed in Section 4.5 of the Traffic Assessment and Supplemental Traffic Assessment (see Appendices J‐2 and J‐3 of the Draft EIR) prepared for the Project.

The Draft EIR identified two significant unavoidable noise impacts from operation of the proposed Development Project at nearby sensitive receptors from: (1) Project traffic at the residences located east of Sunset Avenue between Lincoln Street and Sun Lakes Boulevard/Westward Avenue and at the 674

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MSJC school on the east side of Sunset Avenue south of Sun Lakes Boulevard/Westward Avenue, and (2) noise generated on‐site from Development Project operations at certain residences located immediately south of Bobcat Road. Although these impacts were identified in the Draft EIR as significant and unavoidable (based on the original parameters of the Development Project), in response to public comments, the Development Project is modified by the inclusion of the Project Design Features N‐1 and N‐2, which are detailed in the revised Specific Plan (page 2‐1 and 2‐10, respectively) and Final EIR (Section 4.0 and Appendix I‐2). See also see Final EIR, Section 3.0, response to Comment D‐6‐29.

These PDFs include:
 PDF N‐1: To address traffic noise impacts along Sunset Avenue, the alignment of Sunset Avenue is shifted to the west from its previously proposed location to provide additional distance from sensitive receptors east of Sunset Avenue. More specifically, the centerline of Sunset Avenue between Lincoln Street and Sun Lakes Boulevard/Westward Avenue would be adjusted 42 ft to the west from the existing centerline with implementation of the Development Project, which results in the new centerline being 72 ft from the nearest residential property line and 115 feet from the school at the MSJC Site.
 PDF N‐2: To address the potential for impacts to residences from on‐site Development Project operations, on‐site project operations are revised to require:
○ Cold storage equipment previously allowed on industrial building rooftops will be shielded or relocated to the ground floor; and
○ Construction of 10 ft high “wing walls” on the south end of warehouse buildings 1 and 2, and 6 ft high walls that surround the automobile parking lots south of warehouse buildings 1 and 2 as depicted in the SoundPLAN printoutsin Attachment A to the Supplemental Noise Analysis (Final EIR, Appendix I‐2, Attachment A).

These project design features are included in Mitigation Measure NOI‐2 as follows:

NOI‐2 Prior to approval of roadway plans for Sunset Avenue, the City will confirm that the Development Project design plans for Sunset Avenue incorporate project design feature N‐1 (PDF N‐1) and shift the alignment of Sunset Avenue between Lincoln Street and Sun Lakes Boulevard Extension/Westward Avenue to the west from the existing centerline as required by PDF N‐1 to reduce traffic noise at neighboring sensitive uses to a less than significant level. To reduce operational noise impacts to a less than significant level, prior to issuance of building permits, the City will confirm that the following building design plans are consistent with PDF N‐2: (1) design plans for each building proposed to contain cold storage facilities shall eithershield rooftop cold storage equipment or locate such equipment on the ground level and (2) design plans for buildings adjacent to Bobcat Road (in the location depicted for Buildings 1 and 2 in the Specific Plan), shall include wing walls and parking lot walls meeting the requirements of PDF N‐2.
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As the Final EIR has been revised to include Mitigation Measure NOI‐237 into any future plans for Sunset Avenue and Buildings 1 and 2, these PDFs become fully enforceable through the implementation of the Mitigation Monitoring and Report Program developed for the Project. As described below and in the Supplemental Noise Analysis for the Sunset Crossroads Project, Banning, California (see Final EIR, Appendix I‐2 and revised Section 4.13 Noise), all operational noise impacts from the Development Project are reduced to lessthan significant levels with implementation of these PDFs and revised MM NOI‐2. Cumulatively significant noise impacts require multiple sources and noise receptors, each in close proximity to each other, within the same time period; therefore, in the absence of a Project‐related impact, the Project would not contribute to a cumulatively significant traffic noise; therefore, the effect of traffic noise resulting from the Project would not be cumulatively considerable.

Operational noise resulting from occupation of the Development Site would be typical of that experienced in similar industrial and commercial development and will include noise generated from truck delivery and truck unloading activities, heating, ventilation, and air conditioning (HVAC) equipment, speakerphones, parking activities, fueling activities, and outdoor eating activities. While on‐site operational noises are individual noise occurrences and are not typically additive in nature, with implementation of Mitigation Measure NOI‐2, the significant nighttime operational noise impact previously identified in the Draft EIR at residential uses south of Bobcat Road has been eliminated.

MSJC Site VHDR operational noise would be typical of residential developments. On‐site noise from both the MSJC Site and the RSG site would be limited that that typical of residential and educational uses (e.g., parking area noise, HVAC, recreational activity). Therefore, although the RSG site and MSJC Site are in proximity to the Development Site, it is extremely unlikely that these adjacent properties will generate noises that would be additive in nature for two reasons. First, the noise sources would have to be adjacent or in close proximity to one another in order for the noisesto intermingle. Second, the sensitive receptor or receptors would also have to be adjacent to or in close proximity to the noise generators; therefore, cumulative operational noise is not expected to create significant noise impacts at sensitive receptors. It is reasonable to conclude that each project will be required to identify and mitigate operational noise such that exterior and interior noise levels do not exceed established City standards at any noise‐sensitive use.

Noise‐producing components at the electrical substation would be limited to the transformers. The electrical substation site is located approximately 700 feet northwest of the nearest residential use.

Transformers at the electrical substation would produce a combined maximum noise level of approximately 37 dBA Leq at 45 feet. Assuming standard distance attenuation, noise from the substation would be approximately 19 dBA Leq at the nearest residential uses, which is below the nighttime (most restrictive) allowable level of 45 dBA Leq at residential property lines. Other operational noise related to the electrical substation and potable water reservoir would likely result only from periodic inspection/maintenance activities. Noise from these activities at public facilities are not anticipated to exceed established thresholds and would, additionally, be exempt from City noise control requirements and therefore would not be significant. 37   Note: Mitigation Measure NOI‐2 referenced in the Final EIR and these findings replace Mitigation Measure NOI‐2 included in the Draft EIR. Based on public comment received during public review of the Draft EIR 676

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Special roadway paving and sound walls were considered to mitigate traffic noise associated with the RSG project. These measures were deemed infeasible due to the limited noise reduction achievable (paving) and inability to provide a sound barrier that retained necessary accessto affected residences.

Despite the infeasibility of this measure for the RSG project, cumulatively significant noise impacts require multiple sources and noise receptors, each in close proximity to each other, within the same time period; therefore, in the absence of a Project‐related impact, the Project would not contribute to a cumulatively significant traffic noise; therefore, the effect of traffic noise resulting from the Project would not be cumulatively considerable.

9.14 POPULATION AND HOUSING
Impact Statement: The Project would not result in a cumulatively considerable impact related to population and housing.

Finding
The potential cumulative impacts of the Project related to population and housing are discussed in detail in Section 6.5.14 of the Draft EIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to population and housing; therefore, no mitigation is required.

Substantial Evidence
A cumulatively considerable effect on population would occur if the Project, combined with cumulative development, would directly orindirectly induce substantial unplanned growth or displace substantial numbers of persons or housing necessitating the construction of replacement housing elsewhere. Under existing conditions, no residential structures are located on Development Sites; therefore, there the Project no potential to contribute to a cumulatively significant impact associated with the need to construct unplanned housing units. The MSJC Entitlements could result in development of up to 1,181 units of housing on the MSJC Site, but that is transferring residential capacity from the Development Site resulting in no net change in housing capacity in the City. Other cumulative projects, including the RSG SP and Butterfield Specific Plan, propose a variety of planned residential uses that have or will contribute to population increases in the City but accommodate planned growth. In July 2022, the City of Banning had an estimated population of 30,683. By 2045, the City’s population is expected to increase to 41,500 residents. Within the City, the cumulative projects anticipate development of up to 8,596 residential dwellings. Whether all of these units are ultimately constructed and/or occupied is dependent on future economic conditions and market demand. The cumulative projects represent 165 percent of the number of households forecast in the SCAG RTP/SCS Connect SoCal for 2045; though It should be noted the buildout plans for the BSP and RSG projects envision a 30‐  and 20‐year buildout, respectively; which extend beyond the SCAG forecast period.

The sites for the proposed electrical substation, reverse osmosis facility, potable water reservoir, and Sunset Avenue Bridge are previously planned projectsto support the utility service and transportation needs of the City. The infrastructure that would be constructed in connection with the Development Project and is either already planned for by the City or needed for planned growth as described in the City’s General Plan, IMP, CIP, and/or other City plans. The eventual development of these public 677

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facilities at some future point in time would not result in an unplanned indirect increase in population in the City. The SLB Extension entails the construction of thisroadway as an Arterial Highway between Highland Home Road and Sunset Avenue, in conformance with the City’s Circulation Element, and constitutes a planned infrastructure improvement. As the SLB Extension is implementing a portion of the City’s Circulation Element, it also would not indirectly induce population growth not previously considered by the City.

The Regional Housing Needs Allocation (RHNA) reflects the California Department of Housing and Community Development’s (HCD) determination of the projected housing needs in a region by household income level as a percent of the Area Median Income (AMI). The SCAG was tasked with allocating the RHNA among the jurisdictions in the SCAG region, which includes the City of Banning.

Banning’s RHNA for the current planning period which runs until 2029 is 1,673 units, which includes:
 510 very low‐ and low‐income housing units
 280 moderate‐income housing units
 883 above moderate‐income housing units
The City is able to meet the majority (1,316 units) of its current cycle RHNA with existing Land Use/Zoning classifications and projects that were either pending or approved (pipeline) projects at the time the Housing Element was updated, and on vacant or nonvacant (underutilized) sites. The remaining 357 units have been accommodated by the City’s rezoning of nonvacant or vacant sites.

These actions accommodate a total of 2,691 units, which provides sufficient capacity to meet the City’s 2021–2029 RHNA allocation.

Pursuant to Government Code Section 65890.1, land use patterns should be encouraged that balance the location of employment‐generating uses with residential uses, so that employment‐related commuting is minimized. As stated in Section 4.14.3.3 (page 4.14‐4) of the Draft EIR, the SCAG Connect SoCal Environmental Justice technical report indicates that Riverside County has a jobs‐to‐ housing ratio of 0.88, indicating that the region is “housing rich, but jobs poor.” While neither the City nor SCAG maintain formal statistics regarding Banning’s jobs‐housing ratio, previous evaluations indicated that the City of Banning followed similar trends asthe County as a whole, with more housing available than employment opportunities within the City. Based on the number of jobs (10,500) and housing stock (12,156 units), the City’s jobs/housing ratio would be calculated at approximately 0.86, slightly lower than Riverside County as a whole. Therefore, the jobs added by the Development Project and cumulative projects would serve to improve the jobs‐housing ratio, and would not result in substantial unplanned growth.

According to the Bureau of Labor Statistics (BLS), in February 2024, the Riverside‐San Bernardino‐ Ontario region’s civilian labor force exceeded 2,184,128 persons with more than 2,063,5980 people employed and an unemployment rate of 5.56 percent (or 120,530 persons)38. Within the City and the 38   Bureau of Labor Statistics, Civilian labor force and unemployment by state and metropolitan area, https://www.bls.gov/news.release/metro.t01.htm, Site accessed April 19, 2024. 678

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County of Riverside, the unemployment rate is 6.6 and 4.6 percent, respectively.39 Approximately 86.1 percent of Banning residents commute outside of the city for work.40 The Development Project is anticipated to provide up to 5,993 jobs at full buildout. Following current trends of the City having more housing available than employment opportunities; it is anticipated that local employees will seek jobs at the Development Site and that the Development Project would provide additional employment opportunities, while not displacing or reducing housing opportunities. The Project would provide job opportunities close to home for existing and future Banning residents, which would subsequently help achieve a better job‐to‐housing balance within the city. The employment generated from the Development Project would not induce substantial growth in the area because the Project would result in service‐oriented and industrial‐oriented jobs, which are jobs that are anticipated to be filled by residents of the city and surrounding area (see Final EIR, response to Comment D‐3‐18).

As the City has sufficient existing and planned housing for the anticipated employment growth, and because a sufficient pool of potential employees is available in the City and region, the Project would not cause substantial unplanned population growth or displace existing housing or people; therefore, population and housing impacts of the Project are not cumulatively considerable.

9.15 PUBLIC SERVICES
Impact Statement: The Project would not result in a cumulatively considerable impact related to public services.

Finding
The potential cumulative impacts of the Project related to public services are discussed in detail in Section 6.5.15 of the Draft EIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to public services; therefore, no mitigation is required.

Substantial Evidence
The cumulative impact area is the service area of the respective public service providers. The City maintains a schedule of development impact fees (DIF) imposed on development to fund public services and to offset future developments’ share of public facilities and capital improvements for Police Facilities, Fire Facilities, Parks and Recreation Facilities, General City Facilities, Wastewater Facilities, and Water Facilities.41 The fees collected are dependent on the type and size of development and fund the share of public facilities related to new development in the City. Public services to Project would be provided by the City (police), Riverside County (fire), the Banning Unified School District, and the Banning Library District, which maintain sufficient capacity to provide service 39   Monthly Labor Force Data for Cities and Census Designated Places (CDP) April 2024 ‐ Preliminary, California Economic Development Department.   40   Page 21, Pre‐certified Local Housing Data for the City of Banning, Southern California Association of Governments, updated April 2021. 41   Title 3 (Revenue and Finance) of the City of Beaumont’s Municipal Code also establishes a procedure for the identification of fees, revenue, and assessments to construct and maintain necessary public services and facilities.
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to the Project Sites (see Draft EIR Section 4.15). The Banning Library District (BLD), as it is a California Special District, is funded by property tax revenue. The annual estimate of costs of BLD operations is furnished to Riverside County and the tax required to fund library functions is computed, entered upon the tax rolls, and collected in the same manner as County taxes are computed and collected.

Under the provisions of Senate Bill (SB) 50, the Banning Unified School District (BUSD) is authorized to collect fees to offset the costs associated with increased demand on school facilities resulting from development. Under Assembly Bill (AB) 2926, this funding may go to acquiring school sites, constructing new school facilities, and modernizing existing school facilities. Pursuant to California Government Code Section 65995(h), the payment of these school fees (as established and ratified by the BUSD) by a developer would provide full mitigation of potential impacts on school facilities.

The City’s DIF impact analysisidentifies existing and future service population (residents plus workers) and existing and planned public facilities based on an estimated number of residents, dwelling units, employees, and building square feet in Banning, both in 2018 and in 2040. The base year estimates of residents and dwelling units comes from the California Department of Finance. Future resident and dwelling unit are based on draft Growth Figures from SCAG's Integrated Growth Forecast from the 2016‐2040 Regional Transportation Plan (RTP). Asthe DIF program has already accounted for the 2040 forecasted population/dwellings in the City, it is reasonable to anticipate that the fees established in the current DIF program (or the DIF program isin effect at the time of proposed physical development of cumulative projects). The City may use these feesto pay for the debtservice on the existing facilities or for the construction or purchase of buildings, equipment and land that are part of the system of public facilities to serve new development. As established in Sections 4.15 and 5.4.15.2 of the Draft EIR, the Project will be conditioned to pay applicable development impact fees and required school fees (as required by RCMs PS‐1 through PS‐3 and MSJC RCM PS‐2). The payment of said fees is required under Banning Municipal Code Section 15.68 and the California Government Code. The payment of required fees would off‐set and mitigate for any proportional Project‐related or cumulative projects’ increase in demand for public services.

The need for the proposed electricalsubstation has been identified to by the BEU to support the City’s existing General Plan’s long‐term growth. The potable water reservoir is required to provide the long‐ term water storage requirements of the City and the approved RSG project. The need for additional water storage capacity was identified in the City’s Integrated Master Plan (2018) and the RSG EIR, but the exact location was not identified at that time. The SLB Extension would implement the City’s Circulation Element. As these facilities themselves are planned services to meet public demand, and because activity at these public facilities would be limited to periodic inspection and/or maintenance, no cumulative substantial adverse impacts are anticipated from construction of these facilities which accommodate planned for increases in demand for public services.

As noted in Section 6.3 of the Draft EIR, a number of cumulative projects are located within the City of Beaumont. Similar to the City of Banning, per Title 3 of its Municipal Code,42 the City of Beaumont also maintains a development fee program “Development Related Fee Schedule” (July 1, 2023) that identifiesthe feesrequired to fund public services, including, but not limited to: Fire Protection Impact 42   City of Banning. 2023. Municipal Code, Title 3  ‐  Revenue and Finance. November 22. Website:
https://library.municode.com/ca/beaumont/codes/code_of_ordinances?nodeId=TIT3REFI (accessed September 5, 2023).
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Fee, Police Facilities Impact Fee, Recreation Facilities Impact Fee, Park(s) Impact Fee(s), and Public Facility Fees. The Beaumont Unified School District maintains Level 1 fees for residential uses, commercial, industrial, and self‐storage uses.43 It is reasonable to assume that applicable fees for cumulative development occurring within the City of Beaumont or within the Beaumont Unified School District would be collected by the City or Beaumont USD prior to the construction of those projects and that these fees would appropriately address the proportional cumulative demand for public services in the City of Beaumont.

Although public service impacts tend to be cumulative in nature, each cumulative project would be required to pay development impact fees, school fees, and/or property tax assessments to provide for its fair‐share contribution to any increased demand for public services in the jurisdiction in which it is located. With payment of such fees and tax assessments, which is required pursuant to Banning Municipal Code Chapter 15.68, the Project's contribution to public services impacts is not cumulatively considerable. Further, as the payment of such fees is required for the cumulative development projects, in either the City of Banning or Beaumont, it is reasonable the cumulative impacts on public facilities would not be significant.

9.16 RECREATION
Impact Statement: The Project would not result in a cumulatively considerable impact related to recreation.

Finding
Potential cumulative impacts of the Project related to recreation are discussed in detail in Section

6.5.16 of the Draft EIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to recreation; therefore, no mitigation is required.

Substantial Evidence
The cumulative area for the discussion of recreation facilities/services is the City of Banning. There are currently seven developed public parks within the City, which range in size from the approximately

0.33‐acre Carpenter‐Hamilton Park to the 20‐acre Dysart Equestrian Park. The total parkland acreage in the City of Banning is 66.67 acres, including both active and passive recreational areas The City’s Community Center/Municipal Pool complex occupies an additional 14 acres (see Draft EIR, Table 6.A).

The Development Project does not propose any residential uses or other land use that may generate population that would directly increase the use of existing neighborhood and regional parks or other recreational facilities. The MSJC Entitlements do not propose any development at this time, would accommodate the transfer of residential capacity to the MSJC Site and do not cause an increase in residential units or population in the City that was not previously accounted for in planning or funding programsfor park and/or recreation facilities. Any future development of the MSJC Site would comply with applicable requirements to either include recreational facilities or parks as part of the development or housing units, or would require dedication of and/or payment of required park fees likely resulting in no significant impact on City and regional recreational facilities. Approximately 210 43   Beaumont Unified School District (USD). n.d. Developer Fees, Current Developer Fee Rates. Website:
https://www.beaumontusd.us/apps/pages/Developer_Fees (accessed September 5, 2023). 681

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acres of parks and open space areas are provided within the approved RSG project. Facilities within the RSG project include: an entry park (1.1 acres), neighborhood park (12.7 acres), confluence park (10.2 acres), and community park (26 acres); a linear park along Smith Creek and Pershing Creek (122 acres); village paseos (12.6 acres); and natural open space (25.7 acres), all of which would be in proximity to the Project Sites (Draft EIR, pg 6‐52).

The City determines park demand on a per resident basis. Industrial and commercial uses are not considered by the City to generate park and recreation demand. As described in Section 6.1.14 of the Findings, the Project would not include the development of residential units and as a result buildout of the Development Project would not directly add to the existing population of the City and would not generate new residential park demand. Buildout of the Development Project is anticipated to increase employment in the City by approximately 5,993 jobs, the majority of which are anticipated to be filled by existing City residents or existing County residents as discussed in Section 4.14 of the Draft EIR and Section 6.1.14 of these Findings.

It can be assumed that existing City, City of Beaumont, and County residents already use park and recreation facilities within the respective jurisdictions. Buildout of the Development Project would not indirectly result in a population increase in the City that has not been accounted for. Therefore, the Development Project would not result in existing park and recreational facilities in the City being used by more residents. Nevertheless, the Development Project includes approximately 12.6 acres of Open Space – Parks (comprising a 5.0‐acre passive park and 7.6 acres of passive open space. The passive park on the Development Site would be open to the public and would be accessible to City residents and employees(including Development Site employees) and would add to the existing City’s existing park inventory.

While the City currently does not meet its per resident park requirements, because the Development Project is not expected to result in an unplanned increase in the number of residents and because the City does not consider industrial or commercial uses as generating park and recreation demand, the Development Project is not anticipated to generate an increased need for use of existing neighborhood or regional parks and other recreational facilities such that substantial physical deterioration of facilities would occur or be accelerated and no cumulatively considerable impact would occur. Chapter 15.68 (Development Impact Fees) of the Banning Municipal Code identifies requirements to fund required public facilities, including parkland and recreation facilities. Banning Municipal Code Chapter 15.68 imposes park fees on new residential, commercial, and industrial development to pay for recreational facilities to meet the increased needs, if any, from the effects of new, non‐residential development. Each of the cumulative projects along with the Project would be subject to such paymentrequirements. With payment ofsuch required fees, the Project's contribution to recreation impacts is not cumulatively considerable. Other cumulative projects in the City would be required to demonstrate their level of impact on recreational facilities, including payment of the appropriate development impact fees; therefore, the Project would result in a less than significant cumulative impact related to recreation.

9.17 TRANSPORTATION
Impact Statement: The Development Project’s VMT non‐retail VMT per employee (30.8) would exceed the City’s significance threshold of (25.9) by 4.9, an increase in per employe e VMT of 18.9 682

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percent. While the Transportation Demand Measures implemented pursuant to Mitigation Measure TRA‐1 (which would incorporate Project Design Features T‐1 through T‐3) would realize a maximum

8.4 percent reduction in commute VMT, Project generated VMT per employee would still exceed the City’s adopted VMT impact threshold. Therefore, even with the implementation of MM TRA‐1, the Project’s VMT impact would remain significant and unavoidable. The remaining cumulative transportation impacts are less than significant.

Finding
The potential cumulative impacts of the Project related to transportation are discussed in detail in Section 6.5.17 of the Draft EIR. The City finds that the Development Project would result in less than significant impacts relating to conflicts with the circulation system, roadway design hazards, and emergency access, and therefore, the Development Project would not result in a cumulatively considerable impact. Because the Development Project would result in a significant cumulative VMT impact, the City finds that implementation of Mitigation Measure TRA‐1 would reduce impacts to the extent feasible; however, impacts would remain significant and unavoidable. The City finds that the stated mitigation isfeasible, is adopted, and will reduce to some measure, the level of VMT generated through operation of the proposed uses. The implementation and effectiveness of TDM measures will vary according to the tenants which are unknown at this time; therefore, the extent and effectiveness of mitigation cannot be determined. The significance determination is based on a conservative worst‐ case scenario whereby it is assumed that effectiveness of VMT mitigation and project design features cannot be guaranteed based on research to date, and no additional mitigation is feasible, and therefore, the City finds that the impacts are significant and unavoidable. Pursuant to Section 21081(a)(3) of the California Public Resources Code, as described below, the City has determined that specific economic, legal,social, technological, or other considerations make infeasible the alternatives and mitigation measures identified in the EIR.

Substantial Evidence
A significant cumulative transportation impact would occur if cumulative development conflicts with transportation programs, plans, ordinances, or policies, results in inadequate emergency access, increases transportation hazards, or is inconsistent with VMT reduction policy established by the City.

As discussed in Section 4.17 of the Draft EIR, the Development Project would result in less than significant impacts relating to conflicts with the circulation system, roadway design hazards, and emergency access. To comply with the City’s General Plan and the Banning Municipal Code requirements, development of other past, present, and reasonably foreseeable projects in the City would be required to meet standard requirements to provide transportation facilities that accommodate both pedestrian, bicycle, and vehicle travel and to avoid roadway design hazards and emergency access. Therefore, the Development Project would not result in circulation system, roadway design hazards, and emergency access impacts that are cumulatively considerable.

The proposed electrical substation, reverse osmosis facility, and potable water reservoir would be public facilities. While these facilities would require period inspection/maintenance, per the City’s guidelines, local‐serving community projects and local‐serving essential services are screened from VMT analysis and are assumed to have a less than significant impact. Based on the VMT screening analysis conducted for the SLB Extension, the With Project condition results in a substantial reduction of VMT within a 5‐mile and 10‐mile radius of the SLB Extension and would likely increase Countywide 683

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VMT by approximately 0.0005 percent. This increase is well within the margin of error for transportation models, and as such may not be indicative of a significant impact. When compared with the base year (2012) condition, the SLB Extension results in a decrease under all analyzed geographic limits (5‐  and 10‐mile radius and Countywide); therefore, the VMT impact of the SLB Extension was determined to be less than significant and not cumulatively considerable.

Interstate 10 (I‐10) borders the Project site to the north; the Highland Springs Avenue/I‐10 interchange is located approximately one mile west of the Development Site; and Sunset Avenue interchanges with I‐10 immediately northeast of the Development Site. This Development Site’s location provides direct access to the Project via the interstate freeway system, minimizing trip lengths and VMT for all patrons and employees and reducing travel distances for movement of goods.

This is also consistent with the SB 743 legislative intent. Furthermore, the Project is located within an urbanized area, proximate to prospective employees and patrons. Uses proposed by the Project would increase and diversify the City’s economy and would provide new and varied employment and commercial opportunities closer to the local workforce and customers (see Final EIR, Section 3.0, response to Comment D‐3‐24). The Development Site is located in an area considered to be generally housing rich and jobs poor; therefore, the Project uses at this location promote a balanced jobs/housing condition, reducing commuter trip lengths and VMT. Please refer Final EIR, Section 3.0, responses to Comments D‐3‐8 and D‐3‐18.

Regardless of the Development Project’s location or contribution to remedying the City’s current jobs/housing imbalance, the Development Project’s VMT net change for retail uses and VMT per non‐ retail worker exceeds the City’s respective thresholds of no net increase in regional VMT for retail and

25.9 VMT per non‐retail worker. Even with implementation of the limited feasible mitigation measures, the Development Project’s VMT cannot be reduced to levels that would be less than significant, and the Project wasfound to have a significant and unavoidable VMT impact at the project level. Implementation of Mitigation Measure TRA‐1, including the project design features T‐1 (Commute Trip Reduction Marketing), T‐2 (Ridesharing Program), and T‐3 (End‐of‐Trip Bicycle Facilities) would reduce VMT by 8.4 percent, lessthan 15.9 percent reduction necessary for a lessthan significant VMT impacts. While it is possible the reduction could be greater, because the tenants of the Development Site are currently unknown, this cannot be determined at this time. Therefore, conservatively, even with implementation of all feasible mitigation, Development Project VMT impacts would not be substantially lessened and would remain significant and unavoidable.

Therefore, the Development Project’s contribution to cumulative transportation impacts from increases in VMT would be considerable and significant.

As previously stated in Section 5.4.17.2, moving residential density from the Development Site to the MSJC Site itself would not result in a significant increase in residential units or population beyond that previously considered by the City in its development of its VMT Guidelines. As the MSJC Site is directly adjacent to the Development Site, the proposed MSJC Entitlements and the potential future development of the MSJC Site would not likely increase trip lengths (vehicle miles traveled).

Nonetheless, future development on the MSJC Site will require a project‐specific VMT assessment.

Because the Development Project’s VMT impacts are significant and unavoidable, as a whole, the Project’s contribution to cumulative transportation impacts from increases in VMT would be considerable and significant.
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Changes to the CEQA Guidelines were adopted in December 2018, which require all lead agencies to adopt VMT as a replacement for automobile delay‐based level of service (LOS) as the new measure for identifying transportation impacts for land use projects. This statewide mandate took effect July 1, 2020. Environmental documents for cumulative projects published subsequent to this date (e.g., SLVN and BPSP projects) identified significant VMT impacts. Despite the implementation of mitigation for these projects, the VMT impacts of these other cumulative projects remained significant and unavoidable.

9.18 TRIBAL CULTURAL RESOURCES
Impact Statement: The Project has the potential to result in cumulative impacts to tribal cultural resources.

Finding
The potential cumulative impacts of the Project to tribal cultural resources is addressed in in Section

6.5.18 of the Draft EIR. While no tribal cultural resources are known to occur within the limits of the Development or MSJC Site, through the removal of vegetation or ground disturbance, implementation of the Project has the potential to impact previously unknown or undetected tribal cultural material.

The City finds that Mitigation Measures CUL‐1 through CUL‐6 are feasible, adopted, and would reduce these impacts to a less than significant level. The City has determined that these measures, incorporated into the Project, reduce the potential significant impact identified in the Draft EIR to a less than significant level.

Substantial Evidence
Potential cumulative impacts to known or unknown tribal cultural resources may result from cumulative development in the City and elsewhere and may contribute to cumulatively significant impacts to these resources. However, for each development proposal, the City must engage interested tribal governments pursuant to AB 52 and/or SB 18 and with appropriate project‐specific mitigation, cumulative impacts would be less than significant. The cumulative area for tribal cultural resources is the area(s) of traditional tribal interest identified by respective tribes. Native American consultation was conducted by the City in compliance with Assembly Bill (AB) 52 and Senate Bill (SB) 18 for both the Development project and the MSJC Entitlements. As part of the initial consultation process, a review of the Sacred Lands File (SLF) by the Native American Heritage Commission (NAHC) yielded negative results. Subsequently, a total of 31 Native American representatives were contacted by the City to determine their desire to consult on the Development Project. The City received consultation requestsfrom the Morongo Band of Mission Indians(MBMI), the Soboba Band of Luiseño Indians, the Agua Caliente Band of Cahuilla Indians, and the San Manuel Band of Mission Indians.

Initial consultation meetings were held on April 7, 2022, with MBMI and on April 20, 2022, with the Soboba Band of Luiseño Indians. Because there was no further follow up from the Agua Caliente Band of Cahuilla Indians after the initial consultation request, and the San Manuel Band of Mission Indians did not respond to the initial request, tribal consultation efforts did not move forward beyond the initial tribal consultation request that was received (Draft EIR, Section 4.18.2).

The Development Project is located within the ancestral territory and traditional use area of the Cahuilla and Serrano people of the MBMI. Because the Development Site is located in an area 685

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considered to be sensitive for tribal cultural resources, ground disturbance associated with implementation of the Development Project has a potential to affect undiscovered tribal cultural material, which may inform or provide broader knowledge/context of tribal resources located elsewhere. As such, the Development Project has the potential to result in a substantial adverse change in the significance of a tribal cultural resource. The MBMI emphasized the importance of including archaeological and Native American monitoring in order to thoroughly assess if there are any tribal cultural resources are located at the Development Site.

As detailed in Section 4.18.6.1 of the Draft EIR, mitigation described under MM CUL‐1 through MM CUL‐6 would: (1) require the retention of a qualified archaeologist during all ground disturbance activities and the conduct of a pre‐construction archaeological sensitivity training; (2) mandate development of an archaeological monitoring treatment plan; (3) establish a Native American monitoring agreement detailing the presence, extent, and authority of Native American monitoring during ground disturbance activities; (4) identify the notification process related to human burials; (5) establish a processfor the treatment and disposition of archaeological or Native American cultural material (including human remains); and (6) ensure disclosure of all project‐related cultural data to consulting Native American parties. Implementation of these mitigation measures would reduce impacts to tribal cultural resources within the Development Site to a less than significant level and would not contribute to cumulatively significant impact relative to tribal cultural resources.

The City engaged in Native American consultation related to the SLB Extension, providing cultural resources assessment prepared for the project to the Morongo Band of Mission Indians. No tribal cultural resources were identified within the alignment, nor did the results of the Native American Heritage Commission Sacred Lands File Search indicate the presence of any sacred sites/or locations of religious/ceremonial importance in the SLB Extension study area. Mitigation was identified to reduce potential impacts related to the inadvertent discovery of Native American cultural materials to a less than significant impact. The cultural resources survey areas, survey reports, and tribal consultation for the Development Site encompass the area planned for the eventual development of the electrical substation, reverse osmosis facility, and water reservoir; therefore, it is reasonable the cumulative effect is accounted for in the impacts identified for the Development Site. As the Sunset Avenue Bridge was a component of the RSG project, the impacts of that facility have been considered in the EIR for the RSG project.

For other cumulative projects in the City, the City’s General Plan EIR44 states, “… All development or land use proposal which have the potential to disturb or destroy sensitive cultural resources shall be evaluated by a qualified professional and, if necessary, comprehensive Phase 1 studies and appropriate mitigation measures shall be incorporated into project approval.” This requirement applies equally to City‐sponsored public facility projects. The City maintains a standard practice of providing site‐specific cultural assessments to interested Tribes for review and comment during the consultation process and prior to final City acceptance of said assessments. Furthermore, completion of the consultation processes required under AB 52 and SB 18 and the incorporation of measures recommended by interested tribal governments, is required prior to completion of the CEQA process on all projects. All cumulative projects would be required to conductsite specific assessments, consult 44   City of Banning. 2005. Environmental Impact Report for the City of Banning Comprehensive General Plan and Zoning Ordinance, Section III(G)(3).
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with the interested Tribes, and would be subject to appropriate mitigation measures. Projects located outside the City, within areas of tribal interest, will also be required to comply with applicable existing statutes, regulations, procedures, and policies that address tribal cultural resources, including consultation under SB 18 and/or AB 52. As tribal consultation is required under CEQA, it is reasonable to anticipate that cumulative projects located outside of the City would conduct appropriate assessment to assess potential impacts to tribal cultural resources and to identify and implement appropriate mitigation (similar to or equivalent to the City’s standard measures) so that the cumulative projects would not constitute or contribute to a cumulative considerable or significant impact to tribal cultural resources.

9.19 UTILITIES
Impact Statement: The Project would not result in a cumulatively considerable impact related to utility and service systems.

Finding
The potential cumulative impacts of the Project relative to utility and service systems is provided in Section 6.5.19 of the Draft EIR. The City finds that the Project would not result in a significant cumulative impact related to utility and service systems; therefore, no mitigation is required.

Substantial Evidence
A significant cumulative impact would occurif demands of cumulative development exceed the supply or capacity of existing utility and service systems or result in the construction of new or expansion of existing public utility facilities. The cumulative area for the discussion of utility and service system impacts is the service area of the respective providers. The City manages its own water and wastewater through the City Water and Wastewater Utilities Department and electrical services through the BEU, a not‐for‐profit, publicly owned electrical energy distribution utility. Solid waste collection and transport services in the City, including the SOI, is provided by Waste Management of the Inland Empire. The City’s 2018 Integrated Master Plan (IMP) evaluates the performance and condition of the City’s potable water, wastewater, and recycled water systems through 2040. Since the adoption of the 2015 UWMP, the 2020 UWMP identified, among other proposed uses, eight new developments and included the Butterfield and RSG developments as well as water supply for the mixed use project located on the Development Site. The BSP and RSG project plans, which combined, envision the development of 7,996 residential units. Each project subject to CEQA is required to prepare its own water supply assessment (WSA) to show sufficient water supply to meet the project demand in normal, dry, and multiple dry years.

The Sites (including the area currently within the SOI which will be annexed) are within the service area of Banning Electric Utility (BEU), a not‐for‐profit publicly owned utility. The City manages a Water and Wastewater Utilities Department. The Development Site (including the SOI) and the MSJC Site are both within the City’s service area for these services. The total annual electricity consumption in the BEU service area in 2022 was 151.5 gigawatt‐hours (GWh). The BEU has included the energy usage by this Development Project as well as other large commercial and residential developments or industrial projects in its future planning, which has enabled it to enter into long‐term contracts for the purchase 687

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of renewable sources of electricity as required by State law.45 The Project, in combination with cumulative projects, is well within BEU’s system‐wide net increase in electricity supplies annually over the 2018 to 2030 period (See Draft EIR, pg 6‐33).

The City’s 2020 Urban Water Management Plan conservatively anticipates a projected water demand of 9,507 afy in 2025. In 2045, with an anticipated population within its service area of 66,400, the UWMP projects a demand of 13,467 afy. Per the UWMP, sufficient water is available to the City to meet future water demand during normal, dry, and multiple dry year conditions through 2045. The project‐specific Water Supply Assessment (WSA) provides a comparison of water demand versus water supply based on the General Plan land uses detailed in the 2020 Urban Water Management Plan, including the BSP and RSG projects and indicated sufficient water to supply the Development Project and MSJC Site would be available in normal, dry, and multiple‐dry years through 2045. See Draft EIR, Section 4.19, pages 4.19‐20 through ‐24, including Tables 4.19.I through 4.19.K, and Section

5.4.19.2, pg 5‐75. Because the Project shows a sufficient water supply, the Project would not have a cumulatively considerable or significant impact on water supply.

