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City of Menifee
Motte Business Center Project
Perris Appeal Comments and Responses
Comment Response
City of Perris Review Comments
1. Insufficient Analysis of Cumulative Impacts:
a. The Project needs to address the cumulative impacts of all projects within a 1.5-mile radius of the proposed site to analyze, mitigate, and disclose all environmental impacts from the Project pursuant to the California Environmental Quality Act (“CEQA”).
b. Traffic Study: Perris’ November 13 letter commented that the Project’s traffic consultant failed to contact the City of Perris to confirm which cumulative projects within Perris should be included in the Traffic Study. Menifee Response F9 stated that Perris failed to provide comments in its initial January 13 letter with regard to the cumulative projects w i t h i n t h e C i t y o f P e r r i s t o b e i n c l u d e d a s p a r t o f t h e P r o j e c t ’ s T r a f f i c Study; ho wever, th is does not reli ev e Meni fee or the Pr oject from any obligations arising from CEQA.
1. a. The cumulative projects included in the Project Traffic Study included all projects known to the City of Menifee at the time the Traffic Scoping Agreem ent and the EIR’s Notice of Prep aration were prepar ed. The Traffi c Study analyzed, mitigated, and disclosed all environmental impacts associated with the Project itself, as well as all cumulative projects identified in the Traffic Study pursuant to the CEQA Guidelines. Both project related and cumulative project impacts were fully disclosed throughout the Draft EIR. Refer to Chapters 4.1 through 4.15 of the Draft EIR. Chapters 4.1 through 4.15 of the D r af t E IR f u l l y an al y z e cu m u l at i v e i m p a ct s i n a s ep ar at e s u b - s ect i o n o f t h e analysis.
b. The City of Menifee adhered to the City of Perris’s request to analyze all projects known to the City of Menifee at the time the Traffic Scoping Agreement was prepared at the requested radius of 1.5 miles. The City of Menifee fully met the requirements of CEQA and City of Menifee standards with respect to both the Draft EIR and the Project Traffic Study by fully analyzing and disclosing all project related impacts as well as all cumulative impacts associated with development of the Project based on the cumulative projects list prepared as part of the Traffic Study.
The Traffic Scoping Agreement, including a list of Cumulative Projects (including development projects within the City of Perris) as noted on Table 6 of the Traffic Study for the Project, was sent to the City of Perris for review on January 13, 2023. The City of Perris did not provide comments on the Traffic Scoping Agreement. It should be noted that the City of Perris provided a NOP Comment Letter (dated January 13, 2023), which includes comments regarding transportation, but did not provide comments with regards to 2/1/2024 Page 2
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Motte Business Center Project
Perris Appeal Comments and Responses
specific Cumulative Projects within the City of Perris to be included as part of the Traffic Study.
The City of Perris NOP Comment letter requested that the Traffic Study and EIR analyze imp acts of all projects with in a 1.5-m ile r ad ius of th e proposed Project site. Both the Traffic Study and EIR analyzed the cumulative impacts of all known projects with this 1.5-mile radius. As such, the City of Menifee fully complied with the City of Perris’s requests stated in their NOP comment letter.
2. Insufficient Analysis of Transportation Impacts:
a. Perris raised multiple concerns in its November 13 letter regarding the insufficiency of the EIR’s Traffic Study as the Project analyzes multiple intersections within the City of Perris. Further, a Traffic Impact Analysis p r e p a r e d b y R K E n g i n e e r i n g , t h a t i s r e f e r e n c e d i n P e r r i s ’ p r e v i o u s comment letters, demonstrates adverse environmental impacts caused by increased truck traffic along Ethanac Road that are not properly reflected in the Project Traffic Study.
2. a. No Traffic Impact Analysis prepared by RK Engineering demonstrating impacts caused by truck traffic along Ethanac Road was provided to the City of Menifee in the previous comment letters. The Traffic Study and EIR disclose the Project’s truck traffic impacts along Ethanac Road. As such, no additional response can be provided.
Additionally, the Project Traffic Study fully analyzed all impacted intersections within both the City of Menifee and City of Perris. The only intersections located entirely or a majority within the City of Perris are the following:
· Encanto Drive at Ethanac Road (City of Perris)
· Trumble Road at Ethanac Road (City of Perris)
The Traffic Study fully analyzed all impacted intersections, including those located within or partially within the City of Perris.
U n d e r C E Q A G u i d e l i n e s s e c t i o n 1 5 0 6 4 . 3 , a u t o m o b i l e d e l a y n o l o n g e r i s considered an environmental impact. The Project’s land use impacts are based in part upon determining compliance with the City’s General Plan. The Project 2/1/2024 Page 3
City of Menifee
Motte Business Center Project
Perris Appeal Comments and Responses
b. Level of Service Standards and Measure of Significance: Perris understands that pursuant to Public Resources Code (“PRC”), section 21099(b)(2), automotive delay as measured by various factors including level of service, is no longer considered an environmental i m p a c t f o r p u r p o s e s o f C E Q A . H o w e v e r , P R C , s e c t i o n 2 1 0 9 9 ( c ) s t a t e s this fact does not relieve a public agency of the requirement to analyze a project’s potentially significant transportation impacts related to air quality, noise, safety or any other impact associated with transportation.
Level of Service remains a useful tool in determining whether automobile and truck trips generated by a project results in reasonable foreseeable direct or cumulatively significant traffic safety impacts. The E I R c o n c l u d e s t h e p r o j e c t w i l l n o t r e s u l t i n a n y s i g n i f i c a n t transportation impacts, without mitigation. For the reasons below, P e r r i s d o e s n o t b e l i e v e t h o s e c o n c l u s i o n s a r e s u p p o r t e d w i t h a n adequate Traffic Impact Study, and therefore are not supported with substantial evidence.
Applicant is proposing to improve roadways along the Project’s frontage per the City of Menifee General Plan. The Project Applicant will also improve Ethanac Road from I-215 to Dawson Road to increase the roadway’s vehicle capacity to accommodate the Project and other nearby cumulative project traffic as forecasted in the Project Traffic Study. All roadway improvements associated with the proposed Project would be consistent with the City of Menifee General Plan Circulation Element. The Project improvements per the Draft EIR to portions of intersections or roadways shared with the City of Perris would be coordinated between the City of Menifee and City of Perris prior to final engineering for the Project.
b. The Draft EIR prepared for the Project fully disclosed all impacts associated with the Project itself, in addition to cumulative impacts. All air quality impacts (both Project-specific and cumulatively) were fully analyzed and d i s c l o s e d i n C h a p t e r 4 . 2 o f t h e D r a f t E I R . A s i d e n t i f i e d i n C h a p t e r 4 . 2 , n o significant and unavoidable impacts would occur with mitigation. Similarly, all noise impacts (both Project-specific and cumulatively) were fully analyzed and disclosed in Chapter 4.11 of the Draft EIR. As identified in Chapter 4.11, no significant and unavoidable impacts would occur with mitigation. The Draft EIR also fully analyzed safety related impacts. Refer to Chapter 4.8 of the Draft EIR.
Additionally, while Level of Service is no longer considered an environmental impact under CEQA, the Project Traffic Study included a full analysis of Level of Service effects associated with development of the proposed Project. The Level of Service analysis was included as Appendix K of the Draft EIR. This information was made publicly available during the 45-day Draft EIR review period, which began on September 29, 2023, and concluded on November 13, 2023. Therefore, the Traffic Study prepared for the Project is adequate, and 2/1/2024 Page 4
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Motte Business Center Project
Perris Appeal Comments and Responses
contains substantial evidence to conclude there are no Level of Service effects with the addition of recommended improvements, and fully adheres to CEQA.
The City of Perris Transportation Impact Analysis Guidelines for CEQA (May 2020) notes the following regarding safety:
“A significant impact occurs if the project conflicts with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decreases the performance or safety of such facilities.” The proposed project would not conflict with City of Perris adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities.
The project applicant shall construct sidewalks along the project frontage to enhance pedestrian safety in the area.
Although the City of Perris has no additional significance thresholds concerning transportation and safety, the Riverside County Transportation Analysis Guidelines for Level of Service Vehicle Miles Traveled (December 2020) includes the following safety criteria in the “Safety and Operational Analysis” section:
“The TA (Transportation Analysis) shall examine existing roadway conditions to determine if safety and/or operational improvements are necessary due to an increase in traffic from the project or cumulative conditions.” The types of improvements to be identified may include, but are not limited to:
Need for turning lanes.
