Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 1
Comment #1
that the project would have a direct impact to the intersection of Sherman Road at Ethanac Road as shown under Existing Plus Project traffic conditions resulting in potential safety issues. As a result of this, the project should be 100% responsible for improving this intersection to an acceptable level of service.
Also, the Perris Travel Center project is located north of Ethanac Road between the I-215 Freeway and Trumble Road within the City of Perris. The traffic study for that project prepared by Kimley Horn (June 2024) indicated the LOS at the intersection of Encanto Drive at Ethanac Road was currently failing.
As a result of this and the proximity of the intersection of Trumble Road, the Project will be constructing a median along Ethanac Road that will restrict left turns at this intersection. Therefore, the traffic study must be revised to reflect these conditions. Revising the traffic study to reflect this reasonably foreseeable change in the environmental baseline conditions is consistent with CEQA Guidelines, section 15125(a)(1) which states in relevant part, “Where existing conditions change or fluctuate over time, and where necessary to provide the most accurate picture practically possible of the project's impacts, a lead agency may define existing conditions by referencing historic conditions, or conditions expected when the project becomes operational, or both, that are supported with substantial evidence. In addition, a lead agency may also use baselines consisting of both existing conditions and projected future conditions that are supported by reliable projections based on substantial evidence in the record.” (Underlining added.) Response #1
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. The Project’s responsibility for the improvements necessary to bring the intersection of Sherman Road and Ethanac Road (#5) to an acceptable LOS is indicated as fair share. The improvements that are required to address existing and cumulative (near-term and long-term) deficiencies are considered cumulative as they are not directly caused by the proposed Project. As noted in Table 1-4, the Project applicant would construct the needed improvements to accommodate the ingress and egress truck turns.
Regarding the Perris Travel Center (City of Perris Case No. P22-05022) project and the proposed median along Ethanac Road near Encanto Drive, the traffic study was prepared using the most current and reliable data available at the time of analysis. While the background traffic associated with the Perris Travel Center project was included as a cumulative project, roadway network changes as proposed by the Perris Travel Center development would only be applicable if that project were to be approved and ultimately developed, including the transportation improvements required by the City of Perris (which at the time of preparation of the Traffic Study for the subject project the Perris Travel Center project was not approved). Similarly, the Perris Towne Center project recommended in its Traffic Study the vacation of the intersection at Encanto and Ethanac, which is acknowledged as a footnote in Table 1-4 of the Project Traffic Study. As such, as authorized by CEQA, improvements were identified at the intersection of Encanto and Ethanac Road as if neither cumulative project moves forward, evaluating Encanto at Ethanac as a full access intersection. The transportation effects to the roadway network as proposed by each of the aforementioned City of Perris project would have been evaluated in their own respective environmental studies. Lastly, the proposed Project is anticipated to contribute to through traffic only Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 2
along Ethanac Road at Encanto Drive (no turns of Project traffic is anticipated onto or off of Encanto Drive that would be affected by any access restrictions). As such, revisions to the subject Project Traffic Study is not required.
Comment #2
freeway off-ramps, it does not include a queuing analysis along Ethanac Road itself. This is critical as the queuing at these intersections along Ethanac Road could adversely impact traffic operations at these two ramp intersections thus creating traffic safety hazards. The traffic study needs to address queuing at these critical locations and how they may affect east-west traffic along Ethanac Road over the I-215 freeway.
Response #2
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. The queuing analysis in the traffic study focuses on the I-215 southbound and northbound off-ramps because these locations represent the critical points where queuing directly interacts with freeway mainline. The purpose is to ensure there is no spillback from the arterial onto the I-215 Freeway. However, as shown in Table 7-6 of the Traffic Study and Appendix 7.8, there are no queuing issues anticipated along Ethanac Road under Horizon Year traffic conditions with the proposed improvements. It should also be noted that the Project contributes 0.7% and 1.5% of new traffic at the southbound and northbound ramps, respectively. Given this minimal contribution, a separate queuing analysis along Ethanac Road itself is not warranted.
Comment #3
eastbound and westbound through lanes and left-turn pockets along Ethanac Road (at the I-215 freeway ramp intersections) need to be addressed and appropriate funding sources identified.
It is shown that many improvements recommended in the traffic study would be covered by payment of Transportation Uniform Mitigation Fees (“TUMF”). It is imperative that this is confirmed for each specific improvement, otherwise alternative funding sources would need to be provided that comply with the requirements of CEQA (Anderson First Coalition v. City of Anderson (2005) 130 Cal.App.4th 1173, 1194.
Additionally, as previously stated, the project would have a direct impact to the intersection of Sherman Road at Ethanac Road and as such, the project should be 100% responsible for improving this intersection to an acceptable level of service.
Response #3
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. As stated in the Anderson First Coalition case cited by the City of Perris, imposition of impact fees is an appropriate mitigation when it is linked to a specific mitigation program, here the TUMF program. The TUMF program specifically lists the I-215/Ethanac Road improvements as improvements to be funded through TUMF. These improvements are consistent with TUMF and with what other nearby traffic studies have assumed and recommended for Horizon Year traffic conditions. Although the I-215/Ethanac Road improvements are not identified as part of the Fiscal Year 2024/2025 Central Zone Ethanac Business Park
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5-Year Transportation Improvement Program (TIP) project. The latest Draft TUMF Nexus Study (dated May 9, 2024) identifies a total interchange improvement cost of $32,698,000 and a maximum TUMF share of $32,698,000 (see Table 4.4), with a breakdown in costs summarized in Exhibit H-1. Ethanac Road is also a TUMF facility (although not identified on the 5-year TIP) from the I-215 Freeway to Matthews Road with a maximum TUMF share of $3,562,000 for one lane in each additional direction of travel.
Comment #4
in this traffic study are either partially, or entirely, located within the City of Perris. As such, it is imperative that the correct City of Perris LOS thresholds are utilized. The LOS criteria utilized in the traffic study for determining impacts in the City of Perris is incorrect thus potentially understating the potential traffic safety impacts from the Project. As such, the traffic study should be updated accordingly.
Response #4
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. The City of Perris has the following LOS criteria for the affected study area intersections:
LOS “D” along all City maintained roads (including intersections) and LOS “D” along I-215 and SR 74 (including intersections with 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.
The City of Perris’s Guidelines state for locations that have a pre-project deficiency, and a project contributes 50 or more peak hour trips and increases the peak hour delay by 2.0 seconds or more would be considered direct or cumulative impact. However, it should be noted that the proposed project does not contribute more than 50 peak hour trips to any intersections west of Sherman Road. Additionally, all deficiencies identified in the traffic study have corresponding intersection improvements that have been recommended to bring the intersection’s LOS back to acceptable levels.
The City of Perris LOS criteria and thresholds have been utilized for the applicable analysis locations along with City of Menifee thresholds.
Comment #5
included in this traffic study are either partially, or entirely, located within the City of Perris. The City of Perris utilizes an ambient growth rate of 3% per year, however, the traffic study utilizes an ambient growth rate of 2% per year for all intersections (i.e., City of Menifee criteria). As such, the traffic study understates the traffic volumes/impacts at City of Perris facilities.
Response #5
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. To remain consistent with the scoping agreement and to avoid errors in flow conservation between intersections, a 2% per year ambient growth rate has been applied to all study area intersections, as the Project site is within the City of Menifee’s jurisdiction and follows the City of Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 4
Menifee’s Guidelines. Additionally, the Horizon Year traffic conditions, derived from the RIVCOM regional model, offers a more conservative analysis compared to the cumulative scenarios, regardless of the ambient growth rate used. The average growth in traffic volumes for all study area intersections between Existing Conditions and Horizon Year Conditions is approximately 5% per year compounded over 21 years (for Year 2045). As such, the background growth evaluated for the purposes of the Traffic Study is not understated.
Comment #6
Development Land Use Summary. City of Perris Planning Department shall confirm the list of City of Perris cumulative projects that have been utilized in the traffic study. If discrepancies exist, the traffic study shall be updated accordingly.
Response #6
The most recent list from the City of Perris was used to develop the cumulative projects list during the scoping agreement process. The latest list was obtained at the time the scoping agreement was approved and analysis was underway for the subject Project.
Comment #7
improvements for the I-215 freeway/Ethanac Road intersections involve major improvements including additional through lanes and left-turn pockets. Are these considered interim improvements which will be further modified in the future to its ultimate configuration? Additional clarification is needed.
Response #7
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. The improvements for the I-215/Ethanac Road intersections under EAPC (2026) Conditions are to accommodate near-term, EAPC (2026) traffic conditions. The ultimate improvements, needed for Horizon Year (2045) traffic conditions, are reflected in Table 7-4 of the Traffic Study. However, the ultimate interchange design and future improvements would be determined based on a future Project Study Report (PSR) and supplemental environmental evaluation of improvements to the interchange.
Comment #8
assumes the ultimate reconstruction of the I-215 interchange at Ethanac Road. Is there currently a funding source for these improvements? Additional clarification is needed, including how these improvements will be implemented
Response #8
See Response #3 and Response #7.
Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 5
Comment #9
Developer shall study the intersections of Ethanac Road/Case Road & Ethanac Road/Barnett Road and provide any necessary improvements and/or fair share costs related to the realignment of Barnett Road to align directly across with Case Road. Study for these intersections shall include a queuing analysis.
Response #9
It should be noted that under the CEQA Guidelines, automobile congestion no longer is considered a significant impact. The Project is expected to contribute only 4 AM peak hour and 4 PM peak hour trips west of the I-215 freeway along Ethanac Road. Given this minimal impact, the minimum trip threshold for analysis to study the intersections of Ethanac Road/Case Road and Ethanac Road/Barnett Road is not met per the City of Perris’ Guidelines.
City of Menifee also has the same 50 peak hour trip criteria for the purposes of determining the study area as a criteria for potentially triggering project-specific improvement needs. However, the subject Project’s Traffic Study evaluated a study area that exceeds this criteria since intersections west of Sherman Road (which would have fewer than 50 peak hour trips) were included for analysis at the request of City of Menifee staff during the scoping process. By both City’s Guidelines, the subject Project should not have a measurable effect (or responsibility to improve) any intersection with less than 50 peak hour trips.
Comment #10
The Development’s drainage study shall analyze and mitigate for collection and conveyance for all tributary runoff, including the runoff at the intersection of Ethanac Road and Sherman Road.
Response #10
This comment has been noted. No changes to the traffic study are necessary as this comment pertains to the drainage study.
Comment #11
Developer shall study the intersections of Ethanac Rd/Case Rd & Ethanac Rd/Barnett Rd and provide any necessary improvements and/or fair share costs related to the realignment of Barnett Road to align directly across with Case Road. Study for these intersections shall include a queuing analysis.
Response #11
See Response #9.
Comment #12
The City of Perris’ noise ordinance is not utilized as part of the analysis of the Project’s noise generation, despite the Project’s proximity to sensitive receptors within the City of Perris. This is of particular concern due to the anticipated increase in cumulative and incremental traffic noise along Ethanac Road, which is directly south of the anticipated residential development within the GVSP area. As such, the noise analyze should be revised to incorporate the standards set forth in Perris’ noise ordinance.
Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 6
Response #12
Under CEQA each lead agency must adopt its own thresholds. As such, the City of Menifee has applied a uniform and consistent set of thresholds to address the impacts of the Project. Utilizing the City of Perris, noise ordinance, Noise Element, or similar standards would result in two sets of standards and would result in an inconsistent analysis. Additionally, the City of Menifee has no ability to enforce the City of Perris regulations or standards.
Comment #13
The IS/MND analysis does not address critical details regarding the staging locations for trucks and the anticipated frequency of nighttime concrete pours. There is no information on how often nighttime pours will occur or the schedule of nighttime pours. Understanding the specific location for staging is critical to evaluating potential impacts on nearby resident and sensitive receptors.
Response #13
As with many of the nighttime concrete pours analyzed for projects within the City of Perris, staging areas for concrete pours by necessity are located within the construction area since they are almost exclusively for the creation of the foundations and loading aprons. Additionally, unlike other typical construction, such as roadway construction, the staging areas for concrete pours are limited to a couple of trucks queuing up before they move into position to unload concrete. The time of the concrete pours, and their duration is not relevant to the noise analysis since any violation during any hour of construction would have an impact. Alternately, even if a concrete pour occurred for many days, if it did not exceed the thresholds, there would be no impact.
Comment #14
The evaluation of cumulative off-site traffic noise impacts is based on an incorrect methodology that is inconsistent with the requirements of CEQA. Under CEQA, an environmental document is required to determine whether a significant cumulative impact would occur. If the cumulative impact is significant, the environmental document is required to determine if the contribution of the project is considerable.
In the case of this project and IS/MND, the Noise and Vibration Analysis only evaluates the noise level increase associated with the proposed project under the existing noise levels (Table 7-7), Existing plus Ambient Growth plus Cumulative (“EAC”) noise levels (Table 7-8), and Horizon Year noise levels (Table 7- 9). However, the cumulative traffic noise impact is supposed to be based on the change in noise levels from the existing condition to the future condition with the traffic generated by the proposed project and other cumulative development.
For example, Table 7-7 of the Noise and Vibration Analysis identifies an existing noise level of 69.9 dBA along Ethanac Road west of Trumble Road. Table 7-9 then shows the Horizon Year noise level of 74.2 dBA with the proposed project along this roadway segment. This represents a cumulative noise level increase of 4.3 dBA, which substantially exceeds the 1.5 dBA incremental noise level increase threshold of significance identified for the sensitive receptors along this roadway segment. Under this correct methodology, a cumulative noise level increase of 4.7 dBA would occur at the sensitive receptors along Ethanac Road west of Sherman Road. As such, the IS/MND should have concluded that a significant Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 7
cumulative impact would occur at the sensitive receptors along these roadway segments. While the contribution of the project might not be considerable, the City of Menifee has not acknowledged the significant cumulative impact and has not informed the public about the significant cumulative noise impact. This in violation of CEQA.
Response #14
The analysis correctly assesses the impacts of traffic based on the Project’s contribution. As indicated in the comment, the cumulative increases in noise levels under future conditions are disclosed. As required by CEQA, the analysis focuses on the Project’s impacts to the environment and evaluates the Project’s contribution to future noise level increases. As stated in the report and reiterated in the comment, the Project’s contribution to future traffic noise level increases is less than cumulatively considerable, and therefore, the Project does not have a significant cumulative noise impact.
Comment #15
The IS/MND’s analysis of carbon monoxide hotspots uses outdated data from the Lake Elsinore monitoring station for 2022. The IS/MND concludes that the “traffic volumes for the Project, coupled with the on- going improvements in ambient air quality, would not be capable of resulting in a CO ‘hot spot’ at any study area intersection.” The IS/MND should use current data to collect data for a carbon monoxide hotspots. Since 2022, there have been changes in traffic conditions, and changes in development.
Response #15
The Air Quality Impact Analysis utilized information from the 2022 Lake Elsinore monitoring station which reported the ambient 1-hr. and 8-hr. CO concentration within the Project study area to be 0.9 ppm and
0.6 ppm, respectively. Although the 2023 monitoring station data is now available, it has been reviewed and the ambient 1-hr. and 8-hr. CO concentrations within the Project study were 1.3 ppm and 0.7 ppm, in 2023. Although this is slightly higher than the 2022 CO concentrations, it is a negligible increase and the 2023 concentrations are well below the state one-hour standard of 20 parts per million (ppm) or the eight- hour standard of 9 ppm. As such, no changes are required to the IS/MND and underlying technical reports.
The commentors claim that the analysis fails to provide substantial evidence that the Project would not be capable of resulting in a CO ‘hot spot’ at any study area intersections, however; as stated on page 52 of Appendix A, Air Quality Impact Analysis, the Project specific peak hour traffic volumes taken from Appendix J Ethanac Business Park Traffic Analysis and Vehicles Miles Traveled Assessment were assessed on Table 3-13 and the intersection of the I-215 Southbound Ramps and Ethanac Road would have the highest AM/PM traffic volumes of 3,457 vph and 4,159 vph respectively which is significantly less than the traffic volumes conducted in the 2003 AQMP Study, where the busiest intersection evaluated was that at Wilshire Boulevard and Veteran Avenue, which had AM/PM traffic volumes of 8,062 vph and 7,719 vph respectively.
This is further substantiated on Page 51 where the analysis references the Bay Area Air Quality Management District (BAAQMD) conclusion that under existing and future vehicle emission rates, a given project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 8
hour (vph)—or 24,000 vph where vertical and/or horizontal air does not mix—in order to generate a significant CO impact.
Additionally, as stated on Page 51, the 2003 AQMP the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan), peak carbon monoxide concentrations in the SCAB were a result of unusual meteorological and topographical conditions and not a result of traffic volumes and congestion at a particular intersection. As evidence of this, for example, 8.4 ppm 8-hr. CO concentration measured at the Long Beach Blvd. and Imperial Hwy. intersection (highest CO generating intersection within the “hot spot” analysis), only 0.7 ppm was attributable to the traffic volumes and congestion at this intersection; the remaining 7.7 ppm were due to the ambient air measurements at the time the 2003 AQMP was prepared.
As noted above, only 0.7 ppm were attributable to the traffic volumes and congestion at one of the busiest intersections in the SCAB. Therefore if these traffic volumes were multiplied by ten times, it could be expected that the CO attributable to traffic would increase tenfold as well, resulting in 7 ppm – even if this were added to either the 1-hour or 8-hour CO concentrations within the Project study area, this would result in 8.3 ppm and 7.7 ppm for the 1-hr and 8-hr timeframes, respectively. Neither of which would exceed the applicable 1-hr standard of 20 ppm or the 8-hr standard of 9 ppm. As such the Project would not generate enough volume to create a CO hotspot at the intersections considered either in the context of the 2003 Los Angeles hot spot study or based on representative BAAQMD CO threshold considerations.
The substantial reduction in CO levels from the vehicle fleet and the state’s attainment status for CO further diminish the need for detailed microscale hotspot analyses, reinforcing that existing monitoring and regulatory frameworks adequately address potential air quality concerns.
The changes in traffic conditions and subsequent CO concentration from 2022 to 2023 as stated previously would result in a negligible difference and given that background concentrations are historically low, the potential for CO concentrations or “Hot Spots” are highly unlikely.
On the basis of the preceding discussion, the findings in the IS/MND and underlying Appendix A are substantiated, and no further changes are required.
Comment #16
On page 38, the IS/MND states that “The traffic volumes for the Project, coupled with the on-going improvements in ambient air quality, would not be capable of resulting in a CA ‘hot spot’ at any study area intersections.” However, the analysis fails to provide substantial evidence to support this statement.
Response #16
See response to comment 1.
Comment #17
The MND’s analysis of Criteria Pollutant Health Impacts is inadequate as it does not link emissions to their potential health impacts. While the analysis states that the emissions will not exceed the South Coast Air Quality Management District’s (“SCAQMD”) localized significance thresholds, it fails to connect the emissions to human health consequences. Given the proximity of the project to the GVSP, it is crucial that Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 9
a comprehensive health impact assessment be conduct to provide a more accurate picture on the project’s impact on air quality and public health.
Response #17
Comment noted. The Agency appears to be referring to the Friant Ranch case and a Health Impact Assessment consistent with this case. The IS/MND did in fact consider this case in Appendix A, Air Quality Impact Analysis, Section 3.9.1: Friant Ranch Case on pages 50-52, discusses the December 2018 Sierra Club v. County of Fresno (2018) 6 Cal.5 th 502 (Friant Ranch Case) and concludes that most local agencies including the City of Menifee lack the data to do their own assessment of potential health impacts from criteria air pollutant emissions, as would be required to establish customized, locally-specific thresholds of significance based on potential health impacts from an individual development project.
The commentor states that the analysis failed to link emissions to their potential health impacts, however; as studied in section 3.9.1, the analysis included the SCAQMD Final Localized Significance Threshold Methodology (LST Methodology) in Section 3.6: Localized Significance on pages 45-50 of Appendix A, Air Quality Impact Analysis. The LSTs are based on criteria pollutants emissions standards which consider health effects and are health protective. The Project was found to have a less than significant impact in regards to construction and operational LST emissions and therefore, would not be expected to exceed the most stringent applicable federal or state ambient air quality standards for emissions of CO, NO X, PM10, and PM2.5
As the Project’s emissions would comply with federal, state, and local air quality standards, the proposed Project’s emissions are not sufficiently high enough to use a regional modeling program to correlate health effects on a basin-wide level and would not provide a reliable indicator of health effects if modeled.
Additionally, the IS/MND and underlying technical Appendix A, includes a construction and operational HRA, including the total combined risk for Project construction and operation combined for nearby receptors. The Project was found to not generate significant localized air pollution and would not expose nearby residential, worker, or school child receptors to substantial adverse health risks.
As concluded in the IS/MND and underlying Appendix A, Air Quality Impact Analysis and Health Risk Assessment, the Project was found to have a less than significant impact in regards to Project specific regional and localized air quality and health risk. As such, the findings in the IS/MND and underlying Appendix A are substantiated, and no further changes are required.
Comment #18
The air quality analysis should have analyzed the localized impacts to the sensitive receptor at 3042 Sherman Road, a single-family residence located in the City of Perris, approximately 588.7 meters (0.365 miles) from the proposed project. This analysis essential for accurately assessing potential human health risks and noise impacts associated with the project. By analyzed the potential impacts to this location, the City of Menifee can ensure that any adverse effects on nearby residents are identified and appropriately addressed.
Ethanac Business Park
City of Menifee Initial Study/Mitigated Negative Declaration – Responses to Comments October 2024 Page 10
Response #18
The IS/MND and underlying Appendix A, Air Quality Impact Analysis and Health Risk Assessment evaluated sensitive receptors closer than the receptor noted by the commentor at 3042 Sherman Road. The closest existing residential receptor to the Project was identified to be Location R5, located at 26228 Trumble Rd., approximately 177.1 meters (0.110 miles) west of the Project site. The location identified by the commentor at 3042 Sherman Road, is located approximately 588.7 meters (0.365 miles) north of the Project site, which is over three times the distance than the location R5 identified in the analysis. Emissions concentrations decrease as the distance between the source (Project Site) and receptor increase. This is substantiated with traffic-related studies, where the additional emissions concentrations attributable to proximity were seen within 1,000 feet and was strongest within 300 feet. California freeway studies show about a 70-percent drop-off in particulate pollution levels at 500 feet. Based on California Air Resources Board (CARB) and SCAQMD emission concentrations and modeling analyses, an 80-percent drop-off in pollutant concentrations is expected at approximately 1,000 feet from a distribution center (1). As such, based on the previous discussion and difference in distance between location R5 and the residence at 3042 Sherman Road, impacts that would occur at locations further than Location R5 would be subject to lesser emission concentrations and would not have any greater impacts than what would occur at Location R5.
Additionally, as discussed in Appendix A, Air Quality Impact Analysis, on pages 45-50 the report utilizes the LST methodology which analyzes the Projects emission to nearby sensitive receptors which compared to the Total Concentration thresholds was found to be less than significant for construction and operations. The receptors as identified on Exhibit 3-A on page 48, are all closer to the Project Site than the residence at 3042 Sherman Road as discussed previously. As such, the findings in the IS/MND and underlying Appendix A are substantiated, and no further changes are required.
Comment #19
The IS/MND states that the project will involve the construction of new fire facilities. However, the City’s analysis is insufficient, as it fails to assess the potential impacts of building a fire facility. The analysis should include evaluations of noise, air quality, and other relevant factors associated with the construction of the fire facility, as well as the potential impacts on the surrounding area.
Response #19
The ISMND does not state that development of new fire facilities is part of the proposed Project. The Project would be designed in compliance with all applicable fire protection and prevention requirements and pay Development Impact Fees (DIFs) as per the approved fee schedule toward the construction of new fire facilities. However, payment of DIF constitutes adequate mitigation because through implementation of the DIF program, the City collects DIF from development projects and is mandated to use the DIF funds to construct new fire and emergency service facilities. In addition, the Project’s fire safety and fire suppression features pursuant to the Menifee MC, and the Project applicant’s compliance with all required design regulations, will further minimize the demand for fire protection and emergency public services impacts. Further, because no fire protection facilities exist on the Project site, development of the Project would not conflict with existing fire structures or require modification of fire protection Ethanac Business Park
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facilities. Lastly, the Project would be consistent with planned industrial uses per the Menifee North SP.
When it is determined that a new fire station would be required, the City would determine at that time if that project would be subject to CEQA.
Comment #20
The City must develop a comprehensive analysis regarding the usage of the warehouse. It is important to clarify what materials will be stored in the warehouse and to evaluate whether these materials pose potential fire hazards which will require additional fire fighting infrastructure.
Response #20
As previously stated, the end user for the Project has not been identified at this time. As such, it is unknown what types of materials will be stored within the Project site. Operation of the Project would involve the use of small amounts of hazardous materials, such as industrial cleansers, greases, and oils for cleaning and maintenance purposes. The Project may also involve transport, use, and disposal of hazardous materials; the specific substances and quantities of such materials are presently unknown. The use, storage, transport, and disposal of hazardous materials would be governed by existing regulations of several agencies, including the U.S. EPA, U.S. DOT, California OSHA, and the Riverside County Fire Protection District. Compliance with applicable laws and regulations governing the use, storage, transportation, and disposal of hazardous materials would ensure that all potentially hazardous materials are used and handled in an appropriate manner and would minimize the potential for safety impacts.
Additionally, the Project would also be operated with strict adherence to all emergency response plan requirements set forth by the Riverside County Fire Protection District. Compliance with applicable laws and regulations concerning hazardous materials would ensure that all potentially hazardous materials are used and handled in an appropriate manner and would minimize the potential for significant hazards to the public or the environment.
Comment #21
Since the project is within 900 feet of a sensitive receptor in a non-residential zone, a 50-foot buffer should be provided along the west property line shared with the residential uses to the west to fully screen the project from the sensitive receptors. Buffer areas would need to include a solid decorative wall, landscaped berm and wall, or landscaped berm 10 feet or more in height, drought tolerant natural ground landscaping with proper irrigation, and solid screen buffering trees, planted in two rows along the length of the property line adjacent to the sensitive receptor. Trees used for this purpose shall be evergreen, drought tolerant, to the extent feasible, composed of species with low biogenic emissions, of a minimum 36-inch box size at planting, and spaced at no greater distance than 40 feet on center. Palm trees shall not be utilized.
Response #21
AB 98 explicitly exempts projects which commended the local entitlement process prior to September 20, 2024 which includes this project. Nonetheless, the project incorporates many of the environmental measures included in AB 98 and the project complies with the City of Menifee’s recently enacted Industrial Good Neighbor Policies.
Ethanac Business Park
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Comment #22
The proposed industrial development is incompatible with the residences in the City of Menifee immediately to the east of the project site, located on the east side of Trumble Road and south of Ethanac Road; as well as the residential community in the City of Menifee on the northeast corner of Ethanac Road and Sherman Road. In order to address the potential impacts to the residences in close proximity to the project site, at a minimum a larger buffer, including landscaping consisting of mature evergreen trees, should be provided to adequately screen the proposed warehouse in compliance with the requirements provided in AB 98.
Response #22
AB 98 explicitly exempts projects which commended the local entitlement process prior to September 20, 2024 which includes this project. Nonetheless, the project incorporates many of the environmental measures included in AB 98 and the project complies with the City of Menifee’s recently enacted Industrial Good Neighbor Policies.