- This document is designed for double-sided printing.-
Menifee (Pemcor) Business Park Project
33521 ZEIDERS ROAD PLOT PLAN PLN23-0245
STATE CLEARINGHOUSE # 2024071016
Final Environmental Impact Report
Lead Agency:
City of Menifee
Community Development Dept.
29844 Haun Road
Menifee, CA 92586
Contact: Russell Brown, AICP
(951) 723-3745
[email protected]
Applicant:
Pemcor Properties, Inc.
PO Box 903
Rancho Santa Fe, CA 92067
Contact: Paul Mayer
(604) 687-1818
[email protected]
Prepared by:
MIG, Inc.
6803 Indiana Avenue, Suite 203
Riverside, CA 92506
Contact: Kent Norton, AICP, REPA
(909) 518-8200
[email protected]
October 30, 2025
- This document is designed for double-sided printing.-
Menifee Business Park Project i
City of Menifee
Table of Contents Page
1 Introduction ............................................................................................................................. 1-1 2 Response to Comments ......................................................................................................... 2-1 3 Errata ...................................................................................................................................... 3-1 4 Public Circulation .................................................................................................................... 4-1 5 Mitigation Monitoring and Reporting Program (MMRP) .......................................................... 5-1
List of Tables
Table 2-1 DEIR Comments ........................................................................................................ 2-1 Table 5-1 Mitigation Monitoring and Reporting Program ........................................................... 5-3
APPENDICES
A Notice of Availability/Notice of Completion
B Local Mailing List
C NOA Legal Ad
D Updated Air Quality Study
E Updated GHG Study
ii Final Environmental Impact Report
October 30, 2025
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Menifee Business Park Project 1-1
City of Menifee
1.0 INTRODUCTION
This Final Environmental Impact Report (FEIR) has been prepared to comply with Sections 15088 and 15089 of the State California Environmental Quality Act (CEQA) Guidelines (Guidelines). The City of Menifee (City) has prepared the Final EIR pursuant to the CEQA Guidelines, including Sections 15086 (Consultation Concerning Draft EIR) and 15088 (Evaluation of and Responses to Comments). As noted in Section 15089(b) of the Guidelines, the focus of a FEIR should be on responses to comments on the Draft Environmental Impact Report (DEIR). In conformance with these guidelines, the Final EIR consists of the following volumes:
(1) The Draft EIR circulated for a 45-day public agency and public review and comment period commencing on September 2, 2025 and ending on October 16, 2025. A Notice of Availability was sent to neighboring cities, other government agencies and non-governmental interested parties. The City’s Notification List for the DEIR is provided in Section 4.0 (Public Circulation) of this FEIR.
(2) This Final EIR document includes all written comments received on the Draft EIR during the 45-day public review period, the written responses of the City to these comments, revisions to the Draft EIR in response to comments (presented in Section 3, Errata) and the public circulation record. None of the revisions to the Draft EIR represents a substantial increase in the severity of an identified significant impact or the identification of a new significant impact, mitigation, or alternative considerably different from those already considered in the Draft EIR.
Certification of this Final EIR by the Menifee Planning Commission must occur prior to approval of the Menifee Business Park Project (proposed Project or Project).
Availability of EIR Materials
All materials related to the preparation of this EIR, including information incorporated by reference, were available for public review. The Notice of Preparation and the Draft EIR were posted on the City’s website:
https://www.cityofmenifee.us/325/Environmental-Notices-Documents All materials related to the preparation of this EIR were also available for public review at the following physical location – anyone wanting to review the materials should contact the person listed at the phone number or email address listed:
Russell Brown, AICP, Senior Planner
City of Menifee Planning Department
29844 Haun Road, Menifee, CA 9586
(951) 723-3745
[email protected]
Following the 45-day period of circulation and public review of the Draft EIR, all comments and the City’s responses to the comments have been in corporated into this Final EIR prior to certification of the document by the City of Menifee.
1.0 Introduction
1-2 Final Environmental Impact Report
October 30, 2025
Summary Project Description
The proposed business park involves the development of 337,770 square feet of building area, which would be spread across 11 buildings. The entire 20.03 -acre site would be graded and the portions of the site not developed with buildings would either be har dscaped (e.g., parking or sidewalks) or landscaping. The 11 buildings will be massed into five primary groupings. T hree buildings will face Howard Way and two buildings will front on to Zeiders Road. The buildings range in size from 23,100 square feet to 37,840 square feet and feature two truck dock bays each that would be oriented toward the center of the site (a total of 22 truck docks at the site) and will not be visible from adjoining streets or neighboring properties. Building heights are 38 to 40 feet above ground level.
Contents of this Final EIR
The contents of this FEIR include the following sections:
Section 1: Introduction
Provides an overview of the EIR process and how comments on the Draft EIR will be addressed.
Section 2: Responses to Comments
The City published a Notice of Availability and circulated the Draft EIR for public review and comment for a 45-day review period from August 12, 2025 through September 29, 2025 but was recirculated or reissued on September 2 so the review period was extended to October 16, 2025.
Ten (10) pieces of correspondence w ere submitted to the City during the public review period (either written letters or emails) . This section includes a list of all correspondence submitted to the City of Menifee, each identified by a letter for later reference, together with the authors and the dates the letters were issued. Following this list, all of the letters are presented, with numbered brackets to highlight specific comments that are responded to in the next section.
Review of Environmental Documents. Section 15204 of the CEQA Guidelines provides guidance to the public and public agencies in reviewing CEQA documents. This section is designed not to limit the scope of comments that can be submitted but to focus comments on issues that are substantive to the environmental analysis. Commenting entities should focus on the adequacy of the document in identifying and analyzing impacts to the environment, and should identify any areas they believe to be inadequate. The guidance indicates that comments should be submitted in a manner that:
▪ Identifies a specific environmental effect
▪ Supports the effect and its significance with substantial evidence
Comments should include alternatives or mitigation measures to avoid or reduce identified, specific environmental effects. This section reiterates that the lead agency is bound by “reasonableness” and “good faith” in its analysis and that the lead agency i s not required to respond to comments on the FEIR that do not identify significant environmental issues.
Each response provided in this Final EIR is coded to correspond to the individual comment/author and each of the bracketed comments in that letter. The response will identify if the response introduces “new significant information” under any of the four categories identified in Section 15088 et seq. of the CEQA Guidelines.
1.0 Introduction
Menifee Business Park Project 1-3
City of Menifee
Evaluation of Comments. Section 15088 et seq. of the State CEQA Guidelines provides guidance on the evaluation and response to comments received during circulation of the Draft EIR. To summarize:
▪ The lead agency must evaluate all comments received during the public review period and prepare a written response to comments on significant environmental issues. ▪ The lead agency must provide the response to the commenting entity at least 10 days prior to certification of the EIR.
▪ The response must:
o Identify any significant environmental issues raised in the comment; o Explain, if necessary, why any recommendations provided in the comment were not accepted; and
o Be supported by reasoned analysis.
▪ Responses may be provided as direct revisions to the DEIR or as a separate section of the FEIR with marginal notes in the DEIR text indicated that it was subsequently revised.
A lead agency is required to recirculate the DEIR if “significant new information” is introduced during the public comment period. “Significant new information” includes:
1. New significant impacts
2. Substantial increases in the severity of impacts
3. Feasible alternatives or mitigation that would reduce significant impacts
4. Identification of inadequacies in the analysis
Recirculation is not required when new information is not significant; this includes:
▪ Revisions that clarify or amplify an adequate analysis ▪ Insignificant modifications (such as spelling and grammar corrections)
Section 3: Errata
This section identifies revisions to the Draft EIR to incorporate clarifications developed in response to comments on the Draft EIR. Additions to the text are underlined and deletions have been stricken through. No substantial revisions were made to the Draft EIR, and recirculation of the document is not required pursuant to CEQA.
Section 4: Notices and Distribution
This consists of notices concerning the City’s intent to prepare an EIR (Notice of Preparation) and release of the Draft EIR for public review and comment (Notice of Completion and Availability) , and the list of agencies, groups and individuals sent notices and/or a copy of the Draft EIR.
Section 5: Mitigation Monitoring and Reporting Program
CEQA and the State CEQA Guidelines (PRC Section 21081.6 and State CEQA Guidelines Sections 15091[d] and 15097) require public agencies “to adopt a reporting and monitoring program for changes to the project which it has adopted or made a condition of proje ct approval to mitigate or avoid significant effects on the environment.” A Mitigation Monitoring and Reporting Program (MMRP) is required for the proposed project because the EIR identifies potential significant adverse impacts related to the project impl ementation, and mitigation measures have been identified to reduce those impacts. Adoption of the MMRP would occur along with approval of the project.
1.0 Introduction
1-4 Final Environmental Impact Report
October 30, 2025
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Menifee Business Park Project 2-1
City of Menifee
2.0 RESPONSE TO COMMENTS
The Draft EIR was initially circulated for 4 5-day public review and comment period beginning August 12, 2025 and ending on September 29, 2025, however, it was recirculated or reissued on September 2 and the review period was extended to October 16, 2025 . A Notice of Availability was sent to government agencies, neighboring cities, and non -governmental interested parties.
The City’s Local Agency Notification List , showing who received notice of the Draft EIR, is provided in Section 4.0 - Public Circulation - of this FEIR. Ten (10) comment letters or emails were received from various agencies, conservation organizations, and private groups, as well as electronic notice from the California Office of Planning and Research (OPR) acknowledging receipt of the Draft EIR.
The correspondence listed in Table 2-1 (Draft EIR Comments) was submitted to the City of Menifee concerning the Draft EIR. Written responses to comments are subsequently provided.
The following responses to comments include a summary statement to identify if the response will introduce “new significant information” under any of the four categories i dentified in Section 15088 et seq. of the CEQA Guidelines or if it does not introduce “new significant information.” The four general categories are:
1. New significant impacts
2. Substantial increases in the severity of impacts
3. Feasible alternatives or mitigation that would reduce significant impacts
4. Identification of inadequacies in the analysis
A copy of each comment letter, followed by the City’s written responses to those comments follow.
2.0 Response to Comments
2-2 Final Environmental Impact Report
October 30, 2025
Table 2-1
DEIR Comments
ID Agency/Organization/Individual Date
State Agencies
A
California Office of Planning & Research, State
Clearinghouse acknowledging receipt and posting
of the DEIR
9-2-25
Regional or County Agencies/Companies
B Southern California Gas Company 9-5-25
C
South Coast Air Quality Management District
(SCAQMD) 10-16-25
D
Riverside County Airport Land Use Commission
(RCALUC) Email 8-18-25
E
Riverside County Flood Control and Water
Conservation District (RCFCWCD) Email
(Previous NOP Letter attached)
9-3-25
(7-29-24)
F
Riverside County Transportation Agency
(RCRTA) Email 9-22-25
G Riverside County Department of Waste Resources 9-16-25 Regional Organizations
H
Blum, Collins, & Ho LLP representing Golden State
Environmental Justice Alliance (GSEJA) including
supporting analysis letter from SWAPE
9-24-25
I Advocates for the Environment 9-29-25
J
Lozeau-Drury LLP representing Supporters
Alliance for Environmental Responsibility (SAFER) 10-10-25 City Organizations
None NA
Private Individuals/Organizations/Companies
None NA
2.0 Response to Comments
Menifee Business Park Project 2-3
City of Menifee
COMMENT EMAIL A – CALIFORNIA STATE CLEARINGHOUSE
2.0 Response to Comments
2-4 Final Environmental Impact Report
October 30, 2025
2 PAGES
Russell Brown
From:
Sent:
To:
Subject:
Meng Heu < Meng [email protected]>
Tuesday, September 2, 2025 3:29 PM
Russell Brown
SCH Number 20240710 16 LETTER A
[CAUTION]: This email originated from outside of the organization. Do not click link s or open attachments unle ss you recognize the sender and know the content is safe.
Hello ,
Your project is published and available for review. Please note th e State and Local review 'start ' and 'end ' dates
To view your project and any attachments via CEQAnet: Click " Navigatio n" and select " Publis hed Document"
Additional information is on State Clearinghouse (SCH) website - FAQs: https:/ /lei.ca.gov/sch/fag.html
Notice of Closing Letters: The SCH will not provide a close of review period acknowled geme nt on you CEQA environmental document. Comments submitted by State agencies are made available on CEQAnet by the SCH durin g and aft er th e revi ew p eriod.
To view comments on your project via CEQAnet, please
visit: https :/ /ceqa net. opr .ca .gov/Search/ Adva need • Search for the SCH# using th e Advanced Search in CEOAnet • Select the correct document.
• Und er "Att achments," view attac hments labe led "State Comment Letters (Comm ent s from Stat e Reviewing Agency(ie s)]"
• If there are no comments from a State agen cy about your project, it means none have been rece ived.
A -1
2.0 Response to Comments
Menifee Business Park Project 2-5
City of Menifee
**When Requesting Updates to Published/Posted Document(s)/Project(s): Please note that the State Clearinghouse (SCH) does not remove attachments from published projects unless there is confidential information that cannot be displayed online.
• To make changes to a published document, send requests and any attachments [Link]
to [email protected] . Please also provide a brief memo on lead agency lette rhead explaining what changes/corrections have been made.
Thank you,
Meng Heu I He/Him
Technical Business Analyst
Governor's Office of Land Use and Climate Innovation
(formerly known as Office of Plannin g and Research (OPR)) (916) 445-06131 meng [email protected]
opr.ca.gov I Follow us on Linked In I Follow us on X
**Note : No reply, response, or information provided constitutes legal advice .
To view your submission, use the following link.
https :/ /cegasu bm it. lei .ca .gov/Docu ment/I ndex/303525/4 Confidentiality Notice: The information contained in this emai l and any attac hmen ts is for the exclusi ve use of the intended recipient( s) and may contain confidential and privileged info rmation. It is the property of the California Governor's Office of Land Use and Climate Innovation . Unauthori zed use, disclosur e, or copying of this communication or any part ther eof is strictly prohibited and may be unlawful. If you are not the intended recipient , please notify t he sende r immediately by return email and destroy all copies of the original messa ge and any attachments. 2 2.0 Response to Comments
2-6 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Email A - State Clearinghouse
A-1 The City acknowledges receipt of the Draft EIR for distribution to state agencies through the State Clearinghouse. We also acknowledge the 45 -day public review period runs from April 29, 2025, to June 13, 2025, consistent with our local distribution and newspaper notification date. Thank you for your assistance in this regard.
2.0 Response to Comments
Menifee Business Park Project 2-7
City of Menifee
COMMENT EMAIL B - SOUTHERN CALIFORNIA GAS COMPANY (SCGC or SoCalGas)
2.0 Response to Comments
2-8 Final Environmental Impact Report
October 30, 2025
1 PAGE
Fw: PLN23-0245 Menifee (Pemcor) Business Park Project - [email protected] - Moore lacofano Goltsman Inc Mail ~ Searchmail Active y
II S
El
From: Liao, Willi am <WI iao@socal@s COOP
Sent: Friday, September 5, 2025 2:44 PM
To: Russell Brown <rbrown@cityofm enifee.us>
Cc: SCGSE Redlands <SCGSFRegionRedlaods\JtilitvReo,1est@sernnra11tilities cmn> Subject: FW: PLN23-0245 Menife e (Perncor) Business Park Project You don't often get email from Wfaq@socalgrn . Learn whythi§ is Im~
LETTER B
![CAUTION]: This email originated from outside ct the organization Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Russell.
My name is Will Liao. I am the Region Planning Supervisor for SoCalGas, Redlands HQ. I have received your letter regarding PLN23-0245.
Sof36
SoCalGas has existing medium-pressure facilitie s in t he project area along Zeiders and Bailey Park/Ciccotti. Please help us ensure everyone's safety and have t he developer contact 811/USA prior to any excavation/demolition activities so we can get out to Locate & Mark out our facilities. Also, please have developer send us any plans to our Utili ty Request inbox copied on this email so we can review for conflicts.
If the developer needs gas service, please have them reach out to our Builder Services group as soon as practicable to begin the applic ation pro cess, at Builder Services I SoCalGas.
Please let me know if you have any questions.
Will Liao
Mobile: 840 - 213 - 5899
From: Liao, Willi am <WUao@~ ga5.com>
Sent: Friday, September 5, 2025 2:12 PM
To: Liao, William <WUao @..iQ0.!gas.com >
Subject:
[Message clipped] View entire messaQQ.
B-1
1/1
2.0 Response to Comments
Menifee Business Park Project 2-9
City of Menifee
ID Response to Email B – Southern California Gas Company B-1 The City understands that SoCalGas has existing medium -pressure natural gas facilities in the project area along Zeiders and Bailey Park/Ciccotti. The developer will be conditioned to contact 811/USA prior to any excavation/demolition activities so SoCalGas can locate and mark their facilities. In addition, the developer will be required to send SoCalGas their plans to their Utility Request inbox (copied on this email) so SoCalGas can review the plans for any conflicts. It is anticipated the developer will need gas service so they will be required to contact SoCalGas Builder Services Group to begin the application process.
This information will be added to EIR Section 4.19, Utilities and Service Systems, regarding natural gas service.
2.0 Response to Comments
2-10 Final Environmental Impact Report
October 30, 2025
COMMENT LETTER C – SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD)
2.0 Response to Comments
Menifee Business Park Project 2-11
City of Menifee
~ South Coast
~ Air Quality Management District
--21865 Copley Drive, Diamond Bar, CA 9 1 765-41 78
Lil!llll!J (909) 396-2000, www.aqmd.gov
SENT VIA E-MAIL;
[email protected]
Oc!Ober 16, 2025
Ruiaell Brown. AICP, SaJiar Plmmer
City ofMaiif'ce, Community Dcvelopmem Department
29844 Haun Road
LETTERC
Mmili:e, CA 92586
Dnft EllW'HDletital Jmp, .... R!'P""I (EIR) for the PropONCI Mrdrs iPppmr) Jte♦nr Perk DPiert (PmPPKf. DPiert)
(SCH No.; 2Q24Q71QH)
South Cout M Qualil;y Mwuagmient l)illlril:t (South Cout AQMD) Bbl.lf llpJDCi■tel 1he oppammity to comment on the a)ove-mcnlioned document. TIie City of Menifee is die California Bnvironmemal Quall~ Act (CEQA) Lead Agency for the Pmposed Project. To provicli, c:cmtm, Soulh Cout AQMD a111fi'ball provided a brief IIUDllllal)' of the projcet immmation and piepatc.d 1he filllowiDg cOIIIISDta, orpnized by topic of concem.
Smnmncr qf PJpject Jufimvtipp in Jiu: PIJLft BIR
Based an the Dillft BIR. the Pmpmed Project involve& die dmnalition of an existing esidmdial atrucluJC and the subeequent dewelopnent of 11 iildustrial buildingB, tn1ll~oci111•Wy 337,770 sqaare teet.1 The Pm_posed Project is planmd to inclwlll 22 trur.k 10lding and is anticipeled to generate approximately 154 truck 1rips per day during opention.3 The site ia loc:aled. at 33S21 ZeideJS ROid in Ml::ail'ee.' Based ou a review of cmrcnt aerial image:ry, lhe n.eerat 11e111ilhe recqnor (e.g., Naidelltial uae) is located a_pproximatdy 120 feet to the nadh of the p!Op0led dewlo_pmmt site_ Colll&Iw:lion aetivitieB an, .,,1wh,h,d to Comtlltl1C4I in wmm- l02S and an, npecud to llpllll approuutely 18 mODlhs,5
South Coat AQMD Cummellla
Umupponed 7nlck 7Wp Dlnana .bawnptloM u,ed bl Eml.vk,116 Modeling ACCQl8tely estimating llock 1rip len,:tha is a by parameter when qwrnlifyjDg emwiou &om mobil.o _., especially dime! particulate m8lll!r (DPM;), midl!s of Dib:opn (NOx), and gmenb- pw (OHO). The miedianwtc:malian of avenige q. bgthB, for aarnple, c:m lead to a !ignificam Ullde!e&timalion ofa project's a.irquality impacfs. Accontins to Appendix Bl: MQuality and Hca11h Risk Anessment, a weighted truck trip distana, was developed and rNUbcl in apJIOXimately 31-8 mile■ p« llip.~ However, the analym Jaw the suppm1iDg buis fm detmDiDing 1he llip origiDB 1111d deetinatiou and whc1her the U8llllled clittances ate reflective of ICllial or anticipetecl roll1ing p.uem, of the lacility'a cmrentorfilture 1rllCk fleet.
l Dndl;BJR. p. !-1.
2 lbi4. p. 3-7.
, lbi4. p. 4.17-6.
4 .lbll. p. 3-1.
1Jbll.p.)-2o.
1 Appa,,dmBI: Air~ a4tr.Jthltill- /\nmmml p. 4-4.
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2.0 Response to Comments
2-12 Final Environmental Impact Report
October 30, 2025
Russell Brown, AICP , Senior Planner October 16, 2025
As such, the Final EIR should include a clear and defensible rationale for the use of the 31.8 miles.
The rationale should be supported by docwnentation such as empirical data from fleet operations, transportation logistics studies, regional freight movement data, or other sources that demonstrate the applicability and appropriateness of the selected distances. Additionally, if any truck trips associated with the Proposed Project will include port-related activities, the Final EIR should explain this detail and the modeled trip lengths should accurately reflect the mileage between the Proposed Project site and the relevant port(s), such as the Ports of Los Angeles or Long Beach, which are located approximately 82 to 98 miles one-way from the Proposed Project site.
Therefore, the Lead Agency is recommended to either revise the trip distance assumptions to more accurately reflect realistic operational conditions or provide additional evidence substantiating that the selected distances are representative of actual or reasonably foreseeable truck travel patterns associated with the Proposed Project. Failure to provide supporting evidence to validate these assumptions may compromise the accuracy of the emission estimates, conclusions, and the overall integrity of the air quality analysis presented in the Final EIR.
Truck Idling Duration and Emissions Modeling
Appendix El indicates that an assumption of 15 minutes of idling per truck per day was used to estimate DPM emissions for the operational health risk assessment (HRA).7 However, it may not accurately reflect the actual operating conditions of the Proposed Project. The Proposed Project is anticipated to generate approximately 154 truck trips per day, and for a logistics or distribution facility, 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, particularly during peak hours or in constrained circulation areas. As such, a 15-minute idling duration may underestimate actual on-site idling behavior and, consequently, DPM emissions, which are a key contributor to localized health risks.
While the California Air Resources Board (CARB) limits diesel truck idling to five minutes as set forth in the Airborne Toxic Control Measure (ATCM), an exemption from this requirement is allowed for trucks equipped with engines that meet the optional low-NOx idle emission standard, which is typically applicable to model year 2008 and newer trucks. These vehicles, often referred to as "clean idle" certified, are permitted to idle longer than five minutes when situated more than 100 feet from sensitive land uses such as homes and schools.8 Furthermore, CARB's EMFAC2021 Volume III Technical Document (Table 4.4.2-5) indicates that heavy-duty trucks may idle for up to five hours at a single location under certain conditions.9 As a practical matter, the idling duration for onsite heavy-duty trucks visiting the Proposed Project site could idle for a much longer duration than what was analyzed in the Draft EIR. Thus, the HRA may have substantially underestimated the full extent of operational health risks associated with the DPM emissions from the anticipated onsite heavy-duty truck activities.
Accurate characterization of idling activity is essential to fully assess a project's potential health risk impacts, particularly for nearby sensitive receptors. Therefore, to ensure the HRA provides a 7 Appendix El. p. 4-9.
8 CARB, Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling was promulgated in Chapter 13 of the California Code of Regulations, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling, https://ww2.arb.ca .gov/sites/default/files/2022-06 /13 CCR 2485 OAL 06222022- 2 ADA 06272022 O.pdf
9 CARB, EMFAC2021 Volume ill Technical Document, Table 4.4 .2-5, p. 161., available at https:/lww2.arb.ca.gov /sites/default/files/2021-03 /emfac2021 volume 3 technical document pdf -2-
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2.0 Response to Comments
Menifee Business Park Project 2-13
City of Menifee
Russell Brown, AICP, Senior Planner October 16, 2025
conservative and health-protective estimate of potential exposure, the Lead Agency is recommended to either: 1) revise the operational emissions modeling in the Final EIR to assume a minimum of 30 minutes of idling per truck per day, unless site-specific data or operational constraints justify a shorter duration; or 2) provide empirical evidence, such as facility-specific queuing and processing time studies, vehicle circulation modeling, or comparable industry data, to substantiate the 15-minute assumption as representative of expected operations of the Proposed Project.
Potentially Inco"ect Meteorological Data in the Health Risk Assessment Modeling Appendix El of the Draft EIR indicates that meteorological (MET) data from the South Coast AQMD 's Perris (PERI) station were used for the air dispersion modeling conducted with AERMOD.
Specifically, the modeling utilized five years of PERI station data spanning January 1, 2010, to December 31, 2011, and January 1, 2014, to December 31, 2016.10 It should be noted that this data corresponds to Version 9 of South Coast AQMD's AERMOD-ready MET dataset, which is no longer available. South Coast AQMD released an updated version of AERMOD-ready meteorological data (Version 11) in October 2024.11 This updated dataset was developed using the U.S. EPA's AERMET processor (Version 22112), along with AERMINUTE (Version 15272) and AERSURFACE (Version 20060), and reflects current regulatory guidance and processing methodologies.
Based on the updated Version 11 MET data, the closest available station to the Proposed Project site is the Temecula (TMCA) station, not the Perris (PERI) station. While proximity is a consideration, it is important to recognize that the nearest meteorological station may not always be the most representative of site-specific conditions. Therefore, in accordance with South Coast AQMD guidance and U.S. EPA modeling protocols, the Lead Agency is recommended to evaluate the representativeness of available meteorological data, including prevailing wind patterns, topography, and land use, when selecting the appropriate station for dispersion modeling.
To ensure technical accuracy, transparency, and consistency with current South Coast AQMD recommendations, the Lead Agency is recommended to:
• Reassess the selection of meteorological data using the latest Version 11 dataset • Evaluate the most representative station for the project site (e.g., TMCA versus PERI sites) • Revise the AERMOD modeling inputs accordingly
• Include updated air quality modeling results in the Final EIR This approach will ensure that air dispersion modeling is based on the most recent and appropriate meteorological data, thereby supporting a robust and defensible environmental analysis.
Potential Underestimation of Cancer Risk Calculations in Health Risk Assessment Appendix El of the Draft EIR states that the health risk assessment (HRA) for residential receptors evaluates exposure from the third trimester through 30 years of age, resulting in a reported cancer risk of 6.8 in one million, below South Coast AQMD's cancer risk significance threshold of IO in one million.12
10 Appendix El. p. 4-8.
11 South Coast AQMD AERMOD-Ready MET Data Files available at https:/lwww.aqmd.gov /assets/aermet/AERMET files And HRA Tool.html ll Appendix El. p. 4-25.
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2.0 Response to Comments
2-14 Final Environmental Impact Report
October 30, 2025
Russell Brown, AICP, Senior Planner October 16, 2025
However, a review of the technical calculation file provided by the Lead Agency, titled PEMCOR_HRACalcs, indicates that third-trimester exposure was only considered during the Year 1 construction phase. Notably, early-life exposure groups, the third trimester, were excluded from the operational phase of the project (Years 3-30), during which DPM emissions from truck activity and other sources continue to be present and may contribute to long-term health risks. This omission may result in an underestimation of the lifetime cancer risk for residential receptors, as early-life exposures are generally associated with higher sensitivity to toxic air contaminants, particularly DPM, which is classified as a carcinogen by the California Office of Environmental Health Hazard Assessment (OEHHA).
Given that the reported excess cancer risk is close to the South Coast AQMD threshold, the exclusion of early-life exposure during the operational period represents a significant limitation in the HRA methodology. Therefore, to ensure a complete and health-protective risk assessment consistent with the OEHHA's Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (2015), 13 the Lead Agency is recommended to:
• Re-calculate the lifetime cancer risk to include early-life exposure (third trimester) during the entire exposure duration of 30 years, including the operational phase • Re-evaluate the total excess cancer risk from DPM emissions during both construction and operational activities
• Include the revised HRA and updated results in the Final EIR.
This approach will improve the accuracy and public health defensibility of the environmental analysis and ensure compliance with South Coast AQMD and OEHHA guidance.
Additional Recommended Air Quality and Greenhouse Gas Mitigation Measures and Project Design Features for Consideration
CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized to minimize or eliminate any significant adverse air quality impacts. To further reduce the Proposed Project's air quality impacts, South Coast AQMD recommends incorporating the following mitigation measures and project design considerations into the Final EIR.
Mitigation Measures to Reduce Operational Air Quality Impacts from Mobile Sources
1. Require zero-emission (ZE) or near-zero emission (NZE) on-road haul trucks, such as heavy duty trucks with natural gas engines that meet the CARB's adopted optional NOx emissions standard at 0.02 grams per brake horsepower-hour (g/bhp-hr), if and when feasible.
Note: Given CARB 's clean truck rules and regulations aiming to accelerate the utilization and market penetration of ZE and NZE trucks, such as the Advanced Clean Trucks Rule and the Heavy-duty Low NOx Omnibus Regulation, ZE and NZE trucks will become increasingly more available for use.
2. Require a phase-in schedule to incentivize the use of cleaner operating trucks to reduce any significant adverse air quality impacts.
13 OEIIBA Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments available at htq>s://oehha.ca.gov/sites/default/files/media/downloads/cmr/2015guidancemanual.pdf -4-
C-5
C-6
2.0 Response to Comments
Menifee Business Park Project 2-15
City of Menifee
Russell Brown, AICP, Senior Planner October 16, 2025
Note: South Coast AQMD staff are available to discuss the availability of current and upcoming truck technologies and incentive programs with the Lead Agency .
3. Limit the daily number of trucks allowed at the Proposed Project to levels analyzed in the Final EIR. If higher daily truck volumes are anticipated to visit the site, the Lead Agency should commit to re-evaluating the Proposed Project through CEQA prior to allowing this higher activity level.
4. Provide electric vehicle (EV) charging stations or, at a minimum, provide electrical infrastructure, and electrical panels should be appropriately sized. Electrical hookups should be provided for truckers to plug in any onboard auxiliary equipment.
Mitigation Measures to Reduce Qperational Air Quality Impacts from Other Area Sources
1. Maximize the use of solar energy by installing solar energy arrays.
2. Use light-colored paving and roofing materials.
3. Utilize only Energy Star heating, cooling, and lighting devices and appliances.
Design Considerations for Reducing Air Quality and Health Risk Impacts
1. Clearly mark truck routes with trailblazer signs so that trucks will not travel next to or near sensitive land uses (e.g., residences, schools, daycare centers, etc.).
