Desert Hot Springs City Council
May 2, 2023

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Significant
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Less Than
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Mitigation
Incorporated
Less Than
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No
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City of Desert Hot Springs Page 19
Draft Initial Study / Mitigated Negative Declaration December 2022 The project proposes a one-story, 60,000-square-foot building on the southern portion of a 4.85-acre property with associated improvements including paved drive aisles, parking spaces, and landscaping.

In accordance with Chapter 17.16.230 (Industrial Districts) of the Desert Hot Springs Municipal Code (DHS MC), new industrial development is required to employ design elements that enhance the visual character of a site and avoid certain features deemed undesirable. The design guidelines in the Municipal Code are intended to ensure that the aesthetic quality of proposed industrial facilities, such as this project, surpass the traditional design approach and characteristics found on past development practices. For example, new facilities are expected to employ “variety in structure forms” to create visual interest and avoid plain features, such as “large blank, unarticulated wall surfaces”, which are deemed less attractive.

Entries to buildings should portray a quality appearance while avoiding the use of chain link fencing or barbed wire.

The project design will consist of a one-story, 60,000-square-foot container storage building. The proposed building will be designed to create interest by using various materials. Materials used will consist of masonry block, steel doors and garage doors, and windows. The proposed structure is proposed to be neutral in color (white and grey) with windows and roll-up doors to avoid large monotonous building facades. All architectural plans will require review by the City prior to construction. Renderings of the project buildings and project materials are provided below.

Exhibit I-1 Building Renderings

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Mitigation
Incorporated
Less Than
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City of Desert Hot Springs Page 20
Draft Initial Study / Mitigated Negative Declaration December 2022 Exhibit I-2 Proposed Color & Material Board
According to Chapter 17.16.170 (Site Planning Principles) of the DHS MC, industrial projects shall have controlled access to the site, hidden service areas, convenient access, screening of outdoor storage areas, work areas, and equipment, emphasis on the main building entry and landscaping, and

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City of Desert Hot Springs Page 21
Draft Initial Study / Mitigated Negative Declaration December 2022 landscaped areas. Building setbacks should be provided proportionate to the scale of the structure and in consideration of existing development adjacent to it. Larger structures require more setback area for a balance of scale and so as not to impose on neighboring uses. The heights and setbacks of the proposed facilities will be required to comply with the local standards for light industrial developments. As such, the building height would be less than the 50-foot maximum and the building placement would comply with the required front, rear and side setbacks. The proposed building will be one-story and up to 34 feet in height. See Exhibit I-5, below, for building elevations. The table below indicates the project’s building setbacks from the project’s northern, southern, western, and eastern boundaries.

Table I-1 Building Setbacks
Orientation Proposed Building Setback DHS MC
Standard
In
Compliance?
Front Setback1 44’ setback from western boundary; 35.6’ from southern boundary (Avenue 19) 20’ min Yes
Side Setback /
Rear Setback
186.4’ from northern property boundary;
100’ setback from eastern boundary 10’ min Yes

1. Front includes project frontages along the existing roadways Calle De Los Romos and Avenue 19, west and south of the project, respectively.

Exhibit I-3 Building Elevations
In addition to the proposed buildings, the project also proposes 92 paved parking spaces, internal paved drive aisles, and landscaping throughout. Landscaping has been designed to balance aesthetic, water use and security objectives. The project landscape will include large drought-tolerant flowering trees and shrubs typically found in the region, such as fan palms, live oak or mesquite tree, and blue palo verde.

Exterior irrigation will use drip or micro-spray applicators to avoid overwatering and promote water efficiency. The landscaping at the project’s frontage will consist of trees, along with low level plantings and fencing to visually enhance, protect and blend the cultivation and processing facility into its surroundings while also promoting visibility by law enforcement vehicles from the street. A Conceptual Landscape Plan will be submitted to the City as part of the entitlement process. This plan will include plant types, sizes, quantities, and locations, which will be reviewed by the City of Desert Hot Springs.

On-site improvements also include parking lot facilities and interior drive aisles with downward-oriented light fixtures for nighttime security illumination. The proposed perimeter landscaping throughout the site plan and along the Dillon Road frontage will help enhance the visual character of the streetscape in a manner that is compatible with the local desert environment. The project’s final site design, architecture and landscape architecture will be subject to review and approval by the City of Desert Hot Springs to

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Incorporated
Less Than
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City of Desert Hot Springs Page 22
Draft Initial Study / Mitigated Negative Declaration December 2022 ensure that aesthetic considerations of the community are addressed in the proposed design. Less than significant impacts are expected.

Mitigation Measures: None
d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
Discussion:

The project property and its immediate surroundings to the north, south and east are currently vacant.

The paved roadway, Calle De Los Romos, delineates the project’s western boundary, while the unpaved road, 19th Avenue, delineates the project’s southern boundary. Developed sites are located west of the project boundaries, with existing industrial facilities north and south of 19th Avenue. The existing facilities contribute to the existing light and glare in the project vicinity. These uses operate during typical business hours. Lighting from the existing commercial and industrial buildings are expected to have some source of nighttime lighting for both operational and security purposes. Additional lighting in commercial/industrial areas typically consists of overhead/downward-orienting lamp posts in parking areas, low-intensity, wall-mounted lighting fixtures at building entrances and lamp posts along pedestrian pathways. The project will operate within the City’s allowed operational hours, occurring between the hours of 8:00 a.m. to 10:00 p.m. up to seven days a week. Neither Calle De Los Romos nor Avenue 19 include public street lighting or illuminated traffic signals. However, day-time glare and night-time lighting can be attributed to vehicular traffic on these roadways.

Consistent with the architectural design guidelines for industrial districts, established in Chapter

17.16.230 of the City’s Municipal Code, the proposed buildings include a variety of exterior materials and articulated facades to create an attractive visual character and a quality appearance. The building design includes buildings with natural earth tones (i.e., white, blue, and greys). The project will avoid any bright tones and highly reflective surfaces, such that would result in substantial daytime glare. The proposed combination of exterior materials and surfaces are expected to have partial solar reflectivity. As part of the landscape design, the proposed trees, palms, and other plantings along the project perimeter and frontage are expected to help attenuate the visibility and partial sunlight reflectivity associated with the proposed building.

For security purposes, the project will provide varied nighttime lighting to safely illuminate the parking areas, entrances, signs, walkways and other project features in accordance with the City’s Outdoor Lighting Requirements. These requirements are established to minimize light pollution and trespassing.

Compliance with the City’s lighting requirements is demonstrated in the photometric plan, which includes point-by-point lighting levels (measured in foot-candles) for the entire project based on the proposed placement, orientation, and intensity of exterior light fixtures throughout the site. The lights proposed for the project includes downward-oriented, pole-mounted light fixtures.

Per the project photometric plans, the project will include 15 pole-mounted light fixtures and 12 wallmounted light fixtures throughout the site and along the perimeter of the site for security purposes. The proposed fixtures are designed to minimize light spillage offsite and onto adjacent properties. The property west, south and east of the project site will experience less than one-foot candles emitted from the project site. Light emitted from the project site will be less than 1 foot candle in most areas around

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City of Desert Hot Springs Page 23
Draft Initial Study / Mitigated Negative Declaration December 2022 the project boundaries. One foot candle and less is barely perceivable to the human eye. However, as indicated in the photometric plans, maximum light trespass from the project would occur at the northern boundary where the project would emit 2 foot-candles off-site.

The photometric plan indicates that the proposed distribution of permanent fixtures have been designed, such that illumination is sufficiently diminished at the project edges and adjacent properties. In doing so, unnecessary lighting concentration will not occur since the proposed light fixtures will be oriented downward and away from adjoining properties or the public right-of-way. The proposed lighting is required and will be reviewed by the Planning and/or Police Departments. Therefore, impacts will be less than significant.

During the period of construction, the project is expected to utilize temporary light fixtures as a standard measure of nighttime construction site safety. These fixtures are typically installed on posts and/or on the sides of temporary construction trailers to illuminate stored equipment and building materials. These sources of light are generally downward-oriented and some are only activated by motion. The temporary construction perimeter fencing (with wind fabric) is expected to visually screen the temporary light fixtures, therefore preventing temporary light spillage effects. The temporary nature of proposed lighting will allow for adjustments to ensure that illumination is properly distributed without affecting adjoining areas. Less than significant impacts are expected.

Mitigation Measures: None
II. AGRICULTURE RESOURCES – Would the project:

Sources: California Farmland Mapping and Monitoring Program, California Department of Conservation, 2016; Desert Hot Springs General Plan, 2020; Williamson Act Program 2020-2021 Status Report, California Department of Conservation.
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on
the maps prepared pursuant to the
Farmland Mapping and Monitoring
Program of the California Resources
Agency, to non-agricultural use?
Discussion:

The project will not disturb or convert any designated farmland or other form of agricultural resource. The subject property is designated as “Other Land” according to the Important Farmland Map of the most recent (2016) California Farmland Mapping and Monitoring Program. A large portion of the City of Desert Hot Springs is designated as Other Land, which is land not included in any other mapping category.

Common examples include low density rural development, brush, timber, wetland and riparian areas not suitable for livestock grazing, confined livestock, poultry or aquaculture facilities, strip mines, borrow pits and water bodies smaller than 40 acres. Vacant/nonagricultural land surrounded by urban development and greater than 40 acres is mapped as other land. The subject site and surrounding land to the north, east, south and west are not categorized as Prime Farmland, Unique Farmland, or Farmland of local or statewide importance, thus no impacts are expected.

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Significant
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Less Than
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Mitigation
Incorporated
Less Than
Significant
Impact
No
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City of Desert Hot Springs Page 24
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
b) Conflict with existing zoning for
agricultural use, or a Williamson
Act contract?
Discussion:

The project site is not located in an existing zone for agricultural use or classified as farmland. According to the Williamson Act Program 2020-2021 Status Report, no portion of land within a one-mile radius is recognized as being under a Williamson Act Contract. The project will not impact or remove land from the City or County’s agricultural zoning or agricultural reserve. No impacts are expected.

Mitigation Measures: None
c) Conflict with existing zoning for, or
cause rezoning of, forest land (as defined
in Public Resources Code section 12220
(g)), timberland (as defined by Public
Resources Code section 4526), or
timberland zoned Timberland Production
(as defined by Government Code
section 51104(g))?
Discussion:

The project will occur in an existing urban desert setting zoned for industrial uses. No forest land, timberland or Timberland Production zoning occurs on the project site or in the surrounding area because forest vegetation is not characteristic of the Coachella Valley desert environment. No impacts are anticipated.

Mitigation Measures: None
d) Result in the loss of forest land or
conversion of forest land to non-forest use?
Discussion:

The project will occur in an existing desert setting zoned for commercial and industrial uses. No forest land, timberland or Timberland Production zoning occurs on the project site or in the surrounding area because forest vegetation is not characteristic of the Coachella Valley desert environment. No impacts are anticipated.

Mitigation Measures: None
e) Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland, to non-agricultural use or
Conversion of forest land to non-forest

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 25
Draft Initial Study / Mitigated Negative Declaration December 2022 land?
Discussion:

The project site and vicinity are designated by the Desert Hot Springs General Plan land use map as Industrial (I). The proposed indoor container storage facility will not result in conversion of any farmland or forest land because no farmland or forest land is situated within or adjacent to the project. No impacts are anticipated.

Mitigation Measures: None
III. AIR QUALITY: Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation
of the applicable air quality plan?
Discussion:

Sources: Final 2016 Air Quality Management Plan (AQMP), by SCAQMD, March 2017; Final 2003 Coachella Valley PM10 State Implementation Plan (CVSIP), by SCAQMD, August 2003; Analysis of the Coachella Valley PM10 Redesignation Request and Maintenance Plan, by the California Air Resources Board, February 2010; California Emissions Estimator Model (CalEEMod), Version 2020.4.0.

Existing Air Quality Setting and Regulatory Framework:

The project site and its Coachella Valley regional context are situated within the Riverside County portion of the Salton Sea Air Basin (SSAB), under jurisdiction of the South Coast Air Quality Management District (SCAQMD). Existing air quality in relation to the applicable air quality standards for criteria air pollutants is measured at established air quality monitoring stations throughout the SCAQMD jurisdiction. The three permanent ambient air quality monitoring stations in the Coachella Valley are located in Palm Springs (AQS ID 060655001), Indio (AQS ID 060652002), and Mecca (Saul Martinez - AQS ID 060652005).

To comply with the National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS), SCAQMD has adopted an Air Quality Management Plan (AQMP), which is updated regularly with strategies to effectively reduce emissions, accommodate growth, and minimize any negative fiscal impacts of air pollution control on the economy. The most current version of the AQMP (2016 AQMP) was released in March of 2017 to continue serving as a regional blueprint for achieving the federal air quality standards. The 2016 AQMP includes the most current strategies to meet the air quality standards and ensure that public health is protected to the maximum extent feasible. It also includes a comprehensive analysis of emissions, meteorology, atmospheric chemistry, regional growth projections, and the impact of existing control measures is updated with the latest data and methods.

Moreover, 2016 AQMP provides guidance for the State Implementation Plans (SIP) for attainment of the applicable ambient air quality standards.

Particulate Matter (PM10):

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 26
Draft Initial Study / Mitigated Negative Declaration December 2022 As indicated in the 2016 AQMP, the Coachella Valley is currently designated as a serious nonattainment area for PM10 (particulate matter with an aerodynamic diameter of 10 microns or less). In the Coachella Valley, the man-made sources of PM10 are attributed to direct emissions, industrial facilities, and fugitive dust resulting from unpaved roads and construction operations. High-wind natural events are also known contributors of PM10. The Clean Air Act (CAA) requires those states with nonattainment areas to prepare and submit the corresponding State Implementation Plans (SIPs) to demonstrate how these areas will attain the National Ambient Air Quality Standards (NAAQS). The implementation strategies include modeling, rules, regulations, and programs designed to provide the necessary air pollutant emissions reductions.

Pertaining to PM10 attainment, the Final 2003 Coachella Valley PM10 State Implementation Plan (CVSIP) was approved by the U.S. Environmental Protection Agency (EPA) on December 14, 2005. It incorporated updated planning assumptions, fugitive dust source emissions estimates, mobile source emissions estimates, and attainment modeling with control strategies and measure commitments. Some of those measures are reflected in SCAQMD Rules 403 and 403.1, which are enacted to reduce or prevent man-made fugitive dust sources with their associated PM10 emissions. The CVSIP established the controls needed to demonstrate expeditious attainment of the standards such those listed below:
 Additional stabilizing or paving of unpaved surfaces, including parking lots;  A prohibition on building new unpaved roads;
 Requiring more detailed dust control plans from builders in the valley that specify the use of more aggressive and frequent watering, soil stabilization, wind screens, and phased development (as opposed to mass grading) to minimize fugitive dust;
 Designating a worker to monitor dust control at construction sites; and  Testing requirements for soil and road surfaces.

On February 25, 2010, the ARB approved the 2010 Coachella Valley PM10 Maintenance Plan and transmitted it to the U.S. EPA for approval. With the recent data being collected at the Coachella Valley monitoring stations, consideration of high-wind exceptional events, and submittal of a PM10 Redesignation Request and Maintenance Plan, a re-designation to attainment status of the PM10 NAAQS is deemed feasible in the near future according to the 2016 AQMP.

Ozone and Ozone Precursors:

The Coachella Valley portion of the Salton Sea Air Basin (SSAB) is deemed to be in nonattainment for the 1997 8-hour ozone standard. Coachella Valley is unique in its geography due to its location downwind from the South Coast Air Basin (SCAB). As such, when high levels of ozone are formed in the South Coast Air Basin, they are transported to the Coachella Valley. Similarly, when ozone precursors such as nitrogen oxides (NOx) and volatile organic compounds (VOCs) are emitted from mobile sources and stationary sources located in the South Coast Air Basin, they are also transported to the Coachella Valley.

It is worth noting that SCAQMD deems that local sources of air pollution generated in the Coachella Valley have a limited impact on ozone levels compared to the transport of ozone precursors generated in SCAB.

The U.S. EPA classifies areas of ozone nonattainment (i.e., Extreme, Severe, Serious, Moderate or Marginal) based on the extent to which an area exceeds the air quality standard for that pollutant. The

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Less Than
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City of Desert Hot Springs Page 27
Draft Initial Study / Mitigated Negative Declaration December 2022 higher the exceedance level, the more time is allowed to demonstrate attainment in recognition of the greater challenge involved. However, nonattainment areas with the higher classifications are also subject to more stringent requirements. In the 2016 AQMP, the attainment target date for the 1997 8-hour ozone standard was listed as June 15, 2019. However, based on recent data for higher levels of ozone experienced in 2017 and 2018, it was determined that the Coachella Valley region could not practically attain the said standard by the established deadline. Given that additional time is needed to bring the Coachella Valley into attainment of the ozone standard, SCAQMD submitted a formal request to the United States Environmental Protection Agency (U.S. EPA) to reclassify the Coachella Valley from Severe-15 to Extreme nonattainment, with a new attainment date of June 15, 2024. The reclassification ensures that the Coachella Valley will be given the needed extension to make attainment feasible and prevent the imposition of the non-attainment fees on major stationary sources. This process would also require SCAQMD to develop or update the State Implementation Plan (SIP) documentation to demonstrate how the area will meet the standard on or before June 15, 2024.

As part of the attainment efforts, SCAQMD has provided more than $50 million in grant funding towards paving dirt roads and parking lots, clean energy projects and cleaner vehicles. Future emission reductions anticipated to occur in the South Coast Air Basin associated with current and planned regulations on mobile and stationary sources are expected to contribute to improvements in ozone air quality in the Coachella Valley and lead to attainment of the standard.

Regional Significance Threshold Criteria:

The SCAQMD has determined that impacts to air quality are significant if there is a potential to contribute or cause regional and/or localized exceedances of the federal and/or state ambient air quality standards, such as the NAAQS and CAAQS. To assist lead agencies in determining the significance of air quality impacts, SCAQMD has established suggested short-term construction-related and long-term operational impact significance thresholds for direct and indirect impacts on air quality. Table III-1 displays the established SCAQMD Air Quality Significance Thresholds applicable to construction and operational activities to which the project-specific air emissions results will be compared. Table III-1 is based on the most current standards, published in April of 2019.

Table III-1
SCAQMD’s Air Quality Significance Thresholds (Pounds/Day) Emission Source CO VOC NOx SOx PM10 PM2.5
Construction or Operation 550 75 100 150 150 55
Source: Air Quality Analysis Guidance Handbook and SCAQMD Air Quality Significance Thresholds, April 2019 Localized Significance Threshold Criteria:

The South Coast Air Quality Management District (SCAQMD) has also developed and published the Final Localized Significance Threshold (LST) Methodology to help identify potential impacts that could contribute or cause localized exceedances of the federal and/or state ambient air quality standards (NAAQS/CAAQS). LST methodology was developed in response to environmental justice and health concerns raised by the public regarding exposure of individuals to criteria pollutants in local communities.

The purpose of analyzing LSTs is to determine whether a project may generate significant adverse localized air quality impacts in relation to the nearest exposed sensitive receptors, such as schools,

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
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City of Desert Hot Springs Page 28
Draft Initial Study / Mitigated Negative Declaration December 2022 churches, residences, hospitals, day care facilities, and elderly care facilities. The separation distances between project sites and sensitive receptors, set forth by the LST methodology, range from 25 meters (82 feet) to 500 meters (1,640 feet). LST thresholds represent the maximum emissions from a project that will prevent an exceedance of the most stringent applicable federal or state ambient air quality standard at the nearest sensitive receptor, taking into consideration ambient concentrations in each source receptor area (SRA), project, size, and distance to the sensitive receptor. Therefore, meeting the lowest allowable emissions thresholds translates to meeting the most stringent air quality standards for a project locality.

As part of the LST methodology, SCAQMD has divided its jurisdiction into 37 source receptor areas (SRAs) which can be used to determine whether a project may generate significant adverse localized air quality impacts. The proposed development is located in SRA 30, which covers the Coachella Valley and City of Desert Hot Springs. LSTs only apply to certain criteria pollutants: carbon dioxide (CO2), oxides of nitrogen (NOx) particulate matter equal to or less than 10 microns in diameter (PM10), and particulate matter equal to or less than 2.5 microns in diameter (PM2.5).

Geographic Information Systems (GIS) mapping analysis was used identify the project site in relation to the nearest potential sensitive receptors, such as residential dwelling units or schools. The site is surrounded by vacant land to the north, east, and south. Land to the west is developed as an industrial park. In this context, there are no existing sensitive receptors within the range of distances set forth in the LST methodology. Therefore, the LST method will utilize the longest separation parameter of 500 meters (1,640 feet) as the basis for this analysis.

Air Emissions Methodology:

In May of 2021, the SCAQMD, in conjunction with the California Air Pollution Control Officers Association (CAPCOA) and other California air districts, released the latest version of the California Emissions Estimator Model™ (CalEEMod™) Version 2020.4.0. CalEEMod serves as an adopted platform to calculate both construction emissions and operational emissions from land use projects. CalEEMod can be used to calculate criteria pollutants and greenhouse gases. CalEEMod utilizes widely accepted methodologies for estimating emissions combined with default data that can be used when site-specific information is not available. Sources of these methodologies and default data include but are not limited to the United States Environmental Protection Agency (USEPA) AP-42 emission factors, California Air Resources Board (CARB) vehicle emission models, studies commissioned by California agencies such as the California Energy Commission (CEC) and CalRecycle.

The parameters considered for CalEEMod and air quality analysis were obtained from the most current technical site plan for the project, as subsequently summarized. The most conservative interpretation of proposed land uses, equitable modelling criteria, and associated air quality impacts have been utilized to capture impacts associated with 100% of the proposed onsite structures and operations.  Industrial Park facility with a floor area of 60,000 square feet, ITE Land Use Code 130.  Parking lot, driveway, and hardscape facilities with a combined area of 2.08 acres.

Short-term construction-related emissions were calculated for site preparation, grading (earth movement), vertical construction, paving, and architectural coating. Long-term operational emissions were calculated for mobile sources (vehicle trips, vehicle emissions, fleet mix and road dust), land use

Potentially
Significant
Impact
Less Than
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Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 29
Draft Initial Study / Mitigated Negative Declaration December 2022 area sources, energy use, solid waste disposal, and water use. The model incorporated the fugitive dust control measures required under the City’s Dust Control Ordinance and SCAQMD Rules 403 and 403.1.

The measures required under this local regulatory framework are designed to prevent sediment trackout onto public roads, prevent visible dust emissions from exceeding a 20-percent opacity, and prevent visible dust emissions from extending more than 100 feet (vertically or horizontally from the origin of a source) or crossing any property line. Being a requirement in the Coachella Valley, the dust control practices described above are not treated as mitigation.

Discussion:

The modeling results presented in Table III-2 demonstrate that the peak short-term construction related emissions resulting from site preparation, grading, utilities/building construction, paving, and architectural coating of the project would not exceed the applicable SCAQMD regional thresholds of significance for any criteria pollutants, including PM10 and Ozone precursors. Thus, a less than significant impact would occur for project-related construction-source emissions.

Table III-2
Short Term Air Pollutant Emissions
Associated With Construction of the Proposed Project (Unmitigated) (Pounds/Day) ROG/VOC NOx CO SO2 PM10 PM2.5
Peak Emissions Resulting from
Site Preparation, Grading, Building Construction,
Paving, and Architectural Coating

13.5797 37.6511 35.0827 0.0686 7.3112 4.4605
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded No No No No No No
Note: CalEEMod does not directly calculate ozone (O3) emissions. Instead, the emissions associated with ozone precursors are calculated.

VOC and ROGs are summed in the CalEEMod report under the header ROG. The PM10 and PM2.5 emissions are based on the CalEEMod mitigated results due to the local standard requirement to implement SCAQMD Rule 403 and 403.1 to control fugitive dust.

Moreover, Table III-3 displays the estimate the long-term operational emissions of criteria air pollutants associated with the project’s area, energy, and mobile sources at buildout condition. The estimated emission levels generated from CalEEMod demonstrate that the project would not be expected to exceed the applicable SCAQMD Air Quality Significance Thresholds.

Table III-3
Long Term Operational Air Pollutant Emissions
Associated With Development of the Project (Unmitigated) (Pounds/Day) Emission Source ROG/VOC NOx CO SO2 PM10 PM2.5
Peak Emissions Resulting
from Area, Energy Use,
Mobile Sources

2.0234 0.8479 6.0027 0.0140 1.4065 0.3853
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded No No No No No No
Note: CalEEMod does not directly calculate ozone (O3) emissions. Instead, the emissions associated with ozone precursors are calculated. VOC and ROGs are summed in the CalEEMod report under the header ROG.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 30
Draft Initial Study / Mitigated Negative Declaration December 2022 In summary, by producing emission levels below the applicable SCAQMD Air Quality Significance Thresholds the project will prevent any interference with the City or region’s ability to comply with the most current air quality plans, including the 2016 AQMP, CVSIP for PM10, and the ozone level attainment efforts. Pertaining to the obstruction of an applicable air quality plan, less than significant impacts are anticipated.
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the Project region is non-attainment under
an applicable federal or state ambient air
quality standard?
Discussion:

Under the jurisdiction of SCAQMD, the Coachella Valley portion of the Salton Sea Air Basin (SSAB) is designated as nonattainment (Extreme) for the 1997 8-hour ozone (0.08 ppm) national ambient air quality standard with an attainment deadline to June of 2024. Coachella Valley is located downwind from the South Coast Air Basin (SCAB). As such, when high levels of ozone are formed in the South Coast Air Basin, they are transported to the Coachella Valley. Similarly, when ozone precursors such as nitrogen oxides (NOx) and volatile organic compounds (VOCs) are emitted from mobile sources and stationary sources located in the South Coast Air Basin, they are also transported to the Coachella Valley. SCAQMD has acknowledged that ozone exceedances in the Coachella Valley are primarily due to the direct transport of ozone and its precursors from the South Coast Air Basin, such that emissions in the Coachella Valley are deemed to have a limited impact on ozone levels compared to the transport of ozone precursors generated in SCAB.