Intersections needing future sight distance studies. Parking restrictions.
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Motte Business Center Project
Perris Appeal Comments and Responses
Measures to reduce cut-through traffic in adjacent residential areas and/or assessment of needed traffic calming measures.
Potential impacts to adjacent schools, parks, and/or trails. Queue lengths and deficiencies to adjacent intersections. Need for signal interconnect systems.
The recommended improvements noted in the Project Traffic Study would improve safety conditions in the study area, including the City of Perris study intersections. The recommended improvements include the addition of turn lanes, traffic signalization, and the widening of Ethanac Road, which would reduce queue lengths and provide adequate sight distance along Ethanac Road and adjacent intersections. It should be noted that the recommended improvement at the intersection of Encanto Drive at Ethanac Road would restrict left turns out of the minor street approach (Encanto Drive), which i m p r o v e s o v e r a l l s a f e t y b y r e d u c i n g t h e a m o u n t o f c o n f l i c t p o i n t s a t t h i s intersection. It should be noted that the Project itself is designed to provide adequate sight distance at the project driveways, as well as insure free-flowing and safe circulation on site, including no sharp turns for trucks.
The Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide (May 20, 2020) includes the following safety criteria:
“For the State Highway System and connections with the State Highway S y s t em , C al t r an s m ay r eq u es t a t ar g et ed o p er at i o n al an d s af et y an al y s i s t o a d d r e s s a s p e c i f i c g e o m e t r i c o r o p e r a t i o n a l i s s u e , p a r t i c u l a r l y i s s u e s t h a t impact multimodal access or conflicts between modes. Improvements requested by Caltrans should avoid increases in VMT and should avoid degrading or adding stressors to pedestrians, bicyclists, and transit users.” 2/1/2024 Page 6
City of Menifee
Motte Business Center Project
Perris Appeal Comments and Responses
It should be noted that Caltrans responded to the Notice of Preparation (NOP) for the Project on December 7, 2022 (seeAttachment C) stating the following:
“We do not anticipate a significant amount of traffic to be generated from this s i t e t o a d v e r s e l y i m p a c t t h e n e a r e s t S H S f a c i l i t i e s . W e t h e r e f o r e h a v e n o comments to offer currently.”
The project applicant is required to construct sidewalks along the project frontage to enhance pedestrian safety in the area. The recommended improvements noted in the Project Traffic Study, would improve safety conditions in the study area, including the City of Perris study intersections.
The recommended improvements include the addition of turn lanes, traffic signalization, and the widening of Ethanac Road, which would not impact multimodal access or conflicts between modes.
The City of Menifee LOS Traffic Study Guidelines (October 2020) includes the following safety criteria in the “Safety and Operational Improvements” section and the “Special Uses” section of the guidelines:
“The TS (Traffic Study) shall examine existing roadway conditions to determine if safety and operational improvements are necessary due to an increase in traffic from the project or cumulative projects.” “In addition to the standard TS requirements, projects which are “truck intensive” (distribution centers, warehousing, etc.) may be required to submit a study addressing the truck access routes, adequacy of the existing streets to be used (in terms of geometry and structural section), safety issues relating to the truck traffic, and the impacts of the truck traffic on existing residences or businesses.”
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Motte Business Center Project
Perris Appeal Comments and Responses
c. Perris’ November 13 letter commented that as the traffic study analyzes City of Perris intersections, the City of Perris significance criteria thresholds should also be included and used to evaluate impacts at City of Perris intersections. Menifee Response F4 asserted that, based on a review of Perris’ significance criteria and applicable intersections located within the City of Perris, the Project’s recommended improvements included in the Traffic Study would cause the intersections to operate at an acceptable Level of Service (“LOS”).
H o w e v e r , P e r r i s n o t e d i n i t s D e c e m b e r 1 3 l e t t e r t h a t R e s p o n s e F 4 references outdated City of Perris LOS standards for the Proposed As noted earlier, the recommended improvements noted in the Project Traffic Study would improve safety conditions in the study area, including the City of Perris study intersections. The recommended improvements include the addition of turn lanes, traffic signalization, and the widening of Ethanac Road, which would reduce queue lengths and provide adequate sight distance along Ethanac Road and adjacent intersections. It should be noted that the recommended improvement at the intersection of Encanto Drive at Ethanac Road would restrict left turns out of the minor street approach (Encanto Drive), which improves overall safety by reducing the amount of conflict points at this intersection. It should be noted that the Project itself is designed to provide adequate sight distance at the project driveways, as well as to insure free-flowing and safe circulation on site, including no sharp turns for trucks.
Based on the aforementioned information, the Draft EIR and its technical appendices fully analyzed, disclosed, and provided mitigation for all project related impacts as well as cumulative impacts, including traffic, safety, air quality, noise, and greenhouse gas emissions impacts.
c. The Project Traffic Study included an analysis of both City of Menifee intersections as well as intersections within the City of Perris. Because the Project is located within the City of Menifee, standards developed by the City of Menifee were utilized to analyze impacts. This is common practice in CEQA documents throughout California so that all roadway segments and i n t e r s e c t i o n i m p r o v e m e n t s a r e a n a l y z e d s i m i l a r l y a n d a g a i n s t t h e s a m e baseline. Utilizing this methodology does not invalidate the Traffic Study nor does it make the traffic analysis flawed. The existing Traffic Study prepared for the Project was prepared by credible technical experts using standards recognized in the industry and was provided as part of the CEQA process as substantial evidence that the Project would not create Level of Service effects 2/1/2024 Page 8
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Motte Business Center Project
Perris Appeal Comments and Responses
Project . The most curr ent version of Perris’ LO S standards, whi ch ar e the appropriate standards of review, could cause changes to the results o f t h e a n a l y s e s . T h e C i t y o f P e r r i s i n t e r s e c t i o n s s h o u l d b e r e v i e w e d using the most current Perris LOS standards. Because Menifee failed to utilize Perris’ current LOS standards, the traffic analysis is flawed, not credible and therefore does not constitute substantial evidence. with the addition of recommended improvement as noted in the Project Traffic Study.
Although LOS analysis is not considered a significant impact under CEQA, the following response is provided for informational and disclosure purposes and utilizes the most current Perris LOS standards. Based on theCity of Perris LOS Standards and Traffic Criteria for Traffic Studies (not dated), below are the current City of Perris LOS standards and criteria:
Level of Service Standards
The City of Perris has established the following standards regarding minimum acceptable level of service (LOS):
· LOS “D” along all City maintained roads (including intersections) a n d L O S “ D ” a l o n g I - 2 1 5 a n d S R - 7 4 ( i n c l u d i n g i n t e r s e c t i o n s w i t h local streets and roads). An exception to the local road standard is LOS “E”, at intersections of any Arterials and Expressways with SR- 74, the Ramona-Cajalco Expressway, or at I-215 freeway ramps. · LOS “E” may be allowed within the boundaries of the Downtown Specific Plan Area to the extent that it would support transit- oriented development and walkable communities. Increased congestion in this area will facilitate an increase in transit ridership and encourage development of a complementary mix of land uses within a comfortable walking distance from light rail stations.
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Motte Business Center Project
Perris Appeal Comments and Responses
Thresholds of a Traffic Impact
The City of Perris standards also provide that a project would be considered to have a project-related effect based on the following criteria:
· A p r o j e c t - r e l a t e d t r a f f i c e f f e c t i s c o n s i d e r e d d i r e c t w h e n a s t u d y intersection operates at an acceptable Level of Service for existing conditions (without the project) and the addition of 50 or more AM or PM peak hour project trips causes the intersection delay to increase by 2 seconds or more and causes the intersection to operate at an unacceptable Level of Service for existing plus project conditions.
· A p r o j e c t - r e l a t e d t r a f f i c e f f e c t i s c o n s i d e r e d d i r e c t w h e n a s t u d y intersection operates at an unacceptable Level of Service for existing conditions (without the project) and the addition of 50 or more AM or PM peak hour project trips causes the intersection delay to increase by 2 seconds or more.
