Cities Index.
Agenda packet, second session

Menifee City Council
January 21, 2026

Document
Agenda packet, second session
Meeting
January 21, 2026
Body
Menifee City Council
Pages
16
Original file
129.2 MB
Text extracted from the city's file for reading and search. Open the original on cityofmenifee.primegov.com. That file is the official record.

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 48

Menifee Mayor and City Council
January 21, 2026
Page
270 of 1208

PARCEL MAP OR TRACT MAP NO. DATE:

IP:

IMPROVEMENTS
Landscape $ 391,609.09 $ $
Total 391,609.09 $ $
Warranty Retention (10%) $
Construction items and their quantities, as shown on the attached sheets, are accurate for the improvements required to construct the above project and the mathmatical extensions, using City's unit costs, are accurate for determining bonding costs
Above amounts do include additional 20% for bonding prior to having signed plans (Ordinance460, Section 10.3E).
10/2/2025
Signature Date
David Neault 2884 06/30=2006
Name Typed or printed RLA# Exp. Date
Landscape Architect's Stamp

1. Quantities are to be taken from the Improvement Plans. Unit cost are to be as provided on "City of Menifee Improvement Requirement Worksheet."

2. Show Performance Bond Amounts to the nearest $500.00.

3. For Construction items not covered by "The City of Menifee Improvement Requirements Worksheet", Landscape Architect is to provide his opinion of construction cost and use that cost. If City of Menifee Unit Costs are determined to be too low, in the opinion of the Landscape Architect, the higher costs as provided by the Landscape Architect should be used.
39,200.00

LANDSCAPE ACHITECT'S CALCULATION OF IMPROVEMENT BONDING COSTS *** PLEASE READ INSTRUCTIONS BELOW ***
Construction Costs) Construction Costs)
392,000.00 392,000.00
392,000.00 392,000.00

FAITHFUL PERFORMANCE MATERIAL & LABOR

SECURITY SECURITY
(100% of Estimated (100% of Estimated
25-010L

CITY OF MENIFEE ENGINEERING DEPARTMENT

CONSTRUCTION COST WORKSHEET
Tr. 31229-2 10/3/2025
Approved for bonding
A. Backlund
10-3-25

11. Approved Cost Estimate:

Bonds for Tract #31229-2 For the Construction of Landscape Improvements IP25-010L, executed October 14th, 2025. Bond No. 30258793 by The Continental Insurance Company, 151 N.

Franklin Street, Chicago, IL 60606.

Faithful Performance and Materials & Labor Bond $392,000.

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 49

Menifee Mayor and City Council
January 21, 2026
Page
271 of 1208

Project: Nautical Cove - CFD Streetcape POC 2
IP25-010L
Client: KB Home
36310 Inland Valley Rd
Wildomar, CA 92595
Qty Size Unit Cost Total
2,124 l.f. 6.00$ 12,744.00$
10,558 s.f. 8.00$ 84,464.00$
985 l.f. 40.00$ 39,400.00$
136,608.00$
Qty Size Unit Cost Total
23,716 s.f. 0.16$ 3,794.56$
23,716 s.f. 1.30$ 30,830.80$
39 ea. 250.00$ 9,750.00$
555 ea. 20.00$ 11,100.00$
1,940 ea. 10.00$ 19,400.00$
-$
74,875.36$
Qty Size Unit Cost Total
23,716 s.f. 3.00$ 71,148.00$
1 ea. 17,800.00$ 17,080.00$
1 ea. 12,500.00$ 12,500.00$
100,728.00$
Prepared by:
312,211.36$
46,831.70$
24,976.91$
7,589.12$
391,609.09$
October 2, 2025

CONSTRUCTION
Description
Construction Subtotal
Concrete Mow Curb
Vinyl Rail Fence
Description

PLANTING
Rock Mulch
Landscape Construction Cost Estimate
D.G. Paving w/ Mow Curb
Calsense Controller
Irrigation Subtotal
Meters - Electical & Water
Soil Prep. / Fine Grading
Trees - 24" Box w/ Root Barrier
CFD Point-to-Point Drip Irrigation

IRRIGATION
Botanical Name
Planting Subtotal
Shrub - 5 Gallon
Groundcover - 1 Gallon
365 Day Maintenance
NOTE: All Unit Costs
include material, labor
profit and overhead
for the Landscape
Subcontractor.

Contingency 15%

TOTAL ESTIMATE
Base Estimate
Construction Inspection 8%

Page 1 of 1 ends

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 50

Menifee Mayor and City Council
January 21, 2026
Page
272 of 1208

PARCEL MAP OR TRACT MAP NO. TR 31229-BRIGGS ROAD DATE:

IP:

IMPROVEMENTS
Street/Drainage $ 682,120.96 $ $
*Flood Control $ 0.00 $ $
Dom Wtr EMWD $ 0.00 $ $
Rec Wtr EMWD $ 0.00 $ $
Sewer EMWD $ 0.00 $ $
Total 682,120.96 $ $
Warranty Retention (10%) $
Construction items and their quantities, as shown on the attached sheets, are accurate for the improvements required to construct the above project and the mathmatical extensions, using City's unit costs, are accurate for determining bonding costs
Above amounts do G do not G include additional 20% for recordation prior to having signed plans (Ordinance460, Section 10.3E).

Signature Date
Joseph L. Castanda 59835 12/31/25
Name Typed or printed RCE# Exp. Date
Civil Engineer's Stamp
*Flood Control Construction Cost Estimate to be provided by Flood Control District. Provide a copy of Flood Control District letter stating cost estmate.

1. Quantities are to be taken from the Improvement Plans. Unit cost are to be as provided on "City of Menifee Improvement Requirement Worksheet."

2. Show Performance Bond Amounts to the nearest $500.00. Material and Labor Bond Amounts are 50% of Performance Bond Amountss. **100% for Flood Control items.

3. For Construction items not covered by "The City of Menifee Improvement Requirements Worksheet", Design Engineer is to provide his opinion of construction cost and use that cost. If City of Menifee Unit Costs are determined to be too low, in the opinion of the design engineer, the higher costs as provided by the Design Engineer should be used.

682,000.00 682,000.00
68,200.00

DESIGN ENGINEER'S CALCULATION OF IMPROVEMENT BONDING COSTS *** PLEASE READ INSTRUCTIONS BELOW ***
September 4, 2025

0.00 0.00

0.00 0.00

0.00 0.00
Construction Costs) Construction Costs)
682,000.00 682,000.00

0.00 0.00

FAITHFUL PERFORMANCE MATERIAL & LABOR

SECURITY SECURITY
(100% of Estimated (**100% of Estimated
IP25-007 SD

CITY OF MENIFEE ENGINEERING DEPARTMENT

CONSTRUCTION COST WORKSHEET
September 4, 2025
Approved for bonding
A. Backlund
10-2-25

12. Approved Cost Estimate:

Bonds for Tract #31229-2 For the Construction of Offsite Stormdrain Improvements IP25-007SD, executed October 14th, 2025. Bond No. 30258792 by The Continental Insurance
Company, 151 N. Franklin Street, Chicago, IL 60606.

Faithful Performance and Materials & Labor Bond $682,000 Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 51

Menifee Mayor and City Council
January 21, 2026
Page
273 of 1208

CITY OF MENIFEE ENGINEERING DEPARTMENT

IMPROVEMENT REQUIREMENT WORKSHEET

STREET AND DRAINAGE IMPROVEMENTS

UNIT
ROADWAY SECTION 1 Area = S.F.

Excavation
Cut (c) = C.Y.

Road area and side slopes to daylight Fill (f) = C.Y.

C.Y. $ 0.40 $ 0.00
C.Y. $ 1.10 $ 0.00
C.Y. $ 2.80 $ 0.00
TON $ 90.00 $ 0.00
Thickness in Feet (0.33' min.) =
C.Y. $ 50.00 $ 0.00
Thickness in Feet =
Ton $ 600.00 $ 0.00
ROADWAY SECTION 2 Area = S.F.

Excavation

2. Projects without a Grading Plan: Cut (c) = C.Y.

Road area and side slopes to daylight Fill (f) = C.Y.

C.Y. $ 0.40 $ 0.00
C.Y. $ 1.10 $ 0.00
C.Y. $ 2.80 $ 0.00
TON $ 90.00 $ 0.00
Thickness in Feet (0.33' min.) =
C.Y. $ 50.00 $ 0.00
Thickness in Feet =
Ton $ 600.00 $ 0.00
$ $ 0.00
EA. $ 500.00 $ 1,500.00
EA. $ 300.00 $ 0.00
LF. $ 65.00 $ 3,510.00
LF. $ 40.00 $ 1,320.00
EA. $ 500.00 $ 0.00
EA $ 2,000.00 $ 0.00
EA $ 500.00 $ 4,000.00
EA $ 2,000.00 $ 0.00
EA $ 50,000.00 $ 150,000.00
S.F. $ 6.50 $ 0.00
C.Y. $ 400.00 $ 0.00
C.Y. $ 200.00 $ 0.00
C.Y. $ 80.00 $ 1,440.00
C.Y. $ 90.00 $ 0.00
C.Y. $ 100.00 $ 0.00
C.Y. $ 110.00 $ 0.00
C.Y. $ 100.00 $ 0.00
C.Y. $ 120.00 $ 0.00
C.Y. $ 130.00 $ 0.00
EA. $ 2,350.00 $ 0.00
L.F. $ 113.00 $ 194,812.00
L.F. $ 132.00 $ 0.00
L.F. $ 153.00 $ 0.00
L.F. $ 178.00 $ 0.00
24" R.C.P. round, arch or elliptical
30" R.C.P. round, arch or elliptical
36" R.C.P. round, arch or elliptical
Grouted Rip Rap ( 1 Ton ) Method B
18" ADS 18"x12" inline pipe
18" R.C.P. round, arch or elliptical 1724
Rip Rap ( 2 Ton ) Method B
Grouted Rip Rap ( 1/4 Ton ) Method B
Grouted Rip Rap ( 1/2 Ton ) Method B
Rip Rap ( 1/4 Ton ) Methob B ( 1.9 tons /CY) 18
Rip Rap ( 1/2 Ton ) Method B
Rip Rap ( 1 Ton ) Method B
Interceptor Drain
R.C. Box Culvert (2 - 3'X5' )
Concrete Channel
Caltrans Delineator Type E 8 Curb Outlet Drainage Structure Std 308
Modular Wetland Systems 3 Cut Off Wall ( Std 2' ) 54 A. C. Overside Drain
Under Sidewalk Drain Std 309
Cut Off Wall ( Std 1' ) with #4 Bars @ 18" O.C., E.W 33

DRAINAGE
Concrete Collar 3
Slope Anchors for Pipes

0.5 Asphalt Emulsion (Fog Seal/Paint Binder)
(1 ton = 240 gals)
-
(c.) Import and Fill -
Asphalt Concrete (144 lbs/cu.ft) -

0.39 Agg Base Class II -
(a.) Excavate and Fill -
(b.) Excavate and Export -
C.Y. $ 25.00 $ 0.00 Area x 0.50' (hinge point to hinge point)

0.67 Asphalt Emulsion (Fog Seal/Paint Binder)
(1 ton = 240 gals)

1. Projects with Grading Plan for Roadway
Asphalt Concrete (144 lbs/cu.ft)

0.42 Agg Base Class II
If balance, provide (a.) only, either cut or fill If export, provide (a.)&(b.) a = fill, b = cut - fill If import, provide (a)&(c), a = cut, c = fill - cut (Unit costs for (a),(b), & (c) are 20% of actual costs to assure that work will be corrected to eliminate hazardous conditions.)
(a.) Excavate and Fill -
(b.) Excavate and Export -

2. Projects without a Grading Plan

1. Projects with Grading Plan for Roadway
C.Y. $
(c.) Import and Fill -

ITEM QUANTITY UNIT AMOUNT
COST

25.00 $ 0.00 Area x 0.50' (hinge point to hinge point) Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 52

Menifee Mayor and City Council
January 21, 2026
Page
274 of 1208

L.F. $ 204.00 $ 0.00
L.F. $ 235.00 $ 0.00
L.F. $ 40.00 $ 0.00
L.F. $ 50.00 $ 0.00
L.F. $ 60.00 $ 0.00
L.F. $ 70.00 $ 0.00
L.F. $ 80.00 $ 0.00
L.F. $ 164.00 $ 0.00
EA. $ 2,500.00 $ 2,500.00
EA. $ 4,000.00 $ 4,000.00
EA. $ 5,750.00 $ 5,750.00
EA. $ 7,500.00 $ 0.00
EA. $ 11,000.00 $ 0.00
EA. $ 14,500.00 $ 0.00
EA. $ 2,500.00 $ 0.00
EA. $ 3,500.00 $ 0.00
EA. $ 4,500.00 $ 0.00
EA. $ 3,500.00 $ 0.00
EA. $ 5,000.00 $ 0.00
EA. $ 12,500.00 $ 0.00
EA. $ 12,500.00 $ 0.00
EA. $ 4,500.00 $ 0.00
EA. $ 5,000.00 $ 20,000.00
EA. $ 6,500.00 $ 0.00
EA. $ 2,700.00 $ 0.00
EA. $ 6,500.00 $ 0.00
EA. $ 2,500.00 $ 7,500.00
EA. $ 2,000.00 $ 4,000.00
EA. $ 10,000.00 $ 20,000.00
2000 psi Concrete Slurry C.Y. $ 150.00 $ 0.00
4" Thick Slurry C.Y. $ 150.00 $ 88,200.00
Pipe Riser EA. $ 5,000.00 $ 0.00
18" Thick of 6"-9" Grouted Cobble C.Y. $ 250.00 $ 0.00
6" Schedule 40 Air Release Pipe L.F. $ 30.00 $ 0.00
8" SCH 40 PVC Pipe L.F. $ 35.00 $ 0.00
12" SCH 40 PVC Pipe L.F. $ 55.00 $ 0.00
Bioclean Modular Wetland and Modular Dvert EA. $ 50,000.00 $ 0.00 Caltrans Cable Railing per B11-47 L.F. $ 50.00 $ 3,450.00 Connect to Existing Pipe EA 1,500.00 4,500.00
C.Y. $ 400.00 $ 2,800.00
EA. $ 34,000.00 $ 0.00
L.F. $ 20.00 $ 0.00
L.F. $ 30.00 $ 0.00
EA. $ 1,500.00 $ 0.00
EA. $ 4,000.00 $ 0.00
EA. $ 8,500.00 $ 0.00
EA. $ 2,500.00 $ 0.00
LF. $ 30.00 $ 4,110.00
SF $ 50.00 $ 2,450.00
L.F. $ 35.00 $ 3,465.00
EA. $ 1,200.00 $ 3,600.00
L.F. $ 40.00 $
$ $ 0.00
LS $ 8,000.00 $ 0.00
LS $ 40,000.00 $ 0.00
LS $ 30,000.00 $ 0.00
LS $ 15,000.00 $ 0.00
A. $ 532,907.00
B. Administrative Contingency (20% x A) $ 106,581.40
C. CM - Inspection - LC (8%) $ 42,632.56
D Streets/Drainage Total (A + B) $ 682,120.96
Drop inlet
69 3
Catch Basin W=10' 1
Structural Reinforcement Concrete for Concrete Pads 7
15" C.S.P. or HDPE N12
Gutter depression for curb opening
RCFC&WCD Modified drop inlet
Vortechs 16000 treatment structure
Junction Structure No. 3
Transition Structure No. 2
Transition Structure No. 3
Manhole No. 1 4
Junction Structure No. 2
Junction Structure No. 6
Transition Structure No. 1
Subtotal
Design/submittals/review
Mobilization
Traffic Control
Survey
8" PVC Pipe for Modular Wetland 99
RCFC&WCD Conctrete collar
Norplex Micarta 137
6" Concrete Apron w/ #4 Bars @ 18" O.C., E.W 49
18" CMP PIPE
Contech D-Verts 3
12" C.S.P. or HDPE N12
Manhole No. 2
Manhole No. 3
Manhole No. 4
Local Depression No. 2 3
Special Connections to Catch Basin 2
Caltrans D90 & B3-1C Wingwall 2
588
Catch Basin W=28'
Grated conc.trench drain
Junction Structure No. 1
Catch Basin W=7' 1
Catch Basin W=14'
Catch Basin W=21'
42" C.S.P. or HDPE N12
96" CMP subsurface basin
Catch Basin W=4' 1
24" C.S.P. or HDPE N12
30" C.S.P. or HDPE N12
36" C.S.P. or HDPE N12
42" R.C.P. round, arch or elliptical
48" R.C.P. round, arch or elliptical
18" C.S.P. or HDPE N12
Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 53

Menifee Mayor and City Council
January 21, 2026
Page
275 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 54

Menifee Mayor and City Council
January 21, 2026
Page
276 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 55

Menifee Mayor and City Council
January 21, 2026
Page
277 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 56

Menifee Mayor and City Council
January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 57

Menifee Mayor and City Council
January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 58

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 59

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 60

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 61

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 62

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 63

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 64

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 65

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 92

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 93

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 94

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 95

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 96

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 97

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 98

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 99

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 100

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 101

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 102

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 103

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 104

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 105

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 106

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 107

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 108

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 109

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 110

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 111

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 112

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 113

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 114

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 115

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 116

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 117

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 118

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 119

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 120

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 121

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 122

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 123

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 124

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 125

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 126

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 127

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 128

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 129

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 130

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 131

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 132

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 133

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 134

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 135

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 136

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 137

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 138

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 139

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 140

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January 21, 2026
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Services
Services,
KB Home Cal Management Services, LLC
Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 141

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 142

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 143

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 144

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 145

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January 21, 2026
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Services,
KB Home Cal Management Services, LLC
Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 146

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 147

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 148

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 149

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 150

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 151

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 152

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 153

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 154

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 155

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 156

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 157

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 158

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 159

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 197

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January 21, 2026
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Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

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January 21, 2026
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 199

Menifee Mayor and City Council
January 21, 2026
Page
421 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 200

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 201

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January 21, 2026
Page
423 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 202

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January 21, 2026
Page
424 of 1208

Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 203

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 204

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 205

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 206

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 207

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 208

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January 21, 2026
Page
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Item Title: 10.12
Agreement and Bonds for future Tract Map 31229-1 and 31229-2 Nautical Cove, by KB Home Cal Management Services, LLC.

Item Page Number: 209

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January 21, 2026
Page
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CITY OF MENIFEE
SUBJECT: Public Improvement Acceptance and 90% Release of Security for Tract Map 32628, Adler Ranch, by FPG Tricon Menifee Property, LLC
MEETING DATE: January 21, 2026
TO: Mayor and City Council
PREPARED BY: Crystal Nguyen, Senior Engineer
REVIEWED BY: Nick Fidler, Public Works Director
APPROVED BY: Armando G. Villa, City Manager
-------------------------------------------------------------------------------------------------------------------------------

RECOMMENDED ACTION

1. Accept the public improvements for landscape for Tract Map 32628, Adler Ranch, located at the southeast corner of the intersection of Antelope Road and Craig Avenue; and

2. Authorize the City Engineer to release 90% of the posted securities per the City’s standard policies.

DISCUSSION
FPG Tricon Menifee Property, LLC (Developer) is the developer of Adler Ranch (Project), a subdivision of 29.29 gross acres of land into five total lots for multi-family use. The Project is located at the southeast corner of the intersection of Antelope Road and Craig Avenue.

The Developer has now completed the construction and maintenance period for the landscaping and is requesting acceptance of the completed improvements into the City’s maintenance system.

Staff have inspected the completed improvements, determined that the improvements have been constructed in accordance with City specifications and standards, and verified that all project conditions of approval have been met to release the faithful performance security and labor and materials security in accordance with City policy.

A 10% warranty security would be held for a period of one year in accordance with the City Municipal Code. The original posted securities for the improvements are listed in Table 1 on the following page.

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 1

Menifee Mayor and City Council
January 21, 2026
Page
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City of Menifee Staff Report
Landscape Improvement Acceptance TM 32628
January 21, 2026

Page 2 of 2 ends

3 0
9 4
TABLE 1 - ORIGINAL POSTED SECURITY IMPROVEMENTS
Improvement Security No.

Performance /
Material
Faithful
Performance
Material and
Labor
Landscaping (IP22-029) K41598931 $364,000 $182,000
Total $364,000 $182,000

STRATEGIC PLAN OBJECTIVE
Safe and Vibrant Community

FISCAL IMPACT
There is no fiscal impact associated with the recommended action. The Developer has paid all necessary fees and deposits to cover the costs of the required inspection of the completed improvements. Ongoing maintenance costs for the improvements would be supported through approved Fiscal Year 2025/2026 operating budgets in Community Facilities District (CFD) 2017- 1 Zone 14.

ATTACHMENTS

1. Project Map

2. Agreement

3. Bond
Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 2

Menifee Mayor and City Council
January 21, 2026
Page
433 of 1208

WILLOWOOD
WAY

TWILIGHTVISTADR
ROUGE
LN

GARBANI RD

HALEBLIAN RD

ANTELOPE RD

MISSION DR M
ENIFEE

RDHAUN RD

CRAIG AVEPLEASANT
VALLEY
AVE
§¨¦
215
^_

EVANSRD

SCOTT RD

GARBANI RD

NEWPORT RD

MURRIETA
RD

MENIFEE
RD

BRADLEY RD

AUDIE MURPHY RD
§¨¦215
TM32628 - Adler Ranch

PROJECT MAP
Item Title: 10.13
Public Improvement Acceptance and 90% Release of Security for Tract Map 32628, Adler Ranch, by FPG Tricon Menifee Property, LLC Item Page Number: 3

Menifee Mayor and City Council
January 21, 2026
Page
434 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 4

Menifee Mayor and City Council
January 21, 2026
Page
435 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 5

Menifee Mayor and City Council
January 21, 2026
Page
436 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 6

Menifee Mayor and City Council
January 21, 2026
Page
437 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 7

Menifee Mayor and City Council
January 21, 2026
Page
438 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 8

Menifee Mayor and City Council
January 21, 2026
Page
439 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 9

Menifee Mayor and City Council
January 21, 2026
Page
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 10

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 11

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January 21, 2026
Page
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 12

Menifee Mayor and City Council
January 21, 2026
Page
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 13

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 14

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 15

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 16

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 17

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January 21, 2026
Page
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 18

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January 21, 2026
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Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 19

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January 21, 2026
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450 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 20

Menifee Mayor and City Council
January 21, 2026
Page
451 of 1208

Item Title: 10.13
Public

Improvement

Acceptance

and

90%

Release

of

Security

for

Tract

Map

32628,

Adler

Ranch,

by

FPG

Tricon

Menifee

Property,
LLC
Item Page Number: 21

Menifee Mayor and City Council
January 21, 2026
Page
452 of 1208

CITY OF MENIFEE
SUBJECT: Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project
MEETING DATE: January 21, 2026
TO: Mayor and City Council
PREPARED BY: Russell Brown, Senior Planner
REVIEWED BY: Orlando Hernandez, Community Development Director APPROVED BY: Armando G. Villa, City Manager
-------------------------------------------------------------------------------------------------------------------------------

RECOMMENDED ACTION

1. Adopt a resolution denying Appeal No. PLN25-0208 submitted by the Golden State Environmental Justice Alliance (GSEJA); and

2. Adopt a resolution denying Appeal No. PLN25-0210 submitted by the Supporters Alliance for Environmental Responsibility (SAFER); and

3. Adopt a resolution certifying an Environmental Impact Report (EIR) for Plot Plan No. PLN23- 0245 for the Menifee (Pemcor) Business Park Project generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road; and

4. Adopt a resolution approving Plot Plan No. PLN23-0245 for the Menifee (Pemcor) Business Park Project.

DISCUSSION
On November 12, 2025, the Planning Commission held a duly noticed public hearing and voted unanimously to approve Plot Plan (PP) No. PLN23-0245 along with the related environmental analysis (Project). On November 19, 2025, the City received an application from GSEJA to appeal the Planning Commission decision. A second appeal application was received from SAFER on November 20, 2025.

