Corona City Council
July 1, 2026

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Environmental Impact Report Addendum

Table 10 SHP EIR Regional Operational Emissions Summary Source
Emissions (pounds per day)
VOC NOX CO SO2 PM10 PM2.5
Area 12.70 0.28 24.09 0.00 0.46 0.46
Energy 0.23 1.97 0.84 0.01 0.16 0.16
Mobile 8.43 23.08 91.35 0.31 21.69 6.08
Maximum Daily Emissionsa 21.36 25.33 116.28 0.33 22.31 6.70 Significance Threshold 55 55 550 150 150 55
Significant Impact? No No No No No No
a The maximum daily emissions refer to the maximum emissions that would occur in one day. (Corona, 2016, Table 4.8-7)
the Approved Project’s operational-related emissions would be below all of the SCAQMD Regional thresholds of significance. Thus, the SHP EIR concluded that the Approved Project would have a less-than-significant impact due to regional air quality emissions.

Approved Project Updated Regional Emissions Summary
The Regional air quality emissions calculations presented in the SHP EIR were based on CalEEMod version 2013.2.2.

Since preparation of the Draft SHP EIR, the CalEEMod software has undergone numerous updates to more accurately calculate air quality emissions for development projects. Accordingly, the Regional air quality emissions for the Approved Project were calculated with CalEEMod version 2022.1.1.21, which was released by the California Air Pollution Control Officers Association (CAPCOA) in 2022. The updated calculations were prepared in order to present a comparison between the air quality emissions associated with the Approved Project and the proposed Project using the same version of the CalEEMod modeling software, which is an “apples to apples” comparison, and uses the most accurate and current information. Table 11, Updated Approved Project Regional Operational Emissions, presents the Approved Project’s Regional air quality emissions based on CalEEMod version 2022.1.1.21 and buildout of the Project site with 292 single-family residential dwelling units3 . Detailed operation model outputs
for the Approved Project are presented in Attachment B to the Project’s AQ/GHG Assessment (Technical Appendix C). (UC, 2024, p. 15)
Regional Operational Emissions Comparison – Approved Project vs. Proposed Project Table 12, Regional Emissions Comparison – SHP EIR vs. Proposed Project, presents a comparison between the Regional operational emissions reported by the SHP EIR to the proposed Project’s emissions. As shown, the proposed Project would result in a slight reduction in emissions of VOC and NOX, and a slight increase in emissions of CO, SOX, PM10, and PM2.5. The increase in emissions of CO, SOX, PM10, and PM2.5 likely is the result of changes to the CalEEMod emission factors and modeling assumptions, given that there has been no change in the Project’s operational-related characteristics other than a reduction in the number of proposed dwelling units from 292 units under the Approved Project to 276 units3 under the proposed Project. However, the proposed Project’s emissions

3 It should be noted that although the Project Applicant is proposing to develop the site with only 276 dwelling units, the Project’s AQ/GHG Assessment assumes the Project site would be developed with up to 292 dwelling units; thus, the Project’s AQ/GHG Analysis provides a “worst-case” analysis of the Project’s potential impacts due to air quality and greenhouse gas emissions.

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Environmental Impact Report Addendum

Table 11 Updated Approved Project Regional Operational Emissions Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Mobile Source 10.91 11.21 109.58 0.30 27.41 7.10
Area Source 14.89 5.00 18.66 0.03 0.40 0.40
Energy Source 0.15 2.62 1.12 0.02 0.21 0.21
Total Maximum Daily Emissions 25.96 18.83 129.36 0.35 28.02 7.71 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Winter
Mobile Source 10.28 12.02 90.90 0.28 27.41 7.10
Area Source 13.44 4.84 2.06 0.03 0.39 0.39
Energy Source 0.15 2.62 1.12 0.02 0.21 0.21
Total Maximum Daily Emissions 23.88 19.49 94.07 0.33 28.01 7.70 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
(UC, 2024, Table 6)
Table 12 Regional Emissions Comparison – SHP EIR vs. Proposed Project Source
Peak Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Proposed Project 24.49 18.37 121.83 0.33 26.37 7.25
Approved Project 54.90 79.15 52.10 0.06 7.24 6.77
Net Emissions (Proposed - Approved) -30.41 -60.78 +69.73 +0.27 +19.13 +0.48 of CO, SOX, PM10, and PM2.5 would be far below the SCAQMD Regional thresholds for these pollutants, as shown in Table 9.

Table 13, Updated Emissions Comparison – Approved Project vs. Proposed Project, presents a comparison of the air quality emissions associated with the Approved Project and the proposed Project using the same version of the CalEEMod modeling software. As shown, and would be expected from the less intense Project, the proposed Project is anticipated to generate fewer emissions per day for VOC, NOX, CO, SOX, PM10, and PM2.5 as compared to emissions generated by the Approved Project. (UC, 2024, p. 16) Conclusion - Regional Operational Emissions
As demonstrated in Table 9 and Table 13, the proposed Project would result in Regional air quality emissions that are well below the SCAQMD Regional thresholds of significance, and when comparing emissions between the Approved Project and proposed Project using the same version of the CalEEMod modeling software, the proposed Project would result in a reduction in emissions of all criteria air pollutants. Accordingly, and consistent with the conclusion reached by the SHP EIR, operational-related Regional air quality emissions associated with the proposed Project would not violate any air quality standard or contribute substantially to an existing or projected

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Environmental Impact Report Addendum

Table 13 Updated Emissions Comparison – Approved Project vs. Proposed Project Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Proposed Project 24.49 17.76 121.83 0.33 26.37 7.25
Approved Project 25.96 18.83 129.36 0.35 28.02 7.71
Net Emissions (Proposed - Approved) -1.47 -1.08 -7.52 -0.02 -1.64 -0.45 Winter
Proposed Project 22.53 18.37 88.56 0.31 26.37 7.25
Approved Project 23.88 19.49 94.07 0.33 28.01 7.70
Net Emissions (Proposed - Approved) -1.35 -1.12 -5.52 -0.02 -1.64 -0.45 (UC, 2024, Table 8)
air quality violation and would not result in a cumulatively-considerable net increase of any criteria pollutant for which the region is nonattainment under an applicable federal or State ambient air quality standard. Impacts would be less than significant. Therefore, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.
d) Would the Project expose sensitive receptors to substantial pollutant concentrations? Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR found that implementation of the SHP would not expose sensitive receptors to substantial pollutant concentrations during operational or construction activities. The SHP EIR found that construction and operation of the SHP would not result in emissions that exceed the localized significance thresholds, and that the SHP would not cause or contribute to the formation of CO hotspots. The SHP EIR also found that construction and operation of the SHP would not expose sensitive receptors to substantial sources of Toxic Air Contaminant (TAC) emissions. Therefore, the SHP EIR found that construction and operation of the SHP would be less than significant. (Corona, 2015, pp. 4.B-32 to 4.B-35) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. During both construction and operation, the Project has the potential to expose nearby sensitive receptors to substantial pollutant concentrations. The following provides an analysis based on the applicable Localized Significance Thresholds (LSTs) established by the State of California and SCAQMD and an analysis of the Project’s potential to result in or contribute to CO “hot spots.”
Localized Significance Thresholds
The analysis of Project impacts due to localized emissions uses the methodology included in the SCAQMD Final Localized Significance Threshold Methodology (LST Methodology). The SCAQMD has established that impacts to air quality are significant if there is a potential to contribute or cause localized exceedances of the federal and/or State ambient air quality standards (NAAQS/CAAQS). Collectively, these are referred to as Localized Significance Thresholds (LSTs). The SCAQMD established LSTs in response to the SCAQMD Governing Board’s Environmental

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Justice Initiative I-44. LSTs represent the maximum emissions from a project that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard at the sensitive receptor.

The SCAQMD states that lead agencies can use the LSTs as another indicator of significance in its air quality impact analyses. (UC, 2024, p. 17)
Sensitive Receptors
The SCAQMD recommends that the nearest sensitive receptor be considered when determining a project’s potential to cause an individual or cumulatively significant impact. The nearest land use where an individual could remain for 24 hours to the Project site has been used to determine localized construction and operational air quality impacts for emissions of PM10 and PM2.5 (since PM10 and PM2.5 thresholds are based on a 24-hour averaging time). The nearest receptor used for evaluation of localized impacts of PM10 and PM2.5 is location R3 represented by the existing residence at 1490 Clearview Circle, approximately 53 feet (16 meters) east of the Project site (refer to Figure 8, Sensitive Receptor Locations). (UC, 2024, p. 17) Consistent with LST Methodology, the nearest industrial/commercial use to the Project site is used to determine construction and operational LST air impacts for emissions of NOX and CO as the averaging periods for these pollutants are shorter (8 hours or less) and it is reasonable to assume that an individual could be present at these sites for periods of one to 8 hours. Based on review of the Project area, construction activity surrounds the Project site. As such, it can be assumed that an individual can be present at these construction areas for a period of 8 hours. It should be noted that the existing residence (Location R3 as shown on Figure 8) is located at a closer distance than the nearest industrial/commercial use. As such, Location R3 also was be used for evaluation of localized NOX and CO impacts. (UC, 2024, p. 17)
It should be noted that the LST Methodology explicitly states that “It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.” As such, a 25-meter distance has been used for evaluation of localized PM10, PM2.5, NOX, and CO. (UC, 2024, pp. 17-18)
Localized Construction Emissions
Table 14, Project Localized Construction Emissions, identifies the localized impacts at the nearest receptor location in the vicinity of the Project. Outputs from the model runs for construction LSTs are provided in Attachment A to the Project’s AQ/GHG Assessment (Technical Appendix C). For analytical purposes, emissions associated with peak demolition, site preparation, and grading activities are considered for purposes of LSTs since these phases represent the maximum localized emissions that would occur. Any other construction phases of development that overlap would result in less emissions and consequently less impacts than what is disclosed herein. As shown in Table 14, emissions resulting from construction of the proposed Project would not exceed the numerical thresholds of significance established by the SCAQMD for any criteria pollutant. Thus, and consistent with the 4 The purpose of SCAQMD’s Environmental Justice program is to ensure that everyone has the right to equal protection from air pollution and fair access to the decision-making process that works to improve the quality of air within their communities.

Further, the SCAQMD defines Environmental Justice as “…equitable environmental policymaking and enforcement to protect the health of all residents, regardless of age, culture, ethnicity, gender, race, socioeconomic status, or geographic location, from the health effects of air pollution.”

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Environmental Impact Report Addendum

Figure 8 Sensitive Receptor Locations
(UC, 2024, Exhibit 2)

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Table 14 Project Localized Construction Emissions
On-Site Emissions Emissions (lbs/day)
NOX CO PM10 PM2.5
Demolition
Maximum Daily Emissions 12.29 11.39 0.93 0.52
SCAQMD Localized Threshold 92 508 3 2
Threshold Exceeded? No No No No
Site Preparation
Maximum Daily Emissions 14.19 12.46 2.75 1.61
SCAQMD Localized Threshold 144 841 5 4
Threshold Exceeded? No No No No
Grading
Maximum Daily Emissions 91.70 80.44 10.51 5.82
SCAQMD Localized Threshold 270 1,700 12 8
Threshold Exceeded? No No No No
(UC, 2024, Table 9)
conclusion reached by the SHP EIR, a less-than-significant impact would occur for localized Project-related construction-source emissions and no mitigation is required. (UC, 2024, p. 19) For purposes of disclosure, Table 15, SHP EIR Construction-Related Localized Emissions Summary, provides a summary of the Approved Project’s localized emissions as reported by the SHP EIR. Table 16, Construction-Related Localized Emissions Comparison – SHP EIR vs. Proposed Project, provides a comparison between the proposed Project’s construction-related localized emissions in comparison to what was disclosed for the Approved Project by the SHP EIR. As shown, the proposed Project would result in a slight increase in localized emissions of NOX, CO, and PM10, and would result in reduced localized emissions of PM2.5. The increase in emissions of NOX, CO, and PM10 likely is the result of changes to the CalEEMod emission factors and modeling assumptions, given that there has been no change in the Project’s construction-related characteristics other than a reduction in areas proposed for grading and a reduction in the number of proposed dwelling units. Additionally, the proposed Project’s emissions of NOX, CO, and PM10, and PM2.5 would be below the SCAQMD LSTs for these pollutants, as shown in c)Table 6. On this basis, and consistent with the conclusion reached by the SHP EIR, Project-related construction emissions would not expose sensitive receptors to substantial pollutant concentrations, and the Project’s impacts due to localized emission impacts would be less than significant. (UC, 2024, p. 19) Localized Operational Emissions
According to SCAQMD LST methodology, LSTs would apply to the operational phase of a proposed project if the project includes stationary sources, or attracts mobile sources that may spend long periods queuing and idling at the site (e.g., transfer facilities and warehouse buildings). The proposed project does not include such uses, and thus, due to the lack of significant stationary source emissions, no LST analysis is needed for operations. Although the SHP EIR did include calculations of the Approved Project’s operational localized emissions in comparison to the LSTs, which showed that operational-related localized emissions would be below all of the SCAQMD operational LSTs, because the Project does not include any stationary sources or mobile sources associated with long periods of queuing, an updated analysis of the proposed Project’s operational-related localized impacts is not

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Environmental Impact Report Addendum

Table 15 SHP EIR Construction-Related Localized Emissions Summary Activity
Onsite Emissions (pounds per day)
NOX CO PM10 PM2.5
Site Preparation 56.89 42.63 0.98 6.71
Grading 79.05 50.84 7.02 4.91
Paving 22.39 14.82 1.26 1.16
Building Construction 26.41 18.13 1.78 1.67
Architectural Coating 1.53 1.82 0.09 0.09
Maximum Daily Emissions a 79.05 50.84 7.02 6.71
Localized Significance Threshold 270 1,700 12 8
Exceed Threshold? No No No No
a
Each of the above activities does not occur at the same time; therefore, the maximum daily emissions represent the maximum emissions that would occur in one day. (Corona, 2015, Table 4.B-8)
Table 16 Construction-Related Localized Emissions Comparison – SHP EIR vs. Proposed Project Source Maximum Daily Localized Emissions (lbs/day)
NOX CO PM10 PM2.5
Proposed Project 91.70 80.44 10.51 5.82
Approved Project 79.05 50.84 7.02 6.71
Net Localized Emissions (Proposed - Approved) +12.65 +29.60 +3.49 -0.89 warranted. Notwithstanding, given that the proposed Project would include 276 single-family residential dwelling units, or 16 fewer dwelling units than the 292 dwelling units evaluated by the SHP EIR, it can be concluded that the proposed Project’s localized operational emissions would be slightly less than the localized emissions associated with the Approved Project. Therefore, and consistent with the conclusion reached by the SHP EIR, Project-related construction emissions would not expose sensitive receptors to substantial pollutant concentrations, and the Project’s impacts due to localized emission impacts would be less than significant. (UC, 2024, p. 19)
CO “Hot Spot” Analysis
As discussed below, the Project would not result in potentially adverse CO concentrations or “hot spots.” An adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one-hour standard of 20 parts per million (ppm) or the eight-hour standard of 9 ppm were to occur (UC, 2024, p. 23).

It has long been recognized that CO hotspots are caused by vehicular emissions, primarily when idling at congested intersections. In response, vehicle emissions standards have become increasingly stringent in the last twenty years.

Currently, the allowable CO emissions standard in California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of increasingly sophisticated and efficient emissions control technologies, CO concentration in the SCAB is now designated as attainment. (UC, 2024, p. 23)

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Environmental Impact Report Addendum

To establish a more accurate record of baseline CO concentrations affecting the SCAB, a CO “hot spot” analysis was conducted in 2003 for four busy intersections in Los Angeles at the peak morning and afternoon time periods5 .

This “hot spot” analysis did not predict any exceedance of the 1-hour (20.0 ppm) or 8-hour (9.0 ppm) CO standards, as shown on Table 10 of the Project’s AQ/GHG Assessment (Technical Appendix C). (UC, 2024, p. 23) Based on the SCAQMD's 2003 AQMP and the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan), peak carbon monoxide concentrations in the SCAB were a result of unusual meteorological and topographical conditions and not a result of traffic volumes and congestion at a particular intersection. As evidence of this, for example, of the 8.4 ppm 8-hr CO concentration measured at the Long Beach Boulevard and Imperial Highway. intersection (i.e., the highest CO generating intersection within the “hot spot” analysis), only 0.7 ppm was attributable to the traffic volumes and congestion at this intersection; the remaining 7.7 ppm were due to the ambient air measurements at the time the 2003 AQMP was prepared. In contrast, an adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur. (UC, 2024, pp. 23-24)
The ambient 1-hr and 8-hr CO concentration within the Project study area is estimated to be 1.6 ppm and 1.2 ppm, respectively (data from Metropolitan Riverside County station for 20226 ). Therefore, even if the traffic volumes for
the proposed Project were ten times the traffic volumes generated at the Long Beach Boulevard and Imperial Highway intersection, due to the on-going improvements in ambient air quality and vehicular emissions controls, the Project would not be capable of resulting in a CO “hot spot” at any study area intersections. As noted above, only 0.7 ppm were attributable to the traffic volumes and congestion at one of the busiest intersections in the SCAB. Therefore, if these traffic volumes were multiplied by ten times, it could be expected that the CO attributable to traffic would increase tenfold as well, resulting in 7 ppm – even if this were added to either the 1-hour or 8- hour CO concentrations within the Project study area, this would result in 8.6 ppm and 8.2 ppm for the 1-hr and 8-hr timeframes, respectively, and neither would exceed the applicable 1-hr standard of 20 ppm or the 8-hr standard of 9 ppm. (UC, 2024, p. 24)
Similar considerations are also employed by other Air Districts when evaluating potential CO concentration impacts. More specifically, the Bay Area Air Quality Management District (BAAQMD) concludes that under existing and future vehicle emission rates, a given project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour (vph) – or 24,000 vph where vertical and/or horizontal air does not mix – in order to generate a significant CO impact. Traffic volumes generating the CO concentrations for the “hot spot” analysis are shown on Table 11 of the Project’s AQ/GHG Assessment (Technical Appendix C). The busiest intersection evaluated was that at Wilshire Boulevard and Veteran Avenue, which had AM/PM traffic volumes of 8,062 vph and 7,719 vph respectively. (UC, 2024, p. 24) As shown in Table 12 of the Project’s AQ/GHG Assessment (Technical Appendix C), the highest trips on a segment of road for the proposed Project during AM/PM traffic is 2,848 vph and 3,173 vph, respectively, on Serfas Club Dr. & Green River Road. As such, Project-related traffic volumes are less than the traffic volumes identified in the 2003 AQMP. The Project considered herein would not produce the volume of traffic required to generate a CO “hot 5 The CO “hot spot” analysis conducted in 2003 is the most current study used for CO “hot spot” analysis in the SCAB. 6 It should be noted that the Metropolitan Riverside County monitoring station CO data was utilized in lieu of the Corona/Norco Area monitoring station, as no CO data is available for 2022 at this monitoring station.

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Environmental Impact Report Addendum

spot” either in the context of the 2003 Los Angeles hot spot study or based on representative BAAQMD CO threshold considerations. Therefore, CO “hot spots” are not an environmental impact of concern for the Project.

Accordingly, and consistent with the findings of the SHP EIR, the Project’s localized air quality impacts related to mobile-source emissions would therefore be less than significant. (UC, 2024, p. 25) Conclusion
As demonstrated in the preceding analysis, the proposed Project’s localized emissions during construction and long-term operation would not exceed any of the SCAQMD LSTs, and the Project would not generate traffic levels that have the potential to cause or contribute to a CO “hot spot.” Therefore, and consistent with the findings of the SHP EIR, the proposed Project would not expose sensitive receptors to substantial pollutant concentrations, and impacts would be less than significant. Accordingly, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.
e) Would the Project create objectionable odors that would affect a substantial number of people? Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR found that implementation of the SHP would not create objectionable odors affecting a substantial number of people, and concluded that odors associated with construction and operation of the SHP would be less than significant. (Corona, 2015, pp. 4.B-35 to 4.B-36)
EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The potential for the Project to generate objectionable odors has also been considered. Land uses generally associated with odor complaints include agricultural uses (livestock and farming), wastewater treatment plants, food processing plants, chemical plants, composting operations, refineries, landfills, dairies, fiberglass molding facilities. Similar to the project evaluated in the SHP EIR, the Project does not contain land uses typically associated with emitting objectionable odors. Potential odor sources associated with the proposed Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities and the temporary storage of typical solid waste (refuse) associated with the proposed Project’s (long-term operational) uses.

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 and is thus considered less than significant. It is expected that Project-generated refuse would be stored in covered containers and removed at regular intervals in compliance with the solid waste regulations. The proposed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, and consistent with the conclusion reached by the SHP EIR, odors associated with the proposed Project construction and operations would be less than significant and no mitigation is required. Accordingly, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. (UC, 2024, pp. 25-26)

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f) Would the Project conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan and municipal code) adopted for the purpose of avoiding or mitigating an environmental effect? Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR included an analysis of the Approved Project’s consistency with the City of Corona General Plan, which demonstrated that the Approved Project would not result in a conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan and municipal code) adopted for the purpose of avoiding or mitigating an environmental effect. As such, the SHP EIR concluded that impacts would be less than significant.

EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The SHP EIR was certified in 2017.

However, subsequent to certification of the SHP EIR, the City of Corona City Council adopted an update to the City’s General Plan in 2020, with the most recent amendment to the General Plan occurring in April 2024. Table 17, Project Consistency with General Plan Policies Related to Air Quality, provides an analysis of the proposed Project’s consistency with the air quality-related goals and policies from the 2020 General Plan, which are included in the General Plan Open Space and Conservation Element. As indicated in Table 17, the proposed Project would be consistent with or otherwise would not conflict with the General Plan policies related to air quality. Therefore, and consistent with the finding of the SHP EIR, the proposed Project would not conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect, and impacts would be less than significant. Accordingly, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.

Table 17 Project Consistency with General Plan Policies Related to Air Quality Goal/Policy Project Consistency
Goal OS-7: Improve air quality and seek to reduce
greenhouse gas emissions.

Consistent. As demonstrated by the analysis presented
herein, the proposed Project would result in less-thansignificant impacts due to air quality and GHG emissions.

Policy OS-7.1: Development Design and Practices. Reduce the amount of air pollution emissions from mobile and
stationary sources, and enhance the South Coast Air Basin by using best management practices in development
proposals and project implementation.

Consistent. As demonstrated by the analysis presented
herein, the proposed Project would result in less-thansignificant impacts due to air quality emissions. In addition, the Project would be subject to compliance with all applicable SCAQMD Rules and regulations, and the
Project would be constructed in conformance with the
incumbent Title 24 regulations that include best
management practices intended to reduce air quality
emissions.

Policy OS-7.2: Public Transportation Pursue expansion of the public transportation system, as well as bicycle and pedestrian trails, that are linked to the regional transit network, to reduce vehicle trips.

Consistent. Public transit is not currently available in the Project area, and the expansion of public transit service in the local area is beyond the scope of the Project evaluated herein. However, proposed trails and trail head
improvements within the Project site would provide
connectivity for hikers and bicyclists to the public park amenities and would allow connections to existing trails.

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Goal/Policy Project Consistency
This connectivity to the existing trails would allow public access to City owned properties and trails and connectivity from Foothill Parkway to the Skyline Ridge Trail.

Policy OS-7.3: Alternative Vehicles Promote the use of fuelefficient and low-emissions vehicles, including neighborhood electric vehicles (NEVs).

Consistent. Policy OS-7.3 provides direction to City staff and decision makers to promote the use of fuel-efficient and low-emissions vehicles, including NEVs, and is not
applicable to the proposed Project. Notwithstanding, the Project would be subject to the incumbent Title 24
regulations. Under the current version of the 2022
California Green Building Standards Code, Title 24, Part 11 (CALGreen), all dwelling units are required to be provided with a complete Electric Vehicle (EV) charging circuit and receptacle. The circuit must be 208/240 volt, 40 amp rated, with an EV charging receptacle and ready to charge EVs.

Mandatory compliance with applicable CALGreen
requirements would serve to promote the use of fuelefficient and low-emissions vehicles, including NEVs.

Policy OS-7.4: Municipal Fleet Manage the municipal fleet to achieve the highest possible number of fuel-efficient and low emissions vehicles commercially available.

Not Applicable. Policy OS-7.3 provides direction to City staff and decision makers related to management of the
municipal fleet, and is not applicable to the proposed
Project.

Policy OS-7.5: Trip Reduction Encourage a mix of housing types that are affordable to all segments of the population and are near job opportunities to further reduce vehicle trips.

Consistent. In conformance with this policy, the Project accommodates a mix of three different housing types,
including 92 single family detached housing units (on 7,200 square foot lots), three custom single-family lots, 104 8- cluster single family detached housing units, and 77 4- cluster single family detached housing units. The clustered dwelling units are intended to be more affordable than
typical single-family uses. In addition, the Project site is located in close proximity to employment opportunities, including a concentration of employment-generating uses located along the northern side of State Route 91 (SR 91), or approximately 2.0 miles north of the Project site, with a variety of other employment opportunities available along the southern side of SR 91.

Policy OS-7.6: Transportation Trip Management Encourage employers to implement transportation demand
management (TDM) measures to reduce trips and vehicle
miles traveled.

Not Applicable. Policy OS-7.6 applies to employmentgenerating land uses, and the proposed Project does not include any such uses. Thus, Policy OS-7.6 is not applicable to the proposed Project.

Policy OS-7.7: Clean Technologies Encourage businesses to use clean, innovative technologies and promote the use of alternative clean-fueled vehicles, new transportation
technologies, and other alternatives to the combustion
engine for City vehicles and individual use.

Not Applicable. Policy OS-7.7 applies to businesses and City-owned vehicles. The proposed Project does not
include any commercial or industrial uses, and the Project would not include any City vehicles. Thus, Policy OS-7.7 is not applicable to the proposed Project.

Policy OS-7.8: Green Building Techniques Encourage green building techniques that improve indoor air quality, energy efficiency and conservation in buildings, and utilization of Consistent. The proposed Project would be constructed in accordance with the incumbent Title 24 regulations, which include a number of provisions, including requirements

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Goal/Policy Project Consistency
renewable energy sources. related to EV charging equipment, that would serve to improve indoor air quality, energy efficiency, and
conservation in the Project’s proposed residential
buildings.

Policy OS-7.9: Stationary Source Pollution Continue to
minimize stationary source pollution through the
following:
• Ensure that industrial and commercial land uses are
meeting existing South Coast Air Quality Management
air thresholds by adhering to established rules and
regulations.
• Encourage the use of new technology to neutralize
harmful criteria pollutants from stationary sources.
• Reduce exposure of the City’s sensitive receptor s to poor air quality nodes through smart land use
decisions.

Not Applicable. The proposed Project consists of a
proposed residential subdivision and would not include
any stationary pollution sources, nor would the Project include any commercial or industrial land uses. Thus,
Policy OS-7.9 is not applicable to the proposed Project.

Policy OS-7.10: Sensitive Receptors Locate sensitive
receptors (i.e., residences, playgrounds, childcare centers, athletic facilities, churches, long-term health care facilities, rehabilitation centers, convalescent centers, and
retirement homes) away from significant pollution sources to the maximum extent feasible.

Consistent. As evaluated herein under Air Quality
Threshold d), the proposed Project would not expose any nearby sensitive receptors to substantial pollutant
concentrations. In addition, the land uses surrounding the Project site are not associated with substantial pollution sources.

