Northern Gateway
Logistics Center Project
Final Environmental Impact Report
SCH No. 2021110379
Prepared for:
City of Menifee
29844 Haun Road
Menifee, CA 92586
(951) 769-8520
Prepared by:
Kimley-Horn and Associates, Inc.
Kari Cano, Project Manager
3801 University Avenue, Suite 300
Riverside, CA 92501
May 2025
EXHIBIT "A"
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Table of Contents
Section 1: Introduction
1.1 Introduction ................................ ................................ ................................ ......................... 1.0-1
1.2 Organization of EIR ................................ ................................ ................................ .............. 1.0-2
1.3 CEQA Process Summary ................................ ................................ ................................ .......1.0-2
1.4 Changes to the Draft EIR ................................ ................................ ................................ ......1.0-4
Section 2: Comments and Responses to Draft EIR
2.1 Introduction to Comments and Responses ................................ ................................ ...........2.0-1 Comment Letter A1 – South Coast Air Quality Management District ................................ ....2.0-3 Responses to Comment Letter A1 ................................ ................................ ...................... 2.0-5 Comment Letter A2 – Riverside County Flood Control and Water Conservation District ......2.0-7 Response to Comment Letter A2 ................................ ................................ ....................... 2.0-11 Comment Letter A3 – Riverside County Department of Waste Resources ............................. 2.0-15 Responses to Comment Letter A3 ................................ ................................ ...................... 2.0-23 Comment Letter A4 – South Coast Air Quality Management District ................................ ....2.0-25 Responses to Comment Letter A4 ................................ ................................ ...................... 2.0-33 Comment Letter A5 – City of Perris ................................ ................................ ...................... 2.0-41 Responses to Comment Letter A5 ................................ ................................ ...................... 2.0-49 Comment Letter O1 – Radical Research, LLC ................................ ................................ ........2.0-59 Responses to Comment Letter O1 ................................ ................................ ...................... 2.0-61 Comment Letter O2 – Supporters Alliance for Environmental Responsibility (SAFER), c/o Lozeau Drury, LLP ................................ ................................ ......2.0-63 Responses to Comment Letter O2 ................................ ................................ ...................... 2.0-65 Comment Letter O3 – Golden State Environmental Justice Alliance, c/o Blum, Collins & Ho LLP ................................ ................................ ................................ .........2.0-67 Responses to Comment Letter O3 ................................ ................................ ..................... 2.0-211 Comment Letter T1 – Agua Caliente Band of Cahuilla Indians ................................ ............... 2.0-225 Responses to Comment Letter T1 ................................ ................................ ...................... 2.0-229 Northern Gateway Logistics Center
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Comment Letter P1 – Breanna Harwood ................................ ................................ .............. 2.0-231 Responses to Comment Letter P1 ................................ ................................ ...................... 2.0-233 Comment Letter P2 – Jose Marquez ................................ ................................ ..................... 2.0-235 Response to Comment Letter P2 ................................ ................................ ........................ 2.0-237
Section 3.0: Errata to the Draft EIR
3.1 Introduction to the Errata ................................ ................................ ................................ ....3.0-1
3.2 Changes to the Draft EIR ................................ ................................ ................................ ......3.0-1
List of Tables
Table 2.0-1: Comments from Public Agencies, Organizations and Individuals ................................ .2.0-1
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Section 1.0 Introduction
1.1 INTRODUCTION
The City of Menifee (City) has prepared this Final Environmental Impact Report (FEIR) in compliance with the California Environmental Quality Act (CEQA) for the Northern Gateway Logistics Cente r project (Project). The City is required, after completion of a Draft Environmental Impact Report (Draft EIR) (State Clearinghouse No. 2021110379), to consult with and obtain comments from public agencies having jurisdiction by law with respect to the Project and provide the general public with an opportunity to comment on the DEIR. This FEIR has been prepared to respond to comments received on the DEIR, which was circulated for public review from June 6, 2024, through July 22, 2024. The preceding Table of Contents provides a list of all persons, organizations, and public agencies who commented on the DEIR.
The City will evaluate comments on environmental issues from persons who reviewed the DEIR and will prepare a written response, pursuant to CEQA Guidelines §15088(a). The written response must address any significant environmental issues raised. In addition, there must be a good faith and reasoned analysis in the written response. However, lead agencies need only respond to significant environmental issues associated with the Project and do not need to provide all the information requested by commenters, as long as a good faith effort at full disclosure is made in the EIR (State CEQA Guidelines §15204, §15088).
Those comments are responded to in Section 2.0, Comments on the Draft EIR and Responses to Comments.
State CEQA Guidelines §15088 recommends that where a response to comment makes important changes in the information contain in the text of the DEIR, that the Lead Agency either revise the text of the DEIR or include marginal notes showing that information. Added or modified text is shown in Section 3.0, Errata, by underlining ( example) while deleted text is shown by striking (example). The additional information, corrections, and clarifications are not considered to substantively affect the conclusions within the EIR and therefore the City has determined that recirculation of the DEIR is not required as none of the criteria for recirculation under CEQA Guidelines Section 15088.5 have been met.
CEQA Guidelines §15132 indicates that the contents of a FEIR shall consist of:
a) Environmental Impact Reports shall contain the information outlined in this article, but the format of the document may be varied. Each element must be covered, and when these elements are not separated into distinct sections, the document shall state wher e in the document each element is discussed.
b) The EIR may be prepared as a separate document, as part of a general plan, or as part of a project report. If prepared as a part of the project report, it must still contain one separate and distinguishable section providing either analysis of all the subj ects required in an EIR or, as a minimum, a table showing where each of the subjects is discussed. When the Lead Agency is a state agency, the EIR shall be included as part of the regular project report if such a report is used in the agency’s existing review and budgetary process.
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c) Draft EIRs shall contain the information required by Sections 15122 through 15131. Final EIRs shall contain the same information and the subjects described in Section 15132. d) No document prepared pursuant to this article that is available for public examination shall include a “trade secret” as defined in Section 6254.7 of the Government Code, information about the location of archaeological sites and sacred lands, or any other information that is subject to the disclosure restrictions of Section 6254 of the Government Code.
Pursuant to CEQA Guidelines §15088(b), the City will provide written responses to comments to any public agency that commented on the DEIR, at least ten (10) days prior to the Planning Commission 's consideration of certifying the EIR as adequate under CEQA. Written responses to comments will also be provided to non -public agency individuals, organizations, and entities that commented on the DEIR. In addition, the FEIR will be made available to the general public at the City’s Planning Division office and on the City’s website a minimum of 10 days prior to the Planning Commission public hearing.
The FEIR, along with other relevant information and public testimony at the Planning Commission hearing, will be considered by the City’s Planning Commission.
1.2 ORGANIZATION OF EIR
This Final EIR provides the requisite information required under CEQA and is organized as follows:
Section 1.0 Introduction. This section provides an introduction to the Final EIR, including the requirements under CEQA, the organization of the document, and a brief summary of the CEQA process activities to date.
Section 2.0 Comments and Responses. This section provides a list of public agencies, organizations, and individuals commenting on the Draft EIR, provides a copy of each written comment received, and any response required under CEQA.
Section 3.0 Errata to the Draft EIR. This section presents clarifications, amplifications, and insignificant modifications to the EIR, identifying revisions to the text of the document.
1.3 CEQA PROCESS SUMMARY
The Draft Environmental Impact Report (Draft EIR) is an informational document intended to inform the public and decision-makers about the environmental consequences of the Project. The Project involves the development of two new concrete tilt up warehouse and distribution buildings with associated office space on 20.17 acres of land. Building 1 is proposed to be 105,537 square feet (sq. ft.) consisting of 6,000 sq. ft. of office space and 99,537 sq. ft. of warehouse space and is located on the north side o f the site. Building 2 is on the southern end of the site and is proposed to be 292,715 sq. ft. consisting of 8,000 sq. ft of office space, 7,000 sq. ft. of mezzanine, and 277,715 sq. ft. of warehouse area. Buildings 1 and 2 combined would consist of 398,252 sq. ft. of total building area. Associated facilities and improvements of the Project site includes loading dock doors (15 for Building 1; 37 for Building 2), on site landscaping, and related on -site and off -site improvements (including relocation of an underground flood channel).
The proposed warehouse uses are considered speculative in nature, but may be used for receiving, Northern Gateway Logistics Center
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storing, and distribution of manufactured goods, pursuant to the City of Menifee Development Code (Menifee Development Code)’s definition for Warehousing, logistics, and distribution facilities. The proposed buildings would not include cold storage.
Additionally, SB 330, which provides that the City shall not “chang[e] the general plan land use designation, specific plan land use designation, or zoning…to a less intensive use… below what was allowed under the land use designation and zoning ordinances in effect on January 1, 2018”. However, the Act includes an exception, and general plan and zoning designation changes to a “less intensive use” are permitted so long as the City concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction, such that there is no net loss in residential capacity. (Govt. Code §66300(i).)
Pursuant to CEQA Guidelines § 15082, the City circulated a Notice of Preparation (NOP) advising public agencies, special districts, and members of the public who had requested such notice that an EIR for the proposed Project was being prepared. The initial NOP was distributed on XXX to solicit comments related to the proposed Project.
After receiving public comments on the NOP, the proposed Project was analyzed for its potential to result in environmental impacts. Impacts were evaluated in accordance with the significance criteria developed by the City that are based on criteria present ed in Appendix G, “Environmental Checklist Form,” of the CEQA Guidelines. The criteria in the Environmental Checklist (checklist), was used to determine if the proposed Project would result in, “no impact,” “less than significant impact,” “less than significant impact with mitigation measures,” or potentially significant impact” to a particular environmental resource. In some instances, a project may use the checklist to provide an initial discussion of a project and to screen out certain topics from a full discussion in the Draft EIR.
The Draft EIR describes the existing environmental resources on the Project site and in the vicinity of the Project site, analyzes potential impacts on those resources that would or could occur upon initiation of the proposed Project, and identifies mitigation measures that could avoid or reduce the magnitude of those impacts determined to be significant. The environmental impacts evaluated in the Draft EIR concern several subject areas, including aesthetics/light and glare, air quality, biological resource s, cultural and tribal resources, energy/energy conservation, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services, recreation, tran sportation, utilities and service systems, and wildfire. As noted in the preceding paragraph, public comment was received during the NOP process and included written letters provided to the City during public meetings. A copy of the letters with the NOP and a copy of the letters with the revised NOP is provided in Appendix A to the Draft EIR. The comments were used, as intended, to help inform the discussion of th e Draft EIR and help determine the scope and framework of certain topical discussions.
When the Draft EIR was completed, it was circulated for public review pursuant to CEQA Guidelines § 15087. The 45-day public review for the Draft Environmental Impact Report began on June 21, 2023 and ended on July 20, 2023. All comment letters received during the 45-day public review period previously Northern Gateway Logistics Center
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mentioned are included in this Final EIR. Additionally, a public meeting with was held for the proposed Project on June 27, 2023 at 5:30 p.m.
As set forth in more detail in the Responses to Comments and Errata, none of the clarifications or amplifications set forth herein change the significance conclusions presented in the Draft EIR or substantially alters the analysis presented for public revi ew. Furthermore, the Draft EIR circulated for public review was fully adequate under CEQA such that meaningful public review was not precluded. Thus, the clarifications provided in the Responses to Comments and Errata do not constitute significant new information that might trigger recirculation.
1.4 CHANGES TO THE DRAFT EIR
As stated previously, Section 3.0, Errata to the Draft EIR details the changes to the DEIR. In response to public comments, text changes have been made to DEIR sections to clarify and amplify the analysis or mitigation measures, and to make insignificant modifications to the DEIR. This information does not rise to the level of significant new information as the resulting impact analysis and alternatives considered remain essentially unchanged, and no new or more severe impacts have been identified. These ch anges do not warrant DEIR recirculation pursuant to California Public Resources Code §21092.1 and CEQA Guidelines §15088.5. As discussed herein and as elaborated upon in the respective Response to Comments, none of the clarifications or changes made in the Errata reflect 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, nor do the Errata reflect a “fundamentally flawed” or “conclusory” DEIR. In all cases, as discussed in individual responses to comments and DEIR Errata, these minor clarifications and modifications do not identify new or substantially more severe environmental impacts that the City has not committed to mitigate. Therefore, the public has not been deprived of a meaningful opportunity to comment upon a substantial adverse environmental effect of the Project or an unadopted feasible Project alternative or mitigation measure. Instead, the information added supports the existing analysis and conclusions, and responds to inquiries made from commenters. Therefore, this FEIR is not subject to recirculation prior to certification.
CEQA Guidelines §15088.5 describes when an EIR requires recirculation prior to certification, stating in part:
“(a) 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. As used in this sect ion, the term "information" can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
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(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to apply it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043).
(b) Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.”