2. Design the Proposed Project such that truck entrances and exits are not facing sensitive receptors, and trucks will not travel past sensitive land uses to enter or leave the Proposed Project site.
3. Design the Proposed Project such that any truck check-in point is inside the Proposed Project site to ensure no trucks are queuing outside.
4. Design the Proposed Project to ensure that truck traffic inside the Proposed Project site is as far away as feasible from sensitive receptors.
5. Restrict overnight truck parking in sensitive land uses by providing overnight truck parking inside the Proposed Project site.
Lastly, the South Coast AQMD also suggests that the Lead Agency conduct a review of the following references and incorporate additional mitigation measures as applicable to the Proposed Project in the FinalEIR:
1. State of California - Department of Justice: Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act14
2. South Coast AQMD 2022 Air Quality Management Plan, 15 specifically:
14 State of California- Deparlment of Justice, Warehouse Projects : Best Practices and Mitigation Measures to Comply with the California Environmental Quality A~ available at https;//oag.ca.gov/system/files/media/warehouse-best-pragices,pdf 15 South Coast AQMD, 2022 Air Quality Management Plan (AQMP) available at http://www.aqmd.gov/home/air-<mality/clean air-plans/air-gua]ity-mgt-plan
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C-6
C-7
C-8
C-9
2.0 Response to Comments
2-16 Final Environmental Impact Report
October 30, 2025
Russell Brown, AICP, Senior Planner October 16, 2025
a) Appendix N-A- South Coast AQMD's Stationary and Mobile Source Con1rol Measures b) Appendix N-B-CARB's Strategy for South Coast
c) Appendix N-C - SCAG' s Regional Transportation S1rategy and Control Measure
3. United States Environmental Protection Agency (U.S. EPA) Transportation, Air Quality, and Climate Change.16
South Coast AQMD Air Permits and Role as a Responsible Agency If implementation of the Proposed Project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, etc., one or more air permits from South Coast AQMD will be required. The Final EIR should include a discussion about the South Coast AQMD rules that may be applicable to the Proposed Project. Those rules may include, for example, Rule 201 - Permit to Construct,17 Rule 203 - Permit to Operate,18 Rule 401 - Visible Emissions,19 Rule 402 - Nuisance,20 Rule 403 - Fugitive Dust,21 Rule 1110.2 - Emissions from Gaseous and Liquid Fueled Engines,22 Rule 1113 - Architectural Coatings,23 Regulation XIII - New Source Review,24 Rule 1401 - New Source Review of Toxic Air Contaminants,25 and Rule 1470 - Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines,26 etc.
It is important to note that if air permits from the South Coast AQMD are required, South Coast AQMD's role under CEQA will become the Responsible Agency of the Proposed Project. Per CEQA Guidelines Section 15086, the Lead Agency is required to consult with South Coast AQMD. CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including ma.king a decision on the adequacy of the CEQA document for use as part of the process for conducting a review of the Proposed Project and issuing discretionary approvals. Also, as set forth in CEQA Guidelines Section 15096(h), the Responsible Agency is required to make Findings in accordance with CEQA Guidelines Section 15091 for each significant effect of the project and issue a Statement of Overriding Considerations in accordance with CEQA Guidelines Section 15093, if necessary. Lastly, as set forth in CEQA Guidelines Section 15096(i), the Responsible Agency may file a Notice of Determination.
CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including ma.king a decision on the adequacy of the CEQA document for use as part of the process for conducting a review of the Proposed Project and issuing discretionary approvals. Moreover, it is important to note that if a Responsible Agency determines that a CEQA document is not adequate to rely upon for its 16 United States Environmental Protection Agency (U.S. EPA) Transportation, Air Quality, and Climate Change available at bttps://www.epa.gov/transportation-air-pollution-and-climate-change 17 South Coast AQMD, Rule 201 available at https://www.aQmd.gov/docs/default-source/rule-book/reg-ii/rule-201.pdf 18 South Coast AQMD, Rule 203 available at https://www.agmd .gov/docs/default-source/rule-book/reg-ii/rule-20 3.pdf 19 South Coast AQMD, Rule 401 available at https://www.agmd.gov/docs/default-source/rule-book/rule-iv/rule-401.pdf 20 South Coast AQMD, Rule 402 available at https://www.agmd.gov/docs/default-source/rule-book/rule-jv/rule-402 .pdf 21 South Coast AQMD, Rule 403 available at https://www agmd goy/docs/default-source/rul e-book/rule-iy/rule-403 22 South Coast AQMD, Rule 1110.2 available at https://www.agmd.gov/docs/default-source/rule-book/reg- xi/rl 110 2.pdf 23 South Coast AQMD, Rule 1113 available at https://www.agmdgov/docs/default-source/rule-book/reg-xi/rl 113.pdf 24 South Coast AQMD, Regulation XIII available at: https:/fwww.agmd.gov/bome/rules-compliance/rules/ scagmd-rule book/regulation-xiii
2' South Coast AQMD, Rule 1401 available at https://www.agmd.gov/docs/default-source/rule-book/reg-xiv/rule-1401.pdf 26 South Coast AQMD, Rule 1470 available at https://www.agmd.gov/docs/default-sourc e/rule-book/reg-xiv/rule-1470.pdf -6-
C-9
C-10
C-11
2.0 Response to Comments
Menifee Business Park Project 2-17
City of Menifee
7 PAGES
Russell Brown, AICP, Senior Planner October 16, 2025
discretionary approvals, the Responsible Agency must take further actions listed in CEQA Guideline Section 15096(e), which could have the effect of delaying the implementation of the Proposed Project.
In its role as CEQA Responsible Agency, the South Coast AQMD is obligated to ensure that the CEQA document prepared for this Proposed Project contains a sufficient project description and analysis to be relied upon in order to issue any discretionary approvals that may be needed for air permits.
For these reasons, the final CEQA document should be revised to include a discussion about any and all new stationary and portable equipment requiring South Coast AQMD air permits, provide the evaluation of their air quality and greenhouse gas impacts, and identify South Coast AQMD as a Responsible Agency for the Proposed Project as this information will be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD's Engineering and Permitting staff at (909) 396-3385 for questions regarding what types of equipment would require air permits. For more general information on permits, please visit South Coast AQMD's webpage at https://www.agmd.gov/home/permits.
Conclusion
As set forth in Public Resources Code Section 21092.S(a) and CEQA Guidelines Section 15088(a-b), the Lead Agency shall evaluate comments from public agencies on environmental issues and prepare a written response at least 10 days prior to certifying the Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c), if the Lead Agency's position is at variance with recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.
Thank you for the opportunity to provide comments. South Coast AQMD staff are available to work with the Lead Agency to address any air quality questions that may arise from this comment letter.
Please contact Danica Nguyen, Air Quality Specialist, at [email protected] should you have any questions.
Sincerely,
SaM~
Sam Wang
Program Supervisor, CEQA IGR
Planning, Rule Development & Implementation
SW:DN
RVC250902-03
Control Number
-7-
C- 11
C-12
2.0 Response to Comments
2-18 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter C – South Coast Air Quality Management District C-1 In this comment, the SCAQMD introduces their letter and provides an accurate summary of the Project. Since the comment does not raise any specific questions or comments on the DEIR, no further response is warranted.
C-2 The SCAQMD argues that the analysis lacks evidence for the 31.8 mile trip distance and that the EIR should be revised with updated trip distances or with additional evidence for the selected trip distance, such as empirical data from fleet operations, transportation logistics studies, or regional freight movement data. Add itionally, SCAQMD requests that the EIR explain if there are trips associated with the Ports, and update trip distances accordingly.
The EIR’s estimate of truck trip length is based on regional data from the Southern California Association of Governments’ 2016 Regional Transportation Plan (RTP) used by the SCAQMD in its development of SCAQMD Rule 2305 Warehouse Indirect Source Rule - Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program. The SCAG and SCAQMD data identify a 15.3-mile trip length for Class 2b-3 trucks, a 14.2-mile trip length for Class 4-7 trucks, and a 39.9-mile trip length for class trucks. Appendix E-1 was revised to provide this evidence for the trip distances.
CEQA calls for disclosure of the projects anticipated truck trips based on a likely truck trip destination. However, the reasoning provided in the WAIRE Technical Report indicates that trucks visiting a given facility may involve varying arrangements and operating profiles. As an example, provided in the WAIRE Technical Report, “one truck may travel 30 miles on the inbound trip, and only two miles on the outbound trip.” The memo also acknowledges that one truck may be loaded with goods from multiple warehouses, such that determining what portion of the trip is attributed to each portion of the operation would be impractical. As a result, the weighted average represents a practical estimation of calculating likely truck trip lengths associated with the projec t.
Using the over proportional distance between the project and the nearest ports would double-count the operating arrangements, trips, and lengths that have already been attributed to facilities interfacing with the project.
C-3 SCAQMD argues that the 15-minute idling time used to estimate DPM emissions may underestimate truck activity and associated emissions, noting that there are exemptions to CARB’s Airborne Toxic Control Measure. The SCAQMD recommends the DEIR be revised to a ssume up to 30 minutes of idling per truck per day or that justification be provided for a shorter duration. The City will place a five -minute idling limit on the Project as a Condition of Approval. Therefore, no changes to the DEIR’s operational emissions or text are warranted at this time.
C-4 SCAQMD argues that AERMOD inputs should be revised based on an updated version of meteorological data released in October 2024. This data was released after the project’s Notice of Preparation was released in July 2024 and after modeling was completed on S eptember 12, 2024 (see AERMOD Output file in Appendix E -1). The EIR was evaluated with the data available at the time of its preparation. No change is warranted at this time to the DEIR text.
C-5 The SCAQMD asserts the DEIR underestimated health risks because the third trimester life stage was only exposed to Project emissions in modeled emissions Year 1 and the 0 -2 age life stage was only exposed to Project emissions in modeled emissions Year 1 and 2.
2.0 Response to Comments
Menifee Business Park Project 2-19
City of Menifee
ID Response to Comment Letter C – South Coast Air Quality Management District The SCAQMD is correct that Appendix E1 only includes 3 rd trimester and child (0 -2 years old) age groups in certain exposure scenarios; however, the SCAQMD is incorrect that the DEIR has underestimated potential adverse health risks.
Construction 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 -1, 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. No change in the DEIR text is warranted at this time.
C-6 SCAQMD recommends four specific mitigation measures/project design considerations to incorporate into the EIR to reduce emissions of air quality pollutants and GHG emissions from mobile sources:
• The SCAQMD recommends the City require ZE or NZE on-road haul trucks “if and when feasible”. It is not clear if the SCAQMD recommends this measure to reduce emissions associated with hauling goods and materials during construction activities, operational t rucking emissions, or both. Nor is it clear, as written, “if and when” the SCAQMD’s recommendation would be feasible.
Nonetheless, for construction, the Draft EIR concludes that regional construction air quality impacts would primarily be the result of arc hitectural coating activities, and would be reduced to less than significant levels with Mitigation Measure AIR-1. Thus, reducing truck emissions would not reduce or avoid this impact. For operation, the City finds this measure 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 sites operating characteristics, and neither the City nor future individual developers/tenants can regulate mobile emissions, which is within the purview of state regulatory agencies such as the California Air Resources Control Board (CARB) and local agencies, such as the SCAQMD.
Those agencies can, and have, adopted regulations intended to redu ce emissions from mobile sources, including trucks. The Draft EIR, for example, summarizes CARB’s Advanced Clean Truck Rule, which accelerates a large - scale reduction of tailpipe emissions by focusing on ZE medium and heavy - duty vehicles. The Advanced Clea n Truck Rule and its mandates reflect what CARB considered to be feasible implementation schedules, reflecting technological availability and feasibility. Cars and trucks accessing a specific development project in the plan area in the future would be required to comply with applicable regulations; however, the commenter’s suggestion to require ZE or NZE trucks “if and when feasible” reflects the uncertainty regarding the timeline for availability of those technologies.
• The SCAQMD recommends the City require a phase-in schedule to incentivize the use of cleaner operating trucks. As noted above, developing a phase -in
2.0 Response to Comments
2-20 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter C – South Coast Air Quality Management District schedule is not required because CARB regulations already set forth targets for ZE and NZE deployment.
• The SCAQMD recommends the City limit the daily number of trucks allowed at the project site to the levels analyzed in the EIR and require re -evaluation of the project if higher daily truck volumes are anticipated to visit the site. This suggestion does not reduce the Project’s mobile source emissions and is not warranted for the Project. The Draft EIR made realistic assumptions about the proposed Project’s potential passenger vehicle, truck traffic, and air quality and GHG emissions impacts, and there is no evidence at this time to indicate the Project will exceed the activity levels or emissions estimates presented in this EIR. The City notes that, pursuant to CEQA Guidelines Section 15168 and/or other CEQA provisions, when future implementing projects are proposed, they will require review by the City and, if found to have effects that were not examined in the Program EIR, would be subject to more detailed, individual analysis.
The SCAQMD recommends the City require electric vehicle charging stations or, at minimum, provide electrical infrastructure to support electric vehicle technologies, including electrical hook ups for truck auxiliary engines. It should be noted that Mitigation Measure GHG-2 requires the project to implement electric vehicle charging infrastructure for light -duty vehicles consistent with Tier 2 provisions in the 2022 CALGreen Code. Additionally, as stated in Appendix E-1 (page 3-19), the project would comply with the electrical hook up requirement in the City’s Industrial Good Neighbor Policies. Therefore, the project would be consistent with the electric vehicle charging recommendations.
C-7 The SCAQMD recommends three specific mitigation measures to incorporate into the EIR to reduce operational air quality impacts from other area sources:
• The SCAQMD recommends the project maximize solar energy by installing solar arrays. Through the implementation of Mitigation Measure GHG-4, which states that the City shall require that the proposed buildings include PV solar panels on a minimum of 15% of the total roof area, the project would build upon the 2022 CALGreen Code requirement that 15% of the roof is solar -ready and guarantee that the use of solar energy would occur at the start of project operations. Therefore, the project already includes miti gation that is commensurate with this SCAQMD recommendation (see FEIR Section 3, Errata).
• The SCAQMD recommends using light -colored paving and roofing materials.
The project would consist of concrete tilt-up buildings, a light-colored material.
Furthermore, Title 24 Energy Code already includes design guidelines and requirements commensurate with this measure. For example, the building code establishes minimum solar reflectance index values for non -residential buildings (24 CCR, Section 10 -113, Mandatory Certification and Labelling of Roofing Product Reflectance and Emittance), as well as reflective requirements for building envelopes (Section 140.3(a)1).
2.0 Response to Comments
Menifee Business Park Project 2-21
City of Menifee
ID Response to Comment Letter C – South Coast Air Quality Management District The SCAQMD recommends using only Energy Star appliances and devices. While the project does not have a specific requirement for Energy Star products, it would be subject to 2022 CalGreen Code energy efficiency standards, and appliance and lighting efficien cy standards. Additionally, emission reductions from buildings would already occur with the all-electric and solar mitigation (see Mitigation Measures GHG- 3 and GHG-4 per FEIR Section 3, Errata).
C-8 The SCAQMD recommends five specific Project design considerations to incorporate into the EIR to reduce emissions of air quality pollutants and potential health risk impacts. As a point of clarification, the EIR concludes that localized air quality impacts would be less than significant with mitigation and that health risks would be less than significant. Thus, since the EIR already concludes that potential local air quality and health risk impacts would be less than significant, additional mitigation is no t required to address this impact. Additionally, the project would comply with the City’s Industrial Good Neighbor Policies, including the routing truck traffic to impact the least amount of sensitive receptors, designing buildings so truck driveways and l oading docks are oriented away from sensitive receptors, minimizing the potential for truck queuing to occur and locating queuing away from sensitive receptors. No change in the DEIR text is warranted at this time.
C-9 The SCAQMD suggests the City review more than 500 pages of material that are generally referenced and to incorporate mitigation measures “as applicable”. This comment does not identify any specific measure or measures that the SCAQMD recommends for incorporation into the EIR, nor does it suggest why measures included in the more than 500 pages are specifically relevant or related to the Project and/or the DEIR’s air quality and GHG impact analyses. Nonetheless, the City has reviewed the documents referenced by the SCAQMD and determined that the majority of measures identified in the referenced materials are already reflected in/included in the proposed Project:
• Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act. Many of the best practices identified in this document are commensurate with the requirements of existing regulations and/or the mitigation measures already into the DEIR. For example, Section V. Air Quality and Greenhouse Gas Emissions Analysis and Mitigation, contains a measure to use paints that have volatile organic compound levels of less than 10 grams per liter, which is already required by Mitigation Measure AQ-1. Section V’s measures to reduce travel demand would also be commensurate with the requirements of Mitigation Measure GHG-1 (see FEIR Section 3, Errata) . Most other measures identified in the best practices document are either not applicable to the Project or not considered feasible for the Project.
• SCAQMD 2022 AQMP: The three appendices referenced contain approximately 230 measures, which almost entirely would be implemented by the SCAQMD, CARB, and SCAG. The few measures that could be implemented by employers include travel demand measures in Appendix IV-C that would correspond to similar measures the Project would implement to comply with Mitigation Measure GHG-1 (see FEIR Section 3, Errata).
2.0 Response to Comments
2-22 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter C – South Coast Air Quality Management District • U.S. EPA Transportation, Air Quality, and Climate Change. The commenter has referenced an EPA webpage that provides information on pollutants and describes the EPA’s plans and regulations for transportation that would be implemented at the federal level. I t does not include Project level control measures that could be incorporated into the proposed Project.
The comment for review of additional resources is noted. It does not identify any specific measures that the SCAQMD suggests should be implemented into the DEIR or suggest that the DEIR’s analysis is deficient.
C-10 The SCAQMD notes that if the project would require new stationary or portable sources, it must obtain permits from the SCAQMD. The comment is noted. Please see Response C -11 for a more detailed discussion of permits. The SCAQMD also recommends the EIR incl ude a discussion of applicable SCAQMD rules that may be applicable to the Project and provides a list of potentially relevant rules for the City to consider adding to the EIR. As a point of clarification, Appendix E -1 of the EIR (page 3-17) does include a discussion of SCAQMD rules that may be applicable to the proposed Project, and the majority of the rules referenced by the SCAQMD in their comment were discussed in the DEIR, including rules 401, 402, 403, and 1113. The City notes it has reviewed the SCAQMD’s list of rules, and rules that were not originally included have been added to the EIR (see Appendix E-2 Section 3.3.3.3). This revision does not substantially change the content or findings of the EIR.
C-11 The SCAQMD summarizes the roles and responsibilities of Lead and Responsible Agencies under CEQA. The SCAQMD refers to CEQA procedures for a Responsible Agency, including making a decision on the adequacy of the Project EIR for use in the issuance of potential future discretionary SCAQMD air permits, and expresses concern that the DEIR’s project description and analyses may be inadequate to be relied on for the purpose of issuing permits that the Project may need.
As described in the Proposed Project Description section of Appendix E-1, the project is a speculative development, and the potential future tenants are not currently known.
End users are anticipated to provide a wide range of services ranging from industrial and manufacturing uses to service-commercial and office uses. Since potential future stationary sources are speculative at this time, it is not possible to provide emissions calculations associated for such sources at this time. The Project’s final equ ipment make, model, and operational characteristics would be provided to the SCAQMD for review by the applicant at the time the applicant applies for a permit from the SCAQMD.
C-12 The SCAQMD provides conclusionary remarks. The City appreciates the SCAQMD’s review of the DEIR. As described in response to comments C -2 to C-11, the City has prepared a fact -based evaluation of the proposed Project that fully identifies and discloses the Project’s potential emissions sources and air quality and GHG impacts.
Where the City, as Lead Agency, has taken a different position than the SCAQMD, detailed reasons supported by substantial evidence explain why specific comments and suggestions were not accepted; however, the EIR provides a good faith effort on the part of the City to evaluate the Project air quality and GHG impacts in accordance with SCAQMD guidance, rules, methods, and procedures to ensure that the SCAQMD may rely upon the DEIR as the basis for permit conditions and emissions limits for any air permits the Project may require.
2.0 Response to Comments
Menifee Business Park Project 2-23
City of Menifee
COMMENT EMAIL D – RIVERSIDE COUNTY AIRPORT LAND USE COMMISSION (ALUC)
2.0 Response to Comments
2-24 Final Environmental Impact Report
October 30, 2025
1 PAGE
Fw: Project: PLN23-0245 - [email protected] - Moore lacofano Goltsman Inc Mail ~ Searchmail Active " mm
4of 44
Subject: Project: PLN23-0245
LETTER D
Yau don't often get email frcm yc:asas@rivco org. Learn why this is important ![CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe Good morning,
Thank you for transmitting the above referenced to ALUC for review. Please note that the proposed project is located outside the airport influenced area and therefore review by the ALUC is not required.
If you have any questions, please feel free to contact ALUC Planner, Jackie Vega.
Best regards,
Yesenia Casas
Executive Assistant I
Riverside County Airport Land Use Commission
-1(6) Lemon Stroot, 1-11• FIOOr
Ri~rsit.14:!, Ca 92501
(951)955- 5132
Ycasal@rivco .org
www.rcaluc.org
Confidentiality Dis claimer
This em;iil ls confidentl;i.l ;i.nd intended solelyfortheuse of the indlviduili(s) to whom lt is ;iddressed . The inform;it ion cont ;ilned in this rr.e-ss;ige m;iybeprivileged ;ind confidentiili ;ind protected from disclosure If you ;ire not the ;iuthor's intended rec ipient, be ;idvii.ed th;it you h;ive received this em;iil in et"ror ;ind th;it ;inyuse, diss emin;ition, forw ;a-ding, printing. or copytng of this em;iil is :.trlctlyp rohibited. )fyou h;ive rece ived this eru il in et"ror ple;ii.e delete ilil copies, both electro nic ;ind printed , ;ind cont ;ict the ;iutho r immed i;itely.
~Y of Riverside Plitoroia
[Message clipped] View eonce messooe
One •U.chment • Scanned by Gr19il Security Sandbox
D-1
1/1
2.0 Response to Comments
Menifee Business Park Project 2-25
City of Menifee
ID Response to Comment Email D – RC Airport Land Use Commission D-1 The City acknowledges that the Project is located outside of any airport influence areas and thus is not subject to ALUC review.
I I
2.0 Response to Comments
2-26 Final Environmental Impact Report
October 30, 2025
COMMENT EMAIL/LETTER E – RIVERSIDE COUNTY FLOOD CONTROL AND WATER
CONSERVATION DISTRICT
2.0 Response to Comments
Menifee Business Park Project 2-27
City of Menifee
Fw: Plot Plan PLN 23-0245, Menifee (Pemcor) Business Park Project-Due 9/2512025 - [email protected] - Moore lacofano Goltsman Inc Mail Q. Search mail
CITY FOR e
MENIFEE FA
From: McKinney, Elsa <FMcKiooe@riwo grg>
Sent: Wednesday , Septem ber 3, 2025 8:10 AM
To: Russell Brovm <rbrown@cityq fmenifee-us>
ILIES
Cc: McNeill, Amy <ammcneil@BIYW OBG>; Ccrne lius, William <wmcornel@BIYffi OBG> Subject: P1 ot F1 an PLN 23-0245, Meni fee (Pemca-) Business Pai< Project-cue 9/ 25/ 2025 Active V
LETTER E
ICCAUTION]: This email originated from outside of the organization Do nQt click links or open a:tachments unless you recognize the sender and know the content is safe G::>od morning Russell,
1 of39
Thank you for the opportunity to provide comments. Upon review of the submittal, Riverside County Flocd Control has no further commen ts and I have attached our previous letter for your reference, which still applies. '"Pi ease allow up to 14 calendar days/or a response from the date we receive your submittal.* Kind regards,
@
Elsa McKinney
Engineering Tech I, Development Review
River~ide Co~mn, Flood Control & Water Conservation District [email protected]
1995 Market Street, Riverside. CA 92501
951.955.2878
061
~o ff on Mondays
Confidentiality Disclaimer
This e11Ui! is ronfidentia l and intrnded solely for the use of the individual(s) to whom it is addressed. The infor11Uti,:n contained in this m essage 11UY be privileged and ronlidenti:tl and protnte d !r,::m disclosure If you are not the author's inttndedred.pient, be advised that youhavi! receiVl!d this email in elT\Jr and that any use, dissemina tio:n, forwarding,printing, or copying of this e11Uilis strictly prohibited. Ifyouhavi! r eceiVl!d this email in e?Tor please delet e all c~ies,b oth electroni c and printed. and rontact the author immediately.
~ of Riverside California
E-1
1/1
2.0 Response to Comments
2-28 Final Environmental Impact Report
October 30, 2025
JASON E. UHLEY
General Manager-Chief Engineer
City of Menifee
Planning Division
29714 Haun Road, Building A
Menifee, CA 92586
Attention: Russell Brown
1995 MARKET STREET
RIVERSID E, CA 92501
951.955 .1200
95 1.788.9965 FAX
www.rcflood.org
RIVERSIDE COUNTY FLOOD CONTROL
AND WATER CONSERVATION DISTRICT
July 29, 2024
Re:
LETTERE
PLN 23-0245, Menifee Business Park
APN 384-150-001
257242
The Riverside County Flood Control and Water Conse1Vation District (District) does not normally recommend conditions for land divisions or other land use cases in incorporated cities. The District also does not plan check City land use cases or provide State Division of Real Estate letters or other flood hazard reports for such cases. District comments/recommendations for such cases are normally limited to items of specific interest to the District including District Master Drainage Plan facilities, other regional flood control and drainage facilities which could be considered a logical component or extension of a master plan system, and District Area Drainage Plan fees ( development mitigation fees). In addition, information of a general nature is provided.
The District's review is based on the above-referenced project transmittal, received July 17, 2024. The District has not reviewed the proposed project in detail, and the following comments do not in any way constitute or imply District approval or endorsement of the proposed project with respect to flood hazard, public health and safety, or any other such issue:
~ This project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed.
D This project involves District proposed Master Drainage Plan facilities, namely, ___ . The District will accept ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement establishing the terms and conditions of inspection, operation, and maintenance with the District and any other maintenance partners. Facilities must be constructed to District standards, and District plan check and inspection will be required for District a cceptance. Plan check, inspection, and administrative fees will be required. All regulatory permits ( and all documents pertaining thereto, e.g., Habitat Mitigation and Monitoring Plans, Conservation Plans/Easements) that are to be secured by the E-2 Applicant for both facility construction and maintenance shall be submitted to the District for review. The regulatory permits' tetms and conditions shall be approved by the District prior to improvement plan approval, map recordation, or finalization of the regulatory permits. There shall be no unreasonable constraint upon the District's ability to operate and maintain the flood control facility(ies) to protect public health and safety.
D This project proposes channels, storm drains larger than 36 inches in diameter, or other facilities that could be considered regional in nature and/or a logical extension a District's facility, the District would consider accepting ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement establishing the terms and conditions of inspection, operation, and maintenance with the District and any other maintenance partners. Facilities must be constructed to District standards, and District plan check and inspection will be required for District acceptance. Plan check, inspection, and administrative fees will be required. The regulatory permits' terms and conditions shall be approved by the District prior to improvement plan approval, map recordation, or finalization of the regulatory permits. There shall be no unreasonable constraint upon the District's ability to operate and maintain the flood control facility(ies) to protect public health and safety.
2.0 Response to Comments
Menifee Business Park Project 2-29
City of Menifee
1 PAGE EMAIL
2 PAGES LETTER
City of Menifee
Re: PLN 23-0245, Menifee Business Park
APN 384-150-001
- 2 - July 29, 2024
257242
D This project is located within the limits of the District's -~~- Area Drainage Plan for which drainage fees have been adopted; applicable fees should be paid by cashier's check or money order only to the Flood Control District or City prior to issuance of grading permits . Fees to be paid should be at the rate in effect at the time of issuance of the actual permit. E-2
D An encroachment permit shall be obtained for any construction related activities occurring within District right of way or facilities, namely, _________ . Tfa proposed storm drain connection exceeds the hydraulic performance of the existing drainage facilities, mitigation will be required. For further information, contact the District's Encroachment Permit Section at 951.955.1266. ~ The District's previous comments dated January 30, 2024 are still valid.
GENERAL INFORMATION
This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the State Water I E-3 Resources Control Board. Clearance for grading, recordation , or other final approval should not be given until the City has detennined that the project has been granted a pennit or is shown to be exempt.
If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the City should require the applicant to provide all studies, calculations, plans, and other information required to meet FEM A E-4 requirements, and should further require that the applicant obtain a Conditional Letter of Map Revision (CLOMR) prior to grading, rernrdation, or other final approval of the project and a Letter of Map Revision (LOMR) prior to occupancy.
The project proponent shall bear the responsibility for complying with all applicable mitigation measures defined in the California E nvironmental Quality Act (CEQA) document (i.e., Negative Declaration, Mitigated Negative Declaration, Environmental Impact Report) and/or Mitigation Monitoring and Reporting Program, if a C EQA document was prepared for the project. TI1e project proponent shall also bear lhe responsibility for complying with an other federal, state, and local environmental rules and regulations that may apply.
Tf a natural watercourse or mapped floodplain is impacted by this project, the City should require the applicant to obtain a Section 1602 Agreement from the California Department offish and Wildlife and a Clean Water Act Section 404 Permit from the U.S. Army Corps of Engineers, or written correspondence from these agencies indicating the project is exempt from these requirements. A Clean Water Act Section 401 Water Quality Certification may be required from the local California Regional Water Quality Control Board prior to issuance of the Corps 404 permit.
Attachment
EM:blj
Very truly yours,
~ ?rk.!2dil
AMYMCNElLL
Engineering Project Manager
E-5
E-6
2.0 Response to Comments
2-30 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Email/Letter E – Riverside County Flood Control and Water Conservation District (RCFCWCD)
E-1 The City acknowledges that the RCFCWCD has no further comments on the EIR (see previous comments during NOP period – letter dated 7-29-24 - in responses below).
E-2 This comment letter was submitted to the City based on the Notice of Preparation for the Pemcor Business Park Project released on July 25, 2024 through August 23, 2024. The RCFCWCD indicates this project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed. The Project will pay applicable RCFCWCD fees based on the characteristics of the Project and the fees in place at the time of application.
E-3 The EIR evaluated potential water quality impacts of the Project relative to permitting by various local, regional, and state agencies. The Project will comply with all applicable water quality regulations and requirements, including preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) for construction activities and a Watter Quality Management Plan (WQMP) for operational activities.
E-4 The Project EIR and Project plans evaluated the flood protection and control requirements of the site based on a hydrology study based on RCFCWCD guidelines.
The Project will not require preparation of a CLOMR or LOMR for occupancy.
