Beaumont City Council
May 21, 2024

ME Beaumont Pointe Specific Plan
MO Final Environmental Impact Report
D-6 The commenter suggests mitigation to require electric or alternative -fueled (i.e., non -diesel) construction equipment, if available, including but not limited to, concrete/industrial saws, pumps, aerial lifts, material hoist, air compressors, forklifts, excavator, wheel loader, and soil compactors. Pursuant to the commenter's request the following mitigation measure has been added to Page 4.3-54 of the Draft EIR. The mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-14 If electric or non -diesel off -road trucks and construction support equipment, including but not limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers, plate compactors, and air compressors are available in the construction contractor's equipment fleet and can fulfill the Project's construction requirements during the building construction, paving, and architectural coating phases of Project construction, such equipment shall be used during Project construction. This requirement shall be noted on plans submitted for building permit issuance.

D-7 The commenter suggests mitigation requiring owners and operators of future development projects shall maintain records of all trucks associated with project construction to document that each truck used meets these emission standards and make the records available for inspection. Pursuant to the commenter's request the following mitigation measure has been added to Page 4.3-54 of the Draft EIR. The mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-15
Project construction contractors shall maintain records of all trucks associated with Project construction to document that each truck used meets emission standards. Records shall be kept on -site for the duration of construction activities and shall be made available for periodic inspection by City of Beaumont staff or their designee.

D-8 The commenter suggests construction -related mitigation requiring electric vehicle (EV) charging stations or, at a minimum, provide the electrical infrastructure and electrical panels shall be appropriately sized during construction. Pursuant to the commenter's request, the following mitigation measure has been added to Page 4.3-54 of the Draft EIR. The mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-13
Plans submitted for grading permit issuance and building permit issuance shall specify a designated area of the construction site where electric or non -diesel vehicles, equipment, and tools can be fueled or charged. The provision of temporary electric infrastructure for such purpose shall be approved by the utility provider, Southern California Edison (SCE). If SCE will not approve the installation of temporary power for this purpose, the establishment of a temporary electric charging area will not be required. If electric equipment will not be used on the construction site because the construction contractor(s) does not have such equipment in its fleet (as specified in Mitigation Measure MM

4.3-14), the establishment of a temporary electric charging area also will not be required. If electric powered equipment is in the contractor(s) equipment Lead Agency: City of Beaumont SCH No. 2020099007

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fleet, and SCE approval is secured, the temporary charging location is required to be established upon issuance of grading permits and building permits.

D-9 The commenter suggests the provision of temporary traffic controls such as a flag person, during all phases of significant construction activity to maintain smooth traffic flow, where necessary. As part of the Project's Regulatory Requirement (RR) 17-2, prior to the issuance of grading or building permits, the Project Applicant shall prepare and the City of Beaumont shall approve, a temporary traffic control plan for construction. The temporary traffic control plan shall comply with the applicable requirements of the California Manual on Uniform Traffic Control Devices. A requirement to comply with the temporary traffic control plan shall be noted on all grading and building plans and also shall be specified in bid documents issued to prospective construction contractors. Thus, the City determines that additional mitigation is not warranted.

D-10 The commenter suggests implementation of dedicated turn lanes for the movement of construction trucks and equipment on and off -site, where applicable. The Project site is currently undeveloped and access to the Project site during construction would be provided via Jack Rabbit Trail and at the terminus of 4th Street, which would not interfere with any existing traffic movements. Therefore, dedicated turn lanes are not required. However, refer to Regulatory Requirement RR 17-2 and response to Comment D-9. No further response is required.

D-11
The commenter suggests mitigation to ensure that vehicle traffic inside the project site is as far away as feasible from sensitive receptors. As discussed in Section 4.3, Air Quality, of the Draft EIR, the nearest sensitive receptor to the Project site is Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site.

Therefore, Project's construction activities would not be in close proximity to sensitive receptors. Thus, the City determines that additional mitigation is not warranted.

D-12 The commenter suggests mitigation to reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less during construction. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of best available dust control measures (BACM) during active operations capable of generating fugitive dust. According to Table 1 of South Coast AQMD Rule 403, BACM includes limiting vehicle speeds to 15 miles per hour.10 Nevertheless, to ensure implementation of Rule 403, the following Regulatory Requirement has been added to the Draft EIR and included in the Mitigation Monitoring and Reporting Program, and Draft EIR Page 4.3-36 is modified as follows:

4.3.6 REGULATORY REQUIREMENTS AND PROJECT DESIGN FEATURES The following Regulatory Requirements (RRs) are applicable regardless of CEQA and would apply to any project under similar circumstances and, therefore, do not constitute mitigation measures. However, they will nonetheless be included in the Project's Mitigation Monitoring and Reporting Program to further ensure the implementation of the mandated RRs. 10 https://www.agmd.gov/docs/default-source/rule-book/rule-iv/rule-403.pdf?sfvrsn=4 Lead Agency: City of Beaumont SCH No. 2020099007

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RR 3-1 The Project shall comply with the provisions of South Coast Air Quality Management District Rule 403, "Fugitive Dust." Rule 403 requires implementation of best available dust control measures during construction activities that generate fugitive dust, such as earth moving and stockpiling activities, grading, and equipment travel on unpaved roads, including limiting vehicle speeds to 15 miles per hour.

Thus, the City determines that additional mitigation is not warranted.

D-13 The commenter suggests mitigation to suspend all excavating and grading operations when wind speeds (as instantaneous gusts) exceed 25 mph. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of BACM during active operations capable of generating fugitive dust. Rule 403 also specifies requirements during high wind periods (instantaneous wind speeds which exceed 25 mph). During high wind conditions earth moving activities shall cease or apply water to soil not more than 15 minutes prior to moving such soil to limit visible dust emissions to 20 percent opacity. Additionally, Rule 403 includes measures to reduce dust during grading such as wind barriers, covering bulk materials, application of water or stabilizers, and wind breaks to reduce wind speed. According to Table 1 of South Coast AQMD Rule 403, BACM includes stabilizing wind erodible surfaces to reduce dust. A stabilized surface means any previously disturbed surface area or open storage pile which, through the application of dust suppressants, shows visual or other evidence of surface crusting and is resistant to wind driven fugitive dust and is demonstrated to be stabilized. Stabilization can be demonstrated by one or more of the applicable test methods contained in the Rule 403 Implementation Handbook. Refer also to Regulatory Requirement RR 3-1 above and response to Comment D-12. Thus, the City determines that additional mitigation is not warranted.

D-14 The commenter suggests mitigation to suspend use of all construction activities that generate air pollutant emissions during first stage smog alerts. As discussed in Section 4.3, Air Quality, of the Draft EIR, the nearest sensitive receptor to the Project site is Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site. As concluded in, Table 4.3-9, Localized Significant Summary - Construction, construction of the Project would not result in the exposure of any sensitive receptors to substantial pollutant concentrations (refer to Page 4.2-47). Additionally, the Project would have no potential to result in or contribute to a CO "Hot Spot" or a significant human health or cancer risk to nearby receptors (refer to Pages 4.3-43 to 4.3-48). Thus, the City determines that additional mitigation is not warranted.

D-15 The commenter suggests mitigation to configure construction parking to minimize traffic interference. As part of the Project's Regulatory Requirements (RR) 17-2, prior to the issuance of grading or building permits, the Project Applicant shall prepare and the City of Beaumont shall approve, a temporary traffic control plan for construction. The temporary traffic control plan shall comply with the applicable requirements of the California Manual on Uniform Traffic Control Devices. The traffic control would include configuration of construction parking to minimize traffic interference Thus, the City determines that additional mitigation is not warranted.

Lead Agency: City of Beaumont SCH No. 2020099007

ME Beaumont Pointe Specific Plan
MO Final Environmental Impact Report
D-16 The commenter suggests mitigation to require covering of all trucks hauling dirt, sand, soil, or other loose materials. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of BACM during active operations capable of generating fugitive dust.

According to Table 1 of South Coast AQMD Rule 403, BACM includes covering of haul vehicles prior to exiting the site. Refer also to Regulatory Requirement RR 3-1 and response to Comment D-12. Thus, the City determines that additional mitigation is not warranted.

D-17 The commenter suggests mitigation to install wheel washers where vehicles enter and exit the construction site onto paved roads or wash off trucks and any equipment leaving the site for each trip. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of BACM during active operations capable of generating fugitive dust. According to Table 1 of South Coast AQMD Rule 403, BACM includes washing mud and soils from equipment at the conclusion of trenching activities can prevent crusting and drying of soil on equipment. Section (d)(5) of Rule 403 states no person shall conduct an active operation with a disturbed surface area of five or more acres, or with a daily import or export of 100 cubic yards or more of bulk material without utilizing at least one of the measures listed in subparagraphs (d)(5)(A) through (d)(5)(E) at each vehicle egress from the site to a paved public road, which includes installing and utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the site. Refer also to new Regulatory Requirement RR 3- 1 and response to Comment D-12. Thus, the City determines that additional mitigation is not warranted.

D-18 The commenter suggests mitigation to apply non-toxic soil stabilizers according to manufacturers' specifications to all inactive construction areas (previously graded areas inactive for ten days or more). As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of BACM during active operations capable of generating fugitive dust.

According to Table 3 of South Coast AQMD Rule 403, contingency control measures for large operations includes applying water with a mixture of chemical stabilizer diluted to not less than 1/20 of the concentration required to maintain a stabilized surface for a period of six months on the last day of active operations prior to a weekend, holiday, or any other period when active operations will not occur for not more than four consecutive days. Refer also to new Regulatory Requirement RR 3-1 and response to Comment D-12. Thus, the City determines that additional mitigation is not warranted.

D-19 The commenter suggests mitigation to replace ground cover in disturbed areas as quickly as possible to minimize dust. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of best available dust control measures (BACM) during active operations capable of generating fugitive dust. Rule 403 also requires activities defined as "large operations" to notify the South Coast AQMD by submitting specific forms; a large operation is defined as any active operation on property containing 50 or more acres of disturbed surface area; or any earth moving operation with a daily earth -moving or throughput volume of 3,850 cubic meters (5,000 cubic yards), three times during the most recent 365 day period. Rule 403 provides the option for addressing inactive disturbed areas (but does not require) by Lead Agency: City of Beaumont SCH No. 2020099007

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establishing a vegetative ground cover within 21 days after active operations have ceased.

Refer also to new Regulatory Requirement RR 3-1 and response to Comment D-12. Thus, the City determines that additional mitigation is not warranted.

D-20 The commenter suggests mitigation to pave construction roads and road shoulders, where applicable. Refer to response to Comments D-12 to D-19, which demonstrates how the Project will comply with South Coast AQMD Rule 403 to minimized fugitive dust during construction.

In compliance with this rule, the Project will pave construction roads and shoulders as needed for compliance.

D-21 The commenter suggests mitigation to require sweeping streets at the end of the construction day with South Coast AQMD Rule 1186 and 1186.1 compliant sweepers if visible soil is carried onto adjacent public paved roads (recommend water sweepers that utilize reclaimed water). As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be required to comply with South Coast AQMD Rule 403, which requires the implementation of BACM during active operations capable of generating fugitive dust. According to Table 3 of South Coast AQMD Rule 403, BACM includes using sweeping and water spray to clear forms. Refer also to new Regulatory Requirement RR 3-1 and response to Comment D-12.

Nevertheless, to ensure compliance with Rules 1186 and 1186.1, the following Regulatory Requirement has been added to the Draft EIR and included in the Mitigation Monitoring and Reporting Program, and Draft EIR Page 4.3-36 is modified as follows:

RR 3-2 The Project shall comply with the provisions of South Coast Air Quality Management District Rule 1186 "PMI() Emissions from Paved and Unpaved Roads and Livestock Operations" and Rule 1186.1, "Less -Polluting Street Sweepers." Adherence to Rule 1186 and Rule 1186.1 reduces the release of criteria pollutant emissions into the atmosphere during construction.

Thus, the City determines that additional mitigation is not warranted.

D-22 The commenter provides a summary of the Project's air quality impacts during operation and refers to the list of additional feasible mitigation measures provided in the subsequent portion of the letter that the City should consider. Refer to response to Comments D-23 to D-29 for a detail discussion on the suggested mitigation measures. Thus, no further response is required.

D-23 The commenter suggests a revision to Mitigation Measure MM 4.3-5 to include the incentive and programs found on the South Coast AQMD Incentives & Programs landing page. Pursuant to the commenter's request, Mitigation Measure MM 4.3-5 is revised and Draft EIR Page 4.3- 52 is modified as indicated below. The modification to the mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-5
Prior to tenant occupancy, the Project Applicant or successor in interest shall provide documentation to the City demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program and other Programs promulgated by South Lead Agency: City of Beaumont SCH No. 2020099007

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Coast AQMD (which can be found at the SCAQMD Incentives & Programs landing page, http://www.aqmd.gov/home/programs) that provide incentives for using cleaner -than -required engines and equipment.

D-24 The commenter suggests mitigation to require the use of zero -emission, near -zero emission, or 2014 model year heavy-duty trucks to reduce ongoing and long-term NOX emissions. As of January 1, 2023, all trucks registered in California are required to be 2010 model year heavy duty trucks per State law (13 California Code of Regulations Section 2025; the "CARB Truck and Bus Regulation"). At present, requiring zero -emission vehicles is economically and technologically infeasible; also, such vehicles are not available on a large enough scale to be relied upon. In a report titled "Transitioning to Zero -Emission Heavy -Duty Freight Vehicles," the International Council on Clean Transportation (ICCT) provides an overview of advancing technologies (ICCT, September 2017)." The ICCT reports that although the technology is advancing and although at some point in the distant future non -diesel technology will likely be used in mass to power freight movement, "zero -emission vehicle technologies do present considerable challenges. They have a combination of near- and long-term barriers, issues, and questions that will have to be addressed before they can become widespread replacements for conventional trucks and tractor -trailers that are typically diesel fueled" (ICCT, p. 31). "Tesla's announced battery electric semi -tractor prototype is the only (emphasis added) battery electric project we found in our [world-wide] assessment targeting long -haul heavy-duty applications" (ICCT, p. 31). Requiring the proposed Project to utilize emerging technology as mandatory mitigation when the various types of technological advancements and their timeframes for common availability are not known with any certainty, is not a feasible mitigation measure.

An EIR must describe feasible measures that could minimize the project's significant adverse impacts. 14 Cal Code Regs §15126.4(a)(1). An EIR may decline to propose a mitigation measure that would not effectively address a significant impact. An EIR also need not identify and discuss mitigation measures that are infeasible. Nor must an EIR analyze in detail mitigation measures it concludes are infeasible.

Further, South Coast AQMD recently adopted a Warehouse Indirect Source Rule, Rule 2305, in May 2021. Rule 2305 applies to warehouse operators and owners of warehouses greater than or equal to 100,000 square feet of indoor floor space within a single building that may be used for warehousing activities. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be subject to compliance with Rule 2305 (refer to Pages 4.3-22 and 4.3-23).

Since the proposed Project will not be operated by the current owner, it is not feasible to commit to specific provisions of Rule 2305; however, future tenants will be obligated to comply with its provisions. Additionally, Mitigation Measure 4.3-12 requires the City's Planning Department to confirm that tenant lease agreements requiring the Project Applicant to provide $1.00 per square foot in funding for fleet upgrade financing to be used over the term of their lease on Zero Emissions (ZE) and Near Zero Emissions (NZE) delivery vans or trucks.

Compliance with Rule 2305 would reduce air quality effects associated with the warehouse industry, including the Project, throughout the Air Basin. 11 https://www.theicct.org/sites/default/files/publications/Zero-emission-freight-trucks_ICCT-white- pa per_26092017_vF.pdf
Lead Agency: City of Beaumont SCH No. 2020099007

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■ Final Environmental Impact Report
D-25 The commenter incorrectly assumes that implementation of the proposed Project will require a subsequent, project level environmental analysis and EIR, and that the City should restrict the amount of daily truck traffic to and from the Project to be analyzed in the subsequent project -level analysis. The EIR is a project level EIR (see Draft EIR, Section 1.1, p.l-2), and no other EIR is contemplated or required at this time. The recommendation to impose and enforce a truck trip cap is not feasible or practical nor required by CEQA. CEQA requires that an EIR evaluate the proposed Project based on reasonable assumptions and foreseeable actions.

The number of passenger vehicle and truck trips that the Project is expected to generate is based on Institute of Transportation Engineers (ITE) in their Trip Generation Manual (10th Edition), and Transportation Uniform Mitigation Fee (TUMF) High -Cube Warehouse Trip Generation Study. Information on ITE and TUMF trip rate and vehicle type mixes are found in Attachment C of this Final EIR. The comment does not present any evidence that truck trips associated with the proposed Project would be greater than disclosed in the Draft EIR. There is no substantive information presented by this comment or by any of the information in the Project's administrative record that contradicts the reasonable assumptions made in the Draft EIR about the expected number of truck trips. Instituting a cap on the number of trucks that can access the Project's buildings is not required under CEQA, nor would it be reasonable or feasible for the City to monitor and enforce such a requirement. The Draft EIR has made reasonable assumptions based on substantial evidence by using ITE and TUMF recommendations based on a reasonable type of building occupant that would be permitted by the site's zoning.

For this reason, the City respectfully rejects the commenter's recommendation to impose and enforce a numerical cap on the number of trucks that the Project attracts during its operation or the suggestion that future environmental analysis is required. Based on the foregoing discussion, the City concludes that it is unnecessary to impose and enforce a numerical cap on the number of trucks that access the site on a daily basis during the Project's operation.

D-26 The commenter suggests the Final EIR include design considerations for future development projects to further reduce air quality and health risk impacts. The Specific Plan for the proposed Project contains all required design considerations for the proposed Project and no future projects are under consideration at this time. Therefore, it would be speculative, and therefore unnecessary, for the Final EIR to anticipate future development projects on the Project site.

The commenter suggests that the Final EIR include a requirement that truck routes be clearly marked with trailblazer signs, so that trucks will not travel next to or near sensitive land uses.

The primary regional travel route serving the Project area is SR -60, which is a designated truck route in the City of Beaumont. All truck traffic will access travel east to 4th Street to access SR -60 and/or I-10. As shown on Figure 4.9 in the City's General Plan, the City's Truck Priority Network is designed to minimize travel near sensitive land uses. Additionally, the following mitigation measure has been added to Page 4.3-54 of the Draft EIR. The mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-17
Prior to building final, the Project Applicant or successor in interest shall install signs at each truck exit driveway that provides directional information to the City's truck route. Text on the sign shall read "To Truck Route" with a directional arrow.

Lead Agency: City of Beaumont SCH No. 2020099007

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■ Final Environmental Impact Report
D-27 The commenter suggests that the Project restrict overnight truck parking in sensitive land uses by providing overnight truck parking inside the future development project site. City of Beaumont Municipal Code Section 10.12.030 prohibits commercial vehicles exceeding a manufacturer's gross vehicle weight (commonly referred to as GVW) rating of 10,000 pounds (as defined by California Vehicle Code Section 390) from stopping, standing, or parking on any street, highway, alley, public right-of-way or residential property within the City.

Additionally, there is no prohibition against overnight truck parking at the Project site or sensitive receptors near the Project site. As discussed in Section 4.3, Air Quality, of the Draft EIR, the nearest sensitive receptor to the Project site is Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site.

Therefore, it is not reasonably foreseeable that vehicles accessing the Project site would park in sensitive areas overnight. Accordingly, no revisions to the Draft EIR are warranted.

D-28 The commenter suggests a design for future development projects; however, no future development projects are anticipated by the project -level EIR. The commenter suggests that check -in gates be placed well inside the Project site to prevent truck queuing offsite. As shown in Figure 3-16, Conceptual Site Plan, the Project's proposed industrial uses (Buildings 1 through 5) would be located at the western portion of the Project site while commercial uses at the eastern portion, closest to the Project access to Jack Rabbit Trail. Check -in gates for trucks at the Project site would be located at each end of the truck courts and away from public streets to prevent queuing of trucks outside the property. Moreover, the Project consists of a Specific Plan, therefore, Figure 3-16 is conceptual was prepared to analyze environmental impacts associated with Project operations. The precise location of building placement and orientation and truck courts identified in this Draft EIR are considered conceptual in that they may be modified according the City's requirements. Upon adoption of the Specific Plan, subsequent project specific plot plans or any other actions requiring either ministerial or discretionary approvals would be required to demonstrate consistency with the Specific Plan. Thus, the City determines that additional mitigation is not warranted.

D-29 As previously indicated, no future development projects are anticipated by the project -level EIR. The commenter suggests that truck traffic inside the Project site be placed as far away as feasible from sensitive receptors. Refer to Figure 4.3-1, Sensitive Receptor Locations, and Figure 4.3-2, Modeled Emission Source, of the Draft EIR, which show the sensitive receptor locations, on- and off -site truck travel and loading dock activity. As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would not result in significant health risk impacts to sensitive receptors during operation (refer to Page 4.3-43 to 4.3-48). Additionally, walls and fences would be provided around loading and dock areas, trailer parking areas, and parking lots to screen on -site uses from public views and public roads. Thus, the City determines that additional mitigation is not warranted.

D-30 The commenter states the EIR concludes that the Project would result in significant and unavoidable greenhouse gas emissions impacts, and provides a list of sources to consider for additional mitigation measures. Refer to response to Comments D-31 to D-33 for responses related to each source. Thus, no further response is required.

D-31 The commenter suggests, without identifying specific measures, that the Project consider mitigation measures listed in the California Attorney General's Bureau of Environmental Lead Agency: City of Beaumont SCH No. 2020099007

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Justice guidance document on Warehouse projects, Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act. Many of these mitigation measures are duplicative to those suggested in this comment letter and Comment Letter B. Refer to response to Comments B-34 to B-63 and Comments D-5 to D-29 for a discussion on these suggested mitigation measures.

Additionally, many of these measures are regional in nature or directed to regional planning efforts or policy formation by government bodies, or the daily business operation practices of private enterprises that are outside the scope of the proposed Project. CEQA does not require adoption of every imaginable mitigation measure. CEQA's requirement applies only to feasible mitigation that will "substantially lessen" a project's significant effects. (Public Resources Code, § 21002.) As explained by one court: A lead agency's "duty to condition project approval on incorporation of feasible mitigation measures only exists when such measures would [avoid or] `substantially lessen' a significant environmental effect." (San Franciscans for Reasonable Growth v. City and County of San Francisco (1989) 209 Ca1.App.3d 1502, 1519.) "Thus, the agency need not, under CEQA, adopt every . . . mitigation scheme brought to its attention or proposed in the project EIR." (Ibid.) Rather, an EIR should focus on mitigation measures that are feasible, practical, and effective. (Napa Citizens for Honest Government v. Napa County Board of Supervisors (2001) 91 Ca1.App.4th 342, 365.)
D-32 The commenter suggests that the City consider mitigation measures listed in the South Coast AQMD 2022 South Coast Air Quality Management Plan (AQMP) appendices IV -A, B, and C.

These documents have been reviewed, and they do not include project specific mitigation measures, but rather propose highly programmatic goals, strategies, and measures to reduce air quality emissions. Further, the commenter does not specify which mitigation measures it is recommending in these documents. The AQMP is a regional blueprint for achieving air quality standards and healthful air by providing the strategy and the underlying technical analysis for how the region will meet federal standards by the required dates and continue progress to achieve the state standards. The primary purpose of the 2022 AQMP is to identify, develop, and implement strategies and control measures to meet the 2015 8 -hour ozone NAAQS - 70 parts per billion (ppb) as expeditiously as practicable, but no later than the statutory attainment deadline of August 3, 2038 for South Coast Air Basin and August 3, 2033 for the Riverside County portion of the Salton Sea Air Basin (referred as Coachella Valley Planning Area or Coachella Valley). The majority of the proposed measures are being developed over the next several years and implemented prior to 2037.

As discussed in Section 4.3, Air Quality, of the Draft EIR, the Project would be inconsistent with AQMP Criterion No. 1 and 2, resulting in a potentially significant impact. The Project would implement development -specific air quality mitigation measures to reduce the Project's construction source and operational source air pollutant emissions. Additionally, incorporation of contemporary energy -efficient technologies and operational programs would reduce Project air pollutant emissions and assist South Coast AQMD in meeting its overarching emission reduction goals. The implementation of feasible mitigation measures, the Project's emission - reducing design features, and operational programs are consistent with and support overarching AQMP air pollution reduction strategies. Project implementation of mitigation measures would also promote timely attainment of AQMP air quality standards and would bring the Project Lead Agency: City of Beaumont SCH No. 2020099007

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into conformance with the AQMP to the extent feasible (refer to Draft EIR Pages 4.3-36 to

4.3-38). Accordingly, no revisions to the Draft EIR are warranted.

D-33 The commenter suggests, without specifying measures to be considered, that the City consider mitigation measures listed in the United States Environmental Protection Agency (U.S. EPA):

Mobile Source Pollution - Environmental Justice and Transportation webpage. The source provides a summary of future plans and policies by the U.S. EPA related to environmental justice and transportation, including new criteria standards for medium and heavy duty trucks, partnerships with state and local agencies on reducing mobile source air pollution, partnerships with federal agencies on truck electrification, etc. Without further specifics about which mitigation measures the commenter would like the City to consider that could be applied to this Project, no further response is required. The Project would be required to comply with all applicable federal, state, regional, and local regulations in place at the time of construction and operation. Additionally, environmental justice is not a topic that is required to be evaluated or considered pursuant to CEQA Guidelines Sections 15120-15132 (Contents of Environmental Impact Reports). Accordingly, no revisions to the Draft EIR are warranted.

