Desert Hot Springs City Council
April 21, 2026

A-8 General Plan Consistency | DHS Varner Road Specific Plan This page intentionally left blank.

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DHS Varner Road Project
Specific Plan Amendment 24-2
General Plan Amendment 24-1
Tentative Parcel Map 25-1
Design Review Application 24-4

ADDENDUM TO THE
Desert Land Ventures
Environmental Impact Report
(SCH No. 2017051070)
Prepared for:

City of Desert Hot Springs
11999 Palm Drive
Desert Hot Springs, CA 92240
Prepared by:

Terra Nova Planning & Research, Inc.®
42635 Melanie Place, Suite #101
Palm Desert, California 92211
April 2026
Item Number: 1.

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Table of Contents

1. Introduction and Project Background ............................................................................... 1

1.1. Summary ....................................................................................................................... 1

1.2. Project Location and Existing Conditions ...................................................................... 1

1.3. Background ................................................................................................................... 2

1.4. Purpose of an EIR Addendum .....................................................................................10

2. Proposed Project ........................................................................................................... 11

3. Impact Analysis .............................................................................................................. 23

3.1. Aesthetics ...................................................................................................................23

3.2. Agriculture and Forestry Resources ............................................................................26

3.3. Air Quality ...................................................................................................................28

3.4. Biological Resources ...................................................................................................41

3.5. Cultural Resources ......................................................................................................61

3.6. Geology and Soils ........................................................................................................66

3.7. Greenhouse Gas Emissions .........................................................................................71

3.8. Hazards and Hazardous Materials ..............................................................................78

3.9. Hydrology and Water Quality .....................................................................................83

3.10. Land Use and Planning ...............................................................................................92

3.11. Mineral Resources ......................................................................................................95

3.12. Noise...........................................................................................................................96

3.13. Population and Housing ...........................................................................................111

3.14. Public Services..........................................................................................................113

3.15. Recreation ................................................................................................................116

3.16. Transportation and Traffic ........................................................................................117

3.17. Tribal Cultural Resources ..........................................................................................135

3.18. Utilities and Service Systems ....................................................................................138 List of Exhibits
Exhibit 1 Regional Location Map ................................................................................................. 6 Exhibit 2 Vicinity Map .................................................................................................................. 7 Exhibit 3 Project Location Map .................................................................................................... 8 Exhibit 4 DLVSP Land Use Plan .................................................................................................... 9 Exhibit 5 Proposed Specific Plan Land Use Plan ........................................................................16 Exhibit 6 Project Site Plan ..........................................................................................................17 Exhibit 7 Project Elevations .......................................................................................................18 Exhibit 8 Conceptual Water Facilities and Infrastructure Plan ..................................................19 Exhibit 9 Conceptual Wastewater Facilities and Infrastructure Plan ........................................20 Exhibit 10 Stormwater Infiltration Basins ....................................................................................21 Exhibit 11 TPM 39143 ..................................................................................................................22 Exhibit 12 Jurisdictional Drainages ..............................................................................................60 Item Number: 1.

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List of Figures
Figure 1 Construction Noise Receiver Locations ....................................................................107 List of Tables
Table 1 2018 DLVSP Land Use Development Summary ......................................................... 3 Table 2 DHS Varner Road Specific Plan ................................................................................12 Table 3 2018 EIR: DLVSP Buildout Emissions Summary .......................................................31 Table 4 Buildout Emissions Comparison: 2018 EIR and Proposed 2025 Specific Plan .........38 Table 5 Summary of Jurisdictional Areas .............................................................................54 Table 6 2018 EIR Mitigated GHG Emissions Summary .........................................................74 Table 7 Projected Mitigated GHG Emissions Summary ........................................................77 Table 8 Project Indoor Industrial Water Demand ................................................................90 Table 9 Project Outdoor Irrigation Water Demand ..............................................................90 Table 10 Noise Significance Criteria .....................................................................................106 Table 11 Construction Noise Level Compliance ...................................................................108 Table 12 Operational Noise Level Compliance .....................................................................110 Table 13 Project Construction Vibration Levels ...................................................................110 Table 14 Intersection Analysis Locations .............................................................................128 Table 15 Intersection Analysis for EAP (2027) ......................................................................129 Table 16 Intersection Analysis for EAPC (2027) ...................................................................129 Table 17 Intersection Analysis for Horizon Year 2045 ..........................................................130 List of Appendices
Appendix A Air Quality and Greenhouse Gas Report ................................................................... A Appendix B Health Risk Assessment ............................................................................................ B Appendix C Biological Resources Assessment .............................................................................. C Appendix D Jurisdictional Delineation ......................................................................................... D Appendix E Preliminary Off-Site Drainage Analysis ...................................................................... E Appendix F On-Site Hydrology Study ............................................................................................ F Appendix G Water Supply Assessment ........................................................................................ G Appendix H Noise and Vibration Analysis .................................................................................... H Appendix I Traffic Analysis ............................................................................................................ I Appendix J Final JPR Findings ....................................................................................................... J Appendix K Traffic Analysis Supplemental Technical Memorandum ........................................... K Item Number: 1.

1 DHS Varner Road
Addendum to the
Desert Land Ventures
Environmental Impact Report
(SCH No. 2017051070)

1. INTRODUCTION AND PROJECT BACKGROUND

1.1. SUMMARY
This document is an Addendum to the 2018 Desert Land Ventures Environmental Impact Report (EIR, SCH No. 2017051070). This Addendum has been prepared to evaluate the potential environmental impacts of revising the Desert Land Ventures Specific Plan (“DLVSP,” now titled DHS Varner Road Specific Plan), Tentative Parcel Map (TPM) 39143, General Plan Amendment (GPA), and Design Review for the development of approximately 1.16 million square feet of distribution warehouse use on a 123± acre site, referred to herein as the “Project.” In accordance with the California Environmental Quality Act (CEQA), this Addendum analyzes the proposed Project and demonstrates that all potential environmental impacts associated with the Project at buildout would be within the envelope of impacts already evaluated in the approved EIR, herein referred to as “2018 EIR.”
In this document, Section I provides the detailed description of the City of Desert Hot Spring’s planning procedures and environmental review process under the California Environmental Quality Act (CEQA). Section 2 describes the proposed Project. Section 3 describes the potential environmental impacts of the proposed Project in the context of the 2018 EIR.

1.2. PROJECT LOCATION AND EXISTING CONDITIONS
The Project site consists of 123± acres of vacant, undeveloped land generally located north of the Interstate 10 Freeway (I-10) and approximately 2,800 feet west of the intersection of Palm Drive and Varner Road in the City of Desert Hot Springs, Riverside County, California. The site is bounded by I-10 to the south and west, Mission Creek to the west, the Willow Hole Conservation Area created as part of the Coachella Valley Multiple Species Habitat Conservation Plan Item Number: 1.

2 (CVMSHCP) to the north, and undeveloped desert land to the east. The site is located within the boundaries of the DLVSP and is currently surrounded by vacant lands except for a residential structure near the southeastern end of the site. The Project site is generally located in Section 24, Township 3 South, Range 4 East, San Bernardino Baseline and Meridian and consists of two Assessor’s Parcels 669-150-001 and -02. Regional location and project vicinity maps are provided in Exhibits 1 through 3.

On-site vegetation consists mainly of Sonoran Creosote Brush Scrub in areas not disturbed by existing dirt roads. Varner Road bisects the project site, as the road extends west from Palm Drive to its existing terminus near Mission Creek, creating the property’s north (approximately 37.3 acres) and south (approximately 86.1 acres) parcels. Within the property’s southern parcel, two existing 30-inch diameter gas transmission main lines traverse the site in an east-west alignment as well as existing power lines and poles along Varner Road (115 kV) and I-10 (33 kV and 12 kV) frontages. The property’s northern parcel is located completely within the Willow Hole Conservation Area of the CVMSHCP. A small portion of the property’s southern parcel at its westerly tip is also located within the Willow Hole Conservation Area. Combined, approximately

40.3 acres of the project site is located within the Willow Hole Conservation Area.

As currently mapped by the Federal Emergency Management Agency (FEMA), the entire project site is located within the 100-year flood plain with no base flood elevations determined (Zone A, Map No.: 06065C0895G), receiving flows from the Mission Creek and Big Morongo Wash watersheds.

1.3. BACKGROUND
This Addendum was prepared to analyze potential impacts of the proposed Project as compared to those previously identified in the Desert Land Ventures EIR. In 2018, the City circulated and certified the Desert Land Ventures EIR for a General Plan Amendment (GPA 01-16), Zoning Map Amendment (ZMA 01-16), Desert Land Ventures Specific Plan (SPA 01-16), and Vesting Tentative Tract Map (VTTM 37185) (referred to herein as DLVSP).

The approved DLVSP project consisted of 123.4 acres north and south of Varner Road and was divided into two planning areas (Exhibit 4, DLVSP Land Use Plan). Planning Area 1 consisted of the southern/southeastern 62.9 acres and Planning Area 2 consisted of the northern/northwestern 38.7 acres. The remaining acreage (21.8 acres) would be set aside for development of the backbone infrastructure system including public roads and water, wastewater, and drainage infrastructure that would serve the project site. The project site would be accessed via Varner Road and West Drive, which required improvements to Varner Road that extended approximately 0.5 miles east from the project site to Palm Drive. The DLVSP Mobility Plan also called for a ten-foot wide, parkway-separated multipurpose trail along the south side of Varner Road through the project site.

Planning Area 1 comprised the Mixed-Use land use district and would accommodate a mix of industrial and commercial uses and up to 150 hotel rooms/keys. Industrial uses would include, but were not limited to marijuana facilities (cultivation, processing, manufacturing, testing and Item Number: 1.

3 distribution), warehousing and distribution, light manufacturing facilities, and mixed-use office/industrial. Commercial uses could include a variety of retail trade and services, including but not limited to accessory retail uses, restaurants, retail stores, bed and breakfast establishments, motels or hotels, medical services and offices, marijuana dispensaries, and research and development facilities. The DLVSP allowed ±1.5 million square feet of Mixed Use (Industrial) development, ±359,000 square feet of Mixed Use (Commercial) development and 150 hotel rooms. The 2018 project was cannabis-centric, and was analyzed as such, including substantial cultivation square footage.

Planning Area 2 of the DLVSP includes the preservation of 38.7 acres to be dedicated for open space conservation as part of the CVMSHCP’s Willow Hole Conservation Area, of which 35.6 acres is located at the northern portion of the project site and 3.1 acres is located at the northwestern end of the project site. Planning Area 2 would remain largely undeveloped desert land and habitat, with the exception of approximately 3.9 acres (approximately 10 percent of the conservation area) on the north side of Varner Road that would be set aside for development of water/wastewater facilities and large-scale energy facilities, including wind energy conversion systems, solar fields and/or an electrical substation, needed to supply a portion of the energy/electrical needs for the development and operation of the DLVSP.

Table 1
2018 DLVSP Land Use Development Summary
Planning Area Land Use Acres
(Gross)
Max. Gross
Square Feet
Max. Hotel
Room/Keys
1 Mixed Use (Industrial) 64.9 1,538,757 150 Mixed Use (Commercial) 359,042 2 Open Space/ Conservation 38.7 -- --
Backbone Infrastructure 19.8 -- --
Total 2018 DLVSP 123.4 1,897,799 150
Source: Table 1-1 Land Use Development Summary, DLVSP DEIR, page 1-2.

Utilities
The project site and surrounding area consists of undeveloped desert land, and no wastewater or water infrastructure or systems existed on or in the vicinity of the project site. Ultimate wastewater service to the project site would be provided from the Mission Springs Water District (MSWD) Regional Wastewater Treatment Plant, generally located at the northwest corner of Little Morongo Road and 20th Avenue. Connection to the Regional Wastewater Treatment Plant would be provided via a proposed 8-inch force-main sewer pipeline extending from the approximately 1.0-acre proposed wastewater facility site located in the DLVSP project’s southeast corner. The wastewater facility site would provide a sewer lift station to pump wastewater from the project site to the MSWD Regional Wastewater Treatment Plant. There were two potential alignment options to connect the project site to MSWD’s Regional Wastewater Treatment Plant. The preferred option (Option A) was to connect from the DLVSP project’s wastewater facility site north in West Drive, west in Varner Road, north from Varner Road through the Willow Hole conservation area within a public utility easement, then west Item Number: 1.

4 within the 20th Avenue right-of-way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. The second option (Option B) was to connect from the proposed project’s wastewater facility site north in West Drive, east in Varner Road right-of-way, north in Palm Drive right-of-way, and then west in 20th Avenue right-of-way, to the point of connection near the intersection of Little Morongo Road and 20th Avenue. Other onsite sewer facilities would include 8-inch sewer pipelines, within the internal roadway system, connecting the development areas to an onsite wastewater facility site and sewer lift station.

Water service by MSWD would be provided via a 24-inch proposed water pipeline extending from the project site to the existing MSWD 24-inch water main line located at the intersection of Little Morongo Road and 20th Avenue. There were two potential alignment options to connect the project site to MSWD’s existing water facilities. The preferred option (Option A) was to connect from the northwest corner of the project site north from Varner Road through the Willow Hole conservation area within a public utility easement, then west within 20th Avenue right of way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. The second option (Option B) was to connect from the project site east in the Varner Road right-ofway, north in the Palm Drive right-of-way and then west in the 20th Avenue right-of-way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. Onsite water facilities would include a 24-inch water pipeline in Varner Road and 18-inch water mains branching off into the proposed project’s internal roadway system to serve the development areas.

Dry utilities that would serve the project site include: electricity (Southern California Edison [SCE]), natural gas (Southern California Gas Company), telecommunications facilities (Frontier Communications), cable service (Charter Communications), and solid waste (Desert Valley Disposal). Future development of the project site would include upgrading existing SCE electrical lines and facilities as well as providing new underground distribution lines along the proposed project’s internal roadways, and the development of all other dry utilities within the project site.

Other Applications
At the time the DLVSP was prepared, the Specific Plan Area consisted of two land use designations—Light Industrial (LI) and Rural Development (RD), and two land use/zoning districts—Light Industrial (LI) and Rural Development (RD). A General Plan Amendment (GPA 01- 16) and Zoning Map Amendment (ZMA 01-16) were initiated concurrent with DLVSP to ensure consistency between the DSVSP and the Desert Hot Springs General Plan and City’s Zoning Ordinance. Specifically, the GPA entailed a change in land use designations from RD and LI (County designations) to Specific Plan 01-16 (Desert Land Ventures Specific Plan) and Light Industrial (I-L), General Commercial (C-G), and Private Open Space (OS/PV) in order to allow for the more intense development envisioned and allowed by the DLVSP. The GPA also required an update to the General Plan Land Use Designation Map. The ZMA entailed a change in land use/zoning districts from RD and LI to Specific Plan 01-16. The update to the General Plan Land Use Designation Map was reflected in the City’s update of the map, which occurred concurrently with the Desert Hot Springs General Plan Update that was adopted by the City in May of 2020.

The Zoning Amendment was approved by the Desert Hot Springs City Council on April 17, 2018, under Ordinance No. 666.

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5 A Vesting Tentative Tract Map (VTTM 37185) was also proposed for condominium purposes to subdivide the Specific Plan Area, creating lots (and the ability to further subdivide the property with air space condominiums) for the development and open space areas proposed at the time.

The VTTM was also needed to establish the preliminary design for the required backbone infrastructure and grading to serve development that would be accommodated under the DLVSP. 2018 EIR Findings
The 2018 EIR concluded that the project’s impacts could be mitigated, with the exception of air emissions and greenhouse gas (GHG) emissions. All other CEQA issue areas resulted in less than significant impacts, with or without mitigation. The City certified the EIR and adopted Findings and a Statement of Overriding Considerations for those impacts which could not be mitigated.

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10 1.4. PURPOSE OF AN EIR ADDENDUM
In accordance with CEQA Guidelines Section 15164, a Lead Agency is required to prepare an EIR Addendum to a previously certified EIR if some changes or additions to a project are necessary, but the proposed project modifications do not require preparation of a subsequent EIR, as provided in Guidelines Section 15162. In addition, the proposed modifications cannot result in new or substantially more significant environmental impacts compared with the impacts disclosed in the previously certified 2018 EIR.

CEQA Guidelines Section 15162 states that a subsequent EIR would be required for a project if any of the following conditions exist:

1. Substantial changes to the project require major revisions to the previously certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects.

2. Substantial changes occur with respect to the circumstances under which the project is undertaken that require major revisions to the previously certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or

3. The availability of new information of substantial importance, which was not known or could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified, shows that the project will have one or more significant effects not discussed in the previous EIR, significant effects previously examined will be substantially more severe than shown in the previous EIR, or mitigation measures or alternatives that were previously found not to be feasible or that are considerably different from those analyzed in the previously certified EIR would substantially reduce one or more significant effects on the environment, but the project proponent declines to adopt the mitigation measure or alternative.

This Addendum was prepared to analyze potential impacts of the currently proposed DHS Varner Road Specific Plan and Project amendments and associated applications as compared to those previously identified in the 2018 Desert Land Ventures Project EIR.

Based on the evaluation of information provided in this EIR Addendum, no new significant impacts would occur as a result of the proposed Project, nor would there be any substantial increase in the severity of any previously identified adverse environmental impacts. Therefore, none of the conditions described in Section 15162 of the CEQA Guidelines has occurred. For this reason, an EIR addendum is the appropriate document to comply with CEQA requirements for the proposed Project.

Item Number: 1.

11 2. PROPOSED PROJECT
The Design Review application for the Project proposes the development of approximately ±1.16 million square feet of distribution warehouse on ±123 acres of currently vacant, undeveloped land generally located north of the Interstate 10 Freeway and approximately 2,800 feet west of the intersection of Palm Drive and Varner Road in the City of Desert Hot Springs, Riverside County, California. The Project includes a Specific Plan Amendment (SP 24-2) to the Desert Land Ventures Specific Plan to modify the Specific Plan to allow up to 1.5 million square feet of warehouse space and adjust development standards and guidelines in support of this change; a Tentative Parcel Map 39143 (TPM 25-1) to subdivide the site into four parcels; a General Plan Amendment (GPA 24-1) to remove the segment of Mihalyo Road from Palm Drive to Varner Road from the Mobility and Infrastructure Element’s Roadways Plan; and a Design Review (DR 24-4) of the warehouse building site plan, elevations and landscaping plans.

The amended Specific Plan, now titled DHS Varner Road Specific Plan (referred to herein as “Specific Plan”) encompasses the same 123.4 acres and would allow up to 1.5 million square feet of industrial warehouse space and supports the proposed development of the ±1.16 million square foot warehouse building proposed in the Design Review application, and associated grading, access drives, parking areas, infrastructure improvements, landscaping, trails, and open space areas.

Specific Plan Amendments
The purpose of the proposed DLVSP amendments is to revise the land use plan to adjust the planning area boundaries to allow for a use (or uses) that would not have been previously fully permitted under the currently approved DLVSP. Other Specific Plan amendments include updates to the land use principles, goals and objectives; updates to the development standards and design guidelines; and updates to the mobility and infrastructure and utility plans. Updates to the infrastructure and utility plans consider major infrastructure improvements to the area that would serve both the development accommodated by the Specific Plan and future development of adjacent parcels.

The amended Specific Plan area is divided into three planning areas, as described below and shown in Exhibit 5, Specific Plan Land Use Plan. The Specific Plan boundary comprises the entire 123.4-acre site: 83.3 acres for Planning Area 1A, 11.6 acres for Planning Area 1B, and 28.5 acres for Planning Area 2. The planning areas provide a framework that defines the development potential, land uses, and built form applicable to each planning area. As shown in the table below, the Specific Plan (specifically, Planning Area 1) could ultimately support up to 1.5 million square feet of industrial uses.

Item Number: 1.

12 Table 2
DHS Varner Road Specific Plan
Land Use Development Summary
Planning Area Land Use Acres
(Gross)
Max. Gross Square
Feet
1A Industrial 83.3 1,500,000
1B Stormwater Control 11.6 ---
2 Open Space/ Conservation 28.5 ---
Total 123.4 1,500,000
Source: Table 3-1 Land Use Development Summary, DHS Varner Road Specific Plan.

Overall, the maximum buildout permitted under the Specific Plan has been reduced to 1.5 million square feet of industrial use from the previously allowed ±1.5 million square feet of Mixed Use (Industrial) development, ±359,000 square feet of Mixed Use (Commercial) development and 150 hotel rooms.

Proposed Project Design Review
The Project’s Design Review application proposes a 1,160,989 square foot (SF) distribution warehouse building to include 1,132,189 SF in warehouse space, 28,800 SF in office space, 661 standard auto parking spaces, 721 trailer parking spaces, landscaping, open space, roadway improvements and drainage facilities (Exhibit 6, Project Site Plan, and 7, Project Elevations). The single building would not exceed 50 feet in height and includes a 14,400 SF mezzanine for use as office space. The building will be equipped with 120 dock doors to facilitate the efficient loading and unloading of goods, of which 109 docks are located on the north side of the building and 111 docks are located on the south site of the building. The trailer stalls would be utilized for temporary parking of semi-truck trailers between distribution trips. Landscaping is proposed along the perimeter of the site on all sides, as well as in the vehicular parking areas.

Approximately 14 percent of the site will be landscaped, which is in compliance with the 10 percent landscaping requirement contained in the Specific Plan.

Various roadway classifications and improvements are proposed to serve the project site, with several improvements occurring offsite but adjacent to the Specific Plan Area. Primary vehicular access to the project site from I-10 and Palm Drive will continue to be via Varner Road. The portion of Varner Road that traverses the Specific Plan area will be improved to Secondary I (Modified) road widths and improvements, including roadway paving, a raised landscape median, curb and gutter, landscaping, a 5-foot sidewalk, an 8-foot bike lane, and a 10-foot multipurpose trail. Varner Road will be constructed with four travel lanes (two lanes in each direction) and extend 0.5 miles east (offsite) to connect to Palm Drive. The dedicated right-of-way for Varner Road will accommodate a 92-foot-wide ultimate roadway section. A 10-foot wide, multipurpose trail will be provided along the north side of Varner Road, and a 5-foot wide sidewalk will be provided on the south side. The multipurpose trail will be available for use by cyclists and pedestrians.

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13 West Drive, which forms the eastern boundary of the Specific Plan area, is classified as a Local Collector and will be improved to its ultimate width of 60 feet and include roadway paving, as well as landscaping and a 6-foot wide pedestrian sidewalk on the west side only. With the exception of curb and gutter improvements, no landscaping, sidewalk or other hardscape improvements are proposed for the east side of this road under the Specific Plan. The curb, gutter and sidewalk on the east side of West Drive would be completed by development when it occurs at this location.

The Project will include four points of access:
• One 40 foot wide, truck-accessible driveway and one 26 foot wide vehicle-only driveway on Varner Road, in the northwest quadrant of the site;
• Two 40 foot wide driveways, one truck-accessible and one vehicle-only, on West Drive, in the southeast quadrant of the site.

Overall, buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space and hotel rooms previously analyzed in the 2018 EIR.

Utilities
Water: The Specific Plan is within the northwestern edge of the Coachella Valley Water District’s (CVWD) service area, and water service will be provided by CVWD. However, CVWD does not have an existing water system in the vicinity of the Specific Plan area to serve the site. The closest CVWD water systems are the Date Palm System and the Sky Valley System (Lower ID 8), which are approximately 4 and 3.5 miles away from the Specific Plan Area, respectively. A connection to the Desert Hot Springs Pressure Zone will be required to provide water service to the site; this will require the construction of an 8-inch water line within Varner Road from the eastern end of the site to Palm Drive, which will connect to an 8-inch water line to be installed within Palm Drive that will travel north where it will connect to an existing 18-inch water line just south of the Dillon Road/Palm Drive intersection. From the Dillon Road/Palm Drive intersection, there is an existing 8-inch pipeline that travels west along Dillon Road and connects to a 24-inch pipeline at the intersection of Dillon Road and Atlantic Avenue (see Exhibit 8, Conceptual Water Facilities and Infrastructure Plan). CVWD is requiring the upsizing of the 8-inch pipeline in Dillon Road from 8 inches to 24 inches. Compared to the DLVSP water extension Option B, with the longest extension option of approximately 3 miles, the proposed offsite water line extension would be approximately 4 miles, an increase of one mile compared to what was previously analyzed in the 2018 EIR. Unlike the EIR options, however, the extension would occur entirely in disturbed existing roadways.

Onsite water facilities include an 8-inch water line in Varner Road (the portion of the road that lies within the Specific Plan area boundary) and an 18-inch water main line branching off into the Specific Plan area to serve the proposed development. Buildout also requires the provision of an 8-inch water line along West Drive, which forms the eastern boundary of the project site.

Item Number: 1.

14 Sanitary Sewer: As with water infrastructure, there is no wastewater infrastructure in the immediate area to provide wastewater service to the Project site. The Project lies within CVWD’s service area and is also 0.5 miles southeast of the Mission Springs Water District (MSWD) service area’s southern boundary. MSWD recently completed the construction of a Regional Wastewater Treatment Plant (RWTP), which is located near the Little Morongo Road/20th Avenue intersection, approximately 1.0-mile northwest of the project area. Due to the site’s proximity to the MSWD RWTP, wastewater service to the Project will be provided by MSWD via an interagency agreement with CVWD.

Connection to the RWTP will be provided via a proposed 8-inch force-main sewer pipeline extending from the approximate 1.0-acre wastewater facility site proposed in the Specific Plan area’s southeastern corner. The proposed onsite wastewater facility site will provide a sewer lift station to pump wastewater from the Specific Plan area to the RWTP. There are two potential alignment options to connect the Specific Plan area to MSWD’s RWTP. The preferred option (Option A) is to connect from the Specific Plan Area’s wastewater facility site to the north within West Drive, to the west within Varner Road, then to the north from Varner Road through the Willow Hole Conservation Area through private property and within a public utility easement, and eventually westerly within 20th Avenue right-of-way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. The second option (Option B) is to connect from the Specific Plan Area’s wastewater facility site to the north within West Drive, to the east within Varner Road right-of-way, then to the north within Palm Drive right-of-way, and eventually westerly within 20th Avenue right-of-way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. Other onsite sewer facilities will include 8-inch sewer pipelines within the internal roadway system, connecting the Specific Plan’s development areas to an onsite wastewater facility site and sewer lift station (see Exhibit 9, Conceptual Wastewater Facilities and Infrastructure Plan). The proposed sewer alignment routes are the same routes analyzed in the DLVSP EIR.

Dry Utilities: The utilities and service systems that would serve the Specific Plan Area include electricity (Southern California Edison [SCE]), natural gas (Southern California Gas Company), telecommunications facilities (telephone lines [Frontier Communications]), cable service (Charter Communications), and solid waste (Desert Valley Disposal). Development of the project site would include upgrading existing SCE electrical lines and facilities as well as providing new underground distribution lines along the proposed Project’s internal roadways, and the development of all other dry utilities within the project site. No change to dry utility infrastructure is proposed when compared to what was analyzed in the EIR.

Additionally, due to the location of the gas utility easement and its 30-inch gas transmission lines and in accordance with the Southern California Gas Company’s “General Design Parameters for Development Near Gas Transmission Facilities”, permanent buildings and structures are not permitted in any portion of the easement. The Specific Plan provides solutions to ensure that the easement and underground gas transmission lines are maintained and not impacted, while at the same time allowing for some hardscape and landscape improvements to occur within the easement.

Item Number: 1.

15 Drainage
The Project would provide three on-site stormwater infiltration basins that will comply with the Stormwater Management and Discharge Controls stipulated in Chapter 13.08 of the Desert Hot Springs Municipal Code. The basin capacities are sized to contain the 100-year, 24-hour duration storm event and therefore meet the City’s requirements on Stormwater Management and Discharge Controls and minimize the discharge and transport of pollutants associated with the new developments (Exhibit 10, Stormwater Infiltration Basins).

In addition, the on-site basins have been sized to carry regional flows which currently impact the property. These flows will also require the construction of a channel and retention basin on the northerly parcel, on the north side of Varner Road. Water will be channeled from this retention basin into on-site retention basins, and through the southern parcel, exiting at the southeastern corner.

Other Applications
The TPM is to divide the site into four parcels; Parcel 1 would be for industrial use (83.3 AC), Parcels 2 and 3 for Willow Hole Conservation (28.5 AC) and Parcel 4 for flood control (11.6 AC) (Exhibit 11, TPM 39143). The GPA is to amend the ‘Mobility and Infrastructure Element’ and ‘Figure MI-7 Roadways Plan’ to eliminate a segment of Mihalyo Road as a collector road between Palm Drive and Varner Road as part of the proposed Project.

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23 3. IMPACT ANALYSIS
The Desert Land Ventures Specific Plan EIR is referenced as the “2018 EIR” below. In accordance with CEQA Guidelines §15162, the following analysis addresses each of the environmental issues analyzed in the approved 2018 EIR as compared to the potential changes in environmental impacts due to the proposed Project.