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Section 2.0 Comments and Responses to Draft EIR
2.1 INTRODUCTION TO COMMENTS AND RESPONSES
Table 2.0-1 below provides a list of those parties that provided written comments on the Draft EIR during the public review period. In addition, one comment letter was received after the close of the public review period. Each comment document has been assigned a letter as indicated in the table.
A copy of the written comments are provided in this section and have been annotated with the assigned letter along with a number for each comment. Each comment document is followed by a written response that corresponds to the comments provided.
Table 2.0-1: Comments from Public Agencies, Organizations and Individuals Letter Date Received Organization/Name
Agencies
A1 June 20, 2024 South Coast Air Quality Management District Evelyn Aguilar, Air Quality Specialist, CEQA-IGR
A2 July 10, 2024 Riverside County Flood Control and Water Conservation District Amy McNeill, Engineering Project Manager
A3 July 18, 2024 Riverside County Department of Waste Resources Katherine Avila, Assistant Planner
A4 July 18, 2024 South Coast Air Quality Management District Sam Wang, Program Supervisor, CEQA IGR
A5 July 22, 2024 City of Perris
Patricia Brenes, Planning Manager
Organizations
O1 June 18, 2024 Radical Research, LLC
Mike McCarthy, Ph.D.
O2 July 1, 2024 Supporters Alliance for Environmental Responsibility (SAFER), c/o Lozeau Drury, LLP
Kylah Staley
O3 July 17, 2024 Golden State Environmental Justice Alliance, c/o Blum, Collins & Ho LLP Gary Ho
Tribal
T1 July 23, 2024 Agua Caliente Band of Cahuilla Indians Luz Salazar, Cultural Resources Analyst
Public/Individuals
P1 June 25, 2024 Breanna Harwood
P2 July 16, 2024 Jose Marquez
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Comment Letter A1 - South Coast Air Quality Management District Evelyn Aguilar, Air Quality Specialist, CEQA-IGR
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Responses to Comment Letter A1 - South Coast Air Quality Management District Evelyn Aguilar, Air Quality Specialist, CEQA-IGR
A1-1 This comment includes introductory statements and therefore, no further response is warranted.
A1-2 This comment includes a public records request for all technical documents related to air quality, health risk, and GHG analyses, electronic versions of all emission calculation files, and air quality modeling and health risk assessment files. As requested by the Commenter, the City sent the requested data files on March 26, 2024
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Comment Letter A2 - Riverside County Flood Control and Water Conservation District Amy McNeill, Engineering Project Manager
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Response to Comment Letter A2 - Riverside County Flood Control and Water Conservation District
Amy McNeill, Engineering Project Manager
A2-1 This comment includes introductory statements concerning the Riverside County Flood Control and Water Conservation District’s (District) interest in projects associated with the District Master Drainage Plan facilities and other regional flood control and drainage facilities which could be considered a logical component or extension of a master plan system. Refer to Responses to Comments A2-2 through A2-4 below.
A2-2 It is noted that the Project Applicant will be required to obtain an encroachment permit for any construction-related activities occurring within District right -of-way or facilities, such as the Project’s construction of the District’s Homeland/Romoland Dr ainage Plan and the Project Applicant will be required to pay any applicable fees in accordance with the Rules and Regulations for Administration of Area Drainage Plan as a condition of approval. The Area Drainage Plan (ADP) fees will be paid to the District at the time of issuance of grading permits.
A2-3 It is noted that the Project Applicant will be required to obtain an encroachment permit for any construction-related activities occurring within District right -of-way or facilities , namely Romoland Master Drainage Plan Line A and Romoland Master Drainage Plan Line A-8. Further, the Draft EIR evaluates the Project’s potential impacts on drainage facilities and, at page 4.9 -23, concludes that all proposed drainage improvements would adequately convey flows to the basin and provide flood protection for t he 100-year storm event. Additionally, the Project Applicant would be required to obtain coverage under the National Pollutant Discharge Elimination System (NPDES) Construction Stormwater Permit, and comply with the water quality policies of the City of Menifee General Plan (Menifee GP) and the Riverside County Drainage Area Management Plan (DAMP), which require implementation of construction Best Management Practices (BMPs) per a stormwater pollution prevention plan (SWPPP; see MM HYD-1) and post -construction BMPs in accordance with the Water Quality Control Plan for the Santa Ana River Basin. In addition, the Santa Ana Municipal Separate Storm Sewer Systems (MS4) Permit requires the preparation of a project-specific water quality management plan (WQMP) for all development projects. Pursuant to Santa Ana MS4 Permit, a project-specific WQMP was prepared and is included as Appendix I 1 to the Draft EIR and has incorporated combined low -impact development (LID) treatment, hydrologic control BMPs, and sediment supply BMPs. A final WQMP will be required to address BMP sizing and O&M plan p ursuant to Draft EIR MM HYD -2 and comply with City of Menifee Municipal Code (Menifee MC) Section 15.01, Storm Water/Urban Runoff which includes the requirement for the preparation and implementation of a Project -Specific WQMP and has outlined all BMPs designed to meet water quality standards and mitigate any adverse impacts.
Refer to Draft EIR pages 4.9-15 through 4.9-19 for further discussion.
A2-4 The Commenter’s attachment letter dated July 17, 2023 and submitted during the Project’s Notice of Preparation has been noted. No further response is warranted.
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A2-5 Relevant to the Project, the NPDES permit is divided into two parts: construction and post - construction. The construction permitting is administered by the State Water Resources Control Board (SWRCB), while the post -construction permitting is administered by the Regional Water Quality Control Board (RWQCB). Development projects typically result in the disturbance of soil that requires compliance with the NPDES General Permit, Waste Discharge Requirements for Discharges of Stormwater Runoff Associated w ith Construction Activities (Order No. 2012-0006- DWQ, NPDES Number CAS000002) General Construction Permit. This Statewide General Construction Permit regulates discharges from construction sites that disturb one or more acres of soil. As stated in Response to Comment A2-3 above, the Project would comply with the NPDES permit with the implementation of construction and post -construction BMPs in the SWPPP and Project-specific WQMP. Therefore, the Project would be compliant with the NPDES permitting requirements (see Draft EIR MMs HYD-1 and HYD-2).
A2-6 As discussed in Draft EIR Section 4.9: Hydrology and Water Quality page 4.9 -5, review of Federal Emergency Management Agency (FEMA)’s Flood Insurance Rate Map (FIRM) shows th e Project site being covered by one map panel: 06065C2055H (effective 8/18/2014). According to this FIRM, the westerly portion of the Project site is within Flood Zone X (shaded) under the Letter of Map Revision (LOMR) 21-09-0711P (effective 1/24/2022) and the easterly portion of the Project site is within Flood Zone X (unshaded) . Flood Zone X (shaded) characterize areas of moderate flood hazard and is defined as areas of 0.2-percent annual chance (500-year) flood; areas of 1-percent annual chance (100-year) flood with average depths of less than 1 foot or with drainage areas less than 1 square mile; and areas protected by levees from 1-percent annual chance (100-year) flood.
Flood Zone X (unshaded) is defined as areas of minimal flood hazard.
As discussed in Draft EIR Section 4.9: Hydrology and Water Quality page 4.9-23, BMPs have been incorporated into the site design to fully address all Drainage Management Areas (DMAs). As noted in Draft EIR Preliminary Water Calculations ( Appendix I2), with implementation of the proposed BMP, runoff would be conveyed to the corresponding detention basins which have been designed appropriately to provide flood protection for the 100-year storm event. Implementation of efficient design measures and applicable BMPs pursuant to the Project’s WQMP and SWPPP (MMs HYD-1 and HYD-2,) would prevent flooding on - and off-site due to an increase in surface water runoff. Therefore, the Project will adequately control storm water drainage.
A2-7 The City of Menifee prepared a Draft EIR and this FEIR in accordance with CEQA. The Project applicant will implement mitigation measures proposed in the Draft EIR and comply with applicable federal, state, and local laws, ordinances, and regulations to reduce impacts associated with the Project.
A2-8 As discussed in Draft EIR Section 4.3: Biological Resources page 4.3-17, a Jurisdictional Delineation was conducted for the Drainage 1/Ethanac Wash located along the eastern portion of the Project site. Draft EIR Appendix C3 concluded that no riparian vegetation or wetland obligate plant species were observed within Drainage 1. Review of the United States Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) and the United States Geological Survey (USGS) National Hydrography Dataset did n ot identify any riverine features within or adjacent to the Northern Gateway Logistics Center
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boundaries of the Project site. Further, Drainage 1 does not hold water for long enough to create anaerobic condition, ultimately forming hydric soils. Thus, Drainage 1 did not meet wetland requirements. Therefore, because regulatory approvals from the United States Army Corps of Engineers (USACE) would not be required since Drainage 1 was created wholly in the uplands and did not replace an existing blueline stream it does not qualify as waters of the United States.
However, the RWQCB and CDFW may assert jurisdiction over the storm drain channel which would require a Report of Waste Discharge and Streambed Alteration Agreement. Accordingly, the Project Applicant will obtain a Report of Waste Discharge and Streambed Alteration Agreement prior to Project implementation. Refer to Draft EIR 4.3-17 for further discussion.
A2-9 The Commenter’s attachment letter dated July 17, 2023 and submitted during the Project’s Notice of Preparation has been noted. No further response is warranted.
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Comment Letter A3 - Riverside County Department of Waste Resources Katherine Avila, Assistant Planner
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Response to Comment Letter A3 - Riverside County Department of Waste Resources Katherine Avila, Assistant Planner
A3-1 This comment includes introductory statements and a brief Project description. No further response is warranted.
A3-2 The City appreciates and values these comments during the FEIR participation process. Responses to comments are provided in Responses to Comments A3-3 through A3-6 below.
A3-3 Draft EIR Table 4.15-5: Landfill Information lists the El Sobrante Landfill’s maximum permitted throughput (tons per day), remaining capacity in cubic yards, maximum permitted capacity in cubic yards, and ceased operation date. This information reflected available data at the time the Draft EIR was prepared. The Project’s estimated 5,846 pounds (2.9 tons) of waste per day represented approximately 0.02 percent of El Sobrante’s Landfill’s maximum daily throughput.
Therefore, the Project adequately included information regarding the El Sobrante Landfill in the Draft EIR per the commenter’s suggestion.
A3-4 The Draft EIR anticipated that solid waste from the Project site would ultimately end up in either El Sobrante Landfill or Badlands Landfill. As concluded in Draft EIR Section 4.15 page 4.15-18, the Project’s solid waste disposal needs could be accommodated at one or a combination of the disposal facilities. However, the availability for the Project to utilize the Lamb Canyon Landfill has been noted.
A3-5 Draft EIR Table 4.15 -5: Landfill Information lists the Badlands Sanitary Landfill’s maximum permitted throughput (tons per day), remaining capacity in cubic yards, maximum permitted capacity in cubic yards, and ceased operation date. This information reflected available data at the time the Draft EIR was prepared. The Project’s estimated 5,846 pounds (2.9 tons) of waste per day represented approximately 0.06 percent of the Badlands Sanitary Landfill maximum daily throughput. Therefore, the Project adeq uately included information regarding the Badlands Sanitary Landfill in the Draft EIR per the commenter’s suggestion.
A3-6 As discussed in Draft EIR Section 4.15, page 4.15-18 and 4.15-19, the Project‘s solid waste would be handled and disposed in compliance applicable federal, state, and local regulations which include, but not limited to, with California Green Building Standards Code § 5.408.1, the more stringent of the code sections , that requires a minimum of 65 percent diversion of solid waste; and Menifee MC Sections 6.40.010 and 6.40.050, requiring a 50 percent diversion of solid waste materials from landfills by using recycling, reuse, and diversion programs. Therefore, the Project would adhere to the solid waste goals and requirements of AB 75 and 1383.
A3-7 The City thanks the Commenter for their letter on the Project’s Draft EIR. As requested, the City will include the Commenter on the Project’s public interest list for all future Project noticing. No further response is warranted.
A3-8 The Commenter’s letter on the Project’s Notice of Preparation (NOP) has been noted. The Commenter’s comments made on the NOP were taken into consideration during the preparation of the Draft EIR’s environmental impact analysis pertaining to solid waste. Accordingly, refer to Northern Gateway Logistics Center
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Responses to Comments A3 -3 through A3 -6 above and Draft EIR Sections 4.8, Hazards and Hazardous Materials, and 4.15, Utilities and Service Systems for more information.
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Comment Letter A4 - South Coast Air Quality Management District Sam Wang, Program Supervisor, CEQA IGR
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Response to Comment Letter A4 - South Coast Air Quality Management District Sam Wang, Program Supervisor, CEQA IGR
A4-1 This comment includes introductory statements and therefore, no further response is warranted.
A4-2 The comment includes a summary of the Project description. No further response is warranted.
A4-3 The commenter provides a brief summary of the Project and identifies existing sensitive receptors. The introductory comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. The comment has been noted and no further response is warranted.
