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L3-35 Comment noted. Clarification has been added to MM CUL-1 and MM CUL-2 of the DEIR. Refer to Section 3.0, Errata , of this FEIR .
L3-36 PaleoWest is aware that an archaeological resource survey was completed on the Project area in 2013. The records search conducted for that effort did not identify any cultural resources within the Project area and no resources were documented during the survey effo rt; refer to Appendix D of the DEIR for additional information.
In compliance with PRC § 21080.3.1(b), formal notification has been provided to California Native American triba l representatives which may have interest in projects within the geographic area traditionally and culturally affiliated with the tribe. Native American groups may have knowledge about cultural resources in the area and may have concerns about adverse effects from development on tribal cultural resources (TCRs) as defined in PRC § 21074. The NAHC was contacted on April 28, 2021, for a review of the Sacred Land File (SLF) search.
The SLF search did not return any information of Native American cultural resources (e.g., traditional use or gathering area, place of religious or sacred a ctivity, etc.) within the immediate vicinity of the Project APE. The NAHC responded on May 17, 2021, noting that the SLF returned negative results. However, NAHC noted that the absence of specific site information in the SLF does not indicate the absence of TCRs within the Project area of potential effect (APE). The NAHC requested 23 individuals representing 15 Native American tribal groups be contacted to elicit information regarding cultural resource issues related to the Project. Outreach letters to the 15 recommended tribal groups were sent on June 17, 2021.
These letters were followed up by phone calls on July 2, 2021.
As of July 2021, the following five responses have been received:
• The Quechan Historic Preservation Department sent an email indicatin g the Tribe does not wish to comment on the Project and stating they defer to more local tribes. • Mr. Ryan Nordness, Cultural Resource Analyst for the San Manuel Band of Mission Indians (SMBMI), stated that the Project area is not located within the Serran o ancestral territory.
As such, the Tribe will not be requesting to receive consulting party status with the lead agency and do not wish to participate in scoping, development, or review of documents for the Project.
• The Rincon Band of Luiseno Indians responded by stating that the Project area is not within the Tribe’s specific area of historic interest and as such, they do not have any information to provide and defer to a closer tribe to the Project area. • Mr. Paul Macarro, Cultural Resources Coordinator for the Pechanga Band of Luiseno Indians, responded via phone call and stated that the Project area is outside of the Tribe’s ancestral territory and therefore, the Tribe has no comment to provide for the Project. • Mr. Mark Cochrane, Co-Chairperson for the Serrano Nation of Mission Indians, stated that he did not have any comments to provide for the Project but requested that the Serrano
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Nation, either himself or Mr. Wayne Walker, be notified if any cultural material is encountered during construction.
Based on the lack of TCRs found during the site visit, the lack of TCRs noted by NAHC and the SLF search, and the lack of tribal interest for the APE from tribes, it is concluded that tribal consultation has officially concluded. Additionally, based on the aforementioned, the Project would not be developed in an area listed or eligible for listing in the CRHR, or in a local register of historical resources as defined in Public Resources, and nor is the Project site anticip ated to contain a TCR.
L3-37 As described on page 4.6-23 of the DEIR, the surface and subsurface soils are comprised of cement/concrete, artificial fill, alluvium, and older alluvium. Older granitic and metamorphic bedrock that have a very low paleontological resource potential due to the heat and pressure of their formation. Due to the presence of older alluvium soils throughout the Project site, there is a high possibility of paleontological resources that may be disturbed during construction. Therefore, with implementation of MM GEO -2 (Paleontological Construction Monitoring and Compliance Program), construction of the Project components would not destroy a unique paleontological resource or site or unique geologic feature, thereby reducing any potential impacts to a less than significant level.
L3-38 Comment noted. Clarification has been added to MM GEO -1 of the DEIR. Refer to Section 3.0, Errata, of this FEIR .
L3-39 The commenter disagrees that the use of carbon offsets to mitigation GHG emission is not a viable option. It is acknowledged that the use of carbon offsets is allowable as CEQA mitigation.
Purchased offset credits must be genuine, quantifiable, additional, and verifiable. Even offset credits purchased from CARB -approved offset project registries have been determined to not adequately assure that purchased offset credits accurately and reliably represent actual emissions reductions or cannot guarantee that s uch reductions are additional to any reduction that would occur under business -as-usual operations and reductions required by law. As discussed in Section 4.7, Greenhouse Gas Emissions of the DEIR, offsets purchased from CARB’s approved offset project registries could be determined to not adequately assure that purchased offset credits accurately and reliably represent actual emissions reductions or cannot guarantee that such reductions are additional to any reduction that would occur under business -as-usua l operations and reductions required by law. In addition, the City of Beaumont, the lead agency for the Project and the entity responsible for enforcing any mitigation measures incorporated into the Project to potentially reduce impacts , has no enforcement authority over offset credits that fund carbon reduction projects outside of the City. Many offset credits “sell” reductions in emissions generated outside of California, which may not be genuine or verifiable. Therefore, as a conservative measure, the us e of carbon offsets has not been considered for the Project.
L3-40 The comment suggests that the DEIR consider measures identified within the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Change Vulnerabilities, and Advancing Health and
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Equity (2021 CAPCOA Handbook) to reduce GHG emissions. As discussed in Section 4.7 of the DEIR and shown in Table 4.7-14, all feasible mitigation and design features have been implemented, which includes all applicable measures recommended in the 2021 CAPCOA Handbook. Standard Condition SC GHG -2 requires that the Project be designed to have 15 percent of the roof area “solar ready” and mitigation measure MM GHG-1 requires the installation of solar photovoltaic panels or other renewable energy generation on -site, consistent with measure E -9-A (Establish Onsite Renewable Energy Systems – Generic).
Standard condition SC GHG -3 requires adherence to the City’s Water Efficient Landscape Requirements (Section 17.06.030 of the City’s Municipal Code), which is consistent with measure W-5 (Design Water Efficient Landscapes). Standard Condition SC GHG -4 requires the installation of water efficient fixtures, which is consistent with measure W-4 (Require Low- Flow Water Fixtures). Standard Condition SC GHG -8 requires the future installation of electric vehicle supply equipment, consistent with measure T -13 (Provide Electric Vehicle Charging Infrastructure). Mitigation measure MM-GHG-4 requires the use of electrically powered landscaping equipment, consistent with measure LL -1 (Replace Gas Powered Landscape Equipment with Zero-Emission Landscape Equipment). Mitigation measure MM AQ -3 requires the implementation of a transportation demand management pr ogram, consistent with trip reduction program measures. In addition, the Project would achieve Leadership in Energy and Environmental Design (LEED) certification and meet or exceed CALGreen Tier 2 standards in effect at the time of building permit applicable, as required by mitigation measure MM GHG-2.
As shown in Table 4.7-14, approximately 93 percent of opening year buildout emissions and approximately 98 percent of 2040 buildout emissions are from on-road mobile sources. The City does not have regulatory authority to control tailpipe emissions. The implementation of a TDM program and the installation of infrastructure for electric vehicle charging capabilities would reduce mobile emissions to the extent feasible. As demonstrated, the Project wou ld implement all applicable on-site measures and would reduce GHG emissions to the extent feasible.
L3-41 As identified on page 4.8-22 of the DEIR, as part of the Phase I ESA research, VERTEX submitted a public records request to the County of Riverside De partment of Environmental Health – Hazardous Materials Certified Unified Program Agency for the site parcels on March 12, 2021.
The records provided indicate the following:
• One 10,000-gallon double walled steel UST
• One 1,000-gallon double-walled steel UST
• One 550- gallon double walled steel UST
The research revealed that these USTs were removed from the site in January 1994.
Confirmation sampling indicated relatively low concentrations of petroleum hydrocarbons as diesel, as gasoline, benzene, toluene, ethylbenzene, and xylenes were detected below the USTs. On September 20, 1994, the County of Riverside Department of Environmental Health granted “no further action” for the removed USTs which included the following statement:
“Additionally, be advised that c hanges in the present or proposed use of the site may require
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further site characterization and mitigation activity. It is the property owner’s responsibility to notify this agency of any changes in report content, future contamination findings, or site us age.” Findings revealed that available materials did not indicate if excavated soil was disposed off-site or re-used to backfill the UST excavations. Based on this information and the conditions indicated in the “no further action letter,” the former USTs represent a CREC in connection with the Project site. As such, no mitigation is required.
L3-42 Comment noted. Clarification has been added to MM HAZ-1 of the DEIR. Refer to Section 3.0, Errata, of this FEIR .
L3-43 This conclusion was based on the fact that the Phase I ESA performed in conformance with the scope and limitations of ASTM E 1527-13, Standard Practice for ESAs concluded that no evidence of RECs, CREC or HRECs in connection with the site, except for the following:
• Based on the reported contamination and the conditions indicated in the no further action letter, the former USTs represent a CREC in connection with the site. However, MM HAZ-1 is recommended.
The Project does not include any RECs and is not part of the Cortese List. Additionally, with implementation of MM HAZ-1, the Project create a less than significant impact regarding the creation of a significant hazard to the public or the environment. Refer to Section 4.8, Hazards and Hazardous Materials , for additional information.
L3-44 All applicable General Plan goals and policies are identified in each of the environmental resource sections of the DEIR.
On October 9, 2019, the California Legislature adopted Senate Bill 330 (SB330) which, among other things, adopted Government Code Section 66300, declared a housing crisis in the State of California and imposed certain requirements designed to streamline the construction of new housing, and prevent the loss of existing housing and land available for future residential use, unless replaced in other areas of the affected jurisdiction to ensure no net loss in residential capacity. SB330 became effective on January 1, 2020.
In compliance with SB330, City staff has adopted an amendment to the municipal code, adding Chapter 17.20 “No Net Loss Pr ogram” for SB 330. The provisions of Chapter 17.20 ensure that rezoning actions do not result in a net loss of residential capacity within the City of Beaumont.
The No Net Loss Program (Program) creates a mechanism by which the City can approve a less intensive non-residential use and concurrently make available the residential capacity that would otherwise be lost through the proposed density bonus specified in the Program. The City’s Planning Department will publish the number of available units on the Ci ty’s website.
The Program allows for developers of land currently zoned Traditional Neighborhood (TN), Residential Multiple-Family (MFR), Downtown Residential Multi-Family (DMF), Sixth Street Mixed Use Residential (SSMU-R) and Transit Oriented Development Overlay (TOD) to request a density bonus subject to the number of units available. In the Residential Traditional Neighborhood (RTN) zone a bonus of up to 10% may be requested. In the Residential Multiple - Family (MFR), Downtown Residential Multi-Family (DMF), Sixth Street Mixed Use Residential
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(SSMU-R) or Transit Oriented Development Overlay (TOD) zones a bonus of up to 20% may be requested. If no units are available a density bonus pursuant to this provision may not be requested.
Under the existing Sunny-Cal Specific Plan, the Project site was proposed to accommodate 560 low density residential development units. In accordance with SB 330 and City Municipal Code Chapter 17.20, concurrent with approval of the Project entitlements and cha nge from residential to non-residential (e-commerce, commercial and open space) uses, these 560 residential units that would otherwise be lost will instead be “banked” by the City and made available to applicants for future projects located within the TN, MFR, DMG, SSMU-R and TOD zones that are seeking, and eligible for, a density bonus as part of the No Net Loss Program.
Therefore, the Project will be compliant with SB 330, and no further analysis is warranted.
L3-45 The commenter states that revisions to the noise analysis may be required based on comments to the transportation information.
L3-46 Refer to response to comment L3-44, above.
L3-47 Refer to response to comment L3-44, above.
L3-48 Refer to response to comment L3-27, above.
L3-49 Refer to responses to comment s L3-20 through L3-27, above.
L3-50 Refer to responses to comment s L3-12 through L3-20, above.
L3-51 The commenter notes that a maximum 10 percent VMT reduction is achievable with the TDM plan and that with implementation of MM AQ-3, impacts related to VMT would be significant and. As discussed in Section 4.15 of the DEIR, the commenter is correct and transportation impacts related to VMT would remain significant and unavoidable even with implementation of MM AQ -3. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
L3-52 Refer to response to comment L3-36 above.
L3-53 Pursuant to PRC 21100 and in accordance with the guidance in CEQA Guidelines §15126.6, the City conducted an alternatives analysis that includes a range of reasonable alternatives that would feasibly attain most of the basic objectives of the Project consistent with CEQA §15124(b), while avoiding or lessening impacts. See DEIR Section 6 for a discussion of alternatives considered. The context of an environmentally superior alternative is based on the consideration of several factors including the reduction of environmental impacts to a less than significant level, the Project objectives, and an alternative’s ability to fulfill the objectives with minimal impacts to the existing site and surrounding environment. Specifically, Alternative 2 would not meet Objective #5.
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L3-54 Comment noted.
L3-55 Refer to response to comment L3-39 regarding carbon offsets.
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Comment Letter T1 – Agua Caliente Band of Cahuilla Indians , Tribal Historic Preservation Office Arysa Gonzalez Romero, Cultural Resources Analyst
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Responses to Comment Letter T1 – Agua Caliente Band of Cahuilla Indians, Tribal Historic Preservation Office
Arysa Gonzalez Romero, Cultural Resources Analyst
T1-1 Comment noted.
T1-2 Comment noted.
T1-3 Comment noted.
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Comment Letter O1 – Adams Broadwell Joseph & Cardozo, Attorneys at Law Sheila M. Sannadan, Legal Assistant
Lorrie J. LeLe, Legal Assistant
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Responses to Comment Letter O1 – Adams Broadwell Joseph & Cardozo, Attorneys at Law Sheila M. Sannadan, Legal Assistant
Lorrie J. LeLe, Legal Assistant
O1-1 Comment noted. Refer to response to comment O1-6 and O1-7 below.
O1-2 Comment noted. Refer to response to comment O1-6 and O1-7 below.
O1-3 Comment noted. This comment does not raise any CEQA related issues but is a public records request. Refer to responses to comments O1-6 and O1-7 below.
O1-4 This comment is a summary of the Project’s description and location. No further response is warranted.
O1-5 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
O1-6 The City responded to the commentor’s request on June 13 th through the 16th and on the 27th.
O1-7 See response to O1-6 above.
O1-8 The commentor’s email correspondence requesting for mailed notice of actions and hearings for the proposed Project has been noted.
O1-9 The proposed Project’s CEQA notice of availability and the DEIR in its entirety is available on the City’s website at https://www.beaumontca.gov/1239/Beaumont -Summit-Station and on State Clearinghouse’s website located at https://ceqanet.opr.ca.gov/2021090378/2 . The City will add the commentor to the Project’s distribution list for any future communications pertaining to the Project.
O1-10 This comment is a summary of the Project’s description and location. No further response is warranted.
O1-11 The City will add the commentor to the Project’s distribution list for any future communications pertaining to the Project.
O1-12 As noted above, the City will provide mail notices of any and all hearings and/or actions related to the Project, but the comme ntor can access the DEIR in its entirety from the websites provided above.
O1-13 Comment noted. Refer to responses to comment s O1-6 and O1-7 above.
O1-14 This letter is a duplicate and was already responded t o. See responses to comments O1-3 through O1-7 above.
O1-15 The commentor’s email correspondence requesting for any and all documents has been noted.
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O1-16 Comment Noted, the comment does not raise any CEQA related issues but is a public records request.
O1-17 This comment is a summary of the Project’s description and location.
O1-18 All the documents referenced, incorporated by reference, and relied upon are listed in Section 9.0, References of the DEIR with links to each respective document, with the exception of the technical studies that ar e incorporated into the DEIR’s appendices. The commentor can view the appendices on the City’s website and click on the URL links provided in Section 9.0 to view the referenced documents.
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Comment Letter O2 – Mitchell M. Tsai, Attorney at Law
Malou Reyes, Paralegal
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Responses to Comment Letter O2 – Mitchell M. Tsai, Attorney at Law Malou Reyes, Paralegal
O2-1 The commentor’s email correspondence and attached letter has been received. The City will put the commentor(s) on the Project’s distribution list for any future communications pertaining to the Project.
O2-2 The proposed Project’s CEQA noticing and the DEI R in its entirety is available on the City’s website at https://www.beaumontca.gov/1239/Beaumont -Summit -Station and on State Clearinghouse’s website located at https://ceqanet.opr.ca.gov/2021090378/2 .
O2-3 Refer to response to comment O2-2. As noted above, the City will put the commentor(s) on the Project’s distribution list for any future communications pertaining to the Project.
O2-4 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
O2-5 This comment is related to the Commentor’s request for public records and does not raise any CEQA related issues . Thus, no further response is warranted.
O2-6 Comment noted. The City provided a response to the commentor on May 9 th, 2022.
O2-7 This comment is related to the Commentor’s request for public records and does not raise any CEQA related issues.
O2-8 This comment is related to the Commentor’s request for public records and does not raise any CEQA related issues.
O2-9 This comment is related to the Commentor’s request for public records and does not raise any CEQA related issues.
O2-10 The City will put the commentor(s) on the Project’s distribution list for any future communications pertaining to the Project.
O2-11 The commenter is requesting a copy of Section 4.0, Environmental Impact Analysis of the DEIR. The City sent the commenter a digital copy of Section 4.0 via email on April 21, 2022.
O2-12 The City appreciates the commentors comments and will the commentor(s) on the Project’s distribution list for any future communications pertaining to the Project.
O2-13 The comment suggests that the Applicant provide additional community benefits such as requiring local hire and use of a skilled and trained workforce for the Proje ct. However, this isn’t a requirement under CEQA or the City of Beaumont. However, your comment will be taken into consideration by decision-makers.
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O2-14 This comment suggests that the Project require a percentage of workers to reside within 10 miles of t he Project site to reduce trip lengths, reduce GHG emissions, and provide local economic benefits. The Project would produce more jobs and therefore would support the improvements designated by S in pursuit of an improved jobs -housing -balance for the County.
Because the region is housing -rich, it is expected that jobs at the Project site would be drawn from the local and regional labor force. However, this is not a requirement of CEQA or the City Beaumont .
O2-15 This comment states the importance of developing a skilled workforce to the economy and states that well trained workers are key to delivering emissions reductions. However, this comment fails to make a connection between these two statements and does not explain how training workers will reduce GHG emissions .
O2-16 This comment references a clarification of WAIRE Mitigation Plan Guidelines issued during SCAQMD Board Meeting on May 7, 2021 which states the use of local state certified apprenticeship programs or skilled workforce with a local h ire component can be counted as points toward WAIRE compliance. The comment also notes that the City of Hayward 2040 General Plan supports local hire incentives.
The South Coast AQMD Rule 2305 requires warehouses to achieve their WAIRE Points Compliance Obligation (WPCO). As stated previously, the Project can include a local hire component to generate points toward achieving the WPCO, however this is not required. In addition, the Project is located in the City of Beaumont, not in the City of Hayward. The City does not provide incentives for local hires or require a Project to hire local workers.
O2-17 As noted in response to comment O2-16, the Project is located in the City of Beaumont, not the City of Hayward. The City does not provide incentives for loca l hires or require a Project to hire local workers.
O2-18 The comment suggests that local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. However, this comment fails to make a connection between t hese two statements and does not explain how training workers will reduce VMT impacts. Refer to Section 4.15, Transportation , which discusses the Project’s proposed TDMs that would help reduce VMT-related impacts.
O2-19 Refer to responses O2-13 through O2-18. The comment also suggests that the Project be built to standards exceeding the current 2019 California Green Building Code to mitigate the Project’s environmental impacts and to advance progress towards the State of California’s environmental goals. This comment is vague and doesn’t explain why or how adhering to standards exceeding the 2019 CGB SC would mitigate environmental impacts. The City has adopted the 2019 CGBSC which the Project would be developed consiste ntly with. Note that the new 2022 California Building Standards Code will be published July 1, 2022, with an effective date of January 1, 2023. The project will comply with the 2022 California Building Standards Codes in-place at the time of construction.
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O2-20 Comment Noted – the Comment recites the purpose of CEQA and does not raise any comments specific to the DEIR .
O2-21 CEQA does not require disease specific analysis that Commentor is requesting and requiring a disease specific analysis or finding of significance is not require d or warranted for COVID -19.
The Project is required to comply with applicable health and safety rules and at the time the Project is under construction and operation COVID -19 protocols will be adhered to as required at that time.
O2-22 COVID -19 protocols are continually changing. As discussed in O-21 above, the Project is required to comply with applicable health and safety codes and to the extent that COVID -19 protocols are required at that time, they will be implemented as applicable.
O2-23 Comment noted. This comment refers to work at a healthcare facility which is not being proposed at this location.
O2-24 This comment notes that CEQA Guidelines require discussions of potentially significant effects must provide adequate analysis to inform the public of potential adverse effects. The comment then goes on to acknowledge the EIR identified three locations where noise impacts would be significant and unavoidable, and the comment suggests that the EIR does not explain what mitigation measures were considered and why they were determined not to be feasible.