For wastewater, the City’s Average Dry Weather Flow (ADWF) is projected to increase from 2.80 mgd (2025) to 4.29 mgd by year 2040. As stated in Section 4.19 of this EIR, the City’s current wastewater treatment capacity is 3.5 mgd, sufficient to accommodate the cumulative development (including the BSP and RSG projects). The IMP identified the share of improvements needed to serve existing development and the share needed to serve new development for water and wastewater demand requirements. The City has preexisting plansto upgrade the existing WWTP treatment to meet tertiary standards and facilitate infrastructure to supply recycled water. These upgrades are included in the City’s current CIP. The design of the upgraded WWTP will allow for expansion of the treatment capacity when it becomes necessary. Further, both the BSP and RSG project include provisions for the installation of satellite or package treatment plants that would accept flows from those projects. The requirement for these facilities would be determined as necessary by the City, as development within those projects occur. As facilities are brought on‐line, wastewater flows to the City’s WWTP would be reduced. As detailed in the Draft EIR, Table 4.19.L, the Development Project would generate approximately 0.353 mgd. The increase in wastewater generated by the Development Project can be accommodated within the existing design capacity of the WWTP and no significant wastewater impacts was identified in the Draft EIR. The City’s Development Impact Fee Update Study outlines and updates development impact fees that are imposed on new development in the City to fund public services and includes wastewater and water facilities and improvements allotted to new development. The City imposes development impact fees for Wastewater Facilities, and Water 45   Long‐term forecasts included in the City’s 2015 Power Supply Integrated Resource Plan (IRP) recognize growth in electrical demand from the Rancho San Gorgonio project and the Butterfield – Pardee Home projects, which envision the development of 3,385 and 4,862 residential units, respectively. The anticipated growth in electrical demand in the IRP anticipated that up to 200 homes each year would be built from 2020 through the end of the project period (2034). It was also assumed there would be additional commercial development to support the increased population. The First Hathaway Industrial project (currently under environmental review) envisions development of 1.42 million square feet of industrial warehouse uses north of I‐10. The development of this use is consistent with the existing land use designation (“Business Park”) for that site established by the City; therefore, it is reasonably included in IRP forecasts of future demand.
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Facilities for all development projects. See Banning Municipal Code Chapters 15.068.060 and

15.068.070. As with the Development Project and development on the MSJC Site, developments on all other projects in the City would be required to pay fees to support the water and wastewater system improvements necessary to serve their individual demands. With payment of such fees and tax assessments, which is required pursuant to Banning Municipal Code Chapter 15.68, the Project's and cumulative projects’ contribution to public services impacts are not cumulatively considerable.

The development of the reverse osmosis facility is not needed or required to supply water for the Development Project. The City would develop, own, maintain, and operate the reverse osmosisfacility in order to reduce salt and nitrogen in the water prior to recharge of the aquifer. The reverse osmosis facility that would be built in PA 12 of the Development Site would receive treated water from the existing Banning WRF via a 24‐inch diameter pipeline that is currently located in the future SLB Extension. The treated water would flow into the reverse osmosis facility where TDS (specifically nitrates) would be separated from the treated water. Grey water with the TDS would be recirculated back to the Banning WRF for additional processing. The waterseparated from the TDS (nitrates) would exit the reverse osmosis facility through a 24‐inch diameter pipe where it would be conveyed to the golf course at the neighboring Sun Lakes Community and used for irrigation of the golf course. The reverse osmosis facility would operate as a closed system. The electrical substation and water reservoir are planned public facilities.

The SCAG estimates the City’s 2045 population and employment at 41,500 persons and 11,400 jobs, respectively. Based on current daily per capita disposal rates of 5.6 and 31.5 pounds for residents and employees, future project development in the City could generate up to 591,500 pounds (295.8 tons) of solid waste per day. The volume of solid waste represents approximately 2.9 percent of the current permitted daily throughput of receiving landfills (see Draft EIR, Table 4.19.G). Remaining permitted capacity at the receiving landfills totals approximately 171 million tons. Cumulative solid waste generated City‐wide in 2045 represents approximately 1.4 percent of permitted capacity at receiving landfills.46 As the receiving landfill capacity is permitted through 2059,47 the cumulative contribution of solid waste from the City would not have a cumulatively significant effect on landfill capacity.

The City’s 2018 Integrated Master Plan (IMP)48 evaluates the performance and condition of the City’s potable water, wastewater, and recycled water systems through 2040. The IMP identified six master planned communities,49 other residential developments, and three commercial/industrial developments.50 The six master planned communitiesinclude a mixture of residential, public facilities, commercial, and open space. These developments considered in the IMP include the BSP and RSG project plans, which combined, envision the development of 7,996 residential units. To addressfuture 46   295.8 tons/day x 365 days = 107,967 tons/yr x 22 years = 2.375 million tons cumulative solid waste City wide through 2045. This calculation assumes existing generation rates. Future decreasesin per capita waste generation would proportionally reduce 2045 solid waste totals.   47   Lamb Canyon Landfill through 2032; El Sobrante Landfill through 2051; Badlands Landfill through 2059. 48   Carollo Engineers, Inc. 2018. 2018 Integrated Master Plan, Final Report, Revision 1.2. March.   49   Planned Communities: Black Bench, Five Bridges, Little Europe, Loma Linda, Pardee Butterfield, and Rancho San Gorgonio.   50   Carollo Engineers, Inc. 2018. 2018 Integrated Master Plan, Final Report, Revision 1.2. March. Figure 2.4 Known Developments.
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water and wastewater demand requirements, the IMP identified the share of improvements needed to serve existing development and the share needed to serve new development. The Capital Improvement Program (CIP) isthe foundation of the City’slong‐range capital investment and financial planning. The CIP establishes a specific list of projects to be completed for capital replacements and improvements. The City’s Development Impact Fee Update Study outlines and updates development impact fees that are imposed on new development in the City to fund public services. The Development Impact Fee Update Study identifies the wastewater and water facilities and improvements allotted to new development. The City imposes fees on future developments for capital facilities in the form of a development impact fee for Wastewater Facilities, and Water Facilities. Banning Municipal Code Chapters 15.068.060 and 15.068.070 identify the process for how the development impact fee is administered for required wastewater and water improvements in the City.

The Project and the cumulative projects would each be subject to connection and improvement requirements of the respective utility. Cumulative development would require the construction of necessary infrastructure (water and wastewater lines, storm drain facilities, dry utilities, and others) to serve each project. It is reasonable that as cumulative development is proposed, each such development project would undergo review by the City and appropriate service provider(s) to ensure adequate capacity, supplies, and/or facilities. Similar to Regulatory Compliance Measure (RCM) UT‐1 (see Section 4.19), cumulative projects would be required to pay appropriate required wastewater and water facilities Development Impact Fees required under Section 15.68 of the Banning Municipal Code. As with the Project, adherence to applicable connection requirements, the design of improvements per the utilities’ standards, and payment of required fees and tax assessments, which is required pursuant to Banning Municipal Code Chapter 15.68, would result in a cumulative effect to utility services is neither considerable nor significant, and no mitigation is required.

9.20 WILDFIRE
Impact Statement: The Project would not result in cumulatively considerable impact related to wildfire.

Finding
The potential cumulative impacts of the Project related to wildfire are discussed in detail in Section

6.5.20 of the Draft EIR. The City finds that the development of the proposed Project would not result in significant cumulative impacts related to wildfire; therefore, no mitigation is required.

Substantial Evidence
A significant impact would occur if cumulative development (including infrastructure) increases or exacerbates fire risk or impairs emergency response/evacuation plans. While the Development Site is located in a wildland‐urban interface (WUI) setting, it is not located in an area statutorily designated as a Moderate, High, or Very High Fire Hazard Severity Zone (FHSZ) by the California Department of Forestry and Fire Protection or Riverside County. The Development Project has been designed to reduce wildfire conditions on the Development Site as compared with the natural state. As stated in the Fire Protection Plan (FPP) (see Draft EIR, Appendix G‐2) once the Development Project is built, the 690

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on‐site fire potential will be lower51 than its current condition due to conversion of fire facilitating wildland fuels to ignition resistant buildings, parking areas, managed landscapes, fuel modification areas, improved accessibility for fire personnel, and structures built to the latest ignition and ember resistant fire codes. The Development Project is also accessible to local fire department personnel within acceptable fire response travel times. In addition, the Development Project will adopt a “Ready, Set, Go!” plan for evacuation. When an evacuation is ordered, it will occur according to pre‐ established evacuation decision points or as soon as a notice to evacuate is received, which may vary depending on many environmental and other factors. Therefore, although the Development Project will increase occupancy of the Development Site, it is anticipated that with compliance with building code requirements and Condition of Approval (COA) FIRE‐1, Project impacts would be less than significant.

The MSJC Site is located within a Local Responsibility Area and is designated as a non‐VHFHSZ. Both the Development and MSJC Sites are located within the Wildland Urban Interface (WUI) influence zone. As discussed in Section 5.4.9.1 of the Draft EIR, MSJC Site Mitigation Measures HAZ‐3 requires the preparation of a project‐specific fire protection plan for development on the MSJC Site (at a time when such development occurs). To meet fire code requirements, MSJC Site development would incorporate the same or similar design features as required for the Development Site. The Project would be required to adhere to FPP and fuel management plans (FMP) approved by the City and the Riverside County Fire Department (RCFD). Compliance with these plans would reduce the likelihood of urban conflagration on the Project Sites in the unlikely event of a wildfire and reducing impacts to a less than significant level; therefore, the Project would not have a cumulatively considerable wildland fire impact.

The proposed electrical substation would be developed and operated by the City in compliance with regulations set forth by the California Occupational Safety and Health Administration (Cal/OSHA) and the National Electrical Safety Code (NESC). The reverse osmosis facility and potable water reservoir would be operated by the City in compliance with standards as set forth by the City of Banning Water and Wastewater Department. These facilities would be remotely operated and monitored and include fire suppression features (i.e., sprinklers, defensive space, and fire alarms) that would reduce the exacerbation for fire risk. Chapter 1206 was added to the California Fire Code (CFC) to address a wide range of systems to generate and store energy, including standby and emergency power, portable generation, photovoltaic systems, fuel cell energy systems, and energy storage systems. The provisions of Chapter 1206 apply to the installation, operation, maintenance, repair, retrofitting, testing, commissioning, and decommissioning of these energy systems. It is anticipated the installation and operation of a battery energy storage system as envisioned, as permitted under the Specific Plan, would be conditioned by the City to demonstrate compliance with California Fire Code Chapter 1206. As the City‐sponsored infrastructure and facilities will be constructed, operated, and maintained pursuant to required fire protection requirements for utility facilities, the potential for increased fire risk from these facilities, and the cumulative impact, would be less than significant.

A number of cumulative projects in the cities of Beaumont (e.g., Fairway Canyon, Beaumont Pointe, Heartland) and Banning (e.g., RSG and Butterfield) are located within five miles of the Project Sites and are located within or adjacent to fire hazard severity zones (very high, high, and moderate) 51   Dudek. 2023. Fire Protection Plan Sunset Crossroads. November. 691

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designated by CAL FIRE. As with the Project, cumulative development proposed, approved, and developed within fire hazard severity zones would be required to prepare a project‐specific fire protection plan complying with applicable provisions of the most current edition of the CFC as adopted and amended by Banning Municipal Code Chapter 8.16, City of Beaumont Chapter 15.20, and/or Chapter 8.32 of the Riverside County Code; including applicable portions of CFC Chapter 49 related to development within fire hazard severity zones and wildland‐urban interfaces. It is reasonable the cumulative projects have or will be appropriately conditioned by the approving jurisdiction (City/County) to fully incorporate and implement the features, facilities, and practices established in site‐ and project‐specific FPPs. As with the Project, adherence to these provisions of these FPPs will ensure wildland fire hazards associated with individual projects are reduced to a less than significant level; therefore, with the collective establishment and implementation of the cumulative FPPs, wildfire hazard impacts will not be cumulatively significant.

No emergency facilities are located on the Project Sites nor do the Project Sites currently serve as emergency evacuation routes. During construction and operation of the Development Project and MSJC Site, adequate access for emergency vehicles would be maintained. Cumulative development in the City would increase the number of persons (residents, employees, and patrons) susceptible to wildfire hazards. While the location, intensity, direction, frequency, and/or nature of future wildfire events cannot be precisely predicted, it is reasonable that fire authorities would exercise appropriate judgement as to when, where, and how evacuations are executed. It is further reasonable that during the processing of cumulative development, necessary roadway improvements will be appropriately located and sized to accommodate efficient and safe evacuation as necessary. Implementation of the project specific FPPs through the establishment of fuel management zones, and the installation of water delivery features (e.g., water mains, hydrants, storage capacity) necessary for cumulative development will facilitate firefighting operations should a wildfire event occur. The cumulative development sites would be required to accommodate emergency access and facilities. As such, the Development Project’s contribution to cumulatively considerable impacts would be less than significant. The related SLB Extension would improve circulation within and around the Development Site by improving the road surface and providing additional lanes of traffic that could be used to evacuate in an emergency and allow emergency personnel to access the Development Site and adjacent residential communities faster than using the roadways currently available.

In the unlikely event that a wildfire should spread to the Project Sites, it is not expected that the Development Project would contribute any additional runoff or sedimentation to the on‐site natural drainages or other downstream drainages. The drainage improvements installed on the Project Sites would remain intact after a major wildfire, allowing them to continue to reduce the potential for flooding conditions. Downslope fire‐related flooding hazards are generally site specific and would not extend beyond the immediate area of the Project Sites; therefore, there would be no cumulative effect related to post‐fire down‐stream flooding resulting from other cumulative projects. As such, the Project would not result in a cumulatively significant impact related to this issue. 692

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10.0 FINDINGS REGARDING ALTERNATIVES

10.1 ALTERNATIVES CONSIDERED AND REJECTED
In accordance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines (Section 15126.6), an EIR must describe a reasonable range of alternatives to the project, or to the location of the project, that could feasibly attain most of the project’s basic objectives (see Draft EIR, Sections 3.7 and 8.1.2), while avoiding or substantially lessening any of the significantly adverse environmental effects of the project (see Final EIR, Table 8.A), and evaluate the comparable merits of the alternatives.

The Project’s significant impacts that cannot be mitigated to less than significant are air quality, greenhouse gas emissions, construction noise (off‐site roadway/utility improvements only), and VMT.

In accordance with Section 15126.6(c) of the CEQA Guidelines, an EIR should identify alternatives considered for analysis but rejected as infeasible, and briefly explain the reasons for their elimination.

Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR is a failure to meet most of the basic project objectives, infeasibility, or inability to avoid any of the project’s significant environmental impacts. Additionally, regarding the feasibility of potential alternatives, CEQA Guidelines Section 15126.6(f)(1) provides:
(f) Rule of Reason. The range of alternativesrequired in an EIR is governed by a "rule ofreason" that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. (1) Feasibility. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries… and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site…
In determining an appropriate range of project alternatives to be evaluated in this EIR, a number of possible alternatives were initially considered and then rejected. The following alternatives have been considered and rejected as infeasible, either because they would exceed or not substantially lessen the impacts of the Project being analyzed, are repetitive of other alternatives, or, based on City input, would not meet most of the City’s basic objectives and requirements, or are otherwise considered infeasible.

The City has independently reviewed and considered the information on alternatives provided in the EIR, and the EIR reflects the City's independent judgment as to the alternatives. Six alternatives considered and rejected are described below, and reasons for infeasibility are provided in the discussion. Each individual reason presented below constitutes a separate and independent basis to reject the project alternative as being infeasible.
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10.1.1 Off‐Site Alternative
Regarding alternative locations, per CEQA, the first step is to determine whether any of the significant effects) would be avoided or substantially lessened by putting the project in a different location. Only locations that would avoid or substantially lessen any of the significant effects need be considered.

Any development of the size and type proposed by the Project would have substantially the same environmental effect, regardless of where in the City it was located. The Development Site consists of 533.8 contiguous acres under a single ownership. Based on a review of the current and proposed development in the City, no single undeveloped property of sufficient size to accommodate the Development Project is available.

The First Hathaway and Banning Commerce Center projects, located north of Interstate 10 (I‐10), east of Hathaway Street, are currently under review by the City and are unavailable as an alternative site.

Property east of these sites and west of Malki Road is controlled by the Morongo Band of Mission Indians and is not available as an alternative site. The Banning Distribution Project is slated for development on property south of I‐10 and north of Banning Municipal Airport. Undeveloped land located between Banning Municipal Airport and the City’s wastewater treatment facility is not sufficiently sized to accommodate the Development Project and is occupied by smaller industrial and residential uses which would require relocation. Land farther south is constrained by Smith Creek, rural residential uses, and the foothills of the San Jacinto Mountains. Other large currently undeveloped properties (the Butterfield Specific Plan [BSP] and Rancho San Gorgonio [RSG] sites) are entitled with Specific Plans envisioning the development of residential and commercial uses; therefore, these sites are not available as alternative sites. Due to the size of the Development Site, the current ownership of other properties, current or pending entitlements, and/or site constraints, no alternative site is available to accommodate the Development Project; an off‐site alternative was rejected from further consideration in this EIR.

The Project includes the transfer of residential capacity to the MSJC Site, located south of Westward Avenue and east of Sunset Avenue. As part of its updated Housing Element, the City identified nine parcels that have been rezoned to VHDR to accommodate additional units required by the City’s Regional Housing Needs Assessment (RHNA). Appendix B of the City’s Housing Element update includes an inventory of “Vacant and Underutilized Sites” which was consulted to determine if other alternate sites remain available to accept the Project’s transfer of residential capacity. The relocation of existing residents and removal of existing structures would result in potential impacts and would not be consistent with State law requirements to achieve no net loss of residential units, only vacant sites included in this inventory were considered as potential alternative locations for the transfer of residential capacity. These areas are primarily infill, but none would so efficiently replace the scope and extent of housing and on a unit for unit basis. The transfer of entitlement for the units would generate the same number of trips and therefore equivalent air quality, noise and GHG impacts.

Should the transfer occur over multiple sites, the possibility exists for greater impact to existing uses (due to proximity) and potentially increased VMT impacts due to the dispersed nature of multiple sites.

As there are no other singular potential sites large enough to fully accommodate the transfer of residential capacity required, consideration of an alternative site other than the MSJC Site was deemed infeasible and was not carried forward for further analysis. 694

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10.1.2 Increased Commercial Use Alternative
Under the existing ITE rates used to develop traffic models, commercial trip generation rates are substantially higher than that of the highest intensity industrial use. Therefore, increased commercial intensity or replacement of any industrial use with commercial use would generate more traffic than would the industrial uses under the Development Project. As the Development Project already has significant project‐level and cumulative air quality and greenhouse gas impacts, and because mobile source emissions are the greatest contributor to these emissions, it is reasonable to conclude that increases in project traffic resulting from more intensive commercial uses would be equally or more significant and unavoidable. As this potential alternative would not substantially lessen or avoid significant and unavoidable impacts associated with the Development Project, this alternative was rejected from further consideration in the Draft EIR.

10.1.3 Office Use Alternative
The traffic assessment for the Development Project anticipated a variety of industrial uses. The daily and peak hour trips for the most traffic intensive industrial use estimated daily, a.m. peak hour, and p.m. peak hour rates are 4.96, 0.70, and 0.63 trips per 1,000 square feet of use, respectively. Trip generation rates for general office uses in an urban/suburban setting are 10.84 daily trips, 1.52 a.m. peak hour trips, and 1.44 p.m. peak hour trips per 1,000 square feet. This rejected alternative would generate approximately 59,533 passenger cars trips from offices uses and 7,702 from commercial uses (67,255 passenger car trips total). Truck uses generated total 1,718 trips with 554 and 1,164 generated from office and commercial uses, respectively. In comparison, the Development project generates 17,166 passenger vehicle 3,330 truck trips (20,496 trips total). While truck trips are 52 percent of that associated with the Development project, passenger vehicle trips are increased by nearly 400 percent.

As mobile source emissions are the primary contributor of pollutants and greenhouse gas emissions, with the increase in traffic associated with development of office uses, it is reasonable to conclude that increases in traffic under this potential alternative would increase the level of pollutants and greenhouse gases emitted, and similar to the Development Project would result in significant and unavoidable project‐specific and cumulative impacts.

As this potential alternative would not substantially lessen or avoid the significant and unavoidable impacts associated with the Development Project, this alternative was rejected from further consideration in the Draft EIR.

10.1.4 Residential Alternative (with Annexation)
This alternative would analyze development of the Development Site with a mix of residential options and includes annexation of the Southern Portion of the Development Site into the City for redevelopment with residential uses. Alternative 2 (Existing General Plan and Zoning) already considers potential impacts associated with development of the Development Site with residential uses. Furthermore, without inclusion of development of commercial or industrial uses in this portion of the Development Site, which is in the City’s sphere of influence, it is not likely this potential alternative would generate sufficient revenue to justify annexation into the City; therefore, this alterative was rejected from further consideration in the Draft EIR. 695

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10.1.5 Reduced Residential Alternative
A reduction in the amount of residential development was considered and not addressed further in the Draft EIR as it would require the City to justify that zoning reduction under State law based on public health and safety reasons. Furthermore, such an alternative would fail to satisfy any of the basic project objectives identified by the City for development of the Project.

10.1.6 Increased Residential Alternative
Alternative 2 envisions development of 1,630 units on the Development Site. As detailed in Section

8.4 of the Draft EIR, Alternative 2 was determined to generate vehicle trips and air pollutantsin excess of that associated with the Development Project. A potential alternative further increasing the residential density of the Development Site was considered, though rejected as it would generate traffic in excess of that identified for the Development Project, proportionally increase the emission of air and greenhouse gas pollutants as compared with Alternative 2, and likely increase vehicle miles traveled, making it unlikely to substantially lessen or avoid any of the significant impacts associated with the Development Project.

It is reasonable to conclude that increasing residential density beyond that identified in Alternative 2, when compared to the Development Project, these exceedances would be further increased.

Furthermore, use of the site for residential development would not satisfy the most of the basic project objectives identified by the City for development of the Development Site; therefore, this potential alternative was not further considered in the Draft EIR.

10.2 ALTERNATIVES UNDER CONSIDERATION

10.2.1 No Project/No Build Alternative
Finding
The City finds that the No Project/No Build Alternative fails to satisfy the Project’s underlying purpose and fails to meet most of the basic the project objectives, and rejects it on that basis. The City finds that each of these reasonsis an independent ground for rejecting the No Project/No Build Alternative, and by itself, independent of any other reason, justifies and hereby rejects the No Project/No Build Alternative.

Substantial Evidence
This alternative was analyzed by the City as required by CEQA Guidelines Section 15126.6(e)(3) to compare the environmental effects of the Project with an alternative that would leave the Project Sites in their existing condition (as described in Draft EIR Section 3.3). The No Project/No Build Alternative (Alternative 1) assumes that the 533.8‐acre Development Site would remain in its current undeveloped condition, and the Development Site would not be rezoned. Incidental grazing and agricultural uses could take place but would not be anticipated to occur on a large‐scale basis. Under this Alternative, the MSJC Site would not be rezoned, as there would be no requirement to concurrently rezone another site to avoid net loss of residential capacity; therefore, no potential for future development of the MSJC Site with residential uses would occur. The Sunset Avenue Bridge, which was approved as part of the entitlements for the RSG project, would proceed as required to construct the RSG project.
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Because Alternative 1 would retain the Development Site in its current undeveloped condition, the significant and unavoidable air quality, greenhouse, noise, and VMT‐related impacts associated with the Development Project would not occur. While this alternative would eliminate the significant and unavoidable impacts associated with the Development Project, it would not meet any of the project objectives. Refer to EIR Section 8.3 for a complete description and evaluation of this alternative.

The No Project/No Build Alternative would result in no physical environmental impacts to the Project Sites. Agricultural uses could incidentally proceed but would not be anticipated on a large‐scale basis.

In the absence of development, there would be no impact in terms of construction and operational air quality, biological resources, cultural resources, energy use, geology and soils, GHG emissions, hazards and hazardous materials, hydrology and water quality, mineral resources, construction and operational noise, public services, recreation, transportation, tribal cultural resources, or utilities and service systems. There would be no impacts with respect to land use as there would be no change to the City or County General Plans or zoning.

Under this Alternative, the City could proceed with construction of the Public Facilities to service existing and future demand consistent with the forecastsin the General Plan and/or Integrated Water Plan. As the City maintains more housing than available employment opportunities, absent the Development Project’s 5,993 new jobs the construction and occupation of other large residential projects in the City may exacerbate the existing job‐housing imbalance since the Project serves to improve the jobs‐housing imbalance in the City. The absence of these job opportunities could cause persons to travel further for employment, which could indirectly contribute to a regional increase in VMT, although in the absence of development there would be no direct impacts to VMT. In the absence of fire protection afforded by the Development Project (e.g., development of a fire protection plan, including requirements for ignition resistant building materials, infrastructure improvements, hardened surfaces, landscape management and established of fuel management zones), and due to the extent and volume of existing ignition sources, this alternative could result in greater fire hazard risk to residential areas (e.g., Sun Lakes Community). Therefore, compared to the Project, there is a potential that fire hazards under this alternative may be increased. Although it is reasonable that current fire protection requirements and fire service providers would continue to provide an appropriate level of service to existing uses in the project area, and compliance with current fire protection standards/practices required by the City (e.g., clearance of flammable vegetation, etc.) would continue (see Draft EIR, Section 8.3.2.20).

Further, this Alternative fails to meet the project objectives as described in Section 3.7 of the Draft EIR. Because it would result in no new uses, this Alternative would not: (1) create positive fiscal impact to the City, (2) promote job creating uses that reduce the need for City residents to commute outside of the City for employment, (3) improve transportation efficiency by taking advantage of the site’s proximity to local and regional access for industrial and commercial use, (4) address a need in the City for commercial and industrial land uses that accommodate a variety of modern industrial, business, hospitality, and commercial activities, (5) provide uses that allow for a diversified economy, complements existing uses, and provide a range of employment opportunities, or (6) increase City sales and property tax revenues by establishing commercial and industrial uses in the City that can increase City revenues and assist in offsetting public services costsincurred by the City in development and maintenance of housing and public facilities.
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10.2.2 No Project/Existing General Plan and Zoning Alternative Finding
The City finds that the No Project/Existing General Plan and Zoning Alternative fails to reduce significant Development Project impacts and does not meet most of the basic project objectives.

Specifically, this alternative fails to reduce the emission levels of criteria pollutants and GHGs to less than significant levels. The VMT impact and construction noise (off‐site roadway/utility construction only) would also remain significant.

The development of residential and commercial uses under this would not meet most of the primary project objectives and would increase residential uses in the City without sufficiently increasing the level of employment, exacerbating the existing jobs/housing imbalance and creating additional fiscal impacts without commensurate revenue increases. The City finds that each of these reasons is an independent ground for rejecting the No Project/Existing General Plan and Zoning Alternative, and by itself, independent of any other reason, justifies the rejection of, and hereby rejects the No Project/Existing General Plan and Zoning Build Alternative.

Substantial Evidence
In accordance with CEQA Guidelines Section 15126.6(e)(3)(A), the No Project/Existing General Plan and Zoning Alternative considers development of the Project Site with land uses that are consistent with the current City and Riverside County General Plan land use designations. This alternative assumes that the Development Site would remain undeveloped in the short term, but that future development could occur pursuant to existing City commercial and residential and County residential land use and zoning standards. Total residential development under this alternative would be comprised of 1,630 units. As with the Project, this alternative analyzes development of a 125 room hotel (approximately 90,000 square feet), a 7,500‐square‐foot Travel Center, and 260,900 square feet of commercial/retail uses. As there would be no net loss in residential capacity under this Alternative, the MSJC Site would not be rezoned for residential development. Refer to Section 8.4 of the Draft EIR for a complete description and evaluation of this alternative.

As detailed in Section 8.4 and Table 8.D of the Draft EIR, Alternative 2 would reduce the overall emission of air pollutants and greenhouse gases compared to the Development Project, though the reduction would be insufficient to reduce the emissions to below established thresholds of significance and the air quality and greenhouse gasimpacts would remain significant and unavoidable.

Similar to the Development Project, this alternative would not be consistent with Criterion 2 of the SCAQMD CEQA Air Quality Handbook because it would increase violations of the State and federal ambient air quality standards (AAQS) and delay the timely attainment of air quality standards indicated in the AQMP, and impacts would be significant and unavoidable. A slight increase in overall ADT (384 total trips) would occur, with the reduction in truck traffic (65 percent reduction) contributing to reductions in emissions of VOCs (35 percent), NOx (64 percent), SO (33 percent), PM10 (26 percent) and PM2.5 (27 percent), compared to the Development Project (Final EIR, Revised Table 8.B). The increase in emissions of CO (24 percent) under this alternative would exceed the 550 pounds/day threshold for this pollutant established by the SCAQMD. Because other pollutants while reduced compared to the Development Project, still exceed significance thresholds, the overall significant impact of this alternative compared to the Development Project is unchanged. 698

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Adding residential density and intensity as envisioned by this alternative would reduce the VMT per capita; however, the retail component would increase boundary VMT to the region. Further, although VMT impacts are reduced as compared with the Project, until specific tenants are identified for commercial uses, as with the Development Project it is infeasible to impose and implement specific VMT reduction measures such as traffic demand management measures at commercial uses at this time, and the VMT impact under this alternative remains potentially significant and unavoidable.

Due to changes in land use and a reduction in VMT, compared to the Development Project this alternative would result in a 32 percent decrease in GHGs generated (Final EIR, Revised Table 8.D), but the level of GHGs emitted (26,314.85 MTCO2e/year) would still exceed established thresholds of significance (3,000 MTCO2e/year). Therefore, greenhouse gas impacts would be significant and unavoidable under this alternative.

Based on the supplemental noise assessment (Final EIR, Appendix I‐2), the significant traffic and stationary noise impacts resulting from implementation of the Development Project that were previously identified in the Draft EIR were eliminated. Due to the primarily residential nature of residential nature of the uses under this alternative, and the substantial decrease of truck traffic, the operational noise impact (both traffic‐related and from stationary sources) under this alternative would be lessthan significant. Due to a similarity of construction activity, a similarlevel of construction noise is expected under this alternative. As with the Development Project, implementation of minimum 10‐foot‐high temporary construction barrier at the construction boundary when project construction activities are within 100 feet from the nearest residential structure would reduce construction noise levels by a minimum of 6 dBA and would reduce construction noise levels to

49.7 dBA Leq. With the reduction achieved by a similar mitigation, the construction noise impact resulting from this alternative also would be less than significant.

As development under this alternative (as with the Development Project) would result in earth disturbance, removal of existing natural vegetation, and landform modification throughout the site, land‐based impacts (agricultural, cultural, mineral resources, hydrology, etc.) would be expected to be similar to those associated with the Development Project. Generally, residential uses have higher fiscal impacts related to the provision of public services and would generally generate less revenue to support the resultant population. As this alternative would result in the development of the Development Site under existing land use and zoning designations, it is consistent with the land use and planning policies as well as local and regional population/housing forecasts. While the demand for electricity and diesel fuel under this alternative is reduced, development with residential uses under Alternative 2 would result in a substantial increase in the demand for natural gas and gasoline as compared with the Development Project.

This alternative would not provide, to the same extent as the Development Project or either Alternatives 3 or 4, the level of employment, variety of uses, or revenue increases, and would not meet most of the basic project objectives: (1) create positive fiscal impact to the City, (2) promote job creating uses that reduce the need for City residents to commute outside of the City for employment, (3) improve transportation efficiency by taking advantage of the site’s proximity to local and regional access for industrial and commercial use, (4) address a need in the City for commercial and industrial land uses that accommodate a variety of modern industrial, business, hospitality, and commercial activities, (5) provide uses that allow for a diversified economy, complements existing uses, and 699

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provide a range of employment opportunities, or (6) increase City sales and property tax revenues by establishing commercial and industrial uses in the City that can increase City revenues and assist in offsetting public services costs incurred by the City in development and maintenance of housing and public facilities. The retention of the commercial center under this alternative would satisfy to a much lesser degree some of the basic project objectives, though the overall the primary objectives of job creation, providing for a balanced and diversified land use that maximizes economic opportunity; and the establishment of land uses that will create a positive fiscal impact for the City, for the Project would not be realized with the substantial development of residential uses. As this alternative does not include any industrial uses and only minimal commercial uses, the project objectives would be substantially unrealized with this alternative (see EIR, Table 8.S).

10.2.3 Reduced Commercial Alternative
Finding
The City findsthe Reduced Commercial Alternative failsto reduce significant and unavoidable impacts of the Project to less than significant and fails to sufficiently satisfy most of the basic project objectives. It provides fewer jobs, reduced levels of sales and property tax revenue and a reduced variety of commercial opportunities as compared with the Project. The City finds that each of these reasons is an independent ground for rejecting the Reduced Commercial Alternative and by itself, independent of any other reason, justifies and hereby rejects the Reduced Commercial Alternative.

Substantial Evidence
This alternative assumes that the annexation of the Southern Portion of the Development Site proceeds and that the Development Project proceeds with the following changes: Commercial uses are removed from the Development Project with the exception of the hotel (approximately 90,000 square feet and 125 rooms) and travel center (7,500 square feet), resulting in removal of 260,900 square feet of commercial development. The area identified currently for those commercial uses in the Northern Portion of the Development Site would be replaced with 260,900 square feet of ‘warehousing’ uses (ITE LU 150). Other industrial uses will remain the same throughout the Development Site (same location,size, use, and ITE rates). In total, development under this alternative includes 5,805,900 square feet of industrial uses. As with the Project, to avoid net loss in residential capacity, the MSJC Site would be rezoned to allow development of up to 1,181 residential units. Refer to EIR Section 8.5 for a complete description and evaluation of this alternative.

Though emissions of criteria pollutants are reduced under this alternative as compared with the Development Project, development under this alternative would not reduce the levels of criteria pollutants to below established significance thresholds. Changes in composition of the traffic associated with this alternative would slightly reduce emissions of some pollutants (e.g., VOCs, NOX) while increasing emissions of others (e.g., CO, SO, PM10, and PM2.5). While SOX is reduced by a greater percentage, impacts are lessthan significant under both the Development Project and this alternative.

CO emissions are increased under this Alternative as compared to the Development Project, but as with the Development project, do not exceed SCAQMD thresholds. Despite changes in composition of the traffic associated with this alternative, mitigated emissions of VOC, NOX, PM10 and PM2.5 remain above SCAQMD thresholds and impacts would remain significant and unavoidable. 700

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During operation of this alternative, the volume of VOC and NOX would be reduced to approximately 165 and 323 pounds/day, respectively. In addition, under this Alternative, the volume of CO, PM10, and PM2.5 would be increased to 541, 240, and 65 pounds/day respectively (see Final EIR, revised Table 8.G). Despite the volume reductions achieved under this alternative, emissions of VOC, NOX, PM10 and PM2.5 after mitigation still remain above SCAQMD thresholds and impacts would remain significant and unavoidable. This alternative increases CO emissions to above the SCAQMD threshold of 550 lbs./day, an impact that does not occur under the Development Project. The new exceedance of CO further contributes to the significance determination. Mitigation Measures AIR‐1 and AIR‐2, as revised in the Final EIR to address public comments regarding the Draft EIR, still do not reduce emission levelsto below established SCAQMD significance thresholds. Compared to the Development Project, the significant air quality impacts under this alternative are similar and significant. Based on the requirements for consistency with emission control strategies in the AQMP, this alternative would conflict with or obstruct the implementation of the AQMP; therefore, similar to the Development Project, impacts would be significant and unavoidable.

Compared to the Project, this alternative would reduce to some degree overall ADTs (18.2 percent) and VMT (13.4 percent) (see Final EIR, revised Table 8.Q). This alternative also reduces overall demand for electricity, natural gas, and vehicle fuels (see Final EIR, revised Table 8.H). Therefore, this alternative would result in reduced greenhouse gas emissions (32,801.19 MTCO2e/year, a

15.3 percent reduction compared to the Development Project) (see Final EIR, revised Table 8.I), as compared to the Development Project after implementation of mitigation measures, but would not reduce the greenhouse gas emissions to below the established threshold of significance of 3,000 MTCO2e/year. As such, similar to the Development Project, greenhouse gas impacts under this alternative would remain significant and unavoidable.

The reduced retail component and increase in industrial uses results in VMT per employee being nominally reduced, although still above the City’s VMT impact threshold. The reduction of locally serving retail uses in Alternative 3 results in an increased trip length for the service population (i.e., population and employees) in the nearby area seeking retail services that may now be further away.

This alternative would implement a Transportation Demand Management Strategy report incorporating the same features (PDFs T‐1 through T‐3) as the Development Project and VMT under this alternative would be reduced by 13.4 percent compared to the Development Project.