E-5 The City determined the EIR was the appropriate CEQA compliance document for the Project and recommended appropriate regulatory compliance or mitigation for:
biological resources (nesting bird and burrowing owl surveys) ; cultural resources (monitoring of grading by an archaeologist and tribal representatives; air quality; and greenhouse gas emissions (transportation demand management program).
E-6 The EIR and attendant biological report determined that the site contains jurisdictional drainages that require subsequent permitting through the California Department of Fish and Wildlife.
Summary. Based on the responses to these comments, the information in the RCFCWCD email and letter does not require text or other informational changes to the IS/MND document or any technical studies, and does not change its conclusions or recommended mitigation measures.
2.0 Response to Comments
Menifee Business Park Project 2-31
City of Menifee
COMMENT EMAIL /LETTER F – RIVERSIDE TRANSIT AGENCY (RTA)
2.0 Response to Comments
2-32 Final Environmental Impact Report
October 30, 2025
1 PAGE EMAIL
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Fw: PEMCOR Business Park - knorton@migcom. com - Moore lacofano Goltsman Inc Mail Q. Search mail
MENIFEE
FA···1LIES
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From: Mauricio Alvarez < malwrer@rivecsidet@ □ sir cooJ> Sent: Monday, September 22, 2025 9:27 AM
To: Russell Brc.vm <rbrown@ci tygf menifee \IS>
Subject: PEMCOR Business Pai::
LETTER F
![CAUTION}: This email originated from outside of the organization. Do not click links or open i'.ttachments unless you recognize the sender and know the content is safe Good Morni[l! Russel l,
Thc11k you for including RTA in the developm ent review of Menifee PEMCOR Business Park Project. After further review, ther e are no comments to submi t for th is pcr-ticular project.
Tha-,kyCAJ,
Mauri ci o A l var ez, M BA
Planning Manager
Riverside ll".ris i tAgen cy
p: 9s1.sos.s2c,o I ~= 01¢1 ore11lfl•I ec detceo,1com
~ I ~ I ~ I ~
182S Third Street , Riverside, CA 92$07
[Message clipped] View entire message
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F-1
1/1
2.0 Response to Comments
Menifee Business Park Project 2-33
City of Menifee
ID Response to Comment Letter F – Riverside Transit Agency (RTA) F-1 The City understands RTA has no comments on this Project.
2.0 Response to Comments
2-34 Final Environmental Impact Report
October 30, 2025
COMMENT LETTER G – RIVERSIDE COUNTY DEPARTMENT OF WASTE RESOURCES
2.0 Response to Comments
Menifee Business Park Project 2-35
City of Menifee
RIVERSIDE COUNTY
EPARTMENT OF
ASTE RES URCES
Andy Cortez, General Manager -Chief Engineer
SENT VIA EMAIL ONLY
[email protected]
Russell Brown, AICP, Senior Planner
City of Menifee (City), Planning Department
29844 Haun Road
Menifee, CA 92586
LETTER G
September 16, 2025
RE: Notice of Availability (NOA) of a Draft Environmental Impact Report (DEIR) for the "Menifee (Pemcor) Business Park Project", Plot Plan PLN23-0245 Dear Russell Brown,
The Riverside County Department of Waste Resources (RCDWR) has reviewed the NOA addressing a DEIR for the proposed Menifee (Pemcor) Business Park Project (Project). The Project includes various applications to allow for the development of 11 buildings on 337,770 square feet of building area.
The RCDWR offers the following comments for your consideration while preparing the Project's DEIR:
1. Construction of the Project may generate a substantial quantity of construction and demolition (C&D) waste. Should a large quantity of C&D waste, that is unable to be recycled, be brought G-1 to a County landfill for disposal, it could exceed the landfill's daily permitted capacity , thus a violation of state regulations .1 To assess waste impacts , the DEIR should consider quantitatively analyzing this potential solid waste impact and discuss feasible mitigation programs/regulatory compliance.
Note: CalRecycle's website may be helpful to determine the Project's waste generation :
https://www2.calrecycle .ca.gov/WasteCharacterization /General/Rates
2. The following information can be useful in the analysis of the solid waste impacts:
a) Solid waste generated within the Project area is collected by Waste Management Inc. (WMI), with the bulk of recyclable waste and green waste delivered to the Moreno Vall ey Solid Waste Recycling and Transfer Station (MVTS) for processing . The facility is located at 17700 Indian Street in Moreno Valley. It is permitted for a 2,500 tons per day (tpd) operation .
'Tille 40, Vol. 41 C.F.R § 243.203 et seq (1976).
14310 Frederick Street • Moreno Valley, CA 92553 - (951) 486 -3200 • Fax (951) 486-3205 • Fax (951) 486-3230 www.rcwaste.o rg Q Printed on recycled paper
G-2
2.0 Response to Comments
2-36 Final Environmental Impact Report
October 30, 2025
Russell Brown, AICP, Senior Planner
City of Menifee (City)
NOA DEIR - Menifee (Pemcor) Business Park Project
September 16, 2025
b) The franchise waste hauler primarily utilizes the El Sobrante landfill for disposal, but may also utilize the Lamb Canyon, and/or the Badlands landfill for disposal of the waste generated from the proposed Project. Descriptions of the local landfills are provided below:
El Sobrante Landfill:
The El Sobrante Landfill is located east of Interstate 15 and Temescal Canyon Road to the south of the City of Corona and Cajalco Road at 10910 Dawson Canyon Road. The landfill is owned and operated by USA Waste of California, a subsidiary of Waste Management, Inc., and encompasses 1,322 acres, of which 645 acres are permitted for landfill operation. The El Sobrante Landfill has a total disposal capacity of approximately 209 .9 million cubic yards and can receive up to 70,000 tons per week (tpw) of refuse . USA Waste must allot at least 28,000 tpw for County refuse. The landfill's permit allows a maximum of 16,054 tons per day (tpd) of waste to be accepted into the landfill, due to the limits on vehicle trips. If needed, 5,000 tpd must be reserved for County waste, leaving the maximum commitment of Non-County waste at 11,054 tpd . Per the 2024 Annual Report, the landfill had a remaining in-County disposal capacity of approximately 46.1 million tons. 2 In 2024, the El Sobrante Landfill accepted a daily average of 10,557 tons with a period total of approximately 3,251,611 tons. The landfill is expected to reach capacity in approximately 2059.
Lamb Canyon Landfill:
The Lamb Canyon Landfill is located between the City of Beaumont and City of San Jacinto at 16411 Lamb Canyon Road (State Route 79), south of Interstate 10 and north of Highway 74. The landfill is owned and operated by Riverside County. The landfill property encompasses approximately 1,189 acres, of which 703.4 acres encompass the current landfill permit area. Of the 703.4-acre landfill permit area , approximately 144.6 acres are permitted for waste disposal. The landfill is currently permitted to receive 5,000 tpd of MSW for disposal and 500 tpd for beneficial reuse. The site has an estimated total disposal capacity of approximately 21 .1 million tons .3 As of January 1, 2025 (beginning of day), the landfill has a total remaining capacity of approximately 6.1 million tons. 4 The current landfill remaining disposal capacity is estimated to last, at a minimum , until approximately 2032. 5 From January 2024 to December 2024, the Lamb Canyon Landfill accepted a daily average of 1,973 tons with a period total of approximately 607,583 tons .
Landfill expansion potential exists at the Lamb Canyon Landfill site.
Badlands Landfill:
The Badlands Landfill is located northeast of the City of Moreno Valley at 31125 Ironwood Avenue and accessed from State Highway 60 at Theodore Avenue . The landfill is owned and operated by Riverside County . The existing landfill encompasses 1,168.3 acres, with a total disturbance area of 278 acres, of which 150 acres are for refuse disposal. Landfill expansion potential exists at the Badlands Landfill site. Under the 2022 Solid Waste 2 2024 El Sobrante Landfill Annual Report- Based on 115,286,220 tons remaining capacity (40% for in-county waste). 3 GASB 18_ 2024 - Engineering Estimate for total landfill capacity 4 GASB 18_2024 & Sitelnfo
5 SWFP # 33-AA-0007
G-3
2.0 Response to Comments
Menifee Business Park Project 2-37
City of Menifee
Russell Brown, AICP, Senior Planner
City of Menifee (City)
NOA DEIR - Menifee (Pemcor) Business Park Project
September 16, 2025
Facility Permit (SWFP) , the permitted disturbance area increases from 278 acres to 811 acres, and the refuse disposal area increases from 150 acres to 409 (in multiple stages).
The landfill is currently permitted to receive 5,000 !pd of MSW for disposal and 300 tpd for beneficial reuse. The site has an estimated total capacity of approximately 68.6 million G-3 tons. 6 As of January 1, 2025 (beginning of day), the landfill had a total remaining disposal capacity of approximately 48.9 million tons .7 Under the 2022 SWFP, the landfill would have a remaining disposal capacity estimated to last, at a minimum , until approximately 2059. 8 From January 2024 to December 2024 , the Badlands Landfill accepted a daily average of 3,003 tons with a period total of approximately 924 ,862 tons.
3. Additionally, you may wish to consider incorporating the following measures to help reduce the Project's anticipated solid waste impacts and enhance efforts to comply with the State's mandate (AB 75) of 50% solid waste diversion from landfilling 9:
• The use of mulch and/or compost in the development and maintenance of landscaped areas within the project boundaries is recommended. Recycle green waste through either onsite composting of grass, i.e., leaving the grass clippings on the lawn, or sending separated green waste to a composting facility. • Consider xeriscaping and the use of drought tolerant low maintenance vegetation in all landscaped areas of the project.
• Hazardous materials are not accepted at the Riverside County landfills . Any hazardous wastes, including paint, used during construction must be properly disposed of at a licensed facility in accordance with local, state and federal regulations. For further information regarding the determination, transport , and disposal of hazardous waste, please contact the Riverside County Department of Health, Environmental Protection and Oversight Division, at 1.888.722 .4234. • AB 341 focuses on increased commercial waste recycling as a method to reduce greenhouse gas (GHG) emissions. 10 The regulation requires businesses and organizations that generate four or more cubic yards of waste per week and multifamily units of 5 or more, to recycle . A business shall take at least one of the following actions in order to reuse, recycle, compost, or otherwise divert commercial solid waste from disposal :
• Source separate recyclable and/or compostable material from solid waste and donate or self-haul the material to recycling facilities. • Subscribe to a recycling service with waste hauler.
• Provide recycling service to tenants (if commercial or multi-family complex). • Demonstrate compliance with requirements of California Code of Regulations Title 14.
6 SWFP # 33-AA-0006
7 GASB_ 18_2024 & Site Info
8 SWFP # 33-AA-0006
9 AB. 75, Chapter 764. 1999-2000 Strom-Martin. (Cal. 1999). 10 AB. 341, Chapter 476, 2011-2012 Chesbro, (Cal. 2011).
G-4
2.0 Response to Comments
2-38 Final Environmental Impact Report
October 30, 2025
4 PAGES
Russell Brown, AICP, Senior Planner
City of Menifee (City)
NOA DEIR - Menifee (Pemcor) Business Park Project
September 16, 2025
For more information , please visit:
http://www.rcwaste .org/business /recycling/mcr
• AB 1826 requires businesses and multifamily complexes to arrange for organic waste recycling services. 11 Those subject to AB 1826 shall take at least one of the following actions in order to divert organic waste from disposal :
• Source separate organic material from all other recyclables and donate or self haul to a permitted organic waste processing facility.
• Enter into a contract or work agreement with gardening or landscaping service provider or refuse hauler to ensure the waste generated from those services meet the requirements of AB 1826 .
• Demonstrate compliance with SB 1383 which establishes regulations to reduce organics waste disposal and went into effect on January 1, 2022.12 This law establishes methane emissions reduction targets in a statewide effort to reduce emissions of short-lived climate pollutants caused by organics waste disposal .
Thank you for including RCDWR in the review process . Please continue to include the RCDWR in future transmittals providing us with Project updates and any CEQA documentation as the Project progresses. Please email me at [email protected] if you have any questions regarding the above comments.
Cc: Kinika Hesterly, RCDWR
DM# 362377
11 A.B. 1826, Chapter 727, 201 3-201 4 Chesbro, (Cal. 201 4). 12 AB 1383, Chapter 395, 2015-2016 Lara, (Cal. 2016).
Sincerely,
Katherine Veliz
Associate Planner
G-4
2.0 Response to Comments
Menifee Business Park Project 2-39
City of Menifee
ID Response to Comment Letter G – County Department of Waste Resources G-1 The City appreciates the additional information and the following will be added to FEIR Section 3, Errata, relative to DEIR Section 4. 19.4, Utilities and Service Systems , Impacts and Mitigation Measures, Impact UTL-4 relative to solid waste (added text shown in underline):
Construction of the Project may generate a substantial quantity of construction and demolition(C&D) waste. Should a large quantity of C&D waste, that is unable to be recycled, be brought to a County landfill for disposal, it could exceed the landfill’s daily permitted capacity, thus a violation of state regulations per Title 40, Vol. 41 C.F.R § 243.203 et seq. (1976).
In addition, the waste generation estimate provided in the EIR text was based on CalRecycle’s waste characterization spreadsheet and that will be clarified in the same section of the DEIR text.
G-2 This information will be added to FEIR Section 3, Errata, relative to DEIR Section
4.19.1, Utilities and Service Systems (Solid Waste) under existing conditions.
G-3 This information will be added to FEIR Section 3, Errata, relative to DEIR Section
4.19.1, Utilities and Service Systems (Solid Waste) under existing conditions.
G-4 These recommended actions to help reduce solid waste generation are already incorporated into a number of standard City Conditions of Approval (COA) for the Project as outlined below (in the same order as suggested in the comment letter):
• Mulch/Compost. This is largely addressed in City COAs #112 and #113 (see below) regarding AB 1826 compliance.
• Xeriscape. This is largely addressed in City COA #113 (see below) regarding AB 1836.
• Hazardous Materials. This is largely addressed in City COAs #115 and #116 (see below).
• AB 341 Compliance. City COA #112 specifically duplicates this recommended language.
• AB 1826 Compliance. This is addressed in City COA #113 (see below). • SB 1383 Compliance. This is largely addressed in City COA #113 (see below) regarding reducing organic waste.
City Standard Conditions of Approval
COA 112. AB 341. AB 341 focuses on increased commercial waste recycling as a method to reduce greenhouse gas (GHG) emissions. The regulation requires businesses and organizations that generate four or more cubic yards of waste per week and multifamily units of 5 or more, to recycle. A business shall take at least one of the following actions to reuse, recycle, compost, or otherwise divert commercial solid waste from disposal:
a) Source separate recyclable and/or compostable material from solid waste and donate or self-haul the material to recycling facilities. b) Subscribe to a recycling service with their waste hauler. c) Provide recycling service to their tenants (if commercial or multi-family complex).
2.0 Response to Comments
2-40 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter G – County Department of Waste Resources d) Demonstrate compliance with the requirements of California Code of Regulations Title 14.
For more information please visit:
www.rivcowm.org/opencms/recyclying/recycling_and_compost_business.html#mandatory COA #113: AB 1826. AB 1826 (effective April 1, 2016) requires businesses that generate eight (8) cubic yards or more or organic waste per week to arrange for organic waste recycling services. The threshold amount of organic waste generated requiring compliance by businesses is reduced in subsequent years. Businesses subject to AB 1826 shall take at least one of the following actions in order to divert organic waste from disposal:
Source separate organic material from all other recyclables and donate or self-haul to a permitted organic waste processing facility.
Enter into a contract or work agreement with gardening or landscaping service provider or refuse hauler to ensure the waste generated from those services meet the requirements of AB 1826.
Consider xeriscaping and using drought tolerant/low maintenance vegetation in all landscaped areas of the project.
As of January 1, 2019, the above requirements are now applicable to businesses that generate four (4) or more cubic yards of solid waste per week and one (1) or more cubic yards of organic waste per week. Additionally, as of January 1, 2019, a third trash bin is now required for organics recycling, which will require a larger trash enclosure to accommodate three (3) trash bins. This development is subject to this requirement.
COA #115: Waste Recycling Plan. Prior to the issuance of a building permit for each building, a Waste Recycling Plan (WRP shall be submitted to the City of Menifee Engineering/Public Works Department for approval. Completion of Form B “Waste Reporting Form” of the Construction and Demoli tion Waste Diversion Program may be sufficient proof of WRP compliance, as determined by the Public Works Director / City Engineer. At minimum, the WRP must identify the materials (i.e., concrete, asphalt, wood, etc.) that w ill be generated by construction and development, the projected amounts, the measures/methods that will be taken to recycle, reuse, and/or reduce the amounts of materials, the facilities and/or haulers that will be utilized, and the targeted recycling or r eduction rate. During project construction, the project site shall have, at a minimum, two (2) bins; one for waste disposal and the other for recycling of Construction and Demolition (C&D) materials. Additional bins are encouraged to be used to further sou rce separation of C&D recyclable materials.
Accurate record keeping (receipts) for recycling of C&D recyclable materials and solid waste disposal must be kept. Arrangements can be made through the franchise hauler.
COA #116: Waste Management Clearance. Prior to issuance of an occupancy permit for each building, evidence (i.e., receipts or other type of verification) shall be submitted to demonstrate project compliance with the approved WRP to the Engineering and Public Works Department in order to clear the project for occupancy
2.0 Response to Comments
Menifee Business Park Project 2-41
City of Menifee
ID Response to Comment Letter G – County Department of Waste Resources permits. Receipts must clearly identify the amount of waste disposed and Construction and Demolition (C&D) materials recycled. Completion of Form C, “Waste Reporting Form” of the Construction and Demolition Waste Diversion Program along with the receipts m ay be sufficient proof of WRP compliance, as determined by the PW Director / City Engineer.
2.0 Response to Comments
2-42 Final Environmental Impact Report
October 30, 2025
COMMENT LETTER H – BLUM, COLLINS & HO LLP FOR GOLDEN STATE ENVIRONMENTAL JUSTICE ALLIANCE (GSEJA) + SUPPORTING LETTER FROM SWAPE
2.0 Response to Comments
Menifee Business Park Project 2-43
City of Menifee
Russell Brown
AICP, Senior Planner
BLUM, COLLINS & HO LLP
ATTORNEYS AT LAW
10250 CONSTELLATION BOULEVARD
SUITE2300
LOS ANGELES, CALIFORNIA 90067
(213) 572-0400
September 24, 2025
Via Email to:
rbrown@ciryofmenifee .us
City of Menifee Planning Department
29844 Haun Road
Menifee, CA 92586
LETTERH
Subject: Comments on Menifee (Pemcor) Business Park Project, Plot Plan PLN23-0245 EIR (SCHNO.202407/016)
Dear Mr. Brown,
Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed Menifee (Pemcor) Business Park Plot Plan PLN 23-0245 Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.
1.0Summary
The project proposes the construction and operation of 337,770 square feet of industrial building area, which would be spread across 11 buildings (Plot Plan PLN23-0245) on a 20.03 acre site. The entire 20.03-acre site would be graded and the portions of the site not developed with buildings would either be hardscaped (e.g., parking or sidewalks) or landscaping. Two buildings will face Howard Way and two buildings will front on to Zeiders Road. The buildings range in size from 23, 100 square feet to 37,840 square feet and each feature two truck dock bays each that would be oriented toward the center of the site (a total of22 truck docks at the site). Building heights are 38 to 40 feet above ground level.
H-1
2.0 Response to Comments
2-44 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
Page2
4.3 Air Quality, 4.6 Energy, and 4.9 Greenhouse Gas Emissions The EIR. does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. This is in conflict with CEQA Guidelines Section 15131 ( c ), which requires that "Econom ic, social, and particularly housing factors shall be considered b y public agencies together with technological and environmental factors in deciding whether changes in a project are feasible to reduce or avoid the significant effects on the environment identified in the EIR.. If information on these factors is not contained in the EIR., the information must be added to the record in some other manner to allow the agency to consider the factors in reaching a decision on the project." This is especially significant as the surrounding community is highly burdened by pollution. See also the attached air quality comments and analysis from SW APE.
According to Ca!EnviroScreen 4.01, Ca!EPA's screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project's census tract (6065043279) is highly burdened by pollution. The surroundin g community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicator measured by Ca!EnviroScreen. For example, the project census tract ranks in the 80th percentile for ozone burden, the 46th percentile for particulate matter (PM) 2.5 burden, and 78th percentile for traffic burden. All of these environmental factors are attributed to heavy truck activity in the area. While California has strict vehicle-emissions standards, exhaust from cars and trucks is the main source of air pollution in much of the state2. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure3. Exhaust fumes contain toxic chemicals that can damage DNA, cause cancer, make breathing difficult, and cause low weight and premature births4 .
The census tract also ranks in the 50th percentile for hazardous waste facility impacts and 36th percentile for solid waste facility impacts. H azardous waste generators and facilities contribute to the contamination of air, water and soil near waste generators and facilities can harm the environment as well as people5. Solid waste facilities can expose people to hazardous chemicals, 1 https://experience.arcgis .com/exper ience/ I I d2 52282a54ceebcac7428e6 I 84203/page/Cal EnviroScreen- 4 0/
2 OEHHA Traffic https://oehha.ca.go v/calenviroscree n/indicator/traffic-densi ty 3 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-q uality-ozone 4 OEHHA Traffic https://oehha.ca.gov /calenviroscreen/indicator/traffic -density 5 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenviroscreen/i ndicator/hazardous-wasle -generators-and-faciliti es H-2
2.0 Response to Comments
Menifee Business Park Project 2-45
City of Menifee
Russell Brown
September 24, 2025
Page3
release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations6.
Further, the census tract is a diverse community including 30% Hispanic, 1 % African-American, and 2% Asian-American residents, whom are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 40% of the census tract residents over age 25 has not attained a high schoo l diploma. The community also has a high rate of poverty, meaning 34% of the households in the census tract have a total income before taxes that is less than the poverty level. Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care7 . Poor communities are often located in areas with high levels of pollution8. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution9. Living in poverty is also an indication that residents may lack health insurance or access to medi cal care. Medical care is vital for this census tract as it ranks in the 93rd percentile for incidence of cardiovascular disease and 43rd percentile for incidence of asthma.
The State of California lists three approved compliance modeling softwares10 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. Appendix E: Air Quality/Greenhouse Gas/Energy Report is not included as attachment for public review. rt is listed in the EIR Table of Contents, but not included within the compiled appendices file uploaded to the City's website11 and the LC[ (formerly OPR) CEQAnet database12. Excluding Appendix E: Air Quality/Greenhouse Gas/Energy Report from public review does not comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as Appendix E: Air Quality/Greenhouse Gas/Energy Report contributes directly to analysis of the 6 OEHHA Solid Waste Facilities hnps://oehha .ca.gov/calenviroscreen/in dicator/solid-waste-sites-an d facilities
7 OEHHA Poverty https ://oehha .cagov /calenviroscree n/indicator /poverty 8 Ibid.
9 Ibid.
1° California Energy Commission 2022 Energy Code Compliance Software h ttps :/ /www .energv.ca. gov/programs-a nd-to pies/ programs/bu i !ding ·energy- effi ciency-standards/2 022- bui lding-energy-eftic iency-1
11 Menifee Pemcor DEIR Compiled Appendices
https://www .cityo fineni fee .us/DocumentCenter Nie w/2407 4/D EIR-Appendices h ttps://www.ci tyofin eni fee. us/ Doct1mentCenter/Vi ew/24 07 4/ DEi R •App end ices- 12 Menifee Pemcor DEIR Appendices via CEQAnet https://files.ceganet.lci.ca. oov/303525- 3/attachme nt/nAju2TOyzveJvArb0 k-A iV7VmUhZrp5bTN bjZpl7m ehznEXuGkWm - 73X5 0z8g2S98 CGtGVXjVNdW wB0
H-3
H-4
2.0 Response to Comments
2-46 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
Page4
problem at hand. A revised EIR. must be prepared and recirculated to include A ppendix E: Air Quality/Greenhouse Gas/Energy Report for review, analysis, and comment by the public and decision m akers in order to comply w ith CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Commenter reserves the right to provide additional and/or updated comments should A ppendix E become available, including after the conclusion of the public review period.
4.11 Land Use and Planning
The EIR. does not meaningfully discuss or analyze the project's compliance with the General Plan's Land Use Buildout Scenario. Exhibit LU-4: Land Use Buildout Summary within the General Plan Land Use Element 13 analyzes a 0.38 FAR for Business Park development within EDC-SG and 21,357,032 square feet of non-retail development within all EDC areas. Table 3-2:
Project Development Characteristics states the project site has a FAR of0.46, which is greater than the assumption of the environmental analysis which it attempts to tier from. The EIR. has not provided evidence that the growth generated by the proposed project was anticipated by the General Plan, RTP/SCS, or AQMP. The EIR. must be revised to provide an accurate build-out scenario of the City's General Plan.
Table 4.11-1: 2024-2050 RTP/SCS Consistency Analysis provides a misleading and erroneous consistency analysis with SCA G's 2024 Connect SoCal RTP/SCS 14. The EIR. has exclude relevant analysis regarding the project's s ignificant and unavoidable cumulatively considerable GHG impacts and has not provided any analysis in accordance with the policies of the RTP. Due to errors in modeling, modeling without supporting evidence (as noted throughout this comment letter), and the EIR's determination that the project will generate significant and unavoidable cumulatively considerable Greenhouse Gas Emissions, the proposed project is directly inconsistent with the following and a revised EIR must be included with a finding of significance:
I. Housing the Region Policy 35. Encourage housing development in areas with access to important resources and amenities ( economic, educational, health, social and similar) to further fair housing access and equity across the region.
2. Housing the Region Policy 36. Encourage housing development in transit-supportive and walkable areas to create more interconnected and resilient communities . 13 Menifee General Plan Land Use Element
https://www.cityofmenifee.us/DocumentCen terN iew/ J470l /FINAL Land-Use-Element 11322 14 https://scag.ca.gov/sites/default/files/2024 -05/23-2987-con nect-soca l-2024-final-complete-040424 .pdf H-4
H-5
H-6
2.0 Response to Comments
Menifee Business Park Project 2-47
City of Menifee
Russell Brown
September 24, 2025
Page5
3. Housing the Region Policy 37. Support local, regional, state and federal efforts to produce and preserve affordable housing while meeting additional housing needs across the region.
4. Housing the Region Policy 38. Prioritize communities that are vulnerable to displacement pressures by supporting community stabilization and increasing access to housing that meets the needs of the region.
5. Housing the Region Policy 39. Promote innovative strategies and partnerships to increase homeownership opportunities across the region with an emphasis on communities that have been historically impacted by redlining and other systemic barriers to homeownership for people of color and other marginalized groups.
6. Housing the Region Policy 40. Advocate for and support programs that emphasize reducing housing cost burden (for renters and homeowners), with a focus on the communities with the greatest needs and vulnerabilities.
7. Equitable Engagement and Decision-Making Policy 46. Promote racial equity that is grounded in the recognition of the past and current harms of systemic racism and one that advances restorative justice.
8. Equitable Engagement and Decision-Making Policy 47. Increase equitable, inclusive, and meaningful representation and participation of people of color and disadvantaged communities in planning processes.
9. Sustainable Development Policy 48. Promote sustainable development and best practices that enhance resource conservation, reduce resource consumption and promote resilience.
10. Sustainable Development Policy 49. Support communities across the region to advance innovative sustainable development practices.
11. Sustainable Development Policy 50. Recognize and support the diversity of communities across the region by promoting local place-making, planning and development efforts that advance equity, mobility, resilience and sustainability.
12. Air Quality Policy 51. Reduce hazardous air pollutants and greenhouse gas emissions and improve air quality throughout the region through planning and implementation efforts.
J 3. Air Quality Policy 52. Support investments that reduce hazardous air pollutants and greenhouse gas emissions.
H-6
2.0 Response to Comments
2-48 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
Page6
14. Air Quality Policy 53. Reduce the exposure and impacts of emissions and pollutants and promote local and regional efforts that improve air quality for vulnerable populations, including but not limited to Priority Equity Communities and the AB 6 17 Communities.
15. Climate Resilience Policy 64. Prioritize the most vulnerable populations and communities subject to climate hazards to help the people, places and infrastructure that are most at risk for climate change impacts. In doing so, recognize that disadvantaged communities are often overburdened.
16. Climate Resilience Policy 65. Support local and regional climate and hazard planning and implementation efforts for transportation, land use, and other factors.
17. Climate Resilience Policy 66. Support nature-based solutions to increase regional resilience of the natural and built environment.
The EIR does not provide a consistency analysis with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. Further, Table 4.11-2:
City General Plan Consistency Analysis includes consistency analysis that is erroneous and misleading to the public and decision makers. The EIR is inadequate as an informational document and a revised EIR must be prepared with a consistency analysis with all General Plan policies, including but not limited to the following:
I. Goal S-7: A community that has protected its sensitive structures, functions, and populations from the risks associated with climate change.
2. Policy S-7. I : Continue to require environmental analysis for proposed projects which may produce harmful levels of greenhouse gas.
3. Policy EJ-3.6: Continue to collaborate with the South Coast Air Quality Management District (SCAQMD), California Air Resources Board (CARB), utility providers, Southern California Association of Governments (SCAG), Western Riverside Council of Governments (WRCOG) and nonprofit organizations, neighborhoods groups, and other community organizations to improve air quality, food availability, renewable energy systems, sustainable land use and reduce greenhouse gas emissions (GHGs).
4. Goal OSC-10: An environmentally aware community that is responsive to changing climate conditions and actively seeks to reduce local greenhouse gas emissions.
H-6
H-7
2.0 Response to Comments
Menifee Business Park Project 2-49
City of Menifee
Russell Brown
September 24, 2025
Page7
5. Policy OCS-10.1:Align the city's local GHG reduction targets to be consistent with the statewide GHG reduction target of AB 32.
6. Policy OCS-10.2: Align the city's long-tenn GHG reduction goal consistent with the statewide GHG reduction goal of Executive Order S-03-05.
7. Policy OCS-10.3: Participate in regional greenhou se gas emission reduction initiatives.
8. Policy OCS -10.4: Consider impacts to c limate change as a factor in evaluation of policies, strategies, and projects
9. Policy C-5.3: Support efforts to reduce/eliminate the negative environmental impacts of goods movement.
I 0. Policy C -1.2: Require development to mitigate its traffic impacts and achieve a peak hour Level of Service (LOS) Dor better at intersections, except at constrained intersections at close proximity to the 1-2 15 where LOSE may be pennitted.