However, page 38 of Appendix J, Noise Assessment states that traffic noise could exceed interior noise standards if windows were left open and identifies typical off -site roadway noise mitigation and explains why they are not feasible.
• Rubberized asphalt could be used to repair impacted roads. This mitigation could only be imposed on on-site roadways since the Applicant does not have authorization or control to make off-site improvements. Therefore, applying rubberized asphalt to off-site roadways is not feasible.
• Sound walls or noise attenuation barriers could be constructed to reduce road noise. This mitigation measure was found to be infeasible because sound walls or barriers would restrict right of way and impact views.
O2-25 As shown on page 6 of the VMT memo (Dated February 1, 2022), the Project would provide transportation demand management (TDM)/VMT Mitigation Measures as noted below:
• Provide a transportation information center and on-site TDM coordinator to educate residents, employers, employees, and visitors of surrounding transportation options. • Promote bicycling and walking through design features such as showers for employees, self- service bicycle repair area, etc. around the Project site. • Each building shall provide secure bicycle storage space equivalent to two percent of the automobile parking spaces provided.
• Each building shall provide a minimum of two shower and changing facilities within 200 yards of a building entrance.
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• Provide on-site car share amenities for employees who make only occasional use of a vehicle, as well as others who would like occasional access to a vehicle of a different type than they use day-to-day.
• Promote and support carpool/vanpool/ridesha re use through parking incentives and administrative support, such as ride-matching service.
• Incorporate incentives for using alternative travel modes, such as preferential load/unload areas or convenient designated parking spaces for carpool/vanpool users . • Provide meal options onsite or shuttles between the facility and nearby meal destinations. • Each building shall provide preferred parking for electric, low‐emitting and fuel -efficient vehicles equivalent to at least eight percent of the required number of parking spaces.
O2-26 This comment addresses health risk impacts associated with sensitive receptors. The comment notes that chronic and acute noncancerous impacts would be reduced by MM AQ-1 through AQ-6 and states that the EIR does not explain how the a nalysis was done. However, the health risk analysis is discussed in detail on pages 23 through 30 of the Health Risk Assessment included in Appendix B, Health Risk Assessment. In addition, the comment fails to acknowledge that chronic and acute noncancerous impacts were already below the threshold prior to mitigation, and that the mitigation required to reduce cancer risk to less than significant would result in a further reduction of chronic and acute impacts.
O2-27 Commentor provides an overview of the r equirement of a City’s General Plan. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers .
O2-28 The comment correctly states that CEQA requires the DEIR to analyze the Project for consistency with the City’s General Plan, specific plans and regional plans. Section 4.10, Land Use and Planning , of the DEIR includes the consistency analysis that includes the City’s General Plan (including housing element) as well as SCAG’s Regional Transportation Plan and Sustainable Community Strategy. Commentor does not raise any specific issues related to that analysis but a blanket statement which is noted.
O2-29 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers .
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Comment Letter O3 – Adams Broadwell Joseph & Cardozo, Attorneys at Law Tara C. Rengifo, Alisha C. Pember
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Responses to Comment Letter O3 – Adams Broadwell Joseph & Cardozo, Attorneys at Law Tara C. Rengifo, Alisha C. Pember
O3-1 Commentor is providing background for their request to extend the public review period.
Comment noted.
O3-2 Comment noted. The City made available all documents relied upon in the DEIR.
O3-3 Commented noted. The commentor is reciting the public resources code and does not raise any substantive issues related to the DEIR.
O3-4 See response to comment O3-20 below.
O3-5 See response to comment O3-20 below.
O3-6 See response to comment O3-20 below.
O3-7 See response to comment O3-20 below.
O3-8 See response to comment O3-20 below.
O3-9 Comment noted.
O3-10 Comment noted. All documents referenced or relied upon for the DEIR analysis were included in Section 9.0, References , and as appendices. In addition, refer to response to comment O3-20 below for more information.
O3-11 Comment noted. The comment does not raise any issues with the DEIR as detailed in response to comment O3-20 below.
O3-12 Refer to response to comment O3-10 above.
O3-13 Refer to response to comment O3-10 above.
O3-14 Refer to response to comment O3-10 above. Additionally, the DEIR comment period complied with CEQA requirements.
O3-15 Refer to response to comment O3-10 above. The DEIR included all documents relied upon for the Project ’s environmental impact analysis .
O3-16 See response to comment O3-20 below.
O3-17 Comment noted.
O3-18 All documents relied upon in the DEIR analysis were included in Section 9.0, References , of the DEIR and as appendices to the DEIR. Refer to response to comment O3-20.
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O3-19 Comment noted.
O3-20 Comment noted. Refer to the following responses. • Development agreement is currently being drafted. The Development Agreement is a contract between the City and Developer related to the Project that is analyzed in the DEIR. • As noted in page 28 of Appendix A , footnote eight and nine states “Conservatively assumes nine yard trucks each operating 8 hours per day (i.e., less than the nine trucks each operating 12 hours per day assumed for the emissions analysis). Note that this calculation is preliminary and provided for informational purposes. The WAIRE Points Compliance Obligation is determined by the actual number of truck trips to the facility based on logs of truck trips submitted on January 1 after the first year of operation. The trip rates that SCAQMD uses in the WAIRE User Calculator would be slightly different than what is used in the Project’s Traffic Study.”
• This comment requests the City provide the original native files for AERMOD used in the health risk assessment. However, all the requested information is included in the DEIR as Appendix B, Health Risk Assessment . Starting on page 51 and concluding on page 2,314, Appendix B includes all the AERMOD input data for each mitigated and unmitigated scenario analyzed in the DEIR. In addition, Appendix B also includes the AERMOD results and output files.
• The City sent the commentor the requested Phase II Environmental Site Assessment (ESA)document on June 6, 2022. Also note that the Phase II ESA was prepared for the previous EIR and the proposed Project is not tiering of the previous EIR. Therefore, the Phase II ESA document referenced in Appendix G, Phase I ESA for the Project does not affect the adequacy of the DEIR concerning hazards and hazardous materials.
O3-21 The requested information can be found in the County of Riverside’s Transportation Analysis Guidelines for Level a nd Service and Vehicle Miles Traveled – 2020, as noted in the Traffic Impact Analysis (Appendix K ). That document can be found at the following link:
https://rctlma.org/Portals/7/2020-12-15%20-
%20Transportation%20Analysis%20Guidelines.pdf
O3-22 The commenter is requesting tha t the City extend the public review and comment period for the proposed project for at least 45 days minimum because the City didn’t make all documents referenced in the DEIR available to the public for the duration of the public comment period.
The City respectively declines this request since all documents referenced in the EIR were made available to the were provided for in Section 9.0, References via URL links. Refer to response to comment O3-20 for additional information.
O3-23 Comment noted.
O3-24 Refer to response to comment O3-20.
O3-25 Refer to response to comment O3-22.
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O3-26 Comment noted.
O3-27 Refer to response to comment O3-22.
O3-28 Refer to responses to comments to O3-1 through O3-18.
O3-29 Comment noted.
O3-30 The City responded to this email on June 3rd letting the commenter know that the public review period closes on June 6, 2022 and expressed that the public review period of the DEIR would not be extended.
O3-31 Refer to response to comment O3-20 above.
O3-32 Refer to response to comment O3-30 above.
O3-33 Comment noted.
O3-34 The comment is referring to the Project’s proposed development, open space component, proposed entitlements, associated on-site and off-site improvements, and assessor parcel numbers associated with the Project site.
O3-35 The commentor states that the DEIR fails in significant aspects to perform its function as an informational document because 1) the DEIR’s project objectives are impermissibly narrow and improperly constrain the alternat ives analysis; 2) the DEIR dismisses the environmentally superior alternative without adequate analysis; 3) the DEIR must analyze a 55% reduced Project size, which would substantially reduce significant impacts, as supported by the attached expert comments ; and 4) the Development Agreement may improperly constrain the Project’s Alternative Analysis. Refer to responses to comments O3-43 through O3-57 for more information.
O3-36 The comment states that the DEIR omits an analysis of air quality impacts from tr ansport refrigeration units (TRUs) and states that use of TRUs are reasonably foreseeable. However, as noted in the DEIR Project Description (page 3-4) and PDF AQ-1, the Project does not include cold storage. Additionally, cold storage is not an allowed us e for the site in the Specific Plan, which establishes the uses and development standards for the Project. As cold storage/refrigerated warehouse space are not an allowed use, the Project could not include cold storage and would not include trucks with TRU s.
O3-37 The comment includes a general statement that there are additional feasible mitigation measures and omissions in the VMT analysis and summarizes later more specific comments.
This comment is introductory, and no specific comments are made. Respon ses to specific comments are provided below. No further response is required.
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O3-38 The commented states that the DEIR also fails to meaningfully analyze the Project’s impacts on water supply and that Project’s impacts on biological resources are not adequately disclosed and mitigated in the DEIR.
O3-39 The commentor states that based on their previous statements, the DEIR omits critical information necessary to inform the impact analysis, and therefore, the DEIR must be revised and recirculated. Comment noted and will be taken into consideration by decision-makers.
O3-40 The commentor listed the references used to support their statements. Comment has been noted.
O3-41 CARECA’s statement of interest of the proposed Project has been noted.
O3-42 Comment noted. Commentor is reciting the purpose of CEQA and does not raise any substantive issues with the DEIR.
O3-43 The Project description in the DEIR has not changed and is stable throughout the documents and exhibits. While the buildings are spec buildings, the use of the building as a warehouse will not change once the building is occupied.
O3-44 See response to comment O3-47 below.
O3-45 See response to comment O3-47 below.
O3-46 See response to comment O3-47 below.
O3-47 The Development Agreement is not required to be included in the DEIR, as the commentor states the Development Agreement is a contract between the City and D eveloper. The terms of a Development Agreement are routinely negotiated during the EIR process for the Project that is analyzed in the DEIR.
O3-48 Section 3.0, Project Description , of the DEIR (page 3-7) includes detailed Project objectives as required by CEQA.
O3-49 Project objectives can be tailored to the site and also take into consideration the site details for the efficient use of the property. The DEIR included a number of very detailed project objectives under which the Project and project alternatives are considered. Here the environmentally superior project alternative was rejected.
O3-50 Section 6.0, Alternatives , of the DEIR includes a detailed analysis of the Project alternatives as required by CEQA. The analysis concludes that the reduced intensity alternative would reduce some of the potentially significant impacts, but it does not reduce any significant impacts to below a level of significant. Since the reduced intensity alternative will not reduce any of the significant impacts , and does not meet the Project objectives , the alternative was dismissed.
O3-51 See response to comment O3-50 above.
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O3-52 See response to comment O3-50 above.
O3-53 CEQA does not specify the number or details for project alternatives included in an EIR.
O3-54 CEQA does not require a project alternative be created and evaluated so that it reduces a significant impact to below the significance threshold as suggested by the commentor. The project alternatives included in the DEIR comply with CEQA and no furt her alternatives are required.
O3-55 See response to comment O3-54 above.
O3-56 See response to comment O3-47 above.
O3-57 See response to comment O3-47 above.
O3-58 Commentor recites general CEQA requirements that the DEIR complies with. No specific comments are raised specific to the DEIR analysis or mitigation.
O3-59 Commentor does not raise any specific comments on the DEIR but reiterates a generalized statement regarding the details and information required to be included in an EIR. The DEIR was prepared in accordance with CEQA and includes all of the commentors requested information and analysis.
O3-60 The comment summarizes the commenters view of regional air quality in the area including data from the SCAQMD 2022 Draft AQMP and the DEIR. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O3-61 The comment summarizes the commenters view of regional air quality in the area including data from the SCAQMD 2022 Draft AQMP and the DEIR. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessa ry.
O3-62 The comment summarizes the commenters view of statewide NOX emissions, CARB data, and also states that the Project’s unmitigated NOX emissions are significant. The comment does not raise a specific issue with the DEIR. Responses to specific comme nts are provided below.
O3-63 Refer to response to comment O3-36 regarding TRU emissions. The Project would not include TRUs because cold storage is not an allowed use in the Specific Plan and the DEIR Project Description specifically states that the Project does not include cold storage.
Regarding PDF AQ-4 and PDF AQ-10, the DEIR states that emissions benefits from implementation of PDF AQ-3 through PDF AQ-18 are conservatively not quantified (DEIR pages 3-4, 4.2-22, 4.5-20, and 4.7-29). No credit is taken for these measures. These measures are intended to facilitate the implementation of state regulations and goals that would encourag e fleet turnover and improve emissions.
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The City disagrees with the comment about the effectiveness of MM AQ-3 (requiring a Transportation Demand Management [TDM] program for Phase 1 and Phase 2). As discussed in the DEIR, MM AQ-3 requires a transportation information center, an on-site TDM coordinator to inform employees of surrounding transportation options, promoting bicycling and walking with showers and bicycle repair areas, providing secure bicycle storage, providing shower and changing facilities, provide on-site car share amenities, promote carpool/vanpool/rideshare use through parking incentives and ride -matching services, provide incentives for alternative travel modes, provide meal options onsite or shuttles to nearby meal destinations, and preferential parking for electric low -emitting, and fuel-efficient vehicles. In this case, the performance standard is to provide the above -mentioned amenities and services to encourage trip reduction. Information sharing and marketing are important components to successful commute trip reduction strategies. Furthermore, the measures in MM AQ -3 include specific performance standards, such as requirements for installing two showers/changing facilities within 200 yards of a building entrance for each building and providing preferential parking equivalent to at least eight percent of the required number of parking spaces.
MM AQ-3 notes that the TDM program shall be developed and verified by the City prior to the issuance of occupancy permits. Also refer to response to comment O3-76.
The City disagrees that MM AQ -1 (requiring Tier 4 construction equipment) needs to be strengthened. The comment does not suggest modifications to MM AQ-1 and does not provide substantial evidence demonstrating it is deficient. It should be noted that construction emissions from both Phase 1 and Phase 2 would be below SCAQMD’s construction thresholds for all criteria pollutants (see DEIR Table 4.2-8 and Table 4.2-9). Construction and operational health risk impacts would also be less than s ignificant (see DEIR pages 4.2-50 to 4.2-55). There is no nexus to require modifications to MM AQ-1 as Phase 1 or Phase 2 construction impacts are already reduced to a less than significant level with the implementation of MM AQ -1. Also refer to response to comment O3-78.
O3-64 The comment cites a provision in MM AQ -4 that allows for sufficiently sized electrical rooms that could accommodate power for TRUs. The intent of this measure is to identify all feasible mitigation and to provide flexibility to accommodate future technologies and electrification.
MM AQ -4 does not permit any TRUs to access the site and does not permit any cold storage building area. As noted in response to comment O3-6, the Project would not include TRUs because cold storage is not an allowed use in the Specific Plan and the DEIR Project Description specifically states that the Project does not include cold storage.
O3-65 Standard Condition AQ-1 requires the implementation of fugitive dust control measures in accordance with SCAQMD rules and regulations. Watering disturbed areas is a primary method for reducing fugitive dust. However, as noted in Standard Condition AQ-1 and reiterated in the comment, the listed measures include, but are not limited to those listed.
Furthermore, Beaumont -Cherry Valley Water District Resolution 2022-12 restricts the use of potable water for street cleaning or construction site preparation purposes unless no other method can be used to protect public health and safety. Additionally, the resolution notes that the use of water during construction can be conditionally approved. It should be noted that
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recycled (i.e., non-potable) water is commonly used for construction in additional to chemical stabilizers and the use of tarps and wind breaks. Standard Condition AQ-1 requires compliance with SCAQMD Rule 402 (Nuisance) and Rule 403 (Fugitive Dust) and does not require the use of potable water during construction. Therefore, Beaumont -Cherry Valley Water District Resolution 2022-12 would not result in additional fugitive dust emissions during Project construction.
O3-66 Refer to response to comment O3-65 regarding Beaumont -Cherry Valley Water District Resolution 2022-12 and construction related fugitive dust.
O3-67 Refer to response to comment O3-65 regarding Beaumont-Cherry Valley Water District Resolution 2022-12 and construction related fugitive dust.
O3-68 Refer to response to comment O3-65 regarding Beaumont -Cherry Valley Water District Resolution 2022-12 and construction related fugitive dust.
O3-69 Refer to response to comment O3-65 regarding Beaumont -Cherry Valley Water District Resolution 2022-12 and construction related fugitive dust.
O3-70 The comment summarizes the commenters view of the CEQA guidelines. The comment does not raise a specific issue wit h the adequacy of the DEIR or raise any other CEQA issue.
Therefore, no further response is necessary.
O3-71 The comment summarizes the commenters view of the DEIR. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O3-72 PDF AQ-4 is included as a Project Design Feature to facilitate implementation of the CARB Truck and Bus Regulation and to encourage other efficiency measures could incentivize near zero emission (NZE) or zero emission (ZE) truck visits, which would also facilitate compliance with SCAQMD Rule 2305 (Warehouse Indirect Source Rule). Therefore, it is not appropriate or necessary to include PDF AQ-4 as a mitigation measure. It should be noted t hat the DEIR states that emissions benefits from implementation of PDF AQ-3 through PDF AQ-18 are conservatively not quantified (DEIR pages 3 -4, 4.2-22, 4.5-20, and 4.7-29). No credit is taken for these measures. As noted above, these measures are intended to facilitate the implementation of state regulations and goals that would encourage fleet turnover and improve emissions.
O3-73 The comment suggests mitigation requiring all heavy-duty vehicles entering or operating on the Phase 1 Project site to be model year 2018 or later. However, CARB is addressing emissions from heavy duty vehicles through various regulatory programs including lower emission standards, restrictions on idling, the use of post‐combustion filter and catalyst equipment, and retrofits for diesel truck fleets. These programs are expected to result in significant reductions in NOX, ROG, PM10, PM2.5, and CO emissions as they are fully implemented by 2023. Federal and State agencies regulate and enforce vehicle emission standards. It is not f easible for the
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City of Beaumont to effectively enforce a prohibition on trucks from entering the property that are otherwise permitted to operate in California and access other properties in the City, region, and State. Even if the City were to apply such a restriction, it would cause warehouse operators using older truck fleets to travel to other facilities in the South Coast Air Basin where the restriction does not apply, thereby resulting in no improvement to regional air quality.
Based on data from CARB, most heavy‐duty trucks entering the Project site will meet or exceed 2010 model year emission standards when Phase 1 becomes fully operational in 2024.
Specifically, according to CARB EMFAC inventories, approximately 50 percent of all instate heavy‐heavy duty trucks met the 2010 engine standard in 2019, 59 percent in 2020, 62 percent in 2021. Additionally, 65 percent and 90 percent of trucks were projected to meet the 2010 engine standard in in 2022 and 2023 respectively.1
Requiring model year 2018 trucks or later to operate on the Phase 1 of the Project site would not be consistent with CARB and SCAQMD programs to transition to zero emission (ZE) or near zero emission (NZE) trucks. For example, CARB’s Advanced Clean Truck R egulation requires truck manufacturers to transition from diesel trucks and vans to electric zero -emission trucks beginning in 2024. By 2045, every new truck sold in California is required to be zero -emission.
The Advanced Clean Truck Regulation accelerate s the transition of zero-emission medium-and heavy-duty vehicles from Class 2b to Class 8. CARB’s Mobile Source Strategy facilitates the adoption of ZE buses and trucks. Additionally, CARB’s Sustainable Freight Action Plan utilizes near-zero emissions technology and facilitates the deployment of ZE trucks. Furthermore, the SCAQMD Warehouse Indirect Source Rule (ISR) (Rule 2305) requires the acquisition of ZE or NZE trucks, requires ZE/NZE truck visits, requires ZE yard trucks, and the installation on -site ZE charging/fueling infrastructure, or pay a mitigation fee to incentivize the purchase of ZE/NZE trucks and charging/fueling infrastructure in communities nearby.
The DEIR includes design features and mitigation that would facilitate the use of ZE and NZE trucks consistent with CARB and SCAQMD programs (e.g., Advanced Clean Truck Regulation, Sustainable Freight Action Plan, SCAQMD Rule 2305, etc.). For example, the Project design features require all cargo handling equipment (forklifts, yard trucks, etc.) to be electrically powered to reduce on-site criteria pollutant emissions. In order to promote the use of alternative fuels and clean fleets and facilitate future installation of electric vehicle supply equipment, the Project would install 30 electric light-duty vehicle charging stations, install conduit for 59 electric light -duty vehicle charging stations, and designate 119 parking spaces for clean air/electric vehicle/vanpool parking (refer to the Project design feature on DEIR pages 4.2-22 through 4.2-24). Additionally, the Project design features would require future tenants to attend CARB training for record keeping and ensuring vehicles comply with CARB regulations and are in good condition, enroll in the EPA’s SmartWay program, provide information on CARB’s Carl Moyer Voucher Incentive Program to upgrade fleets, include signage for truck routes and locate check-in points to ensure truck queues do not occur outside of the facility. MM AQ-6 requires Project compliance with SCAQMD Rule 2305 to facilitate the use of ZE and NZE trucks. Additionally, MM AQ-6 requires the Project Applicant to provide
1 CARB. (2017). EMFAC2017, An Update to California On-Road Mobile Source Emissions Inventory . Available at:
https://ww3.arb.ca.gov/msei/downloads/emfac2017_workshop_11_09_2017_final.pdf (accessed June 2022).