· A cumulative effect is considered direct when a study intersection is forecast to operate at an acceptable Level of Service without the project and with th e addition of 50 or more AM or PM peak hour project trips causes the intersection delay to increase by 2 seconds or more and causes the intersection to operate at an unacceptable Level of Service.
· A cumulative effect is considered an indirect traffic effect when a study intersection is forecast to operate at an unacceptable Level of Service with the addition of cumulative/background traffic and the 2/1/2024 Page 10
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Perris Appeal Comments and Responses
d. Project Trip Generation: P e r r i s ’ N o v e m b e r 1 3 c o m m e n t l e t t e r recommended that the traffic study utilize the latest ITE and SCAQMD editions when analyzing passenger car and truck splits for project trip generations, rather than the outdated City of Fontana Truck Trip Generation Study utilized by the Traffic Study. This would impact the l e v e l o f s e r v i c e a t s t u d y a r e a i n t e r s e c t i o n s , e s p e c i a l l y d u r i n g t h e A M peak hour.
Menifee Response F7 stated that difference in the Proposed Project’s trip generation may be considered nominal when analyzed under the latest ITE and SCAQMD editions, rather than the outdated City of Fontana Truck Trip Generation Study utilized by the Traffic Study. However, Perris noted in its December 13 letter that Menifee should show the project trip project contributes 50 or more AM or PM peak hour project trips and causes the intersection delay to increase by 2 seconds or more.
Based on review and comparison of the City of Perris significance criteria and applicable intersections located within or adjacent to the City of Perris, the recommended improvements noted in the Project Traffic Study at deficient study intersections and roadway segments would cause the study locations to operate at an acceptable Level of Service (LOS), would more than offset the project-related additional delay to such intersections, and would address the City of Perris significance criteria. As such, the conclusions of the LOS analysis using both City of Perris standards and City of Menifee standards would result in similar conclusions, although the methodology is somewhat different.
Recommended improvements would remain the same using both methodologies. Therefore, the Traffic Study prepared for the Project fully and adequately disclosed all improvements needed to both City of Menifee and City of Perris intersections.
d. The City of Fontana Truck Trip Generation Study is not considered outdated in the industry, and is widely accepted and used by many cities in the Inland Empire, including as noted in the City of Menifee LOS Traffic Study Guidelines (October 2020), as a method for obtaining truck trips and truck splits. The truck mix in the Fontana Truck Trip G e n e r a t i o n S t u d y i s c o m p a r a b l e t o t h e S C A Q M D t r u c k m i x recommendations. Also, as noted in the Project Traffic Study, the passenger car/truck splits are based on the ITE Trip Generation Manual (10 th Edition Supplement), which is comparable to the p as s en g er car /t r u ck s p l i t s i n t h e I T E T r i p G en er at i o n M an u al ( 1 1th Edition), as requested by the City of Perris. Nevertheless, in order to address this comment, as suggested by the City of Perris, the passenger car/truck split and truck mix for the proposed project have 2/1/2024 Page 11
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Motte Business Center Project
Perris Appeal Comments and Responses
g e n e r a t i o n c a l c u l a t i o n b a s e d o n I T E 1 1 t h E d i t i o n / S C A Q M D , a n d compares these two different volume forecasts to determine if different results may occur using the more recent truck percentage information.
Because Menifee failed to utilize the most current information available, again, the traffic analysis is flawed, not credible and therefore does not constitute substantial evidence
been reviewed based on the ITE Trip Generation Manual (11 th E d i t i o n ) f o r t h e p a s s e n g e r c a r / t r u c k s p l i t s a n d t h e S C A Q M D Warehouse Truck Trip Study Data Results and Usage (dated July 17, 2014) for the truck mix (i.e. 2-axle, 3-axle, 4+axle trucks) . A copy of the noted resources is provided in Attachment A (Passenger Car/Truck Splits and Truck Mix Information) to this response matrix.
The passenger car equivalent (PCE) factors as noted in the Traffic Study were also applied to these trip generation estimates. Based on the methodology noted above, the project is estimated to generate approximately 2,466 daily PCE trips, with 209 PCE trips (169 inbound and 40 outbound) in the morning peak hour and 201 PCE trips (78 inbound and 123 outbound) in the evening peak hour. The trip generation rates, PCE factors, and the resulting trip generation estimates for the project are summarized in Attachment A.
Compared to the trip estimates in the approved Traffic Study, the trip estimates based on the SCAQMD methodology (inclusive of ITE 11 th Edition for the p ass eng er car/truck splits) is est im ated to gener ate 158 ad d i t i o n al d a i l y P C E t r i p s , wi t h 1 6 ad d i t i o n al P C E t r i p s i n t h e m o r n i n g peak hour and 3 fewer PCE trips in the evening peak hour.
A supplemental traffic analysis was conducted with the proposed project trip generation based on the SCAQMD methodology at study locations entirely or a majority within the City of Perris. A summary table of the LOS results are provided in Attachment B to this response matrix. Based on review of the tables, with proposed project trip generation estimated based on the SCAQMD methodology and the recommended improvements noted in the Project Traffic Study, the study locations entirely or a majority within the City of Perris would operate at an acceptable Level of 2/1/2024 Page 12
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Perris Appeal Comments and Responses
Service. Therefore, the recommended improvements would remain the same.
Additionally, the air quality emissions associated with the suggested passen ger car/tru ck split and truck mix percentag e (IT E 155 trip rates, ITE 11 th E d i t i o n p a s s e n g e r c a r / t r u c k s p l i t a n d t h e S C A Q M D t r u c k m i x p er c en t ag es ) h av e b e en m o d el ed f o r i n f o r m at i o n al p u r p o s es . T h e t a b l e below shows that air quality emissions would not exceed the SCAQMD’s thresholds with the Draft EIR mitigation applied. Therefore, the use of ITE 11th E d i t i o n p a s s e n g e r c a r / t r u c k s p l i t s a n d S C A Q M D t r u c k m i x percentages would not change the significance determinations in the Draft EIR, would not require new or modified mitigation measures, and would not trigger the need to recirculate the EIR.
SCAQMD Truck Mix Scenario– Mitigated Operational Emissions Source Maximum Pounds Per Day
ROG NOX CO SO2 PM10 PM2.5
Area Source Emissions 35.48 0.42 49.52 0.00 0.07 0.09
Energy Emissions1 0.15 2.69 2.26 0.02 0.20 0.20
Mobile – Trucks 0.34 23.28 5.23 0.19 5.93 1.84
Mobile – Passenger Cars 3.71 2.99 71.03 0.21 23.82 6.07 Off-Road – Yard Truck 2 0.00 0.00 0.00 0.00 0.00 0.00
Back-up Generators 0.90 2.51 2.29 0.00 0.13 0.13
Total Emissions 40.58 31.89 130.33 0.42 30.15 8.33
SCAQMD Threshold 55 55 550 150 150 55
Exceeds Threshold? No No No No No No
ROG = Reactive Organic Gases; NO X = N i t r o g e n O x id e s ; C O = C a r b o n M o n o x i d e ; S O2 = Sulfur Dioxide; PM10 = Particulate Matter 10 microns in diameter or less; PM 2.5 = Particulate Matter 2.5 microns in diameter or less
Notes:
1. MM GHG-8 limits Project natural gas consumption to less than 10 million kBTU/year.
2. Per MM AQ-3, operational cargo handling equipment would be zero emission.
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs. 2/1/2024 Page 13
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The Draft EIR determined that health risk impacts would be less than significant (see Draft EIR pages 4.2-34 and 4.2-35). Additionally, the Draft EIR requires zero emission cargo handling equipment (MM AQ-3), which would further reduce health risk impacts. As described above, the trip generation suggested in the comment would result in more passenger car trips, but fewer truck trips than what was analyzed in the Draft EIR. The Draft EIR assumed 526 daily truck trips (1,947 total vehicle trips), while the methodology suggested in the comment would result in 261 daily truck trips (2,061 total vehicle trips), which is a truck trip reduction of approximately 50 percent. The reduction of daily truck trips would reduce health risk impacts from what is included in the Draft EIR. Therefore, the Draft EIR shows a worst-case health risk scenario and the conclusions in the Draft EIR would not change.