D-34 The commenter expresses concerns on the potential public health impacts of future siting of other projects that may include sensitive populations in living situations within proximity of sources of air pollution, and recommends that prior to approving future development projects, the Lead Agency consider the impacts of air pollutants on people who will live in and/or nearby a new project location, and provide mitigation where necessary, including consideration of measures in the CARB Air Quality Land Use and Handbook: A Community Health Perspective. This comment does not raise any issues concerning the adequacy of the environmental analysis provided in the Draft EIR. The commenter also recommends review of the CARB Air Quality Land Use and Handbook: A Community Health Perspective. Refer to Pages 4.3-43 to 4.3-48 of the Draft EIR, for an analysis of the Project's impacts related to health risks impacts on sensitive receptors. Refer also to response to Comments D-14 and D-

35. Thus, no further response is required.

D-35 The commenter identifies strategies such as filtration systems to reduce health risk exposures in nearby sensitive receptors. As discussed in Section 4.3, Air Quality, of the Draft EIR, the nearest maximally exposed individual receptor to the Project site is Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site. As concluded in, Table 4.3-9, Localized Significant Summary - Construction, construction of the Project would not result in the exposure of any sensitive receptors to substantial pollutant concentrations (refer to Page 4.2-47). Similarly, Table 4.3-10, Localized Significant Summary — Operation, concluded that operational emissions would not exceed the South Coast AQMD's localized significant thresholds at the maximally impacted receptor location. (refer to Pages 4.3-43 to 4.3-48). Thus, the City determines that additional mitigation is not warranted.

D-36 The commenter requests that the Draft EIR analyze the overlapping construction and operation emissions for peak 2025 construction emissions and phase 2 operational emissions and compare against regional air quality thresholds of significance for operations to determine their level of significance. As discussed in Section 4.3, Air Quality, of the Draft EIR, emissions during the potential overlap of construction and operation are shown in Table 4.3-8. For the Lead Agency: City of Beaumont SCH No. 2020099007

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relevant overlap period (2025), the construction emissions for 2025 in Table 4.3-6 show the totals and which emissions exceed the threshold of significance for construction emissions. For operational emissions for phase 2 (2025), Table 4.3-7 shows emissions and whether operational thresholds of significance are exceeded. South Coast AQMD provides no evidence as to why the operational threshold should be applied to potential overlap of construction and operational activity and when it imposed this requirement. In fact, the reason South Coast AQMD has different thresholds for construction activity versus operational activity is due to the short-term nature of construction impacts versus the on -going nature of operational impacts. To date, South Coast AQMD has not published a threshold or guidance for potential construction and operational overlapping activities. Lastly, even if the operational threshold were applied, impacts would remain significant and unavoidable for emissions associated with VOC, NOx, CO, PMIo and PM2.5 and there would be no new significant impact that was not already identified in the Draft EIR and underlying technical reports (refer to Draft EIR Section 4.3, Air Quality and Technical Appendix B1).

D-37 The commenter requests that the Draft EIR include a discussion on stationary equipment (such as, boilers, heaters, ovens, emergency generators, fire pumps, etc.) that will be used and require South Coast AQMD permits. The future users/operators of the Project's buildings are unknown at this time. As such, it cannot presently be determined whether future users/operators will require the use of stationary equipment. However, the City acknowledges the requirement that users/operators adhere to mandatory South Coast AQMD Rules, and the requirement to obtain South Coast AQMD permits as may be needed for the operation of their business.

D-38 The commenter provides conclusionary remarks and requests written responses to comments in accordance with Public Resources Code Section 21092(a) and CEQA Guidelines Section 15088(b). In accordance with Public Resources Code Section 21092(a) and CEQA Guidelines Section 15088(b), written responses to the South Coast AQMD's comments are included in this Final EIR. A copy of the Final EIR will be provided to the South Coast AQMD prior to the City's consideration of the Final EIR for certification. At least 10 days before certifying a Final EIR, the lead agency must provide any public agency that commented on the EIR with a written proposed response to the agency's comments. This requirement may be met by providing the agency with a copy of the Final EIR. No further response is required.

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COMMENT LETTER 1
From: Sharon Geiser
To: Christina Taylor
Subject: Beaumont Pointe
Date: Monday, February 6, 2023 3:54:08 PM
Here is an article from yesterday's Los Angeles Times
®❑i 2023 Feb 5 LAT Warehouses replace farms as big ...

We have this beautiful pass area surrounded by mountains where Beaumont residents can participate in all sorts of outdoor activities year round. This is why we need to keep it from becoming a warehouse town with poor air quality and streets plugged up with semi trucks and trailers. Our city is already dealing with traffic congestion on all of our major roadways, I can only imagine what it would be like with dozens more warehouses from Yucaipa to Morongo. This is why we are opposed to the proposed Beaumont Pointe development.

It is a sad day when corporate rights and land use policy override the health and safety of a whole community.

Thank you,
Sharon Geiser
406-261-4652
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Responses to Comment 1
Geiser, Sharon, dated February 6, 2023.
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The commenter expresses general opposition to the Project and concerns related to poor air quality, semi -truck movement, and traffic congestion in the City of Beaumont. The commenter attached an article regarding replacement of farms with warehouses. The Project site is currently not a farm or used for agricultural uses and is vacant and undeveloped. The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR. Refer to Draft EIR Sections 4.3, Air Quality, and 4.17, Transportation, for an analysis of the Project's impacts related to those environmental topics. The commenter's concern related to warehouse uses are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 2
From: Tiya Jones
To: Christina Taylor
Subject: Disapproval of Warehouse
Date: Tuesday, February 7, 2023 1:11:17 PM
Good Afternoon,
I am writing to share my concerns of the proposed warehouse off of Cherry Valley Blvd. As an alumni of Beaumont, I would like you to reconsider this addition to our City. The warehouse would take away from wildlife and block the view of our beautiful mountains, which is what the name Beaumont means. Have you considered the impact if a fire was to break out? Would our firehouse be able to handle such a blaze? What about the people who currently live in the area, is traffic going to make life miserable for them? What about the smog that it is going to bring to the area? Air quality is going to drop drastically. We see what happens to our small town when the train stops or when Coachella is in session, why would you add another headache to the citizens of this city? Please express to the Mayor that the little green rectangles, no matter the amount, should not influence the choices he makes for the citizens of this town. Let's not be like Banning and build a giant warehouse promising jobs and then once built, leave it empty. Thank you for the opportunity to express my opinion.

Lead Agency: City of Beaumont SCH No. 2020099007

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Responses to Comment 2
Jones, Tiya, dated February 7, 2023.
2-1 The commenter expresses general opposition to the proposed warehouse project off of Cherry Valley Boulevard. The Project site is not located along Cherry Valley Boulevard. Thus, no further response is required. Additionally, the commenter expresses concern about the impact of the Project on wildlife, view of mountains, fire, traffic and smog (air quality). Refer to Draft EIR Sections 4.1, Aesthetics, 4.3, Air Quality, 4.4, Biological Resources, 4.17, Transportation, and 4.18, Wildfire, for an analysis of the Project's impacts related to those environmental topics. In addition, the commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR. The commenter's concern related to warehouse uses are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 3
From: Nicole Wheelwright
To: Carole Kendrick
Cc: Christina Taylor
Subject: FW: Beaumont Pointe Warehouse Specific Plan
Date: Tuesday, February 7, 2023 3:52:19 PM
See comment received below.
• Nicole
From: [email protected] mcgee
Sent: Monday, February 6, 2023 9:11 PM
To: Nicole Wheelwright
Subject: Beaumont Pointe Warehouse Specific Plan
Council Members of City of Beaumont,
This is to inform you how important I think it is for you to consider the NEGATIVE ENVIRONMENTAL IMPACT that ALL warehouses, whether inside or outside of Beaumont, have on both the city and nearby area. The effect of hundreds of trucks per day cannot be minimized, regardless of the location. Please prioritize your focus for job opportunities for the Beaumont area toward an industry that is not dependent on trucking but instead will bring needed jobs to our area. This recent article: "Warehouse Boom Transformed the Inland Empire" is of particular note. Warehouses should be considered within a particular category.

No amount of fees can repair the damage done to a community after something like this is built.

Thank you so much for putting my comment into the public record.

Norma McGee
1581 Point Park
Beaumont, CA 92223
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McGee, Norma, dated February 7, 2023.
3-1 The commenter expresses general opposition to the Project and concerns related to the amount of truck traffic per day from all warehouses whether inside or outside the City of Beaumont.

The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR. Refer to Draft EIR Section 4.17, Transportation, for an analysis of the Project's impacts related to traffic. The commenter's concern related to warehouse uses are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 4
From: Richard Rizzo
To: Carole Kendrick
Subject: Beaumont pointe
Date: Tuesday, February 7, 2023 9:19:04 PM
To whom it may concern,
I am writing in regards to the Beaumont pointe project and my opposition to it. We as residents value our quite living, a warehouse would drastically impact that in a negative way.

The traffic would be unbearable and I believe it's also a safety issue as it would make getting in and out of the neighboring communities even harder then it is now. There are plenty of open land up towards the desert away from homes and beautiful landscape much more suitable for these types of projects
Richard Rizzo
Tournament hills resident
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Responses to Comment 4
Rizzo, Richard, dated February 7, 2023.
4-1 The commenter expresses general opposition to the Project and concerns related to traffic congestion, traffic safety, and noise. The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR. As discussed in Section 4.13, Noise, of the Draft EIR, Project stationary noise would not expose nearby receivers to unacceptable daytime or nighttime noise levels during Project operations following Project buildout. Refer to Draft EIR Sections 4.13, Noise, and 4.17, Transportation, for an analysis of the Project's impacts related to noise and traffic. No further response is required.

The commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 5
To:

Carole Kendrick: Planning Manager
City of Beaumont
550 East 6th Street Beaumont CA, 92223
[email protected]
From:

Ron Roy
35161 Hogan Dr.

Beaumont, Ca. 92223
Re:

Beaumont Pointe Warehouse Project: West Beaumont: South of SR60, West of Jack Rabbit Trail NOA: General Plan Amendment (PLAN2019-2084) Beaumont Pointe Specific Plan Pre -zone (PLAN2019-0284) Specific Plan; SP2019-0003) Tentative Parcel Map (TPM) No. 82551 Dear Ms. Kendrick and all those it concerns:

I am opposed to the above referenced project.

Below are my concerns and reasons for opposition. I look forward to replies.

I am opposed to the Beaumont Point Project for the following reasons:

POOR LAND USE PLANNING
Sometimes projects, no matter what the claims, are eyesores. They are ugly, no matter how a developer spins the project. Beaumont Pointe is such a project. The developer simply wants to drop the massive high cube warehouses within a few feet of SR60 for the developer's beloved "freeway access" to a Southern California Freeway. The developer is here for the cheap land and access for their logistics network without any regard for anything could harm the community. There's no effort to disguise, reasonably mix, or otherwise balance the warehouse buildings with other more attractive land uses, the surrounding natural foothills and wildlife, the nearby streams and potential already built-in community nature recreation areas.

This project land use is clearly out of balance for what's needed for Beaumont, long term. There need to be limits to the "industrial use" zoning classification in the city. The project attempts to unreasonably stretch the existing "warehouse district", easterly adjacent.

FAILURE TO CONDUCT ADEQUATE ALTERNATIVEs ANALYSIS
CEQA Guidelines 15126 requires an applicant provide an analysis of alternative sites for the project. This includes identifying the location of alternative sites then analyzing to what extent these alternatives, would be superior, comparable, or inferior to the project. Also a no -build alternative needs to be analyzed. As the section states:
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"An EIR must describe a reasonable range of alternatives to a proposed project that could feasibly attain most of the basic project objectives and would avoid or substantially lessen any of the proposed project's significant effects. Additionally, a "No Project" alternative must be analyzed."
The project applicant has failed to conduct an adequate analysis here. At minimum 3 comparative sites should have been identified and analyzed as to their alternative suitability for a warehouse. This was not done. A growing consensus among the Inland Empire residents, believes, warehouses need to be concentrated in districts that are far away from residential areas.

DOES NOT PROVIDE SUSTAINABLE ECONOMIC GROWTH FOR BEAUMONT:

According to the Beaumont General Plan a key goal of the plan is to:
"EXPAND AND ENHANCE EMPLOYMENT OPPORTUNITIES. The City will support economic development strategies that embrace a vision of inclusive growth and allows prosperity to be shared by all residents. Supporting a range of businesses and economic sectors is key to ensuring the economic vitality of Beaumont in the long term. The City recognizes the importance of education and skill development in ensuring access to new job opportunities as well as the necessity to provide a variety of employment opportunities for a diversity of income and education levels. The City will promote strategies to diversify its job base, which also brings fiscal and economic resiliency to the City. The City will also support Downtown revitalization as well as future growth and economic development in the Sphere of Influence, particularly in healthcare, retail, and technology -intensive industries. In doing so, the City also recognizes the need to balance jobs and households."
Unfortunately, as Beaumont, Pass Area, and Inland Empire residents are finding out, warehouse projects cause jobs that are overwhelmingly low wage, extremely high turnover with high injury rates, with poor prospects for upward mobility, that increasingly are replaced by automation, and unable to allow workers to achieve American Dream goals of home -owner ship, raise a family and achieve a secure retirement. This actuality of the warehouse industry is completely in opposition with the economic goals of the city.

Moreover, the city has not demonstrated that the "revenues" from warehouses are in any way sustainable for the city, especially with the expense to the city of building the infrastructure and services to support warehouses.

This warehouse project will not, as the General Plan promises "support..and revitalize... the future growth growth and economic development in the Sphere of Influence, particularly in health care, retail, and technology -intensive industries. 2 5-4
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TOO CLOSE IN PROXIMITY TO MAJOR RESIDENTIAL SENSITIVE RECEPTOR COMMUNITIES - Olivewood
• Jack Rabbit Trail Entrance less than 1000 feet from Olivewood home community including cul-de-sacs of Enzo Court and Montemerano Court. - Fairway Canyon:

Nearest Homes
• 1800 feet from Fairway Canyon at Funk Way
• 1500 feet from Fairway Canyon near Love Lane and Zoeller Street.

Nearest School
• 3000 feet from Elementary School on Sorenstom Drive.

Developer has failed to identify the number of sensitive receptor communities near the project site within a reasonable radius, such as 1-3 miles from project. Developer has also failed to provide data showing the amount of particulate matter, noise, light, and other sources of pollution, on every house within a 2 mile radius of the project, as well as affected schools, recreation, retail and other facilities, and the consequent estimated negative health effects of the projects pollution, given the latest information available. See:
https://calmatters.org/commentary/2023/01/inland-empire-california-warehouse- development/ also: https://www.nbcnews.com/tech/tech-news/treated-sacrifices-families- breathe-toxic-fumes-california-s-warehouse-hub-n1265420 It must be noted that, a cursory map distance analysis by me indicates that virtually all, if not all of significantly concentrated sensitive receptor Specific Plan SFR Beaumont housing communities of Oak Valley Specific Plan (including Fairway Canyon, Tournament Hills, Shadow Creek): and the Heartland Specific Plan (primarily Olivewood), and Calimesa Summerwind Specific Plan Housing Developments, all of which I'm estimating at over 8000 SFR homes with seniors, families and children estimated to be well over 40,000 people in residentially zoned communities, all are sensitive receptors are within a 2 mile radius of the project site, and will be subjected to the various types of air, noise, light and other pollution from the 24/7 diesel truck activity in and out of the warehouses, notably the cancer causing particulate matter from the trucks diesel soot and tires, the blaring noise from the truck traffic, and the light pollution from the lighting needed to light up 5 milllion square feet of warehouses, the traffic congestion from the project.

There's also 2 elementary schools within this 2 mile radius, one of which is only 2000 feeet from the project site where children will be concentrated on site for 6 or more hours per day, engaged in physical activities or collected in classrooms, which will subject their lungs and bodies to the continuous flow of health harming pollution from the warehouses. 3 5-6
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Therefore the applicant needs to specifically and accurately identify the number of sensitive receptors within a 2 mile radius of the project, including the above mentioned Specific Plan Communities, schools, parks, recreation facilities, shopping centers etc.

Also any conditions of approval must involve mitigations for the health hazard and other negative effects from the project on the housing within at least a 2 mile radius of the project.

See PE Article April 30, 2021: " $47 million settlement reached in World Logistics Center lawsuit https://www.pressenterprise.com/2021/04/29/47-million-settlement-reached-in- world-logistics-center-lawsuit/
See also here:
https://envhealthcenters.usc.edu/wp-content/uploads/2016/11/Storing-Harm.pdf Also, given the San Gorgonio Pass unique topography, climate and weather, the project does not analyze, how the Pass's wind, light, and weather conditions will carry/distribute the project's air and other pollution to, not only the sensitive receptor communities within the 2 mile radius, but also to other parts of Beaumont, Calimesa, Banning and surrounding areas.

THE DEVELOPERS CLAIM OF QUALITY ECONOMIC DEVELOPMENT IS NOT SUPPORTED BY BODY

OF EVIDENCE ON THE WAREHOUSE INDUSTRY, WAREHOUSE LABOR PRACTICES, REVENUE GENERATION, AND SUSTAINABILITY.

The Beaumont General Plan States:
"Moving forward, the City will have to determine how to continue to finance, support, and enhance City businesses, services, and programs in a manner that is sustainable over the long term. The reality of limited general fund revenues will require the City to think creatively about economic development strategies that are built on principles of equity, sustainability, collaboration, and innovation."
However, given the amply available data analytics, the applicant has not provided an analysis of cost burden: the estimated initial, construction phase, and long-term maintenance costs for the project site construction, needed addition of area wide infrastructure to support the truck and other vehicular traffic, water, sewer, utilities etc., maintenance of the infrastructure over decades of use, public services, transit etc. These cost burdens have not been compared to estimated revenues to determine if the city receives an overall net financial profit/benefit from this project, not only short-term, but also throughout generations.

Also the
DEVELOPER USES PROMISE OF HOTEL AREA: HOWEVER THIS MAY NOT BE BUILT FOR YEARS Warehouses will go in first with their visual blight. This occurred with a project in Banning where the developer with a plot plan for retail could not guarantee that this would go in first, 4 5-9
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since the retail area was spec. and there were no potential tenants who had shown any interest.

At 30 acre's, the retail/hotel component is only 5.5% of the project acreage. Yet it comes first in the Specific Plan summary, the project misleads the public by characterizing the retail/hotel component as the major land use/attractor, when this project is, in fact, a new mega warehouse district, that will rival the existing warehouse district east adjacent.

TRAFFIC IMPACTS CANNOT BE REASONABLY MITIGATED.

Adding and Connecting the 5 million sq.ft. of the projects warehousing to 4th street via Hidden Springs Industrial Park warehouse complex will overburden the street system, which will not have the capacity to support Beaumont Pointe's truck traffic. Please note 4th street bridge (eastern edge of Hidden Canyon Project) would need to be expanded.

ACTIVE TRANSPORTATION PLAN: -41(-
Neither the city, nor the applicant have demonstrated the project will comply with SB 932 (enacted September 2022) which sets out requirements for an active transportation program and plan for the area. .4 —
DEVELOPERS EIR PROJECT OBJECTIVES: -4—
The following are the EIR's project objectives. My responses to each objective are highlighted in bold red font color.

THE PROJECT OBJECTIVES ARE INCOMPATABLE WITH THE OBJECTIVES OF THE COMMUNITY AND BEAUMONT'S GENERAL PLAN. ALSO SOME OBJECTIVE CLAIMS ARE MISLEADING.

The Developer states the following objectives which are misleading and incompatible with the Beaumont General Plan and interests of Beaumont Residents.

1.2.2 PROJECT OBJECTIVES
The fundamental purpose and goal of the Beaumont Pointe Specific Plan is to accomplish the orderly development of General Commercial, Industrial, Open Space, and Open Space - Conservation land uses over the approximately 539.9 -acre Project site. The Project would achieve this goal through the following Project Objectives:

A. Develop large land areas in the City and particularly south of SR -60 and adjacent to existing industrial uses, infrastructure, and truck routes to meet the growing demand for large scale industrial and warehouse development in the City while minimizing impacts of industrial development on residential and other sensitive receptors in the City, which are primarily located north of SR -60.
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Erroneously concludes that residents demands for ecommerce require locating warehouses on this site. Developer glaringly omits that ecommerce demand is regional in nature, and that fulfillment and other warehouses are amply available in other areas in Southern California, such as Ontario, San Bernardino Valley, etc. to supply Beaumont residents with goods. Warehouse growth can occur in other areas with more industrial concentrations.

Of the projects 540 acres, 232.6 acres and 5 million square feet is for "industrial". The developer fails to call these buildings for what they are: warehouses By omitting the type of industrial use misleads the public of the uses particular environmental impact caused by warehouses: numerous types and sources of pollution, that are deadly to sensitive receptor communities near .

B. Providing for conservation of open space habitat within MSHCP criteria cells in a manner consistent with the MSHCP requirements and providing access for wildlife movement to Caltrans constructed and proposed wildlife under -crossings along the SR -60 Freeway that abut the northern Project boundary to accommodate wildlife movement.

The current land use is rural residential which is compatable with the Beaumont General plan and more condusive to the rural open space including Potrero MSHCP.

Also there's a need to depart from predominance of medium/high density tract housing to lower density housing. The current zoning accomplishes that. Keeping the rural residential zoning not only preserves the visually appealing aesthetic nature of the site, but also accommodates the states need for additional housing. This proposed project will irrevocably disturb the natural terrain, vegetation, and habitat, replacing carbon and water capturing natural areas watershed with man made heat and pollution inducing infrastructure.

C. Maximizing opportunities to develop land in the City's sphere of influence to provide job opportunities and economic benefit to the City and its residents, including new sales and property tax revenues that can be used for City services and providing sufficient fiscal benefit to permit annexation of the Project site into the City.

A city and its residents economic benefits, its value, are importantly defined by the identity that a city developers for itself. Due to lax zoning and enforcement in the face of a warehouse invasion in the IE and Pass area, Beaumont's identity has dramatically changed, as its now becoming known as a "warehouse town", like others in the IE with too many warehouses in their jurisdictions. This is only getting worse, as the city has a reputation as a "warehouse friendly" jurisdiction, which is a reason why the city already has 10 million square feet of existing/operating warehouses with another 30 million square feet of warehouses in its application pipeline, including the 2 square mile project of Legacy Highlands which is located in South Beaumont. With the pollution and other negative effects that come with these massive warehouse projects, residents and families health and well being (quiet, dark skies, clean air and lungs), and property values are under threat.
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It's widely known that the type of jobs from warehouses are not sustainable in terms of upward mobility, longevity, home ownership and ensuring family financial security and wealth. The city is not working with developers to diversify land use away from the increasingly dominant logistics/warehouse land use, which leaves the city financially vulnerable if this single land use experienced a sector economic downturn. Here the city/applicant should be looking at higher ratios for retail/hospitality and other land uses to offset potential economic downturns in logistics/warehousing. For example consider a minimum 50% of a projects land/building square footage should be for non- logistics/warehouse use. Also set a citywide cap for warehouses. Also zoning classifications such as "industrial" are most likely outmoded and should be replaced with more sustainable zoning classes. For example, zoning could be classified based on the amount of pollution/blight induced by a project. Also the applicant has not provided any evidence that any tax or other revenues produced from the project will adequately offset or exceed the cities infrastructure and city service expenses (police/fire/transit/expansion of road system/infrastructure maintenance) needed to service the project and its impacted areas for the long term.

D. Creating new job opportunities within the City of Beaumont which improves the jobs to housing balance within the City and reduces the need for members of the existing local workforce to commute long distances. As stated previously, warehouse jobs are not sustainable in terms of upward mobility, longevity, home ownership and ensuring family financial security and wealth. The average turnover rate for a warehouse job in Riverside County is 107%, which means the average worker works less than one year. Warehouse industry is also notoriously known for poor labor protections, unsafe and stifling working environment (no AC in the hot summers, no adequate breaks, working beyond 40 hours without extra pay, no breast feeding areas, lack of adequate bike racks/bike storage, showers, bathrooms, break areas, food service, building complex bikeway systems, pedestrian walkways.

Warehouse jobs do not improve the housing balance because warehouse wages cannot support an income that allows a worker to qualify for home ownership.

E. Fulfilling a need in the City and region wellness -based retail, including entertainment, recreation, hospitality, and restaurants. This is misleading, the retail/entertainment component will be miniscule (around 5.5% of total project area).

F. Developing a center that will accommodate a variety of future tenants, including light manufacturing, warehouse, distribution tenants and other businesses that rely on transportation efficiency within an industrial corridor in a location with superior access to the local and regional transportation network, thereby minimizing truck traffic on local streets and reducing vehicle miles traveled in the region. This is misleading: there will be no "variety of future tenants" in terms of a variety of land uses. Virtually all tenants will be using the warehouses for logistics uses: refrigeration, distribution, sorting, 7 Ant -
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"fulfillment". Also truck traffic will dramatically increase on local streets and increase VMT. Trucks are the only mode transporting the projects goods. SR60 and 110 are already at capacity, and cannot be expanded to support the projects additional truck traffic. Also trucks from east adjacent warehouses are already using Potrero Blvd Bridge to Oak Valley to Oak Valley Blvd/10 overpass, streets which were designed for residential communities.

Trucks are conflicting with resident's who use these streets to traverse for local needs.

Also trucks are using Viele Ave., Calilfornia Ave., and First St.. These streets were not designed or have the capacity to support the increased truck traffic from existing and proposed warehouses.

G. Developing a project that utilizes existing investment in capital improvements for water, reclaimed water, sewer, storm drain and circulation facilities to further the planned development of land in the City and in its sphere of influence. Misleading: See other comments: applicant has not substantiated this. CIP history for warehouses nearby prove otherwise. There will be a substantial need, increase and burden on existing infrastructure. Project will require significantly expanding infrastructure. For example Hidden Canyon IP had to revise its development agreement to allow it to build substantially more sewer to support sewer demand generated from warehouses.

Beaumont Point project applicant already knows the additional infrastructure needed tc. be added for this project. The applicant needs to disclose this information. Mitigations that show how, and what kind infrastructure will be necessarily expanded in the Beaumont area need to be specifically addressed: Expansion of Sewer, Water, Streets, Roads, SR60, 110 interchange, Oak Valley/I10 interchange, Pennsylvania Ave, 1st Street/SR79 intersection, Ist Street to Highland Springs Ave.

H. Developing a range of warehouse facility options, such as varying structure sizes and building configurations within the City with high quality businesses to facilitate local and regional distribution of goods while minimizing vehicle miles traveled, air quality and greenhouse gas impacts. This is misleading. There is no variety. Projects warehouse buildings are rectangular boxes, there is no variation. Changing sizes and "building configurations" cannot change this. There's only so much a coat of paint can do to disguise lack of variety.