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$1.00 per square foot in funding for fleet upgrade financing to incentivize the use of cleaner operating trucks to reduce future emissions and includes a goal of achieving ZE trucks beginning in 2030. It should be noted that the DEIR conservatively does not take credit for implementation of MM AQ -6.
Operational emissions would be reduced through implementation of mitigation measures that require reduced vehicle idling, use of non-diesel on-site equipment, meeting or exceeding 2010 engine emission standards for all diesel trucks entering the site, electric vehicle charging stations, and prohibition of refrigerated warehouses. As noted above, mitigation and Project design features would facilitate the use of ZE and NZE technology.
The City disagrees with the assertion that the DEIR has not identified all feasible mitigation.
The existing regulatory environment already requires various mobile source emissions reduction measures and transition to ZE and NZE vehicles (as noted above, CARB already regulates truck emissions with the Advanced Clean Truck Regulation, the Mobile Source Strategy [including the low-NOX engine emissions standard], the Sustainable Freight Action Plan, and the Emissions Reduction Plan for Ports and Goods Movement, among others).
Despite these strategies, CARB acknowledges that it will take time for ZE and NZE vehicles to become commercially available and to penetrate the market. For example, CARB’s EMission FACtor (EMFAC) 2021 model provides detailed vehicle registration information and estimates the official emissions inventories of on-road mobile sources, vehicle population, and vehicle miles traveled (VMT) in California. The EMFAC2021 data for Sou th Coast portion of Riverside County shows that in 2024 (the Project’s opening year), approximately 95 percent of heavy trucks would still be powered by diesel and 97 percent of the VMT would occur from diesel trucks. Electric vehicles would make up approx imately 0.31 percent of the heavy-duty fleet and
0.26 percent of the heavy truck VMT. For 2030, the EMFAC data shows that 95 percent of heavy trucks would be diesel-powered and that 96 percent of the heavy truck VMT would be from diesel trucks. Therefore, as CARB data anticipates that the vast majority of trucks to be diesel - powered in the Project opening year and in 2030, it would not be feasible to require all heavy - duty vehicles entering or operating on the Project site to be zero -emission beginning in 2030.
ZE and NZE truck technologies include battery-electric trucks, fuel cell trucks, dual-mode (hybrid) electric trucks with all-electric range and, potentially, other technologies. While heavy duty ZE vehicles are available, they are not commercially ava ilable yet in great numbers in the classifications needed to serve the future users of this site. The majority of ZE and NZE emissions trucks are limited in range of less than 100 miles per charge and require hours to charge.2 These trucks are better suit ed to operate in urban areas for stop-and-go driving for fleets that operate locally and have predictable daily use and return to base to be charged.3 Longer range, heavy duty ZE vehicles currently are limited in availability.4 To require a project to us e ZE heavy duty trucks when the nature of the trips is unknown these types of
2 CARB. (2021) Advanced Clean Trucks, Acceleration Zero-Emission Truck Markets. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-06/200625factsheet_ADA.pdf (accessed June 2022). 3 Ibid.
4 John G. Smith (2020). Zero-emission truck models surge, orders hold steady during Covid-1. Available at:
https://www.trucknews.com/sustainability/zero-emission-truck-models-surge-orders-hold-steady -during-covid-19/1003141253/ (accessed June 2022).
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technologies is not feasible because they are not widely available, and it is unknown when or if they will become widely available in the future. As such, it is not feasible to r equire ZE and NZE trucks because future tenants/operators are currently unknown. As the timeline for ZE and NZE incorporation into the fleet is not known and the end users and truck fleets are not known, the additional mitigation is not feasible, and assum ptions on the available of ZE and NZE vehicles would be speculative at best. CEQA Guidelines Section 15041 specifically requires all mitigation to be feasible and fully enforceable, and all feasible mitigation must be imposed by lead agencies.
Furthermore, it should be noted that the DEIR determined that the Project’s Localized Significance Thresholds (LSTs) would be less than significant (refer to DEIR pages 4.2 -42 through 4.2-46) and health risk impacts would be less than significant (refer to DEIR pages 4.2-50 through 4.2-55), which indicates that the regional increases shown in DEIR Tables 4.2-10 through 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin.
Although as noted above, ZE and NZE trucks are not commercially available at this time, current state regulations would accelerate availability of this technology in future years. CARB’s Advanced Clean Truck Regulation requires truck manufacturers to transition from diesel trucks and vans to electric zero-emission trucks beginning in 2024 and by 2045, every new truck sold in California is required to be zero-emission. CARB’s Mobile Source Strategy takes an integrated planning approach to identify the level of transition to cleaner mobile source technolog ies needed to achieve all of California’s targets by increasing the adoption of ZEV buses and trucks.
A key measure in the Mobile Source Strategy is the low NOX emission standards that reduces NOX emissions by 90 percent.5 The Sustainable Freight Action Plan which improves freight system efficiency, utilizes near -zero emissions technology, and deployment of ZEV trucks. The Sustainable Freight Action Plan applies to all trucks accessing the Project site and may include existing trucks or new trucks that are part of the Statewide goods movement sector. CARB’s Emissions Reduction Plan for Ports and Goods Movement identifies measures to improve goods movement efficiencies such as advanced combustion strategies, friction reduction, waste heat recovery, and elect rification of accessories.
The Project is being built to specification and the future tenant(s) of the Project are unknown at the time of this writing. Accordingly, it is unknown if the ultimate tenant will operate its own fleet. Moreover, most warehouse operators have no control over the trucks entering and exiting their facilities. Consequently, it is infeasible to require trucks with particular emission profiles (e.g., ZE, NZE, or 2010+ model year trucks) to visit the Project.
Subsequent environmental review may require that specific technology that will work with future users be required as condition of approval, but a broad requirement that unknown future users use a specific technology is not currently feasible since current zero -emission technology is very limited in medium-duty and heavy-duty trucks.
O3-74 PDF AQ-10 facilitates implementation of PDF AQ-16, where the Project would provide funding for 30 grants for the employee purchase of electric/zero emission passenger vehicles. The
5 CARB. (2022). Heavy Duty Low NO X. Available at: https://ww2.arb.ca.gov/our -work/programs/heavy-duty -low-nox. (accessed June 2022).
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30 charging stations required in PDF AQ-10 are intended to primarily serve the electric vehicles provided to employees for the purpose of commuting. As noted in response to comment O3-73, the design features are designed to facilitate the use of ZE and NZE trucks consistent with CARB and SCAQMD programs (e.g., Advanced Clean Truck Regulation, Sustainable Freight Action Plan, SCAQMD Rule 2305, etc.). MM AQ-6 requires Project compliance with SCAQMD Rule 2305 to facilitate the use of ZE and NZE trucks. Additionally, MM AQ -6 requires the Project Applicant to provide $1.00 per square foot in funding for fleet upgrade financing to incentivize the use of cleaner operating trucks to reduce future emissions and includes a goal of achieving ZE trucks beginning in 2030. It should be noted that the DEIR conservatively does not take credit for implementation of MM AQ-6.
The comment also suggests additional measures for incorporation into the DEIR. The discussion below provides a response to each of the suggested measures. As shown below, the suggested are already addressed in the DEIR or are CARB regulations that the Project must already comply with. Therefore, additional mitigation is not required.
Suggested Measure Response
Contractual language in tenant lease
agreements that requires future tenants to
exclusively use zero-emission light and
medium-duty delivery trucks and vans.
As noted above, the Project includes Project design
features and mitigation that would facilitate the use
of ZE and NZE vehicles consistent with CARB and
SCAQMD programs (e.g., Advanced Clean Truck
Regulation, Sustainable Freight Action Plan,
SCAQMD Rule 2305, etc.).
MM AQ-6 requires Project compliance with
SCAQMD Rule 2305 to facilitate the use of ZE and
NZE trucks. Additionally, MM AQ-6 requires the
Project Applicant to provide $1.00 per square foot
in funding for fleet upgrade financing to incentivize
the use of cleaner operating trucks to reduce future
emissions and includes a goal of achieving ZE trucks
beginning in 2030. It should be noted that th e DEIR
conservatively does not take credit for
implementation of MM AQ-6.
Additionally, PDF AQ-2 requires all Phase 1 outdoor
cargo handling equipment (including yard trucks,
hostlers, yard goats, pallet jacks, and forklifts) shall be powered by electricity (i.e., zero emission).
Include contractual language in tenant lease
agreements that requires all heavy-duty trucks
entering or on the project site to be model
year 2018 or later, expedite a transition to
zero-emission vehicles, and be fully zero-
emission beginning in 2023. A list of
commercially available zero -emission trucks
can be obtained from the Hybrid and Zero-
emission Truck and Bus Voucher Incentive
Project (HVIP). Additional incentive funds are
available from the Carl Moyer Program and
Voucher Incentive Program.
Refer to response to comment O3 -73 regarding
2018 model year trucks. Additionally, PDF AQ-13
requires the Phase 1 facility operator to provide
tenants with information about the Carl Moyer Air
Program and the On-Road Heavy-Duty Vehicles
Voucher Incentive Program, which provides funding
to purchase newer vehicles.
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Suggested Measure Response
Include contractual language in tenant lease
agreements that requires the tenant to be in,
and monitor compliance with, all current air
quality regulations for on -road trucks
including CARB’s Heavy-Duty (Tractor -Trailer)
Greenhouse Gas Regulation, Advanced Clean
Trucks Regulation, Periodic Smoke Inspection
Program (PSIP), and the Statewide Truck and
Bus Regulation.
This is required under PDF AQ -9 on DEIR page 4.2-
23. Operators and manufacturers are required to
comply with these regulations. CARB’s Tractor-
Trailer Greenhouse Gas Regulation reduces
greenhouse gas emissions by improving the
aerodynamic performance and reducing the rolling
resistance of tractor -trailers. CARB’s Advanced
Clean Trucks regulation is a manufacturer’s ZEV
sales requirement and a one -time reporting
requirement for large entities and fleets. The
Periodic Smoke Inspection Program (PSIP) is CARB's
heavy-duty vehicle inspection program for in -use
trucks and buses that includes roadside testing by
CARB. The Statewide Truck and Bus Regulation
requires fleets to upgrade to 2010 or newer model
year engines by January 1, 2023. The suggested
additional mitigation measures are already State
regulation (i.e., mandatory ). As such these
measures are essentially part of the Project; and
therefore, are not mitigation under CEQA.
Include contractual language in tenant lease
agreements restricting trucks and support
equipment from idling longer than two
minutes while on site.”
The Project would comply with the 5 -minute limit
per CARB regulation/state law. Implementation of
this measure is not quantifiable because CalEEMod
does not allow for the adjustment of idle times. The
Project includes MM AQ-5 requires signage stating
that drivers turn off engines when not in use,
identifying the State’s 5 -minute idling limit
(California Code of Regulations, Title 13, Division 3,
Article 1, Chapter 10, Section 2485 [Airborne Toxic
Control Measure to Limit Diesel-Fueled Commercial
Motor Vehicle Idling]), and including telephone
numbers of the building facilities manager and CARB
to report violations.
Additionally, the Project includes design features to
minimize idling. For example, PDF AQ -5 requires
Phase 1 facility operators to train managers a nd
employees on efficient scheduling and load
management to eliminate unnecessary queuing and
idling of trucks. PDF AQ -8 requires the facility
operator for Phase 1 to ensure that site
enforcement staff in charge of keeping the daily log
and monitoring for excess idling will be
trained/certified in diesel health effects and
technologies, for example, by requiring attendance
at California Air Resources Board-approved courses
(such as the free, one-day Course #512).
O3-75 The City disagrees with the assertion that the DEIR defers mitigation as it relates to MM AQ-3 (TDM Program). MM AQ-3 would be properly implemented as required by the City and as part of the Mitigation Monitoring and Reporting Program, as enforced by the P lanning Manager.
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Therefore, there are assurances that reductions in commute VMT through feasible TDM measures would be provided by the Project and would be implemented as part of future Certificates of Occupancy for future tenants as described in MM AQ-3. Therefore, the City did not defer mitigation and has stated within MM AQ-3 in the D EIR the mitigation measures required to mitigate potentially significant impacts.
O3-76 As discussed on DEIR pages 4.2-21 and 4.7-28, TDM measures were incorporated and quantified in CalEEMod’s mitigation module. The DEIR specifies that measures TRT -1 (Implement Trip Reduction Program), TRT -7 (Market Commute Trip Reduction Option), and TRT-11 (Employee Vanpool/Shuttle) were applied. According to the California Air Pollution C ontrol Officers Association (CAPCOA) guidance Quantifying Greenhouse Gas Mitigation Measures (2011), TRT -1 is a voluntary measure where monitoring and reporting is not required. The performance standards include carpooling encouragement, ride -matching assistance, preferential carpool parking, flexible work schedules for carpools, half time transportation coordinator, vanpool assistance, and bicycle end -trip facilities (parking, showers and lockers). The TRT -7 performance standard is providing information of trip reduction and alternative mode options in the area. TRT -11 requires an employer-sponsored vanpool or shuttle. As discussed in the DEIR, MM AQ -3 requires a transportation information center, an on-site TDM coordinator to inform employees of surrounding transportation options, promoting bicycling and walking with showers and bicycle repair areas, providing secure bicycle storage, providing shower and changing facilities, provide on -site car share amenities, promote carpool/vanpool/rideshare use through parking incentives and ride- matching services, provide incentives for alternative travel modes, provide meal options onsite or shuttles to nearby meal destinations, and preferential parking for electric low -emitting, and fuel-efficient vehicles.
In this case, the performance standard is to provide the above -mentioned amenities and services to encourage trip reduction. Information sharing and marketing are important components to successful commute trip reduction strategies. Furthermore, the measures in MM AQ-3 include specific performance standards, such as requirements for installing two showers/changing facilities within 200 yards of a building entrance for each building and providing preferential parking equivalent to at least eight percent of the requir ed number of parking spaces. MM AQ-3 notes that the TDM program shall be developed and verified by the City prior to the issuance of occupancy permits.
O3-77 Comment indicates additional feasible mitigation should be included in MM AQ-1. However, specific additional feasible mitigation is not provided in this particular comment. Responses to specific comments are provided below.
O3-78 The City disagrees that revising MM AQ -1 to include Tier 4 requirements for equipment less than 50 horsepower would represent a meaningful emissions reduction. It should be noted that MM AQ-1 is consistent with SCAQMD recommended language for off-road construction equipment and consistent with CARB off road regulations. Additionally, during construction, welders are the only piece of modeled equipment that is less than 50 horsepower. The analysis in the DEIR only includes one welder during Phase 1 and one welder during Phase 2 (refer to
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DEIR Appendix A ). All other pieces of equipment (a total of 36 for each phase) are greater t han 50 horsepower.
Furthermore, construction emissions from both Phase 1 and Phase 2 would be below SCAQMD’s construction thresholds for all criteria pollutants (see DEIR Table 4.2-8 and Table 4.2-9). Construction and operational health risk impacts would also be less than significant (see DEIR pages 4.2-50 to 4.2-55). It is not necessary to require equipment less than 50 horsepower to meet Tier 4 standards as Phase 1 or Phase 2 construction impacts are already reduced to a less than significant level with the implementation of MM AQ-1. There is no nexus between the proposed modification to MM AQ-1 and a CEQA impact.
O3-79 Public Health
The DEIR includes a discussion of public health impacts from air pollutants on pages 4.2 -46 to
4.6-50. Additionally, health impacts from Toxic Air Contaminants are discussed on pages 4.2-50 to 4.2-55. The discussion of public health impacts was prepared to directly address the California Supreme Court’s Sierra Club v. County of Fresno decision. As outlined in the Court decision, the analysis specifically explains that ozone concentrations are dependent upon a variety of complex factors, including the presence of sunlight and precursor pollutants, natural topography, nearby structures t hat cause building downwash, atmospheric stability, and wind patterns. Because of the complexities of predicting ground -level ozone concentrations in relation to the NAAQS and CAAQS, none of the health-related information can be directly correlated to the pounds/day or tons/year of emissions estimated from a single, proposed project. It should also be noted that this analysis identifies health concerns related to particulate matter, CO, O3, and NO2 (see DEIR page 4.2-49). The analysis is provided to foster informed decision making and notes that due to the uncertainty in the relationship between project-level mass emissions and regional ozone formation as well as limitations with currently available technical tools, the resulting health effects associated wi th the Project cannot be identified. Given this is speculative, no meaningful conclusion can be drawn with respect to potential health effects from the criteria pollutant emissions of the proposed Project.
Backup Generators
The City also disagrees with the comment that the DEIR underestimates DPM from the Project’s backup generators. The Project proposes the development of industrial speculative warehouse buildings and the end users are not known at this time. It should be no ted that the Project is anticipated to be built out over several years (Project development would be determined by the landowner and/or developer based upon real estate market conditions).
Phase 2 is only programmatically planned, and no specific developme nt is proposed at this time. As the end users of the Project have not been identified, it is not known if backup generators would be needed for the potential buildings. Backup generators would only be used in the event of a power failure and would not be part of the Project’s normal daily operations.
If backup generators are required, the end user would be required to obtain a permit from the SCAQMD prior to installation. Emergency backup generators must meet SCAQMD's Best Available Control Technology (BACT ) requirements and comply with SCAQMD Rule 1470 (Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression
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Ignition Engines), which would minimize emissions. As the end users and future tenants of the proposed Project are unknown, the need for emergency backup generators is speculative . As such, the DEIR assumed a typical size backup generator for each warehouse building for emergency purposes and not necessarily to power the entire facility to continue normal operations. Additiona lly, it should be noted that MM GHG-1 requires the Project’s energy to be supplied by rooftop solar, which would offset the need for backup generators.
Under CEQA Guidelines Section 15384, argument, speculation, unsubstantiated opinion or narrative, evidence that is not credible, and evidence of social and economic impacts does not constitute substantial evidence.
The comment also requests that all backup generators be analyzed to use non-diesel low NOX and zero emissions technology options . As the proposed Project involves speculative warehouse buildings and the end users are unknown, prohibiting specific fuels for backup generators is not feasible, because it is unknown what the specific needs of an end user would be. The DEIR conservatively evaluated the emissions associated with diesel fueled backup generators because that represents the worst -case condition.
Construction and Operational Health Risk
The comment also incorrectly notes that the health risk assessment was segmented between construction and operational phase and relies on an inadequate receptor grid. Pursuant to the California Office of Environmental Health Hazard Assessment (OEHHA) and SCAQMD Risk Assessment Procedures, the Health Risk Assessment calculated carcinogenic risk based on a 30-year exposure duration, which includes age sensitivity factors (with a third trimester start age), and 95th percentile breathing rates.
Based on the Project schedule, Phase 1 construction would begin in 2023 and be completed in 2024. Following construction, the three warehouses in Phase 1 are assumed to be fully operational and generating emissions. Phase 2 construction will begin in 2026 and be completed in 2027, during this time Phase 1 operational emissions from the warehouses would overlap with the Phas e 2 construction emissions. Following the completion of Phase 2, emissions would only be generated by Phase 1 because Phase 2 operations does not include any TAC sources. The Project HRA analyzed this overlap and continuous pollutant exposure and concluded that with Tier 4 construction equipment mitigation (MM AQ-1) and electric cargo handling equipment (PDF AQ-2), health risk impacts would be below SCAQMD thresholds. A maximum health risk for the combined construction and operation of the Project is discus sed on DEIR pages 4.2-50 through 4.2-55 and shown in Table 8 of the DEIR Appendix B.
General Plan Policy 8.4.3
Finally, the comment incorrectly notes that the Project is sited without adequate buffers from sensitive receptors. Although existing sensitive r eceptors are adjacent to the proposed Project’s property line, the receptors would be approximately 230 feet west of the closest proposed warehouse building. Additionally, intervening terrain/slope and a retaining wall are also located between the warehous e and the receptors to the east. Due to the proximity to sensitive receptors, a health risk assessment was conducted for the proposed Project. As noted
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above, health risk impacts were mitigated to less than significant levels (i.e., below SCAQMD thresholds ) (see DEIR pages 4.2-50 through 4.2-55 and Table 8 of the DEIR Appendix B).