The Project was approved by the Planning Commission for a commercial/industrial business park development consisting of 11 single-story buildings ranging in size from approximately 23,100 square feet to 37,840 square feet (total 337,770 square feet) on approximately 20 acres. The Project site is zoned Economic Development Corridor – Southern Gateway (EDC-SG). The Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 1

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January 21, 2026
Page
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City of Menifee Staff Report
Menifee (Pemcor) Business Park Appeal
January 21, 2026

Page 2 of 5 ends

3 1
1 2
anticipated end users are expected to provide services ranging from industrial and manufacturing users to service commercial and office (tenants are not known at this time). Each building includes two dock-high doors for a total of 22 for the entire project.

The Project proposes 677 parking spaces and 121,879 square feet (15%) of irrigated landscaped area. The applicant is proposing approximately 53,300 cubic yards of grading. Furthermore, the Project includes two driveways along Zeiders Road with the southernmost driveway being signalized and aligning with Scott Road Commerce Center.

Location
The site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road (APN: 384-150-001).

IMAGE 1 – PROJECT LOCATION – AERIAL
Appeal No. PLN25-0208
The GSEJA filed an appeal of the Planning Commission’s November 12, 2025, approval of PP No. PLN23-0245, claiming the Planning Commission erred in its decision to approve the Project by determining the Project would not result in further impacts on an already pollution-burdened citizenry. GSEJA provided information depicting the severity of the level of pollution and health hazards the City of Menifee and its citizens are experiencing. The appeal letter reaffirms its concerns that were presented in its original letter dated September 24, 2025 (and reiterated in a Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 2

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January 21, 2026
Page
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City of Menifee Staff Report
Menifee (Pemcor) Business Park Appeal
January 21, 2026

Page 3 of 5 ends

3 1
1 2
November 11, 2025, comment letter), which was responded to by staff, in conjunction with our California Environmental Quality Act (CEQA) Consultant, in the Final EIR.

The commenter provides a table of data which gives the false impression that the area surrounding the Project site is disproportionately impacted. However, the proposed Project would not result in significant and unavoidable air quality impacts. Localized air quality impacts would be less than significant and there are no significant air quality impacts to local residents as a result of approval of the proposed Project.

Both the September 24, 2025, comment letter and the November 11, 2025, comment letter, in addition to the November 19, 2025, appeal letter for the Project contained concerns from GSEJA regarding air quality, greenhouse gas (GHG) emissions, land use and planning, transportation and traffic, growth inducing impacts, alternatives, and population and housing. Staff, the Project Applicant and our CEQA consultant reviewed the claims presented by GSEJA and have determined that the Final EIR adequately addressed concerns raised and no further CEQA analysis is warranted.

Furthermore, the GSEJA comment letters indicated that there was a technical/procedural error and that a technical appendix (Appendix E – GHG, Energy) was not adequately made accessible to the public as required by CEQA. While this was initially true, the omission was noticed by staff and the Draft EIR was officially re-circulated establishing a new 45-day public review period. The original public circulation date for the Draft EIR was August 13, 2025; however, staff noticed the omission of Appendix E and a new public circulation date began on September 2, 2025, and included the appendix.

As such, the previous responses to these resource topics are still appropriate, and no additional points were raised in the appeal letter which would require further analysis.

Appeal No. PLN25-0210
SAFER filed an appeal of the Planning Commission’s November 12, 2025, approval of PP No.

PLN23-0245, claiming areas of the Project (as outlined below), including the environmental analysis, were not adequately analyzed/addressed. The appeal letter raises concerns with the following:

1. Insufficient Analysis of GHG Mitigation Measures

2. Insufficient Access to Vehicle Miles Traveled (VMT) Analysis Document In response to the SAFER appeal letter and the concerns raised above, staff, in conjunction with our CEQA consultant, refute SAFER’s claims that all feasible mitigation measures related to GHGs were not analyzed and included in the Final EIR. All feasible mitigation measures related to GHG impacts are required of the Project.

Finally, the SAFER appeal letter states the analysis of project VMT impacts and Transportation Demand Management (TDM) mitigation relied on a study that was not provided with the Draft EIR appendices. The VMT Assessment prepared by the Ganddini Group, dated November 7, 2024, was included as Draft EIR Appendix L2 on the State Clearinghouse website and a hard copy was Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 3

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January 21, 2026
Page
455 of 1208

City of Menifee Staff Report
Menifee (Pemcor) Business Park Appeal
January 21, 2026

Page 4 of 5 ends

3 1
1 2
available at the public counter at City Hall as indicated in the notice and as required by CEQA Guidelines.

In conclusion, staff, along with our CEQA consultant, have determined the two appeal letters do not provide significant new information or identify new significant impacts or information regarding the project or the Draft EIR/Final EIR analysis. Staff concludes the information provided in the Draft EIR, its appendices (including Appendix E for which the public was provided adequate time to review), the Final EIR and all response to comments and supporting materials adequately address all the issues and comments raised, and therefore, the EIR meets the requirements of CEQA.

Environmental Determination
The Planning Commission adopted Resolution No. PC25-676 certifying an EIR on November 12, 2025, determining the Project will have a significant effect on the environment (related to GHG Emissions). However, an EIR was prepared for this Project pursuant to the provisions of the CEQA. Mitigation measures were made as a condition of the approval of the Project and a Mitigation Reporting or Monitoring Plan (MMRP) was adopted for this Project. A Statement of Overriding Considerations was adopted for this Project and Findings were made pursuant to the provisions of CEQA. Following the Project’s approval, a Notice of Determination (NOD) was filed with the Riverside County Clerk’s Office on November 13, 2025.

The Final EIR, as well as all its technical appendices, can be accessed for review on the City website: https://www.cityofmenifee.us/325/Environmental-Notices-Documents.

Public Notice
The proposed Project was noticed on January 11, 2026, for the January 21, 2026, City Council hearing. A public notice was published in The Press Enterprise and notices were mailed to property owners and non-owner residents within a 1,000-foot radius of the Project site. The proper public notice was posted on-site, and in addition, all relevant public agencies and those requesting notification were notified of the public hearing.

STRATEGIC PLAN OBJECTIVE
Thriving Economy

FISCAL IMPACT
There is no fiscal impact associated with the recommended action.

ATTACHMENTS

1. Appeal Letter - GSEJA

2. Response to Appeal Letter - GSEJA

3. Resolution – GSEJA

4. Appeal Letter – SAFER

5. Response to Appeal Letter – SAFER

6. Resolution – SAFER
Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 4

Menifee Mayor and City Council
January 21, 2026
Page
456 of 1208

City of Menifee Staff Report
Menifee (Pemcor) Business Park Appeal
January 21, 2026

Page 5 of 5 ends

3 1
1 2

7. Resolution EIR

8. Exhibit A – Final EIR

9. Exhibit B – MMRP

10. Exhibit C – Findings of Fact

11. Resolution – Plot Plan

12. Exhibit A – Conditions of Approval

13. November 12, 2025 PC Staff Report

14. Project Exhibits

15. Public Hearing Notice
Item Title: 11.1
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January 21, 2026
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Item Title: 11.1
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Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 7

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Item Title: 11.1
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Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 10

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Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 11

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Item Title: 11.1
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Item Title: 11.1
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to Russell Brown, City of Menifee

from Kent Norton, MIG Riverside

re Pemcor Business Park EIR – Response to City Council Appeal by GSEJA and SAFER

date January 7, 2026

Subsequent to the Planning Commission hearing on November 12, 2025, an appeal to the City Council was submitted for the Menifee (Pemcor) Business Park Project by the Golden State Environmental Justice Alliance (GSEJA) dated November 19, 2025. A second appeal application submitted by Lozeau Drury on behalf of Supporters Alliance For Environmental Responsibility (SAFER) was received on November 20, 2025. It should be noted these two commenters each submitted two previous comment letters on the Pemcor project, one during the DEIR 45-day review period and one after the close of the review period and before the Planning Commission hearing. Responses to these previous letters were prepared and distributed per CEQA requirements.

The following are responses to the comments raised in the two appeal letters. The two appeal letters with comments marked in red are provided at the end of this memorandum. (1) Supporters Alliance For Environmental Responsibility (SAFER) Letter Response S-1: This comment provides general information on the requirements of CEQA and CEQA lead agencies, including the requirement for a lead agency to adequately respond, in good faith and with reasoned analysis, to specific comments or suggestions for ways to mitig ate or avoid a significant environmental impact. SAFER submits these comments in the context of the EIR’s purported failure to adopt all feasible mitigation measures for the project’s significant and unavoidable greenhouse gas (GHG) impacts; however, as described in more detail in Responses to Comments S-2, S-3, and S-4, the City has, in good faith, considered all specific comments related to the EIR, including SAFER’s November 12, 2025 appeal comments, and determined, with reasonable analysis, that all feasible mitigation measures have been incorporate d into the project, and that there are eight specific economic, social, technological, and other benefits of the project that outweigh the project’s significant and unavoidable GHG impact. The appellant is referred to Menifee (Pemcor) Business Park Project EIR Findings of Fact and Statement of Overriding Considerations (Findings/SOC) for the description of these benefits.

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Response S-2: SAFER adequately summarizes EIR information on the magnitude and significance of the project’s GHG emissions sources and the mitigation measures incorporated into the EIR to reduce the project’s GHG emissions. SAFER asserts Mitigation Measure (MM) -GHG-1 an d GHG -3 are inadequate for several reasons; however, as described in more detail below, MM -GHG-1 and MM -GHG-3 establish enforceable performance standards and identifiable actions that would be implemented, monitored, and verified. EIR Mitigation Measures GHG-1 and GHG-3, therefore, are adequate. • Mitigation Measure GHG -1 is not deferred mitigation. It incorporates a clear performance standard for passenger vehicle miles travelled (VMT) and then provides flexibility and options for how to meet this standard. The standard - a

6.2% reduction in passen ger vehicle VMT - is to be achieved through the implementation of one or more of the California Air Pollution Control Officer’s Association (CAPCOA) transportation demand management (TDM) GHG reduction measures identified in the TDM Memorandum prepared for the project by the Ganddini Group and specifically called out in MM -GHG-1. Furthermore, the full implementation of these CAPCOA TDM Measures shall occur within one year of 90% project occupancy. This occupancy rate is considered necessary to support a sit e- wide TDM plan serving all tenants; however, the partial implementation of tenant- specific measures is not precluded prior to reaching 90% occupancy. Finally, Mitigation Measure GHG-1 is fully enforceable. It requires the TDM measures to be managed by the applicant or subsequent developer until a property owners association (POA) is established for the project site. The managing party (i.e., applicant, POA, etc.) is required to submit to the City, for review and verification, initial and ongoing, annual re port that the TDM measures are being implemented and the corresponding VMT reductions estimated to be achieved by the measures.

If, during its review of these reports, the City determines the TDM plan is not achieving the established performance standard, MM-GHG-1 requires the project to implement additional TDM measures to achieve the performance standard. For these reasons, MM-GHG-1 establishes a clear, enforceable, performance standard that could be achieved, as necessary, by one or more actions that wou ld be monitored and enforced in accordance with the project’s Mitigation Monitoring and Reporting Program and Plot Plan PLN23-0245. The City will enforce the MMRP just as they will enforce all their Conditions of Approval (COAs). Thus, MM -GHG-1 satisfies the requirements of CEQA and does not constitute deferred mitigation. • MM-GHG-3 is not deficient. It requires all building energy systems, equipment, and appliances to be powered by electricity unless evidence is submitted to the City demonstrating that it is not technologically or economically feasible to do so. The fact that MM-GHG-3 requires structures to be dual plumbed does not directly reduce or avoid the requirement to use electric systems, nor the effectiveness of this Item Title: 11.1
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measure. This is because the development of new non -residential buildings with natural gas infrastructure is consistent with the California 2025 Building Energy Efficiency Standards (BEES, or the Energy Code), which Chapter 8.17 of the Menifee Municipal Code adopts by reference as the Menefee Energy Code. While the 2025 BEES includes requirements for heat pumps, battery energy storage systems, and other components that support all -electric construction, it allows new non - residential buildings to be plumbed for natural gas and requires new buildings to be pre -wired to support the future installation of electric building systems and appliances. MM-GHG-3 would both be consistent with the Menifee Energy Code and result additional GHG emissions reductions by requ iring electrification of systems and appliances that are not currently required to be so. Thus, MM -GHG-3 is not deficient.

Response S-3: SAFER asserts the EIR is deficient because it fails to consider additional feasible mitigation measures, specifically idling, solar panel, and other “best practices” recommended by the California Department of Justice (DOJ) in its guidance document “Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” This comment is similar to comments submitted by the South Coast Air Quality Management District, the Golden State Environmental Ju stice Alliance (GSEJA), and Advocates for the Environment on the Draft EIR. As explained in Final EIR responses C-6, C-9, H-38, and I-9, the City has reviewed the referenced document and determined that many of the best practices in the document are commensurate with the requirements of existing regulations and/or the mitigation measures incorporated into the EIR. As described in more detail below, the EIR is not deficient, has incorporated feasible measures to reduce GHG emissions, and the additional recommendations made by the appellant are not considered feasible for the project. • SAFER asserts it is feasible to reduce truck idling times to less than the current 5- minute limit imposed on the project. While, as a general fact, it is possible to restrict trucks to idle for less than 5 minutes, such a restriction would be inconsistent with State legal requirements, is likely to be impractical, and would not be proportional to the magnitude of the GHG emissions impact, which is primarily the result of off- site truck travel emissions (and not on -site idling emissions). The City notes that the SCAQMD, in its comments on the Draft EIR (SCAQMD C -3), stated, “It is reasonable to expect that individual trucks may experience extended periods of idling due to on -site queuing, security checks, staging, loading, and unloading operations . . . As such, a 15-minute idling duration may underestimate actual on- site idling behavior . . .”. Furthermore, CARB’s Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (Title 13 of the California Code of Regulations, Section 248 5) has, since 2015, limited the idling of diesel fueled trucks with a gross vehicle weight rating greater than 10,000 pounds to 5 Item Title: 11.1
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consecutive minutes within 100 feet of any real property zoned for residential, school, hotel, motel, hospital, senior care facilities, and child care facilities, or which has one or more such units on it. This restriction would only affect the part of the project area within 100 feet of its northern and western boundary. Finally, the California Air Resources Board’s (CARB) Emission Factor (EMFAC) 2021 database Volume III Technical Document indicates certain out-of-state registered trucks idle for up to five hours at a time, while in-state registered truck idling times can vary between approximately 13 minutes and 4 hours per day (i.e., not per stop).

Together, this data information indicates that the vast majority of the site would not be subject to idling restrictions. The City’s Condition of Approval (COA 28) limiting idling of diesel-fueled trucks to no more than 5 minutes throughout the site (see COA text below) , therefore, represents a substantial additional reduction in idling emissions from diesel -fueled trucks that is equitable by aligning the idling restrictions mandated by the State ACTM that are applicable to part of the site to the full site. For this reason, additional idling restrictions would not be proportionate to the magnitude of the project’s GHG emissions impact.

COA 28
AQMD Rule 402. The project developer shall implement the following measures to reduce the emissions of pollutants generated by heavy -duty diesel-powered equipment operation at the project site throughout the project construction phases. The project developer shall includ e in construction contracts the control measures as may be required under Rule 402, at the time of development, including the following:
a. Keep all construction equipment in proper tune in accordance with manufacturer’s specifications.
b. Use late model heavy-duty diesel-powered equipment at the project site to the extent that it is readily available in the South Coast Air Basin (meaning that it does not have to be imported from another basin and that the procurement of the equipment would not cause a delay in construction activities of more than two weeks).
c. Use low -emission diesel fuel for all heavy -duty diesel -powered equipment operating and refueling at the project site to the extent that it is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another basin, that the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment (this measure does not apply to diesel -powered trucks traveling to and from the site).

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d. Utilize alternative fuel construction equipment (i.e., compressed natural gas, liquid petroleum gas), if equipment is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another air basin, th at the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment).
e. The developer shall post signage on -site limiting truck and equipment idling time to five minutes or less.
f. Rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion engines to the extent feasible.
g. General contractors shall maintain and operate construction equipment so as to minimize exhaust emissions.
• SAFER asserts that it is feasible to require solar panels on more than 15% of building rooftops, which is the current performance standard established by MM - GHG-4. The City notes that 2025 BEES establishes prescriptive and performance - based requirements for installed solar PV capacity for new non-residential buildings, such as the proposed project. In general, the installed capacity is dependent on the type of structure/occupancy, conditioned floor area, climate zone, roof slope, and other factors. In addit ion, the solar access roof area where PV panels could be installed must take into account shading, occupied roof areas, and other code - required roof access, pathway, ventilation requirements. In short, the number of PV panels that can be installed on any s ingle roof is contingent on specific design factors that are not known to the City at this time. The appellant is referred to Draft EIR Table 3 -2 (p. 3 -8), which indicates that each of the project’s 11 potential buildings would be relatively small, between approximately 23,000 and 38,000 square feet in size, which limits the overall roof area for solar PV and other equipment installations. The performance standard required by MM -GHG-4 is considered to be the minimum amount of solar PV installation that is feasible for all project buildings. As described in the FEIR (Appendix E, p. 6-8), it is based on the residential requirements of the 2022 BEES, which was the BEES in effect at the time the was prepared. It is not feasible for the C ity, at this time, to require the project to commit to the installation of solar PV panels on more than 15% of the roof area because of the additional information needed to guarantee such physical installed capacity would be feasible for individual project buildings. • SAFER to zero emission (ZE) yard equipment (e.g., forklifts) and trucks are feasible for the project.

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o With regard to ZE yard equipment, the City notes that the proposed project is not anticipated to involve the operation of any yard equipment and thus this recommendation is not relevant to the project.
o With regard to ZE trucks, as explained in the Final EIR (response C-8), the City has determined mandating the use of ZE trucks for the project is infeasible for legal and technological reasons. Goods movement is a complex process that may involve multiple stops. Trucks may be owned, operated, contracted, etc. as needed depending on each site’s operating characteristics, and neither the City nor future individual developers/tenants can regulate mobile emissions, which is within the purview of state regulator y agencies such as the CARB and local agencies, such as the SCAQMD. Those agencies can, and have, adopted regulations intended to reduce emissions from mobile sources, including trucks.

The Draft EIR, for example, summarized CARB’s Advanced Clean Fleets Ru le, which was intended to accelerate the large-scale reduction of tailpipe emissions by focusing on ZE medium and heavy -duty vehicles. Although CARB recently repealed and or modified the requirements of this rule, its mandate continues to reflect what CARB considers to be feasible implementation schedules, reflecting technological availability and feasibility. Cars and trucks accessing the project in the future would be required to comply with applicable regulations; however, the appellants’ suggestion that the City require ZE trucks is not considered feasible due to logistical and technological reasons.
• SAFER asserts the DOJ’s recommendation to post signs identifying idling restrictions is feasible for the project. As noted in the Final EIR (p. 2 -18, response C-3), the City has conditioned the project to limit truck idling to no more than 5 consecutive minutes. Project conditions will be incorporated into development and lease agreements as appropriate, and the posting of signs on -site would not, in and of itself, be an action that would reduce idling emissions. The City will also include the following Condition of Approval with this Project’s approvals:

NEW COA: The developer shall post signage on-site limiting truck and equipment idling time to five minutes or less.
• SAFER asserts it is feasible to run conduits to support future electric truck charging stations is feasible for the project. As noted in the Final EIR (response H -38), the proposed project would have 22 docks, less than half the amount (50 docks) that the City determined, in its Industrial Good Neighbor Policies, was feasible to require the installation of a conduit for truck charging. Thus, it is not considered feasible to require the installation of electric infrastructure to support future electric trucks at the project site.

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• SAFER asserts it is feasible for standby emergency generators to be powered by non-diesel fuel ; however, the project does not include the installation of any emergency generators and thus this recommendation is not relevant to the project.

Furthermore, as noted in the Final EIR (response H -38), the use of non -diesel generators is not necessary for the Project because this measure would not reduce or avoid an identified significant impact.
• SAFER asserts it is feasible for the project to be designed to meet LEED green building certification standards. As noted by the appellant, the Final EIR (Appendix E, p. 6-4), discloses that building energy use accounts for approximately 14% of the project’s estimated GHG emissions. The City incorporated Mitigation Measure GHG-3 and GHG-4 into the project, which requires the installation of solar PV panels on building roof tops and the use of electric building systems (instead of natural gas). These measures are estimated to substantially reduce the project’s building energy GHG emissions by up to 21.5%. Requiring the project to achieve LEED certification when it will already achieve an estimated 21.5% reduction in building energy use and will be required to meet California Green Building Code requirements would not be proportionate to the building energy use impact identified in the EIR.
• SAFER asserts that the DOJ’s recommendation to provide meal options onsite or shuttles between the facility and meal destinations is feasible for the project. While, as a general concept, on-site meal options may reduce off-site vehicle trips, there is no guarantee that providing this option would reduce vehicle trips. It is also not possible for the City to enforce this as a requirement since the feasibility of this action is contingent on market conditions that are outside the control of the City.

Response S-4: SAFER reiterates its assertion that the City cannot approve the Project and its EIR until all feasible GHG mitigation measures have been applied to the Project.

As described in Responses S-1, S-2, and S-3 above, the City has, in good faith, considered all specific comments related to the EIR, including SAFER’s November 12, 2025 appeal comments, and determined, with reasonable analysis and supported by substantial evidence as defined by CEQA Guidelines Section 15 384 (facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts), that all feasible GHG mitigation measures have been incorporated into the project. The EIR, therefore, does not require revision.

Response S -5: The commenter states the EIR references a Transportation Demand Management (TDM) Assessment prepared by Ganddini Group on February 19, 2025 (“2025 Ganddini Report”) that has not been provided to the Planning Commission or the public. It should be noted the requested document (DEIR Appendix L-2, 2025 Ganddini Item Title: 11.1
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VMT Report) was made available for public review on the State Clearinghouse website (see attached CEQAnet Excerpt).

Response S-6: As outlined in Responses S-1 through S-5 above, the City has considered expansion of existing or additional mitigation measures to help reduce GHG emissions.

In addition, the 2025 Ganddini VMT report was in fact included on the State’s CEQAnet website as Appendix L-2 (see attached CEQAnet Excerpt). Therefore, the EIR does not need to be revised and recirculated for additional public review.

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(2) Golden State Environmental Justice Alliance (GSEJA) Letter Response G-1: GSEJA states its reasons for appeal and denial of the project, citing its September 24, 2025, comments on the Draft EIR, inclusive of expert comments prepared by Soil Water Air Protection Enterprise (SWAPE) on the Draft EIR and September 19, 2025, and its November 11, 2025, comment letter on the Final EIR. The City has already provided detailed responses to these comments. The appellant is directed to Final EIR Responses H -1 to H-39 and the memorandum prepared by MIG, Incorporated (Inc.), “Pemcor Business park EIR – Response to Late GSEJA and SAFER Comment Letters,” dated November 12, 2025. This document is already part of the administrative record as part of the Planning Commission staff report materials.

Response G-2: GSEJA is re -submitting information regarding the existing pollution burden for the census tract (606043279) the Pemcor Business Park is located in. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explained in the MIG memorandum responding to those comments, this information is substantially the same as that provided in the Draft EIR (pp. 4.3-7 to 4.3-11) and Draft EIR Appendix E (pp. 3 -11 to 3-14), which provided a detailed discussion on “Existing Health Risks and Disadvantaged Communities.” The EIR discussion includes not only information on the census tract’s CalEnviroScreen pollution burden, but also information on other existing and planned light industrial facilities within ¼ mile of the project site and South Coast Air Quality Management District (SCAQMD) Multiple Air Toxics Exposure Study (MATES) V study. Importantly, the CalEnviroScreen pollution, health, and socioeconomic percentile data presented by GSEJA are the same as that disclosed in the EIR.

Furthermore, as a point of clarification, the City notes that, as described in CalEnviroScreen 4.0 Report, the CalEnviroScreen model assesse s cumulative impacts using both pollution burden and population characteristic data that are scored and combined to determine a single CalEnviroScreen score.1 This methodology accounts for differences in individual pollution burdens across geographic area so that no one single adverse environmental or public health effect or socioeconomic condition can render an area disadvantaged. Thus, while individual percen tile rankings provide useful information, they may or may not be representative of the total CalEnviroScreen score.