Additionally, the EIR concludes that the project is consistent with "Policy C-5.3: Support efforts to reduce/eliminate the negative environmental impacts of goods movement" because "An EIR is being prepared for this project which is the most extensive environmental documentation that can be prepared under CEQA. Mitigation is recommended where potential significant impacts result from the project. This is erroneous and misleading to the public and decision makers because it omits the fact that the project will generate significant and unavoidable cumulatively considera ble Greenhouse Gas Emissions. The EIR must be revised to include information regarding the project' s significant and unavoidable impacts to Greenhouse Gas Emissions for analysis in this section and a finding of significance due to the project's inconsistency with this policy.
4.14 Population and Housing
The project faces significant inconsistencies with statutory requirements of the Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 33015/SB 816. The HCA/SB 330/SB 8 require replacement housing sites when land designated for housing development experience changes to ensure no net loss of housing capacity. The project site has a General Plan land use designation of Economic Development Corridor - Southern Gateway (EDC-SG) that has a maximum density of24 units per 15 Housing Crisis Act of2019 /SB 330
https://leginfo.le!!islature.ca.gov/faces/billTextClient.xhtml?bill id=201920200S8330 16 SB 8 https://leginfo.le!!islature.ca.gov/faces/billTextClient.xhtm l?bill id=-202120220S88 H-7
H-8
H -9
2.0 Response to Comments
2-50 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
Page8
acre17. The approxima tely 20.3 acre project site can accommodate the development ofup to 487 dwelling units. Additionally, Exhibit LU-4 within the City's General Plan depicts that the EDC SG designation only permits residential development on 30 acres within the planning area, wh ich accommodates the development of residential dwelling units on the project site. The General Plan also states that residential deve lopment in the EDC areas, " ... shall not be allowed on parcels or properties directly adjacent to the freeway," indicating that the project site is one of the few parcels that cou ld accommod ate residential development in the EDC-SG.
Gove rnment Code Sectio n 66300(b)(l)(A) requires that agencies shall not "change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances in effect at the time of the proposed change." Under Government Code Section 66300(b)(l)(A), a "less intensive use" includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or any other action that would individually or cumu latively reduce residential development capac itv. Pursuant to SB 330, replacement capacity for any displaced residential units must be provided concurrc ntlv at the time of pro ject approval.
Approva l of the proposed project will individually and cumulatively reduce residential development capacity allowed by the City's Genera l Plan land use designation.
Government Code Section 66300 (h)(i)(l) states that, "this section does not prohibit an affected county or an affected city, including the local electo rate acting through the initiative process, from changing a land use designation or zoning ordinance to a less intensive use, or reducing the intensity of land use, if the city or county concurren tly changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in resident ial capacity ." As calcu lated above, the project site's EDC-SG designation provides development capacity for 487 residential units. Approval of the proposed project will result in a reduction of the existing residential development capacity by 487 units to a decreased development capacity of 0 residential units.
This is in conflict with SB 8 that expanded the provisions of the HCA to include Government Code Section 66300 (h)(i)(l) requiring concurrent approval of replacement sites to ensure no net loss in residentia l capac ity, and Section 66300 (h)(2)(A) defining "concurrent ly" to mean the action is 17 Menifee General Plan Exhibit LU-4: Land Use Buildout Summary https://www.cityofmenifee.us/DocumentCenterN iew/ 14675/3 LU-4 FINAL H-9
H-10
H-11
H-12
2.0 Response to Comments
Menifee Business Park Project 2-51
City of Menifee
Russell Brown
September 24, 2025
Page9
approved al the same meeting of the legislative body. The EIR has not identified replacement sites for the net loss in residential capacity for 487 units as a result of project implementation. The loss in residential capacity must be included as a finding of significance as part of a revised EIR. The EIR does not act in conformance with the HCA/SB 330/SB 8 and the lost zoning capacity of any dwelling units is a significant environmental impact in violation of the HCA/SB 330/SB 8. The EIR must be revised to include a finding of significance due to this inconsistency.
Additionally, deferring the environmental analysis of construction and operation of replacement sites to a later date is project piecemealing in violation of CEQA. The EIR does not accurately or adequately describe the project, meaning "the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonab ly foreseeable indirect physical change in the environment" (CEQA § 15378). The whole of the action must statutorily and legally include the identification of replacement sites and all associated actions required to implement development of at least 678 residential units.
The EIR utilizes uncerta in language and does not provide any meaningful analysis or supporting evidence to substantiate the conclusion that there will be no significant impact to population and housing. The EIR only briefly discusses the construction related jobs and states that, "Construction workers and employees would come from the City and from surrounding areas as well. These workers are temporary and would not need to be acco unted for in the estimated population growth provided in Table 4.14-1 and the employment forecasts provided in Table 4.14-3." Notably, the geographic boundaries of the "surrounding areas" are undefined and will result in the project attracting a workforce that is exponentially further than that of the "low VMT T AZ" utilized in the EIR to conclude less than significant VMT impacts.
The EIR does not provide substantial evidence that the construction or operational workforce in the City is qualified for or interested in construction work or work in the industrial secto r to support a less than significant finding. Relying on the unemployed workforce population of the overall SCAG region will increase project related VMT and emissions during all phases of construction and operations and a revised EIR must be prepared to account for longer worker trip distances.
The EIR states that the project will generate 553 operational employees, but does not provide the source or methodology for this calculation. Excluding the methodology for calculating employment generation does not comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the methodology for calculating employment H- 12
H-13
H-14
H-15
H-16
2.0 Response to Comments
2-52 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
generation contributes directly to analysis of the problem at hand. A revised Effi. must be prepared and recirculated to include the methodology for calculating employment generation for review, analysis, and comment by the public and decision makers in order to comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)).
SCAG's Connect SoCal Demographics and Growth Forecast18 notes that the City will add 8,500 jobs between 20 19 - 2035. Utilizing the SCAG Employment Density Study calculation of 553 employees, the project represents 3.5% of the City's employment growth from 2019 - 2035. A single project accounting for this amount of the projected employment growth over 26 years represents a significant amount of growth. A revised EIR. must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2019 and projects "in the pipeline" to determine the City's progress towards SCAG's employment growth forecast for the City. For example, other recent industrial projects 19 such as Menifee Commerce Center (2,885 employees), Menifee Commerce Center Phase II (1,962 employees), Northern Gateway Commerce Center (2,267 employees), Ares Warehouse on Murrieta (952 employees), Capstone Industrial (1,205 employees), Wheat Warehouse (151 employees), Corsica Business Park (477 employees), Trumble and Watson Warehouse (571 employees), McLaughlin San Jacinto Warehouses (846 employees), Mapes and Sherman Warehouse (478 employees), United Carports Warehouse (105 employees), Motte Business Center (1,964 employees), Ethanac and Barnett Warehouse ( 440 employees), CADO Menifee (860 employees), Compass Northern Gateway (599 employees), Ares Murrieta Road Warehouse (652 employees), and Northern Logistics Gateway Center (694 employees) combined with the proposed project will cumulatively generate 17,906 employees, which is 210% of the City's employment growth forecast over 26 years accounted for by these industrial projects submitted since 2020. This exceeds the projected growth forecast for the City. This number increases exponentially when the City's commercial development activity and other projects since 2019 (SCAG) and 2013 (General Plan) are added to the calculation. A 18 SCAG 2024 Connect SoCal Demographics and Growth Forecast https://scag.ca .gov/sites/defaulVfiles/2024-05/23-2987-tr -demographics-growth-forecast-final-040424 .pdf 19 Data for listed projects via City of Menifee Land Development Projects Map https://cityofmenifee.maps.a rcgis.com/ap ps/instanVminima lisVindex.html?app id=55fc56d4eee94e588a28 a958cebac908 and Accela Menifee https://aca-
prod.acce la.com/MEN IFEE/Cap/Cap Home.aspx?mo d ule• Planning&TabNam e=Planning&TabLi st=Hom e% ?CO% 7CPermits%7C 1 % 7CEngineer ing% 7C2% 7CPlanning% 7C3% 7CFire% 7C4%7CCurrentTab lnde x%7C3
H-16
H-17
2.0 Response to Comments
Menifee Business Park Project 2-53
City of Menifee
Russell Brown
Septembe r 24, 2025
revised EIR. must be prepared to include a cumulative analysis on this topic in order to provide an adequate and accurate environmenta l analysis.
4.17 Transportation
The project's VMT impacts are misrepresented by the VMT analysis. The EIR. relies upon a VMT screening analysis which concludes that the proposed project site is located in a low VMT generating Traffic Analysis Zone (TAZ) which results in less than significant Transportation impacts. The project site is located in T AZ ID I 053, which is bound by Scott Road to the north, the 1-215 highway to the east, Howard Road to the west, Case Road and Keller Road to the south.
H-17
H-18
2.0 Response to Comments
2-54 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
The T AZ is primarily comprised of vacant land with scattered rural residences, a strip shopping center, and two industrial buildings that were completed sometime between June 2023 and March 202420.The proposed project is unique in that the TAZ in which the Project site is located is over 50% vacant land and the two warehouse buildings were not operational until 2023/2024, which is more than 10 years past the 2012 VMT baseline year the WRCOG tool utilizes for analysis2 1• The VMT scree ning analysis does not adequate ly or accurately represent the VMT impacts of the proposed project and a revised EIR must be prepared with a project-specific VMT analysis.
The Fehr and Peer's WRCOG SB 743 Implementation Pathway Document Package22 states that the exemption for projects in low VMT areas, " may not be appropriate if the project l and uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips." The proposed project will generate I, 751 average daily trips (actual vehicles; 2,030 average daily trips PCE) and daily operations as a warehouse involves extremely high VMT rates during the course of business. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destina tions. Once employees arrive at work at the proposed distribution facility, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a distribution facility, which will drastically increase project-generated VMT. The project's truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity and remove the applied VMT exemption.
Further, Fehr and Peer's WRCOG SB 743 Implementation Pathway Document Package23 states "that a per capita or per employee VMT that is fifteen percent below that of existing deve lopme nt" is a reasonable thresho ld to determine that a project would have a less than significant VMT impact. The EIR states that the Citywide VMT per service population is 33.6 VMT and the Project TAZ rate is 30.7 VMT per service population , which is 2.9 VMT lower than the City average . This does not meet the Implementation threshold of a 15% below existing VMT because it is only a 8% 20 Google Street View
21 https://scag.ca.gov/sites/default/files/2024-05/wrcog-sb743-implementation-pathway.pdf 22 WRCOG SB 743 Implementation Pathway Document Package https://www.fehrandpeers .com/wp content/uploads/20 I 9/l 2/WRCOG -SB743-Document-Packa2e.pdf 23 WRCOG SB 743 Implementati on Pathway Document Package hllps ://www.fehrandpeers .com/wp content/up loads/20 19/ I 2/ WRCOG-SB 743-Document-Package.pd f H-18
H-19
H -20
2.0 Response to Comments
Menifee Business Park Project 2-55
City of Menifee
Russell Brown
September 24, 2025
less than the T AZ VMT. The EIR must be revised to include a finding of significance as it has not presented any substantial evidence to support a less than significant finding.
The EIR has not adequately analyzed the project's potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project's potential to result in inadequate emergency access. There are no dedicated exhibits adequately depicting the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets. There are also no dedicated exhibits adequately depicting the onsite turning radius available for trucks/trailers maneuvering throughout the site. The EIR has not presented any substantial evidence to support a less than significant finding and a finding of significance must be provided in a revised EIR.
The EIR states that there are, "farm-related uses in the area, there is a potential for conflicts with farm equipment. However, drivers/operators of such equipment will likely utilize the remaining rural dirt roads in the area for farm-related access as it minimizes conflicts with more urban vehicles (both passenger vehicles and multi-axle trucks). The rural land north and south of the project site is designated within the Economic Development Corridor-Southern Gateway designations in the General Plan and zoning. Therefore, it is likely that eventually these rural lands will convert to more urban-style development. Project impacts relative to traffic hazards will be less than significant and no mitigation is required." There are no exhibits depicting the location of farms, the alleged dirt roads the farm equipment would utilize, or how the project would not conflict the farming equipment. The EIR has not presented any substantial evidence to support a less than significant finding and a finding of significance must be provided in a revised ECR.
There are also no exhibits depicting emergency vehicle access during construction or operations.
Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation, deferred mitigation, and does not comply with CEQA's requirement for meaningful disclosure and adequate informational documents. The EIR must be revised to include a finding of significance as it has not provided any substantial evidence to support a less than significant finding.
Additionally, the EIR has not provided any analysis of the available horizontal and vertical sight distance at the intersection of the project drivewa ys and adjacent streets. Sight distance is the continuous length of street ahead visible to the driver . At unsignalized intersections, corner sight distance must provide a substantially clear line of sight between the driver of the vehicle waiting on the minor road (driveway) and the driver of an approaching vehicle. The industry standard for H-20
H-21
H-22
H-23
H-24
2.0 Response to Comments
2-56 Final Environmental Impact Report
October 30, 2025
Russell Brown
September 24, 2025
this analysis is the American Association of State Highway an d Transportation Offic ials (AASHTO) Stopping Sight Distance requirement s. The EIR must be revised to include a finding of significance as it has not provided any substantial evidence to support a less than significant finding.
5.0 Alternatives to the Propo sed Project
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.) The alternatives chosen for analysis include the CEQA required "No Project/No Development" alternative and only three others - Less Intense Development Alternative, EDC Mixed Use (C/LI/MFR) Alternative, and EDC Mixed Use (O/BP/MFR) Alternative. The EIR does not include an alternative that meets the project objectives and also eliminates all of the proj ect's significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed d ecis ion making (CEQA § 15126.6). This could include alternatives such as development of the site with a project that reduces all of the proposed project 's significant and unavoidable impact s to a less than significant level, and a mixed-use project that provides affordable housing and exclusive ly local-serving commercial uses that may reduce VMT, GHG emissions and simultaneously improve Air Quality.
6.2 Growth-Inducing Effects
The E IR has not provided an adequate o r accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a c umulative setting. SCAG's Connect SoCa l Demographics and Growt h Forecast24 notes that the City will add 8,500 j obs between 2019 - 2035.
Utilizing the SCAG Employment Density Study calculation of 553 employees, the project represents 3.5% of the City's employment growth from 2019 - 2035. A single project accounting for this amount of the projected employment growth over 26 years represents a significant amount of growth. A revised EIR must be prepared to include this analysis, and also provide a cum ulative analysis discussion of projects approved since 2019 and projects " in the pipeline" to determine the City's progress towards SCAG 's employment growth forecast for the City. For example, other recent industrial projects25 such as Men ifee Commerce Center (2,885 employees), Menifee 24 SCAG 2024 Connect SoCal Demographics and Growth Forecast https://scag.ca.gov/sites/defaull/files/2024-05/23-2987-tr-demographics-growth-forecast-final-040424.pdf 25 Data for listed projects via City of Menifee Land Development Projects Map https://cityofinenifee.maps.arcgis.com/apps/instant/minimalist/index.html?appjd=55fc56d4eee94e588a28 a958cebac908 and Accela Menifee https://aca-
prod.accela.com/MENI FEE/Cap/CapHome.aspx?module=Planning&TabName=Planning&TabList=Hom H-24
H-25
H-26
2.0 Response to Comments
Menifee Business Park Project 2-57
City of Menifee
Russell Brown
September 24, 2025
Commerce Center Phase II (1,962 employees), Northern Gateway Commerce Center (2,267 employees), Ares Warehouse on Murrieta (952 employees), Capstone Industrial (1,205 employees), Wheat Warehouse (151 employees), Corsica Business Park (477 employees), Trumble and Watson Warehouse (571 employees), McLaughlin San Jacinto Warehouses (846 employees), Mapes and Sherman Warehouse (478 employees), United Carports Warehouse (105 employees), Motte Business Center (1,964 employees), Ethanac and Barnett Warehouse (440 employees), CADO Menifee (860 employees), Compass Northern Gateway (599 employees), Ares Murrieta Road Warehouse (652 employees), and Northern Logistics Gateway Center (694 employees) combined with the proposed project will cumulatively generate 17,906 employees, which is 210% of the City's employment growth forecast over 26 years accounted for by these industria l projects submitted since 2020. This exceeds the projected growth forecast for the City.
This number increases exponentially when the City's commercial development activity and other projects since 20 I 9 (SCAG) and 2013 (General Plan) are added to the calculation. A revised EIR must be prepared to include a cumulative analysis on this topic in order to provide an adequate and accurate environmental analysis.
The EIR does not meaningfully discuss or analyze the project's compliance with the General Plan's Land Use Buildout Scenario. Exhibit LU-4: Land Use Buildout Summary within the General Plan Land Use Element26 analyzes a 0.38 FAR for Business Park development within EDC-SG and 21,357,032 square feet of non-retail development within all EDC areas. Table 3-2:
Project Development Characteristics states the project site has a FAR of0.46, which is greater than the assumption of the environmental analysis which it attempts to tier from. The EIR has not provided evidence that the growth generated by the proposed project was anticipated by the General Plan, RTP/SCS, or AQMP. The EIR must be revised to provide an accurate build-out scenario of the City's General Plan.
The EIR utilizes uncertain language and does not provide any meaningful analysis or supporting evidence to substantiate the conclusion that there will be no significant impact to population and housing. The EIR only briefly discusses the jobs generated by the project and states that, "It is reasonable to assume that these jobs would be filled by people living in the City, unincorporated County area, and surrounding cities." Relying upon the entire unemployed workforce within an unspecified distance will result in the project attracting a workforce that is exponentially further e¾ 7C0% 7CPermits% 7C I %7CEng ineering% 7C2% 7CP1anning% 7C3% 7CFire% 7C4% 7CCurrentTab lnde x%7C3
26 Menifee General Plan Land Use Element
https://www.cityofme nifee.us/DocumentCenterNiew / l470 I/FINAL Land-Use-Element 11322 H-26
H-27
H-28
2.0 Response to Comments
2-58 Final Environmental Impact Report
October 30, 2025
16 PAGES BC&H LLP
17 PAGES SWAPE
Russell Brown
September 24, 2025
than that of the "low VMT T AZ" utilized in the EIR to conclude less than significant VMT impacts.
The EIR. does not provide substantia l evidence that the construction or operational workforce in the City is qualified for or interested in construction work or work in the industrial sector to support a less than significant finding. Relying on the unemployed workforce population of the overall SCAG region will increase project related VMT and emissions during all phases of construction and operations and a revised EIR must be prepared to account for longer worker trip distances.
Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.
Sincerely,
Vashon Simien
Blum, Collins & Ho, LLP
Attachments:
I. SW APE Technical Analysis
I H-28
H-29
H-30
2.0 Response to Comments
Menifee Business Park Project 2-59
City of Menifee
I SWAP E I
Technical Consultation, Data Analysis and
Litigation Support for the Environment
~ - ---~
September 19, 2025
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
2656 291h Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
LETTERH
( Cont'd)
Subject: Comments on the Menifee (Pemcor] Business Park Project (SCH No. 2024071016] Dear Mr. Ho,
We have reviewed the August 2025 Draft Environmental Impact Report ("DEIR") for the Menifee (Pemcor) Business Park ("Proj ect") located in t he City of Menifee ("City" ). The Project proposes to construct 337,770-square-feet ('SF") of business park building area spread across 11 buildings on the
20.03-acre site.
Our review concludes t hat the DEIR fails to adeq uately evaluate the Project's hazards, hazardous materia ls, air quality, health risk, and greenhouse gas impacts. As a result , emissions and health risk impacts associated with construction and operat ion of the proposed Project may be underestimated and inadequate ly addressed. A revised Environmenta l Impact Report ("EIR") shou ld be prepare d to adequately assess and mitigate t he potential hazards, hazardous materials, air qual ity, health risk, and greenhouse gas impacts that the project may have on the environment.
Hazards and Hazardous Material s
Inadequate Disclos ure and Analys is of Impacts
The DEIR stat es: " Based upon a review of the City of Men ifee's Permitted Biosolids/S ludge Application Map, the project site is shown as an area where Composite Fields (i.e., biosolid s/ sewage sludge) were allowed but not necessarily deposited. Biosolids/sewage sludge were historically appl ied in the City of Menifee and County of Riverside as a fertilizer both legally under permit, as well as illegally at unknown times and locations." (p. 4.9-2 ). To address this find ing, a Phase I Environmental Site Assessment (ESA) was prepared in 2022 for the Project site (Appendix I). The Phase I ESA includ ed the collection of soil samples which were analyzed for metals, pesticides and fecal coliform.
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2.0 Response to Comments
2-60 Final Environmental Impact Report
October 30, 2025
The Phase I ESA did not includ e the analysis of soil samples for per- and polyfluoroalkyl substances (PFAS) have which are known t o be associated with bioso lids. The occurrence of PFAS in biosolids "is reported to be prevalent nationwide."'
On April 19, 2024, two PFAS, perfluorooctanoic acid {PFOA) and perfluorooctanesulfonic acid (PFOS), were listed as hazardous substances under t he Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) or Superfund. As a result of this rulemakin g PFOA and PFOS now should be considered as part of a Phase I ESA under ASTM Standard E1527-21. For example, this analysis found:
"the potential presence of PFOA and PFOS must now be evaluated as part of a standard Phase I ESA (without the need for further updates to ASTM E1527-21) . As a result, corpo rate and real estate due diligence teams should be updating their due diligence protocols to ensure that their consultant s are evaluating whether the property was used by any of the aforemention ed industries or if PFAS could be present in any components used or manufactur ed at the property.
Though invasive testing is not part of a Phase I ESA, consideration should be given to Phase II sampling for PFAS duri ng the due diligence process based on historical site use and deal consideration s."'
Another analysis found:
"PFOA and PFOS must now be considered as part of a Phase I Environment al Site Assessment under the new ASTM Standard E1527-21 for purpose s of meeting the "all approp riate inqui ries" standard. Compliance with this standard is import ant for prospective real est ate and asset purchasers, in particular, who may seek defenses to lia bility and cleanup obligations under CERCLA. The inclusion of PFOA and PFOS in Phase I Environm ental Site Assessments may prompt sampling or "Phase II" investigations that lead to the id entific ation of histori cal PFOA and PFOS contamination that may trigger cleanup obli gations under CERCLA."3 A revised DEIR should be prepared to include a Phase II ESA that samples for PFAS given : (1) the Project site may have been used for biosolids application; (2) that biosolids are known to be associated with PFAS; and (3) according to the interpretations cited above, Phase I ESAs should now consider PFAS sampling where historic al use indicates it may be present.
Air Quality
Failure to Provide Com plete CalEEMod Output Files
Land use development proje cts under CEQA assess air quality impacts and calculate criteria air pollutant emissions using the California Emissions Estimator Model ("CalEEMod").4 CalEEMod uses site-specific 1 httos://ofas•l.itrcweb.org/wo-content/uploads/2023/10/Biosolids PFAS Fact Sheet Sept2023 flnal.odf 2 https://www.hklaw.com/en/insights/oublications/2024/04/epa-designates-2-ofas-compounds-as-hazardous substances
' htt ps:l/www. kirkland.com/oublicatlons/kirkland-alert/2024/04/pfao-and-pfos-hazardous-substances 4 "CalEEMod User Guide." CAPCOA, April 2022, available at: https://www.caleemod.com/documents/user guide/01 User%20Guide.odf.
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2.0 Response to Comments
Menifee Business Park Project 2-61
City of Menifee
defaults that can be adjusted with justified project-specific data. It calculat es construction and operat ional emissions, generating output files t hat document inputs, changes, and just ifi cations.5 The DEIR reli es on CalEEMod Version 2022.1 provided in t he Air Quali ty and Health Risk Assessment Report ("AQ Analysis") as Appendix E to the DEIR to estimate Project emissions, which fails to generate complete output fil es. Specifically, t he 'User Changes to Default Data ' table omits quantitative details of default value modifications (see screenshot below) (Appendix E, pp. 157).
8. User Changes to Default Data
"'"'""'
Operallons:vetoldeDa1a
Ope~tiofl s: Flee! MO!:
Canslructlon: Construaion Pl'IHM
Operations: Energy Use
ProjeCI specirc condi!lonS per Me plan
Updale:d perlra flc Sc:oplng ~efflffll . IP lflodets p;issenger Yll!rtldes, P.ilBlng Lot models !rude trips Truc.k 1rl) length updated ba~d on SCAOMO Rute 2305 RUlemaklng materials.
Passenger YMid• lrip lfflgth updated based on
Fleet mx updated to rell1d IP modeled as pauengei--wt1ieln and Pl modeltd as trudls.
Ttuck bl'Nl(OCJl'Wn dlrectty from Gao<lclirll. PasSCOQef Yeh ad]U$led based on CMod clef&l.fls. refflOW'9 wuc:u. buses, and motor homes.
B~ tonSlruCmn phase comm"8d 10 accourt b' 18 monfl construction limeline as ~ byAWUcant.
&,ilOing oonslruc!lon eQUipment lnaeased 10 acaxint Jar compressed consln.lctlon schedule, OClfll>,lred lo ca&EE1'.Aod defa&Jls.
Previous CalEEMod Versions, such as 2020.4 .0, provide the specific numeric changes to a mode l's default values (see example screenshot below):
Table Name COiumn Name Detaunvawe New Value
lblConstructionPl'lase NumDays 230.00 I 167.00
••••• • "lbi~-~~a·s~ -----· -: • • ·······pt,;;;~dO;t;······ • ··->;-- --,-,IW20--2-3----+1 .. _ ... ___ 8ll5J2023 .. __ • ___ _ ............................. .;. ............ ............ ..... . . _______ t~~~~"-~~~a-~ _______ : ___ . ... _. ~~~~~~~~t~ _ ..... ... ; 9127/2023 I · ........ 613 712
8/200,202
2 3
3 ........ .
ttJIConsruetiooPhase : PllaseEndOate : 11Yl5/2023
••••••• lbiC~;s~n·ph ·a;~ ••••••• .; ••••••••• Ph~~S~11Di1e· •••••••• -----,,0/2=6120=23,-,------tj ••••••••• 1°d9i2oii ••••••••• lblConsvuctionPhase : PhaseStartO.rte ; • 9128/2023 I-......... 7/112023 . ... ..... . lblland\Jse ; LandUseSquareFeet .:---- --,60--.000-.00-- ----t 160,371.00 ··········· · ···· ····· ······• ·4 ••·· · · ········ ··· · · ····· ··· ·· .. -------------t ···· ··· · ·· · ·· ······· ····· · tblLandUse • LandUseSquareFeet • 119,000.00 I 41.155.00 ••• • • • • • • • 1;,~.;u;.; • • • • • • • • • • 1 · · · •• • · • · • i~ik:reage • • • • • • • • • • .:------ ~3_"'.,------l •• · · · · · · · · · 3.68 • • • • • • • • • • • lbllandUse : lclAaeag e 2.73 2.74
······ ··· ····· ······· ··· ····· •················ ·· ··········· .. -----------~- ·-······················· The output files associated with CalEEMod Version 2022.1 do not includ e a changes table that reveals the exact paramete rs used to calculate Project emissions. We suggest that the DEIR provide access to the mode l's " .JSON" files, which can allow third parties t o review the mode l's revi sed input parameters.• We are unable to verify the DEIR's air modeling and subsequent analysis without access to the comp lete output files and the specific numeri c changes to the default values. 5 "CalEEMod User's Guide." CAPCOA, April 2022, available at: https://www .caleemod.com/documents/user guide/0 1 User%20Guide .pdf. p_ 1.
6 "Video Tutorials for CalEEMod Version 2022.1." CAPCOA, May 2022, available at:
http s:ljwww .caleemod.com/tutorials .
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2.0 Response to Comments
2-62 Final Environmental Impact Report
October 30, 2025
Unsub stantiated Inp ut Para meters Used t o Estima te Project Emiss ions When reviewing the Project's CalEEMod output files, provided in the AQ Analysis as Appendi x E to the DEIR, we identified several model inputs related to Project constru ction and operation that are inconsistent with information disclosed in the DEIR. A revised EIR should be prepared to include an updated air quality analysis that provides a more detailed evaluation of the impact that construction and operation of the Project may have on local and regional air quality.
Incorrect Construction Hauling Trip Length
Review of the CalEEMod output files demonstrates that the "PEMCOR Business Park - Menifee Detailed Report" model includes the default 20-mile hauling trip length (see screenshot below) (Appendix E, pp. 144, 145).
PMJli::
Demolitiotl
Demolition
0,mo'"lon
Demolition
°""""""' Sile Pre~tion
Sill!! Preparation
SiteP~ration
~PA!pata lion
SitePrepar.i,lion
Grading
G<>d"9
~
Gnldi,,g
-BuidingConslnJcl.ion
BoodingCctislNclion
BuUoiogConstruclii:>n
BuiidingConstruclbfl
BuldingC011strucUon
......
Paving
·---
Al'dilteciuralColling
Al(fli!ecwralCoa!k,g
¢¥,.
-.........
Onsite 11\/Ck
Onsit• ~
.........
onsite Wd(
"'""" Onsileb'udt
Atdlilectural Coating Vendor
Alchi!ectural Coating
"'"""'
&:CZ:4-#1-.1
150
175
17.5 000
20.0 ,.,
55.-4
0.00 15.0
0.00 28.4
0.00 l,Wn,pe!'Trfp Vehld&Mbt
19 5 LO.\.LDT1,LDT2
102 HHDT.MHOT
Eio HHOT
HHOT
18.5 LDA.LOT1,LDT2
102 HHOT,"1HOT
ljalg HHOT
HHDT
185 lOA.LDT1.LDT2
102 HK>T,MHOT
620 HHOT
HHOT
195 1.DA.LDT1,lDT2
102 HHDH.tH DT
120.0 HHOT
HHDT
1U LOALOT1.LDT2
102 HHOT,MHOT
li2o HHDT
HHOT
18.5 LOA.LDT1,LDT2
102 HHOT.MHOT
1200 HHOT
In regard to t he landfill to be used by the Project during demolition and grading, the DEIR states:
"Solid waste collection, disposal, and recycling services in Menifee are provided by Waste Management Inc. (WM) . WM operate s the privat e El Sobrante Landfill located at 10910 Dawson Canyon Road in Corona, CA" (p. 4.19-12).
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2.0 Response to Comments
Menifee Business Park Project 2-63
City of Menifee
However, review of Google Maps reveals that the El Sobrante Landfill is located approximately 25.4 miles from the Project site (see screenshot below).
<.> ..
0 0
&plo!Tne.111bf109 1D Daws011C11t1ronRd
0 0 0 0 0
The 20-mile hauling trip route is therefore underestimated by 5.4 miles. CalEEMod uses the hauling trips lengths to estimate the construction-related emissions associated with on-road vehicles! By includi ng an underestimated hauling trip length, the model underestimates the Project's construction-related emissions and should not be relied upon to determine Project significance.