Over the past 15 years, the air quality in the Coachella Valley had steadily improved because of the implementation of emission control measures by SCAQMD and California Air Resources Board (CARB).

However, in 2017 and 2018, higher ozone levels were experienced throughout the State of California due to changes in meteorology, biogenic emissions, and/or anthropogenic emissions. SCAQMD has prepared additional documentation and will be implementing additional measures to comply with the June 2024 deadline. Current and planned regulations on mobile and stationary sources are expected to contribute to improvements to ozone air quality in the Coachella Valley and lead to attainment of the standard.

Tables III-2 and III-3 demonstrate that the project-related short-term construction and long-term operational emission levels will not exceed the applicable SCAQMD Air Quality Significance Thresholds for ozone precursors (NOx and ROG/VOC). By complying with the current adopted thresholds, the proposed development is also complying with the overall attainment strategies reflected in the currently adopted by SCAQMD.

The Coachella Valley is currently designated as a serious nonattainment area for PM10 (particulate matter with an aerodynamic diameter of 10 microns or less). The U.S. EPA-approved Coachella Valley PM10 State Implementation Plan is in place with an attainment strategy for meeting the PM10 standard.

Some of the existing measures include the requirement of detailed dust control plans from builders that specify the use of more aggressive and frequent watering, soil stabilization, wind screens, and phased development to minimize fugitive dust. Desert Hot Springs Municipal Code Chapter 15.84, Control of Fugitive Dust Emissions, requires unpaved roads with average daily traffic levels between 20 and 150 vehicles to take measures (signage or speed control devices) to reduce vehicular speeds to no more

Potentially
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Impact
Less Than
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Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 31
Draft Initial Study / Mitigated Negative Declaration December 2022 than 15 miles per hour. Access to the project site will occur from Dillon Road, which is a paved roadway.

Appropriate air quality measures to prevent fugitive dust are required by the City’s Fugitive Dust Control ordinance and plan implementation requirements, which are consistent with SCAQMD Rules 403 and 403.1 that apply to the Coachella Valley strategy for reducing fugitive dust emissions.

Under the City’s Dust Control Ordinance, a Fugitive Dust Control Plan must be prepared and approved prior to any earth-moving operations. Implementation of the Fugitive Dust Control Plan is required to occur under the supervision of an individual with training on Dust Control in the Coachella Valley. The plan will include methods to prevent sediment track-out onto public roads, prevent visible dust emissions from exceeding a 20-percent opacity, and prevent visible dust emissions from extending more than 100 feet (vertically or horizontally from the origin of a source) or crossing any property line. The most widely used measures include proper construction phasing, proper maintenance/cleaning of construction equipment, soil stabilization, installation of track-out prevention devices, and wind fencing. Since projectrelated emissions would be consistent with the Air Quality Management Plan, the Coachella Valley PM10 SIP, and all SCAQMD Air Quality Significance Thresholds, long-term operational air quality impacts associated with the project should not be considered cumulatively considerable. Less than significant impacts are anticipated.

Mitigation Measures: None
c) Expose sensitive receptors to
substantial pollutant concentrations?
Discussion:

A sensitive receptor is a person or group in the population particularly susceptible (i.e. more susceptible than the population at large) to health effects due to exposure to an air contaminant. Sensitive receptors and the facilities that house them are of particular concern if they are located in close proximity to localized sources of carbon monoxide, toxic air contaminants, or odors. Land uses considered by the SCAQMD to be sensitive receptors include residences, long-term health care facilities, schools, rehabilitation centers, playgrounds, convalescent centers, childcare centers, retirement homes, and athletic facilities. As previously indicated, project surroundings primarily consist of vacant land and an industrial park. There are no nearby locations of potential sensitive receptors within the range of distances set forth by the SCAQMD LST Methodology; therefore, the longest distance interval of 500 meters (1,640 feet) is utilized for this analysis.

Table III-4
Localized Significance Thresholds (LSTs) Associated with Projected Construction With Receptors at 500 Meters (1,640 Feet), 5-Acre Area Increments (In Pounds/Day)
Emission Source NOx CO PM10 PM2.5
Maximum Unmitigated Emissions Resulting from Site
Preparation, Grading, Building Construction, Paving and Architectural Coating (Rounded Value)

37.6511 35.0827 7.3112 4.4605
SCAQMD LST Threshold for SRA 30 875 31,115 248 128
LST Threshold Exceeded? No No No No

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 32
Draft Initial Study / Mitigated Negative Declaration December 2022 Sources: CalEEMod Results and AQMD LST Look-Up Tables
Note: The PM10 and PM2.5 emissions are based on the CalEEMod mitigated results due to the local standard requirement to implement SCAQMD Rule 403 and 403.1 to control fugitive dust.

The CalEEMod results summarized in Table III-4 demonstrate that the construction activities will not result in temporary emissions in excess of the lowest (most conservative) localized thresholds. Therefore, regarding the exposure of sensitive receptors to substantial pollutant concentrations, less than significant impacts are anticipated.

Mitigation Measures: None
d) Result in other emissions (such as
those leading to odors) adversely affecting
a substantial number of people?
Discussion:

Objectionable odors can be associated with toxic or non-toxic emissions. While offensive odors seldom cause physical harm, they can be unpleasant and lead to considerable annoyance and distress among the public. Examples of facilities commonly recognized for generating odors include wastewater treatment plants, sanitary landfills, composting/green waste facilities, recycling facilities, petroleum refineries, chemical manufacturing plants, painting/coating operations, rendering plants, and food packaging facilities.

A sensitive receptor is a person in the population who is particularly susceptible (i.e., more susceptible than the population at large) to health effects due to exposure to an air contaminant. Sensitive receptors and the facilities that house them are of particular concern if they are located in close proximity to localized sources of carbon monoxide (CO), toxic air contaminants, or odors. Examples of sensitive receptors include residences, long-term health care facilities, schools, rehabilitation centers, playgrounds, convalescent centers, childcare centers, retirement homes, and athletic facilities.

As previously described in the project description, the vacant project property is surrounded by vacant land and one industrial park facility. There are no existing or planned residential units located downwind in relation to the prevailing wind patterns.

The proposed enclosed facility of 60,000 square feet will accommodate logistics/warehouse operations with the respective administration partitions (lobby, offices, break room, conference room, restrooms).

Most of the building area will be an open floor for storage containers. The project does not involve any outdoor storage or work areas known to generate odors. As a standard requirement under SCAQMD Rule 402, no operation or activity on-site shall cause the emission of any smoke, fly ash, dust, fumes, vapors, gases, odors, or other forms of air pollution, which exceed levels identified as acceptable by the SCAQMD or the City of Desert Hot Springs. Less than significant impacts related to objectionable odors are anticipated.

Mitigation Measures: None
IV. BIOLOGICAL RESOURCES -- Would the Project:

Sources: Coachella Valley Multiple Species Habitat Conservation Plan/Natural Community Conservation

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 33
Draft Initial Study / Mitigated Negative Declaration December 2022 Plan, CVAG; Desert Hot Springs General Plan, 2020; General and Focused Biological Resources Assessment and CVMSHCP Consistency Analysis, James W. Cornett Ecological Consultants, July 2022. 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?
Discussion:

In July 2022, James W. Cornett Ecological Consultants conducted a project-specific General and Focused Biological Resources Assessment and Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) Consistency Analysis. The assessment area covered the project site and 100 yards beyond all site boundaries. The biological survey and analyses were designed to ascertain the impacts of proposed development on the potential biological resources of the project site and immediate vicinity, as mandated by CEQA and required by the City of Desert Hot Springs. The entire site has been grubbed and graded and is devoid of vegetation. Based upon the near absence of plant life, the site may have been graded within the last twelve months.

The specific objectives of the biological survey are listed below:
 Determine the vascular plant and vertebrate animal species that occur on, and immediately adjacent to, the Project site.
 Ascertain the presence of plant or animal species given special status by government agencies, with an emphasis on sensitive species or communities not covered under the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP).  Ascertain the existence of other significant biotic elements, corridors or communities.  Consider the site’s biological resources as they relate to the CVMSHCP and its Conservation Areas.
 If necessary and where appropriate, recommend measures to mitigate significant adverse impacts of the Project on sensitive species and habitats not covered in the CVMSHCP but determined to occur within the Project boundaries.

Survey methodology included literature, records, collections, website, or staff review to determine resources that are known to exist within the general area and to determine the possible occurrence of sensitive species. The University of California at Riverside Herbarium, the Boyd Deep Canyon Desert Research Center, the Coachella Valley Association of Governments, the Calflora and iNaturalist websites, and the California Department of Fish and Game Natural Diversity Database were reviewed and consulted for specific information regarding the occurrence of sensitive species. Field surveys for plant and animal species were started in April of 2022. Daytime field surveys were conducted on April 30, May 23 through the 27th, June 28th and July 1, 2022. Night surveys were conducted on May 23 and

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 34
Draft Initial Study / Mitigated Negative Declaration December 2022 24, 2022. In addition, twenty-five live-animal traps (which capture animals unharmed) for large and small mammals were set within the Project site for twenty-four-hour periods on May 23 and 24, 2022.

Surveys were conducted by walking north-south transects at 10-yard intervals through the Project site and 100 yards beyond site boundaries (except to the west due to the presence of fenced private property).

The survey techniques used during this assessment have been approved by the U.S. Fish and Wildlife Service for determining the presence or absence of the burrowing owl and desert tortoise and represents an intensive survey effort that resulted in no officially listed or federally protected species being overlooked.

The elevation of the project site is approximately 765 feet above sea level. According to the report, there is no topographical relief. The environment of the project site is part of the desert scrub habitat of the valley floor as described in the CVMSHCP.

The Project Specific Biological Assessment indicates there are no naturally occurring springs or permanent aquatic habitats within or near the project site boundaries. Soil characteristics are relatively uniform over the entire site. Surface soil is sandy with very few pebbles, cobbles, or small boulders.

No plant community exists within the project boundaries. The entire site was first graded in 2018 and has been graded again within the past year. Immediately beyond the north and south project site boundaries lies moderately disturbed Sonoran creosote scrub community, which dominated the site prior to the 2018 grading. Species present at the time the field surveys were conducted in the parcels that abut the project site include creosote bush, burrobush, Mojave indigo bush, brittlebush, and Emory’s Dalea. These plants, and the creosote scrub community, are widespread in the Colorado Desert of southeastern California.

Soil disturbance in and around the project site have resulted in slight intrusion of weed species that germinate and grow after damage of removal of native vegetation. On the project site, such species include Sahara mustard, bugseed, and Schismus grass. Each of these species occur in the Colorado Desert wherever the natural vegetation has been removed.

The Inventory of Rare and Endangered Plants of California, published by the California Native Plant Society (CNPS), the CNDDB Special Plant List (2021), or the Endangered, Threatened, and Rare Plants of California (2021), list a total of twenty-seven plant species occurring within the three USGS quadrangles considered in this study (Desert Hot Springs, Palm Springs and Seven Palms Valley). Only one of these species, the Coachella Valley milk-vetch, sometimes appears on habitats that have been graded.

The Coachella Valley milk-vetch is an uncommon, spring blooming perennial herb that is known to occur on sandy soils in the Coachella Valley. No Individuals of this species were found within the project site boundaries. The milk-vetch is listed as endangered by the U.S. Fish and Wildlife Service. Impacts to the milk-vetch are fully mitigated by the CVMSHCP through the payment of the Plans mitigation fee and no further action is necessary.

The biological report concludes that there is no evidence or records that any plant species considered sensitive occurs within the project site boundaries, particularly since the site has been graded. More importantly, any species that might occur on the project site is either a covered species under the CVMSHCP or not listed (or a candidate for listing) by either the state or federal governments. Therefore, there are no recommendations for future surveys or mitigation.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 35
Draft Initial Study / Mitigated Negative Declaration December 2022 Encountered arthropods on the site included the Eleodes beetle (Eleodes armata), and harvester ant (Pogonomyrmex californicus). Two insect species known to occur within the Coachella Valley have been placed on the California Department of Fish and Game’s Special Animals list. They are the Coachella giant sand treader cricket (Macrobaenetes valgum), and the Coachella Valley Jerusalem cricket (Stenopelmatus cahuilaensis). The United States Fish & Wildlife Service has listed as endangered a third insect species, Casey’s June beetle, (Dinacoma caseyi). (Casey’s June beetle is not a covered species under the CVMSHCP.) None of these three-insect species were found during the surveys though the former two may be present. All are either covered species under the CVMSHCP, are not listed, or are not candidates for listing.

No mammals were recorded within project site boundaries. The long-tailed pocket mouse (Chaetodipus formosus), deer mouse (Peromyscus maniculatus), black-tailed jack rabbit (Lepus californicus) and coyote (Canis latrans) were recorded from neighboring parcels. No individuals of the desert kit fox (Vulpes macrotis arsipus) were seen or detected on or near the project site. Mass grading, human activity, and presence of coyotes in the general areas are the likely explanation for its absence. The desert kit fox is fully protected in California and is not a covered species under the Plan. There are no bat roosting sites on or near the project site.

One mammalian species that was detected in neighboring parcels and contained within the California Department of Fish & Game Special Animals List) is the Palm Springs ground squirrel (Spermophilus tereticaudus chlorus). The Palm Springs ground squirrel is considered a state Species of Special Concern. In the past it was considered a candidate species for listing by the United States Fish & Wildlife Service. It likely occurs on or near the site but is a covered species under the CVMSHCP, and mitigation is fully provided under the Plan.

Frequently observed birds within the project area were common raven (Corvus corax), mourning dove (Zenaida macroura), turkey vulture (Cathartes aura), and Say’s phoebe (Sayornis saya).

No observations or calls of LeConte’s thrasher (Toxostoma lecontei) were recorded during the surveys.

In the Coachella Valley this species is closely associated with golden cholla in which it nests. No large golden chollas, suitable for nest building, were present within the project boundaries. LeConte’s thrasher is a covered species under the CVMSHP.

Two special-status avian species, potentially occurring within the project boundaries, are the burrowing owl (Athene cunicularia) and loggerhead shrike (Lanius ludovicianus).

The burrowing owl was not seen during the field surveys and no evidence of its presence was found.

However, ground squirrel burrows which may be usurped by owls, and friable soil for burrow construction or enlargement is considered suitable habitat for the owl and burrowing owls are known to take up residence on recently graded sites.

No observations of the loggerhead shrike were recorded. Shrikes nest in dense shrubs or trees that are at least three feet in height. No breeding habitat for this species was found. Therefore, no additional surveys for this species are recommended.

Absence of natural shelters and surface water preclude the site being considered a significant resource for other migratory bird species.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 36
Draft Initial Study / Mitigated Negative Declaration December 2022 The only reptile observed within the project site boundaries was the side blotched lizard (Uta stansburiana). No individuals of the officially threatened Coachella Valley fringe-toed lizard, (Uma inornate), were observed, detected, or expected due to the recent grading of the site. An intensive effort was also made to locate evidence of the flat-tailed horned lizard, (Phrynosoma mcallii). However, no individuals were observed, and no sign (scat, tracks) was found. It was concluded the species does not occur on the project site. The flat-tailed horned lizard was proposed to be listed by the federal government as threatened, the proposal has been rescinded. The state government considers the flat-tailed horned lizard a Species of Special Concern. The flat-tailed horned lizard is a covered species under the CVMSHCP and specific mitigation for this species is not required.

A concerted effort was made to locate signs of the officially listed desert tortoise (Goperhus agassizi).

However, no evidence of any kind (shell fragments, scat, tracks, burrows) was found and no direct observations were made. It is concluded that this species does not occur within the project site and immediate vicinity at this time and no additional surveys for this species are warranted.

The project specific biological report concludes that no amphibian species were found during the surveys, and none are expected.

The project lies within the boundary of the CVMSHCP, which outlines policies for conservation of habitats and natural communities. The CVMSHCP implements a habitat mitigation fee from new development in order to support the acquisition of conservation lands. The fee would be applied per Chapter 3.40 of the Desert Hot Springs Municipal Code (Coachella Valley Multiple Species Habitat Conservation Plan/Natural Community Conservation Plan Mitigation Fees). The project is expected to comply with provisions of the CVMSHCP.

Therefore, less than significant impacts are expected to 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 the U.S. Fish and Wildlife Service, following the recommended mitigation measures listed below:

Mitigation Measures:

BR-1: The project proponent shall ensure that burrowing owl clearance survey is performed not more than 14 days prior to project site disturbance (clearing, grubbing, grading, and construction), and then again 24-hours prior to site disturbance, as burrowing owls may colonize or recolonize the site within the time between the original survey and project activities. If any owls are identified, the most current protocol established by the California Department of Fish and Wildlife (Burrowing Owl Mitigation) must be followed.

BR-2: Prior to construction and issuance of any grading permit, the City of Desert Hot Springs shall ensure compliance with the CVMSHCP and its associated Implementing Agreement and shall ensure that payment of the CVMSHCP Local Development Mitigation Fee for the proposed Project is sent to the Coachella Valley Conservation Commission.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 37
Draft Initial Study / Mitigated Negative Declaration December 2022 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 Wildlife
or U.S. Fish and Wildlife Service?
Discussion:

The biological survey performed on the project property did not find any on-site naturally occurring springs, permanent aquatic habitats or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service. No blue-line stream corridors were found within the project boundaries. Therefore, less than significant impacts are expected.

Mitigation Measures: None
c) Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal,
filling, hydrological interruption, or other
means?
Discussion:

According to the Project Specific Biological Resource Assessment, the project site does not contain federally protected wetlands, marshes or other drainage features. No bodies of standing water, streams, or washes are present on site. The National Wetlands Inventory from the USFWS, identified no wetlands or riparian resources on the project property. Furthermore, the Biological Resources Assessments did not identify naturally occurring springs or permanent aquatic habitats in or near the project site boundaries nor are there botanical indicators of such corridors.

Implementation of the project would not result in the direct removal, filling or other hydrological interruption to any of these resources. The proposed on-site storm drain improvements shall include facilities to prevent the direct discharge impacts of runoff to any adjacent land uses. A Project Specific Water Quality Management Plan (WQMP) is expected to be prepared to ensure that the project does not contribute pollutants of concern in any project storm runoff. In addition, the implementation of the on-site storm drain improvements in conjunction with the Project Specific WQMP will work to minimize impacts runoff. Therefore, less than significant impacts are expected.

Mitigation Measures: None
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?

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 38
Draft Initial Study / Mitigated Negative Declaration December 2022 Discussion:

Per the project-specific biological report, no migratory wildlife corridors or native wildlife nursery sites were found on the project or adjacent properties and no discernable and routinely used corridors were identified. No impacts relative to migratory corridors are expected.

Mitigation Measures: None
e) Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance?

Discussion:

The project property is presently vacant and undeveloped with scattered vegetation. Project implementation would not result in demolition or tree removal. The proposed site plan provides landscaping improvements along the project edges in a manner consistent with the local development standards. The project will comply with the provisions of the CVMSHCP. There are no other unique local policies or ordinances protecting biological resources that would cause a conflict nor does the site support high value biological resources that could be affected. There are no applicable tree preservation policies or ordinances and no impacts are expected.

Mitigation Measures: None
f) Conflict with the provisions of an
adopted Habitat Conservation Plan,
Natural Community Conservation Plan,
or other approved local, regional, or state
habitat conservation plan?
Discussion:

As previously mentioned in discussion a), the project lies within the boundary of the CVMSHCP, which outlines policies for conservation of habitats and natural communities. The CVMSHCP implements a habitat mitigation fee from new development in order to support the acquisition of conservation lands.

The fee would be applied per Chapter 3.40 of the Desert Hot Springs Municipal Code (Coachella Valley Multiple Species Habitat Conservation Plan/Natural Community Conservation Plan Mitigation Fees). The project is expected to comply with provisions of the CVMSHCP. Less than significant impacts would result from project implementation provided the procedures established in Mitigation Measure BR-1 and BR-2 of this Initial Study are implemented.

Mitigation Measures: See BR-1 and BR-2
V. CULTURAL RESOURCES –Would the Project:

Sources: Desert Hot Springs General Plan, 2020; Historical/Archaeological Resources Survey Report, CRM Tech, 2022.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 39
Draft Initial Study / Mitigated Negative Declaration December 2022 a) Cause a substantial adverse change in
the significance of a historical resource
pursuant to § 15064.5?
Discussion:

The project is located on approximately 4.85 acres of vacant and undeveloped land in the City of Desert Hot Springs. Currently, the project site is vacant, however, the entire site has been grubbed and graded from previous construction operations. The site exhibits a predominantly flat condition. Overall, there are no salient topographic features or other natural visual landmarks on the project site or its general surroundings.

Between September and December 2022, CRM Tech performed a cultural resources study on the approximately 4.86-acre project site. The purpose of the cultural resource study is to provide the City with the necessary information and analysis to determine whether the project would cause substantial adverse changes to any historical resources, as defined by CEQA, that may exist in or near the project area. In order to identify such resources, CRM Tech initiated a historical/archaeological resources records search, contacted the appropriate Native American representatives, pursued historical background research, and carried out an intensive-level field survey in conjunction with the nearby Agua Caliente Band of Cahuilla Indians (ACBCI). The field survey occurred on November 1, 2022, and was conducted on foot at an intensive level by walking a series of parallel north-south transects spaced approximately 50 feet apart.

In this way, the ground surface in the entire project area was systematically and carefully examined for evidence of human activities dating to the prehistoric or historic period (i.e., 50 years ago or older).

The records search was provided by the Eastern Information Center (EIC) of the California Historical Resources Information System (CHRIS) on October 27, 2022. The EIC search uncovered one previous cultural resources study that included the project area. The previous cultural resource study took place in 2006 by CRM Tech. The 2006 survey did not encounter any cultural resources within or adjacent to the current project boundaries. Other studies did not discover resources within the project site.

Historical background research was conducted by CRM Tech and included reviewing published literature in local history and historical maps and aerial/satellite photographs of the project vicinity. Historical sources consulted show evidence of human activities in the surrounding area as early as the mid-19th century but no such evidence within the project boundaries throughout the historic period. In the 1850s, when the U.S. government conducted the first systematic land survey in the Coachella Valley, an “Indian trail” was noted running east-west approximately a quarter-mile south of the project location. The trail later evolved into U.S. Highway 60/70/99 further to the south by the early 20th century and eventually Interstate Highway 10 by the 1950s, but its presence nearby had little impact on the project area itself.

The desert landscape within the project boundaries remained largely undisturbed until 2017-2018, when the property was cleared, graded, and evidently used as a staging area for the development project to the west (“Coachillin”). Based on these sources, the project area is likely low in sensitivity for cultural resources from the historic period.

Additionally, the site is not identified in the City of Desert Hot Springs General Plan 2020 as having Historic Resource Sensitivity. The research results summarized above and in CRM Tech’ s Cultural Report, found that no potential historical resources were previously recorded within the project area, and none were found during the field survey. Therefore, the project site is not expected to cause a substantial adverse change in the significance of a historical resource as defined by CEQA §15064.5 (b) and less than significant impacts are expected.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 40
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
b) Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to §15064.5?

Discussion:

As previously mentioned, the project site has been graded from previous construction activities and is not likely to have archaeological resources. Additionally, CRM Tech’s Cultural Report, which included records search, historical research, and a field survey, determined further cultural resources investigations are not necessary for the project. However, it is recommended that a cultural resources monitor be onsite during any ground-disturbing activities and that a qualified archaeologist be notified of any cultural finds. Additionally, proper procedures in accordance to State law, which includes contacting the County Coroner, should be followed if any human remains are found during earthmoving activities.

Less than significant impacts are expected following the recommended mitigation measure

Mitigation Measures:

CUL-1: The presence of a qualified archaeological monitor or Cultural Resource Monitor shall be required during all project related ground disturbing activities (clearing, grubbing and grading). In the event that cultural resources are discovered during project activities, all work in the immediate vicinity of the find (within a 50-foot buffer) shall cease and a qualified archaeologist meeting Secretary of Interior standards shall be hired to assess the find. Work on the other portions of the project outside the buffered area may continue during this assessment period.
c) Disturb any human remains, including
those interred outside of formal cemeteries?
Discussion:

The entire project area and radius was closely inspected for evidence of human activities dating to prehistoric or historic periods. As discussed previously, no other sites, features, artifacts, or builtenvironment features of prehistoric or historic age were encountered within the project area during the field survey.

Pursuant to the California Health and Safety Code Section 7050.5, and the CEQA Guidelines Section 15064.5 require that in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site, or any nearby area reasonably suspected to overlay adjacent remains, until the County Coroner has examined the remains. If the coroner determines the remains to be Native American or has reason to believe that they are Native American, the coroner shall contact by telephone within 24-hours of the Native American Heritage Commission. Pursuant to the mentioned California Health and Safety Code, proper actions shall take place in the event of a discovery or recognition of any human remains during project construction activities. Less than significant impacts are expected.