A4-4 The Air Quality Assessment used a truck trip length of 33.2 miles in the emissions modeling based on the California Air Resources Board document Emissions Estimation Methodology for On-Road Diesel-Fueled Heavy-Duty Drayage Trucks at California Ports and Intermodal Rail Yards. It should be noted that this distance is specific to transloading/local distribution facilities and the longest (i.e., most conservative) distance identified in the study for the South Coast Air Basin. Shorter distances are identified for other locations such as off-terminal and intermodal facilities. The CARB study used GIS to estimate travel distances. CARB explains that that estimating travel distances to/from the Ports of Los Angeles and Long Beach to distribution and transload ing facilities is complicated because there are thousands of facilities and the number of trips to each facility and location of each facility is unknown. Therefore, CARB used the Ports’ truck trip origin and destination (O-D) survey data to estimate distribution center travel distances.
The CalEEMod methodology uses average trip lengths, which accounts for some longer trips (e.g., to/from the Ports or other location) and some shorter trips (e.g., to/from other facilities or warehouses in the area). Goods movement can involve several steps (i.e., origin and destination) between the port and a particular warehouse, intermodal facility , or other facility. Each step would be a separate trip. As such, not all truck trips would originate from the Ports; some trips may be from intermodal facilities, storage warehouses, cross -dock warehouses, distribution centers, retail stores, etc. Truck t rips would likely be redistributed from other existing locations.
As described above, the CARB truck trip lengths used in the Air Quality Assessment are based on substantial evidence and representative of warehouse truck trips to/from the Ports in the Sout h Coast Air Basin (i.e., the region where the Project is located).
Based on the State Office of Planning and Research (OPR) Technical Advisory (page 4), “ ’vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project,” where automobile refers to passenger vehicles, specifically cars and light trucks. VMT generated from trucks are not considered in the VMT impact as sessment based on the OPR Technical Advisory. This is due in part with the understanding that trucks are already on the regional roadway network with or without the Project, such as traveling to/from the Ports and using major freeways to end up at their final destinations. The addition of this Project may likely result in a net decrease in regional VMT, as these projects are strategically located near delivery points, thereby reducing trip lengths by providing additional regional warehouses.
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A4-5 The Air Quality Analysis located in Appendix B of the Draft EIR uses the SCAQMD ‘s Mass Rate Localized Significance Threshold (LST) Look-Up Table to analyze LST impacts. The mass rate look- up table identifies the maximum allowable construction and operation emissions without generating significant localized air quality impacts based on the Project location, project size (ranging between 1, 2, and 5 acres), and the distance from sensitive receptors (ranging from 25 meters or less, 50 m, 100 m, 200, and 500 m). As a project increases in size, the allowable emissions continue to increase. The LST screening thresholds are based on dispersion modeling conducted by the SCAQMD. The screening thresholds for sites 1-, 2-, and 5-acres in size were only modeled by the SCAQM D. The commenter noted that the Project is 20.17 acres, however as discussed in Section 4.2.5 of the Draft EIR, the Project uses a disturbance area of 3.5 acres per day in the analysis. Therefore, the construction emissions threshold for 3.5 acre s was interpolated from the 2-acre threshold and the 5 -acre threshold. The operational LST analysis conservatively used the 5-acre emission screening thresholds (i.e., a larger site acreage would have higher/less conservative thresholds because the polluta nts would have more area to disperse). As shown in Table 4.2 -11 and Table 4.2 -12, the Project generated less emissions than is permitted for a 3.5-acre construction site and a 5 -acre warehouse site. Because the emissions generated by the Project are less t han those permitted for a smaller site, it is reasonable to assume that the Project would not generate significant localized air quality impacts even though the Project site is
20.17 acres.
A4-6 The LST analysis conservatively assumed 3.5 -acres would be disturbed per day as shown in Table 4.2-10 of the Draft EIR. However, the commenter notes that SCAQMD staff found that up to a maximum of 4 acres may be disturbed during grading. As discussed above, as the area of disturbance increases, the allowable emissions increase until maxing out at 5 -acre l evels.
Therefore, using the 3.5-acre threshold is more conservative than using the 4-acre threshold. For informational purposes, the results from Tabl e 4.2 -11: Localized Significance of Construction Emissions have been updated with the construction thresholds for 4 acres of disturbance in the table below. As shown, the screening thresholds increase, and impacts remain less than significant.
Description Emissions (Maximum Pounds Per Day)
NOX CO PM10 PM2.5
Site Preparation Emissions 36.00 32.90 1.60 1.47
Grading Emissions 34.30 30.20 1.45 1.33
Building Construction Emissions 10.40 13.00 0.43 0.40
Paving Emissions 7.45 9.98 0.35 0.32
Architectural Coating Emissions 0.88 1.14 0.03 0.03
Infrastructure Improvement Emissions 2.12 2.46 0.08 0.08 Maximum Emissions 36.00 32.90 1.60 1.47
SCAQMD Localized Screening Threshold (adjusted
for 4 acres at 107 meters) 348 3,263 55 15
Exceed SCAQMD Threshold? No No No No
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A4-7 As shown in Errata Exhibit 2-7: Conceptual Site Plan – Building 2, the southern portion of the site was identified as a future road and was not originally included in the analysis, therefore the closest sensitive receptor was identified as being 123 meters from the construction area. When the Project was updated to include the southern portion of the Project site, the distance to the closest sensitive receptor was updated to 107 meters. Although the distance was not updated in the Air Quality Assessment, the correct values are presented in the Draft EIR. As shown in Tables 4.2 -11 and 4.2 -12 of the Draft EIR, emissions remain below the thres holds identified for sensitive receptors located 107 meters from the construction boundary area.
A4-8 The comment includes a statement of nearby warehouse cumulative projects #’s 27, 34, 38, and 48 and their total square footage of approximately 1,591,393 square feet. No further response is warranted here but refer to the following Responses to Comments A4-9 and A4 -10 for further discussion.
A4-9 The commenter notes that SCAQMD is concerned with cumulative air quality impacts. The commenter also notes that SCAQMD has initiated a public process to develop guidance for evaluating cumulative air quality impacts however no final methodologies or thresh olds have been adopted. The comment does not raise a specific issue with the adequacy of the Draft EIR.
The comment has been noted and no further response is warranted.
A4-10 The commenter suggests performing a qualitative analysis of cumulative impacts. A discussion of this topic can be found on pages 4.2-36 and 4.2-37 of the Draft EIR. Additionally, cumulative past, present, and probable future projects are listed in Draft EIR Table 3-1: List of Cumulative Projects and are shown on Draft EIR Exhibit 3 -1: Location of Cumulative Pr ojects. The Draft EIR lists 48 cumulative projects. As discussed, air emissions are largely a cumulative impact and SCAQMD has developed thresholds of significance based on the level above which individual project emissions would result in a cumulatively considerable contribution to air basin’s existing air quality conditions.1 Therefore, a project that exceeds the SCAQMD operational thresholds would also result in a cumulatively considerable contribution to a significant cumulative impact and, inversely, emission volumes below the SCAQMD operational thresholds are not cumulative ly considerable. The analysis follows the approach in South Coast AQMD’s White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution.
The cumulative projects identified in the comment are also subject to CEQA and are required to mitigate potential impacts to the extent feasible. These projects (as with the Project) are also required to comply with all applicable SCAQMD rules and regulations, which would minimize emissions. Draft EIR Table 4.2 -9 shows that the Project would not exceed the SCAQMD operational thresholds. Therefore, as discussed in section 4.2.6 of the Draft EIR, the Project’s emissions would not result in a cumulatively cons iderable contribution to significant cumulative air quality impacts.
1 South Coast Air Quality Management District, White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, Appendix D, 2003.
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A4-11 The commenter summarizes the Project and notes the distance of sensitive receptors from the Project. A Health Risk Assessment was prepared for the Project and included in Appendix B of the Draft EIR. In addition, the results of the study can be found in Ta ble 4.2-13: Carcinogenic Risk Assessment and 4.2-14: Chronic Hazard Assessment in the Draft EIR. As demonstrated in these tables, risks to sensitive receptors from toxic air contaminants are reduced to less than significant with mitigation. Therefore, there is no nexus for additional mitigation.
A4-12 The commenter suggests implementing project design features to reduce impacts from mobile sources. Although the commenter calls them project design features, they are mitigation measures.
The first measure suggests requiring zero-emission or near zero-emission on-road haul trucks. The suggested measures contained in the comment related to zero - and near-zero emission (ZE and NZE) vehicles are not feasible to implement, because the availabil ity of vehicles equipped with such technology in the Project’s opening year is speculative. Even with adoption of CARB’s Advanced Clean Truck Rule, CARB acknowledges that it will take time for ZE and NZE vehicles to become commercially available and to pen etrate the market. For example, CARB’s Staff Report for the Proposed Amendments to the Advanced Clean Trucks Regulation and the Zero -Emission Powertrain Certification Test Procedure (March 26, 2024) explains that the regulation requires manufacturers to sell an increasing percentage of ZE trucks in California. Additionally, by 2035 ZE truck/chassis sales would need to be 55 percent of Class 2b – 3 truck sales, 75 percent of Class 4 – 8 straight truck sales, and 40 percent of truck tractor sales. 2 Based on the regulation’s phase-in, it will take time for fleets to turn over and for the ZE percentages of new truck sales to penetrate the market.
As discussed in Draft EIR pages 4.7 -26 and 4.7 -27, trucks accessing the Project site would be subject to the Advanced Clean Truck Regulation, CARB’s Mobile Source Strategy, CARB’s Sustainable Freight Action Plan, and CARB’s Emissions Reduction Plan for Ports and Goods Movement. Additionally, trucks are subject to the Heavy-Duty Low NOX Omnibus Regulation and SCAQMD’s Rule 2305 – WAIRE Program. These regulations are required for all trucks and the suggested mitigation measure is already part of the existing regulatory environment and would not be considered mitigation under CEQA.
A4-13 The second measure suggests requiring a phase -in schedule to incentivize the use of cleaner trucks. However, the CARB approved the Advanced Clean Fleets (ACF) Regulation which implements a phase-in schedule for transitioning truck fleets to ZE vehicles.3 The ACF Regulation requires fleet operators to replace vehicles with ZE trucks based on age or mileage milestones. 4 As this regulation is already required, it does not qualify as mitigation under CEQA.
A4-14 The third measure suggests limiting the number of trucks allowed to access the Project to levels analyzed in the Final CEQA document. The City disagrees with the suggestion that the Final EIR
2 https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/acf22/isor2.pdf 3 https://ww2.arb.ca.gov/resources/fact -sheets/advanced-clean-fleets-regulation-overview 4 https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/acf22/ac/acffrod31.pdf Northern Gateway Logistics Center
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should include a limit on the daily number of trucks allowed at the Project to levels that were analyzed in the EIR and would require re-evaluating impacts through CEQA should daily truck trips from the Project be anticipated to exceed those levels. The analysis is based on a set of realistic, but conservative, set of assumptions regarding the magnitude of potential activities. The Project’s air quality and GHG analysis is consistent with the TIA which assumed 184 daily truck trips and 497 daily passenger vehicle trips based on ITE Code 150 Warehouse. Therefore, the City does not anticipate total emissions (combined passenger vehicle and truck trips) to exceed those modeled in the EIR, and future re-evaluation is not necessary.
A4-15 The fourth measure suggests providing EV charging stations and electrical hookups for truckers to plug in onboard auxiliary equipment. The Project will be consistent with the EV charging requirements in the 2022 CALGreen building code for warehouses and MM AQ-3 requires the electrical to be oversized to accommodate equipment for future EV charging stations and designate areas for future truck charging. The Project does not require the installation of electrical hookups at dock doors as the Project does not include cold storage and will not employ trucks with transport refrigeration units (TRUs). However, electric hookups can be installed by future tenants if requested. Therefore, the Project would be consistent with this recommended measure.
A4-16 The commenter suggests implementing project design features to reduce impact from other source areas:
1) Maximize the use of solar energy by installing solar energy arrays The Table 4.7-3: Project Greenhouse Gas Emissions on page 4.7-20 of the Draft EIR shows that total GHG emissions are below SCAQMD’s threshold. Therefore, mitigation measures requiring the installation of solar panels to reduce GHG emissions is not necessar y.
However, the Project would comply with all building code requirements and may add solar panels in the future if desired.
2) Use light-colored paving and roofing materials.
California's Title 24, Part 6 Building Energy Efficiency Standards includes cool roof requirements for new and existing buildings. These requirements are in the following sections of the 2022 Title 24, Part 6 standards:
• Section 10-113(a, b) (Mandatory Certification and Labeling of Roofing Product Reflectance and Emittance)
• Section 110.8(i) (Mandatory Insulation, Roofing Products & Radiant Barriers) • Section 140.1 (Performance Approach: Energy Budgets (Nonresidential)) • Section 140.2 (Prescriptive Approach (Nonresidential)) • Section 140.3(a)1 (Prescriptive Requirements for Building Envelopes (Nonresidential))
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Therefore, since Title 24, Part 6 Building Energy Efficiency Standards applies to the Project, the Project would be consistent with this recommended measure. Additionally, the Project’s truck courts would be paved with concrete, which is light -colored. The increased stiffness of concrete makes it able to withstand heavier wheel loads without risk of rutting.