3.1. AESTHETICS
Summary of Findings in the 2018 EIR (Section 4.1, page 4.1-1 et.seq.) Existing Conditions
The 2018 EIR described the City’s existing visual character and scenic resources. The project site is located in the northwestern portion of the Coachella Valley and offers views of the San Gorgonio Mountains to the west, the Little San Bernardino Mountains to the north and east, the San Jacinto Mountains to the southwest and Santa Rosa Mountains to the south. The site consists of undeveloped desert landscape featuring shrubs, scattered boulders, remnants of a rock house with one standing column, and discarded refuse along Varner Road. The site was characterized by mostly flat topography with a slight southeast slope and dominated by Sonoran creosote brush scrub in undisturbed areas, and experiences strong winds due to its location downwind from the San Gorgonio Pass. The surrounding area was largely undeveloped, except for a single occupied residence near the southeastern boundary and two gas stations with minimarts—the Arco AM/PM and a Chevron station with a restaurant—located southeast of the site on Palm Drive near the I-10 intersection. Mission Creek lies 320 feet west of the northwestern boundary and Garnet Hill sits approximately 1,000 feet southwest across I-10.

Impacts to Scenic Vistas
Under the DLVSP, commercial development within Phase 1 would allow for a building height maximum of 35 feet (2 stories), hotel development to allow for a building height maximum of 75 feet (7 stories), and Industrial development to allow for a building height maximum of 50 feet (2 stories). Planning Area 2 would largely remain in its existing condition as undeveloped desert land and habitat within the Willow Hole Conservation Area, with the exception of permitted large-scale sustainable energy facilities.

The 2018 EIR found that due to fast moving vehicles on the freeway, the DLVSP would not significantly impact the views of the San Bernardino Mountains north of the project site. Also, the project is not in close proximity to any mountains in the region and the project is proposed in an area with minimal development nearby. Therefore, the 2018 EIR determined that development of the site under the DLVSP would not be a dominant feature in the overall local landscape, and that the project would maintain consistency with Goal 2 of the City’s General Plan (Open Space and Conservation Goals) in preserving scenic resources. Impacts to scenic vistas were found to be less than significant.

Item Number: 1.

24 Impacts on Scenic Resources
The 2018 EIR determined there are no State scenic highways that run through or near the DLVSP’s project boundary and that the nearest officially designated State scenic highway is State Highway 62 located approximately five miles northwest of the project site. Furthermore, the project site would not be visible from Highway 62 and no impacts to the State Scenic Highway were anticipated. The 2018 EIR determined the DLVSP would not cause a substantial impact to scenic resources.

Impacts to Visual Character or Quality of the Site
The 2018 EIR determined buildout of the site would create a noticeable change to the environment with a new development surrounded primarily by undeveloped, open space desert.

The 2018 EIR noted existing visual impacts from the above-ground power lines running along the south side of the project site. The DLVSP provides Site Design Guidelines and Architectural Design Guidelines and Standards that are pertinent to distant views, but also includes Outdoor Common Area Design, Public Art Design and Landscape Design guidelines that are pertinent to up close onsite views of the project and relevant to the site’s visual onsite character. The 2018 EIR determined these guidelines would provide City staff, the Planning Director, Planning Commission and City Council with the necessary review guidelines for consistency with City requirements to assure aesthetically acceptable industrial developments. Impacts were found to be less than significant through adherence to these regulatory requirements (see Regulatory Requirements, below).

Impacts from Light and Glare
The 2018 EIR found that build out of the DLVSP would result in increased levels of illumination and glare, as previously undeveloped land is developed. However, the 2018 EIR determined impacts resulting from light and glare would be less than significant with compliance with Section

17.40.170 of the Zoning Ordinance, implemented through Regulatory Requirement RR-2, and adoption of the DLVSP’s outdoor lighting considerations and guidelines. These standard requirements would maintain consistency with Policy 10 and Program 10A of the City’s General Plan (Community Design Goal, Policies and Programs) in preserving the City’s night skies and in complying with lighting standards contained in the Zoning Ordinance. The 2018 EIR concluded that the new sources of light and glare associated with project development would not have a significant impact associated with light and glare.

Cumulative Impacts
The 2018 EIR concluded that buildout of the DLVSP would not contribute to cumulative impacts associated with scenic resources, visual character or quality of the site, or light and glare because impacts were found to be less than significant with adherence to General Plan policies, the DLVSP design guidelines and to the City’s Zoning Ordinance. In summary, the 2018 EIR determined buildout of the DLVSP would not result in cumulatively significant impacts to aesthetics.

Mitigation Measures
The 2018 EIR determined mitigation measures were not required for the DLVSP. The 2018 EIR cited two regulatory requirements that ensure impacts to aesthetic resources remain less than significant (Page 4.1-8):

Item Number: 1.

25 RR-1 City Staff shall incorporate the DLVSP’s Design Guidelines and Standards (Section 6) and structural height provisions from City Zoning Ordinance 17.40.160, Height determination (structures,) in the review process for all building structures proposed within the DLVSP.

RR-2 During the review process for proposed development within the project site, City Staff shall ensure that project applicant(s) incorporate the following lighting standards into their design: the City’s Outdoor Lighting Standards (Section 17.40.170, Outdoor Lighting Standards), Table 17.40.170 of the Zoning Ordinance (Requirements for Shielding and Filtering of Outdoor Lighting) and shall incorporate guidelines from Section 6.5 of the Specific Plan (Lighting Design).

Analysis of the Proposed Project
The site’s existing conditions and surrounding environment have remained the same compared to 2018 conditions. The project site is not in close proximity to any mountains in the region and the Project is proposed in an area with minimal development nearby. The Project proposes revisions to the DLVSP that would limit development intensity and type to 1.5 million square feet of industrial uses, maximum building heights of 50 feet/2 stories, and proposes the development of a 1.16 million square foot distribution warehouse facility.

Amendments to the Specific Plan are limited to adjusting the planning area boundaries to allow for a use (or uses) that would not have been previously fully permitted under the prior planning area and boundaries. Other Specific Plan amendments include updates to the land use principles, goals and objectives; updates to the development standards and design guidelines; and updates to the mobility, infrastructure and utility plans. The proposed maximum building height for industrial uses is consistent with those previously analyzed in the 2018 EIR, which assumed 50 feet (2 stories); however, the DLVSP allowed up to 75 feet (7 stories) for hotel uses. Therefore, the proposed Project would reduce the maximum permitted building heights, further reducing previously disclosed impacts to scenic vistas which were found to be less than significant.

Furthermore, the Project has been designed consistent with the development standards set forth in the DLVSP, including a maximum industrial building height of 50 feet, 10-foot street setbacks, 75 percent maximum building coverage, and minimum 10 percent required landscaping. Impacts associated with visual character and scenic resources will be less than significant, consistent with the conclusions of the 2018 EIR.

Buildout of the site would create a noticeable change to the environment with a new development surrounded primarily by undeveloped, open space desert. Consistent with findings in the 2018 EIR, Project impacts resulting from light and glare would be less than significant with compliance with Section 17.40.170 of the Zoning Ordinance. The currently proposed Project would also be subject to the regulatory requirements cited above, which were found to be necessary to the control of light and glare on the site. In addition, the proposed Specific Plan provides Site Design Guidelines and Architectural Design Guidelines and Standards that are relevant to the site’s visual onsite character, and would provide City staff, the Planning Director, Planning Commission and City Council with the necessary review guidelines for consistency with City requirements to assure aesthetically acceptable industrial development, resulting in less than significant impacts.

Item Number: 1.

26 Cumulative Impacts
Buildout of the proposed Project would not result in cumulatively significant impacts to aesthetics because impacts associated with scenic resources, visual character, and light and glare would be less than significant with adherence to applicable General Plan policies, Zoning requirements, and design guidelines set forth in the Specific Plan. Cumulative impacts are comparable to those identified in the 2018 EIR, and buildout of the proposed Project would not result in cumulatively significant impacts to aesthetics.

Summary of Impacts
The proposed Project will result in similar development to that anticipated in the Project area, at reduced intensity in all aesthetic aspects analyzed above. it is not expected to result in impacts beyond those identified in the 2018 EIR. Development of the site will adhere to applicable General Plan policies, Zoning requirements, and design guidelines set forth in the Specific Plan.

Impacts associated with visual character would be comparable to what is currently permitted in the area and that was previously analyzed under the 2018 EIR. Project impacts associated with scenic vistas and resources, visual character, and light and glare would not exceed those expected under the DLVSP and thus would be comparable to those identified in the 2018 EIR. Mitigation is not required.

3.2. AGRICULTURE AND FORESTRY RESOURCES
Summary of Findings in the 2018 EIR (Section 4.2, page 4.2-1 et.seq.) Existing Conditions
As described in the 2018 EIR, the entire project site consists of desert land, with shrubs, boulders and rocks scattered throughout the site. Onsite vegetation consists mainly of Sonoran Creosote Brush Shrub in areas not disturbed by roads that traverse the project site. The surrounding area consists of undeveloped desert land. Two gas stations and a fast-food restaurant are located southeast of the project site, on Palm Drive just north of the 1-10/Palm Drive intersection.

The Existing General Plan and Zoning Designations within the 123.4-acre project site were Light Industrial (LI) and Rural Desert (RD), which are representative of Riverside County designations that were adopted by the City as interim designations with City Equivalent Land Uses which are Residential Estate (R-E-10) and Light Industrial (I-L).

Farmland of Statewide Importance
The 2018 EIR determined that the project site is designated as Other Land, which the FMMP defines as land not included in any other mapping category. Therefore, the 2018 EIR determined the DLVSP would not interfere with any existing or proposed Prime Farmland, Unique Farmland, and Farmland of Statewide Importance on, or designated farmland in close proximity of the project site, and the DLVSP would not convert farmland to a non-agricultural use.

Item Number: 1.

27 Williamson Act
The 2018 EIR determined that there were no sites within the project site that were under a Williamson Act Land Conservation Contract, and that there would be no impacts to existing zoning for agricultural use or Williamson Act Land Conservation contracts.

Forest/Timberland Zoning
The 2018 EIR determined the City of Desert Hot Springs has no existing land designated as forest land, timberland, or land zoned for Timberland Production. Therefore, the 2018 EIR found that implementation of the DLVSP would not conflict with existing zoning for, or cause rezoning of, forest land, timberland or land zoned for Timberland Production, resulting in no impact.

Loss of Forest Land
The 2018 EIR determined there are no established forest lands within the City of Desert Hot Springs and implementation of the DLVSP would not result in the loss of forest land or conversion of forest land to non-forest use. Therefore, there would be no impacts.

Conversion of Farmland or Forest Land
The 2018 EIR reiterated that the City does not have any zones pertaining to farmland nor forest land, and that the site was vacant, void of any physical structures, and consisted of desert land, with shrubs, boulders and rocks scattered throughout the site. Therefore, the 2018 EIR determined that any changes in the existing environment which, due to their location or nature, could not result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.

Cumulative Impacts
The 2018 EIR did not provide a cumulative impact discussion for Agriculture and Forestry Resources because it was concluded that no impacts would occur.

Mitigation Measures
No mitigation measures were required.

Analysis of the Proposed Project
The site is currently vacant and on-site vegetation consists mainly of Sonoran Creosote Brush Scrub in areas not disturbed by existing dirt roads. No change to the site has occurred since the completion of the 2018 EIR. The site is designated for industrial and commercial mixed-use development and open space conservation under the existing DLVSP, and agricultural or forestry uses are not permitted in this designation. There are no existing or mapped agricultural or forestry resources within or in proximity to the Project site, and such uses are not proposed as part of the Project. No prime or unique farmland, or farmland of statewide importance exists within the Project site or vicinity. Therefore, the proposed Project would not create any new impacts associated with these resources, consistent with those identified in the 2018 EIR. No impacts to agricultural or forestry resources would occur under the proposed Project.

The proposed Project would not result in or create any new cumulative impacts on agriculture or forestry resources, as no impacts would occur, consistent with the 2018 EIR.

Item Number: 1.

28 3.3. AIR QUALITY
Summary of Findings in the 2018 EIR (Section 4.3, page 4.3-1 et.seq.) Background
As described in the 2018 EIR, the DLVSP is located within the Salton Sea Air Basin (SSAB) and air quality conditions are administered by the South Coast Air Quality Management District (SCAQMD). The region is impacted by significant air pollution levels caused by the transport of pollutants from coastal air basins to the west, primarily ozone, and locally generated particulate matter (PM10). According to the 2018 EIR, the City of Desert Hot Springs has relatively good air quality, however noticeable deterioration of air quality has occurred due to increased development and population growth, traffic, construction activity, and various site disturbances.

Air Quality in Desert Hot Springs is also affected by the wind transporting sand and dust primarily from the west.

The SCAQMD develops rules and regulations, establishes permitting requirements for stationary sources, inspects emission sources, and enforces such measures through educational programs or fines, when necessary. SCAQMD is directly responsible for reducing emissions from stationary, mobile, and indirect sources. It has responded to this requirement by preparing a sequence of Air Quality Management Plans (AQMP). At the time the 2018 EIR was prepared, the approved and active AQMP was the 2016 SCAQMD AQMP.

Criteria air pollutants consist of carbon monoxide (CO), ozone (O3), nitrogen oxides (NOx), sulfur dioxide (SO2), lead (Pb), and particulate matter with a diameter less than 10 microns and 2.5 microns (PM10 and PM2.5, respectively). The project site is within source receptor area (SRA) 30, Coachella Valley. SCAQMD operated two air monitoring stations in SRA 30, one in Indio approximately 21.08 miles southeast of the project site and the other in Palm Springs approximately 3.1 miles southwest of the project site. When the 2018 EIR was prepared, the Coachella Valley portion of the SSAB was designated by the EPA as a non-attainment area for ozone (O3) and suspended particles (PM10). In 2018, the SSAB was in attainment with the ambient air quality standards for carbon monoxide (CO), lead, sulfur dioxide (SO2), nitrogen dioxide (NO2), and particulate matter (PM2.5).

An Air Quality Impact Analysis (2018 EIR Appendix B) was prepared for the 2018 EIR that projected air quality emissions and analyzed impacts using a combination of the South Coast Air Quality Management District (SCAQMD) “CEQA Air Quality Handbook” (1993), the SCAQMD Final Localized Significant Threshold Methodology (2013), and the California Emissions Estimator Model (CalEEMod) Version 2016.3.2.

Consistency with Air Quality Management Plans
The 2018 EIR identified two key indicators of air quality management plan (AQMP) consistency based on the SCAQMD CEQA Handbook:

1. Whether the project would result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.

Item Number: 1.

29 2. Whether the project would exceed the assumption of the AQMP in 2016 or increments based on the year of project build-out.

In order to determine plan consistency, the 2018 EIR analyzed project-specific emissions. The 2018 EIR determined that build out of the DLVSP would result in significant and unavoidable air quality impacts based on the SCAQMD regional thresholds of significance for short-term (construction) emissions of NOx, and for long-term (operational) emissions of NOx and ROG; therefore, the DLVSP would contribute to the exceedance of air pollutant concentration standards and was found to be inconsistent with the AQMP for Criterion 1.

The 2018 EIR determined that the DLVSP and accompanying GPA and ZMA would not result in an inconsistency with the land use designation in the City’s General Plan; therefore, the DLVSP would not exceed the AQMP assumptions for the project site and was found to be consistent with the AQMP for the Criterion 2. However, based on the failure of Criterion 1, the 2018 EIR determined the DLVSP would result in an inconsistency with the SCAQMD AQMP, which was determined to be a significant impact. The 2018 EIR included mitigation measures geared to both construction activities and long term operation, but found that the project’s impacts could not be reduced enough to eliminate the inconsistency with Criterion 1. As a result, the 2018 EIR determined that even after the implementation of all feasible mitigation measures, the project would have significant and unavoidable impacts as it related to the implementation of local and regional plans.

Air Quality Violations
CalEEMod Version 2016.3.2 was used to calculate criteria pollutant emissions from buildout of the DLVSP. At that time, it was the most current and up-to-date model issued by the SCAQMD.

The 2018 EIR determined that build out of the DLVSP would result in significant and unavoidable air quality impacts based on the SCAQMD regional thresholds of significance for short-term (construction) emissions of NOx, and for long-term (operational) emissions of NOx and ROG, as discussed below and shown in Table 3, 2018 EIR: DLVSP Buildout Emissions Summary.

Construction
Per the 2018 EIR, construction activities associated with the DLVSP were anticipated to include:
grading of approximately 88.54 acres; construction of approximately 1,538,757 square feet of light industrial uses (a maximum of 1,154,068 square feet of the industrial use could be for marijuana cultivation), 359,042 square feet of commercial retail uses (commercial use square footage could include a 150 room/key hotel and a maximum of 115,407 square feet of marijuana dispensary retail space), approximately 40.7 acres for a reservoir site, water well site, sanitary sewer treatment plant, solar and Southern California Edison facilities, open space conservation, retention basin, and gas easement, and approximately 17.8 acres of retention basins/drainage swales (within the gross area of lots 1-5); paving of approximately 3.54 acres for parking lots (remainder of acreage within lots 1 through 5) and approximately 17.8 acres of onsite streets; applications of architectural coatings; and off-site improvements. Off-site improvements included approximately 143,000 square feet of roadway improvements on Varner Road (from the eastern boundary of the project site to Palm Drive).

Item Number: 1.

30 To be consistent with the Traffic Impact Analysis prepared for the DLVSP and to analyze a worstcase scenario, the 2018 EIR modeled the DLVSP as one phase beginning no sooner than January 2018, and taking approximately 24 months to complete. Grading was anticipated to include approximately 194,440 cubic yards of import. The 2018 EIR described major regulatory requirements the project must comply with, including SCAQMD rules for the reduction of fugitive dust emissions, implemented through Regulatory Requirement RR-3, or SCAQMD Rules 403 and 403.1, which require the preparation of a Fugitive Dust Control Plan and best management practices (BMPs). In addition, SCAQMD Rule 1113 requires the architectural coatings applied to buildings be limited to an average of 50 grams per liter or less.

The 2018 EIR determined that the unmitigated emissions would exceed the SCAQMD regional emissions thresholds for NOx during grading, building construction, and when the off-site improvements occur during grading of the project site; therefore, mitigation was required. The 2018 EIR concluded that even with incorporation of Mitigation Measure 1 (AQ-1), which limits architectural coatings applied to buildings to 10 grams per liter VOC and paint striping to 100 g/L VOC; and Mitigation Measure 2 (AQ-2), which states that the project proponent would require the construction contractor to use construction equipment that have Tier 4 final engines, level 3 diesel particulate filters (DPF), with oxidation catalyst that impart a 20 percent reduction in emissions; the DLVSP would still exceed the SCAQMD regional emissions thresholds for NOx.

Incorporation of Mitigation Measure AQ-2 would maintain consistency with the City’s General Plan Policy 1 and Program 1B (Air Quality Goals, Policies and Programs) regarding compliance with SCAQMD Rules and Regulations. Therefore, even with mitigation, the 2018 EIR determined a potentially significant regional air quality impact would occur from implementation of the DLVSP.

The 2018 EIR also determined that no significant short-term construction-related TAC impacts would occur as a result of development of the project site because the duration of construction activities would represent a fraction of the 30-year exposure period used as the basis for assessing the significance of carcinogenic risk exposure and, therefore, would not represent a source of sustained DPM emissions. Furthermore, construction-based particulate matter (PM) emissions (including diesel exhaust emissions) did not exceed any local or regional thresholds.

Operation
The 2018 EIR analyzed operations-related criteria air quality emissions created by implementation of the DLVSP using the CalEEMod model with the buildout year at the end of 2019. The vehicle trips associated with the DLVSP were analyzed by inputting the vehicular trips evaluated in the Traffic Impact Analysis (TIA) prepared for the DLVSP. The DLVSP TIA found that the light industrial portion of the project site would create 8,430 automobile round trips, 858 2- axle truck round trips, 418 3-axle truck round trips, and 1,019 4+-axle truck round trips per day.

The DLVSP TIA identified a total of 10,725 daily vehicle trips with a trip generation rate of 6.97 trips per thousand square feet per day for the proposed light industrial use. In addition, a total of 15,588 daily vehicle trips with a trip generation rate of 42.08 trips per thousand square feet per day (includes the PM diverted trip reduction of 34 percent) was determined for the proposed commercial retail use.

Item Number: 1.

31 CalEEMod defaults were used to estimate emissions from landscaping equipment and the VOC content of architectural coatings were mitigated to 10g/L VOC for buildings and 100g/L VOC for traffic striping per SCAQMD Rule 1113. Energy usage included emissions from the generation of electricity and natural gas used onsite, such as solar panels on the rooftops of all non-cannabis cultivation industrial buildings and carport shade structures and a solar field covering up to approximately 3.9 acres within Planning Area 2. These features were expected to generate approximately 10 percent of the electricity required to operate the proposed land uses within the DLVSP. It should be noted that cannabis cultivation results in high energy use, particularly for electricity.

The 2018 EIR results show that DLVSP operations at buildout would exceed SCAQMD regional thresholds for both ROG and NOx. Therefore, a potentially significant regional air quality impact would occur from project operations, and mitigation measures were required to be implemented to reduce ROG and NOx emissions. Mitigation Measures AQ-3 through AQ-11 were provided to reduce operational emissions. However, the 2018 EIR found that with incorporation of mitigation measures, emissions from the operations would still exceed SCAQMD operational thresholds for both ROG and NOx. Therefore, even with the implementation of all feasible mitigation, the 2018 EIR concluded that a potentially significant regional air quality impact would occur due to operations emissions from land uses within the project site.

Table 3
2018 EIR: DLVSP Buildout Emissions Summary
(pounds/day)
Construction Emissions1 ROG NOx CO SO2 PM10 PM2.5
Unmitigated Max. 69.99 186.86 183.43 0.58 38.30 12.61
Mitigated Max. 66.32 115.65 185.93 0.93 35.86 10.33
SCAQMD Thresholds 75 100 550 150 150 55
Exceeds?
(Unmitigated/Mitigated) No/No Yes/Yes No/No No/No No/No No/No Operational Emissions ROG NOx CO SO2 PM10 PM2.5
Unmitigated Max. 107.11 437.61 491.68 1.91 113.37 32.72 Mitigated Max. 90.19 373.25 350.83 1.32 69.01 20.29
SCAQMD Thresholds 75 100 550 150 150 55
Exceeds?
(Unmitigated/Mitigated) Yes/Yes Yes/Yes No/No No/No No/No No/No Source: DLVSP 2018 EIR, Tables 4.3-5 through 4.3-8, pages 4.3-23 through 4.3-27. 1 Maximum daily emissions from on-site or off-site improvements. Refer to DLVSP EIR Tables 4.3-5 and 4.3-6 Unmitigated and Mitigated Regional Construction-Related Pollutant Emissions for detailed listing of project emissions.

Sensitive Receptor Pollutant Exposure
The 2018 EIR analyzed localized emission impacts to sensitive receptors from construction activities, onsite operations, toxic air contaminants, and project-generated vehicular trips.

Item Number: 1.

32 Construction Activities
The 2018 EIR analyzed for potential local air quality impacts created from construction-related fugitive dust and diesel emissions; toxic air contaminants; and from construction-related odor impacts. The local air quality emissions from construction were analyzed using the SCAQMD’s Mass Rate Localized Significant Threshold (LST) Look-up Tables, and the methodology described in Localized Significance Threshold Methodology, prepared by SCAQMD.

The emission thresholds were calculated in the 2018 EIR based on the Coachella Valley SRA 30 and a disturbance of five acres per day. The nearest sensitive receptor was the existing rural residential land use located approximately 120 feet from the project site’s southern boundary; therefore, SCAQMD Look-up Table for [25] meters was used. The 2018 EIR Tables 4.3-10 and 4.3- 11 demonstrate that construction emissions would not exceed LSTs under unmitigated or mitigated conditions, and that impacts would be less than significant.

Onsite Operations
The 2018 EIR analyzed project-related air emissions from onsite sources such as architectural coatings, landscaping equipment, onsite usage of natural gas appliances, as well as operation of vehicles onsite might have the potential to exceed the federal and State air quality standards on the project site and surrounding area. The same LST methodology used to analyze construction emission impacts was used to assess onsite operation-related emission impacts. Per LST methodology, mobile emissions include only onsite sources which equate to approximately 10 percent of the project-related new mobile sources. Mitigation Measures AQ-3 through AQ-11 were also incorporated to reduce regional operations emissions, and those measures would also reduce PM10 and PM2.5 emissions at a local level. The 2018 EIR Table 4.3-12 demonstrated that even with incorporation of mitigation, emissions from the operation of the DLVSP would still exceed SCAQMD local operational screening thresholds for PM10 and PM2.5. Therefore, more detailed dispersion modeling for PM emissions was conducted.

The dispersion modeling prepared for the 2018 EIR was conducted using the SCAQMD’s recommended methodology for estimating 24-hour PM10 concentrations and followed SCAQMD’s AERMOD Modeling Guidance. Per the 2018 DEIR, the project engineer for the DLVSP stated that the commercial uses would have a negligible number of daily trucks as deliveries were anticipated on a weekly, not daily basis. Therefore, the PM10 concentration from onsite mobile truck sources from the light industrial uses was used in the dispersion modeling. At the boundary closest to the nearest sensitive receptor the PM10 concentration from onsite mobile truck sources from the light industrial uses is 0.02 μg/m3 over a 24-hour period. The SCAQMD operational LST threshold for PM10 (and PM2.5) is 2.5 μg/m3. As the PM10 mobile source concentrations did not exceed the SCAQMD operation LST threshold at the interface between the project boundary and the sensitive receptor property line, the PM2.5 mobile source concentrations would also not exceed thresholds.

Toxic Air Contaminants
The CARB recommends not siting distribution centers with more than 100 truck trips per day within 1,000 feet of a sensitive receptor. A single-family detached residential dwelling unit is located approximately 120 feet to the southeastern corner of the project site. Typically, exposure to air toxics from industrial truck trips to a sensitive receptor located within 200 feet would Item Number: 1.

33 require a Health Risk Assessment to be prepared to analyze potential health risks to sensitive receptors. However, because the DLVSP is a Specific Plan, and the exact location and types of industrial uses were not determined at the time, and Mitigation Measure AQ-11 was provided that requires a HRA to be prepared if a distribution center with more than 100 daily truck trips is to be constructed within 1,000 feet from the property line of the existing detached residential unit located southeast of the project site. Additionally, in-lieu of the HRA, warehouse and/or distribution center-type uses would not be allowed in Lots 4 and 5 and the southern-most portions of Lots 2 and 3, which are located closest to existing sensitive receptors. The 2018 DEIR determined that with incorporation of mitigation, the DLVSP would not expose sensitive receptors to significant levels of toxic air contaminants.

Local CO Emission Impacts from Project-Generated Vehicular Trips The 2018 EIR analyzed whether impacts from development of the DLVSP could cause emission levels in excess of the CO standards. A sensitivity analysis is typically conducted to determine the potential for CO “hot spots” at a number of intersections in the general vicinity of the project site. Because of reduced speeds and vehicle queuing, “hot spots” potentially can occur at high traffic volume intersections with a Level of Service E or worse.

The DLVSP TIA estimated that the DLVSP development projects would generate a maximum of 26,313 trips per day. The intersection with the highest traffic volume at the time was located at Palm Drive and Varner Road and had Year 2035 With Project evening peak hour volume of 2,151 vehicles. The 2018 EIR referred to the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan) which showed that an intersection which has a daily traffic volume of approximately 100,000 vehicles per day would not violate the CO standard. Therefore, as both the intersection and average daily traffic volumes fell short of 100,000 vehicles per day, the 2018 EIR determined CO “hot spot” modeling was not required and no significant long-term air quality impact was anticipated on local air quality.

Objectionable Odors
Per the 2018 EIR, potential sources of operational odors generated by implementation of the DLVSP would include plant blossom odors (cannabis facilities) and disposal of miscellaneous commercial refuse. The EIR determined that adherence to standard regulations, including City of Desert Hot Springs’s Municipal Code Chapters 5.50 and 17.180 regarding cultivation activities, and SCAQMD Rule 402 (odor nuisances), would ensure potential objectionable operationalsource odor impacts remained less than significant.

Cumulative Impacts
The 2018 EIR reiterated that the region was out of attainment for ozone and in 2014 was out of attainment for PM10, and that cumulative impacts to air quality would occur from the incremental addition of pollutants from increased traffic from residential, commercial, and industrial development and the use of heavy equipment and trucks associated with construction of projects. In accordance with the SCAQMD methodology, projects that did not exceed the SCAQMD criteria or could be mitigated to less than criteria levels were not significant, and did not add to the overall cumulative impact. However, the 2018 EIR concluded that implementation of the DLVSP would create significant cumulative impacts to air quality because even with mitigation applied, the project would continue to exceed long-term emissions.

Item Number: 1.

34 Mitigation Measures
According to the 2018 EIR, a wide range of mitigation measures could be applied to reduce project-related criteria pollutant emissions at DLVSP build out. The following Mitigation Measures and Regulatory Requirements are from pages 4.3-34 through -36 of the 2018 EIR. As previously stated, the reductions which these mitigation measures offered could not effectively reduce short-term (construction) emissions of NOx, or long-term (operational) emissions of NOx and ROG. The 2018 EIR determined that despite implementation of mitigation measures, significant unavoidable impacts would occur in regard to the DLVSP’s contribution to the exceedance of air pollutant concentration (Criterion 1) and in exceedance of regional construction and operational emissions thresholds.