It should also be noted that General Plan Policy 8.4.3 recommends this buffer for the siting of new projects and land uses that would produce localized air pollution and specific ally identifies Interstate 10, SR -60, high traffic roads, and certain industrial facilities as sources of pollution sources. General Plan Policy 8.4.3 indicates certain industrial facilities could be sources of pollution, but does not necessarily identify warehouses. The majority of the proposed Project’s emissions would occur from mobile sources that would occur off-site and not in the proximity to the adjacent sensitive receptors. Additionally, as noted above, the results of the health risk assessment (see DEIR pages 4.2-50 through 4.2-55 and Table 8 of the DEIR Appendix B) and the localized impact analysis (see DEIR pages 4.2-44 through 4.2-50) demonstrate warehouse component of the Project would not have significant localized impacts. Therefore, the Project would not be a significant source of localized air pollution noted in General Plan Policy 8.4.3.
O3-80 The comment summarizes the SCAQMD 2022 Draft AQMP. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O3-81 Refer to response to comment O3-79 regarding the backup generator horsepower.
Additionally, as noted in the comment, the backup generators are limited to 50 hours per year for testing pursuant to SCAQMD Rule 1470. Backup generators are required to be tested periodically to ensure that they will operate a s expected. The comment notes that the backup generators will likely operate for 200 hours per year. However, no substantial evidence is provided to support this claim. The SCAQMD limits the operation of backup generators for no more than 200 hours per yea r of operation. Modeling 200 hours for generator emissions would be representative of an emergency condition and not representative of typical P roject operations.
O3-82 Refer to responses to comments O3-79 and O3-81 regarding backup generator assumptions.
O3-83 Refer to responses to comment s O3-79 and O3-81 regarding backup generator assumptions.
O3-84 Refer to response to comment O3-79 regarding backup generator assumptions and non-diesel low NOX zero emissions technology.
O3-85 Refer to response to Comment O3-79 regarding construction and operational health risks.
O3-86 The City disagrees that a receptor grid with spacing smaller than 50 meters should be used. A receptor grid of 50 meters is consistent with the SCAQMD’s Modeling Guidance for AERMOD6.
O3-87 The City disagrees that the dispersion modeling must include building downwash. The modeled sources in the AERMOD dispersion model are line -volume sources that represent on- and off- site truck movements and idling. The purpose of building downwash is to determine if stack
6 http://www.aqmd.gov/home/air -quality/meteorological-data/modeling -guidance
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discharge might become caught in the turbulent wakes of structures within close proximity.
The building downwash modeling option is only applicable to point and flare emission source types and is not applicable to the line-volume sources that were modeled for the proposed Project.
O3-88 Refer to response to comment O3-87 regarding building downwash.
O3-89 Refer to response to comment O3-79 regarding General Plan Policy 8.4.3.
O3-90 General Plan Policy 8.4.4 requires mitigation for sources within 500 feet of sensitive receptors.
However, as noted in response to comment O3-79, the Project would not have localized air quality impacts and health risk impacts would be less than significant with PDF AQ-2 (electric cargo handling equipment) and MM AQ -1 (Tier 4 construction equipment). Therefore, additional mitigation is not required.
O3-91 Given the location of the proposed Project and t he adjacency to sensitive receptors, a Health Risk Assessment (HRA) was prepared for the proposed Project to assess potential health risks to the surrounding community; refer to DEIR pages 4.2-50 through 4.2-55 and Appendix B. The HRA was prepared for the Project using air dispersion modeling (EPA AERMOD). Health risks are determined by examining the types and levels of air toxics generated and the associated impacts to air quality. As described above, impacts related to cancer risk would be less than significant with implementation of MM AQ -1. Additionally, non-carcinogenic hazards are calculated to be within acceptable limits. It should be noted that the impacts assess the Project’s incremental contribution to health risk impacts, consistent with the SCAQMD guidance and methodology. The SCAQMD has not established separate cumulative thresholds and does not require combining impacts from cumulative projects. The SCAQMD considers projects that do not exceed the Project -specific thresholds to generally not be cumulatively significant. Therefore, impacts related to health risk from the Project would be less than significant. Refer to Appendix B of the DEIR for additional information.
While cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time, an EIR or MND can determine that a project’s contribution to a significant cumulative impact will be rendered less than cu mulatively considerable, and thus is not significant (see Section 15130 of the State CEQA Guidelines). In the case of the proposed Project, implementation of MM AQ-1 would render its contribution to impacts to less than cumulatively considerable. As such, Projects that do not exceed the SCAQMD’s 10 in one million incremental threshold would not exacerbate existing conditions.
Furthermore, it should be noted that the DEIR determined that the Project’s Localized Significance Thresholds (LSTs) would be less t han significant (refer to DEIR pages 4.2 -42 through 4.2-45), which indicates that the regional increases shown in DEIR Tables 4.2 -10 through 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin.
O3-92 Refer to response to comment O3-91, above. As noted above the SCAQMD has not established separate cumulative thresholds and does not require combining impacts from cumulative
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projects. The SCAQMD considers projects that do not exceed the Project-specific thresholds to generally not be cumulatively significant. Localized air quality and health risk impacts were evaluated in DIER pages 4.2-43 through 4.2-45 and pages 4.2-50 through 4.2-55 and determined to be less than significant.
The comment provides data from OEHHA’s CalEnviroScreen 4.0. CalEnviroScreen is a mapping tool that helps identify California communities that are most affected by many sources of pollution, and where people are often especially vulnerable to pollution’s effects.
CalEnviroScreen uses environmental, health, and socioeconomic information to produce scores for every census tract in the State. The scores are mapped so that different communities can be compared. An area with a high score is one that experiences a much higher pollution burden than areas with low scores. The CalEnviroScreen score measures the relative pollution burdens and vulnerabilities in one census tract compared to others and is not a measure of health risk.
The City disagrees with the assertion that the Project would exacer bate existing conditions.
The comment notes that the census tract that the Project is located is within the 65 th percentile for traffic, which is consistent with the data presented within CalEnviroScreen 4.0. However, CalEnviroScreen 4.0 also shows that the Project area’s Pollution Burden Percentile is 23 and the Overall Percentile is 29 (also noted on page 12 of DEIR Appendix B (Health Risk Assessment). As noted above, the HRA prepared for the Project and incorporated into DEIR pages 4.2-50 through 4.2-55 show that the Project impacts would be below SCAQMD thresholds. The SCAQMD cancer risk threshold is expressed as “incremental cancer risk.”7 Individual cancer and incremental cancer risk are the likelihood that a person continuously exposed to concentrations of TACs over a lifetime will contract cancer based on the use of standard risk assessment methodology.
As noted above, the Project’s localized emissions would be less than significant (refer to DEIR pages 4.2-43 through 4.2-45), which indicates that t he regional increases shown in DEIR Tables 4.2-11, 4.2-13, and 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin.
O3-93 Refer to responses to comments O3-91 and O3-92, above. The emissions associated wit h the Project’s vehicle miles traveled were quantified and analyzed in the DEIR (refer to Tables 4.2-10 through 4.2-14). It should be noted that these emissions would occur regionally, as emissions associated with mobile sources would occur on roadways thr oughout the County and region and the majority of mobile sources would not be near the Project’s sensitive receptors. As noted in response to comment O3-91, the Project’s localized emissions would be less than significant (refer to DEIR pages 4.2 -43 through 4.2-45) and the Project’s health risks would be less than significant (refer to DEIR pages 4.2 -50 through 4.2-55), which indicates that the regional increases shown in DEIR Tables 4.2-11, 4.2-13, and 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin.
7 SCAQMD, South Coast AQMD Air Quality Significance Thresholds , April 2019.
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O3-94 The comment summarizes the commenters view of the DEIR. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is neces sary. Responses to specific comments are provided below.
O3-95 The comment summarizes the commenters view of the DEIR and a general statement that additional feasible mitigation measures are available. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary. Responses to specific comments are provided below.
O3-96 The comment summarizes the commenters view of the DEIR and a general statement about consistency with plans and policies. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary. Responses to specific comments are provided below.
O3-97 Goal 7 of the Sustainable Beaumont Plan includes various measures to reduce vehicle miles traveled, including: Measure 7.1: Encourage non-motorized transportation options; Measure 7.2: Encourage, promote, incentivize, or expand use of the pass transit system or other transit services; Measure 7.3: Create bicycle master plan to expand bike routes around the City; Measure 7.4: Promote Ride sharing programs within businesses; and Measure 7.5:
Electrify the fleet. Measures 7.3 and 7.5 are the City’s responsibility to implement and would not be the Project’s responsibility. However, the Project would implement a TDM program (DEIR MM AQ-3) that would encourage non-motorized transportation; encourage, promote, and incentivize the use of transit; and promote ride sharing programs. For example, MM AQ-3 requires a transportation information center and TDM coordinator t o provide information on surrounding transportation options, promote bicycling and walking by including on -site amenities, providing bicycle storage, providing shower and changing facilities, providing on - site car share amenities, promoting carpool/vanpool /rideshare, provide incentives for alternative travel modes, provide onsite meal options, and providing preferred preferential parking for electric, and low-emitting vehicles. Therefore, the Project implements feasible TDM measures to be consistent with Goal 7.
O3-98 Refer to response to comment O3-97. The Project would implement various TDM measures and would be consistent with Goal 7 of the Sustainable Beaumont Plan. The fact that the Project’s GHG emissions were determined to exceed thresholds due to mobile sources does not make it inconsistent with the Sustainable Beaumont Plan.
O3-99 The Riverside County Climate Action Plan consistency analysis was provided in the DEIR for informational purposes. Regardless of the type of the source, MM GHG-1 would require that 100 percent of the Project’s energy is renewable clean energy, which is the intent of the Riverside County Climate Action Plan measure. It should be noted that the measure is under the overall category “Clean Energy” and also includes wind turbines, which would also achieve 34 points, as long as 100 percent of the Project’s power needs are provided. As noted above, the consistency analysis with the Riverside County Climate Action Plan Screening Table is provided for informational purpose to demons trate that Phase 1 is implementing all feasible measure to minimize GHG emissions. The DEIR’s impact determination is based on consistency
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with the Sustainable Beaumont Plan and the CARB Scoping Plan, as applicable, and is not based on consistency with the Riverside County Climate Action Plan.
O3-100 The comment notes that RTP/SCS Goal 5 is to reduce GHG emissions and improve air quality.
The proposed Project includes numerous mitigation measures and design features that would reduce emissions; refer to DE IR pages 4.2-22 through 4.2-24, pages 4.2-38 through 4.2-41, pages 4.7-29 through 4.7-31, and pages 4.7-39 through 4.7-40. These include implementation of a TDM program to reduce vehicle trips, charging stations and infrastructure to support future electric vehicle demand to reduce mobile emissions, prohibiting idling when engines are not in use, including signage to report violations, incentives for using cleaner operating trucks, facilitate compliance with SCAQMD Rule 2035, requiring renewable energy, ach ieving CalGreen Tier 2 energy efficiency standards, diverting solid waste, and using electric landscape equipment. The Project’s exceedance of thresholds are primarily due to the size of the Project and not the lack of reduction measures. The implementatio n of the various mitigation measures noted above and design features would ensure emissions are reduced consistent with RTP/SCS Goal 5.
O3-101 The CARB Refrigerant Management Program is a state requirement and is codified in Title 17 of the California Code of Regulations (Section 9 5380). Therefore, the Project would be required to use refrigerants that comply with State law. Additionally, the SCAQMD issued the related Rule 1415 in 1991 covering stationary air conditioning systems, and subsequently adopted Rule 1415.1 in 2010 covering stationary refrigeration systems (a precursor to California's Refrigerant Management Program Rule, which took effect in 2011). Also, in 2010 Rule 1415 was extended to cover high-GWP HFC refrigerants. The RMP is designed to complement the federal and SCAQMD regulations and provide better control of emissions of both ozone depleting substances (ODS) and ODS substitute refrigerants such as HFCs and HFC blends. Therefore, this CARB Scoping Plan measure is implemented at the State an d regional level and not at the project level.
O3-102 This comment summarizes the commenter’s view about the CEQA statutes and feasible mitigation. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary. Responses to specific comments are provided below.
O3-103 This comment summarizes the commenter’s view about the DEIR and feasible mitigation. The comment does not raise a specific issue with the adequacy of the DE IR or raise any other CEQA issue. Therefore, no further response is necessary. Responses to specific comments are provided below.
O3-104 This comment summarizes the commenter’s view about additional feasible mitigation. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary. Responses to specific comments are provided below.
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O3-105 Refer to response to comment O3-74. The comment suggests additional measures for incorporation into the DEIR. The discussion below provides a response to each of the suggested measures. As shown below, the suggested are already addressed in the DEIR or are CARB regulations that the Project must already comply with. Therefore, additional mitigation is not required.
Suggested Measure Response
1. “Include contractual language in tenant lease
agreements that requires tenants to use the
cleanest technologies available, and to provide
the necessary infrastructure to support zero-
emission vehicles and equipment that will be
operating on site.
As noted above, the Project includes Project
design features and mitigation that would
facilitate the use of ZE and NZE vehicles consistent
with CARB and SCAQMD programs (e.g.,
Advanced Clean Truck R egulation, Sustainable
Freight Action Plan, SCAQMD Rule 2305, etc.).
MM AQ-6 requires Project compliance with
SCAQMD Rule 2305 to facilitate the use of ZE and
NZE trucks. Additionally, MM AQ-6 requires the
Project Applicant to provide $1.00 per square foot
in funding for fleet upgrade financing to
incentivize the use of cleaner operating trucks to
reduce future emissions and includes a goal of
achieving ZE trucks beginning in 2030. It should be
noted that the DEIR conservatively does not take
credit for implementation of MM AQ-6 .
Additionally, PDF AQ-2 requires all Phase 1
outdoor cargo handling equipment (including
yard trucks, hostlers, yard goats, pallet jacks, and
forklifts) to be powered by electricity (i.e., zero
emission).
2. Include contractual language in tenant lease
agreements that requires future tenants to
exclusively use zero-emission light and medium-
duty delivery trucks and vans.
Refer to the response above.
3. Include contractual language in tenant lease
agreements requiring all trucks, and cars
entering the Project site be zero-emission.
Refer to the response above.
4. Include contractual language in tenant lease
agreements that requires all heavy -duty trucks
entering or on the project site to be model year
2018 or later, expedite a transition to zero-
emission vehicles, and be fully zero -emission
beginning in 2030.
Refer to r esponse to comment O3 -73 regarding
2018 model year trucks. Additionally, PDF AQ-13
requires the Phase 1 facility operator to provide
tenants with information about the Carl Moyer
Air Program and the On -Road Heavy-Duty
Vehicles Voucher Incentive Program, which
provides funding to purchase newer vehicles.
5. Include contractual language in tenant lease
agreements that requires the tenant be in, and
monitor compliance with, all current air quality
regulations for on -road trucks including CARB’s
Heavy-Duty (Tractor -Trailer) Greenhouse Gas
Regulation, Periodic Smoke Inspection Program
Operators and manufacturers are required to
comply with these regulations. CARB’s Tractor-
Trailer Greenh ouse Gas Regulation reduces
greenhouse gas emissions by improving the
aerodynamic performance and reducing the
rolling resistance of tractor -trailers. CARB’s
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Suggested Measure Response
(PSIP), and the Statewide Truck and Bus
Regulation.
Advanced Clean Trucks regulation is a
manufacturer’s ZEV sales requirement and a one-
time reporting requirement for large entities and
fleets. The Periodic Smoke Inspection Program
(PSIP) is CARB's heavy-duty vehicle inspection
program for in-use trucks and buses that includes
roadside testing by CARB. The Statewide Truck
and Bus Regulation requires fl eets to upgrade to
2010 or newer model year engines by January 1,
2023. The suggested additional mitigation
measures are already State regulation (i.e.,
mandatory). As such these measures are
essentially part of the Project; and therefore, are
not mitigation under CEQA.
6. Limit the daily number of trucks allowed at the
Proposed Project to levels analyzed in the CEQA
document. If higher daily truck volumes are
anticipated to visit the site, the City as the Lead
Agency should commit to re -evaluating the
Proposed Project through CEQA prior to allowing
this land use or higher activity level.”
The DEIR forecast the number of Project
generated vehicle trips using Institute of
Transportation Engineers (ITE) 1 1 th Edition Trip
Generation Manual trip generation rates, with the
breakdown by vehicle type
(passenger car, 2 -axle trucks, 3 -axle trucks, and
4+axle trucks) consistent with SC AQMD
recommendations. Accordingly, the Project's
average daily truck traffic has been modelled
appropriately. However, setting a dail y limit on
truck trips would be infeasible due to expected
day-to -day variations. The EIR is based on a set of
realistic, but conservative, set of assumptions
regarding the magnitude of potential activities
resulting from the proposed Project, including
tr uck trip estimates. Therefore, the City does not
anticipate truck trips to exceed those, and future
re-evaluation is not necessary.
O3-106 This comment provides concluding remarks and does not raise a specific issue with the adequacy of the DEIR or raise any other specific CEQA issue. Therefore, no further response is necessary. Refer above for detailed responses.
O3-107 A 1994 Phase I ESA conducted for the site is referenced in this VERTEX Phase I for the proposed Project. Based on the findings of a 1994 Phase I ESA, a Phase II subsurface investigation was also conducted which did not find methane in subsurface soil gas. The Phase II ESA findings included the following:
1. No gasoline range hydrocarbons or volatile organic compounds (VOCs) were detected in any of the samples that were analyzed. Only one of the six samples analyzed had detectable levels of diesel range hydrocarbons with a value of 130 mg/kg. The concentration of the various metals detected in the samples are consistent with typical backgroun d levels and do not exceed any State or Federal action level.
2. VOCs were not detected in the soil sample that was collected from the "processing area."
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3. Pesticides were not detected in any of the 18 soil samples that were collected from the retention pond/manure spreading areas.
4. Pesticides and herbicides were not detected in any of the 17 soil samples that were collected from the pesticide/chemical storage and chicken coop areas.
The Phase I ESA found that the current 2019 Regional Water Quality Control Board (RWQCB) Residential Environmental Screening Level (ESL) for petroleum hydrocarbons as diesel is 260 mg/kg and 1,200 mg/kg for Commercial/ Industrial use. Based on this informa tion, the detection of diesel at 130 mg/kg represents a de minimis condition and not a REC.
Also, based on review of readily available historical information, the site is located in a rural and residential area. No HRECs were identified with respect to th e historical surrounding property uses.
Several facilities were identified within the American Society for Testing and Materials (ASTM) search distances of the site. Based on distance, apparent gradient relationship, regulatory status, and/or other facility-specific characteristics, no RECs to the site were identified with respect to these facilities. Based on the reported contamination and the conditions indicated in the no further action letter, the former USTs represent a CREC in connection with t he site.
However, MM HAZ-1 is included in the DEIR which requires the preparation of a Soils Management Plan for the Project.
O3-108 The DEIR and VMT analysis disclose the Projects VMT impacts, and feasible mitigation measures have been identified.
As shown on page 6 of the VMT memo (Dated February 1, 2022), the Project would provide transportation demand management (TDM)/VMT Mitigation Measures as noted below:
• Provide a transportation information center and on -site TDM coordinator to educate residents, employers, employees, and visitors of surrounding transportation options. • Promote bicycling and walking through design features such as showers for employees, self-service bicycle repair area, etc. around the Project site. • Each building shall provide secure bicycle storage space equivalent to two percent of the automobile parking spaces provided.
• Each building shall provide a minimum of two shower and changing facilities within 200 yards of a building entrance.
• Provide on-site car share amenities for employees who make only occasional use of a vehicle, as well as others who would like occasional access to a vehicle of a different type than they use day-to-day.
• Promote and support carpool/vanpool/rideshare use through parking incentives an d administrative support, such as ride -matching service. • Incorporate incentives for using alternative travel modes, such as preferential load/unload areas or convenient designated parking spaces for carpool/vanpool users.
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• Provide meal options onsite or shuttles between the facility and nearby meal destinations. • Each building shall provide preferred parking for electric, low‐emitting and fuel -efficient vehicles equivalent to at least eight percent of the required number of parking spaces.
O3-109 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
O3-110 Comment noted. The suggested updates to the VMT analysis and/or DEIR document would not change the findings or conclusions of the transportation/VMT impact as significant and unavoidable.
O3-111 As reported in the VMT analysis memo, there is no existing transit wit hin ½-mile of the Project.
As such, the Project would not have an impact on existing transit ridership.
O3-112 The thresholds used are consistent with the City’s TIA guidelines. SB 743 provides discretion to lead agencies to set their VMT impact thresholds .
O3-113 The thresholds used are consistent with the City’s TIA guidelines. SB 743 provides discretion to lead agencies to set their VMT impact thresholds.
O3-114 The suggested updates to the VMT analysis and/or DEIR document would not change the findings or conclusions of the transportation/VMT impact as significant and unavoidable.
O3-115 Per CEQA Guidelines, Level of Service is not considered as a CEQA impact. Therefore, the analysis was done for General Plan consistency, and the Projects fair share toward these improvements will be conditions of approval and not mitigation measures.