A4-17 The commenter suggests implementing project design features to reduce air quality and health risk impacts:
1) Design the Project such that any truck check -in point is inside the Project site to ensure no trucks are queuing outside.
The Project is a speculative warehouse; therefore, the site plan does not include check-in points. However, the Project does include a large driveway located on Evans Road that will be used to access the two buildings and allow trucks to que ue onsite. Future check- in points will be built by the tenant based on their operational needs. These check -in points would comply with all applicable code and would require the approval of the City.
Consistent with the commenters request, queuing will not occur outside the Project area. 2) Design the Project to ensure that truck traffic inside the Project site is as far away as feasible from sensitive receptors.
The Project has been designed to keep truck traffic away from sensitive receptors. Truck parking is located in the center of the site so that sensitive receptors are shielded from noise by the warehouse buildings. Warehouse docking doors are setback approx imately 775 feet from the property line of the nearest sensitive receptor. As a result, Project parking and drive aisles are located as far from sensitive receptors as possible. 3) Restrict overnight truck parking in sensitive land uses by providing sufficient overnight truck parking inside the Project site.
The Project is required to provide adequate on-site parking in accordance with the City’s parking standards. Therefore, the Project would be consistent with this recommended measure.
A4-18 The commenter provides a list of documents to review and suggests adding any applicable mitigation measures. These documents have been reviewed; however, additional mitigation measures are not necessary because the Project has already incorporated mitigati on to reduce impacts to less than significant.
A4-19 The commenter states that if the Project requires the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, etc., air permits from SCAQMD will be required, and the role of SCAQMD would change from a Commenting Agency to a Responsible Agency under CEQA. However, the Project is speculative, and no end user has been identified. Therefore, the Project has no plans at this time to install emergency generators or other permitted stationary equipment . Emissions from emergency generators were included in Northern Gateway Logistics Center
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the GHG analysis as seen in Table 4.7-3 of the Draft EIR in order to analyze a worst-case scenario.
Following construction of the Project any future tenant that requires the use of a generator or stationary equipment with an internal combustion engine woul d be required to obtain permits from SCAQMD prior to installation.
As previously stated, the Project is speculative and there are no known permitted stationary sources identified as part of the Project. Therefore, SCAQMD would remain a Commenting Agency and is not considered a Responsible Agency.
A4-20 Construction and operation emissions are calculated in CalEEMod and the results are included in the output files in Appendix B and Appendix G.
A4-21 Refer to Response to Comments A4-3 through A4-20 above. The issues raised in these comments have been addressed in detail, and the City’s responses have been provided in good faith, and contain reasoned analysis, without resort to unsupported conclusory statements.
The comment requests that the City comply with CEQA when responding to SCAQMD’s comments. As requested, the City’s responses to SCAQMD’s comments will be sent to the SCAQMD as part of the Final EIR distribution prior to certification of Final EIR. As the comment does not raise any issues with respect to the content and adequacy of the Draft EIR or the Project’s environmental effects, no further response is warranted. T he comment is included here to provide a complete record of the SCAQMD’s letter. The comment will become part of the administrative record and will be considered by the decision-makers.
A4-22 The comment includes conclusionary statements and therefore, no further response is warranted.
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Comment Letter A5 - City of Perris
Patricia Brenes, Planning Manager
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Response to Comment Letter A5 - City of Perris
Patricia Brenes, Planning Manager
A5-1 This comment includes an introductory statement and brief Project description. No further response is warranted.
A5-2 The description of the GVSP located north of the Project site is noted. This comment does not raise any specific reasons why a warehouse use cannot be compatible with nearby areas that are used for residential purposes. Lastly, Ethanac Road is designated as a truck corridor in the City of Menifee’s General Plan. As such, trucks utilizing Ethanac Road for access is appropriate.
A5-3 The commenter states that the Draft EIR did not adequately addressed the potential environmental impacts related to air quality, project alternatives, energy, greenhouse gas emissions, land use, noise, and transportation. This portion of the comment does not raise specific concerns and therefore no further responses is warranted. Responses to the City of Perris’ specific concerns regarding the inadequacy of the Draft EIR are provided below.
A5-4 CalEEMod truck trip lengths , which are utilized in the Draft EIR Air Quality Assessment, were updated to 33.2 miles based on a CARB study entitled Emissions Estimation Methodology for On-Road Diesel-Fueled Heavy-Duty Drayage Trucks at California Ports and Intermodal Rail Yards which determined the average truck distance from port terminals to local distribution facilities.
Refer to Response A4-4, which explains why this average trip length is appropriate for the Project.
A5-5 The CalEEMod default for the one-way warehouse trip length of 11.50 miles was replaced with
33.2 miles , based on the CARB study entitled Emissions Estimation Methodology for On -Road Diesel-Fueled Heavy -Duty Drayage Trucks at California Ports and Intermodal Rail Yards . This distance is consistent with other recent warehouse projects within the City of Menifee. Due to updates in the CalEEMod program, some changes to the default settings are no longer displayed in the CalEEMod outputs. However, the mileage use d can be easily identified by reviewing Section 5.9 Operational Mobile Sources of the Air Quality Assessment Appendix A, located in Appendix B of the Draft EIR and dividing VMT/Year by Trips/Year to get trip length. See excerpt below.
As shown, 2,229,712 vehicle miles traveled ÷ 67,160 trips = 33.2 miles per trip.
A5-6 The commenter questions whether CalEEMod trip lengths were used in air quality analysis for the Draft EIR. As discussed above under responses A5-4 and A5-5, the default tip length of 11.50 miles generated by CalEEMod was replaced with 33.2 miles base on the CARB study entitled Emissions
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Estimation Methodology for On-Road Diesel-Fueled Heavy-Duty Drayage Trucks at California Ports and Intermodal Rail Yards. This distance is consistent with other recent warehouse projects within the City of Menifee.
A5-7 The Project includes an early-suppression fast-response (EFSR) fire sprinkler system and will use an electric or diesel -powered fire pump to provide additional water pressure. If an electric fire pump is installed, in the event that the building loses electricity, power for the electric fire pump will be provided by the emergency backup generator. As noted on page 4.2 -19 and page 4.7-20 of the Draft EIR, emissions from emergency backup generators are included in the operational air quality and GHG analysis of the Project.
A5-8 The commenter notes that diesel powered fire pumps must be tested on a weekly basis for a minimum of 30 minutes. Conservatively, the analysis for this Project assumed that diesel generators would operate for one hour every week and included those emissions in Table 4.2-9 of the Air Quality Section and Table 4.7-3 of the GHG Section of the Draft EIR. Therefore, the Draft EIR analysis conservatively overestimates the contribution from stationary diesel emissions sources by assuming one hour of testing rather than 30 minutes of testing.
A5-9 The commenter notes that health risk impacts are based on emissions generated by construction equipment, mobile sources, off -road equipment, and emergency backup generators within the site and suggests that the analysis needs to include emissions from vehicles travelin g on roadways. However, the commenter is incorrect in assuming mobile sources are only analyzed on site. As shown on page 4 of the Health Risk Assessment Appendix A, located in Appendix B of the Draft EIR, offsite truck routes analyzed include Ethanac Road, Evans Road, and Barnett Road.
The commenter also suggests identifying impacts to residents north of Ethanac Road. The Health Risk Assessment includes health risk results for receptors up to 722 feet north of the Ethanac Road centerline. As identified in Table 4.2-13: Carcinogenic Risk Assessment, the maximum cancer risk with mitigation is 1.73 in one million which is below SCAQMD’s threshold of 10 in one million.
A5-10 Refer to Response A5-4 and A5-5.
A5-11 Refer to Response A5-4 and A5-5.
A5-12 This comment contends that the Project’s warehouse use is not compatible with the GVSP and residential land uses in the surrounding area. As shown in Draft EIR Table 2 -2 (page 2 -2), the Project site and surrounding area has a land use and zoning designation of Economic Development Corridor-Northen Gateway (EDC -NG), respectively. The ECD -NG designation allows for the development of industrial uses, and therefore the proposed industrial uses are permitted within the site and surrounding area. Regarding the Project’s impacts to the residential land uses located in the City of Perris, the Project will comply with the City’s Industrial Good Neighbor Policies which requires that warehouse, logistics, and distribution to minimize impacts to sensitive uses, protect of public health, safety, and welfare by regulating the design, location and operation of facilities; and protect neighborhood character of adjacent communities. As further discussed in Draft EIR Section 4.2, Air Quality, the Project’s localized emissions during construction and operational Northern Gateway Logistics Center
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activity would be less than significant wit hout implementation of mitigation measures (pages 4.2-26 through 4.2-28). Additionally, CO hotspots would not be experienced at any vicinity intersections resulting from 681 additional vehicle trips attributable to the Project and less than significant impacts were determined. As shown in Draft EIR Table 4.2 -13, the Project’ HRA determined that with implementation of MM GHG-2, impacts concerning carcinogenic risk from Diesel Particulate Matter would be reduced belo w SCAQMD’s maximum cancer risk threshold (pages 4.3-33 and 4.2-34). Lastly, as discussed in the Draft EIR at page 4. 7-25, Ethanac Road is designated as a n expressway in the City of Menifee’s General Plan. As such, trucks utilizing Ethanac Road for access is appropriate.
The commenter also states that it is inappropriate for the Draft EIR to study using Evans Rd., which routes trucks further along Ethanac Road, and that only Barnett Road should be utilized instead.
Ethanac Road is currently designated as a truck route . The Project site is not situated such that Barnett Road alone provides sufficient access, and there is not an existing truck route south of the Project site that can also be used to provide access. Accordingly, it was appropriate for the Project Traffic Study to utilize Ethanac to Evans to access the site. It is also considered a conservative, worst-case scenario because the Draft EIR thus analyzed air quality and transportation impacts on the residences north of Ethanac Road, and air quality and transportation impacts were found to be less than significant with mitigation incorporation, and less than significant, respectfully . A global Traffic Study for the Menifee Economic Development Corridor (MEDC) area, including the addition of a truck corridor south of Ethanac Road, is currently being prepared in coordination with the City of Menifee and the City of Perris. However, that global study has not been completed, and therefore it was not appropriate for the Draft EIR to utilize and speculate about alternative truck routes that might later be designated.
A5-13 Ethanac Road is currently a truck route and is generally a straight and flat road, with good visibility, no visual obstructions, and no sharp curves. As noted in the Project Traffic Study, truck access provided to the Project site would consist of one full -movement truck-accessible driveway on Evans Road and one full -movement truck -accessible driveway on Barnett Road. The implementation of improvements is based on direct discussion between City staff and the Applicant via the Conditions of Approval process. 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. The recommended improvements noted in the Project Traffic Study will further improve safety conditions in the study area and would not create hazards due to geometric design features.
A HRA was prepared for the Project and a s identified in Table 4.2 -13: Carcinogenic Risk Assessment of the Draft EIR, the maximum cancer risk with mitigation is 1.73 in one million which is below SCAQMD’s threshold of 10 in one million. In addition, cumulative short-term and long- term impacts were analyzed on pages 4.2 -36 and 4.2-37 of the Draft EIR and it was determined that the Project would not result in a cumulatively considerable contribution to significant cumulative air quality impacts.
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A5-14 Ethanac Road is currently designated as a truck route, and therefore it was appropriate for the Project Traffic Study to utilize Ethanac to access the site. It is also considered a conservative, worst-case scenario because the Draft EIR thus analyzed air quality and transportation impacts on the residences north of Ethanac Road, and air quality and transportation impacts were found to be less than significant with mitigation incorporation, and less than significant, respectfully .
Further, the Project Traffic Study also analyzes both Project-specific and cumulative impacts with the inclusion of Cumulative Project traffic in the surrounding area. Therefore, the Project Traffic Study, as requested by the commenter, includes an area -wide analysis. Accordingly, the Draft EIR’s transportation analysis was supported by substantial evidence. As noted in Response to Comment A5-12, a global Traffic Study for the Menifee Economic Development Corridor (MEDC) area and surrounding area, including the possible addition of a truck corridor south of Ethanac Road, is currently being prepared in coordination with the City of Menifee and the City of Perris.
However, that global study has not been completed, and therefore it was not appropriate for the Draft EIR to utilize and speculate about alternative truck routes that might later be designated.
A5-15 Under CEQA Guidelines Section 15064.3, LOS associated with automobile delay no longer constitutes a significant environmental impact , and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for informational purposes only for the City’s use in evaluating the Project and considering conditions of app roval outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided.
Based on the City 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) 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.