Construction Measures
All development within the project site must adhere to SCAQMD Rules 403 and 403.1 for the control of fugitive dust during all phases of construction. The project proponents of all development projects within the project site will be required to obtain and prepare a Fugitive Dust Control Plan. A copy of each Plan must be submitted to the City Engineer or his/her designer prior to issuance of grading permits. A copy of each Plan must be available at each project site.

AQ-1 Architectural coatings applied to buildings within the project site are to be limited to 10 grams per liter VOC and traffic paints shall be limited to 100 grams per liter VOC content.

AQ-2 The project proponent shall require that all applicable SCAQMD Rules and Regulations (as detailed in Section 4.3.2) are complied with during construction and the construction contractor use construction equipment that has Tier 4 final engines, level 3 diesel particulate filters (DPF), with oxidation catalyst that have a 20 percent reduction in emissions.

Operational Measures
AQ-3 The project proponent shall require the use of the onsite sustainability design features, including: solar panels on all industrial building rooftops (except cultivation buildings) and carport shade structures and a solar farm and/or wind farm; that will provide at least 10 percent of the electrical energy needs for the project site.

AQ-4 The project proponent shall require that: all faucets, toilets and showers installed in the proposed structures utilize low-flow fixtures that would reduce indoor water demand by 20 percent per CalGreen Standards, water-efficient landscaping practices are employed onsite.

AQ-5 The project proponent shall require recycling programs that reduces waste to landfills by a minimum of 75 percent (per AB 341).

AQ-6 The project proponent shall require that high-efficiency lighting (such as LED lighting that is 34 percent more efficient than fluorescent lighting) be installed onsite.

Item Number: 1.

35 AQ-7 The project proponent shall require that employee vanpool/ride share programs shall be provided for at least 80 percent of onsite employees.

AQ-8 Re-application of architectural coatings to protect buildings will be limited to 10 grams per liter VOC and traffic paints shall be limited to 100 grams per liter VOC content.

AQ-9 The project proponent shall provide sidewalks onsite. Will maintain consistency with the City’s General Plan Policy 3 (Air Quality Goals, Policies and Programs) regarding development of pedestrian-oriented retail centers.

AQ-10 The project proponent shall require that all building structures meet or exceed 2016 Title 24, Part 6 Standards and meet 2016 Green Building Code Standards.

AQ-11 If a distribution center with more than 100 daily truck trips is constructed within the project site within 1,000 feet from the property lines of existing single-family detached residential dwelling units located to the southeast of the project site, then the project proponent will require that the individual applicant proposing development prepare a Health Risk Assessment (HRA) to ensure that the cancer risk to existing sensitive uses does not exceed the SCAQMD MICR TAC threshold of 10 in 1 million. If the SCAQMD MICR TAC threshold of 10 in 1 million is exceeded, then the proposed distribution center shall be redesigned to ensure MICR TAC levels are below the threshold.

Regulatory Requirements
RR-3 All development within the project site must adhere to SCAQMD Rules 403 and 403.1 for the control of fugitive dust during all phases of construction. The project proponents of all development projects within the project site will be required to obtain and prepare a Fugitive Dust Control Plan. A copy of each Plan must be submitted to the City Engineer or his/her designer prior to issuance of grading permits. A copy of each Plan must be available at each project site.

Analysis of the Proposed Project
The 2018 EIR analyzed maximum daily emissions based on buildout of the DLVSP. Similar to the 2018 EIR, the current Project’s air quality analysis considers the entire Project as a whole and the combined impacts associated with both on-site and off-site improvements and operations. The following provides a comparison of the assumptions made in the 2018 EIR versus proposed Project revisions.

An Air Quality and Greenhouse Gas Report (Appendix A) and a Health Risk Assessment (Appendix B) were prepared for the Project by Terra Nova Planning and Research and KW Air Quality and Noise, LLC, respectively.

Item Number: 1.

36 2018 EIR Air Quality Modeling Assumptions
Air pollutant emissions in the 2018 EIR were calculated using CalEEMod Version 2016.3.2. The following summarizes the primary construction, operation and mitigation assumptions applied to CalEEMod in the 2018 EIR analysis:
• Total Site Acreage: 88.57 AC (Offsite utility extensions not included) • General Light Industry: 1,538,757 SF
• Regional Shopping Center: 359,042 SF
• Asphalt Paving: 21.34 AC
• Other Non-Asphalt: 23.67 AC
• 24-month buildout (building, paving and arch coating phases have some overlap) o Grading: 70 days
o Building: 400 days
o Paving: 45 days
o Arch coating: 60 days
• 196,440 CY import
• 25,833 daily trips
• Annual vehicle miles traveled (VMT): 51,273,973 unmitigated; 30,959,64 mitigated with carpool/shuttle program
• Trip Lengths: H-W/C-W: 13.8 miles; H-S/C-C/H-O/C-NW: 6.2 miles • Mitigation Measures:
o Water exposed areas
o Arch coating VOC content lowered to 10 g/L for buildings and 100 g/L for parking area
o Oxidation catalyst on construction equipment with reduction of 20% o Tier 4 final engines on equipment
o Level 3 Diesel Particulate Filters on construction equipment o Assumed approximately 10% of energy demand provided by onsite renewables. 2025 Air Quality Modeling Assumptions
The current proposal is for approximately 1.16 million SF of distribution warehousing; however,

1.5 million SF of distribution warehousing was modeled to assess maximum Specific Plan buildout potential, including off-site roadway improvements and utility extensions. Air pollutant emissions were calculated using CalEEMod Version 2022.1, the current version of the model. The following summarizes the primary construction, operation and mitigation assumptions applied to CalEEMod in our analysis:
• Total Area Disturbed Acreage: 115.68 AC (includes road improvement and off-site utility extensions)
• Industrial Park: 75,000 SF
• Unrefrigerated Warehouse-No Retail: 1,425,000 SF
• Parking Lot: 20 AC (95% asphalt for vehicle and truck parking and internal driveways) • Road Widening: 1.37 miles, 14.11 AC disturbed (95% asphalt for Varner and West Drive) • Road Construction: 5.50 miles, 6.67 AC disturbed (20% asphalt for trenching/roadway repair)
Item Number: 1.

37 • On-Site Construction: 24-months buildout, starting May 2026 to 2028 o Grading: 70 days
o Building Construction: 400 days
o Paving: 45 days
o Arch coating: 60 days
• Off-Site Construction: 4-months buildout, starting August 2026 to December 2026 o Grading & Excavation: 60 days
o Drainage, Utilities, & Sub-grade: 60 days
o Paving: 60 days
• Net Export in Grading Phase: 88,400 CY
• Daily Vehicle Trips: 3,194 daily trips (2,234 passenger vehicle trips, 960 trucks/distribution trips)
• Annual VMT: 19,273,363
• Trip Length: H-W: 13.8 miles (consistent with 2017 Desert Land Venture air quality report); W-O: 6.2 miles for industrial park workers (consistent with 2017 air quality report), and 40 miles for long-haul truck trips.
• Off-Road Vehicle and Equipment Operations (Not accounted for in 2017 Project) o Assumes warehouse would operate 30 forklifts1 and 6 holsters/yard goats2, each piece operating approximately 4 hours per day.
o Assumes 2 fire pumps, average 450 horsepower operating 10 hours per year, including non-emergency testing and maintenance.
o Assumes diesel emergency generator with an average of 2000 horsepower operating a max. of 100 hours per year, including non-emergency testing and maintenance.
• Mitigation Measures (consistent with 2018 Project plus additional measures for DPM reductions)
o Water exposed areas
o Arch coating VOC content lowered to 10 g/L for buildings and 100 g/L for parking area
o Oxidation catalyst on construction equipment with reduction of 20% o Tier 4 final engines of equipment
o Level 3 Diesel Particulate Filters on construction equipment o 10% of operational energy demand produced with on-site solar o All electric yard equipment (forklifts and hostlers)
o Assumes 350 of the 960 truck trips would be from electric trucks, with the remaining 610 trucks being diesel.
1 Forklifts: Based on the SCAQMD White Paper presented above, you can assume 0.02 pallet jacks/forklifts per TSF of building area. 2
Hostlers: 2014 SCAQMD High Cube Warehouse Truck Trip Study White Paper Summary Of Business Survey Results (https://www.aqmd.gov/docs/default-source/ceqa/handbook/high-cube-warehouse-trip-rate-studyfor-air-quality-analysis/business-survey-summary.pdf), the average usage was 3.6 hostlers (yard goats) per million square feet of building area.

Item Number: 1.

38 Table 4
Buildout Emissions Comparison: 2018 EIR and Proposed 2025 Specific Plan Maximum Daily Mitigated Emissions (lbs/day)
Max. Mitigated Construction CO ROG NOx SO2 PM10 PM2.5
2018 EIR 185.93 66.32 115.65 0.93 35.86 10.33
Proposed 2025 SP 217 30.4 83.1 0.35 20.6 6.23
2018/2025 SCAQMD Threshold 550 75 100 150 150 55
Exceeds Threshold? (2018/2025)
(Unmitigated/Mitigated) No/No No/No Yes/No No/No No/No No/No 2018 to 2025 Change: 31.07
Increase

35.92 Decrease

32.55 Decrease

0.58 Decrease

15.26 Decrease

4.1 Decrease
Max. Mitigated Operation CO ROG NOx SO2 PM10 PM2.5
2018 EIR 350.83 90.19 373.25 1.32 69.01 20.29
Proposed 2025 SP 167 47.8 71.2 0.82 42.8 12.5
2018 SCAQMD Threshold1 550 75 100 150 150 55
2025 SCAQMD Threshold 550 55 55 150 150 55
Exceeds Threshold? (2018/2025)
(Unmitigated/Mitigated) No/No Yes/No Yes/Yes No/No No/No No/No 2018 to 2025 Change: 183.83
Decrease

42.39 Decrease
302.05
Decrease

0.5 Decrease

26.21 Decrease

7.79 Decrease
Sources: DLVSP 2018 EIR; DHS Varner Road Specific Plan Air Quality and Greenhouse Gas Report, December 2025 (Appendix A).

1. At the time the 2018 EIR was prepared the SCAQMD significance thresholds for operational ROG and NOx emissions in the Coachella Valley were increased to match the more lenient construction-level thresholds, reflecting efforts to address the region’s air quality challenges. However, the Coachella Valley exceptions to operational thresholds are no longer in place, and the Coachella Valley now adheres to the same operational ROG and NOx thresholds as the rest of the South Coast Air Basin.

Consistency with Air Quality Management Plans
The proposed Project site is located within the Salton Sea Air Basin (SSAB) and will be subject to SCAQMD’s 2022 Air Quality Management Plan (2022 AQMP), the 2003 Coachella Valley PM10 State Implementation Plan (2003 CV PM10 SIP) and the 2020 Coachella Valley Extreme 8-Hour Ozone Area Plan (2020 CV Ozone Plan).

The proposed Project and Specific Plan amendment are consistent with the General Plan land uses and would reduce the land use development intensities compared to the approved DLVSP.

The 2022 AQMP is based in part on the land use plans of local jurisdictions, including the City of Desert Hot Springs General Plan. Therefore, it is expected that the proposed Project will result in emissions consistent with those anticipated in the 2022 AQMP. In addition, projects that are consistent with the projections of population forecasts in the 2024 RTP/SCS are considered consistent with the AQMP. The proposed Project is consistent with the City’s land use designations and would not impact population, as employees of the proposed Project are expected to be residents of the city and region.

The proposed Project would be implemented in accordance with all applicable air quality management plans to ensure impacts to air quality are reduced to the greatest extent possible.

Actions include, but are not limited to, the preparation of a standard dust control management plan in compliance with SCAQMD Rule 403.1.

Item Number: 1.

39 The 2018 EIR previously determined that buildout of the DLVSP would cause significant, unavoidable air quality impacts, exceeding SCAQMD regional thresholds for short-term NOx emissions during construction and long-term NOx and ROG emissions during operation.

Consequently, the DLVSP was found to violate air pollutant standards and conflict with the AQMP. The proposed Project, however, only exceeds operational NOx thresholds, and would reduce the severity of emission impacts for criteria pollutants overall, as shown in Table 4. While Project related emissions still constitute a significant and unavoidable impact due to operational NOx emissions, the proposed Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the Certified 2018 EIR.

Impacts to Sensitive Receptors
The nearest sensitive receptor to the Project site is a single-family residence located immediately south of the industrial parcel and approximately 900 feet from the proposed distribution warehouse. According to the 2018 EIR, Mitigation Measure AQ-11 (2017 DEIR p. 4.3-35):

If a distribution center with more than 100 daily truck trips is constructed within the project site within 1,000 feet from the property lines of existing single-family detached residential dwelling units located to the southeast of the project site, then the project proponent will require that the individual applicant proposing development prepare a Health Risk Assessment (HRA) to ensure that the cancer risk to existing sensitive uses does not exceed the SCAQMD MICR TAC threshold of 10 in 1 million. If the SCAQMD MICR TAC threshold of 10 in 1 million is exceeded, then the proposed distribution center shall be redesigned to ensure MICR TAC levels are below the threshold.

An operational Health Risk Assessment (HRA) was prepared for the Project in October 2025 and is provided as part of Appendix B. The HRA analyzed both cancer risks and non-cancer risks to sensitive populations measured at the sensitive receptor approximately 900 feet south of the proposed warehouse. Without mitigation, the HRA determined that no infants, children or adults, within their age brackets, would be exposed to cancer risks in excess of 10 in a million.

The highest cancer risk corresponds to children 2-16 years (HRA, Table 6), with a maximum risk of 7.67 in one million. However, the HRA determined that the cumulative carcinogenic health risk to an individual born during the opening year of the project and located in the project vicinity for the entire 30-year duration, is a maximum of 15.78 in a million. Therefore, as the maximum incremental cancer risk (MICR) exceeded 10 in a million at the closest sensitive receptor location, mitigation measures are required.

Mitigation measures to reduce the DPM emissions from the project include the use of 350 electric trucks, reducing the total number of diesel trucks down from 960 to 610. Regarding on-site DPM emissions reductions, it is assumed that the warehouse would operate 30 electric forklifts and 6 electric holsters/yard goats. Under mitigated conditions, as required by Mitigation Measure AQ1, the MICR was reduced to a maximum of 6.11 in a million and no longer exceeds the threshold.

Item Number: 1.

40 For non-cancer risks, the criterion for significance is a Hazard Index increase of 1.0 or greater.

Using the maximum DPM concentration from opening year (2028) emissions under unmitigated conditions, the HRA determined that the resulting hazard index is 0.0042. Therefore, the ongoing operations of the proposed Project would result in a less than significant impact due to the non-cancer risk from diesel emissions from the Project.

Cumulative Impacts
Similar to findings in the 2018 EIR, buildout of the proposed Project would exceed the SCAQMD criteria thresholds for long-term operations, even with mitigation, and therefore would result in significant and unavoidable cumulative impacts. The proposed Project would reduce emission impacts when compared to the 2018 project and therefore would not result in any new adverse cumulative impacts or increase the severity of cumulative impacts described in the Certified EIR.

Summary of Impacts
The 2018 EIR quantified maximum daily emissions for buildout of the DLVSP and found impacts from criteria pollutants to be significant and unavoidable, even with mitigation. A project-level air quality and greenhouse gas analysis was prepared for the current Project that found impacts to be significant for operational NOx, but less than significant for ROG during construction and operation. A project-level health risk assessment (HRA) was also prepared and determined that Mitigation Measure AQ-1 is required to reduce the maximum incremental cancer risk (MICR) for the adjacent single-family residence to less than significant levels.

Overall, implementation of the proposed Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the Certified EIR, and would reduce those impacts when compared to the previously analyzed project. However, due to the exceedance in operational ROG, impacts associated with air emissions would remain significant and unavoidable.

Mitigation Measures
AQ-1: To reduce cancer-related health impacts from the Project to the residential dwelling located to the southeast of the project site, it is required that all on-site offroad equipment (forklifts and holsters/yard goats) shall be electric and that 350 of delivery trucks utilizing the project site shall be electric trucks. The project shall install electrical charging infrastructure to accommodate the electric vehicles.

Item Number: 1.

41 3.4. BIOLOGICAL RESOURCES
Summary of Findings in the 2018 EIR (Section 4.4, page 4.4-1 et.seq.) This section of the 2018 EIR is based on the findings of the General Biological Resources Assessment, Jurisdictional Delineation and Land Use Consistency Review for the Vesting Tentative Tract Map No. 37185 and Specific Plan Applications Desert Land Ventures III LLC, prepared by Jericho Systems, Inc., July 2017, and the General Biological Assessment, Jurisdictional Determination and Land Use Consistency Review for the Desert Land Ventures III Off-site Sewer Alignment, prepared by Jericho Systems, Inc., December 2017. These reports are included as Appendix C of the 2018 EIR.

Biological Resources Setting
The project area consists primarily of Sonoran creosote brush scrub. No amphibian species were observed or otherwise detected within the project area and none were expected. The only reptiles observed within the project area were zebra-tailed lizard (Callisaurus draconoides) and desert iguana (Dipsosaurus dorsalis). Other common reptile species expected to occur within the project area included Great Basin whiptail (Aspidoscellis tigris tigris), Mojave shovel-nose snake (Chionactis occipitalis occipitalis), desert banded gecko (Coleonyx variegatus variegatus), California kingsnake (Lampropeltis californiae), long-nosed snake (Rhinocheilus lecontei) and western side-blotched lizard (Uta stansburiana elegans). Avian species observed on the project site included red-tailed hawk (Buteo jamaicensis), Costa’s hummingbird (Calypte costae), Wilson’s warbler (Cardellina pusilla), common raven (Corvus corax), and mourning dove (Zenaida macroura). Identification of mammals within the project area was generally determined by physical evidence rather than direct visual identification due to the fact that many of the mammal species that potentially occur on the study areas are nocturnal and would not have been active during the survey, and no mammal trapping was performed. The only mammal species observed was black-tailed jackrabbit (Lepus californicus). Other common species expected to occur within the project area include coyote (Canis latrans), Merriams’ kangaroo rat (Dipodomys merriami), and desert cottontail (Sylvialgus audubonii).

Five State- and/or federally-listed species have been documented in the project vicinity (within approximately 5 miles):
• Peninsular bighorn sheep (Ovis Canadensis nelsoni)
• Coastal California gnatcatcher (Polioptila californica californica) • Coachella Valley fringe-toed lizard (Uma inornata)
• Least Bell’s vireo (Vireo bellii pusillus)
• Coachella Valley milk-vetch (Astragalus lentiginosus var. coachellae) However, the habitat requirements for Peninsular bighorn sheep, Coastal California gnatcatcher and Least Bell’s vireo were absent from the project area, and no further discussion of these species were warranted in the 2018 EIR.

Item Number: 1.

42 Although not State- or federally-listed as a threatened or endangered species, burrowing owl (BUOW) was considered a State SSC and is a migratory bird protected by the international treaty under the MBTA and by State law under the California Fish and Game Code (CDFG Code 3513 & 3503.5). As described in the 2018 EIR, there was suitable habitat for this species within the project site and BUOW have been documented in the vicinity.

The 2018 EIR provided an analysis of the likelihood for occurrence of all CNDDB sensitive species documented in the Desert Hot Springs, Seven Palms Valley, Palm Springs and Cathedral City quads (2018 EIR Table 4.4-1, CNDDB Documented Sensitive Species).

Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) The DLVSP is within the planning area for the CVMSHCP, which is a joint regional planning effort of the USFWS, the CDFW, the Bureau of Land Management (BLM), the U.S. Forest Service (USFS), and the National Park Service (NPS), as well as Riverside County and most jurisdictions in the Coachella Valley, including the City of Desert Hot Springs. This regional multi-agency conservation plan provides for the long-term conservation of approximately 240,000 acres of open space and 27 plant and animal species in the Coachella Valley. The CVMSHCP is subdivided according to specific resource conservation goals that have been organized according to geographic areas, defined as Conservation Areas, that serve as natural habitat for covered species. Per the CVMSHCP, 90 percent of the land within Conservation Areas is to remain open space and 10 percent may be developed. For each Conservation Area, Conservation Objectives and required measures are articulated for conserving Core Habitat for covered species, Essential Ecological Processes necessary to maintain habitat viability, Biological Corridors and Linkages as needed, and the less common Conserved Natural Communities. According to the 2018 EIR, Planning Area 2 (39.7 acres) of the DLVSP is located within the Willow Hole Conservation Area Under the CVMSHCP, a Take Authorization, except for three of the covered species, is allowed for covered activities in accordance with the federal ESA and the California Natural Community Conservation Planning Act. Covered activities include development permitted or approved by local permittees, which includes new projects approved pursuant to county and city general plans. Take activities are limited within Conservation Areas.

Mitigation for the impacts of development on the covered species and their habitats is through payment of a fee to the applicable individual jurisdiction, in this case the City of Desert Hot Springs, which is in turn used by the Coachella Valley Conservation Commission (CVCC) to minimize and mitigate impacts of the taking and provide for conservation of the covered and non-covered species through the acquisition and maintenance of habitat.

Since all proposed development activities associated with the DLVSP would be considered Covered Activities under the CVMSHCP upon project approval, the 2018 EIR concluded that “take” of species covered under the CVMSHCP during construction and operation of the DLVSP would be authorized with payment of the mitigation fee, implemented through RR-4. Take of covered species within the Willow Hole Conservation Area would also be covered by the mitigation fee.

Item Number: 1.

43 Jurisdictional Delineation
The project site is within the Garnet Hill Hydrologic Sub-Area which comprises a 48,375-acre drainage area within the larger Whitewater River Watershed. The Whitewater River is the major hydrogeomorphic feature within the Whitewater River Watershed. The project site is situated north and outside of the historic Whitewater River floodplain, between Mission Creek to the west and Morongo Wash to the east, which are both tributary to the Whitewater River.

As described in the 2018 EIR, no drainages or other water features were identified within the project site that would meet the definition of Waters of the US by the US Army Corps of Engineers (USACE). No jurisdictional features subject to the Clean Water Act under the jurisdictions of the USACE or Regional Water Quality Control Board (RWQCB), exist within the project site. No wetlands were identified in the study area during the field survey based of the absence of hydrophytic vegetation, hydric soil indicators and/or wetland hydrology. The project site is situated on flat to gently-sloped terrain consisting of Larrea tridentata Shrubland Alliance and there are no drainages or other water features that have a definable bed and bank or associated riparian vegetation that would be subject to the Fish and Game Code (FGC) under the jurisdiction of the CDFW.

The 2018 EIR did, however, determine there were three drainage features that traverse 20th Avenue, the northerly portion of the water and sewer line alignment, that would meet the USACE definition of Waters of the US and that would be subject to the Fish and Game Code (FGC) under the jurisdiction of the CDFW.

Impacts to Special Status Species
According to the 2018 EIR, there were no State- and/or federally-listed threatened or endangered species, or other sensitive species observed onsite during the reconnaissance-level field survey.

However, there was some habitat within the project site and along the water and sewer line alignment, that may be suitable for several sensitive species.

Plants
Coachella Valley milk-vetch (Astragalus coachellae)
The Coachella Valley milk-vetch is federally-listed endangered species. The CVMSHCP has modeled suitable Coachella Valley milk-vetch habitat within the larger CVMSHCP area including within the vicinity of the project site, and the project site is completely outside any areas of modeled Coachella Valley milk-vetch habitat. Per the USFWS, Coachella Valley milk-vetch Critical Habitat overlay, the project site is not within any USFWS designated Coachella Valley milk-vetch Critical Habitat.

According to the literature review provided in the Biological Resources Assessment for the project site, the nearest documented Coachella Valley milk-vetch occurrence to the northeast is within approximately 0.3 miles within the proposed Option B alignment of the water and sewer line along 20th Avenue. Mitigation Measure BIO-1 and Regulatory Requirement RR-4 in the 2018 EIR would reduce potential impacts to the Coachella Valley milk-vetch to less than significant levels.

Item Number: 1.

44 Other Sensitive Botanical Species
The 2018 EIR identified nine other sensitive plant species as having a low to moderate potential to occur within the project site:
• chaparral sand-verbena (Abronia villosa var. aurita)
• pygmy lotus (Acmispon haydonii)
• singlewhorl burrobrush (Ambrosia monogyra)
• Arizona spurge (Euphorbia arizonica)
• flat-seeded spurge (Euphorbia platysperma)
• Little San Bernardino Mountains Linanthus (Linanthus maculatus ssp. maculatus) • spiny-hair blazing star (Mentzelia ticuspis)
• slender cottonheads (Nemacaulis denudata var. gracilis) • desert spikemoss (Selaginella eremophila)
However, the species were neither State nor federally listed as endangered or threatened, but had been identified on the CNPS Inventory of Rare and Endangered Plants. While there is some suitable habitat for these species within the project site, including the proposed water and sewer line alignments, the documented occurrences range from approximately 3 miles from the site to as far as 9 miles from the site. Due to these distances, and the low to moderate potential for them to occur on site, the 2018 EIR project-related effects to these species were not likely to occur.

Amphibians and Reptiles
Desert tortoise (Gopherus agassizii)
The desert tortoise is a State- and federally-listed threatened species. There are no desert tortoise occurrences documented on the project site and the site is separated from the nearest documented desert tortoise occurrences by utilities infrastructure and California State Route 62 (SR-62) to the west and residential development to the north/northeast. Furthermore, the CVMSHCP has modeled suitable desert tortoise habitat within the project site or surrounding area and both are completely outside any areas of modeled desert tortoise habitat. Per the USFWS, desert tortoise Critical Habitat overlay, the project sites are not within any USFWS designated desert tortoise Critical Habitat. The 2018 EIR concluded that development of the proposed project would not have a significant impact on the desert tortoise.

Other Sensitive Reptile Species
Two sensitive reptilian species were identified in the 2018 EIR as having a low to moderate potential to occur within the project site:
• red-diamond rattlesnake (Crotalus ruber)
• flat-tailed horned lizard (Phrynosoma mcallii)
These species are neither State nor federally listed as endangered or threatened, but have been designated as SSC by the CDFW. The documented occurrences were not near or within the site and these species were not seen during the site survey, therefore the 2018 EIR determined project-related effects to these species were not likely to occur.

Item Number: 1.

45 Birds
BUOW (Athene cunicularia)
The BUOW was a State-listed SSC and protected by the federal MBTA and by State law under CFG Code 3513 and 3503.5. Focused breeding season protocol BUOW surveys were conducted within the project site because the project site contained habitat that was suitable to support BUOW.

The result of the focused BUOW surveys was that no BUOW individuals or sign, including pellets, feathers or whitewash were observed. The 2018 EIR concluded that development of the DLVSP would have a less than significant impact on BUOW.

Loggerhead shrike (Lanius ludovicianus)
The loggerhead shrike was considered a SSC by the CDFW and protected by the federal MBTA.

The 2018 EIR determined the project site contained habitat that is suitable to support this species, and included Mitigation Measure BIO-3, Preconstruction Nesting Bird Surveys, to avoid any potential project-related impacts to loggerhead shrike or other nesting birds within the project site.

Mammals
No State- and/or federally-listed threatened or endangered, or other sensitive mammalian species were observed onsite during the field survey. However, based on habitat preferences and proximity of documented occurrences to the project site, the following sensitive mammalian species were identified in the 2018 EIR for the project site as having a low to moderate potential to occur within the study area:
• San Diego pocket mouse (Chaetodipus fallax pallidus)
• Palm Springs pocket mouse (Perognathus longimembris bangsi) • Palm Springs round-tailed ground squirrel (Xerospermophilus tereticaudus chlorus) These species are neither State nor federally listed as endangered or threatened, but have been designated as SSC by the CDFW. The 2018 EIR determined project-related effects to these species are not likely to occur because the documented occurrences are not near or within the site and these species were not seen during the site survey, and no critical habitat for these species is present within the project sites. The 2018 EIR concluded that payment of the CVMSHCP mitigation fee, implemented through Regulatory Requirement RR-4, will cover incidental take of the species during the development of the DLVSP project since it is a covered activity under the CVMSHCP.

Impacts to Riparian Habitat
The 2018 EIR determined there was no riparian habitat or other sensitive natural communities within the project site, as the area is a dune and sand field habitat. Therefore, implementation of the DLVSP would not cause significant impacts to riparian habitats. However, there are three channels, washes, or swales as defined by Section 1600 of the FGC under jurisdiction of the CDFW, or Waters of the US as defined by Section 404 of the Clean Water Act (CWA) under the jurisdiction of the USACE within the proposed water and sewer line alignment along 20th Avenue.

Item Number: 1.

46 The summary of acreage of jurisdictional waters detailing the amount of impacts on each jurisdictional drainage feature is provided in Table 4.4-2 of the 2018 EIR, and shown below. The 2018 EIR concluded the project proponent must obtain a Nationwide Section 404 permit from the Army Corps of Engineers (USACE) for the jurisdictional waters that flow north to south, crossing 20th Avenue, implemented with Regulatory Requirement RR-5, to ensure that impacts to riparian habitat are less than significant.