Unsubstantiated Changes to Operational Vehicle Fleet Mix Review of the CalEEMod output files reveals the "PEMCOR Business Park - Menifee Detailed Report" model includes changes to the default operational vehicle fleet mix percentages (see screenshot below) (Appendix E, pp. 157).
8. User Changes to Default Data
""'"'' Operalions : VehideData
conswuction.: Constnici<On Phast'S
Coostrucliorl: Off.-Roa<t Equipment
Operalion s: Energy Usr
Project s.peci('ic aiodillons per site plan.
~led pe( T'8ffic SCOping Agreemenl IP mo:ll'IS passenger vel\ides, Pa111ing lot models tuc.k 11iP$. Tnick 111) terigch upoated b&Sed on SCAQt.lD Ru!t 2305 Rulemaking materials Passenge,vehicle I.rip lenglh updated based on
Fleet mb: updl,ted to refted IP moMled H passet1ger vehicles a1d Pl modeled as lnKb.
Tn.ick bfHkdown dndly from Gandd inl. Passe-nger veh adjusted based on CMod defaults. " 1Mb. euus. Mid mo:«hOMcs.
au~ding constl'\ICtioti l)haseoomprened to KCOunl f0r 181110nll'l 1Xl1'11truction timeline as ~ed by Appllcanl
Building constn.lClicn e~t inc:rl'ased lo~ for comp1111.s11d c:onslrudion schedule, compared lo Ca!EEMod oeratAts.
7 "Cal EE Mod User Guide." CAPCOA, April 2022, available at: https ://www.caleemod .com/documents/user guide/01 User%20Guide.pdf p. 38.
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2-64 Final Environmental Impact Report
October 30, 2025
The Cal EE Mod User's Guide requires any changes to model defaults be justified. 8 The justification provided for these changes is:
"Fleet mix updated to reflect IP modeled as passenger vehicles and PL modeled as trucks . Truck breakdown directly from Ganddini. Passenger veh adjusted based on CMod defaults , removing truc ks, buses, and motor homes" (Appendix E, pp. 157).
The DEIR also includes the following trip generati on table that includes a breakdown of the Project's anticipated passenger car and truck trips (see screenshot below) (p. 4.17-6, Table 4.17-1):
Table 4.17-1 : Proiect Trip Generation
Vehicle Type' AM Peak Hour PM Peak Hour TOTAL In Out Total In Out Total Industrial Park (80%)
Vehicle Trips
Cars 66 15 81 18 63 81 757
Trucks 4 7 11 4 8 12 154
Total 70 22 92 22 71 93 911
PCETrips 2
Cars 66 15 81 18 63 81 757
Trucks 12 19 31 12 22 34 433
Total 78 34 112 30 85 115 1,190
Business Park (20%)
Cars (no trucks) 78 14 92 21 61 82 840
Total Trips
(Vehicles) 148 36 184 43 132 175 1,751
Total Trips (PCE) 156 48 204 51 146 197 2,030 .. Source: GanddmI TlA. Tables 1-3, Pro1ect Tnp Generallon 1 ITE Land Use Code 130 for lnduslriat Park and ITE Land Use Code 770 for Business Park 2 PCE = Passenger Car Equivalent which accounts for greater traffic inpacls due to the longer length of trucks compared to cars.
The changes to the mode l's operational fleet mix values, however, rem ain unsupported. As discussed in the section of this letter titled "Failure to Provide Complete CalEEMod Output Files," the output files for CalEEMod 2022.1 do not present numeric changes to any model defa ults. Changes to fleet mix percentages are not mentio ned outside of the "User Changes to Default Data" table . As the DEIR provides a table with proposed fleet mix values without access to the specific changes, we are unable to verify what values were inputted . Until the DEIR verifies the breakdown of heavy-heavy duty, med ium heavy duty, light-heavy duty trucks used by the model, these values may be inconsistent with the informati on provided by the DEIR and associated documents.
CalEEMod uses operational vehicle fleet mix percentages to calculate the Project's operationa l emissions associated with on-road vehicles.• By including several unsubstantiated changes to the default 8 "CalEEMod User Guide." CAPCOA, April 2022, available at: htlps ://www .caleemod.com/documents/user gulde/01 User%20Guide.pdf p. 13, 14.
9 "CalEEMod User's Guide." CAPCOA, May 2021, available at: https://ww w.agmd.gov/caleemod/user's-guide, p.
36. 6
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2.0 Response to Comments
Menifee Business Park Project 2-65
City of Menifee
operational vehicle fleet mix percentages, the model may under estimate t he Project's mobile-sou rce operatio nal emissions and should not be relied upon to determine Project signifi cance.
Diesel Particulate Matter Emissions Inadequately Evaluated The DEIR conducts a health risk analysis ("HRA") evaluating impacts as a result of exposure to diesel particulate matter ("DPM") emissions from Project construction and operation. Specifically, the DEIR estimates that the tota l maximum cancer risk posed to nearby, existing residential sensitive recepto rs as a result of Project construction and operation would be 6.9 in one million , which would not exceed the South Coast Air Quality Man agement District ("SCAQMD") significance threshold of 10 in one million (see excerpt below) (p. 4.3-26, Table 4.3-11).
Table 4.3-11: Unmitigated Cancer Risk at PMI and MEIR
Annual Average OPM Excess Cancer Risk UTM Locatlon Concentration (µg/m') (par million population) Receptor Year2
East North Year1 Construction Year 3.JO Year Year Year Total Construction and Operatlon 18l 1 2 3-30 Operation iAI
PMl!C) 483610.00 3721409.00 0.10716 0.03134 0.00229 - - - - MEIR 483654.71 3721301.62 0.03465 0.010055 0.00053 5.2 1.4 0.2 16.9101 Source: MIG, 2024 (see Appendix C)
(A) Year 2 includes emissions from both construction and operational actiVities, The Year 2 concentration was calculated multiplying the operational concentration in Year 3-30 by the percent of the year that operallon occurs in Year 2 (50%), and adding that Year 2 operational concentration to the Year 2 construction concentration. The construction DPM concentration for Year 2 was 0.00979 JJQ/m3. The operational DPM contribution during Year 2 was estimated lo be approximately 0.009525 µglm1• which reftecls the remaining approximately six (6) months during the Year 2 lhal the project could be operational. (B) The annual average DPM operational concentration is based on the first full year of operation (Year 3). (C) The PMls vary between Year 1 and Year 2 of construction, as well as project operation; however, the PMls are always to the south of the site in lhe field immediately south of lhe site or, in lhe case of operations, In lhe roadway of Zeiders Road. (D) Total may not equal due to rounding.
The DEIR's constrict ion and operationa l HRA underestimates Fraction of Time At Home ("FAH") values for third trimeste r, infant, and child recepto rs. It uses an FAH value of 0.85 for third t rimester (age -0.25 to 0) and infant (age Oto 2) recepto rs, and 0.72 for child receptors (age 2 to 16) (see excerpt below) (Appendix E, pp. 399).
Risk Parameter Values bl( Age Bin
Variable Residential Age Bin
3rd Trimester 0-2 Years 2-16 Years 16-30 Years 30-70 Years DBR 361 1090 572 261 233
A 1 1 1 1 1
EF 0.96 0.96 0.96 0.96 0.96
CF 1.00E-06 1.00E-06 1.00E-06 1.00E-06 1.00E-06
CPF 1.1 1.1 1.1 1.1 1.1
ASF 10 10 3 1 1
ED 0.25 2 14 14 54
IF~~
ZQ ;zg ZQ 70 70
0.85 0.85 0.72 0.73 0.73
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The FAH values for third trimester, infant, and child receptors in the HRA are incorrect. SCAQMD guidance states that for screening purpo ses, "the FAH is set to 1 for individua ls from the third trimester to age 16, assuming children stay near home for school or daycare with no time discount." 10 Per SCAQMD guidance, the HRA Report should have followed this guidance and used an FAH of 1 for third trimester, infant, and child receptors. By using unsupported FAH values, the DEIR may underestimate the cancer risk to nearby sensitive receptors from Project const ruction and operation .
Failure to Adequate ly Evaluate Green house Gas Impacts The DEIR estimates that the Project would result in net annual greenhouse gas ("GHG") emissions of 10,419.5 metric tons of carbon dioxide equivalents per year (" MT CO,e/year") (see screen shot below) (p. 4.8-18, Table 4.8 -4).
Table 4.84: Unmitigated Project Operational GHG Emissions GHG Emissions (MT/ Year)
Emission Source Refrigerant CO, CH, N2O GHGs CO,e
Area 6.9 <0.1 <0.1 0.0 6.9
Energy 1,497.1 0.1 <0.1 <0.1 1,504.4
Mobile 8,343.2 0.2 0.6 11 .9 8,537.0
Waste 37.4 3.7 0.0 0.0 130.7
Water 108.3 2.6 0.1 0.0 190.3
Refrigerants 0.0 0.0 0.0 14.6 14.6
Amortized Construction 35.1 <0.1 <0.1 <0.1 35.6
Site SubtotaJCAl 10,028.0 6.6 0.7 26.4 10.419.5
Threshold of Significance 3,000
SCAQMD Interim Threshold Exceeded? Yes
Source: MIG 2024 (see Appendix A).
(A) Totals may not equal due to rounding.
The DEIR concludes that the Project would exceed the SCAQMD brig ht- line thres hold of 3,000 MT CO2e/year and result in a significant-and-unavoidab le GHG impact (p. 4.8-22).
Whi le we agree that the Project would result in a significant GHG impact, the DEIR's assertion that this impact is significant-and-unavo idable is unsupported , as additional feasible mitigation is available.
According to CEQA Guidelines §15096(g)(2) :
"When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible 10 "Risk Assessment Procedures." SCAQMD, August 2017, available at: http://www .agmd.gov/docs/defau lt source/rule -book/Proposed·Rules/1401/r iskassessmentprocedures 2017 080717.pdf . p. 7. 8 H-36
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2.0 Response to Comments
Menifee Business Park Project 2-67
City of Menifee
mitigation measures within its powers that would substantially lessen or avoid any significant effect the proje ct would have on the environment." 11
As such, the DEIR is required under CEQA to implement all feasible mitigation to reduce impacts to a less-than-significant level. To reduce the Project's GHG impa cts to the maximum extent possible, additional mitigation measures should be incor porated, such as those suggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Emissions." The Project should not be approved until a revised EIR is prepared , incorporatin g all feasible miti gation to reduce emissions to less than-significant levels if feasible.
Mitigation
Feasible Mitigation Measures Avail able to Reduce Emission s The DEIR is required under CEQA to implement all feasible mitigation to reduce the Project's potential impacts . As demonstrated in the section s above, the Project would result in potentially significant air quality, health risk, and GHG impacts that should be mitigated further.
To reduce the GHG emissions associated with the Project, we recommend the DEIR consider several mitigation measures as listed below . The California Department of Justice ("CA DOJ'') recommends : 12 • Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building's project ed energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and install ing the maximum solar power generation capacity feasible. • Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Requiring all stand- by emergency generators to be powered by a non-diesel fuel. • 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 buildin g certification standards. • Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Requiring facility operators to train managers and employees on efficien t scheduling and load management to eliminate unnece ssary queuing and idling of trucks. 11 "Cal. Code Regs. tit. 14 § 15096." California Legislature, available at: https:ljcasetext .com/regulation/california code-of-regulations/title-14-natural-resources/division-6-resources-agency/chapter-3-guidelines-for implementation-of-the-california-environmental-guality-act/article-7-eir-process/section-15096-process-for-a responsible-agency.
12 "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, September 2022, available at:
https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf. p. 8 - 10. 9 H-37
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• Requiring that every tenant tra in its staff in charge of keeping vehicle records in diesel technologie s and compliance with CARB regulations, by attendin g CA RB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdict ion, air distri ct, and state upon request . • R equiring tenants to enroll in the United States Environmenta l Protection Agency's SmartW ay program, and requiring tenant s who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providi ng tena nts with informatio n on incentive programs, such as t he Carl Moyer Program and Vouch er Incentiv e Program, to upgrade their fleets.
SCAQMD staff recomm ends: 13
• Maximizing the use of solar energy by installing solar energy arrays. • U sing light-colored paving and roofing materi als.
Utili zing only Energy Star heating, cooling, and light ing devices and appliances.
CEQA Guideline s 15126 .4 (c}(3) includ e "[o]ffs ite measures, includ ing offsets that are not otherwise required, to mitigate a project 's emissions" as an option for GHG mitig ation.14 An example of this was in the case of the Oakland Sports and Mixed -Use Project, w here off-site reduction measures in the neighboring com munitie s were recommended.15 We recommend consideration of local carbon offset programs to reduce the Project 's GHG impact s as a measure of last r esort.
As demonstrated above, we have provided several mitiga tion measures that wou ld reduce Project related GHG emissions developed from sources including the DOJ and others. These measures offer a cost-effect ive, feasibl e way to incorporat e lower -emitting design featur es into t he proposed Project , w hich subsequently reduce emissions released during Project const ruct ion and operation.
A revised EIR should be prepared that includes all feasible mitig ation measures, as w ell as update d air quality, health risk and GHG analyses to ensure t hat t he necessary mitigation measures are impl ement ed to reduce emissions to the maximum extent feasible. The revised EIR should also demonstrate a commitment to th e implementation of t hese measures prior to Project approva l, to ensure that the Project's potent ially significant emissions are reduced to t he maximum extent possible . " "Draft Environmental Impact Report (EIR) for the Proposed CADO Menifee Industrial Warehouse Project (Proposed Project)." SCAQMD, April 2024, available at: https://www.agmd .gov/docs/default source/cega/comment-letters/2024/april-2024/RVC240313-05.pdf7sfvrsn=8. p. 3. 14 "Cal. Code Regs. tit. 14 § 15126.4." CEQA Guidelines, May 2024, available at:
https://casetext.com/regulation/california-code-of-regulations/title -14-natural-resources/division-6-resources agency/chapter-3-guidelines-for-implementation-of-the-california-environmental-guality-act/article-9-contents-of environmental-impact-reports/section-151264-consideration-and-discussion-of-mitigation-measures-proposed-to minimize•significant•effects.
15 "Cal. Pub. Resources Code§ 21168.6.7." 2023, available at: https:l/casetext.com/statute/californ ia codes/california-public-resources-code/division-13-environmental-guality/chapter-6-limitations/section-2116867- oakland-sports-and-mixed-use-project-conditions-for-approval-certification-of-project-for-streamlining. 10 H-38
2.0 Response to Comments
Menifee Business Park Project 2-69
City of Menifee
Disclaimer
SWAPE has received limited documentation regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protoco ls, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
Attachment A: CalEEMod Output Files
Attachment B: Matt Hagemann CV
Attachment C: Paul Rosenfeld CV
11 H-39
2.0 Response to Comments
2-70 Final Environmental Impact Report
October 30, 2025
Menifee (Pemcor) Business Park Detailed Report , 9/17/2025 Attachment A
Menifee (Pemcor) Business Park Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.3. Construction Emissions by Year, Mitigated
3. Construction Emissions Details
3.1 . Demolition (2025) - Unmitigated
3.2. Demolition (2025) - Mitigated
3.3. Site Preparation (2025) - Unmitigated
3.4. Site Preparation (2025) - Mitigated
3.5. Grading (2025) - Unmitigated
3.6. Grading (2025) - Mitigated
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2.0 Response to Comments
Menifee Business Park Project 2-71
City of Menifee
3.7. Building Construction (2025) - Unmitigated
3.8. Building Construction (2025) - Mitigated
3.9. Building Construction (2026) - Unmitigated
3.10. Building Construction (2026) - Mitigated
3.11. Paving (2026) - Unmitigated
3.12. Paving (2026) - Mitigated
3.13. Architectural Coating (2026) - Unmitigated
3.14. Architectural Coating (2026) - Mitigated
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Menifee (Pemcor) Business Park Detailed Report , 9/17/2025
4.10.2 . Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.1 . Construction Schedule
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5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2 . Mitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.3.2. Mitigated
5.4. Vehicles
5.4.1. Cons1rudion Vehicle Control Strateg ies
5.5. Ardlitectural Coatings
5.6. Dust Mttigation
5.6.1. Cons1rudion Earthmoving Activities
5.6.2. Construction Earthmo ving Control Strategies
5.7. Constructio n Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.18. Vegetation
5.18.1. Land Use Change
5.18.1 .1. Unmitigated
5.18.1.2. Mitigated
Menttee (Pemcor) Business Parl< Detailed Repor~ 9/17/2025 3 / 52
2.0 Response to Comments
Menifee Business Park Project 2-73
City of Menifee
5.18.1 . Biomass Cover Type
5.18.1 .1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.1 8.2.2. Mitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1 . CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
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Menifee (Pemcor) Business Park Detailed Report , 9/17'2025
8. User Changes to Default Data
5 / 52
2.0 Response to Comments
Menifee Business Park Project 2-75
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE Blum, Collins, & Ho LLP for Golden State Environmental Justice Alliance Letter H-1 The City accepts the comments on behalf of the Golden State Environmental Justice Alliance (GSEJA)(Responses 1-30) plus additional comments from the Soil/Water/Air Protection Enterprise (SWAPE)(Responses 31-39).
H-2 The commenter claims that the EIR does not include environmental justice issues, summarized CalEnviroScreen results for environmental and socioeconomic conditions, described demographic conditions, and described the effects of pollution and poverty on heal th. The commenter has not provided new information that substantially changes the Project setting or the EIR’s evaluation of the Project’s potential adverse health risk impacts. Appendix E-1 contains CalEnviroScreen results (see Section 3.2.3.3) that includes the percentiles for pollution burden indicators and health and vulnerability factors. Additionally, Section 3.2.3.3 contains a description of how socioeconomic factors effect health and that health conditions may add to the severity of pollutions. A description of the effects on health from pollution is contained in Section 3.1.1.
H-3 Please see Response H-2.
H-4 The commenter references three modeling compliance softwares, but makes no argument about their relevance to the analysis. The commenter then accurately notes that Appendix E was not initially included for public review, and asserts that it must be included for meaningful disclosure. The EIR was reissued on September 2, 2025 with Appendix E included. Additional notices were sent to the State Clearinghouse and local agencies informing them of the extended review period.
H-5 4.11 Land Use and Planning. State planning law and CEQA require a project to be generally consistent with the General Plan, including its goals and objectives , but it need not be fully consistent with specific goals (i.e., a project does not have to “rigidly conform” to the general plan). The Project does have an FAR higher than that assumed by the General Plan buildout (0.46 v. 0.38), however, state law and CEQA do not require that individual projects meet all the thresholds for growth and development identified in the GP and/or its EIR. This is because the Project is within the development limits established by the General Plan land use designation and the zoning for the site and is therefore generally consistent with the City’s anticipated growth. These are general guidelines for planning and environmental analysis, not legal limits that cannot be exceeded by any specific development. Therefore, the EIR does not need to be revised to reflect any more restrictive or stringent compliance with the growth forecasts of the City.
It should be noted that the Project’s consistency with the regional Air Quality Management Plan (AQMP) is evaluated in DEIR Section 4.3.4, Air Quality, Impacts and Mitigation (Impact AIR-1) and its consistency with the General Plan and SCAG’s RTP/SCS is evaluated in DEIR Section 4.11.4, Land Use and Planning, Impacts and Mitigation (Impact LAND-2).
H-6 Table 4.11 -1: 2024 -2050 RTP/SCS Consistency Analysis. The commenter is incorrect, the assumptions and modeling used to characterize the GHG emissions of the Project were appropriate and as recommended by SCAQMD. The RTP/SCS does not itself contain thresholds for GHG emissions against which development projec ts
2.0 Response to Comments
2-76 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE are compared, that analysis is the responsibility of the SCAQMD, and the GHG analysis of the Project in this EIR is consistent with SCAQMD methodologies. Due to the size and nature of the Project, it exceeds both the SCAQMD 10,000 MTCO2e and the City’s adopted 3,000 MTCO2e GHG thresholds, so its impacts are significant and unavoidable, even with the recommended mitigation.
In addition, the commenter fails to acknowledge that the Project area is designated for mixed use and may contain residential uses but is not required to include them, as outlined DEIR Sections 3, Project Description, and 4.11, Land Use and Planning.
Since the Project has no residential component, it is unnecessary to compare it to the various SCAG regional goals relative to housing. It is the responsibility of the City to find the correct balance of residential and non-residential land uses as the City grows, as outlined in the City’s Housing Element. The Project site, while being a potential site for housing, is not designated site for a specific amount of housing under the City’s Housing Element. Many of the other SCAG Connect SoCal policies cited by the commenter do not apply to individual non-residential development projects but rather are the responsibility of the City as it processes future development and implements public works projects. The Project is consistent with the General Plan land use designation and zoning classification of the site and so its consistency with every SCAG regional policy is not required since the City’s General Plan is consistent with the SCAG RTP/SCS regional plans in terms of long-term land uses.
Conclusion: this additional information merely clarifies the data and analyses presented in the DEIR and does not change the analyses, conclusions, or determination of the severity of impacts of the Project relative to applicable General Plan goals and policies (i.e., less than significant with project design and regulatory compliance).
H-7 The comment indicates that the EIR must contain a consistency analysis with all General Plan (GP) policies goals and policies . That statement is incorrect, an EIR must only evaluate relevant GP goals and policies depending on the type and size of project, where it is located in the city, and what discretionary actions it will require from the city. State planning law and CEQA require a project to be generally consistent with General Plan goals and objectives but it need not be consistent with every goal or fully consistent with specific goals (i.e., a project does not have to “rigidly conform” to the general plan).This conclusion is clearly supported by the following two court cases:
• Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 719.
“Indeed, it is beyond cavil that no project could completely satisfy every policy stated in the OCP, and that state law does not impose such a requirement. (Greenebaum, supra, 153 Cal.App.3d at pp. 406 –407, 200 Cal.Rptr. 237; 59 Ops.Cal.Atty.Gen. 129, 131 (1976).) A general plan must try to accommodate a wide range of competing interests —including those of developers, neighboring homeowners, prospective homebuyers, environmentalists, current and prospective business owners, jobseekers, taxpayers, and provid ers and recipients of all types of city -provided services —and to present a clear and comprehensive set of principles to guide development decisions.”
2.0 Response to Comments
Menifee Business Park Project 2-77
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE • Holden v. City of San Diego (2019) 43 Cal.App.5th 404, 412. “The requirement that a project be consistent with a general plan does not require the project to rigidly conform to the general plan. (San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656, 678, 125 Cal.Rptr.2d 745 (San Franciscans Upholding).) “State law does not require perfect conformity between a proposed project and the applicable general plan ....” (Friends of Lagoon Valley v. City of Vacaville (2007) 154 Cal.App.4th 807, 817, 65 Cal.Rptr.3d 251.)”
In this case, the Pemcor Project is consistent with the General Plan land use designation and zoning classification for the site, so the goals and policies against which it must be evaluated are limited to those where the Project might have a significant unanticipated impact on some physical aspect of the city. Where there may be such conflict, the EIR provides a text or tabular comparison of the Project to the appropriate goals and policies to determine if or to what degree the Project is consistent in the following sections:
• Greenhouse Gas Emissions
Section Impact GHG -2 evaluates the Project relative to the CARB Scoping Plan, Sustainable Freight Plan and Action Program, SCAG RTP/SCS, and City General Plan in the text (no table).
• Land Use and Planning
Table 4.11-1: 2024-2050 RTP/SCS Consistency Analysis
Table 4.11-2: City General Plan Consistency Analysis
• Transportation
Table 4.17-2: City General Plan Consistency – Circulation Element Conclusion: this additional information merely clarifies the data and analyses presented in the DEIR and does not change the analyses, conclusions, or determination of the severity of impacts of the Project relative to applicable General Plan goals and policies (i.e., less than significant with project design and regulatory compliance).
H-8 The Project does try to reduce impacts of goods movement by proposing business park uses adjacent to the I-215 Freeway in the far southern portion of the City where such uses are currently lacking. There is a typographical error in DEIR Section 4.8.4, Greenhouse Gas Emissions, Impacts and Mitigation, Impact GHG -1 where the conclusion says the impact is Less than Significant, however, Table 4.8 -4 and the supporting text clearly demonstrate and state this impact is Significant and Unavoidable. This impact is correctly stated in DEIR Section 2, Executive Summary, Table 2, Summary of Impacts and Mitigation, under 4.8, Greenhouse Gas Emissions.
It is also stated correctly in DEIR Section 6.3, Significant Unavoidable Impacts.
FEIR Section 3, Errata, will show this correction to DEIR Section 4.8.4, Impacts and Mitigation.
H-9 4.14 Population and Housing. 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 r educe trip lengths between residential and non-residential uses in the area. In addition, the City’s Housing Element does not
2.0 Response to Comments
2-78 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE 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 encourag es or allows future 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.
Conclusion: this additional information merely clarifies the data and analyses presented in the DEIR and does not change the analyses, conclusions, or determination of the severity of impacts of the Project relative to applicable General Plan goals and policies (i.e., less than significant with project design and regulatory compliance).
H-10 The Project does not propose any change to the stated residential density of the EDC- SG designation, it simply proposes non -residential development consistent with that designation (i.e., mixed use). The General Plan does not require residences to be built on parcels with this designation, it allows residential development at the discretion of the City and the developer. This is a non-residential development allowed within a mixed use zone, and the one farmhouse on the site has been vacant for several years. Therefore, it does not need to be replaced under SB 330.
H-11 As outlined in Responses H-9 and H-10 above, the City has complete discretion on if or how much housing is allowed on a particular parcel within the mixed use EDC-SG zone, including the Project site. According to the Housing Element, the City does not depend on any housing being built on this site to meet its RHNA allocation from SCAG and no development standards are being changed within this designation, the developer has simply chosen to develop non-residential uses on this site.
H-12 Since the EDC-SG mixed use designation allows but does not require residential uses there is no regulatory requirement to replace any of the potential housing that could but not necessarily is required to be built within the EDC-SG zone. Likewise, there is no requirement to replace one vacant farmhouse building on the site under either SB 330 or SB 8 since the farmhouse has been vacant for several years, the proposed Project is not residential, and development of housing on this site is not required under the Housing Element to meet the City’s RHNA allocation from SCAG.
H-13 As outlined in Responses H-9 through H-12 above, there is no requirement to replace the one vacant farmhouse on the Project site since the EDC -SG mixed use designation gives the City full discretion to allow a maximum of 487 units down to zero units depending on the type of development proposed. In this case, the entire project is a non-residential business park that is fully consistent with the EDC-SG designation so no replacement housing is needed or required.
H-14 The Project proposes only non -residential uses so by its very nature it would have minimal or no impacts on housing or population. As outlined in Responses H -9
2.0 Response to Comments
Menifee Business Park Project 2-79
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE through H-13 above, the City has full discretion to allow a maximum of 487 units down to zero units depending on the type of development proposed. In this case, the entire project is a non -residential business park with is fully consistent with the EDC -SG designation.
Construction jobs are by their nature temporary and it is much more likely such jobs would be filled by workers already residing in the City or immediate surrounding areas.
There is no statutory or regulatory requirement to identify where potential workers to the Project would reside or commute from. Construction of a project of this size would require a number of months but not years to complete, so it would be overly speculative to even try to determine such unnecessary specific information since it is not necessary or required.
Finally, t he calculation of VMT from the Project area is relative to permanent employees and not temporary construction workers per the City’s guidelines for preparing VMT assessments.
H-15 The EIR estimates the Project will result in a temporary increase in construction workers as outlined in Response H -14 above. It would also be overly speculative to attempt to calculate whether or what percentage of the City’s unemployed workforce is qualified for or interested in work in the future business park uses of the Project.
However, the City does contain numerous light industrial uses, warehouses, and business parks which hire workers from the “industrial” sector so it is reasonable to assume this project would be able to find relatively local workers to fill its new blue collar positions.
The Project will also result in an increase in local long -term employment by 553 workers (Section 4.14-4, Population and Housing, Impacts and Mitigation Measures, Impact POP-1), however, it is overly speculative to attempt to determine from where those additional employees would come. However, it is reasonable to assume they would come from either the unemployed within the City or in surrounding communities as the anticipated payment for s uch work would likely not entice workers from long distances to have to relocate for business park/manufacturing jobs. It is much more likely that workers would commute to the new blue collar positions from within the City or surrounding areas.
H-16 The City worked with the owner and their project broker who have extensive experience with leading and managing industrial and commercial developments. The employment estimate was based on the following:
Employment: typical occupants will have roughly 10% of their space allocated to office. All of the anticipated uses will have ancillary storage and a reasonable estimate of the space allocation for this would be 60% of the remaining 90% (54% of the total) with 40% (36% of the total) commercial activity. Based on a total area of 333,340 sq. ft. this breaks down to office (10%) with 33,340 sq. ft. at 4 people per thousand square feet = 33.3 X 4 = 133, ancillary storage (54%) with 180,000 sq. ft. at one perso n per thousand square feet = 180 X 1 = 180, and commercial activity (36%) with 120,000 sq. ft. at two people per thousand square feet = 120 X 2 = 240 for a total of 553 employees. After review and internal discussion, th is estimate was considered appropriate given the sizes of the proposed buildings and the anticipated uses.
2.0 Response to Comments
2-80 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE Further, the City considered this estimate appropriate for use and analysis in the DEIR.
Conclusion: this additional information merely clarifies the data and analyses presented in the DEIR and does not change the analyses, conclusions, or determination of the severity of impacts of the Project relative to population, housing, and employment (i.e., no impact or less than significant impact).
H-17 As outlined in DEIR Section 6.2, Growth-Inducing Impacts, “the project would have a beneficial effect on the City’s employment base by developing a site that is largely vacant with 11 new light industrial and manufacturing buildings. It is reasonable to assume that these jobs would be filled by people living in the City, unincorporated County area, and surrounding cities. Furthermore, the project site would be served by the public roadways, and utility infrastructure would be installed beneath the public rights-of-way that abut the project site. Additionally, the project does not propose housing that could induce population growth. As a result, the project would not significantly foster economic or population growth beyond what is planned for the City and County.”
The comment is correct that the Project represents significant employment growth as discussed in Response H-20 above. The comment is also correct when it states the EIR calculates the Project would add 289 net new jobs, but it is misleading to only rely on a percentage increase relative to SCAG Connect SoCal growth forecasts to characterize this as significant in an adverse way. The City of Menifee has historically been a “housing rich” community so adding new jobs/employment is considered a benefit to the community. The Project does represent 3.5% of the projected employment growth in the City from 2019 to 2035. However, this amount of employment growth is within the SCAG projections in the Connect SoCal regional plan. CEQA does not require mitigation or o verriding considerations for growth - inducing impacts but just acknowledgement that they will occur as pointed out in the EIR so the decision-makers are aware of the implications of project approval.