• 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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Thresholds of a Traffic Impact
A project would be considered to have a project-related effect based on the following criteria:
• A project-related traffic effect is considered direct when a study 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 intersecti on 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 project-related traffic effect is considered direct 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 intersec tion 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 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. • 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 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 of the study intersections, below are study intersections located within Caltrans right-of-way (ROW) or located entirely or a majority within the City of Perris:
2. Barnett Road/Case Road at Ethanac Road (City of Perris)
3. I-215 SB Ramps at Ethanac Road (Caltrans)
4. I-215 NB Ramps at Ethanac Road (Caltrans)
Based on review 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 effect, and would address the City of Perris significance criteria. The Project Traffic Study notes that all study intersections operate at an acceptable LOS under Existing Plus Project conditions. Therefore, the Project would not cause a direct effect at the study intersections and would not be responsible for constructing recommended improvements.
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.
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A5-16 Detailed truck trip distribution figures are provided in Appendix D of the Traffic Study. As noted in the Project Traffic Study, truck access provided to the Project site would consist of one full - movement truck -accessible driveway on Evans Road and one fu ll-movement truck -accessible driveway on Barnett Road. The Project Traffic Study analyzes a majority of trucks (60%) utilizing Ethanac Road via Evans Road and 40% of trucks using Ethanac Road via Barnett Road.
A5-17 See Response to Comment A5-12.
A5-18 See Response to Comment A5-15.
A5-19 See Response to Comment A5-15.
A5-20 The site plan being referenced in Exhibit 2-7which contained the term “Future Road” has been revised as “Future Private Driveway .” Refer to Section 3.0, Errata to the FEIR for the revised exhibit. This is a future private driveway that would be developed by the Applicant as part of the Project to allow automobiles and trucks to enter Building 1 from Evans Road. Therefore, inclusion of the future driveway was considered as part of the Project’s circulation design. The development of this future private driveway would not affect circulation or distribution of passenger vehicles and trucks on surrounding roadways. Therefore, no additional analysis is needed.
A5-21 The study locations on pages 4 and 5 of the Project Traffic Study have been updated accordingly.
See Response to Comment A5-15 regarding City of Perris impact criteria.
A5-22 A separate signalized intersection typically has its own traffic signal cabinet, which is located on a corner of the intersection to which the signal cabinet is connected to. The traffic signal cabinet assigns phasing, signal timing, and cycle length that direct the operation of the individual traffic signal. In the case of the intersection of Ethanac Road at Barnett Road/Case Road, there is only one traffic signal cabinet located south of Ethanac Road between the two offset legs of the intersection. As such, while the northbound and southbound approaches are offset, the intersection operates as one signalized intersection that has connected phasing, signal timing, and cycle length. As a result, the intersection of Barnett Road/Case Road at Ethanac Road operates as one intersection and should be analyzed as one for analysis purposes.
Ethanac Road is generally a straight and flat road, with good visibility, no visual obstructions, and no sharp curves. Based on the Project Traffic Study, the intersection of Ethanac Road at Barnett Road/Case Road does not decline to an unacceptable LOS with the addition of Project traffic. A separate queuing analysis was conducted in the Project Traffic Study, which included the westbound left-turn pocket at the intersection of Ethanac Road at Barnett Road/Case Road. The queuing analysis noted that the 95th percentile queue for the westbound left-turn pocket at the noted intersection would exceed the queuing capacity of the existing left -turn pocket under Opening Year 2025 Cumulative and Opening Year 2025 Cumulative Plus Project conditions. Based on the queuing analysis, it is recommended in the Project Traffic Study for the westbound left - turn pocket at the intersection of Ethanac Road and Barnett Road/Case Road be extended to 250 feet. It should be noted that the existing left -turn pocket would have adequa te capacity for the Northern Gateway Logistics Center
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95th percentile queue under Existing Plus Project conditions. As such, the project would not have a direct effect on the westbound left-turn pocket.
It should be noted that queuing progression and congestion does not automatically mean there is a safety hazard. As such, for the reasons noted above in this response, there is no evidence that those occurrences will create safety hazards in this case and the City of Perris has not provided any evidence to the contrary.
A5-23 See Response to Comment A5-15.
A5-24 See Response to Comment A5-22.
A5-25 Detailed turning movement percentages at each study intersection for both passenger car and truck Project trips is provided in Appendix D of the Project Traffic Study. Further, as noted in the Project Traffic Study, truck access provided to the Project site would consist of one full-movement truck-accessible driveway on Evans Road and one full -movement truck-accessible driveway on Barnett Road. The Project Traffic Study analyzes a majority of trucks (60%) utilizing Ethanac Road via Evans Road and 40% of trucks using Ethanac Road via Barnett Road. Accordingly, the Project Traffic Study clearly sets forth how Project traffic enters/exits the Project site.
A5-26 See Response to Comment A5-15.
A5-27 The Traffic Scoping Agreement includ ed a list of Cumulative Projects (including development projects within the City of Perris). The City of Perris provided a NOP Comment dated July 20, 2023, which include comments regarding Transportation, but did not provide comments with regards to Cumulative Projects within the City of Perris to be included as part of the Traffic Study.
A5-28 Under CEQA Guidelines Section 15064.3, LOS associated with automobile delay no longer constitutes a significant environmental impact , and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for informational purposes only for the City’s use in evaluating the Project and considering conditions of app roval outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided.
The intersection of Barnett Road/Case Road at Ethanac Road operates as one intersection and should be analyzed as one for analysis purposes. The "right turn on red" volume in the traffic model for the study intersection was zero (0) on all approaches as a worst-case scenario. Based on the Project Traffic Study, the intersection would operate at an acceptable Level of Service with the addition of Project traffic. Therefore, no recommended improvements are required for the Project.
A5-29 Refer to Response to Comment A5-22. No further response is warranted.
A5-30 Under CEQA Guidelines Section 15064.3, automobile delay no longer is considered an environmental impact, and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for inf ormational purposes only for the City’s use in evaluating the Project and considering conditions of approval Northern Gateway Logistics Center
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outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided.
The Project Traffic Study only provides recommended improvements to study intersections and roadway segments that would cause the deficient study locations to operate at an acceptable Level of Service (LOS) and would more than offset the Project-related effect. The implementation of improvements is based on direct discussion between City staff and the Applicant via the Conditions of Approval process. 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. The developer/property owner shall pay fair share costs for off-site improvements as detailed in the Project Traffic Study prior to issuance of a certificate of occupancy.
A5-31 Refer to Response to Comment A5-22. No further response is warranted.
A5-32 Ethanac Road is generally a straight and flat road, with good visibility, no visual obstructions, and no sharp curves. It should be noted that queuing progression and congestion does not automatically mean there is a safety hazard. As such, there is no evidence that those occurrences will create safety hazards in this case and the City of Perris has not provided any evidence to the contrary.
The Project will be contributing a fair-share payment per Condition of Approval #135. It should be noted that the Ethanac Road/I-215 interchange has been identified as a Western Riverside Council of Governments (WRCOG) Transportation Uniform Mitigation Fee (TUMF) project. Therefore, the Project's payment of TUMF fees will cover additional costs to TUMF projects, such as the Ethanac Road/I-215 interchange. Nevertheless, the recommended improvements to deficient s tudy locations are to address automobile delay, which are no longer CEQA impacts and therefore, not required improvements to mitigate CEQA-related impacts.
A5-33 Under CEQA Guidelines Section 15064.3, LOS associated with automobile delay no longer constitutes a significant environmental impact , and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for informational purposes only for the City’s use in evaluating the Project and considering conditions of app roval outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided.
Implementation of dual left-turn lanes would require two receiving lanes for the left turns exiting the intersection, which may not be feasible for all applicable roadways, consistent with the City of Menifee General Plan Circulation Element.
A5-34 Under CEQA Guidelines Section 15064.3, automobile delay no longer is considered an environmental impact, and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for inf ormational purposes only for the City’s use in evaluating the Project and considering conditions of approval Northern Gateway Logistics Center
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outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided.
A5-35 Under CEQA Guidelines Section 15064.3, automobile delay no longer is considered an environmental impact, and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for informational purposes only for the City’s use in evaluating the Project and considering conditions of approval outside of CEQA’s framework. Notwithstanding that this comment raises issues outside the scope of CEQA, the following response is provided. The Project will construct the ultimate half -width cross-section of Evans Road and Barnett Road along the project frontage, consist ent with City of Menifee Road Improvement Standards and Specifications (Design Standards, 2019). Also, site access, including curb radii, driveway width, and truck turn design, will be designed consistent with City Design Standards to provide adequate mane uvering and queuing space for trucks/trailers on-site, as well as at the intersection of project driveways and adjacent streets. A copy of the project site plan with applicable truck-turning templates is provided as an attachment to this FEIR. As shown in the truck-turning templates, driveways, truck turning would be sufficient at a 45-foot radius and the Project is subject to the following condition:
Condition #115. Driveways - Final driveway geometrics may be modified in final engineering as approved by the Public Works Director / City Engineer. Driveways shall meet current standard radii on all existing and proposed commercial drive approaches used as access to the proposed development. The developer shall adhere to all City standards and regulations for access and ADA guidelines. As outlined in the following conditions, medians may be required to restrict turning movements for public safety purposes as determined by the Public Works Director / City Engineer.
As noted in discussion in page 4.13-19 of the Draft EIR, in compliance with Riverside County Fire Department (RCFD) access requirement, adequate emergency access would be provided by the Project. It should be noted that the roadways serving the project site are generally straight and flat. The project driveways have been designed so that adequate sight distance for drivers entering and exiting the site is maintained. Based on the items noted in this response and Section 4.13.5 of the Draft EIR, the Project would improve sight distance and safety conditions in the area and would not create hazards due to geometric design features.
A5-36 The City has noted that the Commenter could potentially provide additional comments on the environmental topics analyzed in the Draft EIR. The City has provided responses to the comments made in this letter submitted during the public review period pursuant to CEQA Guidelines Section 21091. Any additional comment letters submitted after the close of the public review period would be noted, but please note that responses to any late comment letters are not required under CEQA. Additionally, the City wi ll provide all future notices of the Project to the Commenter. No further response is warranted.
A5-37 This comment includes conclusionary statements and therefore, no further response is warranted.
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Comment Letter O1 - Radical Research, LLC
Mike McCarthy, Ph.D.
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Response to Comment Letter O1 - Radical Research, LLC
Mike McCarthy, Ph.D.
O1-1 Refer to the Response to Comment below O1-2.
O1-2 As stated in the response to the commenter, the link provided by the comment er showed this Project and the “Northern Gateway Commerce Center” project proposed west of Evans Road .
Both projects have different APNs and project applicants.
O1-3 This comment includes an introduction and general concern of the Project. No further response is warranted.
O1-4 Refer to Response to Comment O1-2 for explanation of the commenter’s concern on the Project name, applicant, and state clearing house number issue.
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Comment Letter O2 - SAFER, c/o Lozeau Drury, LLP
Kylah Staley
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Response to Comment Letter O2 - SAFER, c/o Lozeau Drury, LLP Kylah Staley
O2-1 This comment includes introductory statements and a brief summary of the Project’s description.
O2-2 The Commenter stated that the Draft EIR fails as an informational document and fails to impose all feasible mitigation measures to reduce the Project’s impact without stating any specific alleged deficiencies with the Draft EIR or providing any evidence that supplements these claims.
Therefore, no further response is warranted.
O2-3 The City has noted that the Commenter could potentially provide additional comments on the environmental topic analyzed in the Draft EIR. The City has provided responses to the comments made in this letter , submitted during the public review period , pursuant to CEQA Guidelines Section 21091. Any additional comment letters submitted after the close of the public review period would be noted, but please note that responses to any late comment letters are not required under CEQA.
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Comment Letter O3 - Golden State Environmental Justice Alliance, c/o Blum, Collins & Ho LLP Gary Ho
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Response to Comment Letter O3 - Golden State Environmental Justice Alliance, c/o Blum, Collins & Ho LLP
Gary Ho
O3-1 This comment includes introductory statements and a request to be added to the public interest list. As requested, the City has added the Commenter and Golden State Environmental Justice Alliance to the Project’s public interest list. No further response is warranted.
O3-2 This comment includes a summary of the Project’s description. No further response is warranted.
O3-3 A floor plan, detailed elevations, and conceptual grading plan are included in the Project’s Planning Application. The colored elevations in the EIR depict the conceptual building based on the detailed elevations submitted during the planning application p rocess. A floor plan and detailed elevations were not included in the Draft EIR, nor are they required to be included, since it is not necessary to fulfill the purpose of the Draft EIR to provide information of the Project’s environmental impacts caus ed during construction and operations of the Project. Draft EIR Section 2.0 , Project Description pages 2-3 and 2 -4 sets forth the Project’s height, floor area, parking spaces, and other detailed Project information, including a Project narrative. Lastly, a legend depicting the Project information is already provided in Draft EIR Exhibit 2 -5, Overall Site Plan so the legend was not reiterated in Exhibits 2-6 and 2-7.