Mitigation Measures: None
VI. ENERGY -- Would the project:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 41
Draft Initial Study / Mitigated Negative Declaration December 2022 Sources: California Emissions Estimator Model (CalEEMod), Version 2020.4.0; Desert Hot Springs General Plan, 2020; Desert Hot Springs General Plan Environmental Impact Report, 2020; California Transportation Data for Alternative Fuels and Vehicles, U.S. Department of Energy, accessed July 2022; U.S. Energy Information Administration, accessed 2022.
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy
resources, during project construction or
operation?
Discussion:

The project proposes the development of one, 60,000-square-foot building to support a climatecontrolled container storage facility and supporting infrastructure improvements. The facility is expected to house a company which moves goods in portable storage units Such units are delivered by truck to homes and businesses where they are filled with personal or business belongings, are then picked up again by truck for storage in the warehouse before the storage unit is moved to the location requested by the client. The storage units are warehoused for a short or long duration, and per the client’s needs are removed from the warehouse for delivery to a local or national destination. This building is not a refrigerated/cold storage warehouse. The project proposes internal paved drive aisles, 92 paved parking spaces, and landscaping throughout. Vehicular access will be provided from Calle De Los Romos.

Electricity and natural gas are the primary sources of energy in the City of Desert Hot Springs. Electricity is provided to the City and Sphere of Influence (SOI) by Southern California Edison (SCE). SCE is regulated by the California Public Utilities Commission and Federal Energy Regulatory Commission (FERC) and receives electric power from a variety of sources. According to SCE’s website, 35.1 percent of SCE’s power came from eligible renewable sources in 2019, including biomass/biowaste, geothermal, hydroelectric, solar, and wind sources.

The Southern California Gas Company (SoCalGas or the Gas Company) provides natural gas to Desert Hot Springs. Natural gas is found in association with petroleum crude oil deposits and is transported throughout the country through transmission and high-pressure distribution lines. The closest distribution lines are located approximately a mile west and north of the project, along Karen Avenue and Dillon Road, respectively. The closest transmission lines to the project is located approximately 0.70 miles south, along Garnet Avene.

Petroleum accounts for approximately 92 percent of California’s transportation energy sources. In 2019, California consumed approximately 14.4 billion gallons of gasoline and 3.98 billion gallons of diesel.

Gasoline and other vehicle fuels are commercially provided commodities and would be available to the project via commercial outlets. Technological advances, market trends, consumer behavior and government policies could result in significant changes to fuel consumption by type and total. Various policies, rules and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation-source air pollutants and greenhouse gas (GHG) emissions, and reduce vehicle miles traveled (VMT), at Federal and State levels.

Technological advances have made use of other energy resources or alternative transportation modes increasingly feasible, as market forces have driven the price of petroleum products steadily upward.

The project is expected to consume energy in the form of electricity, natural gas, and petroleum during

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 42
Draft Initial Study / Mitigated Negative Declaration December 2022 project construction and operation. Analysis of the project-related energy consumption was calculated using the latest version of CalEEMod (v2020.4.0). CalEEMod was used to calculate construction-source and operational-source criteria pollutant and GHG emissions from direct and indirect sources. The most conservative interpretation of proposed land uses, equitable modelling criteria, and associated energy impacts have been utilized to capture impacts associated with 100% of the proposed onsite structures.

The project is categorized into two land uses within CalEEMod: Industrial Park and Parking Lot. Project related energy consumption, via electricity, natural gas, and petroleum is analyzed subsequently.

Electricity
As previously stated, electricity is provided to the City of Desert Hot Springs and the project site by SCE.

SCE’s facilities include high-voltage transmission lines, lower voltage distribution lines, and substations, which lowers voltage so that it can be distributed to homes and businesses. SCE’s transmission system includes high-voltage lines rated at 500, 230, 115, 66 and 55 kilovolts (kV). Distribution lines are those rated below 55 kV. Electric power is transported to individual homes and businesses from substations through 33 and 12 kV distribution lines.

Construction
Temporary electrical power for lighting and electronic equipment, such as computers inside interim construction trailers, would be provided by SCE. Electricity consumed for onsite construction trailers, which are used by managerial staff during the hours of construction activities, as well as electricallypowered hand tools are expected to use a minimal amount of electricity. However, the electricity used for such activities would be temporary and negligible. Most energy used during construction would be from petroleum consumption.

Operation
The project proposes the operation of a container storage facility on approximately 4.85 acres of vacant land. The project would not result in the use of excessive amounts of fuel or electricity and would not result in the need to develop additional sources of energy. Although energy use at the project would not be excessive, the project would incorporate several measures directed at minimizing energy use. These measures include applying energy efficient design features, including using high efficiency lighting, to meet Title 24 Standards, and therefore, reducing electricity consumption during project operation.

According to the CalEEMod calculations, the project is expected to generate the demand for approximately 583,111.7 kWh of annual electricity demand. This is depicted in Table VI-1, Operational Electricity Demand, below.

Table VI-1 Operational Electricity Demand
Electricity Demand
Land Use kWh/yr
Industrial Park 551,400
Parking Lot 31,711.7
Total 583,111.7
According to the Desert Hot Springs General Plan (DHSGP) Environmental Impact Report (EIR), Desert Hot Springs will consume approximately 575,687,510 kWh of electricity annually at buildout (year 2040).

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 43
Draft Initial Study / Mitigated Negative Declaration December 2022 The project is estimated to consume approximately 583,111.7 kWh/yr., which is approximately 0.10 percent of the total annual electricity use for the City at buildout. Operation of the project is not anticipated to use excessive amounts of electricity and impacts are expected to be less than significant.

Natural Gas
According to the DHSGP EIR, natural gas consumption for City of Desert Hot Springs (at buildout) totals to approximately 1,805,720,920 thousand British Thermal Units (kBTU) annually. The proposed project will utilize natural gas during the operation of the project.

Construction
Natural gas is not anticipated to be required during construction of the project. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed under the following petroleum subsection. Any minor amounts of natural gas that may be consumed because of project construction would be temporary and negligible and would not have an adverse effect.

Operation
The consumption of natural gas typically is consumed during building heating, water heating and cooking, which will occur during project operation. The project’s expected natural gas consumption was calculated using the CalEEMod default values. Based on the CalEEMod calculations, the project is estimated to consume approximately 205,800 kBTU of natural gas annually during operation of the entire project. Project natural gas consumption is displayed in Table VI-2, Operational Natural Gas Demand.

Table VI-2 Operational Natural Gas Demand
Natural Gas Demand
Land Use kBTU/year
Industrial Park 205,800
Parking Lot 0
Total 205,800
As such, the project would result in a long-term increase in demand for natural gas. As previously stated, the DHSGP EIR calculated that the City, at total buildout, will consume approximately 1,805,720,920 kBTU of natural gas annually. The project is proposed to consume approximately 205,800 kBTU of natural gas per year, which is approximately 0.01 percent of the estimated total annual natural gas use for the City at buildout. Therefore, natural gas consumption would be appropriate and not excessive or inefficient.

Petroleum
Petroleum is the largest U.S. energy source according to the U.S. Energy Information Administration (EIA). Petroleum products are used to fuel vehicles and produce electricity. U.S. petroleum consumption in 2020 was primarily used by the transportation sector (85 percent). The industrial sector accounted for 12 percent petroleum consumption, the commercial consumed 2 percent, and finally, the residential sector consumed less than 1 percent.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 44
Draft Initial Study / Mitigated Negative Declaration December 2022 Construction
The project will consume petroleum throughout project construction. Fuel consumed by construction equipment would be the primarily energy resource expended over the course of construction, while vehicle miles traveled (VMT) associated with the transportation of construction materials and construction worker commutes would also result in petroleum consumption. Heavy-duty equipment used for project construction would rely on diesel fuel, as would haul trucks involved in off-hauling materials from excavation. Construction workers are expected to travel to and from the project site in gasolinepowered passenger vehicles. There are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive that is used for comparable activities or use of equipment that would not conform to current emission standards (and related fuel efficiencies).

Heavy-duty construction equipment of various types would be used during each phase of construction.

CalEEMod was used to estimate construction equipment usage. Fuel consumption from construction equipment was estimated by converting the total CO2 emissions from each construction phase to gallons using the conversion factors shown in the subsequent tables.

Table VI-3, Construction Worker Gasoline Demand, illustrates the demand of gasoline fuel for construction worker trips to and from the site during each construction phase. Construction worker gasoline demand during each phase of development equals a total of 7,400.3 gallons of gasoline fuel.

Table VI-3 Construction Worker Gasoline Demand
Phase Days Trips Miles VMT KgCO2e Kg/CO2/Gallon Gallons Site Prep. 5 18 14.60 1,314 392 8.89* 44.1
Grading 20 15 14.60 4,380 1301.4 8.89 46.4
Building Const. 230 63 14.60 211,554 61488.5 8.89 6,917 Paving 25 20 14.60 7,300 2119.5 8.89 238.4
Arch. Coating 25 13 14.60 4,745 1372.3 8.89 154.4
Total 7,400.3
*https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-references https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator Table VI-4, Construction Vendor Diesel Fuel Demand (below), illustrates the demand of diesel fuel for construction vendor trips to and from the site. These trips are associated with the delivery of construction materials during the construction phase. Construction vendor demand equals a total of 4,516.2 gallons of diesel fuel.

Table VI-4 Construction Vendor Diesel Fuel Demand
Phase Days Trips Miles VMT KgCO2e Kg/CO2/Gallon Gallons Site Prep. 5 0 0 0 0 10.18* 0
Grading 20 0 0 0 0 10.18 0
Building Const. 230 25 6.20 35,650 45,975.4 10.18 4,516.2 Paving 25 0 0 0 0 10.18 0
Arch. Coating 25 0 0 0 0 10.18 0
Total 4,516.2
*https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-references https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 45
Draft Initial Study / Mitigated Negative Declaration December 2022 Table VI-5, Construction Equipment Diesel Fuel Demand, displays the demand of diesel fuel for construction vehicles on-site during the various construction phases. Construction equipment diesel demand equals a total of 32,090.5 gallons of diesel fuel.

Table VI-5 Construction Equipment Diesel Fuel Demand
Phase Days Equipment Units KgCO2e Kg/CO2/Gallon Gallons Site Prep. 5 7 8,427.4 10.18 827.8
Grading 20 6 26,266.3 10.18 2,580.2
Building Const. 230 9 268,157.4 10.18 26,341.6
Paving 25 8 20,634 10.18 2,026.9
Arch. Coating 25 1 3,196.3 10.18 314
Total 32,090.5
Overall, the project is estimated to consume approximately 7,400.3 gallons of gasoline and 36,606.7 gallons of diesel fuel during the project’s construction phases. In total, the project will consume approximately 44,007 gallons of petroleum. Per the City General Plan Environmental Impact Report (EIR), the City of Desert Hot Springs consumed approximately 21,989,676 gallons of petroleum in year 2019 and is projected to consume approximately 51,531,567 gallons of petroleum in year 2040.

Therefore, project construction will consume approximately 0.20 percent of petroleum consumption compared to consumption in year 2019, and 0.08 percent of petroleum consumed compared to year 2040. Additionally, petroleum use during construction would be temporary. Therefore, construction of the project will not consume petroleum in a manner that is unnecessary, wasteful, or inefficient.

The energy used during the construction of the project would be limited to the development of the project and would not require long-term petroleum use. Additionally, there are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive that is used for comparable activities or use of equipment that would not conform to current emissions standards (and related fuel efficiencies). Thus, project construction would not consume petroleum in a wasteful or inefficient manner.

Operation
According to the figures provided by the CalEEMod calculations, the project would have an estimated annual VMT of 570,302. The average daily trip rate (ADT) for weekdays is 202.2 ADT, 152.4 on Saturdays, and 74.4 on Sundays. Total mobile source CO2e is 194.0335 MT per year, or 194,033.5 kg per year. CalEEMod assumes 92.5 percent of VMT burns gasoline, while the remaining 7.5 percent burn diesel. Thus, of the 194,033.5 kg of mobile emissions, approximately 179,481 kg is generated by gasoline combustion and 14,552.5 kg is generated by diesel combustion. The project would have an annual gasoline demand of 20,189.1 gallons and an annual diesel demand of 1,429.5 gallons, as displayed in Table VI-7.

Table VI-6, Operational Petroleum Demand
Land Use Annual VMT
Industrial Park 570,302
Parking Lot --
Total 570,302

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 46
Draft Initial Study / Mitigated Negative Declaration December 2022 Table VI-7 Operational Annual Petroleum
Annual VMT KgCO2e Kg/CO2/Gallon Annual Gallons
Gasoline 527,529.35 179,481 8.89 20,189.1
Diesel 42,772.65 14,552.5 10.18 1,429.5
Total Petroleum 21,618.6
The Desert Hot Springs General Plan EIR predicts that the City of Desert Hot Springs will consume approximately 8,608,831 gallons of diesel, 42,922,736 gallons of gasoline, for a total petroleum consumption of 51,531,567 gallons at buildout of the City (year 2040). The project is estimated to consume 21,618.6 gallons of petroleum annually, approximately 0.042 percent of the City’s total projected petroleum consumption at buildout. Therefore, operation of the project will not consume petroleum in a manner that is unnecessary, wasteful, or inefficient.

Over the lifetime of the project, the fuel efficiency of vehicles in use is expected to increase, as older vehicles are replaced with newer more efficient models. Therefore, it is expected that the amount of petroleum consumed due to the vehicle trips to and from the project site during operation would decrease over time. Additional advancement of technology includes the use of plug-in hybrid and zero emission vehicles in California, which will also decrease the amount of future petroleum consumed in the state. With the foregoing, operation of the project is expected to use decreasing amounts of petroleum over time, due to advances in fuel economy. Additionally, the proposed facility is located approximately 0.50 miles east of North Indian Canyon Drive. North Indian Canyon Drive is a major corridor within the City that provides access to the City and surrounding cities.

Although the project would result in an increase in petroleum use during construction and operation compared to the existing conditions, the project would implement measures required under the City’s General Plan and City Municipal Code. Additionally, the regional VMTs and associated vehicular-source emissions are reduced by the following project design feature/attribute: on-site sidewalk improvements will be implemented to improve pedestrian connectivity to the surroundings. Given this consideration, petroleum consumption associated with the project operation would not be considered excessive.

In conclusion, the project would increase demand for energy in the project area and in the service area of SCE. However, based on the findings described above, project construction and operation are not anticipated to result in potentially significant impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

Mitigation Measures: None
b) Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency?
Discussion:

The approximately 4.85-acre project proposes the development of one, 60,000-square-foot building to support a container storage facility and supporting infrastructure improvements at the northeast corner

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 47
Draft Initial Study / Mitigated Negative Declaration December 2022 of Calle De Los Romos and 19th Avenue in Desert Hot Springs. As stated in the previous discussion, project development and operation are not anticipated to use an unnecessary amount of energy resources. To ensure the conservation of energy, the State of California and the City of Desert Hot Springs implements various regulations in order to be more energy efficient and reduce the amount of GHG emissions. Some of the State-wide and local regulations are listed below.

State Regulations
Assembly Bill 32
Assembly Bill 32 (AB 32) was signed in 2006 to establish and reduce the amounts of greenhouse gases being emitted on a state-wide level. Specifically, AB 32 requires a reduction of emissions to 1990 levels by 2020. It plans to do this by establishing an annual reporting program for significant sources. Energy efficiency goals listed in AB 32 includes maximizing energy efficiency building and appliance standards, and pursuing additional efficiency efforts including new technologies, and new policy and implementation mechanisms.

Executive Order S-3-05
Executive Order (EO) S-3-05, passed in 2005, established reduction targets of an 80 percent of 1990 levels reduction by 2050, and created agencies to achieve these targets. The passage of this regulation requires the use of more energy efficient practices regarding building development and operation in order to reduce the amount of GHGs produced.

Title 20: Appliance Efficiency Standards
The California Code of Regulations (CCR), Title 20: Division 2, Chapter 4, Article 4, Sections 1601-1608 (Appliance Efficiency Regulations) regulates the sale of appliances in California. The Appliance Efficiency Regulations include standards for both federally regulated appliances and non-federally regulated appliances. 23 categories of appliances are included in the scope of these regulations. The standards within these regulations apply to appliances that are sold or offered for sale in California, except those sold wholesale in California for final retail sale outside the state and those designed and sold exclusively for use in recreational vehicles or other mobile equipment.

Title 24: Building Energy Efficiency Standards and CALGreen Building Standards Code In addition to Title 20 (Sections 1601-1608) of the CCR, Title 24, parts 6 and 11, also outlines energy efficient building designs for new development. The CCR’s 2019 Building Energy Efficiency Standards (Title 24, Part 6), and the CALGreen Building Standards Code (Title 24, Part 11), establish mandatory guidelines and standards requiring more energy efficient new and existing developments. The California Energy Commission adopted the Building Energy Efficient Standards for all new residential and nonresidential construction to reduce greenhouse gases, as a part of the California Building Code, Title

24. This requires new homes to include at least 50 percent of kitchen lighting to be LED, compact fluorescent or similar high efficiency fixtures, double pane windows, cool roofs, and other design techniques to reduce heat loss. Title 24, Part 11, establishes design and development methods that include environmentally responsible site selection, building design, building siting and development to protect, restore and enhance the environmental quality of the site and respect the integrity of adjacent properties. The project will be required to comply with the state implemented standards for energy efficient new developments.

California’s Renewable Portfolio Standards
The California Renewable Portfolio Standards will reduce GHG emissions by requiring utility companies,

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 48
Draft Initial Study / Mitigated Negative Declaration December 2022 such as SCE, to switch from non-renewable resources, such as coal-fired power plants, to renewable resources, such as wind turbines and solar power.

Low Carbon Fuel Standard
The Low Carbon Fuel Standard (LCFS), or Executive Order (EO) S-1-07, establishes a low carbon fuel standard for transportation fuels in California. EO S-1-07 was enacted to reduce carbon intensity in transportation fuels as compared to conventional petroleum fuels, such as gasoline and diesel. It requires that the carbon intensity of California’s transportation fuels be reduced at least 10 percent by 2020.

Clean Car Standards
The Clean Car Standards, otherwise known as Pavley 1493, sets more stringent vehicle fuel economy standards for cars and light trucks that reduce greenhouse gas emissions. In 2009, the federal government enabled the state of California to enforce stricter tailpipe emissions limits on new passenger vehicles. In 2010, the US EPA and the Department of Transportation’s National Highway Safety Administration announced new vehicle greenhouse gas emission standards and corporate average fuel economy standards that reinforce California’s standard.

City Regulations
Desert Hot Springs Climate Action Plan
The Desert Hot Springs Climate Action Plan (CAP) was published in 2013 to act as a comprehensive framework for the development and implementation of policies and programs to reduce greenhouse gas emissions (GHG) within the City of Desert Hot Springs. The CAP is based on the directives of the Global Warming Solutions Act (AB 32) adopted by legislature in 2006, which plans to reduce GHG emissions to 1990 levels by 2020. EO S-3-05, which was issued in 2005, requires the reduction of emissions 80 percent below 1990 levels by 2050, also established directives for the Desert Hot Springs CAP.

According to the CAP, the 2010 baseline GHG emission level within Desert Hot Springs was 100,799 tonnes CO2e.

The CAP includes 80 measures to reduce the City’s GHG emissions, which are grouped into seven spheres. The seven spheres include: where we live, where we work, how we build, how we get around, how we govern, where we visit and play, and how we teach and learn. Measures listed in the CAP vary from educational programs, energy or water conservation audits, implicating ordinances, and promoting energy efficient vehicles and transportation methods. The measures outlined within the CAP are expected to result in an annual savings of 50,040 tonnes CO2e, 739 tonnes CO2e over the City’s AB 32 target reductions of 49,301 tonnes CO2e.

Desert Hot Springs General Plan Update
The City of Desert Hot Springs is committed to reducing energy demand and consumption within their City. Since the production of electricity and natural gas requires the burning of fossil fuels, the increased demand for electricity in the City also leads to an increase in air pollution and greenhouse gas emissions created in the City. Therefore, reducing energy consumption will contribute to the reduction of air pollutants and GHGs generated in the City.

Industrial land uses typically generate large electricity and natural gas demands in the City. The Open Space and Conservation Element of the General Plan addresses existing energy resources and

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 49
Draft Initial Study / Mitigated Negative Declaration December 2022 consumption patterns in an effort to preserve and expand these resources and determine how they may be most effectively managed.

According to the Desert Hot Springs General Plan, energy conservation is important, particularly in the summer months. Energy conservation is encouraged through development regulations, building regulations and General Plan standards. The goal of the Energy and Mineral Resources Element of the General Plan focuses on the conservation and thoughtful management of energy sources and mineral deposits, assuring the long-term viability of limited and non-renewable resources. This is achieved in the General Plan through the promotion of energy conservation in all areas of community development, including transportation, development planning, public and private sector office construction and operation, as well as in the full range of residential, commercial and industrial projects. Program 5B of the Energy and Mineral Resources Element in the General Plan requires that support and facilitate the integration of co-generation and other energy management systems into larger industrial and commercial operations in the City to enhance operational efficiencies and provide additional opportunities for local power production.

In addition to the goals and policies outlined within the General Plan Update, the General Plan also enforces the standards required in Title 24 and Building Code regulations, which require energy efficiency in all new construction of residential and nonresidential projects, as well as providing encouragement for the use of energy efficient construction techniques.

Desert Hot Springs Municipal Code
Similar to the City’s CAP and GPU, the City’s Municipal Code also encourages the conservation of energy. Chapter 15.08.100, California Energy Code, requires that the California Energy is adopted by reference and used to implement, administer and enforce the California Building Standards Code.

Chapter 10.56 (Transportation Demand Management Requirements) is intended to protect the public health, welfare and safety by reducing air pollution caused by vehicle trips and vehicle miles traveled (VMTs). This chapter is intended to reduce emissions by requiring the development of a trip reduction and travel demand element to the congestion management plan (CMP), and adoption and implementation of trip reduction and travel demand ordinances by local agencies.

The project property proposes a container storage facility on approximately 4.85 acres east of Calle De Los Romos and north of Avenue 19, in the City of Desert Hot Springs. The facility will include the development of a 60,000-square-foot building, paved driveways, 92 paved parking spaces, and associated improvements. The project will comply with state-implemented building standards such as those outlined in Title 20 and Title 24 of the California Code of Regulations. Energy efficient appliances will be utilized during project operation. As stated in the previous discussion, project-related energy consumption and VMTs created by the project are not anticipated to be substantial.

The project property is located in an area that this dominated by vacant land in the City of Desert Hot Springs. Existing industrial uses are located west of the project. The project property will comply with all applicable State and local guidelines and regulations regarding energy efficient building design and standards. Therefore, the project is not anticipated to conflict or obstruct a state or local plan for renewable energy or energy efficiency. Less than significant impacts are expected.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 50
Draft Initial Study / Mitigated Negative Declaration December 2022 VII. GEOLOGY AND SOILS -- Would the Project:

Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs General Plan Environmental Impact Report, 2020; Desert Hot Springs Municipal Code; Riverside County General Plan, 2015; Riverside County General Plan Environmental Impact Report, 2015; 2015 Urban Water Management Plan, Missions Springs Water District, 2015; Flood Insurance Rate Map (FIRM) panel 06065C0885G, Federal Emergency Management Agency’s (FEMA), effective August 28, 2008; Land Subsidence, Groundwater Levels and geology in Coachella Valley, California, 1993-2010, USGS Scientific Investigations Report 2014-5075.
a) Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for the
area or based on other substantial
evidence of a known fault?

Discussion:

According to the Desert Hot Springs General Plan Environmental Impact Report (DHSGP EIR), ground shaking from an earthquake can cause damage anywhere in the City, while a fault rupture typically results in only localized damage to structures near the fault. Critical parameters include (1) whether foundations and/or structures straddle the fault, (2) the distance between the fault and various portions in the City, (3) the maximum credible earthquake each fault is capable of generating, (4) the intensity of ground shaking expressed as a fraction of the acceleration of gravity (g), and (5) the Modified Mercalli (MM) seismic intensity values that have been calculated for the City. In general, peak ground accelerations and seismic intensity values decrease with increasing distance from the causative fault. However, local site conditions, such as the top of ridges, may amplify the seismic waves generated by an earthquake, resulting in higher accelerations. Fault rupture can result in serious catastrophic damage to structures if the rupture occurs under the structure and causes injury or death to any occupants inside.

Per the Alquist-Priolo Earth Fault Zone Map corroborated for the purpose of this analysis, no known active faults traverse the project site. The nearest Alquist-Priolo Fault Zone is located approximately 0.20 miles to the northeast and labeled the San Andreas Fault Zone. Alquist-Priolo Maps are corroborated by the Riverside County Seismic Faults and Fault Zones database and by the Desert Hot Springs EIR Map (page 4.7-11, 2020).

Surface rupture occurs when movement on a fault deep within the earth breaks through to the surface.

The DHSGP EIR indicates that fault ruptures usually follow preexisting faults, which are zones of weakness. As indicated by the Alquist-Priolo Earth Fault Zone Map, the project site does not lie within an Alquist-Priolo Earthquake Fault Zone. Although the site is not located within this zone, surface fault rupture could occur at the project site due to the site’s proximity to the San Andreas Fault. Therefore, the project buildings will be required to be constructed in a manner that reduces the risk of seismic hazards (Title 24, California Code of Regulations). The project will be conditioned to comply with the most current

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 51
Draft Initial Study / Mitigated Negative Declaration December 2022 seismic design coefficients and ground motion parameters and all applicable provisions of the California Building Code (CBC). Less than significant impacts are expected.

Mitigation Measures: None
ii) Strong seismic ground shaking?

Discussion:

Although the project site is not located on a fault, strong seismic ground shaking is the primary seismic hazard that can be expected at the project site, due to the project’s proximity to the San Andreas Fault.