Regarding cumulative growth in employment, the overall impacts and extent of growth in the City in terms of housing, population, and employment were addressed in the 2013 General Plan EIR (SCH# 2012071033). GP EIR Section 5.13, Population and Housing, concluded that “General Plan buildout would result in a population of up to 158,942 people, 83,200 jobs, and 63,754 housing units. Therefore, the project would be considered to be growth -inducing, although the project would merely accommodate growth based on m arket conditions” (GP EIR p. 10 -1). The Project’s 553 additional employees represent 0.7 percent of this anticipated employment growth in the City over the General Plan horizon.
Conclusion: There has been no empirical data presented that would indicate the EIR must be revised and recirculated for additional public comment. The comment does not raise a new significant impact or indicate a substantial increase in a significant impact. This add itional information merely clarifies the data and analyses already presented in the DEIR and does not change the analyses, conclusions, or determination of the severity of impacts of the Project relative to anticipated growth (i.e., less than significant with project design and regulatory compliance).
H-18 4.17 Transportation. This comment claims that the project VMT screening assessment is inaccurate because the WRCOG VMT Tool results for TAZ 1053 are
2.0 Response to Comments
Menifee Business Park Project 2-81
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE 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 pro ject, or the project TAZ, that would otherwise be mis - represented by utilizing the data from the WRCOG VMT Tool.
H-19 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). Notwithstanding the above, the proposed project does not include features such as new roadways or land uses not reflected in the socioeconomic data for the project TAZ (see Response to Comment #1) that would “alter the existing built environment in such a way as to increase the rate or length of vehicle trips.” Additionally, the project is consistent with the General Plan land use (EDC-SG).
The legislative intent of Senate Bill 743 was to shift away from automobile delay (as measured by Level of Service) to Vehicle Miles Traveled (VMT) as the primary metric for measuring transportation impacts under CEQA. This change is intended to better align with other Statewide goals of reducing greenhouse gas emissions, promoting a multimodal transportation system, and improving air quality. CEQA Guidelines Section 15064.3, subdivision (a), states, “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project. Guidance from the OPR Technical Advisory further clarifies that:
• “Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light trucks.” (OPR Technical Advisory, page 4)
• “Current targets for the State’s largest MPOs call for a 19 percent reduction in GHG emissions from cars and light trucks from 2005 emissions levels by 2035.” (OPR Technical Advisory, page 8)
CEQA Guidelines allow for Lead Agency discretion in establishing methodologies and thresholds provided there is substantial evidence to demonstrate that the established procedures promote the intended goals of the legislation. Accordingly, the City established a threshold of VMT per service population, in alignment with available
2.0 Response to Comments
2-82 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE guidance from the OPR Technical Advisory and the legislative intent of SB 743 and other Statewide goals that are focused on on-road passenger vehicles.
Notwithstanding the above, the Greenhouse Gas Emissions section of the Draft EIR includes a separate calculation of the total greenhouse gas emissions from the proposed Project using the CalEEMod software, which accounts for all mobile source emissions, including VMT from all vehicle types. Therefore, the total greenhouse gas emissions from the project are fully reported for all vehicle types under the Greenhouse Gas Emissions analysis and the project VMT impacts are adequately reported with respect to the appropriate Transportation thresholds as established by the City of Menifee in accordance with applicable CEQA provisions and State guidance.
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
2.0 Response to Comments
Menifee Business Park Project 2-83
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE
4. Thresholds based on baseline VMT performance by jurisdiction or sub- region [emphasis added].”
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 in Responses H-18 through H -20 above, the VMT analysis was conducted in full conformance with City-established methodologies, no revisions to the EIR or VMT technical report prepared by Ganddini Group are necessary.
H-21 Traffic - Geometric Hazards. The applicant team indicates the project site is contained within the existing city roads surrounding the property. The access points created for the Project and shown on the site plan avoid sharp curves or dangerous intersections. 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.
Therefore, the Project has no significant impacts relative to geometric design features and emergency access, and no changes are needed in the EIR relative to th ese issues.
H-22 Conflicts with Farm Equipment. The locations of existing farms north and south of the site and rural residences west of the site are clearly shown in Exhibit 2, Project Vicinity Map, which shows both existing land uses and dirt access roads on an aerial photograph. The primary dirt road s in the Project vicinity are Howard Way between the Project site and the rural residences to the west and Ciccotti Street between the site and the farm to the north. It is likely farm equipment would utilize these dirt roads to the extent feasible as there would be no conflicts with urban vehicles and trucks.
The farm immediately south of the Project site may have to utilize Zeiders Road for offsite access for its farm equipment, but this site is not part of the Project site and is also eventually planned for urban uses under the EDC-SG designation (as is the farm to the north). Therefore, the Project has no significant impacts relative to potential conflicts with farm equipment and no changes are needed in the EIR relative to this issue.
H-23 Traffic - 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 Projec t buildings wide enough to allow police and fire
2.0 Response to Comments
2-84 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE vehicles unrestricted access. In addition, the City Engineering Department evaluated emergency access in its review of the Project site plans and did not identify any requiring modifications to the site plan in this regard. Therefore, the Project has no significant impacts relative to emergency access and no changes are needed in the EIR relative to this issue.
H-24 Sight Distances. The Project site is located on the west side of Zeiders Road approximately 0.53 mile south of Scott Road and 0.46 mile north of Keller Road. This segment of Zeiders Road is “arrow straight” with no bends or deviations in its horizontal alignment. Google Earth indicates the main Project driveway onto Zeiders Road has an elevation of 1,559 feet above mean sea level (amsl) which the intersection of Scott Road at Zeiders Road has an elevation of 1,527 feet amsl and the intersection of Keller Ro ad at Zeiders Road has an elevation of 1,593 feet amsl.
This means the segment of Zeiders Road from Scott Road to Keller Road has a vertical change of 66 feet over a horizontal distance of 5,227 feet (approx. slope
1.26%) which is considered very flat. Fro m the main Project driveway, Zeiders Road slopes slightly down toward Scott Road at 1.14% and slightly up toward Keller Road at 1.40% (both slopes are considered relatively flat). Since Zeiders Road is both straight and level to the north and south, there would be no adverse sight distance impacts on Project traffic. The City Engineering Department evaluated this condition in its review of the Project site plans and did not identify any conditions requiring modifications to the site plan. Therefore, the Project has no significant impacts relative to site distance and no changes are needed in the EIR relative to this issue.
H-25 5.0 Alternatives. 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 the 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 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,
2.0 Response to Comments
Menifee Business Park Project 2-85
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE 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 threshold (3,000 MTCO2e).
Alternative 1 would not achieve the goals of the Project to the same degree as the proposed Project, and 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.” H-26 6.2 Growth -Inducing Impacts. Section 6.2 of the EIR, Growth -Inducing Effects, indicates the Project’s development would spur economic growth in terms of employment but since it is a non -residential project it would not result in significant growth in housing or population (DEIR page 6-10). CEQA does not require mitigation or overriding consideration of growth-inducing impacts but just acknowledgement that they will occur as pointed out in the EIR.
The comment also conflates growth -inducing impacts with the separate analysis of cumulative impacts. The EIR does analyze potential cumulative impacts of the Project as summarized in Section 6.1 related to CEQA -mandated sections. However, the actual poten tial cumulative impacts of the Project and anticipated growth are evaluated for each environmental issue and examined in Sections 4.1 through 4.20 of the EIR. The cumulative analysis does identify the horizon year of the current City General Plan (2045) an d the traffic section (4.17) indicates its horizon year is 2045 based on the WRCOG regional model. The Hydrology Section (4.10) states the analysis of the Water Supply Assessment (WSA) focuses on regional availability of water over the 20 -year horizon of t he WSA to be consistent with the Urban Water Management Plan for the Eastern Municipal Water District (2020 -2040) based on state law. The Project is consistent with the General Plan land use designation so the growth represented by the Project does not exceed that identified in the General Plan EIR and described in the Project EIR.
H-27 The proposed Project is consistent with the development allowed under the General Plan land use designation for the site (EDC -SG) so it is considered consistent with the Land Use Buildout Scenario outlined in the Genera Plan and evaluated in the 2013 General Plan EIR (SCH# 2012071033). GP EIR Section 5.13, Population and Housing, concluded that “General Plan buildout would result in a population of up to 158,942 people, 83,200 jobs, and 63,754 housing units. Therefore, the project would be considered to be growth-inducing, although the project would merely accommodate growth based on market conditions” (GP EIR p. 10 -1). The Project’s 553 additional employees represent 0.7 percent of this anticipated employment growth in the City over the General Plan horizon.
Conclusion: There has been no empirical data presented that would indicate the EIR must be revised and recirculated to address an accurate buildout scenario of the City’s General Plan. The comment does not raise a new significant impact or indicate a substantial increase in a significant impact. This additional information merely clarifies the data and analyses already presented in the DEIR and does not change the
2.0 Response to Comments
2-86 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE analyses, conclusions, or determination of the severity of impacts of the Project relative to anticipated growth which has been demonstrated as consistent with the General Plan Land Use Buildout Scenario.
H-28 Previous comments regarding potential significant impacts of the Project on population and housing have been addressed the previous Responses H -9 to H-17 above. Impacts related to VMT and a “Low VMT TAZ” are addressed in Responses H-18 to H-20 above.
H-29 Previous comments on potential significant impacts of the Project regarding construction and operational workforce have been addressed the previous Responses H-13 to H-16 above. Impacts related to VMT and a “Low VMT TAZ” are addressed in Responses H-18 to H-20 above.
H-30 Conclusion. The responses above to the various comments by CSEJA indicate that the described information should be added to the DEIR and included in FEIR Section 3, Errata. However, no empirical evidence has been presented that would demonstrate the Project results i n a new of substantially increased environmental impact requiring revision and recirculation of the Project EIR for additional public review.
In addition, the CSEJA is already on the City’s CEQA notification list and would be notified of any future meetings or documents since they have already commented on the Draft EIR. The correspondence will be sent to the address indicated in the comment.
Soil/Water/Air Protection Enterprise (SWAPE) Letter
H-31 The City believes it has accurately and adequately evaluated the various potential environmental impacts of the Project based on available information, assumptions about Project development, onsite conditions, and applicable regulatory compliance.
The City has concluded that the comments in this letter do not trigger a need to revise and recirculate the DEIR for additional public review.
H-32 Hazardous Materials – Phase I ESA and PFAS Chemicals. According to the Phase I and limited Phase II soil testing conducted by SCS Engineers, “one soil sample was reported with a detectable concentration of fecal coliform, and metals were reported in each of the samples analyzed, the reported fecal coliform concentration was below Health Risk Based -Criteria (Table 1), and all metals were reported to be below the Health Risk -Based Criteria and Hazardous Waste Criteria (Table 2). None of the composite samples analyzed were reported with detectable concentrations of OCPs above laboratory reporting limits.” (SCSE 2022) It should be noted the Phase I/II report was prepared in 2022 and at that time PFAS chemicals, including PFOA and PFOS, had not yet been designated as hazardous substances under CERCLA (Superfund) which occurred in 2024. The Phase I/II information indicates it is unlikely biosolids were ac tually deposited on the project site in the past. It was operated by the current owners as a farm since 1951 who indicated no biosolids had been deposited on the Project site during that time. Therefore, there is no need to conduct soil sampling or testing for PFAS chemicals at this time.
H-33 The commenter claims that Appendix E omits quantitative details because the CalEEMod output file does not list the default values that were replaced with site - specific values. The commenter describes the functions of CalEEMod, correctly notes
2.0 Response to Comments
Menifee Business Park Project 2-87
City of Menifee
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE that MIG uses CalEEMod Version 2022.1, and describes differences in the types of output files provided by CalEEMod Version 2022.1 and an older version of the model, CalEEMod Version 2020.4.0. MIG uses CalEEMod Version 2022.1 as it is the most recent version available, and includes modeling improvements and updated data from CalEEMod Version 2020.4.0. Using the most recent version of CalEEMod does not prevent a third party from reviewing the modeling. As the commenter noted, the CalEEMod output includes the User Changes to Default Data section, which notes where modeling changes were made, along with the justification provided by the modeler. MIG elaborates on the changes from model defaults in Section 4.2.1.
CalEEMod, and its user guide explaining its default values, are publicly available, and the numeric values that were entered into CalEEMod are available through the output file. Providing access to the models .json files is not required.
H-34 The commenter notes that the default 20 -mile haul trip distance was used in CalEEMod, while the El Sobrante Landfill that the project would use is approximately
25.4 miles from the proposed project. The modeling and EIR have been revised to use a 25.4 haul trip.
H-35 The commenter notes that there were changes to the default operational vehicle fleet mix percentages in CalEEMod and incorrectly claims the changes were unsupported, that they were not mentioned outside of the User Changes to Default Data table, and that they may underestimate operational emissions. The changes in vehicle fleet mix were described in Section 4.2.1.2 of Appendix E -1. Updating the default fleet mix values in CalEEMod was appropriate to project, and necessary to prevent the underestimation of emissions. The CalEEMod User Guide states that site -specific data supported by substantial evidence should be used instead of default data where available (see page 1 of the CalEEMod User Guide). The fleet mix changes were made based on site-specific information from the traffic report prepared for the project, and resulted in a higher percentage of trucks in the mod eled fleet mix (12.2%) than would have been modeled using default values (8.0%). While providing access to the .json files is not required (see Response H -33 for further discussion), in response to the commenter’s request for a breakdown of the fleet mix i nputs, Appendix E-1 was revised to include the modeled fleet mix percentages.
H-36 The commenter accurately summarizes the HRA and claims that the Fraction of Time at Home (FAH) rate for individuals from the third trimester to age 16 should be increased to 1 consistent with SCAQMD guidance. This guidance is based on a default assumption that children go to school in close proximity to their home, while the MEIR is not located in close proximity to schools. For example, the nearest high school is located over two miles north of the MEIR. Nonetheless, the HRA has been revised with a Fraction of Time at Home (FAH) rate of 1 for individuals from the third trimester to age 16, providing a conservative estimation of risks. This revision does not change the conclusions of the analysis.
H-37 The commenter accurately summarizes the contents of the Draft EIR’s GHG emissions impact analysis, asserts that CEQA requires the City to incorporate all feasible mitigation measures, and recommends that additional feasible measures capable of reducing GHG emissions are incorporated into the EIR. Please refer to Response H -38 for responses to the specific mitigation recommended by the commenter.
2.0 Response to Comments
2-88 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter H – BC&H LLC (GSEJA) + SWAPE H-38 The commenter claims that the project would result in potentially significant air quality, health risk, and GHG impacts, and recommends mitigation measures to further reduce impacts. While GHG impacts would be significant and unavoidable, health risk impacts for the project would be less than significant and air quality impacts would be less than significant with mitigation. Health risk and air quality impacts do not require further mitigation.
The commenter references California Department of Justice recommendations to install solar photovoltaic systems that meet the building’s energy needs, design building roofs to maximize solar panel coverage, oversizing electrical rooms, requiring non-diesel emergency generators, meeting CalGreen Tier 2 green building standards, meeting LEED certification, constructing zero emission truck chargers, require training to eliminate unnecessary queuing and idling, keep vehicle records, enroll in the EPA SmartWay P rogram. The project includes mitigation similar to the suggested measures. With regards to the measures related to solar, electrical capacity, and CalGreen Tier 2, the project includes mitigation to increase solar photovoltaic system requirements above what is required in the CalGreen Code (GHG-4), to have electric infrastructure to allow for all-electric operations (GHG-3), and to require CalGreen Tier 2 EV parking. Building efficiency would be achieved through following 2022 CalGreen Code energy efficienc y standards, and appliance and lighting efficiency standards , and GHG emissions related to building energy would be reduced through GHG-3 and GHG-4. Idling would already be limited as the City will place a five -minute idling limit as a Condition of Approval. In regards to zero emission truck chargers, 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. The use of non -diesel generators is not necessary for the Project because this measure would not reduce or avoid an identified significant impact. Training staff on diesel vehicle recordkeeping would not reduce emissions and is therefore not an effective mitigation measure that should be added to the EIR.
The commenter also references SCAQMD recommendations. Please refer to Response C-7 for an evaluation of the recommendations. Additionally, the commenter suggests carbon offsets. Offsets are not considered feasible mitigation for this project as discussed further in Response I-13.
H-39 The comment consists of a disclaimer regarding the information available for the project. The disclaimer is noted. As demonstrated in Responses H -1 through H -38 above, the comments and their responses merely provide additional information that clarifies or expands on the information presented in the Draft EIR but does not change the analysis, conclusions, or mitigation to the degree that would require revision and recirculation of the Draft EIR for additional public comment. GSEJA is on the City’s contact l ist for CEQA documents including any related to the proposed Pemcor Project.
2.0 Response to Comments
Menifee Business Park Project 2-89
City of Menifee
COMMENT LETTER I – ADVOCATES FOR THE ENVIRONMENT
2.0 Response to Comments
2-90 Final Environmental Impact Report
October 30, 2025
September 29, 2025
Russell Brown
Senior Planner
City of Menifee
29844 H aun Road
Menifee, CA 92584
Advocates for the Environment
A non-profit public-inleresl law firm
and environmental advocacy organization
Via U.S. Mail and email to [email protected]
LETTER!
Re: Comments on the Drafi: Environmental Impact Report for the Menifee Pemcor Business Park Project, SCH No. 2024071016
Dear Mr. Brown:
Advocates for the Environment submits the comments in this letter regarding the proposed Menifee Pemcor Business Park Project (Project), located at 33521 Zeiders Road, between Howard Way and Zeiders Road in the City of Menifee (City). This Project proposes the development of337,770 square feet of building area across 11 buildings, on the 20.03-acre Project site.
We are a non-profit public-interest law firm that uses environmental law co fight co improve the environment in California. We have reviewed the Environmental Impact Report (EIR) prepared in August 2025, and submit comments regarding the sufficiency of the EIR' s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA).
The City Should Require the Project to be Net-Zero
Given the current regulatory context and technological advancements, a net-z ero significance threshold is feasible and extensively supportable. GHG emissions from buildin gs, including indirect emissions from offsite generation of electricity, direct emissions produced onsite, and from construction with cement and steel, amounted to 21 % of global GHG emissions in 2019. (IPCC Sixth Assessment Report , Climate Change 2022, WGIII, Mitigation of Climate Change, p. 9-4.) This is a considerable portion of global GHG emissions.
It is much more affordable to construct new building projects to be net-zero than to obtain the same level ofGHG reductions by expensively retrofitting older buildings to comply with climate change regulations. Climat e damages will keep increasing until we reach net zero GHG emissions, and there is a California state policy requirin g the state to be net-zero by 2045.
It therefore is economically unsound to construct new buildings that are not net-zero.
Environmental groups have achieved incredibl e outcomes by litigation under CEQA.
Two of the largest mixed-use development projects in the history of California, Newhall Ranch 10211 Sunland Blvd., Shadow Hills, CA 91040 (81 8) 650-0030 Xl 01 [email protected] I-1
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Menifee Business Park Project 2-91
City of Menifee
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
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(now FivePoint Valencia), and Centennial (part ofTejon Ranch) decided to move forward as net-zero communities after losing CEQA lawsuits to environmental groups. The ability for these large projects to become net-zero indicates that it is achievable, even for large-scale developments. The Applicant for this Project should do the same.
We urge the City to adopt net-zero as the GHG significance threshold for this Project.
This threshold is well-supported by plans for the reduction of GHG emissions in California, and particularly the CARB Climate Change Scoping Plans. The CARB 2017 Scoping Plan states that "achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development .ff (CARB 2017 Scoping Plan, p. 101.) Additionally, the CARB 2022 Scoping Plan reaffirms the necessity of a net zero target by expressing: "it is clear that California must transition away from fossil fuels to :zero-emission technologies with all possible speed ... in order to meet our GHG and air quality targets." (CARB 2022 Scoping Plan, p. 184.) CARB further encourages a net-zero threshold in its strategies for local actions in Appendix D to the 2022 Scoping Plan. (CARB 2022 Scoping Plan, Appendix D p. 24-26.) Moving this Project forward as a net-zero project would not only be the right thing for the City to do, but also would help protect the City and the Applicant from CEQA GHG litigation.
CEQA GHG Significance Analysis
The EIR derived its GHG significance thresholds from the CEQA Guidelines : whether the Project would: 1) "[g]enerate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment( 2) "[c]onHict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases( and 3) "cause substantial adverse cumulati ve impacts with respect to greenhouse gases.ff (EIR, p. 4.8-
16.) The City used CalEEMod to quantify the Project's annual emissions, which were reported to be 10,419.5 metric tons of carbon dioxide equivalent (MTC02e) per year. (EIR, p. 14.8-18.) As to the first two thresholds, the EIR found that the GHG impact would be less-than significant. (EIR, p. 4.8-20 - 22.) Nonetheless, the EIR concluded that the Project's GHG emissions would be cumulatively significant and unavoidable after mitigation. (EIR, p. 4.8-23.) Inconsistent GHG Significance Findings
The EIR presents contradictory conclusions regarding its GHG impacts. In the section summarizing potentially significant impacts and mitigation, the Project identifies GHG-1 as "significant and unavoidable" even with mitigation. (EIR, p. 2-10). Yet, the detailed GHG analysis in the EIR concludes that GHG-1 would be reduced to '1ess than significant" with mitigation. (EIR, p. 4.8-20). This inconsistency is confusing and misleading for both decisionmakers and the public, and it prevents meaningful review of the Project's actual GHG 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 Xl 01 [email protected] I-2
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2.0 Response to Comments
2-92 Final Environmental Impact Report
October 30, 2025
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
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impacts. The lack of clarity also undermines the later cumulative impact finding, which adopts an overall Significant and Unavoidable finding without resolving these contradictory conclusions. (EIR, p. 4.8-23).
Insufficient Evidence the TOM Program Reduces GHG Impacts Below Significance The EIR acknowledges that a vast majority of the Project's emissions, approximately 82%, come from mobile sources. (EIR. p. 4.8-18.) For this reason, reducing VMT would substantially reduce the Project's overall GHG impact. To address this, the EIR proposes to implement a TDM program described under GHG Mitigation Measure 1 (MM-1) . According to this measure, the Project must implement a TDM program to reduce the Project's VMT for non-truck vehicles by 5%. (EIR. p. 4.8-19.) The measure calls for a reduction program consistent with the California Air Pollution Control Officers Association (CAPCOA) Handbook, relying on CAPCOA strategies, including a voluntary trip reduction program , commute trip reduction marketing, ridesharing, subsidized transit, end-of-trip bicycle facilities, employer-sponsored vanpooling, and electric vehicle charging infrastructure. (EIR, p. 4.8-19.) Alternatively, the Project may participate in a regional VMT mitigation exchange program, if one exists, or adopt other measures such as car-sharing, transit access improvements, or flexible work schedules. (EIR, p. 4.8-19.) While this plan claims that compliance with the TDM policy will lead to a 5% VMT reduction, it fails to provide sufficient evidence that this specified reduction, even if achieved, would reduce the GHG impact to a less-than-significant level.
First, the EIR provides no analysis supporting the 5% CAPCOA reduction measure and no demonstration that this reduction would amount to sufficient mitigation. CAPCOA provides VMT measures, with mitigation potential that varies because the proposed mitigation is project-specific. In fact, the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, Designed for Local Governments, Communities, and Project Developers (Handbook) itself provides only ranges of potential GHG reductions (CAPCOA Measure T-5: up to 4% GHG Mitigation potential; CAPCOA Measure T-14: up to 11.9% GHG Mitigation potential). (Handbook , p. 83, 116.) The EIR does not specify which measures achieve what portion of the proposed 5% reduction.
Moreover, the Project willingly selects the voluntary T-5 program instead of the more robust and effective mandatory measure T-6, which has a substantially higher mitigation potential of up to 26% of employee commute emissions, The EIR provides no explanation for this choice, leaving unclear why a less stringent mitigation approach was deemed adequate, Second, even if the TDM program achieves its full 5% reduction in passenger-vehicle VMT, that reduction addresses only a fraction of the Project's GHG emissions and is insufficient to reduce the GHG impact to a less-than-significant level. While 82% of the Project's emissions are from mobile sources, approximately 61.5% of the mobile impact is from 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] I-4
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Menifee Business Park Project 2-93
City of Menifee
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
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trucks (BIR, p. 4.8-18), which the TOM plan explicitly excludes (BIR, p. 4.8-19). Passenger vehicles account for 3,289 MTCO2e of mobile emissions; a 5% reduction would yield only a 164.45 MTCO2e reduction. 1 Total project emissions would decrease to 10,255.05 MTCO2e, remaining 7,255 MTCO2e over the chosen 3,000 MTCO2e threshold. 2 The TOM program cannot mitigate the majority of mobile-source emissions, let alone total emissions, leaving the Project well above the significance threshold, even after mitigation is imposed.
Consistency with Identified Applicable Plans
The EIR included a discussion of the CARB 2022 Scoping Plan, Sustainable Freight Plan, ACT Program, regional RTP /SCS, and Menifee General Plan to support its conclusion that the Project would not conflict with an applicable plan, policy, or regulation for GHG emissions reductions. However, the BIR conflicts with the CARB 2022 Scoping Plan.
Furthermore, the EIR failed to acknowledge and analyze all applicable plans for the reduction of GHGs. As a result, this significance analysis violates CEQA by being deficient and misleading in several areas.
The 2022 Scoping Plan sets a goal for 50% of all industrial energy demand to be electrified by 2045 (2022 CARB Scoping Plan, p. 77).3 The EIR makes no showing that the Project is consistent with this goal. The 2022 CARB Scoping Plan also places particular emphasis on decarbonizing industrial facilities by "displacing fossil fuel use with a mix of electrification, solar thermal heat, biomethane, low- or zero-carbon hydrogen, and other low carbon fuels to provide energy fur heat and reduce combustion emissions" (2022 CARB Scoping Plan, p. 208). Based on the analysis provided in the EIR, the Project does not appear to meet this objective. Its continued reliance on diesel fuel in operations creates a conflict with the Scoping Plan. (See EIR, p. 4.8-21 [noting diesel use of diesel trucks.]) Additionally, the EIR claims that the Project goes "beyond the policies in the General PlanH by incorporating voluntary Tier 2 EV measures from the 2022 CalGreen Code through Recommended Mitigation Measure GHG-2. (EIR, p. 4.8-22.) However, no such mitigation measure appears in the BIR' s mitigation list. This inconsistency is misleading to decisionmakers and the public and prevents meaningful review of the Project's GHG impacts. Without the actual text ofGHG-2, the EIR provides no evidence that such measures will be implemented or enforceable, undermining its finding of consistency with the General Plan's GHG policies. 1 5% reduction goal x 3,289 MTCO2e (passenger vehicles) = 164.45 MTCO2e 2 10,419.5 - 164.45 = 10,255.05 MTCO2e total emissions; 10,255.05 MTCO2e total emissions - 3,000 MTCO2e threshold = 7,255.05 MTCO2e over threshold
3 2022 Scoping Plan located at: https://ww2.arb.ca.gov/ sites/ default/6les/2023-04/2022-sp.pdf 1-8
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2.0 Response to Comments
2-94 Final Environmental Impact Report
October 30, 2025
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
The EIR Should Have Analyzed All Applicable Plans
Pages
September 29, 2025
The City chose, as its second GHG threshold , whether the Project would "conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing the emissions of greenhouse gases.n (EIR., p. 4.8-20.) This language requires that the EIR analyze the Project's consistency with all other applicable plans, not jwt the plans that the City prefers to analyze.
An agency must consider a project's GHG impact over time to reasonably evaluate the full extent of environmental impact as CEQA requires. The reasonable lifespan of this Project is approximately 30 years, as indicated by the amortization of construction emissions. (EIR., p.
4.8-17). Therefore, the Project must show consistency with long-term State GHG goals, including Executive Orde r B-55-18 (EO B- 55-18), and the 2017 CARB Scoping Plan.
EO B-55-18 requires the State of California to achieve carbon neutrality-net zero GHG emissions-by 2045. The Project is inconsistent with EO B-55-18 because it does not prohibit the use of gasoline, diesel, and natural gas. In fact, the Project would require approxi~tely 62,337 gallons of gasoline and 99,685 gallons of diesel, generating substantial GHG emissions from both construction equipment and heavy-duty truck traffic. (EIR., p. 4.6-20.) Burning non renewable fuels, such as diesel, results in substantial GHG emissions, preventing the Project from ever achieving carbon neutrality, unless it enters into agreements with the applicant and/ or future tenant to ensure that fossil fuel use is on track to be eliminated by 2045. Thus, the Project would conflict with EO B-55-18. As stated by the City's chosen threshold , conflict with any applicable policy would be a significant GHG impact.
The 2017 Scoping Plan was developed to help California comply with SB 32, which =dates a 40% reduction in GHG emissions below 1990 levels by 2030 (Health & Safety Code § 38566). The EIR does not explain how the Project aligns with these objectives or the 2050 goal of reducing emissions by 80% below 1990 levels. Moreover , the 2017 Scoping Plan sets statewide per capita GHG emissions targets of 6 MTCO2e by 2030 and 2 MTCO2e by 2050 (CARB Scoping Plan, p. 99). With the Project's per-service population GHG emissions of19.5 MTCO2e/capita , the Project significantly overshoots the 2050 target.4 Given that this reduction mwt be achieved within the Project's operational lifespan, it is evident that the Project will remain inconsistent with the 2017 Scoping Plan's long-term goals.
Consequently, because the Project is inconsistent with applicable plans for the reduction ofGHGs, it is significant under the second threshold .
The Project's GHG Impacts Must be Fully Mitigated
T he EIR's cumulative GHG analysis under the third GHG threshold is conclusory and unsupported by substantial evidence. The EIR simply asserts that, because climate change is the 4 10,419.5 MTC02e + 533 employees= 19.54 MTC02e/service population 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] I-11
I-12
2.0 Response to Comments
Menifee Business Park Project 2-95
City of Menifee
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
Page6
September 29, 2025
result of global emissions, the Project's contribution is inherently cumulative, and then adopts a significant and unavoidable finding. (BIR, p. 4.8-23.) This analysis fails to connect the dots between the Project's acknowledged significance thresholds and its determination that impacts remain significant and unavoidable. CEQA requires more than a bare conclusion.
CEQA requires that the Project include fair-share mitigation for all significant cumulative impacts. (Napa Citizens for Honest Gov't v. Napa County Board ef Supervisors (2001) 91 Cal.App.4th 342, 364.) Here, this means mitigation of the full extent of the Project's GHG impacts, not just mitigation to the level of significance.