O3-116 Per CEQA Guidelines, Level of Service is not considered as a CEQA impact. Therefore, the analysis was done for General Plan consistency, and the Projects fair share toward these improvements will be conditions of approval and not mitigation measures.
O3-117 Per CEQA Guidelines, Level of Service is not considered as a CEQA impact. Therefore, the analysis was done for General Plan consistency, and the Projects fair share toward these improvements will be conditions of approval and not mitigation measures.
O 3-118 The DEIR and VMT analysis discloses the proposed Projects VMT impacts, and feasible mitigation have been identified. As shown on page 6 of the VMT memo (Dated February 1, 2022), the Project would provide transportation demand management (TDM)/VMT Mitigation Measures as noted below:
• Provide a transportation information center and on-site TDM coordinator to educate residents, employers, employees, and visitors of surrounding transportation options. • Promote bicycling and walking through design features such as showers for employees, self- service bicycle repair area, etc. around the Project site.
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• Each building shall provide secure bicycle storage space equivalent to two percent of the automobile parking spaces provided.
• Each building shall provide a minimum of two shower and changing facilities within 200 yards of a building entrance.
• Provide on-site car share amenities for employees who make only occasional use of a vehicle, as well as others who would like occasional access to a vehicle of a different ty pe than they use day-to-day.
• Promote and support carpool/vanpool/rideshare use through parking incentives and administrative support, such as ride-matching service.
• Incorporate incentives for using alternative travel modes, such as preferential load/unload areas or convenient designated parking spaces for carpool/vanpool users. • Provide meal options onsite or shuttles between the facility and nearby meal destinations. • Each building shall provide preferred parking for electric, low‐emitting and fuel -efficient vehicles equivalent to at least eight percent of the required number of parking spaces.
O3-119 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environ mental analysis.
However, your comment will be taken into consideration by decision-makers.
O3-120 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
O3-121 DEIR Sections 4.10 and 4.12 include detailed analysis related the Projects compliance with the City’s General Plan and housing. The commentor makes a blanket statement but does not raise any specific issues related to the actual analysis in the DEIR.
O3-122 Chapter 17.20 of the Beaumont Municipal Code establishes a No Net Loss Program, whereby concurrent with the approval of any change in zone fr om a residential use to a less intensive use, a density bonus will become available to project applicants subsequently seeking to develop property for residential use within the City.
O3-123 See response to comment O3-122 above.
O3-124 Section 4.12, Population and Housing, of the DEIR includes a detailed analysis on the Project impacts to housing and City’s housing needs. In addition, the City has adopted a No Net Loss Program to replace housing units lost as a result of down zoning. See response to comment O3-122 above.
O3-125 The WSA states the Project has been annexed into the City and into the water service area of BCVWD. The WSA does not make findings of sufficient water supply based on when recycled water will become available. The WSA makes findings of sufficient water supply for the proposed project based on the ample overlying water rights assigned to the Project parcels by
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the Beaumont Basin Judgment that exceed the anticipated water demand (both potable and non-potable demand combined) of the proposed project. The WSA also finds that a future water demand for the Project site that exceeds the project ed water demand of the proposed project was accounted for in BCVWD’s 2020 UWMP 20 -year water demand projections for which the district expects to have sufficient water supply. The future locations of utility extensions to be constructed by the applicant including recycled water lines are not a required element of the WSA (Senate Bill 610) and are therefore not included. The WSA assumes the permanent open space area will not be irrigated based on discussion between Webb and the fire marshal (there is a citation to this effect in the WSA).
O3-126 Refer to Section 3.0, Errata , of this FEIR concerning the updates to the Project’s biological resources mitigat ion measures.
O3-127 Refer to Section 3.0, Errata , of this FEIR concerning the updates to the Project’s biological resources mitigation measures.
O3-128 Refer to Section 3.0, Errata , of this FEIR concerning the updates to the Project’s biological resources mitigation measures.
O3-129 Refer to Section 3.0, Errata , of this FEIR concerning the updates to the Project’s biological resources mitigation measures.
O3-130 The calculation of MSHCP fee s is currently being developed with the appropriate resource agencies. There is no requirement to include the exact fees in the DEIR, as these are developed in conjunction with the appropriate agencies. The Project is required to pay all fees proportionate to their impact, as stated in the DEIR.
Southern California legless lizard is a California Species of Special concern that has moderate potential to occur within the Project due to the presence of suitable habitat and is not covered under the MSHCP. A ma jority of the moderately suitable habitat for southern California legless lizard within the Project site occurs within the drainage south of the grading footprint, which would be avoided during construction of the Project. However, the Project would result in removal of some suitable habitat within the smaller drainages in the northeast portion of the site, which would be adverse. Payment of MSHCP Local Development Mitigation Fees provides habitat -based mitigation within the plan area for all wildlife and plant species, including MSHCP-covered species and Species of Special Concern, impacted due to the loss of suitable habitat from covered projects. As such, loss of habitat for Species of Special Concern would be offset through this habitat -based mitigation under the MSHCP such that the loss of habitat resulting from the Project would not constitute significant impacts. These species are considered adequately covered under the MSHCP; habitat -based impacts on non-listed special-status wildlife species would be less than significant, conditional upon satisfaction of previous mitigation requirements.
O3-131 As stated in page 4.13-10 of Section 4.13, Public Services , the Riverside County Fire Department (RCFD) reviewed the Project’s design to ensure conformance to RCFD requirements and would thereby reduce demands on fire protection services. Additionally,
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payment of the Fire Protection impact fees, property taxes, and other revenues generated by development wit hin the Project area would be available to the City to offset any increased costs for fire protection services with little or no net effect on the City’s budget.
Implementation of the Project would be required to be consistent with the City’s General Plan for e-commerce, commercial, and open space uses as well as permitted floor area ratios (FAR).
Lastly, Project development would be subject to compliance with RCFD requirements for emergency access, fire-flow, fire protection standards, fire lanes, and oth er site design/building standards.
O3-132 Comment noted.
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Comment Letter O4 – Cherry Valley Acres and Neighbors
Pat Doherty, Treasurer
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Responses to Comment Letter O4 – Cherry Valley Acres and Neighbors Pat Doherty, Treasurer
O 4-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
Additionally, evaluating whether or not the introduction of warehouses lowers the values of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by decision-makers O 4-2 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision -makers . In addition, the DEIR fully analyzed and disclosed the proposed Project’s impacts related to air quality and transportation. Refer to Section 4.2, Air Quality and Section 4.15, Transportation of the DEIR for more information.
O 4-3 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers .
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Comment Letter O5 – Solera Oak Valley Greens Association, Board of Directors Christine Rodgers, Vice President of Large Scale Community Management
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Responses to Comment Letter O5 – Solera Oak Valley Greens Association, Board of Directors Christine Rodgers, Vice President of Large Scale
Community Management
O5-1 The Solera Oak Valley Greens Association: Board of Directors Resolution in opposition to the proposed Project has been noted and will be taken into consideration by decision-makers.
O5-2 See response to comment O5-1 above.
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Comment Letter O6 – Center for Biological Diversity, Urban Wildlands Program Hallie Kutak, Senior Conservation Advocate
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Responses to Comment Letter O6 – Center for Biological Diversity, Urban Wildlands Program Hallie Kutak, Senior Conservation Advocate
O6-1 This comment is introductory and states that the DEIR fails to adequately address the Project’s impacts on air quality, greenhouse gas emissions, sensitive receptors, biological resources, noise, and aesthetics. Refer to the following responses.
O6-2 Refer to response to comment O6-1 above.
O6-3 This comment brief summarizes the commentor’s understanding of the proposed Project and Project location.
O6-4 This comment summarizes general air quality impacts and how they affect health. The comment states that ozone, PM2.5 , and toxic air contaminants (TACs) are the greate st concern for Riverside County and relates these pollutants to health conditions. The comment states that the warehouses are a well-documented source of air quality degradation and can cause health impacts for surrounding communities. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O6-5 This comment is introductory to briefly describe the purpose of CEQA and how the DEIR fails to properly disclose and analyze significant air quality, GHG, biological, noise, and aesthetic impacts.
O6-6 This comment states that the DEIR analysis is inadequate, but it does not identify any deficiencies in the analysis. In fact, the comment agrees with the conclusions of t he air quality and greenhouse gas analysis, noting that the Project would result in significant and unavoidable impacts.
O6-7 This comment states that the DEIR underestimates the vehicle trips associated with the Project and does not attempt to mitigate all significant impacts. Vehicle trip generation estimates are based on trip rates obtained from the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition) based on Project land uses. Air quality mitigation measures are discussed on DEIR pages 4.2-38 through 4.2-41. Greenhouse Gas mitigation measures are discussed on DEIR pages 4.7-39 and 4.7-40.
O6-8 The proposed project is consistent with the ITE description for ITE High -Cube Short -Term Storage Warehouse for Buildings 1 and 2, and ITE Warehouse for Building 3. High-Cube Fulfillment Center Warehouse and High-Cube Parcel Hub Warehouse uses are not proposed.
O6-9 The proposed project is consistent with the ITE description for ITE High -Cube Short -Term Storage Warehouse for Buildings 1 and 2, and ITE Warehouse for Building 3. High-Cube Fulfillment Center Warehouse and High-Cube Parcel Hub Warehouse uses are not proposed.
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O6-10 The proposed project is consistent with the ITE description for ITE High-Cube Short -Term Storage Warehouse for Buildings 1 and 2, and ITE Warehouse for Building 3. High -Cube Fulfillment Center Warehouse and High-Cube Parcel Hub Warehouse uses are not proposed.
O6-11 This comment suggests that the DEIR is underestimating diesel pollution by underestimating the dista nce trucks will travel and suggests that truck trip length should be 88 miles one way.
The average truck trip length used in the DEIR was taken from a CARB study, Emissions Estimation Methodology for On-Road Diesel-Fueled Heavy-Duty Drayage Trucks at California Ports and Intermodal Rail Yards. This CARB study estimated travel distances from distribution centers based on weighted trip average distances between ports and rail yards. For warehouses located within the South Coast Air Basin, the average distanc e was estimated to be 33.2 miles per trip. The commenter does not provide a source for the suggested 88 -mile trip length. Furthermore, it should be noted that the DEIR determined that the Project’s Localized Significance Thresholds (LSTs) would be less tha n significant (refer to DEIR pages
4.2-42 through 4.2-46) and health risk impacts would be less than significant (refer to DEIR pages 4.2-50 through 4.2-55), which indicates that the regional increases shown in DEIR Tables 4.2-10 through 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin.
O6-12 This comment incorrectly states that emissions from trucks hauling materials to the Project site during construction were omitted and cites pages 4.2 -28, 4.2-29, Appendix A , thereto at 66-74 as evidence. However, the commenter misunderstood the data presented in the CalEEMod output files. Hauling in CalEEMod refers to the import and export of soil. The pages referenced in the Appendix are for building cons truction, paving, and architectural coating phases, therefore they do not include soil transport. However, vendors in CalEEMod refers to transport of building materials to the Project, the emissions from these trips are included in the data tables. Therefore, construction emissions for Phase 1 and Phase 2 of the Project identified in Table 4.2-8 of page 4.2-28 and Table 4.2-9 of page 4.2-29 include emissions from both hauling soil and transporting construction materials to the site.
O6-13 This comment states that errors in the air quality analysis methodology will also underestimate greenhouse gas emissions. However, as discussed in previous responses, criticisms of the air quality methodology and calculations are unfounded or incorrect.
O6-14 This comment s tates that the DEIR does not analyze cumulative air quality impacts on receptors. However cumulative impacts from construction and operations are analyzed on DEIR pages 4.2-56 and 4.2-57.
O6-15 This comment questions the accuracy of the Health Risk Assessment prepared for the DEIR.
The comment notes that the unmitigated Project would result in 63 cases of cancer for every million residents and 60.9 cases for every worker which exceeds the significance threshold.
The comment then notes that a project design feature and a mitigation measure would reduce cancer impacts to a less than significant level. The commenter questions how such a reduction is possible.
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As discussed in the HRA, all unmitigated emissions are based on diesel -powered construction equipment and diesel-powered cargo handling equipment (including yard trucks, pallet jacks, and forklifts). Mitigated emissions include project design features and mitigation, these require diesel construction equipment to meet CARB Tier 4 Final off -road emis sion standards, be properly maintained, shut -off when not in use, connecting electric tools to a power grid instead of a diesel generator, and requires all cargo handling equipment to be electric. Based on these changes, the cancer risk for emissions modeled in AERMOD were determined to be less than significant. Modeling input values and outputs are included in the HRA appendix.
O6-16 This comment states that the mitigation measures in the DEIR are not sufficient to reduce impacts. The comment summarizes these measures and notes that these measures focus on on-site impacts and do not address mobile emissions. As stated in the DEIR, the Project does not have the authority to regulate vehicle emissions, mitigation measures only include things that Project has the authority to control. However, as shown in the HRA, these measures will reduce cancer cases below South Coast AQMD thresholds.
O6-17 This comment states that South Coast AQMD is considering updating their guidance for cumulative air quality impacts. If South Coast AQMD updates their guidance, future projects would be required to comply with these new guidelines.
O6-18 The City agrees that low rainfall can be adverse for rare plants and rare plant surveys; however, based on existing site conditions, the Rocks Biological Consulting principal biologist determined that the proposed Project site is not likely to support Marvin's onion or many- stemmed dudleya based on the highly disturbed nature of the site and lack of suitable habitat.
These species typically occur within the San Gorgonio mountains and foothills and are significantly less likely on topographically lower areas like the Project site. Further, while low rainfall can reduce plant population size, there are some plants such as perennials that germinate from a bulb (Marvin's onion) or caudex/corm (many-stemmed dudleya) that can produce above ground leaves/stems/flowers even during low rainfall years. As such we believe these species would have been observed if present.
O6-19 The comment states that D EIR must revegetate mesic and riparian areas in order to provide additional habitat for the vireo. As stated in page 4.3 -19 of DEIR Section 4.3, Biological Resources , the Project would implement MM BIO -1 which contains the strategy to avoid vegetation removal during the birds breeding season. Therefore, impacts to the least Bell’s vireo would be less than significant and the Project would comply with General Plan Policies 8.5.5 and 8.7.5.
O6-20 Commented noted. As noted in MM BIO -1 and MM BIO-2, pre-construction/absence/protocol surveys would be conducted by a qualified biologist. Furthermore, the qualified biologist will always be present when during construction activity to ensure that impacts to sensitive biological species are minimized.
O6-21 This comment states that the DEIR does not adequately analyze traffic and cumulative noise impacts and disagrees with the traffic noise results along Brookside Avenue. The DEIR analyzed
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traffic noise along 18 roadway segments. The cumulative noise analysis looks at three different criteria to determine noise impacts; would the Project result in a noticeable increase in noise over existing conditions (an increase of 3.0 dBA or more), would a significant portion of future traffic noise be due to the Project (an increas e of 1.0 dBA or more), and would the resulting traffic noise exceed the acceptable standards for an adjacent land use.
As shown in Table 4.11-16 and explained on pages 4.11-31 and 4.11-32, traffic noise along Brookside Ave. would not result in significant impacts. Traffic noise on Brookside Ave. between Hannon Rd. and Union St. would not exceed the normally acceptable standard and would result in a less than significant impact. Brookside traffic noise between Union St. and Nancy Ave. would exceed the norma lly acceptable standard, combined threshold, and incremental threshold at 100 feet, however these houses are above roadway grade and surrounded by a solid block wall which would attenuate traffic noise to less than significant levels. Brookside traffic noise between Nancy Ave. and Oak View Dr. would also exceed the normally acceptable standard, combined threshold, and incremental threshold at 100 feet. However, there is only one residence along this segment of the road, and it is 150 feet from the centerlin e. At this distance, traffic noise would be attenuated to less than significant levels. Brookside traffic noise between Oak View Dr. and Beaumont Ave. would not exceed the combined threshold; therefore, as noted in the DEIR impacts would be less than signi ficant. However, the City agrees to include a discussion on noise levels concerning Brookside Avenue from Oak View Drive to Beaumont Avenue. See Section 3.0, Errata, of this FEIR for those changes.
O6-22 This comment states that the DEIR did not analyze noise impacts at crucial locations, specifically at residences south of the Project’s property line. Sensitive receptors identified in Table 4.11-3 are sensitive receptors located nearest the Project boundary. These sensitive receptors were considered when analyzing const ruction noise however when analyzing traffic noise, the receptors studied depend on traffic patterns. The traffic study did not identify Project traffic traveling along Brookside Avenue from North Deodar Drive to Hannon Road, therefore traffic noise was not analyzed at this roadway segment.
O6-23 This comment states that the DEIR fails to disclose all Phase 2 construction noise and operational noise from the hotel. However, the DEIR discusses onsite and off -site construction noise for Phase 1 and Phase 2 on pages 4.11-20 and 4.11-21. Operational noise from the hotel is discussed on pages 4.11-21 through 4.11-23. This would include mechanical equipment noise such as HVAC units and parking lot noise. Other than these sources, the hotel would not be a significant source of noise generation. The comment does not identify any additional hotel related noise sources that were not analyzed.
O6-24 The commentor is incorrect in their statement that the DEIR fails to adequate consider whether the Project would create a new source of light, which would affect nighttime v iews in the area.
The DEIR fully analyzes and discloses the proposed Project’s light and glare impacts associated with construction and operation activity. Refer to pages 4.1 -12 through 4.1-13 of DEIR Section 4.1, Aesthetics . As stated in Section 4.1, the Project’s construction source of light and glare would be limited to daylight hours. Additionally, n ighttime security lighting could be utilized for security purposes of the site and equipment. Additionally, it is a common practice
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to provide night-time lighting when a guardhouse/shack is provided on-site for security personnel. No short -term, construction-related impacts associated with light and glare are expected to occur.
Concerning operation of the proposed Project, the Project would incorporate design elements to reduce sources of lighting as approved by the City. In addition, all future development within the City limits would be subject to the provisions of Chapter 8.50, Outdoor Lighting of the Beaumont MC. Chapter 8.50 sets forth restrictive lightin g standards that act to prevent or minimize overall illumination levels, and effectively reduce or preclude potential light/glare overspill impacts. In this regard, the City’s Outdoor Lighting Ordinance establishes specific design, construction, and perfor mance standards applicable to lighting and light fixtures within the City.
Although the proposed Project would result in new light and glare, it would be less than significant.
O6-25 The City agrees to provide more information. Refer to Section 3.0, Errata, of this FEIR for those changes.
O6-26 The City agrees to provide more information. Refer to Section 3.0, Errata, of this FEIR for those changes.
O6-27 This comment is introductory and contains references from CEQA Guidelines and Statutes.
O6-28 The comment states that that vehicular traffic from the Project would be roughly the same because the intensity of use would be similar, resulting in no reduction in air quality or GHG emissions. This statement is incorrect. The DEIR does not state that “no reduction” between alternatives would occur. The DEIR states that vehicular traffic generated from the Project is not anticipated to be significantly reduced, not that no reduction would occur.
O6-29 Section 6.0 of the DEIR includes a details analysis of the alternatives and applicability of the Project objectives to the alternatives. The Commentor is citing to the single sentence conclusion in the summary table and negates the substantial evidence in the DEIR.
O6-30 This comment is introductory and states that the DEIR does not incorporate several basic measures that impacts on adjacent residential communities. No further response is warranted.
O6-31 This comment notes that the Project will exceed the GHG threshold. The comment goes on to discuss GHG emissions and its impact on c limate change. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O6-32 This comment discusses GHG emissions and the impact on California’s climate. The comm ent does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue.
Therefore, no further response is necessary.
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O6-33 This comment notes that the Project will result in a significant and unavoidable GHG impacts but disagrees with the conclusion that additional mitigation is not feasible. The Project has incorporated mitigation measures that reduce onsite GHG emissions by 79 percent, however due to the nature of the Project , the majority of GHG emissions will come from mobile sources.
Neither the Project nor the City has the authority to regulate emissions from vehicles, therefore any proposed mitigation to control vehicle emissions would not be enforceable and therefore is not considered feasible.
O6-34 This comment notes that t he decision under Golden Door Properties, LLC v. County of San Diego (2020) 50 Cal.App.5th 467 that determined the purchase of carbon offset credits did not meet CEQA’s criteria for a valid mitigation measure, but did not invalidate carbon offsets as a mat ter of law. However, as discussed in the DEIR, to reduce emissions and to be valid mitigation under CEQA, purchased offset credits must be genuine, quantifiable, additional, and verifiable. Even offset credits purchased from CARB -approved offset project registries have been determined to not adequately assure that purchased offset credits accurately and reliably represent actual emissions reductions or cannot guarantee that such reductions are additional to any reduction that would occur under business -as-usual operations and reductions required by law. CARB does not have enforcement authority over such reductions, let alone the City of Beaumont. The City of Beaumont, the lead agency for the Project and the entity responsible for enforcing any mitigation mea sures incorporated into the Project and relied upon to reduce impacts to a less than significant level, has no enforcement authority over offset credits that fund carbon reduction projects outside of the City. Many offset credits “sell” reductions in emiss ions generated outside of California, which may not be genuine or verifiable. International offsets are even more difficult to verify, guarantee and enforce. Thus, the purchase of offset credits is not a feasible CEQA mitigation measure to reduce the emiss ions impact of the proposed Project.