I. Minimizing the demand for water resources by creating a development -wide landscape concept that features drought -tolerant plant materials to provide for an aesthetically pleasing outdoor environment and developing a project where recycled water is planned to be available. Misleading: Vegetation landscaping is a minimal component. Water needs, given climate change have not been analyzed. There's no analysis of the potential fire danger the warehouses will have on nearby hilly grasslands and open spaces. 8 5-23
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OTHER CONCERNS
Pertinent CEQA Law needs to be addressed:

1. The California Environmental Quality Act ("CEQA") (Public Resources Code § 21100 et seq.), enacted in 1971, requires government agencies to consider the environmental consequences of their actions before approving projects subject to CEQA's provisions.

2. The Environmental Impact Report ("EIR") is considered "the heart" of CEQA. To effectuate the Legislature's goals of environmental protection, CEQA provides that an adequate EIR must evaluate all potentially significant environmental impacts of a proposed project including both direct and indirect impacts as well as cumulative impacts. (State CEQA Guidelines, §§ 15126, 15126.2 (a), 15130)

3. CEQA establishes a substantive mandate on the part of the lead agency to mitigate the significant environmental impacts of a project. (Public Resources Code § 21002, 21002.1; State CEQA Guidelines, § 15021 (a).) A lead agency may not approve a project for which there are significant environmental impacts unless the agency makes findings that: (a) mitigation measures have been required of the project which avoid or substantially lessen the significant environmental impacts, or (b) mitigation measures are found to be infeasible based on substantial evidence. (Public Resources Code §§ 21081, 21081.5; State CEQA Guidelines, §§ 15091 (a)(b), 15092 (b).)

4. 42. CEQA additionally provides that adopted mitigation measures must be certain and enforceable. (Public Resources Code § 21081.6(b); State CEQA Guidelines, § 15126.6(a)(2).) The lead agency must ensure that mitigation measures are required by or incorporated into the project to ensure that the measures are actually carried out. (Public Resources Code § 21081.6 (a), (b).)

5. 43.CEQA's provides that a lead agency must evaluate alternatives to the proposed project, or the location of the project, which would attain most of the basic objectives of the project but would avoid or substantially lessen any of the project's significant environmental effects. (State CEQA Guidelines, § 15126.6 (a).) The lead agency has a duty to adopt a project alternative if it is feasible. (Public Resources Code § 21002) A lead agency may not reject an alternative unless the agency makes findings supported by substantial evidence showing that the alternative is infeasible. (Public Resources Code, §§ 21081, 21081.5; State CEQA Guidelines, §§ 15091 (a)(3), 15092.)

6. Residents and others will understandably say the EIR failed to adequately evaluate impacts to/from including, but not limited to, aesthetics, air quality, biology, energy, greenhouse gas emissions, land use, noise, and traffic. By way of example, Petitioner and others commented that:

7. a) Aesthetic impacts have not been fully evaluated, and impacts are significant contrary to the conclusions of the EIR because the Project introduces large industrial buildings where no buildings currently exist in the natural visual setting. Likewise, the impacts of construction grading activities have not been fully evaluated and indeed the grading 9 5-27
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plan does not show that impacts are less than significant based on substantial evidence in the record, particularly when it is known that the site contains steep terrain. It is known that the Project entails substantial earthwork.

8. b) The EIR's analysis of the Project's energy impacts is inadequate in terms of the requirements of CEQA Guidelines, Appendix F. The City/County failed to require sufficient analysis of the Project's energy consumption, transportation energy impacts, and to demonstrate that the Project is taking steps to reduce dependency on fossil fuels.

For instance, the City/County failed to evaluate or demonstrate how the Project "increases reliance on renewable energy sources." Moreover, purported requirements to use solar power for the Project's energy needs or to obtain LEED Certification are illusory and not based on enforceable CEQA mitigation measures.

9. c) The analysis of the Project's greenhouse gas emission ("GHG")impacts is based on the County's Climate Action Plan ("CAP"), but the EIR's conclusion of less than significant is not based on substantial evidence. The Project is a substantial source of new GHG emissions, predominately due to the Project's mobile emissions. Alleged compliance with the CAP is not substantial evidence that the Project's GHG impacts are less than significant particularly when the Project only partially satisfies many of the CAP measures (e.g., energy saving features) that supposedly demonstrate compliance with the CAP. And, the Project takes virtually no steps to reduce mobile emissions.

Moreover, the EIR relies upon illusory measures and uncertain mitigation in determining that the Project is compliant with the CAP. For instance, the applicant may dispense with all design features listed in the EIR and substitute them for "equivalent" measures after Project approval.

10. Contrary to the EIR's conclusions, there are significant land use impacts due to the Project's marked deviations from the City's General Plan and the County's General Plan and PAP (Pass Area Plan). Compared to the existing land use designations of the site and surrounding land use designations and uses, the Project is a very intense use and, as a result, brings much greater impacts such as traffic. The Project meets the County's threshold of significance for land use impacts, contrary to the EIR's conclusions, namely the Project would (a) result in a substantial alteration of the present or planned land use of the area; (b) be incompatible with the site's existing or proposed zoning; (c) be incompatible with existing surrounding zoning; (d) be incompatible with existing and planned surrounding land uses; and (e) be inconsistent with the land use designations and policies of the General Plan.

11. e) The EIR concludes that noise impacts during construction and operational phases are less than significant, but this is not demonstrated based on substantial evidence in the record. The EIR's noise analysis indicates, for instance, that construction noise levels are well above ambient conditions at the nearest homes to the Project site; accordingly, the Project results in "a substantial temporary increase in ambient noise conditions," i.e., the Project exceeds an adopted threshold of significance. Further, it not shown in the record that construction noise mitigation is effective at lessening impacts. With respect to operational noise, the noise analysis omits important pieces of information such as existing ambient noise measurements at residences to the north of the Project site, or those planned south of the Project site. The EIR also omits analysis 10 5-33
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of traffic noise on residential receptors. The Project generates thousands of trucks per day traveling on 4th Street, Potrero Blvd, and surrounding streets in close proximity to existing and future residences. The noise analysis, however, entirely omits these residences from the noise study, which is improper in light of CEQA's informational purposes.

12. The EIR's conclusion of less than significant impact with respect to growth -inducement is contrary to the evidence. The Project brings major utilities infrastructure and road improvements to the otherwise rural area, thus enabling future development. For instance, the Project will construct water tanks and a booster station for use by the Beaumont Cherry Valley Water District to serve existing and other development in the service area. Thus the Project removes obstacles for growth by providing infrastructure that would be needed for future growth. The Project's land use amendments also have the potential to set a precedent for similar large-scale industrial development in the rural area. The EIR speciously asserts there are no growth inducing impacts because the existing land use has historically accommodated a variety of industrial and commercial uses." This statement is contrary to the evidence including statements in the EIR that the project site and surrounding hills are predominately rural and not developed with industrial and commercial uses.

13. Not all feasible mitigation was required of this Project, and Petitioner and others proposed feasible mitigation that has not been shown to be infeasible based on substantial evidence in the record.

14. Mitigation with respect to the Project's significant air quality (NOx) impacts, is needed such as requiring that the Project incorporate the phase -in of electric, hybrid electric, hydrogen electric, or battery operated (i.e., non diesel) trucks. The City/County has declined to adopt feasible mitigation to address significant impacts, and the County has failed to make findings supported by substantial evidence that the measure is infeasible.

15. the Project should be limited to the assumptions of the air quality study in terms of truck trips (number and trip length) in order to ensure that significant impacts (NOx) are not more severe than assumed by the EIR. The County declined to adopt feasible mitigation to address significant impacts, and the County failed to make findings supported by substantial evidence that the measure is infeasible.

16. The project buildings should required to be built with an earthen roof and be inserted into and surrounded by earth from the hillsides so as not be able to be seen or install solar panels sufficient to achieve "net zero", i.e., handle the peak energy demands of the Project for both buildings. The County declined to adopt feasible mitigation to address significant impacts, and the County failed to make findings supported by substantial evidence that the measure is infeasible.

17. Proposed mitigation measures are uncertain, unenforceable, ineffective and/or deferred in violation of CEQA

18. The applicant fails to adequately consider alternatives to the proposed Project, including alternative sites, consistent with the mandate of State CEQA Guidelines § 15126.6 (a). The EIR, unreasonably restricts the criteria for analysis of alternative sites, when it is known that there are other feasible sites available for construction of the 11 -41(-
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Project. Moreover, the alternative sites are not infeasible, within the meaning of CEQA, but rather undesirable to the applicant, which by itself is not a valid reason for rejecting an alternative under CEQA.

I reserve the right to provide additional comments on this project.

Given that the notification process makes it very difficult for most Beaumont residents to review the DEIR, I'm requesting that the public comment period is extended an additional 30 days to March 8, 2023.

Ron Roy
Beaumont Resident.
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Responses to Comment 5
Roy, Ron, dated February 8, 2023.
5-1 This comment consists of introductory remarks and expresses opposition to the Project for the reasons provided in Comments 5-2 through 5-45, addressed below. The commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.
5-2 The commenter expresses concerns related to aesthetics of the proposed warehouse portion of the Project and states that no efforts were made to disguise, reasonably mix, or otherwise balance the warehouse buildings with other more attractive land uses, the surrounding natural foothills and wildlife, the nearby streams, and potential already built-in community nature recreation areas.

The Project would provide 124.7 acres of open space to accommodate landscaped manufactured slopes, fuel modification areas, and natural open space as a buffer to adjacent conservation area and 152.4 acres of open space — conservation. The open space — conservation area would be preserved as natural habitat as required by the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP). Additionally, the Project's proposed structures, which would reach a maximum height of 60 feet above finished grade, are not anticipated to block major views to the San Gorgonio Mountains, San Bernardino Mountains, and San Jacinto Mountains due to Project site's orientation and topography in relation to SR - 60 and Frontage Road. Specifically, the topography to the north near SR -60 will be higher than the finished grade building pads for the proposed industrial uses, which would limit the views of the proposed structures from SR -60. Under Project conditions, SR -60 and Frontage Road are anticipated to continue to provide intermittent and partial views to the existing ridgelines (refer to Pages 4.1-9 to 4.1-10).

The Project would include Project Design Features PDF 1-1, which would require development implementing the Beaumont Pointe Specific Plan to comply with the Development Standards set forth in Chapter 3 and the Design Guidelines related to Architectural Design and Landscape Design in Chapter 4 of the Specific Plan. Conformity to the Development Standards and Design Guidelines would be addressed by the City's future review of implementing building permits for compliance with the Specific Plan's requirements and would serve to reduce and/or avoid impacts relating to aesthetics.

This comment does not raise any issues relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.
5-3 The commenter states that the Project's land use is out of balance with the needs of the City and unreasonably stretch the existing warehouse district east. The commenter states that there need to be limits placed on industrial use.

This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

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However, the commenter's concerns are acknowledged and will be forwarded to decision - makers for their review and consideration of the Project. 5-4 The commenter refers to CEQA Guidelines Section 15126, and incorrectly states that the Draft EIR did not provide a no project alternative or appropriately analyze alternative sites, which should have included a minimum of three sites. The commenter states that warehouses need to be concentrated in districts that are far away from residential areas.

Existing residential land uses near the Project site are those across the SR -60 Freeway to the north. Additionally, the Project site is located to the east of the industrial area of the City. As discussed in Section 6.0, Alternatives, of the Draft EIR, the No Project/No Development Alternative was analyzed (refer to Pages 6-9 to 6-15). The Existing City General Plan Alternative was also discussed (refer to Pages 6-15 to 6-22). Additionally, the alternative sites alternative was analyzed under alternatives considered and rejected (refer to Pages 6-5 to 6-6).

The Draft EIR concluded that only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126.6(b)). In addition, an alternative site need not be considered when implementation is remote and speculative, such as when the alternative site is beyond the control of a project applicant. Given the size and type of the proposed development, a similarly sized project and land use elsewhere in the South Coast Air Basin would result in the same or greater project -level and cumulative air quality, GHG emissions, and transportation impacts.

Therefore, analysis of an alternative site for the Project is neither meaningful nor necessary, because the significant impacts resulting from the Project would not be avoided or substantially lessened by its implementation in an alternate location. Furthermore, there are no alternative sites within the City or its sphere of influence that are similarly sized that would be suitable for industrial and commercial uses proposed by the Project. Other developable land within the City would either require a general plan amendment and zone change or would place industrial and commercial uses closer to established residential communities. Additionally, the Project Applicant does not own or control another suitable site that would achieve the underlying purpose and objectives of the Project. As a result, this alternative was rejected from further consideration and no further response is required.
5-5 The commenter cites a section of Page 34 of the City's General Plan related to the City's goal to expand and enhance employment opportunities. The comment states that warehouse projects cause jobs that are overwhelmingly low wage, extremely high turnover with high injury rates, with poor prospects for upward mobility, that increasingly are replaced by automation, and unable to allow workers to achieve American Dream goals of home -owner ship, raise a family and achieve a secure retirement. The commenter states that the warehouse industry is completely in opposition with the economic goals of the city. Further, the commenter states that the city has not demonstrated that the "revenues" from warehouses are in any way sustainable for the city, especially with the expense to the city of building the infrastructure and services to support warehouses; and, therefore, the project would not support and revitalize the future growth and economic development in the Sphere of Influence.

It is recognized that as part of the City's decision making on whether or not to approve a project, the City considers the economic benefits to the City, including revenue and future growth. In accordance with CEQA, the EIR considers the Project's impact to the physical environment.

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CEQA Guidelines Section 15131 state that "an economic or social effect of a project shall not be treated as a significant effect on the environment." It should be noted Section 4.14, Population and Housing, addresses Project generated employment. It is estimated that the Project would generate approximately 5,456 permanent jobs to support the Industrial and General Commercial land uses proposed on site.

This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

However, the commenter's concerns are acknowledged and will be forwarded to decision - makers for their review and consideration of the Project. 5-6 The commenter expresses concern related to the Project's impacts to sensitive receptor communities and schools. The commenter states that the Draft EIR failed to identify sensitive receptors within a 1-3 miles radius, or provide data showing the amount of particulate matter, noise, light, and other sources of pollution, on every house within a 2 -mile radius of the Project, as well as affected schools, recreation, retail and other facilities, and the consequent estimated negative health effects of the Project's pollution.

The Draft EIR complied with conservative protocols specified by the South Coast Air Quality Management District to determine air quality impacts and determine potential impacts to adjacent land uses and other sensitive receptors. For air pollution health risks, this is done through a Localized Significance Thresholds (LST) analysis and health risk assessment. As shown in Section 4.3, Air Quality, of the Draft EIR, results of the LST analysis indicate that the Project will not exceed the South Coast AQMD localized significance thresholds during construction or operation (refer to Page 4.3-47). Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations due to the Project. Additionally, as discussed in Section 4.3, Air Quality, of the Draft EIR, a Health Risk Assessment (Technical Appendix B2) was prepared to analyze the Project's potential health risks to sensitive receptors, including residences, workers, and schools. The Health Risk Assessment identified that the sensitive receptor with the greatest potential exposure to Project diesel particulate matter (DPM) source emissions was at Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site. Any impacts to residents located further away from the Project site than the modeled residential receptor would have a lesser impact than what has already been disclosed in the because concentrations dissipate with distance. At this location, cancer and non -cancer health risks were determined to be less than significant (refer to Page 4.3-45 and 4.3-46).

Moreover, there are no schools located within a quarter mile of the Project site. The closest school to the Project site is Tournament Hills Elementary School, located approximately 1.4 miles northeast to the Project site. Based on California Air Resources Board (CARB) and South Coast AQMD emissions and modeling analyses, an 80% drop-off in pollutant concentrations is expected at approximately 1,000 feet from a distribution center. The 1,000 -foot evaluation distance is supported by research -based findings concerning TAC emission dispersion rates from roadways and large sources showing that. As such, there would be no significant impacts that would occur to any schools in the vicinity of the Project (refer to Page 4.3-46).

As discussed in Section 4.13, Noise, of the Draft EIR, Project stationary noise would not expose nearby receivers to unacceptable daytime or nighttime noise levels during Project operations Lead Agency: City of Beaumont SCH No. 2020099007

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following Project buildout. The Draft EIR determined that the Project would have significant off -site traffic noise level increase at three roadway segments (4th Street east and west of Potrero Boulevard and east of Veile Avenue). However, these locations are located in industrial areas and are not located immediately adjacent to any noise sensitive land uses (refer to Page

4.13-39).

Additionally, according to the Project's Conceptual Lighting Study, which was prepared in compliance with Beaumont Municipal Code Chapter 8.50, lighting generated from the proposed industrial and general commercial uses to the trespass line is at an average of zero footcandles and a maximum of 0.7 footcandles. Therefore, the Draft EIR adequately analyzed air quality, noise, and lighting impacts to sensitive receptors and no revisions to the Draft EIR are required.
5-7 The commenter further details the previous comment related to air quality, noise, and lighting impacts to sensitive receptors (residential communities) within a 2 -mile radius of the Project site. Refer to response to Comment 5-6 above for a detailed discussion on each impact to sensitive receptors. Additionally, it is not necessary to study every single receiver location surrounding Project site because health risks are evaluated based on the maximally exposed individual receptor. Additionally, receivers located at similar distances from the Project site with similar ground elevations, orientation, and intervening physical conditions (e.g., walls, landscaping) as the modeled receptor locations would experience noise levels the same or very similar to those disclosed. Thus, no further response is required. 5-8 The commenter states there are two elementary schools within a 2 -mile radius of the Project site, one of which is 2,000 feet from the Project site and expresses concern on air quality impacts to the students. As discussed in response to Comment 5-6, the closest school to the Project site is Tournament Hills Elementary School, located approximately 1.4 miles northeast to the Project site. The Project does not have the potential to result in significant health risks to schools as there is an approximate 80% drop-off in pollutant concentrations at approximately 1,000 feet from a distribution center and emissions diminish substantially between 500 and 1,000 feet from emission sources (refer to Page 4.3-46). Thus, no further response is required. 5-9 The commenter states that the EIR needs to specifically and accurately identify the number of sensitive receptors within a 2 -mile radius of the project, including the Specific Plan Communities, schools, parks, recreation facilities, shopping centers etc. The surrounding land uses were fully disclosed in Section 3.3.2 of the Draft EIR. As described in response to Comments 5-6 through 5-8, the EIR provided a conservative analysis to determine environmental impacts and air quality, noise, and lighting impacts to sensitive receptors. Thus, no revisions to the Draft EIR are required.
5-10 The commenter provides a link to the news article regarding the World Logistics Center settlement agreement and states that the conditions of approval must involve mitigation for health hazards and other effects from the Project on residences within a 2 -mile radius. Refer to response to Comments 5-6 through 5-8. In accordance with CEQA, the Draft EIR identifies all environmental impacts of the Project and incorporates all feasible mitigation measures to reduce Project impacts.

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5-11 The commenter states that, given the San Gorgonio Pass unique topography, climate and weather; the Project does not analyze how the Pass's wind, light, and weather conditions will carry/distribute the Project's air and other pollution to, not only the sensitive receptor communities within the 2 -mile radius, but also to other parts of Beaumont, Calimesa, Banning and surrounding areas.

The commenter is incorrect. Analysis of air quality impacts to sensitive receptors did take into account the area's meteorology and other unique characteristics that would affect pollutant dispersion. As discussed in the Project's Health Risk Assessment (HRA; Technical Appendix B2), the analysis has been conducted in accordance with the Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis and the Lakes AERMOD View (Version 10.2.0) to calculate annual average particulate concentrations associated with site operations. The model requires additional input parameters including emission data and local meteorology. Meteorological data from the South Coast AQMD's Banning (BNAP) monitoring station (SRA 29) was used to represent local weather conditions and prevailing winds. Thus, no revisions to the Draft EIR are required. 5-12 The commenter states the analysis of cost burden of the Project has not been compared to estimated revenues to determine if the city receives an overall net financial profit/benefit from this project, not only short-term, but also throughout generations. Refer to response to Comment 5-5 related to economic impacts and CEQA. Additionally, as part of the annexation process into the City which will occur after the City considers the EIR, a fiscal impact analysis is required to be provided to the City. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project. 5-13 The commenter raises concern related to the timing of the development of the proposed hotel compared to the warehouse uses; stating that the hotel may not be built for years. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

It should be noted that the General Commercial uses are planned in the final Phase 3 (2027) of Project buildout. As stated in Section 3.0, Project Description, of the Draft EIR, the Project is proposed to be developed in three phases with the construction of the General Commercial uses, including the hotel during Phase 3. Additionally, the creation of jobs under Phase 1 from the warehouse use would result in the demand of additional commercial uses in the area. The Draft EIR adequately discloses the timing of the type of development for each phase. 5-14 The commenter states that the EIR misleads the public by characterizing the retail/hotel component as the major land use/attractor in the Specific Plan summary.

The commenter is referring to Table 3-1 of the Draft EIR, which presents the land use statistical summary to provide the total acreage and square footage for each planning area and associated land use. The statistical summary was presented in the order of planning areas and was not intended to mislead the public. Additionally, the hotel use was identified separately to indicate Lead Agency: City of Beaumont SCH No. 2020099007

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that the 125 hotel rooms are in addition to the target development intensity of 246,000 square feet of General Commercial uses. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project. 5-15 The commenter expresses concern on the Project's impacts on traffic on 4t'' Street and states the 4t'' Street bridge would need to be expanded.

CEQA Guidelines Section 15064.3, effective January 1, 2019, "describes specific considerations for evaluating a project's transportation impacts" and provides that, except for roadway capacity projects, "a project's effect on automobile delay (or LOS)" shall not constitute a significant environmental impact" (CEQA Guidelines Section 15064.3(a)).

Notwithstanding the requirements of State law that the VMT method of analysis, rather than LOS, be utilized to determine transportation impacts, a Traffic Impact Analysis (TIA) was prepared for the Project and included as Attachment C of this Final EIR. As discussed in the Project's (TIA), recommended improvements needed to address the cumulative deficiencies identified under Existing (2020), E+P (Phase 1, Phase 2, and Buildout), Opening Year Cumulative (2023), Opening Year Cumulative (2025), Opening Year Cumulative (2027), and Horizon Year (2045) traffic conditions are shown in Table 1-4. The Project Applicant would be required to pay TUMF fees, DIF fees, and fair share improvement fees that the City would use to ensure the implementation of roadway improvements in the area in order to minimize traffic congestion. Moreover, as stated in Section 3.0, Project Description, of the Draft EIR, 4th Street between Jack Rabbit Trail and Potrero Boulevard is being constructed across the Hidden Canyon Industrial Park site as an industrial collector with a 78 -foot right-of-way and 56 -foot curb -to -curb (refer to Page 3-3). Therefore, no further response is required. 5-16 The commenter states that the Project has not demonstrated compliance with SB 932 (enacted September 2022) which sets out requirements for an active transportation program and plan for the area.

SB 932 requires a county or city to identify high -injury streets and intersections in its General Plan and prioritize safety improvements to reduce traffic collisions. This would be implemented by cities and the counties as part of comprehensive local and regional planning efforts. SB 932 does not place a requirement on the proposed Project or other specific development projects. Therefore, no further response is required. 5-17 The commenter states the Project Objectives are misleading and incompatible with the objectives of the community and Beaumont's General Plan.

CEQA Guidelines section 15124 requires that the project description in the EIR shall include statement of the objectives sought by the proposed project. In accordance with this section, the project objectives are intended to:
. . . help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project and may discuss the project benefits.

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The Project Objectives in the EIR were prepared in accordance with CEQA requirements and are not misleading or incompatible with the objectives of the community and Beaumont's General Plan. Rather, the Objectives document the underlying purposes of the Project in order to develop a reasonable range of alternatives (refer to Section 6.0, Alternatives of the Draft EIR) and support the Project findings.

The commenter provides specific reasons that this applies to each of the Project Objectives, which are addressed in response to Comments 5-17 through 5-26.

Under Objective A,12 the commenter states that the objective erroneously concludes that residents' demands for ecommerce require locating warehouses on this site and omits that ecommerce demand is regional in nature, and can occur in other areas in Southern California.

Additionally, the commenter incorrectly states that the EIR omits the types of industrial uses proposed, namely warehousing, which misleads the evaluation of environmental impacts.

As described in Objective A, one of the purposes of the Project is to locate industrial uses in an area with a growing demand for these types of uses, while minimizing impacts by locating the buildings away from sensitive receptors, near other compatible industrial uses and close to the regional transportation network. Objective A does not discount that there is also a growing demand for industrial uses throughout southern California and in the Inland Empire.

The Draft EIR includes the types of users that would be allowed in the Industrial designation.

As stated in Section 3.0, Project Description, of the Draft EIR, the Industrial uses in the Planning Areas (PAs) 3 through 8 of Specific Plan would accommodate users such as industrial incubators, light manufacturing, parcel hub, warehouse/storage, fulfillment center, high cube warehouse, cold storage warehouse (up to 100,000 sf), and e -commerce operations and includes self -storage uses (permitted only on PA 3). The full list of uses permitted, conditionally permitted, and ancillary in these PAs is provided in the Specific Plan, Chapter 2, Development Plan. Additionally, the Project consists of a Specific Plan and the future occupants of the Project's industrial buildings and commercial area are currently unknown.

Upon adoption of the Specific Plan, subsequent project subdivision maps, plot plans, conditional use permits, grading and building permits, or any other actions requiring either ministerial or discretionary approvals would be required for construction to occur and to demonstrate consistency with the Specific Plan.

Furthermore, impacts relating to air quality to sensitive receptors were fully evaluated in Section 4.3, Air Quality, of the Draft EIR.
5-18 Under Objective B,13 the commenter states that the current land use is rural residential which is compatible with the Beaumont General Plan and more conducive to the rural open space, 12 Objective A - Develop large land areas in the City and particularly south of SR -60 and adjacent to existing industrial uses, infrastructure, and truck routes to meet the growing demand for large scale industrial and warehouse development in the City while minimizing impacts of industrial development on residential and other sensitive receptors in the City, which are primarily located north of SR -60. 13 Objective B. Providing for conservation of open space habitat within MSHCP criteria cells in a manner consistent with the MSHCP requirements and providing access for wildlife movement to Caltrans constructed and proposed wildlife under -crossings along the SR -60 Freeway that abut the northern Project boundary to accommodate wildlife movement.