Intensity can be affected based on distance from faults. Strong shaking from an earthquake can result in secondary actions including landslides, ground lurching, structural damage or destruction, and liquefaction (discussed subsequently in this Geology and Soils Section).

As previously stated, the proposed project buildings will be required to be constructed in a manner that reduces the risk of seismic hazards (Title 24, California Code of Regulations). The project will be conditioned to comply with the most current seismic design coefficients and ground motion parameters and all applicable provisions of the California Building Code (CBC). The CBC includes requirements to design structures in accordance with the appropriate ground-shaking design parameters set forth in the code. Remedial grading and construction will work to reduce exposure of people or structures to adverse effects to the greatest extent possible against seismic hazards. All grading and construction plans will be reviewed and approved by the City. Following compliance with standard conditions relative to seismic design requirements, less than significant impacts are expected.

Mitigation Measures: None
iii) Seismic-related ground failure,
including liquefaction?
Discussion:

The Geology and Soils section in the Desert Hot Springs General Plan EIR indicates that when loose, unconsolidated, saturated, sandy soils are subjected to ground vibrations during a seismic event they may liquefy; this phenomenon is called liquefaction. This occurs in areas where the ground water table is within 50 feet of the ground surface. Effects of liquefaction include a loss of bearing strength, ground oscillations, lateral spread and slumping.

According to the Mission Springs Water District (MSWD) Draft 2015 Urban Water Management Plan, groundwater levels in the Mission Creek Subbasin, in which the project is located, average 300 feet below the ground surface. Therefore, the chance for hazards associated with liquefaction is considered low in the Desert Hot Springs area, principally because of the approximate depth to ground water. The exception includes lands located immediately adjacent to and on the north side of the Banning and Coachella Valley (Mission Creek) Faults, which dike ground water and allow it to rise within 50 feet of the surface. The property is located approximately 2.7 miles southwest from the Mission Creek Fault.

Through the development review process of the proposed structures, a site-by-site analysis is required to assess building design and check that proposed structures meet existing regulations or applicable codes established by the California Building Code (CBC) and the City of Desert Hot Springs. Less than significant impacts are expected.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 52
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
iv) Landslides?
Discussion:

Per the DHSGP EIR, landslides typically occur in areas with steep, unstable slopes. This hazard is found along the perimeter of the City on properties abutting the surrounding hillsides and mountains (page 4.7- 18). The subject property is located near an area with a low susceptibility of being impacted by rock falls and seismically induced landsliding due to the relatively flat topography. The closest area with moderate susceptibility to landsliding is approximately 2.5 miles to the northwest, at an isolated geological feature referred to as Devers Hill. Less than significant impacts are anticipated.

Mitigation Measures: None
b) Result in substantial soil erosion or the
loss of topsoil?
Discussion:

The project property is located north of 19th Avenue and east of Calle De Los Romos in Desert Hot Springs. Soil erosion at the project site can be caused by windborne, waterborne and human-related activities. Erosion during project construction and operation is discussed subsequently.

The project site is currently vacant with various material piles ranging from 3 to 5 feet in height. The observed content of these piles includes fine soils, gravel, and small boulders, as well as intermixed trash and plastic debris. Remedial grading including over-excavation and re-compaction will be required to ensure firm and uniform bearing conditions. These activities may increase the potential of soil erosion at the time of development. Therefore, in order to mitigate the effect of erosion at the project site, the project shall implement the Coachella Valley PM10 State Implementation Plan (PM10 Plan), otherwise identified by the City of Desert Hot Springs as the Fugitive Dust Control Plan. The purpose of this plan is to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic fugitive dust sources by requiring actions to prevent, reduce or mitigate fugitive dust emissions. The PM10 Plan requires the implementation of best management practices (BMPs) such as the use of perimeter fencing, applying adhesive dust suppressant, or watering the project site. The project property shall implement the BMPs outlined within their project specific PM10 Plan during construction of the project site. Refer to the Air Quality section of this environmental document for further information.

In addition to windborne and human-caused erosion, the project property may be subject to waterborne erosion during project construction. According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) panel 06065C0895G, effective August 28, 2008, the entire project and its immediate surroundings are located within Zone X, which include other flood areas with a 0.2 percent chance flood; areas with 1 percent chance flood with average depths of less than 1 foot or with drainage areas less than 1 square mile; and areas protected by levees from 1 percent annual chance flood.

Waterborne erosion can be caused by both human activities (i.e., over-watering of a site) and natural conditions (i.e., stormwater runoff from a rain event). Project development may affect onsite waterborne erosion; therefore, the project is required to comply with the most current Construction General Permit (CGP) (Order No. 2009-0009-DWQ as amended by 2010-0014-DWQ). Compliance with the CGP involves the development and implementation of a project-specific Stormwater Pollution Prevention Plan

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 53
Draft Initial Study / Mitigated Negative Declaration December 2022 (SWPPP), which is designed to reduce potential adverse impacts to surface water quality during the period of construction. The required plan will identify the locations and types of construction activities requiring BMPs and other necessary compliance measures to prevent soil erosion and stormwater runoff pollution. The plan will also identify the limits of allowable construction-related disturbance to prevent any exceedances or violations. Waterborne erosion and the City’s standard conditions associated with the topic are thoroughly discussed in the Hydrology and Water Quality Section of the document.

All onsite 100-year peak discharges would drain into underground retention basins via surface flows and pipes. The project would not alter the FEMA Flood Zone X sheet flow or be impacted by the flood depth.

Additionally, project implementation will include landscaping, buildings, and paved surfaces throughout the property. These features will establish stabilized surfaces at the project site, therefore decreasing the likelihood of onsite windborne, waterborne and human-related erosion. Project operation should not result in significant waterborne erosion.

The implementation of the PM10 Plan and the SWPPP will ensure that impacts from project-related erosion will be less than significant. See the Air Quality and Hydrology and Water Quality sections of this document for further discussion.

Mitigation Measures: None
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the Project, and potentially result
in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?
Discussion:

The onsite area has a predominantly level topography that slopes to the southeast. As discussed previously, hazards associated with liquefaction, lateral spread and offsite landslides are not expected.

The Desert Hot Springs General Plan EIR states that ground subsidence is the gradual settling or sinking of the ground surface with little or no horizontal movement (page 4.7-20). This phenomenon is usually associated with the extraction of oil, gas or ground water from below the surface, but it may also occur as a result of an earthquake. The 4-meter high scarp on the west side of Devers Hill indicates that uplift has occurred within the Desert Hot Springs Area. Devers Hill is approximately 2.25 miles northwest of the subject property.

A USGS Scientific Investigations Report 2014-5075 “Land Subsidence, Groundwater Levels and geology in Coachella Valley, California, 1993-2010” indicates the following: While most of the Coachella Valley was relatively stable, land surfaces declined about nine inches to two feet in some areas of Palm Desert, Indian Wells, and La Quinta, between 1995 and 2010. Following the 2009 installation of groundwater replenishment systems, an important recent exception was observed in La Quinta where groundwater levels stabilized and rose, and the rate of land subsidence substantially decreased. Subsidence is considered a regional problem requiring regional mitigation not specific to the project vicinity.

According to the General Plan, soil collapse typically occurs in recently deposited soils in an arid or semiarid environment. When saturated, collapsible soils undergo a rearrangement of their grains and a loss of cohesion or cementation, resulting in a substantial and rapid settlement even under relatively low

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 54
Draft Initial Study / Mitigated Negative Declaration December 2022 loads. The alluvial sediments which comprise much of Desert Hot Springs are prone to collapse, which can result from surface irrigation. Remedial grading, including proper preparation and compaction of project soil, will be required and indicated in project specific grading plans which will be reviewed and approved by the City (Riverside County Municipal Code Section 15.04). Review of the plans and proper preparation and compaction will address the requirements for development on these soils. Preparation of the site, which includes removing existing piles of debris and loose soil from the existing onsite soils, and compaction using controlled compacted fill will ensure that soils susceptible to collapse are removed from the site and foundation bearing conditions are firm and uniform, per Chapter 18, Soils and Foundations, of the California Building Code. Less than significant impacts are anticipated.

Mitigation Measures: None
d) Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life of the property?
Discussion:

Expansive soil is described as soils that include a significant amount of clay and are subject to swelling.

Expansive soils can change in volume and can exert significant pressure on loads (such as buildings) that are placed on them. In the General Plan study area, expansive soils are not generally considered a hazard because of the relatively minor amount of clay present in the soils. Where expansive soils may occur is in the Qf3 and Qf4 soils, which generally occur north of the Mission Creek Fault and in the vicinity of Whitewater Hill. The property is approximately 8.70 miles southeast of the Mission Creek Fault and

4.72 miles east of Whitewater Hill. Less than significant impacts are anticipated.

Mitigation Measures: None
e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal systems
where sewers are not available for the
disposal of waste water?
Discussion:

Mission Springs Water District (MSWD) currently provides sewer service to the City of Desert Hot Springs. MSWD is initiating the construction of the West Valley Water Reclamation Program (WVWRP).

The WVWRP would be on 60 acres of land between 19th and 20th Avenues in Desert Hot Springs, southeast of the project, and is anticipated to be implemented over an extended period of 3-10 years and will treat 1.5 MGD. Wastewater generated from the project would be conveyed to the WVWRP. The project would have a nominal increase to wastewater and sufficient capacity would be available to serve the project. Additionally, project plans will be reviewed by MSWD and City Staff to ensure wastewater capacity and compliance. Wastewater generated by the project site would be nominal since the facility will utilize efficient irrigation and fixtures. Sewer installation and connection fees in place at the time of development or connection would be collected by MSWD (see the Utilities and Service Systems section for further discussion). Therefore, less than significant impacts are anticipated.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 55
Draft Initial Study / Mitigated Negative Declaration December 2022 f) Directly or indirectly destroy a
unique paleontological resource or
site or unique geologic feature?
Discussion:

According to the Riverside County General Plan, paleontological resources is evidence of past life forms and their biota, that is valued for the information they yield about the history of earth and its past ecological settings. Per Figure OS-8, Paleontological Sensitivity, in the Riverside County General Plan, the property is recognized for having low potential for Paleontological Sensitivity. Areas recognized for having “low” potential have a reduced likelihood of containing significant non-renewable paleontological resources, including vertebrate or significant invertebrate fossils. Moreover, the site is not recognized as a unique paleontological or a unique geologic feature. Additionally, the entire site has been graded, and it is unlikely that paleontological resources are onsite. Therefore, if any paleontological resources or finds are unearthed during any ground-disturbing activities, a qualified paleontologist should be notified. Less than significant impacts are expected following the recommended mitigation measure.

Mitigation Measures:

GEO-1: A qualified paleontologist shall be retained and present during the first days of monitoring. Once the paleontologist has had a chance to assess the sediments and paleontological potential of the project area, he/she may make a recommendation to reduce the monitoring effort, as appropriate, or continue with full time monitoring. This decision shall be communicated along with the rationalization to the City for their records.

VIII. GREENHOUSE GAS EMISSIONS --Would the Project:

Sources: Final 2016 Air Quality Management Plan (AQMP), by SCAQMD, March 2017; Final 2003 Coachella Valley PM10 State Implementation Plan (CVSIP), by SCAQMD, August 2003; Analysis of the Coachella Valley PM10 Redesignation Request and Maintenance Plan, by the California Air Resources Board, February 2010; California Emissions Estimator Model (CalEEMod), Version 2020.4.0. California Greenhouse Gas Emissions for 2000 to 2019, Trends of Emissions and Other Indicators, 2021 Edition, California Air Resources Board; Release No. 18-37 & 19-35, California Air Resources Board Press Release, July 2018 and August 2019.
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
Discussion:

Greenhouse gases (GHG) are a group of gases that trap solar energy in the Earth’s atmosphere, preventing it from becoming too cold and uninhabitable. Common greenhouse gases in the Earth’s atmosphere include water vapor, carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), ozone, and chlorofluorocarbons to a lesser extent. Carbon dioxide is the main GHG thought to contribute to climate change. Carbon dioxide reflects solar radiation back to Earth, thereby trapping solar energy and heat within the lower atmosphere. Human activities (such as burning carbon-based fossil fuels) create water vapor and CO2 as byproducts, thereby impacting the levels of GHG in the atmosphere. Carbon dioxide equivalent (CO2e) is a metric used to compare emissions of various greenhouse gases.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 56
Draft Initial Study / Mitigated Negative Declaration December 2022 To address the long-term adverse impacts associated with global climate change, California’s Global Warming Solutions Act of 2006 (AB 32) requires California Air Resource Board (CARB) to reduce statewide emissions of greenhouse gases to 1990 levels by 2020. In 2016, Governor Jerry Brown signed Senate Bill 32 (SB32) that requires California to reduce GHG emissions to 40 percent below 1990 levels by 2030. With the passage of the California Global Warming Solutions Act of 2006 (Assembly Bill 32) in California, environmental documents for projects pursuant to CEQA are required to analyze greenhouse gases and assess the potential significance and impacts of GHG emissions.

On July 11, 2018, CARB announced in a press release (No. 18-37) that greenhouse gas pollution in California fell below 1990 levels for the first time since emissions peaked in 2004, an achievement roughly equal to taking 12 million cars off the road or saving 6 billion gallons of gasoline a year.

Moreover, according to the CARB report on California Greenhouse Gas Emissions for 2000 to 2017 (published in 2019), which tracks the trends of GHG emissions, California’s GHG emissions have followed a declining trend between 2007 and 2017. In 2017, emissions from GHG emitting activities statewide were 424 million metric tons of CO2 equivalent (MMTCO2e), 5 MMTCO2e lower than 2016 levels and 7 MMTCO2e below the 2020 GHG Limit of 431 MMTCO2e. The largest reductions are attributed to the electricity sector, which continues to see decreases as a result of the state’s climate policies. The transportation sector remains the largest source of GHG emissions in the state, but saw a 1 percent increase in emissions in 2017, the lowest growth rate over the previous 4 years.

On August 12, 2019, California Governor Gavin Newsom announced in a press release (No. 19-35) that GHG emissions in California continued to fall ahead of schedule in 2017 as the state’s economy grew ahead of the national average, according to the California Air Resources Board’s latest state inventory of climate-changing emissions. The data also shows that for the first time since California started to track GHG emissions, the state power grid used more energy from zero-GHG sources like solar and wind power than from electrical generation powered by fossil fuels.

The updated CARB report on California Greenhouse Gas Emissions for 2000 to 2019 (2021 Edition) indicated that in 2019 emissions from GHG emitting activities statewide were 418.1 million metric tons of carbon dioxide equivalent (MMTCO2e), 7.1 MMTCO2e lower than 2018 levels and almost 13 MMTCO2e below the 2020 GHG Limit of 431 MMTCO2e. The 2021 report also indicated that transportation emissions have continued to decline in 2019 as they had done in 2018, with even more substantial reductions due to a significant increase in renewable diesel (up 61 percent from 2018), making diesel fuel bio-components (biodiesel and renewable diesel) 27 percent of total on-road diesel sold in California. Total electric power emissions decreased by almost 7 percent in 2019, due to a continuing increase in renewable energy, including a 46 percent increase in available hydropower in 2019.

Discussion:

CalEEMod Version 2020.4.0 was used to quantify GHG emissions associated with construction and operation of the proposed project. The parameters considered for CalEEMod and air quality analysis were obtained from the most current technical site plan for the project, as subsequently summarized.

The most conservative interpretation of proposed land uses, equitable modelling criteria, and associated air quality impacts have been utilized to capture impacts associated with 100% of the proposed onsite structures and operations.
 Industrial Park facility with a floor area of 60,000 square feet, ITE Land Use Code 130.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 57
Draft Initial Study / Mitigated Negative Declaration December 2022  Parking lot, driveway, and hardscape facilities with a combined area of 2.08 acres The project parameters were factored into the model to evaluate whether the GHG emissions would exceed the established thresholds and therefore conflict with the plans and efforts of reducing the emissions of greenhouse gases. Construction-related GHG emissions were amortized over a 30-year period and added to the project’s annual operational GHG emissions. The operational GHG emissions can be attributed to area sources, mobile sources, solid wastes and water supply, treatment and distribution of the proposed operations.

The currently applicable GHG thresholds for local lead agency consideration are referenced from the SCAQMD Working Group Threshold supporting documentation, which establishes an interim tiered approach.

Under this guidance, a screening threshold of 3,000 metric tons of carbon dioxide equivalent MTCO2e) per year has been an acceptable approach for working groups. The GHG emissions estimates resulting from CalEEMod are displayed below in Table VIII-1.

Table VIII-1 Total Project Greenhouse Gas Emissions
Unmitigated Emission Source
Emissions
(metric tons per year)
Total CO2E
Annual Construction Emissions Amortized Over 30 Years 13.05065 Area, Energy, Mobile Sources, Waste, and Water Usage 399.4357 Total CO2E (All Sources) 412.48635
SCAQMD Threshold for Industrial Projects 3,000
Threshold Exceeded? NO
As shown in VIII-1 resulting from the CalEEMod calculations, the project is expected to generate approximately 412.48635 MTCO2e per year from construction, area, energy, mobile sources, waste, and water usage sources. Therefore, the project GHG emissions would not exceed the threshold of significance set at 3,000 MTCO2e per year. Having been evaluated against the regionally accepted thresholds, which are part of the State’s regulations aimed at addressing climate change, the project is not expected to interfere with the plans, policies, or regulations adopted for the purpose of reducing the emissions of greenhouse gases. Less than significant impacts are anticipated.

Mitigation Measures: None
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing
the emissions of greenhouse gases?
Discussion:

As previously mentioned in discussion a), under Assembly Bill 32 passed in 2006, California must reduce its emissions to 1990 levels (431 million metric tons) by 2020. Senate Bill 32, signed in 2016,

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 58
Draft Initial Study / Mitigated Negative Declaration December 2022 requires the state to go even further than AB 32 and cut emissions 40 percent below 1990 levels by 2030—the most ambitious carbon goal in North America. California’s primary programs for reducing greenhouse gases to 1990 levels by 2020 are the Renewables Portfolio Standard, the Advanced Clean Cars Program, the Low Carbon Fuel Standard and the Cap-and-Trade Program. Additional programs address a variety of greenhouse gas sources. These include the Short-Lived Climate Pollutants Strategy, the Sustainable Communities Strategy and the Sustainable Freight Action Plan. The 2030 Scoping Plan, adopted by CARB, lays out how these initiatives work together to reduce greenhouse gases to achieve California’s 2030 target of 260 million metric tons and also to reduce smog-causing pollutants. This target will require California to more than double the rate at which it has been cutting climate-changing gases. Future reductions will occur against a backdrop of natural sources of GHGs which are increasingly variable because of the climate change California is already witnessing. The SCAQMD adopted the interim GHG significance threshold for stationary/industrial sources on December 5, 2008 which applies to Projects where the SCAQMD is the lead agency. Less than significant impacts are anticipated.

On July 11, 2018, CARB announced in a press release (No. 18-37) that greenhouse gas pollution in California fell below 1990 levels for the first time since emissions peaked in 2004. By 2019, there was evidence of a declining statewide GHG emission trend from 2007 and 2017, such that 2017 emissions were 424 million metric tons of CO2 equivalent (MMTCO2e), 5 MMTCO2e lower than 2016 levels and 7 MMTCO2e below the 2020 GHG Limit of 431 MMTCO2e. By 2019, statewide GHG emissions were 418.1 MMTCO2e, 7.1 MMTCO2e lower than 2018 levels and almost 13 MMTCO2e below the 2020 GHG Limit of 431 MMTCO2e.

The Desert Hot Springs Climate Action Plan (CAP) published in 2013 acts as a comprehensive framework for the development and implementation of policies and programs to reduce greenhouse gas emissions (GHG). The CAP is based on the directives of the State’s global warming strategies previously discussed. Therefore, project compliance with the State’s GHG reduction methods and measures would be equivalent and consistent with the City’s CAP measures.

In summary, the project is expected to result in GHG emissions totaling 412.48635 MTCO2e at full operation of the built-out condition, which is below the established 3,000 MTCO2e threshold under the SCAQMD regional jurisdiction. Additionally, the City of Desert Hot Springs provides GHG reduction measures in their 2020 General Plan to ensure a reduction in total vehicle miles traveled to help improve local air quality and reduce GHG emissions. Some policies to achieve this goal includes reducing vehicle miles traveled and implementing sustainable transportation and land use strategies. The project will not conflict with the goals and policies established by the City to reduce GHG emissions. Overall, the project is not expected to conflict with the applicable plans and strategies for the purposes of reducing greenhouse gas emissions. Less than significant impacts are anticipated.

Mitigation Measures: None
IX. HAZARDS AND HAZARDOUS MATERIALS --Would the project:

Sources: Code of Federal Regulations Title 40 Part 261. Desert Hot Springs General Plan, 2020; Desert Hot Springs General Plan Environmental Impact Report, 2020; EnviroStor, Department of Toxic Substances Control, accessed 2022; Enforcement and Compliance History Online (ECHO), Environmental Protection Agency (EPA), accessed 2022; GeoTracker, State Water Resources Control Board, accessed 2022; Riverside County Municipal Code.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 59
Draft Initial Study / Mitigated Negative Declaration December 2022 a) Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials?
Discussion:

The Code of Federal Regulations (CFR Title 40, Part 261) defines hazardous materials based on ignitability, reactivity, corrosivity, and/or toxicity properties. The State of California defines hazardous materials as substances that are toxic, ignitable or flammable, reactive and/or corrosive, which have the capacity of causing harm or a health hazard during normal exposure or an accidental release. As a result, the use and management of hazardous or potentially hazardous substances is regulated under existing federal, state and local laws. Hazardous wastes require special handling and disposal methods to reduce their potential to damage public health and the environment. Manufacturer’s specifications also dictate the proper use, handling, and disposal methods for the specific substances.

The project property occupies approximately 4.85 acres of vacant desert land north of 19th Avenue and east of Calle De Los Romos in the City of Desert Hot Springs. The project proposes to construct a 60,000- square-foot warehouse storage building. The project will not involve the use of hazardous materials.

Construction of the project is expected to involve the temporary management and use of potentially hazardous substances and petroleum products. The nature and quantities of these products would be limited to what is necessary to carry out construction of the project. Some of these materials would be transported to the site periodically by vehicle and would be stored in designated controlled areas on a short-term basis. When handled properly by trained individuals and consistent with the manufacturer’s instructions and industry standards, the risk involved with handling these materials is considerably reduced.

To prevent a threat to the environment during construction, the management of potentially hazardous materials and other potential pollutant sources will be regulated through the implementation of control measures required in the Storm Water Pollution Prevention Plan (SWPPP) for the project. The SWPPP requires a list of potential pollutant sources and the identification of construction areas where additional control measures are necessary to prevent pollutants from being discharged. Best management practices (BMPs) are necessary for Material Delivery and Storage; Material Use; and Spill Prevention and Control.

These measures outline the required physical improvements and procedures to prevent impacts of pollutants and hazardous materials to workers and the environment during construction. For example, all construction materials, including paints, solvents, and petroleum products, must be stored in controlled areas and according to the manufacturer’s specifications. In addition, perimeter controls (fencing with wind screen), linear sediment barriers (gravel bags, fiber rolls, or silt fencing), and access restrictions (gates) would help prevent temporary impacts to the public and environment. With such standard measures in place, less than significant impacts are anticipated during construction.

Operation of the project would house a company which moves goods in portable storage units. Such units are delivered by truck to homes and businesses where they are filled with personal or business belongings, are then picked up again by truck for storage in the warehouse (or outdoor storage around the warehouse) before the storage unit is moved to the location requested by the client. The storage units are warehoused for a short or long duration, and per the client’s needs are removed from the warehouse for delivery to a local or national destination. This building is not a refrigerated/cold storage warehouse.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 60
Draft Initial Study / Mitigated Negative Declaration December 2022 The entire warehouse and portions of the parking area will be used for storage of the portable storage units. During the transportation of the containers, the storage facilities are handled by trained individuals and transported as part of their service to the clients. The standards for transporting the storage containers will reduce the likelihood for hazards during transportation of the materials.

The storage units will be handled to industry standards during the routine transport or storage of the containers. Less than significant impacts related to the routine transport, use or disposal of hazardous materials are expected.

Mitigation Measures: None
b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous materials
into the environment?
Discussion:

The project site is located within the Industrial land use sector of the City and is separated from residential or other densely populated land uses. As previously determined in discussion a), the project is not expected to handle any significant quantities of hazardous materials.

The substances used during construction of the project would be stored and applied according to the manufacturer’s instructions to reduce the potential for incidental release or reactions. Cleaning of equipment shall not result in water contamination. Best management practices (BMPs) would be implemented during construction of the project. BMPs include concrete washout facilities for the cleaning of equipment or tools. Wastewater flows from the project will be required to connect to the public sewer system. Wastewater generated by the project will be conveyed to the Mission Springs Water District (MSWD) Horton Wastewater Reclamation Plant. Sewer installation and project plans will be reviewed by MSWD and City Staff to ensure wastewater capacity and compliance. See the Utilities and Service Systems section for further discussion.

The project proponent is required to develop and implement an approved Water Quality Management Plan (WQMP) to comply with the most current standards of the Whitewater River Region Water Quality Management Plan for Urban Runoff and the Whitewater River Watershed MS4 Permit. The project specific WQMP will identify a strategy of site design, source controls, and treatment controls with a required operation and maintenance program to address post-construction runoff quality and quantity.

The two retention basins proposed for the project site are required to accept storm water runoff from the project building, hardscape, and parking lots.