The amount of G HG emissions that comprises the Project's fair shareis clear. The reasonable lifespan this Project is approximately 30 years, as indicated by the amortization of construction emissions. (BIR, p. 4.8-17.) Therefore, the Project would likely contribute 312,585 MTCO2e during its entire lifespan.5 This would be a good starting point from which to subtract the effect of additional non-offset mitigation measures, before implementing offset purchases. Mitigation measures that consider the long-term viability of the Project will have the most impact on reducing the Project's lifetime GHG impact.
The EIR makes no claim that no other mitigation measures are feasible beyond the singular identified mitigation measures. The EIR doesn't reject any other mitigation measures are unfeasible either. There are many other mitigation measures that could have been adopted.
For example, the City could require the Applicant to enter into an agreement to install electric truck charging stations proportional to the number of dock doors, require a zero-emission heavy-dury truck fleet to the extent feasible and as soon as practicable, and to produce or buy clean power for the electricity usage for the heavy-duty electric vehicle charging stations. It would also help reduce emissions from idling to provide ample space for on-site parking and queuing.
In addition to implementing zero-emission vehicle fleets to the extent feasible, the Project could install solar panels to offset 100% of the buildings' operational energy usage. More mitigation options for reducing the GHG impact of project operations include requiring on-site equipment, such as forklifts and yard trucks, to be electric, and installing corresponding electrical charging stations as necessary, as well as maintaining and improving vegetation on the project site.
Additionally, there are further on-site mitigation measures specifically for the building related emissions that are feasible, including installing solar water heaters and automatic light switches, among many other mitigation strategies that can be incorporated in the building design. Such features could be adopted individually or as part of a comprehensive goal of 510,419.5 MTC02e per year X 30 years= 312,585 MTC02e
10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 Xl 01 [email protected] I-12
I-13
2.0 Response to Comments
2-96 Final Environmental Impact Report
October 30, 2025
7 PAGES
Comment Letter to City of Menifee
Menifee Pemcor Business Park Project
September 29, 2025
sustainable building certification, sucb as Leadership and Energy and Environmental Design (LEED), which extends beyond CALGreen requirements.
Even after implementing operational emissions reductions to the maximum-feasible extent, the City could also require the Applicant to purchase offsets for the Project's remaining GHG emissions. Overall, there are more options available to mitigate emissions to the full extent of project emissions, including available measures which are outlined in the California Attorney General's CEQA best practices recommendations for warehouse projects,6 and the City failed to acknowledge or implement many mitigation measures whicb are feasible and could help reduce the Project's GHG impact to the fair share extent.
Conclusion
The GHG analysis violates CEQA because the Project should have found a significant GHG impact under the first threshold. Further, the Project would not be consistent with the applicable plans, policies, and regulations for reducing GHGs.
Please put Advocates for the Environment on the list of interested parties to receive updates aboutthe progress of this potential project approval. We make this request under Public Resources Code, section 21092.2.
Sincerely,
~'~~~
Executive Director, Advocates for the Environment
6 See State of California Department of Justice, Rob Banta Attorney General, 'Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act," Updated September 2022, pp. 7 - 10, available at: https://oag.ca.gov/system/liles/media/warehouse-best-practices.pdf. Last accessed July 23, 2025.
10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650--0030 Xl 01 [email protected] 1-13
1-14
2.0 Response to Comments
Menifee Business Park Project 2-97
City of Menifee
ID Response to Comment Letter I – Advocates for the Environment I-1 The commenter provides introductory remarks that accurately summarize the project in a general manner and states it is submitting comments on the sufficiency of the DEIR’s GHG emissions analysis. Comment noted. Refer to responses to comments I-2 to I-14 for detailed responses to specific comments on the DEIR’s GHG emissions analysis.
I-2 The commenter suggests that the City adopt a net-zero GHG threshold for the project.
First, as a point of clarification, under CEQA a lead agency is entitled to discretion with respect to the methodology used and the thresholds of significance applied to the evaluation and determination of t he significance of a project’s GHG emission impacts. The commenter is directed to DEIR Section 4.3.3 (pp. 4.8 -16 to 4.8-17) for the DEIR’s explicit discussion and selection of an appropriate GHG emissions threshold for the proposed project . Comment I -2 doe s not provide any specific remarks on the discussion and justification provided in the DEIR on the City’s applied GHG emissions thresholds. As explained in this section, the City used of the SCAQMD’s 3,000 metric tons carbon dioxide equivalents (MTCO 2e) interim Tier 3 GHG threshold, for which the commenter presents no evidence that the DEIR’s threshold is inappropriate or would result in a significant impact that was not analyzed in the DEIR.
Second, the DEIR includes information commensurate with that provided by the commenter. The DEIR provides information on global CO 2 concentrations (p. 4.8-2), statewide GHG emissions levels from different sources (pp. 4.8-5 and 4.8-6), and the potential effects of climate change on various California resources (p. 4.8 -4). The DEIR also includes detailed information on the regulations that govern GHG emissions, including AB 1279 (pp. 4.8 -9 and 4.8 -21), which established the State’s policy to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissions thereafter, and to ensure that by 2045, statewide anthropogenic GHG emissions are reduced to at least 85% below the 1990 levels, and the 2022 Sc oping Plan (pp. 4.8 -9 to 4.8 -10). The commenter, therefore, does not provide any new information that the City has not considered during the preparation of the DEIR.
Third, the commenter’s general references to CEQA lawsuits do not have any bearing to the project at hand because the commenter has not specifically identified similarities between the referenced cases and the proposed project. While CEQA case law establishes general precedence, such general precedence is to be applied to the specific setting, information, and circumstances under which a particular project is approved.
Finally, the commenter is directed to the DEIR’s discussion of the project’s consistency with the 2022 Scoping Plan (pp. 4.8-21 and 4.8-22), which is fully entitled the 2022 Scoping Plan for Achieving Carbon Neutrality. This analysis identifies that achieving statewide carbon neutrality is a complicated endeavor, requiring reductions from various sources, including energy generation and mobile sources. It also recognizes that carbon neutrality will require technological advances, including deploying carbon capture and other GHG -reducing technologies, and describes the Project’s with the Scoping Plan’s strategies to address key emission sectors and align local actions with State climate goals (transportation electrification, VMT reductions, and building decarbonization). The DEIR concludes that the project would not conflict
2.0 Response to Comments
2-98 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter I – Advocates for the Environment with the Scoping Plan, and that Mitigation Measures GHG -1, GHG-2, and GHG -3 would support the overarching goals of the 2022 Scoping Plan. The commenter does not provide any specific evidence against this conclusion or otherwise indicating the project would not be consistent with the 2022 Scoping Plan.
For the reasons described above, the commenter has not provided any specific evidence for why a net zero threshold is appropriate for the proposed project or why the DEIR’s thresholds are not supported by substantial evidence.
I-3 The commenter correctly identifies the GHG significance thresholds used for the EIR, the project’s annual GHG emissions, and the significance conclusions that were reported on pages 4.8 -20 to 4.8 -22 of the EIR. As discussed more in Comment I -4 below, the conclusion listed on page 4.8 -20 of the EIR was incorrect, and has been revised (see FEIR Section 34, Errata).
I-4 The commenter correctly identifies an inconsistency in the reporting of the GHG significance conclusions. While the correct significance determination of significant and unavoidable was reported in the executive summary of the EIR (page 2 -10) and in the Energy and Greenhouse Gas Report, Appendix E-2 (pages S-II and 6-10), the level of significance after mitigation for Impact GHG-1 on page 4.8-20 was incorrectly listed as less than significant. The EIR has been revised with the correct significance determination (see FEIR Section 34, Errata).
I-5 The comment accurately describes Mitigation Measure GHG -1 as described in the EIR, claims that the EIR does not provide evidence that the measure could achieve a 5% reduction in VMT or that the measure could reduce GHG to a less than significant level. The evidence for the reduction value is based on the Pemcor Commercial Industrial Business Project Transportation Demand Management Assessment (TDM Assessment) prepared by Ganddini for the project. The TDM Assessment is described in Appendix E-2, and the EIR has been revised to include a brief description and reference to the TDM Assessment. It is noted that the EIR has been revised to correct the listed 5% reduction from GHG -1 to a 6.2% reduction, consistent with Appendix E-2 and the TDM Assessment (see FEIR Section 34, Errata).
The measure would not reduce GHG to a less than significant level in regards to Impact GHG -1. As discussed in Responses I -4 and I -5, Impact GHG -1 would be significant and unavoidable. With mitigation, the project would still emit approximately 9,790 metric tons CO 2 each year. Please refer to Table 6 -4 of Appendix E -2 for mitigated GHG emissions.
I-6 The commenter claims that the estimated GHG reduction from VMT measures is not supported with evidence, and notes that CAPCOA’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity includes ranges for its measures’ mitigation. The GHG reduction potential was analyzed in the 2025 TDM Assessment prepared by Ganddini.
This report accounted for the range of mitigation potential mentioned by the commenter by conducting a project -specific as sessment of each of CAPCOA’s measures. For example, CAPCOA’s Measure T -14 could achieve up to an 11.9% reduction, but Ganddini estimated only a 2.3% reduction for the proposed project due to project conditions such as the number of cars accessing the site per day and the number of chargers installed at the site. Approximately 4.0% GHG reduction would
2.0 Response to Comments
Menifee Business Park Project 2-99
City of Menifee
ID Response to Comment Letter I – Advocates for the Environment occur from implementing CAPCPA’s Measure T -5, Implement Commute Trip Reduction Program (Voluntary).
I-7 The commenter claims that implementing CAPCOA Measure T -5: Implement Commute Trip Reduction Program (Voluntary) does not provide adequate mitigation and that CAPCOA Measure T -6: Implement Commute Trip Reduction Program (Mandatory Implementation and Monitor ing) should be implemented instead. The selected measure, CAPCOA Measure T-5, requires the employer to share information with employers about travel options, implement a ridesharing program, provide discounted transit passes, provide bicycle parking and other end-of-trip facilities, and sponsor a vanpool service. CAPCOA Measure T-6 would restrict employees’ choices on their commute and introduce a monitoring program, but would not add additional services, infrastructure, or incentive programs to reduce VMT. The TDM Assessment concluded that CAPCOA Measure T-6 was not a realistic or viable mitigation option, as it would require employers to place travel restrictions on employees and would require ongoing tracking and oversight.
I-8 The commenter correctly notes that the TDM mitigation measures would not reduce the project’s GHG emissions to less than significant levels. As discussed above in Responses I-3 and I -4, Impact GHG -1 would be significant and unavoidable. While the correct significance determination of significant and unavoidable was reported in the executive summary of the EIR and in the Energy and Greenhouse Gas Report, the level of significance after mitigation for Impact GHG -1 on page 4.8 -20 was incorrectly listed as less than significant. The EIR has been revised with the correct significance determination (see FEIR Section 34, Errata).
I-9 The commenter asserts the Project would conflict with the 2022 Scoping Plan because the plan establishes a goal for 50% of all industrial energy demand to be electrified by 2045 and that the project would involve the continued use of diesel in trucks; however, the commenter fails to provide any specific evidence or information for why the Project, as proposed, would result in an actual conflict with this Scoping Plan action. For example, while the commenter correctly identifies that the Scoping Plan targets 50% of industrial manufacturing energy demand electrified by 2045, they fail to disclose that the plan also assumes 0% of industrial energy demand will be electrified by 2030, the timeframe in which the Project would be constructed.
Furthermore, the project’s mitigation would align with the Scoping Plan. As described in Appendix E -2 (page 6 -7), the project includes mitigation for all -electric operation that requires all building energy systems, equipment, and appliances be powered by electricity unless another form of energy is required, and a suitable all -electric alternative is technologically or economically infeasible for the tenant or the equipment is not commercially available and mitigation to provide PV solar (see Mitigation Measure GHG-3 and GHG-4 respectively in FEIR Section 3, Errata).
Thus, the Project would include strategies to electrify manufacturing processes well ahead of the timeline considered by the 2022 Scoping Pan. For these reasons, the Project would not conflict with the specific Scoping Plan action identified by the commenter.
I-10 The commenter correctly notes that GHG-2, the mitigation measure incorporating Tier 2 EV measures from the 2022 CalGreen Code, was not included in the list of mitigation measures in the DEIR. However, GHG -2 was included in Appendix E -2
2.0 Response to Comments
2-100 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter I – Advocates for the Environment (see pages S-III to S-IV and pages 6-7 to 6-7) and the EIR has been revised to include GHG-2 (see FEIR Section 3, Errata).
I-11 The commenter claims that the report did not analyze and show consistency with Executive Order B-55-18 and the 2017 Scoping Plan. The commenter claims the EIR is inconsistent with Executive Order B -55-18 since it does not prohibit the use of gasoline, diesel, and natural gas. and that the report not analyze the GHG goals of a 40% reduction below 1990 levels by 2030 and an 80% reduction below 1990 levels by 2050, a statewide per capita GHG emissions of 6 MTCO2e by 2030 and 2 MTCO2e by 2050 that were in the 2017 Scoping Plan.
The commenter is partially correct. While the DEIR describes the 2017 Scoping Plan (p. 4.8-9) it does not include an explicit discussion of the Project’s consistency with this plan. This is because the 2022 Scoping Plan represents the most up to date plan for achieving compliance with the State’s GHG reduction target for 2030. As stated in the DEIR (p. 4.8-11), the 2022 Scoping Plan “presents a scenario for California to meet the State goal of reducing GHG emissions 40% below 1990 levels by 2030 and to achieve carbon neutrality by 2045. Specifically, the 2022 Scoping Plan . . . identifies a path to keep California on track to meet its SB 32 GHG reduction target of at least 40 percent below 1990 emissions by 2030.” Furthermore, the 2022 Scoping Plan itself states (p. 4), “Four scenarios were extensively modeled to develop this Scoping Plan, with the objective of informing the most viable path to remain on track to achieve our 2030 GHG reduction target, a reduction in anthropogenic emissions by 85% below 1990 levels, and carbon neutrality by 2045. All four have their merits and are informed by stakeholder input. The scenario ultimately chosen as the basis of this Scoping Plan is the alternative that most closely aligns with existing statute and Executive Orders.
It was selected because it best achieves the balance of cost -effectiveness, health benefits, and technological feasibility.” The 2022 Scoping Plan also states (p. 24), “The 2022 Scoping Plan for Achieving Carbon Neutrality (Scoping Plan) is the most comprehensive and far -reaching Scoping Plan developed to date. It identifies a technologically feasible and cost-effective path to achieve carbon neutrality by 2045 while also assessing the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 and laid out in the 2017 S coping Plan.” Importantly, the 2022 Scoping Plan also identifies and plans for an accelerated 2030 GHG reduction target (48% below 1990 emissions by 2030) that is above and beyond the 2017 Scoping Plan requirements.
Therefore, the DEIR’s evaluation of cons istency with the 2022 Scoping Plan also evaluates consistency with previous versions of the Scoping Plan.
Similarly, the analysis describes Executive Order B -55-18 (page 4.8 -15), which requires the State to achieve carbon neutrality by 2045. The Scoping Plan works to achieve the targets set in Executive Order B -55-18, and so the EIR’s analysis of the 2022 Scoping Plan evaluated consistency with the State’s carbon neutrality goals.
Executive Order B-55-18 does not prohibit the use of gasoline, diesel, or natural gas, and the use of these fuels at the start of project operation would not conflict with the State’s carbon neutrality goal for 2045. Additionally, t he specific per capita GHG thresholds that were contained in the 2017 Scoping Plan and referenced by the commenter are not relevant to the Project, because: 1) The 2022 Scoping Plan implements an accelerated 2030 target to support achievement of the State’ s longer term goals (i.e., the per capita targets identified in the 2017 Scoping Plan would no
2.0 Response to Comments
Menifee Business Park Project 2-101
City of Menifee
ID Response to Comment Letter I – Advocates for the Environment longer keep the State on track to achieve long-term GHG reduction goals); and 2) The 2017 Scoping Plan (p. 99) acknowledged that the recommended per capita thresholds were “appropriate for the plan level (city, county, subregional, or regional level, as appropriate), but not for specific individual projects because they include all emissions sectors in the State.” Thus, the per capita metrics would not apply to a specific industrial development proposal such as the Project.
I-12 The commenter claims that the project is required to fully mitigate its GHG emissions.
The commenter’s statement that CEQA requires a project to include “fair -share mitigation for all significant cumulative impacts” is generally correct; however, the commenter’s assertion that, in the case of the proposed project, fair -share mitigation “means mitigation of the full extent of the Project’s GHG impacts, not just mitigation to the level of significance” is not correct. CEQA Guidelines Section 15130 (a) (3) establishes that an EIR may determine a project’s contribution to a significant cumulative impact may be rendered less than cumulative considerable if project implements or funds its fair share of mitigation measures designed to alleviate the cumulative impac t. In general, CEQA only requires an EIR to describe feasible mitigation measures which could minimize the significant environmental effects identified in the EIR, not necessarily eliminate them (CEQA Guidelines § 15126.4(a)(1)). With regards to GHG emissi ons mitigation specifically, CEQA again requires a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, and not necessarily fully eliminating or avoiding the emissions entirely (CEQA Guidelines Section 15126.4(c)).
The commenter also mischaracterizes the project’s GHG emissions levels, estimating that the project would contribute 312,585 metric tons of carbon dioxide equivalents (MTCO2e) over is lifespan. This estimate is not correct because it assumes the project’s annual unmitigated GHG emissions identified in the Draft EIR remain static over a period of 30 years. Additionally, the estimation uses the unmitigated emissions values inst ead of the mitigated values. While the implementation of mitigation measures, such as Mitigation Measure GHG-2: Provide CALGreen Tier 2 EV Parking and GHG-3: All Electric Operations, in concert with State actions that support carbon free electricity generation, would result in substantial reductions of GHG emissions from the project’s bu ilding energy and mobile sources, the actual reductions that would occur with the implementation of these measures and the ability of future actions to achieve State goals cannot be known at this time and, therefore, is uncertain. Thus, although substantia l GHG emissions reductions may occur, the timing and certainty of such reductions cannot be guaranteed, and it would be speculative at this time to quantify when and to what degree those reductions may occur.
I-13 The commenter suggests additional mitigation measures for reducing GHG emissions. In addition to the mitigation measure referenced by the commenter, the project would implement GHG -2 through GHG -4, which would require the site to comply with the CALGreen Voluntary Tier 2 EV parking requirements, require buildings to be powered by electricity unless another form of energy is required, and require the installation of solar panels on 15% of the rooftop area at the time of building construction. The EIR was revised to add these measures in Section 4.8 (see FEIR Section 3, Errata.
2.0 Response to Comments
2-102 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter I – Advocates for the Environment The specific mitigation suggested by the commenter was reviewed, and it was determined:
• Requiring the applicant to enter into an agreement for a zero-emission heavy duty truck fleet “to the extent feasible and as soon as practicable” would not be feasible for the reasons explained in Response C -6. Furthermore, as identified by the commenter, the feasibility and timing of this measure is not clear and thus emissions reductions cannot be guaranteed or quantified at this time.
• Producing or purchasing clean power is already incorporated into the EIR through the solar requirements of GHG-4, and required by state regulations.
Through SB 100, which requires 60% of the power purchased by California to come from renewable sources by 2 030 and that all retail electricity be carbon-free by 2045.
• Requiring the installation of solar panels to offset 100% of the business park’s operational energy use would be speculative at this time. Potential future buildings in the project area would have unique demands for electricity that may or may not be able to be met by on-site solar energy systems. It should be noted that Mitigation Measure GHG -2 does require solar panels, which will contribute in offsetting energy use.
The commenter also states there are additional mitigation options in the Attorney General’s CEQA best practices recommendations but not provide mitigation suggestions from this document. The commenter also states that the Applicant could purchase offsets f or the project’s remaining GHG emissions. The commenter does not identify a specific offset program or local offset project for the City to consider.
Second, mandating carbon offsets as mitigation has been found to not meet the CEQA standards for mitigatio n because such offsets must be, among other requirements, “real, additional, quantifiable, permanent, verifiable, and enforceable.” (Golden Door Properties, LLC v. County of San Diego (2018) 27 Cal.App.5th 892.) To be adequate mitigation, any local offsite project or purchased offsets must be from a registry with a CARB -approved protocol. There are only a limited number of registries with CARB-approved protocols, and access to those reg istries is primarily reserved for participants in California’s Cap -and-Trade Program. Also, there is no guarantee that sufficient offset credits would be available. Therefore, the availability of sufficient, reliable offsets is outside the control of the City and Project applicant.
Finally, mobile sources are key contributor to the Project’s GHG emissions. However, as discussed in the DEIR, although the DEIR calculated Project emissions based on current technologies, mobile source emissions are not necessarily stagnant over time and technological and/or regulatory advances are likely to reduce mobile source emissions. Thus, the purchase of offsets as a means to mitigate future mobile source emissions (which were quantified for CEQA purposes but likely to be substantially reduced in the future) does not allow correlation of the mitigation measure to the future impact.
I-14 The commenter provides conclusionary remarks that are consistent with remarks in comments I-2 to I-14. The commenter is directed to the responses prepared for these comments.
2.0 Response to Comments
Menifee Business Park Project 2-103
City of Menifee
COMMENT LETTER J – LOZEAU DRURY LLP FOR SUPPORTERS ALLIANCE FOR
ENVIRONMENTAL RESPONSIBILITY (SAFER)
2.0 Response to Comments
2-104 Final Environmental Impact Report
October 30, 2025
Via Email
October 10, 2025
T 510.836.4200
F 510.836.4205
Russell Brow n, Senior Planner
Planning Division
Com munity Development Depart ment
City of Menifee
29844 Haun Road
Menifee, CA 92586
rbrown@ci tyofmenif ee. us
1939 Harrison Street, Ste. 150
Oakland, CA 94612
www.lozeaudrury.com
br ian@lozeaudrury,com
LETTERJ
Re: Comment on Draft Environmental Impact Report, Menifee Business Park Project (PLN23-0245)
Dear Mr. Brow n:
This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility ("SAFER") regarding the Draft Environmental Impact Report ("DEIR") prepared for the Menifee Business Park Project (PLN23-0245) , which proposes the development of eleven industrial warehouse buildings totaling 337,770 square feet, located south of Scott Road, north of Keller Road, and west oflnterstate 215, along the western side of Zeiders Road on Assessor Parcel Num bers 384- 150-001 in the City of Menifee ("Project").
SAFER is concerned that the DEIR fails as an informational document and fails to impose all feasible mitigation measures to reduce the Project's impacts. SAFER requests that the Community Developme nt Depart ment address these shortcomings in a revised draft environmental impact report ("RDEIR ") and recirculate the RDEIR prior to considering approvals for the Project.
SAFER reserves the right to supplement these comme nts during the administrative process. Galan te Vineyards v. Monterey Peninsula Water Management Dist., 60 Cal. App. 4th 1109, 1121 (1997).
J- 1
2.0 Response to Comments
Menifee Business Park Project 2-105
City of Menifee
2 PAGES
October l 0, 2025
Comment on Draft Environmental Impact Report, Menifee Business Park Project (PLN23-0245)
Sincerely,
6~~
Brian Flynn
Lozeau Drury LLP
2.0 Response to Comments
2-106 Final Environmental Impact Report
October 30, 2025
ID Response to Comment Letter J – Lozeau Drury LLP for SAFER J-1 The City is unclear how the commenter could conclude the DEIR fails as an informational document since it was posted on the State Clearinghouse Website only today and it would not have been possible to review the almost 700 -page DEIR and its Appendices A-N the same day at the EIR was posted. Nonetheless, the City has examined this claim and concludes the DEIR is in fact sufficient as an informational document and does impose all feasible mitigation measures to reduce the Project’s impacts as outlined in the various analysis sections of the DEIR. The City will consider al comments made on the DEIR and determine if it is necessary to recirculate the EIR according to State CEQA Guidelines Section 15088.5.
J-2 The City understands that SAFER reserves the right to supplement these comments during the administrative process.
Menifee Business Park Project 3-1
City of Menifee
3.0 ERRATA
This section identifies revisions to the City of Menifee’s Menifee Business Park Project Draft EIR to incorporate clarifications , corrections, or additions prepared in response to comments on the Draft EIR . These changes include minor errors or editorial corrections identified through subsequent review. Ad ditions are shown in underline. Deletions are shown in strikethrough.
Commentary Notes are shown in Italic type where needed.
None of the revisions below represent a substantial increase in the severity of an identified significant impact or the identification of a new significant impact, mitigation, or alternative considerably different from those already considered in the Draft EIR.
DEIR Section 2, Executive Summary, Table 2 -2, Detailed Description of Mitigation Measures, page 2-19
AND
DEIR Section 4.4.4, Impacts and Mitigation, page 4.4-15
MM-BIO-3 Regulatory Permitting. Consultation with and subsequent permitting through affected environmental regulatory agencies is required to address potential impacts to the 0.70 -acres of riverine features (i.e., 1,810 feet of ephemeral drainages) on the site. A pre -application meeting will be held with the Western Riverside County Resource Conservation Agency, California Department of Fish and Wildlife, and the US Fish and Wildlife Service, U.S. Army Corps of Engineers, Regional Water Quality Control Board, and th e City of Menifee to discuss the impacts to riverine features and regulated waters issues.
Permanent impacts to 0.70 acre (1,810 linear feet) of potentially jurisdictional features would be mitigated at the Riverpark Mitigation Bank, Riverside Legacy Mitigation Bank, or another bank approved by the involved agencies listed above.
An agreement for sale of credits from the approved bank will be submitted to the City of Menifee prior to grading permit issuance. In compliance with the no-net loss policy, impacts to non-wetland waters would likely require mitigation at a minimum 1:1 ratio but actual m itigation ratios will be determined during the permitting process.
An alternative option is the implementation of 3.0 acres (or as agreed to by the Agencies) of permittee-responsible rehabilitation within one of the Warren Road Partners parcels [Phase 1 (APN 455-130-059) or Phase 2 (APNs 455-130-058 and -030)] in the Hemet Vernal Pool Complex within the San Jacinto Watershed at a ratio of 4:1, to cover the net loss of habitat at a ratio of 3:1 and the temporal loss of habitat during the rehabilitation at a 1:1 ratio (or as agreed to by the Agencies).
Prior to grubbing, cle aring, or grading permit issuance, no impacts shall occur to onsite drainages until appropriate permits have been obtained from the Regional Water Quality Control Board (Section 401 Water Quality Certificate or Waste Discharge Requirements and the Californ ia Department of Fish and Wildlife (Section 1602 Streambed Alteration Agreement).
3.0 Errata
3-2 Final Environmental Impact Report
October 30, 2025
DEIR Section 4.3.4, Air Quality, Impacts and Mitigation, Impact AIR-3, pages 4.3-25 and -26
The HRA for residential receptors evaluated worst-case carcinogenic and non-carcinogenic risks to child (3rd trimester, 0-2 years, and 2-16 years) and adult (16-30 years) receptors. As shown in Appendix C, the calculated, maximum unmitigated construction risks would be approximately 6.2
5.2 excess cancers in a million in Year 1, which corresponds to infant receptors that are less than two years old at the start of construction activities. See Appendix C for risks to all age groups.
Construction would also occur during the first six months of Year 2, after which operation of the proposed project would begin. The proposed project would generate DPM once operational from diesel truck trips to and from the site, as well as their on -site idling. The calculated, maximum unmitigated risks for exposu re to the combined construction and operational concentrations at the MEIR location during Year 2 would be approximately 1.4 1.7 excess cancers in a million. After Year 2, the proposed project would continue to generate DPM from operational activities. An operational HRA was conducted to evaluate the potential health risks posed by these activities.
Whereas construction activities would only last approximately one-and-a-half years, the proposed project’s operational activities would continue to occur year a fter year until the project site is redeveloped or utilized for purposes other than a business park. Health risks from construction and operational activities are presented in Table 4.3-11 for the MEIR. As shown in Table 4.3-11, the maximum excess cancer r isk at the MEIR location would be approximately 6.8 8.1 excess cancers per million population, which is below the SCAQMD threshold of 10.0 excess cancers per million population.
Table 4.3-11: Unmitigated Cancer Risk at PMI and MEIR
Receptor
UTM Location Annual Average DPM
Concentration (µg/m3)
Excess Cancer Risk
(per million population)
East North Year 1
Construction
Year 2
Construction
and
Operation(A)
Year 3-30
Operation(B)
Year
1 Year
2 Year
3-30 Total
PMI(C) 483610.00 3721409.00 0.10716 0.03134 0.00229 -- -- -- -- MEIR 483654.71 3721301.62 0.03465 0.010055 0.00053 5.2
6.2 1.4
1.7 0.2
0.3 6.8
8.1(D)
Source: MIG, 2024 (see Appendix C)
(A) Year 2 includes emissions from both construction and operational activities. The Year 2 concentration was calculated multiplying the operational concentration in Year 3 -30 by the percent of the year that operation occurs in Year 2 (50%), and adding that Year 2 operational concentration to the Year 2 construction concentration. The construction DPM concentration for Year 2 was 0.00979 µg/m3. The operational DPM contribution during Year 2 was estimated to be approximately 0.009525 µg/m3, which reflects the remaining approximately six (6) months during the Year 2 that the project could be operational. (B) The annual average DPM operational concentration is based on the first full year of operation (Year 3). (C) The PMIs vary between Year 1 and Year 2 of construction, as well as project operation; however, the PMIs are always to the south of the site in the field immediately south of the site or, in the case of operations, in the roadway of Zeiders Road. (D) Total may not equal due to rounding.
Cancer Burden
The average cancer risk based on the lifetime exposure scenario (70 years), is 0.8 1.3E-5 (approximately 10.8 13 cases per million people). The product of cancer risk and the estimated population (96) is 0.001001 0.001206 and does not exceed the SCAQMD threshold of 0.5 excess cancer cases.
3.0 Errata
Menifee Business Park Project 3-3
City of Menifee
DEIR Section 4.8.4, Greenhouse Gases, Impacts & Mitigation, Impact GHG-1, page 4.8-20
(First and Last paragraphs of Mitigation Measure MM-GHG-1)
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). The VMT reduction measure shall be quantified in accordance with the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, Designed for Local Governments, Communities, and Project Developers (December 2021). Per the Pemcor Commercial Industrial Business Park Project Transportation Demand Management Assessment Memorandum prepared by Ganddini Group dated February 19, 2025 (MND Appendix L), the project shall provide the following to the satisfaction of City Planning staff:
The VMT/TDM Program is intended to achieve a 6.2% 5% reduction goal starting one year after 90% occupancy is achieved. The developer or POA, whichever is in control at that time, shall submit an annual report showing what programs it is offering and that it is achieving the 6.2% 5% VMT reduction goal. If in the first year they do not achieve the reduction goal, the developer or POA shall expand existing or add new programs the following year to increase employee participation. The applicant/developer or POA shall submit an annual report to the City documenting its success in implementing the VMT/TDM Program.