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including the MSHCP. The commenter expresses his opinion regarding the need for lower density housing rather than medium/high density tract housing. The commenter states that keeping the rural residential zoning not only preserves the visually appealing aesthetic nature of the site, but also accommodates the need for additional housing. Additionally, the commenter states that the proposed project will irrevocably disturb the natural terrain, vegetation, and habitat, replacing carbon and water capturing natural areas watershed with man-made heat and pollution inducing infrastructure.

The commenter is correct that the Project site is currently designated rural residential in the City's General Plan. As a point of clarification, the land use regulations for the Project site are currently under the jurisdiction of Riverside County and set forth in the Pass Area Plan with a designation of Rural Mountainous. The Project site is located in the City's Sphere of Influence and is designated in the City's General Plan as Rural Residential 1(refer to Pages 4.11-2 to

4.11-3 of the Draft EIR). However, the Project site has not been zoned or pre -zoned by the City and there is currently no allowed development at the Project site.

The commenter's concerns regarding the natural terrain, vegetation/habitat and the development impact have been addressed throughout the Draft EIR. As concluded in Section

4.4, Biological Resources, of the Draft EIR, the Project would result in less than significant impacts with the incorporation of mitigation measures and the Project has been designed and mitigated to remain in compliance with all MSHCP conservation goals and guidelines, which includes conservation of 230.82 acres of open space. Thus, no revisions to the Draft EIR are required.
5-19 Under Objective C,14 the commenter expresses concern with the influx of warehouse projects in the City and its impacts on residents. The commenter states that the city has a reputation of being warehouse friendly and is concerned with pollution and other negative effects that come with massive warehouse projects, residents and families' health and well-being (quiet, dark skies, clean air and lungs), and property values are under threat. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.
5-20 Under Objective C, the commenter further states that the type of jobs from warehouses are not sustainable in terms of upward mobility, longevity, home ownership and ensuring family financial security and wealth. The commenter suggests that the city should impose a cap on warehousing and revise zoning for more sustainable land uses to protect against an economic downturn and costs to the city. Additionally, the commenter requests evidence that tax or other revenues produced from the project will adequately offset or exceed the cities infrastructure and city service expenses (police/fire/transit/expansion of road system/infrastructure maintenance) needed to service the project and its impacted areas for the long term. 14 Objective C. Maximizing opportunities to develop land in the City's sphere of influence to provide job opportunities and economic benefit to the City and its residents, including new sales and property tax revenues that can be used for City services and providing sufficient fiscal benefit to permit annexation of the Project site into the City.

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Refer to response to Comment 5-5 on the details on the Project's economic benefits. It should be noted that a Fiscal Impact Analysis will be required as part of the proposed annexation. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.
5-21 Under Objective D,15 the commenter states that warehouse jobs are not sustainable in terms of upward mobility, longevity, home ownership and ensuring family financial security and wealth; and goes on to explain the poor working conditions of the warehouse industry. It does not acknowledge the Objective's purpose to create new job opportunities in the City, improve the jobs to housing balance, and reduce the need for workers to commute long distances.

Additionally, Transportation Demand Management (TDM) program strategies as part of Mitigation Measure MM 4.3-6 include promoting bicycling and walking through design features such as showers for employees, self-service bicycle repair area, etc. around the project site, providing secure bicycle storage space equivalent to 2% of the automobile parking spaces provided, and providing meal options on -site or shuttles between the facility and nearby meal destinations. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

However, the commenter's concerns are acknowledged and will be forwarded to decision - makers for their review and consideration of the Project. 5-22 Under Objective E,16 the commenter states that the objective is misleading due to the retail/entertainment component being miniscule (around 5.5% of total project area). The commercial area is up to 246,000 sf in addition to the 90,000 square foot hotel. Nevertheless, this comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

However, the commenter's concerns are acknowledged and will be forwarded to decision - makers for their review and consideration of the Project. 5-23 Under Objective F,17 the commenter states that the objective is misleading because there will be no variety of future tenants in terms of a variety of land uses. Additionally, the commenter states that trucks are conflicting with streets designed for residential communities, such as Viele Avenue, California Avenue, and First Street.

The Project Objective describes that the variety of future tenants includes light manufacturing, warehouse, distribution tenants and other businesses that rely on transportation efficiency within an industrial corridor. Additionally, as stated in Section 3.0, Project Description, of the Draft EIR, the industrial uses in the Planning Areas (PAs) 3 through 8 of Specific Plan would 15 Objective D. Creating new job opportunities within the City of Beaumont which to improve and maximize the jobs to housing balance within the City and reduces the need for members of the existing local workforce to commute long distances
16 Objective E. Fulfilling a need in the City and region for wellness -based retail, including entertainment, recreation, hospitality, and restaurants.
17 Objective F. Developing a center that will accommodate a variety of future tenants, including light manufacturing, warehouse, distribution tenants and other businesses that rely on transportation efficiency within an industrial corridor in a location with superior access to the local and regional transportation network, thereby minimizing truck traffic on local streets and reducing vehicle miles traveled in the region.

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accommodate users such as industrial incubators, light manufacturing, parcel hub, warehouse/storage, fulfillment center, high cube warehouse, cold storage warehouse (up to 100,000 sf), and e -commerce operations and includes self -storage uses permitted only on PA

3. The full list of uses permitted, conditionally permitted, and ancillary in these PAs is provided in the Specific Plan, Chapter 2, Development Plan.

All Project truck traffic will access 4th Street to the east through industrial areas. Interim regional access to the Project site is available from the SR -60 Freeway via Western Knolls and Veile Avenue/6th Street interchanges and the I-10 Freeway via the Oak Valley Parkway and Beaumont Avenue interchanges. Once the Potrero Boulevard interchange is constructed, regional access to the Project site would be available from the SR -60 Freeway/Potrero Boulevard and I-10 Freeway/Oak Valley Parkway interchanges (refer to Exhibits 4-2 and 4-4 of the Traffic Analysis, Attachment C of this Final EIR). Project trucks would not travel on residential streets, including residential areas adjacent to Viele Avenue, California Avenue and First Street. Trucks would travel through industrial areas and roadways that are not immediately adjacent to any noise sensitive land uses. Accordingly, no revisions to the Draft EIR are required.
5-24 Under Objective G,18 the commenter states the objective is misleading and states that there will be a substantial need, increase, and burden on existing infrastructure due to the need for the expansion of infrastructure. The commenter states that the applicant should disclose the required infrastructure improvements in the Beaumont area, including the expansion of sewer, water, Freeways and roadways.

As discussed in Section 3.0, Project Description, roadways, water, sewer, and drainage systems required for the Project are disclosed in detail (refer to Pages 3-11 to 3-15, Figures 3- 18, Conceptual Potable Water Phasing Plan, 3-19, Conceptual Reclaimed Water Phasing Plan, 3-20, Conceptual Sewer Phasing Plan, and 3-21, Conceptual Drainage and Water Quality Phasing Plan, and Table 1-4 of the Project's Traffic Analysis, Attachment C of this Final EIR). The precise location of roadways, access points, alignments and sizing of sewer facilities identified in the Draft EIR are considered conceptual in that they may be modified to meet the requirements of the City of Beaumont Public Works Depai fluent and to address final grading requirements. Additionally, the Project Applicant would be required to pay TUMF fees, DIF fees, and fair share improvement fees that the City would use to ensure the implementation of roadway improvements in the area in order to minimize traffic congestion.

Accordingly, no revisions to the Draft EIR are required. 5-25 Under Objective H,19 the commenter states the objective is misleading stating that there is no variation in warehouse buildings.
18 Objective G. Developing a project that utilizes existing investment in capital improvements for water, reclaimed water, sewer, storm drain and circulation facilities to further the planned development of land in the City and in its sphere of influence.
19 Objective H. Developing range of warehouse facility options, such as varying structure sizes and building configurations within the City with high quality business to facilitate local and regional distribution of goods while minimizing vehicle miles traveled, air quality and greenhouse gas impacts.

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This Project Objective relates to the variety of warehouse facility operations. The building design would be required to meet the development standards and design guidelines of the Beaumont Pointe Specific Plan. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required. However, the commenter's concerns are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project. 5-26 Under Objective I,20 the commenter states the objective is misleading because vegetation landscaping is a minimal component, water needs and fire danger have not been analyzed.

The Landscape Design Guidelines of the Beaumont Pointe Specific Plan provides a plant palette for three categories: Entrance Planting, Native California Planting, and Industrial Screen Planting. Alternative plant species may be used provided that they are drought -tolerant and complement the Project's design theme. The landscaping plan serves the dual purpose of adding year-round visual appeal while being sensitive to the environment and the Southern California climate, by using drought -tolerant materials. Additionally, the Project's Fuel Modification Area and Fuel Modification Zone would be planted with drought -tolerant, less flammable plants. Water demand for the Project is analyzed in Section 4.19, Utilities and Service Systems, of the Draft EIR (refer to Pages 4.19-22 to 4.19-23). Additionally, wildfire impacts are discussed in Sections 4.9, Hazards and Hazardous Materials, and 4.20, Wildfire, of the Draft EIR and found to be less than significant. Accordingly, no revisions to the Draft EIR are required.
5-27 The commenter states CEQA requires government agencies to consider the environmental consequences of their actions before approving projects subject to CEQA's provisions.

The Draft EIR was prepared in accordance with CEQA Guidelines and is presented to the Lead Agency prior to approval of the Project. Thus, no further response is required. 5-28 The commenter states the EIR must evaluate all potentially significant environmental impacts of a proposed project including both direct and indirect impacts as well as cumulative impacts.

The Draft EIR evaluated all potentially significant direct, indirect, and cumulative environmental impacts of the Project. Table 2-1, Location of CEQA Required Topics in this EIR, of the Draft EIR, provides a reference to Draft EIR sections that the CEQA-required content is provided, including CEQA Guidelines Sections 15126, 15126.2 (a), 15130.

Accordingly, no revisions to the Draft EIR are required. 5-29 The commenter states CEQA establishes a substantive mandate on the part of the lead agency to mitigate the significant environmental impacts of a project and a lead agency may not approve a project for which there are significant environmental impacts unless the agency makes findings that: (a) mitigation measures have been required of the project which avoid or substantially lessen the significant environmental impacts, or (b) mitigation measures are found 20 Objective I. Minimizing the demand for water resources by creating a development -wide landscape concept that features drought -tolerant plant materials to provide for an aesthetically pleasing outdoor environment and developing a project where recycled water is planned to be available.

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to be infeasible based on substantial evidence under CEQA Guidelines, Sections 15021 (a), 15091 (a)(b), and 15092 (b).

CEQA establishes a duty for public agencies to avoid or minimize environmental damage where feasible (CEQA Guidelines Section 15021). The Draft EIR was prepared in accordance to CEQA and provides feasible mitigation measures for each potentially significant environmental impact that would lessen the significant environmental impacts, or finds that mitigation measures infeasible based on substantial evidence. A summary of mitigation measures for the Project are provided under Table 1-1 Summary of Impacts, Mitigation, and Levels of Impact, of the Draft EIR. Accordingly, no revisions to the Draft EIR are required. 5-30 The commenter states mitigation measures must be certain and enforceable and the lead agency must ensure that mitigation measures are required by or incorporated into the project to ensure that the measures are actually carried out under Public Resources Code Section 21081.6 (a) and (b) and CEQA Guidelines Section 15126.6(a)(2).

As discussed in Section 2.0, Introduction and Purpose, of the Draft EIR, in compliance with Public Resources Code Section 21081.6, a Mitigation Monitoring and Reporting Program (MMRP) will be prepared for the Draft EIR. The MMRP is required to be adopted by the City Council concurrent with certification of the Final EIR for the proposed Project. Additionally, Project Design Features (PDFs) and Regulatory Requirements (RRs) are included in the Project's MMRP to further ensure the implementation of the PDFs and mandated RRs (refer to Page 2-17). CEQA Guidelines Section 15126.6(a)(2) does not exist; the commenter may be referring to Section 15126.4(a)(2), which states that mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments.

Through adoption of the MMRP, the Project is compliant with CEQA Guidelines Section 15126.4(a)(2). Accordingly, no revisions to the Draft EIR are required. 5-31 The commenter states CEQA's provides that a lead agency must evaluate alternatives to the proposed project, or the location of the project, which would attain most of the basic objectives of the project but would avoid or substantially lessen any of the project's significant environmental effects, the lead agency has a duty to adopt a project alternative if it is feasible, and lead agency may not reject an alternative unless the agency makes findings supported by substantial evidence showing that the alternative is infeasible under CEQA Guidelines Section 15126.6 (a), 15091 (a)(3), and 15092 and Public Resources Code Section 21002, 21081, and 21081.5.

CEQA's requirements are stated in the relevant provisions and the comment does not summarize the provisions correctly. Alternatives to the Project are discussed in Section 6.0, Alternatives, of the Draft EIR in accordance to CEQA. Accordingly, no revisions to the Draft EIR are required.
5-32 The commenter states that the Draft EIR failed to adequately evaluate impacts to/from including, but not limited to, aesthetics, air quality, biology, energy, greenhouse gas emissions, land use, noise, and traffic. The commenters reasoning for these statements are provided in the subsequent portion of the commenter letter; refer to response to Comments 5-33 to 5-37, below.

Thus, no further response is required.

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5-33 The commenter states that the aesthetic impacts and construction grading activities have not been fully evaluated but does not provide supporting evidence to justify these claims.

As discussed in Section 4.1, Aesthetics. of the Draft EIR, although the Project would convert undeveloped hillside areas to industrial and commercial development, it would not substantially degrade the existing visual character or quality of public views of the Project site and its surroundings, because the existing hillsides surrounding the Project site would be maintained, limiting views of the development. Additionally, the Project's proposed structures, which would reach a maximum height of 60 feet above finished grade, would not block views to the San Gorgonio Mountains, San Bernardino Mountains, and San Jacinto Mountains due to Project site's orientation and topography in relation to SR -60 and Frontage Road. Views of the Project site from the SR -60 Freeway along the Project frontage will include existing landform, manufactured slopes, landscaping, and intermittent views of the proposed buildings. Therefore, the proposed development would not substantially degrade the existing visual character or quality of public views of the Project site and its surroundings. Construction grading impacts are also discussed in detail in Section 4.1 (refer to Pages 4.1-12 to 4.1-16) and project impacts from grading were not found to be significant taking into account the on -site terrain.

Accordingly, no revisions to the Draft EIR are required. 5-34 The commenter states that the Draft EIR's analysis of the Project's energy impacts are inadequate in terms of the requirements of CEQA Guidelines, Appendix F, and failed to require sufficient analysis of the Project's energy consumption, transportation energy impacts; and does not demonstrate with substantial evidence that the Project would increase reliance on renewable energy sources and that mitigation measures are unenforceable.

The commenter does not explain how the mitigation measures are unenforceable. The Project's energy consumption, transportation energy impacts, and energy efficiency and conservation measures are discussed in Section 4.6, Energy, of the Draft EIR (refer to Pages 4.6-9 to 4.6- 32). To further reduce energy use associated with Project operations to the extent feasible, the Project would incorporate the following features into the new facility thus also complying with the requirements of Appendix F of the State CEQA Guidelines to achieve the goal of energy conservation by decreasing reliance on fossil fuels such as coal, natural gas and oil; and increasing reliance on renewable energy sources. In accordance with Mitigation Measure 4.8- 1, prior to issuance of each building permit, the Project Applicant shall provide documentation to the City as part of the plan check process, demonstrating implementation of the Riverside County Climate Action Plan (CAP), which includes solar photovoltaic panels that will meet a minimum of 20% of the power needs of the Project. Implementation of the Project would increase the demand for electricity and natural gas at the Project site and petroleum consumption in the region during operation. However, the electrical and natural gas consumption demands of the Project during operation would conform to the state's Title 24 and to CALGreen standards, which implement conservation measures and are made further efficient by application of CAP points to the Project. Note that after annexation into the City, the County CAP does not apply to the Project, but the City has exercised its discretion to comply with CAP points to increase energy efficiency of the proposed Project. Further, the proposed Project would not directly require the construction of new energy generation or supply facilities and providers of electricity and natural gas are in compliance with regulatory requirements that assist in conservation, including requirements that electrical providers Lead Agency: City of Beaumont SCH No. 2020099007

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achieve state -mandated renewal energy production requirements. Accordingly, no revisions to the Draft EIR are required.
5-35 The commenter incorrectly states that the analysis and mitigation of the Project's greenhouse gas emission ("GHG") impacts is based on the County's Climate Action Plan and Draft EIR relies upon illusory measures and uncertain mitigation in determining that the Project is compliant with the CAP.

As discussed in Section 4.8, Greenhouse Gas Emissions, of the Draft EIR, the Project is consistent with the County's Climate Action Plan and exceeds the minimum number of points required to mitigate GHG impacts. Refer to response to Comment 5-34 for details related to compliance with the County's Climate Action Plan. However, the City of Beaumont has elected to rely on compliance with a numeric threshold of significance to determine the significance of Project -related GHG emissions. Specifically, the City has selected 3,000 MTCO2e per year threshold based on the research and analysis underlying the recommendation by South Coast AQMD staff for residential and commercial sector projects against which to compare Project -related GHG emissions (refer to Page 4.8-32). Moreover, the Project's mitigation measures and project design features are included in the Project's MMRP to further ensure their implementation. Accordingly, no revisions to the Draft EIR are required. 5-36 The commenter states the Project would result in significant land use impacts because the Project would (a) result in a substantial alteration of the present or planned land use of the area; (b) be incompatible with the site's existing or proposed zoning; (c) be incompatible with existing surrounding zoning; (d) be incompatible with existing and planned surrounding land uses; and (e) be inconsistent with the land use designations and policies of the General Plan.

The Project site has not been zoned or pre -zoned by the City and there is currently no allowed development at the Project site. Without zoning and annexation, the Project cannot be considered inconsistent with the City's General Plan and zoning. Analysis of Project consistency is provided in Section 4.10, Land Use and Planning, of the Draft EIR (refer to Pages 4.11-9 to 4.11-39). As discussed, although the Project would result in a change to the General Plan land use designations for the Project site to allow for implementation of the Specific Plan, these changes would not result in a conflict with applicable plans, polices, or regulations adopted for the purpose of avoiding or reducing an environmental effect. Moreover, as stated previously, since the Project site is within the City's SOI within unincorporated Riverside County, the City has not yet adopted any zoning designations for the site. The City's approval and implementation of Pre -Zone PLAN2019-0283 would ensure that the Project would be consistent with the proposed zoning regulations identified in the Specific Plan.

Therefore, the Project would be consistent with the City's General Plan and zoning and no revision to the Draft EIR is required.
5-37 The commenter incorrectly states that construction noise levels are well above ambient conditions at the nearest homes to the Project site and noise analysis omits existing ambient noise measurements at residences to the north of the Project site, or those planned south of the Project site and traffic noise on residential receptors.

As shown in Table 4.13-7, Project Construction Noise Levels, Project construction at all nearby receiver locations would not cause noise levels at receiver locations to exceed 75 dBA Leq.

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Acceptable exterior construction noise level threshold is based on the City of Beaumont 55 dBA Leq interior noise level limit and the 20 dBA reduction in noise associated with typical sensitive receptor building construction. To assess the construction equipment noise levels, the Project construction noise analysis relies on the highest noise level impacts when the equipment with the highest reference noise level is operating at the closest point from the edge of primary construction activity (Project site boundary) to each receiver location. Additionally, the stationary noise analysis evaluates Project -related noise levels at the nearby receiver locations in the Project study area. As shown in Figure 4.13-1, Noise Measurement Locations, of the Draft EIR, the existing noise measurement locations included residential uses to the north of the Project site. Moreover, the roadway segments selected for the traffic noise analysis were based on Urban Crossroads, Inc. review of the Project study area evaluated in the Traffic Analysis (Attachment C of this Final EIR) and the off -site truck trip distributions. Accordingly, no revisions to the Draft EIR are required.
5-38 The commenter states that the Project removes obstacles for growth by providing infrastructure that would be needed for future growth, that Project's land use amendments also have the potential to set a precedent for similar large-scale industrial development in the rural area, and that the Draft EIR speciously states there are no growth inducing impacts because the existing land use has historically accommodated a variety of industrial and commercial uses.

As discussed in Section 5.0, Other CEQA Considerations, of the Draft EIR, since all proposed utility infrastructure would connect to lines at the eastern edge of the Project site and would be sized to exclusively serve the proposed development, this Project infrastructure would not indirectly induce substantial unplanned population growth (refer to Page 5-6). Additionally, the Project's potential influence on other nearby properties to redevelop at greater intensities and/or different uses than the City's General Plan and Zoning Code allow is speculative; however, it should be noted that implementation of the Project would not result in the approval of proposed uses on any other property outside of the Project site. CEQA does not require the analysis of speculative effects (State CEQA Guidelines Section 151454). Lastly, the Draft EIR does not state that the existing land use has historically accommodated a variety of industrial and commercial uses, but instead states that the Project site is currently and has historically been vacant and undeveloped, except for the eastern portion of the site that contains the paved portion of Jack Rabbit Trail (refer to Page 5-4). Accordingly, no revisions to the Draft EIR are required.
5-39 The commenter states that not all feasible mitigation was required of this Project, and Petitioner and others proposed feasible mitigation that has not been shown to be infeasible based on substantial evidence in the record.

The commenter's references to petitioners and proposed mitigation measures by petitioner and others appears to be referencing another project since there has been no litigation initiated by any petitioner to challenge this Project. However, all mitigation measure proposed by persons who commented on the Draft EIR have been considered and incorporated, where feasible, as documented in this Final EIR. Thus, no further response is required. 5-40 The commenter incorrectly states that requiring that the Project incorporate the phase -in of electric, hybrid electric, hydrogen electric, or battery operated (i.e., non -diesel) trucks is needed and the City/County has declined to adopt feasible mitigation to address significant impacts.

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As stated in Mitigation Measure 4.3-7, the buildings' electrical room shall be sufficiently sized to hold additional panels that may be needed to supply power for the future installation of electric vehicle (EV) truck charging stations on the site. Requiring zero -emission vehicles is currently economically and technologically infeasible (refer to response to Comment B-41); also, such vehicles are not available on a large enough scale to be relied upon. Therefore, the current technology required for EV truck charging stations is unknown and technologically infeasible. In addition, the County is not the lead agency on this Project and is not in a position to impose mitigation or required to make findings in connection with this EIR. Thus, the City properly determined that this mitigation is not warranted. 5-41 The commenter states that the Project should be limited to the assumptions of the air quality study in terms of truck trips (number and trip length) in order to ensure that significant impacts (NOx) are not more severe than assumed by the EIR. Further, the commenter states that the County declined to adopt feasible mitigation to address significant impacts, and the County failed to make findings supported by substantial evidence that the measure is infeasible.

As shown in Table 4.3-7, Summary of Peak Operation Emissions, of the Draft EIR, operational emissions generated by the Project are broken down by source types including mobile source and approximately 91% of the Project's NOx emissions are derived from vehicle usage. There are no feasible mitigation measures that would further reduce vehicular emissions at this time.

As discussed in Section 4.3, Air Quality, of the Draft EIR, and described in the Response to Comment B-41, the Project would be subject to compliance with Rule 2305 (refer to Pages

4.3-22 and 4.3-23). Because compliance will be implemented by lessees, the specific measures that will be implemented to comply with Rule 2305 is currently not known, although they potentially would include use of electric duty trucks. Additionally, through the implementation of Mitigation Measure MM 4.3-12, compliance with Rule 2305 would be ensured. Mitigation Measure 4.3-12 requires the City's Planning Department to confirm that tenant lease agreements requiring the Project Applicant to provide $1.00 per square foot in funding for fleet upgrade financing to be used over the term of their lease on Zero Emissions (ZE) and Near Zero Emissions (NZE) delivery vans or trucks. Compliance with Rule 2305 would reduce air quality effects associated with the warehouse industry, including the Project, throughout the air basin, although quantification of such reductions is not feasible at this time. Additionally, the Draft EIR provides an environmental analysis based on buildout of the Specific Plan.

Following adoption of the Specific Plan, the Project Applicant would process Plot Plans and, if required by the terms of the Specific Plan, Conditional Use Permits, that would allow administrative review of building design and layouts that are consistent with the Development Standards and Design Guidelines. Future development accommodated by the Specific Plan would be required to demonstrate compliance with the buildout assumptions in the Specific Plan and the Draft EIR. Accordingly, no revisions to the Draft EIR are required.

As a point of clarification, the City is the Lead Agency for the Project; not the County. The Project has incorporated all feasible mitigation measures as demonstrated throughout this Final EIR.
5-42 The commenter states that project buildings should require to be built with an earthen roof or install solar panels sufficient to achieve "net zero," and continues to incorrectly refer to the Lead Agency: City of Beaumont SCH No. 2020099007

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County as the agency declining to adopt feasible mitigation to address significant impacts when the City of Beaumont is the lead agency for the Project.

As discussed in Section 3.0, Project Description, of the Draft EIR, approximately 20% of the power needs of each building within the Project site shall be provided by Solar Photovoltaic panels or wind, installed on buildings or in collective arrangements (refer to Page 3-19).

Additionally, Project Design Feature, PDF 8-2 would require all roofs within the Project to be rated at 0.15 aged solar reflectance and 0.75 thermal emittance or greater (refer to Page 4.6-9).

Both cool and green roofs provide benefits of lower surface and air temperatures, and decreased energy demand.21 Additionally, it would not be feasible to provide both earthen (green) roofs and solar roofs at the same time, due to the limitation of roof space and benefits of providing solar for emission reductions over earthen roofs. Accordingly, no revisions to the Draft EIR are required.
5-43 The commenter states the that proposed mitigation measures are uncertain, unenforceable, ineffective and/or deferred in violation of CEQA, but provides no evidence to support the claim.

State law requires the preparation of a mitigation monitoring and reporting program (MMRP) to ensure that measures that would avoid or lessen significant environmental effects of the project are adopted as conditions of approval for the project. The mitigation measures identified in this EIR have been described in sufficient detail to provide the necessary information to identify the mitigation, the party or parties responsible for carrying out the mitigation, when the mitigation will be implemented, and why the mitigation has been required. The MMRP will be adopted by the City Council concurrent with certification of the Final EIR for the proposed Project. Accordingly, no revisions to the Draft EIR are required. 5-44 The commenter states the applicant fails to adequately consider alternatives to the proposed Project, including alternative sites, and unreasonably restricted criteria for analysis of alternative sites.