T h e D r a f t E I R d e t e r m i n e d t h a t G H G e m i s s i o n s w o u l d b e s i g n i f i c a n t a n d unavoidable despite the implementation of numerous mitigation measures. As d es cr i b ed ab o v e, t h e u s e o f I T E 1 1th Edition passenger car/truck splits and SCAQMD truck mix percentages would reduce truck trips and increase p a s s e n g e r t r i p s f r o m w h a t w a s a n a l y z e d i n t h e D r a f t E I R . B a s e d o n t h e modeling prepared for informational purposes using ITE 155 trip rates (11 th Edition) ITE 11 th Ed ition pass eng er car/tru ck splits and SCAQMD tru ck m ix percentages, mobile source GHG emissions would decrease by approximately 432 MTCO2e per year. Therefore, the Draft EIR shows a worst-case health risk scenario and additional GHG impacts would not occur and the conclusions in the Draft EIR would not change.
T h e S C A Q M D t r u c k m i x p e r c e n t a g e a s s u m p t i o n ( w i t h I T E 1 1th Edition p a s s e n g e r c a r / t r u c k s p l i t s ) w o u l d a l s o a f f e c t t r a f f i c n o i s e m o d e l i n g i n t h e Draft EIR. The Draft EIR determined that Project traffic noise impacts would be less than significant and noise levels would be below the City of Menifee’s 70 dBA Normally Acceptable noise standard (see Draft EIR pages 4.11-18 and 2/1/2024 Page 14
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e. Additionally, the City of Menifee also stated that they had submitted a scoping agreement to the City of Perris for review on January 13, 2023.
Even if Perris did not initially respond with comments on the scoping agreement, there is no evidence that Menifee followed up with Perris even once to seek Perris’ input.
4.11-19). As described above, the use of ITE 11th Edition passenger car/truck splits and SCAQMD truck mix percentages would reduce truck trips and increase passenger trips from what was analyzed in the Draft EIR. The d e c r e a s e i n t r u c k t r i p s ( d u e t o t h e u s e o f t h e I T E 1 1th Edition passenger car/truck splits and SCAQMD truck mix percentages) would offset the increase in car trips because trucks generate more noise than cars1. Therefore, the Draft EIR shows a worst-case traffic noise scenario and additional noise i m p a c t s w o u l d n o t o c c u r a n d t h e c o n c l u s i o n s i n t h e D r a f t E I R w o u l d n o t change.
As described above, the use of ITE 11th Edition passenger car/truck splits and SCAQMD truck mix percentages would not change the significance determinations in the Draft EIR and would not require new or modified mitigation measures.
e. As previously stated, the Traffic Scoping Agreement with trip generation a s s u m p t i o n s a s n o t e d i n T a b l e 3 o f t h e T r a f f i c S t u d y f o r t h e p r o p o s e d Project was sent to the City of Perris for review and input on January 13, 2 0 2 3 . P l a n n i n g M a n a g e r P a t r i c i a B r e n e s a c k n o w l e d g e d r e c e i p t o f t h e Traffic Scoping Agreement on January 13, 2023 .(see Attachment D) However, besides acknowledging receipt of the Traffic Scoping A g r e e m e n t , t h e C i t y o f P e r r i s d i d n o t p r o v i d e c o m m e n t s o n t h e T r a f f i c Scoping Agreement. Because no comments were provided by the City of Perris, the City of Menifee elected to proceed with the Traffic Study for the Project based on the assumptions in the Traffic Scoping Agreement. The City of Perris asserts that the City of Menifee should have followed up with the City of Perris to confirm that they did not have any comments on the 1 American Association of State Highway and Transportation Officials (AASHTO),Traffic Noise and Transportation, 2023. Available at:
http://environment.transportation.org/education/environmental-topics/traffic-noise/traffic-noise-overview/ 2/1/2024 Page 15
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f. Summary of Intersection Operations: As noted in the Perris November 13 letter, the Project directly impacts intersection #7 (Encanto Drive at Ethanac Road) and intersection #9 (Sherman Road at Ethanac Road) in the City of Perris. A direct impact implies that the project shall be 100% responsible that all necessary improvements are installed to mitigate these impacts (or via some other defined improvement program) prior to project occupancy. However, Menifee Response F8 notes that both Intersections #7 and #9 were considered to have a cumulative effect, as opposed to a direct project effect. Any improvements to portions of intersections shared with the City of Perris would be coordinated between t h e C i t y o f M e n i f e e a n d C i t y o f P e r r i s p r i o r t o f i n a l e n g i n e e r i n g f o r t h e Project.
The Perris December 13 letter noted that in determining the cumulative impact of the two intersections, the Traffic Study’s use of overall intersection delay for an unsignalized intersection is not appropriate and against traffic engineering practices. Perris again asserts that the Project directly impacts the intersections, and a direct impact implies that the project shall be 100% responsible that all necessary improvements are installed to mitigate these impacts (or via some other defined improvement program) prior to project occupancy.
Traffic Scoping Agreement. Similar to the City of Perris, City of Menifee staff constantly coordinate with dozens of other agencies on a daily basis, and as such, once the initial request for comments on the Traffic Scoping Agreement was sent, the City of Menifee expects that the City of Perris would provide any comments they may have. Nevertheless, the City of P er r i s ’ co m m en t d o e s n o t r a i s e an y s u b s t an t i al ev i d en c e o f an y n ew o r more severe environmental impacts.
f. Based on the Project Traffic Study and the City of Menifee significance c r i t e r i a , t h e P r o j e c t - r e l a t e d e f f e c t a t i n t e r s e c t i o n # 7 ( E n c a n t o D r i v e a t E t h an a c R o ad ) an d i n t er s ect i o n # 9 ( S h er m an R o ad at E t h an a c R o ad ) i s considered a cumulative effect.
Based on the City of Perris significance criteria, a direct effect would occur when “a study intersection operates at an unacceptable Level of Service for existing conditions (without the project) and the addition of 50 or more AM or PM peak hour project trips causes the intersection delay to increase by 2 seconds or more.”
The reported delay value (the value noted on the LOS Summary tables in the Traffic Study) for unsignalized intersections is based on the single approach movement with the highest delay, which in this case would be the northbound left-turn movement for both intersections #7 and #9 as the northbound left- turning vehicles have to wait for an acceptable gap in traffic on Ethanac Road.
R e f e r e n c e t o t h e o v e r a l l i n t e r s e c t i o n d e l a y w a s t o n o t e t h a t w h i l e t h e s i d e street approaches operate at a deficient Level of Service based on the highest delay approach, the overall intersection delay would be acceptable. Any queuing that occurs on the side streets are contained on the minor intersection approaches and do not impact the progression of traffic on the main arterials.
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Furthermore, these impacts to intersections create potential traffic safety issues associated with the interface between vehicles and trucks.
As such, this should have been identified as a potentially significant traffic safety impact for which mitigation was required.
Based on the City of Perris significance criteria, the information noted above regarding delay for unsignalized intersections, and review of the analysis w o r k s h e e t s f o r i n t e r s e c t i o n s # 7 a n d # 9 u n d e r E x i s t i n g a n d E x i s t i n g P l u s Project conditions, as provided in the appendices to the Project Traffic Study, only intersection #9 (Sherman Road at Ethanac Road) would cause a direct project-related effect based on the City of Perris significance criteria as the overall intersection delay would increase by more than 2 seconds with the addition of project traffic. However, as noted previously, the single-approach movement with the highest delay that causes intersection #9 to operate at an unacceptable Level of Service under Existing Conditions is the northbound left-turn movement, which is located entirely within the City of Menifee. As such, the City of Menifee significance criteria should be applied to intersection #9. Therefore, the Project-related effect at intersection #9 is considered a cumulative effect.
Intersection #7 (Encanto Drive at Ethanac Road) would be considered a cumulative effect based on the City of Perris significance criteria as the overall intersection delay would not increase by 2 or more seconds with the addition of project traffic under Existing Plus Project conditions.
With regards to construction of recommended improvements at intersections #7 and #9 (as noted in the Project Traffic Study), the City of Menifee typically conditions a project to construct the recommended improvements noted in a traffic study. However, in the case that another development project, whether i n t h e C i t y o f M e n i f e e o r t h e C i t y o f P e r r i s , i s c o n s t r u c t e d f i r s t a n d a l s o constructs the same off-site traffic improvements noted in the original project’s traffic study, the development projects’ developers can enter into an a g r e e m e n t b a s e d o n f a i r - s h a r e t o w a r d s t h e c o n s t r u c t i o n o f t h e o f f - s i t e improvements.