Impacts to Federally Protected Wetlands
The 2018 EIR determined that neither the DLSVP project site nor the proposed water and sewer line alignments contained any federally protected wetlands as defined by Section 404 of the Clean Water Act. Therefore, implementation of the DLVSP would result in no significant impacts to federally protected wetlands.

Movement of Native Wildlife
The 2018 EIR determined that impacts to wildlife movement from implementation of the DLVSP would be less than significant because there are no existing Biological Corridors and Linkages dedicated by the CVMSHCP or the City’s General Plan within the project site and surrounding area, including the water and sewer line alignments, and wildlife movement is currently affected by existing roadways that act as barriers.

Conflict with Local Policies
The 2018 EIR summarizes the Goals, Policies, and Programs relevant to Biological resources from the City of Desert Hot Springs Comprehensive General Plan in Section 4.4.3 of the EIR.

The 2018 EIR determined that any suitable habitat for special status species on the project site would be mitigated through the payment of the CVMSHCP mitigation fee, Regulatory Requirement RR-4, which is consistent with the General Plan regarding assessment and maintenance of habitat suitable for special status species within the City of Desert Hot Springs.

The project site’s location adjacent to and within a CVMSHCP Conservation Area created potential for negative impacts to the designated conservation land. Since approximately 38.7 acres of the DLVSP are within the Desert Willow Conservation Area, land use adjacency guidelines adopted in the CVMSHCP must be followed during development and operation of the DLVSP, implemented through Mitigation Measure, BIO-5.

Item Number: 1.

47 Ultimately, Chapter 3.40.020 of the City of Desert Hot Springs’ Municipal Code determines that in order to realize the goals and objectives of the Coachella Valley Multiple Species Habitat Conservation Plan/Natural Community Conservation Plan (CVMSHCP) and to mitigate the impacts caused by new developments in the City, lands supporting the CVMSHCP must be acquired, monitored and managed through financial supplementation of the local development mitigation fee to achieve habitat conservation in perpetuity. The project proponent was required to adhere to the CVMSHCP requirements outlined in Mitigation Measure BIO-1 (payment of mitigation fee) and BIO-5 (adjacency guidelines).

The 2018 EIR concluded that development of the DLVSP would not conflict with any local policies pertaining to biological resources.

Habitat Conservation
Approximately 38.7 acres of the northern portion of the project site (mostly north of Varner Road) is within the Willow Hole Conservation Area. Likewise, portions of the proposed water and sewer line alignment, under either alignment option are also located within this conservation area. The water and sewer line alignment project fell into the “covered activity” category which includes public facility operations and maintenance such as water and sewer treatment and transmission facilities. The project proponent would be required to adhere to the CVMSHCP Land Use Adjacency Guidelines included in Mitigation Measure BIO-5.

The 2018 EIR determined the project proponent would submit the application to CVCC which would trigger the Joint Project Review process implemented through Regulatory Requirement RR-6. Since the proposed project would be considered a Covered Activity under the CVMSHCP upon project approval, take of covered species within the Willow Hole Conservation Area would also be covered by the mitigation fee, implemented through Regulatory Requirement RR-4.

The dedicated area for open space conservation as part of the CVMSHCP’s Willow Hole Conservation Area was to remain undeveloped except for the solar facility proposed in Planning Area 2. All other project development was restricted to areas outside the Willow Hole Conservation Area. Additionally, as contained in Mitigation Measure BIO-6, a site-specific acoustical analysis was to be required once a site specific site plan was made available in order to demonstrate compliance with the CVMSCHP noise threshold.

The 2018 EIR concluded that the DLVSP would be consistent with the Conservation Goals and Objectives set forth in the CVMSHCP, and impacts would be less than significant.

Cumulative Impacts
The 2018 EIR indicated that impacts on special-status species were cumulative, given that other development was expected to occur in the Coachella Valley. However, cumulative impacts were addressed in the CVMSHCP, which provided mitigation for incidental take resulting from individual development projects (See Regulatory Requirement RR-4). The 2018 project was subject to these requirements, therefore impacts to biological resources were not cumulatively considerable.

Item Number: 1.

48 Mitigation Measures
The following Mitigation Measures and Regulatory Requirements are from pages 4.4-42 through -44 of the 2018 EIR.

BIO-1 Focused Coachella Valley milk-vetch surveys shall be conducted prior to any grading activities within the project site, particularly in the portion of the project site that falls within the Willow Hole Conservation Area (Planning Area 2). Likewise, focused surveys shall be conducted prior to any grading activities within the selected water and sewer line alignments (either Option A or Option B). If any Coachella Valley milkvetch is encountered during the pre-construction survey, it should be flagged and avoided. If avoidance is not an option, the project proponent must work with the appropriate agencies to prepare a salvage plan to be incorporated during construction within the Willow Hole Conservation Area.

BIO-2 Prior to the start of construction activities and for the duration of construction, within one week of employment all new construction workers working within the project site shall attend Worker Environmental Awareness Program (WEAP) training, developed and presented by a qualified biologist. The program shall include information on the life history of the burrowing owl, other raptors, nesting birds, as well as other wildlife and plant species that may be encountered during construction activities. The program shall also discuss legal protection status of each species, the definition of “take” under the Federal Endangered Species Act and California Endangered Species Act, measures the project proponent is implementing to protect the species, reporting requirements, specific measures that each worker shall employ to avoid take of wildlife species, and penalties for violation of the Federal Endangered Species Act or California Endangered Species Act.

BIO-3 If construction activity takes place between January and September, and if said construction activity is unavoidable to schedule outside of this time frame, the applicant(s) can prepare a project-specific Nesting Bird Management Plan to determine suitable buffers.

BIO-4 Preconstruction Nesting Bird Surveys are recommended prior to commencement of any project activities that may occur within the nesting season (January to September), to avoid any potential project-related impacts to nesting birds within the project site.

BIO-5 The project proponent shall implement the following CVMSHCP Land Use Adjacency Guidelines requirements and restrictions as listed in Section 3.2.3 of the Biological Resources Assessment (Appendix C) and shall be adhered to during construction and for post construction operation for any project within the project site that lies adjacent to Conservation Areas. The project proponent shall coordinate with the Coachella Conservation Commission (CVCC) and CVCC staff shall review plans for all planning areas adjacent to the Conservation Area and determine whether the proposed improvements are consistent with the CVMSHCP.

Item Number: 1.

49 1) Drainage ̶ Proposed Development adjacent to or within a Conservation Area shall incorporate plans to ensure that the quantity and quality of runoff discharged to the adjacent Conservation Area is not altered in an adverse way when compared with existing conditions. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials or other elements that might degrade or harm biological resources or ecosystem processes within the adjacent Conservation Area.
2) Toxics ̶ Land uses proposed adjacent to or within a Conservation Area that use chemicals or generate byproducts such as manure that are potentially toxic or may adversely affect wildlife and plant species, Habitat, or water quality shall incorporate measures to ensure that application of such chemicals does not result in any discharge to the adjacent Conservation Area.
3) Lighting ̶ For proposed Development adjacent to or within a Conservation Area, lighting shall be shielded and directed toward the developed area. Landscape shielding or other appropriate methods shall be incorporated in project designs to minimize the effects of lighting adjacent to or within the adjacent Conservation Area in accordance with the guidelines to be included in the Implementation Manual.
4) Noise ̶ Proposed Development adjacent to or within a Conservation Area that generates noise in excess of 75 dBA Leq hourly shall incorporate setbacks, berms, or walls, as appropriate, to minimize the effects of noise on the adjacent Conservation Area in accordance with guidelines to be included in the Implementation Manual.
5) Invasives ̶ Invasive, non-native plant species shall not be incorporated in the landscape for land uses adjacent to or within a Conservation Area. Landscape treatments within or adjacent to a Conservation Area shall incorporate native plant materials to the maximum extent feasible; recommended native species are listed in Table 4-112. The plants listed in Table 4-113 shall not be used within or adjacent to or within a Conservation area. The list may be amended from time to time through a Minor Amendment with Wildlife Agency Concurrence. 6) Barriers ̶ Land uses adjacent to or within a Conservation Area shall incorporate barriers in individual project designs to minimize unauthorized public access, domestic animal predation, illegal trespass, or dumping in a Conservation Area.

Such barriers may include native landscaping, rocks/boulders, fencing, walls and/or signage.
7) Grading/Land Development ̶ Manufactured slopes associated with site Development shall not extend into adjacent land in a Conservation Area.

BIO-6 A site specific final acoustical analysis is required once a site specific site plan is made available in order to demonstrate compliance with the CVMSCHP noise threshold. If the results of the acoustical analysis conclude that proposed development will exceed acceptable noise levels, the proposed development project shall be redesigned to ensure consistency with the CVMSHCP Adjacency noise requirements.

Item Number: 1.

50 Regulatory Requirements
RR-4 New development projects are required to pay the most current CVMSHCP (2017) mitigation fee rate of $5,529 per acre of commercial/industrial use.

RR-5 Prior to start of construction, the project proponent must obtain a Section 404 Permit with the USACE for Waters of the US that could be impacted by development of the proposed project.

RR-6 Per CVMSHCP, the project proponent must undergo Joint Project Review to ensure Plan implementation. The project proponent must submit the application to CVCC which would trigger the Joint Project Review process. CVCC and wildlife agencies would supply comments within 30 days of receipt of the application and any impacts to covered species within the Conservation Area would be discussed.

Analysis of the Proposed Project
A Habitat Suitability Assessment and Coachella Valley Multiple Species Habitat Conservation Plan Consistency Report (Biological Resources Assessment) was prepared for the Project by WSP in December 2024 (Appendix C).

Current Conditions
A biological field survey was conducted on November 13, 2024. Consistent with findings in the 2018 EIR, the project site consists of undeveloped, natural open space, and disturbed areas with a minimally developed rural residential (single-family home) site occurring on the adjacent property to the south. The project site is relatively flat and sandy and contains two types of soils.

The main type of soil present on site is classified as Carsitas cobbly sand, 2-9% slopes, followed by Carsitas gravelly sand, 0-9% slopes. Carsitas soils consist of very deep, somewhat excessively drained soils that formed in alluvium from granitoid and/or gneissic rocks.

No drifts, hummocks, rock outcrops, significant rocky areas, clay lenses, springs, seeps or bodies of water were detected. There were, however, some unnaturally rocky areas, due to apparent dumping and distribution of rubble and rock in a disturbed area on site. Mission Creek, an ephemeral, dry wash is located approximately 0.1 miles (160 m) west of the project site and Morongo Wash is approximately 0.6 miles (965 m) to the east. No washes, drainages or any other evidence of water flow or pooling were observed during analysis of aerial photographs from recent years.

Vegetation
The on-site vegetation community is Sonoran mixed woody and succulent scrub. Dominant perennial plant species observed included creosote bush (Larrea tridentata) and white bursage (Ambrosia dumosa). The dominant annual species, identified entirely through the presence of dead remnants was Saharan mustard (Brassica tournefortii). Other representative, but less abundant, plant species observed included cheesebush (Ambrosia salsola), brittlebush (Encelia Item Number: 1.

51 farinosa), velvet turtleback (Psathyrotes ramosissima), goldenbush species (Ericameria sp.), narrow-leaved cryptantha (Cryptantha angustifolia), silver cholla (Cylindropuntia echinocarpa), bladderpod (Peritoma arborea), blue palo verde (Parkinsonia florida), Emory’s indigo bush (Psorothamnus emoryi), joint-fir species (Ephedra sp.), Yuma sandmat (Euphorbia setiloba), littleleaf ratany (Krameria erecta), common Mediterranean grass (Schismus barbatus), and a wild buckwheat species (Eriogonum sp.).

No wetland, riparian or otherwise special status vegetation communities were observed on the project site.

Wildlife
Two reptiles, one mammal, and one bird were observed on the project site. The two reptiles observed onsite included the western whiptail (Aspidoscelis tigris), and side-blotched lizard (Uta stansburiana). The one mammal detected onsite, through the presence of scat, was the blacktailed jackrabbit (Lepus californicus). The one bird observed onsite included the common raven (Corvus corax).

Impacts to Sensitive Species
No special status species, flora, or fauna were detected onsite. The literature review for the Project Biological Resources Assessment identified 64 special status species as having the potential to occur on or near the Project site. These included thirty (30) plants, three (3) vegetation communities, six (6) invertebrates, five (5) reptiles, ten (10) birds and ten (10) mammals. Of the 64 species identified, 52 are considered to be absent from the site due to a lack of suitable habitat. Six of the remaining 12 species are fully covered and conserved under the CVMSHCP. Participation in the CVMSHP through payment of the requisite CVMSHCP development fee is expected to fully mitigate project related impacts (if any) to these species.

These include: Coachella Valley milk-vetch, Little San Bernardino Mountains linanthus, flat-tailed horned lizard, Coachella Valley fringe-toed lizard, Palm Springs pocket mouse and Coachella Valley (Palm Springs) round-tailed ground squirrel. Regardless of whether these species occur on the project site or not, participation in the CVMSHCP and payment of the development fee is designed and intended to provide full coverage of all potential project-related impacts occurring on the warehouse site. These species will not be discussed further.

The remaining five (5) species, which are not covered, or not fully covered, under the CVMSHCP are discussed below.

Plant Species Not Fully Covered by CVMSHCP
In the 2018 EIR, the Coachella Valley Milk Vetch was identified as potentially occurring on the site and required the implementation of pre-construction surveys prior to construction. However, the species is fully covered by the CVMSHCP, and payment of the development fee described above will mitigate impacts to the species. As a result, the previously required pre-construction surveys for the species are no longer necessary.

Item Number: 1.

52 Desert spike moss (Selaginella eremophila) is considered to have a low potential for occurrence as it is associated with gravelly soils, crevices and is found among rocks. Potentially suitable habitat was observed onsite during the field survey, however the species was not detected onsite during the field survey. Desert spike moss is not listed as threatened or endangered but is designated as S2S3 by the CDFW and List 2B.2 by the CNPS, meaning that it is considered to be “imperiled to vulnerable” by the CDFW and “rare, threated or endangered in California, but more common elsewhere” and “moderately threatened in California.” If a significant population were to be present, unmitigated impacts may be considered significant under CEQA. While the likelihood of the species occurring onsite is very low, Mitigation Measures BIO-1 requires a focused plant survey be conducted during the desert spike moss blooming period (May-July) prior to ground disturbing activities to ensure impacts to the species is avoided or mitigated according to CDFW guidelines. Implementation of mitigation would ensure impacts are less than significant.

Reptile Species Not Fully Covered by CVMSHCP
The red-diamond rattlesnake is not listed as threatened or endangered by the CDFW or USFWS but is designated as a California SSC by the CDFW. The site contains potentially suitable burrows, rocks and other surface cover debris suitable for the red-diamond rattlesnake, however the biological resources assessment determined project-related impacts to this species (if any) would be incremental and localized. As a result, impacts (if any) to this species would not be considered significant under CEQA.

Bird Species Not Fully Covered by CVMSHCP:

Burrowing Owl
The burrowing owl is protected under the Migratory Bird Treaty Act (MBTA) and the State Fish and Game Code (FGC) and is also federally designated as a Bird of Conservation Concern and state designated as a Species of Concern. It was recently proposed for listing by the CDFW. No burrowing owls were observed during the site survey, but is known from the vicinity and has at least some potential to nest and forage on the Project site. Therefore, the biological resources assessment requires, consistent with the requirements of the CVMSHCP and the CDFW, two preconstruction take avoidance surveys (the first within 14-30 days prior to ground disturbance and the second within 24 hours of ground disturbance) to ensure that no direct take of burrowing owls occur, implemented by Mitigation Measure BIO-2, below. If a burrowing owl is found to occur on the project site, the CDFW should be contacted as soon as possible to determine the appropriate course of action required should burrowing owl(s) occupy the site at the time of project implementation. Implementation of mitigation would ensure impacts to the species are less than significant.

Black-tailed gnatcatcher
The black-tailed gnatcatcher is considered to have a low potential for occurrence as it is associated with Mojavean desert and Sonoran desert scrubs. This species is not listed as threatened or endangered but is managed as a Bird of Conservation Concern (BCC) by the USFWS and designated as an SSC by the CDFW. It is also protected from take by the MBTA and California FGC. For these reasons, a pre-construction nesting bird survey would be required to ensure that Item Number: 1.

53 no direct take of black-tailed gnatcatchers occurs, implemented by Mitigation Measures BIO-3.

Implementation of mitigation would ensure impacts to this species are less than significant.

Migratory Bird Treaty Act (MBTA)
The MBTA protects virtually all native migratory and resident bird species that are excluded from coverage under the CVMSHCP. Avoidance of impacts to these nesting migratory and resident birds is a requirement of the federal permit issued for the CVMSHCP. In order to avoid impacting nesting birds, either avoidance of project-related disturbance during the nesting season (generally from approximately 15 January through 31 August) or nesting bird surveys conducted by a qualified ornithologist or biologist immediately prior to on-site disturbance during the nesting season would be required, implemented by Mitigation Measures BIO-3. If nesting birds are found, no work would be permitted near the nest until young have fledged. Implementation of mitigation would ensure impacts to MBTA-covered nesting birds are less than significant.

Mammal Species Not Fully Covered by CVMSHCP
The only potentially occurring mammal species that is not covered under the CVMSHCP is the pallid San Diego Pocket mouse. This species is not listed as threatened or endangered by the USFWS or CDFW. It is, however, designated as an SSC by the CDFW. Although the state has designated it an SSC, it is ranked S3S4 which means that it is “vulnerable to apparently secure.” Although small mammal trapping would be the only way to determine this species status on-site, impacts, even if this species is present, would be not likely meet the threshold of significance under the CEQA, given its lower status of sensitivity and the fact that any individuals found on the site, if they occur, would not result in the permanent loss of the species. The biological resources assessment therefore does not recommend trapping surveys for this species, and impacts are considered less than significant.

Impacts to Wetlands, Riparian Habitats and Sensitive Natural Communities A Jurisdictional Delineation (JD) was conducted on the Project site to determine whether riparian areas or waters of the State were present (Appendix D). The qualified biologist conducted a literature review, a review of aerial photographs, and an intensive field investigation to determine whether any wetland features, hydrophytic plants, hydric soils or wetland hydrology was present, including the digging of soil pits in potential features on the Project site and adjacent to it. No such plants, soil or hydrology was identified.

According to the JD there are no wetlands, ponds, lakes or riverine habitats within the survey area. One drainage, Mission Creek is adjacent to the western edge of the Project area and is mapped as Riverine, Intermittent, Streambed, Intermittently Flooded. The southwestern portion of the Project site was impacted by flooding during tropical storm Hillary in August 2023. The flooding scoured a large area and created channelized areas along the dirt road that runs parallel to I-10 that were not present in 2018 when the EIR was prepared (Exhibit 12, Jurisdictional Drainages). Due to the absence of hydric vegetation and total lack of hydric soils observed within the drainage area, the JD considers it ephemeral and only conveying flowing water during and immediately following large storm events. Due to the drainages not having permanent flows, the drainage area would not be considered USACE under the updated WUS and EPA vs Sackett ruling.

However, the drainage area is considered RWQCB and CDFW jurisdictional based on clear evidence of flows. The JD concluded that the Project requires 1.19 acres of permanent impacts Item Number: 1.

54 to jurisdictional drainages and therefore, authorizations from the RWQCB (401 permit) and CDFW (1602 Streambed Alteration Agreement) are required, implemented by Mitigation Measure BIO-4. This mitigation measure would also apply if the sanitary sewer alignment selected for the proposed Project were to occur along 20th Avenue, as identified in and consistent with the 2018 EIR.

Table 5
Summary of Jurisdictional Areas
Survey Area Watershed WOUS
RWQCB
Length
(feet)
RWQCB
(acre)
CDFW
Length
(feet)
CDFW
(acre) Class
1 (Western drainage
from floodwaters Whitewater NA 1,480 1.19 1,480 1.19 Non-Section 10 Non Wetland Source: Table 3 of Jurisdictional Delineation Report, prepared by WSP. December 2024.

Impacts to Wildlife Movement or Nursery Sites
For the reasons discussed in the 2018 EIR, impacts to wildlife movement from implementation of the Project would be less than significant because there are no existing Biological Corridors and Linkages dedicated by the CVMSHCP or the City’s General Plan within the project site and surrounding area, including the water and sewer line alignments, and wildlife movement is currently affected by existing roadways that act as barriers.

Conflicts with Local Policies or adopted Habitat Conservation Plans The proposed Project is located in the City of Desert Hot Springs, which is within the boundaries of the CVMSHCP, and is therefore subject to payment of the Development Mitigation Fee which will mitigate potential impacts to covered species.

The CVMSHCP Willow Hole Conservation Area (WHCA) consists of approximately 5,600 acres of land generally located east of Little Morongo Road, south of Dillon Road, north of Varner Road and Interstate 10, and west of DaVall Drive (extended). The westerly tip of the property’s southern parcel (APN 669-150-002) is located within the WHCA, and the property’s northern parcel (APN 669-150-001) is entirely located within the WHCA. Combined, approximately 40.3 acres of the project site is located within the WHCA, with Project impacts disturbing approximately 11.65 acres of the conservation area.

The Project’s proposed flood control structures and multimodal path on the north side of Varner Road are within the WHCA and are thus subject to project review under section 6.6.1.1 of the CVMSHCP. The applicant and the City began consultation with the Coachella Valley Conservation Commission (CVCC) in the fall of 2025 when the Project was originally contemplated as a minor amendment to the CVMSHCP, but has since been deemed appropriate to proceed through the Joint Project Review (JPR) process. The purpose of the JPR process is to determine if Project improvements within the WHCA comply with the CVMSHCP and its requirements, ensuring that development is balanced with conservation goals.

Item Number: 1.

55 On April 7, 2026, the CVCC issued final JPR findings (Appendix J) concluding that the Project was conditionally consistent with the CVMSHCP. This addendum will be updated following the Planning Commission hearing and prior to the City Council hearing to incorporate CVCC’s final JPR findings.

The CVCC’s final JPR findings and conditions for activities occurring within the WHCA are summarized below:
• Project Impact Summary
o The CVCC finds that the 11.65 acres of ground disturbance proposed within the WHCA will require Take Authorization under the CVMSHCP. Specifically, CVCC found the Project will incur Take against modeled Core Habitat for Palm Springs pocket mouse, modeled Other Conserved Habitat for Le Conte’s thrasher, sand transport corridors, and biological corridors.
o The CVCC strongly recommends that the time period between site grading and Project construction be reduced to the maximum extent possible to reduce the opportunity for site recolonization by any Covered Species. Furthermore, CVCC encourages the use of ungrouted or partially ungrouted riprap to construct the channel and basin embankments, rather than grouted riprap or cement, to allow for the creation of microhabitat.
o Based on the hydrology analysis, the CVCC concurs that sediment transported by the primary channels of Mission Creek to the west and Morongo Wash to the east is not impacted by the Project.
o The impacted area within the Mission Creek Biological Corridor is minimal and occurs outside the main channel, and is therefore not anticipated to negatively affect the ability of wildlife to utilize Mission Creek to move underneath I-10. o The widening of Varner Road west of Palm Drive is not a Covered Activity under the CVMSHCP, so any proposed roadway modifications within the WHCA must be limited to less than 74 feet in width and no more than one through travel lane per direction; widening beyond the warehouse entry point into the WHCA would violate the CVMSHCP.
• Rough Step Analysis3
o The CVCC finds the Project will not incur a negative Rough Step balance across any Conservation Objective, indicating that adequate conservation has taken place to allocate the necessary Take Authorization.
• Avoidance, Minimization, and Mitigation Measures
o Biological corridors: The CVCC finds the section of Varner Road that abuts the project is not subject to any mitigation measures for biological corridors; no culverts or undercrossings are required.
3 “Rough Step and its calculation is a metric developed by the CVMSHCP to ensure that development within any Conservation Area does not significantly outpace conservation in that Conservation Area. Maintaining Rough Step effectively limits the acres of Take Authorization that may be allocated at any given time to an amount roughly proportional to the acres of habitat that have been conserved up to that time.” CVCC Draft Findings, pg

5. Item Number: 1.

56 o Burrowing owl: CVCC acknowledges the two pre-construction surveys currently proposed as mitigation (Mitigation Measure BIO-2) and reiterates that occupied burrows will need to have buffers established while unoccupied burrows must be made inaccessible. Any relocation of individual owls will need to be coordinated with the Wildlife Agencies.
o Fluvial sand transport: In order to ensure this collected sand remains available to be transported by aeolian processes, the Permittee will require the regular deposition of collected sand on conserved properties within the WHCA. It is anticipated that this will take the form of a license agreement between the Permittee and CVCC authorizing future tenants to utilize CVCC lands for sediment deposition. Only sand removed from the detention basin north of Varner Road will be subject to this requirement; sand collected by basins within the warehouse facility may be contaminated by petroleum products and other industrial byproducts and cannot be deposited onto conservation lands. See Mitigation Measure BIO-5 regarding the handling of fluvial sand transport in the area. o Le Conte’s thrasher: The CVCC finds that the Project application commits to the specific survey and buffer requirements as described in the CVMSHCP o Palm Springs pocket mouse: CVCC recommends that any habitat clearing be prioritized to take place outside of peak breeding season (March through May).

Handling of Palm Springs pocket mice is not covered by the CVMSHCP permits and additional permissions from the Wildlife Agencies would be required. The CVCC acknowledges this measure was incorporated as part of Mitigation Measure BIO5. • Land Use Adjacency Guidelines: The CVCC finds that the Project shall implement CVMSHCP land use adjacency guidelines, where applicable, specifically in regards to drainage, toxics, lighting, noise, invasives, barriers, and grading/land development. Land use adjacency guidelines are appended to the CVCC draft findings (Appendix J). o Drainage: CVCC confirms that all runoff collected by the Project would have previously continued moving beyond the Conservation Area boundary and will continue to be channeled outside the WHCA in its original direction of flow. o Toxics: Due to the risk of contamination, sand collected in any of the detention basins within the warehouse facility will not be dispersed on adjacent conservation sites during maintenance activities.
o Lighting: All lighting must be cast down and shielded and lighting temperatures should not exceed 3,000 Kelvin. Where possible, lighting fixtures should be installed as low to the ground as possible, and should utilize motion activation and timed shut-off functionality. Offsite, illuminance should not exceed 15 lux (or 5 lux above baseline) as measured from 50 feet beyond the warehouse facility boundary.
o Noise: Consistent with 2018 EIR Mitigation Measures BIO-6, a final site-specific acoustical analysis is required to demonstrate compliance with the CVMSCHP noise threshold of 75 dBA Leq hourly, as measured at the property line, and site reconfigurations are required if exceeded.

Item Number: 1.

57 o Invasives: Remove Olea europea from the plant palette, encourages the use of native species in any landscape treatment.
o Barriers: No barriers proposed for the Project.
o Grading/Land Development: Warehouse facility will not extend into the WHCA.

In summary, the CVCC finds the Permittee has sufficient Take Authorization to permit the proposed disturbance, and impacts to modeled habitat are within Rough Step parameters. The Project can be brought into full consistency with the CVMSHCP pending demonstration that Varner Road will not be widened within the WHCA, and upon execution of a legal instrument between CVCC and the Permittee authorizing the distribution of collected sands on conservation lands adjacent to the site (Mitigation Measure BIO-5).

Cumulative Impacts
As was required in the 2018 EIR, the proposed Project is required to pay the mandatory CVMSHCP mitigation fee for incidental take resulting from development of the Project to address cumulative impacts to special status species. Like the 2018 EIR, the regulatory requirements and mitigation measures imposed on the Project address impacts from the Project and would reduce impacts to less than significant levels. The Project would not result in new cumulative impacts or increase the severity of cumulative impacts to biological resources previously identified in the 2018 EIR, and would not be cumulatively considerable, with the implementation of mitigation measures.

Summary of Impacts
The proposed Project could potentially impact sensitive biological resources occurring on the property. A large storm in 2023 created a new drainage area on the southwestern portion of the site that requires authorizations from the RWQCB (401 permit) and CDFW (1602 Streambed Alteration Agreement). However, like the 2018 EIR, the regulatory requirements and mitigation measures imposed on the Project address impacts from the Project and would reduce these impacts to less than significant levels. Since the area to be disturbed by the currently proposed Project is consistent with that which would have been disturbed under the DLVSP, impacts to biological resources would be equivalent to those identified and studied in the 2018 EIR.

Overall, the proposed Project will not result in any new significant impacts or increase the severity of impacts already identified in the EIR. Development conducted pursuant to the mitigation measures set forth below, and in adherence to existing federal, state, and City regulations will ensure potential impacts associated with biological or jurisdictional resources are reduced to less than significant levels.

Mitigation Measures
BIO-1 Focused plant surveys for desert spike moss shall be conducted during the appropriate season and prior to any ground disturbance on the Project site. If significant populations are found, biological monitoring by a qualified biologist may be required near their populations.

Item Number: 1.

58 BIO-2 Burrowing Owl Surveys: Two pre-construction take avoidance surveys are required to determine if burrowing owl presently occur on, or immediately adjacent to, the site to ensure that impacts to burrowing owl do not result from project implementation.