Mitigation Measures: None
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 61
Draft Initial Study / Mitigated Negative Declaration December 2022 Discussion:

The project is not located within one-quarter mile of an existing or proposed school. The nearest existing school is Two Bunch Palms Elementary, which is located approximately 3 miles northeast of the subject property. Thus, the project is not located within a quarter mile of the existing school facilities.

As mentioned throughout this document, the project site would be developed for a storage pod facility.

The nature of the project would not involve the use or handling of hazardous substances that would result in the release of hazardous emissions, materials or waste. Moreover, all hazardous materials associated with the construction and operation of an industrial facility will be subject to federal, state, and local regulations. To further minimize any potential public exposure to accidental risks, proper construction and safety measures will be implemented and temporary impacts during construction will be further mitigated by standard operational procedures and protocols as well as Best Management Practices (BMPs). Less than significant impacts are expected.

Mitigation Measures: None
d) Be located on a site which is included on
a list of hazardous materials sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create
a significant hazard to the public or the
environment?
Discussion:

Record searches on the project property were performed within multiple database platforms compiled pursuant to Government Code 65962.5 and its subsections. The resources consulted included GeoTracker, EnviroStor, and the EPA Enforcement and Compliance History Online (ECHO).

GeoTracker is a database maintained by the State of California Water Resources Control Board that provides online access to environmental data. It serves as the management system for tracking regulatory data on sites that can potentially impact groundwater, particularly those requiring groundwater cleanup and permitted facilities, such as operating underground storage tanks and land disposal sites.

EnviroStor is a database maintained by the State of California Department of Toxic Substances Control (DTSC). The EnviroStor database identifies sites with known contamination or sites for which there may be reasons to investigate further. It includes the identification of formerly contaminated properties that have been released for reuse; properties where environmental deed restrictions have been recorded to prevent inappropriate land uses; and risk characterization information that is used to assess potential impacts to public health and the environment at contaminated sites.

Moreover, the ECHO database focuses on inspection, violation, and enforcement data for the Clean Air Act (CAA), Clean Water Act (CWA) and Resource Conservation and Recovery Act (RCRA) and also includes Safe Drinking Water Act (SDWA) and Toxics Release Inventory (TRI) data.

In June 2022, a search was performed on all three database platforms. The GeoTracker and ECHO databases listed multiple facilities within a one-mile radius of the project property. However, the search

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 62
Draft Initial Study / Mitigated Negative Declaration December 2022 results did not identify any records or sites in connection with the subject property. The registered facilities are discussed below.

The GeoTracker database identified three facilities within a mile radius of the project property. The closest registered facility is Shell North Plan Springs, located on 20000 N Indian Avenue, approximately 0.60 miles southwest of the project. The site is registered as having two Leaking Underground Storage Tank (LUST) Cleanup Sites. However, each incident maintains a status of “Completed - Case Closed” as of October 1999 and December 2001. The next closest registered facility is 76 Station 5699, located on 19995 Indian Avenue, approximately 0.64 miles southwest of the project. The site is registered as Leaking Underground Storage Tank (LUST) Cleanup Sites with a “Completed – Case Closed” status since December 2009. The last facility is Pilot Travel Center #307, located at 6605 North Indian Avenue, approximately 0.79 miles southwest of the project. The site is registered as having two Leaking Underground Storage Tank (LUST) Cleanup Sites with “Completed – Case Closed” statuses since March 2004 and October 2007.

The ECHO database listed three registered facilities within a mile radius of the project property. The facilities are listed as followed:
 Top Notch Automotive LLC, located at 19020 N Indian Canyon Drive, approximately 0.49 miles west of the project. This site is registered as an active “other” facility by the Resource Conservation and Recovery Act (RCRA). According to ECHO, there are not violations associated with the site.
 San Gorgonio West Winds II is located at 19020 N Indian Canyon Drive, approximately 0.83 miles west of the project. This site is registered as an active “other” facility by the RCRA and does not have any violations.
 ARCO AM/PM #82686, located at 20000 Indian Canyon Avenue, approximately 0.60 miles southwest of the project. The site is listed as an active “other” facility by the RCRA. According to ECHO, the site does not have any violations.

Unlike the GeoTracker and ECHO databases, EnviroStor did not identify a registered facility within a mile radius of the project property. The closest registered facility is Desert Hot Springs High School, located at 65850 Pierson Boulevard, approximately 3.68 miles northeast of the project. The site was registered as a School Investigation Site, and as of May 2003, no action has been required.

Per the records search pursuant of Government Code 65962.5, the project site was not registered as having any Leaking Underground Storage Tank (LUST) Cleanup Sites, Land Disposal Sites, Military Sites, DTSC Hazardous Waste Permits, DTSC Cleanup Sites, or Permitted Underground Storage Tanks onsite. The sites registered within the searched databases are not expected to impact the project property due to their distances from the project, and their statuses of Completed - Case Closed, no action, and no violations. Therefore, less than significant impacts are anticipated.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 63
Draft Initial Study / Mitigated Negative Declaration December 2022 e) For a project located within an airport
land use plan or, where such a plan
has not been adopted, within two miles
of a public airport or public use airport,
would the Project result in a safety hazard
or excessive noise for people residing or
working in the project area?
Discussion:

The project is not located near an existing airport or airport land use plan. The nearest airport facility to the project is the Palm Springs International Airport, located approximately 4.75 miles to the south. The Bermuda Dunes Airport is approximately 18.10 miles southeast of the project. No impacts are anticipated.

Mitigation Measures: None

f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
Discussion:

The Safety and Noise Element of the City’s General Plan is designed to address concerns regarding the City’s capability to respond to potential natural or man-made disasters. The Element sets forth goals, policies and programs to ensure an effective response.

The City of Desert Hot Springs contracts with Riverside County Fire Department/Cal Fire (RCFD) for a full range of fire protection services provided 24 hours a day 7 days a week. The RCFD is staffed with a combination of County and State of California Department of Forestry & Fire Protection employees. They operate 94 fire stations that serve approximately two million residents over 7,004 square miles of Riverside County. The City of Desert Hot Springs has three RCFD fire stations, Battalion 10, Station 36, Station 37, and Station 56. Station 36 located at 11535 Karen Avenue is approximately 5.4 driving miles from the project site. Battalion 10, Station 37 is the City’s busiest fire station and is located at 65-958 Pierson Blvd, approximately 6.1 driving miles from the project. Battalion 10, Station 56 is located at 72985 Dillion Road, approximately 10.5 driving miles from the project. Each station is equipped with a Type I, 1500 GPM fire engine and staffed by a minimum of one company officer and one fire fighter at any given time.

In addition to the other RCFD facilities located in the Coachella Valley, the department maintains a cooperative mutual aid agreement with other agencies and communities to assist in suppressing fire or controlling emergency incidents. Mutual aid is an agreement among emergency responders to lend assistance across jurisdictions provided resources are available and is not to the detriment of their own service area. Per the City’s General Plan, agreements are in place with Palm Springs and Cathedral City.

Both of these cities provide their own fire services and do not contract with RCFD/Cal Fire. The nature of the project is not expected to introduce operations that would hinder the City’s ability to implement its emergency response goals, policies or programs.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 64
Draft Initial Study / Mitigated Negative Declaration December 2022 The proposed site plan configuration would be subject to a standard review process by the Riverside County Fire Department to ensure that the site-specific emergency access, water pressure, and other pertinent criteria are met by the project. Less than significant impacts are expected.

Mitigation Measures: None
g) Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury or death involving wildland fires?
Discussion:

Large areas of Southern California are susceptible to wildfires all year round due to the region’s weather, topography and vegetation conditions. The Coachella Valley’s hot dry summer and autumn weather is ideal to generate the dry vegetation that fuels most wildfires. The California Board of Forestry (CDF) ranks fire hazard of wildland areas of the State using four main criteria: fuels, weather, assets at risk, and level of service. Although the project site and its general surroundings are undeveloped with scattered vegetation, these conditions have not been recognized to meet the criteria of high or very high fire hazard zones.

Wildland fire protection in California is the responsibility of either the State, local government, or the federal government. Local responsibility areas include incorporated cities where fire protection is typically provided by City fire departments, fire protection districts, counties, and by CAL Fire under contract to local government. As mentioned previously, the City of Desert Hot Springs contracts with Riverside County Fire Department/Cal Fire (RCFD) for a full range of fire protection services provided 24 hours a day 7 days a week. The responsibility for fire prevention and suppression outside of the City boundaries is under the State and federal agencies.

The Riverside County General Plan and the Cal Fire Maps for Western Riverside County indicate that project and its surroundings are located outside of the Very High Fire Hazard Severity Zone (FHSZ) for Local Responsibility Area and outside of the Very High/High/Moderate FHSZ for State and Federal Responsibility Areas. The project will include the on-site fire protection facilities necessary to satisfy the local Fire Department requirements. Less than significant impacts related to wildland fire are expected.

Mitigation Measures: None
X. HYDROLOGY AND WATER QUALITY -- Would the project:

Sources: Flood Insurance Rate Map No. 06065C0895G, Federal Emergency Management Agency, Effective August 28, 2008; Water Quality Control Plan for the Colorado River Basin Region, January 2019; 2020 Coachella Valley Regional Urban Water Management Plan, June 2021, Mission Creek Subbasin Alternative Plan Update, December 2021.
a) Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or ground
water quality?
Discussion:

Summary of Regulatory Framework Relevant to Hydrology and Water Quality:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 65
Draft Initial Study / Mitigated Negative Declaration December 2022 Hydrology refers to the occurrence, distribution, and movement of surface water, including water found in rivers and stormwater drainage systems. Stormwater particularly refers to the surface runoff and drainage resulting from rain events. Stormwater runoff and surface drainage patterns are determined by the soil conditions, topography, and associated gradients of the land. Surface water quality refers to selected physical, chemical, or biological characteristics found in stormwater in relation to existing standards. Groundwater is the water found underground in the voids in soil, sand, and rock. It is stored in and moves slowly through aquifers. Groundwater supplies are naturally replenished, or recharged, by precipitation that seeps into the land’s surface and by replenishment efforts made by local water agencies.

The Clean Water Act (CWA) of 1972 was enacted to restore and maintain the chemical, physical, and biological integrity of the nation’s waters by regulating the discharge of pollutants to waters of the U.S. from point sources. The National Pollutant Discharge Elimination System (NPDES) was enacted as a program under the CWA to regulate non-point source discharges from urban land runoff and other diffused sources that were also found to contribute to runoff pollution. Under CWA, the Environmental Protection Agency (EPA) delegated the NPDES program responsibility to various state, tribal, and territorial governments, enabling them to perform many of the permitting, administrative, and enforcement aspects of the program. California is a delegated NPDES state and has authority to administer the NPDES program within its limits.

The Porter-Cologne Water Quality Control Act (California Water Code section 13000 et seq.) is the principal law governing water quality regulation for surface waters in California, thus effectuating the delegated provisions of the federal CWA and its NPDES program. It has set forth a comprehensive program to protect water quality and the beneficial uses applicable to surface waters, wetlands, and ground water and to point and nonpoint sources of pollution. The Porter-Cologne Act establishes that, as a matter of policy, all the waters of the State shall be protected; all activities and factors affecting the quality of water shall be regulated to attain the highest water quality within reason; and that the state must be prepared to exercise its full power and jurisdiction to protect the quality of water in the state from degradation. The Porter-Cologne Act established the State Water Resources Control Board (SWRCB) and nine California Regional Water Quality Control Boards (RWQCBs), including Region 7, Colorado River Basin Regional Water Quality Control Board, which has jurisdiction in the City of Desert Hot Springs and project site.

Under this framework, the Colorado River Basin Water Quality Control Plan (Basin Plan) serves as the guiding document prepared, adopted, and maintained to identify the existing and potential beneficial uses of waters of the State and establish water quality objectives to protect these uses. It is worth noting that as defined in Section 13374 of the California Water Code (CWC), the term "Waste Discharge Requirements” (WDRs) is equivalent of the term "permits” and is therefore attained through a regulatory compliance process. Compliance with WDRs is achieved through the appropriate permit registration process under the applicable National Pollutant Discharge Elimination System (NPDES) programs described in this section.

At the regional level, the project is located within the Whitewater River Watershed, which is an arid desert region encompassing approximately 1,645 square miles. Within this watershed, an area of approximately 367 square miles (22 percent) encompassing most of the existing development in the Coachella Valley region, is regulated under the established Whitewater River Region Municipal Separate Storm Sewer System Permit (MS4 Permit). The Riverside County Flood Control and Water Conservation District

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 66
Draft Initial Study / Mitigated Negative Declaration December 2022 (RCFC&WCD), Mission Springs Water District, and the incorporated Coachella Valley cities, including Desert Hot Springs have joint permittee responsibility for coordinating the regional MS4 Permit compliance programs and other activities aimed at reducing potential pollutants in urban runoff from land development construction, municipal, commercial, and industrial areas to the maximum extent possible.

These public entities are generally in charge of stormwater management within their jurisdiction.

At the City level, hydrology and stormwater regulations are codified in Chapter 13.08 (Stormwater Management and Discharge Controls), the purpose of which is to regulate non-stormwater discharges to the municipal separate storm drains, control the discharge of non-stormwater materials, reduce pollutants in stormwater discharges, and protect water quality consistent with the Clean Water Act. The City’s engineering review process ensures that improvement plans are reviewed for compliance with the City’s requirements pertaining to grading, hydrology, and stormwater management. The project site is located outside of the coverage area of for the 1982 Desert Hot Springs Master Drainage Plan (MDP), by RCFC&WCD. As such, there is no formal and approved MDP that applies to the project site.

Existing Vicinity and Site Drainage Conditions:

The project site is characterized by an undeveloped condition that has previously been cleared and graded for temporary material stockpiling and management, resulting in a relatively level condition. Such temporary site management activities are understood to be approved by the City and also permitted under California’s NPDES Construction General Permit (WDID/Permit No. 7 33C383143) with implementation of a Storm Water Pollution Prevention Plan (SWPPP) to comply with the State Water Resources Control Board (SWRCB) regulations and Clean Water Act (CWA) programs. The completion of those activities for the project site resulted in a visibly leveled and clear terrain, absent of any permanent improvements.

Based on the most current published U.S. Geological Survey (USGS) Topographic Map, Desert Hot Springs Quadrangle, 7.5-Minute Series, the project site does not contain any mapped drainage flow lines, wash areas, or water bodies indicative of naturally occurring surface water resources. Moreover, based on Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) Panel 06065C0895G, the project site occurs within a Zone X, corresponding to areas subject to the 0.2 percent annual chance flood hazard. By definition, the designation of Zone X is not considered a Special Flood Hazard Area (SFHA) or floodway. Furthermore, this flood zone is considered to be a moderate-to-low risk area where flood insurance is available, but not mandatory. As a standard condition, the project is required to implement the necessary site design features and engineering improvements to handle the existing conditions in a way that prevents inundation to the proposed structures and any off-site hydrologic modifications.

Regulatory Compliance:

During construction and operation (life of the project), implementation of the proposed development will be required to comply with CWA, NPDES, state, and local regulations designed to prevent violations or impacts to surface water quality standards and waste discharge requirements pertinent to surface or ground water quality. The project does not seek any permitting actions that would vary from the establish requirements and associated compliance plans.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 67
Draft Initial Study / Mitigated Negative Declaration December 2022 The project proponent must comply with the State’s most current Construction General Permit (CGP), Order No. 2009-0009-DWQ, as amended by 2010-0014-DWQ and 2012-006-DWQ. Compliance with the CGP involves the development and implementation of a project-specific Storm Water Pollution Prevention Plan (SWPPP), designed to prevent potential adverse impacts to surface water quality, including erosion and siltation, during the period of construction. The SWPPP is required to identify a strategy of storm water Best Management Practices (BMPs) in accordance with Section XIV (SWPPP Requirements) of the CGP. Storm water BMPs refer to a schedule of activities, prohibitions, practices, maintenance procedures, and other management practices to prevent, eliminate, or reduce the pollution of the receiving waters, primarily focused on preventing erosion, siltation, illicit discharge, and contamination. In the case of the proposed project, BMPs will be established in each SWPPP, and could include such measures as storm drain inlet protection, erosion control, linear sediment barriers, proper waste management, and proper material storage. The SWPPP must be prepared concurrently with final engineering design as a requirement of the City’s grading permit checklist. Compliance with the State’s CGP during construction will be regulated and enforced as part of the local agency site inspection protocols.

During construction, the project will also be required to comply with South Coast Air Quality Management District’s (SCAQMD) Rule 403 and 403.1 and the City’s Fugitive Dust Control Ordinance. Implementation of Fugitive Dust Control Plan primarily pertains to air quality, but also supports water quality protection through the requirement of soil stabilization measures aimed at preventing sediment erosion and trackout. The concurrent implementation of the required SWPPP and Dust Control Plan plans will prevent the potential construction-related impacts to water quality, including erosion and siltation, at the site and its surroundings, therefore, resulting in less than significant impact.

Drainage requirements fall under the jurisdiction of the City of Desert Hot Springs, which is a permittee of the Whitewater River Watershed Municipal Separate Storm Sewer System (MS4) with an existing Stormwater Management and Discharge Controls in Chapter 13.08 of the City’s Municipal Code. The project proponent is required to develop and implement an approved Water Quality Management Plan (WQMP) to comply with the most current standards of the Whitewater River Region Water Quality Management Plan for Urban Runoff and the Whitewater River Watershed MS4 Permit. As a result, the project is required to provide improvements and facilities to capture and retain the incremental increase in stormwater volume between pre-development and post-development conditions resulting from the controlling 100-year storm event for the project area.

As a compliance requirement, a Preliminary Water Quality Management Plan (WQMP) has been prepared to document the proposed site improvements and storm drainage system. Consistent with the Preliminary Hydrology Report, the project area is divided into four tributary on-site areas (“A”, “B”, “C” and “D”) and the respective stormwater runoff volumes have been calculated in order to adequately size the storm drain conveyances and retention capacity. The proposed facility does not involve outdoor storage or other associated operations. Therefore, the proposed storm drain system and retention facilities are only designed to accept runoff from outdoor areas (rooftops, hardscape, parking, and landscaping). Non-stormwater is not to be produced or conveyed to storm drain facilities.

Based on the preliminary engineering plans, runoff from each on-site drainage area will be carried along engineered flow lines (controlled surface flows, gutters, and pipes) to the respective retention facility. It is expected that three of the four retention facilities will be underground structures and one will be a surface basin. The plans indicate that the proposed surface and underground retention facilities for each

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 68
Draft Initial Study / Mitigated Negative Declaration December 2022 drainage area are sized to contain the design capture volume for water quality purposes and the corresponding incremental increase stormwater volume. Therefore, the project will meet the MS4 requirements by capturing runoff in accordance with the local retention requirements and preventing the project from producing incremental urban runoff discharge.

In summary, during construction and operation, project implementation will require compliance with CWA, NPDES, and local regulations to prevent impacts to water quality standards and the beneficial uses assigned to local receiving waters. Following City engineering review and approval, the stormwater capture and management strategy for on- and off-site runoff will avoid waste discharge violations through the implementation of properly sized retention facilities. Less than significant impacts are expected.

Mitigation Measures: None
b) Substantially decrease groundwater supplies
or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of
the basin?
Discussion:

The project is located within the domestic water service area of Mission Springs Water District (MSWD).

MSWD provides water services to over 13,500 retail water customers in the City of Desert Hot Springs and a northern portion of Palm Springs. In 2019, the six urban water suppliers in the Coachella Valley, consisting of MSWD, Coachella Valley Water District (CVWD), Coachella Water Authority, Desert Water Agency (DWA), Indio Water Authority (IWA), and Myoma Dunes Mutual Water Company, agreed to collaborate on the preparation of a 2020 Coachella Valley Regional Urban Water Management Plan (2020 RUWMP) with regional and individual agency content. The 2020 RUWMP describes the region’s water supplies and anticipated demands through 2045. It also describes each agency’s programs to encourage efficient water use. A Water Shortage Contingency Plan (WSCP) has also been prepared to outline each agency’s actions that could be taken during a water shortage to reduce demands. The agencies have coordinated their WSCPs to provide consistent shortage levels and response actions across the region.

The project site is underlain by the Mission Creek Subbasin (Basin No. 7-021.02 in the DWR Bulletin 118), which is described in the 2020 RUWMP as an unconfined aquifer with a saturated thickness of 1,200 feet or more and an estimated total storage capacity on the order of 2.6 million acre-feet (MAF).

The subbasin is naturally recharged by surface and subsurface flow from the Mission Creek, Dry, and Big Morongo Washes, the Painted Hills, and surrounding mountain drainages. Artificial replenishment is achieved through the exchange of State Water Project (SWP) water for Colorado River water at the Mission Creek Groundwater Replenishment Facility (GRF), located approximately 4.4 miles northwest of the project. In 2020, a total of 1,768 AF of Colorado River water was delivered to the Mission Creek GRF for direct replenishment. Since 2003, groundwater levels have risen and stabilized throughout the subbasin, which is deemed evidence that implementation of the recharge strategy has effectively abated the overdraft that preceded it. Currently, groundwater levels in the basin are above their 2009 levels in nearly all monitoring wells that have available groundwater level data for comparison. Moreover, the project is located in an area where groundwater elevation has increased from 15 to 20 feet in the tenyear period from 2008-09 to 2018-19 based on MSWD documentation.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 69
Draft Initial Study / Mitigated Negative Declaration December 2022 In November of 2021, the Mission Creek Subbasin Alternative Plan Update was completed in compliance with the Sustainable Groundwater Management Act (SGMA). The Alternative Plan Update was prepared to ensure that the most current projections for population growth, land use, imported water supply, and other future conditions were incorporated into water management planning for the region. The update improved upon the analysis for future projected groundwater demand and supply based on more current population growth and land development factors. In the context of this plan, the project site was accounted for as land available for development. As such, its generalized water demand was factored into the plan.

The proposed development is consistent with the designated light industrial land use reflected in the adopted General Plan and therefore is not expected to result in a land use proposal or development activity in conflict with existing groundwater management objectives. The proposed warehouse building primarily consists of an open floor area for storage, while only a small portion of the entire building (approximately 1,400 square feet) will be partitioned for administration uses, including a small lobby, two offices, a small conference room, a break room, an electrical room, and two separate restrooms.

Therefore, the nature of the proposed storage building is not expected to include facilities or operations with a demand for water resources. As a standard condition, the facilities must include low-flow plumbing fixtures, drought-tolerant (native) outdoor landscaping, and water-efficient irrigation systems. The project will be expected to furnish the appropriate payment to MSWD based on the meter size, ongoing flow charges, agency fees, and groundwater recharge fees. Additional domestic water improvements necessary to serve this development will be identified by MSWD and included as conditions of approval by the City of Desert Hot Springs during the City’s standard review process.

Furthermore, the requirement to adequately capture and infiltrate the project’s post-development stormwater runoff volume resulting from the controlling storm event will further contribute to groundwater recharge by infiltrating the required stormwater quantity instead of allowing it to leave as runoff. Based on the preliminary engineering plans, the combined retention system will be capable of intercepting approximately 17,884 cubic feet of stormwater volume for on-site percolation. As such, less than significant impacts are expected.

Mitigation Measures: None
c) Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:

i) Result in substantial erosion or siltation
on- or off-site;
Discussion:

The vacant project site exhibits a previously cleared and leveled condition. The most current U.S.

Geological Survey (USGS) Topographic Map, Desert Hot Springs Quadrangle, 7.5-Minute Series, does not identify any mapped drainage flow lines, wash areas, or water bodies within the project limits.

Moreover, the applicable FEMA Map (FIRM Panel 06065C0895G) does not identify a designated

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 70
Draft Initial Study / Mitigated Negative Declaration December 2022 floodway or a Special Flood Hazard Area (SFHA) on the site. As a standard condition, the project is required to implement the necessary site design features and engineering improvements to handle the existing conditions in a way that prevents inundation to the proposed structures and any off-site hydrologic modifications.

Buildout of the proposed project would convert the vacant property into a fully improved facility occupied by one building of approximately 60,000 square feet with associated hardscape, parking and landscaping improvements following a City-approved grading and drainage plan. The increase in impervious land cover would normally result in an increase in the rate and amount of surface runoff produced by a site.

However, as a project design feature and in compliance with the local drainage requirements, the project includes on-site retention facilities sized according to the incremental increase in runoff volume resulting from the controlling 100-year storm event. On-site erosion and sedimentation will be prevented through the proper design of stormwater conveyances (inlets, pipes, concrete gutters) as part of the grading and improvement plans. Where applicable, the project will include stabilized edge conditions to prevent instances of erosion or siltation. Following the standard City review and approval process, less than significant impacts are expected pertaining to erosion or siltation, on- or off-site.

Mitigation Measures: None
ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site?
Discussion:

Based on FEMA FIRM Panel Number 06065C0895G, effective August 28, 2008, the entire project site has a Zone X (Shaded) designation corresponding to the 0.2 percent annual chance flood hazard. As such, the project site is not considered to be in a Special Flood Hazard Area (SFHA), floodway, or other designation prone to a high flood risk. As a standard condition, the project is required to include the adequate improvements and site design features to handle the relevant hydrologic conditions in a way that prevents inundation to the proposed structures and also prevents obstructing off-site drainage patterns.

The project would introduce impervious surfaces (buildings, hardscape, asphalt, etc.) to a vacant property. Associated facilities would also include retention systems to accept and infiltrate the worst-case increase in runoff volume between the pre- and post-development condition resulting from the 100-year controlling storm event. Based on preliminary engineering plans, the combined stormwater retention capacity is expected to be approximately 17,884 cubic feet.