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g. Summary of Intersection Operation Opening Year 2025 Cumulative Plus Project: Perris’ November 13 comment letter noted that the Traffic Study indicates that several intersections in the vicinity of the City of Perris , including inters ect ions #5, #6, #7 , #8 and #9, ar e not meeting level service standards and indicates that the project has a cumulative impact at these locations. The study further indicated what improvements are needed at those intersections and an accompanying project fair-share cost percentage. However, it is unclear how these improvements would be implemented and who would be responsible for providing the required improvements. Additional detail is needed on t h e f u n d i n g m e c h a n i s m s t h a t w i l l b e u t i l i z e d t o m a k e t h e s e r e q u i r e d improvements.
Menifee Response F10 stated that the implementation of improvements is based on direct discussion between City staff and the Applicant via the Conditions of Approval process. Further, the project is conditioned on traffic-related improvement requirements, including those related to the intersections, prior to Certificate of Occupancy. Further, the response states that any improvements to portions of intersections or roadways shared with the City of Perris would be coordinated between the City of Menifee and City of Perris prior to final engineering for the Project.
However, the Perris December 13 letter re-iterated that the Project Traffic Study must show how these improvements will improve delays at the City of Perris previously identified intersections, which Menifee S e e R e s p o n s e t o C o m m e n t 2 b r e g a r d i n g e v a l u a t i o n o f s a f e t y i m p a c t s . T h e proposed project would not create significant traffic safety impacts and the recommended improvements in the Project Traffic Study would help improve traffic safety, as noted in Response to Comment 2b.
g. The Traffic Study fully analyzed impacts to all study intersections, whether they are located within the City of Menifee, City of Perris, or a combination of both. All required improvements located within the City of Menifee would be c o o r d i n a t e d a n d a p p r o v e d b y t h e C i t y o f M e n i f e e . S i m i l a r l y , a n y improvements located within the City of Perris would be coordinated and approved directly with the City of Perris staff. For those intersections in both Menifee and Perris, coordination and approval of improvements would be obtained by both agencies. The funding mechanism for the recommended improvements for intersections within the jurisdiction in the City of Perris would be fair-share payments to be coordinated with the City of Menifee and the City of Perris.
Improvements in delay with the recommended improvements at study intersections are provided in Table 11 “Summary of Intersection Operation – Recommended Improvements” of the Project Traffic Study. The recommended improvements noted in the MBC Traffic Study at deficient study intersections and roadway segments would cause the study locations to operate at an acceptable Level of Service (LOS), would more than offset the project-related effect, and would address the City of Perris significance criteria (see Response to Comment 2c.).
See Response to Comment 2f regarding improvements to intersections #7 and #9.
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R e s p o n s e F 1 0 d o e s n o t a d d r e s s . F u r t h e r , t h e P r o j e c t s h a l l b e 1 0 0 % responsible for all necessary improvements to mitigate the impacts at any directly impacted study intersections, such as intersections #7 and #9 as discussed in further detail above.
h. I n s u m m a r y , t h e p u r p o s e o f a n e n v i r o n m e n t a l i m p a c t r e p o r t i s t o disclose to the public and decision makers the significant environmental impacts of a Project and mitigation measures and alternatives to the project that would avoid or substantially lessen those impacts.
Unfortunately, the traffic analysis in this EIR fails as a disclosure document for the reasons set forth above. Therefore, the traffic analysis s h o u l d b e r e v i s e d i n l i g h t o f P e r r i s ’ c o m m e n t s a n d r e c i r c u l a t e d f o r public review.
h. The Draft EIR prepared for the proposed Project fully discloses to the public and decision makers all environmental impacts, as required by CEQA. The Draft EIR provides mitigation measures and alternatives that avoid and/or reduce impacts, as noted throughout the Draft EIR. As previously discussed, the Traffic Study, attached to the Draft EIR as Appendix K, fully discloses all impacts of the Project and recommended i m p r o v e m e n t s n e e d e d f o r b o t h V e h i c l e M i l e s T r a v e l l e d a n d L e v e l o f Service. Based on the City of Perris’s concerns, as noted above, additional Level of Service analysis was conducted using City of Perris standards (refer to Attachment B). Bas ed on revi ew of the t ables , with proposed project trip generation estimated based on the SCAQMD methodology and the recommended improvements noted in the Project Traffic Study, the study intersections within or adjacent to the City of Perris would operate at an acceptable Level of Service. Therefore, the recommended improvements would remain the same.
As noted earlier, automobile delay no longer is considered an e n v i r o n m e n t a l i m p a c t . A V M T S t u d y w a s p r e p a r e d f o r t h e p r o p o s e d project, which noted that the proposed project would cause a less-than- significant VMT/transportation impact. Therefore, no mitigation measures are required for the proposed project. With regards to traffic safety impacts, the proposed project would not create significant traffic safety impacts and the recommended improvements in the MBC Traffic Study would help improve traffic safety, as noted in Response to Comment 2b.
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3. Insufficient Analysis of Air Quality Impacts:
a. I n i t s c o r r e s p o n d e n t d a t e d N o v e m b e r 9 , 2 0 2 3 t h e S o u t h C o a s t A i r Quality Management District identifies numerous deficiencies in the EIR’s air quality analysis including inconsistent use of trip generation rates and vehicle fleet mix between the air quality studies and the traffic s t u d i e s . P e r r i s e c h o e s t h e s e c o n c e r n s . I n i t s r e s p o n s e s t o t h e A i r District’s comments, Menifee explains away the discrepancies claiming they were done in order to ensure a conservative “worst case” analysis The Traffic Study prepared for the Project fully meets the requirements of CEQA and the City guidelines for traffic studies. The Traffic Study does not need to be revised based on the aforementioned information. The City of Perris’s comments have been fully addressed within this Response Matrix and with the additional information provided in Attachments A through D of this document. As previously stated, even utilizing the City of Perris’s Level of Service methodology, the improvements needed to both Perris facilities and Menifee facilities would remain the same. As such, the Traffic Study included as Appendix K to the Draft EIR is fully sufficient as a disclosure document.
Pursuant to CEQA Guidelines Section 15088.5, a Lead Agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification.
None of the information provided by the City of Perris identify a new significant environmental impact, a substantial increase in the severity of an environmental impact for which mitigation is not proposed, or a new feasible alternative or mitigation measure that would clearly lessen significant environmental impacts but is not adopted. As such, recirculation is not warranted.
3. a. The comment incorrectly states that the SCAQMD found numerous deficiencies in the Draft EIR’s air quality analysis. The SCAQMD incorrectly identified a discrepancy between the truck trips reported on page 19 of the Air Quality Assessment. As described in the Final EIR, Air Quality assessment page 19 correctly notes that 526 truck trips were modeled, which is consistent with the number of truck trips modeled and shown in the CalEEMod outputs.
The Draft EIR and supporting Air Quality Assessment do not use 562 trips, as 2/1/2024 Page 20
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Perris Appeal Comments and Responses
for both traffic and air quality impacts. However, relegating this explanation to a footnote does not engender great confidence in the rationale for utilizing different assumptions for the traffic study and air quality studies.
suggested by the SCAQMD comment. The Final EIR responses explained that a c o n s e r v a t i v e t r u c k p e r c e n t a g e a n d t r i p g e n e r a t i o n r a t e w a s u s e d s o t h a t emissions would not be underestimated. Additionally, implementation of the SCAQMD suggested mitigation measures were not required because the Draft EIR did not identify a significant impact; therefore, no mitigation is required for the Project. Furthermore, the Final EIR explains that many of the suggested mitigation measures are already required by existing regulation, including the City of Menifee building code and the City’s Good Neighbor Policies.
As discussed in the Draft EIR and the Final EIR, different trip generation rates w e r e i n t e n t i o n a l l y s e l e c t e d f o r t h e A i r Q u a l i t y A s s e s s m e n t a n d t h e T r a f f i c Study to conservatively capture a worst-case scenario for each study. Truck emi ssions ar e a gr eater contributor to air qu ality emiss i ons than passeng er cars. Therefore, the Air Quality Assessment used a trip generation with a higher number of daily truck trips, while the Traffic Study used a trip generation with a higher number of total daily vehicles.