Additionally, the CDFW should be contacted for guidance on any burrowing owl(s) found to be present as soon as possible. Relocation of any burrowing owl(s) on-site may be required and would require coordination with the CVAG and CDFW. A copy of a California Native Species Field Survey Form would also be sent to the CDFW, as required.

BIO-3 MBTA Surveys: In order to avoid impacting nesting birds, either avoidance of projectrelated disturbance during the nesting season (generally from approximately 15 January through 31 August) or nesting bird surveys conducted by a qualified ornithologist or biologist immediately prior to on-site disturbance during the nesting season would be required. If active bird nests are found, at any time, proposed project activities would need to be postponed until young have fledged the nest and impacts to nesting birds are entirely avoided.

BIO-4 Prior to start of construction, the project proponent must obtain a Section 401 Permit with the RWQCB and a 1602 Streambed Alteration Agreement with CDFW for jurisdictional waters that could be impacted by development of the proposed project.

BIO-5 The following measures shall be included as mitigation measures for the Development Permit, and placed as conditions of approval on the City’s Tentative Parcel Map 25-1 (TPM 39143) and Design Review 24-4.

1. The Development Project owner/operator shall be required to clear channels and basins constructed on the Development Project site every quarter, or more often if required by storm events to maintain capacity.

2. The Development Project owner/operator shall be required to clear the channel and basin located within Assessor’s Parcel 669-150-001 every quarter, or more often if required by storm events to maintain capacity.

3. Sand removed from Development Project and Project channels and basins shall be transported across West Drive to Assessor’s Parcel 660-060-032 (currently owned by CVCC and held in conservation in perpetuity) and spread to CVCC’s standards in a north-south direction to facilitate sand transport to the east. The City and CVCC will enter into an agreement to allow sand deposition on the CVCC parcel.

4. No development shall be permitted until the CVMSHCP JPR process is complete and the CVCC determines the proposed improvements are consistent with the CVMSHCP, as conditioned.

5. Any habitat clearing occurring within the WHCA shall be prioritized to take place outside of peak breeding season (March through May). Handling of Palm Springs pocket mice is not covered by the CVMSHCP permits and additional permissions from the Wildlife Agencies would be required.

Item Number: 1.

59 6. A final site-specific acoustical analysis is required to demonstrate compliance with the CVMSCHP noise threshold of 75 dBA Leq, as measured at the property line, and site reconfigurations are required if exceeded.

7. Olea europea shall be removed from the Project’s plant palette.

Item Number: 1.

Item Number: 1.

61 3.5. CULTURAL RESOURCES
Summary of Findings in the 2018 EIR (Section 4.5, page 4.5-1 et.seq.) Descriptions and analysis in the Cultural Resources section of the 2018 EIR were based on information contained in the Cultural Resource Assessment for the Vesting Tentative Tract Map No. 37185 Project, (Appendix D1 of 2018 EIR), Paleontological Resource Assessment for the Desert Land Ventures Project (Appendix D2 of 2018 EIR), Historic American Engineering Record Varner Road/Former U.S. Highway 60/70/99 (Appendix D3 of 2018 EIR), and the City of Desert Hot Springs Comprehensive General Plan Archaeological and Historic Resources Element.

Setting
As described in the 2018 EIR, the prehistoric cultural setting begins in the Late Prehistoric period due to the nature and temporal assignment of archaeological sites identified within a one-mile radius of the project site. The Late Prehistoric period (circa 1,200 to 200 years before present) in the Colorado Desert is marked by the introduction of new artifact types and technological innovations of the previous Amargosa Period of the Late Archaic and defined as the Patayan Pattern. This period is characterized by the introduction of ceramics, including, Tizon Brown Ware from the Peninsular Ranges, Colorado Buff Wares from the Colorado River region, and the Salton Buff Ware from the Lake Cahuilla shoreline.

Sites and artifacts of historic significance are generally more than 45 to 50 years of age, but range from the period of the earliest European contacts, around the end of the 1700s, to approximately the end of World War II. Available historic sources from 1856 to 1975 indicate that several old roads and Indian trails once crossed portions of the Desert Hot Springs area. A review of land patent records indicates that homestead applications for portions of the project site were filed with the U.S. General Land Office (GLO) in 1907, 1914, 1917, 1920, and 1923. All of these patents were either relinquished or canceled.

Literature and Records Seach
Results of the records search indicated that 28 cultural resources have been previously documented within a 1-mile radius of the project site. Of these, two historical built-environment resources (Varner Road [33-008408] and an unnamed road [33-024712]), two historical archaeological resources (a refuse scatter [33-017842] and structural foundations with an associated refuse scatter [33-017842]), and one prehistoric archaeological isolated artifact (33- 015281; ceramic fragments) were identified within the study area.

Pedestrian Survey
An intensive pedestrian survey of the project site was performed by Æ on April 6 and 7, 2017. As part of the survey, Æ attempted to revisit the five previously recorded cultural resources identified within the project site. An additional survey of the proposed offsite water and sewer alignments was completed on November 3, 2017. As a result of the survey, the boundary of Varner Road (33-008408) was extended to incorporate the previously recorded historical trash scatter (33-017841). A newly identified historical archaeological site comprising of historical refuse scatter associated with Varner Road (Æ-3634-02H) and a single prehistoric archaeological isolated find (Æ-3634-ISO-1) were also encountered within the project site during the survey Item Number: 1.

62 effort. During the survey of the proposed water and sewer alignments, a segment of 20th Avenue (AE-3634-03H) was encountered. A review of historical maps of the study area indicated one additional buried built-environment resource, a set of Southern California Gas (So Cal Gas) Company pipelines (33-024722), underlies the project site. The gas pipelines are located adjacent to Mihalyo Road, on the south aspect closest to Interstate 10 within a So Cal Gas Company easement corridor.

Historical Resources Impacts
The 2018 EIR identified four historical built-environment resources within the project site:

1. Mihalyo Road: An evaluation of Mihalyo Road suggested that the historical builtenvironment resource did not meet any criteria for listing on the CRHR. The 2018 EIR concluded that Mihalyo Road is not considered a Historical Resource defined by CEQA and no further management of this resource was recommended.

2. So Cal Gas Pipelines: The pair of buried So Cal Gas Company pipelines were not evaluated as part of the 2018 EIR Cultural Resource Assessment as they would be avoided during project implementation. If project designs are modified in the future so that there is a potential for this built-environment resource to be impacted, then a formal evaluation of the buried pipelines should be conducted to determine if the pipelines are eligible for listing on the CRHR.

3. 20th Avenue: This newly identified road segment included a 1.5-mile-long segment of 20th Avenue located between Little Morongo Road on the west and Palm Drive on the east.

Much of the roadway was graded dirt. However, an approximately 530-foot-long (0.1 mile) section of the road west from the intersection of Palm Drive was paved. The 2018 EIR determined that the road does not represent the work of a prominent architect, designer, or builder, nor does it qualify as an important example of its type, period, region, or method of construction.

4. Varner Road: The 2018 EIR found this segment of Varner Road still exhibited a construction type that was considered as historically significant for its close association with early and mid-20th century American automobile culture which is considered as an event of recognized historical significance. Therefore, construction-related project disturbances to this road segment would result in significant impacts to the existing historically significant physical characteristics of Varner Road. The 2018 EIR proposed Mitigation Measure CR-1, requiring preservation through the documentation of the historical resource based on the requirements of the Historic American Engineering Record (HAER), recommended to be completed prior to the start of project development.

The adherence to documentation of Varner Road based on HAER requirements would allow for the perpetual study of the historical resource in relation to engineering and industry. Documentation of Varner Road based on HAER requirements was conducted on July 9, 2017 by Æ. Nonetheless, the 2018 EIR concluded that the DLVSP would still result in unavoidable significant impacts to this roadway.

Item Number: 1.

63 Archaeological Resources Impacts
Three of the 28 cultural resources identified during the literature search were archaeological resources (two historical archaeological sites and one prehistoric archaeological isolated find) and were reported to be located within the project site. The three identified archaeological resources consist of a historic-period refuse scatter (AE-3634-02H), a historic-period site consisting of a foundation and collapsed concrete and cobble walls of a building and a scatter of associated refuse (33-017842/CA-RIV-9233), and a prehistoric isolate artifact consisting of two ceramic shards. (Æ-3634-ISO-01). An evaluation of AE-3634-02H and 33-017842/CA-RIV-9233 suggested that the resources were not identified to be associated with any documented historical land uses, nor individuals associated with any documented historical land uses. Hence, the site was recommended as ineligible for listing on the CRHR. The two ceramic shards that comprise AE-3634-ISO-01 are not unique, unusual, rare, or otherwise exceptional. The isolated artifacts were considered an insignificant resource under CRHR criteria because they lack important associations to events or persons, do not embody any distinctive characteristics of type, period, or method of construction, and do not provide sufficient data to address research questions about the prehistory of the Coachella Valley. The results of the intensive-level cultural resource survey of the project study area provided in the 2018 EIR Cultural Resource Assessment suggest that the three identified archaeological resources do not meet the CRHR criteria, have been evaluated as not eligible for the CRHR, and therefore, are not considered historical resources or significant archaeological resources. As such, no further management of these three resources was recommended in the 2018 EIR.

The 2018 EIR included Mitigation Measure CR-2, which requires an archaeological survey of the proposed water and sewer alignments that were not surveyed due to access restrictions, prior to construction of the project. In addition, Mitigation Measure CR-3 was included that requires all work to halt in the event that intact subsurface archaeological deposits are encountered during construction activities until a qualified archaeological monitor can be called onsite, at the expense of the project proponent, to assess the significance.

The 2018 EIR concluded that with implementation of Mitigation Measures CR-2 and CR-3 any unknown archaeological resources uncovered during ground disturbing activities associated with project development would not be significantly impacted.

Paleontological Resource or Unique Geologic Feature Impact The 2018 EIR Paleontological Resource Assessment, Geologic Units and Paleontological Sensitivity Map, indicated that the Quaternary alluvium and fluvial deposits mapped at the surface of the project site have a low potential to contain intact paleontological resources because they are typically too young to contain fossilized remains. Project excavation was expected to be relatively shallow and sensitive older geologic deposits present at the maximum excavation depth were unlikely to be impacted by project development. As a result, the potential for encountering fossil resources during project-related ground disturbance was considered low.

The 2018 EIR determined impacts to paleontological resources were not anticipated and no further paleontological mitigation was recommended. However, if in the event paleontological resources are discovered, implementation of Mitigation Measure CR-4 would reduce impacts in this regard to less than significant levels.

Item Number: 1.

64 Disturbance of Human Remains
The State of California Health and Safety Code Section 7050.5, State CEQA Guidelines 15064.5(e), and California Public Resources Code (PRC) Section 5097.98 mandate the process to be followed in the unlikely event of an accidental discovery of any human remains in a location other than a dedicated cemetery. The 2018 EIR lists this requirement as Mitigation Measure CR-5 to ensure impacts remain less than significant.

Cumulative Impacts
The 2018 EIR determined that implementation of the DLVSP and development of the site did not have the potential to create cumulative impacts regarding cultural resources because all potential impacts were found to be less than significant with implementation of mitigation measures consistent with CEQA guidelines.

Mitigation Measures
The following Mitigation Measures are from page 4.5-15 and -16 of the 2018 EIR.

CR-1 The portion of Varner Road located within the project site shall be documented following the guidelines of the Historical American Engineering Record (HAER) as stated in the Secretary of the Interior’s Standards and Guidelines for Architectural and Engineering Documentation (48 CFR 190: 44730-34).

CR-2 Prior to construction of the proposed water/sewer alignment, the area that was not surveyed due to access restrictions (see Exhibit 4.5-1) must be surveyed for archaeological resources. If cultural resource(s) are identified in the alignment that cannot be avoided, all activity in the area of the find shall cease until the cultural resource(s) can be evaluated by a qualified archaeologist. If the qualified archaeologist determines that the resources may be significant, he or she shall notify the project proponent and shall develop an appropriate plan of action for the resources. The project proponent shall consult with appropriate Native American tribal representatives (if the find is prehistoric in nature), then the resource(s) shall be evaluated for listing on the CRHR.

CR-3 If during the course of excavation, grading or construction, artifacts or other archaeological resources are discovered, all work in the immediate area of the find shall be halted and the project proponent or his/her designee shall immediately notify the City of Desert Hot Springs City Planner. A qualified archaeologist shall be called to the site by, and at the expense of, the project proponent to evaluate the significance of the find using CRHR eligibility criteria. If evaluated as eligible and the find cannot be avoided, the archaeologist must prepare and submit a data recovery plan to the City Planner. Upon approval, the data recovery plan shall be implemented.

Work shall resume after consultation with the City of Desert Hot Springs and implementation of the recovery plan by the archaeologist.

CR-4 If a paleontological resource is accidentally uncovered during grading or construction activities for the project, the project proponent shall be required to notify the City of Desert Hot Springs City Planner immediately and all excavation work within ten feet Item Number: 1.

65 of the find shall cease immediately. A qualified paleontologist shall be consulted to determine the necessity for monitoring any excavation and to evaluate any paleontological resource exposed during construction. Construction activity shall resume upon consultation with the City and upon implementation of the recommendations of the paleontologist.

CR-5 If human remains are uncovered during excavation or grading activities on the project site, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until:

A) The Riverside County Coroner has been contacted and determined that no investigation of the cause of death is required, and
B) If the coroner determines the remains to be Native American:

The coroner shall contact the Native American Heritage Commission (NAHC) within 24 hours. The NAHC shall designate the person or persons it believes to be the Most Likely Descendent (MLD) of the decreased Native American. The MLD may make recommendations to the landowner or person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code Section 5097.98. The City and developer shall work with the designated MLD to determine the final disposition of the remains.

Analysis of the Proposed Project
The 2018 EIR identified potential impacts to historical, archeological and paleontological resources resulting from development of the project site and offsite improvements.

Development under either the 2018 Project or proposed Project would result in grading of the entire site, disturbance of off-site improvement locations, and equivalent earth moving activities.

The proposed Project will disturb largely the same area of land analyzed in the 2018 EIR, except for the offsite water line utility extension which would disturb an additional mile of land within the Palm Drive and Dillon Road rights-of-way. Although portions of the proposed water line extension were not previously considered as part of the project impact area in the 2018 EIR, new improvements would occur within existing roadway rights-of-way that are currently disturbed, and in which utility trenches have previously occurred. Therefore, the possibility of cultural resources being present in these areas is considered negligible.

Should cultural resources be located on the site during grading and excavation, the impacts to these resources would be considered significant, consistent with the findings of the 2018 EIR. In order to reduce these impacts to less than significant levels, the proposed Project will be required to implement Mitigation Measures CR-1 through CR-5 set forth in the 2018 EIR.

Item Number: 1.

66 Overall, the proposed Project will not result in any new significant impacts or increase the severity of impacts already identified in the EIR. Development conducted pursuant to the mitigation measures set forth in the 2018 EIR, and in adherence to existing federal, state, and City regulations will ensure potential impacts associated with cultural resources are reduced to less than significant levels, and equivalent to those previously analyzed.

Cumulative Impacts
The proposed Project will be required to implement Mitigation Measures CR-1 through CR-5 set forth in the 2018 EIR, thus reducing all potential impacts to less than significant levels, including cumulative impacts. Cumulative impacts to cultural resources would be equivalent to those identified and studied in the 2018 EIR, and would not be cumulatively considerable.

3.6. GEOLOGY AND SOILS
Summary of Findings in the 2018 EIR (Section 4.6, page 4.6-1 et.seq.) The 2018 EIR obtained information for this section from the geotechnical investigation entitled Geotechnical Engineering and Infiltration Update Report; Tentative Tract Map No.37185; SWC Varner Road and West Drive; Desert Hot Springs, Riverside County, California, prepared by Earth Systems Southwest, February, 2017 (Appendix E-1 of 2018 EIR), and the Natural Resources Conservation Services (NRCS), Custom Soil Resource Report for Riverside County, Coachella Valley Area, California, Desert Land Ventures Specific Plan Area, June 2017 (Appendix E-2 of 2018 EIR).

Background/Geologic Setting
As described in the 2018 EIR, the project site is located in the northwestern portion of the Coachella Valley, a part of the Colorado Desert geomorphic province. A significant feature within the Colorado Desert geomorphic province is the Salton Trough. The Salton Trough is a large northwest-trending structural depression that extends approximately 180 miles from the San Gorgonio Pass to the Gulf of California. The Coachella Valley forms the northerly part of the Salton Trough and contains a thick sequence of Miocene to Holocene sedimentary deposits.

Mountains surrounding the Coachella Valley include the Little San Bernardino Mountains and San Bernardino Mountains on the northwest, and the Santa Rosa and Jacinto Mountains to the south and southwest. These mountains expose primarily Precambrian metamorphic and Mesozoic granitic rocks. The San Andreas Fault zone within the Coachella Valley consists of the Banning fault, Garnet Hill fault, North/South branches of the San Andreas Fault, and the Mission Creek fault that traverse along the northeast margin of the Valley.

Elevation at the center of the project site is approximately 652 feet above mean sea level (amsl).

However, the site is generally undulated with a range on the order of two feet. Surface drainage occurs via sheet flow from northwest to southeast. Vegetation consists of Sonoran Creosote Brush Shrub. The upper sediments observed primarily consist of native alluvial fan deposits associated with deposition of Mission Creek and Morongo Wash. Broad and coalesced alluvial fans emanating from the San Bernardino and Little San Bernardino Mountains underlie the site.

Item Number: 1.

67 There are isolated areas with artificial fill which overlay the alluvial fan deposits. These areas of artificial fill are typically associated with fill and spoils placed during construction of any existing site improvements such as Varner Road, dirt roads, above and below ground utilities and with dumping of trash and debris (concrete chunks, wood, grass, metal, etc.).

Soils and Geologic Units
The 2018 EIR described local soils as consisting of interbedded sands and gravels. The U.S.

Department of Agriculture Natural Resource Conservation Service mapped three different types of sand all formed in alluvium within the project site: Carsitas gravelly sand, 0 to 9 % slopes (CdC), at the northwestern corner of the project site; Carsitas fine sand, 0 to 5 % slopes (CkB), cover the edges of the northeastern corner of the site; and Carsitas cobbly sand, 2 to 9 % slopes (ChC), cover the remainder of the project site. CdC is moderately susceptible to water erosion and slightly susceptible to wind erosion. Both CkB and ChC are slightly susceptible to water erosion and highly susceptible to wind erosion.

Seismicity and Faulting
As described in the 2018 EIR, the project site does not lie within a currently (2018) delineated State of California Alquist-Priolo Earthquake Fault Zone. However, the Garnet Hill segment of the San Andreas Fault is located approximately 0.14 miles southwest of the project site, the southern branch or Banning segment of the San Andreas Fault is located approximately 0.7 miles southwest of the project, and the northern branch of the San Andreas Fault is approximately 4.2 miles to the northeast of the project site.

Geologic Hazards
The 2018 EIR described four geologic hazards that could expose people or structures to potentially adverse effects, including fault rupture, seismic ground shaking, seismic related ground failure (including liquefaction), landslides, erosion or loss of top soil, • Rupture of a Known Fault: The 2018 EIR determined that potential impacts from fault rupture would be less than significant because the project site does not lie within a currently delineated State of California, Alquist-Priolo Earthquake Fault Zone. • Strong Seismic Ground Shaking: The 2018 EIR determined a major earthquake above magnitude 7 or 8 originating on the local segment of the San Andreas or nearby fault zones would be the critical seismic event to induce severe seismic ground shaking that may affect the project site within the design life of the project. Therefore, incorporation of Regulatory Requirement RR-7 in designing and constructing all proposed structures in compliance with the current California Building Code, would reduce potential impacts induced by strong seismic ground shaking to a less than significant level. • Seismic-Related Ground Failure, Including Liquefaction: The 2018 EIR determined that site soils were generally dry to damp with moisture contents less than approximately one percent and historic groundwater depth was below 50 feet, therefore liquefaction potential is low due to the deep groundwater depth. Other geologic hazards, including lateral spreading and seismically induced flooding, were also considered low.

Nonetheless, the EIR concluded that incorporation of Mitigation Measure GEO-1 Item Number: 1.

68 requiring appointment of a licensed geotechnical engineer to observe site grading, grading and the bottoms of the excavations before placing fills, would reduce potential impacts from seismic-related ground failure, including liquefaction to a less than significant level.
• Landslides: The 2018 EIR determined the potential impacts from landslides are less than significant because the project site is on generally flat, level land, and more than four miles away from the base and foothills of all surrounding mountains and is not within a landslide susceptibility zone.

Erosion or Loss of Top Soil
As described in the 2018 EIR, the project site is located within an area of moderate to high potential for wind and water erosion and during construction of the project, soils would be disrupted during grading activities, exposure of uncovered soils, thereby increasing the potential for wind or water-related erosion and sedimentation until the construction is completed.

Mitigation measures for the control of fugitive dust and water erosion are included in other sections of the Draft EIR, specifically Mitigation Measures AQ-2 (Air Quality) and HWQ-1 (Hydrology and Water Quality), and would reduce impacts associated with soil erosion to a less than significant level.

Geologic Unit Stability
The 2018 EIR identified site soils as non-uniform and generally in a medium to dense compact condition. Due to the general uniformity of the soils encountered, seismic settlement is expected to occur within the project site. Therefore, the EIR incorporated Mitigation Measure GEO-2, requiring overexcavation and recompaction of site soils in accordance with specifications outlined in the Geotechnical Engineering and Infiltration Updated Report, thus reducing potential impacts to a less than significant level.

Seismically induced flooding which might be considered a potential hazard to a site, normally includes flooding associated with a tsunami (large sea waves), a seiche (i.e. a wave-like oscillation of the surface of water in an enclosed basin that may be initiated by a strong earthquake) or failure of a major reservoir or retention structure upstream of a site. The EIR identified two water storage tanks located approximately five miles north of the project site. In the event of a tank rupture due to seismic activity there is a remote possibility of some flooding at or near the project site, depending on localized drainage courses and man-made modifications to drainage paths should a water tank rupture occur. The DLVSP includes drainage improvement solutions to address the area’s drainage and flooding issues from off-site flows. The DLVSP also included the development of two water tanks at the northwest corner of the site in PA1 and PA2. The EIR concluded that incorporation of Regulatory Requirement RR-7 (compliance with CA Building Code) would reduce the potential impacts from flooding, tsunami, seiche, and slope instability to a less than significant level.

Regarding subsidence, the 2018 EIR determined that the project site does not lie in an area where damaging subsidence related settlement has occurred, but that incorporation of Mitigation Measure GEO-1 (preparation of a building-specific Geotechnical Report) would reduce impacts from subsidence on the project site to a less than significant level.

Item Number: 1.

69 The Geotechnical Engineering and Infiltration Updated Report prepared for the 2018 EIR indicated that the project site is located in a geologic environment where the potential for collapsible soil exists. The EIR incorporated Mitigation Measures GEO-2 for the over excavation and recompaction of site soils, and GEO-3 and GEO-4 requiring procurement and implementation of engineered fill soils in accordance with the Geotechnical Engineering and Infiltration Updated Report, and the addition of significant water to project site soils for compaction purposes, thus reducing the potential collapsible soil impacts to less than significant levels.

A corrosive soils test was also conducted as part of the 2018 EIR in accordance with the ASTM test methods. The corrosion values from the soil tested are normally considered as being “Very Mildly to Moderately Corrosive” to buried metals and as possessing a “Negligible” exposure to sulfate attack on concrete; however, the corrosion values can potentially change based on several factors, such as importing soil from another site and the quality of construction water used during grading and subsequent landscape irrigation. Implementation of Mitigation Measure GEO-5 requiring appointment of a licensed engineer competent in corrosive mitigation to review results conducted by Earth Systems South West, as well as appointment of a licensed engineer to evaluate corrosive results in relation to other corrosive constituents that may be of concern such as nitrates, ammonium, etc., would reduce impacts in regards to corrosive soils to a less than significant level.

Expansive Soils
As described in the 2018 EIR, soils observed on the project site were granular, indicating that site soils have no clay content. Furthermore, the Expansion Index of the project site soils is anticipated to be “very low” as defined by ATSM D 4829. The EIR determined that samples of soils at building pads should be observed or tested during grading to confirm or modify these findings. Potential impacts from expansive soils located on the project site were mitigated to less than significant levels with incorporation of Mitigation Measures GEO-1 and GEO-3.

Septic Tank or Alternative Water Disposal Systems
No wastewater infrastructure or systems exist on or in the vicinity of the project site. The project site lies within the Coachella Valley Water District’s (CVWD) service area. The DLVSP included the provision of a centralized package plant system in the southeastern end of the project site. The EIR stated that prior to development of an onsite wastewater treatment system, the proponent must have an Onsite Wastewater Treatment System (OWTS) report prepared by a registered civil engineer, registered engineering geologist or registered environmentalist health specialist who has expertise in designing onsite wastewater treatment systems. The 2018 EIR determined that implementation of the Mitigation Measures UT-1 (Utilities and Service Systems), HWQ-3 would reduce impacts associated with soils incapable of adequately supporting alternative water disposal system to less than significant levels.

At the time the 2018 EIR was prepared, the MSWD Regional Wastewater Treatment Plant to be located at the intersection of Little Morongo Road and 20th Avenue was planned to be operational within the two years. In order for the project site to be served by MSWD, CVWD and MSWD would enter into an agreement whereby CVWD relinquishes the right to serve the project site in favor of MSWD. CVWD staff indicated they would support, subject to CVWD Board of Item Number: 1.

70 Directors approval, service to be provided by MSWD for the DLVSP project, due to its proximity to MSWD facilities and lower cost to provide infrastructure for service. The 2018 EIR explained that project entitlements would assume service by MSWD subject to a future interagency agreement with CVWD or an annexation into MSWD’s service area through LAFCO (following entitlement). The implementation of a sewer connection to the MSWD plant would eliminate geologic impacts associated with the project.

Cumulative Impacts
The 2018 EIR determined that with implementation of RR-1 and Mitigation Measures GEO-1 through GEO-5 and with adherence to City goals and policies as identified above, cumulative impacts to geology and soils were expected to be less than significant.

Summary of Impacts
Overall, the 2018 EIR found the potential impacts related to geology and soils would be less than significant with implementation of mitigation measures. The City requires compliance with the Uniform Building Code (UBC), which was expected to enable structures to resist major earthquakes without collapsing, although structural damage could occur. The City also requires site-specific soils and/or geotechnical analyses that include an evaluation of seismic and soil conditions and provide recommendations that mitigate geotechnical hazards.

Mitigation Measures
The following Mitigation Measures and Regulatory Requirements are from pages 4.6-11 and -12 of the 2018 EIR.

GEO-1 The project applicant(s) shall appoint a licensed Geotechnical Engineer to observe site clearing, grading and the bottoms of excavations before placing fill, with the additional implementation of preventative measures into the site grading plans to reduce seasonal flooding and erosion.

GEO-2 The project applicant(s) shall ensure that overexcavation and recompaction of site soils are performed in accordance with the specifications outlined in the Geotechnical Engineering and Infiltration Update Report, or most recent geotechnical report, and the stipulations of the appointed licensed Geotechnical Engineer assigned to the Specific Plan to mitigate excessive dry seismic settlement.

GEO-3 The project applicant(s) shall ensure that the procurement and implementation of engineered fill soils are in accordance with the specifications outlined in the Geotechnical Engineering and Infiltration Update Report, or most recent geotechnical report, in order to mitigate the potential impacts of subsidence, and collapsible and expansive soils.

GEO-4 The project applicant(s) shall ensure that sufficient water is added to soils for compaction purposes, in accordance with the recommendation of the Geotechnical Engineering and Infiltration Update Report, or most recent geotechnical report.

Item Number: 1.

71 GEO-5 The project applicant(s) shall appoint a licensed engineer competent in corrosion mitigation review of corrosive results conducted by Earth Systems South West, to design corrosion protection appropriately. Additionally, a competent engineer in corrosion analysis shall also be appointed to evaluate the corrosive results in relation to other corrosive constituents that may be of concern such as nitrates, ammonium, etc.

Regulatory Requirements
RR-7 All proposed structures shall be engineer designed and constructed to earthquakeresistant parameters in compliance with the 2016 edition of the California Building Code (CBC).

Analysis of the Proposed Project
The 2018 EIR analyzed maximum buildout potential under the DLVSP. The site would be fully developed, with the exception of a portion of the conservation area, regardless of buildout scenario (2018 DLVSP or proposed Project). The same mitigation measures associated with stabilizing soils and assuring adequate geotechnical design would apply to the proposed Project.

The proposed Specific Plan would reduce the maximum development intensities, including site density and building heights, and therefore the Project would not generate new significant impacts or a substantial increase in previously identified impacts associated with geology and soils. Instead, impacts would less intense due to these reductions.

Adherence to the City’s Municipal Code, General Plan policies, Project-specific Geotechnical Report, and mitigation measures contained in the EIR would result in less than significant impacts, including cumulative impacts, consistent with the findings of the EIR. Therefore, implementation of the proposed Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the 2018 EIR.