As discussed in response to Comment 5-4 and in Section 6.0, Alternatives, of the Draft EIR, the alternative sites alternative was analyzed under alternatives considered and rejected (refer to Pages 6-5 to 6-6) based on criteria under CEQA. The Draft EIR concluded that only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR (CEQA Guidelines Section 15126.6(b)). In addition, an alternative site need not be considered when implementation is remote and speculative, such as when the alternative site is beyond the control of a project applicant. Given the size and type of the proposed development, a similarly sized project and land use elsewhere in the South Coast Air Basin would result in the same or greater project -level and cumulative air quality, GHG emission, and transportation impacts. Therefore, analysis of an alternative site for the Project is neither meaningful nor necessary, because the significant impacts resulting from the Project would not be avoided or substantially lessened by its implementation in an alternate location. Furthermore, there are no alternative sites within the City or its sphere of influence that are similarly sized that would be suitable for industrial and commercial uses proposed by the Project. Additionally, the Project Applicant does not own or control another suitable site 21 https://www.epa.gov/heatislands/using-green-roofs-reduce-heat-islands Lead Agency: City of Beaumont SCH No. 2020099007

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that would achieve the underlying purpose and objectives of the Project. As a result, this alternative was rejected from further consideration and no further response is required. 5-45 The commenter requests an additional 30 days of public review to the Draft EIR because the notification process made it difficult for most Beaumont residents to review the DEIR.

CEQA requires that a Draft EIR have a review period lasting at least 45 days for projects that have been submitted to the SCH for review (State CEQA Guidelines, Section 15105(a)). The Draft EIR was distributed to various public agencies, organizations, and individuals on December 22, 2022; the EIR was available for public review and comment for a period of 48 days. The review period ended on February 8, 2023. The City used several methods to elicit comments on the Draft EIR. A Notice of Availability (NOA) and the Draft EIR was distributed to the SCH for distribution to State agencies. In addition, the DEIR was posted on the City's website. The NOA was posted also at the San Bernardino County Clerk's office on December 22, 2022. The NOA was mailed to responsible agencies, local government agencies, and interested parties that received the NOP, to individuals who had previously requested the NOA or EIR, and to individuals who provided NOP comments on December 22, 2022. The NOA was also published in Press -Enterprise Newspaper on December 22, 2022; the NOA and Draft EIR were made available for review, on the City's website at:
https://www.beaumontca.gov/1143Beaumont-Pointe-Specific-Plan . Therefore, the City has adequately provided notification in accordance to CEQA and no extension of public review period is warranted.

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COMMENT LETTER 6
Bob Tinker
bominKer curoadrunner,com
Subjeci Beaumont Point Specific Plan
Da+= Feb 8, 2023 at 9:13:38 PM
T [email protected]
have completed my review of this specific plan. I
found the Fire Protection component to be
adequate.

I do have a problem with proximity of the primary
access road and the emergency access gate and
roadway.If a hazmat incident were to develop on.

Hwy# 60 and evacuation of employees is required
there may not be adequate access. Sheltering in
place is not always possible during a hazmat
incident.Some type of additional access should be
in planning areas 7 or 8 .

If you need any additional information give a call.

Bob Tinker
1-951-367-4904
Sent from my iPad
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Responses to Comment 6
Tinker, Bob, dated February 8, 2023.
6-1 The commenter acknowledges the adequacy of the Fire Protection component of the Beaumont Pointe Specific Plan. The commenter expresses concerns related to the location of the primary access road and the emergency access gate, in case evacuation of employees is required during a hazmat incident on SR -60. The commenter recommends a secondary access route to be established in Planning areas 7 or 8 in case of a hazmat incident along SR -60 that would require site evacuation.

In the event of a hazmat incident, the on -site employees/individuals would follow the law enforcement's direction and may evacuate using fewer vehicles, as instructed by the authority.

Fewer evacuation of vehicles at any one time would reduce evacuation times. Moreover, upon reviewing the California's Governor Office of Emergency Services Hazmat Incident reports from 2018 to 2021, there are very few hazmat incidents that have occurred on the roadways/freeways within the County of Riverside that necessitated evacuation. Of all the incidents that required evacuation in the County of Riverside, none involved vehicle accidents or turnovers; rather, they all resulted from contractors striking underground utilities. Thus, the chances of a hazmat incident along SR -60 that would necessitate extensive evacuation are exceedingly slim. Furthermore, any transportation of hazardous materials, aside from common items such as gasoline, must adhere to stringent federal and state regulations, making the likelihood of a hazmat spill during transport along SR -60 very low. Most of the incidents that have occurred involving hazmat spills tend to stem from rail transport. Therefore, a secondary access route to the SR -60 Freeway from Planning Areas 7 and 8 is not required.

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COMMENT LETTER 7
From: Susan Walsh
To: Carole Kendrick
Subject: Beaumont Pointe Warehouse
Date: Monday, February 6, 2023 9:56:23 AM
I just wanted to reinforce how important it is to consider ALL warehouses' environmental impact, whether right inside our city or farther out. The effect of hundreds of trucks per day cannot be minimized regardless of the location. Prioritize an industry that is not dependent on trucking but instead brings needed jobs to our area. Of particular note is this recent article: " Warehouse Boom Transformed the Inland Empire". Warehouses should be considered within a particular category. No amount of fees can repair the damage to a community after something like this is built.

Thank you so much for putting my comment into the public record.

Susan Walsh
1282 Laguna Seca Ct
banning, CA 92220
Sent from my iPhone
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Responses to Comment 7
Walsh, Susan, dated February 6, 2023.
7-1 The commenter expresses general opposition to the Project and concerns related to the amount of truck traffic per day in the City of Beaumont. The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR.

Refer to Draft EIR Section 4.17, Transportation, for an analysis of the Project's impacts related to traffic. The commenter's concerns related to warehouse uses and jobs are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 8
From: Pat Wayne
To: Carole Kendrick
Subject: Beaumont Pointe Specific Plan
Date: Sunday, February 5, 2023 12:55:42 PM
I just wanted to reinforce how important it is to consider environmental impact of ALL warehouses whether right inside our city or farther out. The impact of hundreds of trucks per day cannot be minimized regardless of the location. Prioritize industry that is not dependent on trucking but instead brings needed jobs to our area. Of special note is this recent article: " Warehouse Boom Transformed the Inland Empire". Warehouses should be considered within a special category. No amount of fees can repair the damage to a community after something like this is built.

Thank you so much for putting my comment into the public record.

Pat Wayne
412 Saddlerock
Beaumont
httos:// www.latimes.com/california/story/2023-02-05/warehouses-big-rigs-fi ll-inland-emoire- streets
Warehouse boom transformed
Inland Empire. Are jobs worth
the environmental degradation?
As toxic emissions from diesel traffic choke the
air, activists are calling for a moratorium on new
warehouses and for the governor to declare a
state of emergency.
www.latimes.com
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Responses to Comment 8
Wayne, Pat, dated February 5, 2023.
8-1 The commenter expresses general opposition to the Project and concerns related to the amount of truck traffic per day in the City of Beaumont. The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR.

Refer to Draft EIR Section 4.17, Transportation, for an analysis of the Project's impacts related to traffic. The commenter's concerns related to warehouse uses and jobs are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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COMMENT LETTER 9
From: [email protected]
To: Christina Taylor
Subject: Beaumont Pointe warehouses
Date: Monday, February 6, 2023 12:54:28 PM
Dear Christina, please pass on my opposition to the latest catastrophic proposed warehouse, Beaumont Pointe.

My main objections are, damage to air quality caused by concentrations of mega trucks in a small area giving off deadly diesel particulate matter, which is proven to cause children's brains not to develop and increase lung cancer and breathing difficulties for residents.

The vast increase of truck traffic on I-10 freeway which looks close to capacity already.

The derstruction of wildlife habitat with no regard for needed open space not just parks surrounded by traffic.

There is space further along I-10 to the east , away from Beaumont/Banning where a warehouse could be built but, will they all be needed or just remain empty for years to come? Do we have the water and other services ,like fire fighting if one of these structures goes cup in flames. I would suggest the risk/reward is not in favor of the community and anymore warehouses or "logistic centers" as they try to name them, should not be built.

Geoffrey Wilson,Beaumont.
p.s. please share this e-mail with all members of the City Council.

Lead Agency: City of Beaumont SCH No. 2020099007

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Responses to Comment 9
Wilson, Geoffrey, dated February 6, 2023.
9-1 The commenter expresses general opposition to the Project and concerns related to air quality, truck traffic, wildlife, water supply, and wildfire. The commenter does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR.

Refer to Draft EIR Sections 4.3, Air Quality, 4.4, Biological Resources, 4.17, Transportation,

4.19, Utilities and Service Systems, and 4.20, Wildfire, for an analysis of the Project's impacts related to those environmental topics. The commenter's concern related to warehouse uses are acknowledged and will be forwarded to decision -makers for their review and consideration of the Project.

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SECTION 3.0 CLARIFICATIONS AND REVISIONS
Corrections to the Draft Environmental Impact Report (EIR) text generated either from responses to comments or independently by the City, are stated in this section of the Final EIR. The information included in this section does not constitute substantial new information that requires recirculation of the Draft EIR. Section 15088.5 of the State CEQA Guidelines states in part:
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term "information" can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. "Significant new information" requiring recirculation includes, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (b) Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.

None of the information contained in this section constitutes significant new information or changes to the analysis or conclusions of the Draft EIR. There were no new significant environmental impacts identified following circulation of the Draft EIR. Likewise, there were no substantial increases in the severity of environmental impacts identified after circulation of the Draft EIR. Therefore, recirculation of the Draft EIR is not required because no new information was added to the EIR.

CLARIFICATIONS AND REVISIONS TO THE DRAFT EIR
This section includes recommended clarifications and revisions to the Draft EIR. This section is organized by respective sections of the Draft EIR. Deleted text is shown as strikeout and new text is underlined.

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Title Pa2e

1. The land use entitlement names and application numbers have been updated, as follows:

Lead Agency Discretionary Permits
General Plan Amendment PLAN2019-0284
Pre -Zone PLAN2019-0283
Adoption of the Beaumont Pointe Specific Plan SP2019-0003 Beaumont Pointe Sign Program PLAN2022-0856
Vesting Tentative Parcel Map No. 3816182551
Development Agreement PLAN2023-0906No. 01 2017
Minor Amendment to the Western Riverside County Multiple Species Habitat Conservation Plan
Section 1.0 — Executive Summary

1. Page 1-1 is hereby modified due to updated land use entitlement names and application numbers.

Governmental approvals requested from the City of Beaumont by the Project Applicant to implement the Project include a General Plan Amendment (GPA; PLAN2019-0284); Pre - zoning (PLAN2019- 0283); Adoption of the Beaumont Pointe Specific Plan; Beaumont Pointe Sign Program (PLAN2022-0856); Vesting Tentative Parcel Map No. 3816182551; Pre Annexation and Development Agreement (PLAN2023-0906DA; No. 01 2017); approval by the City and LAFCO of annexation to the City of Beaumont and approval by BCVWD and LAFCO of annexation to the Beaumont -Cherry Valley Water District; and Minor Amendment to the MSHCP. All other related discretionary and administrative actions that are required of the City of Beaumont and other public agencies and entities to construct and operate the Project described in this EIR also are
Section 2.0 — Introduction and Purpose

1. Page 2-6 is hereby modified for clarification.

This EIR has been prepared as a Project EIR, pPursuant to CEQA Guidelines Section 15161, which states that a Project EIR should "...focus primarily on the changes in the environment that would result from the development project," and "...examine all phases of the project including planning, construction, and operation." As the first step in the CEQA compliance process, the City prepared an NOP pursuant to CEQA Guidelines Section 15082. When the Lead Agency determines that an EIR will clearly be required for the project, an Initial Study is not required (CEQA Guidelines Section 15063). Since it was determined that the Project could have a significant effect on the environment, the Lead Agency determined that an EIR was required and an Initial Study was not prepared. Public comments were received on the NOP, and the EIR will address all environmental topics provided in the CEQA Guidelines Appendix G and listed below in Section 2.9, Potential Impacts of the Project Discussed in the EIR.

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Section 3.0 — Project Description

1. Page 3-2 is hereby modified as follows in response to City's request and updates to the Specific Plan.
o Pre -zone (PLAN2019-0283) to "Specific Plan"
o Adoption of the Beaumont Pointe Specific Plan (herein referred to as Specific Plan; SP2019- 0003) that would create 10 planning areas allowing for General Commercial, Industrial, Open Space, and Open Space — Conservation land uses; o Beaumont Pointe Sign Program (PLAN2022-0856);
o Vesting Tentative Parcel Map (TPM) No. 38161 (PM2022-0012)82551 to subdivide the Project site;
o Development Agreement (PLAN2023-0906DA; No. 01 2017); and o Approval by the City and LAFCO of annexation agreement to the City of Beaumont and approval by BCVWD and LAFCO of annexation to the Beaumont -Cherry Valley Water District.

In order to assess the impacts of development of the Project under the Specific Plan and accompanying entitlements, the DEIR includes analysis of a conceptual site plan (see Subsection 3.6.6 and Figure 3- 16) that establishes building footprints that collectively achieve the maximum development square footage for each of the General Commercial and Industrial components of the Project and include a 125 -room hotel. As indicated in the Specific Plan and in more detail below, the size of the individual PAs and the square footage of development within individual General Commercial and Industrial PAs may increase or decrease by up to

15.1 25% but the maximum square footage for the commercial and industrial components of the Project as a whole may not be exceeded and the floor area ratio for each individual General Commercial and Industrial PA may not exceed 0.75. Therefore, the conceptual site plan provides an analysis of a full buildout scenario.

2. Page 3-8 is hereby modified due to updated land use entitlement names and application numbers.
(PLAN2019-0284), Beaumont Pointe Specific Plan (SP2019-0003), Pre -Zone (PLAN2019- 0283), Beaumont Pointe Sign Program (PLAN2022-0856), Vesting Tentative Parcel Map (TPM) No. 3816182551) and Development Agreement (PLAN2023-0906DA) No. 01 2017.

The individual components of the Project are discussed below.

3. Page 3-9 is hereby modified as follows in response to City's request.

The net acreage of each PA may vary by as much as 15.1 25%, provided that the overall maximum acreages for the Industrial PAs and for the General Commercial PAs within this Specific Plan are not exceeded.

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4. Pages 3-13 and 3-14 are hereby modified as follows in response to the changes made in the Beaumont Pointe Specific Plan.

Sewer service is provided by Eastern Municipal Water District (EMWD). As shown on Figure 3-11, Conceptual Sewer Plan, the Project utilizes a gravity sanitary system that services the entire Project site and connects to the City of Beaumont's sanitary system. Due to the grading limitations of the Specific Plan, the sewer system does not provide gravity flow to the proposed point of connection, which is a 12 inch PVC line and a sewer manhole, located at the end of the extension of'lth Street 350 feet east of the Project site. Instead, the gravity system will flow to the proposed sewer lift station located at the northwest corner of PA 5. From there the sewer flow would be conveyed via the proposed Dual Force Main within Industrial Way and Entertainment Avenue, and Jackrabbit Trail towards a connection at 4th Street with an existing 12 inch gravity sewer line utilizes 8" gravity sewer main lines, located within Industrial Way, to move wastewater flows from the project's high points (at PA 8 and PA 1), to the lift station constructed at the low point between PA 5 and 6. Flows from the lift station are then conveyed in dual 6" force main lines located within Industrial Way, Entertainment Way, Jack Rabbit Trail, and 4th Street, to the point of connection at the existing 12" gravity main line at the manhole located at the eastern boundary of the site. The on -site lift station will be designed to the Project's ultimate capacity with no interim condition except potential pump quantity.

Beyond the point of connection, the existing 12 -inch gravity line continues to the east within 4th Street, downstream approximately 2,500 feet, where it connects to the existing Hidden Canyon lift station (also known as the Beaumont Crossroads Lift Station). From there, the existing 6" and 16" force mains within 4th Street continue conveyance.

Although there is some capacity remaining that can be utilized for the Project, buildout of the Project will require upgrades to improvements at the Hidden Canyon Lift Station requiring that the existing sewage pumps to be upsized, including the associated electrical and mechanical improvements for the larger pumps, as well as installation of the ultimate buildout wet well.; which is rated for 300 gallon per minute operation. The existing Hidden Canyon Lift Station is currently approaching its Phase 1 pumping capacity. As a result, a lift station upgrade would be required to serve the Project and would consist of installing a new larger below ground precast wet well sized for the full buildout flows of the service area. The lift station upgrade will add multiple submersible solids handling pumps designed to provide redundant pumping capacity of the wastewater flows. The Project will design and construct the expansion of the Hidden Canyon Lift Station per the City's requirements.

5. Page 3-20 is hereby modified as follows to change the Tentative Parcel Map to a vesting map.

3.6.5 VESTING TENTATIVE PARCEL MAP No. 3816182551
The Project would include a Vesting Tentative Parcel Map. Additional, subdivision maps (parcel and/or tract maps, including vesting map) could be processed in conjunction with this Specific Plan to subdivide the site into smaller parcels and to regulate development of the physical components of the Project.

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6. Page 3-21 is hereby modified due to updated land use entitlement names and application numbers.

3.6.5 DEVELOPMENT AGREEMENT (PLAN2O23-0906DA No. 01 2017)

7. Pages 3-31 and 3-22 are hereby modified as follows in response to updated land use entitlement names and application numbers.

Table 3-7 Project Related Approvals/Permits
Public Agency
Approvals and Decisions
City of Beaumont
Proposed Project — City of Beaumont Discretionary Approvals Planning Commission
• Provide recommendation to the Beaumont City
Council regarding whether to certify the Project's EIR. • Provide recommendations to the Beaumont City
Council regarding whether to approve:
o General Plan Amendment (PLAN2019-0284),
o Pre -Zone (PLAN2019-0283).
o Beaumont Pointe Specific Plan (SP2019-0003),
o Beaumont Pointe Sign Program (PLAN2022-
0856)
o Vesting Tentative Parcel Map
o Development Agreement
City Council
• Certify the Project's EIR (ENV2019-0008) -and adopt
the Mitigation Monitoring and Reporting Program and
Findings and Statement of Overriding Considerations.
• Approval or Adoption of:
o General Plan Amendment (PLAN2019-0284),
o Pre -Zone (PLAN2019-0283).
o Beaumont Pointe Specific Plan (SP2019-0003),
o Beaumont Pointe Sign Program (PLAN2022-
0856)
o Vesting Tentative Parcel Map
o Development Agreement
City of Beaumont
• Annexation Application
• Joint Project Review (as Permittee)
• Minor Amendment to the MSHCP (submitted by the
City with approval by the Wildlife Agencies)
Subsequent City of Beaumont Discretionary and Ministerial Approvals J City of Beaumont
Subsequent Implementing Approvals
• Approve Final Phased Parcel Maps
• Approve Plot Plans
• Approve Landscaping/Irrigation Plan
• Approve Conditional or Temporary Use Permits, if
required.
• Issue Grading Permits
• Issue Building Permits
• Approve Road Improvement Plans
Lead Agency: City of Beaumont
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Public Agency
Approvals and Decisions
•
Approve Infrastructure Plans
•
Issue Encroachment Permits
•
Approve public right-of-way dedications
•
Approve Water Quality Management Plan
•
Approve connections to the municipal sewer system
Responsible Agencies — Approvals and Permits
Beaumont -Cherry Valley Water District (BCVWD)
•
Annexation
•
Adoption of the Water Supply Assessment
•
Approvals for construction of water infrastructure and
connection to water distribution system.

California Department of Fish and Wildlife
Approval Criteria Refinement
•
of
•
Minor Amcndmcnt to the MSHCP
•
Determination Biologically Equivalent Superior
of or
Preservation
•
Issuance Section 1602 Strcambed Alteration
of a
Agreement
Eastern Municipal Water District
•
Approvals for construction of sewer infrastructure and
connection to sewer distribution system.

Riverside County Local Agency Formation
•
Approval of the BCVWD and City annexations.

Commission (LAFCO)
Western Riverside County Regional Conservation
•
Approval of Criteria Refinement
Authority
•
Minor Amendment to the MSHCP
•
Approval of Habitat Evaluation and Negotiation
Strategy
•
Determination of Biologically Equivalent or Superior
Preservation
Regional Water Quality Control Board (RWQCB)
•
Issuance of a Construction Activity General
Construction Permit.
•
Issuance of a National Pollutant Discharge Elimination
System (NPDES) Permit.
•
Issuance of a Section 401 Permit pursuant to the Clean
Water Act
Riverside County Flood Control and Water
•
Approval of master plan of drainage infrastructure
Conservation District
•
Issuance of approvals necessary for the installation of Southern California Gas Company and Southern
California Edison
new SoCalGas and SCE facilities/connections to
service the Project.

South Coast Air Quality Management District
•
Issuance of permits that allow for the construction and operation of the proposed Project.

U.S. Fish and Wildlife Service
•
Approval of Criteria Refinement
•
Minor Amendment to the MSHCP
•
Determination of Biologically Equivalent or Superior
Preservation
•
Issuance of a Section 404 Permit pursuant to the Clean
Water Act
Trustee Agencies — Approvals and Permits
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Public Agency
Approvals and Decisions
Native American Heritage Commission
•
Ensuring California Native American tribes have
accessibility to ancient Native American cultural
resources on public lands overseeing the treatment and
disposition of inadvertently discovered Native
American human remains and burial items, and
administering the California Native American Graves
Protection and Repatriation Act.

California Department of Fish and Wildlife
•
•
•
•
Approval of Criteria Refinement
Minor Amendment to the MSHCP
Determination of Biologically Equivalent or Superior
Preservation
Issuance of a Section 1602 Streambed Alteration
Agreement

8. Page 3-49, Figure 3-16, Conceptual Site Plan, has been updated.

Section 4.3 — Air Quality

1. Page 4.3-36 is hereby modified as follows in response to Comments D-12 and D-21 and typographical error.

4.3.6 REGULATORY REQUIREMENTS AND PROJECT DESIGN FEATURES The following Regulatory Requirements (RRs) are applicable regardless of CEQA and would apply to any project under similar circumstances and, therefore, do not constitute mitigation measures. However, they will nonetheless be included in the Project's Mitigation Monitoring and Reporting Program to further ensure the implementation of the mandated RRs.

RR 3-1 The Project shall comply with the provisions of South Coast Air Quality Management District Rule 403, "Fugitive Dust." Rule 403 requires implementation of best available dust control measures during construction activities that generate fugitive dust, such as earth moving and stockpiling activities, grading, and equipment travel on unpaved roads, including limiting vehicle speeds to 15 miles per hour.

RR 3-2 The Project shall comply with the provisions of South Coast Air Quality Management District Rule 1186 "PMI() Emissions from Paved and Unpaved Roads and Livestock Operations" and Rule 1186.1, "Less -Polluting Street Sweepers." Adherence to Rule 1186 and Rule 1186.1 reduces the release of criteria pollutant emissions into the atmosphere during construction.

RR 3-3 The Project shall comply with the provisions of South Coast Air Quality Management District Rule 402 "Nuisance." Adherence to Rule 402 reduces the release of odorous emissions into the atmosphere.

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■ ■ Beaumont Pointe Specific Plan
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Source(s): Herdman (06-15-2023)
Figure 3-16
i NI

3.0 Project Description
Conceptual Site Plan
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4.3.67 IMPACT ANALYSIS
Consistency Criterion No. 2 refers to violations of the CAAQS and NAAQS. CAAQS and NAAQS violations would occur if LSTs or regional significance thresholds were exceeded. As evaluated under Thresholds b) and c) below, the Project's localized construction -source emissions would not exceed applicable LST thresholds after implementation. However, the Project's regional construction -source emissions would exceed the applicable regional thresholds for emissions of VOCs and NOx. As such, the the Project has the potential to result in a significant impact with respect to this criterion and the Project would have the potential to conflict with the AQMP according to this criterion, and could be potentially significant.

As evaluated under Thresholds b) and c) below, the Project would not exceed the LST thresholds for operational activity. However, the regional operational -source emissions are anticipated to exceed the regional thresholds of significance for NOx, VOC, CO, PM10, and PM25 emissions and would not be reduced to less than significant with imposition of mitigation measures. As such, the Project has the potential to result in a significant impact with respect to this criterion and the Project would have the potential to conflict with the AQMP according to this criterion.

2. Page 4.3-42 is hereby modified as follows due to typographical error.

A. Construction Localized Emissions Impact Analysis
'1. Criteria Pollutant Emissions
Table 4.3-9, Localized Significant Summary - Construction, identifies the localized impacts at the nearest receptor location in the vicinity of the Project. For analytical purposes, emissions associated with peak grading activities are considered for purposes of LSTs since these phases represents the maximum localized emissions that would occur. Any other construction phases of development that overlap would result in lesser emissions and consequently lesser impacts than what is disclosed herein. As shown in Table 4.3-9, Project -related construction emissions would not exceed the applicable South Coast AQMD LSTs for CO, NOx, PM10, or PM2.5 at the maximally impacted receptor location. All other modeled locations in the study area would experience a lesser concentration and consequently a lesser impact.

3. Page 4.3-49 is hereby modified as follows due to typographical error.

As previously shown in Table 4.3-6, Maximum Daily Peak Construction Emission Summary, construction activities associated with the Project would exceed the significance thresholds results established by the South Coast AQMD for VOC and NOx. However, as discussed below, with the implementation of Mitigation Measure MM

4. Page 4.3-50 is hereby modified as follows to add the odor analysis in the Draft EIR to the cumulative impact section.

As previously shown in Table 4.3-10, Localized Significant Summary — Operation, under long- term operating conditions, the Project's localized operational emissions would not exceed any of the South Coast AQMD LST thresholds. Pursuant to the South Coast AQMD's CEQA Air Lead Agency: City of Beaumont SCH No. 2020099007

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Quality Significance Thresholds, the Project would have a less -than -cumulatively considerable LST impact during long term operation. Additionally, the Project would have no potential to result in or contribute to a CO "Hot Spot." Accordingly, impacts associated with CO "Hot Spots" would be less than cumulatively considerable.