Finally, as another point of clarification, GSEJA has incorrectly referred to census tract 606043279 as an “Senate Bill (SB) 535 Disadvantaged Community designation, clearly identifying this as a disadvantaged community under state law.” As explained in the Draft EIR (p. 4.3 -10, emphasis added), “Communities that are within the top 25th percentile for total CalEnviroScreen scores are considered disadvantaged communities pursuant to SB 535. According to the Office of Environmental Health Hazard Assessment

1 Office of Health Hazard Assessment, 2021. CalEnviroScreen 4.0. October 2021.

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(OEHHA) CalEnviroScreen 4.0 Map, the proposed project is Census Tract 6065043279.

This area shows an average pollution indicator percentile of 41% based on the CalEnviroScreen indicators (e.g., exposure, environmental effects, population characteristics, socioeconomic factors) and has a population of 5,075 people . . . Table

4.3-3 summarizes the CalEnviroScreen indicators for census tract 6065043279. As shown in Table 4.3 -3, census tract 6065043279 is not within the top 25% of total CalEnviroScreen percentiles throughout the State and, therefore, is not considered a disadvantaged community pursuant to SB 535.” Thus, GSEJA has, again, failed to submit any information that was not already considered in the Draft EIR’s detailed analysis and evaluation of potential adverse air quality impacts.

Response G-2.1: There were no critical omissions of data or materials. When the City determined that one of the DEIR appendices had not been posted for public review, it issued a revised Notice of Availability and Notice of Completion through the State Clearinghouse which provided an extended and complete 45-day public review period after posting the “missing” appendix. Therefore, the critical air quality modeling data was made available to the public for the necessary period of time which was duly noted in the subsequent notices and DEIR document in the appropriate locations. In this way the document did not violate CEQA’s fundamental mandate for adequate informational documents and meaningful disclosure. The second notice is clearly posted on CEQAnet and all the necessary appendices are posted on that site as well.

The commenter also identified the following list of “legal compliance violations” supposedly committed by the EIR:
• CEQA 15121 – Informational Disclosure. DEIR Appendix E was provided to the public for the full 45 -day extended review period, as discussed in Response G-2.1 above.
• CEQA 15378 – Project Piecemealing. The EIR correctly evaluates the whole of the Pemcor project and the commenter incorrectly conflates the project with other non-related industrial projects in the surrounding area (cumulative project). • SB 1000 – Environmental Justice. The commenter is incorrect, the project site is not part of a disadvantaged community as outlined in Response G-3 below. • SB 330/SB 8 – Housing Crisis Act. As explained in the Final EIR response to comments and the response to supplemental comments to the Planning Commission, the Pemcor project is consistent with the General Plan and zoning designation for the site which allows mixed use but does not require residential uses to be built on any one particular project. Similarly, the Housing Element does not rely on or designate specific residential units on this site (see also Response G-4.1 below).

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• Govt Code 65302(h) – General Plan Env. Justice Element. Response G-5 below demonstrates the project is consistent with the General Plan goals and policies cited by the commenter.
• Govt Code 1135 – Language Access. The Menifee community may have a 30% Hispanic population but the population of the area surrounding the proposed project does not have similar demographic and language characteristics (see Response G-10.1).
• CEQA 15131(c) – EJ Analysis. In 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element in 2021 (see Responses G-3 and G-4 for more information).

Response G-2.2: The commenter is incorrect – there is no “piecemealing” involved with this project, the entire Pemcor Business Park development was described and analyzed in the DEIR. The “segmentation” seems to refer to the cumulative projects list which identifies other industrial developments proposed by other developers o n other sites at distance from the proposed project. These various projects have no direct relationship to the proposed Pemcor project in terms of ownership or application so the CEQA terms piecemealing and segmentation simply do not apply.

Response G-3: GSEJA asserts that, despite census tract 6065043279 being an SB 535 Disadvantaged Community, the City has failed to conduct a required Senate Bill (SB) 1000 analysis of environmental justice. First, as a point of clarification, census tract 6065043279 is n ot an SB 535 Disadvantaged Community (see response G -2 above).

Second, GSEJA’s references to Government Code Section 65302(h) and CEQA Guidelines Section 15131 (c) as “requiring” a project -level environmental justice analysis is incorrect for the following reasons:
• SB 1000 was adopted in 2016 to promote environmental justice through local land use planning. The law requires local governments with disadvantaged communities in their planning areas to develop environmental justice policies as part of their general plans. This requirement is triggered when a local government adopts or revised two or more general plan elements concurrently. Since the Pemcor Business Park does not involve revisions to the Menifee General Plan, SB 1000 does not apply to the project. The City notes that, in 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, in 2021, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element.

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• CEQA Guidelines Section 15131, Economic and Social Effects, states (emphasis added), “Economic or social information may be included in an EIR or may be presented in whatever form the agency desires.” Pursuant to CEQA Guidelines Section 15005, Terminology, the use of the word “may” identifies “a permissive element which is left fully to the discretion of the public agencies involved” in the CEQA proces s. Thus, this section does not require the City to include an environmental justice analysis in the EIR. Se parately, Subsection (c) sets forth that economic, social, and housing factors shall be considered together with technological and environmental factors “in deciding whether changes in a project are feasible to reduce or avoid significant environmental effects.” As explained in Response G-1 and G -2 and referenced materials, the Menifee Pemcor Business Park EIR constitutes a. fact -based evaluation of the proposed Project that fully identifies and discloses the Project’s potential air quality and GHG impacts and identifies feasible measures given the project’s specific technological, environmental, economic, social, and other factors.

Response G-4: GSEJA asserts the project continues decades of environmental racism systematically concentrating pollution facilities in communities of color while protecting affluent areas, refers to the Inland Empire as a “sacrifice zone” for working class-families and communities of color, and provides CalEnviroScreen on environmental and health burdens for census tract 6065043279. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explaine d in the MIG memorandum responding to those comments, the Draft EIR discloses pertinent environmental justice information, adequately evaluates all project emissions sources, and concludes, based on substantial evidence, that the project would not result in substantial pollutant concentrations at sensitive receptor locations. Furthermore, GSEJA’s generalized comments on the land use patterns in the Inland Empire as whole may not be construed on the nature of development in Menifee, which incorporated in 2008, nor the project’s census tract, which is not a disadvantaged community, specifically.

Response G-4.1: The commenter assumes the site must be used for housing but in fact the EDC-SG designation allows housing but does not require it. This designation is primarily intended to generate jobs/employment with housing only helping to support those uses and help reduce trip lengths between residential and non-residential uses in the area. In addition, the City’s Housing Element does not depend on the maximum or any housing being constructed on parcels within the EDC -SG category and is only a small part of the City’s vacant land survey as part of the Housing Element. The Housing Element identifies more vacant land sites for potential residential units than are needed to meet the City’s Regional Housing Needs Assessment (RHNA) allocation from SCAG during the period of the most recently updated Housing Element (6th Cycle, 2021 to 2029). The City has complete discretion as to where it encourages or allows future Item Title: 11.1
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housing to be built, as well as how it implements its approved Housing Element. Thus, the City may approve a development with anywhere from 487 down to zero residential units on the Project site under the mixed -use EDC-SG designation. There has been no zoning change to the mixed-use EDC-SG designation, there is no evidence that there is in fact a decrease on residential capacity in the EDC-SG zone, and therefore no violation of SB 330 or SB 8. Therefore, the project does not result in any “housing violations”.

Response G-5: GSEJA submits comments regarding the adequacy of the EIR’s evaluation of the project’s consistency with certain Menifee General Plan goals and policies, however, as described in more detail below, the project would not conflict with the General Plan policies identified by GSEJA.
• Policy S-7.1. GSEJA correctly identifies that asserts this policy calls for the City to “continue to require environmental analysis for proposed projects that may produce harmful levels of greenhouse gas”. Consistent with this policy, the Notice of Preparation prepared for the project identified greenhouse gases (GHG) as a potential environmental effect of the project, which was subsequently evaluated in project EIR.

Thus, the City has, in fact, conducted the environmental analysis required by Policy S-7.1.

• Policy EJ -3.6. This policy states, “Continue to collaborate with the [SCAQMD], California Air Resources Board (CARB), utility providers, Southern California Association of Governments (SCAG), Western Riverside Council of Governments (WRCOG), and nonprofit organizations, neighborhood groups, and other community organizations to improve air quality, food availability, renewable energy systems, sustainable land use and reduce [GHGs].” GSEJA purports the project conflicts with this policy because the project wo uld degrade air quality. GSEJA is mistaken. As discussed in Draft EIR Section 4.3.4, Air Quality Impacts and Mitigation Measures, the proposed Project would not result in any significant and unavoidable air quality impacts. Furthermore, as stated on Draft EIR page 6 -2, “In developing its CEQA significance thresholds, the SCAQMD considered the emission levels at which a project’s individual emissions would be cumulatively considerable (SCAQMD, 2003; page D-3). The proposed project’s construction and operatio nal emissions would be below applicable SCAQMD regional thresholds for criteria air pollutants after the incorporation of recommended Mitigation Measure AQ -1. Therefore, the proposed project would not result in a cumulatively considerable increase in crite ria air pollutants.” Thus, the Project would not degrade air quality. Furthermore, the City provided each of the agencies and organizations identified in Policy EJ -3.6 with the opportunity to comment on the EIR and, therefore, did provide the SCAQMD and CARB with the opportunity to collaborate on the project. For these reasons, the project would not conflict with Policy EJ-3.6.

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• Goal OSC -10. GSEJA purports that Goal OSC -10 “mandates” GHG emissions reductions, which the project conflicts with because it increases GHG emissions. As a point of clarification, General Plan Goal OSC -10 states, “An environmentally aware community that is responsive to changing climate conditions and actively seeks to reduce local greenhouse gas emissions.” In the case of the proposed project, the City has incorporated Mitigation Measures (MM)-GHG-1 to GHG-4 to reduce the project’s GHG emissions levels. The project, therefore, is consistent with Goal OSC-10.

• Policy C-5.3. GSEJA purports that the project conflicts with this policy because it was add 239 daily truck trips; however, Policy C -5.3 states, “Support efforts to reduce/eliminate the negative environmental impacts of goods movement.” As discussed in Draft EIR Section 4.17.4, the project would not result in any potentially significant transportation-related impacts, with Impact TRANS -1 finding the project would be consistent with all applicable goals and policies of the General Plan Circulation Element. Thus, the project would not have any negative circulation effects that require mitigation. While the type and size of the project results in significant GHG emissions compared to the City’s 3,000 MTCO2e threshold, GHG mitigation measures are included to help reduce project GHG emissions while improving the city’s ability to move goods throughout the region.

Response G-5.1: The following responses regarding VMT are from the Final EIR as prepared by Ganddini:

FEIR Response H-18
This comment claims that the project VMT screening assessment is inaccurate because the WRCOG VMT Tool results for TAZ 1053 are based on conditions as of 2012, which would not have included any warehousing uses.

First, this comment incorrectly references a 2012 model scenario associated with the Riverside County Transportation Analysis Model (RIVTAM), which has now been superseded by the Riverside County Model (RIVCOM). The WRCOG VMT Tool used for the project screening assessment is based on a more recent update, which incorporates the latest RIVCOM data and includes 2018 and 2045 model scenarios.

Furthermore, additional review of the socio-economic data (SED) for the RIVCOM 2018 model scenario shows that TAZ 1053 includes 369 total employment, including 110 employees in the transportation and warehousing sector. Therefore, the latest WRCOG VMT Tool, as used for the project screening assessment, includes SED inputs associated with comparable land uses to the proposed land use such that it is expected to provide a reasonable estimate of the project VMT impacts and there is nothing unique about the Item Title: 11.1
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project, or the project TAZ, that would otherwise be mis -represented by utilizing the data from the WRCOG VMT Tool.

FEIR Response H-20
This comment quotes the WRCOG SB 743 Implementation Pathway Document Package, which was developed by WRCOG in 2019 as a guidance document to help member agencies implement SB 743. While this document may include general information, the City of Menifee, as the Lead Agency, has ultimate authority in establishing the applicable methodology and thresholds as set forth in the City of Menifee Traffic Impact Analysis Guidelines for Vehicle Miles Traveled (Adopted June 3, 2020, Updated January 2022).

The comment incorrectly describes the threshold of 33.6 VMT per service population as the Citywide average rather than the County average and omits the full quote from the WRCOG SB 743 Implementation Pathway Document Package, which is as follows:
“OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold [emphasis added].” These omissions downplay the intent of the WRCOG SB 743 Implementation Pathway Document Package to serve as an early guidance document for member agencies and that other thresholds may also be appropriate. The comment further omits that the WRCOG SB 743 Implementation Pathway Document Package contains additional thresholds for consideration (see “Thresholds Assessment” included in the Executive Summary), as follows:
“Potential VMT thresholds were assessed within the context of the objectives of SB 743, legal opinions related to the legislation, proposed CEQA Guidelines updates, and the technical advisory produced by OPR. Fehr & Peers identified four threshold options for consideration by lead agencies.

1. Thresholds consistent with OPR’s Technical Advisory, recommending that proposed developments generate VMT per person that is 15% below existing VMT per capita,

2. Thresholds consistent with Lead Agency air quality, GHG reduction, and energy conservation goals,

3. Thresholds consistent with RTP/SCS future year VMT projects by jurisdiction or subregion, and

4. Thresholds based on baseline VMT performance by jurisdiction or sub-region [emphasis added].”
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The City of Menifee elected to adopt a threshold of significance that is a variation of the fourth option recommended by the WRCOG SB 743 Implementation Pathway Document Package. Therefore, the project’s VMT screening assessment provides substantial evidence in accordance with the appropriate methodology and thresholds established by the City of Menifee, as the Lead Agency, to support a finding of less than significant VMT impact; no revisions to the EIR are necessary.

Conclusion: As noted above and also in FEIR Responses H-18 through H-20, the VMT analysis was conducted in full conformance with City-established methodologies and no revisions to the EIR or VMT technical report prepared by Ganddini Group are necessary.

Response G-5.2: The project site is adjacent to Zeiders Road and the two access points created for the Project and shown on the site plan avoid sharp curves or dangerous intersections. The two access points were identified by City staff based on fire and police department emergency access requirements. The site was modeled using standard WB67 (72’) sized truck trailers to eliminate any site access limitations. The City Engineering Department evaluated truck turning radii in its review of the Project site plans and did not identify any conditions around any of the Project buildings requiring modifications to the site plan in terms of safe truck access. Project Plan Sheet C07 shows the fire truck radius and Sheet AS1 shows truck turning movements in grey scale.

Relative to emergency access, the site plan shows two full width driveways onto Zeiders Road capable of allowing access for emergency vehicles without the use of a Knox box which can incrementally slow response time. In addition, there is adequate travel lanes around all of the Project buildings wide enough to allow police and fire vehicles unrestricted access. FEIR Response H-24 indicates the site not only has unobstructed horizontal views of Zeiders Road but also no significant elevational (vertical) site distance issues as well. Therefore, the Project has no significant impacts relative to geometric design features and emergency access.

Response G-6: GSEJA re -submits comments on the potential cumulative impacts associated with the concentration of industrial parks in Menifee that are substantially the same as GSEJA submitted on November 11, 2025. The City notes that the Draft EIR discloses there are five existing and planned light industrial facilities within one-quarter mile of the project site, and fully evaluates the potential cumulative air quality, traffic, and other impacts of the proposed project. GSEJA has not submitted any new substantial evidence that demonstrates the proposed project would result in a significant cumulative environmental impact, has not clarified the geographic scope for its cumulative impact assumptions, and has not provided the sources for its employment growth projections.

The appellant is directed to the MIG memorandum responding to GSEJA’s November 11, 2025 comments for additional information on the EIR’s cumulative impacts analysis.

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Response G-7: GSEJA re-submits comments on the technical adequacy of the EIR’s air quality analysis that are substantially the same as SWAPE submitted on September 19, 2025.
• As explained in the Final EIR (Response H -35), changes to the project’s modeled fleet mix were made based on site -specific information from the traffic analysis prepared for the project.

• As explained in the Final EIR (Response H-34), the City revised the EIR’s air quality modeling to use a 25.4 mile haul trip distance as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H -36), the City revised the EIR’s health risk assessment to use a Fraction of Time at Home (FAH) of 1 for individuals from the third trimester to age 16 as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H-32), Phase I/II information compiled for the project indicates it is unlikely biosolids containing polyfluoroalkyl substances (PFAS) were deposited at the project site in the past. GSEJA has not submitted any new substantial evidence to indicate PFAS are present at the project site.

Response G-8: GSEJA states the health risk assessment (HRA) prepared for the EIR is deficient because it did not consider multi -pollutant effects, elevated baseline conditions, vulnerable populations, and cumulative impacts. As noted in Response G-2, the EIR clearly discloses the project’s setting with regard to environmental burdens and socioeconomic conditions, and the City considered this information in its assessment of the project’s potential air quality impacts. Furthermore, the HRA is not deficient. The HRA was conducted in accordance with SCAQMD and OEHHA recommended guidance and reflects a conservative analysis of potential health risks on sensitive populations for the following reasons:
• As explained in the Draft EIR (p. 4.3 -25 and Appendix E, pp. 4 -5 and 4-8), the diesel HRA is based on estimated ground level concentrations of PM 10 instead of PM2.5. While PM 2.5 is a subset of PM 10, use of the PM 10 fraction results in the modeling and assessment of risks on a larger share of particulate pollutants than would occur using the PM2.5 fraction. It should be noted there would be other risks from other pollutants but that DPM is the primary pollutant of concern. This is the reason multi-pollutant risks are not addressed in this analysis.

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• As explained in the Draft EIR (Appendix E, Section 4.2.4) and Final EIR (Response C-5), construction diesel particulate matter (DPM) emissions would be the primary driver of health risks when combining construction and operational related emissions. The excess cancer risk estimate at the MEIR assumes the receptor is an infant (including 3rd trimester) for the first 2 years of exposure and then develops to a child and finally to an adult over the next 28 years of exposure. As shown in Table 4 -18 of Appendix E, the modeled annual average DPM concentrations in construction years 1 and 2 are substantially higher than years 3 through 30. Thus, assuming all early life stages occur during these exposure years results in the most conservative estimate of potential adverse health risks.

• As noted in Response G-7, the FEIR revised the HRA to set the fraction of time at home to 1, even though this change was not required pursuant to SCAQMD or OEHHA guidance. Thus, the HRA conservatively assumes receptors are exposed to modeled pollutants 24 hours per day and nearly 365 days per year.

The above assumptions serve to provide a conservative (i.e., likely to overestimate) potential adverse carcinogenic and non-carcinogenic health risks that could potentially be associated with project emissions. As documented in the EIR, the project’s potential carcinogenic and non-carcinogenic health risks would be less than significant even with these health protective assumptions incorporated into the modeling and assessment methodology. Finally, the Draft EIR (p. 4.3 -26) included an evaluation of cumulat ive health risks impacts and concluded this impact would be less than significant. For these reasons, the appellant has not provided substantial evidence that supports the assertion that the EIR’s HRA is deficient.

Response G-9: GSEJA generally asserts that the City rejects feasible mitigation measures to reduce GHG emissions but does not provide any substantial evidence to support its assertion. GSEJA’s comments are substantially the same as that submitted by SWAPE on September 1 9, 2025, and by Supporters Alliance for Environmental Responsibility (SAFER) on November 12, 2025. The appellant is directed to the Final EIR Response H-38, and to Response S-3 above for detailed responses on why the measures suggested by GSEJA are not feasible for the project.

Response G-9.1: Alternatives. As outlined in FEIR Response H -25, the EIR did select a reasonable range of alternatives given the General Plan land use designation and zoning classification of the site, as well as the identified significant impacts of the proposed Project (air quality and greenhouse gas emissions). In addition to t he No Project – No Development Alternative, one of the alternatives is less intense development (Alternative 1, -25%) but similar development to the proposed Project which is in keeping with selecting alternatives that could reduce or eliminate the Item Title: 11.1
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significant impacts of the Project but also meet all or at least to some degree the objectives of the Project.

The introductory sections go into detail about the possible range of alternatives that could have been studied (Section 5.2, No Project Alternatives and Alternatives Considered But Rejected). The General Plan designation for the site (EDC -SG) could allow a wide range of potential residential and non-residential land uses. However, many of these would be mixed use projects based on the General Plan land use designation for the site which does allow certain residential and other non -residential uses.

Alternative 2 – EDC Mixed Use (C/LI/MFR) would provide 75,000 square feet of retail commercial space, 150,000 square feet of light industrial space, and 400 apartments (20 acres x 20 units/acre). Alternative 3 – EDC Mixed Use (O/BP/R) would provide 100,000 square feet of office space, 100,000 square feet of business park uses, and 300 “for ownership” condominiums (20 acres x 15 units/acre).

City staff considered various mixes of these land uses but knowing that a substantial amount of commercial use would generate substantial amounts of traffic, and a substantial amount of residential units in this area would not be compatible with non - residential uses surrounding the project site. In the end the City selected these alternatives as the most reasonable range of alternatives that could reduce or eliminate one or more of the Project’s significant impacts. Due to the size of the site, no reasonable development-related project was found that could eliminate the one significant impact of the project (GHG emissions) and the two mixed use alternatives actually resulted in significant air quality impacts as well.

Based on the size of the site, it is likely no level of urban development allowed by the General Plan and zoning on this site would reduce potential GHG emissions to less than significant levels due to the City’s relatively low adopted GHG significance thr eshold (3,000 MTCO2e).

FEIR Alternative 1 would not achieve the goals of the Project to the same degree as the proposed Project, and FEIR Alternatives 2 and 3 even less so since they further reduce non-residential development in favor of added residential development. In the end Alternative 1 was selected as the “Environmentally Superior Alternative.” After reviewing this response, the commenter proceeded to suggest five different alternatives to reduce GHG emissions which w as the lone significant impact of the project:
• Zero-Emission Logistics Alternative: All-electric operations with solar canopies and battery storage. The primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to Item Title: 11.1
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support a diverse employment base. Logistics warehousing is not consistent with that primary objective but certainly efforts to achieve or strive toward zero emissions would help reduce GHG emissions, possibly even below the City’s 3,000 MTCO2e significance threshold.
• Light Manufacturing Alternative: Lower truck traffic, higher employment density .

As stated above, the primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to support a diverse employment base. Focusing on only one aspect of this development category would unduly limit the diversity of future employment in this center, but any land use changes that would reduce truck traffic would incrementally reduce GHG emissions as well.
• Mixed-Use Transit -Oriented Alternative: Incorporating affordable housing near future transit. Zeiders Road will eventually have transit service so it would be possible to add market-rate or affordable housing in this area to take advantage of future transit. However, the DEIR did examine two alternatives that included different forms of housing and determined that the addition of residential uses would substantially increase anticipated traffic which in turn would increase air pollutant and GHG emissions.
• Phased Development Alternative: Allowing technology improvements before full buildout. The business park project has 11 separate buildings with a variety of potential uses (light industrial, manufacturing, office) which will practically result in a phased development or occupancy of future uses. However, it is more difficult to require multi-tenant developments to implement “future technology” since it is unknown what such technology will be and if or how various uses could implement such technology.
• Community-Serving Commercial Alternative: Retail, services, and amenities for residents. Section 5 of the DEIR explained that any alternatives that included a high proportion of commercial uses would substantially increase project traffic and thus increase GHG emissions. Therefore this is not a feasible alternative compared to the proposed project.

The commenter concludes that “the City's claim that no alternative could eliminate GHG impacts due to the 3,000 MTCO2e threshold is defeatist and incorrect -a zero-emission facility with renewable energy could achieve carbon neutrality. ” The EIR did propose mitigation measures to help reduce GHG emissions including a Transportation Demand Management (TDM) Plan for future uses to reduce their vehicle miles travelled (VMT) impacts. The project includes allowance for future rooftop photovolta ic solar panels depending on the specific future use/user.