3.7. GREENHOUSE GAS EMISSIONS
Summary of Findings in the 2018 EIR (Section 4.7, page 4.7-1 et.seq.) The 2018 EIR described the existing setting regarding the generation of Greenhouse gasses, and the potential impacts that may occur with implementation of the DLVSP. Prominent greenhouse gasses contributing to this process include carbon dioxide (CO2), methane (CH4), ozone, water vapor, nitrous oxide (N2O), and chlorofluorocarbons (CFCs).

The DLVSP is within the SSAB, and the portion of the SSAB encompassing the project site is regulated by the SCAQMD, the agency principally responsible for comprehensive air pollution control in the South Coast Air Basin, as well as all of the Coachella Valley. SCAQMD develops rules and regulations, establishes permitting requirements for stationary sources, inspects emission Item Number: 1.

72 sources, and enforces such measures through educational programs or fines, when necessary.

SCAQMD is directly responsible for reducing emissions from stationary, mobile, and indirect sources.

Since neither CARB nor the Governor’s Office of Planning and Research (OPR) had developed GHG emissions threshold, SCAQMD formed a Working Group to develop significance thresholds related to GHG emissions. In 2018, the most current version of the draft GHG emissions thresholds recommended a tiered approach that provides a quantitative annual threshold of 10,000 MTCO2e for industrial uses. SCAQMD was in the process of preparing recommended significance thresholds for greenhouse gases for local lead agency consideration; however, the SCAQMD Board had not approved the thresholds as of the date of the of the Draft DLVSP EIR.

The draft thresholds consisted of the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.
• Tier 2 consists of determining whether the project is consistent with a greenhouse gas reduction plan. If a project is consistent with a qualifying local GHG reduction plan, it does not have significant greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to a project’s operational emissions. If a project’s emissions are under one of the following screening thresholds, then the project is less than significant:
o All land use types: 3,000 MTCO2e per year.
o Based on land use type: residential: 3,500 MTCO2e per year; commercial: 1,400 MTCO2e per year; or mixed use: 3,000 MTCO2e per year.
o Based on land type: Industrial (where SCAQMD is the lead agency), 10,000 MTCO2e per year.
• Tier 4 has the following options:
o Option 1: Reduce emissions from business as usual (BAU) by a certain percentage; this percentage is currently undefined.
o Option 2: Early implementation of applicable AB 32 Scoping Plan measures. o Option 3, 2020 target for service populations (SP), which includes residents and employees: 4.8 MTCO2e/SP/year for projects and 6.6 MTCO2e/SP/year for plans; o Option 3, 2035 target: 3.0 MTCO2e/SP/year for projects and 4.1 MTCO2e/SP/year for plans
• Tier 5 involves mitigation offsets to achieve target significance threshold.

The SCAQMD’s draft threshold uses the Executive Order S-3-05 goal as the basis for the Tier 3 screening level. Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations at 450 parts per million (PPM), thus stabilizing global climate. To determine whether implementation of the DLVSP would result in significant impacts, the GHG analysis used the SCAQMD draft local agency tier 3 threshold of 3,000 MTCO2e per year for all land use types.

Item Number: 1.

73 City of Desert Hot Springs Climate Action Plan
The City of Desert Hot Springs adopted a Climate Action Plan (CAP) in May of 2013 to set forth goals to reduce emissions to achieve the targets of AB 32. The CAP identifies that the community would have to reach a 36.4 percent reduction from Year 2010 baseline emissions or a 43.2 percent reduction from Year 2020 business-as-usual emissions by the year 2020 in order to reach the AB 32 target emissions. The CAP targets are based on a predicted population growth rate of 83 percent between 2010 and 2020. However, according to the Census Bureau, the population of Desert Hot Springs was estimated to be 27,049 in April 2010 and 28,164 in July 2014; which shows a growth rate of 4.1 percent; therefore the City of Desert Hot Springs would have to increase its population by 78.9 percent by 2020 to validate the reduction target percentage.

The City of Desert Hot Springs identified 80 measures to be implemented over the course of an eight year period, beginning in 2013, in order to achieve their emission reduction goals. The City promotes energy efficiency and conservation in all areas of community development, including transportation, development planning, and public and private sector construction and operation, as well as in the full range of residential and non-residential projects.

DLVSP GHG Emission Impacts
The 2018 EIR based the greenhouse gas impact analysis on the Desert Land Ventures Air Quality and Global Climate Change Impact Analysis, July 2017, prepared by Kunzman Associates (Appendix B of 2018 EIR). CalEEMod Version 2016.3.2 was used to project GHG emissions. Please refer to Section 3.3, Air Quality for detailed CalEEMod assumptions for the DLVSP.

Implementation of the DLVSP was anticipated to generate GHG emissions from area sources, energy usage, mobile sources, waste, water, and construction equipment. As presented in the 2018 EIR, the unmitigated GHG emissions would be 41,990.35 MTCO2e per year and the mitigated GHG emissions would be 29,954.52 MTCO2e per year.4 The 2018 EIR concluded that
with incorporation of Mitigation Measures GHG-1 through GHG-8, these emissions would still exceed the SCAQMD draft local agency tier 3 threshold of 3,000 MTCO2e per year for all land use types. Therefore, the DLVSP’s GHG emissions were considered to be significant and unavoidable. 4 The emission quantities cited are consistent with findings in the 2018 EIR Appendix B, Air Quality and Greenhouse Gas Report, and EIR Tables 4.7-1 and -2. However, the 2018 EIR Section 4.7 Greenhouse Gas Emissions text references the incorrect quantities (39,533.48 MTCO2E and 30,535.24 MTCO2E). This oversight does not change the EIR conclusions, impacts would remain significant and unavoidable.

Item Number: 1.

74 Table 6
2018 EIR Mitigated GHG Emissions
Summary
(Metric Tons)
Source CO2e (MT/YR)
Area 0.04
Energy 1,806.70
Mobile 19,986.15
Waste 287.29
Water 1,748.19
Sequestration -15.47
Construction 141.63
Total Operational 29,954.52
SCAQMD Threshold 3,000
Exceeds Threshold? Yes
Source: Table 4.7-3 of 2018 EIR.

The 2018 EIR also assessed the DLVSP consistency with applicable measures in the City’s CAP and with SB 32, which requires the State board to ensure that statewide greenhouse gas emissions are reduced by 40 percent below the 1990 level by 2030. The 2018 EIR determined the DLVSP SP was consistent with the CAP measures, as shown in EIR Table 4.7-4, reproduced below, but was inconsistent with SB 32 because the DLVSP’s mitigated emissions exceed the SCAQMD GHG emissions thresholds of 3,000 MTCO2e per year for all land use types. Therefore, the 2018 EIR concluded that the DLVSP greenhouse gas impacts were considered to be significant and unavoidable.

Item Number: 1.

75 Item Number: 1.

76 Cumulative Impacts
The 2018 EIR declared that evaluation of greenhouse gases for a project is an evaluation of a project’s contribution to global climate change. Therefore, the 2018 EIR determined no additional analysis was required.

Mitigation Measures
The following Mitigation Measures are from pages 4.7-23 and -24 of the 2018 EIR.

GHG-1 The project applicant(s) shall implement onsite sustainability design features, including solar panels on all industrial building rooftops (except cultivation buildings) and carport shade structures, and a solar farm and/or wind farm that will provide at least 10 percent of the DLVSP’s electrical energy needs.

GHG-2 The project applicant(s) shall ensure that all faucets, toilets and showers installed in the proposed structures utilize low-flow fixtures that would reduce indoor water demand by 20 percent per CalGreen Standards, water-efficient landscaping practices are employed onsite.

GHG-3 The project applicant(s) shall implementation of recycling programs that reduce waste to landfills by a minimum of 75 percent (per AB 341).

GHG-4 The project applicant(s) shall ensure that high-efficiency lighting (such as LED lighting that is 34 percent more efficient than fluorescent lighting) be installed onsite.

GHG-5 The project applicant(s) shall ensure that employee vanpool/ride share programs are provided for at least 80 percent of onsite employees.

GHG-6 The project applicant(s) shall ensure that the re-application of architectural coatings to protect buildings is limited to 10 grams per liter VOC, and traffic paints are limited to 100 grams per liter VOC content.

Item Number: 1.

77 GHG-7 The project applicant(s) shall provide sidewalks onsite.

GHG-8 The project applicant(s) shall require that all building structures meet or exceed 2016 Title 24, Part 6 Standards and meet 2016 Green Building Code Standards.

Analysis of the Proposed Project
Greenhouse gas emissions associated with buildout of the proposed Specific Plan would be less than those previously analyzed in the EIR due to the reduction in overall development density and building square footage. As shown in Table 7, maximum buildout potential of the proposed Specific Plan (1.5 million square feet) under mitigated conditions would result in 19,038.53 MTCO2E, which is an emission reduction of 36.4 percent compared to the maximum mitigated buildout emissions analyzed in the 2018 EIR. Furthermore, the proposed industrial development proposed under the Design Review for the site, at 1,160,989 square feet, represents a 22 percent reduction in maximum buildout potential under the proposed Specific Plan, which would further reduce GHG emissions.

Table 7
Projected Mitigated GHG Emissions Summary
(Metric Tons)
Source 2018 EIR Proposed
CO2e (MT/YR)
Area 0.04 22
Energy 1,806.70 4,412
Mobile 19,986.15 14,139
Waste 287.29 112
Water 1,748.19 27.7
Sequestration -15.47 --
Refrigerants -- 3.23
Off-Road -- 0
Stationary -- 156
Construction 141.63 166.61
Total Operational 29,954.52 19,038.53
SCAQMD Threshold 3,000
Net Difference 10,915.99 MTCO2e reduction
compared to 2018 Project

1. Buildout construction GHG emissions were amortized over 30-years then added to buildout operational GHG emissions. 4,997/30 = 166.6 As stated in the 2018 EIR, evaluation of greenhouse gases for a project is an evaluation of a project’s cumulative contribution to global climate change. Implementation of the proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact as analyzed in the EIR. Overall impacts are expected to be less than those Item Number: 1.

78 previously identified in the EIR due to the reduction in overall development intensity and square footage proposed in the Specific Plan and proposed development project. Impacts are expected to remain significant and unavoidable, however, because of the number of vehicle trips associated with the proposed Project, when compared to SCAQMD thresholds. Because the Specific Plan and proposed Project are consistent with the analysis of the EIR, however, the Findings and Statement of Overriding Considerations which applied in the 2018 EIR are applicable to the currently proposed Project.

3.8. HAZARDS AND HAZARDOUS MATERIALS
Summary of Findings in the 2018 EIR (Section 4.8, page 4.8-1 et.seq.) Sources used in the preparation of this section in the 2018 EIR included the EPA, California Department of Toxic Substances Control, Riverside County Department of Environmental Health, and the City of Desert Hot Springs General Plan.

As described in the 2018 EIR, hazardous materials are under the jurisdiction of various federal and state agencies and programs which regulate the use, storage, and transportation of hazardous materials. Regulations can be used to reduce or mitigate the danger that hazardous substances may pose to residents, businesses, and visitors, both in normal day-to-day conditions and as a result of a regional disaster.

Construction Impacts
The 2018 EIR determined that the risk of accidental release of hazardous substances during construction activities would be less than significant with compliance with applicable federal, State, and local statutes and regulations regarding transportation, storage, use, and disposal of hazardous materials. This includes preparation of a SWPPP, implemented with Regulatory Requirement RR-8 (see Section 3.9, Hydrology and Water Quality).

Operations Impacts
Mixed-Use Commercial: The 2018 EIR did not anticipate that hazardous waste from mixed-uses would be generated in quantities that would be significant. Waste would be typical of commercial and retail uses, with hazardous materials limited to cleaning products.

Industrial: The 2018 EIR assumed the potential operation of a cannabis cultivation facility which would generate agricultural wastewater which contains nitrates, and other raw elements that cannot be recycled. The types of wastewater treatment options were not known at the time, so the EIR examined two options: reverse osmosis (RO) and hydroponics. Mitigation Measure HAZ1 was provided in the event a cultivation project utilized an RO system for wastewater recycling, and Mitigation Measure HAZ-2 would ensure that cultivation projects utilizing a hydroponic grow system wastewater treatment would reduce impacts to less than significant levels.

Item Number: 1.

79 The 2018 EIR determined industrial operations may result in the storage of hazardous materials in various quantities and type (i.e., solvents, acids, paints, refrigerant gases, etc.), dependent on the type of use that would occupy each building within each future project. Implementation of Regulatory Requirements RR-9 and RR-10, requiring applicable individual project activities to be operated under all current regulations to prepare a Hazardous Materials Business Emergency Plan (HMBEP) and a Spill Prevention Control and Countermeasures Contingency Plan (SPCC), would ensure that the necessary procedures and protocols are in place and exercised in regard to the safe transportation and safe containment and handling of hazardous materials during operation of the project. The 2018 EIR concluded that impacts associated with accidental release of hazardous substances would be less than significant.

School Hazards
The 2018 EIR determined there are no schools within a quarter-mile radius of the project site.

The EIR noted that the nearest school to the project site is Rio Vista Elementary School, located approximately 2.95 miles southeast of the project site, and the nearest child care facility, Coyote Run Headstart, is located approximately 2.2 miles southwest of the project site. Nonetheless, implementation of Regulatory Requirements RR-9 and RR-10, requiring applicable individual project activities to provide an HMBEP and SPCC would ensure that an accidental release, or spill of hazardous materials onsite would be contained and secured.

Hazardous Materials Sites pursuant to Government Code Section 65962.5 The 2018 EIR determined the site was not located on the “Cortese” list of hazardous materials sites, as compiled and pursuant to Government Code Section 65962.5. The EIR noted that hazardous materials at the site are associated with past construction and household debris, however these materials do not constitute a hazardous materials site. Impacts were found to be less than significant.

Airport Hazards
The 2018 EIR determined the site is not located within two miles of a public airport or a private airstrip and there would be no impacts.

Emergency Response Plan
The City of Desert Hot Springs contracted with Riverside County Fire Department for emergency services. The City prepared an Emergency Operations Plan (EOP) in 2008 that addresses the planned response to extraordinary emergency situations associated with natural disasters, technological incidents, and national security emergencies in or affecting the City. The City was also involved in the Community Emergency Response Team (CERT) program.

The 2018 EIR explained that all phases of project development with regard to parking and accessibility would be subject to review by the City’s Engineering Division and the County Fire Department and that service, loading, and shipping and receiving areas in future development within the project site must be designed in a manner that emergency service vehicles have clear and convenient access and do not block adjacent vehicular circulation. The EIR included Regulatory Requirement RR-11 regarding Fire Department review of all projects and concluded Item Number: 1.

80 that the project would not interfere with the existing EOP and CERT protocol. Impacts were found to be less than significant.

Risk of Wildfire
The 2018 EIR determined the project would have no impact with regard to wildland fires due to the sites inland location, desert landscape, and the site is not listed as Fire Hazard Severity Zone according to the CALFIRE Riverside County (WEST) Fire Hazard Severity Zone in State Responsibility Area Map.

Cumulative Impacts
The 2018 EIR determined buildout of the DLVSP does not have the potential to create cumulative impacts associated with hazards and hazardous materials to the public from routine transport, use, or disposal, and in regard to conflict with emergency response and evacuation plans.

Mitigation Measures HAZ-1 through HAZ-4 would ensure that all new development would comply with local, State, and federal regulations; California Health & Safety Code and Title 19; Division 2, of the California Code of Regulations (CCR) by preparing a HMBEP, the preparation of a SPCC and for required plan review and conditioning by the Fire Department. Therefore, with implementation of all mitigation and regulatory requirements and with adherence to goals, policies and programs as identified in the EIR, cumulative impacts were found to be less than significant.

Mitigation Measures
The following Mitigation Measures and Regulatory Requirements are from pages 4.8-15 and -16 of the 2018 EIR.

HAZ-1 Prior to issuance of Certificate of Occupancy, the project applicant(s) that propose to recycle onsite wastewater involving the use of a reverse osmosis (RO) wastewater purification system shall provide the City with information on how concentrated levels of TDS and brine solutions will be disposed of. Proof of contract with a licensed hazardous waste hauler that will be responsible for removing all hazardous wastewater and solid waste generated at the cultivation site will be required.

HAZ-2 Prior to construction of any new building where cannabis cultivation utilizing a hydroponic growing system is proposed, the project applicant(s) shall provide the City and the Riverside County Department of Environmental Health with a detailed description of the project’s proposed treatment for wastewater discharge associated with cultivation. This description shall include how the project applicant(s) will test and dispose of wastewater to the onsite centralized package treatment plant.

Regulatory Requirements
RR-8 Prior to issuance of building permits on vacant or undeveloped parcels within the project site, the project applicant(s) shall prepare a Storm Water Pollution Prevention Plan (SWPPP) for all developments that disturb one acre or more. The SWPPP shall provide a list of Best Management Practices (BMPs) for the control and treatment of runoff from the project site.

Item Number: 1.

81 RR-9 Prior to each Certificate of Occupancy in compliance with Chapter 6.95 of the California Health & Safety Code (HSC) and Title 19, Division 2, of the California Code of Regulations (CCR), the project applicant(s) shall prepare a Hazardous Materials Business Emergency Plan (HMBEP) for all new development projects that include the storage and use of hazardous materials at or above reporting criteria thresholds. The HMBEP shall be reviewed and approved by the County of Riverside CUPA and the Department of Environmental Health prior to operation of the business.

RR-10 Prior to each Certificate of Occupancy, the project applicant(s) shall prepare a Spill Prevention Countermeasures Contingency Plan (SPCC) that addresses appropriate protocol measures to contain accidental spills of hazardous materials for all new development projects that include the use and storage of hazardous materials. A SPCC spill kit shall also be placed onsite at the business or facility. The SPCC shall be reviewed and approved by the County of Riverside CUPA and the Department of Environmental Health prior to operation of the business.

RR-11 As part of the City’s Development Review process, the project applicant(s) shall submit plans to the Fire Department for review and conditioning for safe accessibility of fire and ambulatory services, and for appropriate evacuation routing of the project development in the event of an emergency.

Analysis of the Proposed Project
The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. Buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space previously analyzed in the 2018 EIR.

Handling, Storage, and Disposal of Hazardous Waste
Construction of the Project could involve the use of some hazardous and flammable substances, such as vehicle fuels and oils for the operation of heavy equipment. Other materials required for the potential emergency maintenance of heavy equipment may also be required on-site during construction, however such materials would not be in quantities or stored in a manner that would pose a significant hazard to the public. All potentially hazardous materials used during construction of the proposed development must be stored, used, and disposed of in accordance with manufacturers’ instructions and handled in compliance with applicable federal, State, and local regulations. This includes preparation of a SWPPP, implemented with Regulatory Requirement RR-8
Once operational, the Project will likely use cleaners and solvents as part of daily cleaning and maintenance operations, but is not expected to transport, use or dispose of large quantities of hazardous materials. The Project does not propose a cold storage component within the warehouse facility, therefore the use, storage, or transport of refrigerants in large quantities is not anticipated. The Project would be subject to the same Regulatory Requirements, RR-9 and Item Number: 1.

82 RR-10, set forth in the 2018 EIR requiring applicable individual project activities to be operated under all current regulations to prepare a HMBEP and a SPCC to ensure that the necessary procedures and protocols are in place and exercised in regard to the safe transportation, safe containment and handling of hazardous materials during operation of the project. Therefore, impacts associated with accidental release of hazardous substances would be less than significant, and consistent with those identified in the 2018 EIR. The reduced scope of the proposed Project, and the lack of cannabis-related activities would assure that no new or increased severity of impacts would occur compared to those identified in the EIR.

Emergency Response
As with the 2018 EIR, all phases of project development are subject to review by City’s Engineering Division and the County Fire Department to ensure the project site is designed in a manner that emergency service vehicles have clear and convenient access and do not block adjacent vehicular circulation. The Project is subject to the same Regulatory Requirement RR-11 regarding Fire Department review of plans described in the 2018 EIR. The Project will not interfere with a local emergency response plan. Impacts would remain less than significant, and no new or increased severity of impacts would occur compared to those identified in the EIR.

Proximity to Schools
The subject property is not located in proximity to a school, and no new school has been constructed in the Project area since completion of the EIR. The nearest school to the Project site remains Rio Vista Elementary School, located approximately 2.95 miles southeast of the project site. Implementation of Regulatory Requirements RR-9 and RR-10 set forth in the 2018 EIR, requiring applicable individual project activities to provide an HMBEP and SPCC would ensure that an accidental release, or spill of hazardous materials onsite are contained and secured. No impacts to schools would occur, and no new or increased severity of impacts would occur compared to those identified in the EIR.

Hazardous Material Sites
The subject property is still not included on the list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. No impacts would occur, and no new or increased severity of impacts would occur compared to those identified in the EIR.

Wildfire
The California Department of Forestry and Fire Protection (CalFire) has mapped areas of significant fire hazards in the state through its Fire and Resources Assessment Program (FRAP).

There are no state responsibility areas or very high fire hazard severity zones in the Project vicinity. The nearest fire hazard severity zones are located several miles to the north, near Little Morongo Canyon. Buildout of the site is subject to the same General Plan policies and fire department requirements on fire safety and emergency access. There would be no impact as a result of the proposed Project relating to wildfires. No new or increased severity of impacts would occur compared to those identified in the EIR.

Item Number: 1.

83 Cumulative Impacts
As with the 2018 EIR, the development of the proposed Project does not have the potential to create cumulative impacts related to hazards and hazardous materials that would affect the public due to routine transport, use, or disposal. Additionally, it would not interfere with emergency response or evacuation plans. Adherence to regulatory requirements would ensure development of the project site would have less than significant cumulative impacts, consistent with findings in the 2018 EIR.

Summary of Impacts
Implementation of proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact as previously analyzed in the EIR, including cumulative impacts. Overall impacts are expected to be less intense than those previously identified in the EIR due to the reduction in development intensity and the elimination of cannabis cultivation activities. Therefore, implementation of the proposed Project would not result in any new adverse impacts or increase the severity of previously identified impacts in the Certified EIR.

3.9. HYDROLOGY AND WATER QUALITY
Summary of Findings in the 2018 EIR (Section 4.9, page 4.9-1 et.seq.) The 2018 EIR described the hydrologic conditions of the project area and the regulatory agencies’ responsibilities for flood plain management and hazards mitigation. The entire project site is located within the 100-year flood plain Zone A (no base flood elevations determined) per Flood Insurance Rate Map (FIRM) Map No. 06065C0895G dated August 28, 2008, receiving flows from the Mission Creek and Big Morongo Wash Watersheds. As described in the 2018 EIR, flooding hazards at the project site come from the alluvial watersheds in the mountains to the north. The three main streams that drain from the Little San Bernardino Mountains towards the project site are Morongo Wash, Long and East, and West Wide Canyons.

The Coachella Valley Water District (CVWD) was responsible for regional stormwater planning and development of regional facilities within the Coachella Valley, including the City of Desert Hot Springs and the DLVSP area. Planning, maintenance and construction of improvements for regional facilities falls within the broad management responsibilities with which CVWD is charged. The project site lies within the northwestern edge of the Coachella Valley Water District’s (CVWD) service area; however, CVWD had neither the infrastructure nor immediate plans to provide stormwater management facilities to the DLVSP area at the time the 2018 EIR was prepared.

Violations of Water Quality Standards or Waste Discharge Requirements The 2018 EIR discussed the regulatory requirements of preparing a SWPPP for the construction period (RR-8), and a post-construction WQMP (RR-12) that addresses potential runoff and ongoing maintenance of best management practices (BMPs) related to onsite drainage improvements. These requirements would ensure that impacts to water quality would be reduced to less than significant levels.

Item Number: 1.

84 Impacts to Groundwater Supplies
The 2018 EIR identified two potential water supply sources. The preferred option required a connection to MSWD’s existing 913 Pressure Zone via a 24-inch proposed water pipeline extending from the project site to the existing MSWD 24-inch water main line located at the intersection of Little Morongo Road and 20th Avenue, with two alignment options. Because the DLVSP site was in CVWD’s Water Service Area, a Water Service Agreement needed to be finalized between CVWD and MSWD in order to address roles of both agencies in providing potable water to the project site. Option 2 would involve drilling an onsite groundwater well located at the northwest corner of Planning Area 1 to provide onsite treatment, a ground storage reservoir, a pump station, a hydropneumatic tank, and water pipelines. The private well would serve development within the DLVSP site until such a time that the MSWD water line could be constructed.

A WSA was prepared for the DLVSP and included in the 2018 EIR. At build out, the DLVSP total indoor and outdoor domestic water demand was expected to be approximately 405.44 AFY, or

0.35 percent of the total water supply (114,600 acre-feet per year) for the CVWD service area in 2020; and would represent 0.20 percent of the total water supply (194,300 AFY) for the CVWD service area in 2040 as identified in the CVWD 2015 UWMP for the period from 2020 to 2040.

Project-specific estimates included water demand for industrial, commercial, and landscaping uses, as shown in EIR Table 4.9-1, below. It is important to note that the water use for industrial buildings was very high because of the cannabis cultivation component of the project at the time.

According to the 2018 EIR, there were enough water supplies to meet project demands under Option 1. Use of private wells under Option 2 created a potential for overdrafting groundwater basins. Since the project was anticipated to demand greater than 25 acre-feet annually, the applicant would be required to pay the Replenishment Assessment Charge (RAC) to contribute to CVWD’s groundwater replenishment program and reduce impacts associated with overdraft of the aquifer. Mitigation Measure HWQ-1 required the applicant to pay the RAC prior to commencement of well operation.

If either Option 1 (connecting to MSWD’s supply) or Option 2 (a well) was implemented, a Replenishment Assessment would need to be processed in accordance with the State Water Code prior to development. If approved by the State Water Resources Control Board (SWRCB), all water wells (under Option 2) would be required to be equipped with a water measuring device to be maintained by CVWD. Under Option 1, the proposed project would also require a water measuring device to be maintained by MSWD.

Item Number: 1.

85 The 2018 EIR concluded that implementation of State requirements and CVWD and MSWD monitoring of the project’s water supply source, full build out of the DLVSP would have a less than significant impact on groundwater resources.

Erosion or Siltation
The 2018 EIR determined that project drainage design and implementation of a WQMP (RR-12) and SWPPP (RR-8) would ensure that onsite stormwater runoff would not cause substantial erosion in the vicinity and impacts were found to be less than significant.

Stormwater Runoff Impacts
The 2018 EIR determined the total additional runoff generated by commercial development of the DLVSP was anticipated to be 196.6 cfs for a 100-year storm event. Nine drainage areas were proposed on the project site that would comply with the Stormwater Management and Discharge Controls outlined in Chapter 13.08 of the Desert Hot Springs Municipal Code. Onsite storm drains, drainage swales, catch basins, and infiltration basins would be developed to mimic an overall drainage path that was similar to the existing undeveloped condition, with all the project flows sheet flowing to the existing drainage swale along I-10. The infiltration basins would accommodate the 100-year 24-hour storm runoff volumes as required by the City. The 2018 EIR also found that the regional flood risk associated with the Zone A designation required that buildings be elevated above the base flood elevation to prevent inundation impacts, and included mitigation measure HWQ-2, to implement this requirement. The 2018 EIR determined runoff and flooding related impacts would be less than significant with the implementation of this mitigation measure.

Impacts to Water Quality
The 2018 EIR described two wastewater treatment options for cannabis cultivation: reverse osmosis (RO) or hydroponics. If RO was utilized, the applicant would be required to provide documentation to the City of how concentrated levels of TDS and brine solutions would be disposed of and the licensed entity that would be appointed in receiving the TDS waste, Item Number: 1.

86 implemented through Mitigation Measure HAZ-1. If hydroponics was utilized, prior to issuance of Certificate of Occupancy, any applicant that proposed to recycle and discharge onsite wastewater involving the use of a hydroponic grow system would be required to notify the City prior to initial discharge of hydroponic water media. Mandatory testing for hydroponic practices would be implemented through Mitigation Measure HAZ-2.

The 2018 EIR determined that implementation of Mitigation Measure HAZ-1 and HAZ-2 would ensure that TDS from cultivation practices would not enter the sewer system and impacts to water quality were determined to be less than significant. 100-Year Flood Hazard Area Impacts
The project site is located within FEMA Zone A on the effective FEMA FIRM panel (06065C0895G) which implies that the area is subject to one percent annual chance flooding of some unspecified depth, with no specific base flood elevations (BFEs) calculated or shown on the map. As described above, the 2018 EIR found that the regional flood risk associated with the Zone A designation required mitigation measure HWQ-2, to raise pads above the base flood elevation.

The DLVSP’s proposed land uses consisted of mixed industrial and commercial uses and open space/conservation, with no plans to develop any residential-dwelling uses. Therefore, development of the Specific Plan would not place housing within a 100-year flood hazard area and there would be no impacts.

Other Flooding and Inundation Risks
As described in the 2018 EIR, the project site is not located near a levee or a dam that would increase impacts associated with flooding if failure occurred. Impacts associated with flooding were found to be less than significant.

The project site is not near any large bodies of water, including above-ground storage tanks, so there would be no impact associated with seiche or tsunami. Also, the project site is not near the surrounding mountains and would not be impacted by potential mudflows.