O3-4 Refer to Section 3.0 , Errata to the Draft EIR of this FEIR that includes new Exhibit 4.15-1, Conceptual Utility Plan that illustrates the relocation of the underground flood channel (Line A-8) north of Building 2, and supplemental text that clearly explains the relocation of Line A -8.
Additionally, the relocation of Line A-8 would occur within the Project site and is therefore not an off-site utility improvement. Off-site improvements incorporated in to the analysis include improvements to Evans Road and Barnett Road. Therefore, all improvements, both on -site and off-site, have been incorporated into the air quality, GHG, and noise analysis for the Project.
O3-5 Pursuant to the comment, Exhibits 2-11 through 2-13, depicting the Project’s conceptual grading were created and have been provided in Section 3.0 of this FEIR. Additionally, the Draft EIR Section 2.0 already includes the Project’s projected earthwork (page 2-4).
O3-6 As discussed in Response to Comment O3 -4, information regarding the relocation of the underground flood channel (Line A -8). The corrected reference is provided in Section 3.0 of this FEIR. Additionally, refer to Response to Comment O3-3 for information regarding floor plans, site plan, and elevations. Lastly, the relocation of Line A -8 was factored in the earthwork quantities, as illustrated in Exhibit 2-11.
O3-7 The Commenter states that the list of off-site improvements does not provide sufficient details or state the extent the off-site improvements but doesn’t further explain why the off-site discussion is insufficient. The Commenter also incorrectly states that Evans Road from Ethanac Road to McLaughlin Road needs to be constructed in order to serve the Project. As discussed in Draft EIR Section 3.0 pages 2-3 and 2 -4, the Project’s proposed off -site improvements under Evans Road includes but is not limited to asphalt concrete pavement at the Project frontage. While the Project Northern Gateway Logistics Center
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site is described as 20.17 acres of land on page 2 -3 of the Draft EIR, modeling for the Project included 22.35 acres in order to cover all off -site improvements. As a result, all improvements, both on-site and off-site, have been incorporated in the air quality, GHG, and noise analysis of the Project. Further, refer to FEIR Exhibit O3-1: Truck Turning below that illustrates which portions of Evans Road would be improved to allow trucks to enter the site.
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O3-8 The incorrect reference of future private driveway as “A Street” in the Draft EIR Project Description has been revised, including revisions to Draft EIR Exhibit 2-7 (refer to Section 3.0 of this FEIR). The future driveway is located within the Project site boundaries and is not considered an off -site improvement. Additionally, the relocated underground flood channel , currently traversing the southern portion of the Project site, would be relocated within the Project site and is not considered an off-site improvement. Therefore, all improvements, both on-site and off-site, have been incorporated into the air quality, GHG, and noise analysis for the Project. Refer to Section 3.0 of this FEIR for further information regarding the underground flood channel and Responses to Comments O3-3 through O3-5.
O3-9 The commenter refers to an attachment from SWAPE. The comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. The comment has been noted and no further response is warranted.
O3-10 The commenter suggests the Draft EIR does not include relevant environmental justice issues , including cumulative impacts. The commenter cites to several statistics from CalEnviroScreen regarding ozone, PM 2.5, and traffic in the Project’s census tract . As discussed in Appendix B2 (Health Risk Assessment), CalEnviroScreen and the environmental justice factors are disclosed on pages 11 -12. CEQA does not require consideration of potential implications to environmental justice or socioeconomics as a specific resource, further, environmental justice is not listed within the “Environmental Factors Potentially Affected” in Appendix G, Environmental Checklist Form, to the CEQA Guidelines. Furthermore, as discussed within the Draft EIR, the proposed Project would not result in significant and unavoidable air quality impacts. Localized air quality impacts would be less than significant. Therefore, even if the topic of environmental justice was a required topic within the “Environmental Factors Potentially Affected” in Appendix G, Environmental Checklist Form, there would not be impacts to local residents as a result of approval of the proposed Project. This comment is noted and will be provided to the decision makers for review and consideration. Because the comment does not raise a substantive issue on the content of the Draft EIR, no further response is warranted.
O3-11 The comment provides demographic data. The comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. This comment is noted and will be provided to the decision makers for review and consideration.
O3-12 The commenter states that the census tract adjacent to the Project site is identified as a SB 535 Disadvantaged Community. SB 535 established initial requirements for minimum funding levels to “Disadvantaged Communities” (DACs). The legislation also gives California EPA the responsibility for identifying those communities, stating that the designation of disadvantaged communities must be based on “geographic, socioeconomic, public health, and environmental hazard criteria.” These funds must be used fo r programs that further reduce greenhouse gas emissions. SB 535 does not include project -specific requirements or prohibit developments in proximity to the designated communities. The comment does not raise a specific issue with the adequacy of the Draft E IR or raise any other CEQA issue. This comment is noted and will be provided to the decision makers for review and consideration.
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O3-13 The commenter states that CalEEMod is not listed as an approved Title 24 compliance energy modeling software. With specific regard to the use of CalEEMod for the purposes of modeling energy consumption, the Lead Agency has historically and successfully employed CalEEMod for this purpose. Further, the SCAQMD, the expert commenting agency for air quality considerations, endorses use of CalEEMod to provide a “uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions associated with both construction and operational from a variety of land use projects.” Through the use of CalEEMod, SCAQMD integrates air quality and energy impact analyses. 5 To ensure consistency of and accuracy of analyses in support of SCAQMD policies, the Lead Agency has determined that CalEEMod is appropriate for CEQA modeling of both air quality impacts and energy consumption.
The energy modeling protocols cited by the commenter (CBECC-Com, EnergyPro, and IES VE) are used for the performance approach (energy budget) method for demonstrating compliance with the Title 24 Energy Standards. The analysis in EIR Section 4.5 discloses the amount of energy that the Project would require and is not intended or required to demonstrate compliance for Title 24 energy standard performance.
Additionally, the EIR discloses the Project’s electricity consumption and transportation fuel consumption and determined that the Project’s energy consumption would not be inefficient or wasteful as the Project will be required to comply with the Title 24 Nonresidential Building Energy Efficiency Standards and CALGreen standards published by the CEC, which contain stringent mandatory standards for mechanical systems, lighting (indoor and outdoor), and appliances to minimize energy use. Therefore, the Project used the appropriate model to calculate and disclose the Project’s energy use, and also demonstrated that the Project would be required to comply with 2022 Title 24 Building Energy Efficiency and CALGreen Standards. The findings and conclusions of the EIR are not affected; no revisions are necessary.
O3-14 Refer to Response O3-13.
O3-15 The commenter reports that without mitigation, the Project’s GHG emissions would exceed the GHG threshold and that MM GHG-1 and MM GHG-2 are required to reduce emissions to less than significant. The comment does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issue. The comment has been noted and no further response is warranted.
O3-16 The commenter repeats the requirements of MM GHG-1 and does not raise a specific issue with the adequacy of the Draft EIR. The comment has been noted and no further response is warranted.
O3-17 The commenter repeats the requirements of MM GHG-2 and does not raise a specific issue with the adequacy of the Draft EIR. The comment has been noted and no further response is warranted.
5 https://www.aqmd.gov/caleemod/home
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O3-18 It is the commenters opinion that MM GHG-1 and MM GHG-2 will not result in GHG emission reductions. GHG emissions for the Project were modeled using CalEEMod 2022. CalEEMod is a statewide land use emissions computer model designed to quantify potential criteria pollutant and GHG emissions associated with both construction and operations from a variety of land use projects. The unmitigated emissions for the Project includes equipment and/or appliances typically associated with a warehouse project of this size. MM GHG-1 prohibits the installation of natural gas lines, as a result the Project would not generate any emissions associated with natural gas, hence Table 4.7-3 shows 0 (zero) emissions from “energy -natural gas” under the mitigated column. MM-GHG-2 requires all cargo handling equipment to be powered by electricity or other alternative fuels. As a result, emissions from diesel powered forklifts and yard trucks have been reduced from 350 MTCO2e to 79 MTCO2e per year under the mitigated column. MM GHG-1 and MM GHG-2 include clear performance standards and enforcement mechanisms (e.g., the Project Applicant must provide evidence to the City prior to issuance of building or occupancy permits) for the City to verify that the analyzed reductions will be achieved. The EIR’s Mitigation Monitoring and Reporting Program will ensure that these mitigation measures are implemented and enforced.
O3-19 The commenter notes that the Project is a speculative warehouse and the need for cargo handling equipment is unknown, however based on the size of the buildings it can be assumed that some form of cargo handling equipment will be needed . The estimated number of cargo handling equipment modeled for the Project was calculated based on the size of the warehouse using the formulas identified in the SCAQMD High Cube Warehouse Truck Trip Study White Paper Summary of Business Survey Results . Using this metho dology, the analysis conservatively assumed the Project would employ eight diesel forklifts and one diesel yard truck. However, regardless of the number, MM GHG-2 would require all cargo handling equipment used on site to be electric or use alternative fuels, resulting in reduced emissions. Although the proposed warehouses are speculative, any future occupant would be required to use zero emission cargo handling equipment, if such equipment is necessary. This measure is tie d to the issuance of occupancy permits and would be verified by the City. Future tenants would not be permitted to occupy the Project site unless compliance with the mitigation can be demonstrated.
O3-20 Refer to Response to Comments O3-18 and O3-19. The comment incorrectly concludes that the mitigation cannot be assured. As described above, the mitigation measures have clear performance standards and are tied to issuance of City building and occupancy permits.
Therefore, the City has a mechanism to verify the measures are incorporated.
O3-21 After review of the Perris Valley ALUCP Compatibility Map, correct reference to the Project site being within the Perris Valley Airport ALUCP Compatibility Zone E has been made in Section 3.0 of this FEIR. Please note that this correction does not change the Draft EIR’s significance conclusion of “less than significant impact” concerning the Project resulting in a safety hazard or excessive noise for people residing or working in the Project area.
O3-22 Information regarding ALCU information for Perris Valley ALUCP has been added in Section 3.0 of this FEIR. However, the Commenter incorrectly references that the EIR does not provide any Northern Gateway Logistics Center
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analysis or information regarding regulations and requirements within influence area Zone E of the Perris Valley or March Air Reserve Base (MARB) ALUCPs. As stated in Draft EIR Section 4.8, Hazards and Hazardous Materials page 4.8-27, the Project contains a condition of approval (COA HAZ-1) in consistency with MARB and Perris Valley ALUCP requirements. Furthermore, since the Project is within Zone E of the Perris Valley and MARB ALUCP, and does not propose any legislative action (e.g., general plan amendmen t or zone change), review by Riverside County ALUC is not required, and can be conducted by the City. Therefore, the sentence from the Draft EIR that states, “All new development would be in accordance with the Compatibility Zone E and all state, county, and local goals, policies, and regulations” indicates that the Project would be developed in accordance with relevant City regulations and design guidelines to minimize safety hazards and noise impacts during the Project’s construction and operational phase s Therefore, no further analysis is required as impacts would remain less than significant with addition of the Perris Valley ALUCP discussion.
O3-23 Exhibit LU -4 also states in the Notes section that citywide build -out levels historically do not achieve the maximum allowable density/intensity on every parcel, and on average are lower than allowed by the Menifee GP. However, the build -out estimates in t he Menifee GP assume variations in the build -out intensity. Therefore, if based on the average, as it states, in some instances the FAR will be higher than the 0.40 FAR, which offsets projects that might be over the FAR. In addition, the GP allows fo r a maximum of 1.0 FAR. Additionally, pursuant to Menifee GP FEIR, land assumptions were not site specific, and the EDC land use designation was generally envisioned for a mixture of residential, commercial, office, industrial, entertainment, educational, recreational uses, and/or other uses. Accordingly, the Project is not inconsistent with the GP buildout scenario, RTP/SCS and AQMP.
O3-24 The Commenter states that the Project, due to errors in modeling and modeling without supporting evidence, is not consistent with SCAG’s Connect SoCal Goals 5 through 7. The air quality and greenhouse gas emissions have been modeled in CalEEMod using the approved methodology identified in the CalEEmod User Handbook . The commenter suggests there are errors in the modeling but does not identify them. The commenter also suggests that the Project is inconsistent with RTP/SCS Goals 5, 6, and 7 but provides no evidence. All air quality and greenhouse gas impacts identified in the Draft EIR have been reduced to less than significant with mitigation. Therefore, the Draft EIR presents substantial evidence that the Project is consistent with RTP/SCS Goals 5,6, and 7. The Draft EIR has determined that Project is consistent with all applicable RTP/SCS goals as shown in Table 4.7-4 of the Draft EIR.