Policy OS-7.11: Fugitive Dust Reduce the amount of
fugitive dust released into the atmosphere by construction and demolition, materials handling, paved roads, unpaved roads, and stock piles through development standards and compliance with CEQA regulations.

Consistent. The proposed Project would be required to
comply with SCAQMD Rule 403 for fugitive dust, which
would minimize the amount of fugitive dust that would be generated during the Project’s construction phase.

Policy OS-7.12: Best Management Practices Ensure all
applicable best management practices are used in
accordance with South Coast Air Quality Management
District (SCAQMD) to reduce emitting criteria pollutants during construction.

Consistent. The proposed Project would be subject to
compliance with all applicable SCAQMD best management
practices, rules and regulations, which would serve to
reduce the Project’s level of criteria pollutants during construction. In addition, and as demonstrated herein
under the analysis of Air Quality Thresholds b), c), and d) the Project’s construction-related emissions would be
below the SCAQMD’s Regional thresholds of significance
and also would be below the SCAQMD’s LSTs.

Policy OS-7.13: Partnerships Continue to work with the
WRCOG Regional Air Quality Task Force to implement
regional and local programs designed to meet federal,
state, and regional air quality planning requirements.

Not Applicable. Policy OS-7.13 provides direction to City staff and decision makers to coordinate with other
agencies to implement regional and local programs
designed to meet federal, state, and regional air quality planning requirements, and is not applicable to the
proposed Project.

Policy OS-7.14: Public Education Protect the air from
contamination by working with South Coast Air Quality
Management District and other interested organizations to elevate public awareness regarding air pollution sources and pollutant reduction initiatives.

Not Applicable. Policy OS-7.14 provides direction to City staff and decision makers to work with SCAQMD and other organizations to elevate public awareness regarding air pollution sources and pollutant reduction initiatives, and is not applicable to the proposed Project.

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Goal/Policy Project Consistency
Policy OS-7.15: State Updates Consult and coordinate with State resource and emergency management agencies
regarding updates to climate change science and
development of adaption priorities.

Not Applicable. Policy OS-7.15 provides direction to City staff and decision makers to consult and coordinate with State resource and emergency management agencies
regarding updates to climate change science and
development of adaption priorities, and is not applicable to the proposed Project.

2.4 Biological Resources
New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce Significant
Impact
No Substantial
Change from
Previous
Analysis
Would the Project:
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
b. Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
c. Have a substantial adverse effect on federally
protected wetlands as defined by Section 404 of
the Clean Water Act (including, but not limited to,
marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other
means?
☐ ☐ ☐ ☒
d. Interfere substantially with the movement of any
native resident or migratory fish or wildlife species
or with established native resident or migratory
wildlife corridors, or impede the use of native
wildlife nursery sites?
☐ ☐ ☐ ☒
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☐ ☒
f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community ☐ ☐ ☐ ☒

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New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially
Reduce Significant
Impact
No Substantial
Change from
Previous
Analysis
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?

ENVIRONMENTAL ANALYSIS
In order to evaluate the proposed Project’s potential impacts to biological resources, two Project-specific technical studies have been prepared by L&L Environmental, Inc. (herein, “L&L”). The first report provides a general biological resources assessment, is titled, “An Updated Biological Resources Assessment and Crotch Bumble Bee Survey for TTM 36544; Skyline Heights Project, City of Corona, Riverside County, California” (herein, “BRA”), dated November 2024, and included as Technical Appendix D1 (L&L, 2024). The second report addresses the Project’s potential impacts to riparian/riverine resources and the burrowing owl as required by the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), is entitled, “Revised Determination of Biologically Equivalent or Superior Preservation Report for TTM 36544, Skyline Heights Project, City of Corona, Riverside County, California” (herein, “DBESP”), is dated January 2025, and is included as Technical Appendix D2 (L&L, 2025). a) Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The draft SHP EIR was recirculated in order to address public comments related to impacts to biological resources. The Recirculated SHP EIR (herein, “REIR”) found that five (5) sensitive plant species were observed on the SHP site during the focused plant surveys, including intermediate mariposa lily (IML), paniculate tarplant, chaparral nolina, Fish’s milkwort, and Coulter’s matilija poppy (CMP). Mitigation Measures BIO-MM2, BIO-MM3, and BIO-MM4 were identified in the REIR to ensure that impacts to these species were reduced to a less than significant level.

Three (3) other sensitive plant species were determined by the to have a moderate or high potential of occurrence on the SHP site based on the presence of suitable or potentially suitable habitat, including western spleenwort, Payson’s jewel-flower, and intermediate Mo Nardella. The REIR noted that no occurrences of these three sensitive plant species previously were documented within the SHP site, nor were they observed during focused surveys.

However, the REIR found that their potential presence is not completely eliminated because the species may occur in the chaparral understory. The REIR also disclosed that focused surveys conducted for burrowing owl (BUOW), least Bell’s vireo (LBV), and California gnatcatcher (CAGN) were negative. The REIR imposed Mitigation measures BIO-MM11 and BIO-MM12 to ensure no future impacts would occur to migratory and nesting birds or BUOW, respectively, prior to construction. With the implementation of the proposed mitigation measures, which the REIR found would provide protection to the special-status species if they are found on the SHP site, the REIR concluded that impacts would be reduced to a less than significant level. Mitigation measures also were identified in the REIR to address indirect impacts. (Corona, 2016, pp. 4.C-42 through 4.C-50)

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EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The following discussion examines the potential impacts to sensitive plants and wildlife that would occur as a result of the proposed Project.

Special-Status Plant Species
Impacts to Observed Plant Species
A total of 278 botanical species were observed on or adjacent to the Project site and off-site improvement areas (herein, “Survey Areas”) during all the biological surveys, including the 2013, 2016, 2017, and 2024 focused botanical surveys. Portions of the site are undisturbed and support native habitats. A list of all observed botanical species is included in Table 12 within Appendix A to the Project’s BRA (Technical Appendix D1). (L&L, 2024, p. 45) Botanical species State and/or federally listed as threatened, endangered, proposed, or candidate species for listing as endangered or threatened were evaluated as part of the Project’s BRA. A description of these species and their potential for occurrence is summarized in Table 14 within Appendix A to the Project’s BRA (Technical Appendix D1). These species were either documented by the California Natural Diversity Database (CNDDB) or California Native Plant Society (CNPS) as occurring within the same quadrangle as the survey area or adjacent quadrangles, addressed in previous reports, or were identified by the United States Fish and Wildlife Service (USFWS), U.S. Forest Service (USFS), or other agency as potentially occurring in the area. (L&L, 2024, p. 47) The Survey Area was evaluated for potential presence or absence of suitable habitat to support State- and/or federally-listed plant species. Braunton’s milk-vetch, Munz’s onion, San Diego ambrosia, slender-horned spineflower, Santa Ana River woollystar, and thread-leaved brodiaea were determined to have potentially suitable habitat in the Survey Area. These species were not observed during surveys in 2013, 2016, 2017 or 2024 and have low probability of occurrence in the survey area. As such, no impacts to federal or State-listed plants are anticipated and no mitigation is required. (L&L, 2024, p. 99) Six (6) special-status species, intermediate mariposa lily (IML), paniculate tarplant, chaparral nolina, Fish’s milkwort, Coulter’s matilija poppy (CMP), and Brewer’s calandrinia, were observed in the Survey Area during L&L’s focused surveys. Three (3) other special status-species have suitable or potentially suitable habitat in the Survey Area and the species were determined to have moderate or high potential of occurrence: western spleenwort, intermediate monardella, and San Diego County viguiera. No occurrences of these additional plants previously were documented within the Survey Area, nor were they observed during the current surveys, but the species may occur in inaccessible areas. (L&L, 2024, p. 99)
The California Rare Plant Rank (CRPR) was used to evaluate the significance of impacts for special-status plants.

The CNPS, in coordination with the California Department of Fish and Wildlife (CDFW), has cataloged California's rare and endangered plants into lists according to population distributions and viability. These lists are numbered and indicate the following CRPRs: (1A) presumed extinct in California; (1B) rare, threatened, or endangered throughout their range; (2A) presumed extirpated in California, but more common in other states; (2B) threatened or endangered in California, but more common in other states; (3) more information is needed to establish rarity; and (4) plants of limited distribution in California (i.e., naturally rare in the wild), but whose populations do not appear to be susceptible to threat. A CRPR may also have an extension (e.g., 1B.x) that indicates current level of threat: seriously threatened (x.1), moderately threatened (x.2), or not very threatened (x.3). (L&L, 2024, p. 99)

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The design of the proposed Project would impact 18 of the 30 (60 percent) observed Fish’s milkwort, all 342 (100 percent) paniculate tarplant, the one (100 percent) Brewer’s calandrinia, 463 of the 676 (71 percent) observed intermediate mariposa lily (IML), 316 of the 716 (44 percent) Coulter’s matilija poppy (CMP), and ±2,180 of the estimated 5,343 (41 percent) chaparral nolina based on the number of individuals recorded on site (refer to Table 16 in Appendix A to the Project’s BRA, included as Technical Appendix D1). (L&L, 2024, p. 100) IML, Fish’s milkwort, and CMP are covered species under the MSHCP and adequately conserved under the Plan.

The MSHCP does not require surveys or mitigation for these species. Accordingly, Project-related impacts to IML, Fish’s milkwort, and CMP are a covered impact under the MSHCP, and impacts to these species would be less than significant with mandatory compliance with the MSHCP and payment of the MSHCP Mitigation Fee as required pursuant to Corona Municipal Code (CMC) Section 16.33.070. (L&L, 2024, p. 100) Brewer’s calandrinia has a CRPR rank of 4.2 and is not a covered species under the MSHCP. This species has a wide range in California from Sacramento south, largely near the coast, continuing all the way to Mexico. Calflora identifies 47 records within the Santa Ana Mountains, and all but one are located within Public/Quasi-Public (PQP) conserved lands. Impacts to a single Brewer’s calandrinia represents an adverse but less-than-significant impact requiring no mitigation. (L&L, 2024, p. 100)
Paniculate tarplant has a CRPR rank of 4.2 and is not a covered species under the MSHCP. This species has a wide range in southern California from San Luis Obispo south through Orange and Riverside County and continuing into San Diego County. Calflora identifies over 317 records within western Riverside County. Numerous populations are located within PQP and Western Riverside County Regional Conservation Authority (RCA) conserved lands. Projectrelated impacts would not substantially affect regional populations of paniculate tarplant. Additionally, although this species is not covered under the MSHCP, the conservation lands that comprise the MSHCP reserve assembly include habitat suitable to support this species. Therefore, any potential impact would be addressed through Project consistency with the MSHCP, as suitable habitat for these species has been conserved on a regional level.

Based on the wide distribution, number of locations within western Riverside County, and known locations of this species within MSHCP conservation areas, impacts to paniculate tarplant would be adverse but less than significant and no additional mitigation is required. (L&L, 2024, pp. 100-101) Chaparral nolina has a CRPR rank of 1B.2 (plants rare, threatened, or endangered in California and elsewhere, moderately threatened in California) and is not covered under the MSHCP. Chaparral nolina is recorded over a wide area in the coastal mountains from Ventura County south through San Diego County. The majority of populations are recorded in the Cleveland National Forest and/or on the western slopes of the Santa Ana Mountains. Often these populations include numerous individuals. Half of the CNDDB records document populations over 50 individuals or identify the population as common or abundant. Thirteen (13) populations are between 100 and 900 plants, six (6) populations are over 1000 plants, and one (1) is recorded as over 10,000. The Santa Ana Mountains appear to support the largest population of chaparral nolina and, according to the CNPS, the principal populations of this species are found in the northern Santa Ana Mountains. Chaparral nolina is, however, represented by few occurrences within Riverside County, having only two (2) recorded populations in the CNDDB.

The population within the survey area is estimated at ±5,343 plants. Impacts to chaparral nolina are estimated based on acres impacted for the three (3) largest populations. The chaparral nolina population south of the 10- acre USFS Parcel (NAP) is not proposed for impact. Due to the rarity of this species in Riverside County, impacts

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would be considered significant and mitigation measures are proposed to avoid and minimize impacts to chaparral nolina. (L&L, 2024, p. 101)
REIR Mitigation Measure BIO-2 (as modified/supplemented herein) requires preparation of a Chaparral Nolina Planting Plan and collection of nolina seed from the Project site with propagation to an onsite or offsite preserved property. SHP EIR Mitigation Measure BIO-3 requires the conservation in perpetuity of an area that supports approximately ±1,396 chaparral nolina. SHP EIR Mitigation Measure BIO-4 requires the preservation of an area that supports ±1,767 chaparral nolina and further requires that this area be deed restricted so as to prevent future development or disturbance. In total, an estimated 3,163 chaparral nolina would be conserved, preserving the largest recorded population in Riverside County. Implementation of the required mitigation would reduce Project impacts to chaparral nolina to less-than-significant levels. (L&L, 2024, p. 101) Impacts to Plant Species Not Observed but with the Potential to Occur Special status plants western spleenwort, intermediate monardella, and San Diego County viguiera have not been observed during surveys but have a moderate potential to occur in the survey area. If present, these species may be impacted by the proposed Project. (L&L, 2024, p. 101) Western spleenwort is distributed over the foothills and mountains of southern California in Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura Counties into Baja California, Mexico. Calflora records 21 locations within the Cleveland National Forest. There are also several locations within western Riverside County, Santa Ana Mountains, and MSHCP identified PQP lands. Although this species is not covered under the MSHCP, the conservation lands that comprise the MSHCP reserve assembly include habitat suitable to support this species.

Therefore, any potential impact would be addressed through consistency with the MSHCP, as suitable habitat for this species has been conserved on a regional level. If western spleenwort is present, impacts would be adverse but not significant and no additional mitigation is required. (L&L, 2024, p. 102) Intermediate monardella is restricted to the Santa Ana and Palomar Mountains. It is recorded in 38 locations spread throughout the Santa Ana Mountains and into the adjacent foothills in Orange, Riverside, and San Diego Counties. There are also a few records from the northwestern foothills of the Palomar Mountains. Nineteen (19) of the 38 records are located within the Cleveland National Forest, three (3) are within parks or preserves, and two (2) are on tribal lands. Although this species is not covered under the MSHCP, the conservation lands that comprise the MSHCP reserve assembly include habitat suitable to support this species. Therefore, any potential impact would be addressed through consistency with the MSHCP, as suitable habitat for this species has been conserved on a regional level. If intermediate monardella is present, impacts would be adverse but not significant and no additional mitigation is required. (L&L, 2024, p. 102)
San Diego County viguiera is identified as locally common in southern San Diego County but shows limited records north of San Diego County. Calflora shows only two recorded observations in the Santa Ana Mountains north of Ortega Highway, with one located in the Cleveland National Forest (CNF). The closest record is approximately 7.2 miles southwest, in Santiago Canyon. The CNPS indicates that all occurrences outside of San Diego County are introduced. If this species is present on the site, individuals may be impacted but the natural distribution of the species would not be affected. Impacts would be less than significant, and no additional mitigation is required. (L&L, 2024, p. 102)

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Indirect Impacts to Sensitive Plant Species
Indirect impacts to special status botanical species in the immediate Project vicinity would result from long-term “edge effects.” A potential increase in non-native species over time, which could impact native plant species, could occur along the Project margins where newly exposed soils, not developed or landscaped, could provide fertile ground. Invasive species occur within the impact area and could, therefore, disperse seed to newly turned soil.

Invasive and noxious weed species seed could be spread or introduced into the area by vehicles or machinery. SHP EIR Mitigation Measure BIO-MM5 requires the preparation of landscape plans that exclude the use of certain plant species in site landscaping, including White Cloud matilija poppy, and further requires the recordation of CC&Rs prohibiting the planting of invasive plant species. SHP EIR Mitigation Measure BIO-MM15, which has been modified as part of this Addendum No. 1 to the SHP EIR, required the preparation and distribution to new home owners an education package informing future residents regarding prohibited plant species. SHP EIR Mitigation Measures BIO-MM16 and BIO-MM17 address potential construction-related impacts due to invasive species that may occur as a result of heavy construction equipment or due to the proximity of proposed construction staging areas. (L&L, 2024, pp. 98-99)
Human and pet encroachment into surrounding habitat areas supporting sensitive plant species may increase over time due to its proximity to increased occupied residential units and recreational use of the natural environment, including Off-Road Vehicle (ORV) and pedestrian uses. Encroachment would be reduced by the incorporation of barriers between avoided areas and development in the Project design, signage requesting that people remain on the existing trails, and Homeowner education materials. SHP Mitigation Measure BIO-MM20, which has been modified as part of this Addendum No. 1 to the SHP EIR, requires the incorporation of measures that address the MSHCP Urban/Wildlands Interface Guidelines (UWIG) requirements. Compliance with SHP EIR Mitigation Measure BIO-20 (as modified herein) would ensure that indirect impacts affecting the conservation areas are reduced to less-than-significant levels. (L&L, 2024, p. 99) Changes that would occur within impacted areas of the unnamed blueline stream located in the middle of the Survey Area (and identified herein as “Feature 3”) could cause downstream impacts and would require special design features to reduce changes to the flood regime. Post-development changes to flooding and water flow through the drainage and its alluvial terraces could negatively impact downstream habitat and individual species, such as Coulter’s matilija poppy. Design features would be required to ensure post-development flow volume and energy levels are consistent with pre-Project levels to prevent impacts to avoided resources. In addition, cultivated and hybrid breeds of matilija poppy can change the wild populations of Coulter’s matilija poppy with an influx of the gene material from these cultivars. Implementation of SHP EIR Mitigation Measures BIO-MM5 and BIO-MM15 and new Mitigation Measure BIO-MM20 would reduce the Project’s potential indirect impacts to Coulter’s matilija poppy to below a level of significance. Implementation of SHP EIR Mitigation Measure BIO-MM5 (as modified herein) would ensure that the Project’s landscape plans do not include any common cultivar forms of Coulter’s matilija in the plant palette, and further would ensure that the landscaping plant palette excludes those plant species identified by MSHCP Table 6-2, Plants that Should be Avoided Adjacent to the MSHCP Conservation Area.

SHP EIR Mitigation Measure BIO-MM15 (as modified herein) requires the Project Applicant to prepare and provide to future homeowners an education package informing future tenants/homeowners of the list of prohibited plant species identified by Mitigation Measure BIO-MM5. Implementation of New Mitigation Measure BIO-MM20 would ensure that the Project’s Codes, Covenants, and Restrictions (CC&Rs) include a provision prohibiting the

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planting of any of the plant species identified by Mitigation Measure BIO-5, which would help ensure that such plant species are not planted by future homeowners/tenants. Implementation of the required mitigation would reduce the Project’s indirect impacts to sensitive plant species to below a level of significance. (L&L, 2024, pp. 102- 103)
Special-Status Wildlife Species
Direct Impacts to Special-Status Wildlife Species
Mountain lion and Crotch’s bumble bee, both candidates for State listing, were observed in the Survey Area. No other listed wildlife was detected in the Survey Area. Three (3) listed or fully protected wildlife species (golden eagle, Coastal California Gnatcatcher [CAGN], and Quino Checkerspot Butterfly [QCB]) have been determined to have a high or moderate potential for occurrence in the Survey Area. Focused coastal California gnatcatcher surveys conducted in 2013 were negative. (L&L, 2024, p. 103) Habitat potentially suitable to support Stephen’s kangaroo rat (SKR) is present in the Survey Area. The Project site is not within the boundaries of the Stephens’ Kangaroo Rat Habitat Conservation Plan (SKR HCP). The MSHCP covers impacts to Stephens’ kangaroo rat because the Project site is located within the MSHCP boundaries but is located outside of the boundaries of the SKR HCP. Stephens’ kangaroo rat is a covered species under the MSHCP and adequately conserved under the Plan. Project-related impacts (if any) to Stephens’ kangaroo rat would be a covered impact under the MSHCP and would therefore be less than significant, with no mitigation required. (L&L, 2024, p. 103)
Ten (10) special-status wildlife species were observed or detected during biological surveys: coastal whiptail, orange-throated whiptail, red-diamond rattlesnake, Cooper’s hawk, southern California rufous-crowned sparrow, Vaux’s swift, black-chinned sparrow, California horned lark, Lawrence’s goldfinch, and San Diego black-tailed jackrabbit. (L&L, 2024, p. 103)
Thirteen (13) other special-status wildlife species were not observed during surveys but have a high or moderate potential for occurrence in the survey area: American bumble bee, southern California legless lizard, California glossy snake, San Bernardino ringneck snake, California mountain kingsnake, coast horned lizard, coast patchnosed snake, Bell’s sage sparrow, oak titmouse, pallid bat, Dulzura pocket mouse, hoary bat, and San Diego desert woodrat. (L&L, 2024, p. 103)
Two (2) USFS Management Indicator Species (mountain lion and song sparrow) were observed and one (1) was determined to have a high potential to occur (mule deer). (L&L, 2024, p. 103) Crotch’s bumble bee was observed during focused surveys in 2024 and could be impacted by loss of individuals or colonies. At the time The SHP EIR was certified in 2017, the Crotch’s bumble bee was not listed as endangered or threatened; however, the Crotch’s bumble bee has since been listed as a candidate for State listing as an endangered species. The Crotch's bumble bee is not a covered species under the MSHCP. In the event the Crotch bumble bee is listed as endangered or threatened by the CDFW, Project impacts to this species would be potentially significant. New Mitigation Measure BIO-MM21 has been imposed on the Project and would apply in the event that the Crotch’s bumble bee ultimately is listed as endangered or threatened. The mitigation prohibits clearing/ground disturbing activities from February 1 through September 30 within suitable habitat. For

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construction between October 1 and January 31, Mitigation Measure BIO-MM21 requires a pre-construction survey within suitable habitat to confirm that no nests occur on site. Should any nests be identified, the mitigation requires the Project biologist to consult with CDFW to determine if a permit is required. In addition, Best Management Practices (BMP) measures during construction would be employed to prohibit the use of pesticides considered to be harmful to the Crotch bumble bee. SHP EIR Mitigation Measure BIO-MM4 also requires the conservation of the unimpacted portions of the Survey Area to preclude potential impacts to Crotch bumble bee habitat within the planned open space area on site. Impacts to Crotch bumble bee would be less than significant with implementation of proposed mitigation. (L&L, 2024, p. 104) Mountain lion was detected on the Project site during surveys. Mountain lion is a covered species under the MSHCP and adequately conserved under the Plan. The MSHCP does not require surveys or mitigation for this species. Implementation of SHP EIR Mitigation Measure BIO-13 (as modified herein) would further ensure that human-lion interactions are minimized and avoided. Regardless, any Project-related impacts to mountain lion are a covered impact under the MSHCP; thus, impacts to the mountain lion would be less than significant and no additional mitigation is required. (L&L, 2024, p. 104)
CAGN, QCB, and golden eagle were not observed during surveys but have high or moderate potential for occurrence within the Survey Area. These species are covered under the MSHCP and adequately conserved under the Plan. The MSHCP does not require surveys or mitigation for these species (since the Project site is not within Criteria Cells, restrictions on vegetation clearing during the CAGN nesting season do not apply). Project-related impacts to these species, if any, are a covered impact under the MSHCP and therefore Project impacts to these species would be less than significant. (L&L, 2024, p. 104) Of the remaining special-status species that occur or potentially occur in the Survey Area, the following are covered under the MSHCP and adequately conserved under the Plan: orange throated whiptail, coastal whiptail, reddiamond rattlesnake, coast horned lizard, California horned lark, Cooper’s hawk, southern California rufouscrowned sparrow, Bell’s sage sparrow, San Diego desert woodrat, and San Diego black-tailed jackrabbit. The MSHCP does not require surveys or mitigation for these species. Project-related impacts to these species are a covered impact under the MSHCP and thus would be less than significant. (L&L, 2024, p. 104) Although Project impacts to CAGN, QCB, golden eagle, orange throated whiptail, coastal whiptail, California horned lark, Cooper’s hawk, southern California rufous-crowned sparrow, and Bell’s sage sparrow would be less than significant because these species are considered adequately conserved under the MSHCP, the MSHCP does not provide take authorization for nesting birds. The Project has the potential to result in impacts to these species if construction activities were to occur during the critical nesting period (January 1 through September 1). SHP EIR Mitigation Measure BIO-MM11 (as supplemented/modified herein) would apply, which requires pre-construction surveys and avoidance of any active nests during the breeding season. Implementation of the revised SHP EIR Mitigation Measure BIO-MM11 would reduce the Project’s potential impacts to nesting birds, including nesting CAGN, QCB, golden eagle, orange throated whiptail, coastal whiptail, California horned lark, Cooper’s hawk, southern California rufous-crowned sparrow, and Bell’s sage sparrow individuals, to below a level of significance.

In addition, the Project site is located in the MSHCP required survey area for the Burrowing Owl (BUOW). No BUOW or BUOW sign was observed in the survey area during the 2013 focused survey nor any of the other subsequent biological field surveys. Supplemental habitat assessments and burrow surveys were performed in 2016 and 2024.

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No BUOW, BUOW sign or suitable burrows were observed in the Survey Area. This species is migratory and has potential to relocate to the Project site. Potentially suitable habitat for BUOW is present on the site and the MSHCP requires a protocol survey for all projects located within the MSHCP Burrowing Owl Survey Area. However, the Project would be subject to compliance with SHP EIR Mitigation Measure BIO-12 (as revised/supplemented herein), which requires a 30-day preconstruction survey for BUOW to be conducted to prevent impacts to the species and details actions to be taken if BUOW are observed. Impacts would be less than significant with implementation of the required mitigation. (L&L, 2024, p. 105) The remaining species with a potential to occur on site are not covered under the MSHCP. This includes American bumble bee, southern California legless lizard, California glossy snake, San Bernardino ringneck snake, coast patchnosed snake, oak titmouse, Vaux’s swift, Lawrence’s goldfinch, black-chinned sparrow, pallid bat, Dulzura pocket mouse, and hoary bat. The California mountain kingsnake is covered under the MSHCP but is not adequately conserved. In evaluating the rarity of these species, the CNDDB ranks species from S1 to S5 and 0.1-0.3 with the rarest as S1.1 and most common as S5. The definitions of these rankings identify S4 and S5 as secure in California and S3 as vulnerable, but not currently rare. Species ranked S4 and S5 typically exhibit relatively widespread distribution and species ranked S3 have not reached a level of threat and numbers or populations have not declined to a point that would cause them to be considered “rare”. S3 species are either uncommon or require more data to monitor their status. These species utilize a wide variety of habitats with specialized, but generally available, microhabitats (moisture, loose soil nectar plants). The wide range and diversity of habitats utilized indicates the development of the proposed Project would not substantially decrease available habitat or reduce regional populations for these species. Large tracts of suitable habitat would remain adjacent to and in the Project vicinity, including ±97.6 acres of avoided habitats. Although these species are not covered under the MSHCP, the conservation lands that comprise the MSHCP reserve assembly include habitat suitable to support these species.