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Response G-10: GSEJA submits a general assertion that the City has dismissed “California Department of Justice recommendations” without adequate analysis.

Assuming that GSEJA is referring to the Department of Justice’s (DOJ) guidance document “Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act,” this comment is similar to other comments submitted by the South Coast Air Quality Manageme nt District, the Golden State Environmental Justice Alliance (GSEJA), and Advocates for the Environment on the Draft EIR. As explained in Final EIR Responses C-6, C-9, H-38, and I-9, the City has reviewed the referenced document and determined that many of the best practices in the document are commensurate with the requirements of existing regulations and/or the mitigation measures incorporated into t he EIR. The EIR has incorporated feasible measures to reduce GHG emissions, and the additional recommendations made by the appellant are either not feasible for the project or not necessary to address an identified significant impact.

Response G-10.1: The City provides Spanish language translation services at meetings and for critical public documents, however, the City has determined that CEQA documents are not essential public documents per state law. In this case, neither the project site nor the immediate surrounding area is consider ed a disadvantaged community in need of focused language services relative to this project (see Response G-2 above). In addition, it should be noted that no comments were received during the NOP/Scoping period, the Draft EIR review period, or subsequently at the Planning Commission indicating a need or desire for the CEQA documents for this project to be provided in Spanish.

Response G-10.2: The commenter stated the city’s public notices failed to:
• Identify the site as in a disadvantaged community. As discussed in Response G-2 above, the project site and immediate surrounding area are not within a disadvantaged community.
• Disclose the 93rd percentile cardiovascular disease burden. The appropriate area- specific information from the CalEnviroScreen website was provided in DEIR Section 3.3, Air Quality.
• Mention cumulative impacts from surrounding warehouses. Potential contributions of the proposed project to cumulative impacts were discussed in each of the environmental analysis sections of the DEIR (4.1 through 4.20) and, other than greenhouse gas emissions, the project was not found to make a substantial contribution to any significant cumulative regional impact. Specifically, the Draft EIR (p. 4.3 -26) included an evaluation of cumulative health risks impacts and concluded this impact would be less than significant.

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• Provide health risk information in lay terms . DEIR Section 4.3, Air Quality, describes the health effects of various air pollutants and goes into great detail about the potential health risks of the proposed project. • Offer resources for technical assistance to residents. It is not clear what “technical assistance” has not been made available to local residents regarding the planning or environmental processes for this project. The project planner, Russell Brown, was contacted by and discussed project characteristics with only one local resident during the NOP and EIR review process. No other related services were requested.

Response G-10.3: The commenter indicated the following regarding the City’s previous responses to their earlier comments on the DEIR:
• Dismissive tone toward environmental justice concerns . The commenter is not clear about this comment but the DEIR and FEIR both demonstrate the project is not within a disadvantaged community so that it is possible the commenter considered this a “dismissal” of its overall concerns regarding EJ. That is not t he case as the City has actually incorporated a number of EJ goals and policies into various elements of its recently updated General Plan.
• Reliance on technicalities rather than substantive analysis. It is not clear to which sections or analyses the commenter was referring but the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and opinions.
• Failure to provide requested data and calculations. Not clear what is meant but as indicated above, the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and opinions. The misposting of Appendices E and L -2 have been explained and the 45-day public review period was extended to allow full review time for the DEIR and its appendices once the appendices were posted. All of the calculations for air quality and greenhouse gas emissions were provided in the appendices and summarized in the DEIR sections.
• Mischaracterization of legal requirements. Again, the commenter did not explain particulars of this comment and all of their comments regarding various legal CEQA requirements were addressed in FEIR (response to comments and errata sections), and subsequent response to comments memos (including this one). • Refusal to consider feasible mitigation. The DEIR did consider feasible mitigation, and the FEIR and subsequent response to comments memos (including this one) indicate a desire to accommodate the recommended additional or expanded mitigation to the extent practical or feasible which is all expl ained in the various CEQA documents as appropriate.

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Response G -10.4: The commenter indicated t he FEIR fail ed to analyze economic impacts on the disadvantaged community. Again, it must be made clear the project site and surrounding properties are not located within a disadvantaged community (see Response G-2 above).

Job Quality Analysis Absent:
• No wage data for proposed 553 jobs. CEQA does not involve the evaluation of fiscal impacts such as wages unless a clear connection to adverse physical changes to the environment can be shown. In this case, the commenter did not suggest one other than a supposed link to a disadvantaged community. The DEIR and FEIR clearly indicated the site and surrounding properties are not within or part of a disadvantaged community. Even if such data was requ ested/required by the City and/or CEQA, it would be overly speculative to try to estimate specific wage data since this is a multi- tenant business park with no committed tenants yet.
• No comparison to living wage standards . As outlined above, specific wage data is not required by the City or CEQA and in this case is overly speculative since none of the actual tenants have been identified yet.
• No analysis of benefits availability. The project is consistent with the General Plan and zoning so no specific community benefits are required as part of development, and the commenter did not explain the purpose or content of such an analysis. • No local hire requirements. At most this is a potential planning consideration of the project approval process and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific local hiring requirements for such projects.
• No job training partnerships. This is a potential planning consideration of the project approval process at most and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific requirements for such projects regarding job training partnerships.

Displacement Impacts ignored:
• Property value impacts from industrial encroachment. There is no “encroachment” since the project is consistent with the General Plan and zoning designations and only one vacant farmhouse is being removed by this project.
• Small business displacement from truck traffic . The commenter did not clarify the intent of this comment so it is not clear what if any displacement of small businesses might occur from project -related truck traffic. In any case, such financial effects of project planning are not considerations under CEQA which focuses on physical changes to the environment.

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• Residential displacement from cumulative impacts. No evidence was presented that critical housing, existing or planned, would be displaced by development of the project or other cumulative development.
• Loss of land for community -serving uses . The project site has a General Plan designation and zoning classification of “Economic Development Corridor -Southern Gateway” designation (EDC-SG) which allows for a mixture of specific uses as part of the “mixed use” land use grouping (i.e., light industrial, manufacturing, office, and residential in support of non -residential uses). The selection of land uses under the mixed use category necessari ly means some uses will be chosen over other uses.

Since the project is consistent with the General Plan and zoning, the General Plan EIR addressed the potential land use and other environmental impacts of this land use selection process.

Fiscal Impact omissions:
• Public health costs from increased pollution . The project is consistent with the General Plan and zoning designations of the site, and the potential environmental and health impacts of project air pollutant emissions were calculated and evaluated in DEIR Section 4.3, Air Quality, and the health risk assessment outlined in DEIR Section

4.3.4, Impacts b and c. CEQA does not involve the evaluation of fiscal impacts unless a clear connection to adverse physical changes to the environment can be shown. • Infrastructure wear from truck traffic . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed. CEQA does not involve the evaluation of fiscal impacts unles s a clear connection to adverse physical changes to the environment can be shown.
• Emergency service demands . Potential impacts of the project on emergency services were addressed in DEIR Section 4.17, Public Services (police and fire) including fiscal impacts related to development impact fees to help fund such services.
• Lost property tax from residential prohibition . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed.

Finally, CEQA does not involve the evaluation of fiscal impacts such as these unless a clear connection to adverse physical changes to the environment can be shown and the commenter provided no such connection.

Response G-11: Climate Vulnerability. GSEGA asserts the DEIR fails to analyze general climate vulnerability factors such as heat island effects, extreme heat events, etc. The appellant is directed to Draft EIR p. 4.8-4 and 4.8-5 for a discussion of potential climate change effects in California, Section 4.10.4 for a discussion of the project’s potential Item Title: 11.1
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hydrology, flooding, and water quality impacts, and Chapter 4.20 for setting and impact discussions related to wildfire. As a point of clarification, the EIR’s GHG analysis, including the project direct and indirect GHG emissions levels and consistency wit h applicable plans and policies adopted for the purposes of reducing GHG emissions, is a fact-based analysis of the project’s potential GHG and related climate change impacts.

This is because, as explained in the Draft EIR (p. 4.8-2), “Gases that “trap” heat in the atmosphere and affect regulation of the Earth’s temperature are known as ‘greenhouse gases’ . . .GHG that contribute to climate regulation are a different type of pollutant than criteria or hazardous air pollutants because climate regulation is g lobal in scale, both in terms of causes and effects . . . GHG emissions from human activities such as fuel combustion (e.g., CO2) and refrigerants use (e.g., hydrofluorocarbons, or HFCs) significantly contribute to overall GHG concentrations in the atmosph ere, climate regulation, and global climate change . . . The effects of increased GHG concentrations in the atmosphere include increasing shifts in temperature and precipitation patterns and amounts, reduced ice and snow cover, sea level rise, and acidific ation of oceans.

These effects in turn will impact food and water supplies, infrastructure, ecosystems, and overall public health and welfare.”
Response G-12: The City believes it has complied with the spirit (intent) as well as the legal and procedural requirements of CEQA and has made a good faith effort to provide a comprehensive detailed environmental information document for the public and decision-makers. The DEIR indicates the potential impacts of the project would not be unequally distributed onto at -risk populations or neighborhoods already bearing environmental burdens. The project is consistent with the General Plan and zoning designations, will only have one environmental impact that is significant and unavoidable even with mitigation (i.e., greenhouse gas emissions), and would benefit the community overall (see “Findings and Statement of Overriding Considerations”) when viewed in relation to its environmental impacts.

Response G -13: The commenter made a number of r ecommendations which was essentially the following laundry list of “requirements” the project should implement. It should be noted that many of these items appear to be related to the project’s supposed impacts to a disadvantaged neighborhood, but as the DEIR and FEIR clearly demonstrate, the project and surrounding properties are not within a disadvantaged community:

Zero-Emission Operations Timeline:
• 50% zero-emission (ZE) trucks by 2030. This project is a multi-tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their trucking fleet. This action would be implemented to the degree that new truck fleet operators will be required to buy zero emission trucks.

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• 100% zero-emission trucks by 2035. See response above regarding 50% ZE trucks by 2030. See response above relative to 50% zero emission trucks by 2030.
• Installation of charging infrastructure before occupancy . The project will install charging infrastructure required by the California Green Building Code and the City’s development requirements.
• Monthly emissions monitoring and public reporting. The project is not a logistics warehouse subject to the SCAQMD “Warehouse Actions and Investments to Reduce Emissions (WAIRE) Rule 2305 so monthly emissions monito ring and reporting is not required.

Community Health Protection:
• $5 million community benefit fund for health programs. The DEIR found no nexus or rough proportionality of project impacts that would require or suggest such a contribution since the air pollutant/health risk impacts of the project are less than significant under CEQA (only GHG emissions were found to be significant). • Indoor air filtration systems for nearby schools. As outlined in DEIR Section 4.9, Hazards and Hazardous Materials, there are no schools within a quarter mile of the project site and its air pollutant emissions would not exceed any SCAQMD or state (OEHHA) significance thresholds for health risks. Therefore, there is no nexus o r rough proportionality for imposing such a requirement on this project. • Community air monitoring network with real -time data. There is no nexus or rough proportionality to require such a measure for a project that is consistent with the GP and zoning and the EIR air quality assessment does not indicate it will result in significant air quality or health risk impacts. • Quarterly health impact assessments . See response above for community air monitoring network suggestion.

Local Hiring and Training:
• 50% local hire requirement (Menifee residents) . While the City may encourage new employers to hire local workers, it cannot mandate numerical hiring quotas.

In addition, the project is a multi -tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their individual hiring practices. This is also not a CEQA issue but the City may work with the applicant and/or future tenants to encourage local hiring practices.
• Partnership with community colleges for job training . This is not a CEQA issue but the City may work with the applicant and/or future tenants to encourage partnering with local community colleges for job training. • Living wage requirement ($25/hour minimum). The City cannot legally mandate wage requirements for future businesses since at present none have been selected for this multi-tenant business park.

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• Healthcare benefits for all employees . The City cannot legally mandate future tenants to provide healthcare benefits to their workers as those business practices are regulated by state and federal agencies and private insurance corporations.

Operational Restrictions:
• No operations between 10 PM and 6 AM . The City will enforce whatever appropriate operational hours limitations are established in its Municipal Code.

Since no tenants are currently identified, it is not possible to restrict or preclude future users from overnight activities.
• No idling beyond 3 minutes . The project is already subject to a 5 -minute idling limitation by City Conditions of Approval (COAs) consistent with SCAQMD recommendations. The appellant/commenter did not provide any support for imposing a more strict idling limit and the air quality ass essment for the project did not recommend a more stringent idling limit since air pollutant emissions were estimated to be less than significant.
• Designated truck routes avoiding residential streets . The City has established truck routes and mapping so trucks/drivers utilizing the proposed project will access the designated streets. The City will also impose a Condition of Approval (COA) restricting project trucks to designated truck routes and to inst all the necessary signage on the site for drivers to follow.
• Maximum 100 truck trips per day . DEIR Section 4.17, Transportation, did not identify any significant traffic -related impacts of the project related to either vehicle miles traveled (VMT) or levels of service (LOS) which is no longer considered a CEQA significance criteria for traffic impa cts. Therefore, there is no nexus or rough proportionality for requiring a daily truck traffic limit on the project.

Environmental Justice Compliance:
• Environmental Justice Advisory Committee (EJAC) with voting power. The City has an Environmental Justice Element (EJE) of its General Plan. However, CalEnviroScreen has not identified any disadvantaged communities within the City.

The EJE does not include an EJAC at this time and one would have to implemented at a City level and not for a particular development project. • Monthly compliance reports in English and Spanish. This would need to be a city- wide program as part of the EJE monitoring and it not currently in place. • Annual environmental justice impact assessment. This would need to be a city- wide program as part of the EJE monitoring and it not currently in place. • Community right to enforcement action . This would need to be a city -wide program as part of the EJE monitoring and it not currently in place.

Response G-14: The commenter/appellant states “the FEIR is fundamentally flawed and a new EIR must be prepared for the proposed project and circulated for public review. Appellant requests the City of Menifee City Council reverse the decision of the Item Title: 11.1
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Planning Commission's certification of the project and require a new EIR. ” The City believes the DEIR and FEIR comply with the intent and legal requirements of CEQA and do not require revision and recirculation or preparation of a new EIR.

CONCLUSION
Staff’s conclusion is the two appeal letters do not provide significant new information or identify new significant impacts or information regarding the project or the DEIR analysis.

City staff concludes the information provided in the Draft EIR, its appendices (including Appendices E and L for which the public was provided adequate time to review), the Final EIR and all response to comments and supporting materials adequately address all the issues and comments raised. Therefore, the EIR meets the requirements of CEQA and it and its technical studies do not need to be revised and recirculated for additional public review.

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RESOLUTION NO. 26-______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MENIFEE, CALIFORNIA DENYING APPEAL NO. PLN25-0208 SUBMITTED ON

BEHALF OF THE GOLDEN STATE ENVIRONMENTAL JUSTICE

ALLIANCE FOR THE MENIFEE (PEMCOR) BUSINESS PARK
PROJECT, PLOT PLAN NO. PLN23-0245
WHEREAS, on December 21, 2023, the project applicant, Pemcor Properties, Inc. (“Applicant”), filed a formal application with the City of Menifee for the approval of Plot Plan (PP) No. PLN23-0245 Menifee (Pemcor) Business Park Project, a business park development consisting of 11 single-story buildings ranging in size from approximately 23,100 square feet to 37,840 square feet (total 337,770 square feet) on approximately 20 acres. The site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road (APN: 384-150-001); and
WHEREAS, collectively, all the applications are referred to as the “Project” or “Menifee (Pemcor) Business Park Project”; and
WHEREAS, pursuant to the requirements of the California Environmental Quality Act (CEQA), a Final Environmental Impact Report (EIR) and Mitigation Monitoring Reporting Program (MMRP) have been prepared to analyze and mitigate the Project's potentially significant environmental impacts; and
WHEREAS, on November 12, 2025, at a legally noticed public hearing, the Planning Commission voted 4-0-1 (Ramirez abstain) to certify the EIR, Findings of Fact, Mitigation Monitoring and Reporting Plan (MMRP), and approve PP No. PLN23-0245 for the Project; and
WHEREAS, on November 19, 2025, an application to appeal Planning Commission certification of the EIR for the Project and approval of PP No. PLN23-0245 was submitted by the Golden State Environmental Justice Alliance (GSEJA); and WHEREAS, on January 21, 2026, the City Council of the City of Menifee held a public hearing on the appeal of the Planning Commission’s certification of the EIR and approval of PP No. PLN23-0245, considered all public testimony as well as all materials in the staff report and accompanying documents for the appeal, which hearing was publicly noticed by a publication in The Press Enterprise, a newspaper of general circulation, an agenda posting, notice to property owners within 1,000 feet of the Project boundaries, on-site posting at the Project site, and to persons requesting public notice.

NOW, THEREFORE, the City Council of the City of Menifee resolves as follows:

1. That the City Council finds the facts presented within the public record and within Exhibit “A” of the Resolution provides the basis to deny Appeal No. PLN25-0208.

2. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at the Community Development Department – Planning Division, 29844 Haun Road, Menifee, CA 92586. This information is provided in compliance with Public Resources Code section 21081.6.

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Appeal of Menifee (Pemcor) Business Park - GSEJA
January 21, 2026

Page 2 of 2 ends

PASSED, APPROVED AND ADOPTED this 21st day of January 2026. _________________________
Bob Karwin, Mayor Pro Tem
Attest:
______________________________
Stephanie Roseen, City Clerk
Approved as to form:
______________________________
Jeffery T. Melching, City Attorney
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CITY OF MENIFEE

APPEAL APPLICATION
Decision to be appealed: ______________
A
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hat result to you want? ___________________________________________________________________ Applicant’s Signature ______________________________________________ Date: _________________ Owner Certification: I certify under the penalty of the laws of the State of California that I am the property owner of the property that is the subject matter of this appeal application . I am authorizing and hereby do consent to the filing of this application and acknowledge that the final approval by the City of Menifee, if any, may result in restrictions, limitations and construction obligations being imposed on this real property.

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PLN23-0245
Supporters Alliance for Environmental Responsibility (SAFER) 510-836-4200
510-836-4205
[email protected]
1939 Harrison Street, Suite 150 Oakland, CA 94612
Pemcor Properties, Inc. (Applicant)
604-687-1818
[email protected]
P.O. Box 903 Rancho Santa Fe, CA 92067
Menifee Business Park, APN: 384-150-001, 33521 Zeiders Road Menifee, CA 92584 Planning Commission
November 12, 2025
Decision to approve the project, certify the
Environmental Impact Report ("EIR") (SCH 2024071016) and the MMRP prepared for the project, and adopt Plot Plan No. PLN23-0245.

X
Revision and recirculation of the EIR for the project before making any project approvals. 11/20/2025
Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 166

Menifee Mayor and City Council
January 21, 2026
Page
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November 12, 2025
Via Email
Randy Madrid, Chair
Ivan Holler, Vice Chair
Michael Knighten
Tammy Ramirez
Chris Thomas
Planning Commission
City of Menifee
29844 Haun Road
Menifee, CA 92586
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Russell Brown, Senior Planner
Planning Division
Community Development Department
City of Menifee
29844 Haun Road
Menifee, CA 92586
[email protected]
Re: SAFER Comment
Menifee Business Park Project
Environmental Impact Report - SCH No. 2024071016
Planning Commission Agenda Item 9.2 (Nov. 12, 2025)
To Chair Madrid, Vice Chair Holler, Honorable Commissioners, and Planner Brown:

This comment is submitted on behalf of Supporters Alliance For Environmental Responsibility (“SAFER”) and its members living or working in and around the City of Menifee (“City”) regarding the Menifee Business Park Project (“Project”) to be heard as Agenda Item 9.2 at the Planning Commission’s November 12, 2025 mee ting.

SAFER is concerned that Project’s Environmental Impact Report (“EIR”), consisting of the Draft EIR (“DEIR”) released in August 2025 and Final EIR (“FEIR”) released in October 2025, is inadequate under the California Environmental Quality Act (“CEQA”) due to its failure to require all feasible mitigation measures for the Project’s significant and unavoidable greenhouse gas impact. Furthermore, the EIR makes multiple references to a Transportation Demand Management Assessment prepared by Ganddini Group in 2025 that was not included with the DEIR or the FEIR. SAFER also joins in the comments submitted on behalf of Golden Item Title: 11.1
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SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025

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State Environmental Justice Alliance and Advocates for the Environment.

SAFER respectfully requests that the Planning Commission refrain from approving the Project and its EIR at this time. Instead, SAFER requests that the Commission continue further consideration of this Project until: (1) the City fully considers additional feasible mitigation measures to reduce the Project’s greenhouse gas impacts, as required by CEQA and (2) the City makes the 2025 Ganddini Report available for public review.

PROJECT DESCRIPTION
The Project proposes a commercial/industrial business park consisting of 11 single-story buildings ranging in size from approximately 23,100 square feet to 37,840 square feet (total 337,770 square feet) on an approximately 20-acre site. The anticipated end users are expected to provide services ranging from industrial and manufacturing users to service commercial and office (tenants are not known at this time). The Project will provide 677 surface parking spaces and two dock-high doors on each building.

The 20-acre Project site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road.

Currently, the site contains a single-family home, which will be demolished as part of the Project. The Project site is surrounded by rural residences to the north, west, and south, and light industrial land uses to the west.

LEGAL STANDARD
CEQA requires that an agency analyze the potential environmental impacts of its proposed actions in an EIR (except in certain limited circumstances). (See, e.g., Pub. Resources Code, § 21100.) The EIR is the very heart of CEQA. (Dunn-Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Environment v. Cal. Resources Agency (2002) 103 Cal.App.4th 98, 109 (CBE v. CRA).) CEQA has two primary purposes. First, CEQA is designed to inform decision makers and the public about the potential, significant environmental effects of a project. (14 CCR § 15002(a)(1).) “Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR ‘protects not only the environment but also informed self-government.’” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.) The EIR has been described as “an environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.” (Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal.App.4th 1344, 1354 (Berkeley Jets); County of Inyo Item Title: 11.1
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PC Agenda Item 9.2 (Nov. 12, 2025)
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v. Yorty (1973) 32 Cal.App.3d 795, 810.)
Second, CEQA requires public agencies to avoid or reduce environmental damage when “feasible” by requiring “environmentally superior” alternatives and all feasible mitigation measures. (14 CCR § 15002(a)(2) and (3); see also Berkeley Jets, 91 Cal.App.4th at 1354; Citizens of Goleta Valley, 52 Cal.3d at 564.) The EIR serves to provide agencies and the public with information about the environmental impacts of a proposed project and to “identify ways that environmental damage can be avoided or significantly reduced.” (14 CCR § 15002(a)(2).) If the project will have a significant effect on the environment, the agency may approve the project only if it finds that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns.” (Pub. Res. Code, § 21081; 14 CCR § 15092(b)(2)(A) and (B).)
While the courts review an EIR using an “abuse of discretion” standard, “the reviewing court is not to ‘uncritically rely on every study or analysis presented by a project proponent in support of its position. A ‘clearly inadequate or unsupported study is entitled to no judicial deference.’” (Berkeley Jets, 91 Cal.App.4th at 1355 [quoting, Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal. 3d 376, 391, 409, n. 12.) “A prejudicial abuse of discretion occurs ‘if the failure to include relevant information precludes informed decisionmaking and informed public participation, thereby thwarting the statutory goals of the EIR process.’” (Berkeley Jets, supra, 91 Cal.App.4th at 1355.) An EIR must “include[] sufficient detail to enable those who did not participate in its preparation to understand and to consider meaningfully the issues the proposed project raises.” (Sierra Club v. Cty. of Fresno (2018) 6 Cal.5th 502, 510.) “Whether or not the alleged inadequacy is the complete omission of a required discussion or a patently inadequate one- paragraph discussion devoid of analysis, the reviewing court must decide whether the EIR serves its purpose as an informational document.” (Id. at 516.) “The determination whether a discussion is sufficient is not solely a matter of discerning whether there is substantial evidence to support the agency’s factual conclusions.” (Id.) As the Court emphasized:
[W]hether a description of an environmental impact is insufficient because it lacks analysis or omits the magnitude of the impact is not a substantial evidence question.