T h e c o m m e n t e x p r e s s e s a n o p i n i o n a b o u t e x p l a i n i n g t h e d i s c r e p a n c y i n a footnote. However, the Traffic Study (Draft EIR Appendix K) clearly explains the trip generation used (see page 17 and Table 3 of the Traffic Study). The Air Quality Assessment (Draft EIR Appendix B) methodology discussion clearly explains the trip generation rate that was modeled for the project emissions analysis (see page 19 in the Air Quality Assessment). Furthermore, footnote 4 (page 19) of the Air Quality Assessment mobile source emissions methodology discussion clearly explains the trip generation difference and also explains this approach was intentionally selected to provide a conservative, worst- case, analysis. As described above, the use of the suggested trip generation and SCAQMD truck trips would not change the significance determinations in the Draft EIR and would not require new or modified mitigation measures. 2/1/2024 Page 21
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Perris Appeal Comments and Responses
4. Inadequate Alternatives Analysis:
a. An EIR is required to describe a range of reasonable alternatives to the project which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant e f f e c t s o f t h e p r o j e c t . ( C E Q A G u i d e l i n e s , s e c t i o n 1 5 1 2 6 . 6 ( a ) ) T h e E I R identified significant an unavoidable impacts related Air Quality and GHG according to the discussion of Alternatives 2 and 3. However, the Table ES-1 states that all Air Quality Impacts are less than significant. Be that as it may, in addition to the required “No Project” alternative, the EIR contains only two other alternatives, Alternative 2 – the Reduced B u i l d i n g A l t e r n a t i v e ( 1 5 P e r c e n t R e d u c t i o n ) a n d A l t e r n a t i v e 3 – Building Square Footage Reduction with Additional Trailer Parking.
The analysis of Alternative 2 states that it would lessen the Air Quality a n d G H G i m p a c t s b u t n o t t o l e v e l s o f l e s s t h a n s i g n i f i c a n t . H o w e v e r , there is no discussion that this alternative “substantially lessens” either the Air Quality or the GHG significant impacts. Furthermore, the analysis then utilizes a standard different that that set forth in CEQA Guidelines, section 15126.6 regarding meeting project objectives. The standard is “feasibly attain most of the basic objectives of the project.” However, the analysis states Alternative 2 does not maximize the City’s benefits realized or achievement of the Project Objectives when compared to the proposed Project. This is not the standard for determining the adequacy of an alternative and represents procedural error.
T h e a n a l y s i s o f A l t e r n a t i v e 3 s u f f e r s f r o m t h e s a m e d e f e c t s a s t h e analysis of Alternative 2.
The EIR is required to contains alternatives that “avoid or substantially lessen” a project’s s igni fi cant imp acts . Th e E IR fails in t his regard and
4. a. The reference to significant and unavoidable air quality impacts within Chapter 6, Alternatives, w a s i n e r r o r . A s i d e n t i f i e d i n i n T a b l e E S - 1 o f t h e Executive Summary Chapter of the Draft EIR, as well as Chapter 4.7, the Project has one significant and unavoidable impact, as noted below, and does not have any significant and unavoidable air quality impacts:
i. Greenhouse Gas Emissions
a. Despite consistency with the City’s General Plan, California Air Resources Board’s 2022 Scoping Plan, and Southern
California Association of Government’s Connect SoCal,
incorporation of all feasible mitigation measures and
compliance with all applicable local, state, or federal regulations or laws, the Project’s operational mitigated mobile source emissions would continue to exceed the
SCAQMD MTCO2e threshold.
Further, while there was a minor typographical error in the alternatives chapter, this does not warrant recirculation of the DEIR pursuant to CEQA Guidelines Section 15088.5, as this error does not identify a new significant environmental impact, a substantial increase in the severity of an environmental impact for which mitigation is not proposed, or a new feasible alternative or mitigation measure that would clearly lessen significant environmental impacts but is not adopted. In addition, the changes do not reflect a fundamentally flawed or conclusory DEIR.
Additionally, the alternatives analyzed in the Draft EIR were chosen to avoid and/or reduce the proposed Project’s impacts. Both Alternative 2 and Alternativ e 3 reduce m any impacts wh en compar ed to the Project (refer to Table 6-3 in Chapter 6, Alternatives, of the EIR). Neither the Public Resources 2/1/2024 Page 22
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Perris Appeal Comments and Responses
also fails to explain why it is unable to provide such alternatives. The alternatives analysis is also defective as it fails to consider alternatives that would avoid or substantially lessen the other significant impacts of the project, without mitigation, as required by CEQA. As such, the alternatives analysis fails to comply with CEQA.
Code nor the State CEQA Guidelines require a specific number of alternatives be evaluated, rather only those alternatives necessary to foster informed decision-making. As defined in CEQA Guidelines Section 15126.6(f), the rule of reason limits alternatives analyzed to those that would avoid or substantially lessen one or more of the significant effects of a project. Of those alternatives, an EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. As such, the alternatives analysis contained within the Draft EIR fully comply with CEQA.
P u r s u a n t t o P R C 2 1 1 0 0 a n d i n a c c o r d a n c e w i t h t h e g u i d a n c e i n C E Q A Guidelines §15126.6, the City conducted an alternatives analysis that includes a range of reasonable alternatives that would feasibly attain most of the basic objectives of the Project consistent with CEQA §15124(b), while avoiding or l e s s e n i n g i m p a c t s . S e e D E I R S e c t i o n 6 f o r a d i s c u s s i o n o f a l t e r n a t i v e s considered.
Alternative 2 would likely reduce emissions impacts through a reduction in energy use in a smaller space. However, the energy usage rate of the Project site would remain similar. Even with a reduction in energy use emissions, the mobile source emissions associated with vehicular travel would not be largely reduced. Therefore, Alternative 2 would likely remain in excess of the City’s GHG emissions thresholds. This is considered a conservative determination because GHG emissions were not modeled for the alternatives analysis. CEQA Guidelines Section 15126.6(d) states that alternatives do not need to be described or analyzed at the same level of detail as the Project, and as such, modeling for the alternatives was not conducted. Therefore, the assumption t h a t A l t e r n a t i v e 2 w o u l d l i k e l y r e m a i n i n e x c e s s o f t h e C i t y ’ s t h r e s h o l d s i s conservative. The impact would be expected to remain a significant and unavoidable impact.
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Alternative 2 would meet all of the Project Objectives. However, Alternative 2 does not maximize the City’s benefits realized or achievement of the Project Objectives when compared to the proposed Project due to the reduced building square footage (200,000 SF) of interior mezzanine.
Alternative 3 would result in less intensive impacts concerning air quality, energy, greenhouse gas emissions, noise, and transportation impacts than the proposed Project due to shorter construction timeline and a smaller building footprint. Additionally, Alternative 3 would meet all of the Project Objectives.
H o w e v e r , A l t e r n a t i v e 3 d o e s n o t m a x i m i z e t h e C i t y ’ s b e n e f i t s r e a l i z e d o r achievement of the Project Objectives when compared to the proposed Project due to the 38.5 percent reduction in building size (700,000 SF remaining) with t h e e x c e s s l a n d f o r t r a i l e r / a u t o p a r k i n g l o t c o n s i s t i n g o f 6 1 6 a u t o m o b i l e parking stalls and 684 trailer parking stalls. Specifically, Alternative 3 would not generate as many job opportunities within the City when compared to the proposed Project. It would also not maximize the development potential of the Project site as the building footprint would be smaller.
Additionally, pursuant to CEQA Guidelines Section 15126.6(d), alternatives do not need to be described or analyzed at the same level of detail as the Project.
Sufficient detail and analysis have been provided in Chapter 6, Alternatives, of the Draft EIR, such that the Lead Agency can differentiate the impacts between the alternatives to select the Environmentally Preferred Alternative.