Therefore, any potential impact would be addressed through consistency with the MSHCP, as suitable habitat for these species has been conserved on a regional level. Project-related impacts to these species are not expected to appreciably affect overall population or range. Impacts would be considered adverse, but not significant and no additional mitigation is required. (L&L, 2024, p. 105)
Loss of foraging habitat for wildlife species would add to cumulative regional loss of habitat for these species. This is considered an adverse, but less-than-significant impact because of extensive foraging habitat available in the Project vicinity. (L&L, 2024, p. 106)
In addition to the mitigation measures described above, the Project also would be subject to several additional mitigation measures to further avoid and minimize potential impacts to special-status wildlife species that may be present. SHP EIR Mitigation Measure BIO-MM1 (which has been modified/supplemented as part of this Addendum No. 1 to the SHP EIR) includes measures to preclude potential encroachment into preserved areas on site during construction, including a requirement to delineate the conservation areas with flagging/fencing to prevent inadvertent impacts to these areas. The revised SHP EIR Mitigation Measure BIO-MM1 further requires biological monitoring during construction activities. SHP EIR Mitigation Measure BIO-MM3 obligates the Project Applicant to conserve a minimum 10-acre parcel composed of natural habitat adjacent to USFS land. SHP EIR Mitigation Measure BIO-MM4 (as modified herein) the permanent conservation of planned open space areas on site through deed restrictions or conservation easements, including areas containing Riparian/Riverine areas that have been avoided by the design of the proposed Project. Implementation of SHP EIR Mitigation Measures BIOMM1, BIO-MM3, and BIO-MM4 (as modified herein) would ensure that future landscaping on site does not result

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in the introduction of invasive species into the conserved habitat areas on site. In addition, SHP EIR Mitigation Measures BIO-MM1, BIO-MM4, BIO-MM16 through BIO-MM19 (as modified/supplemented herein) impose construction-related requirements to preclude indirect construction-related impacts to the on-site conservation areas. New Mitigation Measure BIO-22 requires the implementation of a Workers Environmental Awareness Program (WEAP) training, which would ensure that construction contractors and employees are fully educated regarding biological habitats and the need to avoid such areas. Implementation of the required mitigation would reduce indirect impacts to sensitive wildlife species to below a level of significance.

Indirect Impacts to Special-Status Wildlife Species
Habitat fragmentation would consist of the permanent loss of ±157.1 acres and temporary loss of 1.7 acres of habitats and isolation of habitats east of the Project from the larger Core B habitat area. The Project would incorporate barriers to prevent both common and special status wildlife species from entering the residential development, thereby decreasing the potential for impact by humans, vehicles, pets, or other urban hazards. The barriers also would prevent human and pet encroachment and reduce potential for direct impacts by those means.

These preventative measures, while incorporated for the safety of wildlife and adjacent habitat, also would restrict wildlife movement and add to habitat fragmentation. Movement restriction and habitat fragmentation can be especially important for large mammals, like the mountain lion population. The proposed Project would not remove movement corridors but would reduce the overall habitat and further constrict the available range habitat for this species. Impacts to mountain lions are addressed above. Management of “edge effects” pursuant to the MSHCP UWIG (as required by SHP EIR Mitigation Measure BIO-20, which has been modified herein) would reduce indirect impacts to all wildlife species, including mountain lions, and would ensure indirect impacts to this species remain below a level of significance. (L&L, 2024, p. 106) Amphibian, reptile, avian, mammal, and insect species may experience impacts from construction, including increases in noise, chemical emissions, and vibration, resulting in avoidance and abandonment of the area.

Movement of species could concentrate populations, increase competition for resources in adjacent habitats, and leave displaced individuals vulnerable to predation. Those species that may use the Project area for foraging still would have access to large expanses of relatively undisturbed habitat in the Project vicinity, including Cleveland National Forest lands to the west. In addition, the MSHCP considers development throughout western Riverside County and balances development with conservation of contiguous blocks of native habitats. The MSHCP determined the survey area is not a Conservation Area or Criteria Area. (L&L, 2024, p. 106) After completion of construction, noise levels adjacent to the site would be increased over current conditions but would not exceed residential noise standards. In addition, barriers are proposed between residential development and conservation areas, which would reduce the amount of noise, chemical emissions, and fugitive dust from the development crossing into or affecting wildlife in the conservation areas after completion of construction. As such, impacts would be less than significant. (L&L, 2024, p. 107) A potential increase in invasive species could occur along the perimeter of the impact area, where newly exposed soils could provide fertile ground. Invasive species that may occur along the current roadway and within the impact area could disperse seed to newly turned soil. SHP Mitigation Measures BIO-MM5 and BIO-MM15 through BIOMM17 would apply (as modified/supplemented herein), along with new Mitigation Measure BIO-MM22.

Mitigation Measure BIO-5 imposes requirements to ensure that invasive plant species are excluded from

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landscaped areas on site, while SHP EIR Mitigation Measures BIO-MM16 through BIO-MM19 impose requirements on heavy equipment, storage areas, refuse, and vehicle speeds to further prevent the potential for invasive plant species. Implementation of the SHP EIR mitigation measures (as modified/supplemented herein) would ensure that the Project’s indirect impacts to sensitive wildlife species would be less than significant. (L&L, 2024, p. 106) Conclusion
With implementation of the biological mitigation measures identified by the SHP EIR (as modified/supplemented herein), Project direct and indirect impacts to special-status plant and wildlife species would be reduced to lessthan-significant levels. It also bears noting that the Project would disturb essentially the same area as identified for disturbance by the SHP EIR, and in fact, result in less total disturbance in comparison to the Approved Project.

Thus, as a general matter, the SHP EIR already anticipated and analyzed all of the impacts to biological resources that would occur from the currently proposed Project. For all these reasons, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.
b) Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The REIR found that implementation of the SHP project would result in significant impacts to three riparian habitat alliances and a sensitive natural sage scrub community. However, the REIR found that implementation of mitigation measures BIO-MM6 through BIO-MM10 would reduce potentially significant impacts to a less-than-significant level. (Corona, 2016, pp. 4.C-50 through 4.C-55)
EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. Under existing conditions, three (3) general vegetation types currently exist in the immediate vicinity of the Survey Area: riparian/woodland, upland, and unvegetated/altered. These vegetation types include multiple plant communities that make up the landscape of the survey area (as summarized in Table 5 and depicted on Figures 6, 6a, and 6b of the Project’s BRA, included as Technical Appendix D1). Non-native ornamental species (eucalyptus and pepper trees) are located adjacent to urban areas. The majority of the Survey Area is undisturbed and consists of a variety of chaparral habitats on the north-facing slopes and coastal sage scrub habitats on the dry south facing slopes. Needle grass grasslands are present in previously cleared areas on the ridgelines. Grasslands occur throughout the survey area and primarily are composed of non-native species including bromes (Bromus species), short-pod mustard (Hirschfeldia incana), filaree (Erodium species), and Russian thistle (Salsola tragus), and native species such as doveweed (Croton setigerus) and deerweed (Acmispon glaber). There is a concentration south of the offsite flood control basin at the eastern end of Mabey Canyon Wash. (L&L, 2024, p. 27)
Of the vegetation communities found in the Survey Area, eight (8) are considered sensitive: foothill needle grass grassland, purple needle grass grassland, scale broom scrub (SBS), California sycamore woodlands, California brittle bush scrub, bush penstemon scrub, Eastwood manzanita chaparral, and toyon chaparral (L&L, 2024, p. 44).

In addition, L&L found six (6) main jurisdictional ephemeral drainage features with 56 tributaries, for a total of 62 drainage features. Vegetation in and adjacent to jurisdictional features includes coastal live oak woodland,

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sycamore woodland, mulefat scrub, SBS, as well as upland and disturbed habitats. Riparian/riverine corridors in the form of sycamore woodland, mulefat, SBS are located within Drainage Features 1, 3, and 6. Riparian and woodland habitats, including California sycamore (Platanus racemosa) woodland and mulefat (Baccharis salicifolia) scrub, are located in and adjacent to Drainage Feature 3 and Mabey Canyon Wash (Drainage Feature 6), as is SBS. Coast live oak woodland is present in the three main drainage features, Drainage Feature 1, Drainage Feature 3, and Mabey Canyon Wash (Drainage Feature 6). (L&L, 2024, p. 81) The Survey Area has been impacted by off-road vehicles, bicycles, and hikers in the more accessible areas. Dirt roads and trails crisscross the survey area, providing access for illegal trash disposal and off-road usage and grading of the Foothill Parkway Westerly Extension (FPWE). (L&L, 2024, p. 27) Consistent with the findings of the SHP EIR, implementation of the proposed Project would result in direct and indirect impacts to sensitive vegetation communities, including riparian/riverine habitats. Specifically, implementation of the proposed Project would result in the estimated direct permanent loss of approximately 151.8 acres onsite and ±5.3 offsite of native and non-native habitat, as shown on Figures 15 and 15a – c of the Project’s BRA (Technical Appendix D1) and depicted on Figure 9, Overview of Vegetation Community Impacts, and as summarized in Table 18, Project Impacts to Vegetation Communities. An additional ±1.7 acres offsite would be temporarily impacted within the proposed temporary haul road. The ±157.1 acres of permanently impacted habitat would add to the reduction in the availability of nesting, denning, and roosting sites and foraging habitats for species that utilize woodlands, shrublands, grasslands, riparian, and disturbed habitats. The ±1.7 acres offsite would be restored to jurisdictional drainage, but habitat currently is identified as disturbed. Approximately 97.6 acres of the Project site would be avoided and would remain and continue to provide habitat to local species that utilize the site. (L&L, 2024, p. 90)
Provided below is a discussion of the Project’s impacts to sensitive natural communities and riparian habitats and the mitigation measures identified to address such impacts.

Riparian/Riverine Impacts
The proposed Project would avoid ±7.74 acres (40 percent) of the ±19.30 acres of riparian/riverine habitat in the Survey Area including riparian/riverine habitats within the offsite impact areas. Included in the habitat impacts are permanent impacts to ±10.51 acres of MSHCP Riparian/Riverine area, including sycamore woodland (±0.11 acre), mulefat scrub (±0.09 acre), scale broom scrub (±3.61 acres); and impacts to upland habitats, including coast live oak woodland (±4.61 acres) and unvegetated or other upland habitats (±2.09 acres). Impacts would result from pad development, drainage improvements, and primary ingress/egress into the Project site. Additionally, ±1.13 acres of temporary impacts would occur due to the need to construct a temporary haul road between the two development areas and in one portion of the site where a detention basin would be located after development.

Avoidance of Feature 3, the largest drainage in the survey area, is not feasible because of the need for dual access points, earthwork balance, and the extensive cost of bridge development. (L&L, 2024, p. 97) Project impacts to ±4.61 acres of the ±8.57 acres of coast live oak woodland that are considered riparian/riverine habitat, as well as Project impacts to ±0.11-acre of sycamore woodland, ±0.09-acre of mulefat scrub, and ±3.61 acres of SBS represents a significant impact of the proposed Project. Although permanent impacts to ±10.51 acres

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Figure 9 Overview of Vegetation Community Impacts
(L&L, 2024, Figure 15)

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Table 18 Project Impacts to Vegetation Communities
Vegetation Community
2024
Survey Area
(acres)
Avoided
Onsite
(acres)
Project
Impacts
Onsite
(acres)
Impacts
Offsite
(acres)
Riparian/
Riverine
Impacts
(acres)
Coastal Sage Scrub

California Sagebrush Scrub 1.81 0 1.81 0.14
Ca. Sagebrush – Ca. Buckwheat
Scrub

8.81 2.22 6.59
California Buckwheat Scrub 9.25 3.13 6.12 0.01
Ca. Sagebrush – Black Sage Scrub 2.09 0.61 1.48 0.16
Black Sage Scrub 21.94 4.33 17.61 0.002
California Brittle Bush Scrub 0.09 0 0.09
Brittle Bush Scrub 2.04 0 2.04
Deerweed Scrub 0.30 0 0.30
Total CSS Alliances 46.33 10.29 36.04 0.31
Coastal Sage Scrub/Chaparral
Laurel Sumac Scrub 10.28 6.08 4.20 0.29
Bush Penstemon Scrub 41.61 18.38 23.23 0.02
Total CSS/Chaparral Alliances 51.89 24.46 27.43 0.31
Chaparral
Chamise Chaparral 21.66 13.96 7.70
Chamise-Buckwheat-Chaparral 11.05 3.45 7.60
Chamise-Black Sage Chaparral 21.06 5.72 15.34 0.03
Hoaryleaf Ceanothus Chaparral 32.38 13.91 18.47
Scrub Oak Chaparral 6.79 0.65 6.14 0.04
Scrub oak – Chamise Chaparral 13.74 5.27 8.47
Eastwood Manzanita Chaparral 3.34 2.39 0.95
Toyon Chaparral 0.31 0 0.31
Total Chaparral Alliances 110.33 45.35 64.98 0.07
Grasslands
Ca. Annual Grassland 0.43 0 0.43
Needle Grass Grassland 2.32 0.50 1.82
Total Grassland Alliances 2.75 0.5 2.25
Riparian/Riverine/Woodlands
Coast Live Oak Woodland 8.57* 0.84 7.73

0.01 4.61
Sycamore Woodland 0.27 0.16 0.11 0.11
Mulefat Scrub 0.27 0.18 0.09 0.09
Scale broom scrub 9.87 6.27 3.60 3.61
Total Riparian/Riverine/Woodlands Alliances 18.98 7.45 11.53 0.01 8.42 Developed/Disturbed/Ornamental

Eucalyptus Alliance 1.26 0.87 0.39
Pepper Alliance 1.03 0.87 0.16 6.31
Disturbed 16.83 7.81 9.02
Total Developed/Disturbed 19.12 9.55 9.57 6.31
GRAND TOTAL 249.4 97.6 151.8 7.0 8.42
*Only ±5.71 acres are within the drainage and therefore designated riverine. (L&L, 2024, Table 10)
and temporary impacts to ±1.13 acre of riparian/riverine habitat would represent a significant impact of the Project, SHP EIR Mitigation Measures BIO-MM6 and BIO-MM7 would apply, in addition to new Mitigation Measure BIO-MM23. Mitigation Measure BIO-MM6 requires the replacement of oak trees impacted by the Project at no less than a 2:1 ratio (mitigation:impact), to be planted in the undeveloped natural areas on site. SHP EIR Mitigation

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Measure BIO-MM7 (as modified/supplemented herein) requires mitigation for impacts to ±10.51 acres at a 2:1 ratio through offsite mitigation with the Riverside-Corona Resource Conservation District (RCRCD) or other suitable approved organization with available credits. Mitigation Measure BIO-MM23 is a new mitigation measure that is proposed to address impacts to riparian/riverine areas due to the construction of the temporary haul road, and requires the restoration of the temporary impact areas to their existing (former) condition. Implementation of the SHP EIR mitigation measures, in addition to new Mitigation Measure BIO-MM23, would reduce the Project’s impacts to riparian/riverine habitats to below a level of significance. (L&L, 2024, p. 97) Coast Live Oak Impacts
The Project would result in direct permanent impacts to ±7.73 acres of coast live oak woodlands. Of this, ±4.61 acres of coast live oak woodlands are located within riverine areas (and are discussed above under the analysis of Project impacts to riparian/riverine areas), while the remaining ±3.12 acres are located within upland areas and are not considered to comprise riparian/riverine habitat. Impacts to oaks are considered significant, but SHP EIR Mitigation Measure BIO-MM6 (as modified/ supplemented herein) requires the replacement of oak trees impacted by the Project at no less than a 2:1 ratio (mitigation:impact), to be planted in the undeveloped natural areas on site. Replacement values for the impacted oaks would be consistent with the City of Corona oak tree conservation policy, at a value of 2:1. The proposed Project also would provide for the conservation of ±0.84 acres of existing oak woodlands. Impacts to this community are considered less than significant with implementation of Mitigation Measure BIO-6 (as modified/supplemented herein). (L&L, 2024, p. 97) Scale Broom Scrub (SBS) Impacts
The Project would result in permanent impacts to ±3.61 acres of SBS. L&L mapped ±9.87 acres of SBS in the survey area, of which ±6.27 acres would not be impacted and would remain as open space that would be deed restricted from future development. CDFW ranks SBS as S3 (vulnerable) and it is considered sensitive. Impacts to SBS are considered significant, but SHP EIR Mitigation Measure BIO-MM4 (Designate Unimpacted Areas as Open Space), which has been modified herein, would conserve avoided habitat (including SBS) and prevent future impacts. SBS also would be mitigated for as riparian/riverine habitat (as discussed above). SHP EIR Mitigation Measure BIOMM7 (as modified/ supplemented herein) would reduce impacts to riparian/riverine habitat by replacing habitat at a value of 2:1. Impacts to SBS communities are adverse but would be considered a less than significant with implementation of the identified mitigation measures. (L&L, 2024, p. 97) Needle Grass Grassland Impacts
Needle grass grassland was observed in four (4) locations (generally within the center of the Survey Area) totaling ±2.32 acres, of which ±1.82 acres would be impacted by the Project. Needle grass grassland is a form of the valley and foothill grasslands identified in the MSHCP that are distributed over approximately 2,700 acres within the Plan Area on the Santa Rosa Plateau. MSHCP Core F consists of the Santa Rosa Plateau Ecological Reserve and Subunit 6: Santa Rosa Plateau and will add additional reserve lands adjacent to the Core. Therefore, conservation lands that comprise the MSHCP reserve assembly include this habitat. The Project’s impacts to this sensitive plant community would be addressed through consistency with the MSHCP and payment of the MSHCP Mitigation Fee as required pursuant to CMC Section 16.33.070. Impact to this community represents an adverse but less than significant impact, as Project impacts to this vegetation community would not regionally significant. Therefore, no additional mitigation is required. (L&L, 2024, p. 98)

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Coastal Sage Scrub Impacts
Included in the Project’s habitat impacts are permanent impacts to ±36.04 acres of coastal sage scrub onsite and ±0.31 acres offsite. Coastal sage scrub is identified in the MSHCP as being distributed over approximately 156,450 acres of the Plan Area . The conservation lands that comprise the MSHCP reserve assembly include this habitat; therefore, any potential impact would be addressed through compliance with the MSHCP and payment of the MSHCP Mitigation Fee as required pursuant to CMC Section 16.33.070, as this habitat has been conserved on a regional level. Impact to this vegetation communities represents an adverse but less-than-significant impact under the MSHCP. Therefore, no additional mitigation is required. (L&L, 2024, p. 98) Indirect Impacts to Sensitive Natural Communities
The Project has the potential to result in indirect impacts to sensitive natural communities due to construction activities, invasive non-native plant species, and due to human and domestic pet encroachment into the undisturbed habitats on site. These impacts are discussed below.

The use of heavy equipment, the exposure of soils, and access to/from the Project site on dirt roads during construction activities all would result in higher than usual fugitive dust and emission levels during Project clearing and grading activities, which can affect the health of local wildlife and plants. Dust particles settling directly on vegetation can affect vegetation by physical shading, thereby reducing photosynthesis, blocking leaf stomata, and/or uptake into leaf tissue. These impacts can most notably reduce vegetation growth rates. Long-term impacts are expected to be similar to what occurs under existing conditions. However, the Project would be subject to compliance with SHP EIR Mitigation Measure BIO-8 (as modified/supplemented herein), which requires the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) during construction activities, which would specify Best Management Practices (BMPs) to prevent discharges (e.g., siltation) from entering the jurisdictional areas on site (including riparian/riverine areas) and to reduce the amount of airborne dust. In addition, SHP EIR Mitigation Measure BIO-MM19 (as modified/ supplemented herein) requires limiting vehicle/truck speeds within the active construction site and on unpaved roads to 15 miles per hour or less, which further would reduce the potential for fugitive dust and erosion/sedimentation impacting the on-site jurisdictional areas and associated riparian/riverine habitats. With implementation of the required mitigation, Project indirect impacts due to fugitive dust and erosion/siltation affecting sensitive riparian/riverine habitats on site would be reduced to less-than-significant levels. (L&L, 2024, p. 98) A potential increase in non-native species over time, which could impact native plant species, could occur along the Project margins where newly exposed soils, not developed or landscaped, could provide fertile ground.

Invasive species to occur within the impact area and could, therefore, disperse seed to newly turned soil. Invasive and noxious weed species seed could be spread or introduced into the area by vehicles or machinery. This represents a significant indirect impact of the proposed Project. The proposed Project would be subject to compliance with SHP EIR Mitigation Measures BIO-MM5 and BIO-MM15 through BIO-MM17 (as modified/supplemented herein). In addition, in order to further preclude the potential for invasive species impacts, the Project also would be subject to compliance with new Mitigation Measure BIO-MM24. SHP EIR Mitigation Measure BIO-MM5 (as modified/supplemented here) requires the preparation and implementation of a landscape plan for the site that explicitly excludes more common cultivar forms of Coulter’s matilija poppy, including the White Cloud matilija poppy, and that excludes the species identified in MSHCP Table 6-2, Plants that

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Should be Avoided Adjacent to the MSHCP Conservation Area. SP EIR Mitigation Measure BIO-MM15 requires that the Project Applicant develop and provide to the City of Corona for review and comment a homeowner education plan, which would be provided to future tenants/residents to inform them about the prohibition on planting the species identified by SHP EIR Mitigation Measure BIO-MM5. SHP EIR Mitigation Measure BIO-16 requires all heavy equipment on site shall be washed prior to entering the site to prevent the spread of weedy species. SHP EIR Mitigation Measure BIO-MM17 requires that staging areas shall occur in areas that have previously been disturbed and within the Project footprint, and further requires such areas be maintained in a weed/noxious weed-free condition. New Mitigation Measure BIO-MM24 requires the Project Applicant to record Codes, Covenants, and Restrictions (CC&Rs) that explicitly prohibit the planting of the species identified by SHP EIR Mitigation Measure BIO-MM5 during the life of the Project. Implementation of the required mitigation would reduce Project indirect impacts due to invasive plant species to below a level of significance. (L&L, 2024, pp. 98-99) Human and pet encroachment into surrounding habitat areas may increase over time due to its proximity to increased occupied residential units and recreational use of the natural environment, including off-road vehicle (ORV) and pedestrian uses. Encroachment would be reduced by the incorporation of barriers between avoided areas and development (as already required by the design of the proposed Project), signage requesting that people remain on the existing trails, and Homeowner education materials. SHP EIR Mitigation Measure BIO-MM20 (as modified/supplemented herein)requires the incorporation of MSHCP measures that address this Urban/Wildlands Interface Guidelines (UWIG). Compliance with the UWIG requirements would reduce Project impacts due to human and domestic pet encroachment into on site open space areas to below a level of significance.

Conclusion
Implementation of the SHP EIR Mitigation Measures (as modified/supplemented herein) and implementation of new Mitigation Measures BIO-MM21 through BIO-MM24 would ensure that the Project’s direct and indirect impacts to sensitive vegetation communities, including riparian/riverine habitats, are reduced to below a level of significance. The mitigation measures include more stringent requirements than were identified by the SHP EIR.

It also bears noting that the Project would disturb essentially the same area as identified for disturbance by the SHP EIR, and in fact, result in less total disturbance that the Approved Project. Thus, as a general matter, the SHP EIR already anticipated and analyzed all of the impacts to biological resources that would occur from the currently proposed Project. For all these reasons, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.
c) Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The REIR disclosed that there are no wetlands within the SHP site and as such the REIR found that the SHP would not result in impacts to federally-protected wetlands. However, the REIR found that the SHP site supports jurisdictional waters of the U.S. and riparian scrub and streambed. Thus, the REIR found that compliance with applicable regulatory requirements and implementation of the prescribed mitigation measures (BIO-MM 7 through BIOMM10) would reduce potentially significant impacts in these regards to a less than significant level. (Corona, 2016, pp. 4.C-56 through 4.C-59)

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EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. Provided below is a discussion of the proposed Project’s potential direct and indirect impacts to wetlands and jurisdictional areas.

Project Impacts to Vernal Pools
No naturally occurring vernal pools were observed in the Survey Area. No vernal pool indicator species were observed. Soil types mapped on the site are not consistent with an alkali playa or vernal pool complex. Two areas of seasonal ponding were observed and were inundated for a short period of time during the 2024 rainy season.

CNDDB records the closest special status fairy shrimp species at more than twenty miles from the Project. Wet and dry season protocol level survey conducted in 2024 had negative findings for fairy shrimp species and no other vernal pool species was observed. The areas of ponding are believed to have resulted from an interim condition between the recent development footprint of the FPWE and the ultimate condition of the Skyline Heights Project.

These seasonal ponding areas within man-made low points will be resolved once the Skyline Heights Project infrastructure is in place. (L&L, 2024, p. 125)
Direct Impacts to Jurisdictional Drainages/Wetlands
Although the SHP EIR indicated that the SHP would result in impacts to 1.57 acres (5,232) of jurisdictional habitat subject to regulation by the United States Army Corps of Engineers (USACE) and although the USACE previously issued a 404 Permit pursuant to the federal Clean Water Act (CWA), under the current USACE guidance the drainages in the Survey Area are all ephemeral, non-Relatively Permanent Waters (RPW) that no longer are considered jurisdictional by the USACE. The area previously considered to be federal waters is now only waters of the State (RWQCB) under the Porter-Cologne Water Quality Control Act. Accordingly, the proposed Project would not result in any impacts to waters under federal jurisdiction. However, he Project would be subject to compliance with SHP Mitigation Measures BIO-MM6 and BIO-MM7, which have been modified/supplemented herein and provide more stringent mitigation for Project impacts to jurisdictional areas as compared to what previously was required by SHP EIR Mitigation Measure BIO-MM7. (L&L, 2024, pp. 83-84) The proposed Project would impact ±10.51 acres of CDFW jurisdiction (as shown on Figure 16 of the Project’s BRA, included as Technical Appendix D1), of which ±3.81 acres are CDFW wetlands and ±6.7 acres are CDFW streambeds.

The proposed Project also would impact ±1.48 acres of Santa Ana Regional Water Quality Control Board (RWQCB) jurisdiction State waters (as also depicted on BRA Figure 16). An additional ±1.13 acres of CDFW streambeds and ±0.25-acre of RWQCB state waters would be temporarily impacted within the proposed temporary haul road.

Impacts to the individual drainage features are summarized below in Table 19, Summary of Project Impacts to Jurisdictional Drainages/Wetlands. Feature details, including length, average width, and impacts to each drainage and tributary are provided in BRA Table 21 within BRA Appendix A.