O3-25 The City respectfully disagrees that the Draft EIR does not provide a consistency analysis with applicable goals, policies, and regulations for the Project. Goal S-7 and Policy S-7.1 refer to climate change and GHG emissions. Consistent with Goal S-7 and Policy S-7.1 a GHG Emissions Assessment was prepared to identify and inform the City of GHG impacts. Policy EJ-3.6 refers to continuing to collaborate with SCAQMD, CARB, SCAG, and WRCOG that would be conducted by the City, and therefore not Project-specific. The commenter does not state how the Draft EIR is not consistent with Policy C -5.3. The Project would comply with Goal OSC -10 since the Project includes Northern Gateway Logistics Center
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implementation of MMs GHG -1 and GHG-2 and compliance with local, state, or federal regulations or laws to reduce mitigation GHG emissions to less than significant levels. Pursuant to Policy OSC -10.1, the Draft EIR page 4.7 -256 includes a discussion regarding the Project’s consistency with the 2022 CARB Scoping Plan. Policies OCS-10.2 through OCS-10.3 would also be conducted by the City, and not by the Project applicant.
The commenter suggests that the Draft EIR does not show consistency with the City of Menifee General Plan. However, all applicable goals and policies in the General Plan are discussed on pages 4.7-23 and 4.7-24 of the Draft EIR. The commenter then lists goals and policies from the General Plan that are either not applicable or have already been discussed in the Draft EIR.
1. Goal S -7: This goal is relevant to city planning and is beyond the scope of the Project.
Therefore, this goal is not applicable to the Project. However, development of the Project would not conflict with this Goal because all impacts associated with air quality and GHG, including those associated with health risk and sensitive receptors, have been reduced to less than significant with mitigation.
2. Policy S-7.1: This is a policy relevant to city planning and is beyond the scope of the Project.
Therefore, this policy is not applicable to the Project. However, the preparation of the Draft EIR provides the environmental analysis the City seeks to achieve by implementing Policy S-7.1.
3. Policy EJ-3.6: This is a policy relevant to city planning and is beyond the scope of the Project.
Therefore, this policy is not applicable to the Project. However, development of the Project would not conflict with this policy.
4. Policy C-5.3: This is a policy relevant to city planning and is beyond the scope of the Project.
Therefore, this policy is not applicable to the Project. However, the Project will comply with all applicable laws and regulations, including those that will reduce/eliminate the negative environmental impacts of goods movement.
5. Goal OSC-10: This goal is relevant to city planning and is beyond the scope of the Project.
Therefore, this goal is not applicable to the Project. However, development of the Project would not conflict with this goal.
6. Policy OSC-10.1: Consistent, refer to page 4.7-23 of the Draft EIR.
7. Policy OSC-10.2: Consistent, refer to page 4.7-24 of the Draft EIR.
8. Policy OSC-10.3: Consistent, refer to page 4.7-24 of the Draft EIR.
9. Policy OSC-10.4: Consistent, refer to page 4.7-24 of the Draft EIR.
10. Policy C-5.3: Refer to number 4 of this list.
O3-26 The commenter summarize s an excerpt from the Project Traffic Impact Analysis that recommended improvements for various deficient intersections, but the comment does not raise Northern Gateway Logistics Center
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any deficiencies with the analysis or conclusions. Comment has been noted, and no further response is warranted.
O3-27 Under CEQA Guidelines Section 15064.3, LOS associated with automobile delay no longer constitutes a significant environmental impact , and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning these proposed improvements was provided for informational purposes only for the City’s use in evaluating the Project and considering conditions of approval outside of CEQA’s framework. The implementation of these improvements would be based on direct discussion between City staff and the Applicant and would be imposed via the Conditions of Approval process , not through CEQA. Further, the Project’s land use impacts are based in part upon determining compliance with the City’s General Plan. The Project Applicant is proposing to improve roadways along the Project’s frontage per the City of Menifee General Pla n. All roadway improvements associated with the Project would be consistent with the City of Menifee General Plan Circulation Element.
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 offsite engineering for the Project.
O3-28 See Response to Comment O3-26.
O3-29 See Response to Comment O3-27.
O3-30 Based on the State Office of Planning and Research (OPR) Technical Advisory (page 4), “’vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project,” where automobile refers to passenger vehicles, specifically cars and light trucks. VMT generated from trucks are not considered in the VMT impact assessment based on the OPR Technical Advisory. The proposed facility does not anticipate delivery van trips. However, if the Project were to implement deliver y vans, it would likely result in a net decrease in regional VMT, as these projects are strategically located near delivery points, thereby reducing trip lengths by providing additional regional warehouses.
O3-31 The Project’s land use impacts are based in part upon determining compliance with the City’s General Plan. The Project Applicant is proposing to improve roadways along the Project’s frontage per the City of Menifee General Plan. All roadway improvements as sociated with the Project, including Project driveways and emergency access, would be consistent with the City of Menifee General Plan Circulation Element and the City of Menifee Road Improvement Standards and Specifications (Design Standards, 2019 ). Site access, including curb radii, driveway width, and truck turn design, will be designed consistent with City Design Standards to provide adequate maneuvering and queuing space for trucks/trailers on-site, as well as at the intersection of project driveways and adjacent streets. A copy of the project site plan with applicable truck -turning templates is provided as an attachment to this FEIR. As shown in the truck -turning templates, driveways, truck turning would be sufficient at a 45 -foot radius and the Project is subject to the following condition:
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Condition #115. Driveways - Final driveway geometrics may be modified in final engineering as approved by the Public Works Director / City Engineer. Driveways shall meet current standard radii on all existing and proposed commercial drive approaches used as access to the proposed development. The developer shall adhere to all City standards and regulations for access and ADA guidelines. As outlined in the following conditions, medians may be required to restrict turning movements for public safety purposes as determined by the Public Works Director / City Engineer.
As noted in discussion in page 4.13-19 of the Draft EIR, in compliance with Riverside County Fire Department (RCFD) access requirement, adequate emergency access would be provided by the Project. It should be noted that the roadways serving the project site are generally straight and flat. The project driveways have been designed so that adequate sight distance for drivers entering and exiting the site is maintained. Based on the items noted in this response and page 4.13.19 of the Draft EIR, the Project wo uld improve sight distance and safety conditions in the area and would not create hazards due to geometric design features.
O3-32 See Response to Comment O3-31. No further response is warranted.
O3-33 All roadway improvements associated with the Project, including Project driveways and emergency access, would be consistent with the City of Menifee General Plan Circulation Element and the City of Menifee Road Improvement Standards and Specifications (Design Standards, 2019) As noted in the discussion on page 4.13-19 of the Draft EIR, in compliance with Riverside County Fire Department (RCFD) access requirement, adequate emergency access would be provided by the Project. It should be noted that the roadways serving the project site are generally straight and flat. The project driveways have been designed so that adequate sight distance for drivers entering and exiting the site is maintained. Based on the items noted in this response and Section 4.13.19 of the Draft EIR, the Project would improve sight distance and safety conditions in the area and would not create hazards due to geometric design features.
O3-34 The roadways serving the Project site are generally straight and flat, with no visual obstructions.
Therefore, there is no evidence that driver visibility will be inadequate and the commenter has not provided evidence otherwise. Accordingly, no further analysis of sight distance is warranted.
O3-35 Refer to Response to Comment O3-13 above.
O3-36 Refer to Response to Comment O3-23 above.
O3-37 The City respectfully disagrees that the Draft EIR does not include a meaningful discussion of potential growth inducing impacts. Section 15126 of the CEQA Guidelines requires that an EIR address the “growth inducing” effects of the Project. Pursuant to § 15126.2(d) of the Guidelines, a project would be considered to have a growth-inducing effect if it would:
• Directly or indirectly foster economic or population growth, or the construction of additional housing;
• Remove obstacles to population growth;
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• Tax existing community services or facilities, requiring the construction of new facilities that could cause significant environmental effects; or
• Encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.
As discussed in detail in Draft EIR Chapter 5, Other CEQA Consideration s, the Project would not induce employment growth projected in SCAG’s Connect SoCal . Utilizing SCAGs Employment Density Study 1 employee per square feet per employee (581 for warehousing; 481 for Office) in Riverside County , the Project could potentially create approximately 6 92 permanent job opportunities. This would represent 4.5 percent of employment growth. The Project’s proposed uses are consistent with the E conomic Development Corr idor – Northern Gateway land use designation which accounted for warehouse development. For the reasons discussed in the Draft EIR Section 5.0 , the Project’s employee base is expected to come from within the city or immediately surrounding region and would not require new housing; would have no effect on stimulating population growth; and provides sufficient infrastructure to meet its needs concurrent with development. Lastly, data from the Joint Center for Housing Studies of Harvard University found that approximately 13 percent of Americans move ea ch year, and of those 21 percent move for job-related reasons. 13 percent of 692 is 90 people and 21 percent of 90 people is approximately 19 people. Therefore, the Project could potentially generate approximately 19 new residents in the City Menifee which represents approximately 0.07 percent of the City’s population growth forecast of 129,800 people by 2045.
O3-38 This is a direct quote from Draft EIR Section 7.4 -1. No further comments were made here and therefore, no further response is warranted.
O3-39 The Commenter provides no substantial evidence of a significant environmental impact. The Project would not result in cumulative citywide or countywide population and housing impacts.
The term local area encompasses the City, unincorporated County area, and surrounding communities, such as Perris and Murrieta due to a high unemployment rate, currently at 5.7 percent for the City of Menifee, and 5.2 percent for the County of Riverside. Furthermore, the Project’s potential employment opportunities would provide much needed employment within the City and support the City’s pursuit in a more balanced jobs -housing ratio. The Project VMT Analysis was conducted consistent with the City of Menifee Traffic Impact Analysis Guidelines for Vehicles Miles Traveled (VMT Guidelines, January 2022). The Project VMT Analysis concluded that the Project’s Employment -Based VMT does not exceed the City’s VMT threshold and that the project would have a less-than=significant VMT impact.
O3-40 The Comment provides no supporting evidence of how a qualified or interested workforce versus an unqualified workforce would impact VMT, and therefore a calculation of longer worker trips is not warranted. Additionally, the commenter does not provide any supporting evidence that an unemployment rate below 5 percent is considered full employment.
O3-41 Refer to Section 3.0 of this FEIR for information regarding the Project’s potential employment growth.
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O3-42 Refer to Response to Comment O3 -41 above. Additionally, the comment mistakenly references this document as a mitigated negative declaration, and states that an EIR must prepared. This comment is not applicable to this project.
O3-43 The Commenter fails to specify why the sentence provided by the commenter needs to be deleted. Draft EIR Sections 4.9, Hydrology and Water Quality and 4.15, Utilities and Service Systems go in depth about the potential utility infrastructure that would be needed to service the Project. As discussed in Response to Comment O3-8, the reference to “Street A” has been corrected. Additionally refer to Section 3.0 of the FEIR for a conceptual utility figure that depicts proposed on- and off -site utility impr ovements. Lastly, the commenter incorrectly states that “50% of the land within the vicinity of the project site is vacant, meaning that the project site is not located in a developed area of the City ” without pointing to this reference in the Draft EIR.
Draft EIR Section 7.0 states multiple times that the Project is located in a partially developed portion of the City which is accurate Lastly, the Project is located between Evans Road which is a dirt road that can currently be used to access the Project site, and Barnett Road that is currently developed.
O3-44 Refer to Response to Comment O3-37.
O3-45 This comment includes conclusionary statements, and therefore no further response is warranted.
O3-46 This comment is noted for the record and will be provided to the decision makers for review and consideration. However, response s to comments for further information regarding the commenter’s comments regarding AQ, GHG, Hazards and Hazardous Materials , and transportation are provided in Response to Comments O3-4, O3-7 through O3-20, O3-24 through O3-25, O3-26 through O3-34, and O3-39. Refer to those responses for more further details.
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Comment Letter T1 - Agua Caliente Band of Cahuilla Indians Luz Salazar, Cultural Resources Analyst
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Response to Comment Letter T1 - Agua Caliente Band of Cahuilla Indians Luz Salazar, Cultural Resources Analyst
T1-1 This comment includes introductory and conclusion statements and refers the City to review comments made on the Draft EIR. Please review the following respons es to the comments for further discussion.
T1-2 The comment stating that a “Tribal monitor needs to be present during off -site improvements” has been noted. COA-CUL-4 and COA-CUL-5 already require that a tribal monitor be present “on- site” or in person during all ground -disturbing activities ground disturbing activities within the Project site, and off-site improvement locations.
T1-3 The correct reference to spelling of “Pechanga” has been noted and corrected in Section 3.0, Errata to the Draft EIR of this FEIR.
TI-4 The Commenter is incorrectly referencing this COA by stating that all cultural resources are significant. The term “unique archeological resource" is defined in subdivision (g) of CEQA Guidelines Section 21083.2 as an archaeological artifact, object, or si te about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
(1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. (2) Has a special and particular quality such as being the oldest of its type or the best available example of its type.
(3) Is directly associated with a scientifically recognized important prehistoric or historic event or person.
Therefore, this COA will be implemented to specifically address impacts to unique archeological resources defined by CEQA, and is not intended to devalue the significance of nonunique cultural resources.