The Project would not result in a source of odors that would adversely affect a substantial number of people during construction or operation. Compliance with these standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction. Further, potential sources of operational odors generated by the Project would include disposal of commercial and industrial refuse and the use of diesel equipment. It is expected that Project -generated refuse would be stored in covered containers and removed at regular intervals in compliance with City's solid waste regulations, thereby precluding substantial generation of odors due to temporary holding of refuse on site. Additionally, the Project includes the construction of a sewer lift station; however, the location of the sewer lift station, which is located more than '/4 mile or 1,320 feet from the nearest residential land use, would not result in the potential odor source affecting a substantial number of people. The Project also would be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, odors associated with the proposed Project would not adversely affect a substantial number of people, and Project impacts during short-term construction or long-term operations would be less than significant. (DEIR, pp. 4.3-49 to 4.3-49) There are no nearby projects with sources of odors that the Project odors would combine with to adversely affect a substantial number of people; therefore, impacts would be less than cumulatively considerable.

5. Page 4.3-52 is hereby modified as follows in response to Comment D-23.

MM 4.3-4
MM 4.3-5
Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable CARB anti - idling regulations. At a minimum, each sign shall include: 1) instructions for truck drivers to shut off engines when not in use; 2) instructions for drivers of diesel trucks to restrict idling to no more than three (3) five (5) minutes once the vehicle is stopped, the transmission is set to "neutral" or "park," and the parking brake is engaged; and 3) telephone numbers of the building facilities manager and the CARB to report violations. Prior to the issuance of an occupancy permit, the City shall conduct a site inspection to ensure that the signs are in place.

Prior to tenant occupancy, the Project Applicant or successor in interest shall provide documentation to the City demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program and other Programs promulgated by South Coast AQMD (which can be found at the SCAQMD Incentives & Programs landing page, http://www.agmd.gov/home/programs) that provide incentives for using cleaner -than -required engines and equipment.

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6. Page 4.3-54 is hereby modified as follows in response to Comments B-35, B-39, B-60, and D-

7. MM 4.3-13
MM 4.3-14
MM 4.3-15
MM 4.3-16
MM 4.3-17
Plans submitted for grading permit issuance and building permit issuance shall specify a designated area of the construction site where electric or non -diesel vehicles, equipment, and tools can be fueled or charged. The provision of temporary electric infrastructure for such purpose shall be approved by the utility provider, Southern California Edison (SCE). If SCE will not approve the installation of temporary power for this purpose, the establishment of a temporary electric charging area will not be required. If electric equipment will not be used on the construction site because the construction contractor(s) does not have such equipment in its fleet (as specified in Mitigation Measure MM

4.3-14), the establishment of a temporary electric charging area also will not be required. If electric powered equipment is in the contractor(s) equipment fleet, and SCE approval is secured, the temporary charging location is required to be established upon issuance of grading permits and building permits.

If electric or non -diesel off -road trucks and construction support equipment, including but not limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers, plate compactors, and air compressors are available in the construction contractor's equipment fleet and can fulfill the Project's construction requirements during the building construction, paving, and architectural coating phases of Project construction, such equipment shall be used during Project construction. This requirement shall be noted on plans submitted for building permit issuance.

Project construction contractors shall maintain records of all off -road diesel construction equipment associated with Project construction to document that each off -road diesel construction equipment used meets emission standards.

Records shall be kept on -site for the duration of construction activities and shall be made available for periodic inspection by City of Beaumont staff or their designee.

During construction activities, the City shall conduct periodic inspections to verify compliance with construction -related mitigation measures pursuant to the Mitigation Monitoring and Reporting Program.

Prior to building final, the Project Applicant or successor in interest shall install signs at each truck exit driveway that provides directional information to the City's truck route. Text on the sign shall read "To Truck Route" with a directional arrow.

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7. Page 4.3-55 is hereby modified as follows due to typographical error.

B. Operation/ Emissions Impact Analysis
The Project would exceed regional thresholds of significance established by the South Coast AQMD for emissions of CO, VOC, NOx, PM10, and PM25. During Phase 1, the Project would exceed the numerical
Section 4.5 — Cultural Resources

1. Page 4.5-14 is hereby modified as follows for clarification purposes.

BFSA reviewed the NRHP Index and Office of Historic Preservation, Built Environment Resources Directory, which did not indicate the presence of any historical resources within the Project boundaries. As described under Section 4.5.1B.2, the Project site contains the following six potentially historic resources: RIV-5060 (historic trash scatter), RIV-5061 (historic trash scatter), P-33-006229 (historic Jack Rabbit Trail Road alignment), P-33-009027 (prehistoric isolate), P-33-015672 (potentially historic water storage tank and valves), and P-33-015673 (concrete pads and trash scatter). As previously stated, Phase II significance testing consisted of archaeological testing at the two archaeological sites, RIV-5060 and RIV-5061, which was previously identified as having historic trash scatter, while survey information and the already presented archival data was utilized for the remaining resources. Results of the Phase I and Phase II study determined that the six potentially historic resources were not eligible for listing under the CRHR or NRHP. The results of the testing are presented below; however, further detail can be found in Technical Appendix D.

2. Page 4.5-20 is hereby modified as follows due to typographical error.

4.5.10 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold b: Less Than Significant Impact with Mitigation Incorporated. Implementation of Mitigation Measures MM 4.5-1 and MM 4.5-2 would ensure the proper identification and subsequent treatment of any significant archaeological resources that may be encountered during ground -disturbing activities associated with implementation of the Project. With implementation of the required mitigation, the Project's potential impacts to important archaeological resources would be reduced to less than significant.

Section 4.6 — Ener2v

1. Page 4.6-9 is hereby modified as follows due to typographical errors.

PDF 8-1
Office space within the warehouses shall be insulated with a minimum R-13 value in the walls and R-30 in the attic, and all windows will have a minimum

0.57 U -factor and 0.32 SHGC or greater.

PDF 8-3 Occupant sensing lighting that dims to at least 50% when unoccupied shall be installed within the interior areas of warehouses. All interior lighting shall be Lead Agency: City of Beaumont SCH No. 2020099007

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LED lighting with 40 lumens/watt for 15 watt or less fixtures, 50 lumens/watt for 15-40 watt fixtures, and 60 lumens/watt for all fixtures exceeding 40 watts.

Section 4.7 — Geolo2v and Soils

1. Page 4.7-18 is hereby modified as follows due to typographical error.

Furthermore, the Project would be required to be designed and constructed in accordance with applicable seismic safety guidelines, including the requirements of the CBSC and City of Beaumont Municipal Code and Building Code. As stated previously, the City will condition the Project to comply with the site -specific ground preparation and construction recommendations contained in Section 5 of Technical Appendix Fl of this EIR, which will further reduce the risk of seismic -related ground failure due (see Regulatory Requirement RR 7-1). Mandatory compliance with the recommendations contained within the Project's Geotechnical Report (as required by the CBSC and Beaumont Municipal Code and Building Code) would ensure that the impact remains less than significant. As such, implementation of the Project would not directly or indirectly expose people or structures to substantial hazards associated with seismic -related ground failure and/or liquefaction hazards. Impacts would be less than significant.

2. Page 4.7-26 and 1-27 is hereby modified as follows due to typographical error. c) In the laboratory, individual fossils shall be cleaned of extraneous matrix, any breaks are repaired, and the specimen, if needed, is stabilized by soaking in an archivally approved acrylic hardener (e.g., a solution of acetone and Paraloid B72).

Section 4.8 — Greenhouse Gas Emissions

1. Page 4.8-34 is hereby modified as follows in response to Comment B-43.

PDF 8-1
PDF 8-3
PDF 8-5
Office space within the warehouses shall be insulated with a minimum R-13 value in the walls and R-30 in the attic, and all windows will have a minimum

0.57 U -factor and 0.32 SHGC or greater.

Occupant sensing lighting that dims to at least 50% when unoccupied shall be installed within the interior areas of warehouses. All interior lighting shall be LED lighting with 40 lumens/watt for 15 watt or less fixtures, 50 lumens/watt for 15-40 watt fixtures, and 60 lumens/watt for all fixtures exceeding 40 watts.

Tenant lease agreements for the Project shall include contractual language restricting trucks and support equipment from nonessential idling longer than 3 5 minutes while on site in exceedance of the City of Beaumont Idling Ordinance.

2. Table 4.8-7, SCAG Connect SoCal Applicability Analysis, on Page 4.8-42 is hereby modified as follows in response to Comment B-7.

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5 Reduce greenhouse gas
emissions and improve
air quality.

No Conflict. An analysis of the Project's environmental impacts is provided throughout this EIR and mitigation measures are specified where warranted. Air quality impacts are addressed in Section 4.3, Air Quality. Impacts would be reduced to the maximum extent feasible through the implementation of
Mitigation Measures and Project Design Features, which limit truck idling, provide incentives for using clean engines and equipment, require installation of conduit for EV truck charging stations, electric indoor material handling equipment and off -road equipment, preferential parking for fuel -efficient and carpool/van vehicles, EV charging stations.

Additionally, as discussed herein, the Project would incorporate measures related to building design, landscaping, and energy systems to promote the efficient use of energy. The Project would be consistent with the County of Riverside CAP requirement by achieving 581 points, which is significantly more than the required minimum of 100 points to determine consistency.

Furthermore, as demonstrated in Table 4.8-5 of the Draft EIR, the Project would not conflict with the City's Sustainable Beaumont:

The City's Roadmap to Greenhouse Gas Reductions, which
serves as a long-term plan to achieve sustainability in the City by reducing GHG emissions from existing and future development.

Although the Project would exceed the City's GHG significance threshold of 3,000 MTCOze per year, all feasible mitigation measures have been included to reduce GHG impacts.

Specifically, Mitigation Measures 4.3-3 through 4.3-13 relating to air quality would also reduce GHG impacts and Mitigation Measure 4.8-1 requires verification that the Project would achieve 581 points from the County CAP Screening Table for GHG
Implementation Measures CAP's rcquircmcnt to achicvc at least 100 havc less than individual
points and would significant and
impact GHG
cumulatively considerable on cmissionti.

Moreover, the City of Beaumont is identified as one of the priority growth areas for job centers in the region under the Connect SoCal Plan. When growth is concentrated in Job Centers, the length of vehicle trips for residents can be reduced, thereby reducing greenhouse gas emissions and improving air quality.

Section 4.9 — Hazards and Hazardous Materials

1. Page 4.9-5 is hereby modified due to CalFire's update to the Fire Hazard Severity Zones Maps.

C. Wiidiand Fire Hazards
The Project site is in the SOI for the City of Beaumont and within the San Timoteo Badlands, which are considered wildlands. As shown on Figure 4.9-1, Fire Hazard Severity Zones, the Riverside County Information Technology (RCIT) and California Department of Forestry and Fire Protection (Cal Fire) designates the Project site as located within a State Responsibility Area (SRA) for "High" and "Very High" fire hazard severity (Cal Fire, 2007; RCIT, 2021) CalFire has released an updated version of their fire hazard severity zone maps that, if adopted, Lead Agency: City of Beaumont SCH No. 2020099007

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would revise the fire hazard designation of the Project and its surroundings to all Very High rather than the current combination of Very High and High. (CalFire, 2023).

2. Page 4.9-17 is hereby modified to add in a description of the City's new fire station. The new fire station was not needed for the Project nor relied upon for the analysis of impacts to fire protection services, and the EIR concluded that the existing facilities would provide adequate protection even with the increase in call volume. Modifications are as follows:

The Project's proposed industrial/commercial development is anticipated to increase the call volume at a rate of up to 191 calls per year (4 calls per week or 16 calls per month). Fire Stations 66 and 20 combined emergency responses in 2017 totaled 4,943 calls per year or 5.43 and 8.11 calls per day per station, respectively. The level of service demand for the Project would increase overall call volume; however, the increase is not anticipated to impact the existing fire stations to a point that they cannot meet the demand. (Dudek, 2022, p. 37) In September 2022, the City commenced the construction of new Fire Station No. 106 (the "West Side Fire Station") along Potrero Boulevard across from Olivewood Avenue.

Construction is expected to take approximately twelve months. The new fire station will be approximately 10,000 sq. ft. and will include living quarters, offices, a fitness center and large bays to house multiple fire apparatus. Staffing will include three to four personnel, including a paramedic to provide advanced life support care. Services from the facility will be provided 24 hours a day, 7 days a week and 365 days of the year. Personnel at this station will be equipped with cardiac monitors, advanced life support medications, intubation equipment, trauma life support equipment, auto extrication tools, and more. The apparatus which will be housed in the facility will be capable of suppressing structure, wildland, vehicle, and other types of fires. The new station will decrease response times for the City's west side communities, including Olivewood, Tournament Hills, Tukwet and the new logistics centers located off of SR -60.

Furthermore, it should be noted that the Project would be required by City of Beaumont Chapter 3.36, Emergency Preparedness Facilities Fees, to contribute costs to improve Emergency Preparedness Centers.

3. Page 4.9-20 is hereby modified due to CalFire's draft update to the Fire Hazard Severity Zones Maps.

As shown in Figure 4.9-1, the Project site is designated within a "High" and "Very High" Fire Hazard Severity Zone within an SRA by the Riverside County General Plan and CalFire (RCIT, 2021; CalFire, 2021). CalFire has released an updated version of their fire hazard severity zone maps that, if adopted, would revise the fire hazard designation of the Project and its surroundings to all Very High rather than the current combination of Very High and High. (CalFire, 2023). Because of these designations, a Fire Protection Plan (FPP) was prepared.

Adoption of CalFire's new fire hazard zone maps would not change the findings in the FPP, which was planned and prepared for the Project as if it was entirely within the Very High Fire Hazard Severity Zone. After being annexed into the City of Beaumont, it is possible that Project could be re -designated as Local Responsibility Area (LRA) in a future update of CalFire's hazard severity zone maps, which would mean the City of Beaumont would have the primary responsibility for the prevention and suppression of wildland fires at the Project site.

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Section 4.10 — Hydrology and Water Quality

1. Page 4.10-14 is hereby modified as follows due to typographical error.

RR 10-5 Prior to the issuance of each building permit for the Project, the Project proponent shall provide evidence to the City that the Project complies with the requirements of the RWQCB Municipal Permit General MS4 Permit. The MS4 Permit requirements for new development calls for compliance with water quality regulatory requirements applicable to stormwater runoff and waste discharge. Specifically, the MS4 permit would require the Project proponent to develop and implement a comprehensive Stormwater Management Program (SWMP) that must include pollution prevention measures, treatment or removal techniques, monitoring, use of legal authority, and other appropriate measures to control the quality of stormwater discharged to the storm drains.

2. Page 4.10-17 is hereby modified as follows due to updated Project Specific Water Quality Management Plan (see Attachment B of this Final EIR).

Additionally, the Project's Preliminary WQMP identifies site -design and structural and non- structural source -control BMPs that would be implemented for the Project. Furthermore, as described under Section 3.8, Phasing, of this EIR, Phase 1 of the Project includes mass grading of PAs 1 and 2, which will remain graded and undeveloped until construction of the commercial uses in Phase 3. Under this interim condition, the mass graded pads are considered self -treating areas (no impervious area and gentle slopes) and storm drain lateral stub outs will be provided to connect the future onsite storm drain to the infrastructure storm drain system proposed by this project temporary bioretention basins would be required to capture debris flows and ensure SWPPP compliance.

The Project would maintain the 16 existing culverts as the ultimate discharge locations for the property; however, runoff from the impervious surfaces (i.e., proposed buildings, parking lots, and road improvements) would be collected by the Project's proposed drainage system. As shown on Figure 4.10-2, Proposed Hydrology Map and Water Quality Plan, the Project site would be divided into 17 drainage management areas (DMAs). The proposed drainage system would consist of catch basins, parking inlets, storm drain pipes with sizes varying from 18 inches to 48 inches, outlet structures, and four detention basins (Basins 1 — 4), one for each tributary area. The drainage system would route the runoff from the proposed impervious surfaces to the four detention basins. Where possible, runoff from impervious areas drain towards landscaped areas and biefetentionBMP basins through curb cutouts. All runoff from PAs 1 through 8 will enter the basins (Basins 1, 2, 3 & 4) for treatment and mitigation before discharging into their respective culverts. Runoff from streets and sidewalks from PAs 1 and 2

3. Page 4.10-18 is hereby modified as follows due to updated Preliminary Hydrology and Hydraulic Study (see Attachment A of this Final EIR).
will enter Basin 5 located at the northeast corner of the property, adjacent to Jackrabbit Trail.

Each culvert has natural depressed areas upstream which also acts as a natural detention area.

Each basin would provide stormwater treatment for each of their respective tributaries. The proposed stormwater treatment basins will provide peak runoff mitigation before discharging Lead Agency: City of Beaumont SCH No. 2020099007

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to the culverts_ with the exception of Basin 1. Basin 1 within PA 1 discharges into a detention located at the southwest corner of the property that is tucked in the existing foothills. This detention area was the result of the required grading for the proposed improvements which will serve as a detention basin for off site flows originating from the southern hills and runoff discharged from Basin 1. The detention basins would remove pollutants from runoff and filter the water to meet the water quality standards of the SARWQCB pursuant to the design requirements of the LID BMP Design Manual. The LID BMP Design Manual requires that basins are designed to capture runoff from the 0.75 inch, 24 -hour rainfall event or the 85th percentile, 24 -hour rainfall event, whichever is greater; thereby providing first -flush capture, detention, and filtration of stormwater runoff before it is discharged from the Project site.

4. Figure 4.10-1, Existing Hydrology Map, and Figure 4.10-2, Proposed Hydrology Map and Water Quality Plan, are hereby modified as follows due to updated Preliminary Hydrology and Hydraulic Study (Attachment C of this Final EIR).

5. Page 4.10-21 is hereby modified as follows due to updated Preliminary Hydrology and Hydraulic Study (Attachment C of this Final EIR).

A. Erosion and Siltation (Threshold c./)
The Project would include the installation of an integrated, on -site storm drain system consisting of catch basins, grated inlets, storm drain pipes with varying sizes, and four detention basins. The on -site storm drain system is designed to capture the on -site stormwater runoff flows, convey the runoff to the proposed detention basins, and treat the runoff to minimize water -borne pollutants transported from the Project site. As discussed previously, Basin 1 in PA 1 will also serve as a detention basin for offsite flows originating from the southern hills.

6. Page 4.10-22 is hereby modified as follows due to typographical error and the updated Preliminary Hydrology and Hydraulic Study (see Attachment A of this Final EIR).

B. Stormwater Runoff (Thresho/d c.// and c///)
As described above, the Project's proposed grading, earthwork activities, and the addition of impervious surfaces on the Project site would alter the site's existing interior drainage characteristics. Although the Project would introduce impervious surfaces to the Project site, the Project would maintain a similar drainage pattern as compared to existing conditions.

Under post -development conditions, the Project site would be divided into 17 DMAs, similar to pre -development conditions. The pre -development (existing) and post -development (proposed) DMAs represent different tributary areas but were created to maintain similar or less peak flows for each area which ultimately flow to its corresponding culvert, as shown on Figure 4.10-2.

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Source(s): Proactive Engineering Consultants (February 2023) Figure 4.10-1
A NI

PLANNING

4.10 Hydrology and Water Quality
Existing Hydrology Map
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4.10 Hydrology and Water Quality
Source(s): Proactive Engineering Consultants (February 2023) Figure 4.10-2
Proposed Hydrology Map and Water Quality Plan
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The 16 existing culverts would remain as the ultimate discharge locations for the Project site except for culverts 1 and 2, which will be replaced with a 20 foot' by x 20' foot reinforced concreate box (RCB) to be installed west of culvert 1 as part of the Caltrans SR -60 improvements. Additionally, runoff from the Project site would be captured by the proposed storm drainage system prior discharging to the existing culverts.

As shown in previous Table 4.10-1, under existing conditions, the Project site has a peak runoff volume of 1,482.4 cfs. Table 4.10-5, Developed 100 -Year Peak Flow Rates, identifies the peak flow rates discharges from each DMA under Project conditions, which results in a total peak runoff volume of 1,379.51384.4 cfs. Therefore, the implementation of the Project would result in an overall 100.998 cfs reduction in peak runoff

7. Table 4.10-5, Developed 100 -Year Peak Flow Rates, on Page 4.10-22 is hereby modified as follows due to the updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Table 4.10-5 Developed 100 -Year Peak Flow Rates
Area ID
Acreage
Existing Peak
Runoff
Proposed
Peak Runoff
(cfs)
Basin ID
Culvert Size (in)
Culvert
Capacity (cfs)
1 78.1
376.7
389.7428.1
Basin 4
54 CMP*
483.4**
178:4
2 2.6

9.0 9.0
30 CMP*
3 6.77.0

28.4 20.021.0
30CMP

96.0 4

6.7 54.5

21.6 36 CMP
154.1
45 0.4

1.8 1.8
Not Applicable
Not Applicable
5 5.1

16.4 15.6
30 CMP

71.8 6

43.79 160.5
113.9114.2
Basin 3
42CMP
132.0
7 4.2

14.3 15.2
24 CMP

59.5 8

5.2 22.6

16.9 24 CMP

51.5 9

9.6 49.7

31.3 24 CMP

38.7 10

0.5 2.2

2.1 24 CMP

77.8 11

12.1 212.6

36.7 48 CMP

79.2 12

2.9 10.5

10.2 24 CMP

54.1 13***
117.9
191.2
313.1
Basin 2
36 CMP
138.8
14 4.2

8.7 13.7
36 CMP
118.6
15 7.7

88.4 22.2
36 CMP
119.6
16 136.3137.3
234.7
311.7
Basin 1
(2) 48 CMP
476.9
Total
543.5544.9
1,482.4
1,379.5

8. Table 4.10-6, Detention Basin 100 -Year Peak Flow Capacity, on Page 4.10-24 is hereby modified as follows due to the updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

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Table 4.10-6 Detention Basin 100 -Year Peak Flow Capacity Area
ID
Acreage
100-Yr
1 -Hr Volume
(ac -ft)
100-Yr
24-HrVolume
(ac -ft)
100-Yr
1 -Hr Peak Flow
(Q, cfs)
100-Yr
24 -Hr Peak Flow
(Q, cfs)
Basin
ID
Basin
Capacity
(ac -ft)
1 70.851.6
5-46_1

23.517.1
268.0197.5

51.337.5
4 9.4
6 834.0
44_1

12.512.6
120.0120.9

24.025.2
3 9.5
13 88.7

10.6 32.7
333.7

65.0 2

11.1 16

85.6 10.2

32.8 320.3

63.3 1

10.3 9. Page 4.10-27 is hereby modified as follows due to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Threshold c: Less -than -Significant Impact. The Project would not alter the drainage pattern of a stream or river. The Project would result in the introduction of impervious surfaces on site; however, the drainage pattern of the Project site under developed conditions would be similar as compared to existing conditions. Overall, the Project would result in a 49098 cfs reduction in peak flow rates. The Project's drainage system, which include detention basins, is designed to ensure that all runoff is conveyed by facilities to bypass off -site tributary flows from the south, intercept and treat runoff from the development, and provide peak flow mitigation for the 100 -year storm events, as required by RCFC&WCD. Accordingly, the Project would not contribute runoff that would exceed the capacity of existing or planned stormwater drainage systems and would not result in flooding on- or off -site, and a less -than -significant impact would occur. Implementation of the Project's proposed BMPs (include on -site water quality detention basins) also would ensure the Project does not contribute substantial

10. Page 4.10-26 is hereby modified as follows for additional analysis.

Operational activities on the Project site would be required to comply with the Project's WQMP to minimize the amount of waterborne pollution discharged from the site. Other development projects within the watershed would similarly be required by law to prepare and implement site -specific WQMPs to ensure that runoff does not substantially contribute to water quality violations for surface water or groundwater. Compliance with the Santa Ana Region MS4 Permit, the Riverside County Drainage Area Management Plan — Santa Ana Region (DAMP) would ensure that the cumulative contribution of pollutants in the Santa Ana River Basin and the Upper Santa Ana Valley — San Timoteo Groundwater Basin would not be cumulatively considerable. Accordingly, operation of the Project would not contribute to cumulatively considerable water quality effects.

Section 4.11— Land Use and Planning

1. Page 4.11-8 is hereby modified due to updated land use entitlement names and application numbers.

This EIR analyzes the physical environmental effects associated with all components of the Project, including Project construction and operation. Governmental approvals requested from the City of Beaumont include a General Plan Amendment (GPA; PLAN2019-0284), Pre - zoning (PLAN2019- 0284) to "Specific Plan," Adoption of the Beaumont Pointe Specific Plan Lead Agency: City of Beaumont SCH No. 2020099007

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(SP2019-0003), Vesting Tentative Parcel Map (TPM) No. 38161 1-, and a Pre Annexation and Development Agreement (PLAN2023-0906DA; No. 01 2017). The Beaumont Pointe Specific Plan is referred to herein as Specific Plan.

2. Table 4.11-1, General Plan Applicability Analysis, on Page 4.11-12 is hereby modified to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Policy 3.10.7: Support practices that
promote low impact development,
including water resilient communities,
prevention of urban runoff, and mitigation
of industrial pollution.

No Conflict. No Conflict. In accordance with the Project's WQMP, the Project would install LID BMPs (e.g., bioretention and biotreatment) to detain stormwater on site for runoff mitigation. The Project proposes to install four detention basins within drainage management areas. The detention basins would remove pollutants from runoff and filter the water, thereby providing first -flush capture, detention, and filtration of stormwater runoff before it is discharged from the Project site.

Additionally, the Project proposes structural and non-structural source control BMPs (see Table 4.10-4 of this EIR) to mitigate industrial pollution. Furthermore, the Project would slightly reduce peak stormwater flows by approximately 40098 cfs and would not cause adverse hydrologic or biologic impacts to downstream receiving waters, including groundwater. As such, the Project would not conflict with General Plan Policy 3.10.7.

Policy 3.11.5: Preserve watercourses and
washes necessary for regional flood
control, ground water recharge areas and
drainage for open space and recreational
purposes. These include San Timoteo
Creek, Little San Gorgonio Creek and
Noble Creek, among others.

No Conflict. As further discussed in Section 4.10, Hydrology and Water Quality, of this EIR, the Project site is not within the recharge area for Little San Gorgonio Creek. The Project Applicant proposes to preserve 124.7 acres on site as Open Space and 152.4 acres as Open Space — Conservation. The Project would result in a 40098 cfs reduction in peak
stormwater runoff rates, and drainage from the development areas would continue to flow to San Timoteo Creek.