The Project’s direct impacts to areas considered jurisdictional by the CDFW and/or RWQCB would be significant prior to mitigation. However, the proposed Project would be subject to compliance with the SHP EIR mitigation measures, as modified/supplemented herein. Mitigation Measure BIO-MM7 would apply, which requires mitigation for impacts to ±10.51 acres of riparian/riverine impacts at a minimum 2:1 basis (mitigation:impact), either through purchase of mitigation credits at an approved mitigation bank or through on-site mitigation. Onsite mitigation areas, if proposed, would be subject to compliance with a Habitat Mitigation and Monitoring Plan

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Table 19 Summary of Project Impacts to Jurisdictional Drainages/Wetlands Drainage/
Feature*
Total Combined Impacts to
CDFW Jurisdictional Areas
Breakdown of Jurisdiction
Impacts to State
(CDFW) Wetlands &
MSHCP Riparian
Impacts to State
(CDFW) Streambeds
& MSHCP Riverine
Impact to State Waters
(RWQCB)
Sq. ft. Acres Length Sq. ft. Acres Sq. ft. Acres Sq. ft. Acres Length Permanent Impacts
F-1 71,746 1.65 4,179 0 0 71,746 1.65 34,421 0.790 4,043 F-1 Offsite 6,332 0.15 131 0 0 6,332 0.15 2,600 0.060 131 F-2 0 0 0 0 0 0 0 0 0 0
F-3 346,410 7.95 11,394 158,110 3.63 188,300 4.32 24,918 0.572 10,013 F-4 0 0 0 0 0 0 0 0 0 0
F-5 12,407 0.28 2,433 0 0 12,407 0.28 2,317 0.053 1,974 F-6 21,203 0.48 497 8,061 0.18 13,142 0.30 100 0.002 112 Total 458,098 10.51 18,634 166,171 3.81ac 291,927 6.7 64,356 1.48 16,273 Temporary Impacts
F-5 3,568 0.08 222 0 0 3,568 0.08 2,206 0.05 219
F-6 Offsite 45,787 1.05 222 0 0 45,787 1.05 8,647 0.20 222 Total 49,355 1.13 444 0 0 49,355 1.13 10,853 0.25 441
*including tributaries; Difference in some totals is the result of rounding. (L&L, 2024, Table 11)
(HMMP), which would be subject to approval by the City of Corona and Wildlife Agencies. New Mitigation Measure BIO-MM23 requires the Project Applicant to restore to its current condition the areas on site that would be temporarily impacted due to the need to construct a temporary haul road. SHP EIR Mitigation Measures BIO-MM9 and BIO-MM10 (as modified/supplemented herein) also would apply, which require the Project Applicant to obtain appropriate permits from the RWQCB and CDFW for Project impacts to jurisdictional waters. Because the Project Applicant would be required to mitigate direct impacts to ±10.51 acres of riparian/riverine habitat (inclusive of impacts to 10.51 acres of CDFW jurisdictional areas and impacts to 1.48 acres of RWQCB jurisdictional areas) at a minimum ratio of 2:1, and with the restoration of the ±1.13 acres that would be temporarily impacted in association with the temporary haul road, Project impacts to jurisdictional waters subject to regulation by the CDFW and/or RWQCB would be reduced to below a level of significance. (L&L, 2024, pp. 107-111) Indirect Impacts to Jurisdictional Drainages/Wetlands
Long-term downstream impacts could occur from inadvertent discharges released from occupied residential units, park, or open space areas and roadways. This could include organic debris and chemicals from landscaped areas and household chemicals, and would represent a potentially significant indirect impact of the proposed Project.

However, the Project would be subject to SHP EIR Mitigation Measure BIO-MM8, as modified/supplemented herein, which requires the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) during construction activities, which would specify Best Management Practices (BMPs), including water quality basins and homeowner education, to prevent discharges from entering the jurisdictional areas on site (including riparian/riverine areas) and to reduce the amount of airborne dust. With implementation of Mitigation Measure BIO-8, the Project’s long-term indirect impacts to downstream habitat would be reduced to less-than-significant levels.

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Conclusion
With implementation of the mitigation measures identified in the SHP EIR, as modified/supplemented herein, the Project’s direct permanent, direct temporary, and indirect impacts to jurisdictional waters and wetlands would be reduced to less-than-significant levels, consistent with the conclusion reached by the SHP EIR. It also bears noting that the Project would disturb essentially the same area as identified for disturbance by the SHP EIR, and in fact, result in less total disturbance that the Approved Project. Thus, as a general matter, the SHP EIR already anticipated and analyzed all of the impacts to biological resources that would occur from the currently proposed Project. For all these reasons, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. d) Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The REIR found that the SHP site does not contain suitable habitat for migratory fish; therefore, the REIR concluded that the SHP project would not have any impact on migratory fish and no mitigation is required. However, the REIR disclosed that the site contains vegetation suitable for nesting birds. Therefore, the REIR found that the SHP project may result in significant impacts on nesting bird species that are protected under the California Fish and Game Code and the Migratory Bird Treaty Act (MBTA) if removal, clearing, and/or grubbing were to occur during the general avian nesting season (January 1 to September 1). However, the REIR concluded that implementation of Mitigation Measure BIO-MM11 would reduce impacts to a less-than-significant level. The REIR also found that Impacts to regional wildlife movement would be less than significant requiring no mitigation. (Corona, 2016, pp. 4.C-59 through 4.C-60)
EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The Survey Area is bordered by dense urban development to the north and east, a few parcels of low-density residential development and open space to the west; and open space to the northwest, west and south. The survey area is north and east of MSHCP Core B (Cleveland National Forest). (L&L, 2024, p. 86)
No native wildlife nursery sites are located within the Survey Area and therefore, no significant impacts to wildlife nursery sites would occur.

The Survey Area includes native habitat that supports a variety of wildlife species and likely contributes generally to the Corona-Temecula Foothills linkage. However, it does not constitute a wildlife corridor (i.e., a piece of habitat, usually linear in nature, that connects two or more habitat patches that would otherwise be fragmented or isolated from one another), as movement on a regional scale is not confined within a specific corridor in this area. Rather, it is composed of open space at the interface with urban development and is contiguous with a large expanse of open space within MSHCP Core B and the Cleveland National Forest. Thus, wildlife currently moves freely throughout the Survey Area and surrounding areas via existing travel routes such as drainages, ridgelines, and existing dirt roads. (L&L, 2024, pp. 86-87)
It should be noted that Wardlow Wash, just offsite to the north of the survey area, was identified by BonTerra Consulting as a regional wildlife corridor that facilitates movement between the Cleveland National Forest and

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Prado Basin, as referenced by the Foothill Parkway Westerly Extension (FPWE) EIR. However, Wardlow Wash is relatively constrained by development on either side, road crossings at three locations (Paseo Grande, Serfas Club Drive, and Palisades Drive), and State Route 91, which are significant barriersto wildlife movement. Wardlow Wash would not be impacted by the proposed Project. A recognized connection between the Santa Ana Mountains and the Chino Hills area is farther to the west via Coal Canyon. The MSHCP also proposes a connection between Existing Core A (Prado Basin/Santa Ana River) with Existing Core B (Cleveland National Forest) via Constrained Linkages 1 and 2, which are also farther to the west (but east of Coal Canyon). The Survey Area also currently provides for movement on a smaller, local scale for species that live within the Survey Area. (L&L, 2024, p. 87) Upon build-out of the proposed Project, wildlife species are anticipated to continue to use open space areas adjacent (west and south) of the Project site. Thus, potential impacts to regional movement would be less than significant and no mitigation is required. Wardlow Wash would not be impacted by the Project, and the proposed Project impacts are approximately 300 feet south of the wash. The Project would not inhibit wildlife movement along the drainage; thus, impacts to regional wildlife movement are less than significant. (L&L, 2024, pp. 111-112) Although the Project site does not comprise a wildlife movement corridor, the Project site contains vegetation suitable for nesting birds, which may include species protected under the Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code (CFCG). In the absence of mitigation, the Project has the potential to result in impacts to nesting migratory bird species. However, the proposed Project would be subject to compliance with SHP EIR Mitigation Measure BIO-MM11 (as modified/supplemented herein), which requires either avoidance of vegetation removal during the general avian nesting season (January 1 to September 1) when possible, and further requires a pre-construction survey in the event that construction activities must occur during the nesting season.

If active nests are found during the pre-construction survey, appropriate buffers would be established, and construction activities would be adjusted to avoid disturbance. The required mitigation would ensure that any impacts to nesting birds are minimized and reduced to a less-than-significant level. (L&L, 2024, p. 111) In addition, human presence, noise, lighting, and predator subsidies could indirectly hinder wildlife movement and could result in avoidance and abandonment of the area. However, the Project would be subject to compliance with the development standards and design guidelines specified by the proposed SHSP, applicable provisions of the CMC, and the mitigation measures identified by the SHP EIR (as supplemented/modified herein). Subsection

5.3.8 of the proposed SHSP includes the following requirement that has been included specifically to exclude human and domestic animal intrusion into the proposed open space areas on site:
“Special edge treatments shall be implemented where development areas abut open space areas, including the installation of minimum 8-foot-tall exclusion fencing in areas abutting natural open space areas, which shall be subject to review and approval by the City of Corona. No gates or other openings are allowed along rear yard walls or fences that abut biological open space areas.” (SHSP, Subsection 5.3.8) The City of Corona would review future implementing grading and building permits to ensure that the required fencing is installed at all interfaces between development areas and open space areas. In addition, after completion of construction, noise levels adjacent to the site would be increased over current conditions but would not exceed residential noise standards, and thus indirect noise impacts affecting wildlife movement would be less than significant. Development of the Project also would be subject to compliance with CMC Section 17.84.070 (Glare), which requires that “[a]ll areas of exterior lighting shall be designed to direct light downward with minimal

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spillover onto adjacent residences, sensitive land uses and open space,” which would preclude potential indirect lighting impacts affecting wildlife movement within the on-site and adjacent open space areas. Furthermore, the Project would be subject to compliance with SHP EIR Mitigation Measure BIO-MM20 (Urban/Wildlands Interface), which requires the incorporation of MSHCP measures that address the Urban/Wildlands Interface Guidelines (UWIG). Mandatory compliance with the SHP EIR mitigation measures (as supplemented/modified herein), the CMC, and the development standards and design guidelines of the proposed SHSP would ensure that the Project’s indirect impacts to wildlife movement are reduced to less-than-significant levels.

Based on the foregoing analysis, and with implementation of the SHP mitigation measures (as modified/ supplemented herein), mandatory compliance with the MSHP UWIG, compliance with the development standards and design guidelines of the proposed SHSP, and applicable provisions of the CMC, the proposed Project would not directly or indirectly interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, and the Project would not impede the use of native wildlife nursery sites. Impacts would be less than significant. It also bears noting that the Project would disturb essentially the same area as identified for disturbance by the SHP EIR, and in fact, result in less total disturbance that the Approved Project. Thus, as a general matter, the SHP EIR already anticipated and analyzed all of the impacts to biological resources that would occur from the currently proposed Project. For all these reasons, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. e) Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR found that implementation of the SHP would not conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the SHP project (including, but not limited to the General Plan and Municipal Code). The SHP EIR concluded that the impact would be less than significant. (Corona, 2015, p. 4.B-36) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. Aside from the MSHCP, which is addressed separately under the analysis of Threshold f), below, the only applicable local policies or ordinances are Chapter 12.22 of the Corona Municipal Code (CMC) and the City of Corona General Plan policies related to biological resources.

Chapter 12.22 of the CMC includes the Community Forestry Program, which describes requirements regarding the planning, planting, maintenance, alteration, and removal of all trees, shrubs, and landscape materials on public property. There are no existing parkways located on the Project site, beyond the existing parkways that exist along Foothill Parkway and the western terminus of Trudy Way. Improvements proposed as part of the Project that could affect these existing parkways include proposed on-site roadway connections to Trudy Way and two proposed connections to Foothill Parkway (i.e., proposed Streets “B” and “P” on TTM 36544R1). However, with exception of the southern parkway at the Foothill Boulevard intersection with Border Avenue, which includes low-lying shrubs within the parkway, the proposed entrances into the Project site currently do not include any landscaping that would be subject to Chapter 12.22. Although the Project would result in the removal of the existing low-lying shrubs that exist along the southern edge of Foothill Boulevard as part of the construction of proposed Street “B,” TTM 36544R1 includes an overall landscape plan that identifies future landscaping requirements for the Project

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site and that implements the landscape design guidelines included in the proposed SHSP. The landscape plan calls for the planting of extensive street trees and groundcover along Street “B,” while proposed Street “P” would include trees and groundcover within both the parkways and median. In addition, the landscape plan call for the planting of street trees along the westerly extension of Trudy Way, which would result in the completion of the landscaped parkways for this portion of the roadway. The City of Corona has reviewed the Project’s proposed overall landscape plan, and has determined that the proposed landscaping for the Project would fully comply with all applicable provisions of CMC Chapter 12.22. Accordingly, and consistent with the findings of the SHP EIR, impacts due to a conflict with CMC Chapter 12.22 would not occur.

Table 4.C-4 of the SHP EIR included an analysis of the Approved Project’s consistency with the goals and policies contained within the City of Corona General Plan Environmental Resources Element. However, subsequent to certification of the SHP EIR, the City of Corona City Council adopted an update to the City’s General Plan in 2020, with the most recent amendment to the General Plan occurring in April 2024. Table 20, Project Consistency with General Plan Policies Related to Biological Resources, provides a discussion and analysis of the Project’s consistency with each of the goals and policies listed under the Biological Resources section of the Environmental Resources Element of the City’s 2020-2040 General Plan. As indicated in Table 20, with implementation of the mitigation measures presented in the SHP EIR (as supplemented/modified herein), the proposed Project would be fully consistent with the Biological Resources goals and policies contained within the General Plan Environmental Resources Element. Accordingly, Project impacts due to a conflict with General Plan goals and policies related to biological resources would be less than significant.

Table 20 Project Consistency with General Plan Policies Related to Biological Resources Goal/Policy Project Consistency
Goal ER-6: Protection, enhancement, and sustaining of
significant plant and wildlife species and habitat that exist in Corona and its Planning Area, for the long-term benefit of the natural environment and Corona residents and
visitors.

Consistent. The revisions proposed to TTM 36544 would
result in a reduction in areas planned for physical
disturbance on site from approximately 170.70 acres under the approved TTM 36544 to 151.8 acres under proposed
TTM 36544R1. As more fully documented in the Project’s
BRA and DBESP and in the analysis of Project consistency with Policies ER-6.1 through ER-6.5, with the
implementation of mitigation measures the Project would contribute to the protection, enhancement, and sustaining of significant plant and wildlife species and their habitat.

Policy ER-6.1 Support the rehabilitation and enhancement of the biological diversity, and integrity of the City’s natural resources through such means as vegetation restoration, control of alien plants and animals, landscape buffering, and natural watercourse channel restoration.

Consistent. As more fully discussed under the analyses of Thresholds b) and c), mitigation measures are proposed to reduce the Project’s impacts to sensitive plant and animal species to below a level of significant. The mitigation program includes a required 10-acre compensation parcel; the preservation of unimpacted areas on site as permanent natural open space; the salvaging of Coulter’s matilija poppy (CMP) and intermediate mariposa lily (IML) plants for replanting on or off site as compensation for Project impacts to 316 CMJ individuals and impacts to 676 IML
individuals; the translocation and seed propagation on or off site of chaparral nolina as compensation for Project

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Goal/Policy Project Consistency
impacts to ±2,180 chaparral nolina individuals; and
mitigation prohibiting the use of plants listed in Section

6.1.4 of the MSHCP.

Policy ER-6.2 Preserve the wildlife and plant species and habitats listed in Tables 4-12 and 4-13 of the Technical Background Report for the General Plan and EIR and those that may be considered by the City of Corona in the future.

Consistent. As more fully discussed under the analyses of Thresholds a) and b), no State- or federally-listed plant species were observed in the survey area during surveys conducted by L&L in 2024. However, the proposed Project would result in impacts to 18 of the 30 (60 percent)
observed Fish’s milkwort, all 342 (100 percent) paniculate tarplant, the one (100 percent) Brewer’s calandrinia, 463 of the 676 (71 percent) observed intermediate mariposa
lily (IML), 316 of the 716 (44 percent) Coulter’s matilija poppy (CMP), and ±2,180 of the estimated 5,343 (41
percent) chaparral nolina. IML, Fish’s milkwort, and CMP are covered species under the MSHCP and adequately
conserved under the Plan, and as such Project impacts to these species would be less than significant with
mandatory compliance with the MSHCP and payment of
MSHCP development fees. Brewer’s calandrinia has a wide range in California, and Project impacts to a single Brewer’s calandrinia would be considered an adverse but less-thansignificant impact. Based on the wide distribution, number of locations within western Riverside County, and known locations of this species within MSHCP conservation areas, impacts to paniculate tarplant would be considered
adverse but less than significant. Although the Project would result in impacts to ±2,180 chaparral nolina
individuals, impacts would be reduced to less-thansignificant levels with implementation of proposed new Mitigation Measure BIO-MM2. Impacts to all other plant
species on site would be less than significant.

Policy ER-6.3 Ensure that new developments and
circulation improvements demonstrate compliance with
state and federal regulations concerning the status,
location, and condition of significant and sensitive
biological species and habitats and riparian and riverine corridors. Biological surveys, as required and defined by the Western Riverside County Multiple Species Habitat
Conservation Plan, should identify potential impacts on biological resources and include mitigation measures to protect/replace resources in like kind
Consistent. Updated biological technical reports were
prepared for the proposed Project (refer to Technical
Appendices D1 and D2). As more fully discussed under the analyses of Thresholds a), b), and f), with implementation of the mitigation measures identified by the SHP EIR (as supplemented/modified herein), the proposed Project
would be fully consistent with all applicable State and federal regulations concerning biological species, their habitats, and riparian and riverine corridors. The
mitigation also would ensure full Project consistency with all applicable provisions of the MSHCP.

Policy ER-6.4 Ensure that new developments through the
development review process adhere to the Western
Riverside County Multiple Species Habitat Conservation
Plan, the Stephens’ Kangaroo Rat Habitat Conservation
Plan, and other habitat plans as appropriate to conserve Consistent. The Project site is not targeted for conservation under the Stephens’ Kangaroo Rat Habitat Conservation
Plan (SKR HCP), and the Project site falls outside of the fee area for the SKR HCP; thus, the Project has no potential to conflict with the SKR HCP (RCA, 1996, Figure 21). As

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Goal/Policy Project Consistency
biological diversity through protection of natural
communities.
indicated under the discussion and analysis of Threshold f., with mitigation the proposed Project would be fully
consistent with all applicable provisions of the MSHCP.

Policy ER-6.5 Preserve wildlife habitat of significant natural open space areas, including expanding habitat ranges,
movement corridors, and nesting sites by adhering to and implementing the core biological linkages identified in the MSHCP for parts of the Temescal Canyon Area Plan in the City. Any proposed recreational use of those areas such as trails shall be designed to not interfere with the
preservation efforts established in the MSHCP.

Consistent. As indicated under the discussion and analysis of Threshold f), the Project site is not targeted for
conservation under the MSHCP, and the Project would
accommodate a total of 182.48 acres (73% of the Project site) of natural open space and landscaped slopes. In
addition, beyond existing trails that occur on the property under existing conditions and that would not be further improved as part of the Project, all trails proposed as part of the Project would occur outside of areas proposed to be conserved as open space.

Goal ER-7 Adequate protection of biological resources and increased public awareness of their value to the
community.

Consistent. The analysis of Thresholds a) through d)
demonstrate that with mitigation, Project impacts to
biological resources would be reduced to less than
significant levels and would provide for the adequate
protection of biological resources that occur on site. The remaining portion of this goal provides direction to City of Corona staff and decision makers.

Policy ER-7.1 Require that public and private construction activities be conducted in a manner to minimize adverse impacts on natural resources and biological resources in proximity to MSHCP conservation areas and adhere to the MSHCP Guidelines pertaining to Urban/Wildlife Interface for drainage, toxics, lighting, noise, invasive barriers, and grading [MSHCP Section 6.1.4].

Consistent. As indicated under the discussion and analysis of Threshold f), the Project would be subject to compliance with the mitigation measures identified in the SHP EIR (as modified/supplemented herein), which include
requirements that implement the Urban/Wildlife Interface Guidelines (UWIG) provisions of the MSHCP.

Policy ER-7.2 Allow for publicly accessible sites that
facilitate observation of natural resources in Corona and its sphere without compromising environmental quality.

Consistent. The Project would accommodate existing trail connections within planned open space areas on site,
which would afford public access to natural resources
available on site without compromising environmental
quality.

Policy ER-7.3 Promote education programs and materials
prepared by the Western Riverside County Regional
Conservation Authority, Riverside-Corona Resource
Conservation District, and other entities that promote
awareness of biological resources conservation.

Not Applicable. Policy ER-7.3 provides direction to City staff and decision makers, and is not applicable to the proposed Project.

Goal ER-8 Protection of forest and vegetation resources in the City of Corona
Consistent. As discussed herein in Subsection 2.2, the
Project site does not contain any forestry resources under existing conditions. As discussed under the analysis of Thresholds a) and b), with implementation of the SHP EIR mitigation measures (as modified/supplemented herein),
Project impacts to vegetation communities would be
reduced to less-than-significant levels.

Policy ER-8.1 Cooperate with federal and state agencies to achieve the sustainable conservation of forest lands as a Not Applicable. Policy ER-8.1 provides direction to City staff and decision makers, and is not applicable to the proposed Project.

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Goal/Policy Project Consistency
means of providing open space and protecting natural
resources and MSHCP habitat.

Policy ER-8.2 Support conservation programs to reforest privately held forest lands.

Not Applicable. Policy ER-8.2 provides direction to City staff and decision makers, and is not applicable to the proposed Project.

Policy ER-8.3 Work with Riverside County to update the
Vegetation Map for Corona and the SOI areas in
cooperation with the California Department of Fish and
Wildlife, the Natural Diversity Data Base, the United States Forest Service, and other knowledgeable agencies.

Not Applicable. Policy ER-8.3 provides direction to City staff and decision makers, and is not applicable to the proposed Project.

Policy ER-8.4 Maintain and conserve superior examples of native trees (including oak trees), natural vegetation, stands of established trees, and other features for
aesthetic and water conservation purposes.

Consistent. The Project would accommodate a total of
182.48 acres (73% of the Project site) of natural open
space and landscaped slopes. In addition, and as indicated under the analysis of Thresholds a) and b), although the Project would result in direct permanent impacts to ±7.73 acres of coast live oak woodlands, the Project would be subject to compliance with SHP EIR Mitigation Measure
BIO-MM6 (as modified herein), which requires the
replacement of all impacted oak trees at a minimum 2:1
ratio.

Policy ER-8.5 Conserve the oak tree resources in the City to the extent feasible.

Consistent. As indicated under the analysis of Thresholds a) and b), although the Project would result in direct
permanent impacts to ±7.73 acres of coast live oak
woodlands, the Project would be subject to compliance
with SHP EIR Mitigation Measure BIO-MM6 (as modified
herein), which requires the replacement of all impacted oak trees at a minimum 2:1 ratio.

Goal ER-9 Protection of regional washes and waterways
and their use for recreational and open space purposes
such as trails, habitat preservation, and groundwater
recharge.

Consistent. As indicated in the discussion of Thresholds b) and c), implementation of the Project would result in
permanent impacts to ±10.51 acres and temporary impacts to ±0.11-acre of MSHCP Riparian/Riverine areas. The
Project would be subject to compliance with the mitigation measures included in the SHP EIR (as modified/
supplemented herein). Specifically, the Project would be subject to compliance with SHP EIR Mitigation Measures
BIO-MM6 (Oak Tree Replacement) and BIO-MM7
(Riparian/Riverine Mitigation), and new Mitigation
Measure BIO-MM23 (Restoration). Implementation of the
required mitigation would reduce the Project’s impacts to riparian and riverine resources to below a level so
significance.

Policy ER-9.1 Protect sensitive biological resources in the Temescal Canyon Area Plan through adherence to policies in the Western Riverside County MSHCP.

Consistent. As indicated under the discussion and analysis of Threshold f), with implementation of the mitigation
measures included in the SHP EIR (as modified/
supplemented herein), the proposed Project would be fully consistent with the Western Riverside County MSHCP.

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Goal/Policy Project Consistency
Policy ER-9.2 Conserve existing wetlands and wetland
functions and values in the Temescal Canyon Wash, Prado Basin, and the Santa Ana River with a focus on
conservation of existing riparian, woodland, coastal sage scrub, alluvial fan scrub, and open water habitats.

Not Applicable. The Project site is not located within or in close proximity to the Temescal Canyon Wash, Prado Basin, or the Santa Ana River.

Policy ER-9.3 Conserve existing known populations of least Bell’s vireo and southwestern willow flycatcher in the
Temescal Canyon Area Plan, including at Prado Basin, Santa Ana River, and Temescal Canyon Wash. Maintain existing
breeding habitat for these species at Prado Basin, Santa Ana River, and Temescal Wash where applicable to a
particular project and location.

Consistent. As documented in the Project’s BRA (Technical Appendix D1), least Bell’s vireo (LBV) was not observed during biological surveys and the riparian habitat present on the Project site does not provide suitable territorial or breeding habitat for LBV (L&L, 2024, p. 72). Additionally, the Project site does not contain any habitat suitable to support the southwestern willow flycatcher (L&L, 2024, p. 126). The remaining provisions of this policy relate to lands in close proximity to the Prado Basin, Santa Ana
River, and/or Temescal Wash and are not applicable to the proposed Project.

Policy ER-9.4 Conserve and manage suitable habitat for
species known to exist in the Temescal Canyon Area Plan of Western Riverside County’s Multiple Species Habitat
Conservation Plan.

Consistent. As indicated under the discussion and analysis of Threshold f), with implementation of the mitigation
measures included in the SHP EIR (as modified/
supplemented herein), the proposed Project would be fully consistent with the Western Riverside County MSHCP.

Policy ER-9.5 Conserve clay soils supporting sensitive plant species known to occur in the Temescal Canyon area,
including Munz’s onion, Palmer’s grappling hook, smallflowered morning glory, long-spined spineflower, threadleaved brodiaea, small-flowered microseris, and manystemmed dudleya.

Consistent. The Project site does not include any soil
groups with high clay content, with exception of
unmapped clay inclusions that are present in some areas along the ridgelines. As documented in the Project’s BRA (Technical Appendix D1), Munz’s onion Palmer’s grappling hook, small-flowered morning glory, long-spined
spineflower, thread-leaved brodiaea, small-flowered
microseris, and many-stemmed dudleya were not observed
on site and have a low probability to occur (L&L, 2024, Table 14).

Policy ER-9.6 Conserve sandy soils co-occurring with
chaparral supporting Palomar monkeyflower, known to
occur in the Temescal Canyon area.

Consistent. Palomar monkey flower has a low potential to occur on site and was not observed during field surveys conducted in 2024.

Policy ER-9.7 Conserve locations supporting California
muhly, heart-leaved pitcher sage, Hall’s monardella, and other sensitive plant species that may occur in a wide
variety of habitat types within the Temescal Canyon Area Plan.

Consistent. California muhly, heart-leaved pitcher sage, and Hall’s monardella were not observed during field
surveys conducted in 2024 and have a low potential to
occur (L&L, 2024, Table 14).

Policy ER-9.8 Provide for and maintain connection(s) from the Cleveland National Forest to Prado Basin and the Santa Ana River within Temescal Canyon, providing opportunities for offsite connections to Chino Hills State Park.

Not Applicable. Policy ER-9.8 provides direction to City staff and decision makers, and is not applicable to the proposed Project. No component of the proposed Project
would conflict with this policy.

Policy ER-9.9 Conserve upland habitat adjacent to the
Temescal Canyon Wash to augment existing upland habitat conservation in the Lake Matthews/Estelle Mountain
Reserve areas and provide for contiguous connection of
Not Applicable. Policy ER-9.9 relates to lands adjacent to the Temescal Canyon Wash and upland habitat to the east within the Lake Matthews/Estelle Mountain Reserve areas, and the Project site is not located within close proximity to

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Goal/Policy Project Consistency
upland habitat blocks from the existing reserve to Temescal Wash. Habitat conservation should focus on blocks of
existing upland habitat east of Temescal Canyon Wash
connecting to Lake Matthews/Estelle Mountain Reserve.
either the Temescal Canyon Wash or the Lake
Matthews/Estelle Mountain Reserve areas.

Policy ER-9.10 Conserve floodplain areas supporting
sensitive plant species known to occur in Temescal Canyon, including Parry’s spineflower, peninsular spineflower,
smooth tarplant, and Coulter’s matilija poppy.