Cumulative Impacts
The 2018 EIR determined the project would contribute to a cumulative increase in groundwater demand that could result in overdraft if no countermeasures were enforced. However, the applicant’s payment of the RAC would contribute to aquifer replenishment efforts and reduce the overall amount of water removed from the aquifer.

In addition, adherence to regulatory requirements would assure stormwater runoff and flooding impacts are not significant or cumulatively considerable.

Implementation of Mitigation Measures HAZ- 1 and HAZ-2 would ensure that TDS from cultivation practices proposed under the DLVSP project would not enter the sewer system and cause a cumulative impact to water quality in the area. Therefore, cumulative impacts were found to be less than significant.

Item Number: 1.

87 Summary of Impacts
As described above, the 2018 EIR found that potential significant impacts associated with water consumption and the FEMA Zone A designation would be significant, and required mitigation, provided in HWQ-1 and HWQ-2. All other hydrologic and water quality impacts would be less than significant and required no mitigation.

Mitigation Measures
The following Mitigations Measures and Regulatory Requirements are from pages 4.9-18 and -19 of the 2018 EIR.

HWQ-1 Because the proposed private wells on site are anticipated to pump more than 25 acre-feet per year from the aquifer, the project applicant will be required to pay the Replenishment Assessment Charge (RAC) to CVWD before issuance of a certificate of occupancy to contribute to groundwater replenishment efforts. The applicant shall provide proof of payment to the City before issuance of proof of occupancy and before start of project operations.

HWQ-2 All construction pads on the project site shall be elevated above the FEMA floodplain base flood elevations, consistent with the Regional Flood Protection Report.

The following mitigation from EIR Section 4.8, Hazards and Hazardous Materials, applied to Hydrology and Water Quality as well:

HAZ-1 Prior to issuance of Certificate of Occupancy, the project applicant(s) that propose to recycle onsite wastewater involving the use of a reverse osmosis (RO) wastewater purification system shall provide the City with information on how concentrated levels of TDS and brine solutions will be disposed of. Proof of contract with a licensed hazardous waste hauler that will be responsible for removing all hazardous wastewater and solid waste generated at the cultivation site will be required.

HAZ-2 Prior to construction of any new building where cannabis cultivation utilizing a hydroponic growing system is proposed, the project applicant(s) shall provide the City and the Riverside County Department of Environmental Health with a detailed description of the project’s proposed treatment for wastewater discharge associated with cultivation. This description shall include how the project applicant(s) will test and dispose of wastewater to the onsite centralized package treatment plant.

Regulatory Requirements
RR-12 Prior to issuance of building permits on vacant parcels within the DLVSP site, a WQMP for post-construction conditions shall provide a list of appropriate Best Management Practices (BMPs) for the control and treatment of runoff from the project site.

RR-13 Prior to issuance of grading permits, the project proponent must obtain a CLOMR from FEMA for the proposed development areas on the project site.

Item Number: 1.

88 RR-14 Prior to issuance of building permits, the project proponent must obtain a LOMR from FEMA to finalize the revised floodplain mapping.

The following regulatory requirement from Section 4.8 of the 2018 EIR, Hazards and Hazardous Materials, applied to Hydrology and Water Quality as well:

RR-8 Prior to issuance of building permits on vacant or undeveloped parcels within the project site, the project applicant(s) shall prepare a Storm Water Pollution Prevention Plan (SWPPP) for all developments that disturb one acre or more. The SWPPP shall provide a list of Best Management Practices (BMPs) for the control and treatment of runoff from the project site.

Analysis of the Proposed Project
The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. Buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space previously analyzed in the 2018 EIR.

The entire project site is located within the 100-year flood plain with no base flood elevations determined (Zone A) per Flood Insurance Rate Map (FIRM) Map No. 06065C0895G dated August 28, 2008, receiving flows from the Mission Creek and Big Morongo Wash watersheds.

Drainage and Stormwater Management
Off-Site Drainage Management
As described in the 2018 EIR, the site is subject to substantial off-site flows from regional drainage flowing through the Mission Creek and Big Morongo watersheds. In order to determine the potential level of impact associated with regional flows, and to assure that the currently proposed Project would be safe from flooding, a preliminary off-site drainage analysis was prepared, and is included in Appendix E5. The analysis was conducted to inform the on-site hydrology described below, and to serve as the basis for a request for a Conditional Letter of Map Revision (CLOMR) from FEMA. The analysis showed that with the proposed drainage design through, on and adjacent to the development site, the Project will not be negatively impacted by regional flows, and has been designed to assure that the building will be located above maximum projected water surface elevation. The improvements analyzed include the construction of a channel and retention basin on the northern parcel, north of Varner Road, connecting to a series of on-site basins to channel water to the south property line and off-site in a manner consistent with current conditions. As a result of these improvements, and as demonstrated in Appendix E, the Project will not have a significant impact on downstream flows and property. 5 “DHS Varner Road Preliminary Off-Site Drainage Analysis,” prepared by JE Fuller Hydrology and Geomorphology Inc., February 2025.

Item Number: 1.

89 On-Site Drainage Management
Based on the preliminary off-site drainage analysis described above, a project-specific Preliminary Hydrology Study was prepared by Hunsaker & Associates in February 2025 (Appendix F). According to the Study, the site contains one drainage area that encompasses 93.0 acres of on-site development areas and produces a 100-year storm peak flow rate of 212.1 cfs.

The Project would provide three (3) on-site stormwater infiltration basins that during the life of the project will comply with the Stormwater Management and Discharge Controls stipulated in Chapter 13.08 of the Desert Hot Springs Municipal Code. The provided basin capacities are sized to contain the 100-year, 24-hour duration storm event and therefore meet the City’s requirements on Stormwater Management and Discharge Controls and minimize the discharge and transport of pollutants associated with the new developments.

Two of the three infiltration basins proposed for the project site – Basin B and Basin D – are interconnected, with a concrete spillway in between. The concrete spillway was provided for the protection of the existing gas lines and was used to bypass the off-site storm runoff. The volumes below the spillways were used for on-site storm runoff infiltration. The basins are also proposed for low impact development (LID) and water quality treatment purposes. The water quality functions will be incorporated into the Project’s WQMP, to assure that sediments and pollutants do not contaminate surface or ground water resources. Overall, the drainage path is similar to the existing condition with all the Project flows exiting the site and sheet flowing to the existing drainage swale along I-10.

Water Resources/Demand
A Water Supply Assessment was prepared for the Project by Terra Nova Planning and Research in March 2025 (Appendix G). The WSA assumed maximum buildout potential of 1.5 million square feet of industrial warehousing and distribution space, of which 750,000 square feet was distribution/office space, and 750,000 square feet was storage space. In addition, the WSA assumed 384,199.20 square feet of irrigated landscape area, 38.7 acres (1,685,772 square feet) of open space/habitat conservation, and 21.7 acres (945,252 square feet) of roadway improvements with an additional 44,388.42 square feet of irrigated landscape area.

The projected indoor commercial and industrial unit usage for this WSA is based on the American Water Works Association Research Foundation’s (AWWARF) Commercial and Industrial End Uses of Water and the U.S. Energy Information Administration. The projected indoor commercial and industrial water demand for the Project totals 42.35 AFY as shown in Table 7 below.

Item Number: 1.

90 Table 8
Project Indoor Industrial Water Demand
Use Indoor
Area (ft2)
Water Demand
Factor(gal/SF/year)1
Water
Demand
(gpd)
Water
Demand
(AFY)
Distribution/Office Space 750,000 15 30,821.92 34.52
Storage Space 750,000 3.4 6,986.30 7.83
TOTAL 1,500,000 37,808.22 42.35 1 AWWARF Commercial and Industrial End Uses of Water, 2000. 2 Storage Space Water Demand: CBECS 2012 Water Consumption in Large Buildings Summary, February 2017.

The projected outdoor irrigation water usage is based on the Maximum Applied Water Allowance (MAWA) equation from Appendix D of Coachella Valley Water District’s (CVWD’s) Landscape Ordinance No. 1302.5, which meets the water conservation goals of the California Department of Water Resources (DWR) Model Efficient Landscape Ordinance (MWELO). The projected outdoor irrigation water demand for the Project is 30.59 AFY as shown Table 8 below.

Table 9
Project Outdoor Irrigation Water Demand
Planning Area Landscaped
Area (ft2)
ETo
(in/yr)1 ETAF2
Conversion
Factor (gal/ft2)
3 Water
Demand
(gpd)
Water
Demand
(AFY)
Project Site 384,199.20 83.34 0.45 0.62 24,474.92 27.42 Roadway
Improvements 44,388.42 83.34 0.45 0.62 2,827.71 3.17
TOTAL 428,587.62 27,302.63 30.59 1 Reference Evapotranspiration (ETo) for ETo Zone 5 from CVWD Landscape Ordinance 1302.5, Appendix C 2 Evapotranspiration Adjustment Factor (ETAF) from CVWD Landscape Ordinance 1302.5, Appendix D 3 Conversion Factor from CVWD Landscape Ordinance 1302.5, Appendix D The total projected water demand for the Project is 72.96 AFY, or 0.591 acre-feet per acre. The 2018 DLVSP project was projected to generate a demand of 405.44 AFY, meaning the proposed Project’s water demand of 72.96 AFY represents an 82 percent reduction in projected water demands previously analyzed in the 2018 EIR. Therefore, the current Project will represent a substantial reduction in impacts associated with the quantity of water consumed on the Project site.

According to the 2020 Coachella Valley Regional UWMP, CVWD’s projected 2025 urban water supply is 137,061 AFY, and the projected 2045 regional water supply is 164,966 AFY.

Approximately 90 percent of water supplies are expected to be groundwater and 10 percent are expected to be recycled water. Projections are based on existing water sources and expected future water supply projects or programs. The proposed Project’s water demand (72.96 AFY) is

0.05 percent of projected 2025 regional water supplies and 0.04 percent of projected 2045 regional water supplies. Therefore, there is substantial evidence that the Project will not substantially decrease local groundwater supplies or interfere with groundwater recharge such Item Number: 1.

91 that it would impede sustainable management of the basin. The Project includes irrigation requirements, including the use of water-efficient fixtures and drought-tolerant landscape materials, which will help reduce water demand over the long term. Impacts will be less than significant.

Finally, it must be noted that two components of the analysis contained in the 2018 EIR have changed, and will reduce the impacts associated with water resources. First, the building proposed currently is for a warehouse, not a cannabis operation, which will both reduce water consumption and the potential for water contamination from pesticides, fertilizers and water recycling. Second, the Project no longer plans to drill on-site wells, and will instead connect to the CVWD water system. By doing so, the Project will eliminate the potential impact of unregulated water extraction that was considered in the 2018 EIR, which will allow the balanced flow of domestic water to the site through the established public water system. Mitigation measures HWQ-1, HAZ-1 and HAZ-2 would not be required with the implementation of the proposed Project. Overall, impacts associated with water resources will be reduced when compared to those analyzed in the 2018 EIR.

Water Quality
The Project is subject to the same regulatory requirements described in the 2018 EIR of preparing a Stormwater Pollution Prevention Plan (SWPPP) for the construction period (RR-8), and a postconstruction Water Quality Management Plan (WQMP) (RR-12) that addresses potential runoff and ongoing maintenance of best management practices (BMPs) related to onsite drainage improvements. The implementation of existing regulations and standards will ensure that development of the Project will not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Impacts are expected to be less than significant.
100-Year Flood Hazard Area Impacts
The Project proposes industrial land uses and open space/conservation, with no plans to develop any residential-dwelling uses. Therefore, development of the Specific Plan will not place housing structures within a 100-year flood hazard area, as was the case in the 2018 EIR, and there will be no impacts.

Other Flooding and Inundation Risks
The project site is not located near a levee or a dam that would increase impacts associated with flooding if failure occurred. The project site is not near any large bodies of water, including aboveground storage tanks, so there will be no impact associated with seiche or tsunami. The project site is not near the surrounding mountains and will not be impacted by potential mudflows. The proposed Project will not change the level of impact because physical conditions on the site and in the region have remained consistent with what was analyzed in the 2018 EIR.

Cumulative Impacts
Similar to the 2018 EIR, all potential impacts to hydrology or water quality would be reduced to less than significant levels with adherence to standard regulatory requirements. However, the Project would eliminate the need for mitigation measures HWQ-1, HWQ-2, HAZ-1 and HAZ-2 Item Number: 1.

92 because the Project does not propose an on-site well or cultivation uses. Overall, cumulative impacts are expected to be less than those previously identified in the 2018 EIR, and will be less than significant.

Summary of Impacts
Implementation of the proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact as previously analyzed in the EIR, including cumulative impacts. Water demand will be reduced substantially based on the reduced intensity of development proposed in the Specific Plan. Development of the site would increase the amount of impervious surfaces in the City under both buildout scenarios. The Project will be required to comply with all City regulations, implement regional flood control measures to assure that no flooding occurs within the Project building, and control the 100-year storm on-site. The Project will also be required to prepare SWPPP and WQMP documents to prevent surface and ground water pollution. Buildout of the site is required to comply with local, state and federal regulations, and policies set forth in the General Plan and Municipal Code that pertain to the protection of local hydrology and water quality. The currently proposed Project will reduce impacts and eliminate the need for mitigation measures HWQ-1, HWQ-2, HAZ-1 and HAZ-2, but will comply with the Regulatory Requirements provided in the 2018 EIR, to assure that impacts are reduced to less than significant levels.

Overall impacts are expected to be less than those previously identified in the EIR. Therefore, implementation of the Specific Plan amendment and buildout of the Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the 2018 EIR.

3.10. LAND USE AND PLANNING
Summary of Findings in the 2018 EIR (Section 4.10, page 4.10-1 et.seq.) As described in the 2018 EIR, the DLVSP consists of approximately 123.4 acres of undeveloped open desert land with shrubs, boulders and rocks scattered throughout the area, and is located north of Interstate 10 (I-10) and west of the intersection of Palm Drive and Varner Road. The project site was part of a larger 4,000-acre area that was the subject of an annexation - the I-10 Community Annexation - approved by the Riverside County Local Agency Formation Commission (LAFCO) in 2010. The 2018 General Plan and Zoning Designations within the 123.4-acre project area were Light Industrial (LI) and Rural Desert (RD). The RD and LI designations were representative of Riverside County designations that were adopted by the City as interim designations upon annexation, with City Equivalent Land Uses which are Residential Estate (R-E10) and Light Industrial (I-L).

Divide an Established Community
The 2018 concluded that the DLVSP would not physically divide an established community because the site was vacant, and no residential uses occurred onsite.

Item Number: 1.

93 Conflict with Land Use Plan, Policy or Regulation
The 2018 EIR concluded that the DLVSP would not conflict with any Land Use Plan, Policy or Regulation as described below.

City of Desert Hot Springs Comprehensive General Plan (2000) As described in the 2018 EIR, the DLVSP would be consistent with Policy 3 of the City’s General Plan (Industrial Goals, Policies and Programs) in requiring projects with larger size industrial areas to create a Specific Plan with the inclusion of a master plan for the required infrastructure (i.e., extension of roadways, drainage facilities and utilities). Furthermore, the DLVSP would be consistent with Program 3A of the City’s General Plan (Industrial Goals, Policies and Programs) by incorporating development standards and guidelines into the document in order to assure efficient industrial development consistent with the character of the community. The 2018 EIR determined there would be no conflict.

General Plan Amendment
The DLVSP included a General Plan Amendment (GPA 01-16) to allow for a change in the site’s land use designations from Light Industrial (LI) and Rural Development (RD) (County-designated) to Light Industrial (I-L) (City-designated) and Commercial Retail (CR) (City-designated), in order to allow for the more intense development envisioned by the Specific Plan. The General Plan Amendment was undertaken in accordance with the process outlined in Chapter 17.100 (General Plan Amendments) of the City’s Zoning Ordinance (Title 17 of the Desert Hot Springs Municipal Code). The 2018 EIR determined there would be no conflict.

Zoning Map Amendment
As described in the 2018 EIR, the DLVSP would be adopted by the Desert Hot Springs City Council as an ordinance and would function as the regulatory document that serves as the implementing zoning for the project site. The Zoning Map Amendment (ZMA 01-16), would change the land use/zoning districts from Light Industrial (LI) and Rural Development (RD) to Specific Plan, consistent with Policy 2 of the City’s General Plan (General Land Use Goals, Policies and Programs) by requiring that the Zoning Ordinance directly correspond to General Plan land use designation for the project site and to provide appropriate zoning regulations within the project site that implement the Land Use Element. The 2018 EIR determined there would be no conflict.

City of Desert Hot Springs Municipal Code, Zoning Ordinance, and City Council Ordinance As described in the 2018 EIR, the DLVSP general development standards and regulations would incorporate the City of Desert Hot Spring’s Zoning and Municipal Code ordinances pertaining to general provisions, commercial district standards, industrial district standards, property development standards, off-street loading, art in public places, special uses, massage establishments, motion picture production, and marijuana facility standards and regulations, consistent with Program 3A of the City’s General Plan (Industrial Goals, Policies, and Programs) in regards to developing a specific plan that will assure efficient industrial development consistent with the character and quality of the community. The 2018 EIR determined implementation of the DLVSP would not conflict with any land use plan, policy or regulation.

Item Number: 1.

94 Conflict with Habitat or Natural Community Conservation Plan As described in the 2018 EIR, the northern portion of the project site, north of Varner Road (35.6 acres), along with a smaller site south of Varner Road in the northwestern portion (3.1 acres) of the project site were completely within the Willow Hole Conservation Area of the CVMSHCP for a combined total of approximately 38.7 acres. Planning Area 2 of the DLVSP would largely remain in its existing condition, as undeveloped desert land and habitat, with the exception of permitting the solar fields proposed in Planning Area 2, and water/sanitary sewer facilities for up to a maximum of 10 percent of the land coverage (approximately 3.9 acres) of the overall planning area acreage, as provided by the CVMSHCP. Therefore, the DLVSP would maintain consistency with Goal 1, Goal 2, and Policy 1 of the City’s General Plan (Open Space and Conservation Goals, Policies and Programs) regarding protecting environmental resources, preserving the City’s atmosphere, including native desert communities, and preserving open space areas. The 2018 EIR determined impacts to any habitat or natural community conservation plan would be less than significant.

Cumulative Impacts
The 2018 EIR determined that subject to the City’s adoption of both GPA 01-16 and ZMA 01-16, and adherence to the City’s Zoning and Municipal Code ordinances, implementation of the DLVSP would not result in any potential cumulative impacts.

Mitigation Measures
No mitigation were required, because impacts were found to be less than significant.

Analysis of the Proposed Project
The proposed Specific Plan amendment does not propose an increase to overall land use densities or change in industrial development standards. As a result, the consistency identified in the 2018 EIR with the General Plan’s policies and programs also applies to the currently proposed Project. The proposed Specific Plan is consistent with the previously approved Specific Plan and development of the proposed Project will be in accordance with the requirements of the Specific Plan and other applicable regulations, including payment of the CVMSHCP development impact fee and the implementation of its standards. As discussed in the Biological Resources section, the CVCC finds the Project consistent with the CVMSHCP with incorporation of Mitigation Measure BIO-5. As the Specific Plan acts as the zoning document for the Project, the proposed development Project will be consistent with the City’s zoning standards, since it meets of exceeds the Specific Plan development standards.

The currently proposed GPA is to amend the ‘Mobility and Infrastructure Element’ and ‘Figure MI-7 Roadways Plan’ to eliminate a segment of Mihalyo Road as a collector road between Palm Drive and Varner Road as part of the proposed Project. The GPA will be undertaken in accordance with the process outlined in Chapter 17.100 (General Plan Amendments) of the City’s Zoning Ordinance (Title 17 of the Desert Hot Springs Municipal Code). As proposed, the GPA would eliminate a roadway which is currently shown to terminate on the Project site, and is not needed to serve the Project (please see Section 3.16, Transportation & Traffic). The GPA would not impact Item Number: 1.

95 the City’s roadway system, or conflict with General Plan goals, policies or programs. Therefore, there will be no conflict with applicable General Plan or Zoning requirements.

As was identified in the 2018 EIR, the Project would not physically divide an established community because the site is vacant, and no residential uses occur onsite.

Similar to the 2018 EIR, subject to the City’s adoption of GPA 24-1, and adherence to the City’s Zoning and Municipal Code ordinances, implementation of the proposed Project would not result in cumulative impacts to land use and planning.

In summary, implementation of proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact previously analyzed in the 2018 EIR.

Overall impacts associated with planning or zoning consistency are expected to be similar to those previously identified in the 2018 EIR. Therefore, implementation of the proposed Project and Specific Plan amendment would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the Certified EIR.

3.11. MINERAL RESOURCES
Summary of Findings in the 2018 EIR (Section 4.11, page 4.11-1 et.seq.) The 2018 EIR described mineral resources within the planning area as primarily consisting of sands and gravels, however no existing mining operations are located within the project site or surrounding area. Other mineral deposits occurring in the region include copper, limestone, specialty sands, and tungsten. These deposits are limited to rocky outcroppings occurring in the Little San Bernardino Mountains, located outside the City.

The 2018 EIR determined the project site is in an area that has been classified as MRZ-3, which are defined as areas where the significance of mineral deposits cannot be evaluated from available data. The EIR concluded there was no evidence indicating that the project site contains any mineral resource that could be of value on a regional or State level. The project site is neither classified as a mineral resource recovery area in the California Department of Conservation’s Mineral Land Classification report, nor identified as a locally important mineral resource recovery site in the City’s General Plan or any other land use plan. The 2018 EIR concluded that development of the DLVSP would have no impact to mineral resources.

Cumulative Impacts
The 2018 EIR determined no project-related impacts would occur, and therefore, implementation of the DLVSP would not contribute to cumulative impacts to mineral resources.

Mitigation Measures
No mitigation measures were required because there would be no impacts to mineral resources.

Item Number: 1.

96 Analysis of the Proposed Project
The proposed distribution warehouse is consistent with permitted uses under the industrial land use designation for the site in the DLVSP. The Project does not propose mining activities and there are no mining land uses or activities in the vicinity. The development of the site will be in accordance with the requirements of the DHS Varner Road Specific Plan, General Plan, Zoning Code, and other applicable regulations.

Implementation of proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact as previously analyzed in the 2018 EIR, including cumulative impacts. As was the case in the 2018 EIR, the Project will have no cumulative impact on mineral resources.

3.12. NOISE
Summary of Findings in the 2018 EIR (Section 4.12, page 4.12-1 et.seq.) As described in the 2018 EIR, the City of Desert Hot Springs General Plan utilizes a Land Use Compatibility Noise Matrix for Community Noise Exposure Standards. The interior and exterior noise standards are in terms of the CNEL. The standards state that for residential land uses, exterior noise exposure levels of up to 60 dBA CNEL are considered “normally acceptable” and noise levels of up to 65 dBA CNEL are considered “conditionally acceptable”. Heavy Commercial/Industrial land uses are considered “normally acceptable” in environments where the noise level reaches up to 75 dBA CNEL. The Desert Hot Springs municipal code regulates noise under Chapter 8.12, "Noise Control," aiming to reduce excessive and annoying noise for the well-being of residents and sets specific restrictions, such as limiting construction activities to certain daytime hours to minimize disruption.

Information for this section of the 2018 EIR was obtained from the Noise Impact Assessment, prepared by Kunzman Associates, November 2017 (Appendix G of 2018 EIR).

Existing (2018 EIR) Noise Levels
Ambient noise levels were determined for the project site during a field survey on July 10, 2017.

Two 10-minute daytime noise measurements were taken between 4:29 PM and 5:00 PM along the project site’s perimeter adjacent to the I-10 Freeway. Ambient noise levels were 67.1 and

67.5 dBA Leq during the daytime. The dominant noise source was from vehicles traveling along the I-10 freeway, as shown in EIR Table 4.12-4, duplicated below.

Item Number: 1.

97 Table 4.12-5 of the 2018 EIR, Existing (Without Project) Exterior Noise Levels Along Roadways, duplicated below, shows existing traffic noise conditions in the project site and surrounding area.

Traffic noise levels were calculated 50 feet from the centerline of the analyzed roadway Construction Noise Impacts
As described in the 2018 EIR, the City does not have a specific construction noise threshold it enforces, however the City’s Municipal Code outlines specific times when construction is allowed to occur. Near the southeast corner of the project site, construction noise could reach up 84 dBA Leq at the nearest sensitive receptor (130 feet south of the southern property line). The construction noise levels would be below the Occupation Safety and Health standards of 85 dBA and would be consistent with the City’s Municipal Code for construction noise.

Willow Hole Conservation Area (DLVSP Planning Area 2)
The CVMSHCP Adjacency Guidelines specific to Noise are as follows:

Proposed development adjacent to or within a Conservation Area that generates noise in excess of 75 dBA Leq hourly shall incorporate setbacks, berms, or walls, as appropriate, to minimize the effects of noise on the adjacent Conservation Area in accordance with the guidelines to be included in the Implementation Manual.

According to the 2018 EIR, development of the 3.9 acres of energy improvements would require some grading and may require creation of concrete pads. Construction of concrete pads would require concrete mixers. The 2018 EIR explained maximum noise levels during construction could reach 90 dBA at 50 feet from the noise source. The EIR anticipated development of the energy improvements to be relatively short in duration and require equipment that would generate intermittent noise levels in excess of 75 dBA at 50 feet.

If prior to commencement of construction activities adjacent to the Conservation Area the project biologist determined that there are sensitive wildlife species in the vicinity of the proposed project, the 2018 EIR determined the project proponent would erect a temporary Item Number: 1.

98 construction barrier along the northern boundary of the project site (Mitigation Measure BIO-5 item 4). The implementation of temporary barriers can reduce noise levels between 5 to 15 dB, depending on wall heights and placement. In addition, the implementation of silencers and equipment shrouds can reduce noise levels by 10 to 15 dB. With the implementation of temporary barriers and equipment silencers and shrouds the noise levels during construction were anticipated to remain below the 75 dBA noise standard at the conservation area As described in the 2018 EIR, the CVMSHCP does not have a specific requirement not to exceed limit for construction noise, however the DLSVP had the potential to significantly impact the Conservation Area during construction due to the potential for adjacent animal species (per the CVMSHCP). To ensure that construction within the project site did not significantly impact animal species within the adjacent Conservation Area, a site specific final acoustical study was required to demonstrate compliance to CVMSHCP noise thresholds for each development project proposed within the project site, implemented through Mitigation Measure NOI-6.

Operational Impacts
According to the 2018 EIR, DLVSP generated on-site operational noise may include parking lot activities, loading and unloading, and heating and cooling units (HVAC) and operation of the various businesses on the site.

Parking Lot Noise Impacts
Although detailed plans and the exact locations of all parking lots and associated parking spaces within the boundaries of each parcel were not known at the time the 2018 EIR was drafted, worst-case noise impacts to residences due to parking lot related activities were estimated based on parking lot noise reference levels with the assumption that a parking lot could be located anywhere within the confines of each parcel expected to contain a parking lot.

Assuming a conservative reference noise level of 70 dB Leq at 25 feet, the 2018 EIR determined noise levels associated with loading and unloading activities were not expected to exceed the City’s noise standard of 65 dBA Leq at the nearest sensitive receptor, which would be located approximately 270 feet away from the nearest potential loading/unloading area.

HVAC Noise Impacts
As described in the 2018 EIR, the buildings associated with buildout of the DLVSP would include roof-top mounted heating, ventilation, and air conditioning (HVAC) units; however, the type, size and number of mechanical equipment was not known at the time. Future development projects would be required to ensure that new development, including HVAC equipment would not result in the generation of noise that exceeds the City’s noise standards. Mitigation Measure NOI-6 required future development projects prepare a project specific acoustical study to ensure that each project within the project site would develop necessary noise attenuation to avoid significant noise impacts.

Wastewater Treatment Plant Nosie Impacts
The 2018 EIR noted that until such time as CVWD extended water and sewer services to the project area, or the MSWD regional wastewater facilities came on-line, the project would require Item Number: 1.

99 the installation and operation of a wastewater package treatment plant. The wastewater treatment plant was sited at the southeast corner of the project site approximately 300 feet from the property boundary. The treatment plant would be separated from the property boundary by a retention basin and would be surrounded by a wall. During the planning process for the wastewater treatment plant to determine the exact location and size of the facility, the project proponent would be required to prepare a noise study to address proximity to the residence and determine the optimum location of the plant, as well as the type and height of the perimeter wall around the treatment plant. Operations of the proposed project would be subject to Section 8.12 of the Desert Hot Springs Municipal Code which regulates noise within the City. Mitigation Measure NOI-8 required future development of the wastewater treatment plant prepare a sitespecific noise study to determine the amount of noise generated by the plant, and to establish attenuation requirements to avoid significant noise impacts.

Groundborne Vibration
Construction activity can result in varying degrees of ground vibration, depending on the equipment used on the site. The City of Desert Hot Springs prohibits any land uses that generate a discernible vibration impact from 50 feet and beyond the property line or source. The threshold at which there may be a risk of architectural damage to normal houses with plastered walls and ceilings is 0.20 PPV in/second. According to the 2018 EIR, construction equipment was anticipated to be located at least 130 feet from any existing sensitive receptor south of the site.