A conclusory discussion of an environmental impact that an EIR deems significant can b e determined by a court to be inadequate as an informational document without reference to substantial evidence.
(Id. at 514.)
In general, mitigation measures must be designed to minimize, reduce or avoid an identified environmental impact or to rectify or compensate for that impact. (14 CCR § 15370.) Where several mitigation measures are available to mitigate an impact, each should be discussed and the basis for selecting a particular measure should be identified. (14 CCR § Item Title: 11.1
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15126.4(a)(1)(B).) A lead agency may not make the required CEQA findings unless the administrative record clearly shows that all uncertainties regarding the mitigation of significant environmental impacts have been resolved.

DISCUSSION
I. The EIR Fails to Adopt All Feasible Mitigation Measures for the Project’s Significant and Unavoidable Greenhouse Gas Impacts.

CEQA prohibits a lead agency from approving a project with significant environmental effects if there are feasible mitigation measures or alternatives that can substantially lessen or avoid those effects. (Pub. Res. Code § 21002; Mountain Lion Found. v. Fish & Game Comm’n (1997) 16 Cal.4th 105, 134; Laurel Heights, 47 Cal.3d at 403 [“The chief goal of CEQA is mitigation or avoidance of environmental harm”].) CEQA defines “feasible” as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors.” (PRC §21061.1; 14 CCR § 15364.) “The core of an EIR is the mitigation and alternatives sections.” (Citizens of Goleta Valley, 52 Cal.3d at 564.) When an EIR concludes that a project will have significant impacts, the lead agency has two duties: to meaningfully consider feasible mitigation measures and alternatives, and to identify mitigation measures and alternatives rejected as infeasible. (See Preservation Action Council v. City of San Jose (2006) 141 Cal.App.4th 1336, 1353.) The lead agency may not approve a project with significant impacts unless it makes one or more of three findings:
(1) that changes or alternations have been required in, or incorporated into, the project that mitigate or avoid the significant effects on the environment; (2) that the agency making the findings lacks jurisdiction to make the change, but that another agency does have such authority, and either has made or can and should make, the change; and/or
(3) that specific economic, legal, social, technological, or other considerations … make infeasible the mitigation measures or project alternatives identified in the EIR. (Pub. Res. Code §21081(a); 14 CCR §15091(a.).)
When a comment suggests “better ways to avoid or mitigate the significant environmental impacts” (14 CCR §§15088(c), 15204(a)), the lead agency must respond to the comment by either explaining why further consideration of the alternative or mitigation was rejected or by providing an evaluation of the alternative. (Marin Mun. Water Dist. v. KG Land Cal. Corp. (1991) 235 Cal.App.3d 1652, 1666; Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 992 (CNPS).) “‘[A]n adequate EIR must respond to specific Item Title: 11.1
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suggestions for mitigating a significant environmental impact unless the suggested mitigation is facially infeasible.’ [citation omitted] ‘While the response need not be exhaustive, it should evince good faith and a reasoned analysis.’” (CNPS, 177 Cal.App.4th at 992 [citing L.A. Unified School Dist. v. City of L.A. (1997) 58 Cal.App.4th 1019, 1029; see also, Citizens for Quality Growth v. City of Mount Shasta (1988) 198 Cal.App.3d 433, 442, fn. 8.) The EIR concludes that the Project will result in significant and unavoidable greenhouse gas (“GHG”) impacts. (FEIR, p. 3-4.) The EIR explains,
The primary source of the project’s unmitigated GHG emissions (8,537 MTCO2e, approximately 82% of overall emissions) would be attributable to mobile sources (i.e., passenger vehicles and truck trips). Building energy use is the second highest source of project GHG emissions, accounting for approximately 14% of operational GHG emissions.
(FEIR, Appendix E, p. 6-4.)
The EIR then claims that these emissions have been mitigated to the extent feasible through four mitigation measures: (1) VMT/TDM Reduction Plan (MM-GHG-1); (2) Tier 2 EV Parking (MM-GHG-2); (3) All-Electric Operation (MM-GHG-3); and (4) Solar panels on 15% of total roof tops (MM-GHG-4). (FEIR, pp. 3-3 to -4.)
As an initial matter, MM-GHG-1 and MM-GHG-3 are inadequate under CEQA because they fail to ensure that GHG impacts will actually be mitigated. MM-GHG-1 states that the VMT/TDM Reduction Plan is “intended to achieve a 6.2% reduction goal starting one year after 90% occupancy is achieved.” (FEIR, p. 3-3.) However, MM-GHG-1 also states that, if a 6.2% reduction is not met, “the developer or POA shall expand existing or add new programs the following year to increase employee participation.” (Id.) There is simply no guarantee that future unspecified measures will meet and 6.2% reduction. As a result, MM-GHG-1 is a textbook example of deferred mitigation that is not permissible under CEQA. (See, e.g., Save the Agoura Cornell Knoll v. City of Agoura Hills (2020) 46 Cal.App.5th 665, 688, 693; League for Protection of Oakland’s Architectural & Historic Resources v. City of Oakland (1997) 52 Cal.App.4th 896; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1396.) MM-GHG-3 is similarly deficient in that it purports to require that “all building energy systems, equipment, and appliances be powered by electricity” but at the same time states that “[t]he proposed structures shall be dual-plumbed with electricity and natural gas, and tenants shall be able to use natural gas should they be able to demonstrate an all-electric alternative is unavailable or infeasible.” (FEIR, p. 3-4.) The EIR cannot claim that it is mitigating GHG impacts by requiring all-electric buildings while at the same time setting up the buildings to use natural gas.

Putting aside the inadequacy of MM-GHG-1 and MM-GHG-3, the EIR is fundamentally Item Title: 11.1
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Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
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deficient for failing to consider additional feasible mitigation measures for the Project’s significant and unavoidable GHG impacts. Because the Project’s GHG impacts remain significant and unavoidable even with incorporation of MM-GHG-1 through MM-GHG-4, the City must consider and require all feasible mitigation measures to reduce the impact to the extent feasible prior to proceeding with the Project. (Pub. Res. Code §21081(a); 14 CCR §15091(a.).) There is ample opportunity for the City to require additional feasible mitigation measures prior to approving this Project. For example, the EIR states that the Project will limit equipment/truck idling to 5 minutes in accordance with state law and the City’s general plan. (DEIR, pp. 4.6-20, 4.9-12.) The California Attorney General has issued a guidance document titled “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act” (“DOJ’s Best Practices”). A copy of the DOJ’s Best Practices is attached hereto as Exhibit A. The DOJ’s Best Practices explicitly state that operational impacts can be mitigated, in part, by “[f]orbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.” (DOJ’s Best Practices, p. 9.) Clearly, it is feasible to reduce idling time below 5 minutes—and the City must do so prior to concluding that GHG impacts are significant and unavoidable.

The DOJ’s Best Practices also recommends “[d]esigning all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible.” (DOJ’s Best Practices, p. 9.) Here, MM-GHG-4 requires solar panels on only 15% of the buildings’ rooftops. There is no discussion or analysis in the EIR of whether additional solar panels beyond 15% is feasible. The EIR must be revised to assess and require the maximum amount of feasible solar panels prior to concluding that GHG impacts are significant and unavoidable.

The DOJ’s Best Practices list numerous additional mitigation measures for GHG impacts that the EIR has failed to consider including:
• Requiring all on-site motorized operational equipment, such as forklifts and yard trucks, to be zero-emission with the necessary charging or fueling stations provided.
• Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
• Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager. • Running conduit to designated locations for future electric truck charging stations. • Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations.

Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 172

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January 21, 2026
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Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025

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(DOJ’s Best Practices, pp. 9-10.)
The City cannot approve the Project and its EIR until all feasible GHG mitigation measures have been applied to this Project, even if the Project’s GHG impacts remain significant and unavoidable. SAFER respectfully requests that the Commission continue further consideration of the Project until the EIR is revised to include all the mitigation measures discussed above or otherwise to justify why such additional mitigation measures are infeasible.

II. The EIR Relies on a 2025 Transportation Assessment that Either Does Not Exist or Has Not Been Made Available to the Commission or the Public.

The EIR references a Transportation Demand Management Assessment prepared by Ganddini Group on February 19, 2025 (“2025 Ganddini Report”) that has not been provided to the Planning Commission or the public.

The 2025 Ganddini Report is referenced twice in MM-GHG-1 (VMT/TDM Reduction Plan):

To reduce GHG emissions, the proposed project shall implement a commute trip reduction program consisting of transportation demand management (TDM) measures that reduce annual Vehicle Miles Traveled (VMT) for non-truck project- related vehicles, consistent with the recommendations in the Project’s TDM Assessment (Ganddini 2025). . . . Per the Pemcor Commercial Industrial Business Park Project Transportation Demand Management Assessment Memorandum prepared by Ganddini Group dated February 19, 2025 (MND [SIC] Appendix L), the project shall provide the following to the satisfaction of City Planning staff . . . (FEIR, p. 3-3; see DEIR pp. 2-21, 4.8-19.) The FEIR’s Errata added the following reference to the EIR’s GHG section: “2025. Pemcor Commercial Industrial Business Project Transportation Demand Management Assessment Project No. 19729. Ganddini Group. February 19, 2025.” (FEIR, p. 3-4.) The DEIR also references the 2025 Ganddini Report (DEIR, p. 2-21 [“For more details on the specifics of each measure refer to the TDM assessment memorandum prepared by Ganddini Group in 2025”], 4.8-19.)
There was no such Ganddini Report dated Febraury 19, 2025 provided in the appendices to the DEIR or FEIR on the City’s website1 or on CEQANet. The only Appendix L available— which the EIR inaccurately labels as an MND appendix even though this is clearly an EIR—is a Ganddini Traffic Impact Analysis dated October 3, 2024, which does not address transportation demand management whatsoever.2
1 https://www.cityofmenifee.us/325/Environmental-Notices-Documents 2 https://www.cityofmenifee.us/DocumentCenter/View/24282/Appdx-L-1_Pemcor-LOS-TIA-10-3-24 Item Title: 11.1
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January 21, 2026
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Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025

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To the extent that the EIR relies on the 2025 Ganddini Report, the Report must be made available to the Commission and the public The EIR relies heavily on the 2025 Ganddini Report to mitigate the Project’s significant and unavoidable GHG impacts. The Commission and the public deserve the right to review the 2025 Ganddini Report to ensure that MM-GHG-1 is effective at reducing the Project’s GHG impacts. Furthermore, without the 2025 Ganddini Report, the EIR lacks substantial evidence to validate its assessment of the Project’s GHG impacts. For those reasons, SAFER respectfully requests that the Planning Commission continue further consideration of the Project and its EIR until the 2025 Ganddini Report is made public or until the EIR is revised to omit all references to the 2025 Ganddini Report and to amend its discussion and conclusions accordingly.

CONCLUSION
For the reasons discussed above, SAFER respectfully requests that the Planning Commission refrain from taking any action on this Project at this time. Instead, the Commission should continue the matter until: (1) the City fully considers additional feasible mitigation measures to reduce the Project’s greenhouse gas impacts, as required by CEQA and (2) the City makes the 2025 Ganddini Report available for public review Sincerely,
Brian B. Flynn
Lozeau Drury LLP
Item Title: 11.1
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EXHIBIT A
Item Title: 11.1
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l

ROB BONTA State of California
Attorney General DEPARTMENT OF JUSTICE

Warehouse Projects: Best Practices and
Mitigation Measures to Comply with the
California Environmental Quality Act

Item Title: 11.1
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Table of Contents

I. Background .......................................................................................................................... 1 II. Proactive Planning: General Plans, Local Ordinances, and Good Neighbor Policies ......... 3 III. Community Engagement ..................................................................................................... 4 IV. Warehouse Siting and Design Considerations ..................................................................... 5 V. Air Quality and Greenhouse Gas Emissions Analysis and Mitigation ................................ 7 VI. Noise Impacts Analysis and Mitigation ............................................................................. 10 VII. Traffic Impacts Analysis and Mitigation ........................................................................... 11 VIII. Other Significant Environmental Impacts Analysis and Mitigation .................................. 12 IX. Conclusion ......................................................................................................................... 13

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Updated September 2022

1 In carrying out its duty to enforce laws across California, the California Attorney General’s Bureau of Environmental Justice (Bureau)1 regularly reviews proposed warehouse projects for compliance with the California Environmental Quality Act (CEQA) and other laws.

When necessary, the Bureau submits comment letters to lead agencies regarding warehouse projects, and in rare cases the Bureau has filed litigation to enforce CEQA.2 This document builds upon the Bureau’s work on warehouse projects, collecting information gained from the Bureau’s review of hundreds of warehouse projects across the state.3 It is meant to help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals.
4 While CEQA analysis is necessarily project-specific, this document provides information on feasible best practices and mitigation measures, nearly all of which have been adapted from actual warehouse projects in California.

I. Background
In recent years, the proliferation of e-commerce and rising consumer expectations of rapid shipping have contributed to a boom in warehouse development.5 California, with its ports, population centers, and transportation network, has found itself at the center of this trend.

In 2020, the Ports of Los Angeles, Long Beach, and Oakland collectively accounted for over 34% of all United States international container trade. 6 The Ports of Los Angeles and Long
Beach alone generate about 35,000 container truck trips every day.7 Accordingly, the South Coast Air Basin now contains approximately 3,000 warehouses of over 100,000 square feet each, with a total warehouse capacity of approximately 700 million square feet, an increase of 20 percent over the last five years.8 This trend has only accelerated, with e-commerce growing to

1 https://oag.ca.gov/environment/justice.
2 https://oag.ca.gov/environment/ceqa; People of the State of California v. City of Fontana (Super. Ct. San Bernardino County, No. CIVSB2121829); South Central Neighbors United et al. v. City of Fresno et al. (Super. Ct. Fresno County, No. 18CECG00690). 3 This September 2022 version revises and replaces the prior March 2021 version of this document.
4 Anyone reviewing this document to determine CEQA compliance responsibilities should consult their own attorney for legal advice.
5 As used in this document, “warehouse” or “logistics facility” is defined as a facility consisting of one or more buildings that stores cargo, goods, or products on a short- or long-term basis for later distribution to businesses and/or retail customers. 6 Data from the Bureau of Transportation Statistics, Container TEUs (Twenty-foot Equivalent Units) (2020), https://data.bts.gov/stories/s/Container-TEU/x3fb-aeda/ (Ports of Los Angeles, Long Beach, and Oakland combined for 14.157 million TEUs, 34% of 41.24 million TEUs total nationwide) (last accessed September 18, 2022).
7 U.S. Dept. of Transportation, Federal Highway Administration, FHWA Operations Support – Port Peak Pricing Program Evaluation (2020), available at https://ops.fhwa.dot.gov/publications/fhwahop09014/sect2.htm (last accessed September 18, 2022).
8 South Coast Air Qual. Mgmt. Dist., Final Socioeconomic Assessment for Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program and Proposed Rule 316 – Fees for Rule 2305, at 7-8, 41 (May 2021).

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2 13% of all retail sales and 2021 being a second consecutive record year for new warehouse space leased.9 The latest data and forecasts predict that the next wave of warehouse development will be in the Central Valley.10
When done properly, these activities can contribute to the economy and consumer welfare. However, imprudent warehouse development can harm local communities and the environment. Among other pollutants, diesel trucks visiting warehouses emit nitrogen oxide (NO
x)—a primary precursor to smog formation and a significant factor in the development of respiratory problems like asthma, bronchitis, and lung irritation—and diesel particulate matter (a subset of fine particular matter that is smaller than 2.5 micrometers)—a contributor to cancer, heart disease, respiratory illnesses, and premature death. 11 Trucks and on-site loading activities
can also be loud, bringing disruptive noise levels during 24/7 operation that can cause hearing damage after prolonged exposure.
12 The hundreds, and sometimes thousands, of daily truck and passenger car trips that warehouses generate contribute to traffic jams, deterioration of road surfaces, and traffic accidents.

These environmental impacts also tend to be concentrated in neighborhoods already suffering from disproportionate health impacts and systemic vulnerability. For example, a comprehensive study by the South Coast Air Quality Management District found that communities located near large warehouses scored far higher on California’s environmental justice screening tool, which measures overall pollution and demographic vulnerability. 13 That

9 U.S. Census Bureau News, Quarterly Retail E-Commerce Sales 4th Quarter 2021 (February 22, 2022), https://www.census.gov/retail/mrts/www/data/pdf/ec_current.pdf (last accessed September 18, 2022); CBRE Research, 2022 North America Industrial Big Box Report: Review and Outlook, at 2-3 (March 2022), available at https://www.cbre.com/insights/reports/2022- north-america-industrial-big-box#download-report (last accessed September 18, 2022). 10 CBRE Research, supra note 9, at 4, 36; New York Times, Warehouses Are Headed to the Central Valley, Too (Jul. 22, 2020), available at
https://www.nytimes.com/2020/07/22/us/coronavirus-ca-warehouse-workers.html. 11 California Air Resources Board, Nitrogen Dioxide & Health, https://ww2.arb.ca.gov/resources/nitrogen-dioxide-and-health (last accessed September 18, 2022) (NOx); California Air Resources Board, Summary: Diesel Particular Matter Health Impacts, https://ww2.arb.ca.gov/resources/summary-d
iesel-particulate-matter-health-impacts
(last accessed September 18, 2022); Office of Environmental Health Hazard Assessment and American Lung Association of California, Health Effects of Diesel Exhaust, https://oehha.ca.gov/media/downloads/calenviroscreen/indicators/diesel4-

02.pdf (last accessed
September 18, 2022) (DPM).
12 Noise Sources and Their Effects,
https://www.chem.purdue.edu/chemsafety/Training/PPETrain/dblevels.htm (last accessed September 18, 2022) (a diesel truck moving 40 miles per hour, 50 feet away, produces 84 decibels of sound).
13 South Coast Air Quality Management District, “Final Socioeconomic Assessment for Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program and Proposed Rule 316 – Fees for Rule 2305” (May 2021), at 4-5.

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3 study concluded that, compared to the South Coast Air Basin averages, communities in the South Coast Air Basin near large warehouses had a substantially higher proportion of people of color; were exposed to more diesel particulate matter; had higher rates of asthma, cardiovascular disease, and low birth weights; and had higher poverty and unemployment rates.14 Each area has its own unique history, but many of these impacts and vulnerabilities reflect historic redlining practices in these communities, which devalued land and concentrated poverty, racial outgroups, and pollution into designated areas.15
II. Proactive Planning: General Plans, Local Ordinances, and Good Neighbor Policies To systematically guide warehouse development, we encourage local governing bodies to proactively plan for logistics projects in their jurisdictions. Proactive planning allows jurisdictions to prevent land use conflicts before they materialize and direct sustainable development. Benefits also include providing a predictable business environment, protecting residents from environmental harm, and setting consistent expectations jurisdiction-wide.

Proactive planning can take many forms. Land use designation and zoning decisions should channel development into appropriate areas. For example, establishing industrial districts near major highway and rail corridors but away from sensitive receptors 16 can help attract
investment while avoiding conflicts between warehouse facilities and residential communities.

Transition zones with lighter industrial and commercial land uses may also help minimize conflicts between residential and industrial uses.

In addition, general plan policies, local ordinances, and good neighbor policies should set minimum standards for logistics projects. General plan policies can be incorporated into existing economic development, land use, circulation, or other related general plan elements. Many jurisdictions alternatively choose to consolidate policies in a separate environmental justice element. Adopting general plan policies to guide warehouse development may also help

14 Id. at 5-7.
15 Beginning in the 1930s, federal housing policy directed investment away from Black, immigrant, and working-class communities by color-coding neighborhoods according to the purported “riskiness” of loaning to their residents. In California cities where such “redlining” maps were drawn, nearly all of the communities where warehouses are now concentrated were formerly coded “red,” signifying the least desirable areas where investment was to be avoided.

See University of Richmond Digital Scholarship Lab, Mapping Inequality, https://dsl.richmond.edu/panorama/redlining/#loc=12/33.748/-118.272&city=los-angeles-ca (Los
Angeles), https://dsl.richmond.edu/panorama/r edlining/#loc=13/32.685/-117.132&city=san- diego-ca (San Diego), https://dsl.richmond.edu/panorama/redlining/#loc=11/37.81/- 122.38&city=oakland-ca ( Oakland),
https://dsl.richmond.edu/panorama/redlining/#loc=13/37.956/-121.326&city=stockton-ca (Stockton), https://dsl.richmond.edu/panorama/redlining/#loc=12/36.751/-119.86& city=fresno- ca (Fresno) (all last accessed September 18, 2022).
16 In this document, “sensitive receptors” refers to residences, schools, public recreation facilities, health care facilities, places of worship, daycare facilities, community centers, or incarceration facilities.

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4 jurisdictions comply with their obligations under SB 1000, which requires local government general plans to identify objectives and policies to reduce health risks in disadvantaged communities, promote civil engagement in the public decision making process, and prioritize improvements and programs that address the needs of disadvantaged communities.17 Local ordinances and good neighbor policies that set development standards for all warehouses in the jurisdiction are a critical and increasingly common tool that serve several goals. When well-designed, these ordinances direct investment to local improvements, provide predictability for developers, conserve government resources by streamlining project review processes, and reduce the environmental impacts of industrial development. While many jurisdictions have adopted warehouse-specific development standards, an ordinance in the City of Fontana provides an example to review and build upon. 18 Good neighbor policies in
Riverside County and by the Western Riverside Council of Government include additional measures worth consideration.
19 The Bureau encourages jurisdictions to adopt their own local ordinances that combine the strongest policies from those models with measures discussed in the remainder of this document.

III. Community Engagement
Early and consistent community engagement is central to establishing good relationships between communities, lead agencies, and warehouse developers and tenants. Robust community engagement can give lead agencies access to community residents’ on-the-ground knowledge and information about their concerns, build community support for projects, and develop creative solutions to ensure new logistics facilities are mutually beneficial. Examples of best practices for community engagement include:
• Holding a series of community meetings at times and locations convenient to members of the affected community and incorporating suggestions into the project design.
• Posting information in hard copy in public gathering spaces and on a website about the project. The information should include a complete, accurate project description, maps and drawings of the project design, and information about how the public can provide input and be involved in the project approval process. The

17 For more information about SB 1000, see https://oag.ca.gov/environment/sb1000. 18 https://oag.ca.gov/system/files/attachments/press-
docs/Final%20Signed%20Fontana%20Ordinance.pdf (last ac cessed September 18, 2022). 19 For example, the Riverside County policy requires community benefits agreements and supplemental funding contributions toward additional pollution offsets, and the Western Riverside Council of Governments policy sets a minimum buffer zone of 300 meters between warehouses and sensitive receptors.
https://www.rivcocob.org/wp-
content/uploads/2020/01/Good-Neighbor-Policy-F-3-Final-Adopted.pdf ( last accessed September 18, 2022) (Riverside County);
http://www.wrcog.cog.ca.us/DocumentCenter/View/318/Good-N eighbor-Guidelines-for-Siting- Warehouse-Distribution-Facilities-PDF?bidId= ( last accessed September 18 , 2022) (Western Riverside Council of Governments).

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5 information should be in a format that is easy to navigate and understand for members of the affected community.
• Providing notice by mail to residents and schools within a certain radius of the project and along transportation corridors to be used by vehicles visiting the project, and by posting a prominent sign on the project site. The notice should include a brief project description and directions for accessing complete information about the project and for providing input on the project. • Providing translation or interpretation in residents’ native language, where appropriate.
• For public meetings broadcast online or otherwise held remotely, providing for access and public comment by telephone and supplying instructions for access and public comment with ample lead time prior to the meeting. • Partnering with local community-based organizations to solicit feedback, leverage local networks, co-host meetings, and build support.
• Considering adoption of a community benefits agreement, negotiated with input from affected residents and businesses, by which the developer provides benefits to the affected community.
• Creating a community advisory board made up of local residents to review and provide feedback on project proposals in early planning stages. • Identifying a person to act as a community liaison concerning on-site construction activity and operations, and providing contact information for the community liaison to the surrounding community.
• Requiring signage in public view at warehouse facilities with contact information for a local designated representative for the facility operator who can receive community complaints, and requiring any complaints to be answered by the facility operator within 48 hours of receipt.

