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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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nce complete, you will receive confirmation and a hearing date as well as additional appeal information. For questions, please contact the City Clerk at (951) 672-6777.
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
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 SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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 SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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 § SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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 SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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 SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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.
SAFER Comment
Menifee Business Park Project
PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
(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 SAFER Comment
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PC Agenda Item 9.2 (Nov. 12, 2025)
November 12, 2025
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
EXHIBIT A
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
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
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).
Updated September 2022
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.
Updated September 2022
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).
Updated September 2022
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 Updated September 2022
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 Updated September 2022
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 Updated September 2022
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.