Consistent. Parry’s spineflower and peninsular spineflower were not observed during field surveys conducted in 2024 and have a low potential to occur. No habitat is present on site for smooth tarplant, which has no potential to
occur. The proposed Project would result in impacts to 316 of the 716 (44 percent) Coulter’s matilija poppy (CMP)
(L&L, 2024, Table 14). As more fully discussed under the analyses of Thresholds b) and c), mitigation measures are proposed to reduce the Project’s impacts to sensitive plant species to below a level of significant. The mitigation program includes a requires a 10-acre compensation
parcel; the preservation of unimpacted areas on site as permanent natural open space (both of which support
CMP) and the salvaging of CMP plants for replanting on or off site as compensation for Project impacts to the 316 CMJ individuals. In addition, CMP are covered species
under the MSHCP and adequately conserved under the
Plan, and as such Project impacts to these species would be less than significant with mandatory compliance with the MSHCP and payment of MSHCP development fees.

Policy ER-9.11 Conserve rocky soils co-occurring with
coastal sage scrub, peninsular jumper, or chaparral
supporting Payson’s jewelflower, known to occur in the
Temescal Canyon area.

Consistent. The majority of the Project site consists of sandy loams and loamy sands, and the only portion of the Project site that contains rock outcrop complexes occurs in the extreme western portion of the Project site that is not proposed for disturbance or development as part of the
Project. Additionally, Payson’s jewelflower was not
observed during the 2024 biological surveys, and this
species has only a low potential to occur on site. (L&L, 2024, Table 14 and Figure 5)
Policy ER-9.12 Provide for and maintain a continuous
linkage along the Temescal Canyon Wash from the
southern boundary of the Temescal Canyon to the Santa
Ana River.

Not Applicable. Policy ER-9.12 provides direction to City staff and decision makers, and is not applicable to the proposed Project. Additionally, the Project site is not located in close proximity to the Temescal Canyon Wash or lands between the Temescal Canyon Wash and Santa Ana
River.

Accordingly, and based on the foregoing analysis, the proposed Project would not conflict with any applicable policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, and impacts would be less than significant. Therefore, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.

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f) Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The REIR found that the SHP site supports Riparian/Riverine Areas, which will be mitigated consistent with the requirements of the wildlife agencies via Mitigation Measures BIO-MM1, BIO-MM4 through BIO-MM6, BIO-MM7, BIO-MM9, BIOMM10, BIO-MM11, and BIO-MM14 through BIO-MM19. The REIR found that impacts to sensitive species would be addressed Mitigation Measures BIO-MM3 and BIO-MM4, and that the SHP project also would incorporate measures to meet the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Urban/Wildlands Interface guidelines and requirements as required by BIO-MM20; therefore, the REIR found that impacts would be less than significant. The REIR disclosed that although the SHP site is in the Burrowing Owl Survey Area and supports suitable habitat, focused surveys were negative. In accordance with the MSHCP, the REIR imposed BIO-MM12 requiring a preconstruction survey for BUOW, which the REIR found would reduce potential future impacts to BUOW to less than significant. Additionally, the REIR found that the Project Applicant would be required to pay the MSHCP development mitigation fee, which would ensure full compliance with the MSHCP. (Corona, 2016, pp. 4.C-65 through 4.C-70)
EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The only applicable Habitat Conservation Plan in the Project area is the Western Riverside County MSHCP, as the Survey Area is not located within the SKR HCP conservation area and is not within the SKR HCP fee area. Provided below is an evaluation of the Project’s consistency with MSHCP Reserve Assembly requirements, Section 6.1.2 (Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools), Section 6.1.3 (Protection of Narrow Endemic Plant Species), Section 6.1.4 (Guidelines Pertaining to the Urban/Wildlands Interface [UWIG]), and Section 6.3.2 (Additional Survey Needs and Procedures).

Project Consistency with MSHCP Reserve Assembly Requirements The MSHCP defines two distinct consistency processes for development projects based on their location within the MSHCP’s coverage area, with separate processes for projects located outside of Criteria Areas and those within a Criteria Area. Criteria Areas consist of 160-acre ‘cells’ with identified conservation objectives. The Survey Area is not located within any MSHCP Criteria Cells, indicating that no portion of the Survey Area is targeted for conservation under the MSHCP. The nearest MSHCP Criteria Cell (Cell 1902) occurs approximately 0.8-mile northwest of the Project site. Accordingly, the proposed Project has no potential to conflict with the MSHCP Reserve Assembly Requirements. No impact would occur, and no mitigation measures are required.

Project Consistency with MSHCP Section 6.1.2 (Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools)
As discussed in further detail under the analysis of Threshold c), no naturally occurring vernal pools were observed within the Survey Area. In addition, focused surveys for listed fairy shrimp species were negative for all species of fairy shrimp, both common and listed. Thus, the proposed Project has no potential to conflict with MSHCP Section

6.1.2 with respect to vernal pools or sensitive vernal pool species (L&L, 2024, p. 125). Impacts would not occur.

Streambed/wetland delineation studies identified ±19.3 acres of riparian/riverine area (sycamore woodland [±0.27 acre], mulefat scrub [±0.27 acre], coast live oak woodland [±5.71 acres], SBS [±9.87 acres], and streambeds

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within unvegetated or upland habitats [±3.18 acres]) in the Survey Area, including offsite impact areas. The proposed Project would result in impacts to riparian/riverine areas subject to MSHCP Section 6.1.2, including permanent impacts to ±10.51 acres riparian/riverine habitat (sycamore woodland [±0.11 acre], mulefat scrub [±0.09 acre], coast live oak woodland [±4.61 acres], SBS [±3.61 acres], and streambeds within upland habitats [±2.09 acres]). An additional ±1.13 acres of riverine habitat will be temporarily impacted. Consistent with the findings of the SHP EIR, Project impacts to riparian/riverine areas subject to MSHCP Section 6.1.2 would be significant prior to mitigation. However, the proposed Project would be subject to compliance with the SHP EIR mitigation measures, as modified/supplemented herein. SHP EIR Mitigation Measure BIO-MM7 would apply, which has been modified as part of this EIR Addendum No. 1 to require mitigation for impacts to ±10.51 acres of riparian/riverine impacts at a minimum 2:1 basis(mitigation:impact), either through purchase of mitigation credits at an approved mitigation bank or through on-site mitigation. On-site mitigation areas, if proposed, would be subject to compliance with a Habitat Mitigation and Monitoring Plan (HMMP), which would be subject to approval by the City of Corona and Wildlife Agencies. New Mitigation Measure BIO-MM23 also requires the Project Applicant to restore to its existing/former condition the areas on site that would be temporarily impacted due to the need to construct a temporary haul road. Because the Project Applicant would be required to mitigate direct impacts to ±10.51 acres of riparian/riverine habitat (inclusive of impacts to 10.51 acres of CDFW jurisdictional areas and impacts to 1.48 acres of RWQCB jurisdictional areas) at a minimum ratio of 2:1, and with the restoration of the ±1.13 acres that would be temporarily impacted in association with the temporary haul road, Project impacts to riparian/riverine areas on site would be reduced to less-than-significant levels. (L&L, 2024, pp. 124- 125)
Surveys in 2013 included protocol surveys for least Bell's vireo (LBV). LBV was not observed in the Survey Area and riparian vegetation suitable to provide territorial or breeding habitat for LBV is not present. Although some scattered willow and cottonwood species are present, vegetation diversity and density is not adequate to support the species. No suitable LBV breeding habitat is present on the site and none would be impacted. No LBV were observed on the site, and none would be impacted. The Project would have no impact on LBV, and no mitigation is required. (L&L, 2024, p. 126)
No habitat suitable to support the southwestern willow flycatcher and western yellow-billed cuckoo is present in the Survey Area and none would be impacted. The Project would have no impact on southwestern willow flycatcher and western yellow-billed cuckoo and no mitigation is required. (L&L, 2024, p. 126) Other MSHCP Section 6.1.2 species are either absent, not expected to occur, or have a low potential for occurrence, with the exception of Coulter’s matilija poppy and Fish’s milkwort (L&L, 2024, p. 126).

Coulter’s matilija poppy (CMP) was observed on the site during surveys from 2008 through 2024. Fourteen (14) locations of CMP were identified in 2008 and again in 2013 in the Survey Area. Results of the surveys in 2008 found 526 individuals. In 2013, only ±236 plants were found. Plants were found along the high flow level of active Feature 3 (unnamed drainage) and on the unpaved fire road in the middle of the Survey Area. In 2016, 37 individual CMP and groups were identified and mapped within Feature 3 and its tributaries, which is where most of the CMP were identified in 2008 and 2013. Approximately 691 plants were observed during the 2016 survey within Feature 3, which included locations not previously identified. The plants observed in 2016 were found again in 2017 and 2024. Three additional locations were observed in 2017 consisting of a total of 25 plants. Coulter’s matilija poppy is covered under the MSHCP and adequately conserved under the Plan. Implementation of the Project would

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impact these plants through loss of habitat and loss of individuals or populations within the disturbance area.

Since Coulter’s matilija poppy is covered under the MSHCP and adequately conserved under the Plan, Projectrelated impacts to Coulter’s matilija poppy would be a covered impact under the MSHCP and no mitigation is required beyond payment of the MSHCP Mitigation Fee as required pursuant to Corona Municipal Code (CMC) Section 16.33.070. (L&L, 2024, pp. 126-127)
Fish’s milkwort was identified during multiple surveys including the 2024 focused botanical surveys. A total of 25 plants were observed. Each location consisted of one or two plants, with two exceptions. Location #633 consisted of six plants and #937 consisted of five plants. All of the Fish’s milkwort identified in the Survey Area is found within Feature 3 and its tributaries and is associated with coast live oak woodland or scrub oak chaparral. Under the MSHCP, Fish’s milkwort conservation requirements have been met and this species is now adequately conserved under the Plan. Implementation of the Project would impact these plants through loss of habitat and loss of individuals or populations within the disturbance area. Since Fish’s milkwort is covered under the MSHCP and adequately conserved under the Plan, Project-related impacts to Fish’s milkwort would be a covered impact under the MSHCP and no mitigation is required beyond payment of the MSHCP Mitigation Fee as required pursuant to Corona Municipal Code (CMC) Section 16.33.070. (L&L, 2024, p. 127) Accordingly, and based on the foregoing analysis, with implementation of the SHP EIR Mitigation Measures (as modified/supplemented herein), the proposed Project would be fully consistent with MSHCP Section 6.1.2, and impacts would be reduced to less-than-significant levels.

Project Consistency with MSHCP Section 6.1.3 (Protection of Narrow Endemic Plant Species) Section 6.1.3 of the MSHCP, Protection of Narrow Endemic Plant Species, states that the MSHCP database does not provide sufficient detail to determine the extent of the presence/distribution of Narrow Endemic Plant Species within the MSHCP Plan Area. Additional surveys may be needed to gather information to determine the presence/absence of these species to ensure that appropriate conservation of these species occurs. According to mapping information available from the Western Riverside County Regional Conservation Authority (RCA), the Project site is not located in an MSHCP Section 6.1.3 designated survey area for narrow endemic plant species (RCA, n.d.). Section 6.1.3 species are either absent, not expected to occur, or have a low potential for occurrence.

The Project would have no impact on narrow endemic plant species. Therefore, the proposed Project has no potential to conflict with MSHCP Section 6.1.3, and no impacts would occur.

Project Consistency with MSHCP Section 6.1.4 (Urban/Wildlands Interface Guidelines) MSHCP Core B (Cleveland National Forest) lies immediately west and south of the Project site. Indirect impacts that result from development, including lighting, urban runoff, toxics, and domestic predators, would be minimized through Project design. Provided below is an analysis of the Project’s potential direct and indirect effects to the MSHCP Core Conservation area that could adversely affect biological resources.

Drainage
The Project incorporates streets, open channels, and natural drainage courses as well as a comprehensive system of underground storm drains to handle storm runoff from the Project site. Storm water from the Project site and offsite areas would be directed to storm drains. The design and operation of the drainage channel would be

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adequate to preclude discharge of untreated urban runoff into open space areas. The proposed development would be required to incorporate measures, including measures required through the National Pollutant Discharge Elimination System (NPDES), to ensure that quantity and quality of runoff discharged to open space area is not altered in an adverse way when compared to existing conditions. Measures would be put in place to avoid discharge of untreated surface runoff from developed and paved areas into open space areas. Storm water systems would be designed to prevent the release of toxins, chemicals, petroleum products, invasive plant materials, or other elements that might degrade or harm biological resources or ecosystem wide processes within open space areas. This would be accomplished using a variety of methods including natural detention basins, grass swales, or mechanical trapping devices. Regular maintenance would occur to ensure effective operations of runoff control systems. The Project’s proposed design also incorporates all of the requirements of SHP EIR Project Design Feature (PDF) BIO-1, which is listed at the end of this subsection. Accordingly, the proposed Project would not conflict with MSHCP Section 6.1.4 with respect to drainage. (L&L, 2024, pp. 130-131) Toxics
The proposed Project is designed to utilize natural drainage patterns for the flow of surface water. Water Quality BMPs include education, storm drain stenciling, and street sweeping in compliance with City of Corona requirements. The earthen channel would be designed to filter potential toxics in storm water prior to its discharge into open space areas. These BMPs would be implemented as part of the storm water pollution prevention measures for the Project, in accordance with all appropriate NPDES requirements. The Project would result in the additional use of hazardous materials in limited quantities associated with normal residential activity, such as cleaning products, solvents, herbicides, and insecticides. Household and other goods used by residential homes that contain toxic substances usually are low in concentration and small in amount. Residents are required to dispose of household hazardous waste, including pesticides, batteries, old paint, solvents, used oil, antifreeze, and other chemicals, at a Household Hazardous Waste Collection Facility. Also, as of February 2006, fluorescent lamps, batteries, and mercury thermostats can no longer be disposed in the trash. Furthermore, the transport, use, and disposal of hazardous materials are fully regulated by the EPA, State, Riverside County, and/or the City of Corona.

Mandatory compliance with applicable regulations would reduce the potential risk of toxic substance discharges to a level that is less than significant. Moreover, the Project would be subject to compliance with SHP EIR PDF BIO2, which is listed at the end of this subsection and specifies requirements related to BMPs to address toxics that could indirectly impact downstream receiving waters. Accordingly, the proposed Project would not conflict with MSHCP Section 6.1.4 with respect to toxics, and impacts would be less than significant. (L&L, 2024, pp. 130-131) Lighting
No nighttime construction activities are proposed as part of the Project, and as such construction-related lighting impacts affecting on- or off-site open space areas would not occur. Development of the Project would be subject to compliance with CMC Section 17.84.070 (Glare), which requires that “[a]ll areas of exterior lighting shall be designed to direct light downward with minimal spillover onto adjacent residences, sensitive land uses and open space,” which would preclude potential indirect lighting impacts affecting on- and off-site open space areas, including within MSHCP Core B. The City of Corona would review future implementing projects (i.e., building permits) to ensure compliance with CMC section 17.84.070, which would ensure that long-term operational lighting does not adversely affect the on- or off-site open space areas. Additionally, the Project would be subject to compliance with SHP EIR PDF BIO-3, which prohibits Project lighting from adversely affecting proposed open space areas on site and prohibits nighttime construction unless absolutely necessary, and further requires all

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Project lighting to comply with City of Corona requirements. As such, the Project would not conflict with the lighting provisions of MSHCP Section 6.1.4, and impacts would be less than significant.

Noise
The proposed Project incorporates landscape elements, including trees, shrubs, and groundcover, which would assist in noise reduction in native habitats adjacent to the Project. In addition, a Project-specific Noise and Vibration Analysis (NVA) was prepared for the Project and is included as Technical Appendix I to this SHP EIR Addendum No. 1. As more fully discussed under the analysis of Project noise impacts in Subsection 2.13, longterm operation of the proposed Project would not expose any surrounding land uses to daytime operational noise levels exceeding 36.8 dBA Leq or nighttime noise levels exceeding 33.9 dBA Leq, which are well below the daytime residential noise standards of 55 dBA during daytime hours and 50 dBA during nighttime hours as established by CMC Section 17.84.040 (Noise) for single-family residential land uses. In addition, the Project has been designed to implement SHP EIR PDF BIO-4, which requires the incorporation of landscaping elements at the Project perimeter with open space areas, and the analysis presented in Subsection 2.13 demonstrates that noise associated with Project operations would not expose open space areas to noise levels exceeding 65 dBA during the daytime hours and 45 DBA during the nighttime hours. Therefore, no noise created on the Project site would exceed residential noise standards. As such, the Project would be consistent with MSHCP Section 6.1.4 provisions related to noise, and impacts would be less than significant. (L&L, 2024, p. 131; UC, 2023, Tables 10-3 and 10-4) Invasive Species
Projects adjacent to the MSHCP Conservation Areas are required to avoid the use of invasive plant species in landscaping, including invasive, non-native plant species listed in Volume I, Table 6-2 of the MSHCP. Future development on site would be subject to compliance with the proposed SHSP. SHSP Table 5-3, Community Plant List, identifies a list of plant species that may be planted within the SHSP area. Based on a review of SHSP Table 5- 3, the SHSP does not include any of the prohibited plant species listed in MSHCP Volume 1, Table 6-2. In addition, SHP EIR Mitigation Measures BIO-MM5 and BIO-MM15 and (new) Mitigation Measure BIO-16 have been identified and imposed on the Project to reduce the Project’s potential to result in the introduction of invasive species on site. The Project also would be subject to compliance with SHP EIR PDF BIO-5, which is listed at the end of this subsection and requires providing future homeowners with a list of native landscaping materials allowed within the proposed development and further prohibits the use of plant species prohibited pursuant to MSHCP Table 6-

2. Implementation of SHP EIR Mitigation Measure BIO-MM5 would ensure that the Project’s landscape plans do not include any common cultivar forms of Coulter’s matilija in the plant palette, and further would ensure that the landscaping plant palette excludes those plant species identified by MSHCP Table 6-2, Plants that Should be Avoided Adjacent to the MSHCP Conservation Area. SHP EIR Mitigation Measure BIO-MM15 requires the Project Applicant to prepare and provide to future homeowners an education package informing future tenants/homeowners of the list of prohibited plant species identified by Mitigation Measure BIO-MM5. New Mitigation Measure BIO-MM24 would ensure that the Project’s Codes, Covenants, and Restrictions (CC&Rs) include a provision prohibiting the planting of any of the plant species identified by SHP EIR Mitigation Measure BIO-MM5, which would help ensure that such plant species are not planted by future homeowners/tenants.

Accordingly, with compliance with the SHSP mitigation measures and new Mitigation Measure BIO-MM24, the proposed Project would not result in the introduction of invasive species within MSHCP Core B or any of the onsite open space areas, and impacts would be reduced to less-than-significant levels. (L&L, 2024, p. 132)

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Barriers
Proposed land uses adjacent to the MSHCP Conservation Areas are required to incorporate barriers, where appropriate in individual project designs, to minimize unauthorized public access, domestic animal predation, illegal trespass or dumping in the MSHCP Conservation Areas. Such barriers may include native landscaping, rocks/boulders, fencing, walls, signage and/or other appropriate mechanisms. The proposed Project has been designed to include theme walls along Project perimeter streets adjacent to public streets, along with walls and fencing located where public view and/or important interfaces are of concern. The Project would be subject to compliance with the development standards and design guidelines specified by the proposed SHSP, applicable provisions of the CMC, and the mitigation measures identified by the SHP EIR (as supplemented/modified herein).

Subsection 5.3.8 of the proposed SHSP includes the following requirement that has been included specifically to exclude human and domestic animal intrusion into the proposed open space areas on site: (L&L, 2024, p. 132) “Special edge treatments shall be implemented where development areas abut open space areas, including the installation of minimum 6-foot-tall exclusion fencing in areas abutting natural open space areas, which shall be subject to review and approval by the City of Corona. No gates or other openings are allowed along rear yard walls or fences that abut biological open space areas.” (SHSP, Subsection 5.3.8) Thus, the Project would be required to incorporate special edge treatments designed to separate development areas from open space areas, which would serve to minimize unauthorized public access, domestic animal predation, and illegal trespass and dumping within the on- and off-site open space areas. All fencing would be permanent and maintained in perpetuity. Approval of the fencing design also would be required by the City of Corona prior to Project initiation. The Project’s proposed fencing also would implement the requirements of SHP EIR PDF BIO-6, which requires the provision of barriers to separate development areas from open space areas, measures to restrict access to the open space areas, and to preclude impacts from domestic animal predation within the open space areas. It should be noted that PDF BIO-6 has been slightly modified as part of this Addendum to require only six-foot-tall fencing per the recommendations of the Project’s biologist and in order further the City’s goal to encourage the use of the Project’s trail system by bicycles and pedestrians. Additionally, the Project would be subject to the requirements of PDF BIO-7, which requires the posting of signage at the trail entrances to inform trail users to stay on trails to avoid impacting open space areas. In addition, and as required by SHP EIR PDF BIO-8, the Project Applicant would be required to provide Homeowner Educational pamphlets to inform them of the potential impacts by uncontrolled pets on native habitats and to request residents be good stewards of the land and prevent or limit their domestic cats from being allowed to openly hunt in the avoidance area. There are no components of the proposed Project that would have the potential to conflict with the barriers provisions of MSHCP Section 6.1.4. Accordingly, potential impacts due to a conflict with MSHCP Section 6.1.4 requirements related to barriers would be less than significant. (L&L, 2024, p. 132) Grading/Land Development
The MSHCP states that manufactured slopes associated with development shall not extend into the MSHCP Conservation Areas. As depicted on the grading plan included as part of TTM 36544R1, Project grading would not extend into the off-site areas that comprise MSHCP Core B. As such, and in accordance with SHP EIR PDF BIO-9 (listed at the end of this Subsection), the Project would not conflict with the MSHCP requirements related to grading and land development, and impacts would be less than significant.

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Project Consistency with MSHCP Section 6.3.2 (Additional Survey Needs and Procedures) In accordance with Section 6.3.2 of the MSHCP, Additional Survey Needs and Procedures, additional surveys may be needed for certain species in order to achieve coverage for these species. The query of the RCA MSHCP Information Map and review of the MSHCP determined that the Study Area is located within the designated survey area for Burrowing Owl (BUOW) as depicted in Figure 6-4 within Section 6.3.2 of the MSHCP. The Project site is not located within the survey area for any other species pursuant to MSHCP Section 6.3.2. (RCA, n.d.) Burrowing owl is currently designated as a California Species of Special Concern (SSC). The burrowing owl is a grassland specialist distributed throughout western North America where it occupies open areas with short vegetation and bare ground within shrub, desert, and grassland environments. Burrowing owls use a wide variety of arid and semi-arid environments with level to gently-sloping areas characterized by open vegetation and bare ground. The western burrowing owl (Athene cunicularia ssp. hypugaea), which occurs throughout the western United States including California, rarely digs its own burrows and is instead dependent upon the presence of burrowing mammals (i.e., California ground squirrels, coyotes, and badgers) whose burrows are often used for roosting and nesting. The presence or absence of colonial mammal burrows is often a major factor that limits the presence or absence of burrowing owls. Where mammal burrows are scarce, burrowing owls have been found occupying man-made cavities, such as buried and non-functioning drainpipes, stand-pipes, and dry culverts. They also require low growth or open vegetation allowing line-of-sight observation of the surrounding habitat to forage and watch for predators. In California, the burrowing owl breeding season extends from the beginning of February through the end of August.

Under the MSHCP burrowing owl is considered an adequately conserved covered species that may still require focused surveys in certain areas as designated in Figure 6-4 of the MSHCP. The Project site occurs within the MSHCP burrowing owl survey area and a habitat assessment was conducted for the species to ensure compliance with MSHCP guidelines for the species. In accordance with the MSHCP Burrowing Owl Survey Instructions (2006), survey protocol consists of two steps, Step I – Habitat Assessment and Step II – Locating Burrows and Burrowing Owls.

A focused study conducted in 2013 on the Project site found no BUOW or BUOW sign. A habitat assessment and burrow survey conducted in 2016 found no BUOW, no BUOW sign and no suitable burrows. An updated habitat assessment and burrow survey conducted in 2024 found no BUOW, no BUOW sign and no suitable burrows. BUOW is not expected to occupy large portions of the site due to high vegetation density and steep-walled canyons. As such, burrowing owls are presumed to be absent from the Project site. Although focused surveys conducted for the proposed Project determined that the burrowing owl is absent from the Study Area, there is nonetheless a potential for the site to become occupied with burrowing owls prior to construction activities. This finding is consistent with the conclusion reached by the SHP EIR, which imposed Mitigation Measure BIO-MM12 to require pre-construction clearance surveys. The SHP EIR concluded that with implementation of Mitigation Measure BIOMM12, impacts to the BUOW would be reduced to less-than-significant levels. Mitigation Measure BIO-MM12 has been revised as part of this Addendum No. 1 to the SHP EIR in order to provide more specific requirements related to the BUOW and to fully ensure all applicable MSHCP requirements are met. Accordingly, with implementation of the revised Mitigation Measure BIO-MM12, Project impacts to the burrowing owl would be reduced to less-than-significant levels. Thus, with implementation of the required mitigation the proposed Project would not conflict with MSHCP Section 6.3.2, and impacts would be reduced to less-than-significant levels. (L&L, 2024, pp. 77, 128)

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Conclusion of MSHCP Consistency
As indicated in the preceding analysis, the proposed Project has the potential to conflict with MSHCP Section 6.1.2 (due to Project impacts to ±10.51 acres riparian/riverine habitat), MSHCP Section 6.1.4 (due to the potential for introduction of invasive species), and MSHCP Section 6.3.2 (due to potential impacts to the burrowing owl). With mandatory compliance with applicable provisions from the CMC, the development standards and design guidelines contained within the proposed SHSP, and the SHP EIR mitigation measures (as modified/supplemented herein), the proposed Project would be fully consistent with all applicable provisions of the MSHCP. Consistent with the findings reached by the SHP EIR, Project impacts due to a conflict with the MSHCP would be reduced to less than significant levels. It also bears noting that the Project would disturb essentially the same area as identified for disturbance by the SHP EIR, and in fact, result in less total disturbance that the Approved Project. Thus, as a general matter, the SHP EIR already anticipated and analyzed all of the impacts to biological resources that would occur from the currently proposed Project. For all these reasons, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.

Mitigation Measures
The following mitigation measures from the SHP EIR shall apply, as modified/supplemented below, in order to reduce the Project’s potential impacts to biological resources to below a level of significance. Revisions/additions to the SHP EIR Mitigation Measures are shown below in strikeout/underline format. The revisions to the SHP EIR mitigation measure were incorporated in order to reflect current mitigation requirements for impacts to biological resources, and reflect more stringent requirements as compared to the mitigation measures included in the SHP EIR.

BIO-MM1 Biological Monitor/BMPs. The project impact areas and avoidance areas shall be flagged or fenced prior to clearing to prevent incursion into unsurveyed or avoided areas. A qualified biological monitor(s) shall monitor work activities during the initial clearing and grading phase of construction (including any ground or vegetation disturbance, demolition, fence installation, grading of existing roads, material delivery, etc.). The monitoring biologist shall ensure the flagging or fencing remains intact and no incursions into avoided areas occurs. The monitoring biologist shall examine each area of impact as the clearing/grading operations move into an uncleared native habitat area or into any area that has had a lapse in construction for more than 30 days to ensure no sensitive wildlife species are present. The biologist shall inspect debris piles, pipes, burrows, vegetation, leaf litter piles, and other potential refugia for sensitive wildlife species prior to initiation of clearing, grubbing, grading, or any other Project activity that may injure or kill sensitive wildlife species.