IV. Warehouse Siting and Design Considerations
The most important consideration when planning a logistics facility is its location.

Warehouses located in residential neighborhoods or near sensitive receptors expose community residents and those using or visiting sensitive receptor sites to the air pollution, noise, traffic, and other environmental impacts they generate. Therefore, placing facilities away from sensitive receptors significantly reduces their environmental and quality of life harms on local communities. The suggested best practices for siting and design of warehouse facilities does not relieve lead agencies’ responsibility under CEQA to conduct a project-specific analysis of the project’s impacts and evaluation of feasible mitigation measures and alternatives; lead agencies’ incorporation of the best practices must be part of the impact, mitigation and alternatives analyses to meet the requirements of CEQA. Examples of best practices when siting and designing warehouse facilities include:

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6 • Per California Air Resources Board (CARB) guidance, siting warehouse facilities so that their property lines are at least 1,000 feet from the property lines of the nearest sensitive receptors.20
• Providing adequate amounts of on-site parking to prevent trucks and other vehicles from parking or idling on public streets and to reduce demand for off-site truck yards.
• Establishing setbacks from the property line of the nearest sensitive receptor to warehouse dock doors, loading areas, and truck drive aisles, and locating warehouse dock doors, loading areas, and truck drive aisles on the opposite side of the building from the nearest sensitive receptors—e.g., placing dock doors on the north side of the facility if sensitive receptors are near the south side of the facility.
• Placing facility entry and exit points from the public street away from sensitive receptors—e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. • Ensuring heavy duty trucks abide by the on-site circulation plans by constructing physical barriers to block those trucks from using areas of the project site restricted to light duty vehicles or emergency vehicles only. • Preventing truck queuing spillover onto surrounding streets by positioning entry gates after a minimum of 140 feet of space for queuing, and increasing the distance by 70 feet for every 20 loading docks beyond 50 docks. • Locating facility entry and exit points on streets of higher commercial classification that are designed to accommodate heavy duty truck usage. • Screening the warehouse site perimeter and onsite areas with significant truck traffic (e.g., dock doors and drive aisles) by creating physical, structural, and/or vegetative buffers that prevent or substantially reduce pollutant and noise dispersion from the facility to sensitive receptors.
• Planting exclusively 36-inch box evergreen trees to ensure faster maturity and four-season foliage.
• Requiring all property owners and successors in interest to maintain onsite trees and vegetation for the duration of ownership, including replacing any dead or unhealthy trees and vegetation.
• Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Including signs and drive aisle pavement markings that clearly identify onsite circulation patterns to minimize unnecessary onsite vehicle travel. • Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

20 CARB, Air Quality and Land Use Handbook: A Community Health Perspective (April 2005), at ES-1. CARB staff has released draft updates to this siting and design guidance which suggests a greater distance may be warranted in some scenarios. CARB, Concept Paper for the Freight Handbook (December 2019), available at
https://ww2.arb.ca.gov/sites/default/files/2020-
03/2019.12.12%20-%20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf (last accessed September 18, 2022).

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7 V. Air Quality and Greenhouse Gas Emissions Analysis and Mitigation Emissions of air pollutants and greenhouse gases are often among the most substantial environmental impacts from new warehouse facilities. CEQA compliance demands a proper accounting of the full air quality and greenhouse gas impacts of logistics facilities and adoption of all feasible mitigation of significant impacts. Although efforts by CARB and other authorities to regulate the heavy-duty truck and off-road diesel fleets have made excellent progress in reducing the air quality impacts of logistics facilities, the opportunity remains for local jurisdictions to further mitigate these impacts at the project level. Lead agencies and developers should also consider designing projects with their long-term viability in mind. Constructing the necessary infrastructure to prepare for the zero-emission future of goods movement not only reduces a facility’s emissions and local impact now, but it can also save money as demand for zero-emission infrastructure grows. In planning new logistics facilities, the Bureau strongly encourages developers to consider the local, statewide, and global impacts of their projects’ emissions.

Examples of best practices when studying air quality and greenhouse gas impacts include:
• Fully analyzing all reasonably foreseeable project impacts, including cumulative impacts. In general, new warehouse developments are not ministerial under CEQA because they involve public officials’ personal judgment as to the wisdom or manner of carrying out the project, even when warehouses are permitted by a site’s applicable zoning and/or general plan land use designation.21 • When analyzing cumulative impacts, thoroughly considering the project’s incremental impact in combination with past, present, and reasonably foreseeable future projects, even if the project’s individual impacts alone do not exceed the applicable significance thresholds.
• Preparing a quantitative air quality study in accordance with local air district guidelines.
• Preparing a quantitative health risk assessment in accordance with California Office of Environmental Health Hazard Assessment and local air district guidelines.
• Refraining from labeling compliance with CARB or air district regulations as a mitigation measure—compliance with applicable regulations is required regardless of CEQA.
• Disclosing air pollution from the entire expected length of truck trips. CEQA requires full public disclosure of a project’s anticipated truck trips, which entails calculating truck trip length based on likely truck trip destinations, rather than the distance from the facility to the edge of the air basin, local jurisdiction, or other truncated endpoint. All air pollution associated with the project must be considered, regardless of where those impacts occur.

21 CEQA Guidelines § 15369.

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8 • Accounting for all reasonably foreseeable greenhouse gas emissions from the project, without discounting projected emissions based on participation in California’s Cap-and-Trade Program.

Examples of measures to mitigate air quality and greenhouse gas impacts from construction are below. To ensure mitigation measures are enforceable and effective, they should be imposed as permit conditions on the project where applicable. • Requiring off-road construction equipment to be hybrid electric-diesel or zero- emission, where available, and all diesel-fueled off-road construction equipment to be equipped with CARB Tier IV-compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground-disturbing and construction activities.
• Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day.
• Using electric-powered hand tools, forklifts, and pressure washers, and providing electrical hook ups to the power grid rather than use of diesel-fueled generators to supply their power.
• Designating an area in the construction site where electric-powered construction vehicles and equipment can charge.
• Limiting the amount of daily grading disturbance area. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
• Forbidding idling of heavy equipment for more than three minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications. • Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts.
• Using paints, architectural coatings, and industrial maintenance coatings that have volatile organic compound levels of less than 10 g/L.
• Providing information on transit and ridesharing programs and services to construction employees.
• Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.

Examples of measures to mitigate air quality and greenhouse gas impacts from operation include:
• Requiring all heavy-duty vehicles engaged in drayage
22 to or from the project site
to be zero-emission beginning in 2030.

22 “Drayage” refers generally to transport of cargo to or from a seaport or intermodal railyard.

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9 • Requiring all on-site motorized operational equipment, such as forklifts and yard trucks, to be zero-emission with the necessary charging or fueling stations provided.
• Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
• Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
• Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager. • Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building’s projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible.
• Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Running conduit to designated locations for future electric truck charging stations. • Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Constructing and maintaining electric light-duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance) • Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light-duty charging stations. • Installing and maintaining, at the manufacturer’s recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.
• Installing and maintaining, at the manufacturer’s recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
• Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of Item Title: 11.1
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10 trucks.
• Requiring operators to establish and promote a rideshare program that discourages single-occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking. • Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking.
• Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations.
• Posting signs at every truck exit driveway providing directional information to the truck route.
• Improving and maintaining vegetation and tree canopy for residents in and around the project area.
• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB- approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request.
• Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

VI. Noise Impacts Analysis and Mitigation
The noise associated with logistics facilities can be among their most intrusive impacts to nearby sensitive receptors. Various sources, such as unloading activity, diesel truck movement, and rooftop air conditioning units, can contribute substantial noise pollution. These impacts are exacerbated by logistics facilities’ typical 24-hour, seven-days-per-week operation. Construction noise is often even greater than operational noise, so if a project site is near sensitive receptors, developers and lead agencies should adopt measures to reduce the noise generated by both construction and operation activities.

Examples of best practices when studying noise impacts include:
• Preparing a noise impact analysis that considers all reasonably foreseeable project noise impacts, including to nearby sensitive receptors. All reasonably foreseeable project noise impacts encompasses noise from both construction and operations, including stationary, on-site, and off-site noise sources. • Adopting a lower significance threshold for incremental noise increases when baseline noise already exceeds total noise significance thresholds, to account for the cumulative impact of additional noise and the fact that, as noise moves up the decibel scale, each decibel increase is a progressively greater increase in sound Item Title: 11.1
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11 pressure than the last. For example, 70 dBA is ten times more sound pressure than 60 dBA.
• Disclosing and considering the significance of short-term noise levels associated with all aspects of project operation (i.e. both on-site noise generation and off-site truck noise). Considering only average noise levels may mask noise impacts sensitive receptors would consider significant—for example, the repeated but short-lived passing of individual trucks or loading activities at night.

Examples of measures to mitigate noise impacts include:
• Constructing physical, structural, or vegetative noise barriers on and/or off the project site.
• Planning and enforcing truck routes that avoid passing sensitive receptors. • Locating or parking all stationary construction equipment as far from sensitive receptors as possible, and directing emitted noise away from sensitive receptors. • Verifying that construction equipment has properly operating and maintained mufflers.
• Requiring all combustion-powered construction equipment to be surrounded by a noise protection barrier
• Limiting operation hours to daytime hours on weekdays. • Paving roads where truck traffic is anticipated with low noise asphalt. • Orienting any public address systems onsite away from sensitive receptors and setting system volume at a level not readily audible past the property line.

VII. Traffic Impacts Analysis and Mitigation
Warehouse facilities inevitably bring truck and passenger car traffic. Truck traffic can present substantial safety issues. Collisions with heavy-duty trucks are especially dangerous for passenger cars, motorcycles, bicycles, and pedestrians. These concerns can be even greater if truck traffic passes through residential areas, school zones, or other places where pedestrians are common and extra caution is warranted.

Examples of measures to mitigate traffic impacts include:
• Designing, clearly marking, and enforcing truck routes that keep trucks out of residential neighborhoods and away from other sensitive receptors. • Installing signs in residential areas noting that truck and employee parking is prohibited.
• Requiring preparation and approval of a truck routing plan describing the facility’s hours of operation, types of items to be stored, and truck routing to and from the facility to designated truck routes that avoids passing sensitive receptors.

The plan should include measures for preventing truck queuing, circling, stopping, and parking on public streets, such as signage, pavement markings, and queuing analysis and enforcement. The plan should hold facility operators responsible for violations of the truck routing plan, and a revised plan should be required from any new tenant that occupies the property before a business license Item Title: 11.1
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12 is issued. The approving agency should retain discretion to determine if changes to the plan are necessary, including any additional measures to alleviate truck routing and parking issues that may arise during the life of the facility. • Constructing new or improved transit stops, sidewalks, bicycle lanes, and crosswalks, with special attention to ensuring safe routes to schools. • Consulting with the local public transit agency and securing increased public transit service to the project area.
• Designating areas for employee pickup and drop-off.
• Implementing traffic control and safety measures, such as speed bumps, speed limits, or new traffic signs or signals.
• Placing facility entry and exit points on major streets that do not have adjacent sensitive receptors.
• Restricting the turns trucks can make entering and exiting the facility to route trucks away from sensitive receptors.
• Constructing roadway improvements to improve traffic flow. • Preparing a construction traffic control plan prior to grading, detailing the locations of equipment staging areas, material stockpiles, proposed road closures, and hours of construction operations, and designing the plan to minimize impacts to roads frequented by passenger cars, pedestrians, bicyclists, and other non-truck traffic.

VIII. Other Significant Environmental Impacts Analysis and Mitigation Warehouse projects may result in significant environmental impacts to other resources, such as to aesthetics, cultural resources, energy, geology, or hazardous materials. All significant adverse environmental impacts must be evaluated, disclosed and mitigated to the extent feasible under CEQA. Examples of best practices and mitigation measures to reduce environmental impacts that do not fall under any of the above categories include:
• Appointing a compliance officer who is responsible for implementing all mitigation measures, and providing contact information for the compliance officer to the lead agency, to be updated annually.
• Creating a fund to mitigate impacts on affected residents, schools, places of worship, and other community institutions by retrofitting their property. For example, retaining a contractor to retrofit/install HVAC and/or air filtration systems, doors, dual-paned windows, and sound- and vibration-deadening insulation and curtains.
• Sweeping surrounding streets on a daily basis during construction to remove any construction-related debris and dirt.
• Directing all lighting at the facility into the interior of the site. • Using full cut-off light shields and/or anti-glare lighting. • Requiring submission of a property maintenance program for agency review and approval providing for the regular maintenance of all building structures, landscaping, and paved surfaces.
• Using cool pavement to reduce heat island effects.

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13 • Planting trees in parking areas to provide at least 35% shade cover of parking areas within fifteen years to reduce heat island impacts. • Using light colored roofing materials with a solar reflective index of 78 or greater. • Including on-site amenities, such as a truck operator lounge with restrooms, vending machines, and air conditioning, to reduce the need for truck operators to idle or travel offsite.
• Designing skylights to provide natural light to interior worker areas. • Installing climate control and air filtration in the warehouse facility to promote worker well-being.

IX. Conclusion
California’s world-class economy, ports, and transportation network position it at the center of the e-commerce and logistics industry boom. At the same time, California is a global leader in environmental protection and environmentally just development. The guidance in this document furthers these dual strengths, ensuring that all can access the benefits of economic development. The Bureau will continue to monitor proposed projects for compliance with CEQA and other laws. Lead agencies, developers, community advocates, and other interested parties should feel free to reach out to us as they consider how to guide warehouse development in their area.

Please do not hesitate to contact the Environmental Justice Bureau at [email protected] if
you have any questions.

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to Russell Brown, City of Menifee

from Kent Norton, MIG Riverside

re Pemcor Business Park EIR – Response to City Council Appeal by GSEJA and SAFER

date January 7, 2026

Subsequent to the Planning Commission hearing on November 12, 2025, an appeal to the City Council was submitted for the Menifee (Pemcor) Business Park Project by the Golden State Environmental Justice Alliance (GSEJA) dated November 19, 2025. A second appeal application submitted by Lozeau Drury on behalf of Supporters Alliance For Environmental Responsibility (SAFER) was received on November 20, 2025. It should be noted these two commenters each submitted two previous comment letters on the Pemcor project, one during the DEIR 45-day review period and one after the close of the review period and before the Planning Commission hearing. Responses to these previous letters were prepared and distributed per CEQA requirements.

The following are responses to the comments raised in the two appeal letters. The two appeal letters with comments marked in red are provided at the end of this memorandum. (1) Supporters Alliance For Environmental Responsibility (SAFER) Letter Response S-1: This comment provides general information on the requirements of CEQA and CEQA lead agencies, including the requirement for a lead agency to adequately respond, in good faith and with reasoned analysis, to specific comments or suggestions for ways to mitig ate or avoid a significant environmental impact. SAFER submits these comments in the context of the EIR’s purported failure to adopt all feasible mitigation measures for the project’s significant and unavoidable greenhouse gas (GHG) impacts; however, as described in more detail in Responses to Comments S-2, S-3, and S-4, the City has, in good faith, considered all specific comments related to the EIR, including SAFER’s November 12, 2025 appeal comments, and determined, with reasonable analysis, that all feasible mitigation measures have been incorporate d into the project, and that there are eight specific economic, social, technological, and other benefits of the project that outweigh the project’s significant and unavoidable GHG impact. The appellant is referred to Menifee (Pemcor) Business Park Project EIR Findings of Fact and Statement of Overriding Considerations (Findings/SOC) for the description of these benefits.

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2 MIG, Inc.

Response S-2: SAFER adequately summarizes EIR information on the magnitude and significance of the project’s GHG emissions sources and the mitigation measures incorporated into the EIR to reduce the project’s GHG emissions. SAFER asserts Mitigation Measure (MM) -GHG-1 an d GHG -3 are inadequate for several reasons; however, as described in more detail below, MM -GHG-1 and MM -GHG-3 establish enforceable performance standards and identifiable actions that would be implemented, monitored, and verified. EIR Mitigation Measures GHG-1 and GHG-3, therefore, are adequate. • Mitigation Measure GHG -1 is not deferred mitigation. It incorporates a clear performance standard for passenger vehicle miles travelled (VMT) and then provides flexibility and options for how to meet this standard. The standard - a

6.2% reduction in passen ger vehicle VMT - is to be achieved through the implementation of one or more of the California Air Pollution Control Officer’s Association (CAPCOA) transportation demand management (TDM) GHG reduction measures identified in the TDM Memorandum prepared for the project by the Ganddini Group and specifically called out in MM -GHG-1. Furthermore, the full implementation of these CAPCOA TDM Measures shall occur within one year of 90% project occupancy. This occupancy rate is considered necessary to support a sit e- wide TDM plan serving all tenants; however, the partial implementation of tenant- specific measures is not precluded prior to reaching 90% occupancy. Finally, Mitigation Measure GHG-1 is fully enforceable. It requires the TDM measures to be managed by the applicant or subsequent developer until a property owners association (POA) is established for the project site. The managing party (i.e., applicant, POA, etc.) is required to submit to the City, for review and verification, initial and ongoing, annual re port that the TDM measures are being implemented and the corresponding VMT reductions estimated to be achieved by the measures.

If, during its review of these reports, the City determines the TDM plan is not achieving the established performance standard, MM-GHG-1 requires the project to implement additional TDM measures to achieve the performance standard. For these reasons, MM-GHG-1 establishes a clear, enforceable, performance standard that could be achieved, as necessary, by one or more actions that wou ld be monitored and enforced in accordance with the project’s Mitigation Monitoring and Reporting Program and Plot Plan PLN23-0245. The City will enforce the MMRP just as they will enforce all their Conditions of Approval (COAs). Thus, MM -GHG-1 satisfies the requirements of CEQA and does not constitute deferred mitigation. • MM-GHG-3 is not deficient. It requires all building energy systems, equipment, and appliances to be powered by electricity unless evidence is submitted to the City demonstrating that it is not technologically or economically feasible to do so. The fact that MM-GHG-3 requires structures to be dual plumbed does not directly reduce or avoid the requirement to use electric systems, nor the effectiveness of this Item Title: 11.1
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measure. This is because the development of new non -residential buildings with natural gas infrastructure is consistent with the California 2025 Building Energy Efficiency Standards (BEES, or the Energy Code), which Chapter 8.17 of the Menifee Municipal Code adopts by reference as the Menefee Energy Code. While the 2025 BEES includes requirements for heat pumps, battery energy storage systems, and other components that support all -electric construction, it allows new non - residential buildings to be plumbed for natural gas and requires new buildings to be pre -wired to support the future installation of electric building systems and appliances. MM-GHG-3 would both be consistent with the Menifee Energy Code and result additional GHG emissions reductions by requ iring electrification of systems and appliances that are not currently required to be so. Thus, MM -GHG-3 is not deficient.

Response S-3: SAFER asserts the EIR is deficient because it fails to consider additional feasible mitigation measures, specifically idling, solar panel, and other “best practices” recommended by the California Department of Justice (DOJ) in its guidance document “Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” This comment is similar to comments submitted by the South Coast Air Quality Management District, the Golden State Environmental Ju stice Alliance (GSEJA), and Advocates for the Environment on the Draft EIR. As explained in Final EIR responses C-6, C-9, H-38, and I-9, the City has reviewed the referenced document and determined that many of the best practices in the document are commensurate with the requirements of existing regulations and/or the mitigation measures incorporated into the EIR. As described in more detail below, the EIR is not deficient, has incorporated feasible measures to reduce GHG emissions, and the additional recommendations made by the appellant are not considered feasible for the project. • SAFER asserts it is feasible to reduce truck idling times to less than the current 5- minute limit imposed on the project. While, as a general fact, it is possible to restrict trucks to idle for less than 5 minutes, such a restriction would be inconsistent with State legal requirements, is likely to be impractical, and would not be proportional to the magnitude of the GHG emissions impact, which is primarily the result of off- site truck travel emissions (and not on -site idling emissions). The City notes that the SCAQMD, in its comments on the Draft EIR (SCAQMD C -3), stated, “It is reasonable to expect that individual trucks may experience extended periods of idling due to on -site queuing, security checks, staging, loading, and unloading operations . . . As such, a 15-minute idling duration may underestimate actual on- site idling behavior . . .”. Furthermore, CARB’s Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (Title 13 of the California Code of Regulations, Section 248 5) has, since 2015, limited the idling of diesel fueled trucks with a gross vehicle weight rating greater than 10,000 pounds to 5 Item Title: 11.1
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consecutive minutes within 100 feet of any real property zoned for residential, school, hotel, motel, hospital, senior care facilities, and child care facilities, or which has one or more such units on it. This restriction would only affect the part of the project area within 100 feet of its northern and western boundary. Finally, the California Air Resources Board’s (CARB) Emission Factor (EMFAC) 2021 database Volume III Technical Document indicates certain out-of-state registered trucks idle for up to five hours at a time, while in-state registered truck idling times can vary between approximately 13 minutes and 4 hours per day (i.e., not per stop).

Together, this data information indicates that the vast majority of the site would not be subject to idling restrictions. The City’s Condition of Approval (COA 28) limiting idling of diesel-fueled trucks to no more than 5 minutes throughout the site (see COA text below) , therefore, represents a substantial additional reduction in idling emissions from diesel -fueled trucks that is equitable by aligning the idling restrictions mandated by the State ACTM that are applicable to part of the site to the full site. For this reason, additional idling restrictions would not be proportionate to the magnitude of the project’s GHG emissions impact.

COA 28
AQMD Rule 402. The project developer shall implement the following measures to reduce the emissions of pollutants generated by heavy -duty diesel-powered equipment operation at the project site throughout the project construction phases. The project developer shall includ e in construction contracts the control measures as may be required under Rule 402, at the time of development, including the following:
a. Keep all construction equipment in proper tune in accordance with manufacturer’s specifications.
b. Use late model heavy-duty diesel-powered equipment at the project site to the extent that it is readily available in the South Coast Air Basin (meaning that it does not have to be imported from another basin and that the procurement of the equipment would not cause a delay in construction activities of more than two weeks).
c. Use low -emission diesel fuel for all heavy -duty diesel -powered equipment operating and refueling at the project site to the extent that it is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another basin, that the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment (this measure does not apply to diesel -powered trucks traveling to and from the site).

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d. Utilize alternative fuel construction equipment (i.e., compressed natural gas, liquid petroleum gas), if equipment is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another air basin, th at the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment).
e. The developer shall post signage on -site limiting truck and equipment idling time to five minutes or less.
f. Rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion engines to the extent feasible.
g. General contractors shall maintain and operate construction equipment so as to minimize exhaust emissions.
• SAFER asserts that it is feasible to require solar panels on more than 15% of building rooftops, which is the current performance standard established by MM - GHG-4. The City notes that 2025 BEES establishes prescriptive and performance - based requirements for installed solar PV capacity for new non-residential buildings, such as the proposed project. In general, the installed capacity is dependent on the type of structure/occupancy, conditioned floor area, climate zone, roof slope, and other factors. In addit ion, the solar access roof area where PV panels could be installed must take into account shading, occupied roof areas, and other code - required roof access, pathway, ventilation requirements. In short, the number of PV panels that can be installed on any s ingle roof is contingent on specific design factors that are not known to the City at this time. The appellant is referred to Draft EIR Table 3 -2 (p. 3 -8), which indicates that each of the project’s 11 potential buildings would be relatively small, between approximately 23,000 and 38,000 square feet in size, which limits the overall roof area for solar PV and other equipment installations. The performance standard required by MM -GHG-4 is considered to be the minimum amount of solar PV installation that is feasible for all project buildings. As described in the FEIR (Appendix E, p. 6-8), it is based on the residential requirements of the 2022 BEES, which was the BEES in effect at the time the was prepared. It is not feasible for the C ity, at this time, to require the project to commit to the installation of solar PV panels on more than 15% of the roof area because of the additional information needed to guarantee such physical installed capacity would be feasible for individual project buildings. • SAFER to zero emission (ZE) yard equipment (e.g., forklifts) and trucks are feasible for the project.