ATTACHMENT A
PASSENGER CAR/TRUCK SPLITS AND
TRUCK MIX INFORMATION
SCAQMD Warehouse Truck
Study Truck Fleet Mix
Grouping All Trucks
Actual %
2-Axle 3-Axle 4+ Axle
SCAQMD Composite 31.0% 6.8% 5.5% 18.7%
With Cold Storage 44.7% 15.5% 4.9% 24.3%
Without Cold Storage 27.5% 4.6% 5.7% 17.2%
Fontana Study 20.4% 3.5% 4.6% 12.3%
3 Grouping All Trucks
Normalized %
2-Axle 3-Axle 4+ Axle
SCAQMD Composite 31.0% 21.9% 17.7% 60.3%
With Cold Storage 44.7% 34.7% 11.0% 54.4%
Without Cold Storage 27.5% 16.7% 20.7% 62.5%
Fontana Study 20.4% 17.2% 22.5% 60.3%
ITE AM Peak Hour PM Peak Hour
Code Unit Daily In Out Total In Out Total
155 KSF 1.810 0.122 0.029 0.150 0.062 0.098 0.160
1.580 0.106 0.025 0.131 0.058 0.092 0.150
0.230 0.016 0.004 0.020 0.004 0.006 0.010
AM Peak Hour PM Peak Hour
Quantity Unit Daily In Out Total In Out Total
1,138.638 KSF 2,061 139 33 172 71 112 183
1,800 121 29 150 67 105 172
261 18 4 22 4 7 11
AM Peak Hour PM Peak Hour
Daily In Out Total In Out Total
Passenger Vehicles -- 1,800 1.0 1,800 121 29 150 67 105 172 2-Axle Trucks 16.7% 44 1.5 66 5 1 6 1 2 3
3-Axle Trucks 20.7% 54 2.0 108 8 2 10 2 3 5
4+ Axle Trucks 62.6% 164 3.0 492 35 8 43 8 13 21
Total Truck PCE Trips 666 48 11 59 11 18 29
Total Project PCE Trips 2,466 169 40 209 78 123 201
Total Project PCE Trips from Appro ved MBC Traffic Study 2,308 156 37 193 79 125 204 Net Trip Difference (SCAQMD Trips - Appro ved Trips) 158 13 3 16 -1 -2 -3 PCE = Passenger Car Equivalent
KSF = Thousand Square Feet
Passenger Vehicles
Trucks
PROJECT TRIPS - PASSENGER CAR EQUIVALENTS (PCE)
Vehicle Type Truc
k Mix 2 Daily
Vehicles
PCE
Factor
1 Source: Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition 2 Truck mix percentages based on the SCAQMD Warehouse Truck Study Truck Fleet Mix for "Without Cold Storage" Warehouse.
PROJECT TRIP GENERATION
Project Land Use
High-Cube Fulfillment Center Warehouse - Non-Sort
TABLE A
SUMMARY OF PROJECT TRIP GENERATION - BASED ON SCAQMD METHODOLOGY MOTTE BUSINESS CENTER PROJECT
TRIP GENERATION RATES 1
ITE Land Use
High-Cube Fulfillment Center Warehouse - Non-Sort
Passenger Vehicles (87.3% Daily, 86.7% AM, 93.7% PM)
Trucks (12.7% Daily, 13.3% AM, 6.3% PM)
Motte Business Center
Response to Comments
Kimley-Horn Associates Inc.
February 2024
ATTACHMENT B
INTERSECTION AND ROADWAY
LEVEL OF SERVICE RESULTS
TABLE 1
SUMMARY OF INTERSECTION OPERATION
EXISTING CONDITIONS
Traffic AM Peak Hour PM Peak Hour
Int. # Intersection Control Delay LOS Delay LOS
7 Encanto Drive at Ethanac Road U 38.3 E 41.8 E
8 Trumble Road at Ethanac Road S 22.5 C 21.0 C
Notes:
- Bold values indicate intersections operating at an unacceptable Level of Service - Delay values for unsignalized intersections represent the average vehicle delay on the worst (highest delay) intersection approach.
S = Signalized
U = Unsignalized
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
AM Peak Hour PM Peak Hour
Int. # Intersection Traffic
Control Delay LOS Delay LOS Delay LOS Delay LOS
7 Encanto Drive at Ethanac Road U 38.3 E 51.0 F 12.7 Yes 41.8 E 55.7 F 13.9 Yes 8 Trumble Road at Ethanac Road S 22.5 C 21.9 C -0.6 No 21.0 C 20.2 C -0.8 No EXISTING PLUS PROJECT
SUMMARY OF INTERSECTION OPERATION
Without Project With Project
Notes:
- Bold values indicate intersections operating at an unacceptable Level of Service Project-
Related
Effect?
Change
in
Delay
Change
in
Delay
Project-
Related
Effect?
TABLE 4
Without Project With Project
- Delay values for unsignalized intersections represent the average vehicle delay on the worst (highest delay) intersection approach.
S = Signalized
U = Unsignalized
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
TABLE 7
SUMMARY OF INTERSECTION OPERATION
OPENING YEAR 2025 CUMULATIVE
Traffic AM Peak Hour PM Peak Hour
Int. # Intersection Control Delay LOS Delay LOS
7 Encanto Drive at Ethanac Road U >180 F >180 F
8 Trumble Road at Ethanac Road S 101.3 F 124.8 F
Notes:
- Bold values indicate intersections operating at an unacceptable Level of Service - Delay values for unsignalized intersections represent the average vehicle delay on the worst (highest delay) intersection approach.
S = Signalized
U = Unsignalized
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
AM Peak Hour PM Peak Hour
Int. # Intersection Traffic
Control Delay LOS Delay LOS Delay LOS Delay LOS
7 Encanto Drive at Ethanac Road U >180 F >180 F - Yes >180 F >180 F - Yes 8 Trumble Road at Ethanac Road S 101.3 F 126.8 F 25.5 Yes 124.8 F 152.8 F 28.0 Yes Project-
Related
Effect?
Without Project With Project
Change
in Delay
Project-
Related
Effect?
Notes:
- Bold values indicate intersections operating at an unacceptable Level of Service - Delay values for unsignalized intersections represent the average vehicle delay on the worst (highest delay) intersection approach.
S = Signalized
U = Unsignalized
TABLE 9
SUMMARY OF INTERSECTION OPERATION
OPENING YEAR 2025 CUMULATIVE PLUS PROJECT
Without Project With Project
Change
in Delay
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
OPENING YEAR 2025 CUMULATIVE PLUS PROJECT
Int. # Intersection Improvements Delay LOS Delay LOS Delay LOS AM >180 F >180 F 27.3 D
PM >180 F >180 F 24.9 C
AM 101.3 F 126.8 F 32.4 C
PM 124.8 F 152.8 F 43.8 D
Proposed
Traffic
Control
Peak
Hour
TABLE 11
SUMMARY OF INTERSECTION OPERATION
RECOMMENDED IMPROVEMENTS
Without Project With Project
Add 2nd eastbound through lane
Add 2nd westbound through lane
U
S8
7 S = Signalized
U = Unsignalized
With Improvements
Trumble Road at Ethanac Road
Add 2nd eastbound through lane
Add 2nd westbound through lane
Modify the northbound shared left-turn/right-
lane to a dedicated right-turn lane only
Notes:
- Bold values indicate intersections operating at an unacceptable Level of Service Encanto Drive at Ethanac Road
- Delay values for unsignalized intersections represent the average vehicle delay on the worst (highest delay) intersection approach.
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
I-215 NB Ramps to Encanto Drive 2-Lane Arterial 15,813 13,000 1.216 F Trumble Road to Sherman Road 2-Lane Arterial 12,086 13,000 0.930 E Notes: 1 Source: City of Menifee Engineering Department, LOS Traffic Study Guidelines, October 2020 LOS = Level of Service
ADT = Average Daily Traffic
V / C = Volume to Capacity
TABLE 2
SUMMARY OF ROADWAY SEGMENT ANALYSIS
EXISTING CONDITIONS
V/CExisting
ADTSegmentRoadway LOSLOS E
Capacitiy1
Existing
Configuration
Ethanac Road
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
Roadway Segment Existing Configuration Existing
ADT
Project
ADT
Existing Plus
Project ADT
LOS E
Capacitiy1 V/C LOS
I-215 NB Ramps to Encanto Drive 2-Lane Arterial 15,813 1,584 17,397 13,000 1.338 F Trumble Road to Sherman Road 2-Lane Arterial 12,086 1,584 13,670 13,000 1.052 F Notes: 1 Source: City of Menifee Engineering Department, LOS Traffic Study Guidelines, October 2020 ADT = Average Daily Traffic
V / C = Volume to Capacity
LOS = Level of Service
TABLE 5
SUMMARY OF ROADWAY SEGMENT ANALYSIS
EXISTING PLUS PROJECT
Ethanac Road
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
Roadway Segment Existing
ADT
Opening Year
2025
Base ADT
Cumulative
Projects
Opening Year
2025
Cumulative
ADT
LOS E
Capacitiy1 V/C LOS
I-215 NB Ramps to Encanto Drive 15,813 16,762 8,620 25,382 13,000 1.952 F Trumble Road to Sherman Road 12,086 12,811 6,660 19,471 13,000 1.498 F Notes: 1 Source: City of Menifee Engineering Department, LOS Traffic Study Guidelines, October 2020 ADT = Average Daily Traffic
V / C = Volume to Capacity
TABLE 8
SUMMARY OF ROADWAY SEGMENT ANALYSIS
OPENING YEAR 2025 CUMULATIVE
LOS = Level of Service
Ethanac Road
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
Roadway Segment
Opening Year
2025
Cumulative
ADT
Project ADT
Opening Year
2025
Cumulative
Plus Project
ADT
LOS E
Capacitiy1 V/C LOS
I-215 NB Ramps to Encanto Drive 25,382 1,584 26,966 13,000 2.074 F Trumble Road to Sherman Road 19,471 1,584 21,055 13,000 1.620 F Notes: 1 Source: City of Menifee Engineering Department, LOS Traffic Study Guidelines, October 2020 ADT = Average Daily Traffic
V / C = Volume to Capacity
TABLE 10
SUMMARY OF ROADWAY SEGMENT ANALYSIS
OPENING YEAR 2025 CUMULATIVE PLUS PROJECT
LOS = Level of Service
Ethanac Road
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
Roadway Segment Existing Configuration Recommended
Configuration
Opening Year
2025
Cumulative
ADT
Project ADT
Opening Year
2025 Plus
Project ADT
Recommended
LOS E Capacitiy1 V/C LOS
I-215 NB Ramps to Encanto Drive 2-Lane Arterial 4-Lane Arterial 25,382 1,584 26,966 37,000 0.729 C Trumble Road to Sherman Road 2-Lane Arterial 4-Lane Arterial 19,471 1,584 21,055 37,000 0.569 A Notes: 1 Source: City of Menifee Engineering Department, LOS Traffic Study Guidelines, October 2020 ADT = Average Daily Traffic
V / C = Volume to Capacity
LOS = Level of Service
TABLE 12
SUMMARY OF ROADWAY SEGMENT ANALYSIS WITH IMPROVEMENTS
OPENING YEAR 2025 CUMULATIVE PLUS PROJECT
Ethanac Road
Motte Business Center Project
Response to Comments
Kimley-Horn and Associates, Inc.
February 2024
ATTACHMENT C
CALTRANS NOP RESPONSE LETTER
“Caltrans improves mobility across California”
STATE OF CALIFORNIA------- BUSINESS, TRANSPORTATION AND HOUSING AGENCY EDMUND G. BROWN Jr. Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 8
PLANNING
464 WEST 4th STREET, 6th Floor MS 725
SAN BERNARDINO, CA 92401-1400
PHONE (909) 383-4557
FAX (909) 383-6890
TTY (909) 383-6300
F lex your power!
Be energy efficient!
D
ecember 7, 2022
C
ity of Menifee
Brett Hamilton
29844 Haun Road
Menifee, California 92586
M
otte Business Center NOP (PLN22-0114). Riv-215-PM 22.754 M
r. Hamilton,
We h
ave completed our review for the above notification for the project located east of Interstate 215 (I-215) in the City of Menifee south of Ethanac Road, west of Antelope Road and east of Dawson Road. This project calls for the construction of a concrete ti lt-up building totalin g 1,138,638 square-feet. Site development also includes 610 automobile parking spaces, and 282 truck trailer parking spaces.
A
s the owner and operator of the State Highway System (SHS), it is our responsibility to coordinate and consult with local jurisdictions when proposed development may impact our facilities. As the responsible agency under the California Environmental Quality Act (CEQA), it is also our responsibility to make recommendations to offset associated impacts with the proposed project. Although the project is under the jurisdiction of the City of Menifee due to the Project’s potential impact to State facilities it is also subject to the policies and regulations that govern the SHS.
W
e do not anticipate a significant amount of traffic to be generated from this site to adversely impact the nearest SHS facilities. We therefore have no comments to offer currently.
H
owever, if this development proposal is later modified in any way, the above c omment may become invalid. Please forward copies of revised plans as necessary so that we may reevaluate all proposed changes for possible impact to the nearby State Highways.
Wh
en dev elopment does occur, any work performed within the SHS will require review and issuance of a Caltrans E ncroachment Permit. As part of the encroachment permit process, the developer must provide evidence of City entitlement a long with appropriate environmental approval for potential environmental impacts to State Highway R/W. Additional information will be provided in the event encroachment is later determined necessary.
M
r. Hamilton
December 7, 2022
“Caltrans improves mobility across California”
I
f you have any questions regarding this letter, please contact Talvin Dennis at (909) 963-9608 for assistance.
S
incerely,
R
OSA F. CLARK
Office Chief
Land Development Review
ATTACHMENT D
CITY OF PERRIS NOP RECEIPT EMAIL
CITY OF PERRIS TRAFFIC SCOPING
RECEIPT EMAIL
1 From: Patricia Brenes <[email protected]>
Sent: Friday, January 13, 2023 6:05 PM
To: Brett Hamilton
Cc: Kenneth Phung; Stuart McKibbin
Subject: RE: Motte Business Center Traffic Scoping
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Thank you Brett! Have a nice weekend.
Please be informed that the Development Services Department is temporarily relocating to the following location:
ØFront Counterstaff consisting of building, planning, housing, and business license has relocated temporarily to 11 S. D Street effective Tuesday, September 6th. Please mail and submit plans to the new location.
Ø The balance of the Planning and Housing staff will be relocating temporarily to1093 Harley Knox Boulevard.
Due to limited office areas, staff will be available to meet via zoom unt il further notice by emailing [email protected] the assigned planner. Special arraignment can be made to meet in person by request.
Thank you,
Patricia Brenes
PlanningManager
City of Perris
Development Services Department | Planning Division
101 N. D Street
Perris, CA 92570
951-943-5003 Ext 355
[email protected]
Below are helpful links:
Link for City applications: https://www.cityofperris.org/our-city/city-hall/city-forms/-folder-155 Link for City cannabis applications: https://www.cityofperris.org/our-city/city-hall/city-forms/-folder-147 Link for City fee schedule: https://www.cityofperris.org/home/showpublisheddocument/2537/637217201195900000 Link for City Development Impact Fees:
https://www.cityofperris.org/home/showpublisheddocument/13652/637775940661530000 Link for City GIS / Zoning Information: https://www.cityofperris.org/our-city/about-perris/maps Link for City Municipal Code: https://library.municode.com/ca/perris/codes/code_of_ordinances Link for City Specific Plans: https://www.cityofperris.org/departments/development-services/specific-plans Link for City General Plan, Special Studies, and Policy Documents:
https://www.cityofperris.org/departments/development-services/general-plan Link for CEQA Documents in Public Review: https://www.cityofperris.org/departments/development- services/planning/environmental-documents-for-public-review 2 From: Brett Hamilton <[email protected]>
Sent: Friday, January 13, 2023 4:52 PM
To: Patricia Brenes <[email protected]>
Cc: Kenneth Phung <[email protected]>; Stuart McKibbin <[email protected]> Subject: Motte Business Center Traffic Scoping
Patricia,
Please see the attached traffic scoping forms for Motte Business Center. Please let us know if you have anycomments in addition to the NOP response sent today.
Best,
Brett Hamilton, AICP | Senior Planner
Community Development Department – Planning Division
“Creating a HEALTHY, VIBRANT, and CONNECTED community for everyone.” City of Menifee | 29844 Haun Road | Menifee, CA 92586
Direct: (951) 723-3747| City Hall: (951) 672-6777 | Fax: (951) 723-2579 [email protected] | www.cityofmenifee.us
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