Nevertheless, the VMT impact resulting from this alternative remains significant and unavoidable.

Due to the similarity of uses, this alternative would also implement the project design features identified after public review (PDFs N‐1 and N‐2) which eliminate the traffic noise impacts along Sunset Avenue, and the nighttime operation noise impacts to sensitive receptors south of Bobcat Road identified in the Draft EIR. As such, noise impacts under this alternative would be similar to but slightly less than those associated with the Development Project and less than significant. The development proposed under this alternative would require mass grading, fine grading, and various construction activities across the site at a location, extent, intensity and duration similar to that required of the Development Project; therefore, noise associated with grading and construction operations would also be substantially similar. As with the Development Project, implementation of minimum 10‐foot‐high temporary construction barrier at the construction boundary (as required under Mitigation Measure NOI‐1) when project construction activities are within 100 feet from the 701

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nearest residential structure would reduce construction noise levels by a minimum of 6 dBA and would reduce construction noise levels to 49.7 dBA Leq. With the reduction achieved by a similar mitigation, the construction noise impact resulting from this alternative also would be less than significant.

A similar suite of land use entitlement modifications would be required to develop either this alternative or the Development Project and physical modifications to the Development Site such as earth disturbance, removal of existing natural vegetation, and landform modification under this alternative would result in substantially similar building footprints as what is planned under the Development Project. With adherence to standard City codes, regulations, standards, and/or project‐ specific mitigation, it is reasonable that this alternative would have similar aesthetics, agricultural, biological resource, wildfire, hydrology and water quality, recreational, and cultural and tribal cultural resource impacts to those associated with the Development Project. The replacement of the commercial uses with an additional warehouse building will slightly reduce (4.5 percent) potential future jobs available (from 5,993 jobs to 5,725 jobs and would result in incremental changes in the demand for public services and utilities as commercial uses would be decreased and industrial uses increased, resulting in a decreased demand for water (to 90.6% of that required for the Development Project) and a reduction in wastewater but with no change in solid water requirements and for both this alternative and the Development Project would have less than significant impacts.

While the Reduced Commercial Alternative would satisfy most of the basic project objectives, removal of commercial, entertainment, and leisure‐related attractions geared to a multi‐generational, regional cliental under this alternative deprivesthe City of a balanced, diversified use of the Development Site, reduces the number and variety of employment opportunities, and creates a reduced fiscal benefit to the City. (See Final EIR, Table 8.S.) The hotel and travel center uses retained under Alternative 3 (Reduced Commercial) would provide a less diversified economy and more limited range of commercial employment opportunities than included in the Development Project. The Development Project’s regional commercial and entertainment leisure‐focused attractions provide opportunities for retail and professional office development that are either not currently available or not available in this configuration in the City of Banning. As such, the removal of these uses would result in Alternative 3 satisfying the objectives of the Project to a lesser extent than the Development Project because it would not provide jobs to the same extent as the Development Project (5,725 jobs under this alternative versus 5,993 with the Development Project), would result in reduced levels of sales and property tax revenue, and a reduced variety of commercial opportunities (see Final EIR, Table 8.S).

10.2.4 Reduced Industrial Alternative
Finding
The City finds that the Reduced Industrial Alternative (Alternative 4) does not meet most of the basic project objectives to the same extent as the Development Project and lessens but does not reduce the significant environmental impacts of the Project to less than significant. The City finds that each of the reasons set forth below is an independent ground for rejecting the Reduced Industrial Alternative, and by itself, independent of any other reason, justifies and hereby rejects the Reduced Industrial Alternative.
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Substantial Evidence
The Reduced Industrial Alternative assumes that the annexation of the Southern Portion of the Development Site proceeds and that the Development Project proceeds, but with the elimination of Building 9 (274,000 square feet of warehousing uses). This alternative further combines the cold storage usesinto a single building (combined Building 5/6). This alternative reducesindustrial building square footage by approximately 7.6 percent. This alternative foregoesthe extension of Lincoln Street over the Smith Creek drainage. All other components of the Development Project would remain unchanged. Due to these changes, the overall footprint and square footage of industrial development of the Development Project is reduced. Alternative 4 reduces but does not eliminate the significant impacts associated with the Development Project.

Emissions of criteria pollutants under Alternative 4 are reduced as compared with the Development Project, but not to a sufficient extent to reduce the levels of criteria pollutants below established significance thresholds. This alternative would slightly reduce ADTs (total traffic generated under this alternative represents approximately 97.6 percent of the traffic associated with the Development Project) and VMT (reduction of 6.4 percent) (see Final EIR, revised Table 8.Q), which would also slightly reduce the overall emission of air pollutants and greenhouse gases. During operation of this alternative, the volume of all criteria pollutants would be reduced or remain the same: VOC (reduction of 5%), NOX (reduction of 6%), CO (reduction of 2%), SO (no change), PM10 (reduction of 4%) and PM2.5 (reduction of 5%) (see Final EIR, revised Table 9.L). Mitigation Measures AIR‐1 and AIR‐2, as revised in the Final EIR to address public comments regarding the Draft EIR, still do not reduce emission levels to below SCAQMD significance thresholds. Despite the reductions achieved under this alternative, and even with revised mitigation, emissions of all criteria pollutants under this alternative, as with the Development Project, remain significant and unavoidable. Because development under this alternative would require a general plan land use change,similar to the Development Project, it would not be consistent with AQMP Consistency Criterion No. 1. The reduction in truck trips (202 daily trips) associated with this alternative would proportionally reduce TAC emissions; the TAC emissions and health risks resulting from the operation of industrial uses permitted under this alternative but as compared with the Development Project, both would remain similar and less than significant.

The mitigated greenhouse gas emissions resulting from this alternative total 33,829.54 MTCO2e/year or a reduction of 12.6 percent as compared with the Development Project (see Final EIR, revised Table 8.N) but would not reduce the emissions to below the 3,000 MTCO2e/year threshold of significance. As such, similar to the Development Project, greenhouse gas impacts under this alternative would remain significant and unavoidable.

Although implementation of Alternative 4 would reduce VMT, because Alternative 4 assumes a reduction in industrial intensity it results in no change of VMT per employee. As the City of Banning’s VMT threshold is framed in an efficiency metric, the reduction of intensity and the subsequent reduction of employees remains proportional to the home‐based work VMT generated. Therefore, as with the Project, VMT under Alternative 4 scenario in its entirety remains significant and unavoidable.

Due to the similarity of uses, Alternative 4 would also implement the project design features adopted subsequent to public review of the Draft EIR (PDFs N‐1 and N‐2) which eliminate the traffic noise impacts along Sunset Avenue, and the nighttime operation noise impacts to sensitive receptors south 703

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of Bobcat Road identified in the Draft EIR. As such, construction noise impacts under this alternative would be similarly to those associated with the Development Project, and operational noise impacts would be slightly lower than the Development Project. Therefore, this alternative would have similar impacts to the Development project and would be less than significant.

A similar suite of land use entitlement modifications would be required to develop either this alternative or the Development Project. Due to the removal of Building 9 under this alternative, the Lincoln Street crossing of Smith Creek is not required; therefore, impacts to biological resources and jurisdictional features are reduced and no change in the rate or capacity of sediment transport would occur in this drainage. Because the area planned for Building 9 would remain undeveloped, development under this alternative would reduce the overall extent of earth disturbance and reduce the amount existing natural vegetation removed. Landform modification throughout the balance of the Development Site would result in substantially similar building footprints as what is planned under the Development Project and would have similar aesthetics, agricultural, wildfire, hydrology and water quality and cultural and tribal cultural resource impacts as well as recreational impacts to those associated with the Development Project. Incremental changes in the demand for public services and utilities would occur. Because the industrial uses are reduced under this Alternative, the overall demand for electricity, natural gas, and vehicle fuel is reduced as compared with the Development Project.

The Reduced Industrial Alternative would satisfy (see Draft EIR, Table 8.S) most of the project objectives, though to a lesser extent than the Development Project. Alternative 4 provides a similar diversified economy but has a lower range of employment opportunities than the Development Project (5,584 jobs versus 5,993 jobs for the Development Project). Because it retains the commercial uses, this alternative would meet the City’s objectives of accommodating development that generates sales and property tax revenues that can increase City revenues and assist in offsetting other public services costs incurred by the City but to a lesser extent than the Development Project. As compared with the Development Project, as a result of the 7.6 % reduction in overall industrial building square footage under Alternative 4, property tax revenue from industrial buildings would be reduced as a result of the reduction in assessed valuation, and Development Project contributions under the Development Agreement, DIF fee payments,service use tax and other project related revenues, which are substantially tied to projectsquare footage, would be reduced commensurately (by approximately

7.6%). The reduction in square footage and employees under Alternative 4 as compared with the Development Project result in decreases in a variety of revenue streams to the City without eliminating the significant unavoidable impacts of the Development Project. Although reduced, all of the significant unavoidable impacts of the Development Project would remain with this alternative.

10.3 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Finding
The City finds that Alternative 1 (No Project/No Build Alternative) would be environmentally superior to the Development Project based on the avoidance of physical environmental impacts and the avoidance of significant and unavoidable air quality, greenhouse, construction noise (roadway/utility improvements only), and VMT‐related impacts associated with the Development Project; however, Alternative 1 does not meet any of the project objectives. 704

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CEQA Guidelines Section 15126.6(e)(2) requires that the EIR identify an environmentally superior alternative among the other alternatives if the no project alternative is the environmentally superior alternative. Therefore, the City finds that Alternative 4 is the environmentally superior alternative as it would slightly reduce environmental effects compared to the Project and would further reduce the less than significant biological and jurisdictional waters impacts of the Development Project and Alternatives 2 and 3 while meeting most of the basic project objectives. However, the City further finds that as compared with the Development Project, Alternative 4 would produce fewer employment opportunities and would result in substantial reductions in tax, service tax and DIF fees and payments to the City which are linked to or based on project square footage. Under Alternative 4, the significant and unavoidable impacts associated with the Development Project remain.

Although, as with the Development Project and Alternatives 2 and 3, mitigated impacts to Biological Resources and Hydrology are less than significant, the removal of Building 9 under Alternative 4 eliminates the need for a crossing over Smith Creek (at Lincoln Street) thus eliminating the need for mitigation to reduce potential impacts to lessthan significant. Compared to the Development Project, Alternative 4 slightly reduces air pollutants, greenhouse gas emissions, noise, and overall traffic, reducesthe number of crossings ofsensitive drainage features, maintains existing sediment transport in Smith Creek, and meets most of the basic project objectives. As compared with Alternative 3, Alternative 4 slightly reduces air pollutants and its GHG emissions are very similar to Alternative 3, and Alternative 4 would be substantially more effective in meeting the City’s basic project objectives.

Further, although Alternative 3 contributes slightly less to the other significant and unavoidable impacts of the Project than does Alternative 4, under both Alternative 3 and Alternative 4, the significant and unavoidable impacts associated with the Development Project remain. Therefore, the City finds that Alternative 4 is the Environmentally Superior Alternative.

Substantial Evidence
As detailed in Section 8.4 and Table 8.D, Alternative 2 would reduce the overall emission of air pollutants and greenhouse gases, though the reduction would be insufficient to reduce the emissions to below established thresholds of significance and the air quality and greenhouse gas impacts would remain significant and unavoidable. Furthermore, while adding residential density and intensity to the Project would reduce the VMT per capita, the retail component continues to increase boundary VMT to the region; therefore, the VMT impact resulting from Alternative 2 in its entirety would be considered potentially significant. Changes in vehicle traffic and the removal of large industrial buildings that would occur under Alternative 2 would reduce traffic‐related and stationary noise sources; though the significant and unavoidable operational impacts of the Development Project previously identified in the Draft EIR (e.g. operational traffic noise east of Sunset Avenue and nighttime operational noise south of Bobcat Road) have been eliminated through the implementation of project design features; therefore, the noise impacts associated with Alternative 2 would be similar to that of the Development Project, and less than significant (Draft EIR Section 8.7).

Compared to the Development Project and Alternative 4, Alternative 3 increases emissions of CO, SO, PM10, and PM2.5, with emissions of CO increasing beyond established significance thresholds (a new impact not created by the Development Project). Under Alterative 4, the level of VOCs, NOX, CO, PM10 and PM2.5 criteria pollutants is reduced from that resulting from Development Project. Additionally, when the overall emissions from Alternative 3 and 4 are compared, emissions of VOCs, CO, PM10 and PM2.5 criteria pollutants for Alternative 4 are the lower of the two, except for emissions of NOX (which 705

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are 5 lb/day or one percent greater than NOx emission from Alternative 3). As detailed in REVISED Tables 8.G and 8.L, both alternatives still exceed the established significance thresholds, and would require mitigation. While implementation of revised Mitigation Measures AIR‐1 and AIR‐2 would apply equally to either alternative, the air quality impacts of either alternative remains, similar to the Development Project, significant and unavoidable. Since Alternative 4 does reduce the level of all criteria pollutants (when compared to the Development Project) and does not result in a new CO exceedance (see REVISED Table 8.Q), of the two, Alternative 4 provides a greater reduction in pollutant levels.

While the significant and unavoidable air quality, greenhouse gas, noise, and VMT impacts would still occur under either of these alternatives, as established in Sections 8.5 and 8.6 and as compared to the Development Project, Alternative 4’s relative contribution to these impacts is slightly reduced.

Project design features PDF N‐1 and PDF N‐2 would apply equally to either Alternative 3 or 4, and similar to the effect of these features on the Development Project, the traffic related noise (east of Sunset Avenue) and operational noise (south of Bobcat Road) would be reduced to a less than significant level under either alternative. Like the Development Project, the significant and unavoidable construction impact resulting from roadway and utility improvements would remain under both Alternative 3 and 4.

With respect to meeting the Project objectives, Alternative 4 would be substantially more effective (see Table 8.S) in meeting the City’s basic project objectives than would Alternative 3. Alternative 4 meets all of the basic project objectives compared to Alternative 3, although to a lesser degree than the Development Project, and with the removal of Building 9, eliminates the need for a crossing over Smith Creek (at Lincoln Street) and retains the area planned for Building 9 in an undeveloped state reducing the overall extent of earth disturbance and the amount existing natural vegetation removed.

Draft EIR Section 8.6.3.

The hotel and travel center uses retained under Alternative 3 (Reduced Commercial) would provide a less diversified economy and more limited range of commercial employment opportunities than that included in Alternative 4 (Reduced Industrial). In addition, Alternative 3 would provide much lesssales tax revenue and reduced property tax revenue than Alternative 4 (Reduced Industrial) and would be materially less effective in satisfying the City’s economically based objectives for development of the Development Site.

The City’s economically based objectives are of critical importance to the City. In its 2023 and 2024 fiscal years, the City has had to draw from reserves to meet its general fund budgeted requirements.

Therefore, while Alternative 4 is the environmentally superior alternative and best meets most of the basic objectives over the other alternatives, the reduction in revenue over the Development Project is problematic for the City. Further, Alternative 4 reduces the scope of but does not eliminate the significant and unavoidable impacts identified for the Project. The City concludes therefore that the Development Project provides the best balance between the Project objectives, the Project's benefits as described in the Statement of Overriding Considerations, and mitigates environmental impacts to the extent feasible.
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ATTACHMENT A

STATEMENT OF OVERRIDING CONSIDERATIONS

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SUNSET CROSSROADS SPECIFIC PLAN PROJECT

STATEMENT OF OVERRIDING CONSIDERATIONS
Pursuant to Section 15093 of the State CEQA Guidelines
and Section 21081(b) of the Public Resources Code
The City of Banning (the City), upon consideration of all evidence in the record of proceedings for the Project, adopts the following findings based on its independent review and judgment. The City specifically finds and determines that this Statement of Overriding Considerations (Statement) is based upon and supported by substantial evidence in the record. Initially capitalized terms used in this Statement have the meaningsset forth in the CEQA Findingsto which this Statement is appended.

The City acknowledges that implementation of the Project will result in significant and unavoidable impacts. As detailed in this Statement, the City has carefully considered and balanced the benefits of the Sunset Crossroads Project against its unavoidable environmental risks as required by Section 15093(a) of the State CEQA Guidelines, which states: “[i]f the benefits of a Project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable.‘ “Section 15093(b) of the State CEQA Guidelines provides that when the decision of the public agency results in the occurrence of significant impacts that are identified in the EIR, the agency must state in writing the reasons to support its actions based on the EIR and/or other information in the record. Courts have upheld overriding considerations that were based on a variety of policy considerations including, but not limited to, new jobs, stronger tax base, implementation of an agency’s economic development goals, growth management policies, redevelopment plans, the need for housing and employment, conformity to community plan, and provision of construction jobs. See Towards Responsibility in Planning v. City Council (1988) 200 Cal App.3d 671; Dusek v. Redevelopment Agency (1985) 173 Cal App. 3d 1029; City of Poway v City of San Diego (1984) 155 Cal App. 3d 1037; Markley v. City Council (1982) 131 Cal App.3d 656.

Public Resource Code Section 21002 provides: "In the event specific economic, social and other conditions make infeasible such Project alternatives or such mitigation measures, individual projects can be approved in spite of one or more significant effects thereof." Section 21002.1(c) provides: "In the event that economic, social, or other conditions make it infeasible to mitigate one or more significant effects of a project on the environment, the project may nonetheless be approved or carried out at the discretion of a public agency...."
Public Resources Code Section 21061.1 defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, legal, and technological factors.”
As the CEQA Lead Agency for the proposed Project, the City has reviewed the EIR, the Project description and the alternatives to the Project presented in the EIR, and the City fully understands the Project, its alternatives, and proposed mitigation measures. The City finds and determines that:
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(i) the majority of the significant impacts of the Project will be reduced to less‐than significant and acceptable levels by the mitigation measures described in the Final EIR and approved and adopted by these Findings;
(ii) the City’s approval of the Project will result in certain significant adverse environmental effects that cannot be avoided even with the incorporation of all feasible mitigation measures into the Project; and
(iii) all potential adverse environmental impacts and all feasible mitigation measures to reduce the impacts from the Project have been identified in the DEIR, Final EIR and public testimony and there are no other feasible mitigation measures or feasible Project alternatives that would further mitigate or avoid the remaining significant environmental effects. The significant effectsthat have not been mitigated to a less‐than‐significant level are therefore considered significant and unavoidable. Having considered the potential for the Project to cause or contribute to significant and unavoidable adverse impacts to air quality, greenhouse gas emissions, noise, and transportation, the City hereby determines that all feasible mitigation measures have been adopted to reduce or avoid the significant and unavoidable impacts identified in the EIR, and that no additional feasible mitigation or alternatives are available to further reduce or avoid significant impacts.

The City has carefully considered all of the environmental impacts that have not been mitigated to a less than significant level. The City has also carefully considered the economic, fiscal, legal, social and technological benefits of the Project, as well as other considerations. Based upon the substantial evidence in the administrative record, including but not limited to the EIR and the Development Agreement associated with the Development Project, and as detailed below and the City of Banning Comprehensive Economic Development Strategy (CEDS) 2021‐2026 dated December 2021 (“Banning CEDS”), the City finds that specific economic, legal, social, technological or other benefits of the Project outweigh the Project’s unavoidable adverse environmental effects, and furthermore, finds that such adverse, environmental effects are “acceptable”. Specifically, the City finds that each of the following benefits, on their own, is sufficient to justify the adverse environmental effects of the Development Project. This Statement is made as to every significant, unavoidable impacts of the Project identified in the EIR and Findings which occur despite the adoption of feasible mitigation measures, and which create or otherwise contribute to related cumulative impacts and the City finds that any one of these Project benefits standing alone would be sufficient to sustain this Statement.

THE CITY HEREBY FINDS AND DECLARES that, having reduced the adverse significant environmental effects of the Project to the extent feasible by incorporating project design features, taking into account required regulatory measures and adopting the mitigation measures identified in the MMRP, having considered the entire administrative record on the Project and having weighed the benefits of the Project against its unavoidable significant impacts after mitigation, the City has determined that the social, economic and other benefits of the Project outweigh the potential unavoidable significant impacts and render those potential significant impacts acceptable based upon the following considerations:
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1. The Project would meet the Project objectives established by the City.

As demonstrated by the EIR, the Findings, this Statement, the Specific Plan and the remainder of the documents and evidence comprising the administrative record, the Project meets the following objectives established by the City in the Specific Plan and EIR, which objectives are fundamental to the approval of the Project by the City:
 Establish a functional and balanced pattern of land use that maximizes economic opportunity and provides needed public improvements for City residents.  Establish land uses for properties in the City’s sphere of influence that will create positive fiscal impact to the City and provide sufficient fiscal benefit to permit annexation of the property upon which the project is proposed into the City.  Promote job creating uses that reduce the need for City residents to commute outside of the City for employment, thereby improving the City’s jobs to housing ratio.  Locate industrial and commercial uses that rely on transportation efficiency in areas with convenient access to the local and regional transportation network, thereby minimizing truck traffic on local streets and reducing vehicle miles traveled in the region to the extent feasible.  Address a need in the City for commercial and industrial land usesthat accommodate a variety of modern industrial, business, hospitality, and commercial activities.  Use comprehensive planning tools to create a master‐planned development that will be marketable to users, establish an aesthetically pleasing environment, and minimize impacts to adjoining uses.
 Increase City sales and property tax revenues by establishing commercial and industrial uses in the City that can increase City revenues and assist in offsetting public services costsincurred by the City in development and maintenance of housing and public facilities.  Assist in managing supply and demand for electric services to maintain and increase the existing renewables portfolio standard while minimizing costs to rate payers.  Assist the City in developing roadway and utility infrastructure to support the anticipated growth requirements of the City and to improve accessibility in areas of the City and the City’s sphere of influence that currently have limited infrastructure to serve the needs of local residents and businesses.
 Conserve natural drainage features and open space to provide a balance between the built and natural environment.
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2. The Development Project is consistent with and will contribute to achieving the policies, goals and objectives established by the City of Banning General Plan.

The Development Project will establish a functional and balanced pattern of land use that maximizes economic opportunity and provides needed public improvements for City residents.

Implementing the City’s General Plan and its policies is a legal and social prerogative of the City.

The City of Banning General Plan Land Use Element seeks to ensure a balance of residential, commercial, industrial, open space and public lands, and to allow changes to the General Plan land use categories for the remaining capacity of undeveloped land. The addition of industrial, retail, professional and medical offices, education, recreation, and hospitality uses that are permitted by the Sunset Crossroads Specific Plan will contribute to the City of Banning’s sales tax base and will provide a diverse set of modern usesto support job creation, needed retail, wellness and medicalservices as well asleisure activities of City residents and visitors, consistent with these policies. The Sunset Crossroads Specific Plan retains the existing General Commercial designation for the northeastern portion of the Development Site and the Open Space – Park, and Open Space –Resources land uses elsewhere on the Development Site to provide recreational opportunities and avoid development of riparian/riverine resources and related upland areas. The remainder of the Development Site is redesignated with the adoption of the Development Project from Residential to Industrial. The Land Use Element recognizes that industrial development has been and will continue to be an important source of jobs in the City and incorporates policies to allow the City to attract industrial land uses. Large‐scale residential development is occurring in other areas of the City and residentially‐zoned land makes up 53 percent of all the vacant land in the City, while open space comprises 35 percent. Although industrial and commercial development are key economic drivers to the City to achieve fiscal sustainability, only 12 percent of undeveloped land in the City is zoned commercial, industrial, and public facilities and only 8 percent of developed land is zoned for existing industrial uses. Further, as identified in Chapter

8.0 of the DEIR, there is limited undeveloped land available in the City for large‐scale industrial development and no single undeveloped property in the City is of sufficient size to accommodate the range and size of uses of the Development Project. Development of the Development Project on undeveloped land in the City and within the City’s sphere of influence would expand industrial options within the City and San Gorgonio Pass region in a manner consistent with General Plan goals, policies and objectives.

The General Plan also identifies specific plans as an important tool in the coordinated development of larger parcels, or of projects which propose a variety of land uses to ensure the coordinated, orderly development of a project. To minimize impacts to adjoining uses, and to assure that the design, development, operation, and maintenance of uses, infrastructure, landscaping and open space will be consistent with the General Plan, each specific plan will develop standards and guidelines directing development. Circulation and infrastructure improvements would also be required to be in conformance with the roadway classification and design outlined in the City’s General Plan. Thus, the Project is consistent with and furthers the City’ General Plan policies, goals and objectives.
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3. The Project meets the core economic objectives of the City identified in the City’s Comprehensive Economic Development Strategy (2021‐2026) (“Banning CEDS”) and General Plan, as follows:
a. Increase fiscal revenue generation.

The General Plan identifies that the City’s tax revenues have not kept pace with its need for services. As described in the Fiscal Impact Analysis attached as Exhibit 1 to this Statement (“Fiscal Impact Analysis”), the construction and development of the Development Site would produce an economic stimulus as a result of the payment of one‐time feesincluding estimated total development impact fees to the City and region of approximately $71 million  based on the current fee schedule in effect. The City fees are used to fund police, fire, general city, wastewater, water, and traffic control facilities and regional fees support transportation and conservation policies of the region that enhance transportation infrastructure and open space conservation in a manner that supports City needs and policies. Additionally, construction of the Development Project would result in the payment of fees designated for the Banning Unified School District for discretionary use, which would provide a benefit to current and future residents of the City.

The Fiscal Impact Analysis identifies net recurring annual general fund surplus paid to the City at buildout, of approximately $2.95 million. The Development Project is expected to result in approximately $1.75 million of recurring annual expenditure to the City associated with the Development Project. These annual revenues more than cover the coststo the City associated with the Development Project and as a result will offset certain public services costs incurred by the City from the development and maintenance in the City of uses such as housing and public facilities that have a negative fiscal impact. Additionally, the $2.95 million in net recurring annual general fund surplus will serve to reduce or eliminate the need to expend cash reserves, such as was done in fiscal years 2022–23 and 2023–24 when city cashflows from operations were negative, or avoid the reduction of services provided to citizens within the City due to general fund limitations.

Through the Development Agreement, the Development Project will also support a City created service special tax establishing a perpetual maintenance tax on industrial portions of the Development Project to contribute to the City’s long‐term infrastructure maintenance. .

Development and construction of the Project will create both temporary and permanent onsite jobs, will indirectly support local and regional jobs and will create a one‐time stimulus to the local and regional economies. The Development Project is estimated to generate approximately 3,500 annual full time equivalent construction related jobs, and over 5,500 permanent jobs. Temporary construction and long‐term operational jobs created by the Development Project would result in increased spending throughout the region, including in the City. Any development of the MSJC Site, should it occur, would create construction jobs and one‐time development impact fee revenues to the City as well. It is anticipated that the Project would increase annual personal earnings through the generation of these new jobs, and these earnings would ripple through the local and regional economy, creating a one‐time 713
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increase in output and earnings associated with construction jobs and an on‐going increase in output and earnings associated with permanent jobs.
b. Enhance employment, educational and business opportunities and industrial job creation and further a balance of land uses.

The Project will improve industrial job opportunities in the City (and thus the City’s jobs‐to‐ housing balance) consistent with Banning General Plan Land Use Element goals and policies.

The Land Use Element identifies industrial development as an important source of jobs in the City and notes that industrial development can bring stable and generally higher paying jobs to a community and can induce development in a variety of secondary or supporting industries. The General Plan encourages designation of sufficient industrial lands for manufacturing, warehousing and distribution while carefully considering compatibility with adjacent lands (General Plan Land Use Element‐Commercial and Industrial Goals and Policies, Policy 7). The General Plan encourages industrial campuses and master planned projects (General Plan Land Use Element‐Commercial and Industrial Goals and Policies, Policy 11).

As identified in the Banning CEDS, compared to Riverside County, Banning has a higher concentration of jobs in the health care and social assistance sector and to a lesser extent in other services. Weaknesses to the economic health of the City identified in the Banning CEDS include outdated zoning that does not precisely consider current land use trends, and a limited job base forcing most workers to commute long distances. Major goals of the City identified in the Banning CEDS are to expand and diversify industrial uses to provide a wide range of quality employment opportunities and expand workforce development programs. (Banning CEDS, p. 34). However, the Banning CEDS indicated that while Riverside County has seen 80 million square feet of new industrial development in the past decade (50% growth) and there has been 4 million square foot growth in the Beaumont / Hemet submarket, there was zero growth in Banning for these uses. The report identifies this as a major job expansion opportunity for the City. (Banning CEDS at p. 15‐17).

The Development Project directly supports the City’s industrial development goals and objectives in that it is anticipated to provide over 5,500 permanent new jobs, including approximately 4,920 industrial employees, 520 retail employees and 73 service employees (Draft EIR, Table 4.17.A as modified as identified in Supplemental CEQA Memorandum). Job creation associated with industrial and commercial uses is also consistent with the types of jobs sought by Banning residents. According to the US Census Bureau 2019 Average Community Survey 5‐Year Estimates cited in the Banning CEDS, approximately 52 percent of the population in Banning aged 25 years and older had high school education or lower, while 15 percent had earned a Bachelor’s degree or higher. Riverside County and California featured higher college attainment (22 percent and 34 percent, respectively). As stated in the Banning EDS, “this lack in educational attainment suggests that a sizable proportion of the labor force may not have the education required to compete in the labor market for higher‐skilled jobs with higher wages.” The range of opportunities provided by the Development Project would suit a range of workers from unskilled to skilled, including food service, retail service, various warehouse positions, hospitality service positions, office worker positions, and management level positions for all industries. With projected employment for the Development Project 714
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anticipated to be over 5,500, the Development Project would provide varied employment opportunities for the City’s population through the horizon year of 2045 (Draft EIR, Section

4.14.3.1).

Increasing employment opportunities will also improve the jobs‐housing balance in the City and surrounding area (Draft EIR, p. 4.14‐4; response to Comment D‐3‐18), furthering City and regional goals of placing employment near housing to reduce commute times and obtain benefits to the environment from reductions in vehicle miles traveled. Approximately

86.1 percent of Banning residents commute outside of the City for work (Pre‐certified Local Housing Data for the City of Banning, Southern California Association of Governments, updated April 2021, page 21). While no specific jobs‐housing balance data is available for the City, the SCAG Connect SoCal RTP/SCS Environmental Justice technical report indicates that Riverside County has a jobs‐to‐housing ratio of 0.88 and previous evaluations indicated that the City of Banning followed similar trends as the County as a whole, with more housing available than employment opportunities within the City. Based on the number of jobs (10,500) and housing stock (12,156 units) in the City, the City’s jobs/housing ratio would be calculated at approximately 0.86, slightly lower than Riverside County as a whole. The City follows the general trend of having more housing available than employment opportunities within the City. The Project would provide job opportunities close to home for existing and future Banning residents, which would subsequently help achieve a better job‐to‐housing balance within the City.

The unemployment in the City and County of Riverside in August 2023 was at 6.6 and 4.6 percent, respectively. (See Monthly Labor Force Data for Cities and Census Designated Places (CDP) April 2024 ‐ Preliminary, California Economic Development Department and response to EIR Comment D‐3‐18.) By providing job opportunities in a housing‐rich area and commercial and industrial uses near the regional transportation network, the Development Project supports the strong planning processes emphasized under the SCAG RTP/SCS, helps reduce commuting distance to jobs, and facilitates more efficient movement of goods throughout the region. Therefore, the Project would have a beneficial impact on the City’sjob creation goals and support existing residential land uses in the City, with a balance of other uses.
c. Enhance Banning’s commercial and residential market by attracting and retaining a healthy balance of local and national businesses.

The Banning CEDS identifies a need for community shopping centers to support existing and planned residential development in the City. The 47.9‐acre commercial components of the Sunset Crossroads Specific Plan (referred to as Sunset Crossroads) have been crafted to support City residents by attracting new businesses, including warehouse club uses and leisure, retail, medical office, professional office, education, recreation and entertainment uses along with a freeway accessible 125‐room hotel restaurants and wellness facilities,.

These uses are either not currently available or not available in this configuration in the City of Banning. As detailed in Section 3.b above, the Development Project would provide approximately 520 retail employees and 73 service jobs generated from commercial use. The addition of retail,  and the opportunity for offices, education, recreation, and hospitality uses 715
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will contribute to the City of Banning’s sales tax base and will provide a diverse set of uses to create an enjoyable shopping and dining experience and to support leisure activities of City residents and visitors. The Development Project includes design guidelines for on‐site development, open space areas, and lighting that would ensure consistency with the City’s General Plan goals and policies regarding aesthetics. The project design uses contemporary architecture, lighting and signage, combined with architectural elevations and a variety of uses to create a safe and welcoming environment for residents and visitors and to create a destination that contributes to the long‐term prosperity of the City of Banning. d. Develop a wide range of housing options.

Consistent with goals of the Banning CEDS, through the Sunset Crossroads development, the Development Project would provide additional commercial opportunities that support buildout of properties zoned as residential in the City. At the same time, with the zoning of the MSJC Site southeast of the Development Site for high density residential development allowing at least 1,146 very high density residential units (Draft EIR, p. 4.14‐4), the Development Project allows the City to comply with State law mandates that there be no net loss of housing entitlement and to support its Housing Element Goals of achieving a wide range of housing options, including very high density residential units. Although the City General Plan and zoning provides for very high density residential development, there are only limited areas in the City where VHDR zoning is in place and thus this rezoning supports a diversity of housing type options in the City.

As indicated in the City of Banning 6th Cycle Housing Element, low‐income households (50 to 80 percent AMI) comprised 24 percent of the City’s households, while moderate and above‐ moderate income households comprised 40 percent of the City and approximately 36 percent of Banning households were considered extremely low or very low‐income. Given thisincome spread, higher density, lower cost housing is an essential element of the City’s residential planning effort. Although the MSJC Site is not designated for housing development to support RHNA goals, the Housing Element identified a shortage of VHDR zoning in the City and required the City to develop standards for the VHDR zone with a minimum density of 20 du/acre and maximum of 30 du/acre by October 2023. Application of the City’s General Plan requirement for a specific plan overlay for the MSJC Site would ensure that residential development of that site, should it occur, is carried out in a cohesive manner, would account for the provision of adequate public infrastructure (i.e., roads, storm drain, electricity, sewer, potable and recycled water availability), and would provide the opportunity for clustering of residential development on the property, supporting the City’s housing goals and objectives.

4. The Development Project will fund critical infrastructure improvements that the City would not otherwise be able to fund with current revenue streams and provide land for development of key City infrastructure projects.

The Development Project will contribute substantial roadway and utility infrastructure through direct construction and payment of development impact fees, fair share fees and public benefit fees that will support the anticipated growth requirements of the City and improve accessibility in areas of the City and the City’s sphere of influence that currently have limited infrastructure to 716
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serve the needs of residents and businesses. The City has a detailed Integrated Master Plan (2018), development impact fee program, and other plans that together establish and plan for the infrastructure needs for the City and provide funds for capital improvements as projects are developed, but lacks funding to fulfill its objectives. Construction of the Development Project would result in the payment of one‐time fees including estimated total development impact fees, including TUMF and MSHCP impact fees (before DIF transportation reduction described in the Development Agreement) to the City and region of approximately $71 million   based on the current fee schedule in effect, which will be used to address City and regional infrastructure needs including development of road and utility infrastructure and for conservation (MSHCP) purposes.

Additionally, construction of the Development Project would result in the payment of fees designated for the Banning Unified School District for discretionary use, which would provide a benefit to current and future residents of the City. Development of the MSJC Site, should it occur, would provide further development impact fees to support City infrastructure. The City General Plan has identified construction of the Sun Lakes Boulevard Extension as a key City goal to help reduce impacts to the intersections of Highland Springs Avenue at Interstate 10 (I‐10) and West Ramsey Street and create an east/west link across the City of Banning, south of I‐10, supporting regional transportation planning and assisting in maintaining peak hour levels of service to “D” or better on roadways and intersections.   As a component of its DIF funding, the Development Project will contribute an accelerated payment of $5.1 million for design and construction of the Sun Lakes Boulevard extension.

In addition, through the Development Project’s Development Agreement and Specific Plan requirements, the Development Project Applicant will be providing additional public benefits supporting the surrounding community, including:
 Increased real property taxes, sales taxes, transit occupancy taxes and other revenues to the City;
 Provision of public facilities, including the construction of the Sunset Avenue Improvements;  Provision of $1,000,000 for a new fire ladder truck or other fire suppression equipment;  Provision of $750,000 for City downtown beautification/small business assistance;  Dedication of property to the City as a site for a possible future fire station, a water tank, electrical substation and a reverse osmosis facility; A public benefit fee of the lesser of $8 Million or $1.44 per square foot of entitled warehouse/logistics/industrial building square footage, that can be used by the City to support its infrastructure needs not required by the Development Project of which $1 million will be paid at issuance of initial grading permit;  Construction of surrounding and internal roadways and improvements to circulation features in the existing surrounding community, enhancing connectivity within the City;  Undergrounding of all existing utility lines along the perimeter of the Development Site; 717
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 Contribution of up to $15 million for a possible future fire station or other uses as determined by the City in its sole discretion and $10 million for design and construction of BEU’s planned substation;
 Dedication of land for a possible fire station, waterreservoir and pump facility, for city’sfuture use, if determined necessary by the city;
 Establishment of a job fair to benefit City residents, and a requirement that all leases include language requiring lessees to provide two weeks’ advance notice to City residents when new lessees are hiring employees.
 Setting aside approximately 53 acres for Open Space Resource Land and approximately 5 acres for parks and recreational facilities and construction and maintenance of park facilities.  Provision of both construction jobs and permanent jobs.