If wildlife is discovered, the biological monitor shall take appropriate action as defined in the mitigation measures, permit conditions, and regulations. The biological monitor may move wildlife or humanely encourage it to move out of harm’s way, if safe and feasible and permitted to do so.

Potential day roosts for pallid bat (e.g., caves, crevices, mines, hollow trees, buildings, etc.) shall be inspected by a qualified bat biologist prior to initial ground disturbance. If bats are roosting, a bat exclusion plan shall be prepared and submitted to CDFW for review prior to impacts. If a colony

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is discovered during the breeding season (March 1 -October 1), the biologist shall determine appropriate avoidance measures, including, but not limited to sound walls, buffers, and Project phasing/timing, to prevent disturbance to the colony until all young are weaned and capable of foraging independently.

Monitoring and survey activities shall be documented on a daily basis. All monitoring reports and communications shall be retained in Project files to allow review by the City of Corona, CDFW, and USFWS, if requested.

BIO-MM2 Special Status Botanical Species. Mitigation shall be provided forThe following measures shall apply to address and minimize potential impacts to Coulter’s matilija poppy, intermediate mariposa lily, and chaparral nolina to the extent feasible.  Impacts shall be minimized and avoided to the extent feasible. Prior to commencement of ground-disturbing activities (i.e., clearing and grading), Coulter’s matilija poppy and intermediate mariposa lily plants within the development footprint shall be salvaged for use in the Project area, avoidance area, or reuse in local restoration projects. In addition, a qualified botanist shall collect seeds from plants within the grading impact area during the spring or summer before grading commencement.
 Prior to commencement of ground-disturbing activities (i.e., clearing and grading), Iimpacts to chaparral nolina shall be mitigated through translocation and seed collection with propagation to an on-site or off-site preserved property acceptable to the City. Prior to any ground disturbance, the Applicant shall prepare a Chaparral Nolina Planting Plan (Plan) for chaparral nolina. The property shall be composed of habitat characteristics suitable to support chaparral nolina, including but not limited to: appropriate soils, elevation, and supporting chaparral or coastal sage scrub (or a combination thereof) habitat. The property shall be conserved via recordation of a conservation easement or deed restriction in favor of a California Department of Fish and Wildlife (CDFW)-due diligence approved local conservation entity to protect chaparral nolina on the property in perpetuity. Alternatively, the land may be transferred in fee title to a CDFW-approved local conservation entity. A management fund shall be established by the Applicant and will consist of an interest-bearing account with the amount of capital necessary to generate sufficient interest and/or income to fund all monitoring, management, and protection of the conservation area(s), including but not limited to, reasonable administrative overhead, biological monitoring, invasive species and trash removal, signage replacement and repair, law enforcement measures, long-term management reporting (as described below), and other actions designed to maintain and improve the habitat of the conserved land(s), in perpetuity.  Prior to commencement of ground-disturbing activities, a Property Analysis Record, or substantially equivalent analysis, shall be conducted by the Applicant and approved by the City to determine the management needs and costs described above, which then will be used to calculate the capital needed for the management of the fund. This management fund shall be held and managed by a CDFW-approved local conservation entity. To protect the mitigation area(s), the Project Applicant shall place appropriate signage around the perimeter of each

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site. Except for uses appropriate to a habitat conservation area, the public shall not have access to the mitigation area(s), and no activities shall be permitted within the mitigation areas, except maintenance of habitat, including the removal of nonnative plant species, trash, and debris, and the installation of native plant materials. Prior to any ground disturbance, the Applicant shall prepare a Chaparral Nolina Planting Plan (Plan) for chaparral nolina. The Plan shall require a replacement ratio of 1:1 by area, and ensure a minimum 90 percent survivorship at the end of a five-year monitoring period, which shall be verified by the monitoring biologist (minimum qualifications of the monitoring biologist are specified below).

At a minimum, the five-year plan shall include the following information:

5. a description of the existing conditions of the receiver site(s) characterizing the suitability of the site(s) for chaparral nolina, and documenting the acreage of the site,

6. a description of how the site will be preserved in perpetuity, e.g., conservation easement, deed restriction, etc., and the name of the CDFW-approved due diligence entity that will hold the easement/deed restriction, etc.,

7. qualifications of the monitoring biologist. At a minimum the monitoring biologist will possess a minimum of five-year's experience conducting habitat restoration projects in coastal sage scrub and/or chaparral habitat in Riverside County, California,

8. receiver site preparation for transplanting,

9. goals for success,

10. schedule,

11. propagation techniques,

12. transplant and seedling installation methods,

13. plant spacing,

14. performance criteria for success, including provision for control of non-native and invasive species,

15. monitoring and reporting procedures for each of the five years of the monitoring period,

16. adaptive management strategies, including a contingency plan should the site fail to meet the specified success criteria, and

17. maintenance requirements that will be reviewed and approved by the City. The Plan shall also ensure a mixture of both male and female plants.

BIO-MM3. Compensation Parcel. Prior to issuance of a grading permit, the project Applicant shall preserve a minimum of ten (10) acres (a 1:1 ratio) of natural habitat, which shall be biologically equivalent or superior to the Public/Quasi-Public (PQP) land the project site surrounds, and shall be located adjacent to USFS land. The compensation parcel shall either be:

1. Deeded in fee title to the United States Forest Service (USFS) or Western Riverside County Regional Conservation Authority (RCA) to ensure appropriate protection and permanent habitat management in perpetuity, or

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2. Conserved via recordation of a conservation easement or deed restriction in favor of a CDFWdue diligence approved local conservation entity.

BIO-MM4. Designate Unimpacted Areas as Open Space. Prior to recordation of Final Maps for each phase of the proposed development, Tthose areas of the project site not impacted by the project footprint, including Riparian/Riverine and excluding the minimum 10-acre preservation area identified in BIO-MM3, shall be conserved in perpetuity via the recordation of a conservation easement or deed restriction in favor of a CDFW-approved local conservation entity; or transferred in fee title to a CDFW-approved local conservation entity. The avoided Riparian/Riverine areas shall be conserved prior to issuance of a grading permit. The CDFW-approved local conservation entity shall manage the conservation areas to protect the long-term conservation, functions and values in-perpetuity.

BIO-MM5. Other Species to Avoid in Landscaping. Prior to issuance of grading permits, building permits, and/or road improvement plans, the Project Applicant shall prepare a landscape plan for review and approval by the City of Corona The landscape plan shall prohibit the use of The project Applicant shall add more common cultivar forms of Coulter’s matilija poppy to the list of plants to be avoided in site landscaping, including White Cloud matilija poppy. Additional non-native plants to be avoidedthat shall not be planted within any onsite mitigation or landscaping include coyote brush (Baccharis pilularis) and fourwing saltbush (Atriplex canescens). In addition, the landscape plan shall exclude those species identified in Table 6-2, Plants that Should be Avoided Adjacent to the MSHCP Conservation Area, of the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP). To ensure these non-native plants are not used in landscaping within the project site, the project Applicant shall include a list of plant species to avoid within the CC&Rs for the development. The project applicant shall also develop and distribute a suitable homeowner education package to residents / new owners covering the species to avoid.

BIO-MM6. Oak Tree Replacement. The project Applicant shall replace oak trees impacted by the project at a ratio consistent with the City of Corona oak tree conservancy policy (10.10.5), at no less than a 2:1 ratio. Replacement trees shall be located in undeveloped natural areas suitable to support these trees or in onsite mitigation areas where possible. If spacing requirements limit the number of replacement trees in these areas additional plantings may be located in landscaped areas as close to open space as feasible. All replacement trees shall be planted prior to issuance of the Certificate of Occupancy.

BIO-MM7. Riparian/Riverine. Prior to issuance of a grading permit, the project Applicant shall provide mitigation for ±10.5107 acres of Riparian/Riverine impacts at no less than a 2:1 basis, as determined through consultation with the City of Corona and wWildlife aAgencies based on their approval of the Determination of Biologically Equivalent or Superior Preservation (“DBESP”; see SHP EIR Addendum No. 1 Technical Appendix D2) that provides a functions and values analysis pursuant to the requirements of the MSHCP. The project Applicant proposes mitigation in the form of offsite mitigation with the Riverside-Corona Resource Conservation District (RCRCD) or other suitable approved organization with available credits. Currently, mitigation in banks is favored to preserve large areas of habitat where it is needed to fulfill the conservation goals of the

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MSHCP. In the event mitigation with the RCRCD is not finalized for any reason, the project Applicant shall provide equal or greater value mitigation in one or more of the following forms:
offsite acquisition and preservation, participation in an approved mitigation bank, onsite creation, offsite creation, enhancement, or reestablishment. If offsite mitigation is incorporated, the preferred choice shall be to find mitigation within or adjacent to the Santa Ana Watershed and in or adjacent to Corona if possible. In addition, some avoided resources within the open space areas shall be preserved to the extent feasible pursuant to a in an open space area and deed restrictioned or other appropriate legal mechanism to prevent future development.

If onsite mitigation is proposed as an alternative mitigation, the project Applicant shall prepare a Habitat Mitigation and Monitoring Plan (HMMP) shall be developed and provided for review and approval by local and regulatory agencies, which and shall include at a minimum the following components:
 Quantitative success criteria (vegetation cover and species richness);  Recommendations for soil preparation;
 A plant palette to include native species occurring on the site, such as coast live oak and Coulter’s matilija poppy;
 Planting methods;
 Irrigation and maintenance requirements; and
 A long-term mitigation maintenance and monitoring plan with remedial measures.

BIO-MM8. Storm Water Pollution Prevention Plan. Prior to the first ground disturbance issuance of a grading permit, the project Applicant shall prepare and implement a Storm Water Pollution Prevention Plan or for City of Corona review and approval of a Stormwater Pollution Prevention Plan (SWPPP), which shall identify all standard best management practices (BMPs) to prevent discharges from entering avoided jurisdictional drainages WoUS during construction. The required SWPPP shall at a minimum include BMPs shall that include but are not be limited to:
 Use of erosion control or sedimentation prevention methods, such as fiber rolls, sand bags, rice mats, straw wattles, or similar measures, where appropriate; and  Proper use and disposal of oil, gasoline, diesel fuel, antifreeze, and other toxic substances will be enforced.

Compliance with the City-approved SWPPP shall be required as a condition of grading permit approval, compliance with the SWPPP shall be required by bid documents issued to prospective construction contractors, and the Project construction contractors shall permit periodic inspection of the construction site by City of Corona staff or its designee to confirm compliance during all construction activities.

BIO-MM9. Regional Water Quality Control Board Permit. Prior to the issuance of a grading permit, to mitigate for the loss of 1.4857 acres and temporary loss of ±0.25-acre of State waters regulated by non-wetland WoUS due to project construction, project Applicant shall enter into an agreement with the U. S. Army Corps of Engineers (via issuance and implementation of a Nationwide permit

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or Individual permit) and with the California Santa Ana Regional Water Quality Control Board (via issuance and implementation of a Clean Water Act [CWA] Section 401 Certification) to replace permanently-impacted State waters as specified by the agreement with RWQCB affected WoUS and wetlands at a ratio specified by the U. S. Army Corps of Engineers and California Regional Water Quality Control Board, but at not less than a 2:1 basis, through offsite acquisition and preservation, participation in an approved mitigation bank, and/or on or offsite creation, enhancement, or reestablishment of WoUS State waters or a combination of these options.

Temporary impacts to RWQCB State waters shall be mitigated through on-site restoration within the temporarily impacted areas or as otherwise specified by the CWA Section 401 certification.

The exact ratio shall be based on a functions and values assessment included in the Project’s Determination of Biologically Equivalent or Superior Preservation (“DBESP”; see SHP EIR Addendum No. 1 Technical Appendix D1) and pursuant to RWQCB’s approval. Preparation of a Habitat Mitigation and Monitoring Plan (HMMP) outlining the details of the mitigation shall be required for any on-site mitigation or off-site mitigation on lands not already subject to an RWQCBapproved HMMP.

BIO-MM10. California Department of Fish and Wildlife Permit. Prior to the issuance of a grading permit, to mitigate for the loss of ±10.5107 acres of streambed and wetlands and the temporary loss of ±1.13 acres of streambed due to project construction, the project Applicant shall enter into an agreement with the California Department of Fish and Wildlife (CDFW) via issuance and implementation of a Section 1600 Streambed Alteration Agreement , Section 1600) to replace affected streambed at not less than a 2:1 basis (mitigation:impact) for permanent impacts and restoration of temporarily impacted areas to their existing/former condition, as specified by the California Department of Fish and Wildlife, through a combination of offsite acquisition and preservation, participation in an approved mitigation bank, and/or on or offsite creation, enhancement, or reestablishment of the streambed. The exact ratio shall be based on a functions and values assessment pursuant to CDFW’s approval of the required Streambed Alteration Agreement. Preparation of a Habitat Mitigation and Monitoring Plan (HMMP) outlining the details of the mitigation shall be required for on-site mitigation or off-site mitigation on lands not already subject to a CDFW-approved HMMP.

BIO-MM11. Nesting Birds. To prevent impacts to sensitive, migratory, and nesting birds (including raptors), clearing, or other work in native habitats, should shall be avoided during the critical nesting period of January 1 – September 1. If work cannot be avoided during this timeframe, a nesting bird survey shall be conducted by a qualified biologist within three (3) days prior to initiation of clearing and/or grading. A letter report documenting the clearance survey and its results shall be provided to the City of Corona prior to any disturbance to the Project site. If nesting birds are present, a nesting bird plan will shall be developed and implemented and to include appropriate measures to mitigate potential impacts, including maintaining a buffer area until fledging has occurred.

Active bird nests should shall be mapped utilizing a hand-held global positioning system (GPS) (getting as close as possible without disturbing the nest) and a buffer will be flagged around the nest (typically 300 feet for most species, 500-foot buffer for raptor nests), as determined appropriate by the biologist. Construction should not be permitted within the buffer area while

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the nest continues to be active (eggs, chicks, etc.). Once fledging has occurred no further avoidance is required.

BIO-MM12. Burrowing Owl. A pre-construction burrowing owl clearance survey shall be conducted by an experienced burrowing owl qualified biologist no more than 30 days before earth disturbance (construction). The survey will be conducted as close to the actual construction initiation date as possible. A letter report documenting the clearance survey and its results shall be provided to the City of Corona prior to any disturbance to the Project site and prior to commencement of grading activities. If owls are present, the project biologist will shall consult with local and state agencies, as appropriate, and develop a mitigation plan. Mitigation will be based on the following goals and requirements included in the MSHCP:

1. If the site contains or is part of an area supporting less than 35 acres of suitable habitat or the survey reveals that the site and the surrounding area supports fewer than three (3) pairs of burrowing owls, the onsite burrowing owls will be passively or actively relocated following accepted protocols.

2. Occupied nests shall be avoided during the nesting season (February 1 – August 31) and a buffer of 300 to 500 feet shall be employed, depending on the level of disturbance surrounding the burrow.

3. Burrow exclusion shall be utilized outside of the nesting season by installing a one-way door in burrow openings. The burrow shall be closed following verification burrows are empty (through site monitoring and scoping).

4. If the site (including adjacent areas) supports three (3) or more pairs of burrowing owls, supports greater than 35 acres of suitable habitat, and is non-contiguous with MSHCP Conservation Area lands, at least 90 percent of the area with long-term conservation value and burrowing owl pairs will be conserved onsite.

BIO-MM13. AMountain Lion Program. Prior to issuance of the first Certificate of Occupancy for each phase of development, a mountain lion (Puma concolor) program shall be developed by the project Applicant for City review and approval in an effort to reduce likelihood of human-lion conflicts.

The program shall include the following components:

1. A suitable homeowner education package for distribution to residents / new owners;

2. A suitable road sign program warning of the presence of mountain lions and the need for reduced speeds and increased caution;

3. A suitable CC&R provision limiting unsupervised outdoor pets and pet feeding practices that may encourage mountain lions to enter residential yards in search of food; and

4. A suitable mountain lion safety plan.

The Project’s CC&Rs shall include a provision specifically requiring future homeowners to comply with the requirements of the Mountain Lion Program.

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BIO-MM14. A qualified biologist shall monitor clearing and grubbing activities as they impact vegetation on the site. A qualified biologist shall inspect debris piles, pipes, burrows, vegetation, leaf litter piles, and other potential refugia for sensitive wildlife species prior to initiation of clearing, grubbing, grading, or any other project activity that may injure or kill sensitive wildlife species. If wildlife is discovered, the qualified biologist shall move it out of harm’s way or allow it to move safely out of the work area prior to initiation of project activities.

Potential day roosts for pallid bat (e.g., caves, crevices, mines, hollow trees, buildings, etc.) shall be inspected by a qualified bat biologist prior to initial ground disturbance. If bats are roosting, a bat exclusion plan shall be prepared and submitted to CDFW for review prior to impacts. If a colony is discovered during the breeding season (March-October), the biologist shall determine appropriate avoidance measures, including, but not limited to sound walls, buffers, and project phasing/timing, to prevent disturbance to the colony until all young are weaned and capable of foraging independently.

BIO-MM15. Homeowner Education Package (Invasive Species). Prior to issuance of occupancy permits, the Project Applicant shall develop for review and approval by the City of Corona, a homeowner education package providing and informing future occupants that the list of plant species identified in Mitigation Measure BIO-5 are prohibited and may not be planted on any individual lot. The homeowner education package also shall include a list of recommended non-prohibited plant species. A copy of the City-approved homeowner education package shall be provided to future owners/tenants as part of all future lease/sales agreements. Design guidelines for the proposed project shall provide the new homeowners with a list of native landscaping materials permitted within the development area. These materials have been selected for their contribution to the project theme, adaptability to local climatic and soil conditions, and for their compatibility with the unique natural environment in the area. None of the plants listed in Section 6.1.4 of the MSHCP will be utilized in the development and their use by future homeowners will be prohibited.

The MSHCP has identified invasive plants that should be removed from open space areas. This list is included in Table 6-2 of the MSHCP and in Appendix C, and shall be included in the CC&Rs prepared for the subdivision.

BIO-MM16. Invasive Vegetation Control – Heavy Equipment. All heavy equipment used onsite shall be washed, particularly the wheels and under carriage, prior to bringing it onto the project site from other construction sites to prevent the spread of weedy species.

BIO-MM17. Invasive Vegetation Control – Staging Areas. Staging areas shall be placed in areas that have been previously disturbed or have degraded habitat within the project footprint but do not show an infestation of non-native species. Staging areas shall be maintained in a weed/noxious weed-free condition.

BIO-MM18. All refuse created or brought onsite by clearing personnel or contractors shall be placed in covered containers, removed from the site daily, and disposed of properly.

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BIO-MM19. Field crews shall maintain the speed limit on posted roads and limit vehicle/truck speeds on unpaved surfaces to 15 miles per hour or less.

BIO-MM20. Urban/Wildlands Interface. Prior to issuance of grading or building permits, the City of Corona shall review the grading/building plans to ensure that measures Applicant shall ensure that the grading and building plans have incorporated the measures to meet the requirements of the The proposed project shall incorporate measures to meet MSHCP Urban/Wildlands Interface guidelines and requirements (see MSHCP Volume I, Part 2 of 2, subsection 6.1.4) with respect to These measures will address Drainage, Toxics, Lighting, Noise, Barriers, Access, Pets, and Grading/Land Development (See Section 9.5 of the BRA Report included in Appendix D to this Draft EIR).

Additional measures that have been included in this Addendum No. 1 to the SHP EIR based on current site conditions and changes to biological regulations, and area listed below.

BIO-MM21 Crotch’s Bumble Bee. In the event the Crotch’s bumble bee (Bombus crotchii) status is listed as candidate, threatened or endangered by the CDFW at the time of construction, the following measures shall be implemented.
 Clearing/ground-disturbing activities shall be prohibited from February 1 through September 30 within suitable habitat for the Crotch’s bumble bee. As part of this requirement, if construction is proposed during this period, a qualified biologist shall go out and mark all of the suitable habitat on site, which must be avoided and fencing provided around any accessible areas until at least September 30. A letter report documenting the actions performed and completion of this measure shall be provided to the City of Corona prior to any disturbance of the Project site. Construction activities may commence in areas outside of suitable habitat for the bee.
 For construction between October 1 and January 31, a pre-construction survey is required within suitable habitat to confirm that no nests occur on site. Should any nests be identified, the Project biologist shall consult with CDFW to determine if permits are required. Clearance within that portion of the property determined by the biologist to support a nest and a suitable buffer shall be avoided until consultation with the CDFW determines activities can resume or the site is no longer occupied. If the pre-construction survey identifies no nests, then construction activities may proceed as normal. A letter report documenting the actions performed and completion of this measure shall be provided to the City of Corona prior to any disturbance of the Project site. If consultation with the CDFW is required a second letter report shall be provided documenting the CDFW determination, requirements and approval prior to moving forward with construction activities on that portion of the Project site.  Pesticides considered harmful to the Crotch bumble bee shall be prohibited during construction.

BIO-MM22 Workers Environmental Awareness Program. All persons employed or otherwise working on the Project site during the vegetation clearing and grading phase of construction shall attend a

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Workers Environmental Awareness Program (WEAP) training. All workers must attend WEAP training prior to performing any work on-site. The WEAP shall consist of a presentation (either provided in person by the biological monitor or a recorded training session) that includes a discussion of the biology of the habitats and species that may be present at the site. The WEAP shall also include information about the special-status plant and wildlife species that may be present, legal protections for those species, penalties for violations, and mitigation measures. The WEAP shall include but not be limited to burrowing owl, nesting birds, and other special-status species. The WEAP shall also include information on weed control practices, appropriate trash disposal, fire prevention and procedures for smoking, spill prevention and procedures, jurisdictional waters and SWPPP, BMPs, biological monitors and compliance responsibilities, and other issues such as pets, firearms, etc. Attendance at training shall be documented and construction workers provided with a hardhat sticker. Supporting materials shall be provided to all personnel during the training program, including contact information for the biological monitor and/or other compliance personnel. Informal or formal refresher training shall be conducted as needed to maintain compliance.

BIO-MM23 Restoration. Prior to final grading inspection, temporary impact areas associated with the haul road required during site mass grading activities shall be restored to its former condition.

BIO-MM24 Invasive Species Restrictions and CC&Rs. Prior to issuance of occupancy permits, the Project Applicant shall provide the City of Corona with a copy of the Project’s Codes, Covenants, and Restrictions (CC&Rs). The Project CC&Rs shall explicitly prohibit the planting of the non-native plant species identified by Mitigation Measure BIO-5.

PDF BIO-1 Drainage. The project incorporates project streets, open channels and natural drainage courses as well as a comprehensive system of underground storm drains to handle storm runoff from the project site. Storm water from the project site and off-site areas will be directed to storm drains.

The design and operation of the drainage channel shall be adequate to preclude discharge of water into open space areas that are of lower quality or higher quality than current conditions.

The proposed development shall incorporate measures, including measures required through the NPDES requirements, to ensure that the quantity and quality of runoff discharged to the open space area is not altered in an adverse way when compared with existing conditions. In particular, measures shall be put in place to avoid discharge of untreated surface runoff from developed and paved areas into open space areas. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials, or other elements that might degrade or harm biological resources or ecosystem processes within open space areas. This will be accomplished using a variety of methods including natural detention basins, grass swales, or mechanical trapping devices. Regular maintenance shall occur to ensure effective operations of runoff control systems.

PDF BIO-2 Toxics. The proposed project is designed to utilize natural drainage patterns for the flow of surface water. Water Quality Best Management Practices (BMPs) include education, storm drain stenciling, and street sweeping in compliance with the City of Corona’s requirements. The earthen channel shall be signed to filter potential toxics in the storm water prior to its discharge into open

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space areas. These BMPs will be implemented as part of the storm water pollution prevention measures for the project, in accordance with all appropriate NPDES requirements. The project would result in the additional use of hazardous materials in limited quantities associated with normal residential use such as cleaning products, solvents, herbicides, and insecticides. However, compliance with regulations will reduce the potential risk of hazardous material exposure to a level that is less than significant. An information pamphlet has been prepared for each homeowner regarding the use of toxics.

PDF BIO-3 Lighting. Outdoor lighting of residences will be designed so that all direct beams would be confined to dwelling sites. Project lighting will not intrude into the open space conservation areas.

Street lighting, parking lot lighting, and other project-related illumination sources will be positioned, directed, and shielded so as to avoid “light spill” into the conserved areas. The proposed project will avoid any night lighting adjacent to the open space areas. Night lighting will not be used during the course of construction unless absolutely necessary. If necessary, the lights will be directed and shielded to minimize lighting of the surrounding habitat. The level of off-site lighting and lighting fixtures would comply with the applicable requirements and policies of the City of Corona.

PDF BIO-4 Noise. The proposed project incorporates landscape elements including trees, shrubs, and groundcover, which will assist in noise reduction on the project site. In addition, a noise analysis prepared for the project found that no proposed on-site or surrounding sensitive land uses would experience long-term noise levels in excess of 65 dBA during the daytime hours under build-out of the proposed project. This daytime noise level would not result in exterior nighttime levels greater than 45 dBA. Therefore, no noise created on the project site would exceed residential noise standards.

PDF BIO-5 Invasives. Exotic Vegetation Control – Design guidelines for the project will provide the homeowners with a list of native landscaping materials permitted within the project site. These materials have been selected for their contribution to the project theme, adaptability to local climatic and soil conditions, and for their compatibility with the unique natural environment in the project site. The MSHCP has identified exotic invasive plants that should be areas avoided adjacent to the MSHCP Conservation Area in Table 6-2, Section 6.1.4 of the MSHCP; none of these plants will be utilized for the proposed project and their use by future homeowners will be prohibited.

PDF BIO-6 Barriers. The proposed project will include theme walls along project perimeter streets adjacent to public streets, and will include walls and fencing located where public view and/or important interfaces are of concern. The proposed project will incorporate special edge treatments designed to separate development areas from open space areas. These areas of native landscaping and fencing will serve to minimize unauthorized public access, domestic animals predation, and illegal trespass and dumping. Exclusion fencing will be permanently placed where development abuts avoided and adjacent open space areas. The exclusion fence will be a minimum of eight six feet in height and will be installed and maintained for the purposed of controlling human and pet access (cats and dogs) into the open space area and be in compliance with MSHCP requirements. The

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fencing will be permanent and will be maintained in perpetuity. Approval of the fencing design will be required by the City of Corona prior to project initiation.

PDF BIO-7 Access. Access points between native habitats and the project development will be posted with signage requesting residents to stay on the trails and not to disturb habitat. Yard fencing with no back gate will reduce access to native habitats adjacent to the project.

PDF BIO-8 Pets. Uncontrolled pets, feral dogs and cats can predate on native wildlife species. Appropriate signage will be posted requesting residents leash their pets. Homeowner Educational pamphlets will be used to inform them of the potential impacts by uncontrolled pets on native habitats and to request residents be good stewards of the land and prevent or limit their domestic cats from being allowed to openly hunt in the avoidance area.

PDF BIO-9 Grading/Land Development. All manufactured slopes associated with site development will be within the project site and there will be no impact to the MSHCP Conservation Area. All manufactured slopes that abut the natural open space will be retained as open space buffer zones.

All manufactured slopes and areas disturbed by construction of these slopes will be revegetated with appropriate non-invasive buffer species during project construction.