O6-35 As discussed in response to comment O6-34, project offset registries have been determined to not adequately assure that purchased offset credits accurately and reliably represent actual emissions reductions. There fore, investing in mitigation credits may not result in a reduction in GHG emissions and thus would not be valid CEQA mitigation.
O6-36 This comment is introductory and quotes text from CEQA Guidelines. No further response is warranted.
O6-37 This comment summarizes South Coast AQMD Rule 2305. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
O6-38 This comment summarizes the California Attorney Gener al document entitled Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, which provides example mitigation measures. These mitigation measures were considered during Project design and have be en included as design features or mitigation measures if feasible for the Project.
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Proposed Mitigation Measures Method of Project Incorporation Requiring all off-road construction equipment—
not just cargo equipment-- to be zero-emission,
where available, and all diesel fueled off -road
construction equipment, to be equipped with
CARB Tier IV compliant engines or better, and
including this requirement in applicable 7 bid
documents, purchase orders, and contracts, with
successful contractors demonstrating the ability to
supply the compliant construction equipment for
use prior to any ground -disturbing and
construction activities.
MM AQ-1 (DEIR page 4.2 -38) requires
construction equipment to meet CARB Tier 4
standards. Additionally, PDF AQ -2 requires
electric c argo handling equipment during
operations.
Prohibiting off-road diesel-powered equipment
from being in the “on” position for more than 10
hours per day.
DEIR MM AQ-1 requires all construction
equipment and delivery vehicles shall be turned
off when not in use, or limit on-site idling for no
more than 5 minutes in any 1 hour to achieve
this measure.
Providing electrical hook ups to the power grid,
rather than use of diesel -fueled generators, for
electric construction tools, such as saws, drills, and
compressors, and using electric tools whenever
feasible.
DEIR MM AQ-1 requires on-site electrical hook
ups to a power grid shall be provided for
electric construction tools including saws, drills,
and compressors, where feasible, to reduce the
need for die sel powered electric generators.
Limiting the amount of daily grading disturbance
area.
The project would be required to comply with
SCAQMD Rule 403, which limits daily grading
disturbance area to minimize fugitive dust (see
SC AQ-1 on DEIR page 4.2 -37).
Prohibiting grading on days with an Air Quality
Index forecast of greater than one hundred for
particulates or ozone for the project area.
The emissions analysis for the Project
determined that regional and localized
construction emissions would not exceed
SCAQMD thresholds (see DEIR pages 4.2-27
through 4.2 -29 and pages 4.2 -42 through 4.2-
44). Therefore, the Project would not have the
potential to influence localized pollutant
concentrations and implementation of this
measure is not necessary.
Forbidding idling of heavy equipment for more
than two minutes.
The Project would comply with the 5 -minute
limit per CARB regulation/state law.
Implementation of this measure is not
quantifiable because CalEEMod does not allow
for the adjustment of idle times. The Project
includes MM AQ-5 requires signage stating that
drivers turn off engines when not in use,
identifying the State’s 5 -minute idling limit
(California Code of Regulations, Title 13,
Division 3, Article 1, Chapter 10, Section 2485
[Airborne Toxic Control Measure to Limit
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Proposed Mitigation Measures Method of Project Incorporation Diesel-Fueled Commercial Motor Vehicle
Idling]), and including telephone numbers of
the building facilities manager and CARB to
report violations.
Additionally, the Project includes design
features to minimize idling. For example, PDF
AQ-5 requires Phase 1 facility operators to train
managers and employees on efficient
scheduling and load management to eliminate
unnecessary queuing and idling of trucks. PDF
AQ-8 requires the facility operator for Phase 1
to ensure that site enforcement staff in charge
of keeping the daily log and monitoring for
excess idling will be trained/certified in diesel
health effects and technologies, for example,
by requiring attendance at California Air
Resources Board-approved courses (such as the
free, one -day Course #512).
Keeping onsite and furnishing to the lead agency or
other regulators upon request, all equipment
maintenance records and data sheets, including
design specifications and emission control tier
classifications.
MM AQ-1 (DEIR page 4.2 -38) requires a copy of
each unit’s Best Available Control Technology
(BACT) documentation (certified tier
specification or model year specification), and
CARB or SCAQMD operating permit (if
applicable) to be provided to the City at the
time of mobilization of each applicable unit of
equipment.
PDF AQ-6 (DEIR page 4.2 -22) requires tenants
train staff to keep vehicle records in diesel
technologies and comply with CARB
regulations.
PDF AQ-7 (DEIR page 4.2 -23) requires Phase 1
tenants to maintain records on its fleet
equipment and vehicle engine maintenance to
ensure that equipment and vehicles serving the
warehouses within the Project are in good
condition, and in proper tune pursuant to
manufacturer’s specifications.
Conducting an on -site inspection to verify
compliance with construction mitigation and to
identify other opportunities to further reduce
construction impacts.
See PDF AQ-4 and PDF AQ-6,
As noted above, compliance with SCAQMD
rules are required as standard condition and
would be enforced by S CAQMD inspection.
Additionally, the emissions analysis for the
Project determined that regional and localized
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Proposed Mitigation Measures Method of Project Incorporation construction emissions would not exceed
SCAQMD thresholds (see DEIR pages 4.2-27
through 4.2 -29 and pages 4.2 -42 through
4.2-44). CARB’s In-Use Off-Road Diesel Vehicle
Regulation ensures equipment meets
standards.
Using paints, architectural coatings, and industrial
maintenance coatings that have volatile organic
compound levels of less than 10 g/L.
MM AQ-2 (DEIR pages 4.2 -38 to 4.2 -39)
requires the Project to use “Super-Compliant”
low volatile organic compound (VOC) paints
(i.e., a VOC content of 10 g/L or less).
Requiring that all facility-owned and operated fleet
equipment with a gross vehicle weight rating
greater than 14,000 pounds accessing the site
meet or exceed 2010 model -year emissions
equivalent engine standards as currently defined in
California Code of Regulations Title 13, Division 3,
Chapter 1, Article 4.5, Section 2025. Facility
operators shall maintain records on-site
demonstrating compliance with this requirement
and shall make records available for inspection by
the local jurisdiction, air district, and state upon
request.
Refer to PDF AQ-4 on DEIR Page 4.2-22.
Requiring all heavy-duty vehicles entering or
operated on the Project site to be zero-emission
beginning in 2030.
Refer to response to c omment O3 -73. The
existing regulatory environment already
requires various mobile source emissions
reduction measures and transition to ZE and
NZE vehicles (CARB already regulates truck
emissions with the Advanced Clean Truck
Regulation, the Mobile Source Strategy
[including the low-NO X engine emissions
standard], the Sustainable Freight Action Plan,
and the Emissions Reduction Plan for Ports and
Goods Movement, among others).
The DEIR includes design features and
mitigation that would facilitate the use of ZE
and NZE trucks consistent with CARB and
SCAQMD programs (e.g., Advanced Clean Truck
Regulation, Sustainable Freight Action Plan,
SCAQMD Rule 2305, etc.). For example, the
Project design features require all cargo
handling equipment (forklifts, yard trucks, etc.)
to be electrically powered to reduce on -site
criteria pollutant emissions. In order to
promote the use of alternative fuels and clean
fleets and facilitate future installation of
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Proposed Mitigation Measures Method of Project Incorporation electric vehicle supply equipment, the Project
would install 30 electric light-duty vehicle
charging stations, install conduit for 59 electric
light-duty vehicle charging stations, and
designate 119 parking spaces for clean
air/electric vehicle/vanpool parking (refer to
the Project design feature on DEIR pages 4.2-22
through 4.2 -24).
PDF AQ-13 requires the Phase 1 facility
operator to provide tenants with information
about the Carl Moyer Air Program and the On-
Road Heavy-Duty Vehicles Voucher Incentive
Program, which provides funding to purchase
newer vehicles. Additionally, MM AQ-6
requires the Project Applicant to provide $1.00
per square foot in funding for fleet upgrade
financing to incentivize the use of cleaner
operating trucks to reduce future emiss ions
and includes a goal of achieving ZE trucks
beginning in 2030. It should be noted that the
DEIR conservatively does not take credit for
implementation of MM AQ-6 .
Requiring tenants to use zero -emission light- and
medium-duty vehicles as part of business
operations.
Refer to the response above. The Project
includes Project design features and mitigation
that would facilitate the use of ZE and NZE
vehicles consistent with CARB and SCAQMD
programs (e.g., Advanced Clean Truck
Regulation, Sustainable Freight Action Plan,
SCAQMD Rule 2305, etc.).
MM AQ-6 requires Project compliance with
SCAQMD Rule 2305 to facilitate the use of ZE
and NZE trucks. Additionally, MM AQ-6
requires the Project Applicant to provide $1.00
per square foot in funding for fleet upgrade
financing to incentivize the use of cleaner
operating trucks to reduce future emissions
and includes a goal of achieving ZE trucks
beginning in 2030. It should be noted that the
DEIR conservatively does not take credit for
implementation of MM AQ-6 .
Additionally, PDF A Q-2 requires all Phase 1
outdoor cargo handling equipment (including
yard trucks, hostlers, yard goats, pallet jacks,
and forklifts) to be powered by electricity (i.e.,
zero emission).
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Proposed Mitigation Measures Method of Project Incorporation Forbidding trucks from idling for more than two
minutes and requiring operators to turn off
engines when not in use.
The Project would comply with the 5 -minute
limit per CARB regulation/state law.
Implementation of this measure is not
quantifiable because CalEEMod does not allow
for the adjustment of idle times. The Project
includes MM AQ-5 requires signage stating that
drivers turn off engines when not in use,
identifying the State’s 5 -minute idling limit
(California Code of Regulations, Title 13,
Division 3, Article 1, Chapter 10, Section 2485
[Airborne Toxic Control Measur e to Limit
Diesel-Fueled Commercial Motor Vehicle
Idling]), and including telephone numbers of
the building facilities manager and CARB to
report violations.
Additionally, the Project includes design
features to minimize idling. For example, PDF
AQ-5 requires Phase 1 facility operators to train
managers and employees on efficient
scheduling and load management to eliminate
unnecessary queuing and idling of trucks. PDF
AQ-8 requires the facility operator for Phase 1
to ensure that site enforcement staff in c harge
of keeping the daily log and monitoring for
excess idling will be trained/certified in diesel
health effects and technologies, for example,
by requiring attendance at California Air
Resources Board-approved courses (such as the
free, one -day Course #512).
Posting both interior - and exterior -facing signs,
including signs directed at all eight dock and
delivery areas, identifying idling restrictions and
contact information to report violations to CARB,
the air district, and the building manager.
See MM AQ-5 on DEIR pages 4.2 -40 to 4.2 -41.
Installing and maintaining, at the manufacturer’s
recommended maintenance intervals, air filtration
systems at sensitive receptors within a certain
radius of facility for the life of the Project.
A Project specific He alth Risk Assessment was
prepared for the Project and determined that
with the implementation of PDF AQ -2 and
MM AQ-1, health risks would be reduced to
less than significant levels. Therefore,
mitigation requiring air filtration systems such
as MERV 13 filters would not be required.
Installing and maintaining, at the manufacturer’s
recommended maintenance intervals, an air
monitoring station proximate to sensitive
receptors and the facility for the life of the Project
CARB currently operates the Banning Airport
Monitoring Station located approximately 9.6
miles southeast of the Project site. As the
Project emissions modeling did not exceed
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Proposed Mitigation Measures Method of Project Incorporation and making the resulting data publicly available in
real time. While air monitoring does not mitigate
the air quality or greenhouse gas impacts of a
facility, it nonetheless benefits the affected
community by providing information that can be
used to improve air quality or avoid exposure to
unhealthy air.
SCAQMD’s Localized Sensitive Thresholds, the
Project would not affect the ambient air quality
in the area. This measure is not required per
CEQA and would not reduce project emissions.
Constructing electric truck charging stations
proportional to the number of dock doors at the
Project.
MM AQ-4 (DEIR page 4.2 -40) accommodates
the future installation of EV truck charging
stations for when this technology becomes
commercially available and the buildings are
being served by trucks with electric-powered
engines.
Constructing electric light-duty vehicle charging
stations proportional to the number of parking
spaces at the Project.
PDF AQ-10 (DEIR page 4.2 -22) requires at least
30 electric light-duty vehicle charging stations
and conduit for 59 future electric light- duty
charging stations. SC AQ -10 (DEIR page 4.2 -38)
requires electric vehicle supply equipment at
six percent of the total parking spaces.
Requiring all stand-by emergency generators to be
powered by a non-diesel fuel.
Natural gas generators typically require a
dedicated 3” gas line and are limited to 400 kW
or 600 amps of 480 -volt power. Buildings in a
project of this scale would require more power
than could be provided by a non -diesel
generator. In addition, these generators are not
considered a reliable source of power in an
event such as an earthquake.
Requiring operators to establish and promote a
rideshare program that discourages single-
occupancy vehicle trips and provides financial
incentives for alternate modes of transportation,
including carpooling, public transit, and biking.
See MM AQ-3 on DEIR page 4.2-39.
Providing meal options onsite or shuttles between
the facility and nearby meal destinations.
See MM AQ-3 on DEIR page 4.2 -39.
Plant trees and vegetation near structures to shade
buildings and reduce energy requirements for
heating/cooling.
See PDF AQ-18 on DEIR page 4.2 -24.
Additionally, the Project would include
landscaping consistent with City design
requirements.
Preserve or replace onsite trees (that are removed
due to development) as a means of providing
carbon storage.
See PDF AQ -18. The project would include
landscaping consistent with City design
requirements.
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Proposed Mitigation Measures Method of Project Incorporation Replace traffic lights, streetlights, and other
electrical uses to energy efficient bulbs and
appliances.
This is a municipal measure and not applicable
at the project level.
Retrofit municipal water and wastewater systems
with energy efficient motors, pumps, and other
equipment, and recover wastewater treatment
methane for energy production.
This is a municipal measure and not applicable
at the project level.
O6-39 This comment lists general mitigation measures identified by CARB to reduce construction and operational emissions. These mitigation measures were considered during Project design and have been included as design features or mitigation measures if feasible for the Project.
In construction contracts, include language that
requires all off-road diesel-powered equipment
used during construction to be equipped with Tier
4 or cleaner engines, except for specialized
construction equipment in which Tier 4 engines are
not available. In lieu of Tier 4 engines, equipment
can incorporate retrofits such that emission
reductions achieved equal or exceed that of a Tier
4 engine.
MM AQ-1 (DEIR page 4.2 -38) requires
construction equipment to meet CARB Tier 4
standards.
In construction contracts, include language that
requires all off-road equipment with a power
rating below 19 kilowatts (e.g., plate compactors,
pressure washers, etc.) used during project
construction be battery powered.
Construction emissions are mitigated to below
SCAQMD thresholds. Therefore, mitigation
requiring battery powered construction
equipment is not required.
In construction contracts, include language that
requires all heavy -duty trucks entering the
construction site, during either the grading or
building construction phases be model year 2014
or later. Starting in the year 2022, all heavy -duty
haul trucks should also meet CARB's lowest
optional low-NOx standard.
Construction emissions are mitigated to below
SCAQMD thresholds. Therefore, mitigati on
requiring heavy-duty construction trucks to be
model year 2014 is not required.
Include contractual language in tenant lease
agreements that require tenants to use the
cleanest technologies available, and to provide the
necessary infrastructure to supp ort zero-emission
vehicles and equipment that will be operating
onsite.
See PDF AQ-2, PDF AQ-4, PDF AQ-6, PDF AQ-7,
PDF AQ-8, PDF AQ-9, and PDF AQ-10 on DEIR
pages 4.2 -22 through 4.2 -23, as well as
MM AQ-4, and MM AQ-6 on DEIR pages 4.2-40
through 4.2 -41.
Include contractual language in tenant lease
agreements that requires all loading/unloading
docks and trailer spaces be equipped with
electrical hookups for trucks with transport
refrigeration units (TRU) or auxiliary power units
As noted in the DEIR Project Description
(page 3-4) and PDF AQ-1, the Project does not
include cold storage. Additionally, cold storage
is not an allowed use for the site in the Specific
Plan, which establishes the uses and
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(APU). This will eliminate the amount of time that
a TRU powered by a fossil -fueled internal
combustion engine can operate from within the
Project site. Use of zero-emission all-electric plug-
in TRUs, hydrogen fuel cell transport refrigeration,
and cryogenic transport refrigeration are
encouraged and can also be included in lease
agreements.
development standards for the Project. As the
Project would not include cold storage, it would
not include TRUs.
Include contractual language in tenant lease
agreements that requires the tenant be in, and
monitor compliance with, all current air quality
regulations for on -road trucks including CARB's
Heavy-Duty (Tractor -Trailer) Greenhouse Gas
Regulation, Periodic Smoke Inspection Program
(PSIP), and the Statewide Truck and Bus
Regulation.
See PDF AQ-9 on DEIR page 4.2-23. Operators
and manufacturers are required to comply with
these regulations. CARB’s Tractor -Trailer
Greenhouse Gas Regulation reduces
greenhouse gas emissions by improving the
aerodynamic performance and reducing the
rolling resistance of tracto r -trailers. CARB’s
Advanced Clean Trucks regulation is a
manufacturer’s ZEV sales requirement and a
one -time reporting requirement for large
entities and fleets. The Periodic Smoke
Inspection Program (PSIP) is CARB's heavy-duty
vehicle inspection program f or in-use trucks
and buses that includes roadside testing by
CARB. The Statewide Truck and Bus Regulation
requires fleets to upgrade to 2010 or newer
model year engines by January 1, 2023. The
suggested additional mitigation measures are
already State regu lation (i.e., mandatory). As
such these measures are essentially part of the
Project; and therefore, are not mitigation under
CEQA.
Since no cold storage operations are planned,
include contractual language and permit
conditions that prohibit cold storage operations
unless a health risk assessment is conducted, and
the health impacts mitigated.
cold storage is not an allowed use for the site in
the Specific Plan, which establishes the uses
and development standards for the Project.
Therefore, cold storage cannot be added
without additional environmental review and
approvals.
And while the Project has committed to covering
one -quarter of its rooftop with solar to cover the
Project’s needs, the Project should also consider
additional rooftop solar panels, wi th a capacity
that matches the maximum allowed for distributed
solar connections to the grid
See SC AQ -4 (DEIR page 4.2 -37) and MM GHG-1
(DEIR page 4.2 -39). MM GHG-1 requires the
Project to provide 100 percent of the building
load and the plug-load with on-site renewable
energy (i.e., photovoltaic panels). The
mitigation measure inaccurately notes that the
Project has committed to covering one-quarter
of its rooftop with solar.
O6-40 Commented noted and will be taken into consideration by decision-makers.
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O6-41 Chapter 17.20 of the Beaumont Municipal Code establishes a No Net Loss Program, whereby concurrent with the approval of any change in zone from a residential use to a less intensive use, a density bonus will become available to proje ct applicants subsequently seeking to develop property for residential use within the City.
O6-42 Commented noted and will be taken into consideration by decision-makers.
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Comment Letter O7 – Blum Collins & Ho, LLP., Attorneys at Law Gary Ho
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Responses to Comment Letter O7 – Blum Collins & Ho, LLP., Attorneys at Law Gary Ho
O7-1 Comment noted. The City will put the commentor(s) on the Project’s distribution list for any future communications pertaining to the Project.
O7-2 This comment is a summary of the proposed Project. No further response is warranted.
O7-3 Section 3.0, Project Description , of the DEIR includes a detailed description of the Project including site plans, street sections, land use plans and preliminary grading. The grading plans include grading contours with elevations which are all standard and customary for a DEIR.
O7-4 Commentor raises concern that the Specific Plan is not included in the DEIR, specifically so they can review the development standards. Section 3.9 of the DEIR includes a summary of the Development Plan that includes land sues and development standards including building heights, FAR, etc.
O7-5 A list of development projects within the cumulative study area were identified and are presented in Table 4-1. The list includes past projects, projects under construction and approved, and pending projects that are anticipated to be either under construction or operational by the time of the completion of the proposed project. Because the area within which a cumulative effect can occur varies by resource area, for the purpose of this analysis, the geographic scope also varies according to the resource being evaluated. There is no requirement to depict the cumulative projects via an exhibit. The City has instead opted to provide the data in a table format.
The omission of the Potrero Logistics Center Project on Table 4-1 was an error. However, due to the location of the Potrero Logistics Center project in relation to the proposed Project, no additional or greater impacts to study intersection impacts or other related impacts would occur. Refer to Section 3.0, Errata , of this FEIR.