Only runoff quantities in excess of the storm drain system capacity will be allowed to leave the site in a properly controlled manner consistent with the historic drainage conditions. The final engineering design is required to demonstrate the adequate improvements to handle the existing conditions in a way that prevents inundation to the proposed structures. Following City engineering review, the proposed development is not expected to substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Less than significant impacts are anticipated.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 71
Draft Initial Study / Mitigated Negative Declaration December 2022 iii) Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff?
Discussion:

The City of Desert Hot Springs is a Permittee of the Whitewater River Watershed Municipal Separate Storm Sewer System (MS4) permit area. Within the City limits, MS4 facilities include a system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains) designed for collecting and conveying stormwater. Storm drain facilities can be public or private. Examples of public facilities include pipes, gutters, channels, and basins occurring on the public right-of-way and/or maintained by a public agency. Private facilities are distinguished by being maintained separately by a private entity. The undeveloped project site and immediate surroundings are absent of any formal public or private storm drain facilities.

The proposed project will include a private storm drain system with distributed retention facilities sized to accept and infiltrate incremental increase in stormwater runoff resulting from the controlling 100-year storm event. Based on the project location, size, impervious cover characteristics, the on-site retention system capacity will be approximately 17,884 cubic feet, therefore preventing off-site discharge of stormwater runoff in rates and quantities capable of causing a burden to the local MS4 system. Following City engineering review and approval, the project will prevent the possibility of contributing runoff pollutants to the surrounding areas. Less than significant impacts are anticipated.

Mitigation Measures: None
iv) Impede or redirect flood flows?
Discussion:

The project site is located outside of any designated SFHA, floodway, or drainage flow line as determined by FEMA and USGS maps. Therefore, the project will not impede or redirect any discernable drainage course, floodplain, or flood prone area. As a standard condition, the proposed development will include stabilized edge conditions, a storm drain system and associated retention facilities to meet the City’s engineering requirements and to provide adequate protection to the new facilities. Any stormwater volume or flood flows in excess of the retention capacity must be conveyed across the site in a manner consistent with the prevailing drainage gradient and condition. The associated grading and hydrology plans will be subject to City review and approval. In doing so, the project will not be permitted to impede or redirect flood flows, resulting in less than significant impacts.

Mitigation Measures: None
d) In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?
Discussion:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 72
Draft Initial Study / Mitigated Negative Declaration December 2022 The project is not located near any coastal areas or any large body of water and therefore is not prone to tsunami hazards or seiche risks. The project site is not located in a floodplain or special flood hazard area. As a standard requirement, the project incorporates on-site retention facilities to handle projectrelated runoff volume while also accommodating for excess flows in a manner that prevents hydrologic modifications off-site. As proposed, the project facilities do not involve any outdoor storage or indoor storage of hazardous materials that could be released from accidental discharge. With these required improvements subject to City review and approval, less than significant impacts are anticipated pertaining to flood hazard.

Mitigation Measures: None
e) Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
Discussion:

The project proponent is required to implement a project-specific Water Quality Management Plan (WQMP) to comply with the most current standards of the Whitewater River Region MS4 Permit. The final WQMP must incorporate the grading, hydrology, and other plans to document how the site design, source controls, and operation and maintenance program will achieve compliance. Based on the preliminary engineering documents, the proposed site will be divided into three drainage management areas, each with a respective stormwater retention facility sized for the incremental increase in runoff volume. The combined retention capacity for the project is expected to be approximately 17,884 cubic feet. Only runoff quantities in excess of the system capacity will be managed to exit the project in a manner consistent with the existing conditions and gradients. Moreover, the project’s storm water retention facilities will ensure that only stormwater runoff is recharged into the ground via infiltration.

Combined with the required water conservation practices, and City review and approval of plans, the project is expected to contribute to the groundwater sustainability efforts implemented for the Coachella Valley region. Less than significant impacts are anticipated.

Mitigation Measures: None
XI. LAND USE AND PLANNING - Would the project:

Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs Municipal Code. a) Physically divide an established
community?
Discussion:

The project site sits on approximately 4.85 acres of vacant land on the northeast corner of Calle De Los Romos and 19th Avenue. The site is zoned Light Industrial (I-L) with an Industrial Cannabis Overlay. The project property is surrounded by developed land to the north and south, developing land to the west, and disturbed vacant land to the east. The surrounding properties to the north, east and south are also located within the City’s I-L zone with Industrial Cannabis Overlay. The property west of the project, separated by Calle De Los Romos, is designated as the Coachillin Specific Plan, which also has an Industrial Cannabis Overlay. Coachillin is surrounded by block wall fencing. Calle De Los Romos delineates the project’s western boundary, while the unpaved Avenue 19 delineates the project’s southern boundary. Conclusively, there is no established community pattern in the project vicinity that

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 73
Draft Initial Study / Mitigated Negative Declaration December 2022 would be divided by the project. Less than significant impacts relative to the division of an established community are expected.

Mitigation Measures: None
b) Cause a significant environmental impact
due to a conflict with any land use plan, policy,
or regulation adopted for the purpose of
avoiding or mitigating an environmental effect?
Discussion:

The project proposes the development of a container storage facility on approximately 4.85 acres of vacant land on the northeast corner of Calle De Los Romos and 19th Avenue in Desert Hot Springs. As previously stated, the project is zoned Light Industrial (I-L). I-L districts intend to retain, enhance, and intensify existing and provide for the new development of lighter industrial uses along major transportation routes serving the City. I-L districts accommodate all industrial uses operating entirely in enclosed buildings, requiring limited and screen-able outdoor storage space. The General Plan land use designations for the site is identified as Industrial (I). Industrial land uses allow for a broad range of light industrial, light manufacturing, and indoor cultivation uses housed in multi-tenant, low-scale industrial developments. The project site is largely segregated from the City’s intense residential and commercial uses and is consistent with the City’s zoning and land use designations. The project is located within an industrial district in the City and is considered consistent with the permitted locations established under Municipal Code Chapter

17.16. The project includes approval of a Design Review to thoroughly evaluate the design and operation of the proposed facility and render it in full compliance with City regulations. The project’s physical characteristics and internal operations will not conflict with the City’s land use, zoning or other regulatory policies. Site design features will be reviewed and approved by the City relative to compliance with the City’s General Plan and Zoning. Less than significant impacts are expected.

Mitigation Measures: None
XII. MINERAL RESOURCES -- Would the project:

Sources: Desert Hot Springs General Plan, 2020; Riverside County General Plan, 2015. a) Result in the loss of availability of a
known mineral resource that would
be of value to the region and the
residents of the state?
Discussion:

In accordance with the Surface Mining and Reclamation Act of 1975 (SMARA), mineral land classification maps and reports have been developed to assist in the protection and development of mineral resources.

Local agencies, including the City of Desert Hot Springs, utilize the existing information on mineral classifications for land use plan development and decision-making. According to the SMARA map of Desert Hot Springs, the project and its surroundings are located within Mineral Resource Zone 3 (MRZ3), which applies to areas where the significance of mineral deposits cannot be evaluated from the

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 74
Draft Initial Study / Mitigated Negative Declaration December 2022 available data. There are no specific known mineral resource deposits or facilities on or near the project.

Additionally, the land use designation for the site is not compatible with mining operations.

The nature of the project does not involve the extraction of mineral deposits. Construction of the proposed storage pod facility would rely on existing local and regional aggregate resources from permitted facilities.

The project is not expected to result in a considerable extraction and/or loss of known mineral resources that are considered important to the Coachella Valley Region or residents of California. Less than significant impacts are expected related to the loss of availability of known mineral resources.

Mitigation Measures: None
b) Result in the loss of availability of a
locally-important mineral resource
recovery site delineated on a local
general plan, specific plan or other
land use plan?
Discussion:

Mineral resources that are known to exist in the Coachella Valley region primarily consist of sand and gravel (aggregate) typically deposited along and near local drainages. Aggregate material is deemed necessary to the local building industry as a component of asphalt, concrete, road base, stucco and plaster. Local or regional construction industries tend to be dependent on readily available aggregate deposits within reasonable distance to the market region. The project site is not recognized as a mineral resource recovery site delineated in the County of Riverside General Plan, City of Desert Hot Springs General Plan or the resource maps prepared pursuant to SMARA. Less than significant impacts are expected.

Mitigation Measures: None
XIII. NOISE -- Would the project result in:

Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs General Plan Environmental Impact Report, 2020; Desert Hot Springs Municipal Code. a) Generation of a substantial temporary
or permanent increase in ambient noise
levels in the vicinity of the project in excess
of standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?
Discussion:

Noise is simply defined as unwanted sound that interferes with normal activities or diminishes the quality of the environment. Sounds also becomes unwanted when it causes actual physical harm or when it has adverse effects on health. Noise is measured on a logarithmic scale of sound pressure level known as a decibel (dB). An A-weighted decibel (dBA) is an expression of the relative loudness of sounds in air as perceived by the human ear. In an A-weighted system, the decibel value of sounds at low frequencies are reduced compared with unweighted decibels, in which no correction is made for audio frequency.

Excessive noise or prolonged exposure to noise can contribute to temporary and permanent impairments, such as hearing loss, fatigue, stress, sleep deprivation, anxiety and annoyance. Although noise has been

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 75
Draft Initial Study / Mitigated Negative Declaration December 2022 accepted as a necessary by-product of urban development, it can become an environmental hazard.

Various components of the urban environment generate noise, such as construction equipment and activities, motor vehicles, air traffic, mechanical equipment, and household appliances.

The most common sound range for human exposure is between 40 dB (very quiet) and 100 dB (very loud). Community noise impacts are commonly evaluated using the Community Noise Equivalent Level (CNEL) noise index, which reduces the combined effect of daily noise exposure to a single number. The value computed by this method is the sum of the decibel values of sound, averaged over 24 hours, with corrections for time of day, such as a 5 dBA penalty for noises occurring during the evening time period (from 7 p.m. to 10 p.m.) and a 10 dBA penalty for noises occurring during the nighttime period (from 10 p.m. to 7 a.m.).

According to the Desert Hot Springs General Plan (DHS GP) Environmental Impact Report (EIR), the City’s noise environment can be characterized as relatively quiet, with the primary sources of noise being motor vehicle traffic on highways and major arterials. The City of Desert Hot Springs has the authority to establish land use noise standards and corresponding restrictions under the City’s Noise Ordinance. The range of noise standards apply to different receiving land uses based on sensitivity and compatibility.

The land use and noise standards are displayed in Table SN-2, Community Noise and Land Use Compatibility, from the DHS GP Noise Element. The proposed corresponding container storage facility corresponds to the land use category of “Industrial”, based on the property’s land use designation. For this category, the recommended “normally acceptable” noise limit ranges from 50 to 65 dBA. Noise levels up to 80 dBA are considered “conditionally acceptable” for industrial uses. This is depicted in Table SN2 from the General Plan:

Table SN-2
Community Noise and Land Use Compatibility

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 76
Draft Initial Study / Mitigated Negative Declaration December 2022 The project property is located on vacant land surrounded by developed, industrial uses to the west and vacant land to the north, east and south. Calle De Los Romos delineates the project’s western boundary, and the unpaved 19th Avenue delineates the project’s southern boundary. The project and the surrounding area are zoned Light Industrial (I-L). I-L districts intend to retain, enhance, and intensify existing and provide for the new development of lighter industrial uses along major transportation routes serving the City. I-L districts accommodate all industrial uses operating entirely in enclosed buildings, requiring limited and screen-able outdoor storage space and cannabis cultivation facilities. Project related noise during construction and operation is further analyzed as followed.

Construction
Construction of the project site is expected to generate short-term noise increases compared to the existing levels. A temporary incremental increase in noise levels along local roadways is expected to occur during the transport of workers and equipment to and from the site. Noise increases will also be generated by the actual on-site construction activities. Equipment used during the construction phases would generate both steady state and episodic noise that would be heard both on and off the project site.

Noise levels generated during various construction phases are presented in Table XIII-1, Typical Maximum Noise Levels for Construction Phases, below. Equipment estimates used for the analysis for grading and building construction noise levels was provided by the U.S. Department of Transportation and are representative of worst-case conditions, since it is unlikely that all the equipment contained onsite would operate simultaneously.

Table XIII-1
Typical Maximum Noise Levels for Construction Phases
Appropriate Leq dBA without Noise Attenuation
Construction Phase 25 Feet 50 Feet 100 Feet 200 Feet
Clearing 90 84 78 72
Excavation 94 88 82 78
Foundation/Conditioning 94 88 82 78
Laying Subbase/Paving 85 79 73 67
Source: U.S. Department of Transportation, Construction Noise Handbook, Chapter 9.0, August 2006.

Areas north, south, and east of the project will not be impacted by construction noise because they are currently undeveloped and vacant. The industrial business park, Coachillin, is located west of the project site, separated by Calle De Los Romos. Coachillin is surrounded by masonry block wall and landscaping.

Additionally, there are no residential uses, schools, or other sensitive receptors near the project site. The nearest residential property to the site is located approximately 0.50 miles northwest of the project. Thus, noise levels generated by the project construction is not anticipated to substantially impact surrounding properties or sensitive receptors.

Although construction noise generated from the project site is not anticipated to result in significant impact, the project shall follow common industry standards that will help limit noise level increases during construction. For example, all construction equipment, fixed or mobile, should be equipped with properly operating and maintained mufflers and the engines should be equipped with shrouds. Approved haul routes shall be used to minimize exposure of sensitive receptors to potential adverse levels from hauling

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 77
Draft Initial Study / Mitigated Negative Declaration December 2022 operations. All construction equipment shall be in proper working order and maintained to reduce backfires. Grading activities would involve the use of standard earth moving equipment, which would be stored on the site during construction to minimize disruption of the surrounding land uses. Above-grade construction activities would involve the use of standard construction equipment, such as hoist, cranes, mixer trucks, concrete pumps, laser screeds and other related equipment.

Construction traffic and equipment is also anticipated to generate noise along access routes to the proposed development. The larger pieces of heavy equipment would be moved onto the development only one time for each construction activity (i.e., site prep, grading, etc.). Daily transportation of construction workers and the hauling of materials both on and off the project site are expected to cause increases in noise levels along surrounding roadways.

As a standard requirement, the project is expected to abide by the Municipal Code regulations on construction hours, which limit activities to the less sensitive times of the day. Construction activities are only permitted between 7:00 a.m. and 5:00 p.m. Monday through Saturday. During daylight savings time, construction is permitted between 6:00 a.m. and 6:00 p.m. Monday through Saturday. Construction is not permitted on Sundays and national holidays. Therefore, construction of the project is required to occur during the permitted hours to minimize noise impacts generated by development. Additionally, the project will utilize construction equipment compliant with industry standards. Less than significant impacts are anticipated during project construction.

Operation
The vacant project property is located in Desert Hot Springs’s Industrial land use district. The area surrounding the project is characterized by vacant land to the north, east, and south, and an industrial business park to the west. The project is separated from land uses that are sensitive to noise levels by approximately 0.50 miles. According to the DHS GP, industrial operations can create substantial noise problems. Warehousing operations and other acoustically unscreened operations, such as chillers, refrigerator units and heating/air conditioning equipment associated with commercial centers will raise issues of impact and compatibility. These can be mitigated through design features such as sound barriers including walls, landscaping and placement of the equipment. There are no residential uses, schools, or other sensitive receptors near the project site. The project is not located near sensitive receiver properties such as residential neighborhoods.

In addition to stationary sources, the Noise Element of the DHS GP and GP Environmental Impact Report (EIR) identifies vehicular traffic as the principal source of noise in the community. To understand and evaluate the impacts of land use patterns, traffic and development on the noise environment, computer models and simulations were used to calculate transportation noise along major roadways based upon the operating characteristics and traffic volumes. The calculations identify the projected noise contours along major roadways at General Plan Buildout in Table 4.13-4, Future (2040) Traffic Noise Level Contour Distances, in the DHS GP EIR. Per Table 4.13-4, North Indian Canyon Drive is the closest major roadway to the project property, lying approximately 0.50 miles west of the project. 70 dBA CNEL is anticipated to be observed at 497 feet from North Indian Canyon Drive centerline, 65 dBA CNEL is anticipated to be observed at 1,570 feet, and 60 dBA CNEL would be observed at 4,966 feet, according to Table 4.13-4.

Additionally, Interstate 10 (I-10) is located approximately 0.50 miles south of the proposed project.

According to Table 4.13-4, 70 dBA CNEL is anticipated to be observed at 6,344 feet from I-10 centerline, and 65 dBA would be observed at 20,062 feet. Thus, 60 dBA CNEL generated from North Indian Canyon Drive would be observed at the project site, and 70 dBA CNEL generated from I-10 would be observed

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 78
Draft Initial Study / Mitigated Negative Declaration December 2022 by the proposed project. However, the project’s proposed operation as a container storage facility is not anticipated to experience significant impacts from the road. Additionally, the project is located within the City’s industrial land use area, where increased noise levels are generally anticipated.

Outdoor activities will be limited during the life of the project. These include vehicular access and circulation in the project’s parking lot and drive aisles; access to the trash enclosures for waste management (disposal and pick-up); access to the outdoor utilities for maintenance purposes (i.e., storm drain system components, chillers, HVAC equipment, etc.).

While the project would result in an increase in noise levels compared to the existing vacant condition, the nature and intensity of operations that would occur in the proposed structures are not expected to result in the generation of noise levels that would surpass the community noise and land use compatibility standards. Additionally, the project may result in an incremental increase in traffic-related noise levels on the local roadways, however, it would not create a substantial increase in noise levels. Noise generated by the project site is anticipated to be similar to the existing light industrial uses in nearby areas. Less than significant impacts are expected.

Mitigation Measures: None
b) Generation of excessive groundborne
vibration or groundborne noise levels?
Discussion:

Groundborne vibration also referred to as earthborne vibration, can be described as perceptible rumbling, movement, shaking or rattling of structures and items within a structure. Groundborne vibration can generate a heightened disturbance in residential areas. These vibrations can disturb residential structures and household items while creating difficulty for residential activities such as reading or other tasks. Although groundborne vibration is sometimes perceptible in an outdoor environment, it does not result in the degree of disturbance that is experienced inside a building. Groundborne vibration can be measured in terms of amplitude and frequency or vibration decibels (VdB). Trains, buses, large trucks and construction activities that include pile driving, blasting, earth moving, and heavy vehicle operation commonly cause these vibrations. Other factors that influence the disturbance of groundborne vibration include distance to source, foundation materials, soil and surface types.

The project is surrounded by vacant land to the north, east, and south. Existing industrial facilities are located west of the project. The existing source of groundborne vibration is attributed to the circulation of vehicles and trucks along the surrounding roadways.

Construction of the project will involve the temporary operation of vehicles and equipment that could result in localized, short-term vibration increases during the permitted hours of construction established by the City. All construction equipment staging will be located within the temporary construction limits, while vehicular and equipment access to the construction site would be restricted to only the approved entry points that minimize disturbance to local traffic. Short-term increases in vibration and sound during construction are not expected to result in significant impact.

After construction, the nature of the proposed cultivation and processing facility would not typically involve activities expected to generate excessive vibration or groundborne noise. All activities within the project will be required to adhere to the City’s Noise Ordinance. Less than significant impacts are anticipated.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 79
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
c) For a Project located within the vicinity
of a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels?

Discussion:

The project site is located approximately 4.75 miles north of Palm Springs International Airport, and 18.10 miles northwest of the Bermuda Dunes Airport. Therefore, the project site is not located within two miles of a public airport or the vicinity of a private airstrip, and as such, no impact related to the exposure of people residing or working in the project area to excessive airport related noise levels is anticipated.

Mitigation Measures: None
XIV. POPULATION AND HOUSING – Would the project:

Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs Municipal Code. a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?

Discussion:

Operations of the approximately 4.85-acre project is compatible with uses permitted in the Light Industrial (I-L) zones. The project will have approximately 7 employees during operation. The project may encourage relocation for employment; however, considering the facility’s purpose, employment generated through these facilities would not be substantial. The project does not have a residential component and improvements to roads and other infrastructure associated with the project would not induce substantial growth to the area. Less than significant impacts are expected.

Mitigation Measures: None
b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?

Discussion:

The entire property is currently vacant land designated by the City General Plan and zoning for Light Industrial activity. Development and operation of the project would not displace any existing housing or require replacement housing. No impacts are anticipated.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 80
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
XV. PUBLIC SERVICES
Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs Municipal Code; United States Census, 2020.
a) Would the Project result in substantial
adverse physical impacts associated
with the provision of new or physically
altered governmental facilities, need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts,
in order to maintain acceptable service
ratios, response times or other performance
objectives for any of the public services:

Fire protection?
Discussion:

The City of Desert Hot Springs contracts with Riverside County Fire Department/Cal Fire (RCFD) for a full range of fire protection services provided 24 hours a day, 7 days a week. The RCFD is staffed with a combination of County and State of California Department of Forestry & Fire Protection employees. They operate nearly 100 fire stations that serve approximately two million residents over 7,004 square miles of Riverside County. The City of Desert Hot Springs has three RCFD fire stations, Battalion 10 Station 36, Battalion 10 Station 37, and Battalion 10 Station 56 (refer to the Hazards and Hazardous Materials Section for Station locations). Each station is staffed by 8.2 full time personnel and each shift has 3 professionals, consisting of a Fire Captain/and or engineer and one or two Firefighter II / licensed paramedic on duty at all times. Each station is also equipped with a Type I, 1500 GPM fire engine.

In addition to the other RCFD facilities located in the Coachella Valley, the department maintains a cooperative mutual aid agreement with other agencies and communities to assist in suppressing fire or controlling emergency incidents. Mutual aid is an agreement among emergency responders to lend assistance across jurisdictions provided resources are available and is not to the detriment of their own service area. Per the City’s General Plan, agreements are in place with both Palm Springs and Cathedral City. These cities provide their own fire services and do not contract with RCFD/Cal Fire. Further discussion of this topic is found within the Hazards and Hazardous Materials discussion of this document.

The project proposes a storage pod facility on approximately 4.85 acres. Development of the proposed project is not expected to have a significant impact on fire services nor cause an undue hardship to the fire department. The development could be adequately served without the expansion of a new fire facility and adequate response times would be met. Additionally, the project would be required to implement all applicable and current California Fire Code Standards. This would include installation of fire hydrants as well as sprinkler systems inside the buildings. Furthermore, the project will be reviewed by City and Fire officials to ensure adequate fire service and safety as a result of project implementation. The project will also be required to comply with the City’s Development Impact Fees (DIF) to assist with the funding of public facilities and services, including fire, therefore, less than significant impacts are expected.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 81
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
Police protection?
Discussion:

Police services are provided to the project area by the Desert Hot Springs Police Department. The police department operates out of a single location and is located at 65-950 Pierson Blvd, approximately 3.8 miles from the project site. The DHSPD has 34 officers and 7 support staff, totaling 41 positions. The department serves a population of approximately 32,512 residents according to the United States Census Bureau (2020). The project could result in additional incident call and responses but not to the extent that would delay response times or create demands that would require the construction of a new police station or other facilities.

Furthermore, the project will be reviewed by City and Police officials to ensure adequate police service and safety as a result of project implementation. The project will also be required to comply with the City’s Development Impact Fees (DIF) to assist with the funding of public facilities and services, including police, therefore, less than significant impacts are expected.

The project proposes a storage pod warehouse facility on approximately 4.85 acres. Security measures will be thoroughly incorporated into the project design, as required by the City. The site will be entirely enclosed within perimeter security fencing and gated entry/exit drives will control vehicular access onto and off the property.

Although the project may require additional demand for police services, the demand is not expected to hinder the City’s ability to provide police protection services and adequate response times would be met.

The project will also be required to comply with the City’s Development Impact Fees (DIF) to assist with the funding of public facilities and services, including police, therefore, less than significant impacts are expected.

Mitigation Measures: None
Schools?
Discussion:

The proposed project falls under the Palm Springs Unified School District (PSUSD). Development of the project would not create a direct demand for school service. The project proposes the development of a storage pod facility. Employment generated by the project would not be expected to draw a substantial number of new residents that would generate school age children requiring public education or substantially alter school facilities or the demand for public education and no new facilities would need to be constructed. At the time of writing, current development fees are $4.08 a square foot for residential and $.66 a square foot for commercial projects. Therefore, implementation of the proposed project is not expected to increase the demand for school facilities or result in facility deterioration. No impacts to school facilities are anticipated.

Mitigation Measures: None
Parks?

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 82
Draft Initial Study / Mitigated Negative Declaration December 2022 Discussion:

As discussed below in Section XVI(a) and XVI(b), the proposed project would not create additional demand for public park facilities, nor result in the need to modify existing or construct new park facilities.

No impacts are expected to parks.

Mitigation Measures: None
Other public facilities?
Discussion:

No increase in demand for government services and other public facilities is expected beyond those discussed in this section. No impacts to other public facilities are expected.

Mitigation Measures: None
XVI. RECREATION
Sources: Desert Hot Springs General Plan, 2020; Desert Hot Springs Municipal Code. a) Would the project increase the use
of existing neighborhood and regional
parks or other recreational facilities such
that substantial physical deterioration
of the facility would occur or
be accelerated?
Discussion:

As discussed in the project description, the project proposes to construct a storage warehouse facility.

Properties immediately to the east, south, and north of the project are in a vacant state with similar conditions to those found on-site. An existing industrial business park facility is located west of the project, separated by Calle De Los Romos.

No residential land uses are proposed, and the approximate proposed employees would not cause a substantial increase to the current existing neighborhood community, regional or local parks. Therefore, no impacts are expected relative to use or deterioration of existing parks.