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o With regard to ZE yard equipment, the City notes that the proposed project is not anticipated to involve the operation of any yard equipment and thus this recommendation is not relevant to the project.
o With regard to ZE trucks, as explained in the Final EIR (response C-8), the City has determined mandating the use of ZE trucks for the project is infeasible for legal and technological reasons. Goods movement is a complex process that may involve multiple stops. Trucks may be owned, operated, contracted, etc. as needed depending on each site’s operating characteristics, and neither the City nor future individual developers/tenants can regulate mobile emissions, which is within the purview of state regulator y agencies such as the CARB and local agencies, such as the SCAQMD. Those agencies can, and have, adopted regulations intended to reduce emissions from mobile sources, including trucks.

The Draft EIR, for example, summarized CARB’s Advanced Clean Fleets Ru le, which was intended to accelerate the large-scale reduction of tailpipe emissions by focusing on ZE medium and heavy -duty vehicles. Although CARB recently repealed and or modified the requirements of this rule, its mandate continues to reflect what CARB considers to be feasible implementation schedules, reflecting technological availability and feasibility. Cars and trucks accessing the project in the future would be required to comply with applicable regulations; however, the appellants’ suggestion that the City require ZE trucks is not considered feasible due to logistical and technological reasons.
• SAFER asserts the DOJ’s recommendation to post signs identifying idling restrictions is feasible for the project. As noted in the Final EIR (p. 2 -18, response C-3), the City has conditioned the project to limit truck idling to no more than 5 consecutive minutes. Project conditions will be incorporated into development and lease agreements as appropriate, and the posting of signs on -site would not, in and of itself, be an action that would reduce idling emissions. The City will also include the following Condition of Approval with this Project’s approvals:

NEW COA: The developer shall post signage on-site limiting truck and equipment idling time to five minutes or less.
• SAFER asserts it is feasible to run conduits to support future electric truck charging stations is feasible for the project. As noted in the Final EIR (response H -38), the proposed project would have 22 docks, less than half the amount (50 docks) that the City determined, in its Industrial Good Neighbor Policies, was feasible to require the installation of a conduit for truck charging. Thus, it is not considered feasible to require the installation of electric infrastructure to support future electric trucks at the project site.

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• SAFER asserts it is feasible for standby emergency generators to be powered by non-diesel fuel ; however, the project does not include the installation of any emergency generators and thus this recommendation is not relevant to the project.

Furthermore, as noted in the Final EIR (response H -38), the use of non -diesel generators is not necessary for the Project because this measure would not reduce or avoid an identified significant impact.
• SAFER asserts it is feasible for the project to be designed to meet LEED green building certification standards. As noted by the appellant, the Final EIR (Appendix E, p. 6-4), discloses that building energy use accounts for approximately 14% of the project’s estimated GHG emissions. The City incorporated Mitigation Measure GHG-3 and GHG-4 into the project, which requires the installation of solar PV panels on building roof tops and the use of electric building systems (instead of natural gas). These measures are estimated to substantially reduce the project’s building energy GHG emissions by up to 21.5%. Requiring the project to achieve LEED certification when it will already achieve an estimated 21.5% reduction in building energy use and will be required to meet California Green Building Code requirements would not be proportionate to the building energy use impact identified in the EIR.
• SAFER asserts that the DOJ’s recommendation to provide meal options onsite or shuttles between the facility and meal destinations is feasible for the project. While, as a general concept, on-site meal options may reduce off-site vehicle trips, there is no guarantee that providing this option would reduce vehicle trips. It is also not possible for the City to enforce this as a requirement since the feasibility of this action is contingent on market conditions that are outside the control of the City.

Response S-4: SAFER reiterates its assertion that the City cannot approve the Project and its EIR until all feasible GHG mitigation measures have been applied to the Project.

As described in Responses S-1, S-2, and S-3 above, the City has, in good faith, considered all specific comments related to the EIR, including SAFER’s November 12, 2025 appeal comments, and determined, with reasonable analysis and supported by substantial evidence as defined by CEQA Guidelines Section 15 384 (facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts), that all feasible GHG mitigation measures have been incorporated into the project. The EIR, therefore, does not require revision.

Response S -5: The commenter states the EIR references a Transportation Demand Management (TDM) Assessment prepared by Ganddini Group on February 19, 2025 (“2025 Ganddini Report”) that has not been provided to the Planning Commission or the public. It should be noted the requested document (DEIR Appendix L-2, 2025 Ganddini Item Title: 11.1
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VMT Report) was made available for public review on the State Clearinghouse website (see attached CEQAnet Excerpt).

Response S-6: As outlined in Responses S-1 through S-5 above, the City has considered expansion of existing or additional mitigation measures to help reduce GHG emissions.

In addition, the 2025 Ganddini VMT report was in fact included on the State’s CEQAnet website as Appendix L-2 (see attached CEQAnet Excerpt). Therefore, the EIR does not need to be revised and recirculated for additional public review.

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(2) Golden State Environmental Justice Alliance (GSEJA) Letter Response G-1: GSEJA states its reasons for appeal and denial of the project, citing its September 24, 2025, comments on the Draft EIR, inclusive of expert comments prepared by Soil Water Air Protection Enterprise (SWAPE) on the Draft EIR and September 19, 2025, and its November 11, 2025, comment letter on the Final EIR. The City has already provided detailed responses to these comments. The appellant is directed to Final EIR Responses H -1 to H-39 and the memorandum prepared by MIG, Incorporated (Inc.), “Pemcor Business park EIR – Response to Late GSEJA and SAFER Comment Letters,” dated November 12, 2025. This document is already part of the administrative record as part of the Planning Commission staff report materials.

Response G-2: GSEJA is re -submitting information regarding the existing pollution burden for the census tract (606043279) the Pemcor Business Park is located in. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explained in the MIG memorandum responding to those comments, this information is substantially the same as that provided in the Draft EIR (pp. 4.3-7 to 4.3-11) and Draft EIR Appendix E (pp. 3 -11 to 3-14), which provided a detailed discussion on “Existing Health Risks and Disadvantaged Communities.” The EIR discussion includes not only information on the census tract’s CalEnviroScreen pollution burden, but also information on other existing and planned light industrial facilities within ¼ mile of the project site and South Coast Air Quality Management District (SCAQMD) Multiple Air Toxics Exposure Study (MATES) V study. Importantly, the CalEnviroScreen pollution, health, and socioeconomic percentile data presented by GSEJA are the same as that disclosed in the EIR.

Furthermore, as a point of clarification, the City notes that, as described in CalEnviroScreen 4.0 Report, the CalEnviroScreen model assesse s cumulative impacts using both pollution burden and population characteristic data that are scored and combined to determine a single CalEnviroScreen score.1 This methodology accounts for differences in individual pollution burdens across geographic area so that no one single adverse environmental or public health effect or socioeconomic condition can render an area disadvantaged. Thus, while individual percen tile rankings provide useful information, they may or may not be representative of the total CalEnviroScreen score.

Finally, as another point of clarification, GSEJA has incorrectly referred to census tract 606043279 as an “Senate Bill (SB) 535 Disadvantaged Community designation, clearly identifying this as a disadvantaged community under state law.” As explained in the Draft EIR (p. 4.3 -10, emphasis added), “Communities that are within the top 25th percentile for total CalEnviroScreen scores are considered disadvantaged communities pursuant to SB 535. According to the Office of Environmental Health Hazard Assessment

1 Office of Health Hazard Assessment, 2021. CalEnviroScreen 4.0. October 2021.

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(OEHHA) CalEnviroScreen 4.0 Map, the proposed project is Census Tract 6065043279.

This area shows an average pollution indicator percentile of 41% based on the CalEnviroScreen indicators (e.g., exposure, environmental effects, population characteristics, socioeconomic factors) and has a population of 5,075 people . . . Table

4.3-3 summarizes the CalEnviroScreen indicators for census tract 6065043279. As shown in Table 4.3 -3, census tract 6065043279 is not within the top 25% of total CalEnviroScreen percentiles throughout the State and, therefore, is not considered a disadvantaged community pursuant to SB 535.” Thus, GSEJA has, again, failed to submit any information that was not already considered in the Draft EIR’s detailed analysis and evaluation of potential adverse air quality impacts.

Response G-2.1: There were no critical omissions of data or materials. When the City determined that one of the DEIR appendices had not been posted for public review, it issued a revised Notice of Availability and Notice of Completion through the State Clearinghouse which provided an extended and complete 45-day public review period after posting the “missing” appendix. Therefore, the critical air quality modeling data was made available to the public for the necessary period of time which was duly noted in the subsequent notices and DEIR document in the appropriate locations. In this way the document did not violate CEQA’s fundamental mandate for adequate informational documents and meaningful disclosure. The second notice is clearly posted on CEQAnet and all the necessary appendices are posted on that site as well.

The commenter also identified the following list of “legal compliance violations” supposedly committed by the EIR:
• CEQA 15121 – Informational Disclosure. DEIR Appendix E was provided to the public for the full 45 -day extended review period, as discussed in Response G-2.1 above.
• CEQA 15378 – Project Piecemealing. The EIR correctly evaluates the whole of the Pemcor project and the commenter incorrectly conflates the project with other non-related industrial projects in the surrounding area (cumulative project). • SB 1000 – Environmental Justice. The commenter is incorrect, the project site is not part of a disadvantaged community as outlined in Response G-3 below. • SB 330/SB 8 – Housing Crisis Act. As explained in the Final EIR response to comments and the response to supplemental comments to the Planning Commission, the Pemcor project is consistent with the General Plan and zoning designation for the site which allows mixed use but does not require residential uses to be built on any one particular project. Similarly, the Housing Element does not rely on or designate specific residential units on this site (see also Response G-4.1 below).

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• Govt Code 65302(h) – General Plan Env. Justice Element. Response G-5 below demonstrates the project is consistent with the General Plan goals and policies cited by the commenter.
• Govt Code 1135 – Language Access. The Menifee community may have a 30% Hispanic population but the population of the area surrounding the proposed project does not have similar demographic and language characteristics (see Response G-10.1).
• CEQA 15131(c) – EJ Analysis. In 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element in 2021 (see Responses G-3 and G-4 for more information).

Response G-2.2: The commenter is incorrect – there is no “piecemealing” involved with this project, the entire Pemcor Business Park development was described and analyzed in the DEIR. The “segmentation” seems to refer to the cumulative projects list which identifies other industrial developments proposed by other developers o n other sites at distance from the proposed project. These various projects have no direct relationship to the proposed Pemcor project in terms of ownership or application so the CEQA terms piecemealing and segmentation simply do not apply.

Response G-3: GSEJA asserts that, despite census tract 6065043279 being an SB 535 Disadvantaged Community, the City has failed to conduct a required Senate Bill (SB) 1000 analysis of environmental justice. First, as a point of clarification, census tract 6065043279 is n ot an SB 535 Disadvantaged Community (see response G -2 above).

Second, GSEJA’s references to Government Code Section 65302(h) and CEQA Guidelines Section 15131 (c) as “requiring” a project -level environmental justice analysis is incorrect for the following reasons:
• SB 1000 was adopted in 2016 to promote environmental justice through local land use planning. The law requires local governments with disadvantaged communities in their planning areas to develop environmental justice policies as part of their general plans. This requirement is triggered when a local government adopts or revised two or more general plan elements concurrently. Since the Pemcor Business Park does not involve revisions to the Menifee General Plan, SB 1000 does not apply to the project. The City notes that, in 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, in 2021, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element.

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• CEQA Guidelines Section 15131, Economic and Social Effects, states (emphasis added), “Economic or social information may be included in an EIR or may be presented in whatever form the agency desires.” Pursuant to CEQA Guidelines Section 15005, Terminology, the use of the word “may” identifies “a permissive element which is left fully to the discretion of the public agencies involved” in the CEQA proces s. Thus, this section does not require the City to include an environmental justice analysis in the EIR. Se parately, Subsection (c) sets forth that economic, social, and housing factors shall be considered together with technological and environmental factors “in deciding whether changes in a project are feasible to reduce or avoid significant environmental effects.” As explained in Response G-1 and G -2 and referenced materials, the Menifee Pemcor Business Park EIR constitutes a. fact -based evaluation of the proposed Project that fully identifies and discloses the Project’s potential air quality and GHG impacts and identifies feasible measures given the project’s specific technological, environmental, economic, social, and other factors.

Response G-4: GSEJA asserts the project continues decades of environmental racism systematically concentrating pollution facilities in communities of color while protecting affluent areas, refers to the Inland Empire as a “sacrifice zone” for working class-families and communities of color, and provides CalEnviroScreen on environmental and health burdens for census tract 6065043279. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explaine d in the MIG memorandum responding to those comments, the Draft EIR discloses pertinent environmental justice information, adequately evaluates all project emissions sources, and concludes, based on substantial evidence, that the project would not result in substantial pollutant concentrations at sensitive receptor locations. Furthermore, GSEJA’s generalized comments on the land use patterns in the Inland Empire as whole may not be construed on the nature of development in Menifee, which incorporated in 2008, nor the project’s census tract, which is not a disadvantaged community, specifically.

Response G-4.1: The commenter assumes the site must be used for housing but in fact the EDC-SG designation allows housing but does not require it. This designation is primarily intended to generate jobs/employment with housing only helping to support those uses and help reduce trip lengths between residential and non-residential uses in the area. In addition, the City’s Housing Element does not depend on the maximum or any housing being constructed on parcels within the EDC -SG category and is only a small part of the City’s vacant land survey as part of the Housing Element. The Housing Element identifies more vacant land sites for potential residential units than are needed to meet the City’s Regional Housing Needs Assessment (RHNA) allocation from SCAG during the period of the most recently updated Housing Element (6th Cycle, 2021 to 2029). The City has complete discretion as to where it encourages or allows future Item Title: 11.1
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housing to be built, as well as how it implements its approved Housing Element. Thus, the City may approve a development with anywhere from 487 down to zero residential units on the Project site under the mixed -use EDC-SG designation. There has been no zoning change to the mixed-use EDC-SG designation, there is no evidence that there is in fact a decrease on residential capacity in the EDC-SG zone, and therefore no violation of SB 330 or SB 8. Therefore, the project does not result in any “housing violations”.

Response G-5: GSEJA submits comments regarding the adequacy of the EIR’s evaluation of the project’s consistency with certain Menifee General Plan goals and policies, however, as described in more detail below, the project would not conflict with the General Plan policies identified by GSEJA.
• Policy S-7.1. GSEJA correctly identifies that asserts this policy calls for the City to “continue to require environmental analysis for proposed projects that may produce harmful levels of greenhouse gas”. Consistent with this policy, the Notice of Preparation prepared for the project identified greenhouse gases (GHG) as a potential environmental effect of the project, which was subsequently evaluated in project EIR.

Thus, the City has, in fact, conducted the environmental analysis required by Policy S-7.1.

• Policy EJ -3.6. This policy states, “Continue to collaborate with the [SCAQMD], California Air Resources Board (CARB), utility providers, Southern California Association of Governments (SCAG), Western Riverside Council of Governments (WRCOG), and nonprofit organizations, neighborhood groups, and other community organizations to improve air quality, food availability, renewable energy systems, sustainable land use and reduce [GHGs].” GSEJA purports the project conflicts with this policy because the project wo uld degrade air quality. GSEJA is mistaken. As discussed in Draft EIR Section 4.3.4, Air Quality Impacts and Mitigation Measures, the proposed Project would not result in any significant and unavoidable air quality impacts. Furthermore, as stated on Draft EIR page 6 -2, “In developing its CEQA significance thresholds, the SCAQMD considered the emission levels at which a project’s individual emissions would be cumulatively considerable (SCAQMD, 2003; page D-3). The proposed project’s construction and operatio nal emissions would be below applicable SCAQMD regional thresholds for criteria air pollutants after the incorporation of recommended Mitigation Measure AQ -1. Therefore, the proposed project would not result in a cumulatively considerable increase in crite ria air pollutants.” Thus, the Project would not degrade air quality. Furthermore, the City provided each of the agencies and organizations identified in Policy EJ -3.6 with the opportunity to comment on the EIR and, therefore, did provide the SCAQMD and CARB with the opportunity to collaborate on the project. For these reasons, the project would not conflict with Policy EJ-3.6.

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• Goal OSC -10. GSEJA purports that Goal OSC -10 “mandates” GHG emissions reductions, which the project conflicts with because it increases GHG emissions. As a point of clarification, General Plan Goal OSC -10 states, “An environmentally aware community that is responsive to changing climate conditions and actively seeks to reduce local greenhouse gas emissions.” In the case of the proposed project, the City has incorporated Mitigation Measures (MM)-GHG-1 to GHG-4 to reduce the project’s GHG emissions levels. The project, therefore, is consistent with Goal OSC-10.

• Policy C-5.3. GSEJA purports that the project conflicts with this policy because it was add 239 daily truck trips; however, Policy C -5.3 states, “Support efforts to reduce/eliminate the negative environmental impacts of goods movement.” As discussed in Draft EIR Section 4.17.4, the project would not result in any potentially significant transportation-related impacts, with Impact TRANS -1 finding the project would be consistent with all applicable goals and policies of the General Plan Circulation Element. Thus, the project would not have any negative circulation effects that require mitigation. While the type and size of the project results in significant GHG emissions compared to the City’s 3,000 MTCO2e threshold, GHG mitigation measures are included to help reduce project GHG emissions while improving the city’s ability to move goods throughout the region.

Response G-5.1: The following responses regarding VMT are from the Final EIR as prepared by Ganddini:

FEIR Response H-18
This comment claims that the project VMT screening assessment is inaccurate because the WRCOG VMT Tool results for TAZ 1053 are based on conditions as of 2012, which would not have included any warehousing uses.

First, this comment incorrectly references a 2012 model scenario associated with the Riverside County Transportation Analysis Model (RIVTAM), which has now been superseded by the Riverside County Model (RIVCOM). The WRCOG VMT Tool used for the project screening assessment is based on a more recent update, which incorporates the latest RIVCOM data and includes 2018 and 2045 model scenarios.

Furthermore, additional review of the socio-economic data (SED) for the RIVCOM 2018 model scenario shows that TAZ 1053 includes 369 total employment, including 110 employees in the transportation and warehousing sector. Therefore, the latest WRCOG VMT Tool, as used for the project screening assessment, includes SED inputs associated with comparable land uses to the proposed land use such that it is expected to provide a reasonable estimate of the project VMT impacts and there is nothing unique about the Item Title: 11.1
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project, or the project TAZ, that would otherwise be mis -represented by utilizing the data from the WRCOG VMT Tool.

FEIR Response H-20
This comment quotes the WRCOG SB 743 Implementation Pathway Document Package, which was developed by WRCOG in 2019 as a guidance document to help member agencies implement SB 743. While this document may include general information, the City of Menifee, as the Lead Agency, has ultimate authority in establishing the applicable methodology and thresholds as set forth in the City of Menifee Traffic Impact Analysis Guidelines for Vehicle Miles Traveled (Adopted June 3, 2020, Updated January 2022).

The comment incorrectly describes the threshold of 33.6 VMT per service population as the Citywide average rather than the County average and omits the full quote from the WRCOG SB 743 Implementation Pathway Document Package, which is as follows:
“OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold [emphasis added].” These omissions downplay the intent of the WRCOG SB 743 Implementation Pathway Document Package to serve as an early guidance document for member agencies and that other thresholds may also be appropriate. The comment further omits that the WRCOG SB 743 Implementation Pathway Document Package contains additional thresholds for consideration (see “Thresholds Assessment” included in the Executive Summary), as follows:
“Potential VMT thresholds were assessed within the context of the objectives of SB 743, legal opinions related to the legislation, proposed CEQA Guidelines updates, and the technical advisory produced by OPR. Fehr & Peers identified four threshold options for consideration by lead agencies.

1. Thresholds consistent with OPR’s Technical Advisory, recommending that proposed developments generate VMT per person that is 15% below existing VMT per capita,

2. Thresholds consistent with Lead Agency air quality, GHG reduction, and energy conservation goals,

3. Thresholds consistent with RTP/SCS future year VMT projects by jurisdiction or subregion, and

4. Thresholds based on baseline VMT performance by jurisdiction or sub-region [emphasis added].”
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The City of Menifee elected to adopt a threshold of significance that is a variation of the fourth option recommended by the WRCOG SB 743 Implementation Pathway Document Package. Therefore, the project’s VMT screening assessment provides substantial evidence in accordance with the appropriate methodology and thresholds established by the City of Menifee, as the Lead Agency, to support a finding of less than significant VMT impact; no revisions to the EIR are necessary.

Conclusion: As noted above and also in FEIR Responses H-18 through H-20, the VMT analysis was conducted in full conformance with City-established methodologies and no revisions to the EIR or VMT technical report prepared by Ganddini Group are necessary.

Response G-5.2: The project site is adjacent to Zeiders Road and the two access points created for the Project and shown on the site plan avoid sharp curves or dangerous intersections. The two access points were identified by City staff based on fire and police department emergency access requirements. The site was modeled using standard WB67 (72’) sized truck trailers to eliminate any site access limitations. The City Engineering Department evaluated truck turning radii in its review of the Project site plans and did not identify any conditions around any of the Project buildings requiring modifications to the site plan in terms of safe truck access. Project Plan Sheet C07 shows the fire truck radius and Sheet AS1 shows truck turning movements in grey scale.

Relative to emergency access, the site plan shows two full width driveways onto Zeiders Road capable of allowing access for emergency vehicles without the use of a Knox box which can incrementally slow response time. In addition, there is adequate travel lanes around all of the Project buildings wide enough to allow police and fire vehicles unrestricted access. FEIR Response H-24 indicates the site not only has unobstructed horizontal views of Zeiders Road but also no significant elevational (vertical) site distance issues as well. Therefore, the Project has no significant impacts relative to geometric design features and emergency access.

Response G-6: GSEJA re -submits comments on the potential cumulative impacts associated with the concentration of industrial parks in Menifee that are substantially the same as GSEJA submitted on November 11, 2025. The City notes that the Draft EIR discloses there are five existing and planned light industrial facilities within one-quarter mile of the project site, and fully evaluates the potential cumulative air quality, traffic, and other impacts of the proposed project. GSEJA has not submitted any new substantial evidence that demonstrates the proposed project would result in a significant cumulative environmental impact, has not clarified the geographic scope for its cumulative impact assumptions, and has not provided the sources for its employment growth projections.

The appellant is directed to the MIG memorandum responding to GSEJA’s November 11, 2025 comments for additional information on the EIR’s cumulative impacts analysis.

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Response G-7: GSEJA re-submits comments on the technical adequacy of the EIR’s air quality analysis that are substantially the same as SWAPE submitted on September 19, 2025.
• As explained in the Final EIR (Response H -35), changes to the project’s modeled fleet mix were made based on site -specific information from the traffic analysis prepared for the project.

• As explained in the Final EIR (Response H-34), the City revised the EIR’s air quality modeling to use a 25.4 mile haul trip distance as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H -36), the City revised the EIR’s health risk assessment to use a Fraction of Time at Home (FAH) of 1 for individuals from the third trimester to age 16 as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H-32), Phase I/II information compiled for the project indicates it is unlikely biosolids containing polyfluoroalkyl substances (PFAS) were deposited at the project site in the past. GSEJA has not submitted any new substantial evidence to indicate PFAS are present at the project site.

Response G-8: GSEJA states the health risk assessment (HRA) prepared for the EIR is deficient because it did not consider multi -pollutant effects, elevated baseline conditions, vulnerable populations, and cumulative impacts. As noted in Response G-2, the EIR clearly discloses the project’s setting with regard to environmental burdens and socioeconomic conditions, and the City considered this information in its assessment of the project’s potential air quality impacts. Furthermore, the HRA is not deficient. The HRA was conducted in accordance with SCAQMD and OEHHA recommended guidance and reflects a conservative analysis of potential health risks on sensitive populations for the following reasons:
• As explained in the Draft EIR (p. 4.3 -25 and Appendix E, pp. 4 -5 and 4-8), the diesel HRA is based on estimated ground level concentrations of PM 10 instead of PM2.5. While PM 2.5 is a subset of PM 10, use of the PM 10 fraction results in the modeling and assessment of risks on a larger share of particulate pollutants than would occur using the PM2.5 fraction. It should be noted there would be other risks from other pollutants but that DPM is the primary pollutant of concern. This is the reason multi-pollutant risks are not addressed in this analysis.