5. The Project will expand industrial options within the City and provide needed infrastructure, services, and jobs, in proximity to regional transportation in a manner that is consistent with regional plans and policies and City General Plan Elements.

The Sunset Crossroads Specific Plan Project will locate high‐quality, large‐scale high cube warehouse/distribution centers with convenient access to the local and regional transportation network, thereby minimizing truck traffic on the local (non‐highway) roadway system and reducing vehicle miles traveled in the region to the extent feasible. The Development Site is located immediately adjacent to Interstate 10 (I‐10), a regionally and nationally important east‐ west transportation facility that connects the City to the greater Los Angeles area, including the Ports of Los Angeles and Long Beach, and to other major metropolitan areas to the east. Regional connectivity is further provided by interchanges on I‐10 connecting to State Routes (SR) 60, 62, 111, and 243 which provide access to Moreno Valley/Riverside, Yucca Valley/29 Palms, Palm Springs, and Idyllwild, respectively. (Draft EIR at p. 3‐7) Regional access to the Development Site is provided via the I‐10 Freeway at the Sunset Avenue, which is a full interchange located within 1/4 mile of the Development Site. The location of the Development Site thus facilitates implementation of SCAG’s 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) goals by creating a major employment centerin an RTP/SCS designated priority growth area designed to reduce VMT and improve the existing jobs to housing imbalance. The Development Site location also implements the RTC/SCS goal of supporting the vital goods movement industry by allowing trucks traveling to and from the Development Project to efficiently access the regional transportation network ((SR‐60, I‐15, and I‐215) to facilitate the movement of goods throughout the region.

The location of the Development Site at Sunset Avenue and in close proximity to the Sunset Avenue / I‐10 interchange, is consistent with existing City General Plan policies that indicate that industrial lands shall be located on major roadways with good access to Interstate 10, to assure that potential traffic impacts associated with tractor‐trailers are minimized. (General Plan Land Use Element‐Commercial and Industrial Goals and Policies, Policy 8). The location of the Development Site is unique in the City in terms of itssize and location and provides an opportunity 718
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for development proximate to major transportation corridors and existing and planned infrastructure in the City.

At the same time, the size of the Development Site allows for design standards and guidelines imposed by the Sunset Crossroads Specific Plan to create buffer areas from adjoining uses and allows a functional and balanced land use plan for the Development Site and the area that conforms to General Plan goals, policies and objectives. The proximity to I‐10 by direct arterial and secondary highways, the shift of the Sunset Avenue alignment to the west away from existing residential uses and incorporation of other project design features including a truck route management plan that restricts tractor‐trailer access to residential neighborhoods is consistent with City General Plan Land Use and Noise Elements policies that encourage industrial development while also seeking to restrict truck traffic on residential roads. As a result of its location, project design features and mitigation measures imposed by the EIR and Specific Plan and conformance with General Plan goals, policies and objectives, the Development Project does not result in significant localized significant air quality or health risk impacts, or in noise impacts other than with respect to roadway and utility construction and conforms with a range of City policies promoting a balance of land uses, including industrial, commercial and residential uses in the City.

6. The Project will facilitate the City’s goal of sustainable development by being energy and water efficient in conformance with the City’s General Plan Policies and other State and Regional Plans.

The Specific Plan requires the Development Project to be energy efficient in that it must be consistent with or exceed the criteria from the California Building Code, Title 24 standards which the City has adopted by ordinance. As a result, the Development Project Specific Plan imposes minimum requirementsrelated to energy efficientstructures, lighting and appliances; compliance with building code solar requirements; energy efficient heating and cooling, potable water systems, water efficient irrigation systems for drought tolerant landscaping that can be served by recycled water, installation of EV charging stations, and incorporation of transportation demand management features and bicycle access and parking.

7. The Development Project will assist the City’s municipally owned utility (BEU) in managing supply and demand for electric services to maintain and increase the existing renewables portfolio standard while minimizing costs to rate payers.

Banning Electric Utility (BEU) isthe City’s municipal utility, and itsservice area includes the Project Site. SB 100 requires BEU's portfolio to be 100 percent renewable by 2045. BEU competes with other utilities which likewise are required to increase their renewable portfolios. According to the U.S. Census, the City’s median income in 2022 was $54,083 and the poverty rate was 18.9%; therefore, it is important that electricity rates for residents remain affordable as the City’s renewable portfolio grows to meet State requirements. To keep electricity costs down for residents, the City needs to enter into long‐term renewable energy purchase contracts in as large an amount as possible to obtain favorable rates for renewable sources. However, due to State mandated solar requirements for rooftops, the City has an abundance of solar generation from newer residential developments during daylight hours depressing its electrical demand system 719
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load and forcing BEU to “dump” excess electricity, including the electricity from its current solar power purchase agreement, into the California Independent System Operator (CAISO) wholesale markets, at low to no return due to the glut of solar on the grid during the daytime. Increases in large commercial and industrial development within the City, that purchase electricity from BEU, like the Development Project, facilitate and support the utility’s long‐term renewable energy contracts and promote efficiency in electrical generation and usage. The Development Project will directly and immediately support BEU’s renewable power objectives. At buildout and with the implementation of the stated mitigation and PDFs, the Development Project electricity use would be 25,570,405 kilowatt‐hours (kWh) (or 25.570 GWh) of electricity per year. As total electricity consumption in the BEU service area in 2022 was 151.5 GWh, the Development Project electric demand represents approximately 16.9 percent of existing electricity consumption within the BEU service area and 0.14 percent of current electrical demand in Riverside County. (DEIR at p. 4.19‐ 27). The BEU has included the energy usage by this Development Project as well as two other large residential projects in its future planning, which has enabled it to enter into long‐term contracts for the purchase of renewable sources of electricity as required by State law. (DEIR at p. 4.19‐28). Construction of the Development Project allowsthe City to continue to maintain these power agreements while keeping costs for its users at reasonable rates.

In addition, the Development Project includes the right to develop a 65 megawatt‐hours (MWh) Battery Energy Storage System (BESS) facility in an industrially zoned portion of the Development Site. The BESS would be a privately owned and operated 65‐megawatt‐hour (MWh) battery energy storage facility proposed to support storage of energy by the BEU to assist BEU in managing the supply of energy it receives. (DEIR at p. 4.9‐11). As such, it would also facilitate BEU’s goals of maximizing renewable sources of energy and minimizing costs to its customers by allowing BEU to store energy generated when there is a glut of solar production for use in hours when there is more demand.

8. The Development Project would conserve natural drainage features and open space to provide a balance between the built and natural environment.

The Sunset Crossroads Specific Plan creates approximately 12.6 acres of Open Space – Parks and

53.0 acres of Open Space – Resource. Consistent with City General Plan Biological Resources Element Policy 4 (encouraging preservation of drainage channels in natural open space to the greatest extent possible), the Development Project was designed to avoid most of the drainage features as well as providing a buffer area around the drainages. With implementation of the Project, permanent conservation of 7.92 of 8.99‐acres of riparian/riverine lands on the Development Site and a surrounding buffer of 32.58‐acres will be preserved, and a minimum of

3.21‐acres of Project Site riparian habitat will be enhanced or restored (a 3:1 ratio) within the conservation area on‐site. With these actions, a total of 40.5 acres of land will be designated in the General Plan as Open Space‐Resources. These open space and conservation lands will be preserved and managed in perpetuity to protect environmental resources and provide enhanced recreational opportunities and scenic qualities in the City. Where new roads cross the riparian corridors, undercrossings allowing wildlife movement and continued downstream sediment transport are required. These undercrossings will assure the long‐term conservation of the riparian/riverine resources which are being avoided and preserve their associated functions and 720
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values for Project Site features and for downstream conservation areas associated with the sediment transport system. Any development on the MSJC Site would be required to meet regulatory mitigation requirements as well.

Although the Development Project would not include the development of residential units and would not add to the existing population nor generate new residential park demand, the Development Project provides a 12.6‐acre Open Space – Parks area that would be publicly accessible, including a 5 acre passive park within the Development Site that could provide a variety of recreational amenitiesincluding a tot lot playground, picnic tables, trails, walking paths, surface parking lot, and restroom.
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Exhibit 1
EXHIBIT 1

SUNSET CROSSROADS SPECIFIC PLAN FISCAL IMPACT ANALYSIS

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FISCAL IMPACT ANALYSIS
FOR

SUNSET CROSSROADS
(Fiscal Impact Analysis Tables Only)
September 2025
Prepared By:
724
Table 1
Sunset Crossroads
Fiscal Impact Analysis Summary
Annual Recurring Revenues:

Property Tax $ 629,792 Table 5
Sales Tax 578,130 Table 6
Property Tax in-lieu of Vehicle License Fees 1,306,101 Table 7 Transient Occupancy Tax 533,813 Table 8
CFD Revenues 1,013,400 Table 9
Other Revenues 634,348 Table 10
Total Recurring Revenue $ 4,695,584
Annual Recurring Expenditures:

City Council $ 8,693 Table 11
City Manager 34,439 Table 11
Economic Development 11,031 Table 11
Personnel 14,070 Table 11
City Clerk 5,804 Table 11
City Attorney 19,868 Table 11
TV Government Access 5,874 Table 11
Fiscal Services 54,908 Table 11
Purchasing 19,242 Table 11
Police 653,000 Table 11
Dispatch 74,249 Table 11
Animal Control 19,641 Table 11
Animal Shelter 3,570 Table 11
Fire 213,440 Table 11
Building and Safety 115,422 Table 11
Code Enforcement 39,183 Table 11
Planning 99,196 Table 11
Engineering 106,066 Table 11
Building Maintenance 12,946 Table 11
Parks 70,588 Table 11
Recreation 34,052 Table 11
Aquatics 48,951 Table 11
Day Care 4,072 Table 11
Senior Center 6,983 Table 11
Public Information 19,813 Table 11
Grants Management 47,408 Table 11
Elections 212 Table 11
Community Enhancement 7,086 Table 11
Total Recurring Expenditures $ 1,749,805
Net Annual Fiscal Surplus (Deficit) $ 2,945,779
Fiscal Impact Annual Summary
725
Table 2
Sunset Crossroads
Population and Employment Data
Population 31,213 (a) -
Employees 10,600 (b) 3,951
Residents + 50% Employees 36,513 (c) 1,975 (c)
Footnotes:
(b) Per State of California, Employment Development
Department April 2025 estimate.

City Project
(a) Per the E-5 City / County Population and Housing Estimates report published by the California Department of Finance dated 1/1/2025.
(c) The Per Capita-and-Employee Multiplier Method represents the total service population for the City and Project respectively, as each employee is counted as one-half of a resident to reflect their relative impact in generating City public service costs or City revenues. This multiplier method is a widely accepted standard of estimating per capita and employee impacts. 726
Table 3
Sunset Crossroads
Estimated Commercial Uses Property Value Using Income Method Industrial Commercial
Gross Square Feet 5,067,000 223,753
Less: Non-leasable Space @ 10% (a) - -
Leasable Square Feet 5,067,000 223,753

REVENUE
Average Monthly NNN Rental Rate per s.f. (b) $ 1.18 $ 1.77 Total Scheduled Annual NNN Rents $ 71,748,720 $ 4,752,514

EXPENSES
Vacancy (%) (b) 6.70% 6.50%
Vacancy ($) $ 4,807,164 $ 308,913
Unreimbursed Expenses (vacant space) (c) 13,388,311 1,644,132 Total Expenses $ 18,195,475 $ 1,953,046
NET OPERATING INCOME $ 53,553,245 $ 2,799,468
CAP RATE (d) 5.00% 5.75%
TOTAL VALUE $ 1,071,064,892 $ 48,686,404
VALUE PER GROSS SQUARE FOOT 211.38 217.59
VALUE PER GROSS SQUARE FOOT (ROUNDED) 211.00 218.00
Hotel
No. of Rooms 125
Average Daily Rate $ 150
Occupancy 65%
Annual Room Revenue $ 4,448,438
Other Revenues (5% of Room Rev.) 222,422
Total Revenue $ 4,670,859
Operating Expenses as % of Revenue 65%
Total Operating Expenses 3,036,059
Net Operating Income $ 1,634,801
Cap Rate (c) 6.75%
TOTAL VALUE $ 24,219,271
VALUE PER ROOM 193,754
VALUE PER ROOM (ROUNDED) 194,000
Footnotes:
(a) Analysis estimates office site is comprised of approximately 10% common area. (b) Commercial per CBRE MarketView Inland Empire Retail, Q4 2024 Report. Industrial per Cushman and Wakefield Inland Empire Industrial, Q1 2025 Report. Office per the CBRE Inland Empire Office, Q4 2024 (c) Operating Expenses for Warehouse and Office estimated at 20.0% of revenue based on California Department of Transportation. Assumes operating expenses at 37% of rental revenue; based on U.S. Super Community/Community Shopper Center operating cost data per Dollars & Cents of Shopping Center (2008) published by ULI for Commercial and Retail. (d) Commercial Retail cap rate per CBRE North America Cap Rate Survey Second Half 2025 for Stabilized Retail property in the Inland Empire. Industrial cap rate per CBRE North America Cap Rate Survey Second Half 2024 for Class A Stabilized Industrial property in the Inland Empire. Office cap rate per the CBRE North America Cap Rate Survey Second Half 2024 for Class A Stabilized Suburban Office property in Orange COunty. Hotel cap rate per CBRE North America Cap Rate Survey Seond Half 2025 for hotels in the Los Angeles Market, not in a city center or luxury destination. 727
Table 4
Sunset Crossroads
Land Use and Assessed Value Assumptions
Building 1 1,420,000 $ 211 $ 299,620,000
Building 2 1,386,000 211 292,446,000
Building 3 575,000 211 121,325,000
Building 4 44,000 211 9,284,000
Building 5 - 211 -
Building 6 - 211 -
Building 7 896,000 211 189,056,000
Building 8 250,000 211 52,750,000
Building 9 274,000 211 57,814,000
Building 10 222,000 211 46,842,000
Subtotal Industrial 5,067,000 $ 211 $ 1,069,137,000
Restaurant 18,748 $ 218 $ 4,087,020
Retail 205,005 218 44,691,134
Subtotal Commercial Retail 223,753 $ 218 $ 48,778,154
Hotel 125 $ 194,000 $ 24,250,000
Subtotal Hotel 125 $ 194,000 $ 24,250,000
Total Project Assessed Value $ 1,142,165,154
Footnotes:
(a) Commercial estimated value per square foot per Table 3.

Retail
Hotel 125 Keys
Probable Tenant Type Number of
Rooms
Estimated
Assessed Value
per Room (a)
Total Assessed
Value
Probable Tenant Type Bldg. SF
Estimated
Assessed Value
per SF (a)
Total Assessed
Value
Industrial
Probable Tenant Type Bldg. SF
Estimated
Assessed Value
per SF (a)
Total Assessed
Value
728
TRA (a)
Within City of Banning - Agency 001-006 001-022 Within Unincorporated County - Agency 055-008 General Purpose 0.0000000% 0.0000000% 0.0000% General Purpose 0.00000000% General 10.3949007% 10.3949007% 10.3949% General 13.65333663% City of Banning 9.1329641% 9.1329641% 9.1330% Co Structure Fire Protection 5.69552712% RDV Banning DW / Mid 03ANX AB 1290 0.0000000% 0.0000000% 0.0000% Banning Unified School 38.03740800% Banning Unified School 38.0374080% 38.0374080% 38.0374% Mt San Jacinto Jr College 3.84743700% Mt San Jacinto Jr College 3.8474370% 3.8474370% 3.8474% Riverside Co OFC of Education 3.97160400% Riverside Co Office of Education 3.9716040% 3.9716040% 3.9716% Co Waste Resource Management District 0.00000000% Flood Control Admin 0.2279164% 0.2279164% 0.2279% Riverside Co Regional Park and Open Space 0.33700907% Flood Control Zone 5 4.7564996% 4.7564996% 4.7565% Flood Control Admin 0.22791635% CSA 152 0.0000000% 0.0000000% 0.0000% Flood Control Zone 5 4.75649962% Summit Cemetery District 1.8195520% 1.8195520% 1.8196% CSA 152 0.00000000% San Gorgonio Pass Memorial Hospital 1.9601130% 1.9601130% 1.9601% Summit Cemetery District 1.81955201% Banning Library District 4.3229931% 4.3229931% 4.3230% San Gorgonio Pass Memorial Hospital 1.96011300% San Gorgonio Pass Water Agency District 3.4427847% 3.4427847% 3.4428% Banning Library District 4.32299313% Inland Empire Jt (33,36) Res 0.0000000% 0.0000000% 0.0000% San Gorgonio Pass Water Agency 3.44278472% ERAF Rdv 0.0000000% 0.0000000% 0.0000% Inland Empire JT (33, 36) Res 0.00000000% Eraf Fund 18.0858274% 18.0858274% 18.0858% ERAF Fund 17.92781935% Total 100.000000% 100.000000% 100.0000% 100.0000%
Project Acres (c) 157 121 277.95 241
% of Total 56.48% 43.52% 100.00% 100.00%
Total City General Fund 9.1330% Total Unincorporated County General Fund 13.6533% Total Assessed Value $ 419,490,154 Total Assessed Value $ 722,675,000 Base 1% Ad-Valorem Tax 1.00% Base 1% Ad-Valorem Tax 1.00% Base Commercial Ad-Valorem Revenue $ 4,194,902 Commercial Ad-Valorem Revenue Before Annexation $ 7,226,750 City of Banning Allocation $ 383,119 City of Banning Annexation Allocation 25.00% City of Banning Base Ad-Valorem Revenue $ 1,806,688
City of Banning Allocation from Annexed Parcels $ 246,673 Total City of Banning Property Tax Allocation $ 629,792 Source: Fiscal Year 2024-25 Share of the Basic Tax per Riverside County Auditor-Controller's Office, Property Tax Division. (a) Shares of the basic tax that are received by the City and County for each TRA are highlighted in bold print. (b) The weighted average of TRAs was calculated by the distribution of acreage among the TRAs within the Project. (c) TRA and acreage data per LandVision, 1/11/2023.

Footnotes:

Table 5
Sunset Crossroads
Post-ERAF Share of the Basic Tax Calculation
TRA (a) Wtd. Avg. of
TRAs (b)
729
Table 6
Sunset Crossroads
On-Site Sales Tax Revenue
Probable Tenant Type (a) Bldg. SF
Estimated Sales
per SqFt (b)
Total Estimated
Taxable Sales
Commercial
Restaurant 18,748 350 $ 6,561,730
Retail 205,005 250 51,251,300
Total 223,753 $ 57,813,030
Annual Sales Tax to City 1.00% $ 578,130
Footnotes:
(a) Estimated tenant types per 10/21/2020 - Sunset Crossroads - Concept Site Plan, Uses and Activities. (b) Preliminary DPFG estimates based on industry knowledge and review of various data sources in addition to Dollars & Cents of Shopping Centers (2008) by Urban Land Institute. 730
Table 7
Sunset Crossroads
Property Taxes In Lieu of Vehicle License Fee ("VLF")
FY 2025/26 In Lieu VLF Allocation to City $ 4,447,926 (a) FY 2024/25 City Assessed Value 3,889,641,412 (b)
Total Project Assessed Value 1,142,165,154 (c)
AV Growth from Project 29.364%
Annual City Property Taxes In Lieu of VLF $ 1,306,101
Footnotes:

Annual City Property Taxes In Lieu of VLF
(b) Per County of Riverside Assessor's Office 2024/2025 Assessment Roll. (c) Per Table 3.
(a) Per City of Banning FY 2024-25 and 2025-26 two year budget. 731
Table 8
Sunset Crossroads
Transient Occupancy Taxes
No. of Rooms 125
Average Daily Rate (ADR) $ 150 (a)
Occupancy Rate (%) 65.0% (a)
Total Annual Room Revenues 4,448,438
Annual County Transient Occupancy Tax 12.00% (b) $ 533,813 Footnotes:
(a) Estimate per DPFG ADR rate research regarding hotels located within Project area dated 1/26/2024.
(b) Transient occupancy tax rate per City of Banning Measure L. Measure L was then extended per Measure E which was passed by voters in 2014.

Proposed Hotel
732
Table 9
Sunset Crossroads
Community Facilities District
Building 1 1,420,000 $ 0.20 $ 284,000
Building 2 1,386,000 0.20 277,200
Building 3 575,000 0.20 115,000
Building 4 44,000 0.20 8,800
Building 5 - 0.20 -
Building 6 - 0.20 -
Building 7 896,000 0.20 179,200
Building 8 250,000 0.20 50,000
Building 9 274,000 0.20 54,800
Building 10 222,000 0.20 44,400
Subtotal Industrial 5,067,000 $ 0.20 $ 1,013,400
Footnotes:
(a) Per Table 4.
(b) Estimated CFD annual revenues based on preliminary Development Agreement terms.

Industrial
Probable Tenant Type (a) Bldg. SF Estimated CFD
Cost per SqFt (b)
Total Annual CFD
Revenue
733
Table 10
Sunset Crossroads
Other Recurring Revenues
Revenue Category
City FY 2025/2026
Budget (a)
Marginal
Increase Adjusted Budget Multiplier Factor
Project
Equivalent
Persons
Project
Revenues
Property Taxes $ 4,791,779 100% $ 4,791,779 Case Study - Table 5 N/A - $ - Property Taxes In-Lieu of VLF 4,447,926 100% 4,447,926 Case Study - Table 8 N/A - - Sales and Use Tax 6,643,039 100% 6,643,039 Case Study - Table 9 N/A - - Franchise Tax 525,000 100% 525,000 Per Capita & 50% Employee 14.38 1,975 28,401 Transient Occupancy Tax 1,250,000 100% 1,250,000 Case Study - Table 7 N/A - - Other Taxes 720,000 100% 720,000 Per Capita & 50% Employee 19.72 1,975 38,950 Business License 215,000 100% 215,000 Per Capita & 50% Employee 5.89 1,975 11,631 Internal Service Revenues 2,590,159 0% - Per Capita & 50% Employee 0.00 1,975 - Interfund Transfers 1,460,121 0% - Per Capita & 50% Employee 0.00 1,975 - Licenses and Permits 7,017,429 100% 7,017,429 Per Capita & 50% Employee 192.19 1,975 379,624 Charges for Services 793,533 100% 793,533 Per Capita & 50% Employee 21.73 1,975 42,928 Miscellaneous Income 2,185,315 50% 1,092,658 Per Capita & 50% Employee 29.93 1,975 59,110 Sales and Service Charges 1,269,480 10% 126,948 Per Capita & 50% Employee 3.48 1,975 6,868 Fines and Forfeitures 261,830 100% 261,830 Per Capita & 50% Employee 7.17 1,975 14,164 Other Intergovernmental Revenues 848,668 100% 848,668 Per Capita & 50% Employee 23.24 1,975 45,911 State Motor Vehicle In-Lieu Fees 40,000 0% - Per Capita & 50% Employee 0.00 1,975 - Use of Money and Property 307,600 0% - Per Capita & 50% Employee 0.00 1,975 - Other Income 125,000 100% 125,000 Per Capita & 50% Employee 3.42 1,975 6,762 Contributions 280,400 0% - Per Capita & 50% Employee 0.00 1,975 - Total $ 35,772,279 $ 28,858,810 $ 634,348
Footnotes:
(a) Per City of Banning FY 24-25 and 25-26 Biennial Budget Report dated June 25, 2024 on the City of Banning OpenGov Budget webpage. 734
Table 11
Sunset Crossroads
Recurring Expenditures
Expenditure Category
City FY 2025/2026
Preliminary Operating
Budget (a)
Marginal
Increase Adjusted Budget Multiplier Factor
Project
Equivalent
Persons Project Cost
City Council $ 321,376 50% $ 160,688 Per Capita & 50% Employee 4.40 1,975 $ 8,693 City Manager 1,273,234 50% 636,617 Per Capita & 50% Employee 17.44 1,975 34,439 Economic Development 407,808 50% 203,904 Per Capita & 50% Employee 5.58 1,975 11,031 Personnel 520,162 50% 260,081 Per Capita & 50% Employee 7.12 1,975 14,070 City Clerk 214,563 50% 107,282 Per Capita & 50% Employee 2.94 1,975 5,804 City Attorney 734,531 50% 367,266 Per Capita & 50% Employee 10.06 1,975 19,868 TV Government Access 217,149 50% 108,575 Per Capita & 50% Employee 2.97 1,975 5,874 Subtotal - General Government 3,688,823 1,844,412 99,778 Fiscal Services 2,029,956 50% 1,014,978 Per Capita & 50% Employee 27.80 1,975 54,908 Purchasing 711,370 50% 355,685 Per Capita & 50% Employee 9.74 1,975 19,242 Subtotal - Finance 2,741,326 1,370,663 74,149
Police 12,070,856 100% 12,070,856 Per Capita & 50% Employee 330.59 1,975 653,000 Dispatch 1,372,511 100% 1,372,511 Per Capita & 50% Employee 37.59 1,975 74,249 Subtotal - Law Enforcement 13,443,367 13,443,367 727,249 Animal Control 363,060 100% 363,060 Per Capita & 50% Employee 9.94 1,975 19,641 Animal Shelter 66,000 100% 66,000 Per Capita & 50% Employee 1.81 1,975 3,570 Subtotal - Animal Control 429,060 429,060 23,211
Fire 3,945,491 100% 3,945,491 Per Capita & 50% Employee 108.06 1,975 213,440 Building and Safety 2,133,610 100% 2,133,610 Per Capita & 50% Employee 58.43 1,975 115,422 Subtotal - Fire and Life Safety 6,079,101 6,079,101 328,863 Code Enforcement 724,302 100% 724,302 Per Capita & 50% Employee 19.84 1,975 39,183 Planning 1,833,652 100% 1,833,652 Per Capita & 50% Employee 50.22 1,975 99,196 Engineering 1,960,662 100% 1,960,662 Per Capita & 50% Employee 53.70 1,975 106,066 Building Maintenance 239,301 100% 239,301 Per Capita & 50% Employee 6.55 1,975 12,946 Parks 1,304,828 100% 1,304,828 Per Capita & 50% Employee 35.74 1,975 70,588 Recreation 629,463 100% 629,463 Per Capita & 50% Employee 17.24 1,975 34,052 Subtotal - Development Services 6,692,208 6,692,208 362,030 Aquatics 904,872 100% 904,872 Per Capita & 50% Employee 24.78 1,975 48,951 Day Care 75,278 100% 75,278 Per Capita & 50% Employee 2.06 1,975 4,072 Senior Center 258,156 50% 129,078 Per Capita & 50% Employee 3.54 1,975 6,983 Public Information 244,166 150% 366,249 Per Capita & 50% Employee 10.03 1,975 19,813 Grants Management 350,539 250% 876,348 Per Capita & 50% Employee 24.00 1,975 47,408 Elections 3,923 100% 3,923 Per Capita & 50% Employee 0.11 1,975 212 Community Enhancement 130,979 100% 130,979 Per Capita & 50% Employee 3.59 1,975 7,086 Subtotal - Community Services 1,967,913 2,486,727 134,525 Total $ 35,041,798 $ 32,345,537 $ 1,749,805
Footnotes:
(a) Per the City of Banning Citywide Preliminary Biennial Budget FY 2024-25 and FY 2025-26 on the City Council agenda dated May 28, 2024. 735
Table 12
Sunset Crossroads
Permanent Employment
Building 1 1,420,000 1,500 947
Building 2 1,386,000 1,500 924
Building 3 575,000 1,500 383
Building 4 44,000 1,500 29
Building 5 - 1,500 -
Building 6 - 1,500 -
Building 7 896,000 1,500 597
Building 8 250,000 1,500 167
Building 9 274,000 1,500 183
Building 10 222,000 1,500 148
Subtotal Industrial 5,067,000 1,500 3,378
Restaurant 18,748 500 37
Retail 205,005 500 410
Subtotal Commercial Retail 223,753 500 448
Hotel 125 1 125
Subtotal Hotel 125 125
Total Employees 3,951
Footnotes:
(a) Per Table 4.
(b) Estimated employees per square foot per the United States Green Building Council default occupancy count and review of various data sources. Estimated employees represent full time equivalent (“FTE”) employees. Actual employee count, including part-time and seasonal employees, may result in a potentially higher total headcount value depending on tenant mix. Per Table 10 FTE employees are estimated to generate $321.15 in Other Revenues and per Table 11 FTE employees are estimated to generate $885.86 in Expenditures for a net change of $564.71 per FTE employee.

Estimated
Employees Tenant Type (a) Number of Rooms (a) Employees per Room (b) Industrial
Retail
Hotel 125 keys
Tenant Type (a) Bldg. SqFt / Acre (a) Estimated SqFt per Employee (b)
Estimated
Employees
Tenant Type (a) Bldg. SqFt / Acre Estimated SqFt per
Employee (b)
Estimated
Employees
736

TECHNICAL MEMORANDUM
20341 SW Birch Street | Suite 230 | Newport Beach, CA 92660 | (949) 660-1994 | urbanxroads.com DATE: October 23, 2025
TO: David Newell, City of Banning
FROM: Charlene So, Urban Crossroads, Inc.

Haseeb Qureshi, Urban Crossroads, Inc.

Bill Maddux, Urban Crossroads, Inc.

Alex So, Urban Crossroads, Inc.

JOB NO: 13534-16
SUBJECT: SUNSET CROSSROADSPROJECT –SUPPLEMENTAL CEQA

MEMORANDUM
Attached is the revised Supplemental CEQA Memorandum that addresses the peer review comments and adds some additional clarifying language.
737

TECHNICAL MEMORANDUM
20341 SW Birch Street | Suite 230 | Newport Beach, CA 92660 | (949) 660-1994 | urbanxroads.com DATE: October 23, 2025
TO: David Newell, City of Banning
FROM: Charlene So, Urban Crossroads, Inc.

Haseeb Qureshi, Urban Crossroads, Inc.

Bill Maddux, Urban Crossroads, Inc.

Alex So, Urban Crossroads, Inc.

JOB NO: 13534-15
SUBJECT: SUNSET CROSSROADSPROJECT –SUPPLEMENTAL CEQA

MEMORANDUM
Urban Crossroads, Inc. is pleased to provide the following supplemental CEQA analysis for the Sunset Crossroads (Project). The Project Applicant, NP Banning Industrial, LLC, is proposing to develop a 533.8-acre property (Development Site) located partly within the City of Banning (City) and in part in the City’s sphere of influence (SOI) in unincorporated Riverside County (County) which included the following mix of uses as evaluated in the Draft and Final Environmental Impact Reports (EIR)( SCH No. 2021020011) for the Sunset Crossroads project ( (“Original Project”):
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 197,500 square feet of General Light Industrial use
• 490,500 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 330,000 square feet of High-Cube Cold Storage Warehouse use • 12,000 square feet of Retail use
• 40,700 square feet of Go-Kart Racing use
• 13,000 square feet of Rock Climbing use
• 12,500 square feet of Trampoline Park use
• 116,700 square feet of Health/Fitness Club
• 9,500 square feet of Quality Restaurant use
• 40,000 square feet of High Turnover Sit-Down Restaurant use • 7,000 square feet of Fast-Food Restaurant with Drive-Through Window use • 9,500 square feet of Medical-Dental Office use
• 125-room Hotel
• 7,500 square foot Truck Stop
A joint public informational meeting was held on May 28, 2025 before the City Council and Planning Commission. Thereafter, the City considered the comments and questions raised at the meeting, and recommended modifications to the Project Applicant. As a result, the Project Applicant has 738
13534-15 CEQA Memo Redline13534-1415CEQA Memo 2 Sunset Crossroads made certain modifications and proposes the following modifications (as so modified, the “Modified Project”):
• Removal of 330,000 square feet of High-Cube Cold Storage Use (Buildings 5 & 6) • Removal of 105,500 square feet of Warehousing use (Buildings 5 & 6) • Removal of 42,500 square feet of General Light Industrial use (Buildings 5 & 6) • Removal of 40,700 square feet of Go-Kart Racing use
• Removal of 13,000 square feet of Rock Climbing use
• Removal of 116,700 square feet of Health/Fitness Club use • Removal of 9,500 square feet of Medical-Dental Office use • Removal of 7,500 square feet of Truck Stop use
• Removal of 9,500 square foot Quality Restaurant use
• Reduce Retail use from 12,000 square feet to 5,005 square feet • Reduce High Turnover Sit-down Restaurant use from 40,000 square feet to 10,595 square feet
• Reduce Fast-food Restaurant With Drive-Through Window use from 7,000 square feet to 645 square feet
• Addition of 200,000 square feet of Discount Club use
• Addition of 7,508 square feet of Fast-Food Without Drive-Through Window use.

The Specific Plan permits each of these uses and decreases in the square footage of the project. As compared to the Original Project, the Modified Project results in a reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses, and replaces these Commercial Retail uses with 200,000 square feet of Discount Club use and 7,508 square feet of Fast-Food Without Drive-Through Window use resulting in a slight decrease in overall commercial square footage. All other Industrial and Retail uses remain unchanged. All mitigation measures and project design features also remain unchanged.

The purpose of this memorandum is to explain and document the modifications to the Original Project and provide supplemental technical support and analysis to reflect the proposed changes to the Original Project in order to comply with CEQA.

In order to evaluate the effect of the Modified Project as compared with the Original Project, the Modified Sunset Crossroads (SP No. 20-20000002) Trip Generation Assessment (see Attachment A to this Memorandum), a trip generation analysis, was prepared. Although CEQA does not require assessment of impacts from project trip generation, and vehicle trips no longer are considered an environmental impact due to SB 743, this information is used to calculate air quality and GHG emissions and noise impacts. The analysis shows that modifications to the Original Project result in a decrease in passenger vehicle and truck trips.

As a result, and as detailed below, implementation of the Modified Project reduces environmental impacts for each impact area in which significant and unavoidable impacts were identified (i.e., Air Quality, GHG, Noise and Transportation) and, with respect to certain air pollutants, reduces previously significant and unavoidable impacts to less than significant levels. Because the 739
13534-15 CEQA Memo Redline13534-1415CEQA Memo 3 Sunset Crossroads modifications result in a decrease in environmental impacts, there is no significant new information1 and the criteria set forth in Section 15088.5(a) of the State CEQA Guidelines requiring recirculation are not met. Therefore, the EIR does not need to be recirculated prior to certification. 2 Air Quality and GHG3
The Air Quality & Greenhouse Gas Evaluation (see Attachment B to this Memorandum) quantified emissions reductions from the changes to the project which reduced the amount of industrial square footage and focused commercial use on Discount Clubs. These modifications to the proposed project result in a decrease in truck trips and truck miles traveled, and a decrease in passenger car trips. An updated CalEEMod emissions output was prepared which accounted for the decrease in truck and passenger vehicle trips, miles traveled, and decrease in passenger vehicle travel. The methodology utilized in FEIR Appendices C-5 and C-6 was used to calculate a weighted average of three types of trucks to be used in project operations and calculated truck trip lengths based on the WAIRE Implementation Guidelines thus addressing both the SCAQMD and CARB FEIR comments related to truck trip length. The updated CalEEMod emissions outputs and this methodology were used to update the Air Quality and GHG emissions analyses. All project design features and mitigation measures described in the FEIR remain the same.

The FEIR showed that for the Original Project, criteria pollutant emissions except for CO and SOx, exceeded the threshold of significance and were identified as significant and unavoidable impacts.

Under the Modified Project, all criteria pollutant emissions (VOC, NOx, CO, SOx, PM10, and PM2.5) are reduced as compared to the Original Project. With the Modified Project, CO, SOx and PM2.5 are reduced to below the threshold of significance while the other pollutants still exceed the threshold of significance but with a net decrease compared to the 2024 FEIR. Therefore, the Modified Project continues to result in a significant and unavoidable impact .

For GHG emissions, the same methodology described above was used to calculate the GHG emissions for the Modified Project. The Modified Project would further reduce mitigated GHG emissions by 5,298.76 metric tons of CO2 annually, from 44,174.26 metric tons per year to 38,875.50 metric tons per year. However, the Modified Project still would result in a total of approximately 38,875.50 MTCO2e per year and continue to result in a significant and unavoidable impact.

The Modified Project further reduces Air Quality and GHG impacts and does not result in a new significant environmental impact or substantial increase in severity of an environmental impact.