At a distance of 130 feet a large bulldozer would yield a worst-case 0.015 PPV (in/sec) and would not put the nearest existing sensitive receptors located south of the project site at risk for damage. The 2018 EIR determined vibration associated with construction would be less than significant.

Traffic Noise Impacts: Off-Site Receptors
The 2018 EIR modeled worst-case project generated traffic noise levels utilizing the FHWA Traffic Noise Prediction Model - FHWA-RD-77-108. Traffic noise levels were calculated 50 feet from the centerline of the analyzed roadway, based on the assumptions shown in EIR Table 4.12-8, duplicated below.

Item Number: 1.

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The potential off-site noise impacts caused by an increase of traffic volumes from operation of the DLVSP on the nearby roadways was calculated in the 2018 EIR for the following scenarios:
• Existing Year (without Project): This scenario refers to existing year traffic noise conditions and is demonstrated in Table 4.12-5 of the 2018 EIR [see Existing (2018 EIR) Noise Levels, above).
• Existing Year (Plus Project): This scenario refers to existing year traffic noise conditions and is demonstrated in Table 4.12-9 of the 2018 EIR, duplicated below.

According to Table 4.12-11of the 2018 EIR, duplicated below, the DLVSP was anticipated to change the noise levels by a nominal amount (approximately 0.3 to 2.6 dBA CNEL) with the exception of Varner Road west of Palm Drive, which was evaluated to have no traffic volumes for the existing traffic condition. Although the increase in noise level was considered significant, Item Number: 1.

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there were no sensitive receptors located within the confines of the 60 dBA CNEL contour of Varner Road and the nearest sensitive receptor was located approximately 1,800 feet from the centerline of Varner Road and would fall outside of the 55 dBA CNEL contour line of Varner Road.

The 2018 EIR determined the impact would be considered less than significant.

Willow Hole Conservation Area
The 2018 EIR noted the General Plan EIR for the CVMSHCP Conservation Area accounted for traffic noise impacts generated by existing and future conditions, including build out of the site and its surroundings, and therefore the EIR determined project-related impact would be less than significant.

DLVSP Noise Impacts
As described in the 2018 EIR, the City of Desert Hot Springs land use compatibility guidelines state that the DLVSP would be “normally acceptable” in areas with noise levels up to 75 dBA CNEL. The DLVSP had the potential to experience noise levels approaching 78 dBA CNEL for year 2035 at 300 feet from the centerline of the I-10 Freeway. The noise level exceeds the City’s “normally acceptable” 75 dBA CNEL compatibility limit and would therefore fall within the “normally unacceptable” 75 to 80 dBA CNEL range. The 75 dBA CNEL noise contour was located approximately 450 feet from the centerline of the I-10 Freeway and any development that occurred beyond 450 feet from the centerline would be within the City’s “normally acceptable” 75 dBA CNEL compatibility limit for industrial use.

Prior to issuance of building permits, the 2018 EIR determined future project proponents would be required to submit an acoustic report that demonstrates compliance to acoustic requirements set forth by the CalGreen Code (Mitigation Measures NOI-6).

Item Number: 1.

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To remain consistent with the noise/land use compatibility criteria set forth in the City’s land use compatibility guidelines, the 2018 EIR states that hotel or light commercial land uses such as retail or restaurants built on the project site should be located outside the 65 dBA CNEL contour to be within the “normally acceptable” limits and within the 65-70 dBA CNEL contour to be within the “conditionally acceptable” limits. Mitigation Measure NOI-6 requires future development projects prepare a project specific acoustical study to ensure that each project within the project site would develop necessary noise attenuation to avoid significant noise impacts.

With regard to the adjacency to the Willow Hole Conservation Area, the CVMSHCP Adjacency Guidelines identify 75 dBA as the threshold whereby mitigation in the form of noise attenuation berms or other sound barriers may be required. Compliance with Regulatory Requirements RR15 and RR-16, and Mitigation Measure BIO-5 and BIO-6 would ensure that noise impacts related to the conservation area would remain less than significant.

Airport Noise Impacts
The 2018 EIR determined the project site is approximately 3.5 miles north of the Palm Springs International Airport, and there are no private airstrips in the area. The project site is not located within the noise compatibility contours of the Riverside County Airport Land Use Compatibility Plan for the Palm Springs International Airport. The 2018 EIR determined there would be no noise impacts associated with proximity to an airport.

Cumulative Impacts
The 2018 EIR determined implementation of the DLVSP would increase existing noise levels on project site roadways between 0.3 and 2.2 dBA within 50 feet of the centerline, which was below the 3dBA threshold and therefore would not contribute significantly to an increase in noise. With regard to the Varner Road, however, the noise levels would increase to 74.7 dBA which was considered a significant increase, but that impacts were less than significant because there were no sensitive receptors located within the 60 dBA CNEL contour of Varner Road. Overall, cumulative impacts to noise were found to be less than significant.

Mitigation Measures
The following Mitigations Measures and Regulatory Requirements are from pages 4.12-24 through -27 of the 2018 EIR.

Grading and Site Development
In addition to adherence to the City of Desert Hot Springs’s policies found in the Noise Element and Municipal Code limiting the construction hours of operation, the following mitigation measures shall be implemented to reduce construction noise and vibrations emanating from future construction projects at the project site. These measures shall be included as notes on all grading plans and construction plans as appropriate, to the satisfaction of the City Engineer or his/her designee.

Item Number: 1.

103
Construction
NOI-1 During all project site excavation and grading onsite, construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturer standards.

NOI-2 Construction contractors shall place all stationary construction equipment so that emitted noise is directed away from the noise sensitive receptors nearest the project site.

NOI-3 Construction contractors shall ensure that equipment is shut off and not left to idle when not in use.

NOI-4 Construction contractors shall locate equipment staging in areas that will create the greatest distance between construction-related noise/vibration sources and sensitive receptors nearest the project site during all project construction.

NOI-5 Construction contractors shall ensure that jackhammers, pneumatic equipment, and all other portable stationary noise sources are shielded and noise is directed away from sensitive receptors.

Building Development
NOI-6 The project is required to comply with 2016 CalGreen Code Section 5.507, Environmental Comfort. Prior to issuance of building permits the project proponent shall submit an acoustic report that demonstrates compliance to acoustic requirements set forth by CalGreen Code, to the satisfaction of the Community Development Director or his/her designee. The acoustic report shall provide either a prescriptive or performance based evaluation.

NOI-7 The project applicant(s) will be required to adhere to 2016 Title 24 during all construction activities, which states that interior noise levels within multiple-family or habitable dwelling units generated by exterior noise sources shall not exceed 45 dBA Ldn/CNEL, with windows closed, in any habitable room for general residential uses.

In order to ensure this standard is met, all exposed exterior wall assembly/window combinations that face the I-10 freeway and subject roadways need to provide an exterior to interior noise reduction of at least 33 dBA if located within 300 feet of the centerline of the I-10 freeway and/or a noise reduction of 30 dBA if located within 450 feet of the centerline of the I-10 freeway. Prior to issuance of building permits, the project proponent for any development project within the project site shall submit site specific noise studies that show how noise from the freeway would be attenuated, to the satisfaction of the Community Development Director or his/her designee.

NOI-8 Prior to construction of the wastewater treatment plant, proposed to be located in the southeast corner of the project site, a site specific noise study shall be prepared to determine the amount of noise generated by the plant, and to establish Item Number: 1.

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attenuation requirements, to the satisfaction of the Community Development Director or his/her designee, to address proximity to the existing single family residence located approximately 200 feet south of the project site; as well as any future noise sensitive uses (hotel) that may be located on the project site in close proximity to the plant site.

The following mitigation measures from Section 4.4, Biological Resources of the 2018 EIR, apply to Noise as well:

BIO-5 The project proponent shall implement the following CVMSHCP Land Use Adjacency Guidelines requirements and restrictions as listed in Section 3.2.3 of the Biological Resources Assessment (Appendix C) and shall be adhered to during construction and for post construction operation for any project within the project site that lies adjacent to Conservation Areas. The project proponent shall coordinate with the Coachella Conservation Commission (CVCC) and CVCC staff shall review plans for all planning areas adjacent to the Conservation Area and determine whether the proposed improvements are consistent with the CVMSHCP.
1) Drainage ̶ Proposed Development adjacent to or within a Conservation Area shall incorporate plans to ensure that the quantity and quality of runoff discharged to the adjacent Conservation Area is not altered in an adverse way when compared with existing conditions. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials or other elements that might degrade or harm biological resources or ecosystem processes within the adjacent Conservation Area.
2) Toxics ̶ Land uses proposed adjacent to or within a Conservation Area that use chemicals or generate byproducts such as manure that are potentially toxic or may adversely affect wildlife and plant species, Habitat, or water quality shall incorporate measures to ensure that application of such chemicals does not result in any discharge to the adjacent Conservation Area.
3) Lighting ̶ For proposed Development adjacent to or within a Conservation Area, lighting shall be shielded and directed toward the developed area. Landscape shielding or other appropriate methods shall be incorporated in project designs to minimize the effects of lighting adjacent to or within the adjacent Conservation Area in accordance with the guidelines to be included in the Implementation Manual.
4) Noise ̶ Proposed Development adjacent to or within a Conservation Area that generates noise in excess of 75 dBA Leq hourly shall incorporate setbacks, berms, or walls, as appropriate, to minimize the effects of noise on the adjacent Conservation Area in accordance with guidelines to be included in the Implementation Manual.
5) Invasives ̶ Invasive, non-native plant species shall not be incorporated in the landscape for land uses adjacent to or within a Conservation Area. Landscape treatments within or adjacent to a Conservation Area shall incorporate native plant materials to the maximum extent feasible; recommended native species are listed in Table 4-112. The plants listed in Table 4-113 shall not be used within or Item Number: 1.

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adjacent to or within a Conservation area. The list may be amended from time to time through a Minor Amendment with Wildlife Agency Concurrence. 6) Barriers ̶ Land uses adjacent to or within a Conservation Area shall incorporate barriers in individual project designs to minimize unauthorized public access, domestic animal predation, illegal trespass, or dumping in a Conservation Area.

Such barriers may include native landscaping, rocks/boulders, fencing, walls and/or signage.
7) Grading/Land Development ̶ Manufactured slopes associated with site Development shall not extend into adjacent land in a Conservation Area BIO-6 A site specific final acoustical analysis is required once a site specific site plan is made available in order to demonstrate compliance with the CVMSCHP noise threshold.

Regulatory Requirements
R-15 Due to the proximity of the project site (within 65 dBA CNEL of freeway) as it relates to the I-10 Freeway, the project proponent (where occupants will likely be affected by exterior noise) is required to comply with 2016 CalGreen Code Section 5.507 Environmental Comfort. Prior to issuance of building permits the project proponent shall submit an acoustic report that demonstrates compliance to acoustic requirements set forth by CalGreen Code. The acoustic report shall provide either a prescriptive or performance based evaluation.

RR-16 The project proponent will be required to adhere to 2016 Title 24 Chapter 12 – Interior Environment – Section 1207 during all construction activities, which states that interior noise levels within multiple family or habitable dwelling units generated by exterior noise sources shall not exceed 45 dBA Ldn/CNEL, with windows closed, in any habitable room for general residential uses. In order to ensure this standard is met, all exposed interior wall assembly/window combinations that face the I-10 Freeway and subject roadways need to provide an exterior to interior noise reduction of at least 33 dB.

Analysis of the Proposed Project
The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. Compared to the 2018 EIR analysis, buildout of the Specific Plan (1.5 million SF industrial) would result in a 2.52 percent reduction in industrial space and 100 percent reduction in commercial space, and buildout of the proposed development (1.16 million SF industrial) would result in a 24.5 percent reduction in industrial space and a 100 percent reduction in commercial space. Therefore, construction and operational noise levels associated with buildout of the Project are anticipated to be less intense than those previously analyzed in the 2018 EIR due to the reduction in building square footage.

A Project-specific Noise and Vibration Analysis was prepared by Urban Crossroads in March 2025 (Appendix H) that assessed 1,500,000 square feet (SF) of high cube warehouse, consistent with maximum buildout of the Project Specific Plan. Noise impacts shall be considered significant if any of the following occur as a direct result of the proposed development.

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Table 10
Noise Significance Criteria
Analysis Receiving Land Use Condition(s) Significance Criteria Daytime Nighttime
Off-Site
Traffic Noise-Sensitive
If ambient is < 60 dBA CNEL1
If ambient is 60-65 dBA CNEL1
If ambient is > 65 dBA CNEL1
≥ 5 dBA CNEL Project increase
≥ 3 dBA CNEL Project increase
≥1.5 dBA CNEL Project increase
Off-Site
Traffic
Non-NoiseSensitive If ambient is > 70 dBA CNEL2 ≥ 3 dBA CNEL Project increase Operational Noise-Sensitive
Residential Exterior Noise Level3
If ambient is < 60 dBA Leq1
If ambient is 60-65 dBA Leq1
If ambient is > 65 dBA Leq1
65 dBA Leq 45 dBA Leq
≥ 5 dBA Leq Project increase
≥ 3 dBA Leq Project increase
≥ 1.5 dBA Leq Project increase
Construction Noise-Sensitive
Noise Level Threshold4
Exterior Noise Level Increase5
Vibration Level Threshold6
80 dBA Leq 70 dBA Leq
20 dBA Leq

0.3 PPV (in/sec) 1FICON, 1992.
2City of Desert Hot Springs Noise and Land Use Compatibility Guidelines (Exhibit 3-1) 3County of Riverside General Plan Noise Element, Policy N 4.1. 4Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual. 5Temporary construction noise increases that can be tolerated without significant adverse effects. 6Caltrans Transportation and Construction Vibration Manual, April 2020 Table 19 “Daytime: = 7:00 a.m. to 10:00 p.m.; “Nighttime” = 10:00 p.m. to 7:00 a.m.

To assess the potential for long-term operational and short-term construction noise impacts, six receiver locations, as shown on Figure 1, were identified as representative locations for analysis.

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Figure 1: Construction Noise Receiver Locations
Source: Exhibit 8-1 of the Noise and Vibration Analysis Construction Noise Impacts
To evaluate whether the Project will generate potentially significant short-term noise levels at nearest receiver locations, a construction-related daytime noise level threshold of 80 dBA Leq is used as a reasonable threshold to assess the daytime construction noise level impacts. The construction noise analysis shows that the nearest receiver locations will satisfy the reasonable daytime 80 dBA Leq significance threshold during Project construction activities as shown on Table 10. Therefore, the noise impacts due to Project construction noise are considered less than significant at all receiver locations.

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Table 11
Construction Noise Level Compliance
Receiver
Location1
Construction Noise Levels (dBA Leq)
Highest Construction
Noise Levels2 Threshold3 Threshold Exceeded?4
R1 42.8 80 No
R2 40.8 80 No
R3 49.6 80 No
R4 50.8 80 No
R5 51.2 80 No
R6 36.5 80 No
Source: Table 10-3 of Noise and Vibration Analysis
Construction activities associated with build out of the proposed Project would adhere to the City’s allowable construction hours, and would also be temporary in nature. Construction-related noise due to the proposed Project be lower than those estimated in the 2018 EIR at sensitive receptor locations, and would not result in any new impacts or increase the severity of a previously identified significant impact analyzed in the 2018 EIR, and impacts would remain less than significant.

Operational Noise Impacts
This operational noise analysis is intended to describe noise level impacts associated with the expected typical daytime and nighttime activities at the Project site. To present the potential worst-case noise conditions, the analysis assumes the Project would be operational 24 hours per day, seven days per week. Consistent with similar projects, the Noise Analysis assumed the Project business operations would primarily be conducted within the enclosed building, except for traffic movement, parking, as well as loading and unloading of trucks at designated loading bays. The on-site Project-related noise sources are expected to include: loading dock activity, tractor trailer storage activity, truck movements, trash enclosure activity, roof-top air conditioning units, and parking lot vehicle movements.

Existing Noise Levels: To assess the existing noise level environment, 24-hour noise level measurements were taken at six locations in the Project study area on Thursday, February 20, 2025. Results of the ambient noise level measurements are provided in Section 5.3 of the Noise Analysis. In summary, noise levels in the Project area have a daytime range of 44.2 to 73.7 dBA Leq, a nighttime range of 38.9 to 68.2 dBA Leq, and a CNEL range of 46.8 to 76.4 (Table 5-1 of the Noise and Vibration Analysis).

Off-Site Traffic Noise: The Noise Analysis identified six off-site study area roadway segments to assess the Project’s off-site dBA CNEL transportation noise impacts. The ADT volumes used in the Noise Analysis are based on the Varner Road / West Drive Logistics Traffic Analysis prepared by Urban Crossroads, Inc. (Appendix I) for the following traffic scenarios • Existing without Project (E)
• Existing with Project (EP)
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• Existing plus Ambient plus Cumulative (EAC) 2027 without Project • Existing plus Ambient plus Cumulative (EACP) 2027 with Project • Horizon Year 2045 (HY) without Project
• Horizon Year 2045 (HYP) with Project
The Noise Analysis concluded that land uses adjacent to the study area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels for all traffic scenarios, as described below.

• The Existing without Project exterior noise levels are expected to range from 64.2 to 77.0 dBA CNEL, without accounting for any noise attenuation features such as noise barriers or topography. The Existing with Project conditions will range from 64.9 to 78.4 dBA CNEL.

The Project off-site traffic noise level impacts will range from 0.0 to 1.4 dBA CNEL. Based on the significance criteria for off-site traffic noise presented in Table 9, land uses adjacent to the study area roadway segments would experience less than significant noise level impact due to unmitigated Project-related traffic noise levels, because none of the increases would be perceptible or reach the significance threshold. • The EAC (2027) without Project exterior noise levels are expected to range from 64.3 to

77.9 dBA CNEL, without accounting for any noise attenuation features such as noise barriers or topography. The EACP (2027) with Project conditions will range from 65.1 to

79.0 dBA CNEL. The Project off-site traffic noise level increases will range from 0.0 to 1.1 dBA CNEL. Based on the significance criteria for off-site traffic noise presented in Table 9, land uses adjacent to the study area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels, because none of the increases would be perceptible or reach the significance threshold. • The HY (2045) without Project exterior noise levels are expected to range from 69.0 to

78.4 dBA CNEL, without accounting for any noise attenuation features such as noise barriers or topography. The HY (2045) with Project conditions will range from 69.3 to

79.4 dBA CNEL. The Project off-site traffic noise level increases will range from 0.0 to 1.1 dBA CNEL. Based on the significance criteria for off-site traffic noise presented in Table 9, land uses adjacent to the study area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels, because none of the increases would be perceptible or reach the significance threshold.

Operational Noise Impacts: The Noise Analysis used reference noise levels to represent the Project operations that include loading dock activity, tractor trailer storage activity, truck movements, trash enclosure activity, roof-top air conditioning units, and parking lot vehicle movements. As shown in Table 11, the daytime hourly noise levels at the off-site receiver locations are expected to range from 29.0 to 43.9 dBA Leq and the nighttime hourly noise levels at the existing off-site receiver locations are expected to range from 29.0 to 43.9 dBA Leq. Table 11 shows that the mitigated operational noise levels associated with Project will not exceed the daytime and nighttime exterior noise level standards at the existing nearby noise-sensitive receiver locations. Therefore, the mitigated operational noise impacts are considered less than significant at the nearby noise-sensitive receiver locations.

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Table 12
Operational Noise Level Compliance
Receiver
Location1
Project Operational
Noise Levels (dBA Leq)
2 Noise Level Standards
(dBA Leq)
3 Noise Level Standards
Exceeded?4
Daytime Nighttime Daytime Nighttime Daytime Nighttime
R1 34.3 34.3 65.0 45.0 No No
R2 32.7 32.7 65.0 45.0 No No
R3 41.6 41.6 65.0 45.0 No No
R4 43.9 43.9 65.0 45.0 No No
R5 43.4 43.4 65.0 45.0 No No
R6 29.0 29.0 65.0 45.0 No No
Source: Table 9-4 Noise and Vibration Analysis.

In addition, the Noise Analysis determined the Project will generate daytime operational noise increases ranging from 0.0 to 0.3 dBA Leq at the nearest receiver locations, and nighttime operational noise level increases ranging from 0.0 to 0.9 dBA Leq at the nearest receiver locations. Project-related operational noise level increases would not exceed the operational noise level increase significance criteria presented in Table 9. Therefore, Project related operational noise level increases at the sensitive receiver locations will be less than significant.

Groundborne Vibration
Table 12 presents the expected Project related vibration levels at the nearby receiver locations.

At distances ranging from 189 to 8,735 feet from Project construction activities, construction vibration velocity levels are estimated to range from 0.000 to 0.010 PPV in/sec. Based on maximum acceptable continuous vibration threshold of 0.2 PPV (in/sec), the typical Project construction vibration levels will fall below the building damage thresholds at all the noise sensitive receiver locations. Therefore, the Project-related vibration impacts are considered less than significant during typical construction activities at the Project site.

Table 13
Project Construction Vibration Levels
Location1
Distance
to
Const.

Activity
(Feet)2
Typical Construction Vibration Levels
PPV (in/sec)3 Thresholds
PPV
(in/sec)4
Thresholds
Exceeded?5 Small
bulldozer
JackhammerLoaded
Trucks
Large
bulldozer
Vibratory
Roller
Highest
Vibration
Level
R1 4,8921 0.000 0.000 0.000 0.000 0.000 0.000 0.3 No
R2 5,8651 0.000 0.000 0.000 0.000 0.000 0.000 0.3 No
R3 2,1541 0.000 0.000 0.000 0.000 0.000 0.000 0.3 No
R4 1,6781 0.000 0.000 0.000 0.000 0.000 0.000 0.3 No
R5 1891 0.000 0.002 0.004 0.004 0.010 0.010 0.3 No
R6 8,7351 0.000 0.000 0.000 0.000 0.000 0.000 0.3 No
Source: Table 10-7 Noise and Vibration Analysis.

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Airport Noise Impacts
As was the case in the 2018 EIR, the Project site is approximately 3.5 miles north of the Palm Springs International Airport, and there are no private airstrips in the area. The project site is not located within the noise compatibility contours of the Riverside County Airport Land Use Compatibility Plan for the Palm Springs International Airport. There will be no noise impacts associated with proximity to an airport.

Cumulative Impacts
The proposed Project will not exceed acceptable noise levels for industrial uses and land uses adjacent to the study area roadway segments would experience less than significant noise level impacts due to unmitigated Project-related traffic noise levels, and lower noise levels than those analyzed in the 2018 EIR. Therefore, consistent with the findings of the 2018 EIR, the proposed Project would not contribute to a cumulative increase in noise levels that would be significant.

Summary
Noise generated at and from the Project will not exceed acceptable noise levels for industrial uses. The proposed Project has implemented the 2018 EIR’s mitigation NOI-6, and demonstrated the noise and vibration levels that can be expected from the Project. Implementation of the proposed Project would result in lower noise levels than those estimated in the 2018 EIR, and would not result in any new significant impacts or increase the severity of a previously identified significant impact as previously analyzed in the 2018 EIR. Overall noise impacts are expected to be lower than or similar to those previously identified in the EIR. Therefore, implementation of the proposed Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the EIR.

3.13. POPULATION AND HOUSING
Summary of Findings in the 2018 EIR (Section 4.13, page 4.13-1 et.seq.) According to the 2018 EIR, the 2010 U.S. Census estimated Desert Hot Springs’ population to be 25,938. Based on Department of Finance data in the 2017 E-5 Report, the population in Desert Hot Springs grew by 10.9 percent to 29,111 as of January 1, 2017. This represented an average annual growth of 1.82 percent over the 6-year period between 2010 and 2017.

According to the California Department of Finance, E-5 Report data, there were a total of 10,902 housing units in the City in 2010, and a total of 11,507 housing units as of January 1, 2017. This represented a 5.3 percent increase over the 6-year period. The Regional Housing Needs Allocation (RHNA) for Desert Hot Springs between 2014 and 2021 was 4,196 housing units.

Population Growth
According to the 2018 EIR, development of land uses within the DLVSP had the potential to generate approximately 2,212 employees, upon buildout (2019). The EIR used the Department of Finance estimate of 3.12 persons per household and estimated the project had the potential to generate 6,901 new residents in the City. Although the worst case scenario population increase Item Number: 1.

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for the proposed project was assumed to be 6,901 new residents, the majority of the employees were anticipated to be local, either from the City of Desert Hot Springs or surrounding communities close enough to allow commuting. In addition, the EIR noted the City’s 19.3 percent vacancy rate (2017), which translated to 2,220 vacant housing units able to absorb some of the population increase. Furthermore, the City’s unemployment rate at the time of the 2018 EIR was

6.7 percent, which translated to approximately 1,950 unemployed residents who could potentially be employed by the project. The 2018 EIR determined that the DLVSP would not induce substantial population growth, and impacts would be less than significant.

Displacement of Housing or People
The 2018 EIR determined the DLVSP would not displace housing or people because the site was vacant.

Cumulative Impacts
Although the DLVSP had the potential to generate approximately 2,212 employees upon buildout, the 2018 EIR determined that it would not substantially impact population growth because employees would likely include existing city residents and the vacant homes within the city could assist in accommodating the potential population growth. The EIR concluded that the 2018 project would not contribute to a cumulative impact on housing and population.

Mitigation Measures
No mitigation was required because impacts were less than significant.

Analysis of the Proposed Project
The Project would not displace housing or people because the site is currently vacant. According to the U.S. Census, the City of Desert Hot Springs had a population of 32,500 in 2020.6 In 2024, Desert Hot Springs had an estimated population of 32,654 people.7 SCAG projects that the Desert Hot Springs population will reach 61,000 by 2045, representing approximately 86.8 percent growth beyond the City’s 2024 population.8
According to the California Employment Development Department, the City of Desert Hot Springs has an estimated labor force of 16,300 people in 2025, and an unemployment rate of 6.4 percent.

Riverside County is estimated to have an unemployment rate of 5.2 percent in 2025.9 6 United States Census Bureau, QuickFacts, Desert Hot Springs city, California. https://www.census.gov/quickfacts/fact/table/deserthotspringscitycalifornia/PST045224 (Accessed March 2025). 7
Table E-5 Population and Housing Estimates for Cities, Counties, January 2021-2024. California Department of Finance. 8
Southern California Association of Governments, 2020-2045 Regional Transportation Plan / Sustainable Communities Strategy (RTP/SCS) Demographics and Growth Forecasts. Note, the current 2024-2050 RTP does not provide city-specific population growth projections, thus the 2020-2045 RTP was referenced. 9 California Employment Development Department, Labor Force and Unemployment Rate for Cities and Census Designated Places – February 2025.

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The proposed Project would not directly induce growth through the building of new homes.

However, the jobs generated by the Project may induce growth by attracting new residents to the City. Using the conversion factor of 1,030 square feet per employee, the maximum SP buildout of 1.5 million SF of warehousing could employ 1,456 people. According to the 2018 EIR, the DLVSP had the potential to generate approximately 2,212 employees, which is 756 more employees than projected under the proposed Project. Similar to the 2018 EIR, it would be likely that employees would be from the City or the region, and that limited new residents, beyond the growth anticipated by SCAG, would move to the City to seek employment at the Project. In addition, given the City’s higher unemployment rate, existing City residents are demonstrably available to work at the Project site. Therefore, implementation of the proposed Project would not result in any new significant impacts or increase the severity of a previously identified significant impact as analyzed in the EIR, including cumulative impacts. Overall impacts are expected to be less severe than those previously identified in the EIR due to the reduced buildout density and employment projections. Therefore, implementation of the proposed Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts in the EIR.

3.14. PUBLIC SERVICES
Summary of Findings in the 2018 EIR (Section 4.14, page 4.14-1 et.seq.) Fire Protection
Fire protection for the project site and surrounding area is provided by the Riverside County Fire Department. Implementation of the DLVSP and the expected increase in additional structures, roadway congestion, and population was expected to result in an increase in demand for fire protection services. Implementation of Regulatory Requirement RR-17 (payment of Development Impact Fees) would ensure that funding to maintain an acceptable level of fire protection was met.

Furthermore, implementation of Regulatory Requirements RR-18 and RR-19 would ensure that as the DLVSP builds out, new “standards of cover” developed in association with the Fire Department’s Strategic Plan would be applied to the new development. This would ensure consistency with Policy 1 and Program 1A of the City’s General Plan (Fire and Police Protection Element). Future development of the DLVSP would continue to be subject to Fire Department review and new facilities would be considered as needed to ensure provision of fire protection services. The 2018 EIR concluded that implementation of regulatory requirements, impacts on fire service would be less than significant.

Police Protection
Police protection for the project site and surrounding area is provided by the City of Desert Hot Springs Police Department. The Desert Hot Springs Police Department operated out of the Desert Hot Springs City Hall located at 65950 Pierson Boulevard about 5.8 miles north of the project site (City Hall has since relocated). The 2018 EIR determined the future developers would be required to pay a City Development Impact Fee (DIF) for Law Enforcement Facilities to help fund additional Item Number: 1.