Mitigation Measures: None
b) Does the Project include recreational
facilities or require the construction
or expansion of recreational facilities
which might have an adverse physical
effect on the environment?
Discussion:

The construction of the proposed storage facility, located within an area zoned Light Industrial, will not involve a recreational facility. No construction or expansion of other recreational facilities is required for project implementation and no impacts are anticipated.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 83
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
XVII. TRANSPORTATION -- Would the project:

Sources: California Emissions Estimator ModelTM (CalEEModTM) Version 2020.4.0 California Air Pollution Control Officers Association (CAPCOA); Desert Hot Springs General Plan Environmental Impact Report, 2020; Desert Hot Springs Municipal Code; Traffic Census Report, Coachella Valley Association of Governments, 2015. Riverside County Transportation Commission, Long Range Transportation Study, December 2019; California Office of Planning and Research (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018. DHS 109 Project Vehicle Miles Traveled Memorandum prepared by the Ganddini Group, November 4, 2020 a) Conflict with a program plan, ordinance
or policy the circulation system, including
transit, roadway, bicycle and pedestrian
facilities?
Discussion:

The project site sits on approximately 4.85 acres of vacant land at the northeast corner of 19th Avenue and Calle De Los Romos in the City of Desert Hot Springs. The project proposes the development of 1 approximately 60,000 sf building to support a climate-controlled container storage facility and supporting infrastructure improvements. The site has a General Plan (GP) land use designation of Industrial (I). The project also occurs within the City’s Industrial Cannabis Overlay. The site is zoned as Light Industrial (IL) with an Industrial Cannabis Overlay.

The project property is surrounded by developed uses to the west, and vacant and undeveloped land to the north, east and south. An Anaerobic Digester Facility is proposed approximately 800 feet to the east.

The surrounding properties are also located within the City’s I-L zones, with an Industrial Cannabis Overlay. The Light Industrial Zone and Industrial Cannabis Overlay is intended to provide for any and all industrial uses operating entirely in enclosed buildings, and those requiring limited and screen-able outdoor storage space. The project site is largely segregated from the City’s intense residential uses.

Therefore, no future land use conflicts with residential or commercial uses are anticipated. This is consistent with the City’s General Plan land use designation.

The project site will have three entry points, two on Calle De Los Romos along the western boundary and one on 19th Avenue along the southern boundary. Calle De Los Romos is currently paved with curb and gutter on the west side but not fully improved adjacent to the property. 19th Avenue is not paved adjacent to the proposed project. Local north-south circulation is provided by Indian Canyon Drive located approximately 0.25 miles west of the project. Regional access to the site is provided by the I-10 Freeway located approximately 0.50 mile south of the project.

The facility’s loading docks, and truck access area will be enclosed within gated perimeter security fencing. Two gated entry/exit drives will control vehicular access from the loading area. One is located near the northernmost entry on Calle De Los Ramos, the second one is located near 19th Avenue.

Primary entrance to the public accessible front office will be from Calle De Los Ramos. A paved surface is proposed for the main drive aisles and parking areas. The proposed surfaces and entry/exit drives will

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 84
Draft Initial Study / Mitigated Negative Declaration December 2022 improve accessibility of the site. Circulation and parking will be consistent with City parking standards as determined by City Staff.

Operations: The facility is expected to house a company which moves goods in portable storage units.

Such units are delivered by truck to homes and businesses where they are filled with personal or business belongings, are then picked up again by truck for storage in the warehouse before the storage unit is moved to the location requested by the client. The storage units are warehoused for a short or long duration, and per the client’s needs are removed from the warehouse for delivery to a local or national destination. This building is not a refrigerated/cold storage warehouse.

Level of Service Standard (LOS)
With the implementation of SB 743, intersection Level of Service (LOS) is not calculated to determine transportation impacts, however it provides information regarding intersection capacity and General Plan consistency for the City. The transportation assessment of LOS was conducted for consistency with the City of Desert Hot Springs General Plan and to evaluate the proposed project’s effect on the surrounding transportation network.

Average Daily Trips (ADT) refers to the total number of vehicles that travel a defined segment of roadway over a twenty-four-hour period. The standard most often used to evaluate the operating conditions of the transportation system is called level of service (LOS). LOS is a qualitative assessment of the quantitative effect of factors such as: speed and travel time, traffic volume, geometric features, traffic interruptions, delays, and freedom to maneuver, driver comfort and convenience, and vehicle operating costs LOS is a measure of transportation system performance based upon the ratio of traffic volume relative to the capacity of the roadway or intersection. The volume-to-capacity ratio (V/C) indicates the overall performance of the roadway segment or intersection and corresponds to a rating of A through F identifying its level of capacity utilization and relative level of congestion. LOS A represents free-flow traffic with little or no delay whereas LOS F represents a breakdown of traffic flow and a high incidence of delay. The City of Desert Hot Springs has established LOS D as the minimum level of service for its street segments and intersections.

Table XVII-1
Level of Service - Roadway Segment
Description Mid-Link and Uninterrupted Flow
Level of Service Volume/Capacity Ratio
A 0.00 – 0.60
B 0.61 – 0.70
C 0.71 – 0.80
D 0.81 – 0.90
E 0.91 – 1.00
F Not Meaningful
Source: Highway Capacity Manual, Transportation Research Board – Special Report 209, National Academy of Science, Washington, D.C. 2000.

For roadway segment travel LOS is a measure of the flow of traffic, while for intersections, the LOS is based on the number of seconds the vehicle is delayed in passing through the intersection. Although accepting a lower level of service (LOS E or even F) at certain intersections and segments during peak

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 85
Draft Initial Study / Mitigated Negative Declaration December 2022 season may result in periodic congestion, once familiar with network constraints, travelers will seek alternative paths and traffic will be distributed to those parts of the network with surplus capacity.

Table XVII-2 Level of Service Thresholds
Level of Service Intersection Control Delay (Seconds / Vehicle) Signalized Intersection Unsignalized Intersection
A ≤ 10.0 ≤ 10.0
B > 10.0 to ≤ 20.0 > 10.0 to ≤ 15.0
C > 20.0 to ≤ 35.0 > 15.0 to ≤ 25.0
D > 35.0 to ≤ 55.0 > 25.0 to ≤ 35.0
E > 55.0 to ≤ 80.0 > 35.0 to ≤ 50.0
F > 80.0 > 50.0
Source: Transportation Research Board, Highway Capacity Manual (6th Edition.) Project Impacts
For the proposed warehouse activity, the total number of employees is anticipated to be approximately

7. Since warehouse activity will require significantly less employees per SF of building area relative to typical industrial uses, it is more appropriate to forecast proposed project staff related traffic based on number of employees of a General Light Industrial project rather than based on building SF.

For the proposed trucking operations, the total number of trucks per day is anticipated to be 15, with an ADT of 30 trips (one to access and one to leave the facility). Deliveries will be conducted throughout the day with no established peak hours.

Trip generation was calculated by land use type and was calculated using the reference Trip Generation, prepared by the Institute of Transportation Engineers (ITE) as well as data provided by the applicant.

Table XVII-1 and XVII-2 illustrate the Trip Generation Summary for the project based on the ITE Land Use Classification and applicant data.

The corresponding trip generation rates were made consistent with the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition based on the respective land use codes.  Indoor storage facilities with a floor area of 60,000 square feet and 7 employees representative of an General Light Industrial use, ITE Land Use Code 110.  Delivery Truck Trips, provided by applicant.

Table XVII ‐1 Project Trip Generation Summary
Trip Generation Rates (note 1 and 2)
Land Use  ITE LU
Code
Quantity  AM Peak Hour  PM Peak Hour  Daily
Total  Total
Light Industrial   110  Employees  0.44  0.42  3.37
Delivery Trucks  NA  Trucks  NA  NA  2.00

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 86
Draft Initial Study / Mitigated Negative Declaration December 2022 Table XVII ‐2 Project Trip Generation Summary
Trip Generation Results  (note 1)
Land Use  ITE LU
Code
Quantity  AM Peak Hour  PM Peak Hour  Daily
Total  Total
Light Industrial   110  7 Employees  3  3  21
Delivery Trucks  NA  15 trucks  NA  NA  30
Total      3  3  51

1. Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual.

2. Truck total provided by applicant.

The proposed project is expected to generate a net total of approximately 51 external trip-ends per day on a typical weekday with 3 external vehicles per hour (VPH) during the weekday AM peak hour and 3 external VPH during the weekday PM peak hour.

According to Appendix B of the Riverside County Transportation Analysis Guidelines for Level of Service and Vehicle Miles Traveled, Traffic Analysis Exemptions, certain types of development proposals are generally exempt from Traffic Analysis requirements per Board of Supervisor’s action November 5, 1996 (Item no. 3.27). Exemption #10 indicates that an exemption is appropriate for any use which can demonstrate, based on the most recent edition of the Trip Generation Report published by the Institute of Transportation Engineers (ITE) or other approved trip generation data, trip generation of less than 100 trips during the peak hours. As noted above the project is anticipated to generate approximately 51 ADT for the project and 3 ADT during the AM peak hour and 3 ADT during the PM peak hour and is therefore not required to prepare a formal Traffic Study.

Calle De Los Romos: designated an Industrial Collector with 4-lanes and a painted median. It is a northsouth roadway on the site’s western boundary with a 78’ ultimate right of way and sidewalks on both sides. It is currently partially paved with curb and gutter on the west half, and no curb and gutter adjacent to the project’s western boundary.
19th Avenue: designated as a Major Arterial with 4 lanes undivided with an 88’ ultimate right of way and on-street bike lanes on both sides. This roadway also includes sidewalks on both sides. It is currently an unimproved dirt roadway along the project’s southern boundary.

Indian Canyon Drive: designated as a Primary I roadway, with a proposed 110 foot right of way, six lanes divided, and no parking. This roadway provides regional access to the project.

In 2017 the Coachella Valley Association of Governments (CVAG) Traffic Census Report indicated an ADT of 13,768 on Indian Canyon Drive north of 20th Avenue.

The Transportation and Traffic Section of the City’s General Plan Environmental Impact Report (DHSGP EIR) Table 4.17-5 indicates that the Indian Canyon Drive segment between Dillon Road and 20th Avenue currently has an ADT of 14,183 and a LOS of C (LOS E capacity of 18,000 ADT). Using a 2% yearly growth rate for 2 years (567 ADT) the 2022 ADT is estimated to be 14,750.

Table 4.17-12 indicates that the Indian Canyon Drive segment between Dillon Road and 20th Avenue has a buildout ADT of 39,200 with LOS C (V/C of 0.73) and a LOS E capacity of 54,000 ADT. General Plan

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 87
Draft Initial Study / Mitigated Negative Declaration December 2022 buildout street improvements have been designed to accommodate increasing traffic conditions associated with planned land uses.

The project is anticipated to have a maximum of approximately 20 employees. Total trips associated with the project are estimated to add approximately 51 ADT to the local roadway system. This total is approximately 0.13% of the projected 39,200 ADT associated with LOS C at buildout and approximately

0.09% of 54,000 ADT associated with LOS E at buildout. This increase will not significantly impact the LOS of Indian Canyon Drive.

Prior to approval, the proposed site circulation, including offsite street design standards and the project’s fair share portion of offsite street improvements will be reviewed by the City as part of the site and conditional use analysis. As a Standard Condition, the applicant shall complete adjacent roadway improvements as designated by the General Plan.

Alternative Transportation
SunLine Transit Agency provides bus services to the City of Desert Hot Springs through Lines 2 and 3.

Line 5 is available on weekdays only. No routes are located near the project. The nearest bus stop is and located approximately 4.0 miles in driving/biking distance to the northeast at the intersection of Dillon Road and Palm Drive.

SunLine Transit Agency buses are wheelchair accessible and include bicycle racks accommodating two or three bicycles. The potential use of local bus services by future project employees is not expected to conflict with or substantially increase the demand for this transit service. Project implementation is not anticipated to interfere with the existing service or performance at bus stop facilities. Less than significant impacts are anticipated.

If future demand warrants, expansion of available services may be appropriate. Transit services are monitored by both the City and SunLine. Additional services are periodically considered in response to anticipated increase in use. A future bus route is proposed along Indian Canyon Drive but there is no indication of the date of initiation of this route.

The project would improve pedestrian mobility by incorporating pedestrian sidewalks along the frontage of Calle De Los Romos and Avenue 19th where currently none exist. The widening and improvements of the roadways includes on-street bicycle lanes on 19th Avenue. Improvements resulting from the project are expected to enhance, rather than obstruct or conflict with the City’s established goals on bicycle transportation or with any existing facilities. Less than significant impacts are expected.

TUMF
The Transportation Uniform Mitigation Fee (TUMF) Ordinance became effective July 1, 1989. The TUMF program is a component of the twenty-year Measure Α sales tax program managed by the Coachella Valley Association of Governments (CVAG) and approved by voters in November 1988. In 2002, a thirtyyear extension was approved by Riverside County voters and resulted in an expiration date of 2039.

Under the TUMF, developers of residential, industrial and commercial property pay a development fee to fund transportation Projects that will be required as a result of the growth the Projects create. TUMF will be required as a Condition of Approval.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 88
Draft Initial Study / Mitigated Negative Declaration December 2022 CMP
The Congestion Management Program (CMP), prepared by the Riverside County Transportation Commission (RCTC), is intended to link land use, transportation and air quality with reasonable growth management methods, strategies and programs that effectively utilize new transportation funds to alleviate traffic congestion and related impacts. As the designated Congestion Management Agency (CMA), the RCTC prepares the CMP that designates a system of highways and roadways to include all State Highway facilities within Riverside County and a system of “principal arterials” to be included as the Congestion Management System (CMS). Program updates include consultation with local agencies, the County of Riverside, transit agencies and sub-regional agencies like the Coachella Valley Association of Governments (CVAG).

It is the responsibility of local agencies, when reviewing and approving development proposals to consider the traffic impacts to the CMS. All development proposals and circulation projects to be included within the City of Desert Hot Springs are required to comply with the current policies and procedures set forth by the RCTC’s CMP. The CMA provides a uniform database of traffic impacts for use in a countywide transportation computer model. The RCTC has recognized use of the Coachella Valley Area Transportation System (CVATS) sub-regional transportation model and the Riverside Transportation Analysis Model (RIVTAM) to analyze traffic impacts associated with development proposals or land use plans. The methodology for measuring LOS must be that contained in the most recent version of the Highway Capacity Manual. Traffic standards must be set no lower than LOS E for any segment or intersection on the CMP system unless the current LOS is lower (i.e., LOS F).

The project is located approximately 0.50 miles northeast of the Indian Canyon westbound on-ramp to the Interstate 10 Freeway (I-10). Interstate 10 is identified as a CMP corridor. According to the RCTC Long Range Transportation Study, the I-10 at this location has an LOS of D or better. Traffic (3 ADT for the AM Peak Hour and 3 ADT for the PM Peak Hour) resulting from the operations at the proposed facility, in compliance with the General Plan, is not anticipated to individually or cumulatively contribute to an exceedance of a level of service standard established in the CMP. Impacts are expected to be less than significant.

Following implementation of Standard Conditions and Development Impact Fees (DIF,) the project is not anticipated to conflict with an applicable plan, ordinance or Policy establishing measures of effectiveness for the performance of the circulation system. Less than significant impacts are expected.

Mitigation Measures: None
b) Would the project conflict or be inconsistent
inconsistent with CEQA Guidelines Section
15064.3, subdivision (b)?
Discussion:

Vehicle Miles Travelled (VMT)
Changes to California Environmental Quality Act (CEQA) Guidelines were adopted in December 2018, which require all lead agencies to adopt VMT as a replacement for automobile delay-based level of service (LOS) as the new measure for identifying transportation impacts for land use projects. This statewide mandate went into effect July 1, 2020. To aid in this transition, the Governor’s Office of Planning

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 89
Draft Initial Study / Mitigated Negative Declaration December 2022 and Research (OPR) released a Technical Advisory on Evaluating Transportation Impacts in CEQA (December of 2018) (Technical Advisory).

VMT is a measure of the amount of travel for all vehicles in a geographic region over a given period of time, typically a one-year period. Goals for reducing Greenhouse Gasses (GHG) have been the primary motivation for the shift to VMT measures. Reductions in VMT produce many other potential benefits such as reductions in other air pollutant emissions, water pollution, wildlife mortality and traffic congestion, as well as improvements in safety and health and savings in public and private costs.

The County of Riverside Transportation Analysis Guidelines for Level of Service and Vehicle Miles Traveled provide a series of analytical steps for SB-743 compliance. The process contains a stepped approach that includes screening criteria, identifying significance measure and threshold, VMT analysis and mitigation measures.

Screening criteria were developed to determine if a presumption of non-significant transportation impact can be made on the facts of the project. A detailed CEQA assessment is not required for land use elements of a project that meet the screening criteria included in the Guidelines. The following project types are considered for screening: Small Projects, Projects Near High Quality Transit, Local Essential Service, Map-Based (Low VMT Area) Screening and Redevelopment Projects.

The City of Desert Hot Springs utilizes the Transportation Analysis Guidelines for Level of Service and Vehicle Miles Traveled, County of Riverside Transportation Department, December 2020, which sets forth screening criteria under which Projects are not required to submit detailed VMT analysis. This guidance for determination of non-significant VMT impact is primarily intended to avoid unnecessary analysis and findings that would be inconsistent with the intent of SB 743. VMT screening criteria for development projects include the following:
 Small Projects with low trip generation per existing CEQA exemptions or resulting in a 3,000 metric tons of Carbon Dioxide Equivalent per year screening level threshold.  Low VMT Area Screening within an area of development under threshold based upon RIVTAM modeling, and
 Redevelopment Projects which replace an existing VMT-generating land use and do not result in a net overall increase in VMT.

Small Project Screening
The Project has been reviewed for VMT screening based upon its size as a small project, and no further VMT analysis is needed. Per the GHG Analysis prepared for the Project Specific CEQA document, emission estimates resulted in less than a 3,000 metric tons of Carbon Dioxide Equivalent per year screening level threshold.

Greenhouse Gas Emission Summary
CalEEMod Version 2020.4.0 was used to quantify GHG emissions associated with construction and operation of the proposed project. The corresponding trip generation rates were made consistent with the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition based on the

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 90
Draft Initial Study / Mitigated Negative Declaration December 2022 respective land use codes. There are currently no specific ITE Land Use Codes available for the proposed onsite uses. The most conservative interpretation of proposed land uses, equitable modelling criteria, and associated greenhouse gas impacts have been utilized to capture impacts associated with 100% of the proposed floor area of onsite structures and operations.  Industrial Park facility with a floor area of 60,000 square feet, ITE Land Use Code 130.  Parking lot, driveway, and hardscape facilities with a combined area of 2.08 acres Under this guidance, a screening threshold of 3,000 metric tons of carbon dioxide equivalent MTCO2e) per year has been an acceptable approach for working groups. The GHG emissions estimates resulting from CalEEMod are displayed below in Table XVII-3.

Table XVII-3
Total Project Greenhouse Gas Emissions
Unmitigated Emission
Source
Emissions
(metric tons per year)
Total CO2E
Annual Construction
Emissions Amortized Over 30 13.05065
Area, Energy, Mobile Sources,
Waste, and Water Usage 399.4357
Total CO2E (All Sources) 412.48635
SCAQMD Threshold for
Industrial Projects 3,000
Threshold Exceeded? NO
As shown in Table-1 resulting from the CalEEMod calculations, the project is expected to generate approximately 412.5 MTCO2e per year from construction, area, energy, mobile sources, waste, and water usage sources. Therefore, the project GHG emissions would not exceed the threshold of significance set at 3,000 MTCO2e per year. Having been evaluated against the regionally accepted thresholds, which are part of the State’s regulations aimed at addressing climate change, the project is not expected to interfere with the plans, policies, or regulations adopted for the purpose of reducing the emissions of greenhouse gases.

VMT Screening Conclusion
The Project has been reviewed for VMT screening based upon its size as a small project, and no further VMT analysis is needed. Per the GHG Analysis prepared for the Project Specific CEQA document, emission estimates resulted in less than a 3,000 metric tons of Carbon Dioxide Equivalent per year screening level threshold.

Following implementation of the project design features, TUMF, DIF and standard conditions, the project is expected to result in less than significant impacts.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 91
Draft Initial Study / Mitigated Negative Declaration December 2022 c) Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
Discussion:

The proposed facility is a permissible facility within the existing zoning of Light Industrial (I-L) on and around Indian Canyon Drive. In its current condition, the undeveloped project property is bordered by the paved (but not fully improved) alignment of Calle De Los Romos and unpaved 19th Avenue.

To provide proper access to the facility, off-site design and the proposed off-site improvements include street paving on portions of Calle De Los Romos and 19th Avenue along the project’s frontage. Circulation design will undergo City and Fire Department review before approval to ensure that the local development standards for roadways, in interior and exterior circulation designs, are met without resulting in traffic safety impacts including hazardous design features. The project will not include sharp curves or dangerous intersections. No incompatible uses will result from the project.

A traffic control plan will be prepared prior to construction to reduce the potential for temporary hazards associated with construction activities. This requirement will work to coordinate traffic associated with the facility staff, construction traffic and existing users along 19th Avenue. All project plans shall be reviewed and approved by the City Engineering Department. Impacts are expected to be less than significant.

Mitigation Measures: None

d) Result in inadequate emergency access?
Discussion:

The project will provide adequate access to emergency response vehicles, as required by the City of Desert Hot Springs and in accordance with the Fire Department review and requirements. Site plan review would include in-depth analysis of emergency access to the site to ensure proper access to facilities. As mentioned in Section 1.1, the Purpose and Authority section of Chapter 1, the proposed site plan provides two primary vehicular access points on Calle De Los Romos and one on 19th Avenue. The design details of the vehicular driveways will be reviewed and approved by the Fire Department and the City.

The project is anticipated to provide proper premises identification with legible site name, address numbers, and clear signage indicating the site access points. Security gates, controlled access key boxes, operational fire hydrants and extinguishers are also required in accordance with Chapter 15.24 of the Desert Hot Springs Municipal Code for Cultivation projects. Off-site Project improvements will involve paving on Calle De Los Romos and 19th Avenue within the required rights-of-way and according to the City’s designated street standards.

Following implementation of standard conditions, the project is anticipated to result in less than significant impact related to emergency access.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 92
Draft Initial Study / Mitigated Negative Declaration December 2022 XVIII. TRIBAL CULTURAL RESOURCES -- Would the Project:

Sources: Historical/Archaeological Resources Assessment, CRM Tech, 2020. a) Would the Project cause a substantial
Adverse change in the significance of a
Tribal cultural resource, defined in Public
Resource Code Section 21074 as either
a site, feature, place, cultural landscape that
is geographically defined in terms of the size
scope of the landscape, sacred place, or object
with cultural value to a California Native
American tribe, and that is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
Register of historical resources as defined
in Public Resource Code Section 5020.1(k), or:

Discussion:

As previously discussed in the Cultural Resources Section, the project site has been cleared and graded and no historical resources were encountered on the site. However, unknown archaeological resources have the potential to be uncovered during ground disturbance and excavation activities. Therefore, following implementation of the recommended mitigation measure outlined in the Cultural Resources Section of this Initial Study, less than significant impacts are expected following the recommended mitigation measure.

Mitigation Measures: CUL-1
ii) A resource determined by the lead agency,
in its discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying the criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1, the lead agency shall
consider the significance of the resource to a
California Native American Tribe.

Discussion:

Public Resource Code 21074 identifies “Tribal Cultural Resources” as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American Tribe” and that are either included or determined to be eligible for inclusion on the national, state, or local register of historic resources, or that are determined by the lead agency, in its discretion, to be significant when taking into consideration the significance of the resource to a California Native American Tribe.

To ensure that all significant Tribal Resources are identified and fully considered, AB 52 Consultation will be conducted by the City of Desert Hot Springs. On August 15, 2022, AB 52 notification letters were sent

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 93
Draft Initial Study / Mitigated Negative Declaration December 2022 to 14 Native American tribal governments or designated tribal representatives via USPS mail. During the comment period (which ended on September 14, 2022), the City received two letters. The Agua Caliente Band of Cahuilla Indians (ACBCI) provided a comment letter on August 30th. Within their letter, the ACBCI requested the following:
 Formal consultation;
 A cultural resources inventory of the project by a qualified archaeologist prior to any development activities in the project area;
 A copy of the records search with associated survey reports and site records from the information center; and
 Copies of any cultural resource documentation (reports and site records) generated in connection with the project.

The Morongo Band of Mission Indians also sent a letter to the City during the comment period. The Morongo Tribe stated that the project site is located within the ancestral territory and traditional use area of the Cahuilla and Serrano people of the Morongo Band of Mission Indians. Therefore, the Tribe requested the following:
 AB 52 consultation;
 Project design and grading maps;
 A records search conducted at the appropriate CHRIS center and cultural resource documentation generated through the search;
 Tribal participation (i.e., tribal monitors) during the pedestrian survey and testing, if the fieldwork has not already taken place. Or copies of the current Phase I study or other cultural assessments;  Shapefiles of the project area of potential effect (APE); and  Geotechnical Report.

The materials requested by the ACBCI and Morongo Tribes were sent on January 3, 2023. Upon receiving the materials, the tribes may further provide recommendations and/or mitigation measures.