2.5 Cultural Resources
New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially Reduce
Significant Impact
No Substantial
Change from
Previous Analysis
Would the Project:
a. Cause a substantial adverse change in the
significance of a historical resource as
defined in Section 15064.5 of the State
CEQA Guidelines?
☐ ☐ ☐ ☒
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to State CEQA Guidelines Section
15064.5?
☐ ☐ ☐ ☒
c. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
☐ ☐ ☐ ☒
d. Disturb any human remains, including those
interred outside of formal cemeteries? ☐ ☐ ☐ ☒
e. Conflict with an applicable plan, policy, or
regulation adopted for purposes of avoiding
or mitigating physical impacts associated
with cultural resources?
☐ ☐ ☐ ☒

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ENVIRONMENTAL ANALYSIS
In order to evaluate the proposed Project’s potential impacts to cultural and paleontological resources, two Project-specific technical studies were prepared for the Project by BFSA Environmental Services (herein, “BFSA”).

The first report is a Cultural Resources Assessment (herein, “CRA”) titled, "A Phase I Cultural Resources Assessment for the Skyline Heights Project," dated October 26, 2023, and included as Technical Appendix E to this EIR Addendum (BFSA, 2023a). The second report addresses paleontological resources, is titled, “Paleontological Sensitivity Update and Revised Monitoring Recommendations for the Skyline Heights Project, City of Corona, Riverside County, California (Sch. No. 2014021003)” (herein, “PRA”) is dated October 26, 2023, and is included as Technical Appendix F to this EIR Addendum (BFSA, 2023b). a) Would the Project cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the State CEQA Guidelines? Skyline Heights Project EIR Findings: No Impact. The SHP EIR found that no historic resources are located on the SHP site. As such, the SHP EIR found that there is no potential for the SHP to cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the CEQA Guidelines. The SHP EIR concluded that no impact would occur. (Corona, 2015, p. 4.D-14) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. As discussed in further detail in Subsection 4.2 of the Project’s CRA (Technical Appendix E), in April and May of 2013, LSA (2014) completed a Phase I Cultural Resources Assessment of the Project site. The survey resulted in the relocation of the Sky Ranch site (identified as Site P-33-016976) and the identification of an erosion control system composed of approximately 30 circa 1940s to 1950s automobiles buried on their side (identified as Site P-33-029450). The Sky Ranch was previously identified by LSA in 2006 and recorded in 2008 by SWCA. SWCA recorded a “small masonry shed, a metal water tank, a concrete residence and aircraft hangar foundations, arroyo stone walls and bridge, and other remnant landscaping features. While the majority of the site was determined to be ineligible for listing on the California Register of Historical Resources (CRHR) according to CEQA criteria, SWCA evaluated the bridge feature as eligible for listing on the CRHR as a separate property. Although ground visibility was poor, LSA relocated all of the features identified by SWCA and noted that the site appeared to be generally unchanged from the previous survey conducted in 2008 by SWCA. While the automobile erosion control system was noted, the feature was not formally recorded, as “its origin and date of deposition could not be determined…” As a result, no previouslyunrecorded cultural resources were identified within the Project area as a result of the 2013 Cultural Resources assessment and LSA recommended monitoring of all ground-disturbing activities within the project area “on a part-time (spot-check) basis.” (BFSA, 2023a, p. 4.0-16) An updated site reconnaissance was conducted for the Project site by BFSA in June 2023. The archaeological survey of the property conducted by BFSA was a reconnaissance consisting of a series of parallel survey transects spaced at 10-meter intervals. Generally, visibility throughout the property was very poor, with just five percent of the ground surface visible. A small portion of the property was developed with paved roads and dirt bike trails (approximately five percent). Vegetation observed throughout the property included primarily inland sage scrub and riparian communities, with a small quantity of eucalyptus noted. The cultural resources survey resulted in the relocation of a portion of the Sky Ranch site and the erosion control feature. No additional prehistoric or historic archaeological resources were identified during the survey conducted by BFSA. (BFSA, 2023a, p. 4.0-16)

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The Sky Ranch site (Site P-33-016976) was relocated and identified in very poor condition. Of the recorded features, the hangar foundations, a demolished structure foundation, and an arroyo stone wall were identified (Plates 4.2–3 through 4.2–6). No other features, including the CRHR-eligible bridge feature, could be relocated. As a result of the survey, the previous determination of Site P-33-016976 as being ineligible for listing on the CRHR was confirmed. (BFSA, 2023a, p. 4.0-16)
In addition to the Sky Ranch site features, the erosion control feature, consisting of the circa 1940s to 1950s automobiles, was relocated by BFSA. Aerial photographs indicate that the feature likely was created after 1980.

However, given that the approximate manufacture dates of the automobiles are older than 50 years in age, they were recorded as a new resource (Site P-33-029450). While Site P-33-029450 is associated with the property, it does not appear to be directly linked to it, since the property was vacant at the time it was created. Therefore, a firm connection between Site P-33-029450 and Site P-33-016976 could not be established. Site P-33-029450 is not associated with any individuals or events important to local, State, or national history. Further, this feature could not be tied to any great architectural works or the work of a master architect, artist, or builder. In addition, the automobiles are severely rusted, crushed, and demolished, lacking all original integrity. Therefore, the erosion control feature consisting of circa 1940s to 1950s automobiles does not constitute a significant historical resource according to CEQA criteria and is not eligible for listing on the CRHR. (BFSA, 2023a, p. 4.0-21) In summary, although both Site P-33-029450 nor Site P-33-016976 were relocated during the 2023 site reconnaissance conducted by BFSA, these features were determined to be ineligible for listing on the CRHR. In addition, no other historical resources were identified on the Project site during the 2023 or prior surveys.

Accordingly, and consistent with the conclusion reached by the SHP EIR, implementation of the proposed Project would not result in any impacts to any known historical resources, and impacts would be less than significant.

Therefore, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. b) Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines Section 15064.5?
Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The SHP EIR found that implementation of the SHP would not cause a substantial adverse change in the significance of a known archaeological resources pursuant to Section 15064.5 of the CEQA Guidelines. However, the SHP found that there is a potential for the SHP project to impact previously undiscovered archaeological resources during construction activities. The SHP EIR imposed Mitigation Measure CR-1, which the SHP EIR found would reduce impacts to below a level of significance. (Corona, 2015, pp. 4.D-15 to 4.D-16) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. As noted under the analysis of Threshold a), the 2023 archaeological survey conducted by BFSA resulted in the relocation of the Sky Ranch property site (Site P-33-016976) and the erosion control feature consisting of 1940s to 1950s vehicles (Site P-33- 029450). However, the previously-recorded Sky Ranch Arroyo Bridge feature that was recommended as eligible for the CRHR could not be relocated. The Sky Ranch property was found in poor condition and was previously determined as not eligible for the CRHR; BFSA concurs with this determination. The row of 1940s to 1950s vehicles was recorded as a new site, Site P-33-029450, and was evaluated as not eligible for the CRHR according to CEQA

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criteria. As designed, the CRHR-eligible Sky Ranch bridge feature would not be impacted by the proposed development. In addition, no previously-unrecorded prehistoric cultural resources were identified during the survey. Therefore, and consistent with the findings reached by the SHP EIR, the proposed Project would not impact any significant archaeological resources as defined by CEQA Guidelines Section 15064.5(a), and no impacts to known archaeological resources would occur with implementation of the Project. (BFSA, 2023a, p. 5.0-1) Although impacts to previously-discovered archaeological resources would not occur, the Project area is located in an area of high cultural resources sensitivity, given the access to multiple natural sources of water throughout the property and the ecological setting (plants and animals available) of the property. The ground surface visibility of the property was very poor, with only five percent of the ground surface visible at the time of the survey.

Therefore, and consistent with the findings of the SHP EIR, the potential exists that buried prehistoric cultural deposits may be present within the development envelope. The proposed Project would be subject to compliance with the mitigation measures identified by the SHP EIR (as modified/supplemented herein). Specifically, grading and ground-disturbing activities would be monitored by an archaeological monitor and Native American monitor, as required by SHP EIR Mitigation Measure CR-1. SHP EIR Mitigation Measure CR-1 further requires appropriate treatment of any newly-discovered cultural resources, including the development of avoidance strategies, capping with fill material, or mitigation of impacts through data recovery programs such as excavation or detailed documentation. Such monitoring also would be required to be conducted pursuant to a Treatment Agreement between affected Tribes. Consistent with the conclusion reached by the SHP EIR, implementation of Mitigation Measure CR-1 would reduce the Project’s potential impacts to previously-undiscovered cultural resources to below a level of significance. Therefore, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. (BFSA, 2023a, p. 5.0-1)
c) Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Skyline Heights Project EIR Findings: Less-than-Significant Impact With Mitigation Incorporated. The SHP EIR found that implementation of the SHP could directly impact paleontological resources during construction activities. The SHP EIR found that this potentially significant impact would be reduced to a less-than-significant level with implementation of SHP EIR Mitigation Measures CR-2 to CR-4. (Corona, 2015, p. 4.D-16) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. An updated paleontological resource assessment report for the SHP was prepared in support of the SHP EIR by LSA in 2013 (herein, “2013 PRA”), which was included in Appendix E to the SHP EIR. In the 2013 PRA, three geologic formations present at the project were found to have a high potential to yield significant nonrenewable paleontological resources during earth disturbance activities. The 2013 PRA recommended that a Paleontological Resources Impact Mitigation Program (PRIMP) be implemented to reduce potential impacts to paleontological resources during earth disturbance activities. In a 2014 supplementary study prepared by LSA and updating their 2013 assessment (herein, “2014 PRA Update”), LSA revised their 2013 PRA, adding several parcels to the analysis. With the addition of the new parcels, LSA expanded their previous record search, concluded that four mapped geologic units (1:
undifferentiated Williams and Ladd Formations; 2: Baker Canyon Conglomerate Member of the Ladd Formation; 3: Ladd Formation; 4: Silverado Formation) are potentially fossiliferous, and recommended that a PRIMP be implemented. The 2014 PRA Update indicated the Pleistocene and Holocene-aged deposits mapped at the SHP

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site “are generally considered too coarse or too young to contain significant vertebrate fossils in a meaningful stratigraphic context,” but the 2014 PRA Update did not provide guidance for their treatment, should they be encountered during excavation or grading activities. (BFSA, 2023b, pp. 1-2) The City of Corona adopted its current General Plan in 2020 and concurrently certified an EIR. General Plan Figure HR-1 and Figure 5.7-6 of the General Plan EIR depict a city-wide map presenting levels of paleontological sensitivity assigned to geologic formations. The map is the result of a tabulation of every mapped geologic formation within Corona and the Corona sphere of influence, with a rating of paleontological sensitivity assigned to each formation.

Ratings of None, Low, Low-to-High, High, and Unknown are provided. Based on these classifications, Table 21, Project Site Paleontological Sensitivity, summarizes the paleontological sensitivity of the Project site.

As shown in Table 21, the paleontological sensitivity geologic formations within the on-site drainages are classified as having “Low-to-High” paleontological sensitivity, while the majority of the property is classified as having a “High” sensitivity for containing paleontological resources. The General Plan identifies a “low-to-high” sensitivity as where “[s]ome sedimentary deposits are too young to preserve fossils at the surface or shallow subsurface but may preserve fossils at greater depth or overlie older units that have high paleontological sensitivity.” A “high” sensitivity is defined as “…. geologic formations that are known to preserve abundant or scientifically significant fossils, therefore giving them high sensitivity to paleontological resources.” (Corona, 2020, p. HR-16) Table 21 Project Site Paleontological Sensitivity
Geologic Formation Geologic Age Paleontological Sensitivity Young alluvial fan deposits Holocene and late Pleistocene Low-to-High Young alluvial (axial) channel deposits Holocene and late Pleistocene Low-to-High Young landslide deposits Holocene and late Pleistocene Low-to-High Very old alluvial fan deposits Early Pleistocene High
Silverado Formation Paleocene High
Williams and Ladd Formations,
undifferentiated
Upper Cretaceous High
Ladd Formation Upper Cretaceous High
Ladd Fm., Baker Canyon Conglomerate
Member
Upper Cretaceous High
(BFSA, 2023b, p. 5)
Based on the Project’s proposed grading plan, it is not anticipated that the Project would require grading at depths that may potentially encounter paleontological resources within the portions of the Project site that are considered to have a “Low-to-High” sensitivity for paleontological resources. As such, and consistent with the conclusion reached by the SHP EIR, Project impacts to paleontological resources within the on-site drainages would be less than significant. However, the majority of the remaining portions of the Project site are considered to have a “high” sensitivity for paleontological resources. Thus, and consistent with the conclusion reached by the SHP EIR, Project impacts to paleontological resources would be potentially significant within the portions of the Project site containing the following geologic formations (as shown on Figure 1 of the Project’s PRA, included as Technical Appendix F): 1) Very old alluvial fan deposits; 2) Silverado Formation; 3) Williams and Ladd Formations, undifferentiated; 4) Ladd Formation; and 5) Ladd Fm., Baker Canyon Conglomerate Member. (BFSA, 2023b, p. 7)

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However, the proposed Project would be subject to compliance with SHP EIR Mitigation Measures CR-2 through CR-4 requiring the preparation and implementation of a PRIMP. Consistent with the finding of the SHP EIR, implementation of SHP EIR Mitigation Measures CR-2 through CR-4 would reduce the Project’s potential impacts to paleontological resources to below a level of significance. Therefore, with implementation of SHP EIR Mitigation Measures CR-2 through CR-4, the proposed Project would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. (BFSA, 2023b, p. 7)
d) Would the Project disturb any human remains, including those interred outside of formal cemeteries? Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR found that in the unlikely event human remans are discovered during grading or construction activities within the site, compliance with State law (Health and Safety Code Section 7050.5) would be required and would mitigate for potential impacts to human remains. Therefore, the SHP EIR concluded that impacts related to the discovery of buried human remains would be less than significant and no mitigation is necessary. (Corona, 2015, pp. 4.D-16 to 4.D-17) EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. Consistent with the findings of the SHP EIR, the Project site is not a designated cemetery, nor is it located adjacent to one. There is no known history of human remains being interred outside formal cemeteries on the site, nor is the site recognized as being situated on a burial ground or having previously yielded human remains. Nevertheless, the remote potential exists that human remains may be unearthed during grading and excavation activities associated with Project construction.

If human remains are unearthed during Project construction, the construction contractor would be required by law to comply with California Health and Safety Code, § 7050.5, “Disturbance of Human Remains.” According to § 7050.5(b) and (c), if human remains are discovered, the County Coroner must be contacted and if the Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner is required to contact the Native American Heritage Commission (NAHC) by telephone within 24 hours. Pursuant to California Public Resources Code § 5097.98, whenever the NAHC receives notification of a discovery of Native American human remains from a county coroner, the NAHC is required to immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of the discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. According to Public Resources Code § 5097.94(k), the NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials. Consistent with the conclusion reached by the SHP EIR, mandatory compliance with the applicable provisions of California Health and Safety Code § 7050.5 and California Public Resources Code § 5097 et. seq. would ensure that Project impacts to human remains would be less than significant.

Therefore, and based on the preceding analysis, Project impacts to human remains would be less than significant with mandatory regulatory compliance, and as such the proposed Project would not result in any new impact not

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already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR.
e) Would the Project conflict with an applicable plan, policy, or regulation adopted for purposes of avoiding or mitigating physical impacts associated with cultural resources? Skyline Heights Project EIR Findings: Less-than-Significant Impact. The SHP EIR found that implementation of the SHP would not conflict with an applicable plan, policy, or regulation adopted for the purpose of avoiding or mitigating physical impacts associated with cultural resources, and therefore concluded that impacts would be less than significant. (Corona, 2015, pp. 4.D-17 to 4.D-19)
EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. The SHP EIR was certified in 2017.

However, subsequent to certification of the SHP EIR, the City of Corona City Council adopted an update to the City’s General Plan in 2020, with the most recent amendment to the General Plan occurring in April 2024.

Accordingly, Table 22, Project Consistency with General Plan Policies Related to Cultural Resources, provides an updated analysis of the proposed Project’s consistency with the 2020 General Plan policies related to cultural resources. As indicated in Table 22, the Project would be consistent with, or otherwise would not conflict with, all applicable goals and policies of the General Plan with respect to cultural resources. Accordingly, Project impacts due to a conflict with General Plan goals and policies related to cultural resources would be less than significant.

Therefore, implementation of the Project would not result in any new impacts not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified in the SHP EIR.

Table 22 Project Consistency with General Plan Policies Related to Cultural Resources Goal/Policy Project Consistency
Goal HR-1: A comprehensive historic resource
management program that identifies, designates, and
protects resources that are significant to the historic development, identity, and character of Corona
Not Applicable. Goal HR-1 provides direction to City staff and decision makers regarding implementation of a
comprehensive historic resource management program,
and is unrelated to the proposed Project.

Notwithstanding, the Project would result in less-thansignificant impacts to historic resources, as no such resources are known to occur on the site and none are
likely to be uncovered during site grading activities.

Policy HR-1.1: Continue to implement and expand upon,
as feasible, the following historic resources management strategies:
• A local Corona Historic Register that includes
significant “Landmark” properties, “Historic Districts,” and “Historical Markers” as prescribed in the Corona
Municipal Code.
• A Corona Heritage Inventory that includes surveyed
properties meeting all the criteria as prescribed in the Corona Municipal Code to be considered a local
historic resource.
• Procedures and criteria for determining the eligibility for listing properties on the Corona Historic Register
and the Corona Heritage Inventory.

Not Applicable. Policy HR-1.1 provides direction to City staff and decision makers regarding historic resources
management strategies, and is unrelated to the proposed Project. Notwithstanding, the Project would result in lessthan-significant impacts to historic resources, as no such resources are known to occur on the site and none are
likely to be uncovered during site grading activities.

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Goal/Policy Project Consistency
• Standards and regulations governing the identification, protection, restoration, maintenance, alteration,
relocation, or removal of historic resources.

Policy HR-1.2: Expand existing surveys of historic resources to include areas of potential historic importance not
previously surveyed, and develop an ongoing program for updating the surveys on a regular basis.

Consistent. The Project’s CRA included an updated site
investigation that confirmed the presence of two
previously-identified historic resources, both of which were determined to be ineligible for listing in the CRHR.

Policy HR-1.3: Continue to implement criteria and
guidelines for the inclusion of historic resources and
historic structures for the Historic Register and Heritage Inventory, including but not limited to: sites, parks,
landscape elements, streets, streetlights, signs,
monuments, murals, and public art.

Not Applicable. Policy HR-1.3 provides direction to City staff and decision makers regarding implementation of
criteria and guidelines for the inclusion of historic
resources in the Historic Register and Heritage Inventory.

Notwithstanding, the Project’s CRA included an updated
site investigation that confirmed the presence of two
previously-identified historic resources, both of which were determined to be ineligible for listing in the CRHR.

Policy HR-1.4: Continue to implement and expand upon
preservation incentive programs that encourage property owners to preserve, restore, and maintain historic
properties, and secure public and private funding sources to assist in said preservation.

Not Applicable. Policy HR-1.4 provides direction to City staff and decision makers regarding the implementation
and expansion of preservation incentive programs that
encourage property owners to preserve, restore, and
maintain historic properties, and is unrelated to the
proposed Project, which would result in less-thansignificant impacts to historical resources.

Policy HR-1.5: Support the preservation of historic
resources controlled by other governmental agencies,
including those related to federal, state, county, school district, and other agencies. This includes resources under the jurisdiction of the Army Corps of Engineers at Prado Basin.

Not Applicable: Policy HR-1.5 provides direction to City staff and decision makers regarding providing support for the preservation of historic resources controlled by other agencies, and is unrelated to the proposed Project.

Policy HR-1.6: Seek and support City-sponsored, nonprofit, and privately sponsored public events and festivals, as feasible, that recognize and promote the cultural and
historic heritage of Corona.

Not Applicable: Policy HR-1.6 provides direction to City staff and decision makers to support public events and
festivals promoting the cultural and historic heritage of the City of Corona, and is unrelated to the proposed Project.

Goal HR-2: Promote the retention, restoration, adaptive reuse, and maintenance of historic structures and
properties in a manner that will conserve the integrity of the resource in the best possible condition.

Not Applicable: Goal HR-2 provides direction to City staff and decision makers regarding the retention, restoration, adaptive reuse and maintenance of historic structures and properties. Based on the results of the Project’s CRA, the Project site does not include any historic resources eligible for listing on the CRHR; thus, Goal HR-2.1 is not applicable to the proposed Project.

Policy HR-2.1: Assist and encourage property owners and tenants to maintain the character and integrity of the
historic resource, and to restore and reuse historic
properties in a manner compatible with their original
architectural style.

Not Applicable: Policy HR-2.1 provides direction to City staff and decision makers to assist property owners and tenants to maintain the character and integrity of historic resources. Based on the results of the Project’s CRA, the Project site does not include any historic resources eligible for listing on the CRHR; thus, Policy HR-2.1 is not applicable to the proposed Project.

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Goal/Policy Project Consistency
Policy HR-2.2: Continue to implement design guidelines for restoring historic and architecturally significant structures, including but not limited to, the Secretary of the Interior’s Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings.

Not applicable: Policy HR-2.2 provides direction to City staff and decision makers regarding the implementation of design guidelines for restoring historic and architecturally significant structures. Based on the results of the Project’s CRA, the Project site does not include any historic
resources eligible for listing on the CRHR; thus, Policy HR2.2 is not applicable to the proposed Project.

Policy HR-2.3: Develop an inventory of information and
resources regarding the proper rehabilitation techniques to assist owners and developers of historic buildings.

Not applicable: Policy HR-2.3 provides direction to City staff and decision makers to develop an inventory of
information and resources regarding the proper
rehabilitation techniques to assist owners and developers of historic buildings, and is unrelated to the proposed Project.

Policy HR-2.4: Administer the State Historic Building Code to facilitate the restoration and rehabilitation of historic structures in a manner that is more appropriated to older structures than the standard building codes.

Not Applicable: Policy HR-2.4 relates to historic buildings, while the results of the Project’s CRA indicate the Project site does not include any historic resources eligible for listing on the CRHR; thus, Policy HR-2.4 is not applicable to the proposed Project.

Policy HR-2.5: Require all modifications to historic
properties to be consistent with the Secretary of the
Interior’s “Standards for the Treatment of Historic
Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings” or
“Standards for Rehabilitation and Guidelines for
Rehabilitating Historic Buildings.”
Not Applicable: Policy HR-2.5 relates to historic properties, while the results of the Project’s CRA indicate the Project site does not include any historic resources eligible for listing on the CRHR; thus, Policy HR-2.5 is not applicable to the proposed Project.

Goal HR-3: Recognize the importance of archeological and paleontological resources and ensure the identification and protection of those resources within the City of Corona.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which would reduce the Project’s potential impacts to
archaeological and paleontological resources to below a level of significance.

Policy HR-3.1: Require appropriate treatment/preservation of archaeological collections in a culturally appropriate manner, in accordance with state and federal standards, and in consultation with interested Native American tribes that have traditional cultural affiliation with the project area and/or the resources affected by the project.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.1.

Policy HR-3.2: Require that development proposals
incorporate specific measures to identify, protect, and preserve cultural resources in the planning, environmental review, and development process.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.2.

Policy HR-3.3: Archaeological resources found prior to or during construction shall be evaluated by a qualified
archaeologist and appropriate mitigation measures
applied, pursuant to § 21083.2 of CEQA, before the
resumption of development activities. Any measures
applied shall include the preparation of a report meeting professional standards, which shall be submitted to the Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.3.

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Goal/Policy Project Consistency
appropriate CHRIS information center.

Policy HR-3.4: Any project that involves earth-disturbing activities in an area determined to be archaeologically or culturally sensitive shall require evaluation of the site by a qualified archaeologist. The applicant shall implement the recommendations of the archaeologist, subject to the
approval of the City. Planning Department.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.4.

Policy HR-3.5: Any project that involves earth-disturbing activities in an area determined to be archaeologically or culturally sensitive shall require consultation by the
applicant with interested federally recognized American Indian Tribe(s) that have a traditional cultural affiliation with the project area and/or the resources affected by the project, for the purposes of determining resources impacts and appropriate mitigation to address such impacts.

Applicant shall also arrange for monitoring of earthdisturbing activities by interested federally recognized American Indian Tribe(s) that have a traditional cultural affiliation with the project area and/or the resources
affected by the project, if requested.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.5.

Policy HR-3.6: Any project that involves earth-disturbing activities in soil or rock units known or reasonably
suspected to be fossil-bearing shall require monitoring by a qualified paleontologist retained by the project applicant for the duration of excavation or trenching.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.6.

Policy HR-3.7: Paleontological resources found prior to or during construction shall be evaluated by a qualified
paleontologist, and appropriate mitigation measures
applied, pursuant to § 21083.2 of CEQA, before the
resumption of development activities. Any measures
applied shall include the preparation of a report meeting professional standards, which shall be submitted to the Riverside County Museum of Natural History.

Consistent: The Project would be subject to compliance
with the mitigation measures presented in the SHP EIR,
which implement the requirements of Policy HR-3.7.

Policy HR-3.8: In the event of the discovery of a burial, human bone, or suspected human bone, all excavation or
grading in the vicinity of the find shall halt immediately and the area shall be protected and the project applicant immediately shall notify the Riverside County Coroner and comply with provisions of the Health and Safety Code §
7050.5, including PRC § 5097.98, if applicable. If the find is determined to be Native American human remains, the
applicant shall consult with the Most Likely Descendent to determine appropriate treatment for such remains.

Consistent: The Project would be subject to compliance
with the applicable provisions of California Health and Safety Code § 7050.5 and California Public Resources Code § 5097 et. seq. in the event of discovery of human remains during Project construction activities.

Goal HR-4: Recognize, identify, and protect natural
resources for their historic and cultural value, and include these features in the historic resource management
program.

Not applicable: Goal HR-4 provides direction to City staff and decision makers to recognize, identify, and protect natural resources for their historic and cultural value, and

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Goal/Policy Project Consistency
include these features in the historic resource management program, and is unrelated to the proposed Project.

Policy HR-4.1: Develop an inventory and map
concentrations of Heritage Street Trees, which are
representative of the City’s character and history, for consideration and official inclusion on the Corona Historic Register or the Heritage Inventory.

Not applicable: Policy HR-4.1 provides direction to City staff and decision makers to develop an inventory and map concentrations of Heritage Street Trees, and is unrelated to the proposed Project.

Policy HR-4.2: Designate “Landmark Trees” in accordance with existing City policy and ordinance to preserve and protect individual specimen trees, which display particular historic value to the community.

Not applicable: Policy HR-4.2 provides direction to City staff and decision makers to designate “Landmark Trees” in accordance with existing City policy and ordinance, and is unrelated to the proposed Project.

Policy HR-4.3: List applicable parks within Grand Boulevard, as resources on the Corona Historic Register, to preserve their historic identity and become eligible for funding for future restoration and maintenance.

Not applicable: Policy HR-4.2 provides direction to City staff and decision makers to list applicable parks within Grand Boulevard as resources on the Corona Historic
Register, and is unrelated to the proposed Project.

Goal HR-5: Foster increased community awareness and
appreciation for Corona’s unique heritage and the many
cultural and historical resources found in the City.

Not applicable: Goal HR-5 provides direction to City staff and decision makers to foster increased community
awareness and appreciation for Corona’s unique heritage and the many cultural and historical resources found in the City, and is unrelated to the proposed Project.

Policy HR-5.1: Encourage, participate in, and promote
activities and events designed to educate the community about Corona’s unique heritage and the recognition of its many cultural and historic resources.