O7-6 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
O7-7 The first sentence states that the EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. This is especially significant as the surrounding community is highly burdened by pollution. This is incorrect. The DEIR fully analyzed and disclosed the proposed Project’s cumulative impacts in Section 4.1, Aesthetics through Section 4.18, Wildfire. More specifically, the DEIR fully analyzed and disclosed the proposed Pr oject’s impacts concerning air quality, transportation, and hazards and hazardous materials in Section 4.2, Air Quality, Section 4.8, Hazards and Hazardous Materials , and Section 4.15, Transportation, respectfully.
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The comment notes that the Project is adjacent to a census tract (6065043811)8 , which is designated as a SB 535 Disadvantaged Community. In fact, the Project is located more than 3 miles from this census tract according to the OEHHA SB 535 mapping. It should be noted that SB 535 does not include project specific requirements or prohibit developments in proximity to the designated communities.
SB 535 directs 25 percent of the proceeds from the Greenhouse Gas Reduction Fund (i.e., funds from the AB 32 cap-and-trade program) to go to projects that provide a benefit to disadvantaged communities (as identified by the OEHHA mapping). As noted throughout this Final EIR, an HRA was prepared for the Project and quantified risk levels at nearby sensitive receptors and determined that impacts would be less than significant.
O7-8 Refer to response to comment O7-7 above.
O7-9 The comment states that the DEIR did not used an approved energy compliance modeling software to calculate energy demand for the Project , citing that CalEEMod is not listed as approved software. The energy analysis presented in the DEIR is for purposes of estimating Project demand. The analysis included in the DEIR is not intended to demonstrated compliance with the 2019 Building Energy Efficiency Standards. Therefore, the energy analysi s does not need to be redone using either CBECC -Com, EnergyPro, or IES Ve and the DEIR does not need to be recirculated.
O7-10 The commenter does not agree that the Project is consistent with SCAG RTP/SCS Goal 2:
Improve mobility, accessibility, reliability, and travel safety for people and goods based on the Project’s significant and unavoidable impact on transportation/VMT. Howe ver, the proposed Project includes numerous mitigation measures and design features that would reduce emissions; refer to DEIR pages 4.2-22 through 4.2-24, pages 4.2-38 through 4.2-41, pages 4.7- 29 through 4.7-31, and pages 4.7-39 through 4.7-40. Mitigation Measure MM AQ-3 requires the implementation of a transportation demand management (TDM) program. The TDM will detail potential strategies that would reduce the use of single occupancy vehicles by increasing the number of trips by walking, bicycle, carpool, vanpool, and transit. The Project’s location in proximity to existing transit routes supports SCAG’s goal by providing an accessible workplace for employees who choose to use transit. The Project’s significant impact with regard to VMT is not relevant in determining accessibility and use of transit.
O7-11 The comment inaccurately states that the DEIR states that, the Project will impede the SCAG region’s ability to enhance the preservation, security, and resilience of the regional transportation system because it will result in significant and unavoidable cumulatively considerable impacts to Transportation/VMT.”
As noted in the cumulative impact section of DEIR Section 4.15, Transportation, the Project would not result in significant traffic related impacts resulting from conflicts with transportation plans or policies and is consistent with all applicable General Plan policies such as working with Caltrans, making needed roadway improvements, payment of TUMF fee or
8 https://oehha.ca.gov/calenviroscreen/sb535
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fair share contribution etc. Furthermore, according to DEIR Appendix K , Traffic Study , the City of Calimesa, with Caltrans and the County of Riverside proposes to reconstruct the Interstate 10 (I -10)/Cherry Valley Boulevard interchange to relieve congestion and improve traffic operations.
• Widen Cherry Valley Boulevard to two lanes in each direction • Add turn pockets along Cherry Valley Boulevard approaching on-ramps • Add pedestrian crosswalks and curb ramps
• Reconstruct and realign on- and off-ramps
• Realign Calimesa Boulevard north of the I -10/Cherry Valley Boulevard interchange • Provide channelized turning on Cherry Valley Boulevard to Calimesa Boulevard • Install new traffic signals
• Construct sidewalks and bicycle lanes along Cherry Valley Boulevard • Add a 1,300-foot-long auxiliary lane to the ea stbound off-ramp and 3,400-foot-long auxiliary lane to the westbound on-ramp.
Although not a regional transportation project, the Project would support SCAG’s RTP/SCS Goal
3. O7-12 The City respectfully disagrees with the comment. The Project is not a regi onal transportation project and therefore doesn’t dictate the City’s and Caltrans potential improvements on to the regional system. Furthermore, the comment states because of the EIR’s determination that the Project will have significant and unavoidable cumulatively considerable impacts to Air Quality, Greenhouse Gas Emissions, and Transportation/VMT, the proposed project is directly inconsistent with Goal 7 to adapt to a changing climate. This is also incorrect. The air quality, health risk, and greenhouse gas emissions assessments, and traffic impact analysis reports prepared for the Project were prepared in accordance with applicable state and/or regional thresholds. Additionally, any updates to the air quality, health risk, GHG assessment and VMT analysis and/or DEIR document would not change the findings or conclusions of the impacts as significant and unavoidable.
O7-13 The City agrees with this comment. See Section 3.0, Errata, of this FEIR for these changes.
However, also note that removal of farmland of local importance is not considered a significant impact under CEQA and therefore, does not make the proposed Project’s agriculture and forestry impact analysis inadequate.
O7-14 Refer to response to comment O3-100. The commenter notes that RTP/SCS Goal 5 is to reduce GHG emissions and improve air quality. The proposed Project includes numerous mitigation measures and design features that would reduce emissions; refer to DEIR pages 4.2-22 through
4.2-24, pages 4.2-38 through 4.2-41, pages 4.7-29 through 4.7-31, and pages 4.7-39 through
4.7-40. These include implementation of a TDM program to reduce vehicle trips, charging
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stations and infrastructure to support future electric vehicle demand to reduce mob ile emissions, prohibiting idling when engines are not in use, including signage to report violations, incentives for using cleaner operating trucks, facilitate compliance with SCAQMD Rule 2035, requiring renewable energy, achieving CalGreen Tier 2 energy efficiency standards, diverting solid waste, and using electric landscape equipment. The Project’s exceedance of thresholds are primarily due to the size of the Project and not the lack of reduction measures. The implementation of the various mitigation me asures noted above and design features would ensure emissions are reduced consistent with 2020-2045 RTP/SCS Goal 5.
O7-15 As noted on DEIR page 4.7-48, although the Project exceeds regional thresholds for criteria pollutants, the Project’s Localized Significance Thresholds (LSTs) would be less than significant (refer to DEIR pages 4.2-42 through 4.2-46) and health risk impacts would be less than significant (refer to DEIR pages 4.2-50 through 4.2-55), which indicates that the regional increases shown in DEI R Tables 4.2-10 through 4.2-14 are over counting truck emissions since not all these trips are in reality new to the air basin. Additionally, the Project would incorporate PDF AQ-2 (electric cargo handling equipment) and MM AQ-1 (4 construction equipment) that would also reduce localized impacts. The reduction of localized emissions would support healthy and equitable communities.
O7-16 As discussed in Section 4.10, Land Use and Planning of the DEIR, CEQA requires that an EIR consider whether a Project would conflict with any applicable land use plan, policy, or regulation (including, but not limited to a general plan, specific plan, or zoning ordinance) that was adopted for the purpose of avoiding or mitigating environmental effect(s). This environmental determination differs from the larger policy determination of whether a proposed Project is consistent with a jurisdiction’s general plan. The broader general plan consistency determination considers all evidence in the record concerning the Project characteristics, its desirability, as well as its economic, social, and other non -environmental effects. Regarding plan or policy consistency, a project is evaluated in terms of whether the proposed site plan, project design, and/or development within a given loc ation would substantially impede implementation of an adopted plan or policy resulting in a significant environmental effect. The mere fact that a project may be inconsistent in some manner with particular policies in a general plan or zoning ordinance doe s not, per se, amount to a significant environmental effect. In the context of land use and planning, significant impacts occur when a conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project results in an adverse physical environmental impact.
The Project site is presently designated as “Single Family Residential” by the General Plan. A new Specific Plan and a General Plan Amendment would change the property’s land use designation from Single Family Residential to Industrial, General Commercial, and Open Space.
The proposed land use designations would be consistent with the proposed e‐commerce center, commercial area, and permanent open space uses. Because approval of the Specific Plan and General Plan Amendment are part of the overall Project approvals, it is appropriate to measure consistency with the General Plan with these Project components in mind. As such, the conclusion in the DEIR is correct.
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O7-17 Refer to response to comment O7-16 above.
O 7-18 The Project’s inconsistencies with the AQMP and California’s statewide GHG reduction goals were thoroughly discussed in their appropriate impact analysis threshold within Section 4.2, Air Quality , and Section 4.7, Greenhouse Gas Emissions of the DEIR.
O7-19 Refer to Reponses to Comments O7-10 through O7-15. The commenter incorrectly states that the Project would but inconsistent with the SCAG 2020-2025 RTP/SCS.
O7-20 Although the Project’s potential employment is forecasted to represent a significant portion of SCAG’s forecasted employment for the City, this does not constitute a significant impact according to CEQA. The City is considered housing -rich and in need for employment opportunities as the City has a high unemployment rate and a majority of C ity residents commute outside the City for work.
O7-21 The commenter is incorrect and the proposed Project’s impact to population and housing does not require the Project quantify all employees generated by all other non-residential projects to determine a project-level impact concerning population and housing. As stated in DEIR Section 4.12, Population and Housing , the Project would not result in cumulative citywide or countywide population and housing impacts, since the Project would be ade quately served by the regional and local workforce and improve SCAG’s job-housing balance for the region, without necessitating additional housing . Furthermore, the Project’s potential employment opportunities would provide much needed employment within the City and support the City’s pursuit in a more balanced jobs -housing ratio.
O7-22 The City respectfully disagrees with the comment. Refer to response to comment O3-21 above.
The information in Table 4.12-7 is correct and accurately depicts the Project’s e mployment, household, and jobs -housing ration versus SCAG’s demographic data for the City and County.
O7-23 Upon approval of the General Plan Amendment and Specific Plan would make the proposed Project consistent with the General Plan.
O7-24 The commenter claims that the DEIR does not provide specific information regarding commutes and that construction jobs generated by the Project would potentially lead to the relocation of construction employees to the City. As discussed in Appendix K of the DEIR, the R ivTAM tool was used to calculate VMT for the Project . The RivTAM model considers the interaction between different land uses based on socio -economic data such as population, households, and employment. The suggested updates to the VMT analysis and/or DEIR document would not change the findings or conclusions of the transportation/VMT impact as significant and unavoidable.
Regarding the relocation of construction employees to the City, construction activities would not result in direct generation of population growth. Construction activities are short term in nature and construction workers would go from one job to another and typically live and work within the same region.
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O7-25 Chapter 17.20 of the Beaumont Municipal Code establishes a No Net Loss P rogram, whereby concurrent with the approval of any change in zone from a residential use to a less intensive use, a density bonus will become available to project applicants subsequently seeking to develop property for residential use within the City.
O7-26 See response to comment O7-25 above.
O7-27 The proposed project is consistent with the ITE description for ITE High-Cube Short -Term Storage Warehouse for Buildings 1 and 2, and ITE Warehouse for Building 3. High -Cube Fulfillment Center Warehouse and High-Cube Parcel Hub Warehouse uses are not proposed.
O7-28 C EQA Guidelines Section 15064.3, subdivision (a) states “For the purposes of this section ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” The OPR 2018 Technical Advisory clarifies the definition of the term automobile.
O7-29 The suggested updates to the VMT analysis and/or DEIR document would not change the findings or conclusions of the transportation/VMT impact as significant and unavoidable.
O7-30 This is already discuss ed on page 5-4 of Section 5.0, Other CEQA Considerations.
O7-31 Refer to response to comment O7-21 above.
O7-32 Refer to Section 3.0, Errata, of this FEIR that reflects the changes.
O7-33 Section 6.0 of the DEIR includes a detailed analysis of the Project alternatives as required by CEQA. The analysis concludes that the reduced intensity alternative would reduce some of the potentially significant impacts, but it does not reduce any significant impacts to below a level of significant. Put another way, the reduced density alternative will not reduce any of the significant impacts and does not meet the Project objectives so was dismissed.
O7-34 Comment noted and will be taken into consideration by decision-makers.
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Comment Letter G1 – Sonny Lee
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G1-1 Comment noted. This comment acknowledges the receipt of the Notice of Availability for the DEIR.
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Comment Letter G2 – Mary Daniel
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Responses to Comment Letter G2 – Mary Daniel
G2-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G2-2 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-3 As discussed in Section 4.10, Land Use and Planning of the DEIR, CEQA requires that an EIR consider whether a Project would conflict with any applicable land use plan, policy, or regulation (including, but not limited to a general plan, specific plan, or zoning ordinance) that was adopted for the purpose of avoiding or mitigating environmental effect(s). This environmental determination differs from the larger policy determination of whether a proposed Project is consistent with a jurisdiction’s general plan. The broader general plan consistency det ermination considers all evidence in the record concerning the Project characteristics, its desirability, as well as its economic, social, and other non -environmental effects. Regarding plan or policy consistency, a project is evaluated in terms of whether the proposed site plan, project design, and/or development within a given location would substantially impede implementation of an adopted plan or policy resulting in a significant environmental effect. The mere fact that a project may be inconsistent in some manner with particular policies in a general plan or zoning ordinance does not, per se, amount to a significant environmental effect. In the context of land use and planning, significant impacts occur when a conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project results in an adverse physical environmental impact.
The Project site is presently designated as “Single Family Residential” by the General Plan. A new Specific Plan and a General Plan Amendment would change the property’s land use designation from Single Family Residential to Industrial, General Commercial, and Open Space.
The proposed land use designations would be consistent with the proposed e‐commerce center, commercial area, and permanent open space uses. Because approval of the Specific Plan and General Plan Amendment are part of the overall Project approvals, it is appropriate to measure consistency with the General Plan with these Project components in mind. As such, the conclus ion in the DEIR is correct.
G2-4 Comment noted. Refer to response to comment G2-3, above.
G2-5 The City respectfully disagrees with the commentor. On September 26, 2006, City Planning Commission (Commission) held a public hearing on the Sunny‐Cal Specific Plan, North Brookside Community Plan, Sphere of Influence Amendment, and Annexation to the City. After the conclusion of the public testimony, the Commission closed the public hearing and continued the Project to November 14, 2006, at which time the Commis sion requested refinements to the Sunny-Cal Specific Plan and took action to recommend City Council approval of the Project.
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On July 17, 2007, the City Council held a public hearing on the Project. At the conclusion of the public testimony, the City Council closed the public hearing and after consideration of the Project, requested elimination of the North Brookside Community Pl an component of the Project and a revision to the Sphere of Influence Amendment to include only that territory within the boundaries of the Sunny‐Cal Specific Plan area. The approved 2007 Sunny‐Cal Specific Plan document incorporated the City Council’s dir ection.
The previous Project Applicant for the Sunny-Cal Specific Plan never moved forward with the development of the Sunny-Cal project even though they had approvals to do so. As such, the property was sold and the current Project Applicant has submitte d an application for a new specific plan.
Adoption of the proposed Specific Plan (SP2021-0005) is a discretionary action subject to City Council approval. Adopted by Ordinance, the Specific Plan document will serve both planning and regulatory functions. This document contains the development standards and procedures necessary to fulfill these purposes, and would replace the existing Sunny-Cal Specific Plan. The proposed Specific Plan would implement the City’s General Plan as amended. The Specific Plan would be considered by the Planning Commission and City Council and would be adopted by Ordinance and would become the zoning for the Project.
G2-6 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-7 Comment noted. Section 4.2, Air Quality, of the DEIR fully analyzes and discloses all air quality impacts associated with the development of the proposed Project. Similarly, Section 4.15, Transportation, fully analyzed and discloses all traffic-related impacts associated with t he proposed Project.
Although not required as part of CEQA, the Project includes a full Traffic Impact Analysis that contains an LOS discussion; refer to Appendix K of the DEIR . This additional information is provided for informational purposes only, as a dditional delay – to an intersection or roadway segment – is no longer considered a significant impact under CEQA. The DEIR includes a full discussion of all required impacts, as required by CEQA.
G2-8 This text is taken directly from the DEIR, as the comm entor notes in Comment G2-1. The comment restates the impact determination regarding cumulative air pollutant emissions impacts. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-9 Comment noted. This comment summarizes the commenter’s views on the increase in vehicle trips and opines that feasible mitigation includes denying the Project. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary. Section 4.2, Air Quality , of the DEIR fully analyzed and discloses all air quality impacts associated with the development of the proposed Project.
Additionally, a Health Risk Assessment was prepared for the proposed Project (refer to Appendix B of the DEIR). The Health Risk Assessment determined that the proposed Project would not have an adverse impact on surrounding residents.
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G2-10 This comment states that truck emissions would be detrimental to human health and that current legislation in California prohibits warehouse use within 1,000 feet of a residential use.
A health risk assessment (HRA) was conducted pursuant to the South Coast Air Quality Management District ’s (SCAQMD’s) Health Risk Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions, the SCAQMD Risk Assessment Procedures, and guidance from the Office of Environmental Health Hazard Assessment (Refer to DEIR Appendix B).
Results of the HRA indicate that construction and operation of the Project would not result in significant caner or non-cancer risks (refer to DEIR pages 4.2 -50 through 4.2-55 and DEIR Appendix B, Table 8). With regard to California legislation prohibiting the citing of warehouse uses within 1,000 feet of residential use, this legislation is pending and has not been promulgated. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is nec essary.
G2-11 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1. The comment restates the description and effects of diesel particulate matter (DPM). The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-12 As discussed in Section 4.10, Land Use and Planning , the baseline conditions and impact analyses are based on review of Project maps and drawings; analysis of aerial and grou nd‐level photographs; and review of various data available in public records, including local planning documents (inclusive of the General Plan). The determination that a Project component will or will not result in “substantial” adverse effects on land us e and planning standards considers the available policies and regulations established by local and regional agencies and the amount of deviation from these policies in the Project’s components. The proposed Project would be consistent with the City’s Zoning Ordinance and Zoning Map; therefore, it would be consistent with all goals, policies, within the Beaumont GP upon Project approval. As such, inconsistency with City land use plans and regulations and the creation of environmental effects from Project implementation would be less than significant.
A Health Risk Assessment (HRA) was prepared for the proposed Project (refer to Appendix B of the DEIR). The Health Risk Assessment determined that the proposed Project would not have an adverse impact on surrounding residents. As discussed in Section 4.2 of the DEIR, localized construction and operational emissions would not exceed applicable SCAQMD localized thresholds. In addition, the results of the HRA indicate that the Project would not result in significant cancer or non-cancer risks. Therefore, the Project would not produce localized air pollution in a way that would impact existing air quality -sensitive receptors. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other C EQA issue. Therefore, no further response is necessary.
G2-13 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1. The comment restates that the Project would be inconsistent with the AQMP. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue.
Therefore, no further response is necessary.
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G2-14 As discussed in Section 4.2, Air Quality , of the DEIR, ozone concentrations are dependent upon a variety of complex factors, including the presence of sunlight and precursor pollutants, natural topography, nearby structures that cause building downwash, atmospheric stability, and wind patterns. Because of the complexities of predicting ground -level ozone concentrations in relation t o the NAAQS and CAAQS, none of the health-related information can be directly correlated to the pounds/day or tons/year of emissions estimated from a single, proposed project. It should also be noted that this analysis identifies health concerns related to particulate matter, CO, O3, and NO2. Table 4.2-1 of the DEIR includes a list of criteria pollutants and summarizes common sources and effects. Thus, this analysis is reasonable and intended to foster informed decision making. This is standard industry pra ctice.
G2-15 This comment is a quote from the DEIR. The comment restates the significance determination with regards to GHG emissions. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-16 The comment summarizes the commenters view of the City’s inability to control on -road motor vehicle emissions. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. There fore, no further response is necessary.
G2-17 This comment is a quote from the DEIR. The comment restates the potential health effects of community noise. Section 4.11, Noise of the DEIR, noise associated with construction activity would be limited to the hours between 6:00 A.M. and 6:00 P.M. during the months of June through September and between 7:00 A.M. and 6:00 P.M. during the months of October through May, pursuant to City Municipal Code § 9.02.111. In addition, no sounds would exceed 55 dBA for inter vals of more than 15 minutes per hour as measured in the interior of the nearest occupied residence or school. As shown in Table 4.11-10, project construction would not exceed the Federal Transit Administration’s noise threshold as noise levels would not exceed 70 dBA, interior noise levels would attenuate to 55 dBA or less (conservatively assuming 15 dBA outdoor to indoor noise reduction with windows open).
Therefore, noise levels when measured in the interior of the nearest occupied residence would not exceed the City’s threshold of 55 dBA at any time and impacts would be less than significant. Lastly, concerning operational noise, Tables 4.11-13 through 4.11-15, concluded that the Project at Project buildout (2027) and Project horizon year (2040) would not create significant noise impacts. Refer to Section 4.11, Noise for more information.
G2-18 The comment summarizes the commenters view of the subjectivity of noise and the noise from semi-trucks. The comment does not raise a specific issue with t he adequacy of the DEIR or raise any other CEQA issue. Refer to response G2-17 and Section 4.11, Noise for more information.
G2-19 The comment summarizes the commenters view of the potential cumulative traffic noise impact resulting from operation of the Project and other projects in the vicinity. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue.
Therefore, no further response is necessary.
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G2-20 The comment summarizes the commenters view of the City’s responsibility to protect the health and welfare of its citizens with respect to noise. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-21 Comment noted. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-22 Comment noted. The comment does not raise a specific issue with the adequacy of the DEIR or rais e any other CEQA issue. Therefore, no further response is necessary.
G2-23 Comment noted. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-24 Comment noted. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-25 Comment noted. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G2-26 The BCVWD 2020 Urban Water Management Plan (UWMP) discusses the Beaumont Basin and the Project WSA addresses the UWMP and addresses the current condition of water supply and known future projects.
G2-27 The BCVWD 2020 Urban Water Management Plan (UWMP) discusses the Beaumont Basin and the Project WSA addresses the UWMP and addresses the current condition of water supply and known future projects.
G2-28 The supply of recycled water is related to drainage or stormwater quality. The Project has an approved Hydrology Report and Water Quality Management Plan.
G2-29 The Project has made pr ovisions to use recycled water once available via the City’s recycled water system.
G2-30 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-31 Under CEQA, a scenic vista is defined as a viewpoint that provides expansive views of a highly- valued landscape for the benefit of the public. The Beaumont GP does not designate any scenic vistas near the Project site or in the City. Although no area within the City is officially designated as a scenic vista, the City is situated a t a half-mile elevation in the County’s The Pass Area Plan, south of southern California’s highest peak, San Gorgonio Mountain, and north of San Jacinto Peak which provide the most prominent views from the City. Because there are no scenic vistas on the Project site or in the vicinity of the Project site and the implementation of the Project would not obstruct views of the scenic vistas provided by the San Bernardino
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Mountains and the San Jacinto Mountains from any publicly accessible point outside of the Project site, impacts in this regard would be less than significant.
G2-32 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-33 Refer to Section 4.1, Aesthetics, Light, and Glare of the DEIR. As noted in Section 4.1, all aesthetics impacts were deemed to be less than significant.
G2-34 As discussed in Chapter 3, Project Description, the Project includes the following approvals:
Specific Plan Adoption. SP2021-0005
Adoption of the proposed Specific Plan is a discretionar y action subject to City Council approval. Adopted by Ordinance, the Specific Plan document will serve both planning and regulatory functions. This document contains the development standards and procedures necessary to fulfill these purposes, and would re place the existing Sunny-Cal Specific Plan. The proposed Specific Plan would implement the City’s General Plan as amended. The Specific Plan would be considered by the Planning Commission and City Council and would be adopted by Ordinance and would become the zoning for the Project.
General Plan Amendment No. PLAN2021 -0656
The Project site is presently designated as “Single Family Residential” by the General Plan. A General Plan Amendment would change the property’s land use designation from Single Family R esidential to Industrial, General Commercial, and Open Space. The proposed land use designations would be consistent with the proposed e‐commerce center, commercial area, and permanent open space uses.
Tentative Parcel Map No. PM2021-0009
The Specific Plan area is comprised of several parcels. The Project includes a Tentative Parcel Map (TPM) to create five legal development parcels and would dedicate the rights -of-way for utility easements, if required by the City.
Plot Plan/Site Plan (Plot Plan) No. PP2021-0388
Three separate Plot Plans for the Project, consisting of an e -commerce project with three proposed structures, parking, landscaping, drainage facilities, and new and driveways is proposed. A separate Plot Plan/Site Plan will be required for each bui lding area within the Specific Plan. Statutory Development Agreement
A statutory development agreement, authorized pursuant to California Government Code § 65864 et seq., may be processed concurrently with the approval of this Specific Plan. The development agreement would include, among other items, the term of entitlements and any provisions for off‐site improvements if applicable. Ministerial actions that follow the initial approvals include the following:
• Grading Plans/Permits
• Improvement Plans
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• Final Map review and approval (City), recordation (County) • Jurisdictional Permits (if required by agencies)
With the approvals listed above, the Project would be consistent with the General Plan and Zoning Map.
Additionally, to further reduce changes in the visual environment, the Project would incorporate perimeter landscaping, trees, and ground covers to visually buffer the structures.
For this reason, it is anticipated that implementation of the commercial and e -commerce uses would not degrade the visual c haracteristics that are already considered low. Impacts in this regard would be less than significant. The Project also proposes to preserve a total of 30.6 acres of permanent open space within planning area 3 to ensure that adjacent uses are adequately separated from the Project.
G2-35 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-36 Pursuant to PRC 21100 and in accordance with the guidance in CEQA Guidelines §15126.6, the City conducted an alternatives analysis that includes a range of reasonable alternatives that would feasibly attain most of the basic objectives of the Project consistent with CEQA §15124(b), while avoiding or lessening impacts. The Project Applicant cannot propose to develop a project on parcel(s) that they do not own or control. See DEIR Section 6.0 for a discussion of alternatives considered.
G2-37 Refer to response to comment G2-31, above.
G2-38 The DEIR fully analyzes and disclosed all impacts associated with the Project, including transportation related impacts. Refer to Section 4.15, Transportation, for additional information.
G2-39 This text is taken directly from the DEIR, as the commentor notes in Comment G2 -1.
G2-40 Comment noted. Refer to DEIR Section 6.0 for a discussion of alternatives considered for additional analysis.
G2-41 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G2-42 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G2-43 Comment noted. The City communicated with the commentor that Appendix L was provided on the City’s website. Additionally, hard copies of the DEIR and appendices are located at City Hall, and on State Clearinghouse’s website located at
https://ceqanet.opr.ca.gov/2021090378/2
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G2-44 Refer to response to comment G2-43, above.
G2-45 Refer to response to comment G2-43, above.
G2-46 Refer to response to comment G2-43, above.
G2-47 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G2-48 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
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Comment Letter G3 – Allan Lovelace
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Responses to Comment Letter G3 – Allan Lovelace
G3-1 Comment noted.
G3-2 A Water Supply Assessment (WSA) was prepared for the proposed Project. The WSA determined that there are adequate water supplies to service the Project. Refer to Appendix I for additional information.
G3-3 The DEIR fully analyzed and disclosed all impacts associated with the Project, including air quality impacts. Refer to Section 4.2, Air Quality , for additional information.
G3-4 Comment noted. Refer to responses to comments G3-2 and G3-3, above, for additional information regarding water supply and air quality impacts related to the Project.
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Comment Letter G4 – Gayla Faux
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Responses to Comment Letter G4 – Gayla Faux
G4-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
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Comment Letter G5 – Dolores Weitz
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Responses to Comment Letter G 5 – Dolores Weitz
G5-1 Comment noted.
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Comment Letter G6 – Pablo Soto
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Responses to Comment Letter G 6 – Pablo Soto
G6-1 The commentor is correct, in that the Project does include a warehouse component. More specifically, the Project is proposed as follows:
Planning Area 1 (Parcels 1, 2, and 3) is proposed to be developed with three separate e - commerce/warehouse buildings with supporting office, as follows:
• Building 1: 985,860 square feet
• Building 2: 1,213,235 square feet
• Building 3: 358,370 square feet
Planning Area 2 (Parcel 4) would include the development of up to 150,000 square feet of commercial uses and would be developed as part of Phase 2, as follows:
• Hotel: 100,000 square feet
• General Retail: 25,000 square feet
• Food Uses: 25,000 square feet
Planning Area 3 (Parcel 5) would remain as permanent open space.
Lastly, the distance between the Project and Beaumont City Hall is irrelevant as it pertains to approval/disapproval of the Project. The Project is located in a semi -rural area of Beaumont, adjacent unincorporated Riverside County. Development associated with the Project is not located directly adjacent to any residential neighborhoods.
G6-2 Please consider that 100’s of man hours were spent thoroughly evaluating the potential impacts associated with 18 environmental resources areas for the Project.
Traffic/transportation impacts are evaluated in DEIR Section 4.15 and noise impact s are evaluated in DEIR Section 4.11.
Also note that traffic (diesel) circulation associated with the Project would predominantly occur between the Project site and the I -10/Cherry Valley Boulevard interchange. Traffic (diesel) associated with the Project would not frequent Brookside Avenue, as the Project is not accessible via Brookside Avenue, nor is there a fully functional interchange at I -10 and Brookside Avenue. Refer to Section 3.0, Project Description and Section 4.15, Transportation of the DEIR which discusses the Pr oject’s circulation system and recommended improvements.
Additionally, refer to page 4.15 -19 of the DEIR for more information which describes the Project site access improvements . Project traffic would not overrun roadways associated with residential neig hborhoods. Lastly, permanent open space would separate the Project from Stetson to the south.
G6-3 Comment noted. Mr. Soto will remain on the Project distribution list for any future communications pertaining to the Project.
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Comment Letter G7 – Steve Mehlman
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Responses to Comment Letter G7 – Steve Mehlman
G7-1 The name of the Project Applicant, as presented in the Notice of Availability, is Exeter Cherry Valley Land, LLC.
G7-2 The Project would be presented to the City Council and the Planning Commission at hearings, on dates yet to be determined, following the close of the comment period, June 6, 2022.
G7-3 Impacts to sensitive receptors were evaluated in DEIR Section 4.2: Air Quality , Impact 4.2.3.
Said impacts were found to be less than significant with mitigation incorporated.
G7-4 According to Attachments B -1 and B-2 of the Project’s Traffic Study (DEIR A ppendix K ), the High-Cube Transload and Short -Term Storage proposed use would generate 493 truck trips daily, and the Warehousing proposed use would generate 166 truck trips daily.
G7-5 Evaluating whether or not the introduction of warehouses lowers the va lues of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by decision-makers.
Additionally, development associated with the Project would not be located adjacent to Solera/Oak Valley Greens, but would be separated by Brookside Avenue, undeveloped land, and permanent open space.
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Comment Letter G8 – Richard Hobson
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Responses to Comment Letter G8 – Richard Hobson
G8-1 This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
G8-2 This comment addresses the method in which emissions increases is measured. Increases in emissions attributed to the Project have been estimated and summarized in Section 4.2 of the DEIR. With regard to air pollution monitoring stations within the vicinity of the Project, the nearest monitoring station is the Banning Airport Monitoring Station located approximately
9.5 miles to the southeast of the site. A summary of pollutant concentrations from the years 2018, 2019, and 2020 is included in Section 4.2 of the DEIR. The comment does not raise a specific issue with the adequacy of the DEIR or raise any other CEQA issue. Therefore, no further response is necessary.
G8-3 See response to comment G8-2.
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Comment Letter G9 – Eugene De Fouw
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Responses to Comment Letter G 9 – Eugene DeFouw
G9-1 This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
G9-2 This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
G9-3 This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
G9-4 Traffic circulation associated with the Project would predominantly occur between the Project site and the I -10/Cherry Valley Boulevard interchange. Traffic associated with the Project would not frequent Brookside Avenue, as the Project is not ac cessible via Brookside Avenue, nor is there a fully functional interchange at I -10 and Brookside Avenue. Refer to Section 4.11, Transportation, page 4.15-19 for more information which describes the Project site access improvements. Furthermore, Planning Ar ea 3 would be preserved as permanent open space.
According to DEIR Exhibit 3.0-6: Conceptual Site Plan, the Project could add 425 dock doors.
However, this conceptual site plan is shown for illustrative purposes as one potential layout.
Final site planning will be provided as part of implementing project site plan review submittals G9-5 According to DEIR Appendix K , Traffic Study , the City of Calimesa, with Caltrans and the County of Riverside proposes to reconstruct the Interstate 10 (I -10)/Cherry Valley Boulevard interchange to relieve congestion and improve traffic operations.
The Locally Preferred Alternative will include the following improvements:
• Widen Cherry Valley Boulevard to two lanes in each direction • Add turn pockets along Cherry Valley Boulevard approaching on-ramps • Add pedestrian crosswalks and curb ramps
• Reconstruct and realign on- and off-ramps
• Realign Calimesa Boulevard north of the I -10/Cherry Valley Boulevard interchange • Provide channelized turning on Cherry Valley Boulevard to Calimesa Boulevard • Install new traffic signals
• Construct sidewalks and bicycle lanes along Cherry Valley Boulevard • Add a 1,300-foot-long auxiliary lane to the eastbound off-ramp and 3,400-foot-long auxiliary lane to the westbound on-ramp
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The Project proposes to contribute towards the planned improvements at the I -10/Cherry Valley Boulevard interchange by a payment of TUMF fee and or fair share contribution.
G9-6 This comment does not identify a specific concern with the adequacy of the D EIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
G9-7 This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis. However, your comment will be taken into consideration by decision-makers.
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Comment Letter G10 – Carol Marquez
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Responses to Comment Letter G 10 – Carol Marquez
G10-1 Comment noted.
G10-2 Visual impact were evaluated in Section 4.1, Aesthetics, of the DEIR and were found to be less than significant.
G10-3 Comment noted.
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Comment Letter G11 – Kathleen Schneider
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Responses to Comment Letter G 11 – Kathleen Schneider
G11-1 Comment noted. Air quality impacts are assessed in DEIR Section 4.2, Air Quality ; noise and vibration impact s are assess ed in Section 4.11, Noise; and transportation impacts in Section 4.15, Transportation.
Noise impacts would be less tha n significant with the exception of cumulative off-site traffic noise along Cherry Valley Boulevard (from Project access to Hannon Road, from Hannon Road to Union Street, and from Union Street to Nancy Avenue). Cumulative traffic noise impacts would occur primarily as a result of increased traffic on local roadways due to buildout of the Project and other projects in the vicinity.
See DEIR Appendix K, Traffic Study for recommended roadway improvements; I -10/Cherry Valley Boulevard interchange improvements; site adjacent roadway improvements; and site access improvements.
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Comment Letter G12 – Rodger Thompson
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Responses to Comment Letter G 12 – Rodger Thompson
G12-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G12-2 Permanent open space and undeveloped land would separate the Project from Stetson to the south. Visual impact were evaluated in DEIR Section 4.1, Aesthetics , and were found to be less than significant. Evaluating whether or not the introduction of warehouses lowers the values of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by decision-makers.
G12-3 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers .
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Comment Letter G13 – Linda Amarante
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Responses to Comment Letter G 13 – Linda Amarante
G13-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Permanent open space and undeveloped land would separate the Project from Stetson to the south. Noise/vibration impacts are analyzed in DEIR Section 4.2, Air Quality and transportation impacts in DEIR Section 4.15, Transportation . There is no justification that the Project would affect the safety of the neighborhood.
G13-2 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environ mental analysis.
However, your comment will be taken into consideration by decision-makers .
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Comment Letter G14 – Helen Messrah
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Responses to Comment Letter G 14 – Helen Messrah
G14-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G14-2 Comment noted. This comment does not identify a specifi c concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G14-3 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
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Comment Letter G15 – Gerald Griffin
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Responses to Comment Letter G 15 – Gerald Griffin
G15-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Evaluating whether or not the introduction of warehouses lowers the values of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by de cision-makers.
Additionally, development associated with the Project would not be located adjacent to Solera/Oak Valley Greens, but would be separated by Brookside Avenue, undeveloped land, and permanent open space.
G15-2 According to DEIR Appendix K , Traffic Study , the City of Calimesa, with Caltrans and the County of Riverside proposes to reconstruct the Interstate 10 (I -10)/Cherry Valley Boulevard interchange to relieve congestion and improve traffic operations.
The Locally Preferred Alternative will include the following improvements:
• Widen Cherry Valley Boulevard to two lanes in each direction • Add turn pockets along Cherry Valley Boulevard approaching on -ramps • Add pedestrian crosswalks and curb ramps
• Reconstruct and realign on- and off-ramps
• Realign Calimesa Boulevard north of the I -10/Cherry Valley Boulevard interchange • Provide channelized turning on Cherry Valley Boulevard to Calimesa Boulevard • Install new traffic signals
• Construct sidewalks and bicycle lanes along Cherry Valley Boulevard • Add a 1,300-foot-long auxiliary lane to the eastbound off-ramp and 3,400-foot-long auxiliary lane to the westbound on-ramp
The Project proposes to contribute towards the planned improvements at the I -10/Cherry Valley Boulevard interchange by a payment of TUMF fee and or fair share contribution.
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Comment Letter G16 – Mark and Audrey Larsh
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Responses to Comment Letter G 16 – Mark and Audrey Larsh G16-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comme nt related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
G16-2 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Planning Area 2 (Parcel 4) would include the development of up to 150,000 square feet of commercial uses and would be developed as part of Phase 2, as follows:
• Hotel: 100,000 square feet
• General Retail: 25,000 square feet
• Food Uses: 25,000 square feet
See DEIR Appendix K, Traffic S tudy for recommended roadway improvements; I -10/Cherry Valley Boulevard interchange improvements; site adjacent roadway improvements; and site access improvements.
G16-3 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
Air quality impacts are assessed in DEIR Section 4.2, Air Quality; noise and vibration impacts are assess ed in Section 4.11, Noise; and transportation impacts in Section 4.15, Transportation.
Evaluating whether or not the introduction of warehouses lowers the values of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by decision-makers.
Development associated with the Project would not be located adjacent to Solera/Oak Valley Greens, but would be separated by Brookside Avenue, undeveloped land, and permanent open space.
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Comment Letter G17 – Patricia Skriletz
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Responses to Comment Letter G 17 – Patricia Skriletz
G17-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
According to DEIR Appendix K , Traffic Study , the City of Calimesa, with Caltrans and the County of Riverside proposes to reconstruct the Interstate 10 (I -10)/Cherry Valley Boulevard interchange to relieve congestion and improve traffic operations.
The Locally Preferred Alternative will include the following improvements:
• Widen Cherry Valley Boulevard to two lanes in each direction • Add turn pockets along Cherry Valley Boulevard approaching on-ramps • Add pedestrian crosswalks and curb ramps
• Reconstruct and realign on- and off-ramps
• Realign Calimesa Boulevard north of the I -10/Cherry Valley Boulevard interchange • Provide channelized turning on Cherry Valley Boulevard to Cal imesa Boulevard • Install new traffic signals
• Construct sidewalks and bicycle lanes along Cherry Valley Boulevard • Add a 1,300-foot-long auxiliary lane to the eastbound off-ramp and 3,400-foot-long auxiliary lane to the westbound on-ramp
The Project proposes to contribute towards the planned improvements at the I -10/Cherry Valley Boulevard interchange by a payment of TUMF fee and or fair share contribution.
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Comment Letter G18 – Patricia Norcutt
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Responses to Comment Letter G 18 – Patricia Norcutt
G18-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Air quality impacts are assessed in DEIR Section 4.2, Air Quality; noise and vibration impact are assess ed in Section 4.11, Noise; and transportation impacts in Section 4.15, Transportation.
G18-2 Impacts to sensitive receptors were evaluated in DEIR Section 4.2, Air Quality , Impact 4.2.3.
Said impacts were found to be less than significant with mitigation incorporated.
G18-3 According to Attachments B-1 and B-2 of the Project’s Traffic Study (DEIR Appendix K ), the High-Cube Transload and Short -Term Storage proposed use would generate 493 truck trips daily, and the Warehousing proposed use would generate 166 truck trips daily.
G18-4 Comment noted. This comment does not identify a specific concern wit h the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Evaluating whether or not the introduction of warehouses lowers the values of homes is not within the purview of CEQA and therefore is not included in the DEIR. However, your comment will be taken into consideration by decision-makers.
Development associated with the Project would not be located adjacent to Solera/Oak Valley Greens, but would be separated by Brookside Avenue, undeveloped land, and permanent open space.
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Comment Letter G19 – John and Sandra Stearn
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Responses to Comment Letter G 19 – John and Sandra Stearn G19-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Impa cts to sensitive receptors were evaluated in DEIR Section 4.2, Air Quality , Impact 4.2.3.
Said impacts were found to be less than significant with mitigation incorporated.
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Comment Letter G20 – Wiltraud Dukes
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Responses to Comment Letter G 20 – Wiltraud Dukes
G20-1 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.
Impacts to sensitive receptors were evaluated in DEIR Section 4.2, Air Quality , Impact 4.2.3.
Said impacts were found to be less than significant with mitigation incorporated.
G20-2 Comment noted. This comment does not identify a specific concern with the adequacy of the DEIR or note a specific issue or comment related to the DEIR’s environmental analysis.
However, your comment will be taken into consideration by decision-makers.