CRM Tech, as stated in the Cultural Report, contacted representatives of local Native American groups for further information on potential resources. CRM Tech contacted the ACBCI for additional information and tribal participation in the fieldwork. In a written response dated October 6, 2022, Nicole Raslich of the ACBCI Tribal Historic Preservation Office confirmed that the project area lay within the tribe’s traditional use area and requested copies of all cultural resources documentation generated for the project for tribal review. In addition, the tribe recommended onsite monitoring by an archaeologist and an approved Agua Caliente Native American Cultural Resource Monitor during ground-disturbing activities associated with the proposed project. Ms. Raslich subsequently participated in the field survey of the project area on November 1, 2022. The project ground surface has been extensively disturbed over the past five years in association with its use as a staging area for the adjacent development, and the likelihood of any prehistoric or historical cultural remains surviving intact on or near the ground surface is considered to be low. Although CRM Tech concluded negative results for potential cultural resources, the project shall retain an archaeologist and an approved Agua Caliente Native American Cultural Resource Monitor during ground-disturbing activities associated with the proposed project. This is required by Mitigation Measure TCR-1.

Mitigation Measures: TCR-1

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 94
Draft Initial Study / Mitigated Negative Declaration December 2022 TCR-1: The project shall retain an archaeologist and an approved Agua Caliente Native American Cultural Resource Monitor during ground-disturbing activities associated with the proposed project.

XIX. UTILITIES AND SERVICE SYSTEMS -- Would the project:

Sources: Desert Hot Springs General Plan, 2020; Coachella Valley Urban Regional Water Management Plan, Mission Springs Water District, 2015; Sewer Master Plan, Mission Springs Water District, 2007. a) Require or result in the relocation or
construction of new or expanded water,
or wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which would
significant environmental effects?

Discussion:

Domestic water for the proposed development would be provided to the project by connecting into the existing water and sewer mains located along 19th Avenue and Calle Del Los Ramos. The project would then connect to water and sewer through a series of water service lines and sewer laterals. Electric power, telecommunication and natural gas connections are also located within proximity of the project’s boundary. The project is designed with an on-site stormwater retention system that during the life of the project will comply with the City’s drainage requirements by preventing site discharge and transport of untreated runoff. The proposed storm drain system includes facilities which have been preliminarily sized to provide enough storage for the 100-year controlling storm event. Therefore, no new construction or new water, wastewater, electric power, natural gas, or telecommunications facilities will need to be constructed or relocated. Less than significant impacts are expected.

Mitigation Measures: None
b) Have sufficient water supplies available
to serve the project and reasonably
foreseeable future development during
normal dry and multiple dry years?

Discussion:

MSWD provides water and sewer services to the communities of Desert Hot Springs, West Garnet, North Palm Springs, and various portions of unincorporated Riverside County. The District provides water service to approximately 37,600 people in their water service area. Groundwater is the primary source of domestic water supply in the Coachella Valley; the Mission Springs Water District (MSWD) provides potable water to the City by extracting groundwater from the Mission Creek Subbasin. The existing MSWD distribution system consists of three independent water distribution systems: 1) Desert Hot Springs and surrounding area system – encompasses the City of DHS, a portion of the City of Palm Springs and surrounding unincorporated area of Riverside County, 2) Palm Springs Crest System, and 3) West Palm Springs Village System.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 95
Draft Initial Study / Mitigated Negative Declaration December 2022 The 2020 Coachella Valley Regional Urban Water Management Plan (CVRUWMP) has been developed to assist the agency in reliably meeting current and future water demands. This document also serves to ensure that adequate water supplies are available to meet the existing and future urban water demands.

As shown in Table 8-1 Current and Projected Population, from the 2020 Coachella Valley RUWMP, the 2020 population for the City of DHS is 38,962. The California Department of Finance population estimate for the City in 2020 is 30,086 persons, which is below the RUWMPs estimate for 2020.

As shown in Table 8-10 Baselines and Target Summary, the District has continued to meet its per-capita water usage over multiple years. The actual water use for 2020 was 189 gpcd, which is below the Districts 2020 target use of 234.9 gpcd. It is anticipated that per-capita water usage will continue to decrease due to the implementation of plumbing code and updated landscape ordinance.

The project is a container storage or portable storage unit facility that will be developed in an existing light industrial area of the City. The project site is currently vacant and undeveloped land and therefore, is not currently using domestic water services. The project will connect to an existing water main located on Calle De Los Ramos and run 4” inch water laterals through the project site. The proposed development will be expected to follow water conservation guidelines to mitigate impacts to public water supplies.

Examples of these water conservation methods include water conserving plumbing fixtures, drought tolerant landscaping, and drip irrigation systems as well as on-site stormwater infiltration. Additional domestic water improvements necessary to serve this development will be identified by MSWD and included as conditions of approval by the City of Desert Hot Springs during the City’s standard review process. Therefore, less than significant impacts relative to water supply are expected.

Mitigation Measures: None

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 96
Draft Initial Study / Mitigated Negative Declaration December 2022 c) Result in a determination by the
wastewater treatment provider which
serves or may serve the Project that it
has adequate capacity to serve the
Project’s projected demand in addition
to the provider’s existing commitments?
Discussion:

The proposed storage facility would not result in a substantial increase to wastewater flows and the project will be required to connect to the public sewer system. Wastewater in the City is currently conveyed to MSWD Horton Wastewater Reclamation Plant. MSWD currently has 9,100 sewer connections throughout its service area and provides sewer service to approximately 26,000 people. Per the Coachella Valley Regional Urban Water Management Plan (RUWMP), the Horton Wastewater Treatment Plant (Horton WWTP), located on Verbena Drive, has a capacity of 2.3 million gallons per day (mgd) (2,800 AFY). The average daily flow metered to the Horton Plan in 2020 was 2.0 MGD.

MSWD is constructing the West Valley Wastewater Treatment Plan (WVWWTP). The WVWWTP would be located at the northwest corner of 20th Avenue and Little Morongo Road, south of the project, and is anticipated to be implemented over an extended period of 3-10 years with an ultimate buildout capacity of 20 MGD. The MSWD 2007 Sewer Master Plan estimates a 2020 sewer connection of 35,245 connections. However, per the 2019 WVWWTP DEIR, the District currently has 9,100 sewer connections, which is far below the estimated demand. Wastewater generated from the project would be conveyed to the WVWWTP. The project would have a nominal increase to wastewater and sufficient capacity would be available to serve the project. The project will extend a 12” sewer main to connect at Calle De Los Ramos and run 6” water laterals through the project site. Additionally, project plans will be reviewed by MSWD and City Staff to ensure wastewater capacity and compliance. Wastewater generated by the project site would be nominal since the facility will utilize efficient irrigation and fixtures. Sewer installation and connection fees in place at the time of development or connection would be collected by MSWD.

Therefore, less than significant impacts relative to wastewater capacity are expected.

Mitigation Measures: None
d) Generate solid waste in excess of State
or local standards, or in excess of the
capacity of local infrastructure, or otherwise
impair the attainment of solid waste
reduction goals?
Discussion:

Solid waste disposal and recycling services for the City of Desert Hot Springs are provided by Desert Valley Disposal (DVD). Solid waste and recycling collected from the project will be hauled to the Edom Hill transfer station. Waste from this transfer station is then sent to a permitted landfill or recycling facility outside of the Coachella Valley. These include Badlands Disposal Site, El Sobrante Sanitary Landfill and Lamb Canyon Disposal Site. Cal-Recycle data indicates the Badlands Disposal site has 15,748,799 cubic yards of remaining capacity, the El Sobrante Landfill has a remaining capacity of 3,834,470 cubic yards of solid waste, and Lamb Canyon Disposal has a remaining solid waste capacity of 19,242,950 cubic yards. Solid waste generated by the project would consist of standard household/office waste. Unused

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 97
Draft Initial Study / Mitigated Negative Declaration December 2022 plant material will be composted and reintroduced into soil composite and not disposed of in unsecured waste receptacles.

As part of its long-range planning and management activities, the Riverside County Department of Waste Resources (RCDWR) ensures that Riverside County has a minimum of 15 years of capacity, at any time, for future landfill disposal. The 15-year projection of disposal capacity is prepared each year by as part of the annual reporting requirements for the Countywide Integrated Waste Management Plan. The most recent 15-year projection by the RCDWR indicates that no additional capacity is needed to dispose of countywide waste through 2024, with a remaining disposal capacity of 28,561,626 tons in the year 2024.

In addition, development of the project would be required to comply with mandatory commercial and multifamily recycling requirements of Assembly Bill 341. Therefore, the project will comply with all applicable solid waste statutes, policies and guidelines; and the project will be served by a landfill with sufficient capacity to serve the project. Therefore, less than significant impacts relative to solid waste are anticipated.

Mitigation Measures: None
e) Comply with federal, state, and local
management and reduction statutes
and regulations related to solid waste?

Discussion:

The project will comply with all applicable solid waste statutes and guidelines. All development is required to comply with the mandatory commercial and multi-family recycling requirements of Assembly Bill 341.

The project will also comply with the recycling requirements of Cal Green and develop a waste management plan that will include diverting at least 50% of construction and demolition material fill from landfills. In addition, the project will not involve the use or storage of hazardous materials other than small amounts of cleaning products. These materials will be stored and applied according to manufacturer’s instructions to mitigate the potential for incidental release of hazardous materials or explosive reactions.

No impacts are expected relative to applicable solid waste statues and regulations.

Mitigation Measures: None
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Sources: Fire Hazard Severity Zones in State Responsibility Areas, CAL FIRE. a) Substantially impair an adopted emergency
response plan or emergency evacuation
plan?
Discussion:

The approximately 4.85-acre project site is characterized by vacant, graded land with various material piles ranging from 3 to 5 feet in height. Situated north of Avenue 19 and east of Calle De Los Romos, the site is located within a primarily undeveloped context within the City of Desert Hot Springs’s Light Industrial zoning designation. According to CAL Fire’s Fire Hazard Severity Zones (FHSZ) in State Responsibility Areas (SRA) Map, the project is not located in an SRA or located in an area classified as

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 98
Draft Initial Study / Mitigated Negative Declaration December 2022 very high fire hazard severity zone (VHFHSZ). Additionally, the project property is not located in or near lands classified as high or moderate fire hazard severity zones. The closest SRA or VHFHSZ classified area is located approximately 5 miles north of the project site, bordering the City’s northern boundary.

Due to the project’s distance from SRAs and areas designated as VHFHSZs, no impacts are anticipated.

Mitigation Measures: None
b) Due to slope, prevailing winds, and
other factors, exacerbate wildfire risks,
and thereby expose project occupants
to pollute concentrations from a wildfire
or the uncontrolled spread of a wildfire?
Discussion:

See previous discussion. No impact.

Mitigation Measures: None
c) Require the installation or maintenance
of associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?
Discussion:

See previous discussion. No impact.

Mitigation Measures: None
d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
Discussion:

See previous discussion. No impact.

Mitigation Measures: None
XXI. MANDATORY FINDINGS

OF SIGNIFICANCE --

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 99
Draft Initial Study / Mitigated Negative Declaration December 2022 a) Does the project have the potential
to substantially degrade the quality of
the environment, substantially reduce
the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop
below self-sustaining levels, threaten to
eliminate a plant or animal community,
substantially reduce the number or restrict
the range of a rare or endangered plant or
animal or eliminate important examples
of the major periods of California history
or prehistory?
Discussion:

As concluded in the Biological and Cultural Resources sections of this Initial Study, the project would result in no impacts or less than significant impacts with mitigation to these resources. The project is compatible with the City of Desert Hot Springs Zoning and its surroundings. The project will not significantly degrade the overall quality of the region’s environment, or substantially reduce the habitat if a wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California History or pre-history.

Based upon the information and mitigation measures provided within this Initial Study and independent studies prepared for Biological and Cultural Resources, approval and implementation of the project is not expected to substantially alter or degrade the quality of the environment, including biological, cultural or historical resources. Following the mitigation measures outlined in the Biological and Cultural Resource section, less than significant impacts are expected.

Mitigation Measures: See Biological and Cultural Resource Sections b) Does the project have impacts that are
individually limited, but cumulatively
considerable? ("Cumulatively considerable"
means that the incremental effects of a
Project are considerable when viewed in
connection with the effects of past Projects,
the effects of other current Projects, and
the effects of probable future Projects)?
Discussion:

The project is located in an area designed for light industrial uses. The facility would be compatible with the existing and future land uses within the Light Industrial zone. Future developments in the vicinity of the project are anticipated to occur, however, developments would be consistent with the surrounding land uses, which includes light industrial facilities. Future developments in the area would be required to obtain the appropriate approvals and permits prior to development. Based upon the information and mitigation measures provided within this Initial Study, approval and implementation of the proposed facility is not expected to result in impacts that, when considered in relation to other past, current or probable future projects, would be cumulatively considerable. Less than significant impacts are expected.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
City of Desert Hot Springs Page 100
Draft Initial Study / Mitigated Negative Declaration December 2022 Mitigation Measures: None
c) Does the project have environmental
effects which will cause substantial
adverse effects on human beings,
either directly or indirectly?

Discussion:

As discussed in the various sections throughout this Initial Study, the project would not include a land use that could result in substantial adverse effects on human beings. The City of Desert Hot Springs has established regulations pertaining to light industrial facilities to ensure these facilities do not conflict with the City’s General Plan, its surrounding uses, or become detrimental to the public health, safety and welfare. The City’s detailed review process of improvement plans and facility operations will ensure that the regulations are fully implemented. Based upon the findings provided in this document, and mitigation measures and standard conditions incorporated into the project, less than significant impacts are expected.

Mitigation Measures: None

City of Desert Hot Springs Page 101
Draft Initial Study / Mitigated Negative Declaration December 2022 Sources
Analysis of the Coachella Valley PM10 Redesignation Request and Maintenance Plan, by the California Air Resources Board, February 2010
California Emissions Estimator Model (CalEEMod), Version 2040.4.0 City of Desert Hot Springs General Plan, adopted May 2020 City of Desert Hot Springs General Plan Draft EIR, 2020 City of Desert Hot Springs Municipal Code
DHS 109 Project Vehicle Miles Traveled Memorandum prepared by the Ganddini Group, November 4, 2020
Final 2003 Coachella Valley PM10 State Implementation Plan (CVSIP), by SCAQMD, August 2003
Final 2016 Air Quality Management Plan (AQMP), by SCAQMD, March 2017 Flood Insurance Rate Map (FIRM) Panel # 06065C0895G, Federal Emergency Management Agency, Effective August 28, 2008
General and Focused Biological Resource Assessment, prepared by James W. Cornett, Ecological Consultants, July 2022
Historical/Archaeological Resources Survey Report, prepared by CRM Tech, December 28, 2022 Master Drainage Plan for the Desert Hot Springs Area (DHS MDP), prepared in February of 1982 by the Riverside County Flood Control and Water Conservation District (RCFC) Mission Springs Water District 2015 Urban Water Management Plan, June 2016 Mission Springs Water District Wastewater System Comprehensive Master Plan, April 2007 Mission Springs Water District Program DEIR for the West Valley Water Reclamation Program, April 2019
Riverside County General Plan, revised December 2015.

Water Quality Control Plan for the Colorado River Basin Region, January 2019

Via Email
February 10, 2023
James Nindel, Vice Chairman
Leroy Aleman, Commissioner
Mary-Kate Stoever, Commissioner
Dirk Voss, Commissioner
Chris Wagstaff, Commissioner
Planning Commission
City of Desert Hot Springs
11-999 Palm Dr.

Desert Hot Springs, CA 92240
Patricia Villagomez, Principal
Planner
Planning Division
City of Desert Hot Springs
11-999 Palm Dr.

Desert Hot Springs, CA 92240
[email protected]
Jerryl Soriano, City Clerk
City of Desert Hot Springs
11-999 Palm Dr.

Desert Hot Springs, CA 92240
[email protected]
[email protected]
Re: Comment on the PODS Logistics Center (Development Permit No. 22-4) Dear Honorable Members of the Planning Commission and Ms. Villagomez:

I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Initial Study and Mitigated Negative Declaration (“MND”) prepared for the proposed 60,000 square-foot warehouse facility to be located on the 4.85-acre property on the northeast corner of Calle De Los Romos and 19th Avenue (APN No. 666-360-017) in the City of Desert Hot Springs (“Project.”) The MND and Project are scheduled to be considered by the Planning Commission on February 14, 2023. Please include these comments on the administrative record for this matter.

After reviewing the MND, it is evident that it is inadequate and that it fails as an informational document. Specifically, there is substantial evidence of a fair argument that the Project may have significant, unmitigated adverse environmental impacts. Therefore, CEQA requires that the City of Desert Hot Springs (“City”) prepare an environmental impact report (“EIR”) for the Project, pursuant to the California Environmental Quality Act (“CEQA”), Public Resources Code section 21000, et seq. SAFER respectfully requests that you deny approval of the MND and instead direct the City’s Planning Division to prepare an EIR for the Project.

SAFER Comment on MND for PODS Logistics Center
February 10, 2023
I. LEGAL STANDARD
As the California Supreme Court has held, “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-320 (CBE v. SCAQMD) (citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504–505).) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code (“PRC”) § 21068; see also 14 CCR § 15382.) An effect on the environment need not be “momentous” to meet the CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc., 13 Cal.3d at 83.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Env’t v. Cal. Res.

Agency (2002) 103 Cal.App.4th 98, 109 (CBE v. CRA).)
The EIR is the very heart of CEQA. (Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” (Bakersfield Citizens, 124 Cal.App.4th at 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR process “protects not only the environment but also informed self-government.” (Pocket Protectors, 124 Cal.App.4th at 927.) An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also Pocket Protectors, 124 Cal.App.4th at 927.) In very limited circumstances, an agency may avoid preparing an EIR by issuing a negative declaration, a written statement briefly indicating that a project will have no significant impact thus requiring no EIR (14 CCR § 15371), only if there is not even a “fair argument” that the project will have a significant environmental effect. (PRC §§ 21100, 21064.) Since “[t]he adoption of a negative declaration . . . has a terminal effect on the environmental review process,” by allowing the agency “to dispense with the duty [to prepare an EIR],” negative declarations are allowed only in cases where “the proposed project will not affect the environment at all.” (Citizens of Lake Murray v.

San Diego (1989) 129 Cal.App.3d 436, 440.)
Mitigation measures may not be construed as project design elements or features in an environmental document under CEQA. The IS/MND must “separately identify and analyze the significance of the impacts … before proposing mitigation measures […].” (Lotus vs.

Department of Transportation (2014) 223 Cal.App.4th 645, 658.) A “mitigation measure” is a measure designed to minimize a project’s significant environmental impacts, (PRC §

SAFER Comment on MND for PODS Logistics Center
February 10, 2023
21002.1(a)), while a “project” is defined as including “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.” (CEQA Guidelines § 15378(a).) Unlike mitigation measures, project elements are considered prior to making a significance determination. Measures are not technically “mitigation” under CEQA unless they are incorporated to avoid or minimize “significant” impacts. (PRC § 21100(b)(3).) To ensure that the project’s potential environmental impacts are fully analyzed and disclosed, and that the adequacy of proposed mitigation measures is considered in depth, mitigation measures that are not included in the project’s design should not be treated as part of the project description. (Lotus, 223 Cal.App.4th at 654-55, 656 fn.8.) Mischaracterization of a mitigation measure as a project design element or feature is “significant,” and therefore amounts to a material error, “when it precludes or obfuscates required disclosure of the project’s environmental impacts and analysis of potential mitigation measures.” (Mission Bay Alliance v.

Office of Community Investment & Infrastructure (2016) 6 Cal.App.5th 160, 185.) Where an initial study shows that the project may have a significant effect on the environment, a mitigated negative declaration may be appropriate. However, a mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” (PRC §§ 21064.5, 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331.) In that context, “may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, 124 Cal.App.4th at 927; League for Protection of Oakland’s etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904–05.)
Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect—even if contrary evidence exists to support the agency’s decision. (14 CCR § 15064(f)(1); Pocket Protectors, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, 124 Cal.App.4th at 928.) The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘fair argument’ standard is very different from the standard normally followed by public agencies in their decision making. Ordinarily, public agencies weigh the evidence in the record and reach a decision based on a preponderance of the evidence. [Citation]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact.

SAFER Comment on MND for PODS Logistics Center
February 10, 2023
(Kostka & Zishcke, Practice Under the California Environmental Quality Act, §6.37 (2d ed. Cal.

CEB 2021).) The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, 124 Cal.App.4th at 928 (emphasis in original).) For over forty years the courts have consistently held that an accurate and stable project description is a bedrock requirement of CEQA—the sine qua non (that without which there is nothing) of an adequate CEQA document:

Only through an accurate view of the project may affected outsiders and public decision-makers balance the proposal’s benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the “no project” alternative) and weigh other alternatives in the balance. An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR.

(County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185 at 192–93.) CEQA therefore requires that an environmental review document provide an adequate description of the project to allow for the public and government agencies to participate in the review process through submitting public comments and making informed decisions.

Lastly, CEQA requires that an environmental document include a description of the project’s environmental setting or “baseline.” (CEQA Guidelines § 15063(d)(2).) The CEQA “baseline” is the set of environmental conditions against which to compare a project’s anticipated impacts. (CBE v. SCAQMD, 48 Cal.4th at 321.) CEQA Guidelines section 15125(a) states, in pertinent part, that a lead agency’s environmental review under CEQA:
…must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time [environmental analysis] is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant.
(See Save Our Peninsula Committee v. County of Monterey (2001) 87 Cal.App.4th 99, 124-25 (“Save Our Peninsula”).) As the court of appeal has explained, “the impacts of the project must be measured against the ‘real conditions on the ground,’” and not against hypothetical permitted levels. (Id. at 121-23.)
II. DISCUSSION
a. There Was Insufficient Notice for Consideration of the Project.

Meaningful public participation is a central premise of the CEQA review process.

Therefore, a minimum of 20 days is required for public review of a proposed MND. (Pub.

Resources Code, § 21091, subd. (b).) However, despite having filed a CEQA notice request with

SAFER Comment on MND for PODS Logistics Center
February 10, 2023
the City for notification of all such proceedings, SAFER was not notified of the proposed project until a Planning Commission agenda was publicly posted for the February 14, 2023 meeting. In the spirit of informing meaningful public participation, SAFER respectfully requests that you continue any hearings for the proposed Project for a minimum of 20 days to better inform the public’s consideration of the proposed MND.
b. There is a Fair Argument that Significant Adverse Impacts Will Result from the Project.

There is a fair argument that the Project will have significant impacts on air quality, greenhouse gas (“GHG”) emissions, human health, and biological resources. In fact, the air quality and greenhouse gas (“GHG”) impacts of warehouses and other large-scale industrial projects are so severe that the California Attorney General has published guidelines – and an extensive set of proposed mitigation measures – to reduce these significant impacts.1

The significant adverse environmental impacts which often result from these projects has been highlighted by the increasing prevalence of warehouses and distribution centers throughout the state – and the corresponding health impacts caused by the significant increase in heavy-duty truck trips and their emissions of diesel particulate matter (“DPM”), a known human carcinogen.

The MND fails to adequately account for these impacts and incorporates no mitigation to reduce the Project’s impacts to air quality and GHG emissions.

In addition to the Project’s individual impacts, the project will have cumulative impacts when considered together with other existing and reasonably foreseeable projects in the area.

CEQA requires analysis of cumulative impacts. CEQA Guidelines section 15130(a). This requirement flows from CEQA section 21083, which requires a finding that a project may have a significant effect on the environment if “the possible effects of a project are individually limited but cumulatively considerable. . . . ‘Cumulatively considerable’ means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” “Cumulative impacts” are defined as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” CEQA Guidelines section 15355(a). “[I]ndividual effects may be changes resulting from a single project or a number of separate projects.” CEQA Guidelines section 15355(a). In this case, the City should analyze the cumulative impacts of the Project together with other warehouses in the area, as well as the proposed nearby anaerobic digester. 1 California Department of Justice, “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environemtnal Quality Act,” available:
https://oag.ca.gov/sites/all/files/agweb/pdfs/environment/warehouse-best-practices.pdf.

SAFER Comment on MND for PODS Logistics Center
February 10, 2023
III. CONCLUSION
There is a fair argument that the Project will have significant unmitigated impacts which must be further analyzed and mitigated by an EIR. Therefore, we respectfully request that you deny approval of the Project at this time and instead direct staff to prepare an EIR.

We reserve the right to supplement these comments at public hearings concerning the Project. Galante Vineyards v. Monterey Peninsula Water Management Dist., 60 Cal. App. 4th 1109, 1121 (1997). Thank you for considering these comments.

Sincerely,
Adam Frankel

State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Inland Deserts Region
3602 Inland Empire Blvd c220
Ontario, CA 91764
www.wildlife.ca.gov
March 13, 2023
Patricia Villagomez, Principal Planner
City of Desert Hot Springs
11999 Palm Drive
Desert Hot Springs, CA 92240
[email protected]
Subject: Mitigated Negative Declaration (MND)

4.85 Acre Logistics Center (Project)
State Clearing House No. 2023020381
Dear Ms. Villagomez:

The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to Adopt an MND from the City of Desert Hot Springs for the Project pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802.). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381.). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY
Proponent: Snider Interests, LLC
Objective: The objective of the Project is to construct a warehouse facility for temporarily holding goods in portable storage units. The Project will consist of a 60,000 square-foot warehouse, two retention basins, 92 parking spaces, and street improvements to Calle De Los Romos. Primary Project activities include construction of the warehouse and the supporting infrastructure. This includes grading, paving, and landscaping the Project site.

Location: The Project site is located on the northeast corner of Calle De Los Romos and Avenue 19 in the City of Desert Hot Springs, California, in San Bernardino County. The Project site is vacant lot located on Assessor’s Parcel Number 666-360-017 at Latitude

33.911189 N and Longitude -116.535817 W. The Project site is bordered to the north and south by undeveloped land and to the east and west by graded and/or developed land.

Timeframe: No timeframe is given for the Project.

1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

DocuSign Envelope ID: C7C6F5B5-4A86-4CC3-8F13-569A1F05AECF