Not applicable: Policy HR-5.1 provides direction to City staff and decision makers to encourage, participate in, and promote activities and events designed to educate the
community about Corona’s unique heritage and the
recognition of its many cultural and historic resources, and is unrelated to the proposed Project.

Policy HR-5.2: Promote the archival collection and
documentation of Corona’s history at the Heritage Room of the Corona Public Library, and establish this facility as the official local repository for historic and cultural resource records.

Not applicable: Policy HR-5.2 provides direction to City staff and decision makers to promote the archival
collection and documentation of Corona’s history at the Heritage Room of the Corona Public Library and establish this facility as the official local repository for historic and cultural resource records, and is unrelated to the proposed Project.

Policy HR-5.3: Develop educational and interpretive
brochures for distribution to the public and property
owners about the City’s historic resources, preservation programs, financial incentives for designated properties, and restoration requirements and guidelines.

Not applicable: Policy HR-5.3 provides direction to City staff and decision makers to develop educational and
interpretive brochures, and is unrelated to the proposed Project.

Policy HR-5.4: Foster neighborhood conservation and
beautification programs and consider preservation awards or recognition certificates for historic properties displaying exceptional care, maintenance, or restoration.

Not applicable: Policy HR-5.4 provides direction to City staff and decision makers to foster neighborhood
conservation and beautification programs and consider
preservation awards or recognition certificates for historic properties, and is unrelated to the proposed Project.

Policy HR-5.5: Inform property owners of the benefits of being a listed historic property and provide information on conservation methods and professional resources.

Not applicable: Policy HR-5.5 provides direction to City staff and decision makers to inform property owners of the benefits of being a listed historic property and provide

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Goal/Policy Project Consistency
information on conservation methods and professional
resources, and is unrelated to the proposed Project.

Goal HR-6: Build and strengthen preservation partnerships between the City and property owners, businesses,
community organizations, educational institutions, and
State and federal agencies.

Not applicable: Goal HR-6 provides direction to City staff and decision makers to build and strengthen preservation partnerships between the City and property owners,
businesses, community organizations, educational
institutions, and State and federal agencies, and is
unrelated to the proposed Project.

Policy HR-6.1: Coordinate with the Chamber of Commerce, Corona Historic Preservation Society, State Office of
Historic Preservation, and other organizations or agencies regarding potential programs that promote tourism,
filming, and economic development in association with
historic resources.

Not applicable: Policy HR-6.1 provides direction to City staff and decision makers to coordinate with the Chamber of Commerce, Corona Historic Preservation Society, State Office of Historic Preservation, and other organizations or agencies, and is unrelated to the proposed Project.

Policy HR-6.2: Encourage the involvement of the CoronaNorco Unified School District in preservation activities, local history programs, and the potential listing of
identified historic school sites on the Corona Historic Register.

Not applicable: Policy HR-6.2 provides direction to City staff and decision makers to encourage the involvement of the Corona-Norco Unified School District in preservation activities, local history programs, and the potential listing of identified historic school sites, and is unrelated to the proposed Project.

Policy HR-6.3: Work cooperatively with the Corona
Heritage Foundation in the establishment and
improvement of Heritage Park as a historic citrus ranch complex in South Corona.

Not applicable: Policy HR-6.3 provides direction to City staff and decision makers to work cooperatively with the Corona Heritage Foundation in the establishment and
improvement of Heritage Park as a historic citrus ranch complex in South Corona, and is unrelated to the proposed Project, which is not located within South Corona.

Policy HR-6.4: Consider application to the State of
California Historic Preservation Office for acceptance as a Certified Local Government, and for having a Certified
Local Ordinance for historic resource management.

Not applicable: Policy HR-6.4 provides direction to City staff and decision makers to consider application to the State of California Historic Preservation Office for
acceptance as a Certified Local Government, and is
unrelated to the proposed Project.

Policy HR-6.5: Continue to consider and assist in the
nomination of Corona’s historic resources to the National Register of Historic Places, the California Historic
Landmarks program, and the California Points of Historical Interest program.

Not applicable: Policy HR-6.5 provides direction to City staff and decision makers to consider and assist in the nomination of Corona’s historic resources to the National Register of Historic Places, the California Historic
Landmarks program, and the California Points of Historical Interest program, and is unrelated to the proposed Project.

Policy HR-6.6: Work cooperatively with the Corona Historic Preservation Society, and other nonprofit and community organizations, in the placement of appropriate Historical Markers, monuments, or plaques to memorialize historic
sites in Corona.

Not applicable: Policy HR-6.6 provides direction to City staff and decision makers to work cooperatively with the Corona Historic Preservation Society, and other nonprofit and community organizations, in the placement of
appropriate Historical Markers, monuments, or plaques to memorialize historic sites in Corona, and is unrelated to the proposed Project.

Policy HR-6.7: Work cooperatively with the Corona Historic Preservation Society and other nonprofit organizations and Not applicable: Policy HR-6.7 provides direction to City staff and decision makers to work cooperatively with the

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Goal/Policy Project Consistency
individuals applying for available local, State, and federal funding for the rehabilitation and restoration of historic properties and resources.

Corona Historic Preservation Society and other nonprofit organizations and individuals applying for available local, State, and federal funding for the rehabilitation and
restoration of historic properties and resources, and is unrelated to the proposed Project.

Mitigation Measures
The following mitigation measures from the SHP EIR shall apply in order to reduce the Project’s potential impacts to cultural resources to below a level of significance. Revisions/additions to the SHP EIR Mitigation Measures are shown below in strikeout/underline format, and have been made to reflect the results of the Project’s PRA. The revisions to the SHP EIR mitigation measures reflect more stringent requirements as compared to the mitigation measures included in the SHP EIR.

CR-1 Tribal Monitoring. Prior to the issuance of a grading permit the applicant shall contact the consulting Native American Tribe(s) that have requested monitoring through consultation with the City during the SB 18 process ("Monitoring Tribes”). The applicant shall coordinate with the Tribe(s) to develop individual Tribal Monitoring Agreement(s). A copy of the signed agreement(s) shall be provided to the City of Corona Planning Department prior to the issuance of a grading permit. The Agreement shall address the treatment of any known tribal cultural resources (TCRs) including the project's approved mitigation measures and conditions of approval; the designation, responsibilities, and participation of professional Tribal Monitors during grading, excavation and ground disturbing activities; project grading and development scheduling: terms of compensation for the monitors; and treatment and final disposition of any cultural resources, sacred sites, and human remains/burial goods discovered on the site per the Tribe(s) customs and traditions and the City’s mitigation measures/conditions of approval. The Tribal Monitor will have the authority to stop and redirect grading in the immediate area of a find in order to evaluate the find and determine the appropriate next steps, in consultation with the Project archaeologist.

If changes are made to the project footprint to include earth-moving activities in areas not previously studied, additional archaeological investigations shall be required.

In the event that archaeological materials are discovered during construction, all earth-moving activity within and around the immediate discovery area shall be diverted until a qualified archaeologist can assess the nature and significance of the find, and, if necessary, develop appropriate treatment measures. Treatment measures typically include development of avoidance strategies, capping with fill material, or mitigation of impacts through data recovery programs such as excavation or detailed documentation. If during cultural resources monitoring the qualified archaeologist determines that the sediments being excavated are previously disturbed or unlikely to contain significant cultural materials, the qualified archaeologist can specify that monitoring be reduced or eliminated.

Native American monitors from affected Tribes shall observe all project-related grading activities, and the treatment of any recovered artifacts shall be carried out in accordance with the provisions of a Treatment Agreement between affected Tribes. The Treatment Agreement shall be executed by the consulting Tribes prior to the issuance of grading permits for each construction phase. All

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cultural materials that are collected during the grading monitoring program and from any previous archaeological studies or excavations on the project site shall be curated according to the current professional repository standards. The collections and associated records shall be transferred, including title, to an appropriate curation facility which meets the standards set forth in 36 CFR Part 79 for federal repositories. All sacred sites, should they be encountered within the project area, shall be avoided and preserved as the preferred mitigation.

If changes are made to the project footprint to include earth-moving activities in areas not previously studied, additional archaeological investigations shall be required.

CR-2: Archaeological Monitoring. At least 30-days prior to application for a grading permit and before any grading, excavation and/or ground disturbing activities on the site take place, the Project Applicant shall retain a Secretary of Interior Standards qualified and RPA-certified archaeological monitor to monitor all ground-disturbing activities in an effort to identify any unknown archaeological resources/TCRs and assist with avoidance, preservation and/or mitigation per the City's Mitigation Measures on known resources.

The Project Archaeologist in consultation with the Monitoring Tribe(s), the Developer and the City, shall develop a Cultural Resources Monitoring Plan (CRMP) to address the details, timing and responsibility of all archaeological and cultural activities that will occur on the project site. Details in the Plan shall include:
a. Project grading and development scheduling;
b. The Project archeologist and the Monitoring Tribe(s) shall attend the pre-grading meeting with the construction manager and any contractors and will conduct a mandatory Cultural Resources Worker Sensitivity Training to those in attendance. The Training will include a brief review of the cultural sensitivity of the Project and the surrounding area: what resources could potentially be identified during earthmoving activities; the requirements of the monitoring program: the protocols that apply in the event inadvertent discoveries of cultural resources are identified, including who to contact and appropriate avoidance measures until the find(s) can be properly evaluated; and any other appropriate protocols. All new construction personnel that begin work on the Project following the initial Training must take the Cultural Sensitivity Training prior to beginning work and the Project archaeologist and Monitoring Tribe(s) shall make themselves available to provide the training on an as-needed basis. c. The coordination of a monitoring schedule as agreed upon by the Monitoring Tribe(s), the Project archaeologist and the applicant;
d. The protocols and stipulations that the Developer. City, Monitoring Tribe(s) and Project archaeologist will follow in the event of inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits that shall be subject to a cultural resources evaluation.

Prior to issuance of any grading permit, the Applicant shall retain a qualified vertebrate [sic] to develop a paleontological resource impact mitigation program (PRIMP) for excavations into the Upper Cretaceous Ladd Canyon Formation [sic], the Upper Cretaceous Williams Formation, ; and the Paleocene Silverado Formation. A qualified vertebrate paleontologist is defined as a paleontologist meeting the criteria established by the Society of Vertebrate Paleontology. The

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qualified vertebrate paleontologist shall conduct a preconstruction field assessment to locate fossils at surface exposures. The qualified vertebrate paleontologist shall supervise a paleontological monitor who shall be present at such times as required by the paleontologist during construction excavations into the fossiliferous formations referenced above. Monitoring shall consist of visually inspecting fresh exposures of rock for larger fossil remains and, where appropriate, collecting wet or dry screened sediment samples of promising horizons for smaller fossil remains. The frequency of monitoring shall be determined by the paleontologist and shall be based on the rate of excavation and grading activities, the materials being excavated, and the depth of excavation, and if found, the abundance and type of fossils encountered. If resources are located, monitoring hours shall be increased if needed.

CR-3: Treatment and Disposition of Tribal Cultural Resources. In the event that Tribal Cultural Resources (TCRs) are inadvertently discovered during the course of grading for this Project and avoidance of the TCRs is not feasible, the following procedures will be carried out for treatment and disposition of the discoveries:

1. Temporary Curation and Storage: During the course of construction. All discovered resources shall be temporarily curated in a secure location onsite or at the offices of the project archaeologist. The removal of any artifacts from the project site will need to be thoroughly inventoried with tribal monitor oversight of the process: and

2. Treatment and Final Disposition: The landowner(s) shall relinquish ownership of all cultural resources, including all archaeological artifacts and non-human remains as part of the required mitigation for impacts to tribal cultural resources. Human remains, sacred/ceremonial items and burial good will be addressed per State Law. Mitigation Measure CR-1 and the Agreement required in Mitigation Measure CR-1. The applicant shall relinquish the artifacts as indicated below and provide the City of Corona Planning Division with evidence of same:
a. Professional curation, including a curation agreement with a qualified repository in Riverside County that meets federal standards per 36 CFR Part 79, and which shall be made available to all qualified researchers upon application. The collections and associated records shall be transferred, including title, to an appropriate curation facility within Riverside County, to be accompanied by payment of the fees necessary for permanent curation;
b. At the completion of grading, excavation and ground disturbing activities on the site, a Phase IV Monitoring Report shall be submitted to the City Planning Division documenting monitoring activities conducted by the project Archaeologist and Native Tribal Monitors within 60 days of completion of grading. This report shall document the impacts to the known resources on the property; describe how each mitigation measure was fulfilled; document the type of cultural resources recovered and the disposition of such resources; provide evidence of the required cultural sensitivity training for the construction staff held during the required pregrade meeting; and, in a confidential appendix, include the daily/weekly monitoring notes from the archaeologist. All reports produced will be submitted to the City of Corona, Eastern Information Center and Monitoring Tribe(s).

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If a potential fossil is found, the qualified vertebrate paleontologist or paleontological monitor shall be allowed to temporarily divert or redirect grading and excavation activities in the area of the exposed fossil, as determined appropriate by the monitor, to assess the significance of the find and, if necessary, develop appropriate treatment measures. Treatment measures may include avoidance or preservation in place, if feasible. If preservation or avoidance of the resource is not feasible, then the resource shall be removed from its location. Removal activities may consist of the relatively rapid removal of small isolated fossils from an active cut, to hand-quarrying of larger fossils from a bone bed over several days. These activities may include the assistance of the grading and excavation contractor’s equipment to facilitate removal. Any fossils encountered and recovered shall be prepared to the point of identification and catalogued before they are donated to their final repository. Any fossils collected shall be donated to a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County, San Bernardino County Museum, the John D. Cooper Archaeological and Paleontological Curation Center at the California Sate University, Fullerton, or Western Science Center in Hemet, California. Accompanying notes, maps, and photographs shall also be filed at the repository.

CR-4: Sacred Sites. All sacred sites, should they be encountered within the project area, shall be avoided and preserved as the preferred mitigation, if feasible. Prior to the release of the grading bond, the paleontologist shall prepare a report summarizing the results of the monitoring and salvaging efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall be submitted by the Applicant to the Community Development Director or his/her designee for approval. In addition, the report shall be submitted to at least one of the repositories mentioned in Mitigation Measure CR-3 and other appropriate or concerned agencies to signify the satisfactory completion of the project and required mitigation measures.

CR-5 Discovery of Human Remains. In the event that human remains (or remains that may be human) are discovered at the project site during grading or earthmoving. the construction contractors, project archaeologist, and/or designated Native American Monitor shall immediately stop all activities within 100 feet of the find. The project applicant shall then inform the Riverside County Coroner and the City of Corona Planning Division immediately, and the coroner shall be permitted to examine the remains as required by California Health and Safety Code Section 7050.5(b).

Section 7050.5 requires that excavation be stopped in the vicinity of discovered human remains until the coroner has made the necessary findings as to origin If human remains are determined to be Native American,, the applicant shall comply with the state law relating to the disposition of Native American burials that fall within the jurisdiction of the NARC (PRC Section 5097). The coroner shall contact the NAHC within 24 hours and the NAHC will make the determination of most likely descendant(s). The MLD shall complete his or her inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. Treatment and disposition of the remains shall be determined in consultation with the most likely descendant(s) to determine the most appropriate disposition of human remains and any associated grave artifacts. In the event that the applicant and the MLD are in disagreement regarding the disposition of the remains. State law will apply and the mediation process will occur with the NAHC. if requested (see PRC Section 5097.98(e) and 5097.94(k)).

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The specific locations of Native American burials and reburials are confidential and may not be disclosed to the general public. The locations will be documented by the consulting archaeologist in conjunction with the various stakeholders and a report of findings will be filed with the Eastern Information Center (EIC). A Sacred Lands File form will be submitted to the NAHC by the project archaeologist and the Monitoring Tribe(s).

According to the California Health and Safety Code, six or more human burials at one location constitutes a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052).

CR-62 Prior to issuance of any grading permit, the Applicant shall retain a qualified vertebrate paleontologist [sic] to develop a paleontological resource impact mitigation program (PRIMP) for excavations into the Upper Cretaceous Ladd Canyon Formation [sic], the Upper Cretaceous Williams and Ladd Formations (undifferentiated), the Early Pleistocene Very Old Alluvial Fan Deposits; the Upper Cretaceous Ladd Forma�on/Baker Canyon Conglomerate member; and Paleocene Silverado Formation. A qualified vertebrate paleontologist is defined as a paleontologist meeting the criteria established by the Society for Vertebrate Paleontology. The qualified vertebrate paleontologist shall conduct a pre-construction field assessment to locate fossils at surface exposures. The qualified vertebrate paleontologist shall supervise a paleontological monitor who shall be present at such times as required by the paleontologist during construction excavations into the fossiliferous formations mentioned above. Monitoring shall consist of visually inspecting fresh exposures of rock for larger fossil remains and, where appropriate, collecting wet or dry screened sediment samples of promising horizons for smaller fossil remains. The frequency of monitoring shall be determined by the paleontologist and shall be based on the rate of excavation and grading activities, the materials being excavated, and the depth of excavation, and if found, the abundance and type of fossils encountered. If resources are located, monitoring hours shall be increased as needed.

CR-73 If a potential fossil is found, the qualified vertebrate paleontologist or paleontological monitor shall be allowed to temporarily divert or redirect grading and excavation activities in the area of the exposed fossil, as determined appropriate by the monitor, to assess the significance of the find and, if necessary, develop appropriate treatment measures. Treatment measures may include avoidance or preservation in place, if feasible. If preservation or avoidance of the resource is not feasible, then the resource shall be removed from its location. Removal activities may consist of the relatively rapid removal of small isolated fossils from an active cut, to hand-quarrying of larger fossils over several hours, to excavations of large fossils or large numbers of smaller fossils from a bone bed over several days. These activities may include the assistance of the grading and excavation contractor’s equipment to facilitate removal. Any fossils encountered and recovered shall be prepared to the point of identification and catalogued before they are donated to their final repository. Any fossils collected shall be donated to a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County, San Bernardino County Museum, the John D. Cooper Archaeological and Paleontological Curation Center at the California State University, Fullerton, or Western Science Center in Hemet, California.

Accompanying notes, maps, and photographs shall also be filed at the repository.

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CR-84 Prior to the release of the grading bond, the paleontologist shall prepare a report summarizing the results of the monitoring and salvaging efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall be submitted by the Applicant to the Planning Director or his/her designee for approval. In addition, the report shall be submitted to at least one of the repositories mentioned in Mitigation Measure CR-7 and other appropriate or concerned agencies to signify the satisfactory completion of the project and required mitigation measures.

2.6 Energy
New
Significant
Impact
More
Severe
Impacts
New Ability to
Substantially Reduce
Significant Impact
No Substantial
Change from
Previous Analysis
Would the Project:
a. Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project construction
or operation?
☐ ☐ ☐ ☒
b. Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency? ☐ ☐ ☐ ☒

ENVIRONMENTAL ANALYSIS
a) Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Skyline Heights Project EIR Findings: Although SHP EIR did not address this subject because it was not a required CEQA topic at the time the SHP EIR was adopted, the SHP EIR contained enough information about projected energy consumption associated with the SHP that with the exercise of reasonable diligence, information about the SHP’s potential effect due to energy conservation was readily available to the public. Specifically, Technical Appendix C to the SHP EIR included an Air Quality and Greenhouse Gas Analysis and SHP EIR Subsection 4.F, Greenhouse Gas Emissions, provided a discussion of the SHP project’s anticipated greenhouse gas (GHG) emissions, including the GHG emissions related to energy consumption. The SHP EIR and Technical Appendix C documented the energy conservation requirements applicable to buildout of the SHP, including a description of the requirements of California’s Energy Efficiency Standards for Residential and Nonresidential Buildings and the California Green Building Standards. Additionally, Appendix A to SHP EIR Technical Appendix C included the CalEEMod outputs, which indicated that long-term operation of the SHP would result in a future unmitigated demand for 9,826,170 kBTU/yr of natural gas and 2,234,780 kWh per year of electricity. Subsection 4.N of the SHP EIR also included a detailed discussion of applicable State regulations related to energy conservation. The SHP EIR did not identify any impacts due to the wasteful, inefficient, or unnecessary consumption of energy resources and did not identify any impacts due to a conflict with or obstruction of a State or local plan for renewable energy or energy efficiency.

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EIR Addendum No. 1 Finding: No Substantial Change from Previous Analysis. Although the issue of Energy was not explicitly evaluated in the SHP EIR as detailed impact analysis was not required at that time, the SHP EIR did acknowledge that future buildout of the SHP area would increase consumption of electricity and natural gas resources. However, the currently proposed Project includes 16 fewer dwelling units as compared to the project evaluated in the SHP EIR; thus, the proposed Project would result in an overall reduction in energy demand as compared to the project evaluated by the SHP EIR. Regulations and other energy standards have also only become more stringent since the certification of the SHIP EIR, and as a result, the proposed Project is also likely to require less energy on a per unit basis than the Approved Project.

Specifically, the proposed Project would be required to meet at a minimum the 2022 version of the California Title 24 energy efficiency requirements, which became effective on January 1, 2023, and impose more stringent energy efficiency requirements in comparison to the 2013 or 2016 versions of the Title 24 regulations that were in effect at the time the SHP EIR was prepared and certified, respectively. The 2022 Title 24 standards require solar photovoltaic systems for new homes, encourage demand responsive technologies for residential buildings, and update indoor and outdoor lighting standards for nonresidential buildings. The California Energy Commission (CEC) anticipates that the 2022 energy code will provide $1.5 billion in consumer benefits and reduce GHG emissions by 10 million metric tons. Additionally, nonresidential buildings will use approximately 30% less energy due to lighting upgrades compared to the prior code. (CEC, 2022) The Project’s compliance with the current version of the Title 24 standards would ensure that the Project energy demands would not be inefficient, wasteful, or otherwise unnecessary. The Project would not cause or result in the need for additional energy producing or transmission facilities. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California.

In addition, the currently-proposed Project would be subject to compliance with all applicable State and local regulations related to renewable energy and energy efficiency. Additionally, and as noted above, the Project would be subject to compliance with the 2022 version of Title 24, which imposes more stringent requirements related to energy efficiency as compared to what was required by the 2013 or 2016 version of Title 24. Because the Project would be required to comply with all applicable regulations related to energy efficiency, the Project would not result in potentially significant environmental impacts due to a conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

The Project also would result in a reduction in overall traffic associated with the AVSP site. Specifically, and as shown in Table 4-2, Trip Generation Comparison, of the Project’s Traffic Analysis (“TA”; Technical Appendix J), the Project, which includes 16 fewer units than the project evaluated by the SHP EIR, would result in a net reduction of 176 average daily trips (ADT). Thus, it can be concluded that the proposed Project would result in a substantial reduction in the amount of transportation-related fuel that would be consumed by the Project as compared to the project evaluated by the SHP EIR. Additionally, due to increasing regulatory requirements related to fuel efficiency, vehicles associated with the currently-proposed Project would have a higher level of fuel efficiency and would consume less fossil fuels as compared to the project evaluated by the SHP EIR. Thus, the Project’s overall transportation-related energy demands would be less than what was assumed by the SHP EIR.

As supported by the preceding analyses, Project operations would not result in the inefficient, wasteful, or unnecessary consumption of energy, and impacts would be less than significant. Therefore, the proposed Project

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would not result in any new impact not already analyzed in the SHP EIR or increase the severity of a significant impact previously identified and analyzed in the SHP EIR. b) Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Under existing conditions, there are no adopted State or local plans for renewable energy or energy efficiency in the Project area. Thus, the Project would have no potential to conflict with such plans, and no impact would occur.

Additionally, and as discussed below, the Project would be consistent with or otherwise would not conflict with policies and requirements related to energy conservation. • Project Consistency with Intermodal Surface Transportation Efficiency Act (ISTEA) of 1991: The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of intermodal transportation systems to maximize mobility as well as address national and local interests in air quality and energy. ISTEA contained factors that Metropolitan Planning Organizations (MPOs) were to address in developing transportation plans and programs, including some energy-related factors. To meet the new ISTEA requirements, MPOs adopted explicit policies defining the social, economic, energy, and environmental values guiding transportation decisions.

Transportation and access to the Project site is provided primarily by the local and regional roadway systems. The Project would not interfere with, nor otherwise obstruct intermodal transportation plans or projects that may be realized pursuant to the ISTEA because SCAG is not planning for intermodal facilities on or through the Project site.
• Project Consistency with the Transportation Equity Act for the 21st Century (TEA-21): The Transportation Equity Act for the 21st Century (TEA-21) was signed into law in 1998 and builds upon the initiatives established in the ISTEA legislation, discussed above. TEA-21 authorizes highway, highway safety, transit, and other efficient surface transportation programs. TEA-21 continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of good transportation decisions. TEA-21 also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of Intelligent Transportation Systems, to help improve operations and management of transportation systems and vehicle safety.

The Project site is located along major transportation corridors with proximate access to the Interstate freeway system. The site selected for the Project facilitates access, acts to reduce Vehicle Miles Traveled (VMT), takes advantage of existing infrastructure systems, and promotes land use compatibilities through collocation of similar uses. This is because the Project site is located within an area already served with roadway and utilities infrastructure and the Project site is located in an area surrounded by existing and planned residential development. As such, the Project supports the strong planning processes emphasized under TEA-21 by taking advantage of the regional and proximate transportation infrastructure. The Project is therefore consistent with, and would not otherwise interfere with, nor obstruct implementation of TEA-21.

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• Project Consistency with the California Integrated Energy Policy Report (Senate Bill 1389): Senate Bill 1389 (Bowen, Chapter 568, Statutes of 2002) requires the California Energy Commission to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the State’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety (Public Resources Code § 25301a). The Energy Commission prepares these assessments and associated policy recommendations every two years, with updates in alternate years, as part of the Integrated Energy Policy Report. The 2019 Integrated Energy Policy Report (2019 IEPR) was published in February 2020, and continues to work towards improving electricity, natural gas, and transportation fuel energy use in California.

Electricity would be provided to the Project by Southern California Edison (SCE). SCE’s Clean Power and Electrification Pathway (CPEP) white paper is an integrated approach to reduce GHG emissions and air pollution by taking action in three California economic sectors: electricity, transportation, and buildings.

It builds on existing state programs and policies, and uses a combination of measures to produce the most cost-effective and feasible path forward among the options studied. By 2030, it calls for: 1) an electric grid supplied by 80 percent carbon-free energy; 2) more than 7 million electric vehicles on California roads; and 3) using electricity to power nearly one-third of space and water heaters, in increasingly energyefficient buildings. These electrified technologies will use zero-emission resources like solar and wind to provide most of their power, and can in turn support the electric grid by balancing electricity demand with supply. Because all power supplied to the Project by SCE would be subject to the energy conservation and renewable energy requirements of the CPEP, the Project is inherently consistent with, would not otherwise interfere with, and would not obstruct implementation of, the goals presented in the 2019 IEPR. • Project Consistency with State Energy Plan: The CEC is responsible for preparing the State Energy Plan, which identifies emerging trends related to energy supply, demand, conservation, public health and safety, and the maintenance of a healthy economy. The Plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators and encouragement of urban designs that reduce vehicle miles traveled and accommodate pedestrian and bicycle access.

The Project site is located along major transportation corridors with proximate access to the Interstate freeway system. The site selected for the Project facilitates access and takes advantage of existing infrastructure systems. The Project therefore supports urban design and planning processes identified under the State of California Energy Plan, is consistent with, and would not otherwise interfere with, nor obstruct implementation of the State of California Energy Plan. • Project Consistency with California Code Title 24, Part 6 (California Energy Code): California Code of Regulations Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings, was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation