CITY OF
CITY OF MENIFEE
APPEAL APPLICATION
MENIFEE
Decision to be appealed: PLN 23-0040
APPELLANT/REPRESENTATIVE City of Perris / Patricia Brenes, Planning Manager 951-943-5003/Ext 355 LAST E-MAIL [email protected] PHONE NO. FAX NO.
ADDRESS 135 North "D" Street, City of Perris, CA 92570-1998
STREET CITY STATE ZIP
PROPERTY OWNER
(if different) LAST FIRST
PHONE NO. FAX NO. _ _ E-MAIL
ADDRESS
STREET CITY STATE
Northern Gateway Logistics Center - South of Ethanac Rd Between East Name of Project, APN/Address: Side of Evans Rd and Barnett Rd- PLN23-0040 Appealing the decision of (Specify Community Development Director, Building and Safety Director City Manager, Planning Commission): Planning Commission Approval Action and Date: Wednesday, May 14, 2025
Explain specify what action or decision is being appealed: Adoption of Resolution Adopting Final Environmental Impact Review and Adoption of Resolution Approving Project Do you have additional evidence not already presented? X _Yes _ _ No. If Yes, please attach.
What result to you want? Denial o e Project Unless modified to address City of Perris comments Applicant's Signature Date: 5/23/2025
Owner Certification:_I certify under the penalty-o the laws of the State of California that I am the property owner of the property that is the subject matter of this appeal application. I am authorizing and hereby do consent to the filing of this application and acknowledge that the final approval by the City of Menifee, if any, may result in restrictions, limitations and construction obligations being imposed on this real property.
Owner's Signature: _Date:_
Print Name:
Written authorization from the legal property owner is required. An authorized agent for the owner must attach a notarized letter of authorization from the legal property owner.
No application will be accepted until is complete and the fee paid.
Once complete, you will receive confirmation and a hearing date as well as additional appeal information. For questions, please contact the City Clerk at (951) 672-6777.
John Fox [email protected]
Aleshire & Wynder p (310) 527-6660 | awattorneys.com
May 23, 2025
VIA HAND DELIVERY
Honorable Mayor and City Council
City of Menifee
29844 Haun Road
Menifee, CA 92584
SUBJECT: APPEAL OF APPROVAL OF NORTHERN GATEWAY LOGISTICS
CENTER - LOCATED SOUTH OF ETHANAC ROAD BETWEEN EVANS
ROAD AND BARNETT ROAD - PLOT PLAN (PLN23-0040)
Dear Honorable Mayor and Members of the City Council:
Our firm serves as the City Attorney for the City of Perris ("Perris"). On behalf of Perris this letter is submitted to explain the basis for Perris' Appeal of the Menifee Planning Commission's May 14, 2025 decision to approve Planning Case PLN23-0040 to permit the construction and operation of the Northern Gateway Logistics Center in the City of Menifee ("Menifee") totaling approximately 398,041 square feet on 20.17 acres located south of Ethanac Road between Evans Road and Barnett Road ("Project") and certify the Final Environment Impact Report ("EIR") prepared for the Project.
Introductory Statement
The City of Perris ("Perris") submits this appeal following the Planning Commission's improper approval of the Project due to non-compliance with the California Environmental Quality Act ("CEQA") regarding the environmental impacts of the Project. The Project square footage will include Building 1 (northern building), 45 feet-1 inch in height and approximately 99,326 square feet of warehousing space with 6,000 square feet of office space for a total of 105,326 square feet and Building 2, 45 feet-7 inches in height and approximately 277,715 of warehousing space, 8,000 square feet of office space and a 7,000 square-foot mezzanine for a total of 292,715 square feet.
Both warehouses have a combined total of approximately 398,041 square feet. The Project proposes to include 52 dock-high doors (Building 1 - 15 and Building 2 - 37) and four grade-level truck doors (two per building). It also proposes 15 trailer stalls (including dock spaces) on the truck court on Building 1, 78 trailer stalls on Building 2, 108 passenger car spaces on Building I's site, and 244 passenger car spaces on Building 2's site.
The Project is located south of the Green Valley Specific Plan (GVSP) in the City of Perris.
The GVSP is a master-planned community totaling, 1,269 acres of land envisioned to be developed with 3,460 single-family detached homes, 750 multi-family residential units, 42.3 acres of business 3701 Wilshire Blvd., Suite 725 | Los Angeles, CA 90010
and professional office space, 72.7 acres of commercial retail, 108.7 acres of industrial, 24 acres for three school sites, and 51.1 acres of public parks.
Although there are some industrial zones in the GVSP, they are located adjacent to the Perris Valley Airport north of the San Jacinto River, which has land use density limitations. All the development in the GVSP south of the San Jacinto River to Ethanac Road is residential, with some commercial development towards the I-215 Freeway. Due to the proximity of residential uses to Ethanac Road, industrial development in the City of Perris is not allowed to utilize Ethanac Road as a truck route.
On July 22, 2024, Perris submitted to Menifee an initial comment letter identifying many of the same concerns at issue in this appeal. On May 14, 2025, Perris submitted to Menifee another comment letter, also identifying many of the same concerns at issue in this appeal that were not addressed in the letter dated July 22, 2024. Menifee provided responses to Perris' letter dated July 22, 2024, as part of the Final Environmental Impact Report ("Menifee Response""); however, the concerns raised by Perris in the July 22, 2024, letter were not adequately addressed by the Menife Response. The July 22, 2024 letter and May 14, 2025 letter are attached hereto as Exhibit A and are incorporated herein by this reference.
Therefore, City of Perris submits this appeal due to the Project's unaddressed impacts on the City of Perris' residential neighborhoods, public safety concerns, inadequacy of the Final EIR, and increased truck traffic on Ethanac Road. Specifically, the City of Perris appeals as set forth below.
STATEMENT OF ISSUES APPEALED
The following are the basis for the City of Perris' appeal of the Planning Commission's May 14, 2025, approval of Plot Plan No. PLN23-0040:
A. Analysis of Land Use and SB 330 (No Net Loss)
Pursuant to Senate Bill 330, local jurisdictions are prohibited from downzoning unless they upzone an equivalent amount elsewhere. Although no downzoning is technically proposed, the Project site is located in the Economic Development Corridor (EDC) Northern Gateway, where is designated for industrial development (Refer to Menifee's General Plan Land Use Element Exhibit LU-B2B: Northern Gateway below). As there are projects in process or have been recently remove homes, the zoning designation has no implementation program to monitor and ensure the loss of residential capacity does not drop below 5%. Therefore, the EIR would need to analyze and discuss how the City intends to preserve or monitor that 5% of the land use will be retained for future residential uses. Without an implementation plan /monitoring program in place, the Project, in combination with other projects in the pipeline, would have the potential net effect of eliminating housing without providing for a provision in place to ensure that 5 percent of the land is preserved for future residential development as envisioned EDC Northern Gateway identified in Menifee's General Plan. Therefore, the Project would effectively downzone the property.
ExHiBIr LUB2B: EDC NORTHERN GATEWAY (594 ACRES)
Presidential
Industrial
Envisioned as an employment center at
Menifee's norther gateway that focuses
on providing opportunity for business
park development and more traditiona
industrial (less office) than enviseoned for
the Southern Gateway (Scott Road) EDC
area Limited residential development may
be appropriate between new business park
uses and existing single-family homes, or
in places where residential projects have
already been approved Emphasis should be
on job creation and creating connections to
regional transportation corficors, including
-215 and the railroad
B. Transportation Impacts
This project is located within "Island 7" of the Economic Development Corridor-Northern Gateway (EDC-NG) area. As part of the study, several deficiencies in roadway facilities were identified (within both the City of Menifee & City of Perris), and corresponding improvements were identified to offset these deficiencies. Since this Project is part of the EDC-NG and will contribute to the overall degradation of these roadway facilities, the Project shall be responsible for its fair share contribution towards all of these improvements.
Allowing the proposed industrial development would generate truck traffic along Ethanac Road, as trucks are anticipated to access the site via Evans Road. The existing westbound left turn pocket on Ethanac Road at Evans Road was not designed for queuing of trucks to minimize impacts to existing and future residential development. To avoid land use impacts, it is recommended that trucks be required to access the site via Barnett Road only, as access via Evans Road would place queuing of trucks directly across the already entitled residential development in the GVSP area in Specifically, the traffic study and FEIR fail to properly (or entirely) assess the following critical issues:
a. The traffic study incorrectly utilizes Ethanac Road as a two-way truck access route to/from the project from Evans Road
b. The traffic study fails to consider the findings of the EDC-NG Master Circulation Plan a traffic study for alternative truck routes and cumulative deficiencies.
The analysis methodology utilized for the Case Road/Barnett Road at Ethanac Road offset intersections fails to fully analyze the unique characteristics of these offset intersections
and ultimately understates how the project will contribute to the degradation of traffic safety at this location.
d. The FEIR states that LOS/queuing is no longer considered under CEQA, but it is still ultimately required with respect to General Plan consistency/Menifee's traffic study guidelines. Additionally, several traffic safety issues are not properly analyzed, which is a CEQA requirement.
e. The traffic study does not properly analyze/address the excessive queuing along Ethanac Road.
1. The traffic study limits the recommended roadway improvements to site-adjacent roadways only. The project shall contribute to all improvements identified in the EDC-NG Master Circulation Plan traffic study.
C. Previously Approved Surrounding Industrial Development The proximity of this project, in conjunction with the previously approved Menifee's Phelan project, located northeast of the project site, exacerbates a public safety and traffic issue without fair share funding for the I-215 Interchange and fixing the Barnett/Ethanac realignment.
CONCLUSION
The City of Perris asks that the Menifee City Council reverse the Planning Commission decision and deny the Project Plan in light of the significant deficiencies in the Project and Final EIR described above. The City of Perris looks forward to working with Menifee to facilitate the preparation and consideration of a Project and proper Final EIR that meets the requirements of applicable state housing laws and the California Environmental Quality Act.
Respectfully,
ALESHIRE & WYNDER, LLP
John 1o. 70X
John W. Fox
CC: Clara Miramontes, City Manager
Wendell Bugtai, Assistant City Manager
Sunny Soltani, City Attorney
John Pourkazemi, City Engineer
Kenneth Phung, Director of Development Services
Attachment: Exhibit A - City of Perris Letters Dated May 14, 2025 and July 22, 2024
EXHIBIT A
CITY OF PERRIS
eS
DEVELOPMENT SERVICES DEPARTMEN
PLANNING DIVISION
135 N. "D" Street, Perris, CA 92570-2200
INC. 19 •TEL: (951) 943-5003 FAX: (951) 943-8379
May 14, 2025
Randy Madrid, Chair
Ivan Holler, Vice-Chair
Michael Knighten, Planning Commissioner
Tammy Ramirez, Planning Commissioner
Chris Thomas, Planning Commissioner
City of Menifee Planning Commission
29844 Haun Road
Menifee, CA 92586
SUBJECT: ITEM 9.2 - DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR
THE PROPOSED NORTHERN GATEWAY LOGISTICS CENTER -
LOCATED SOUTH OF ETHANAC ROAD BETWEEN EVANS ROAD AND
BARNETT ROAD - PLOT PLAN (PLN23-0040)
Dear Honorable Chair Madrid, Vice-Chair Holler, and Members of the Menifee Planning Commission:
The City of Perris appreciates the opportunity to comment on the proposed 398,041 square foot circulation analyzed in the traffic study, as summarized below. This letter is in addition to, and incorporates herein by reference, the letter sent by the City of Perris dated July 22, 2024. The City respectfully requests that this letter and the City's comment letter dated July 22, 2024 be included in the record of proceedings for this Project. Perris notes that it has been in negotiations with the City of Menifee in the hopes of resolving many of the issues raised in this letter more globally and will continue to engage in those important conversations. However, Perris must continue to preserve its concerns regarding this and other projects in Menifee until an amical resolution is reached between Perris and Menifee.
The City of Perris has reviewed the Proposed Project, including Menifee's responses to the City of Perris' letter dated July 22, 2024, and found those responses inadequate. Based upon the foregoing, the City of Perris raises the following concerns with the environmental analysis of the 01006.0003 2005798.1 5/13/2025
Proposed Project and the Project's compliance with the Housing Crisis Act (Government Code, section 66300 et al.) as follows:
Land Use Analysis and SB 330 (Not Net Loss)
1. Pursuant to Senate Bill 330, local jurisdictions are prohibited from downzoning unless they upzone an equivalent amount elsewhere. Although no downzoning is technically proposed, the Project site is located in the Economic Development Corridor (EDC) Northern Gateway, where 5% of the land is intended to be preserved for residential development, while the remaining land is designated for industrial development ( Refer to Menifee's General Plan Land Use Element Exhibit LU-B2B: Northern Gateway below). As there are projects in process or have been recently approved in the Economic Development Corridor that will remove existing residential tracts or remove homes, the zoning designation has no implementation program to monitor and ensure the loss of residential capacity does not drop below 5%. Therefore, the EIR would need to analyze and discuss how the City intends to preserve or monitor that 5% of the land use will be retained for future residential uses.
Without an implementation plan /monitoring program in place, the Project, in combination with other projects in the pipeline, would have the potential net effect of eliminating housing without providing for a provision in place to ensure that 5 percent of the land is preserved for future residential development as envisioned EDC Northern Gateway identified in Menifee's General Plan. Therefore, the Project would effectively downzone the property.
ExHIBIT LUB2B: EDC NORTHERN GATEWAY (594 ACRES)
Residential 5%
95%
Envisioned as an employment center at
Menifee's northern gateway that focuses
on providing opportunity for business
park development and more traditional
industrial (less office) than envisioned ior
the Southern Gateway (Scott Road) EDC
area. Limited residential development may
be appropriate between new business park
uses and existing single-family homes, or
in places where residential projects have
already been approved. Emphasis should be
on job creation and creating connections to
regional tansportation cordors, including
I-215 and the railroad.
Transportation
General/Major Comments
1. The traffic study for the Economic Development Corridor-Northern Gateway (EDC-NG) Master Circulation Plan is nearing completion. This project is located within "Island 7" of the EDC-NG area. As part of the study, several deficiencies in roadway facilities were identified (within both the City of Menifee & City of Perris), and corresponding improvements were identified to offset these deficiencies. Since this project is part of the EDC-NG and will contribute to the overall degradation of these roadway facilities, the project shall be responsible for its fair share contribution towards all of these improvements.
Specific Traffic Study Comments
2. The responses provided in the FEIR do not adequately address the concerns that the City of Perris has previously commented on regarding the traffic impacts of the project. Specifically, the traffic study and FEIR fail to properly (or entirely) assess the following critical issues:
a. The traffic study incorrectly utilizes Ethanac Road as a two-way truck access route to/from the project from Evans Road.
b. The traffic study fails to consider the findings of the EDC-NG Master Circulation Plan traffic study for alternative truck routes and cumulative deficiencies. c. The analysis methodology utilized for the Case Road/Barnett Road at Ethanac Road offset intersections fails to fully analyze the unique characteristics of these offset intersections and ultimately understates how the project will contribute to the degradation of traffic safety at this location.
d. The FEIR states that LOS/queuing is no longer considered under CEQA, but it is still ultimately required with respect to General Plan consistency/Menifee's traffic study guidelines. Additionally, several traffic safety issues are not properly analyzed, which is a CEQA requirement.
e. The traffic study does not properly analyze/address the excessive queuing along Ethanac Road.
f. The traffic study limits the recommended roadway improvements to site-adjacent roadways only. The project shall contribute to all improvements identified in the EDC-NG Master Circulation Plan traffic study.
Cumulative Impacts
3. Previously Approved Surrounding Industrial Development - The proximity of this project, in conjunction with the previously approved Menifee's Phelan project, located northeast of the project site, exacerbates a public safety and traffic issue without fair share funding for the I-215 Interchange and fixing the Barnett/Ethanac realignment.
California Environmental Quality Act (CEQA)
4. The City of Perris reserves the right to provide further comments on the environmental topics analyzed in the Draft EIR as the project moves forward in the process. Please provide future notices prepared for the Project pursuant to the California Environmental Quality Act ("CEQA") under any provision of Title 7 of the California Government Code governing California Planning and Zoning Law, including: notices of any public hearing held pursuant to CEQA.
The City of Perris appreciates the opportunity to comment on this Project and related Draft EIR.
Please contact me at (951) 943-5003, ext. 355 or [email protected], if you have any questions or would like to discuss the above concern in further detail.
Sincerely.
Patricia Brénes
Planning Manager
CC: Clara Miramontes, City Manager
Wendell Bugtai, Assistant City Manager
Sunny Soltani, City Attorney
John Pourkazemi, City Engineer
Kenneth Phung, Director of Development Services
Attachment: City of Perris Letter - Dated July 22, 2024 City of Perris Letter - Dated July 22, 2024
CITY OF PERRIS
DEVELOPMENT SERVICES DEPARTMENT
7° PLANNING DIVISION
135 N. "D" Street, Perris, CA 92570-2200
ING. TEL: (951) 943-5003 FAX: (951) 943-8379
19 July 22, 2024
Brandon Cleary
City of Menifee
Community Development Department
29844 Haun Road
Menifee, CA 92586
SUBJECT: CITY OF PERRIS COMMENTS - NOTICE OF AVAILABILITY (NOA) OF
A DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE
PROPOSED NORTHERN GATEWAY LOGISTICS CENTER - LOCATED
ON SOUTH OF ETHANAC ROAD BETWEEN EAST SIDE OF EVANS
ROAD AND BARNETT ROAD - PLN23-0040
Dear Mr. Cleary:
The City of Perris appreciates the opportunity to comment on the "Northern Gateway Logistic Center" ("Proposed Project") proposal to construct two industrial buildings totaling 398,252 square feet on 20.17 acres, located south of Ethanac Road between Evans Road and Barnett Road within the City of Menifee.
The Proposed Project is located south of the Green Valley Specific Plan (GVSP) in the City of Perris. The GVSP is a master-planned community totaling 1,269 acres of land envisioned to be developed with 3,460 single-family detached homes, 750 multi-family residential units, 42.3 acres of business and professional office space, 72.7 acres of commercial retail, 108.7 acres of industrial, 24 acres for three school sites, and 51.1 acres of public parks. Industrial zones are located adjacent to the Perris Valley Airport north of the San Jacinto River. Due to the proximity of residential uses to Ethanac Road, industrial development in the City of Perris is not allowed to utilize Ethanac Road as a truck route.
The City of Perris has expressed concerns about the proposed Project during the NOP comment period. After reviewing the Draft EIR and technical reports, the City believes the Project has not adequately addressed the potential environmental impacts related to air quality, energy, greenhouse gas emissions, land use, and transportation. Thus, the City continues to have concerns with the Project as detailed in the comments provided below. 01006 0005/1000628.1
Air Quality
1. The operational air pollutant emissions associated with the project may be underestimated.
The South Coast Air Quality Management District (AQMD) has informed the City of Perris in the past that the default trip lengths programmed into CalEEMod are not appropriate for the average trip distances of trucks traveling to and from warehouse projects. Instead, the South Coast AQMD has recommended that the default lengths be increased to account for the longer average truck trips. For example, the South Coast AQMD's Final Staff Report for Proposed Rules 2305 and 316 identify average trip lengths of 14.2 miles per trip for medium-heavy trucks and 39.9 miles for heavy-heavy duty trucks. These trip lengths are based on SCAG's 2016 Regional Transportation Plan modeling analysis. The South Coast AQMD recommends the use of these distances for the evaluation of air quality impacts from warehouses.
There is no mention of changes to the default operational trip lengths within the text of the Draft EIR or Air Quality Assessment. Section 8. User Changes to Default Data in the CalEEMod results sheets also does not identify any changes to the default operational trip lengths. The environmental documents for other recent warehouse projects within the City of Menifee have changed the default values to the South Coast AQMD's recommendations in order to more realistically estimate the operational emissions associated with the proposed projects. This includes the recent Murrieta Road Warehouse Project. The City should confirm whether the default trip lengths were used for this analysis and, if so, the Air Quality Assessment and Draft EIR should be revised to increase the truck trip lengths to be consistent with South Coast AQMD recommendations and other recent projects in the City of Menifee.
2. The evaluation of air quality impacts discusses the speculative use of emergency backup generators and includes the emissions from this equipment in the estimates of operational air pollutant emissions. The City of Perris agrees that the proposed warehouses may not need emergency backup generators for general operation. However, the two buildings would require the installation, maintenance, and regular testing of emergency fire water Part 9). Where provided, fire pumps for fire protection systems shall be installed in accordance with Section 913 of the California Fire Code and the National Fire Protection Association (NFPA) 20, Standard for the Installation of Stationary Pumps for Fire Protection. Fire pumps are generally powered by diesel engines. According to the National Fire Protection Association, diesel fire pumps must be tested on a weekly basis for a minimum of 30 minutes. This requirement is not speculative, and the analysis should be revised accordingly.
3. The evaluation of diesel particulate health risk impacts appears to be based on the emissions generated by construction equipment, mobile sources, off-road equipment, and emergency backup generators within the project site and experienced at nearby existing receptor locations. However, the analysis needs to confirm or be revised to evaluate the emissions from the diesel sources at the project site and traveling along the roadways between the project site and I-215. In addition, the analysis needs to identify the potential 01006.0005/1000628.1|
health risk impacts to the residents of the Green Valley Specific Plan area to the immediate north of Ethanac Road
Energy
4. As discussed above, the trip lengths for trucks traveling to and from the project site may not be appropriate for the average trip distances of trucks traveling to and from warehouse projects. An increased trip length for trucks would result in greater energy demands than what is estimated in the Draft EIR. The City should confirm whether the default trip lengths trom CalEEMod were used for this analysis and, if so, the Draft EIR should be revised to be consistent with South Coast AQMD recommendations for longer trip lengths and other recent projects in the City of Menifee.
Greenhouse Gas Emissions
5. As discussed above, the trip lengths for trucks traveling to and from the project site may not be appropriate for the average trip distances of trucks traveling to and from warehouse projects. An increased trip length for trucks would result in greater greenhouse gas emissions than what is estimated in the Draft EIR. The City should confirm whether the default trip lengths from CalEEMod were used for this analysis and, if so, the Draft EIR should be revised to be consistent with South Coast AQMD recommendations for longer trip lengths and other recent projects in the City of Menifee. Given how close the current emissions estimates are to the City's threshold os significance, an increase in greenhouse gas emissions may result in a significant and unavoidable impact that was not identified in the Draft EIR.
Land Use Inconsistency with Surrounding Areas
6. The proposed industrial development is incompatible with the residential development in the City of Perris due to its proximity to the GVSP area. Allowing the proposed industrial development would generate truck traffic along Ethanac Road, as trucks are anticipated to access the site via Evans Road. The existing westbound left turn pocket on Ethanac Road at Evans Road was not designed for queuing of trucks to minimize impacts to existing and future residential development. To avoid land use impacts, it is recommended that trucks be required to access the site via Barnett Road only, as access via Evans Road would place queuing of trucks directly across the already entitled residential development in the GVSP area.
7. Truck Circulation Route - The developer should be required to prepare a Truck Circulation Plan. According to the site layout, truck access is proposed on Ethanac Road heading both east and westbound. Truck circulation needs to be minimized to avoid impacts to sensitive receptors and analyzed in light of other industrial projects in the development entitlement pipeline. In addition, it should be noted that the existing median on Ethanac Road is within Perris City limits and is not designed for truck queuing. 01006.0005/1000628.1
Transportation
General/Major Comments
8. The preparation of the site-specific traffic study for the Northern Gateway Logistics Center Project is premature in that the overall traffic study for the Menifee Economic Development Corridor (MEDC) needs to be completed first in order to master plan the entire MEDC area which encompasses the Northern Gateway Logistics Center Project. A more comprehensive review of the entire area along Ethanac Road needs to be completed before site-specific studies can be prepared for individual projects.
9. All four (4) study area intersections analyzed in this traffic study are either partially or entirely located within the City of Perris. For these intersections, along with any study roadway segments, the City of Perris traffic impact criteria must be utilized (see Appendix A). If the project has a direct impact, then the project will be responsible for completing the required improvements unless a funding mechanism can be identified (e.g., TUMF fees, DIF fees, completed by other development, etc.).
10. It is unclear from the traffic study if truck traffic will access the project via both Evans Road and Barnett Road. An interim conditions analysis should be conducted if truck access cannot be taken from Evans Road and 100% of trucks are required to enter/exit the site from Barnett Road
11. It is our understanding that the Master Plan for the MEDC will be providing roadway connections for trucks that will not impact City of Perris non-truck route roadways. This must be considered as part of the traffic study and the analysis should be revised accordingly.
12. The traffic study will need to clearly identify what improvements are necessary, whether they have direct or indirect impact from the project, and how they will be implemented.
Again, direct impacts will be determined for City of Perris intersections and roadway segments based upon the City of Perris traffic criteria.
Specific Traffic Study Comments
13. Page 1, First Paragraph. The traffic study will also have to follow City of Perris requirements for those intersections and roadway segments within the City of Perris.
14. Page 3. Figure 2: Site Plan. The site plan shows a "Future Road" bordering the site to the South at doc is not apd ar as inough this voiday was accounted for in the TA. Further a. Who will be building this roadway?
b. What is the timing for construction of this roadway? c. Will this be a private or public road?
01006.0005/1000628.1
Depending on the answers above, additional analysis may be needed as circulation could be affected.
15. Page 4. Study Locations. The traffic study should identify whether the intersections and roadway segments are located within the City of Menitee, Perris or both. For those intersections and roadway segments located in the City of Perris, the City of Perris impact criteria and thresholds need to be utilized, as opposed to City of Menifee criteria.
16. Page 5, Figure 3. Existing Lane Configuration and Traffic Control. Study Intersection #2 actually consists of two separate (offset) intersections (Barnett Road & Case Road). Both of these intersections should be analyzed separately (from a LOS and queuing standpoint), and the recommended improvements should involve realigning Barnett Road with Case Road (and other associated intersection improvements if necessary). The project shall pay a fair share contribution towards this realignment, or 100% of the cost if the project directly impacts these intersections).
17. Page 8. Level of Service Standards and Major Measures of Significance. For roadway segments and intersections in the City of Perris, the City of Perris criteria should be utilized.
18. Page 13. Figure 6. Intersection #2 should be shown (and analyzed) as two separate intersections, since they do not align with each other.
19. Page 18, Figure 7. Project Trip Distribution. The project distribution needs to be updated to show both the passenger vehicle and truck turning percentages at each intersection.
Currently, it is unclear how project traffic enters/exits the project site. An interim conditions analysis should be conducted if truck access cannot be taken from Evans Road and 100% of trucks are required to enter/exit the site from Barnett Road.
20. Page 2s. Table 4 - Summary of Intersection Operations - Existing Plus Project. This table needs to include what jurisdiction each study intersection is located within to determine which intersections are considered directly impacted per City of Perris criteria.
21. Page 25 and 26. Figure 10 and Table 6. The City of Perris Planning Department will need to review and confirm the list of cumulative projects is accurate within the City of Perris.
22. Page 34, Table 9: Summary of Intersection Operation Opening Year 2025 Cumulative Plus Project. As previously described, Study Intersection #2 actually consists of two separate (offset) intersections (Barnett Road & Case Road). The currently reported delay (which again, is incorrect because both intersections are analyzed together as a single intersection), is very close to operating at deficient LOS. There is a "no right-turn on red" sign for SBR vehicles from southbound Case Road onto westbound Ethanac Road. Please confirm this turn restriction is accounted for as it would worsen the intersection LOS, potentially dropping it to an unacceptable level.
01006.0005/1000628.1
23. Page 37. Recommend Improvements. The realignment of Barnett Road/Case Road at Ethanac Road needs to be considered as a possible recommendation for improving the level of service and queuing along Ethanac Road, ultimately increasing traffic safety.
24. Pages 38 to 39, Recommended Improvements. For direct project impacts of City of Perris transportation facilities, 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. It is also unclear how these improvements would be implemented and who would be responsible for providing the required improvements. Additional detail is needed on the funding mechanisms that will be utilized to make these required improvements.
25. Page 42, Storage Capacity at Left Turn Pockets. Study Intersection #2 actually consists of two separate (offset) intersections (Barnett Road & Case Road). This analysis should also evaluate both of these intersections separately (i.e., Barnett Road at Ethanac Road & Case Road at Ethanac Road) due to the limited spacing between both intersections.
Furthermore, the City of Perris is concerned about the project's impact to queuing/progression along Ethanac Road at the I-215 interchange. A simulation analysis should be conducted to identify any queuing deficiencies, and if applicable, improvements should be identified.
26. Page 42, Left Turn Lane Recommended Lengths. Several of the recommendations call for left-turn pockets in excess of 300 feet. Given these long storage length requirements, would it be more appropriate to consider dual left-turn lanes at these locations? This also pertains to Table 14.
Furthermore, the recommendation of extending the WBL turn pocket at Evans Road to 475 feet does not leave adequate storage for a future EBL turn pocket at Green Valley Parkway.
Refinements to these improvements are necessary.
27. General: It doesn't appear any of the proposed driveways are analyzed. Please include a Site access analysıs which shall account for LOS analysis, truck turning templates, queuing analysis, and driveway spacing requirements.
CEQA.
28. The City of Perris reserves the right to provide further comments on the environmental topics analyzed in the Draft EIR as the project moves forward in the process. Please provide future notices prepared for the Project pursuant to the California Environmental Quality Act ("CEQA") under any provision of Title 7 of the California Government Code governing California Planning and Zoning Law which includes: notices of any public hearing held pursuant to CEQA.
01006.0005/1000628.1
The City of Perris appreciates the opportunity to comment on this Project and related Draft EIR.
Please feel free to contact me at (951) 943-5003, ext. 355 or [email protected], if you have any questions or would like to discuss the above concern in further detail.
Sincerely,
Planning Manager
CC: Clara Miramontes, City Manager
Wendell Bugtai, Assistant City Manager
Robert Khuu, City Attorney
John Pourkazemi, Interim City Engineer
Kenneth Phung, Director of Development Services
01006.0005/1000628.1