The implementation of the Project would not interfere with the City's ability to preserve watercourses and washes necessary for regional flood control, groundwater recharge areas and drainage for open space and recreational purposes. Therefore, the Project would not conflict with General Plan Policy 3.11.5.

3. Table 4.11-1, General Plan Applicability Analysis, on Page 4.11-17 is hereby modified as follows due to typographical error.

Policy 4.6.1: Prioritize goods movement
along specific routes in the City, consistent
with the adopted layered network, to foster
efficient freight logistics.

No Conflict. The Project site is situated in close proximity to the regional transportation network which connects the site to the Ports of Long Beach and Los Angeles, both major gateways for international trade, the Inland Empire and the Western United States. Located along the south side of the SR -60 and I- 10 Freeway, access to the regional transportation system from the site is provided via 4th Street through an industrial area to the east. Interim regional access to the Project site is available Lead Agency: City of Beaumont
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from the SR -60 Freeway via Western Knolls and Veile
Avenue/6th Street interchanges and the I-10 Freeway via the Oak Valley Parkway and Beaumont Avenue interchanges.

Once the Potrero Boulevard interchange is constructed,
regional access to the Project site would be available from the SR -60 Freeway/Potrero Boulevard and I-10 Freeway/Oak
Valley Parkway interchanges, to the SR 60 I
and access and
10 Freeway from 'Ith Street is the Potrero
provided at
Boulevard interchange, approximately 1.25 miles to the east.

Truck trips be routed through an industrial area to
would
Potrero Boulevard, identified City Truck
also as a potential
Priority roadway [City to Due to the Project
confirm]. site's
proximity to SR -60, trucks accessing the Project site would efficiently reach the State highway system to facilitate the movement of goods throughout the region. In addition, the Project would be consistent with SCAG's Connect SoCal
goals, which are described in detail in EIR Section 4.11, Land Use and Planning. Based on the foregoing, the Project would not conflict with General Plan Policy 4.6.1.

4. Table 4.11-1, General Plan Applicability Analysis, on Page 4.11-20 is hereby modified to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Policy 7.4.1: Incorporate low -impact
development (LID) techniques to improve
stormwater quality and reduce run-off
quantity
No Conflict. In accordance with the Project's WQMP, the Project would install LID BMPs (e.g., bioretention and
biotreatment) to detain stormwater on site for runoff mitigation.

The Project proposes to install four detention basins within drainage management areas. The detention basins would
remove pollutants from runoff and filter the water, thereby providing first -flush capture, detention, and filtration of stormwater runoff before it is discharged from the Project site.

Additionally, the Project proposes non-structural BMPs to mitigate industrial pollution. Furthermore, the Project would slightly reduce peak stormwater flows by approximately 44998 cfs and would not cause adverse hydrologic or biologic impacts to downstream receiving waters, including groundwater. As such, the Project would not conflict with General Plan Policy

7.4.1 5. Table 4.11-1, General Plan Applicability Analysis, on Page 4.11-20 is hereby modified to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Policy 7.5.5: Require hydrological/
hydraulic studies and WQMPs to ensure
that new developments and redevelopment
projects will not cause adverse hydrologic
or biologic impacts to downstream
receiving waters, including groundwater.

No Conflict. As further discussed in EIR Section 4.10,
Hydrology and Water Quality, a Project -specific WQMP and a Project -specific Hydrology Study was prepared by Proactive Engineering Consultants West, Inc. (PECW). The WMQP
identified BMPs that would be installed to mitigate water quality impacts and the Hydrology Study identified that the implementation of the Project would not result in substantial Lead Agency: City of Beaumont
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flooding on or off site. The detention basins to be installed on site would remove pollutants from runoff and filter the water, thereby providing first -flush capture, detention, and filtration of stormwater runoff before it is discharged from the Project site. Furthermore, the Project would slightly reduce peak stormwater flows by approximately -1-A998 cfs and would not cause adverse hydrologic or biologic impacts to downstream receiving waters, including groundwater. As such, the Project would not conflict with General Plan Policy 7.5.5.

6. Table 4.11-2, SCAG Connect SoCal Consistency Analysis, on Page 4.11-41 is hereby modified as follows in response to Comment B-7.
5 Reduce greenhouse gas
emissions and improve
air quality.

No Conflict. An analysis of the Project's environmental impacts is provided throughout this EIR and mitigation measures are specified where warranted. Air quality impacts are addressed in Section 4.3, Air Quality. Impacts would be reduced to the maximum extent feasible through the implementation of
Mitigation Measures and Project Design Features, which limit truck idling, provide incentives for using clean engines and equipment, require installation of conduit for EV truck charging stations, electric indoor material handling equipment and off -road equipment, preferential parking for fuel -efficient and carpool/van vehicles, EV charging stations.

Additionally, as discussed herein, the Project would incorporate measures related to building design, landscaping, and energy systems to promote the efficient use of energy. The Project would be consistent with the County of Riverside CAP requirement by achieving 581 points, which is significantly more than the required minimum of 100 points to determine consistency.

Furthermore, as demonstrated in Table 4.8-5 of the Draft EIR, the Project would not conflict with the City's Sustainable Beaumont:

The City's Roadmap to Greenhouse Gas Reductions, which
serves as a long-term plan to achieve sustainability in the City by reducing GHG emissions from existing and future development.

Although the Project would exceed the City's GHG significance threshold of 3,000 MTCO2e per year, all feasible mitigation measures have been included to reduce GHG impacts.

Specifically, Mitigation Measures 4.3-3 through 4.3-13 relating to air quality would also reduce GHG impacts and Mitigation Measure 4.8-1 requires verification that the Project would achieve 581 points from the County CAP Screening Table for GHG
Implementation Measures CAP's requirement to achieve at least 100 have less than individual
points and would significant and
impact GHG
cumulatively considerable on emissions.

Moreover, the City of Beaumont is identified as one of the priority growth areas for job centers in the region under the Connect SoCa1 Plan. When growth is concentrated in Job Centers, the length of vehicle trips for residents can be reduced, thereby reducing greenhouse gas emissions and improving air quality.

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Section 4.13 — Noise

1. Page 4.13-22 is hereby modified as follows due to typographical error.

Acceptable exterior construction noise level threshold is based on the City of Beaumont 55 dBA Leq interior noise level limit and the 20 dBA noise reduction associated with typical building construction. As shown in Table 4.13-7, Project construction would not cause noise levels at receiver locations to exceed 75 dBA Leq. Accordingly, Project construction would not result in substantial noise -related health safety hazards and impacts would be less than significant.

2. Page 4.13-39 is hereby modified as follows for clarification purposes.

Threshold a: Significant Direct and Cumulative Impact. The Project would not generate a substantial temporary or permanent increase in ambient noise levels during construction or on - site operation, in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. The Project would result in a significant impact from traffic noise at four roadway segments (#1, #4, #5, and #6). Therefore, the Project -related construction and off -site traffic noise level increases at adjacent noise -sensitive land uses are considered a significant impact.

3. Page 4.13-41 is hereby modified as follows due to typographical error.

Both rubberized asphalt and off -site noise barriers are considered as potential noise mitigation measures to reduce the potentially significant off -site traffic noise level increases. However, due the reasons outlined aboveut neither form of mitigation is recommended for implementation since they would not eliminate the off -site traffic noise level increases at the adjacent land uses to the impacted roadway segments. Therefore, Project -related off -site traffic noise level increases are considered significant and unavoidable under Project -level and cumulative conditions.

Section 4.14 — Population and Housing

1. Page 4.14-8 is hereby modified as follows in response to Comment B-17.

According to the Bureau of Labor Statistics (BLS), in August 2021, the Riverside -San Bernardino -Ontario region's civilian labor force exceeded 2,090,800 persons with more than 1,931,500 people employed and an unemployment rate of 7.6% (or 159,300 persons) (BLS, 2021). Accordingly, the Riverside -San Bernardino -Ontario region contains an ample supply of potential employees under existing conditions and the Project's labor demand is not expected to draw a substantial number of new, unplanned residents to the area. Furthermore, approximately 91.1% of Beaumont residents commute outside of the City for work and more housing units are expected to be built within the City over the next 20 years (City of Beaumont, 2020b). The Project would provide job opportunities close to home for existing and future Beaumont residents, which would subsequently help achieve a better job -to -housing balance within the City, as analyzed below.

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2. Page 4.14-1 1 is hereby modified as follows due to typographical error.

With the related projects (see Section 4.0, for the related projects list), there would be an increase of 13,317 residential units, 6,318,000 square feet of industrial uses, and 60,899 square feet of commercial uses. The related projects' industrial and commercial uses would generate approximately 6,370 jobs, which when combined with the Project, results in 11,826 jobs.3 As shown in Table 4.14-5, Cumulative Projects Population, Housing, and Employment Growth Trends in Beaumont, the projected population, housing units, and employment growth generated by the Project and related projects would be within the anticipated growth for the City. Additionally, by adding housing and non-residential uses in the City, the Project, along with related projects, would increase the City's jobs -housing ratio from 0.66 (Buildout Year Without Project) to 0.75 (Buildout Year With Project Plus Related Projects), which is within the City's projected grewtlhjobs-housing of 0.93 in 2040. The increase in housing and jobs from the related projects and jobs generated by the Project would contribute to the City's projected growth and jobs -housing ratio. Therefore, the Project with related projects would improve the City's jobs -housing balance and impacts would be less than significant.

Section 4.15 — Public Services

1. Page 4.15-2, Subsection 4.15.1, Existing Conditions, is hereby modified to describe a new fire station that is in the process of being constructed in the City. The new fire station was not needed for the Project nor relied upon for the analysis of impacts to fire protection services, and the EIR concluded that the existing facilities would provide adequate protection even with the increase in call volume. Modifications are as follows:

Within the area's emergency services system, fire and emergency medical services are also provided by other Riverside County Fire Stations. Generally, each agency is responsible for structural fire protection and wildland fire protection within their area of responsibility.

However, mutual aid agreements enable non -lead fire agencies to respond to fire emergencies outside their district boundaries. In the Project area, fire agencies cooperate under a statewide master mutual aid agreement for wildland fires. There are also mutual aid agreements in place with neighboring fire agencies and typically interdependencies that exist among the region's fire protection agencies for structural and medical responses; these are primarily associated with the peripheral "edges" of each agency's boundary (Dudek, 2022).

In September 2022, the City kicked off the construction of new Fire Station No. 106 (the "West Side Fire Station") along Potrero Boulevard across from Olivewood Avenue. Construction is expected to take approximately twelve months. The new fire station will be approximately 10,000 sq. ft. and will include living quarters, offices, a fitness center and large bays to house multiple fire apparatus. Staffing will include three-four personnel, including a paramedic to provide advanced life support care. Services from the facility will be provided 24 hours a day, 7 days a week and 365 days of the year. Personnel at this station will be equipped with cardiac monitors, advanced life support medications, intubation equipment, trauma life support equipment, auto extrication tools, and more. The apparatus which will be housed in the facility will be capable of suppressing structure, wildland, vehicle, and other types of fires. The new station will decrease response times for the City's west side communities, including Olivewood, Tournament Hills, Tukwet and the new logistics centers located off of SR -60.

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Section 4.17 — Transportation

1. Table 4.17-1, General Plan Applicability Analysis, on Page 4.17-14 is hereby modified as follows due to typographical error.

Policy 4.6.2: Minimize or restrict heavy
vehicle traffic near sensitive areas such as
schools, parks, and neighborhoods.

No Conflict. The closest sensitive area to the Project site is an existing single-family residence located approximately 483 feet south of the Project site's southernmost boundary.

Other residential uses are located north across Frontage Road (1,253 feet) and beyond SR -60. However, the Project would not restrict access to or from the existing residence; the Project would provide private residential access on -site to the existing residence, cars and trucks will not pass by this residence under the proposed roadway plan. Truck trips
would be routed through an industrial area to SR -60 and I- 10 Potrero Boulevard and would not pass by sensitive areas.

Based on these restrictions, the Project would not conflict be consistent with General Plan Policy 4.6.2.

2. Page 4.17-22 is hereby modified as follows due to typographical error.

The Technical Advisory relies on the Quantifying Greenhouse Gas Mitigation Measures, (CAPCOA) 2010 resource document to help justify the 15 percent reduction in VMT threshold stating, " . . . fifteen percent reduction in VMT are achievable at the project level in a variety of place types . . . ". A more accurate reading of the CAPCOA document is that a fifteen percent is the maximum reduction when combining multiple mitigation strategies for the suburban center4 place type. For suburban 5 place types 10 percent is the maximum and requires a project to contain a diverse land use mix, workforce housing, and project -specific transit. It is also important to note that the maximum percent reductions were not based on data or research comparing the actual performance of VMT reduction strategies in these place types. Instead, the percentages were derived from a limited comparison of aggregate citywide VMT performance for Sebastopol, San Rafael, and San Mateo where VMT performance ranged from 0 to 17 percent below the statewide VMT/capita average based on data collected prior to 2002.

Little evidence exists about the long-term performance of similar TDM strategies in different land use contexts. As such, VMT reductions from TDM strategies cannot be guaranteed in most cases (Fehr & Peers, 2019, pp. 65-66).

3. Page 4.17-23 and 1-33 hereby modified as follows due to typographical error.

MM 4.17-1 Prior to the issuance of building permits, the Project Applicant shall incorporate the TDM measures identified below. Verification that the TDM measures tee -completed shall be verified by the City's Public Works Director. a. Where applicable ensure design of key intersections and roadways encourage the use of walking, biking and, where applicable, transit.

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b. Collaborate with the Riverside Transit Authority (RTA) to determine the feasibility of providing new or re-route existing transit services to the site. c. Commute trip reduction (CTR) programs offered to encourage the use of biking.
d. Encourage CTR programs may also provide for alternative work or compressed work schedules to reduce the number of days an employee commutes to work.

Section 4.19 — Utilities and Service Systems

1. Page 4.19-5 is hereby modified to update the closure date of the Badlands Landfill. • Badlands Landfill — Located approximately 4.3 miles northwest of the Project site in the City of Moreno Valley at 31125 Ironwood Avenue. The landfill is operated by the RCDWR. The landfill has permitted tonnage of 4,800 tpd, has a remaining capacity of 15,748,799 cy as ofJanuary 2015, and has an estimated closure date ofJanuary 2059 2.

2. Page 4.19-20 is hereby modified as follows in response to the changes made in the Beaumont Pointe Specific Plan.

The Project is anticipated to have a wastewater generation rate of 0.26 million gallons of wastewater per day. The Project would construct a wastewater conveyance system to service the Project site and connect to the City's sanitary system. The Project utilizes a gravity sanitary system. However, due to the grading limitations, the sewer system does not provide gravity flow to the proposed point of connection, which is a 12 inch PVC line and a sewer manhole, located at the end of the extension of 4th Street 350 feet east of the Project site in'Ith Street in the existing right of way. Instead, the gravity system will flow to the proposed sewer lift station located at the northwest corner of PA 5. From there the sewer flow will be conveyed via the Trail towards a conncction at 'Ith Street with an existing 12 inch gravity sewer line utilizes 8" gravity sewer main lines, located within Industrial Way, to move wastewater flows from the project's high points (at PA 8 and PA 1), to the lift station constructed at the low point between PA 5 and 6. Flows from the lift station are then conveyed in dual 6" force main lines located within Industrial Way, Entertainment Way, Jack Rabbit Trail, and 4th Street, to the point of connection at the existing 12" gravity main line at the manhole located at the eastern boundary of the site. The on -site lift station shall be designed and limited to the Project's ultimate capacity with no interim condition except potential pump quantity.

3. Page 4.19-3 is hereby modified as follows to disclose additional imported water available to the Beaumont -Cherry Valley Water District (BCVWD) from the San Gorgonio Pass Water Agency (SGPWA).

In 2022, SGPWA entered into a 20 -year Agreement with the City of San Buenaventura (Ventura) and the Casitas Municipal Water District (Casitas). Together, the City of Ventura and the Casitas Municipal Water District have a combined Table A water allocation of 20.000 Lead Agency: City of Beaumont SCH No. 2020099007

ME Beaumont Pointe Specific Plan
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acre-feet. Ventura and Casitas do not plan to take direct delivery of their respective Table A water. The Ventura Water Agreement allows SGPWA to purchase water from Ventura and Casitas through its contractual arrangement. Of the 20,000 acre-feet total Table A allocation, the agreement allows for SGPWA to receive up to 10,000 acre-feet in addition to the existing 17,300 acre-feet Table A allocation for SGPWA. The average percentage of SGPWA Table A water available to BCVWD can be found in Tables 9-5 and 9-6 in the WSA Addendum #1 (Technical Appendix L2 of the Draft EIR). It is expected that BCVWD will receive the same percentage of water from the Ventura Water Agreement as it receives from SGPWA's Table A allocation. The average percentage of BCVWD's historical SWP water from SGPWA can be found in Table 9-9 in the WSA Addendum #1 (Technical Appendix L2 of the Draft EIR). The Table below shows the normal year, single dry year, and five consecutive dry years planned SWP Ventura Water Allocations for San Gorgonio Pass Water Agency through 2045.

Future Ventura Allocations by Year Type Through 2045 (AFB) Total Supply
2025
2030
2035
2040
2045
Normal
5800
5800
5800
5800
Single Dr- Year
500
500
500
500
•
al 2
o
',ill 6A
14 Fear 1
3500
3500
3500
3500
Year 2
500
500
500
500
Year 3
500
500
500
500
Year 4
2000
2000
2000
2000
Years
3500
3500
3500
3500

4. Page 4.19-26 is hereby modified as follows due to typographical error.

Hazardous waste generated during construction would be disposed of per existing legal requirements regulations (discussed in Section 4.9, Hazards and Hazardous Materials, of this EIR). Similarly, hazardous materials used during the construction and operation of the warehouse uses, including maintenance activities, would be disposed ofconducted in compliance with applicable regulations. Further, as discussed above, solid waste generated during construction activities would adhere to the diversion requirements outlined in the CalGreen Code, and would not exceed the required 65% diversion rate. The Project would participate in established programs for commercial development projects to reduce solid waste generation, in accordance with the provisions of the Riverside Countywide Integrated Waste Management Plan.

Section 4.20 — Wildfire

1. Page 4.20-7 is hereby modified due to CalFire's update to the Fire Hazard Severity Zones Maps.

As shown in Figure 4.20-1, Fire Hazard Severity Zone, the Project site is designated within a Very High Fire Hazard Severity Zone (VHFHSZ) and High Fire Hazard Severity Zone within an SRA by the Riverside County General Plan and CalFire. Adjacent to the Project site, within the City of Beaumont's jurisdictional boundary, the land is primarily designated as a Very High Lead Agency: City of Beaumont SCH No. 2020099007

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Fire Hazard Severity Zone (VHFHSZ) and High Fire Hazard Severity Zone (HFHSZ) local responsibility area (LRA). Additionally, CALFire has released an updated version of their draft fire hazard severity zone maps that, if adopted, would revise the fire hazard designation of the Project site and its surroundings to all Very High rather than the current combination of Very High and High. Adoption of CALFire's new fire hazard zone maps would not change the findings in the Fire Protection Plan (Technical Appendix M1), which was planned and prepared for the Project as if it was entirely within the VHFHSZ. After being annexed to the City of Beaumont, it is possible that the Project site could be re -designated as LRA in a future update of CAL FIRE's Hazard Severity Zone, which would mean the City of Beaumont would have the primary responsibility for the prevention and suppression of wildland fires at the Project (RCIT, 2021; CalFire, 2021; Dudek, 2022).

2. Page 4.20-9 is hereby modified to add in a description of the City's new fire station. The new fire station was not needed for the Project nor relied upon for the analysis of impacts to fire protection services, and the EIR concluded that the existing facilities would provide adequate protection even with the increase in call volume. Modifications are as follows:

As discussed in Section 4.15, Public Services, the Project's proposed industrial/commercial development is anticipated to increase the call volume at a rate of up to 191 calls per year (4 calls per week or 16 calls per month). Fire Stations 66 and 20 combined emergency responses in 2017 totaled 4,943 calls per year or 5.43 and 8.11 calls per day per station, respectively. The level of service demand for the Project would increase overall call volume; however, the increase is not anticipated to impact the existing fire stations to a point that they cannot meet the demand. (Dudek, 2022)
In September 2022, the City commenced the construction of new Fire Station No. 106 (the "West Side Fire Station") along Potrero Boulevard across from Olivewood Avenue.

Construction is expected to take approximately twelve months. The new fire station will be approximately 10,000 sq. ft. and will include living quarters, offices, a fitness center and large bays to house multiple fire apparatus. Staffing will include three to four personnel, including a paramedic to provide advanced life support care. Services from the facility will be provided 24 hours a day, 7 days a week and 365 days of the year. Personnel at this station will be equipped with cardiac monitors, advanced life support medications, intubation equipment, trauma life support equipment, auto extrication tools, and more. The apparatus which will be housed in the facility will be capable of suppressing structure, wildland, vehicle, and other types of fires. The new station will decrease response times for the City's west side communities, including Olivewood, Tournament Hills, Tukwet and the new logistics centers located off of SR -60.

Furthermore, it should be noted that the Project would be required by City of Beaumont Chapter 3.36, Emergency Preparedness Facilities Fees, to contribute costs to improve Emergency Preparedness Centers.

3. Page 4.20-11 is hereby modified to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

According to RCIT and FEMA, the Project site is within an area of minimal flooding (RCIT, 2021; FEMA, 2014). As further discussed under Threshold c of EIR Section 4.10, Hydrology and Water Quality, the Project would maintain a similar drainage pattern as compared to Lead Agency: City of Beaumont SCH No. 2020099007

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existing conditions. It should be noted that the overall development pad would be elevated by the proposed design grading to be situated above local drainage courses. As such, the risk of flooding is low. (KCG, 2019) Additionally, the implementation of the Project would result in a 4-0098 cfs reduction in peak flows discharging from the Project site. As such, impacts related to downslope/downstream flooding and drainage changes would be less than significant.

4. Page 4.20-24 is hereby modified to updated Preliminary Hydrology and Hydraulic Study (refer to Attachment A of this Final EIR).

Threshold d: Less -than -Significant Impact. The Project site is within an area of minimal flooding. Additionally, the Project would maintain a similar drainage pattern as compared to existing conditions and would reduce peak flow rates by 4-0098 cfs. Additionally, portions of the Project site have a "low" to "moderate" susceptibility for landslides. The Project would be required by the CBC and Beaumont Building Code to comply with the recommendations identified in the Project's Preliminary Geotechnical Investigation and constructed to maximize stability in order to preclude safety hazards to on -site areas. The implementation of the Project is not anticipated to directly or indirectly cause potential substantial risks, including landslides, as a result of runoff, post -fire instability or drainage change. Impacts would be less than significant.

Section 6.0 — Alternatives

1. Page 6-26 is hereby modified due to updated land use entitlement names and application numbers.
/C Land Use and Planning
Similar to the Project, the Reduced Development Area and Intensity Alternative would require a General Plan Amendment, Pre -zoning to "Specific Plan, Adoption of the Beaumont Pointe Specific Plan, Vesting Tentative Parcel Map and Development Agreement a Pre Annexation to implement the development. Similar to the Project, this alternative would be consistent with the SCAG's Connect SoCal policies, the City's General Plan and Zoning Ordinance, and Western Riverside County MSHCP. While, like the Project, this alternative would not conflict with the SCAG's Connect SoCal policies, it would impede the Connect SoCal goal of growing the Beaumont area as a job center to a greater extent than would the Project. Therefore, the Reduced Development Area and Intensity Alternative would still result in a less than significant impact related to land use and planning and similar to the Project.

2. Page 6-33 is hereby modified due to updated land use entitlement names and application numbers.
/C Land Use and Planning
The Reduced Intensity Alternative would require a General Plan Amendment, Pre -zoning to "Specific Plan, Adoption of the Beaumont Pointe Specific Plan, Vesting Tentative Parcel Map and Development Agreement a Pre Annexation to implement the development similar to the Project. Similar to the Project, this alternative would be consistent with the SCAG's Connect Lead Agency: City of Beaumont SCH No. 2020099007

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SoCal policies, the City's General Plan and Zoning Ordinance, and Western Riverside County MSHCP. Therefore, the Reduced Development Area and Intensity Alternative would result in a less than significant impact related to land use and planning and impacts would be similar compared to the Project.

3. Page 6-40 is hereby modified due to updated land use entitlement names and application numbers.

K Land Use and Planning
The Truck Storage Yard Alternative would require a General Plan Amendment, Pre -zoning to "Specific Plan, Adoption of the Beaumont Pointe Specific Plan, Vesting Tentative Parcel Map and Development Agreement a Pre Annexation to implement the development similar to the Project. This alternative would have the same type of consistency with the SCAG's Connect SoCal policies, the City's General Plan and Zoning Ordinance, and Western Riverside County MSHCP. While, like the Project, this alternative would not conflict with the SCAG's Connect SoCal policies, it would impede the Connect SoCal goal of growing the Beaumont area as a job center to a greater extent than would the Project. Nevertheless, the Truck Storage Yard Alternative would result in a less than significant impact related to land use and planning and similar compared to the Project.

Technical Appendices
The following technical appendices have been updated and do not contain new significant information or change the findings of the Draft EIR. These technical appendices are incorporated herein as Attachments A — D of this Final EIR:
• Draft EIR Appendix I1, Hydrology and Hydraulic Study
• Draft EIR Appendix I2, Preliminary Water Quality Management Plan • Draft EIR Appendix K1, Traffic Analysis
• Draft EIR Appendix M1, Fire Protection Plan
Lead Agency: City of Beaumont SCH No. 2020099007

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PLANNING
Irvine, CA 1 San Diego, CA 1 Murrysville, PA
1N 1195-002
3200 El Camnin❑ Real, Suite 100

MEMORANDUM
To: Carole Kendrick, Planning Manager
City of Beaumont
550 East 6th Street
Beaumont CA, 92223
FROM:

DATE:

RE:

Irvine, CA 92602
F
714.507.6360
Nicole Morse, Esq., Principal
March 4, 2024
Beamont Pointe Specific Plan — Supplemental CEQA Memorandum The Project Applicant, JRT BP 1 LLC, is requesting approval of an annexation of 541.2 acres of unincorporated Riverside County properties within the Sphere of Influence of the City of Beaumont into the City; a pre -zone to establish a specific plan zone; amendment to the General Plan land use designation from Rural Residential (1 acre lots) to Industrial (I), General Commercial (GC), and Open Space (OS); a Specific Plan to allow up to 4,995,000 square feet of industrial uses within five (5) buildings plus a 35,000 square foot self -storage building, up to 246,000 square feet of general commercial uses plus a 125 room hotel (approximately 90,000 square feet), for a total of approximately 5,331,000 square feet of commercial and industrial development, 124.7 acres of open space and 152.4 acres of open space conservation; a development agreement between the City of Beaumont and Beaumont Pointe Partners, LLC; a Vesting Tentative Parcel Map to subdivide the property; a comprehensive sign program and the consideration of the Final Environmental Impact Report (Final EIR) including the Draft Environmental Impact Report (Draft EIR) and Statement of Overriding Considerations for the Beaumont Pointe Specific Plan Project (Project; SCH No. 2020099007).

Two Planning Commission hearings were held for the Project on November 29, 2023, and January 10, 2024. On January 10, 2024, the City of Beaumont Planning Commission recommended approval of the Project to the City Council with certain modifications. In response to the Planning Commission's recommendation for modifications, new and revised mitigation measures are being incorporated into the Project and other modifications to the project design features of the Project are being made, as specified below. The purpose of this memorandum is to explain and document the revisions to the project design features and mitigation measures, provide supplemental technical support, and update the Mitigation Monitoring and Reporting Program to reflect the changes. The revisions outlined below provide additional environmental protection and do not include significant new www.rb)lanning.com
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information and do not meet any of the criteria set forth in Section 15088.5(a) of the State CEQA Guidelines requiring recirculation1-2; therefore, the EIR does not need to be recirculated prior to its certification.

I. AESTHETICS
At the November 29, 2023 Planning Commission Hearing, Commissioners asked questions related to aesthetics.

Specifically, they asked whether the Project Applicant could 1) Enhance the City of Beaumont identity on the freeway signs; 2) provide more robust landscaping; 3) commit to enhanced industrial building design and use earthtone colors; and 4) prepare view simulations from dedicated locations. At the January 10, 2024 Planning Commission Hearing, the Project Applicant presented responses on each of the foregoing, including the view simulations shown below.

A. Freeway Signs
The Project Applicant has modified the design of the Freeway Oriented Pylon Signs to prominently welcome the public to the City of Beaumont by emphasizing the city name. The revised Freeway Oriented Pylon Sign conceptual illustration is provided in the Sign Program. The requested changes to the Freeway Oriented Pylon Signs would modify the content of the signs but would not modify the height or other characteristics of the signs analyzed in the EIR. See Draft EIR Section 4.1.6(a).

B. Landscaping
The Project Applicant has modified the Landscape Design Guidelines and Plant Palette to require the following design of the landscape screening on the north side of the Project:
• 50% of trees to be 36 -inch box;
• Trees to be planted 25 feet on center in offset rows to create a "denser" screen and facilitate selective removal as trees mature;
• Trees to be planted at different elevations (top of building pad and staggered near top of manufactured slope) to create a visually dense, natural looking vegetation for more effective screening.

As discussed at the January 10, 2024 Planning Commission meeting, the Landscape Architect (Hunter Landscape) and the Fire Protection Consultant (Dudek) worked collaboratively to ensure that the Landscape Screen Plan is consistent with the fuel modification zones and the overall Fire Protection Plan, including selecting appropriate trees and groundcover in accordance with widely accepted fuel modification zone plant lists for Southern 1 Under CEQA Section 15088.5 (a), "Significant new information" requiring recirculation includes, for example, a disclosure showing that: (1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented; (2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance; (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it; or (4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. 2 Under CEQA Section 158088.5(b), recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. ww. w.rhpL i 11 1i ng.coin
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BEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024

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California, requiring tree limbs be pruned to at least four feet to avoid fuel laddering, spacing trees close enough to maximize screening while also minimizing fire hazard by having canopies too close together, and providing for ongoing maintenance. All Project landscape plans will be subject to review and approval by the City as part of the Plot Plan Review process. The modifications to the landscape program were carefully designed to provide further screening of the Project site from the SR -60 and further viewpoints, and to remain compliant with the requirements of the Fire Protection Program and does not provide significant new information. The City's review of landscape plans as part of the Plot Plan Review process will ensure that the Fire Protection Plan is complied with. No further analysis of impacts is required.

C. Building Design and Color Palette
The Project Applicant has changed the color palette for the industrial buildings from "light tones" and "gray tones" to "earth tones" within the Beaumont Pointe Specific Plan (Sections 4.2.2, 4.3.2 (5)). All Project building architecture design and colors will be reviewed and approved by the City as part of the Plot Plan Review process.

Furthermore, the Beaumont Pointe Specific Plan provides Building Design Criteria (design, form, colors and textures, windows and doors) and Screening (loading docks, walls and fences, equipment, trash enclosures) in Sections 3.4.1, 4.2.2, 4.3.1, 4.3.2, 4.3.3, 4.3.4, 4.3.5, 4.3.6, and 4.3.8. The changes to the Building color palette will allow the buildings to blend into the surrounding hillsides and will not modify the other characteristics of the buildings described in the Specific Plan and EIR. No further analysis of impacts is required.

D. View Simulations
As shown in Section 4.1, Aesthetics, of the Draft EIR, Figure 4.1-1, On -Site Visual Character, the Draft EIR presents the existing setting of the Project site and depicts the hilly nature and natural landforms of the Project site. Section

4.1.1, Existing Conditions, of the Draft EIR discusses the Project's existing setting in relation to aesthetics. As discussed in Section 4.1, Aesthetics, the Project would not have the potential to substantially damage scenic resources, including, but not limited to, trees, rock outcroppings and historic buildings within a State scenic highway (refer to Page 4.1-10 of the Draft EIR). There are no rock outcroppings on the Project site, and the City has not designated any portion of the Development Site as a scenic resource. In addition, the Project is not located within or visible from any designated scenic roadways and there are no scenic resources in the Project site vicinity. (Refer to Pages 4.1-10 and 4.1-27 of the Draft EIR). The Project site includes and is in proximity to hillsides, ridges, canyons, and valleys; however, the City does not designate these natural landforms as scenic vistas. However, the City does generally recognize the value of ridgelines and hillsides as significant natural and visual resources.

Specifically, the City's General Plan EIR states that special attention should be given to development proposals within the Badlands area, and projects that could affect views of, or otherwise alter ridgelines (Draft EIR, p. 4.1- 9). As stated in the Draft EIR,
Therefore, although landforms in mid -ground views (PAs 1-8) would be altered for the development, the Project would not allow grading within PA 10, which would preserve foreground landforms along the SR -60 Freeway and ridgeline background views behind the development.

Landform would not change along the north-northeast edge of the Project site between the site's north-northeast property line to the SR -60 Freeway. Additionally, the Project's proposed structures, which would reach a maximum height of 60 feet above finished grade, are not anticipated to block major views to the San Gorgonio Mountains, San Bernardino Mountains, and San Jacinto Mountains due to Project site's orientation and topography in relation to SR -60 and Frontage Road. Specifically, the topography to the north near SR -60 will be higher than the finished www.rhpL i11 1i ng.coin
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BEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024

PLANNING
grade building pads for the proposed industrial uses, which would limit the views of the proposed structures from SR -60. Under Project conditions, SR -60 and Frontage Road are anticipated to continue to provide intermittent and partial views to the existing ridgelines.

Table 4.1-3 of the Draft EIR analyzes the consistency of the Project with the Land Use and Community Design Element of the City of Beaumont's General Plan and concludes that the Project does not conflict with the goals and policies, that Project would preserve the scenic views within the area and would not result in an impact on scenic vistas.

View simulations were presented at the Planning Commission Hearing on January 10, 2024, and are shown below.

The images below show views that were photographed on a location map; existing views; and proposed view simulations that reflect the design grading plan, the conceptual building architecture and colors, and the Landscape Screen Plan with five -years and 10 years of plant growth after initial planting. The view simulations reinforce the analysis of aesthetic impacts in DEIR and the conclusion that there will be no significant visual impact with respect to preservation of scenic views within the area or scenic vistas.

View Simulation — Locations
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1 BEAUMONT POINTE SPECIFIC PLAN - SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024
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Existing View — Tuscany Place
View Simulation at 5 Years — Tuscany Place
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1 BEAUMONT POINTE SPECIFIC PLAN - SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024
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View Simulation at 10 Years — Tuscany Place
Existing View — Artisan Place
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View Simulation at 5 Years — Artisan Place
View Simulation at 10 Years — Artisan Place
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1 mgBEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024
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Existing View — Tukwet/Oak Valley
View Simulation at 5 Years — Tukwet/Oak Valley
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1 mgBEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024
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View Simulation at 10 Years — Tukwet/Oak Valley
Existing View — Palmer/Oak Valley
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View Simulation at 5 Years — Palmer/Oak Valley
View Simulation at 10 Years — Palmer/Oak Valley
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Existing View — Tukwet/Roxy
View Simulation at 5 Years — Tukwet/Roxy
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E. Conclusion
The additional information provided above related to freeway signs, landscaping, building design and color result in further visual enhancement and buffering of the Project site from surrounding areas. The view simulations provide further visual evidence of the analysis in the EIR but do not modify the Project or its consistency with the Land Use and Community Design Element of the Beaumont General Plan nor does it modify the conclusions of the EIR that there is no significant impact with respect to visual character or scenic vistas. These modifications and view simulations do not result in a new significant environmental impact or substantial increase in severity of an environmental impact. Therefore, this does not represent significant new information as defined in Section 15088.5(a) of the State CEQA Guidelines. The new measures do not change the findings in the Final EIR of no significant impact.

II. GREENHOUSE GAS EMISSIONS
As shown in Section 4.8, Greenhouse Gas Emissions, of the Draft EIR, the Project requires compliance with a variety of GHG reduction measures. Mitigation Measure MM 4.8-1 requires that the Project provide documentation during the plan check process demonstrating that the Project will implement measures identified in Table 4.8-6, which were obtained from the Riverside County Greenhouse Gas Emissions Screening Table or that the Project achieves equivalent emission reductions from other measures approved by the City. Implementing these mitigation measures is required to be verified by the City prior to the issuance of the final Certificate of Occupancy.

The Project as described in the Final EIR identified a minimum requirement of 581 points under the County of Riverside Climate Action Plan (CAP)(Refer to Draft EIR p. 4.8-38). The Final EIR and underlying technical GHG www.tbplanning.com
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emissions quantification is conservative and did not take credit for emissions reductions that would occur associated with the Project Design Features (PDFs) and Mitigation Measures (MMs) specified in the Final EIR, including, but not limited to:
• Installation of electric vehicle (EV) passenger vehicle charging stations (Table 4.8-6 & MM 4.8-1) • Installation of conduit in tractor trailer parking areas to accommodate installation of EV truck charging stations and to supply power to trailers with transport refrigeration units (TRUs) during the loading/unloading of refrigerated goods and a sufficiently sized electrical room for additional panels (MMs

4.3-7 and 4.3-8)
• On -site idling of no more than three minutes per idling event (MM 4.3-4 & PDF 8-3) • Electrification of truck bays serving refrigerated trucks (MM 4.3-9) • Funding for Zero Emission (ZE) and Near Zero Emission (NZE) vans or trucks by providing a $1 per square foot lease credit to industrial tenants who purchase ZE or NZE vehicles (MM 4.3-12) In addition, the Project Applicant has subsequently added the following project design features and measures:
• The industrial portion of the Project will meet LEED-ready requirements. • Natural gas will be prohibited in the industrial buildings, • New recycling measures
• An increase in the number of EV charging stations for passenger cars from 60 to 175 as required by the updated CalGreen Building Code requirements.

At the time the Draft EIR was prepared, only four mitigation measures (MM 4.3-10, MM 4.8-1, MM 4.3-6, and MM

4.8-1) were quantified to provide a conservative analysis of emissions reductions for Air Quality and Greenhouse Gas emissions. The Air Quality & Greenhouse Gas Evaluation (see Attachment A of this Memorandum) provides additional quantification of emissions reductions from project design features and mitigation measures described in the EIR but not quantified and from quantification of the new measures, which together would further reduce GHG emissions by 7,233.29 metric tons annually. In total, the Project would reduce GHG emissions by 10,506.27 metric tons annually. However, the Project would result in a total of approximately 53,404.80 MTCO2e per year and continue to result in a significant and unavoidable impact. The new measures further reduce impacts and do not result in a new significant environmental impact or substantial increase in severity of an environmental impact. Therefore, this does not represent significant new information as defined in Section 15088.5(a) of the State CEQA Guidelines. The new measures do not change the finding in the Final EIR that there are no additional feasible mitigation measures available that would further reduce emissions because the majority of the Project's emissions come from mobile sources which are regulated by the State and not the City of Beaumont.

To reflect the additional measures added in response to Planning Commission requested modifications, Mitigation Measure MM 4.8-1 has been revised and MM 4.8-2 is proposed to increase the number of points that would be implemented from the Riverside County Greenhouse Gas Emissions Screening Tables and to prohibit natural gas in the industrial and warehouse components of the Project, respectively.

MM 4.8-1
Prior to issuance of building permits, the Project shall provide documentation to the City as part of the plan check process demonstrating that the Project will implement the measures identified in Table 4.8 6, measures identified in which were obtained from the Riverside County www.rbplannfng.com
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BEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024

Greenhouse Gas Emissions Screening Tables, 2019 up to a minimum of 1,850 points. The Project may also achieve equivalent emission reductions from other measures approved by the City.

Implementing these mitigation measures shall be verified by the City prior to the issuance of final Certificate of Occupancy.

MM 4.8-2 The Project shall prohibit the use of natural gas in the industrial and warehouse components of the Project within Planning Areas 4 through 8, which shall be verified during plan check.

The revisions quantify reductions from existing measures, add recently adopted regulatory requirements, or make other minor modifications to the EIR that lessen GHG impacts without causing any new environmental impacts.

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

M. TRANSPORTATION
In response to the Planning Commission's recommendations, the Project Applicant commits to prepare a Truck Traffic Demand Management Plan (see Attachment B of this Memorandum providing details regarding the scope of the proposed truck management plan), approved by the City, which will establish the actions that the Project Applicant will take to prohibit Project trucks from driving on Potrero (and Oak Valley Parkway) north of the Potrero/SR-60 Interchange. The Truck Traffic Demand Management Plan will include the following: lease provisions clearly identifying the required truck routes; CC&R restrictions with financial penalties for violations and City ability to enforce as third -party beneficiary; truck route maps provided to all drivers and posted in breakrooms and throughout the Project; and designation of a Traffic Coordinator contact for the City to notify in the event of traffic issues. Accordingly, as shown below, new Mitigation Measure MM 4.17-2 has been incorporated into the Project.

MM 4.17-2
Prior to the issuance of occupancy permits for the first buildings in Planning Areas 4-8 (i.e., industrial/warehouse buildings), the Project Applicant shall prepare and submit a Truck Traffic Demand Management Plan to the Planning Department for approval in order to prohibit Project trucks from driving on Oak Valley Parkway or on Potrero Boulevard north of the Potrero/SR-60 Interchange. The Truck Traffic Demand Management Plan shall include, but is not limited to the following:
• Lease provisions clearly identifying the required truck routes; • CC&R restrictions with financial penalties for violations and City ability to enforce as third - party beneficiary;
• Truck route maps provided to all drivers and posted in breakrooms and throughout the Project;
• Designation of a Traffic Coordinator contact for the City to notify in the event of traffic issues;
• Annual reports to the City's Planning Department.

The revisions add an enforcement mechanism to ensure the Project's planned truck routes, which would not cause or result changes to or new environmental impacts. Therefore, the criteria for recirculation set forth in Section 15088.5(a) and (b) of the State CEQA Guidelines are not met. www.rhpLaaning.com
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BEAUMONT POINTE SPECIFIC PLAN — SUPPLEMENTAL CEQA MEMORANDUM March 4, 2024

IV. SUMMARY OF CHANGES
Mitigation Measure MM 4.8-1 has been updated to reflect the increase in the number of minimum points required from the Riverside County Greenhouse Gas Emissions Screening Tables. New Mitigation Measures MM 4.8-2 and MM 4.17-2 have been incorporated into the Project to prohibit natural gas in the industrial and warehouse components of the Project within Planning Areas 4 through 8and to restrict Project trucks from driving on Oak Valley Parkway and Potrero north of the Potrero/SR-60 Interchange, respectively. Therefore, the Project's Mitigation Monitoring Reporting Program (Attachment C of this Memorandum) has also been updated accordingly.
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1 BEAUMONT POINTE SPECIFIC PLAN SUPPLEMENTAL CEQA MEMORANDUM L;
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Attachment A:

Air Quality & Greenhouse Gas Evaluation
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Wty.,4141 1 [MUMMA

EXHIBIT H
DATE: January 3, 2024
TO: Mike Masterson, JRT BP 1 LLC
FROM: Haseeb Qureshi
JOB NO: 12397-11 Supplemental AQ & GHG Evaluation

BEAUMONT POINT SPECIFIC PLAN AIR QUALITY (AQ) & GREENHOUSE

GAS (GHG) EVALUATION
Mike Masterson,
Urban Crossroads, Inc. is pleased to provide the following Air Quality (AQ) & Greenhouse Gas (GHG) Evaluation for the Beaumont Point Specific Plan (Project). The following assessment is in response to comments received at the Planning Commission Hearing on November 29, 2023, that encouraged the Project to consider adding voluntary sustainability commitments to further reduce GHG emissions.

This evaluation serves to clarify the existing regulatory requirements, project design features (PDFs), and Draft Environmental Impact Report (DEIR) mitigation measures (MMs) that will reduce both AQ and GHG emissions. Additional mitigation measures have been identified that would also reduce both AQ and GHG emissions and will be incorporated into the Project. Lastly, this evaluation will further clarify the quantified GHG reduction from existing and proposed MMs.

EXISTING REGULATORY REQUIREMENTS
As summarized in the DEIR and underlying technical AQ and GHG appendices, the Project is required to comply with several existing regulatory requirements that will serve to reduce both AQ and GHG emissions, particularly from trucks associated with the Project, which is the largest contributor of emissions. The following regulatory requirements would reduce AQ and GHG emissions, it should be noted that this list is not exhaustive and there may be additional regulatory actions that exist or are being proposed that would further reduce AQ and GHG emissions from the Project's trucks.

12397-12 Supplemental AQ & GHG Evaluation

Mike Masterson
January 3, 2024

SUMMARY OF REGUALTORY REQUIREMENTS THAT WOULD REDUCE AQ AND GHG EMISSIONS The following summary includes existing regulatory requirements that would reduce AQ and GHG emission associated with the primary source of emissions from the Project - vehicular travel associated with trucks. The following list of regulatory requirements is not all inclusive and the purpose of this list is to highlight existing regulatory requirements that would have the greatest impact in reducing AQ and GHG emissions associated with the Project. • CARB's Mobile Source Strategy focuses on reducing emissions through the transition to zero and low emission vehicles and from medium -duty and heavy-duty trucks (1). • CARB's Sustainable Freight Action Plan establishes a goal to improve freight efficiency by 25 percent by 2030, deploy over 100,000 freight vehicles and equipment capable of zero emission operation and maximize both zero and near -zero emission freight vehicles and equipment powered by renewable energy by 2030 (1).
• CARB's Emissions Reduction Plan for Ports and Goods Movement (Goods Movement Plan) in California focuses on reducing heavy-duty truck -related emissions focus on establishment of emissions standards for trucks, fleet turnover, truck retrofits, and restriction on truck idling . While the focus of Goods Movement Plan is to reduce criteria air pollutant and air toxic emissions, the strategies to reduce these pollutants would also generally have a beneficial effect in reducing GHG emissions.

US EPA Cleaner Truck Initiative: In response to a petition from SCQMD, the US EPA has committed to updating its truck engine standard to reduce NOx emissions. • CARB's Transport Refrigeration Unit Regulation. Measure to reduce residual risk from TRUs by transitioning to zero -emission technologies.
• CARB's Advanced Clean Truck Rule: Requires truck manufacturers to sell an increasing percentage of zero -emission trucks by 2030 (up to 15 percent or 50 percent, depending on truck type). Also, this proposed rule would require one-time fleet reporting for large businesses. • CARB's Zero -Emission Fleet Rule: Would require some fleets to transition to zero -emissions • CARB's Heavy -Duty Low NOx Program: Would set new statewide engine standards, test cycles, and warranty and durability requirements to reduce NOx from trucks. • CARB's Heavy -Duty Inspection/Maintenance Program: Would set new inspection and maintenance requirements to ensure emissions controls are functioning properly. • SCAQMD's Warehouse Indirect Source Review (ISR): SCAQMD adopted an ISR rule for warehouse distribution centers 100,000 square feet and larger. The Warehouse ISR requires warehouse projects to implement facility -based measures or pay a fee that would reduce local air quality emissions (2).

As shown, there are at least ten major regulatory requirements that would reduce AQ and GHG emissions associated with the Project but the amount of reduction cannot be quantified at this time.

Emissions Reductions from Project Design Features and Mitigation Measures The DEIR includes fourteen AQ mitigation measures (MMs 4.3-3 through 4.3-16), an additional GHG mitigation measure (MM 4.8-1), and five project design features (PDFs 8-1 through 8-5) for a total of seventeen measures that collectively reduce GHG emissions from the Project.

URBAN CROSSROADS

12397-12 Supplemental AQ & GHG Evaluation

Mike Masterson
January 3, 2024

At the time the DEIR was prepared, GHG reductions from only four of these measures were quantified (See footnotes to Table 4.8-10 of the DEIR). The reality is that the remaining thirteen mitigation measures identified in the DEIR would also reduce GHG emissions.

Additionally, the Project has also agreed to enhance existing measures and has decided to include additional measures that would further reduce GHG emissions.

Table 1 includes a summary of the GHG emissions presented in the DEIR for both Unmitigated (without MMs or PDFs) and Mitigated conditions previously identified. Table 1 also includes a quantification of reductions associated with the existing measures that were not previously quantified as well as the reduction from additional new measures. The footnotes to Table 1 include additional details on the source of additional reductions.

As shown on Table 1, the Project as quantified herein would reduce GHG emissions by 10,506.27 metric tons annually.

Climate Action Plan Checklist
The DEIR identified that the Project would achieve a minimum of 581 points pursuant to the County of Riverside Climate Action Plan Checklist. As noted in the DEIR, the County of Riverside Climate Action Plan Checklist only requires 100 points to be garnered. As summarized in the DEIR, the Project would exceed this requirement by 581%. With implementation of the additional measures identified in Table 1 with respect to providing additional electric vehicle (EV) charging stations for passenger vehicles and trucks, the Project would achieve up to an additional 1,320 points pursuant to the CAP Screening Tables, for a total of 1,901 total points, as such, the Project would have the potential to exceed the CAP requirements by 1,900%.

Attorney General's Additional Measures
As noted in the FEIR, the Project is in fact incorporating applicable measures from the Attorney General's Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act guidance document. Responses to Comment B-34 and D-31 provide additional detail. As noted in the FEIR, many of the recommended measures from the Attorney General are regional measures that are not feasible on the Project level. Notwithstanding, the Project will be consistent with measures recommended by the Attorney General, including, but not limited to:
•
•
•
•
•
•
•
•
Requiring all on -site cargo handling equipment to be electric.

Limiting the idling of trucks to three minutes.

Installing solar photovoltaic systems.

Constructing EV charging stations and providing EV infrastructure (for cars and trucks).

Running conduit to designated locations for future EV truck charging stations.

Requiring plug-in capability for TRUs if Cold Storage uses are constructed.

Oversizing electrical rooms.

URBAN CROSSROADS

12397-12 Supplemental AQ & GHG Evaluation

Mike Masterson
January 3, 2024

• Designing the industrial portion of the Project to meet LEED requirements.

TABLE 1: GHG EMISSIONS SUMMARY
Emission Source
Emissions (MT/yr)
Unmitigated
Emissions from DEIR
Mitigated Emissions
from DEIR
Additional Quantified
Reductions
Net
Emissions
Construction Emissions
1,200.61
1,200.61
0 1,200.61
Area Source Emissions

0.45 0.24
0 0.24
Energy Source
7,685.89
5,183.39
-1,620.361
-1782
3,385.03
Mobile Source
50,624.69
49,865.32
-1,1883
-1,4554
-398.925
-1,606.536
45,216.87
TRUs
236.63
236.63
-23.66'
212.97
On -Site Equipment
922.58
922.58
0 922.58
Waste
3,051.27
3,051.27
-762.828
2,288.45
Water Usage
188.96
178.05
0 178.05
Total CO2e (All Sources)
63,911.07
60,638.09
-7,233.29
53,404.80
1 Reduction quantified for new mitigation measure that would restrict natural gas to the industrial buildings. 2 Reduction quantified for compliance with the CAP Checklist measures that require enhanced building energy efficiency. 3 Reduction quantified for compliance with the CAP Checklist for installation of passenger vehicle EV charging stations. The DEIR assumed up to 60 charging stations would be provided, this has been revised in the FEIR to 175 EV charging stations that would be provided for passenger vehicle charging to comply with CalGreen Building Code requirements. 4 Reduction quantified for MM 4.3-7 and 4.3-8, the assumption is that conduit will be provided and would facilitate up to 50 charging locations for trucks at the Project site.
5 Reduction quantified for PDF 8-5 and MM 4.3-4 which has been revised in the FEIR to limit idling to 3 minutes on -site per idling event, for a total of 9 minutes of idling, compared to the assumed 5 minutes per idling event and 15 minutes of total idling assumed in the DEIR. 6 Reduction quantified for MM 4.3-12 which would provide up to $4,995,000 in funding for EV Trucks, this could result in an additional 20 diesel trucks being replaced with electric trucks.

Reduction quantified for MM 4.3-9 which requires all truck/dock bats that serve cold storage facilities to be electrified. This would reduce the time they would idle at the loading docks.
8 Reduction quantified for CAP Measure S1.B.1 which requires separate recycling bins within each building and large external recycling collection bins. This measure is presumed to reduce solid waste by 25%.

URBAN

CROSSROADS