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• As explained in the Draft EIR (Appendix E, Section 4.2.4) and Final EIR (Response C-5), construction diesel particulate matter (DPM) emissions would be the primary driver of health risks when combining construction and operational related emissions. The excess cancer risk estimate at the MEIR assumes the receptor is an infant (including 3rd trimester) for the first 2 years of exposure and then develops to a child and finally to an adult over the next 28 years of exposure. As shown in Table 4 -18 of Appendix E, the modeled annual average DPM concentrations in construction years 1 and 2 are substantially higher than years 3 through 30. Thus, assuming all early life stages occur during these exposure years results in the most conservative estimate of potential adverse health risks.

• As noted in Response G-7, the FEIR revised the HRA to set the fraction of time at home to 1, even though this change was not required pursuant to SCAQMD or OEHHA guidance. Thus, the HRA conservatively assumes receptors are exposed to modeled pollutants 24 hours per day and nearly 365 days per year.

The above assumptions serve to provide a conservative (i.e., likely to overestimate) potential adverse carcinogenic and non-carcinogenic health risks that could potentially be associated with project emissions. As documented in the EIR, the project’s potential carcinogenic and non-carcinogenic health risks would be less than significant even with these health protective assumptions incorporated into the modeling and assessment methodology. Finally, the Draft EIR (p. 4.3 -26) included an evaluation of cumulat ive health risks impacts and concluded this impact would be less than significant. For these reasons, the appellant has not provided substantial evidence that supports the assertion that the EIR’s HRA is deficient.

Response G-9: GSEJA generally asserts that the City rejects feasible mitigation measures to reduce GHG emissions but does not provide any substantial evidence to support its assertion. GSEJA’s comments are substantially the same as that submitted by SWAPE on September 1 9, 2025, and by Supporters Alliance for Environmental Responsibility (SAFER) on November 12, 2025. The appellant is directed to the Final EIR Response H-38, and to Response S-3 above for detailed responses on why the measures suggested by GSEJA are not feasible for the project.

Response G-9.1: Alternatives. As outlined in FEIR Response H -25, the EIR did select a reasonable range of alternatives given the General Plan land use designation and zoning classification of the site, as well as the identified significant impacts of the proposed Project (air quality and greenhouse gas emissions). In addition to t he No Project – No Development Alternative, one of the alternatives is less intense development (Alternative 1, -25%) but similar development to the proposed Project which is in keeping with selecting alternatives that could reduce or eliminate the Item Title: 11.1
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significant impacts of the Project but also meet all or at least to some degree the objectives of the Project.

The introductory sections go into detail about the possible range of alternatives that could have been studied (Section 5.2, No Project Alternatives and Alternatives Considered But Rejected). The General Plan designation for the site (EDC -SG) could allow a wide range of potential residential and non-residential land uses. However, many of these would be mixed use projects based on the General Plan land use designation for the site which does allow certain residential and other non -residential uses.

Alternative 2 – EDC Mixed Use (C/LI/MFR) would provide 75,000 square feet of retail commercial space, 150,000 square feet of light industrial space, and 400 apartments (20 acres x 20 units/acre). Alternative 3 – EDC Mixed Use (O/BP/R) would provide 100,000 square feet of office space, 100,000 square feet of business park uses, and 300 “for ownership” condominiums (20 acres x 15 units/acre).

City staff considered various mixes of these land uses but knowing that a substantial amount of commercial use would generate substantial amounts of traffic, and a substantial amount of residential units in this area would not be compatible with non - residential uses surrounding the project site. In the end the City selected these alternatives as the most reasonable range of alternatives that could reduce or eliminate one or more of the Project’s significant impacts. Due to the size of the site, no reasonable development-related project was found that could eliminate the one significant impact of the project (GHG emissions) and the two mixed use alternatives actually resulted in significant air quality impacts as well.

Based on the size of the site, it is likely no level of urban development allowed by the General Plan and zoning on this site would reduce potential GHG emissions to less than significant levels due to the City’s relatively low adopted GHG significance thr eshold (3,000 MTCO2e).

FEIR Alternative 1 would not achieve the goals of the Project to the same degree as the proposed Project, and FEIR Alternatives 2 and 3 even less so since they further reduce non-residential development in favor of added residential development. In the end Alternative 1 was selected as the “Environmentally Superior Alternative.” After reviewing this response, the commenter proceeded to suggest five different alternatives to reduce GHG emissions which w as the lone significant impact of the project:
• Zero-Emission Logistics Alternative: All-electric operations with solar canopies and battery storage. The primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to Item Title: 11.1
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support a diverse employment base. Logistics warehousing is not consistent with that primary objective but certainly efforts to achieve or strive toward zero emissions would help reduce GHG emissions, possibly even below the City’s 3,000 MTCO2e significance threshold.
• Light Manufacturing Alternative: Lower truck traffic, higher employment density .

As stated above, the primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to support a diverse employment base. Focusing on only one aspect of this development category would unduly limit the diversity of future employment in this center, but any land use changes that would reduce truck traffic would incrementally reduce GHG emissions as well.
• Mixed-Use Transit -Oriented Alternative: Incorporating affordable housing near future transit. Zeiders Road will eventually have transit service so it would be possible to add market-rate or affordable housing in this area to take advantage of future transit. However, the DEIR did examine two alternatives that included different forms of housing and determined that the addition of residential uses would substantially increase anticipated traffic which in turn would increase air pollutant and GHG emissions.
• Phased Development Alternative: Allowing technology improvements before full buildout. The business park project has 11 separate buildings with a variety of potential uses (light industrial, manufacturing, office) which will practically result in a phased development or occupancy of future uses. However, it is more difficult to require multi-tenant developments to implement “future technology” since it is unknown what such technology will be and if or how various uses could implement such technology.
• Community-Serving Commercial Alternative: Retail, services, and amenities for residents. Section 5 of the DEIR explained that any alternatives that included a high proportion of commercial uses would substantially increase project traffic and thus increase GHG emissions. Therefore this is not a feasible alternative compared to the proposed project.

The commenter concludes that “the City's claim that no alternative could eliminate GHG impacts due to the 3,000 MTCO2e threshold is defeatist and incorrect -a zero-emission facility with renewable energy could achieve carbon neutrality. ” The EIR did propose mitigation measures to help reduce GHG emissions including a Transportation Demand Management (TDM) Plan for future uses to reduce their vehicle miles travelled (VMT) impacts. The project includes allowance for future rooftop photovolta ic solar panels depending on the specific future use/user.

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Response G-10: GSEJA submits a general assertion that the City has dismissed “California Department of Justice recommendations” without adequate analysis.

Assuming that GSEJA is referring to the Department of Justice’s (DOJ) guidance document “Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act,” this comment is similar to other comments submitted by the South Coast Air Quality Manageme nt District, the Golden State Environmental Justice Alliance (GSEJA), and Advocates for the Environment on the Draft EIR. As explained in Final EIR Responses C-6, C-9, H-38, and I-9, the City has reviewed the referenced document and determined that many of the best practices in the document are commensurate with the requirements of existing regulations and/or the mitigation measures incorporated into t he EIR. The EIR has incorporated feasible measures to reduce GHG emissions, and the additional recommendations made by the appellant are either not feasible for the project or not necessary to address an identified significant impact.

Response G-10.1: The City provides Spanish language translation services at meetings and for critical public documents, however, the City has determined that CEQA documents are not essential public documents per state law. In this case, neither the project site nor the immediate surrounding area is consider ed a disadvantaged community in need of focused language services relative to this project (see Response G-2 above). In addition, it should be noted that no comments were received during the NOP/Scoping period, the Draft EIR review period, or subsequently at the Planning Commission indicating a need or desire for the CEQA documents for this project to be provided in Spanish.

Response G-10.2: The commenter stated the city’s public notices failed to:
• Identify the site as in a disadvantaged community. As discussed in Response G-2 above, the project site and immediate surrounding area are not within a disadvantaged community.
• Disclose the 93rd percentile cardiovascular disease burden. The appropriate area- specific information from the CalEnviroScreen website was provided in DEIR Section 3.3, Air Quality.
• Mention cumulative impacts from surrounding warehouses. Potential contributions of the proposed project to cumulative impacts were discussed in each of the environmental analysis sections of the DEIR (4.1 through 4.20) and, other than greenhouse gas emissions, the project was not found to make a substantial contribution to any significant cumulative regional impact. Specifically, the Draft EIR (p. 4.3 -26) included an evaluation of cumulative health risks impacts and concluded this impact would be less than significant.

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• Provide health risk information in lay terms . DEIR Section 4.3, Air Quality, describes the health effects of various air pollutants and goes into great detail about the potential health risks of the proposed project. • Offer resources for technical assistance to residents. It is not clear what “technical assistance” has not been made available to local residents regarding the planning or environmental processes for this project. The project planner, Russell Brown, was contacted by and discussed project characteristics with only one local resident during the NOP and EIR review process. No other related services were requested.

Response G-10.3: The commenter indicated the following regarding the City’s previous responses to their earlier comments on the DEIR:
• Dismissive tone toward environmental justice concerns . The commenter is not clear about this comment but the DEIR and FEIR both demonstrate the project is not within a disadvantaged community so that it is possible the commenter considered this a “dismissal” of its overall concerns regarding EJ. That is not t he case as the City has actually incorporated a number of EJ goals and policies into various elements of its recently updated General Plan.
• Reliance on technicalities rather than substantive analysis. It is not clear to which sections or analyses the commenter was referring but the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and opinions.
• Failure to provide requested data and calculations. Not clear what is meant but as indicated above, the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and opinions. The misposting of Appendices E and L -2 have been explained and the 45-day public review period was extended to allow full review time for the DEIR and its appendices once the appendices were posted. All of the calculations for air quality and greenhouse gas emissions were provided in the appendices and summarized in the DEIR sections.
• Mischaracterization of legal requirements. Again, the commenter did not explain particulars of this comment and all of their comments regarding various legal CEQA requirements were addressed in FEIR (response to comments and errata sections), and subsequent response to comments memos (including this one). • Refusal to consider feasible mitigation. The DEIR did consider feasible mitigation, and the FEIR and subsequent response to comments memos (including this one) indicate a desire to accommodate the recommended additional or expanded mitigation to the extent practical or feasible which is all expl ained in the various CEQA documents as appropriate.

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Response G -10.4: The commenter indicated t he FEIR fail ed to analyze economic impacts on the disadvantaged community. Again, it must be made clear the project site and surrounding properties are not located within a disadvantaged community (see Response G-2 above).

Job Quality Analysis Absent:
• No wage data for proposed 553 jobs. CEQA does not involve the evaluation of fiscal impacts such as wages unless a clear connection to adverse physical changes to the environment can be shown. In this case, the commenter did not suggest one other than a supposed link to a disadvantaged community. The DEIR and FEIR clearly indicated the site and surrounding properties are not within or part of a disadvantaged community. Even if such data was requ ested/required by the City and/or CEQA, it would be overly speculative to try to estimate specific wage data since this is a multi- tenant business park with no committed tenants yet.
• No comparison to living wage standards . As outlined above, specific wage data is not required by the City or CEQA and in this case is overly speculative since none of the actual tenants have been identified yet.
• No analysis of benefits availability. The project is consistent with the General Plan and zoning so no specific community benefits are required as part of development, and the commenter did not explain the purpose or content of such an analysis. • No local hire requirements. At most this is a potential planning consideration of the project approval process and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific local hiring requirements for such projects.
• No job training partnerships. This is a potential planning consideration of the project approval process at most and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific requirements for such projects regarding job training partnerships.

Displacement Impacts ignored:
• Property value impacts from industrial encroachment. There is no “encroachment” since the project is consistent with the General Plan and zoning designations and only one vacant farmhouse is being removed by this project.
• Small business displacement from truck traffic . The commenter did not clarify the intent of this comment so it is not clear what if any displacement of small businesses might occur from project -related truck traffic. In any case, such financial effects of project planning are not considerations under CEQA which focuses on physical changes to the environment.

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• Residential displacement from cumulative impacts. No evidence was presented that critical housing, existing or planned, would be displaced by development of the project or other cumulative development.
• Loss of land for community -serving uses . The project site has a General Plan designation and zoning classification of “Economic Development Corridor -Southern Gateway” designation (EDC-SG) which allows for a mixture of specific uses as part of the “mixed use” land use grouping (i.e., light industrial, manufacturing, office, and residential in support of non -residential uses). The selection of land uses under the mixed use category necessari ly means some uses will be chosen over other uses.

Since the project is consistent with the General Plan and zoning, the General Plan EIR addressed the potential land use and other environmental impacts of this land use selection process.

Fiscal Impact omissions:
• Public health costs from increased pollution . The project is consistent with the General Plan and zoning designations of the site, and the potential environmental and health impacts of project air pollutant emissions were calculated and evaluated in DEIR Section 4.3, Air Quality, and the health risk assessment outlined in DEIR Section

4.3.4, Impacts b and c. CEQA does not involve the evaluation of fiscal impacts unless a clear connection to adverse physical changes to the environment can be shown. • Infrastructure wear from truck traffic . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed. CEQA does not involve the evaluation of fiscal impacts unles s a clear connection to adverse physical changes to the environment can be shown.
• Emergency service demands . Potential impacts of the project on emergency services were addressed in DEIR Section 4.17, Public Services (police and fire) including fiscal impacts related to development impact fees to help fund such services.
• Lost property tax from residential prohibition . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed.

Finally, CEQA does not involve the evaluation of fiscal impacts such as these unless a clear connection to adverse physical changes to the environment can be shown and the commenter provided no such connection.

Response G-11: Climate Vulnerability. GSEGA asserts the DEIR fails to analyze general climate vulnerability factors such as heat island effects, extreme heat events, etc. The appellant is directed to Draft EIR p. 4.8-4 and 4.8-5 for a discussion of potential climate change effects in California, Section 4.10.4 for a discussion of the project’s potential Item Title: 11.1
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hydrology, flooding, and water quality impacts, and Chapter 4.20 for setting and impact discussions related to wildfire. As a point of clarification, the EIR’s GHG analysis, including the project direct and indirect GHG emissions levels and consistency wit h applicable plans and policies adopted for the purposes of reducing GHG emissions, is a fact-based analysis of the project’s potential GHG and related climate change impacts.

This is because, as explained in the Draft EIR (p. 4.8-2), “Gases that “trap” heat in the atmosphere and affect regulation of the Earth’s temperature are known as ‘greenhouse gases’ . . .GHG that contribute to climate regulation are a different type of pollutant than criteria or hazardous air pollutants because climate regulation is g lobal in scale, both in terms of causes and effects . . . GHG emissions from human activities such as fuel combustion (e.g., CO2) and refrigerants use (e.g., hydrofluorocarbons, or HFCs) significantly contribute to overall GHG concentrations in the atmosph ere, climate regulation, and global climate change . . . The effects of increased GHG concentrations in the atmosphere include increasing shifts in temperature and precipitation patterns and amounts, reduced ice and snow cover, sea level rise, and acidific ation of oceans.

These effects in turn will impact food and water supplies, infrastructure, ecosystems, and overall public health and welfare.”
Response G-12: The City believes it has complied with the spirit (intent) as well as the legal and procedural requirements of CEQA and has made a good faith effort to provide a comprehensive detailed environmental information document for the public and decision-makers. The DEIR indicates the potential impacts of the project would not be unequally distributed onto at -risk populations or neighborhoods already bearing environmental burdens. The project is consistent with the General Plan and zoning designations, will only have one environmental impact that is significant and unavoidable even with mitigation (i.e., greenhouse gas emissions), and would benefit the community overall (see “Findings and Statement of Overriding Considerations”) when viewed in relation to its environmental impacts.

Response G -13: The commenter made a number of r ecommendations which was essentially the following laundry list of “requirements” the project should implement. It should be noted that many of these items appear to be related to the project’s supposed impacts to a disadvantaged neighborhood, but as the DEIR and FEIR clearly demonstrate, the project and surrounding properties are not within a disadvantaged community:

Zero-Emission Operations Timeline:
• 50% zero-emission (ZE) trucks by 2030. This project is a multi-tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their trucking fleet. This action would be implemented to the degree that new truck fleet operators will be required to buy zero emission trucks.

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• 100% zero-emission trucks by 2035. See response above regarding 50% ZE trucks by 2030. See response above relative to 50% zero emission trucks by 2030.
• Installation of charging infrastructure before occupancy . The project will install charging infrastructure required by the California Green Building Code and the City’s development requirements.
• Monthly emissions monitoring and public reporting. The project is not a logistics warehouse subject to the SCAQMD “Warehouse Actions and Investments to Reduce Emissions (WAIRE) Rule 2305 so monthly emissions monito ring and reporting is not required.

Community Health Protection:
• $5 million community benefit fund for health programs. The DEIR found no nexus or rough proportionality of project impacts that would require or suggest such a contribution since the air pollutant/health risk impacts of the project are less than significant under CEQA (only GHG emissions were found to be significant). • Indoor air filtration systems for nearby schools. As outlined in DEIR Section 4.9, Hazards and Hazardous Materials, there are no schools within a quarter mile of the project site and its air pollutant emissions would not exceed any SCAQMD or state (OEHHA) significance thresholds for health risks. Therefore, there is no nexus o r rough proportionality for imposing such a requirement on this project. • Community air monitoring network with real -time data. There is no nexus or rough proportionality to require such a measure for a project that is consistent with the GP and zoning and the EIR air quality assessment does not indicate it will result in significant air quality or health risk impacts. • Quarterly health impact assessments . See response above for community air monitoring network suggestion.

Local Hiring and Training:
• 50% local hire requirement (Menifee residents) . While the City may encourage new employers to hire local workers, it cannot mandate numerical hiring quotas.

In addition, the project is a multi -tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their individual hiring practices. This is also not a CEQA issue but the City may work with the applicant and/or future tenants to encourage local hiring practices.
• Partnership with community colleges for job training . This is not a CEQA issue but the City may work with the applicant and/or future tenants to encourage partnering with local community colleges for job training. • Living wage requirement ($25/hour minimum). The City cannot legally mandate wage requirements for future businesses since at present none have been selected for this multi-tenant business park.

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• Healthcare benefits for all employees . The City cannot legally mandate future tenants to provide healthcare benefits to their workers as those business practices are regulated by state and federal agencies and private insurance corporations.

Operational Restrictions:
• No operations between 10 PM and 6 AM . The City will enforce whatever appropriate operational hours limitations are established in its Municipal Code.

Since no tenants are currently identified, it is not possible to restrict or preclude future users from overnight activities.
• No idling beyond 3 minutes . The project is already subject to a 5 -minute idling limitation by City Conditions of Approval (COAs) consistent with SCAQMD recommendations. The appellant/commenter did not provide any support for imposing a more strict idling limit and the air quality ass essment for the project did not recommend a more stringent idling limit since air pollutant emissions were estimated to be less than significant.
• Designated truck routes avoiding residential streets . The City has established truck routes and mapping so trucks/drivers utilizing the proposed project will access the designated streets. The City will also impose a Condition of Approval (COA) restricting project trucks to designated truck routes and to inst all the necessary signage on the site for drivers to follow.
• Maximum 100 truck trips per day . DEIR Section 4.17, Transportation, did not identify any significant traffic -related impacts of the project related to either vehicle miles traveled (VMT) or levels of service (LOS) which is no longer considered a CEQA significance criteria for traffic impa cts. Therefore, there is no nexus or rough proportionality for requiring a daily truck traffic limit on the project.

Environmental Justice Compliance:
• Environmental Justice Advisory Committee (EJAC) with voting power. The City has an Environmental Justice Element (EJE) of its General Plan. However, CalEnviroScreen has not identified any disadvantaged communities within the City.

The EJE does not include an EJAC at this time and one would have to implemented at a City level and not for a particular development project. • Monthly compliance reports in English and Spanish. This would need to be a city- wide program as part of the EJE monitoring and it not currently in place. • Annual environmental justice impact assessment. This would need to be a city- wide program as part of the EJE monitoring and it not currently in place. • Community right to enforcement action . This would need to be a city -wide program as part of the EJE monitoring and it not currently in place.

Response G-14: The commenter/appellant states “the FEIR is fundamentally flawed and a new EIR must be prepared for the proposed project and circulated for public review. Appellant requests the City of Menifee City Council reverse the decision of the Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 217

Menifee Mayor and City Council
January 21, 2026
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28 MIG, Inc.

Planning Commission's certification of the project and require a new EIR. ” The City believes the DEIR and FEIR comply with the intent and legal requirements of CEQA and do not require revision and recirculation or preparation of a new EIR.

CONCLUSION
Staff’s conclusion is the two appeal letters do not provide significant new information or identify new significant impacts or information regarding the project or the DEIR analysis.

City staff concludes the information provided in the Draft EIR, its appendices (including Appendices E and L for which the public was provided adequate time to review), the Final EIR and all response to comments and supporting materials adequately address all the issues and comments raised. Therefore, the EIR meets the requirements of CEQA and it and its technical studies do not need to be revised and recirculated for additional public review.

Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 218

Menifee Mayor and City Council
January 21, 2026
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RESOLUTION NO. 26-______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MENIFEE, CALIFORNIA DENYING APPEAL NO. PLN25-0210 SUBMITTED ON

BEHALF OF THE SUPPORTERS ALLIANCE FOR ENVIRONMENTAL

RESPONSIBILITY FOR THE MENIFEE (PEMCOR) BUSINESS PARK
PROJECT, PLOT PLAN NO. PLN23-0245
WHEREAS, on December 21, 2023, the project applicant, Pemcor Properties, Inc. (“Applicant”), filed a formal application with the City of Menifee for the approval of Plot Plan (PP) No. PLN23-0245 Menifee (Pemcor) Business Park Project, a business park development consisting of 11 single-story buildings ranging in size from approximately 23,100 square feet to 37,840 square feet (total 337,770 square feet) on approximately 20 acres. The site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road (APN: 384-150-001); and
WHEREAS, collectively, all the applications are referred to as the “Project” or “Menifee (Pemcor) Business Park Project”; and
WHEREAS, pursuant to the requirements of the California Environmental Quality Act (CEQA), a Final Environmental Impact Report (EIR) and Mitigation Monitoring Reporting Program (MMRP) have been prepared to analyze and mitigate the Project's potentially significant environmental impacts; and
WHEREAS, on November 12, 2025, at a legally noticed public hearing, the Planning Commission voted 4-0-1 (Ramirez abstain) to certify the EIR, Findings of Fact, Mitigation Monitoring and Reporting Plan (MMRP), and approve PP No. PLN23-0245 for the Project; and
WHEREAS, on November 20, 2025, an application to appeal Planning Commission certification of the EIR for the Project and approval of PP No. PLN23-0245 was submitted by the Supporters Alliance for Environmental Responsibility (SAFER); and
WHEREAS, on January 21, 2026, the City Council of the City of Menifee held a public hearing on the appeal of the Planning Commission’s certification of the EIR and approval of PP No. PLN23-0245, considered all public testimony as well as all materials in the staff report and accompanying documents for the appeal, which hearing was publicly noticed by a publication in The Press Enterprise, a newspaper of general circulation, an agenda posting, notice to property owners within 1,000 feet of the Project boundaries, on-site posting at the Project site, and to persons requesting public notice.

NOW, THEREFORE, the City Council of the City of Menifee resolves as follows:

1. That the City Council finds the facts presented within the public record and within Exhibit “A” of the Resolution provides the basis to deny Appeal No. PLN25-0210.

2. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at the Community Development Department – Planning Division, 29844 Haun Road, Menifee, CA 92586. This Item Title: 11.1
Appeal of the Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 219

Menifee Mayor and City Council
January 21, 2026
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Appeal of Menifee (Pemcor) Business Park - SAFER
January 21, 2026

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