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Comment Letter P1 - Breanna Harwood
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Response to Comment Letter P1 - Breanna Harwood
P1-1 This comment does not raise any substantive issues regarding the adequacy of the Draft EIR. This comment is noted for the record and no further response is needed.
P1-2 The Commenter’s concerns regarding the Project’s impacts on aesthetic, air quality, health risk, biological resources, hazards materials, traffic congestion and noise pollution have been noted for the record, but this comment did not provide substantive evidence regarding the inadequacy of the aforementioned environmental topics analyses discussed in the Draft EIR. Additionally, home property values are not considered a CEQA issue, but this has also been noted for the record.
An air quality assessment and health risk assessment were both prepared to analyze health impacts associated with emissions from the Project.
• Construction Emissions. As shown in Table 4.2 -8: Construction Related Emissions and Table 4.2-11: Localized Significance of Construction Emissions, all emissions generated during construction of the Project are below SCAQMD’s construction thresholds. • Operational Emissions. As shown in Table 4.2-9: Unmitigated Operational Emissions and Table 4.2 -12: Localized Significance of Operational Emissions of the Draft EIR, all operational emissions are below SCAQMD’s operational thresholds. • Health Risk. With the incorporation of MM GHG -2, which requires all cargo handling equipment operating onsite to be electric or powered by alternative fuels, the cancer risk and chronic non-carcinogenic health impacts will be reduced below SCAQMD threshold levels as shown in Tables 4.2-13: Carcinogenic Risk Assessment and Table 4.2-14: Chronic Hazard Assessment of the Draft EIR.
The Draft EIR also analyzed the impacts of noise on the surrounding sensitive receptors. • Construction Noise. As shown in Table 4.11 -8: Project Construction Noise Levels of the Draft EIR, construction noise at the nearest sensitive receptor would not exceed the applicable noise threshold.
• Operational Noise. Operational noise levels, both daytime and nighttime, are below the applicable City noise standard as shown in Table 4.11-9: Project Operational Noise Levels of the Draft EIR. The operational noise analysis included noise generated from mechanical equipment, on-site traffic, and parking lot noise.
• Offsite Traffic Noise. Roadway noise was also analyzed and shown in Table 4.11 -10:
Project Traffic Noise Levels of the Draft EIR. As shown in Table 4.11-10, traffic noise levels would be less than significant.
The Draft EIR also analyzed impacts related to Aesthetics.
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• Construction and Operations. Construction and operation of the Project would result in a less than significant impact concerning scenic vistas, and light and glare. No impacts from a CEQA perspective would occur concerning the confliction with applicable zoning and other regulations governing scenic quality and scenic resources within a state scenic highway.
The Draft EIR also analyzed impacts related to the burrowing owl species. • Construction. As discussed further in Draft EIR Section 4.3, Biological Resources, despite a systemic search of the Project site, no burrowing owls or sign (pellets, feathers, castings, or whitewash) were observed on or within 500 feet, where accessible, of the Project site during the field investigation. However, based on a review of CDFW’s CNDDB, 22 burrowing owl observations have been recorded within five miles of the Project site in previous years. Therefore, the Project would implement MM BIO-2 which would require the Project Applicant would retain a qualified biologist to conduct a 30 -day preconstruction survey for burrowing owl. With implementation of MM BIO -2, impacts would be reduced to less than significant levels. (Draft EIR pages 4.3-14 through 4.3-16) The Draft EIR also analyzed impacts related to hazards and hazardous materials. • Construction and Operation. As discussed in Draft EIR Section 4.8, Hazards and Hazardous Materials, the Project would implement MM HAZ -1 to e nsure proper handling of contaminated soils and substances which may be encountered during construction activities. Additionally, compliance with applicable laws and regulations concerning hazardous materials would ensure that all potentially hazardous mat erials are used and handled in an appropriate manner and would minimize the potential for safety impacts during both construction and operations.
Concerning traffic congestion, Under CEQA Guidelines Section 15064.3, automobile delay no longer is considered an environmental impact, and therefore this comment does not raise concerns within the scope of CEQA. The analysis included in the Draft EIR concerning LOS was provided for inf ormational purposes only for the City’s use in evaluating the Project and considering conditions of approval outside of CEQA’s framework.
P1-3 The Commenter’s opposition to the Project has been noted for the record. Per the Commenter’s request, the City will send the Commenter a public notice during distribution, prior to certification of this Final EIR.
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Comment Letter P2 – Jose Marquez
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Response to Comment Letter P2 – Jose Marquez
P2-1 The Economic Development Corridor designation including the subarea Economic Development Corridor – Northern Gateway that the Project is located in was approved as part of the adopted Menifee GP. Pursuant to the Menifee Development Code, the Economic Development Corridor – Northern Gateway area is envisioned as a business park area with more intensive industrial uses (less office) and a buffer and transition between the commercial uses in Perris to the north and the residential uses in Menifee, south of McLaughlin Road . Therefore, the Project’s proposed industrial uses are consistent with current land use and zoning designations. The Draft EIR prepared for this Project include s an analysis of the Project’s impacts related to aesthetics, air quality, health risk assessment, biological resources, noise, and transportation. No significant unavoidable impacts were identified, but the City advises that the commenter read through the Draft EIR for further information.
P2-1 The Commenter’s opposition to the Project has been noted for the record. Per the Commenter’s request, the City will send the Commenter a public notice during distribution, prior to certification of this Final EIR.
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Section 3.0 Errata to the Draft EIR
3.1 INTRODUCTION TO THE ERRATA
The Draft EIR for the Northern Logistics Center Project dated May 2024 , is hereby incorporated by reference as part of the Final EIR. Changes to the Draft EIR are further detailed below.
The changes to the Draft EIR do not affect the overall conclusions of the environmental document, and instead represent changes to the Draft EIR that provide clarification, amplification and/or insignificant modifications, as needed as a result of public comments on the Draft EIR, or due to additional information received during the public review period. These clarifications and corrections do not warrant Draft EIR recirculation pursuant to CEQA Guidelines Section 15088.5.
None of the changes or information provided in the comments reflect 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 Draft EIR.
Changes to the Draft EIR are listed by Section, page, paragraph, etc. to best guide the reader to the revision. Changes are identified as follows:
• Deletions are indicated by strikeout text.
• Additions are indicated by underlined text.
3.2 CHANGES TO THE DRAFT EIR
Associated facilities and improvements of the Project site includes loading dock doors (15 for Building 1; 37 for Building 2), on site landscaping, and related on -site utility improvements and off-site improvements, including the relocation of an underground flood channel approximately 200 feet northerly along the same alignment to avoid conflicts with the proposed utility improvement; refer to Section 4.9, Hydrology and Water Quality.
The proposed buildings would not include cold storage.
The Project is expected to use tractors, graders, dozers, and scrapers during the grading construction phase; refer to Exhibit 2-11, Conceptual Grading Plan – Building 1, Exhibit 2-12, Conceptual Grading Plan – Building 2 Part 1 , and Exhibit 2 -13, Conceptual Grading Plan – Building 2 Part 2 . As shown in Exhibits 2-11 through 2-13, Tthe Project would require approximately 34,865 Cubic Yards (CYs) of soil cut and 33,346 CYs soil fill resulting in approximately 1,519 CYs of export to balance the site.
New Pages 2-15 through 2-17
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Exhibit 2-11, Conceptual Grading Plan – Building 1
Exhibit 2-12, Conceptual Grading Plan – Building 2 Part 1 Exhibit 2-13, Conceptual Grading Plan – Building 2 Part 2
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• Storm System: 18” and 24” Reinforced Concrete Pipes (RCP) storm system in A Streetthe future driveway. Installation of 7’ catch basin and five manholes in A Streetthe future driveway.
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It should be noted that the Project does not include cold storage.
The City conducted tribal consultation in compliance with Assembly Bill (AB) 52 and has received responses from the Rincon Band of Luiseño Indians and PachangaPechanga Band of Indians.
The entirety of Project site is located within Compatibility Zone E of the March Air Reserve Base47 MARB airport land use compatibility plan (ALUCP), but a small portion of the northwestern Project site is also located within Compatibility Zone E of the Perris Valley Airport AL UCP.47 Please note that the portion of the Project site within Perris Valley Airport ALUCP encompasses the proposed northwest driveway only.
All new development would be in accordance with the Compatibility Zone E and all state, county, and local goals, policies, and regulations. Furthermore, the Project does not require review by ALUC because the City is consistent withSince the Project is within compatibility zones E of the Perris Valley and MARB airport land use compatibility plan ( ALUCPs), but does not propose any legislative action (e.g., general plan amendment or zone change), review by R CALUC is not required and can be conducted by the Ci ty.
As discussed throughout this EIR, the Project would be developed in accordance with all state, regional, and local regulations and design standards to minimize noise impacts during the Project’s construction and operational phases; refer to Section 4.11: Noise for further information. Additionally , the Project would To be consistent with the requirements of Zone E, by complying with COA HAZ-1 has been included,. and tTherefore, the Project’s potential to result in a safety hazard or excessive noise for people residing or working in the Project area would be less than significant. Project would not result in a significant impact.
MDP facility Line A -8 (Line A -8) traverses northly through the easterly through the northerly portion of the proposed Building 2 location, ultimately connecting to Line A. As concluded in the Preliminary Hydrology Calculations, the MDP 100-year flow rate in Line A -8 on the MDP map 292 cfs, although the storm drain plan shows 283 cfs.
To collect surface water and runoff from the impervious areas, an extensive drainage plan would be in place which includes ribbon gutters, subsurface storm drains, curb cuts, u-channels, and detention basins.
The basins are designed to weaken the flow of post-development runoff to pre-development conditions, and have been designed to treat runoff for pollutants, pursuant to SW RCB regulations. Additionally, the existing Line A -8 would be removed and relocated approximately 200 feet northerly alon g the same alignment to avoid conflicts the proposed drainage improvements. The relocated storm drain would maintain the same size (10 feet-width by 6 feet-height) and downstream hydraulic controls as the existing drain. The relocated Line A -8 would continue to discharge into Romoland MDP Line A. Refer to Northern Gateway Logistics Center
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Exhibit 4.9-2: Conceptual Storm Drain Plan for that illustrates the Project’s proposed drainage improvements and relocated Line A-8.
As shown in Exhibit 4.15-1, Conceptual Utility Plan, Eexisting utilities would be extended and upgraded as needed during construction of Project to serve the anticipated demands and to accommodate operation of the warehouses. All required improvements and extensions to existing electrical, natural gas, or telecommunications utilities would occur within the existing roadway rights -of-way adjacent to the Project site, and off-site at including Evans Road, Barnett Roads, and McLaughlin Road. All areas adjacent to the existing roadways are also disturbed and are within the overall footprint of the Project. All impacts are discussed and disclosed as part of this Draft EIR, within the various sections of this document.
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Refer to Sections 4.1 through 4.15 of this EIR. As discussed above, the Project No project-specific or cumulatively significant impacts were discovered during the analysis of the Project. Mitigation measures would be implemented to ensure that all environmental impacts are reduced to less than significant levels. As such, the Project would not result in activities that could significantly affect the environment, either individually or cumulatively.
Construction of the Project would generate temporary employment opportunities, including short-term design, engineering, and construction jobs. Construction related jobs would not result in a significant population increase because those jobs are temporary in nature and are expected to be filled by persons within the local area. This expectation is based on the latest unemployment data for Riverside County 6 (4.5 percent) and the City of Menifee 7 (4.2 percent). Utilizing SCAGs Employment Density Study of 1 employee per square feet per employee (581 for warehousing; 481 for Office) in Riverside County, the Project could potentially create approximately 692 permanent job opportunities once the Project is developed. This would represent 4.5 percent of employment growth. However, employment growth does not directly translate into population growth.
Data from the Joint Center for Housing Studies of Harvard University found that approximately 13 percent of Americans move each year, and of those 21 percent move for job-related reasons. 13 percent of 692 is 90 people and 21 percent of 90 people is 1 9 people. Therefore, the Project could potentially generate approximately 19 new residents in the City Menifee which represents approximately 0.07 percent and
0.003 percent of the City’s and County’s population growth forecast of 129,800 people , and 2,927,000 people, respectfully, by 2045.8Additionally, theThe SCAG’s Connect SoCal notes that it is anticipated that the population would in Riverside County would grow to 2,927,000 .8 Similarly, the Menifee GP Draft EIR states that the population is forecast to grow to 119,332 by 20359.
As such, population growth in the City is anticipated with future development and such growth has been considered in the City’s General Plan. Furthermore, the Project site is served by existing public roadways, and utility infrastructure would be installed beneath the public rights -of-way that abut the Project site.
For these reasons, Project constructiondevelopment of the Project would not directly or indirectly induce substantial, unplanned population growth in the City. Therefore, the Project is anticipated to have a less than significant impact on unplanned population growth.