Therefore, this does not represent significant new information as defined in Section 15088.5(a) of the State CEQA Guidelines. The project modifications do not change the findings in the Final EIR that there are no additional feasible mitigation measures available that would further reduce emissions 1 Under CEQA Section 15088.5 (a), “Significant new information” requiring recirculation includes, for example, a disclosure showing that: (1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented; (2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance; (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it; or (4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. 2Under CEQA Section 158088.5(b), recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. 3Construction emissions are discussed in Attachment B.
740
13534-15 CEQA Memo Redline13534-1415CEQA Memo 4 Sunset Crossroads because the majority of the Project’s emissions come from mobile sources which are regulated by the State and not the City of Banning.

In summary, the project modifications reduce the square footage of industrial and commercial buildings, lessen vehicle trips and miles traveled, and lessen Air Quality and GHG impacts without causing any new environmental impacts. Therefore, criteria for recirculation set forth in Section 15088.5(a) and (b) of the State CEQA Guidelines are not met.

ENERGY
Quantification of operational energy consumption of the Modified Project is not required in this Supplemental Memorandum. As analyzed in the EIR, energy impacts are less than significant.

Changes in vehicle types discussed in Attachment A regarding Trip Generation and the decrease in overall building square footage will result in less energy usage. This reduction occurs because a smaller building footprint typically requires less electricity for lighting, heating, cooling, and other operational needs. Furthermore, the decrease in overall vehicle trips would also reduce transportation-related energy consumption. Accordingly, the energy impact of the Modified Project remains less than significant.

VMT
The Modified Sunset Crossroads Specific Plan (SP No. 200-20000002) Vehicle Miles Traveled (VMT) Comparative Analysis (see Attachment C to this Memorandum) performed VMT calculations for the Modified Project and compared them to the VMT analysis performed for the Draft EIR.4 The calculations for the Modified Project were based on employment estimates derived from square footage for each type of use – retail, hotel, and industrial- measured against the threshold of significance, and compared to the 2023 VMT analysis which utilized the same methodology. All project design features and mitigation measures described in the FEIR remain the same for the Modified Project.

For retail VMT, the Modified Project showed a decrease over the 2023 VMT analysis; however, both were less than the threshold of significance. However, for non-retail VMT, while the Modified Project shows a slight decrease over the 2023 VMT analysis per employee and overall, both exceed the City’s threshold of significance. Accordingly, overall, the Modified Project also exceeds the City’s threshold of significance for VMT per employee, and the Modified Project continues to result in a significant and unavoidable impact.

The Modified Project does not result in a new significant environmental impact or substantial increase in severity of an environmental impact. Accordingly, the changes to the project do not represent significant new information as defined in Section 15088.5(a) of the State CEQA Guidelines.

Therefore, criteria for recirculation set forth in Section 15088.5(a) and (b) of the State CEQA Guidelines are not met.

Noise5
4A revised VMT analysis was not prepared for the FEIR so the VMT analysis at Appendix J-1 as revised August 25, 2023 contains the relevant data for comparison.
5 Construction and operational vibration impacts are discussed in Attachment D. 741
13534-15 CEQA Memo Redline13534-1415CEQA Memo 5 Sunset Crossroads The Sunset Crossroads Noise Assessment for the Modified Project (see Attachment D to this Memorandum) assessed construction and on-site and off-site operational noise impacts of the Modified Project and compared them to the Original Project. All project design features and mitigation measures described in the FEIR remain the same for the Modified Project. See FEIR Appendix I-2 – Supplemental Noise Analysis.

The DEIR identified certain significant and unavoidable construction noise and operational on-site (stationary source) and off-site noise impacts. The FEIR added project design features that eliminated significant and unavoidable impacts identified in the DEIR from operational off-site traffic noise levels and on-site stationary noise levels generated from project operations. The FEIR identified stationary operations noise sources, as including truck delivery and truck loading/unloading activities; heating, ventilation, and air conditioning (HVAC), including cold storage, equipment; refrigeration equipment; drive-through speakerphones; parking activities; fueling activities; and outdoor eating activities. The FEIR Supplemental Noise Analysis concluded that with implementation of additional project design features and mitigation measures, operational noise levels generated from operation of the Development Project would be less than significant, including at residential noise receivers.

The FEIR evaluated on-site construction activities and off-site traffic noise from construction deliveries and workers accessing the Development Project site. The analysis included Mass Grading, Grading, Sitework-Utilities, Building Construction, Paving, and Architectural Coatings. The FEIR concluded that noise levels generated from on-site construction activity and off-site constructionrelated traffic would be less than significant, including at residential noise receivers. However, because it is yet to be determined if a noise barrier can be constructed on the City's right-of-way, construction noise impacts for the construction of the roadway and utilities on Sunset Boulevard would be considered significant and unavoidable.

The Modified Project significantly decreased the square footage of industrial buildings, slightly decreased the square footage of commercial buildings, decreased truck trips, and decreased passenger vehicle trips. As a result, the Modified Project shows a 7 percent (7%) decrease in vehicle trips and a 44% decrease in truck trips over the Original Project. This represents a decrease in the level of noise because trucks produce noise levels up to 10 times higher than those of passenger vehicles. Thus, overall, the Modified Project would generally result in a 2 dBA CNEL decrease over off-site traffic noise levels. Because off-site traffic noise levels were identified in the FEIR as less than significant after imposition of additional project design features and mitigation, and the Modified Project reduces the number of truck trips on the adjoining roadways, it would continue to result in a less than significant noise impact. Further, as stated in the FEIR Appendix I-2 Supplemental Noise Analysis, truck traffic is a component of stationary operations noise sources, so the decrease in truck traffic would also result in a slight decrease in those noise impacts, which remain less than significant with the Modified Project.

The Modified Project would include similar on-site noise sources as the Development Project; however, there would be fewer loading docks and less on-site truck activity, as well as less rooftop equipment associated with cold storage, which is anticipated to result in lower overall noise levels at surrounding receivers. Since the same project design features included in the FEIR would continue to be applicable to the Modified Project and the noise sources are similar, the Modified Project also would result in less than significant impacts.
742
13534-15 CEQA Memo Redline13534-1415CEQA Memo 6 Sunset Crossroads The Modified Project would require a similar level of construction effort, including similar phases of construction, equipment requirements, number of workers, and deliveries. Thus, construction noise from the construction of the Modified Project is anticipated to be nearly identical to the Project and would therefore result in similar impacts as the Project. Therefore, the Modified Project would also result in significant and unavoidable impacts.

The Modified Project further reduces noise impacts and does not result in a new significant environmental impact or a substantial increase in the severity of an environmental impact.

Therefore, this does not represent significant new information as defined in Section 15088.5(a) of the State CEQA Guidelines. The project modifications do not change the findings in the Final EIR and lessen noise impacts without causing any new environmental impacts. Therefore, the criteria for recirculation set forth in Section 15088.5(a) and (b) of the State CEQA Guidelines are not met.

CONCLUSION
Implementation of the Modified Project reduces environmental impacts for each impact area in which significant and unavoidable impacts were identified (i.e., Air Quality, GHG, Noise, and Transportation) and, with respect to PM2.5, reduces previously significant and unavoidable impacts to less than significant levels. Because the modifications result in a decrease in environmental impacts, there is no significant new information, and the criteria set forth in Section 15088.5(a) of the State CEQA Guidelines requiring recirculation are not met. Therefore, the EIR does not need to be recirculated prior to certification.

If you have any questions, please contact us at: Charlene So at [email protected], Haseeb Quresthi at [email protected], Bill Maddux at [email protected], or Alex So at [email protected].
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ͭͯͱͯͰ-ͭͱ CEQA Memo Redline ͳ Sunset Crossroads
ATTACHMENT A:

TRIP GENERATION
744

TECHNICAL MEMORANDUM
20341 SW Birch Street | Suite 230 | Newport Beach, CA 92660 | (949) 660-1994 | urbanxroads.com DATE: September 3, 2025
TO: J.J. Jenkins, NP Banning Industrial, LLC
FROM: Charlene So, Urban Crossroads, Inc.

JOB NO: 13534-12 TG Memo
SUBJECT: MODIFIED SUNSET CROSSROADS (SP NO. 20-20000002) TRIP

GENERATION ASSESSMENT
Urban Crossroads, Inc. has prepared the following Trip Generation Assessment for the Modified Sunset Crossroads (Modified Project), which is located south of the I-10 Freeway and west of Sunset Avenue in the City of Banning. This technical memorandum presents the updated trip generation based on the proposed change in land uses and provides a comparison of the analysis findings to those previously presented in the Sunset Crossroads Supplemental Traffic Assessment(dated August 31, 2023) attached as Appendix J-3 of the Sunset Crossroads Draft Environmental Impact Report (SCH No. 2021020011) dated December 2023 (“DEIR”); hereafter referred to as the “2023 Supplemental Traffic Assessment.” Specifically, the purposes of this assessment it to determine whether the Modified Project’s proposed land use changes would require any further traffic operations analysis based on the City’s Traffic Impact Analysis Guidelines for Local Transportation Analysis and Vehicle Miles Traveled Analysis (dated October 2021, referred to as City Guidelines).

PROJECT OVERVIEW
The DEIR and the 2023 Supplemental Traffic Assessment evaluated 5,545,000 square feet of Warehousing/Industrial/Light industrial use including 330,000 square feet of High-Cube Cold Storage Warehousing use and a commercial component that includes up to 268,400 square feet (including a 7,500 square foot Truck Stop with Fueling Stations), plus a 125-room Hotel with the following mix of uses:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 197,500 square feet of General Light Industrial use
• 490,500 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 330,000 square feet of High-Cube Cold Storage Warehouse use • 12,000 square feet of Retail use
• 40,700 square feet of Go-Kart Racing use
• 13,000 square feet of Rock Climbing use
• 12,500 square feet of Trampoline Park use
• 116,700 square feet of Health/Fitness Club
• 9,500 square feet of Quality Restaurant use
• 40,000 square feet of High Turnover Sit-Down Restaurant use 745
13534-12 TG Memo.docx 2 Modified Sunset Crossroads
• 7,000 square feet of Fast-Food Restaurant with Drive-Through Window use • 9,500 square feet of Medical-Dental Office use
• 125-room Hotel
• 7,500 square foot Truck Stop
The following trip generation assessment compares the Modified Project with the changes proposed as part of the Development Agreement to the Project analyzed in the DEIR and the 2023 Supplemental Traffic Assessment to ensure the environmental effects are less than those already disclosed in the DEIR. Specifically, the changes to the Modified Project are outlined as follows:
• Removal of 330,000 square feet of High-Cube Cold Storage Use (Buildings 5 & 6) • Removal of 105,500 square feet of Warehousing use (Buildings 5 & 6) • Removal of 42,500 square feet of General Light Industrial use (Buildings 5 & 6) • Removal of 40,700 square feet of Go-Kart Racing use
• Removal of 13,000 square feet of Rock Climbing use
• Removal of 116,700 square feet of Health/Fitness Club use • Removal of 9,500 square feet of Medical-Dental Office use • Removal of 7,500 square feet of Truck Stop use
• Removal of 9,500 square foot Quality Restaurant use
• Reduce Retail use from 12,000 square feet to 5,005 square feet • Reduce High Turnover Sit-down Restaurant use from 40,000 square feet to 10,595 square feet • Reduce Fast-food Restaurant With Drive-Through Window use from 7,000 square feet to 645 square feet
• Addition of 200,000 square feet of Discount Club use
• Addition of 7,508 square feet of Fast-Food Without Drive-Through Window use This results in a total reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses and replacing these uses with 200,000 square feet of Discount Club use and 7,508 square feet of Fast-Food Without Drive-Through Window use. All other Industrial and Retail uses remain the same.
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13534-12 TG Memo.docx 3 Modified Sunset Crossroads

TRIP GENERATION
Trip generation represents the amount of traffic which is both attracted to and produced by a development. Determining traffic generation for a specific project is therefore based upon forecasting the amount of traffic that is expected to be both attracted to and produced by the specific land uses being proposed for a given development. 2023 SUPPLEMENTAL TRAFFIC ASSESSMENT
The DEIR identified and the 2023 Supplemental Traffic Assessment analyzed the following mix of uses for the Industrial component:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 197,500 square feet of General Light Industrial use
• 490,500 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 330,000 square feet of High-Cube Cold Storage Warehouse use These were analyzed in the 2023 Supplemental Traffic Assessment. The trip generation rates utilized in the 2023 Supplemental Traffic Assessment to analyze this use are provided in Appendix 1. Table 1 summarizes the Project’s trip generation as evaluated in the 2023 Supplemental Traffic Assessment with 20,496 two-way trips per day, 1,264AM peak hour trips, and 1,792 PM peak hour trips.Appendix 2 includes the detailed trip generation as evaluated in the 2023 Supplemental Traffic Assessment. 747
13534-12 TG Memo.docx 4 Modified Sunset Crossroads
TABLE 1: 2023 SUPPLEMENTAL TRAFFIC ASSESSMENT TRIP GENERATION SUMMARY AM Peak Hour PM Peak Hour
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 1 (No Changes)
Buildings 1, 2, 3 & 4 3,425.000 TSF
Passenger Cars: 295 85 380 140 375 515 6,120
Trucks: 52 16 68 20 51 71 1,306
Phase 1 Total Trips 347 101 448 160 426 586 7,426
Phase 2
Commercial Retail Uses (plus
hotel) (No Changes) 268.400 TSF
Passenger Cars: 196 196 393 452 274 726 7,702
Trucks: 33 33 66 28 25 53 1,164
Commercial Retail Total Trips 229 229 459 480 299 779 8,866 Building 5: Warehousing (With
Changes)2 105.500 TSF
Passenger Cars: 10 1 11 4 11 15 118
Trucks: 1 0 1 1 1 2 50
Building 6: General Light
Industrial (With Changes)3 42.500 TSF
Passenger Cars: 22 1 23 2 21 23 172
Trucks: 0 0 0 0 0 0 20
New: High-Cube Cold Storage
(With Changes)4 330.000 TSF
Passenger Cars: 9 1 11 5 13 18 276
Trucks: 8 2 10 2 7 9 248
Phase 2 Total Trips 280 234 515 495 352 847 9,750
Phase 3 (With Changes)5
Buildings 7 & 10 1,118.000 TSF
Passenger Cars: 109 14 123 31 116 146 1,482
Trucks: 13 4 17 6 12 18 304
Phase 3 Total Trips 122 18 140 37 128 164 1,786
Phase 4 (No Changes)
Buildings 8 & 9 524.000 TSF
Passenger Cars: 100 44 144 116 72 187 1,296
Trucks: 10 6 16 2 6 8 238
Phase 4 Total Trips 110 50 160 118 78 195 1,534
Project Buildout (Updated)
Project Total Passenger Cars 742 343 1,086 750 881 1,631 17,166 Project Total Trucks 117 61 178 59 102 161 3,330
Updated Project Total Trips 859 404 1,264 809 983 1,792 20,496 1 TSF = Thousand Square Feet 2 Warehousing use is reduced from 326,000 SF to 105,500 SF (a reduction of 220,500 SF). 111,000 SF of Warehousing use moved to Phase 3. 3 General Light Industrial use is reduced from 152,000 SF to 42,500 SF (a reduction of 109,500 SF). 4 330,000 SF of High-Cube Cold Storage Warehouse use added. No net change in square footage for Phase 2 (220,500 SF + 109,000 SF = 330,000 SF). 5 111,000 SF of High-Cube Cold Storage Warehouse use moved from Phase 3 to Phase 2 and replaced with 111,000 SF of Warehousing use. 748
13534-12 TG Memo.docx 5 Modified Sunset Crossroads

MODIFIED PROJECT
The Modified Project includes a total reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses and replacing these uses with 200,000 square feet of Discount Club use and 7,508 square feet of Fast-Food Without Drive-Through Window use with the following summary of uses:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 155,000 square feet of General Light Industrial use
• 385,000 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 200,000 square feet of Discount Club use
• 5,005 square feet of Retail use
• 10,595 square feet of High Turnover Sit-Down Restaurant use • 7,508 square feet of Fast-Food Restaurant without Drive-Through Window use • 645 square feet of Fast-Food Restaurant with Drive-Through Window use • 125-room Hotel
The trip generation rates utilized for the Modified Project are also provided in Appendix 1. Table 2 summarizes the Modified Project’s trip generation with 17,852 two-way trips per day, 1,187AM peak hour trips, and 1,642 PM peak hour trips. Appendix 3 includes the detailed trip generation for the Modified Project.

The Modified Project introduces changes in land use mix and intensity; however, the distribution patterns of both passenger cars and trucks would remain consistent with those evaluated in the DEIR as the types of uses and the locations of those uses (commercial retail and industrial) are generally located within the same areas. Project-related traffic forecast adjustments are attributable to updated land use and intensities, and these modifications are expected to result in overall reductions in traffic volumes compared to the original DEIR analysis due to the overall reduction in total trip generation in conjunction with the same DEIR distribution patterns. 749
13534-12 TG Memo.docx 6 Modified Sunset Crossroads
TABLE 2:MODIFIED PROJECT TRIP GENERATION SUMMARY
AM Peak Hour PM Peak Hour
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 1
Buildings 1, 2, 3 & 4 3,425.000 TSF
Passenger Cars: 295 85 380 140 375 515 6,120
Trucks: 52 16 68 20 51 71 1,306
Phase 1 Total Trips 347 101 448 160 426 586 7,426
Phase 2
Commercial Retail Uses (plus hotel) 223.753 TSF
Passenger Cars: 225 126 351 347 318 665 6,778
Trucks: 0 0 0 0 0 0 0
Commercial Retail Total Trips 225 126 351 347 318 665 6,778 Phase 2 Total Trips 225 126 351 347 318 665 6,778
Phase 3
Buildings 7 & 10 1,118.000 TSF
Passenger Cars: 123 26 149 35 127 162 1,704
Trucks: 13 4 17 6 12 18 304
Phase 3 Total Trips 136 30 166 41 139 180 2,008
Phase 4
Buildings 8 & 9 524.000 TSF
Passenger Cars: 114 92 206 120 83 203 1,402
Trucks: 10 6 16 2 6 8 238
Phase 4 Total Trips 124 98 222 122 89 211 1,640

Project Total Passenger Cars 757 329 1,086 642 903 1,545 16,004 Project Total Trucks 75 26 101 28 69 97 1,848
Modified Project Total Trips 832 355 1,187 670 972 1,642 17,852 1 TSF = Thousand Square Feet
Table 3 summarizes the trip generation comparison between the DEIR and 2023 Supplemental Traffic Assessment to the Modified Project. As shown, the land uses evaluated for the Modified Project are anticipated to result in a net reduction of 2,644 two-way trips per day with a net reduction of 77 AM peak hour trips and 150 PM peak hour trips as compared to the uses and trips identified in the DEIR and 2023 Supplemental Traffic Assessment. As such, the deficiencies and recommended improvements identified in the DEIR would also be applicable to the uses evaluated for the Modified Project.

If you have any questions, please contact me directly at [email protected]. 750
13534-12 TG Memo.docx 7 Modified Sunset Crossroads
TABLE 3: 2023 SUPPLEMENTAL TRAFFIC ASSESSMENT COMPARISON VS.MODIFIED PROJECT AM Peak Hour PM Peak Hour
Daily Land Use In Out Total In Out Total
Project
Passenger Cars 742 343 1,086 750 881 1,631 17,166
Trucks 117 61 178 59 102 161 3,330
Project Total 859 404 1,264 809 983 1,792 20,496

Modified Project
Passenger Cars 757 329 1,086 642 903 1,545 16,004
Trucks 75 26 101 28 69 97 1,848
Modified Project Total 832 355 1,187 670 972 1,642 17,852

Net Change of Passenger Cars 14 -14 0 -108 22 -86 -1,162 Net Change of Trucks -42 -35 -77 -31 -33 -64 -1,482
Total Project Net Change -28 -49 -77 -139 -11 -150 -2,644

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13534-12 TG Memo.docx 8 Modified Sunset Crossroads
APPENDIX 1:

TRIP GENERATION RATES
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13534-12 TG Memo.docx 9 Modified Sunset Crossroads
TABLE 1-1: ITE TRIP GENERATION RATES
ITE
LU AM Peak Hour PM Peak Hour Daily
Land Use1 Units2 Code In Out Total In Out Total
General Light Industrial3 TSF 110 0.616 0.084 0.700 0.082 0.548 0.630 4.960 Passenger Cars 0.598 0.081 0.679 0.080 0.537 0.617 4.563 2-Axle Trucks 0.003 0.000 0.004 0.000 0.002 0.002 0.066 3-Axle Trucks 0.004 0.001 0.004 0.000 0.002 0.003 0.082 4+-Axle Trucks 0.012 0.002 0.013 0.001 0.007 0.008 0.248 Warehousing3 TSF 150 0.131 0.039 0.170 0.051 0.139 0.190 1.740 Passenger Cars 0.114 0.034 0.148 0.044 0.118 0.162 1.270 2-Axle Trucks 0.003 0.001 0.004 0.001 0.003 0.005 0.078 3-Axle Trucks 0.004 0.001 0.005 0.002 0.004 0.006 0.097 4+-Axle Trucks 0.011 0.003 0.014 0.005 0.013 0.018 0.294 High-Cube Transload and ShortTerm Storage Warehouse
(Without Cold Storage)3
TSF 154 0.062 0.018 0.080 0.028 0.072 0.100 1.400
Passenger Cars 0.049 0.015 0.064 0.024 0.060 0.084 1.176 2-Axle Trucks 0.002 0.001 0.003 0.001 0.002 0.003 0.037 3-Axle Trucks 0.003 0.001 0.003 0.001 0.002 0.003 0.046 4+-Axle Trucks 0.008 0.002 0.010 0.003 0.007 0.010 0.140 High-Cube Fulfillment Center
Warehouse4 TSF -- 0.094 0.028 0.122 0.046 0.119 0.165 2.129 Passenger Cars 0.079 0.024 0.103 0.040 0.104 0.144 1.750 2-4 Axle Trucks 0.006 0.002 0.008 0.003 0.008 0.011 0.162 5+-Axle Trucks 0.008 0.003 0.011 0.003 0.007 0.010 0.217 High-Cube Parcel Hub3,5 TSF 156 0.350 0.350 0.700 0.435 0.205 0.640 4.630 Passenger Cars 0.333 0.333 0.352 0.431 0.203 0.452 4.213 2-Axle Trucks 0.003 0.003 0.058 0.001 0.000 0.031 0.070 3-Axle Trucks 0.004 0.004 0.072 0.001 0.000 0.039 0.086 4+-Axle Trucks 0.011 0.011 0.218 0.003 0.001 0.117 0.261 High-Cube Cold Storage
Warehouse (With Cold Storage)3 TSF 157 0.085 0.025 0.110 0.032 0.088 0.120 2.120 Passenger Cars 0.062 0.018 0.080 0.025 0.067 0.092 1.378 2-Axle Trucks 0.008 0.002 0.010 0.003 0.007 0.010 0.257 3-Axle Trucks 0.003 0.001 0.003 0.001 0.002 0.003 0.082 4+-Axle Trucks 0.012 0.004 0.016 0.004 0.011 0.015 0.403 753
13534-12 TG Memo.docx 10 Modified Sunset Crossroads
ITE LU AM Peak Hour PM Peak Hour
Daily Land Use1 Units2 Code In Out Total In Out Total
Truck Stop TSF 950 13.245 13.245 26.490 12.047 10.683 22.730 455.530 Passenger Cars 8.874 8.874 17.748 8.312 7.371 15.684 300.650 Total Trucks 4.371 4.371 8.742 3.735 3.312 7.046 154.880 2-Axle Trucks (4.9%) 0.214 0.214 0.428 0.183 0.162 0.345 7.589 3-Axle Trucks (16.2%) 0.708 0.708 1.416 0.605 0.537 1.142 25.091 4+-Axle Trucks (78.9%) 3.449 3.449 6.897 2.947 2.613 5.560 122.200 K-1 Kart Racing7 TSF -- N/A N/A N/A 0.36 0.27 0.63 6.76 Rock Climbing6 TSF 434 0.46 0.94 1.40 0.93 0.71 1.64 16.40 Health/Fitness Club6 TSF 492 0.67 0.64 1.31 1.97 1.48 3.45 34.50 Trampoline Park6 TSF 436 N/A N/A N/A 0.72 0.78 1.50 15.00 Medical-Dental Office TSF 720 2.17 0.61 2.78 0.97 2.49 3.46 34.80 Shopping Center5 TSF 820 0.82 0.51 1.33 2.23 2.41 4.64 49.55 Shopping Center8 TSF 820 0.82 0.51 1.33 2.23 2.41 4.64 49.55 Discount Club TSF 857 0.40 0.16 0.56 2.12 2.12 4.24 41.80 Quality Restaurant TSF 931 0.37 0.37 0.73 5.23 2.57 7.80 83.84 High Turnover Sit-Down
Restaurant TSF 932 5.47 4.47 9.94 6.06 3.71 9.77 112.18 Fast-food Without Drive-Thru TSF 933 15.06 10.04 25.10 14.17 14.17 28.34 346.23 Fast-Food Restaurant with DriveThru Window TSF 934 20.50 19.69 40.19 16.99 15.68 32.67 470.95 Hotel RM 310 0.28 0.19 0.47 0.31 0.29 0.60 8.36
1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Tenth Edition (2017). 2 TSF = thousand square feet; RM = Rooms
3 Vehicle Mix Source: ITE Trip Generation Handbook Supplement (2020), Appendix C.

Truck Mix: South Coast Air Quality Management District’s (SCAQMD) recommended truck mix, by axle type.

Normalized % - Without Cold Storage: 16.7% 2-Axle trucks, 20.7% 3-Axle trucks, 62.6% 4-Axle trucks.

Normalized % - With Cold Storage: 34.7% 2-Axle trucks, 11.0% 3-Axle trucks, 54.3% 4-Axle trucks. 4 Vehicle Mix Source: High Cube Warehouse Trip Generation Study, WSP, January 29, 2019.

Inbound and outbound split source: ITE Trip Generation Manual, Tenth Edition (2017) for ITE Land Use Code 154. 5 Rate based on the regression equation from the ITE Trip Generation Manual, Tenth Edition (2017), for 12,000 sf. 6 No weekday daily value provided in ITE. Estimated based on 10 times the PM peak hour. 7 Source: Trip Generation and Parking Rate Analysis for the proposed K-1 Speed Indoor Kart Track, Linscott Law & Greenspan Engineers, June 20, 2005. 5 Rate based on the regression equation from the ITE Trip Generation Manual, Tenth Edition (2017), for 19,500 sf. 754
13534-12 TG Memo.docx 11 Modified Sunset Crossroads
APPENDIX 2:

PROJECT TRIP GENERATION – 2023 SUPPLEMENTAL TRAFFIC ASSESSMENT 755
13534-12 TG Memo.docx 12 Modified Sunset Crossroads
TABLE 2-1: 2023 SUPPLEMENTAL TRAFFIC ASSESSMENT PROJECT TRIP GENERATION SUMMARY Land Use Quantity Units1 In Out Total In Out Total Daily Phase 1
Building 1: High-Cube Fulfillment 1,420.000 TSF
Passenger Cars: 113 34 147 57 147 204 2,486
Truck Trips:
2-4-axle: 9 3 12 4 11 15 230
5+-axle: 12 4 16 4 10 14 308
Total Trucks: 21 7 28 8 21 29 538
Building 1 Total Trips 2 134 41 175 65 168 233 3,024
Building 2: High-Cube Fulfillment 1,386.000 TSF
Passenger Cars: 110 33 143 56 144 200 2,426
Truck Trips:
2-4-axle: 9 3 12 4 11 15 226
5+-axle: 12 4 16 4 10 14 302
Total Trucks: 21 7 28 8 21 29 528
Building 2 Total Trips 2 131 40 171 64 165 229 2,954
Building 3: High-Cube Fulfillment 575.000 TSF
Passenger Cars: 46 14 60 23 60 83 1,006
Truck Trips:
2-4-axle: 4 1 5 2 5 7 94
5+-axle: 5 1 6 2 4 6 126
Total Trucks: 9 2 11 4 9 13 220
Building 3 Total Trips 2 55 16 71 27 69 96 1,226
Building 4: General Light Industrial 44.000 TSF
Passenger Cars: 26 4 30 4 24 28 202
Truck Trips:
2-axle: 0 0 0 0 0 0 4
3-axle: 0 0 0 0 0 0 4
4+-axle: 1 0 1 0 0 0 12
Total Trucks: 1 0 1 0 0 0 20
Building 4 Total Trips 2 27 4 31 4 24 28 222
Phase 1 Total Passenger Cars 295 85 380 140 375 515 6,120 Phase 1 Total Trucks 52 16 68 20 51 71 1,306
Phase 1 Total Trips 2 347 101 448 160 426 586 7,426
Phase 2
Retail (Pad M) 12.000 TSF 10 6 16 27 29 56 596
Internal Capture 3 -4 -2 -6 -10 -7 -18 -192
Pass-By (34% PM/Daily) 4 0 0 0 -6 -6 -11 -138
Go-Kart Racing (Pad D-2) 40.700 TSF 0 0 0 15 11 26 276
Internal Capture 3 -2 -1 -3 -5 -3 -8 -90
Rock Climbing (Pad C-3) 13.000 TSF 6 12 18 12 9 21 214
Internal Capture 3 -1 -1 -2 -4 -3 -6 -66
Trampoline Park (L-3) 12.500 TSF 0 0 0 9 10 19 188
Internal Capture 3 0 0 0 -3 -2 -6 -58
Health/Fitness Club (Pad C-1, C-2, D-1, D-3, D-4, D-5, D6, D-7, E, L-1, L-2) 116.700 TSF 78 75 153 229 173 403 4,028 Internal Capture 3 -26 -15 -41 -70 -51 -121 -1,212
Retail Total 61 74 135 194 160 354 3,546
Quality Restaurant (Pad K-1) 9.500 TSF 3 3 7 50 24 74 798 Internal Capture 3 -12 -8 -20 -21 -23 -44 -480
Pass-By (44% PM/Daily) 4 0 0 0 0 0 -1 -140
High Turnover Sit-Down Restaurant (Pad A, B, H, I, J) 40.000 TSF 15 15 29 209 103 312 3,354 Internal Capture 3 -30 -22 -52 -55 -62 -116 -1,254
Pass-By (43% PM/Daily) 4 0 0 0 -18 -18 -36 -904
AM Peak Hour PM Peak Hour
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13534-12 TG Memo.docx 13 Modified Sunset Crossroads
Land Use Quantity Units1 In Out Total In Out Total Daily Fast-Food Restaurant with Drive-Thru (Pad N, O) 7.000 TSF 143 138 281 119 110 229 3,298 Internal Capture 3 -18 -13 -31 -33 -37 -70 -1,012
Pass-By (49% AM; 50% PM/Daily) 4 -61 -61 -123 -36 -36 -73 -1,050 Restaurant Total 40 52 92 214 61 275 2,610
Medical-Dental Office (Pad K-2, K-3, K-4, K-5) 9.500 TSF 21 6 26 9 24 33 332 Internal Capture 3 -11 -5 -15 -3 -9 -12 -118
Office Total 10 1 11 6 15 21 214
Hotel (Pad F) 125 RM 35 24 59 38 37 75 1,046
Internal Capture 3 -1 -11 -12 -23 -25 -48 -670
Hotel Total 34 13 47 15 12 27 376
Truck Stop (Pad G) 7.500 TSF
Passenger Cars: 67 67 133 62 55 118 2,256
Internal Capture 3 -16 -9 -25 -39 -28 -68 -1,300
Net Passenger Car Trips: 51 57 108 23 27 50 956
Truck Trips:
2-axle: 2 2 4 1 1 2 58
3-axle: 5 5 10 5 4 9 188
4+-axle: 26 26 52 22 20 42 918
Total Trucks: 33 33 66 28 25 53 1,164
Truck Stop 84 90 174 51 52 103 2,120
Total Retail Passenger Cars 196 196 393 452 274 726 7,702 Total Retail Trucks 33 33 66 28 25 53 1,164
Total Retail Trips 2 229 229 459 480 299 779 8,866
Building 5: Warehousing 105.500 TSF
Passenger Cars: 12 4 16 5 12 17 134
Internal Capture 3 : -2 -3 -5 -1 -1 -2 -16
Net Passenger Car Trips: 10 1 11 4 11 15 118
Truck Trips:
2-axle: 0 0 0 0 0 0 8
3-axle: 0 0 0 0 0 0 10
4+-axle: 1 0 1 1 1 2 32
Total Trucks: 1 0 1 1 1 2 50
Building 5 Total Trips 2 11 1 12 5 12 17 168
Building 6: General Light Industrial 42.500 TSF
Passenger Cars: 25 3 28 3 23 26 194
Internal Capture 3 : -3 -2 -5 -1 -2 -3 -22
Net Passenger Car Trips: 22 1 23 2 21 23 172
Truck Trips:
2-axle: 0 0 0 0 0 0 4
3-axle: 0 0 0 0 0 0 4
4+-axle: 0 0 0 0 0 0 12
Total Trucks: 0 0 0 0 0 0 20
Building 6 Total Trips 2 22 1 23 2 21 23 192
High-Cube Cold Storage 330.000 TSF
Passenger Cars: 20 6 26 8 22 30 456
Internal Capture: -11 -5 -15 -3 -9 -12 -180
Net Passenger Car Trips: 9 1 11 5 13 18 276
Truck Trips:
2-axle: 3 1 4 1 2 3 86
3-axle: 1 0 1 0 1 1 28
4+-axle: 4 1 5 1 4 5 134
- Truck Trips 8 2 10 2 7 9 248
Cold Storage Total Trips 2 17 3 21 7 20 27 524
Phase 2 Only Total Passenger Cars 238 199 438 464 319 783 8,268 Phase 2 Only Total Trucks 42 35 77 31 33 64 1,482
Phase 2 Only Total Trips 2 280 234 515 495 352 847 9,750 Phase 1+2 Total Passenger Cars 533 284 818 604 694 1,298 14,388 Phase 1+2 Total Trucks 94 51 145 51 84 135 2,788
Phase 1+2 Total Trips 2 627 335 963 655 778 1,433 17,176 AM Peak Hour PM Peak Hour
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13534-12 TG Memo.docx 14 Modified Sunset Crossroads
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 3
Building 7: High-Cube Transload 896.000 TSF
Passenger Cars: 44 13 57 21 54 75 1,054
Internal Capture 3: -14 -12 -26 -4 -11 -16 -222
Net Passenger Car Trips: 30 1 31 17 43 59 832
Truck Trips:
2-axle: 2 1 3 1 2 3 34
3-axle: 2 1 3 1 2 3 42
4+-axle: 7 2 9 3 6 9 126
Total Trucks: 11 4 15 5 10 15 202
Building 7 Total Trips 2 41 5 46 22 53 74 1,034
Building 10: General Light Industrial (50%) 111.000 TSF Passenger Cars: 66 9 75 9 60 69 508
Truck Trips:
2-axle: 0 0 0 0 0 0 8
3-axle: 0 0 0 0 0 0 10
4+-axle: 1 0 1 0 1 1 28
Total Trucks: 1 0 1 0 1 1 46
Building 10: Warehousing (50%) 111.000 TSF
Passenger Cars: 13 4 17 5 13 18 142
Truck Trips:
2-axle: 0 0 0 0 0 0 10
3-axle: 0 0 0 0 0 0 12
4+-axle: 1 0 1 1 1 2 34
Total Trucks: 1 0 1 1 1 2 56
Building 10 Passenger Cars 79 13 92 14 73 87 650
Building 10 Trucks 2 0 2 1 2 3 102
Building 10 Total Trips 2 81 13 94 15 75 90 752
Phase 3 Only Total Passenger Cars 109 14 123 31 116 146 1,482 Phase 3 Only Total Trucks 13 4 17 6 12 18 304
Phase 3 Only Total Trips 2 122 18 140 37 128 164 1,786
Phase 1+2+3 Total Passenger Cars 642 299 941 634 810 1,444 15,870 Phase 1+2+3 Total Trucks 107 55 162 57 96 153 3,092
Phase 1+2+3 Total Trips 2 749 354 1,103 691 906 1,597 18,962 AM Peak Hour PM Peak Hour
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13534-12 TG Memo.docx 15 Modified Sunset Crossroads
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 4
Building 8: High-Cube Parcel Hub 250.000 TSF
Passenger Cars: 83 83 166 108 51 159 1,054
Internal Capture 3 : -14 -48 -62 -4 -11 -16 -106
Net Passenger Car Trips: 69 35 104 104 40 143 948
Truck Trips:
2-axle: 1 1 2 0 0 0 18
3-axle: 1 1 2 0 0 0 22
4+-axle: 3 3 6 1 0 1 66
Total Trucks: 5 5 10 1 0 1 106
Building 8 Total Trips 2 74 40 114 105 40 144 1,054
Building 9: Warehousing 274.000 TSF
Passenger Cars: 31 9 40 12 32 44 348
Truck Trips:
2-axle: 1 0 1 0 1 1 22
3-axle: 1 0 1 0 1 1 28
4+-axle: 3 1 4 1 4 5 82
Total Trucks: 5 1 6 1 6 7 132
Building 9 Total Trips 2 36 10 46 13 38 51 480
Total Industrial Trips
Phase 4 Only Passenger Cars 100 44 144 116 72 187 1,296 Phase 4 Only Trucks 10 6 16 2 6 8 238
Phase 4 Only Total Trips 2 110 50 160 118 78 195 1,534
Project Buildout (Phase 1+2+3+4) Total Passenger Cars 742 343 1,086 750 881 1,631 17,166 Project Buildout (Phase 1+2+3+4) Total Trucks 117 61 178 59 102 161 3,330 Project Buildout (Phase 1+2+3+4) Total Trips 2 859 404 1,264 809 983 1,792 20,496 1 TSF = thousand square feet; RM = Rooms
2 Total Trips = Passenger Cars + Truck Trips.
4 Source: ITE Trip Generation Handbook , 3rd Edition, 2017.

AM Peak Hour PM Peak Hour
3 Internal capture calculated from NCHRP 684 Internal Trip Capture Estimation Tool. Internal capture includes the office portion of the industrial buildings that are in close proximity to the retail/restaurant uses (Buildings 5, 6, 7, and 8). 759
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APPENDIX 3:

MODIFIED PROJECT TRIP GENERATION
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13534-12 TG Memo.docx 17 Modified Sunset Crossroads
TABLE 3-1: PROPOSED PROJECT TRIP GENERATION SUMMARY
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 1
Building 1: High-Cube Fulfillment 1,420.000 TSF
Passenger Cars: 113 34 147 57 147 204 2,486
Truck Trips:
2-4-axle: 9 3 12 4 11 15 230
5+-axle: 12 4 16 4 10 14 308
Total Trucks: 21 7 28 8 21 29 538
Building 1 Total Trips 2 134 41 175 65 168 233 3,024
Building 2: High-Cube Fulfillment 1,386.000 TSF
Passenger Cars: 110 33 143 56 144 200 2,426
Truck Trips:
2-4-axle: 9 3 12 4 11 15 226
5+-axle: 12 4 16 4 10 14 302
Total Trucks: 21 7 28 8 21 29 528
Building 2 Total Trips 2 131 40 171 64 165 229 2,954
Building 3: High-Cube Fulfillment 575.000 TSF
Passenger Cars: 46 14 60 23 60 83 1,006
Truck Trips:
2-4-axle: 4 1 5 2 5 7 94
5+-axle: 5 1 6 2 4 6 126
Total Trucks: 9 2 11 4 9 13 220
Building 3 Total Trips 2 55 16 71 27 69 96 1,226
Building 4: General Light Industrial 44.000 TSF
Passenger Cars: 26 4 30 4 24 28 202
Truck Trips:
2-axle: 0 0 0 0 0 0 4
3-axle: 0 0 0 0 0 0 4
4+-axle: 1 0 1 0 0 0 12
Total Trucks: 1 0 1 0 0 0 20
Building 4 Total Trips 2 27 4 31 4 24 28 222
Phase 1 Total Passenger Cars 295 85 380 140 375 515 6,120 Phase 1 Total Trucks 52 16 68 20 51 71 1,306
Phase 1 Total Trips 2 347 101 448 160 426 586 7,426
Phase 2
Retail (Pad M) 5.005 TSF 4 3 7 11 12 23 248
Internal Capture 3 0 0 0 -2 -2 -4 -40
Pass-By (34% PM/Daily) 4 0 0 0 -3 -3 -6 -72
Discount Club 200.000 TSF 80 32 112 424 424 848 8360
Internal Capture 3 -10 -5 -15 -63 -54 -117 -1,158
Pass-By (34% PM/Daily) 4 0 0 0 -123 -123 -245 -2,450
Retail Total 74 30 104 244 254 499 4,888
Fast-Food Without Drive-Through 7.508 TSF 113 75 188 106 106 212 2600 Internal Capture 3 -5 -5 -10 -40 -47 -87 -1,068
Pass-By (43% PM/Daily) 4 0 0 0 -25 -25 -51 -660
High Turnover Sit-Down Restaurant (Pad A, B, H, I, J) 10.595 TSF 4 4 8 55 27 83 890 Internal Capture 3 -2 -2 -4 -14 -17 -31 -332
Pass-By (43% PM/Daily) 4 0 0 0 -5 -5 -10 -240
AM Peak Hour PM Peak Hour
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13534-12 TG Memo.docx 18 Modified Sunset Crossroads
Land Use Quantity Units1 In Out Total In Out Total Daily Fast-Food Restaurant with Drive-Thru (Pad N, O) 0.645 TSF 13 13 26 11 10 21 304 Internal Capture 3 -1 -1 -1 -5 -6 -10 -148
Pass-By (49% AM; 50% PM/Daily) 4 -6 -6 -12 -2 -2 -5 -68 Restaurant Total 117 77 194 81 42 122 1,278
Hotel (Pad F) 125 RM 35 24 59 38 37 75 1,046
Internal Capture 3 -1 -5 -6 -16 -15 -31 -434
Hotel Total 34 19 53 22 22 44 612
Total Retail Passenger Cars 225 126 351 347 318 665 6,778 Total Retail Trucks 0 0 0 0 0 0 0
Total Retail Trips 2 225 126 351 347 318 665 6,778
Phase 2 Only Total Passenger Cars 225 126 351 347 318 665 6,778 Phase 2 Only Total Trucks 0 0 0 0 0 0 0
Phase 2 Only Total Trips 2 225 126 351 347 318 665 6,778 Phase 1+2 Total Passenger Cars 520 211 731 487 693 1,180 12,898 Phase 1+2 Total Trucks 52 16 68 20 51 71 1,306
Phase 1+2 Total Trips 2 572 227 799 507 744 1,251 14,204 Phase 3
Building 7: High-Cube Transload 896.000 TSF
Passenger Cars: 44 13 57 21 54 75 1,054
Truck Trips:
2-axle: 2 1 3 1 2 3 34
3-axle: 2 1 3 1 2 3 42
4+-axle: 7 2 9 3 6 9 126
Total Trucks: 11 4 15 5 10 15 202
Building 7 Total Trips 2 55 17 72 26 64 90 1,256
Building 10: General Light Industrial (50%) 111.000 TSF Passenger Cars: 66 9 75 9 60 69 508
Truck Trips:
2-axle: 0 0 0 0 0 0 8
3-axle: 0 0 0 0 0 0 10
4+-axle: 1 0 1 0 1 1 28
Total Trucks: 1 0 1 0 1 1 46
Building 10: Warehousing (50%) 111.000 TSF
Passenger Cars: 13 4 17 5 13 18 142
Truck Trips:
2-axle: 0 0 0 0 0 0 10
3-axle: 0 0 0 0 0 0 12
4+-axle: 1 0 1 1 1 2 34
Total Trucks: 1 0 1 1 1 2 56
Building 10 Passenger Cars 79 13 92 14 73 87 650
Building 10 Trucks 2 0 2 1 2 3 102
Building 10 Total Trips 2 81 13 94 15 75 90 752
Phase 3 Only Total Passenger Cars 123 26 149 35 127 162 1,704 Phase 3 Only Total Trucks 13 4 17 6 12 18 304
Phase 3 Only Total Trips 2 136 30 166 41 139 180 2,008
Phase 1+2+3 Total Passenger Cars 643 237 880 522 820 1,342 14,602 Phase 1+2+3 Total Trucks 65 20 85 26 63 89 1,610
Phase 1+2+3 Total Trips 2 708 257 965 548 883 1,431 16,212 AM Peak Hour PM Peak Hour
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13534-12 TG Memo.docx 19 Modified Sunset Crossroads
Land Use Quantity Units1 In Out Total In Out Total Daily Phase 4
Building 8: High-Cube Parcel Hub 250.000 TSF
Passenger Cars: 83 83 166 108 51 159 1,054
Truck Trips:
2-axle: 1 1 2 0 0 0 18
3-axle: 1 1 2 0 0 0 22
4+-axle: 3 3 6 1 0 1 66
Total Trucks: 5 5 10 1 0 1 106
Building 8 Total Trips 2 88 88 176 109 51 160 1,160
Building 9: Warehousing 274.000 TSF
Passenger Cars: 31 9 40 12 32 44 348
Truck Trips:
2-axle: 1 0 1 0 1 1 22
3-axle: 1 0 1 0 1 1 28
4+-axle: 3 1 4 1 4 5 82
Total Trucks: 5 1 6 1 6 7 132
Building 9 Passenger Cars 31 9 40 12 32 44 348
Building 9 Trucks 5 1 6 1 6 7 132
Building 9 Total Trips 2 36 10 46 13 38 51 480
Total Industrial Trips
Phase 4 Only Passenger Cars 114 92 206 120 83 203 1,402 Phase 4 Only Trucks 10 6 16 2 6 8 238
Phase 4 Only Total Trips 2 124 98 222 122 89 211 1,640
Project Buildout (Phase 1+2+3+4) Total Passenger Cars 757 329 1,086 642 903 1,545 16,004 Project Buildout (Phase 1+2+3+4) Total Trucks 75 26 101 28 69 97 1,848 Project Buildout (Phase 1+2+3+4) Total Trips 2 832 355 1,187 670 972 1,642 17,852 1 TSF = thousand square feet; RM = Rooms
2 Total Trips = Passenger Cars + Truck Trips.
4 Source: ITE Trip Generation Handbook , 3rd Edition, 2017. 3 Internal capture calculated from NCHRP 684 Internal Trip Capture Estimation Tool. Internal capture includes the office portion of the industrial buildings that are in close proximity to the retail/restaurant uses (Buildings 5, 6, 7, and 8).

AM Peak Hour PM Peak Hour
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ͭͯͱͯͰ-ͭͱ CEQA Memo Redline ʹ Sunset Crossroads
ATTACHMENT B:

AIR QUALITY &GHG
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TECHNICAL MEMORANDUM
13534-16 AQ & GHG Assesment13534-1416 AQ & GHG Assesment 1 Modified Sunset Crossroads
DATE: October 10, 2025
TO: J.J. Jenkins, NP Banning Industrial, LLC
FROM: Haseeb Qureshi, Urban Crossroads, Inc.

JOB NO: 13534-1416AQ & GHG Assesment
SUBJECT: MODIFIED SUNSET CROSSROADS(SP NO. 20-20000002)AIR

QUALITY AND GREENHOUSE GAS ASSESSMENT
Urban Crossroads, Inc. has prepared the following Air Quality and Greenhouse Gas (GHG) Assessment for the Modified Sunset Crossroads Project (Modified Project), which is located south of the I-10 Freeway and west of Sunset Avenue in the City of Banning. This technical memorandum presents the updated AQ and GHG emissions based on the proposed change in land uses and provides a comparison of the analysis findings to those previously presented in the Sunset Crossroads Specific Plan Supplemental Air Quality Assessment (dated July 11, 2024) and the Sunset Crossroads Supplemental Greenhouse Gas (GHG) Emissions Assessment (dated June 28, 2024,)both of which are included in the Sunset Crossroads Final Environmental Impact Report (FEIR) (SCH No. 2021020011) dated July 2024, Appendix C-5 and Appendix C-6; hereafter referred to as the “2024 AQ Assessment” and “2024 GHG Assessment”. Specifically, the purpose of this assessment is to determine whether the Modified Project’s proposed land use changes would result in any new AQ or GHG impacts compared to what was previously disclosed in the FEIR.

PROJECT BACKGROUND
The Project, as evaluated in the FEIR included the following mix of uses:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 197,500 square feet of General Light Industrial use
• 490,500 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 330,000 square feet of High-Cube Cold Storage Warehouse use • 12,000 square feet of Retail use
• 40,700 square feet of Go-Kart Racing use
• 13,000 square feet of Rock Climbing use
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13534-16 AQ & GHG Assesment13534-1416 AQ & GHG Assesment 2 Modified Sunset Crossroads
• 12,500 square feet of Trampoline Park use
• 116,700 square feet of Health/Fitness Club
• 9,500 square feet of Quality Restaurant use
• 40,000 square feet of High Turnover Sit-Down Restaurant use • 7,000 square feet of Fast-Food Restaurant with Drive-Through Window use • 9,500 square feet of Medical-Dental Office use
• 125-room Hotel
• 7,500 square foot Truck Stop
The following assessment compares the Modified Project with the changes proposed as part of the Development Agreement to ensure the environmental effects are less than those already disclosed in either of the prior studies. Specifically, the changes to the latest Modified Project are outlined as follows:
• Removal of 330,000 square feet of High-Cube Cold Storage Use (Buildings 5 & 6) • Removal of 105,500 square feet of Warehousing use (Buildings 5 & 6) • Removal of 42,500 square feet of General Light Industrial use (Buildings 5 & 6) • Removal of 40,700 square feet of Go-Kart Racing use
• Removal of 13,000 square feet of Rock Climbing use
• Removal of 116,700 square feet of Health/Fitness Club use • Removal of 9,500 square feet of Medical-Dental Office use • Removal of 7,500 square feet of Truck Stop use
• Removal of 9,500 square foot Quality Restaurant use
• Reduce Retail use from 12,000 square feet to 5,005 square feet • Reduce High Turnover Sit-down Restaurant use from 40,000 square feet to 10,595 square feet • Reduce Fast-food Restaurant With Drive-Through Window use from 7,000 square feet to 645 square feet
• Addition of 200,000 square feet of Discount Club use
• Addition of 7,508 square feet of Fast-Food Without Drive-Through Window use This results in a total reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses and replacing these uses with 200,000 square feet of Discount Club use and 7,508 square feet of Fast-Food Without Drive-Through Window use. These modifications to the Project result in a net reduction of 1,162 passenger car and 1,482 truck trips per day compared to the Project as evaluated in the FEIR, which results in a reduction of emissions.

Additionally, the removal of the High-Cube Cold Storage Use further reduces emissions since that land use type specifically includes Transport Refrigeration Units (TRUs) on the trucks, which would no longer be required. All other Industrial and Retail uses remain the same. 2024 FEIR AIR QUALITY AND GHG ASSESSMENT
Table 1 below summarizes the mitigated operational emissions for the project identified in the 2024 FEIR (See Appendix C-5,Table 6, Completed Development Project). 766
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TABLE 1:REGIONAL MITIGATED OPERATIONAL EMISSIONS – 2024 FEIR Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Completed Development 188 420 537 3 220 63
SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? YES YES NO NO YES YES
Table 2 below presents the mitigated operational GHG emissions identified in the 2024 FEIR (Appendix C-6,Table F, Total Operational Emissions).

TABLE 2:MITIGATED OPERATIONAL GHGEMISSIONS – 2024 FEIR
Emission Source
Emissions (MT/yr)
Total CO2e
Total Operational Emissions 44,174.26

MODIFIED PROJECT
As previously stated, the Modified Project includes a total reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses and replacing these uses with 200,000 square feet of Discount Club use and 7,508 square feet of FastFood Without Drive-Through Window use with the following summary of uses:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 155,000 square feet of General Light Industrial use
• 385,000 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 200,000 square feet of Discount Club use
• 5,005 square feet of Retail use
• 10,595 square feet of High Turnover Sit-Down Restaurant use • 7,508 square feet of Fast-Food Restaurant without Drive-Through Window use • 645 square feet of Fast-Food Restaurant with Drive-Through Window use • 125-room Hotel

CONSTRUCTION
The modified project removes industrial uses from planning area 2 and it is uncertain at this time what uses will be proposed and therefore it would be speculative to analyze potential future impacts associated with construction of planning area 2. However, site preparation and grading would occur across the entire site under both the Original Project and the Modified Project, but no other construction activity would occur in planning area 2. As such, the Modified Project’s construction impacts would not exceed what was disclosed in the EIR relative to site preparation and grading but would be less than what was disclosed for the vertical construction activities since no construction is proposed in planning area 2. Additionally, the anticipated reduction in overall daily emissions would correlate to a decrease in localized pollutant concentrations. Consequently, localized concentrations 767
13534-16 AQ & GHG Assesment13534-1416 AQ & GHG Assesment 4 Modified Sunset Crossroads
of pollutants such as NOX, CO, PM10, and PM2.5 are considered to be less than significant similar to and consistent with the EIR.

OPERATIONAL ACTIVITIES
Table 3 below presents the operational emissions generated by the Modified Project. Appendix 1 includes the CalEEMod emissions output for the Modified Project. Consistent with the FEIR, the truck trip lengths are based on the average truck trip length from the SCAQMD WAIRE Implementation Guide1, which identifies a trip length of 15.3 miles for 2-axle trucks, 14.2 miles for 3- axle trucks, and 39.9 miles for 4+ axle trucks. This results in a weighted average for the General Light Industrial Land use of 29.98 miles and 30.44 miles for the Warehousing, High-Cube Transload Warehouse, and High-Cube Parcel Hub Warehouse land use categories. As previously noted, the Modified Project result in a net reduction of 1,162 passenger car and 1,482 truck trips per day compared to the Project as evaluated in the FEIR, which consequently results in a reduction of emissions. Additionally, the removal of the High-Cube Cold Storage Use further reduces emissions since that land use type specifically includes Transport Refrigeration Units (TRUs) on the trucks, which would no longer be required.

TABLE 3: SUMMARY OF MITIGATED OPERATIONAL EMISSIONS – MODIFIED PROJECT Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Modified Project Operational Emissions 151 263 466 2 190 53 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? YES YES NO NO YES NO
Table 4 below presents the operational GHG emissions generated by the Modified Project. Appendix 1 includes the CalEEMod emissions output for the Modified Project.

TABLE 4: SUMMARY OF MITIGATED OPERATIONAL EMISSIONS - MODIFIED PROJECT Emission Source Total CO2e Emissions (MT/yr)
Modified Project Operational Emissions 38,875.50
COMPARISON OF 2024 FEIR AND MODIFIED PROJECT AQ EMISSIONS Table 5 below presents a comparison of the 2024 FEIR and Modified ProjectAQ emissions. As shown below, the Modified Project would result in a net decrease in air quality emissions when compared to the 2024 FEIR.
1 South Coast Air Quality Management District (SCAQMD). 2021. Rule 2305 Warehouse Indirect Source Rule. June. Website:
www.aqmd.gov/docs/default-source/planning/fbmsm-docs/waire-implementation-guidelines.pdf (accessed April 2024). An attachment of the WAIRE Implementation Guidelines is appended to this assessment as Attachment “A”. 768
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TABLE 5:REGIONAL MITIGATED OPERATIONAL AQEMISSIONS COMPARISON TO FEIR Scenario
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
2024 FEIR Operational Emissions 188 420 537 3 220 63
SCAQMD Threshold 55 55 550 150 150 55
Exceeds Threshold? YES YES YES NO YES YES
Modified Project Operational Emissions 151 263 466 2 190 53 New Significant Impact? NO NO NO NO NO NO
COMPARISON OF 2024 FEIR AND MODIFIED PROJECT GHG EMISSIONS Table 6 below presents a comparison of the 2024 FEIR and Modified Project GHG emissions. As shown below, the Modified Project would result in a net decrease in greenhouse gas emissions when compared to the 2024 FEIR.
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TABLE 6: ANNUAL MITIGATED OPERATIONAL GHGEMISSIONS COMPARISON TO FEIR Emission Source
Emissions (MT/yr)
Total CO2e
2024 FEIR Operational Emissions 44,174.26
Threshold 3,000
Exceed Threshold? YES
Modified Project Operational Emissions 38,875.50
New Significant Impact? NO

CONCLUSION
As summarized in Tables 5 and 6, the Modified Project’s emissions would generate less air quality and GHG emissions when compared to the land uses as evaluated in the 2024 FEIR. As such, no new air quality or greenhouse gas impacts occur beyond what was disclosed previously in the FEIR.

If you have any questions, please contact me directly at [email protected]. 770
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APPENDIX 1:

MODIFIED PROJECTCALEEMOD OUTPUT
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AQ EMISSIONS
Source
Emissions (lbs/day)
VOC NOX CO SO2 PM10 PM2.5
Summer
Area Source1 113.61 2.78E-03 0.32 2.00E-05 8.30E-04 8.30E-04 Energy Source2 0.74 6.77 5.68 0.04 0.51 0.51
Light Duty Vehicle Source3 31.22 33.89 390.03 1.10 137.80 37.04 Heavy Duty Vehicle Source4 5.14 209.19 70.13 1.17 51.44 15.88 Warehouse Equipment5 0.00 0.00 0.00 0.00 0.00 0.00
Maximum Daily Emissions 150.72 249.84 466.16 2.31 189.76 53.43 Winter
Area Source6 113.61 2.78E-03 0.32 2.00E-05 8.30E-04 8.30E-04 Energy Source7 0.74 6.77 5.68 0.04 0.51 0.51
Light Duty Vehicle Source8 26.64 35.89 337.69 1.00 137.80 37.04 Heavy Duty Vehicle Source9 4.86 219.87 68.78 1.17 51.44 15.88 Warehouse Equipment 0.00 0.00 0.00 0.00 0.00 0.00
Maximum Daily Emissions 145.85 262.53 412.47 2.21 189.76 53.44 Maximum Daily Emissions10
Area Source 113.61 2.78E-03 0.32 2.00E-05 8.30E-04 8.30E-04 Energy Source 0.74 6.77 5.68 0.04 0.51 0.51
Light Duty Vehicle Source 31.22 35.89 390.03 1.10 137.80 37.04 Heavy Duty Vehicle Source 5.14 219.87 70.13 1.17 51.44 15.88 Warehoues Equipment 0.00 0.00 0.00 0.00 0.00 0.00
Total Maximum Daily Emissions 151 263 466 2 190 53
1Area source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases CombinedLight Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Summer" CalEEMod Output file 2 Energy source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases CombinedLight Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Summer" CalEEMod Output file 3 LD and HD vehicles were analyzed separately. Light duty vehicle source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases Combined- Light Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Summer" CalEEMod Output file
4 LD and HD vehicles were analyzed separately. HD vehicle trip lengths were adjusted using a weighted average based on the distribution of 2-, 3-, and 4+ axle trucks, consistent with the traffic assessment for each industrial land use modeled in CalEEMod. Heavy duty vehicle source emissions can be found on page 7 of 18 of the "Sunset Crossroads Operations - All 4 Phases Combined- HD Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Summer" CalEEMod Output file
5 Since the warehouse equipment is electric-powered, no direct emissions are expected 6 Area source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases CombinedLight Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Winter" CalEEMod Output file 7 Energy source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases CombinedLight Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Winter" CalEEMod Output file 772
13534-16 AQ & GHG Assesment13534-1416 AQ & GHG Assesment 9 Modified Sunset Crossroads
8 Light duty vehicle source emissions can be found on page 9 of 20 of the "Sunset Crossroads Operations - All 4 Phases Combined- Light Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Winter" CalEEMod Output file
9 Heavy duty vehicle source emissions can be found on page 7 of 18 of the "Sunset Crossroads Operations - All 4 Phases Combined- Light Vehicles - incl. Project Design Features - San Bernardino - South Coast County, Winter" CalEEMod Output file
10 Maximum daily emissions between Summer and Winter scenario identified

GHG EMISSIONS REDUCTIONS CALCULATION
Source Unmitigated Emissions with
DEIR Mitigation
Additional
Quantified
Reductions1
Emissions with DEIR
Mitigation and
Additional Quantified
Reductions
2024 GHG Assessment 62,357.47 44,580.17 -405.91 44,174.26 Modified Project 48,594.36 - -9,718.87 38,875.49
1 As shown in the 2024 GHG Assessment, implementation of the DEIR mitigation measures and additional quantified reductions would result in Project emissions of 44,174.26 MT/yr, a 29.16% reduction from the unmitigated scenario. A similar reduction is expected to occur for the Modified Project, as a conservative measure, a 20% reduction to the unmitigated values for the Modified Project has been applied. 773
Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features San Bernardino-South Coast County, Summer
Project Characteristics - Utility Emission Factors for Banning Electric Land Use - Total Project area = 505.5 acres, assume that all area not covered by buildings or included as open space is paved. BESS represented by General Light Industry.

Construction Phase - Operations-only analysis.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 General Light Industry 10.00 1000sqft 0.23 10,000.00 0
Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0 Fast Food Restaurant with Drive Thru 0.65 1000sqft 0.01 645.00 0 High Turnover (Sit Down Restaurant) 10.60 1000sqft 0.24 10,595.00 0 Hotel 125.00 Room 4.17 90,000.00 0
Regional Shopping Center 5.01 1000sqft 0.11 5,005.00 0
Discount Club 200.00 1000sqft 4.59 200,000.00 0
Fast Food Restaurant w/o Drive Thru 7.51 1000sqft 0.17 7,508.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 774
Off-road Equipment -
Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip rates from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses; pass-by and diverted accounted for. BESS represented by General Light Industry.

Vehicle Emission Factors -
Vehicle Emission Factors -
Vehicle Emission Factors -
Consumer Products -
Area Coating - Assume all coatings comply with SCAQMD Rule 1113.

Landscape Equipment -
Energy Use -
Water And Wastewater -
Solid Waste -
Construction Off-road Equipment Mitigation -
Mobile Land Use Mitigation -
Mobile Commute Mitigation -
Area Mitigation -
Energy Mitigation - PF-Enhanced bldg and window insulation, LED lighting, improved efficiency HVAC, Energy Star commercial appliances Water Mitigation - PF-low water plants, Weather based irrigation control systems combined with drip irrigation (demonstrate 20% reduced water), Graywater (purple pipe) irrigation system
Waste Mitigation - PF-enhanced recycling provisions
Operational Off-Road Equipment - Assume each of the 9 warehouses would have 4 forklifts and 4 tenders, PF specifies that all would be electric-powered.

Fleet Mix - Fleet mix from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses.

Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 50
tblAreaCoating Area_EF_Nonresidential_Interior 100 50
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tblAreaMitigation UseLowVOCPaintNonresidentialExteriorV alue
50 100
tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV alue
50 100
tblConstructionPhase NumDays 120.00 0.00
tblConstructionPhase PhaseEndDate 9/15/2023 4/2/2023
tblFleetMix HHD 0.02 0.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.80
tblFleetMix LDA 0.55 0.80
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
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tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandUse LandUseSquareFeet 181,500.00 90,000.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblTripsAndVMT VendorTripLength 6.90 0.00
tblTripsAndVMT WorkerTripLength 14.70 0.00
tblVehicleTrips DV_TP 40.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 38.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 15.00 0.00
tblVehicleTrips PB_TP 50.00 0.00
tblVehicleTrips PB_TP 12.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
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tblVehicleTrips PB_TP 43.00 0.00
tblVehicleTrips PB_TP 4.00 0.00
tblVehicleTrips PB_TP 11.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 45.00 100.00
tblVehicleTrips PR_TP 29.00 100.00
tblVehicleTrips PR_TP 51.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 37.00 100.00
tblVehicleTrips PR_TP 58.00 100.00
tblVehicleTrips PR_TP 54.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 53.75 23.76
tblVehicleTrips ST_TR 616.12 136.43
tblVehicleTrips ST_TR 696.00 116.14
tblVehicleTrips ST_TR 6.42 4.58
tblVehicleTrips ST_TR 1.99 0.00
tblVehicleTrips ST_TR 122.40 30.01
tblVehicleTrips ST_TR 8.19 4.90
tblVehicleTrips ST_TR 46.12 27.17
tblVehicleTrips ST_TR 1.74 1.73
tblVehicleTrips SU_TR 33.67 23.76
tblVehicleTrips SU_TR 472.58 136.43
tblVehicleTrips SU_TR 500.00 116.14
tblVehicleTrips SU_TR 5.09 4.58
tblVehicleTrips SU_TR 5.00 0.00
tblVehicleTrips SU_TR 142.64 30.01
tblVehicleTrips SU_TR 5.95 4.90
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2.0 Emissions Summary
tblVehicleTrips SU_TR 21.10 27.17
tblVehicleTrips SU_TR 1.74 1.73
tblVehicleTrips WD_TR 41.80 23.76
tblVehicleTrips WD_TR 470.95 136.43
tblVehicleTrips WD_TR 346.23 116.14
tblVehicleTrips WD_TR 3.93 4.58
tblVehicleTrips WD_TR 4.96 0.00
tblVehicleTrips WD_TR 112.18 30.01
tblVehicleTrips WD_TR 8.36 4.90
tblVehicleTrips WD_TR 37.75 27.17
tblVehicleTrips WD_TR 1.74 1.73
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 779

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 780

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Energy 0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 Mobile 31.2151 33.8830 389.9758 1.0965 137.1237 0.6580 137.7817 36.4269 0.6106 37.0375 Offroad 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 Total 151.2327 121.7118 809.1769 1.2859 137.1237 4.1049 141.2286 36.4269 3.8781 40.3050 Unmitigated Operational
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Energy 0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 Mobile 31.2151 33.8830 389.9758 1.0965 137.1237 0.6580 137.7817 36.4269 0.6106 37.0375 Offroad 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 Total 151.1753 121.4547 808.7307 1.2843 137.1237 4.0844 141.2081 36.4269 3.8576 40.2845 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 No Construction Analysis Site Preparation 4/3/2023 4/2/2023 5 0 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.04 0.21 0.06 0.12 0.00 0.50 0.01 0.00 0.53 0.05 0.00 0.00 0.00 0.00 0.00 0.00 Acres of Grading (Site Preparation Phase): 180
Acres of Grading (Grading Phase): 0
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor No Construction Analysis Rubber Tired Dozers 0 8.00 247 0.40 No Construction Analysis Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
No Construction
Analysis
0 0.00 0.00 0.00 0.00 0.00 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Paving: 0
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 785
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 31.2151 33.8830 389.9758 1.0965 137.1237 0.6580 137.7817 36.4269 0.6106 37.0375 Unmitigated 31.2151 33.8830 389.9758 1.0965 137.1237 0.6580 137.7817 36.4269 0.6106 37.0375

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Discount Club 4,752.00 4,752.00 4752.00 16,405,432 16,405,432 Fast Food Restaurant with Drive Thru 88.00 88.00 88.00 265,718 265,718 Fast Food Restaurant w/o Drive Thru 872.00 872.00 872.00 2,614,808 2,614,808 General Heavy Industry 709.99 709.99 709.99 3,370,800 3,370,800 General Light Industry 0.00 0.00 0.00
High Turnover (Sit Down Restaurant) 318.00 318.00 318.00 1,020,008 1,020,008 Hotel 612.00 612.00 612.00 2,162,142 2,162,142
Regional Shopping Center 136.00 136.00 136.00 467,892 467,892 Unrefrigerated Warehouse-No Rail 8,515.93 8,515.93 8515.93 39,128,777 39,128,777 Total 16,003.93 16,003.93 16,003.93 65,435,576 65,435,576 Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Discount Club 16.60 8.40 6.90 16.70 64.30 19.00 100 0 0 Fast Food Restaurant with Drive
Thru

16.60 8.40 6.90 2.20 78.80 19.00 100 0 0
Fast Food Restaurant w/o Drive
Thru

16.60 8.40 6.90 1.50 79.50 19.00 100 0 0
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Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Heavy Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 General Light Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 100 0 0
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 100 0 0
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 100 0 0 Unrefrigerated Warehouse-No
Rail

16.60 8.40 6.90 59.00 0.00 41.00 100 0 0

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Discount Club 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant with Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant w/o Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 General Heavy Industry 0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 General Light Industry 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 High Turnover (Sit Down
Restaurant)

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Hotel 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Regional Shopping Center 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Unrefrigerated Warehouse-No
Rail

0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail

5.1 Mitigation Measures Energy
Exceed Title 24
Install High Efficiency Lighting
Install Energy Efficient Appliances
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 787
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 NaturalGas
Unmitigated

0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 788

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Discount Club 1205.48 0.0130 0.1182 0.0993 7.1000e0048.9800e0038.9800e0038.9800e0038.9800e003 Fast Food
Restaurant w/o
Drive Thru
5608.58 0.0605 0.5499 0.4619 3.3000e0030.0418 0.0418 0.0418 0.0418 Fast Food
Restaurant with
Drive Thru
481.824 5.2000e0030.0472 0.0397 2.8000e0043.5900e0033.5900e0033.5900e0033.5900e003 General Heavy
Industry
13729.2 0.1481 1.3460 1.1306 8.0800e0030.1023 0.1023 0.1023 0.1023 General Light
Industry
885.753 9.5500e0030.0868 0.0729 5.2000e0046.6000e0036.6000e0036.6000e0036.6000e003 High Turnover (Sit
Down Restaurant)
7914.61 0.0854 0.7759 0.6518 4.6600e0030.0590 0.0590 0.0590 0.0590 Hotel 14661.4 0.1581 1.4374 1.2074 8.6200e0030.1092 0.1092 0.1092 0.1092 Regional
Shopping Center

30.1671 3.3000e0042.9600e0032.4800e0032.0000e0052.2000e0042.2000e0042.2000e0042.2000e004 Unrefrigerated
Warehouse-No
Rail
27049.6 0.2917 2.6519 2.2276 0.0159 0.2016 0.2016 0.2016 0.2016 Total 0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 789
Use Electric Lawnmower
Use Electric Leafblower

6.1 Mitigation Measures Area

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Discount Club 1.15342 0.0124 0.1131 0.0950 6.8000e0048.5900e0038.5900e0038.5900e0038.5900e003 Fast Food
Restaurant w/o
Drive Thru

5.5295 0.0596 0.5421 0.4554 3.2500e0030.0412 0.0412 0.0412 0.0412 Fast Food
Restaurant with
Drive Thru

0.47503 5.1200e0030.0466 0.0391 2.8000e0043.5400e0033.5400e0033.5400e0033.5400e003 General Heavy
Industry

13.4064 0.1446 1.3144 1.1041 7.8900e0030.0999 0.0999 0.0999 0.0999 General Light
Industry

0.864932 9.3300e0030.0848 0.0712 5.1000e0046.4400e0036.4400e0036.4400e0036.4400e003 High Turnover (Sit
Down Restaurant)

7.80301 0.0842 0.7650 0.6426 4.5900e0030.0581 0.0581 0.0581 0.0581 Hotel 13.9882 0.1509 1.3714 1.1520 8.2300e0030.1042 0.1042 0.1042 0.1042 Regional
Shopping Center

0.0288645 3.1000e0042.8300e0032.3800e0032.0000e0052.2000e0042.2000e0042.2000e0042.2000e004 Unrefrigerated
Warehouse-No
Rail

25.7173 0.2773 2.5213 2.1179 0.0151 0.1916 0.1916 0.1916 0.1916 Total 0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 Mitigated
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Use Electric Chainsaw
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Unmitigated 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

6.8455 0.0000 0.0000 0.0000 0.0000
Consumer
Products
106.7369 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0509 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Total 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 791
Apply Water Conservation Strategy

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

6.8455 0.0000 0.0000 0.0000 0.0000
Consumer
Products
106.7369 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0216 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Total 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Mitigated

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

8.0 Waste Detail

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type Forklifts 36 8.00 260 89 0.20 CNG
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11.0 Vegetation
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Equipment Type lb/day lb/day
Forklifts 0.7215 34.4755 344.1364 0.0550 0.6691 0.6691 0.6691 0.6691 Other General
Industrial
Equipment

4.8910 46.3320 68.6185 0.0922 2.2427 2.2427 2.0632 2.0632 Total 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 UnMitigated/Mitigated
Other General Industrial Equipment 36 8.00 260 88 0.34 CNG

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 20 Date: 8/20/2025 11:49 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 793
Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features San Bernardino-South Coast County, Winter
Project Characteristics - Utility Emission Factors for Banning Electric Land Use - Total Project area = 505.5 acres, assume that all area not covered by buildings or included as open space is paved. BESS represented by General Light Industry.

Construction Phase - Operations-only analysis.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 General Light Industry 10.00 1000sqft 0.23 10,000.00 0
Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0 Fast Food Restaurant with Drive Thru 0.65 1000sqft 0.01 645.00 0 High Turnover (Sit Down Restaurant) 10.60 1000sqft 0.24 10,595.00 0 Hotel 125.00 Room 4.17 90,000.00 0
Regional Shopping Center 5.01 1000sqft 0.11 5,005.00 0
Discount Club 200.00 1000sqft 4.59 200,000.00 0
Fast Food Restaurant w/o Drive Thru 7.51 1000sqft 0.17 7,508.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 794
Off-road Equipment -
Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip rates from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses; pass-by and diverted accounted for. BESS represented by General Light Industry.

Vehicle Emission Factors -
Vehicle Emission Factors -
Vehicle Emission Factors -
Consumer Products -
Area Coating - Assume all coatings comply with SCAQMD Rule 1113.

Landscape Equipment -
Energy Use -
Water And Wastewater -
Solid Waste -
Construction Off-road Equipment Mitigation -
Mobile Land Use Mitigation -
Mobile Commute Mitigation -
Area Mitigation -
Energy Mitigation - PF-Enhanced bldg and window insulation, LED lighting, improved efficiency HVAC, Energy Star commercial appliances Water Mitigation - PF-low water plants, Weather based irrigation control systems combined with drip irrigation (demonstrate 20% reduced water), Graywater (purple pipe) irrigation system
Waste Mitigation - PF-enhanced recycling provisions
Operational Off-Road Equipment - Assume each of the 9 warehouses would have 4 forklifts and 4 tenders, PF specifies that all would be electric-powered.

Fleet Mix - Fleet mix from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses.

Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 50
tblAreaCoating Area_EF_Nonresidential_Interior 100 50
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 795
tblAreaMitigation UseLowVOCPaintNonresidentialExteriorV alue
50 100
tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV alue
50 100
tblConstructionPhase NumDays 120.00 0.00
tblConstructionPhase PhaseEndDate 9/15/2023 4/2/2023
tblFleetMix HHD 0.02 0.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.80
tblFleetMix LDA 0.55 0.80
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 796
tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandUse LandUseSquareFeet 181,500.00 90,000.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblTripsAndVMT VendorTripLength 6.90 0.00
tblTripsAndVMT WorkerTripLength 14.70 0.00
tblVehicleTrips DV_TP 40.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 38.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 15.00 0.00
tblVehicleTrips PB_TP 50.00 0.00
tblVehicleTrips PB_TP 12.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 797
tblVehicleTrips PB_TP 43.00 0.00
tblVehicleTrips PB_TP 4.00 0.00
tblVehicleTrips PB_TP 11.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 45.00 100.00
tblVehicleTrips PR_TP 29.00 100.00
tblVehicleTrips PR_TP 51.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 37.00 100.00
tblVehicleTrips PR_TP 58.00 100.00
tblVehicleTrips PR_TP 54.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 53.75 23.76
tblVehicleTrips ST_TR 616.12 136.43
tblVehicleTrips ST_TR 696.00 116.14
tblVehicleTrips ST_TR 6.42 4.58
tblVehicleTrips ST_TR 1.99 0.00
tblVehicleTrips ST_TR 122.40 30.01
tblVehicleTrips ST_TR 8.19 4.90
tblVehicleTrips ST_TR 46.12 27.17
tblVehicleTrips ST_TR 1.74 1.73
tblVehicleTrips SU_TR 33.67 23.76
tblVehicleTrips SU_TR 472.58 136.43
tblVehicleTrips SU_TR 500.00 116.14
tblVehicleTrips SU_TR 5.09 4.58
tblVehicleTrips SU_TR 5.00 0.00
tblVehicleTrips SU_TR 142.64 30.01
tblVehicleTrips SU_TR 5.95 4.90
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2.0 Emissions Summary
tblVehicleTrips SU_TR 21.10 27.17
tblVehicleTrips SU_TR 1.74 1.73
tblVehicleTrips WD_TR 41.80 23.76
tblVehicleTrips WD_TR 470.95 136.43
tblVehicleTrips WD_TR 346.23 116.14
tblVehicleTrips WD_TR 3.93 4.58
tblVehicleTrips WD_TR 4.96 0.00
tblVehicleTrips WD_TR 112.18 30.01
tblVehicleTrips WD_TR 8.36 4.90
tblVehicleTrips WD_TR 37.75 27.17
tblVehicleTrips WD_TR 1.74 1.73
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 799

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 800

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Energy 0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 Mobile 26.6363 35.8901 337.6473 1.0003 137.1237 0.6582 137.7819 36.4269 0.6109 37.0378 Offroad 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 Total 146.6539 123.7190 756.8484 1.1897 137.1237 4.1051 141.2288 36.4269 3.8784 40.3053 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 801

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Energy 0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 Mobile 26.6363 35.8901 337.6473 1.0003 137.1237 0.6582 137.7819 36.4269 0.6109 37.0378 Offroad 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 Total 146.5965 123.4619 756.4022 1.1881 137.1237 4.0846 141.2083 36.4269 3.8579 40.2848 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 No Construction Analysis Site Preparation 4/3/2023 4/2/2023 5 0 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.04 0.21 0.06 0.13 0.00 0.50 0.01 0.00 0.53 0.05 0.00 0.00 0.00 0.00 0.00 0.00 Acres of Grading (Site Preparation Phase): 180
Acres of Grading (Grading Phase): 0
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor No Construction Analysis Rubber Tired Dozers 0 8.00 247 0.40 No Construction Analysis Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
No Construction
Analysis
0 0.00 0.00 0.00 0.00 0.00 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Paving: 0
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
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3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 26.6363 35.8901 337.6473 1.0003 137.1237 0.6582 137.7819 36.4269 0.6109 37.0378 Unmitigated 26.6363 35.8901 337.6473 1.0003 137.1237 0.6582 137.7819 36.4269 0.6109 37.0378

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Discount Club 4,752.00 4,752.00 4752.00 16,405,432 16,405,432 Fast Food Restaurant with Drive Thru 88.00 88.00 88.00 265,718 265,718 Fast Food Restaurant w/o Drive Thru 872.00 872.00 872.00 2,614,808 2,614,808 General Heavy Industry 709.99 709.99 709.99 3,370,800 3,370,800 General Light Industry 0.00 0.00 0.00
High Turnover (Sit Down Restaurant) 318.00 318.00 318.00 1,020,008 1,020,008 Hotel 612.00 612.00 612.00 2,162,142 2,162,142
Regional Shopping Center 136.00 136.00 136.00 467,892 467,892 Unrefrigerated Warehouse-No Rail 8,515.93 8,515.93 8515.93 39,128,777 39,128,777 Total 16,003.93 16,003.93 16,003.93 65,435,576 65,435,576 Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Discount Club 16.60 8.40 6.90 16.70 64.30 19.00 100 0 0 Fast Food Restaurant with Drive
Thru

16.60 8.40 6.90 2.20 78.80 19.00 100 0 0
Fast Food Restaurant w/o Drive
Thru

16.60 8.40 6.90 1.50 79.50 19.00 100 0 0
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Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Heavy Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 General Light Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 100 0 0
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 100 0 0
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 100 0 0 Unrefrigerated Warehouse-No
Rail

16.60 8.40 6.90 59.00 0.00 41.00 100 0 0

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Discount Club 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant with Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant w/o Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 General Heavy Industry 0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 General Light Industry 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 High Turnover (Sit Down
Restaurant)

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Hotel 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Regional Shopping Center 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Unrefrigerated Warehouse-No
Rail

0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail

5.1 Mitigation Measures Energy
Exceed Title 24
Install High Efficiency Lighting
Install Energy Efficient Appliances
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 807
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 NaturalGas
Unmitigated

0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 808

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Discount Club 1205.48 0.0130 0.1182 0.0993 7.1000e0048.9800e0038.9800e0038.9800e0038.9800e003 Fast Food
Restaurant w/o
Drive Thru
5608.58 0.0605 0.5499 0.4619 3.3000e0030.0418 0.0418 0.0418 0.0418 Fast Food
Restaurant with
Drive Thru
481.824 5.2000e0030.0472 0.0397 2.8000e0043.5900e0033.5900e0033.5900e0033.5900e003 General Heavy
Industry
13729.2 0.1481 1.3460 1.1306 8.0800e0030.1023 0.1023 0.1023 0.1023 General Light
Industry
885.753 9.5500e0030.0868 0.0729 5.2000e0046.6000e0036.6000e0036.6000e0036.6000e003 High Turnover (Sit
Down Restaurant)
7914.61 0.0854 0.7759 0.6518 4.6600e0030.0590 0.0590 0.0590 0.0590 Hotel 14661.4 0.1581 1.4374 1.2074 8.6200e0030.1092 0.1092 0.1092 0.1092 Regional
Shopping Center

30.1671 3.3000e0042.9600e0032.4800e0032.0000e0052.2000e0042.2000e0042.2000e0042.2000e004 Unrefrigerated
Warehouse-No
Rail
27049.6 0.2917 2.6519 2.2276 0.0159 0.2016 0.2016 0.2016 0.2016 Total 0.7718 7.0163 5.8937 0.0421 0.5332 0.5332 0.5332 0.5332 Unmitigated
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Use Electric Lawnmower
Use Electric Leafblower

6.1 Mitigation Measures Area

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Discount Club 1.15342 0.0124 0.1131 0.0950 6.8000e0048.5900e0038.5900e0038.5900e0038.5900e003 Fast Food
Restaurant w/o
Drive Thru

5.5295 0.0596 0.5421 0.4554 3.2500e0030.0412 0.0412 0.0412 0.0412 Fast Food
Restaurant with
Drive Thru

0.47503 5.1200e0030.0466 0.0391 2.8000e0043.5400e0033.5400e0033.5400e0033.5400e003 General Heavy
Industry

13.4064 0.1446 1.3144 1.1041 7.8900e0030.0999 0.0999 0.0999 0.0999 General Light
Industry

0.864932 9.3300e0030.0848 0.0712 5.1000e0046.4400e0036.4400e0036.4400e0036.4400e003 High Turnover (Sit
Down Restaurant)

7.80301 0.0842 0.7650 0.6426 4.5900e0030.0581 0.0581 0.0581 0.0581 Hotel 13.9882 0.1509 1.3714 1.1520 8.2300e0030.1042 0.1042 0.1042 0.1042 Regional
Shopping Center

0.0288645 3.1000e0042.8300e0032.3800e0032.0000e0052.2000e0042.2000e0042.2000e0042.2000e004 Unrefrigerated
Warehouse-No
Rail

25.7173 0.2773 2.5213 2.1179 0.0151 0.1916 0.1916 0.1916 0.1916 Total 0.7438 6.7615 5.6796 0.0406 0.5139 0.5139 0.5139 0.5139 Mitigated
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Use Electric Chainsaw
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Unmitigated 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

6.8455 0.0000 0.0000 0.0000 0.0000
Consumer
Products
106.7369 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0509 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Total 113.6333 5.0100e0030.5525 4.0000e0051.9600e0031.9600e0031.9600e0031.9600e003 Unmitigated
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Apply Water Conservation Strategy

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

6.8455 0.0000 0.0000 0.0000 0.0000
Consumer
Products
106.7369 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0216 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Total 113.6040 2.7800e0030.3204 2.0000e0058.3000e0048.3000e0048.3000e0048.3000e004 Mitigated

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

8.0 Waste Detail

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type Forklifts 36 8.00 260 89 0.20 CNG
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11.0 Vegetation
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Equipment Type lb/day lb/day
Forklifts 0.7215 34.4755 344.1364 0.0550 0.6691 0.6691 0.6691 0.6691 Other General
Industrial
Equipment

4.8910 46.3320 68.6185 0.0922 2.2427 2.2427 2.0632 2.0632 Total 5.6125 80.8075 412.7549 0.1473 2.9117 2.9117 2.7323 2.7323 UnMitigated/Mitigated
Other General Industrial Equipment 36 8.00 260 88 0.34 CNG

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 20 Date: 8/20/2025 11:50 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 813
Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features San Bernardino-South Coast County, Annual
Project Characteristics - Utility Emission Factors for Banning Electric Land Use - Total Project area = 505.5 acres, assume that all area not covered by buildings or included as open space is paved. BESS represented by General Light Industry.

Construction Phase - Operations-only analysis.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 General Light Industry 10.00 1000sqft 0.23 10,000.00 0
Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0 Fast Food Restaurant with Drive Thru 0.65 1000sqft 0.01 645.00 0 High Turnover (Sit Down Restaurant) 10.60 1000sqft 0.24 10,595.00 0 Hotel 125.00 Room 4.17 90,000.00 0
Regional Shopping Center 5.01 1000sqft 0.11 5,005.00 0
Discount Club 200.00 1000sqft 4.59 200,000.00 0
Fast Food Restaurant w/o Drive Thru 7.51 1000sqft 0.17 7,508.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
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Off-road Equipment -
Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip rates from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses; pass-by and diverted accounted for. BESS represented by General Light Industry.

Vehicle Emission Factors -
Vehicle Emission Factors -
Vehicle Emission Factors -
Consumer Products -
Area Coating - Assume all coatings comply with SCAQMD Rule 1113.

Landscape Equipment -
Energy Use -
Water And Wastewater -
Solid Waste -
Construction Off-road Equipment Mitigation -
Mobile Land Use Mitigation -
Mobile Commute Mitigation -
Area Mitigation -
Energy Mitigation - PF-Enhanced bldg and window insulation, LED lighting, improved efficiency HVAC, Energy Star commercial appliances Water Mitigation - PF-low water plants, Weather based irrigation control systems combined with drip irrigation (demonstrate 20% reduced water), Graywater (purple pipe) irrigation system
Waste Mitigation - PF-enhanced recycling provisions
Operational Off-Road Equipment - Assume each of the 9 warehouses would have 4 forklifts and 4 tenders, PF specifies that all would be electric-powered.

Fleet Mix - Fleet mix from traffic study adjusted to only include light vehicles for gas station, warehouse, and industrial land uses.

Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 50
tblAreaCoating Area_EF_Nonresidential_Interior 100 50
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tblAreaMitigation UseLowVOCPaintNonresidentialExteriorV alue
50 100
tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV alue
50 100
tblConstructionPhase NumDays 120.00 0.00
tblConstructionPhase PhaseEndDate 9/15/2023 4/2/2023
tblFleetMix HHD 0.02 0.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.80
tblFleetMix LDA 0.55 0.80
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT1 0.06 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LDT2 0.17 0.10
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix LHD2 6.8240e-003 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MDV 0.13 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
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tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandUse LandUseSquareFeet 181,500.00 90,000.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperFuelType Diesel CNG
tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 36.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblTripsAndVMT VendorTripLength 6.90 0.00
tblTripsAndVMT WorkerTripLength 14.70 0.00
tblVehicleTrips DV_TP 40.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 38.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 15.00 0.00
tblVehicleTrips PB_TP 50.00 0.00
tblVehicleTrips PB_TP 12.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 817
tblVehicleTrips PB_TP 43.00 0.00
tblVehicleTrips PB_TP 4.00 0.00
tblVehicleTrips PB_TP 11.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 45.00 100.00
tblVehicleTrips PR_TP 29.00 100.00
tblVehicleTrips PR_TP 51.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 37.00 100.00
tblVehicleTrips PR_TP 58.00 100.00
tblVehicleTrips PR_TP 54.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 53.75 23.76
tblVehicleTrips ST_TR 616.12 136.43
tblVehicleTrips ST_TR 696.00 116.14
tblVehicleTrips ST_TR 6.42 4.58
tblVehicleTrips ST_TR 1.99 0.00
tblVehicleTrips ST_TR 122.40 30.01
tblVehicleTrips ST_TR 8.19 4.90
tblVehicleTrips ST_TR 46.12 27.17
tblVehicleTrips ST_TR 1.74 1.73
tblVehicleTrips SU_TR 33.67 23.76
tblVehicleTrips SU_TR 472.58 136.43
tblVehicleTrips SU_TR 500.00 116.14
tblVehicleTrips SU_TR 5.09 4.58
tblVehicleTrips SU_TR 5.00 0.00
tblVehicleTrips SU_TR 142.64 30.01
tblVehicleTrips SU_TR 5.95 4.90
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 818

2.0 Emissions Summary
tblVehicleTrips SU_TR 21.10 27.17
tblVehicleTrips SU_TR 1.74 1.73
tblVehicleTrips WD_TR 41.80 23.76
tblVehicleTrips WD_TR 470.95 136.43
tblVehicleTrips WD_TR 346.23 116.14
tblVehicleTrips WD_TR 3.93 4.58
tblVehicleTrips WD_TR 4.96 0.00
tblVehicleTrips WD_TR 112.18 30.01
tblVehicleTrips WD_TR 8.36 4.90
tblVehicleTrips WD_TR 37.75 27.17
tblVehicleTrips WD_TR 1.74 1.73
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 819

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2023 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 820
Highest

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 20.7352 6.3000e0040.0691 1.0000e0052.5000e0042.5000e0042.5000e0042.5000e0040.0000 0.1347 0.1347 3.5000e0040.0000 0.1434 Energy 0.1409 1.2805 1.0756 7.6800e0030.0973 0.0973 0.0973 0.0973 0.0000 2,335.311 4 2,335.311
4 0.1245 0.0337 2,348.465
9 Mobile 4.8040 6.6979 64.1144 0.1852 24.4825 0.1196 24.6021 6.5133 0.1110 6.6244 0.0000 17,046.93 83 17,046.93
83 0.5839 0.5866 17,236.34
86 Offroad 0.7296 10.5050 53.6581 0.0191 0.3785 0.3785 0.3552 0.3552 0.0000 1,873.675 9 1,873.675
9 0.6060 0.0000 1,888.825
5 Waste 0.0000 0.0000 0.0000 0.0000 1,213.043
6 0.0000 1,213.043
6 71.6888 0.0000 3,005.264
0 Water 0.0000 0.0000 0.0000 0.0000 380.1038 823.6437 1,203.747 5 39.1258 0.9290 2,458.721
3 Total 26.4097 18.4840 118.9171 0.2120 24.4825 0.5957 25.0782 6.5133 0.5638 7.0771 1,593.147 4 22,079.70
39 23,672.85
13 112.1294 1.5493 26,937.76
88 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 821

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 20.7315 3.5000e0040.0401 0.0000 1.0000e0041.0000e0041.0000e0041.0000e0040.0000 0.0726 0.0726 1.5000e0040.0000 0.0763 Energy 0.1357 1.2340 1.0365 7.4000e0030.0938 0.0938 0.0938 0.0938 0.0000 1,954.052 8 1,954.052
8 0.0892 0.0299 1,965.195
6 Mobile 4.8040 6.6979 64.1144 0.1852 24.4825 0.1196 24.6021 6.5133 0.1110 6.6244 0.0000 17,046.93 83 17,046.93
83 0.5839 0.5866 17,236.34
86 Offroad 0.7296 10.5050 53.6581 0.0191 0.3785 0.3785 0.3552 0.3552 0.0000 1,873.675 9 1,873.675
9 0.6060 0.0000 1,888.825
5 Waste 0.0000 0.0000 0.0000 0.0000 606.5218 0.0000 606.5218 35.8444 0.0000 1,502.632 0 Water 0.0000 0.0000 0.0000 0.0000 95.0260 205.9109 300.9369 9.7815 0.2322 614.6803 Total 26.4009 18.4372 118.8490 0.2117 24.4825 0.5920 25.0745 6.5133 0.5601 7.0734 701.5477 21,080.65 05 21,782.19
82 46.9051 0.8488 23,207.75
84 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 No Construction Analysis Site Preparation 4/3/2023 4/2/2023 5 0 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.03 0.25 0.06 0.14 0.00 0.62 0.01 0.00 0.65 0.05 55.96 4.52 7.99 58.17 45.21 13.85 CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 822

3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor No Construction Analysis Rubber Tired Dozers 0 8.00 247 0.40 No Construction Analysis Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
No Construction
Analysis
0 0.00 0.00 0.00 0.00 0.00 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 180
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 823

3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 824

3.2 No Construction Analysis - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 825

4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 4.8040 6.6979 64.1144 0.1852 24.4825 0.1196 24.6021 6.5133 0.1110 6.6244 0.0000 17,046.93 83 17,046.93
83 0.5839 0.5866 17,236.34
86 Unmitigated 4.8040 6.6979 64.1144 0.1852 24.4825 0.1196 24.6021 6.5133 0.1110 6.6244 0.0000 17,046.93 83 17,046.93
83 0.5839 0.5866 17,236.34
86 4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Discount Club 4,752.00 4,752.00 4752.00 16,405,432 16,405,432 Fast Food Restaurant with Drive Thru 88.00 88.00 88.00 265,718 265,718 Fast Food Restaurant w/o Drive Thru 872.00 872.00 872.00 2,614,808 2,614,808 General Heavy Industry 709.99 709.99 709.99 3,370,800 3,370,800 General Light Industry 0.00 0.00 0.00
High Turnover (Sit Down Restaurant) 318.00 318.00 318.00 1,020,008 1,020,008 Hotel 612.00 612.00 612.00 2,162,142 2,162,142
Regional Shopping Center 136.00 136.00 136.00 467,892 467,892 Unrefrigerated Warehouse-No Rail 8,515.93 8,515.93 8515.93 39,128,777 39,128,777 Total 16,003.93 16,003.93 16,003.93 65,435,576 65,435,576 CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 826
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Discount Club 16.60 8.40 6.90 16.70 64.30 19.00 100 0 0 Fast Food Restaurant with Drive
Thru

16.60 8.40 6.90 2.20 78.80 19.00 100 0 0
Fast Food Restaurant w/o Drive
Thru

16.60 8.40 6.90 1.50 79.50 19.00 100 0 0
General Heavy Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 General Light Industry 16.60 8.40 6.90 59.00 28.00 13.00 100 0 0 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 100 0 0
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 100 0 0
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 100 0 0 Unrefrigerated Warehouse-No
Rail

16.60 8.40 6.90 59.00 0.00 41.00 100 0 0

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Discount Club 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant with Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Fast Food Restaurant w/o Drive
Thru

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 General Heavy Industry 0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 General Light Industry 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 High Turnover (Sit Down
Restaurant)

0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Hotel 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Regional Shopping Center 0.547196 0.056762 0.174118 0.130529 0.024505 0.006824 0.012367 0.017399 0.000546 0.000242 0.024357 0.000961 0.004193 Unrefrigerated Warehouse-No
Rail

0.800000 0.100000 0.100000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail

5.1 Mitigation Measures Energy
Exceed Title 24
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 827
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 610.7326 610.7326 0.0634 5.2800e003613.8927 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 941.3521 941.3521 0.0977 8.1500e003946.2230 NaturalGas
Mitigated

0.1357 1.2340 1.0365 7.4000e0030.0938 0.0938 0.0938 0.0938 0.0000 1,343.320 2 1,343.320
2 0.0258 0.0246 1,351.302
9 NaturalGas
Unmitigated

0.1409 1.2805 1.0756 7.6800e0030.0973 0.0973 0.0973 0.0973 0.0000 1,393.959 3 1,393.959
3 0.0267 0.0256 1,402.242
9 Install High Efficiency Lighting
Install Energy Efficient Appliances
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 828

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Discount Club 440000 2.3700e0030.0216 0.0181 1.3000e0041.6400e0031.6400e0031.6400e0031.6400e0030.0000 23.4801 23.4801 4.5000e0044.3000e00423.6196 Fast Food
Restaurant w/o
Drive Thru

2.04713e
+006

0.0110 0.1004 0.0843 6.0000e0047.6300e0037.6300e0037.6300e0037.6300e0030.0000 109.2427 109.2427 2.0900e0032.0000e003109.8919 Fast Food
Restaurant with
Drive Thru
175866 9.5000e0048.6200e0037.2400e0035.0000e0056.6000e0046.6000e0046.6000e0046.6000e0040.0000 9.3849 9.3849 1.8000e0041.7000e0049.4406 General Heavy
Industry

5.01115e
+006

0.0270 0.2456 0.2063 1.4700e0030.0187 0.0187 0.0187 0.0187 0.0000 267.4141 267.4141 5.1300e0034.9000e003269.0032 General Light
Industry
323300 1.7400e0030.0159 0.0133 1.0000e0041.2000e0031.2000e0031.2000e0031.2000e0030.0000 17.2525 17.2525 3.3000e0043.2000e00417.3550 High Turnover (Sit
Down Restaurant)

2.88883e
+006

0.0156 0.1416 0.1190 8.5000e0040.0108 0.0108 0.0108 0.0108 0.0000 154.1591 154.1591 2.9500e0032.8300e003155.0752 Hotel 5.3514e
+006

0.0289 0.2623 0.2204 1.5700e0030.0199 0.0199 0.0199 0.0199 0.0000 285.5711 285.5711 5.4700e0035.2400e003287.2681 Regional
Shopping Center
11011 6.0000e0055.4000e0044.5000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.5876 0.5876 1.0000e0051.0000e0050.5911 Unrefrigerated
Warehouse-No
Rail

9.87312e
+006

0.0532 0.4840 0.4065 2.9000e0030.0368 0.0368 0.0368 0.0368 0.0000 526.8673 526.8673 0.0101 9.6600e003529.9982 Total 0.1409 1.2805 1.0756 7.6700e0030.0973 0.0973 0.0973 0.0973 0.0000 1,393.959 3 1,393.959
3 0.0267 0.0256 1,402.242
9 Unmitigated
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Discount Club 421000 2.2700e0030.0206 0.0173 1.2000e0041.5700e0031.5700e0031.5700e0031.5700e0030.0000 22.4662 22.4662 4.3000e0044.1000e00422.5997 Fast Food
Restaurant w/o
Drive Thru

2.01827e
+006

0.0109 0.0989 0.0831 5.9000e0047.5200e0037.5200e0037.5200e0037.5200e0030.0000 107.7024 107.7024 2.0600e0031.9700e003108.3424 Fast Food
Restaurant with
Drive Thru
173386 9.3000e0048.5000e0037.1400e0035.0000e0056.5000e0046.5000e0046.5000e0046.5000e0040.0000 9.2525 9.2525 1.8000e0041.7000e0049.3075 General Heavy
Industry

4.89335e
+006

0.0264 0.2399 0.2015 1.4400e0030.0182 0.0182 0.0182 0.0182 0.0000 261.1278 261.1278 5.0000e0034.7900e003262.6795 General Light
Industry
315700 1.7000e0030.0155 0.0130 9.0000e0051.1800e0031.1800e0031.1800e0031.1800e0030.0000 16.8470 16.8470 3.2000e0043.1000e00416.9471 High Turnover (Sit
Down Restaurant)

2.8481e
+006

0.0154 0.1396 0.1173 8.4000e0040.0106 0.0106 0.0106 0.0106 0.0000 151.9855 151.9855 2.9100e0032.7900e003152.8887 Hotel 5.1057e
+006

0.0275 0.2503 0.2102 1.5000e0030.0190 0.0190 0.0190 0.0190 0.0000 272.4596 272.4596 5.2200e0035.0000e003274.0787 Regional
Shopping Center
10535.5 6.0000e0055.2000e0044.3000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.5622 0.5622 1.0000e0051.0000e0050.5656 Unrefrigerated
Warehouse-No
Rail

9.38683e
+006

0.0506 0.4601 0.3865 2.7600e0030.0350 0.0350 0.0350 0.0350 0.0000 500.9171 500.9171 9.6000e0039.1800e003503.8938 Total 0.1357 1.2340 1.0365 7.3900e0030.0938 0.0938 0.0938 0.0938 0.0000 1,343.320 2 1,343.320
2 0.0257 0.0246 1,351.302
9 Mitigated
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5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Discount Club 2.428e
+006
127.2798 0.0132 1.1000e003127.9384
Fast Food
Restaurant w/o
Drive Thru
346569 18.1677 1.8900e0031.6000e00418.2618
Fast Food
Restaurant with
Drive Thru
29773.2 1.5608 1.6000e0041.0000e0051.5688
General Heavy
Industry

1.5376e
+006

80.6036 8.3700e0037.0000e00481.0206
General Light
Industry
99200 5.2002 5.4000e0044.0000e0055.2271
High Turnover (Sit
Down Restaurant)
489065 25.6376 2.6600e0032.2000e00425.7703
Hotel 1.5705e
+006

82.3282 8.5500e0037.1000e00482.7542
Regional
Shopping Center
60760.7 3.1852 3.3000e0043.0000e0053.2017
Unrefrigerated
Warehouse-No
Rail

1.13958e
+007
597.3890 0.0620 5.1700e003600.4801
Total 941.3521 0.0978 8.1400e003946.2230
Unmitigated
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Use Electric Lawnmower
Use Electric Leafblower

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Discount Club 1.5456e
+006

81.0229 8.4100e0037.0000e00481.4422
Fast Food
Restaurant w/o
Drive Thru
290680 15.2379 1.5800e0031.3000e00415.3168
Fast Food
Restaurant with
Drive Thru
24971.8 1.3091 1.4000e0041.0000e0051.3158
General Heavy
Industry

1.15661e
+006

60.6314 6.3000e0035.2000e00460.9452
General Light
Industry
76240 3.9966 4.1000e0043.0000e0054.0173
High Turnover (Sit
Down Restaurant)
410196 21.5032 2.2300e0031.9000e00421.6144
Hotel 1.16231e
+006

60.9300 6.3300e0035.3000e00461.2452
Regional
Shopping Center
38213.2 2.0032 2.1000e0042.0000e0052.0136
Unrefrigerated
Warehouse-No
Rail

6.94557e
+006
364.0983 0.0378 3.1500e003365.9823
Total 610.7326 0.0634 5.2800e003613.8927
Mitigated
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Use Electric Chainsaw
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 20.7315 3.5000e0040.0401 0.0000 1.0000e0041.0000e0041.0000e0041.0000e0040.0000 0.0726 0.0726 1.5000e0040.0000 0.0763 Unmitigated 20.7352 6.3000e0040.0691 1.0000e0052.5000e0042.5000e0042.5000e0042.5000e0040.0000 0.1347 0.1347 3.5000e0040.0000 0.1434

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

1.2493 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

19.4795 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 6.3600e0036.3000e0040.0691 1.0000e0052.5000e0042.5000e0042.5000e0042.5000e0040.0000 0.1347 0.1347 3.5000e0040.0000 0.1434 Total 20.7352 6.3000e0040.0691 1.0000e0052.5000e0042.5000e0042.5000e0042.5000e0040.0000 0.1347 0.1347 3.5000e0040.0000 0.1434 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 833
Apply Water Conservation Strategy

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

1.2493 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

19.4795 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 2.7000e0033.5000e0040.0401 0.0000 1.0000e0041.0000e0041.0000e0041.0000e0040.0000 0.0726 0.0726 1.5000e0040.0000 0.0763 Total 20.7315 3.5000e0040.0401 0.0000 1.0000e0041.0000e0041.0000e0041.0000e0040.0000 0.0726 0.0726 1.5000e0040.0000 0.0763 Mitigated
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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 300.9369 9.7815 0.2322 614.6803
Unmitigated 1,203.747
5 39.1258 0.9290 2,458.721
3 CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 835

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Discount Club 14.8145 /

9.07986

20.1002 0.4843 0.0115 35.6449
Fast Food
Restaurant w/o
Drive Thru

2.27954 /

0.145502

2.3639 0.0745 1.7700e0034.7520
Fast Food
Restaurant with
Drive Thru

0.197297 /

0.0125934

0.2046 6.4400e0031.5000e0040.4113
General Heavy
Industry

35.8438 /
0 35.8379 1.1705 0.0278 73.3820
General Light
Industry

2.3125 / 0 2.3121 0.0755 1.7900e0034.7343
High Turnover (Sit
Down Restaurant)

3.21746 /

0.20537

3.3365 0.1051 2.5000e0036.7073
Hotel 3.17085 /

0.352316

3.3755 0.1036 2.4600e0036.6979
Regional
Shopping Center

0.370363 /

0.226996

0.5025 0.0121 2.9000e0040.8911
Unrefrigerated
Warehouse-No
Rail
1135.9 / 0 1,135.714
2 37.0938 0.8807 2,325.500
5 Total 1,203.747
5 39.1258 0.9290 2,458.721
3 Unmitigated
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7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Discount Club 3.70363 /

2.26996

5.0251 0.1211 2.8800e0038.9112
Fast Food
Restaurant w/o
Drive Thru

0.569885 /

0.0363756

0.5910 0.0186 4.4000e0041.1880
Fast Food
Restaurant with
Drive Thru

0.0493242
/

0.0031483
5 0.0512 1.6100e0034.0000e0050.1028
General Heavy
Industry

8.96094 /
0 8.9595 0.2926 6.9500e00318.3455
General Light
Industry

0.578125 /
0 0.5780 0.0189 4.5000e0041.1836
High Turnover (Sit
Down Restaurant)

0.804364 /

0.0513424

0.8341 0.0263 6.2000e0041.6768
Hotel 0.792712 /

0.0880791

0.8439 0.0259 6.2000e0041.6745
Regional
Shopping Center

0.0925907
/

0.0567491

0.1256 3.0300e0037.0000e0050.2228
Unrefrigerated
Warehouse-No
Rail
283.975 /
0 283.9286 9.2735 0.2202 581.3751
Total 300.9369 9.7815 0.2322 614.6803
Mitigated

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

8.0 Waste Detail
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Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 606.5218 35.8444 0.0000 1,502.632
0 Unmitigated 1,213.043
6 71.6888 0.0000 3,005.264
0 Category/Year
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 838

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Discount Club 860.14 174.6007 10.3186 0.0000 432.5657
Fast Food
Restaurant w/o
Drive Thru

86.51 17.5608 1.0378 0.0000 43.5060
Fast Food
Restaurant with
Drive Thru

7.49 1.5204 0.0899 0.0000 3.7667
General Heavy
Industry
192.2 39.0149 2.3057 0.0000 96.6577
General Light
Industry

12.4 2.5171 0.1488 0.0000 6.2360
High Turnover (Sit
Down Restaurant)
126.14 25.6053 1.5132 0.0000 63.4360
Hotel 68.44 13.8927 0.8210 0.0000 34.4186
Regional
Shopping Center

5.25 1.0657 0.0630 0.0000 2.6402
Unrefrigerated
Warehouse-No
Rail
4617.28 937.2661 55.3908 0.0000 2,322.037
1 Total 1,213.043
5 71.6888 0.0000 3,005.264
0 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 839

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Discount Club 430.07 87.3003 5.1593 0.0000 216.2829
Fast Food
Restaurant w/o
Drive Thru

43.255 8.7804 0.5189 0.0000 21.7530
Fast Food
Restaurant with
Drive Thru

3.745 0.7602 0.0449 0.0000 1.8834
General Heavy
Industry

96.1 19.5074 1.1529 0.0000 48.3288
General Light
Industry

6.2 1.2585 0.0744 0.0000 3.1180
High Turnover (Sit
Down Restaurant)

63.07 12.8026 0.7566 0.0000 31.7180
Hotel 34.22 6.9464 0.4105 0.0000 17.2093
Regional
Shopping Center

2.625 0.5329 0.0315 0.0000 1.3201
Unrefrigerated
Warehouse-No
Rail
2308.64 468.6331 27.6954 0.0000 1,161.018
6 Total 606.5218 35.8444 0.0000 1,502.632
0 Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type Forklifts 36 8.00 260 89 0.20 CNG
Other General Industrial Equipment 36 8.00 260 88 0.34 CNG CalEEMod Version: CalEEMod.2020.4.0 Page 27 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 840

11.0 Vegetation
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Equipment Type tons/yr MT/yr
Forklifts 0.0938 4.4818 44.7377 7.1500e0030.0870 0.0870 0.0870 0.0870 0.0000 820.6852 820.6852 0.2654 0.0000 827.3208 Other General
Industrial
Equipment

0.6358 6.0232 8.9204 0.0120 0.2915 0.2915 0.2682 0.2682 0.0000 1,052.990 8 1,052.990
8 0.3406 0.0000 1,061.504
7 Total 0.7296 10.5050 53.6581 0.0191 0.3785 0.3785 0.3552 0.3552 0.0000 1,873.675 9 1,873.675
9 0.6060 0.0000 1,888.825
5 UnMitigated/Mitigated

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 28 Date: 8/20/2025 11:52 AM Sunset Crossroads Operations - All 4 Phases Combined - Light Vehicles - incl. Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 841
Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features San Bernardino-South Coast County, Summer
Project Characteristics - Utility Emission Factors for Banning Electric Land Use -
Construction Phase - Operations-only analysis.

Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip Rates from Traffic Study, Trip Lengths based on SCAQMD WAIRE Methodology Consumer Products - Mobile truck run only
Area Coating - Mobile truck run only
Landscape Equipment - Mobile truck run only

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 842
Energy Use - Mobile truck run only
Water And Wastewater - Mobile truck run only
Solid Waste - Mobile truck run only
Fleet Mix - Fleet Mix base on information provided in the Traffic analysis Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 0
tblAreaCoating Area_EF_Nonresidential_Interior 100 0
tblAreaCoating Area_EF_Parking 100 0
tblAreaCoating Area_EF_Residential_Exterior 50 0
tblAreaCoating Area_EF_Residential_Interior 50 0
tblAreaCoating Area_Nonresidential_Exterior 2533500 0
tblAreaCoating Area_Nonresidential_Interior 7600500 0
tblAreaCoating ReapplicationRatePercent 10 0
tblConsumerProducts ROG_EF 1.98E-05 0
tblConsumerProducts ROG_EF_Degreaser 3.542E-07 0
tblConsumerProducts ROG_EF_PesticidesFertilizers 5.152E-08 0 tblEnergyUse LightingElect 2.93 0.00
tblEnergyUse LightingElect 1.17 0.00
tblEnergyUse NT24E 5.02 0.00
tblEnergyUse NT24E 0.82 0.00
tblEnergyUse NT24NG 17.13 0.00
tblEnergyUse NT24NG 0.03 0.00
tblEnergyUse T24E 1.97 0.00
tblEnergyUse T24E 0.33 0.00
tblEnergyUse T24NG 15.20 0.00
tblEnergyUse T24NG 1.98 0.00
tblFleetMix HHD 0.02 0.61
tblFleetMix HHD 0.02 0.62
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 843
tblFleetMix LDA 0.55 0.00
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD1 0.02 0.08
tblFleetMix LHD2 6.8240e-003 0.11
tblFleetMix LHD2 6.8240e-003 0.10
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.09
tblFleetMix MDV 0.13 0.08
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.11
tblFleetMix MHD 0.01 0.10
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandscapeEquipment NumberSummerDays 250 0
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 844
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste SolidWasteGenerationRate 192.20 0.00
tblSolidWaste SolidWasteGenerationRate 4,617.28 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CW_TL 16.60 29.98
tblVehicleTrips CW_TL 16.60 30.44
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 6.42 0.43
tblVehicleTrips ST_TR 1.74 0.36
tblVehicleTrips SU_TR 5.09 0.43
tblVehicleTrips SU_TR 1.74 0.36
tblVehicleTrips WD_TR 3.93 0.43
tblVehicleTrips WD_TR 1.74 0.36
tblWater IndoorWaterUseRate 35,843,750.00 0.00
tblWater IndoorWaterUseRate 1,135,900,000.00 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 845

2.0 Emissions Summary

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 847

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 5.1414 209.1856 70.1298 1.1702 49.1442 2.2985 51.4427 13.6773 2.1981 15.8754 125,986.0 514
125,986.0
514

4.1465 18.0387 131,465.2
585
Total 5.1889 209.1903 70.6458 1.1702 49.1442 2.3003 51.4445 13.6773 2.2000 15.8773 125,987.1 604
125,987.1
604

4.1493 18.0387 131,466.4
395
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 5.1414 209.1856 70.1298 1.1702 49.1442 2.2985 51.4427 13.6773 2.1981 15.8754 125,986.0 514
125,986.0
514

4.1465 18.0387 131,465.2
585
Total 5.1889 209.1903 70.6458 1.1702 49.1442 2.3003 51.4445 13.6773 2.2000 15.8773 125,987.1 604
125,987.1
604

4.1493 18.0387 131,466.4
395
Mitigated Operational
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3.0 Construction Detail

3.1 Mitigation Measures Construction
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Construction not analyzed Site Preparation 8/20/2025 2/3/2026 5 120 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Construction not analyzed Rubber Tired Dozers 0 8.00 247 0.40 Construction not analyzed Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Construction not
analyzed
0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 180
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 849

3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 850

3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
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3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
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3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
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4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 5.1414 209.1856 70.1298 1.1702 49.1442 2.2985 51.4427 13.6773 2.1981 15.8754 125,986.0 514
125,986.0
514

4.1465 18.0387 131,465.2
585
Unmitigated 5.1414 209.1856 70.1298 1.1702 49.1442 2.2985 51.4427 13.6773 2.1981 15.8754 125,986.0 514
125,986.0
514

4.1465 18.0387 131,465.2
585

4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
General Heavy Industry 66.00 66.00 66.00 720,229 720,229 Unrefrigerated Warehouse-No Rail 1,782.07 1,782.07 1782.07 19,745,661 19,745,661 Total 1,848.07 1,848.07 1,848.07 20,465,889 20,465,889
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Heavy Industry 29.98 8.40 6.90 100.00 0.00 0.00 100 0 0 Unrefrigerated Warehouse-No
Rail

30.44 8.40 6.90 100.00 0.00 0.00 100 0 0

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 854
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Heavy Industry 0.000000 0.000000 0.000000 0.090910 0.090910 0.106060 0.106060 0.606060 0.000000 0.000000 0.000000 0.000000 0.000000 Unrefrigerated Warehouse-No
Rail

0.000000 0.000000 0.000000 0.083830 0.083830 0.103870 0.103870 0.624600 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 NaturalGas
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 855

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated
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6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Unmitigated 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Total 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 857

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Total 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 858

11.0 Vegetation

8.1 Mitigation Measures Waste

8.0 Waste Detail

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 18 Date: 8/20/2025 9:19 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 859
Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features San Bernardino-South Coast County, Winter
Project Characteristics - Utility Emission Factors for Banning Electric Land Use -
Construction Phase - Operations-only analysis.

Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip Rates from Traffic Study, Trip Lengths based on SCAQMD WAIRE Methodology Consumer Products - Mobile truck run only
Area Coating - Mobile truck run only
Landscape Equipment - Mobile truck run only

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 860
Energy Use - Mobile truck run only
Water And Wastewater - Mobile truck run only
Solid Waste - Mobile truck run only
Fleet Mix - Fleet Mix base on information provided in the Traffic analysis Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 0
tblAreaCoating Area_EF_Nonresidential_Interior 100 0
tblAreaCoating Area_EF_Parking 100 0
tblAreaCoating Area_EF_Residential_Exterior 50 0
tblAreaCoating Area_EF_Residential_Interior 50 0
tblAreaCoating Area_Nonresidential_Exterior 2533500 0
tblAreaCoating Area_Nonresidential_Interior 7600500 0
tblAreaCoating ReapplicationRatePercent 10 0
tblConsumerProducts ROG_EF 1.98E-05 0
tblConsumerProducts ROG_EF_Degreaser 3.542E-07 0
tblConsumerProducts ROG_EF_PesticidesFertilizers 5.152E-08 0 tblEnergyUse LightingElect 2.93 0.00
tblEnergyUse LightingElect 1.17 0.00
tblEnergyUse NT24E 5.02 0.00
tblEnergyUse NT24E 0.82 0.00
tblEnergyUse NT24NG 17.13 0.00
tblEnergyUse NT24NG 0.03 0.00
tblEnergyUse T24E 1.97 0.00
tblEnergyUse T24E 0.33 0.00
tblEnergyUse T24NG 15.20 0.00
tblEnergyUse T24NG 1.98 0.00
tblFleetMix HHD 0.02 0.61
tblFleetMix HHD 0.02 0.62
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 861
tblFleetMix LDA 0.55 0.00
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD1 0.02 0.08
tblFleetMix LHD2 6.8240e-003 0.11
tblFleetMix LHD2 6.8240e-003 0.10
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.09
tblFleetMix MDV 0.13 0.08
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.11
tblFleetMix MHD 0.01 0.10
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandscapeEquipment NumberSummerDays 250 0
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 862
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste SolidWasteGenerationRate 192.20 0.00
tblSolidWaste SolidWasteGenerationRate 4,617.28 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CW_TL 16.60 29.98
tblVehicleTrips CW_TL 16.60 30.44
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 6.42 0.43
tblVehicleTrips ST_TR 1.74 0.36
tblVehicleTrips SU_TR 5.09 0.43
tblVehicleTrips SU_TR 1.74 0.36
tblVehicleTrips WD_TR 3.93 0.43
tblVehicleTrips WD_TR 1.74 0.36
tblWater IndoorWaterUseRate 35,843,750.00 0.00
tblWater IndoorWaterUseRate 1,135,900,000.00 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 863

2.0 Emissions Summary

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 864
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 865

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 4.8570 219.8653 68.7789 1.1685 49.1442 2.3005 51.4447 13.6773 2.2001 15.8773 125,818.7 150
125,818.7
150

4.1328 18.0646 131,305.2
971
Total 4.9045 219.8700 69.2949 1.1685 49.1442 2.3023 51.4465 13.6773 2.2019 15.8792 125,819.8 240
125,819.8
240

4.1357 18.0646 131,306.4
781
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 4.8570 219.8653 68.7789 1.1685 49.1442 2.3005 51.4447 13.6773 2.2001 15.8773 125,818.7 150
125,818.7
150

4.1328 18.0646 131,305.2
971
Total 4.9045 219.8700 69.2949 1.1685 49.1442 2.3023 51.4465 13.6773 2.2019 15.8792 125,819.8 240
125,819.8
240

4.1357 18.0646 131,306.4
781
Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 866

3.0 Construction Detail

3.1 Mitigation Measures Construction
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Construction not analyzed Site Preparation 8/20/2025 2/3/2026 5 120 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Construction not analyzed Rubber Tired Dozers 0 8.00 247 0.40 Construction not analyzed Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Construction not
analyzed
0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 180
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 867

3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 868

3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 869

3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
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3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 871

4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 4.8570 219.8653 68.7789 1.1685 49.1442 2.3005 51.4447 13.6773 2.2001 15.8773 125,818.7 150
125,818.7
150

4.1328 18.0646 131,305.2
971
Unmitigated 4.8570 219.8653 68.7789 1.1685 49.1442 2.3005 51.4447 13.6773 2.2001 15.8773 125,818.7 150
125,818.7
150

4.1328 18.0646 131,305.2
971

4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
General Heavy Industry 66.00 66.00 66.00 720,229 720,229 Unrefrigerated Warehouse-No Rail 1,782.07 1,782.07 1782.07 19,745,661 19,745,661 Total 1,848.07 1,848.07 1,848.07 20,465,889 20,465,889
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Heavy Industry 29.98 8.40 6.90 100.00 0.00 0.00 100 0 0 Unrefrigerated Warehouse-No
Rail

30.44 8.40 6.90 100.00 0.00 0.00 100 0 0

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 872
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Heavy Industry 0.000000 0.000000 0.000000 0.090910 0.090910 0.106060 0.106060 0.606060 0.000000 0.000000 0.000000 0.000000 0.000000 Unrefrigerated Warehouse-No
Rail

0.000000 0.000000 0.000000 0.083830 0.083830 0.103870 0.103870 0.624600 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 NaturalGas
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 873

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated
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6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Unmitigated 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Total 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 875

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Total 0.0475 4.6800e0030.5160 4.0000e0051.8300e0031.8300e0031.8300e0031.8300e0031.1089 1.1089 2.8800e0031.1810 Mitigated
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11.0 Vegetation

8.1 Mitigation Measures Waste

8.0 Waste Detail

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 18 Date: 8/20/2025 9:21 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 877
Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features San Bernardino-South Coast County, Annual
Project Characteristics - Utility Emission Factors for Banning Electric Land Use -
Construction Phase - Operations-only analysis.

Off-road Equipment - Operations-only analysis.

Trips and VMT - Operations-only analysis.

Grading - Operations-only analysis.

Architectural Coating - Operations-only analysis.

Vehicle Trips - Trip Rates from Traffic Study, Trip Lengths based on SCAQMD WAIRE Methodology Consumer Products - Mobile truck run only
Area Coating - Mobile truck run only
Landscape Equipment - Mobile truck run only

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Heavy Industry 155.00 1000sqft 3.56 155,000.00 0 Unrefrigerated Warehouse-No Rail 4,912.00 1000sqft 112.76 4,912,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 32

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company User Defined
Operational Year 2027
CO2 Intensity
(lb/MWhr)
115.57 CH4 Intensity 0.012
(lb/MWhr)
N2O Intensity 0.001
(lb/MWhr)
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Energy Use - Mobile truck run only
Water And Wastewater - Mobile truck run only
Solid Waste - Mobile truck run only
Fleet Mix - Fleet Mix base on information provided in the Traffic analysis Table Name Column Name Default Value New Value
tblAreaCoating Area_EF_Nonresidential_Exterior 100 0
tblAreaCoating Area_EF_Nonresidential_Interior 100 0
tblAreaCoating Area_EF_Parking 100 0
tblAreaCoating Area_EF_Residential_Exterior 50 0
tblAreaCoating Area_EF_Residential_Interior 50 0
tblAreaCoating Area_Nonresidential_Exterior 2533500 0
tblAreaCoating Area_Nonresidential_Interior 7600500 0
tblAreaCoating ReapplicationRatePercent 10 0
tblConsumerProducts ROG_EF 1.98E-05 0
tblConsumerProducts ROG_EF_Degreaser 3.542E-07 0
tblConsumerProducts ROG_EF_PesticidesFertilizers 5.152E-08 0 tblEnergyUse LightingElect 2.93 0.00
tblEnergyUse LightingElect 1.17 0.00
tblEnergyUse NT24E 5.02 0.00
tblEnergyUse NT24E 0.82 0.00
tblEnergyUse NT24NG 17.13 0.00
tblEnergyUse NT24NG 0.03 0.00
tblEnergyUse T24E 1.97 0.00
tblEnergyUse T24E 0.33 0.00
tblEnergyUse T24NG 15.20 0.00
tblEnergyUse T24NG 1.98 0.00
tblFleetMix HHD 0.02 0.61
tblFleetMix HHD 0.02 0.62
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tblFleetMix LDA 0.55 0.00
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LDT2 0.17 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD1 0.02 0.08
tblFleetMix LHD2 6.8240e-003 0.11
tblFleetMix LHD2 6.8240e-003 0.10
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.13 0.09
tblFleetMix MDV 0.13 0.08
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MH 4.1930e-003 0.00
tblFleetMix MHD 0.01 0.11
tblFleetMix MHD 0.01 0.10
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix OBUS 5.4600e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix SBUS 9.6100e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblFleetMix UBUS 2.4200e-004 0.00
tblGrading AcresOfGrading 0.00 180.00
tblLandscapeEquipment NumberSummerDays 250 0
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 4.00 0.00 tblProjectCharacteristics CH4IntensityFactor 0 0.012
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 22 Date: 8/20/2025 9:17 AM Sunset Crossroads Operations All Phases Combined - HD Vehicles - with Project Features - San Bernardino-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 880
tblProjectCharacteristics CO2IntensityFactor 0 115.57
tblProjectCharacteristics N2OIntensityFactor 0 0.001
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillCaptureGasFlare 94.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste LandfillNoGasCapture 6.00 0.00
tblSolidWaste SolidWasteGenerationRate 192.20 0.00
tblSolidWaste SolidWasteGenerationRate 4,617.28 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CW_TL 16.60 29.98
tblVehicleTrips CW_TL 16.60 30.44
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips ST_TR 6.42 0.43
tblVehicleTrips ST_TR 1.74 0.36
tblVehicleTrips SU_TR 5.09 0.43
tblVehicleTrips SU_TR 1.74 0.36
tblVehicleTrips WD_TR 3.93 0.43
tblVehicleTrips WD_TR 1.74 0.36
tblWater IndoorWaterUseRate 35,843,750.00 0.00
tblWater IndoorWaterUseRate 1,135,900,000.00 0.00
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2.0 Emissions Summary

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2025 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2025 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2026 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Maximum 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) Highest

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 Unmitigated Operational
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mobile 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Water 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Construction not analyzed Site Preparation 8/20/2025 2/3/2026 5 120 ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Acres of Grading (Site Preparation Phase): 180
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3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Construction not analyzed Rubber Tired Dozers 0 8.00 247 0.40 Construction not analyzed Tractors/Loaders/Backhoes 0 8.00 97 0.37 Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Construction not
analyzed
0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
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3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
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3.2 Construction not analyzed - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
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3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated Construction Off-Site
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3.2 Construction not analyzed - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0955 0.0000 0.0955 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated Construction Off-Site
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4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 Unmitigated 0.9041 40.2903 12.5003 0.2124 8.7960 0.4180 9.2140 2.4529 0.3997 2.8526 0.0000 20,747.71 87 20,747.71
87 0.6827 2.9784 21,652.34
74 4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
General Heavy Industry 66.00 66.00 66.00 720,229 720,229 Unrefrigerated Warehouse-No Rail 1,782.07 1,782.07 1782.07 19,745,661 19,745,661 Total 1,848.07 1,848.07 1,848.07 20,465,889 20,465,889
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Heavy Industry 29.98 8.40 6.90 100.00 0.00 0.00 100 0 0 Unrefrigerated Warehouse-No
Rail

30.44 8.40 6.90 100.00 0.00 0.00 100 0 0

4.4 Fleet Mix
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Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Heavy Industry 0.000000 0.000000 0.000000 0.090910 0.090910 0.106060 0.106060 0.606060 0.000000 0.000000 0.000000 0.000000 0.000000 Unrefrigerated Warehouse-No
Rail

0.000000 0.000000 0.000000 0.083830 0.083830 0.103870 0.103870 0.624600 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 NaturalGas
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 NaturalGas
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

5.1 Mitigation Measures Energy
Historical Energy Use: N
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated
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6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated
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6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated
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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Heavy
Industry
0 / 0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
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7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Heavy
Industry
0 / 0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000
Category/Year
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8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Heavy
Industry
0 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated

9.0 Operational Offroad
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11.0 Vegetation
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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ͭͯͱͯͰ-ͭͱ CEQA Memo Redline ͵ Sunset Crossroads
ATTACHMENT C:

VMT
900

TECHNICAL MEMORANDUM
260 E Baker Street | Suite 200 | Costa Mesa, CA 92626 | (949) 660-1994 | urbanxroads.com DATE: October 10, 2025
TO: J.J. Jenkins, NP Banning Industrial, LLC
FROM: Alex So, Urban Crossroads, Inc.

JOB NO: 15718-01 VMT
SUBJECT: MODIFIED SUNSET CROSSROADS SPECIFIC PLAN(SP NO. 200- 20000002)VEHICLE MILES TRAVELED (VMT) COMPARATIVE

ANALYSIS
Urban Crossroads, Inc. has completed the following Vehicle Miles Traveled (VMT) Comparative Analysis for the Modified Sunset Crossroads Specific Plan (Modified Project), which is generally located south of the I-10 Freeway and west of Sunset Avenue in the City of Banning. This technical memorandum presents an analysis of project-generated VMT based on a proposed change in land use and provides a comparison of analysis findings to those previously presented in the Sunset Crossroads VMT Analysis (dated August 25, 2023) and the Sunset Crossroads Draft Environmental Impact Report (SCH No. 2021020011) dated December 2023; hereafter referred to as the “2023VMT Analysis”. Specifically, the purpose of this analysis is to determine whether the Modified Project’s proposed land use changes would result in any new VMT impacts as compared to those previously disclosed in the 2023 VMT Analysis.

PROJECT OVERVIEW
The DEIR and the 2023 VMT Analysis evaluated 268,400 square feet of commercial uses and a hotel with 125 rooms and comprised of approximately 90,000 square feet within a 47.9-acre portion of the Development Site designated for freeway-oriented General Commercial land uses, 5,545,000 square feet of industrial land uses within a 392.0-acre portion of the development site, with the remaining

93.9 acres designated as Open Space-Resources (53.0 acres), Open Space-Parks (12.6 acres), or assigned for circulation features (28.3 acres).

This VMT analysis evaluates proposed land use changes defined as part of the Modified Project to ensure VMT impacts are no greater than those already disclosed in the 2023 VMT Analysis.

Specifically, the following land use changes have been evaluated as part of a Modified Project description:
o Removal of 330,000 square feet of High-Cube Cold Storage Use (Buildings 5 & 6) o Removal of 105,500 square feet of Warehousing use (Buildings 5 & 6) o Removal of 42,500 square feet of General Light Industrial use (Buildings 5 & 6) o Removal of 40,700 square feet of Go-Kart Racing use
o Removal of 13,000 square feet of Rock Climbing use
o Removal of 116,700 square feet of Health/Fitness Club use o Removal of 9,500 square feet of Medical-Dental Office use 901
13534-04 DA VMT Redlines 2 Modified Sunset Crossroads Specific Plan o Removal of 7,500 square feet of Truck Stop use
o Removal of 9,500 square foot Quality Restaurant use
o Reduce Retail use from 12,000 square feet to 5,005 square feet o Reduce High Turnover Sit-down Restaurant use from 40,000 square feet to 10,595 square feet o Reduce Fast-food Restaurant With Drive-Through Window use from 7,000 square feet to 645 square feet
o Addition of 200,000 square feet of Discount Club use
o Addition of 7,508 square feet of Fast-Food Without Drive-Through Window use This results in a total reduction of 478,000 square feet of Industrial use along with a total reduction of 239,655 square feet of Commercial Retail uses and replacing these uses with 200,000 square feet of Discount Club use and 7,508 square feet of Fast-Food Without Drive-Through Window use. All other Industrial and Retail uses remain the same.

VMT METRIC AND SIGNIFICANCE THRESHOLD
This VMT analysis has been prepared in accordance with the City’s adopted Traffic Impact Analysis Guidelines for Local Transportation Analysis and Vehicle Miles Traveled Analysis (1). (dated October 2021, referred to as City Guidelines).As stated in Section 4.2.3 of the City Guidelines, “for mixed‐use projects (i.e., projects containing more than one land use type), the VMT analysis should be performed separately for each component of the project using the most appropriate VMT metric.”1 In addition, this VMT analysis is prepared consistent with the Project Draft Environmental Impact Report (DEIR) on page 4.17.2 with the following VMT metric and thresholds:

The City has adopted the VMT metric for retail projects greater than 50,000 sf of gross leasable area to utilize the metric of net change in total VMT. Therefore, for purposes of this analysis with respect to the Modified Project’s Retail uses a significant impact to VMT would occur if the addition of the Modified Project’s retail component would result in a net increase in total VMT for the WRCOG region. City Guidelines defines the region as the WRCOG region for VMT analysis.

For projects that are not residential, office, or retail land use types, (i.e., non-retail uses),the City Guidelines identify VMT per employee as the appropriate VMT metric for analysis.

Therefore, the Project’s non-retail uses should be evaluated based on the metric VMT per employee. A significant impact to VMT would occur if the addition of the Project’s non-retail component would result in Project generated VMT per employee to exceed the City’s significance threshold of 25.9.

Accordingly, like the EIR’s analysis of VMT for the Project, the analysis for the modified project uses the City VMT Guidelines which assesses whether there is a net increase in total VMT for the WRCOG region, and does not examine whether there is the net change in Total VMT within the City of Banning.
1 City’s Guidelines; Page 20.

Formatted: Indent: Left: 0.31", Right: 0.25"
902
13534-04 DA VMT Redlines 3 Modified Sunset Crossroads Specific Plan

PROJECT VMT ESTIMATES
In the Modified Project, the reduction in estimated employees is attributable solely to decreases in building square footage rather than any change to employee density assumptions. Employee estimates are derived using the County of Riverside’s standard conversion factors of 1,030 square feet per employee for industrial uses and 500 square feet per employee for retail uses. Accordingly, the original 5,545,000 square feet of industrial space generated 5,383 employees, while the reduced 5,067,000 square feet under the Modified Project generates 4,920 employees. Similarly, retail employment decreased from 537 to 520 employees as retail building area declined from 268,400 to 223,753 square feet. Hotel employment remains unchanged at 73 employees. While certain jurisdictions apply a lower employee ratio for big-box retail than for smaller shops, the County’s standard factor of 500 square feet per employee was applied uniformly across all retail space in this analysis. Tables 1 & 2 identify the 2023 VMT Analysis and the Modified Project’s employment estimates.

TABLE 1: 2023 VMT ANALYSIS EMPLOYMENT ESTIMATES
Land Use Building Area Conversion Factor1 Estimated Employees Industrial 5,545,000 SF 1,030 SF per employee 5,383 Industrial Employees Retail 268,400 SF 500 SF per employee 537 Retail Employees Hotel 125 Rooms 14.34 trips per employee2 73 Service Employees Riverside County General Plan; Appendix E-2
2 ITE Trip Generation Manual (10th Edition). 1,046 hotel daily trips / 14.34 trips per employee = 73 hotel employees TABLE 2:MODIFIED PROJECT EMPLOYMENT ESTIMATES
Land Use Building Area Conversion Factor1 Estimated Employees Industrial 5,067,000 SF 1,030 SF per employee 4,920 Industrial Employees Retail 223,753 SF 500 SF per employee 520 Retail Employees Hotel 125 Rooms 14.34 trips per employee2 73 Service Employees Riverside County General Plan; Appendix E-2
2 ITE Trip Generation Manual (10th Edition). 1,046 hotel daily trips / 14.34 trips per employee = 73 hotel employees

RETAIL VMTCALCULATION
As described previously, retail land uses are evaluated using net change in total VMT for the WRCOG region. RIVCOM was applied to calculate link level VMT for the WRCOG region under both “Baseline No Project” and “Baseline With Project” scenarios. This approach, commonly referred to as the “boundary method,” accounts for all vehicle trips with one or both trip ends within a defined geographic area, in this case the WRCOG region. As shown in Table 3, the Modified Project results in a net decrease in total VMT within the WRCOG Region, which falls below the City’s impact threshold.

By comparison, the Modified Project results in less total VMT within the WRCOG Region than that previously reported in the 2023 VMT Analysis.
903
13534-04 DA VMT Redlines 4 Modified Sunset Crossroads Specific Plan TABLE 3:NET CHANGE IN TOTAL VMT
Retail No Project Modified Project 2023 VMT Analysis
Total VMT 46,664,450 46,206,951 46,241,002
+/- to Total VMT - -457,499 -423,448
Net Increase? - No No
Exceeds Threshold? - No No

NON-RETAIL VMTCALCULATION
The City’s Guidelines specify VMT per employee as the appropriate metric for evaluating industrial land uses. For this analysis, RIVCOM was used to estimate the Project-generated VMT associated with the non-retail land uses. This value was then divided by the Project’s employment estimate to determine the Project’s VMT per employee. Table 3 summarizes the home-based work (HBW) VMT results from RIVCOM along with the estimated number of non-retail employees and the corresponding VMT per employee metric. As shown in Table 3, the Modified Project was found to result in less HBW VMT as compared to the 2023 VMT Analysis, and the resulting VMT per employee metric was also found to be lower for the Modified Project as compared to the 2023 VMT Analysis.

TABLE 3:NON-RETAIL VMT PER EMPLOYEE
Non-Retail Modified Project 2023 VMT Analysis
HBW VMT 151,224 165,615
Employment 4,920 5,383
VMT per Employee1 30.7 30.8
City Threshold 25.9 25.9
Difference +4.8 +4.9
Percent Above Threshold +18.5% +18.9%
Exceeds Threshold? Yes Yes
HBW VMT per Employee is a measure of all auto trips between home and work and does not include heavy duty truck trips or freight, which is consistent with City Guidelines.

VMT REDUCTION STRATEGY
The mitigation measure required in the DEIR (Page 4.17-14) consists of preparation of a Transportation Demand Management (TDM) strategy report to reduce employee VMT and would be formulated based on future tenants. It includes the consideration of the following VMT reducing project design features:
o Commute Trip Reduction Marketing
o Ridesharing Program
o End of Trip Facilities
However, as noted in the DEIR, a detailed TDM strategy cannot be developed at this time because the future tenants are not yet known. The same approach applies to the modified project. As with the original project, because specific tenants and their operational characteristics are currently unknown, it is not possible to determine which TDM measures would be appropriate or whether implementation of feasible measures would reduce the Project’s VMT per employee to a less-than904 13534-04 DA VMT Redlines 5 Modified Sunset Crossroads Specific Plan significant level. Accordingly, under CEQA, the conclusion remains that VMT impacts would be significant and unavoidable.

CONCLUSION
Based on the results of this analysis, the following findings are made:
o Changes to land use for the Modified Project results in a reduction of 478,000 square feet of industrial uses and 239,655 square feet of retail uses, partially replaced by 200,000 square feet of Discount Club use and 7,508 square feet of Fast Food Without Drive Through use. o The retail VMT analysis shows a decrease in total regional VMT for the Modified Project as compared to that evaluated in the 2023 VMT Analysis.
o The Modified Project was also found to result in less HBW VMT as compared to the 2023 VMT Analysis, and the resulting VMT per employee metric was also found to be lower for the Modified Project as compared to the 2023 VMT Analysis. o The Modified Project would result in the same VMT impact findings as the 2023 VMT Analysis.
• The Retail component would continue to result in a less than significant VMT impact. • Conversely, the non-retail components of the Project would continue to result in a significant and unavoidable VMT impact.
• All previously identified VMT-reducing measures and project design features remain applicable and appropriate to reduce project-related VMT to the extent feasible.As the future tenants are still unknown, the Modified Project VMT impact remains significant and unavoidable.

If you have any questions, please contact me directly at [email protected].

REFERENCES

1. City of Banning. Traffic Impact Analysis Guidelines For Local Transportation Analysis and Vehicle Miles Traveled Analysis. City of Banning : s.n., October 2021. 905
ͭͯͱͯͰ-ͭͱ CEQA Memo Redline ͭͬ Sunset Crossroads
ATTACHMENT D:

NOISE
906

TECHNICAL MEMORANDUM
ͮͬͯͰͭ SW Birch Street | Suite ͮͯͬ | Newport Beach, CA ͵ͮͲͲͬ | (͵Ͱ͵) ͲͲͬ-ͭ͵͵Ͱ | urbanxroads.com DATE: October ͭͬ, ͮͬͮͱ
TO: JJ Jenkins, NP Banning Industrial, LLC
FROM: Bill Maddux, Urban Crossroads, Inc.

JOB NO: ͭͯͱͯͰ-ͭͰ
SUBJECT: SUNSET CROSSROADS NOISE ASSESSMENT
Urban Crossroads, Inc. is pleased to provide the following supplemental Noise Assessment in support of the Sunset Crossroads (Project). A Final Environmental Impact Report (FEIR) for the Original Project was completed and released for public review in ͮͬͮͰ. (ͭ) The FEIR determined that all Project noise impacts would be reduced to less than significant with the incorporation of project design features and mitigation measures.

The purpose of this assessment is to determine whether the Modified Project’s proposed land use changes would result in any new or additional noise impacts based on the City’s noise standards and thresholds used in the FEIR that were not previously analyzed.

PROJECT BACKGROUND
The FEIR for the Sunset Crossroads Project evaluated ͱ,ͱͰͱ,ͬͬͬ square feet of Warehousing/Industrial/Light industrial use, including ͯͯͬ,ͬͬͬ square feet of High Cube Cold Storage Warehouse use, with a commercial component that included up to ͮͲʹ,Ͱͬͬ square feet (including a ͳ,ͱͬͬ square foot Truck Stop with Fueling Stations), plus a ͭͮͱ-room Hotel (Project) with the following mix of uses:
• 3,381,000 square feet of High-Cube Fulfillment Center Warehouse use • 197,500 square feet of General Light Industrial use
• 490,500 square feet of Warehousing use
• 896,000 square feet of High-Cube Transload and Short-term Storage Warehouse use • 250,000 square feet of High-Cube Parcel Hub Warehouse use • 330,000 square feet of High-Cube Cold Storage Warehouse use • 12,000 square feet of Retail use
• 40,700 square feet of Go-Kart Racing use
• 13,000 square feet of Rock Climbing use
• 12,500 square feet of Trampoline Park use
• 116,700 square feet of Health/Fitness Club
• 9,500 square feet of Quality Restaurant use
• 40,000 square feet of High Turnover Sit-Down Restaurant use • 7,000 square feet of Fast-Food Restaurant with Drive-Through Window use • 9,500 square feet of Medical-Dental Office use
• 125-room Hotel
• 7,500 square foot Truck Stop
A new ͮͬͮͱ trip generation assessment has been prepared by Urban Crossroads, Inc. that compares the Modified Project with the changes proposed as part of the Development Agreement to the Project in the FEIR to ensure the environmental effects are less than those already disclosed in the DEIR. (ͮ) Specifically, the changes to the Modified Project are outlined as follows:
907
ͭͯͱͯͰ-ͭͰ Noise Memo SUNSET CROSSROADS
• Removal of 330,000 square feet of High-Cube Cold Storage Use (Buildings 5 & 6) • Removal of 105,500 square feet of Warehousing use (Buildings 5 & 6) • Removal of 42,500 square feet of General Light Industrial use (Buildings 5 & 6) • Removal of 40,700 square feet of Go-Kart Racing use
• Removal of 13,000 square feet of Rock Climbing use
• Removal of 116,700 square feet of Health/Fitness Club use • Removal of 9,500 square feet of Medical-Dental Office use • Removal of 7,500 square feet of Truck Stop use
• Removal of 9,500 square feet of Quality Restaurant use • Reduce Retail use from 12,000 square feet to 5,005 square feet • Reduce High Turnover Sit-down Restaurant use from 40,000 square feet to 10,595 square feet • Reduce Fast-food Restaurant With Drive-Through Window use from 7,000 square feet to 645 square feet • Addition of 200,000 square feet of Discount Club use
• Addition of 7,508 square feet of Fast-Food Without Drive-Through Window use This results in a total reduction of Ͱͳʹ,ͬͬͬ square feet of Industrial use, along with a total reduction of ͮͯ͵,Ͳͱͱ square feet of Commercial Retail uses, and replacing these uses with ͮͬͬ,ͬͬͬ square feet of Discount Club use and ͳ,ͱͬʹ square feet of Fast-Food Without Drive-Through Window use. All other Industrial and Retail uses remain the same.

OFF-SITE TRAFFIC EVALUATION
The Modified Project generates ͭͳ,ʹͱͮ average daily trips (ͭͲ,ͬͬͰ passenger vehicles and ͭ,ʹͰʹ trucks), a reduction from the Project's ͮͬ,ͰͲ͵ average daily trips (ͭͳ,ͭͲͲ passenger vehicles and ͯ,ͯͬͬ trucks). This represents a ͳ percent (%) decrease in vehicle trips and a ͰͰ% decrease in truck trips (ͯͮ% total). Table ͭ summarizes the estimated trip generation between the alternatives after converting the project truck trips to passenger vehicles.

According to California Department of Transportation (Caltrans) Technical Noise Supplement (TeNS) to the Noise Analysis Protocol, when measuring traffic noise and there are difference in vehicle classification, i.e. a mix of auto mobiles and trucks, between the measurements, the noise levels can be normalized by multiplying the trucks by a factor of ͭͬ or more to equal a similar number of automobiles. In essence, trucks are at least ͭͬ times louder than automobiles, and multiplying the number of trucks by ͭͬ, they can be added to the automobile volume, and the totals can be compared to determine the noise level change due to the change in total traffic volume. Table ͭ summarizes the estimated trip generation between the alternatives after and the normalized traffic volumes.
908
ͭͯͱͯͰ-ͭͰ Noise Memo SUNSET CROSSROADS
TABLE 1: TRIP GENERATION SUMMARY
Traffic Volumes
Land Use Daily Normalized
Project
Passenger Cars 17,166 17,166
Trucks 3,330 33,300
Project Total 20,496 50,466

Modified Project
Passenger Cars 16,004 16,004
Trucks 1,848 18,480
Modified Project Total 17,852 34,484

Project vs. Modified Project
Net Change of Passenger Cars -1,162 -1,162
Net Change of Trucks -1,482 -14,820
Total Project Net Change -2,644 -15,982

OFF-SITE TRAFFIC NOISE
Given that trucks produce noise levels up to ͭͬ times higher than passenger vehicles, as noted in the California Department of Transportation (Caltrans) Technical Noise Supplement ( TeNS),, this reduction is significant for noise impacts. (ͯ) If we evaluate the increasechange in trip generation between the Project and the Modified Project, converting all vehicles to passenger vehicle equivalents using Caltrans normalization, gives us a ͯͮ% decrease in overall equivalent vehicles.

Because decibels are logarithmic units, noise levels “cannot be added or subtracted by ordinary arithmetic means.” For example, if a specific volumes of traffic passes an observer and generates Ͳͱ dBA CNEL, doubling that traffic volume would not produce ͭͯͬ dB; they would combine to produce Ͳʹ dBA CNEL. According to Caltrans, “two decibel-addition rules are important. First, when adding a noise level to an approximately equal noise level, the total noise level increases ͯ dB. For example, doubling the traffic on a highway would result in an increase of ͯ dB. Conversely, reducing traffic by one half would reduce the noise level by ͯ dB. Second, when two noise levels are ͭͬ dB or more apart, the lower value does not contribute significantly (less than ͬ.ͱ dB) to the total noise level.” This can be calculated using the Following equation: ͭͬ*LOGͭͬ(Modified Project Volume/Original Project Volume). Using the normalized traffic volumes shown in Table ͭ results in an approximate ͮ dBA CNEL decrease in traffic noise levels.

As identified in the Modified Sunset Crossroads (SP No. ͮͬ-ͮͬͬͬͬͬͬͮ) Trip Generation Assessment the distribution of traffic under the Modified Project would be similar to the Project. (ͮ) Therefore, based on the difference in acoustic energy between the normalized volumes, this decrease in traffic volumes, which would occur on the same roadways identified in the FEIR and, would result in a ͮ dBA CNEL decrease over off-site traffic noise levels identified for the Project in the FEIR. 909
ͭͯͱͯͰ-ͭͰ Noise Memo SUNSET CROSSROADS

OPERATION
The FEIR identified stationary operations noise sources, including truck delivery and truck loading/unloading activities; heating, ventilation, and air conditioning (HVAC), including cold storage, equipment; refrigeration equipment; drive-through speakerphones; parking activities; fueling activities; and outdoor eating activities. The FEIR Supplemental Noise Analysis concluded that with Project design features included in the FEIR, noise levels generated from operations of the Development Project would be less than significant, including at residential noise receivers (Ͱ).