(The following 3 measures were inadvertently omitted from the Draft EIR text but were included in the analysis in the GHG Technical Study and the Draft EIR – their addition here does not change the analysis or conclusions of the DEIR regarding GHG emissions)(These measures are also to be considered added to DEIR Section 2, Executive Summary, Table 2 -2, Detailed Description of Mitigation Measures, page 2-19).
MM-GHG-2 Provide CALGreen Tier 2 EV Parking. To reduce potential GHG emissions from mobile sources, the proposed Project shall include EV parking spaces and infrastructure consistent with the Tier 2 provisions in the 2022 CALGreen Code, Appendix A5: Nonresidential Voluntary Measures, Section A5.106.5 .1, Section A5.601.3.4(1)(a), and Section A5.601.3.4(1)(b). These provisions require the following:
• Provide a minimum of 50% of the parking capacity as designated parking for any combination of zero -emitting, high -efficiency, and carpool/vanpool vehicles.
Comply with the provisions in CALGreen Code Section A5.106.5.1.4 for marking parking stalls as parking for clean air vehicles.
• EV charging that meets one of the two following provisions:
• Consistent with CALGreen Table A5.106.5.3.3, 45% of parking spaces are required to be EV capable spaces (with infrastructure capable of supporting EV charging), and 33% of EV capable spaces are required to have EV charging stations installed; or
3.0 Errata
3-4 Final Environmental Impact Report
October 30, 2025
• Consistent with CALGreen Table A5.106.5.3.4, the project is required to meet a power level determined by the following equation: Total required power (kVA) = Number of Parking Spaces x 0.45 x 6.61 (A maximum of 75% of kVA can be allocated to EV capable spaces).
Under either option, at least one Level 2 EV charging station would be required.
MM-GHG-3 All-Electric Operation. To reduce potential GHG emissions from energy sources, the City shall require all building energy systems, equipment, and appliances be powered by electricity unless another form of energy is required, and a suitable all- electric alternative is technologically or economically infeasible for the tenant or the equipment is not commercially available. The 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.
MM-GHG-4 Provide PV Solar. To reduce GHG emissions associated with building energy, City shall require that the proposed buildings include PV solar panels on a minimum of 15% of the total roof area.
Level of Significance After Mitigation
Less than significant.
Significant and Unavoidable
Section 4.8.6, Greenhouse Gases, References, page 4.8-24 2025. Pemcor Commercial Industrial Business Project Transportation Demand Management Assessment Project No. 19729. Ganddini Group. February 19, 2025.
Section 4.19, Utilities and Service Systems, Natural Gas, page 4.19-2, add after para 6
The City understands that SoCalGas has existing medium -pressure natural gas facilities in the project area along Zeiders and Bailey Park/Ciccotti. The developer will be conditioned to contact 811/USA prior to any excavation/demolition activities so SoCalGas can locate and mark their facilities. In addition, the developer will be required to send SoCalGas their plans to their Utility Request inbox (copied on this email) so SoCalGas can review the plans for any conflicts. It is anticipated the developer will need gas service so t hey will be required to contact SoCalGas Builder Services Group to begin the application process.
DEIR Section 4.19.1, Existing Conditions (Solid Waste), page 4.19-2
Solid Waste and Recycling Services
Solid waste collection, disposal, and recycling services in Menifee are provided by Waste Management Inc. (WM). WM operates the private El Sobrante Landfill located at 10910 Dawson Canyon Road in Corona, CA. The landfill has a disposal acreage of 78 acres, a maximum permitted capacity of 6,003,343 cubic yards (CY), and a maximum daily throughput of 400 tons per day (CalRecycle 2024).
Solid waste generated within the Project area is collected by Waste Management Inc.(WMI), with the bulk of recyclable waste and green waste delivered to the Moreno Valley Solid Waste Recycling and Transfer Station (MVTS) for processing. The facility is located at 17700 Indian Street in Moreno Valley. It is permitted for a 2,500 tons per day(tpd) operation.
3.0 Errata
Menifee Business Park Project 3-5
City of Menifee
The franchise waste hauler primarily utilizes the El Sobrante landfill for disposal, but may also utilize the Lamb Canyon, and/or the Badlands landfill for disposal of the waste generated from the proposed Project. Descriptions of the local landfills are provided below:
El Sobrante Landfill
The El Sobrante Landfill is located east of Interstate 15 and Temescal Canyon Road to the south of the City of Corona and Cajalco Road at 10910 Dawson Canyon Road. The landfill is owned and operated by USA Waste of California, a subsidiary of Waste Management, Inc., and encompasses 1,322 acres, of which 645 acres are permitted for landfill operation. The El Sobrante Landfill has a total disposal capacity of approximately209.9 million cubic yards and can receive up to 70,000 tons per week (tpw) of refuse. USA Waste must allot at least 28,000 tpw for County refuse. The landfill’s permit allows a maximum of 16,054 tons per day (tpd) of waste to be accepted into the landfill, due to the limits on vehicle trips. If needed, 5,000 tpd must be reserved for County waste, leaving the maximum commitment of Non-County waste at 11,054 tpd. Per the 2024 Annual Report, the landfill had a remaining in -County disposal capacity of approximately
46.1 million tons.2 In 2024, the El Sobrante Landfill accepted a daily average of 10,557 tons with a period total of approximately 3,251,611 tons. The landfill is expected to reach capacity in approximately 2059.
Lamb Canyon Landfill
The Lamb Canyon Landfill is located between the City of Beaumont and City of San Jacinto at 16411 Lamb Canyon Road (State Route 79), south of Interstate 10 and north of Highway 74. The landfill is owned and operated by Riverside County. The landfill property encompasses approximately 1,189 acres, of which 703.4 acres encompass the current landfill permit area. Of the 703.4-acre landfill permit area, approximately 144.6acres are permitted for waste disposal.
The landfill is currently permitted to receive 5,0 00tpd of MSW for disposal and 500 tpd for beneficial reuse. The site has an estimated total disposal capacity of approximately 21.1 million tons.3 As of January 1, 2025 (beginning of day), the landfill has a total remaining capacity of approximately 6.1 million tons. 4 The current landfill remaining disposal capacity is estimated to last, at a minimum, until approximately 2032. 5 From January 2024 to December 2024, the Lamb Canyon Landfill accepted a daily average of 1,973 tons with a period total of approxim ately 607,583 tons. Landfill expansion potential exists at the Lamb Canyon Landfill site.
Badlands Landfill
The Badlands Landfill is located northeast of the City of Moreno Valley at 31125 Ironwood Avenue and accessed from State Highway 60 at Theodore Avenue. The landfill is owned and operated by Riverside County. The existing landfill encompasses 1,168.3 acres, with a total disturbance area of 278 acres, of which 150 acres are for refuse disposal. Landfill expansion potential exists at the Badlands Landfill site. Under the 2022 Solid Waste Facility Permit (SWFP), the permitted disturbance area increases from 278 acres to 811 acres, and the refuse disposal area increases from 150 acres to 409 (in multiple stages). The landfill is currently permitted to receive 5,000 tpd of MSW for disposal and 300 tpd for beneficial reuse. The site has an estimated total capacity of approximately 68.6 million tons.6
As of January 1, 2025 (beginning of day), the landfill had a total remaining disposal capacity of approximately 48.9 million tons. 7 Under the 2022 SWFP, the landfill would have a remaining disposal capacity estimated to last, at a minimum, until approximately 2059.8 From January 2024 to December 2024, the Badlands Landfill accepted a daily average of 3,003 tons with a period total of approximately 924,862 tons.
3.0 Errata
3-6 Final Environmental Impact Report
October 30, 2025
Added References (cited in added text above)
2 2024 El Sobrante Landfill Annual Report- Based on 115,286,220 tons remaining capacity (40% for in-county waste).
3 GASB 18_ 2024 – Engineering Estimate for total landfill capacity 4 GASB 18_2024 & Site Info
5 SWFP # 33-AA-0007
6 Solid Waste Facility Permit (SWFP) # 33-AA-0006
7 GASB_18_2024 & Site Info
8 Solid Waste Facility Permit (SWFP) # 33-AA-0006
DEIR Section 4.19.5, Impacts and Mitigation (Solid Waste), Impact UTL-4, page 4.19-12 Construction
Construction of the Project may generate a substantial quantity of construction and demolition(C&D) waste. Should a large quantity of C&D waste, that is unable to be recycled, be brought to a County landfill for disposal, it could exceed the landfill’s daily permitted capacity, thus a violation of state regulations as outlined in Title 40, Vol. 41 C.F.R § 243.203 et seq. (1976).
Implementation of the project as proposed will involve the development of a new business park with 11 units/buildings with a total of approximately 337,770 square feet of gross building space on approximately 20 acres. It is estimated the project’s buildin g construction could generate approximately 1.2 tons of construction waste each day for approximately 30 days. This represents a total of 36 tons of demolition waste during construction. This estimate is based on the “Construction and Demolition Composition Calculator” spreadsheet on CalRecycle’s website:
https://www2.calrecycle.ca.gov/WasteCharacterization/General/ConDemoCalculator This estimated amount of waste would not exceed the daily capacities of any of the three county landfills that serve the Project area (El Sobrante as primary with Lamb Canyon and Badlands as secondary).
Menifee Business Park Project 4-1
City of Menifee
4.0 PUBLIC CIRCULATION
Availability and Distribution
The Notice of Preparation (NOP) was submitted to the State Clearinghouse for distribution to State agencies on the standard notification list maintained by the City of Menifee Planning Department. The NOP was circulated for a 30 -day public review period from July 25, 2024 to August 23, 2024. The NOP was electronically filed with the State Clearinghouse on July 23, 2024.
It was available on the City’s website during the entire NOP public review period (see Appendix A of the Draft EIR).
An in-person Scoping Meeting was held on July 31, 2024 at City Hall for public agencies and the public to ask questions about the EIR and provide input as to important issues that should be addressed in the EIR (see Appendix A of the Draft EIR).
The Notice of Availability (NOA)(FEIR Appendix A) for the Draft EIR was distributed on August 12 to all agencies and other entities on the standard notification list via certified mail (see below)(FEIR Appendix B) and was posted to the Riverside County Recorder/Clerk and published in the Press Enterprise newspaper on August 11, 2025 (see FEIR Appendix C). The NOA was sent to the same agencies and entities that received notification of the NOP. The NOA was sent to government agencies, neighboring cities, and non -governmental interested parties. The NOA and Notice of Completion (NOC) were submitted electronically to the State Clearinghouse for distribution to State agencies. The NOA and DEIR materials were also available on the City’s website during the entire DEIR review period. Notification was also submitted to local Native American Tribal Governments in accordanc e with CEQA statutes, guidelines, and Assembly Bill (AB) 52 (see Appendix B of the Draft EIR). The 45-day public review period for the Draft EIR ran from August 12 to September 29, 2025, but was recirculated or reissued on September 2 so the review period was extended to October 16, 2025.
Agency Mailing List Recipients
Federal Agencies
None
State of California (most per NOC through State Clearinghouse)
State Clearinghouse
Department of Transportation (Caltrans) District 8 – Riverside/San Bernardino Counties Native American Heritage Commission
Regional Water Quality Control Board - Region 8 – Santa Ana Department of Toxic Substances Control
Department of Fish and Wildlife – Region 6 - Inland Desert California Council of the Blind
4-2 Final Environmental Impact Report
October 30,.2025
Riverside County
Airport Land Use Commission
County Clerk/Recorder
Department of Environmental Health
Planning Department
Transportation Commission
Waste Management Department
Regional
Santa Ana Regional Water Quality Control Board
South Coast Air Quality Management District CEQA – Inter-Governmental Review Group Valley-Wide Recreation and Parks District
Western Riverside County Regional Conservation Authority
Local Cities
City of Perris Planning Department
Transportation
Riverside Transit Agency
Education
Menifee Union School District
Perris Union High School District
Utilities/Services
Eastern Municipal Water District
Southern California Edison
Southern California Gas Company
Verizon Business Office
Native American Tribal Groups
Pechanga Band of Mission Indians
Soboba Band of Luiseño Indians
Community Groups/Other Groups/Individuals
Lozeau Drury LLP
Menifee Business Park Project 5-1
City of Menifee
5.0 MITIGATION MONITORING & REPORTING PLAN (MMRP)
This Mitigation Monitoring and Reporting Program (MMRP or Program ) identifies Mitigation Measures incorporated into the Menifee Business Park Project Draft EIR for the City of Menifee.
For each Mitigation Measure, the MMRP identifies the significant impact, the related mitigation measure, the implementation entity, the monitoring and verification entity, and timing requirements.
Authority
This MMRP has been prepared pursuant to Section 21081.6 of the California Environmental Quality Act (CEQA)(Public Resources Code Sections 21000 et seq.), and the State CEQA Guidelines (14 Cal. Code Regs. Sections 15000 et seq.) Sections 15091(d) and 15097, to ensure implementation of and provide for the monitoring of mitigation measures required of the Menifee Business Park Project (Project) as set forth in the Final Environmental Impact Report (FEIR) prepared for the Project. The report will be kept of fil e in the Planning office of the CEQA Lead Agency, the City of Menifee (City).
As noted in the EIR, the Project has been designed to reduce or avoid adverse environmental impacts through the implementation of a number of Project Design Features (PDFs) as well as a number of standard Conditions of Approval (COAs) as developed by the C ity. When significant impacts were still identified even after implementation of PDFs and COAs, the EIR identified a number of mitigation measures to avoid or substantially lessen significant environmental impacts.
The MMRP outlined in matrix Table 5 -1 below is designed for the City to monitor and ensure implementation of all mitigation measures that are adopted for the Project.
The City is the Lead Agency for the Project and assumes ultimate enforcement responsibilities for implementation of all mitigation measures listed in this Program. The City may assign responsibility for implementation or monitoring to appropriate designees such as a construction manager or third-party monitor. However, as the Lead Agency, the City remains responsible for ensuring that implementation of the mitigation measures occurs in accordance with this Program.
In some cases, the Project or the City is required to secure permits or approvals from third party agencies in order to implement a mitigation measure. In these cases, the City is responsible for verifying that such permits or approvals have been obtained in accordance with the conditions stipulated in th e mitigation measure. The City’s existing planning, engineering, operations, and procurement review and inspection processes will be used as the basic foundation for the Program procedures and will also serve to provide the documentation for the reporting Program.
Monitoring Schedule
Prior to construction, while detailed design plans are being programs the applicant/developer, City staff will be responsible for ensuring compliance with mitigation monitoring applicable to the Project construction, development, and design phases. Once construction has begun and is underway, monitoring of the mitigation measures associated with construction will be included in the responsibilities of City staff who shall prepare, or cause to be prepared, periodic monitoring reports as appropriate. Regulato ry agencies will have to coordinate CEQA mitigation and regulatory permit conditions and monitoring/reporting as part of their regulatory permitting process
5.0 Mitigation Monitoring & Reporting Program (MMRP)
5-2 Final Environmental Impact Report
October 30, 2025
and will likely require submittal of formal monitoring reports. Once construction has been completed, the City will monitor the Project as specified in the mitigation measures.
Support Documentation
Findings and related documentation supporting the findings involving modifications to mitigation measures shall be maintained in the Project file with the Program and shall be made available to the public upon request.
Format of Mitigation Monitoring Matrix (FEIR Table 5-1)
The mitigation monitoring matrix (FEIR Table 5 -1) identifies the environmental issue areas for which monitoring is required, the required mitigation measures, the time frame for monitoring, and the agency or organization responsible for implementing and monitoring the measures.
Definitions
Acronym Definition
ACM Asbestos-Containing Material
CDFW California Department of Fish and Wildlife
COA Condition of Approval
dBA Decibel (measure of sound pressure) on the A-weighted scale DPM Diesel Particulate Matter
DTSC (State) Department of Toxic Substances Control
EV Electric Vehicle
EVCS Electric Vehicle Charging Station
EVSC Electric Vehicle Supply Equipment
FAA Federal Aviation Administration
GHG Greenhouse Gas
LBP Lead-Based Paint
Leq Noise Equivalent Level
NOx Oxides of Nitrogen
NZEV Near Zero Emission Vehicle
ONT Ontario International Airport
QEP Qualified Environmental Professional
SCAQMD South Coast Air Quality Management District
TDM Transportation Demand Management
TRU Transport Refrigeration Unit
VMT Vehicle Miles Traveled
VOC Volatile Organic Compound
ZEV Zero Emission Vehicle
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-1
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
AIR QUALITY
Cumulatively
Considerable Net
Increase of
Criteria Pollutants
(AIR-2)
MM-AQ-1: Reduce VOC Emissions. To reduce
VOC emissions associated with the application of
architectural coatings, the construction contractor
for the Project shall be required to utilize “Super -
Compliant” VOC architectural coatings for interior
and exterior paint applications at the pro posed
business park during construction. Consistent with
the South Coast Air Quality Management District’s
definition, “Super -Compliant” architectural
coatings shall have a maximum VOC content of 10
grams of VOC per liter.
Project
Applicant/
Paining
Contractor
City
Construction
Inspector(s)
During
application of
architectural
coatings
BIOLOGICAL RESOURCES
5.1-2 Final Environmental Impact Report
October 30, 2025
Impacts on
candidate,
sensitive, or
special status
species (BIO-1)
Interfere with
wildlife movement
or migration
corridors (BIO-4)
MM-BIO-1: Burrowing Owl Pre -Construction
Survey. A 30 -day pre -construction survey for
burrowing owls shall be conducted prior to initial
ground-disturbing activities (e.g., vegetation
clearing, clearing and grubbing, grading, tree
removal, site watering, equipment staging) to
ensure that no owls have colonized the site in the
days or weeks preceding the ground -disturbing
activities. If burrowing owls have colonized the
Project boundary prior to the initiation of ground -
disturbing activities, the Project pro ponent will
immediately inform the Regional Conservation
Authority (RCA) and the Wildlife Agencies and will
need to coordinate further with RCA and the
Wildlife Agencies, including the possibility of
preparing a Burrowing Owl Protection and
Relocation Plan , prior to initiating ground
disturbance. If ground -disturbing activities occur,
but the site is left undisturbed for more than 30
days, a pre -construction survey must again be
conducted to ensure that burrowing owls have not
colonized the site since it was last disturbed.
If burrowing owls have colonized the Project
boundary prior to the initiation of construction, the
Project proponent shall immediately inform the
Wildlife Agencies and the WRCRCA. Approval of
a Burrowing Owl Protection and Relocation Plan
by the Wildlife A gencies prior to initiating ground
disturbance would be required. Translocation of
any owls present on -site would be required to
occur within the nonbreeding season. With
implementation of the 30 -day preconstruction
survey and the Burrowing Owl Protection and
Relocation Plan, if warranted, impacts to
burrowing owl, including possible take of active
nests, would be avoided. If ground -disturbing
activities occur but the site is left undisturbed for
more than 30 days, a pre-construction survey will
again be necessary to ensure that burrowing owl
Project
Biologist
City Planning
Department
3 days prior to
the start of
grading
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-3
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
have not colonized the site since it was last
disturbed.
Impacts on
candidate,
sensitive, or
special status
species (BIO-1)
Interfere with
wildlife movement
or migration
corridors (BIO-4)
MM-BIO-2: Nesting Bird Pre -Construction
Survey. Habitat clearing, grubbing, grading, and
associated construction actions will be timed to
avoid the avian breeding season of January 15 to
August 31. if vegetation clearing cannot be
avoided during the bird nesting season, a pre -
construction nest survey sh all be conducted by a
qualified biologist and occur no more than seven
days prior to vegetation removal. Additionally,
raptors (birds of prey) are known to begin nest
building in January or February. If vegetation
clearing is to occur between January 1 and
February 15, a nesting raptor survey will be
conducted within the survey area.
If active bird nests are confirmed to be present
during the pre-construction survey, a buffer zone,
restricting ground disturbance, grading and
construction activities, will be established by a
qualified biologist until it has verified by the
biologist that the young have fledged or the nest
has otherwise become inactive.
Project
Biologist
City Planning
Department
3 days prior to
the start of
grading
5.1-4 Final Environmental Impact Report
October 30, 2025
Have a
substantial
adverse effect on
any riparian
habitat or other
sensitive natural
community
(BIO-2)
MM-BIO-3: Regulatory Permitting. Consultation
with and subsequent permitting through affected
environmental regulatory agencies is required to
address potential impacts to the 0.70 -acres of
riverine features (i.e., 1,810 feet of ephemeral
drainages) on the site. A pre -application meeting
will be held with the Western Riverside County
Resource Conservation Agency, California
Department of Fish and Wildlife, and the US Fish
and Wildlife Service, U.S. Army Corps of
Engineers, Regional Water Quality Control Board,
and the City of Menifee to di scuss the impacts to
riverine features and regulated waters issues.
Permanent impacts to 0.70 acre (1,810 linear feet)
of potentially jurisdictional features would be
mitigated at the Riverpark Mitigation Bank,
Riverside Legacy Mitigation Bank, or another bank
approved by the involved agencies listed above.
An agreement fo r sale of credits from the
approved bank will be submitted to the City of
Menifee prior to grading permit issuance. In
compliance with the no-net-loss policy, impacts to
non-wetland waters would likely require mitigation
at a minimum 1:1 ratio but actual m itigation ratios
will be determined during the permitting process.
An alternative option is the implementation of 3.0
acres (or as agreed to by the Agencies) of
permittee-responsible rehabilitation within one of
the Warren Road Partners parcels [Phase 1 (APN
455-130-059) or Phase 2 (APNs 455-130-058 and
-030)] in the Hemet Vernal Pool Complex within
the San Jacinto Watershed at a ratio of 4:1, to
cover the net loss of habitat at a ratio of 3:1 and
the temporal loss of habitat during the
rehabilitation at a 1:1 ratio (or as agreed to by the
Agencies).
Prior to grubbing, clearing, or grading permit
issuance, no impacts shall occur to onsite
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-5
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
drainages until appropriate permits have been
obtained from the Regional Water Quality Control
Board (Section 401 Water Quality Certificate or
Waste Discharge Requirements and the California
Department of Fish and Wildlife (Section 1602
Streambed Alteration Agreement).
GREENHOUSE GAS EMISSIONS
Generate
significant GHG
emissions on a
direct, indirect, or
cumulative basis
(GHG-1 and
GHG-3)
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).
The VMT reduction measure shall be quantified in
accordance with the California Air Pollution
Control Officers Association (CAPCOA)
Handbook for Analyzing Greenhouse Gas
Emission Re ductions, Assessing Climate
Vulnerabilities, and Advancing Health and Equity,
Designed for Local Governments, Communities,
and Project Developers (December 2021). Per the
Pemcor Commercial Industrial Business Park
Project Transportation Demand Management
Assessment Memorandum prepared by Ganddini
Group dated February 19, 2025 (MND Appendix
L), the project shall provide the following to the
satisfaction of City Planning staff:
• Voluntary Commute Trip Reduction Program
(CAPCOA Measure T-5)
Project
Applicant
City Planning
Department
Review/
Approve
Annual Report
5.1-6 Final Environmental Impact Report
October 30, 2025
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
• Commute Trip Reduction Marketing
(CAPCOA Measure T-7)
• Ridesharing Program (CAPCOA Measure T -
8)
• Subsidized or Discounted Transit Program
(CAPCOA Measure T-9)
• End-of-Trip Bicycle Facilities (CAPCOA
Measure T-10)
• Employer-Sponsored Vanpool (CAPCOA
Measure T-11)
• Electric Vehicle Charging Infrastructure
(CAPCOA Measure T-14)
It should be noted that CAPCOA Measures T -7
through T -11 are required as part CAPCOA
Measure T -5 as part of the VMT/TDM program.
For more details on the specifics of each measure
refer to the TDM assessment memorandum
prepared by Ganddini Group in 2025.
Implementation Parameters
In lieu of a VMT/TDM Program, the Project may
participate in a regional VMT mitigation
exchange/banking program (if one has been
established) to reduce VMT from the Project or
other land uses to achieve stated levels.
If the VMT/TDM Reduction Plan cannot implement
all CAPCOA requirements for the indicated
actions of the measure (T-5, T-7 through T-11, and
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-7
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
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Entity
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Requirements Initials Date
T-14), the project shall implement one or more of
the following additional actions to the satisfaction
of the City Planning Department:
1) Provide car -sharing, bike sharing, and ride -
sharing programs;
2) Improve or increase access to transit;
3) Offer programs or incentives to further reduce
transportation requirements such as work
from home and flexible work schedules.
The project is not limited to these measures but
must describe the planned VMT/TDM reduction
measure(s) and subsequently demonstrate their
successful implementation to the City in its annual
report.
This VMT/TDM Reduction Plan shall be managed
by the applicant/developer until such time as a
Property Owners Association (POA) is formed and
active on behalf of the onsite uses/users.
The VMT/TDM Program is intended to achieve a
6.2% 5% reduction goal starting one year after
90% occupancy is achieved. The developer or
POA, whichever is in control at that time, shall
submit an annual report showing what programs it
is offering and that it is achieving the 6.2% 5%
VMT reduction goal. If in the first year they do not
achieve the reduction goal, the developer or POA
shall expand existing or add new programs the
following year to increase employee participation.
The applicant/developer or POA shall submit an
5.1-8 Final Environmental Impact Report
October 30, 2025
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
annual report to the City documenting its success
in implementing the VMT/TDM Program.
Generate
significant GHG
emissions on a
direct, indirect, or
cumulative basis
(GHG-1 and
GHG-3)
MM-GHG-2: Provide CALGreen Tier 2 EV
Parking. To reduce potential GHG emissions from
mobile sources, the proposed Project shall include
EV parking spaces and infrastructure consistent
with the Tier 2 provisions in the 2022 CALGreen
Code, Appendix A5: Nonresidential Voluntary
Measures, Section A5.106.5 .1, Section
A5.601.3.4(1)(a), and Section A5.601.3.4(1)(b).
These provisions require the following:
* Provide a minimum of 50% of the parking
capacity as designated parking for any
combination of zero-emitting, high-efficiency, and
carpool/vanpool vehicles. Comply with the
provisions in CALGreen Code Section
A5.106.5.1.4 for marking parking stalls as parking
for clean air vehicles.
* EV charging that meets one of the two following
provisions:
* Consistent with CALGreen Table
A5.106.5.3.3, 45% of parking spaces are
required to be EV capable spaces (with
infrastructure capable of supporting EV
charging), and 33% of EV capable spaces are
required to have EV charging stations installed;
or
* Consistent with CALGreen Table
A5.106.5.3.4, the project is required to meet a
power level determined by the following
equation: Total required power (kVA) =
Project
Applicant
City Planning
Department
Review/
Approve
Project Plans
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-9
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
Number of Parking Spaces x 0.45 x 6.61 (A
maximum of 75% of kVA can be allocated to
EV capable spaces).
Under either option, at least one Level 2 EV
charging station would be required.
MM-GHG-3: All -Electric Operation. To reduce
potential GHG emissions from energy sources, the
City shall require all building energy systems,
equipment, and appliances be powered by
electricity unless another form of energy is
required, and a suitable all -electric alternative is
technologically or economically infeasible for the
tenant or the equipment is not commercially
available. The 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 a n all -electric
alternative is unavailable or infeasible.
Project
Applicant
City Planning
Department
Review/
Approve
Project Plans
MM-GHG-4: Provide PV Solar. To reduce GHG
emissions associated with building energy, City
shall require that the proposed buildings include
PV solar panels on a minimum of 15% of the total
roof area.
Project
Applicant
City Planning
Department
Review/
Approve
Project Plans
HAZARDS AND HAZARDOUS MATERIALS
Create a
significant hazard
through
reasonably
foreseeable upset
and accident
MM-HAZ-1: Pre-Demolition Surveys. Prior to
demolition of any structures on the Project site, the
developer shall retain qualified licensed
environmental contractor(s) to survey the existing
onsite farm buildings and any related structures for
asbestos-containing materials (ACMs) and Lead -
Project
QEP/Applicant
City Planning
Department
and City
Inspectors, as
appropriate
Prior to
demolition of
any onsite
structures
5.1-10 Final Environmental Impact Report
October 30, 2025
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
conditions
(HAZMAT-2)
Based Paints (LBPs). If the survey finds the
presence of any ACMs or LBPs on the site, the
contractor(s) shall follow all relevant guidance
from affected regulatory agencies (e.g., CalEPA,
SCAQMD, DTSC, County Health Department,
etc.) in terms of safe remo val and disposal of the
contaminated materials as appropriate. The
contractor(s) shall prepare and submit a final
report to the City Planning Department within 30
days after completion of demolition/removal for
ACMs and LBPs on the project site.
Create a
significant hazard
through
reasonably
foreseeable upset
and accident
conditions
(HAZMAT-2)
MM-HAZ-1: Inadvertent Hazmat Discovery.
Prior to issuance of a grading permit, the Project
proponent shall retain a qualified environmental
professional (QEP) experienced with remediating
hazardous materials from infill urban construction
sites. The QEP must be on-call and summoned to
the site immediately if any potentially hazardous
materials are found during grading. Grading must
be halted within 100 feet of an area that appears
to contain hazardous materials. The QEP will halt
grading as necessary to eff ectively identify the
potential contaminated materials, including
directing any sampling and laboratory testing that
may be required.
If soils are found to be contaminated at levels that
are only slightly in excess of applicable residential
standards, the QEP shall exercise professional
discretion and have the option to coordinate with
the grading contractor and developer to either
remove contaminated soil and/or mix the
contaminated soil with clean soil from either onsite
Project
QEP/Applicant
City Planning
Department
and City
Inspectors, as
appropriate
Prior to
issuance of
any grading
permits
During all
grading
activities
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-11
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
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and
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or offsite to dilute any contaminants to below
applicable exposure standards for residential
development.
Remediated areas must be retested to assure
potential contaminant levels are below applicable
commercial standards. The results of any testing
shall be provided to the City or other agencies as
appropriate. Any contaminated soil that must be
removed from the site shall be done by a licensed
contractor and hauled to a landfill approved for
such materials. This measure shall be
implemented to the satisfaction of the City
Planning Department.
NOISE
Exposure to
Noise Levels in
Excess of
Standards
(NOISE-1)
MM-NOI-1: Reduce Potential Construction
Noise Levels. To reduce potential construction
noise levels generated by the development of
rezone sites, the City shall require future
development projects to:
A. Notify Nearby Land Uses of Planned
Construction Activities. This notice shall be
provided at least two (2) weeks prior to the
start of any construction activities, describe
the noise control measures to be implemented
by the Project, and include the name and
phone number of the designated developer’s
or contractor’s representative responsible for
handling construction -related noise
complaints. This notice shall be provided to all
properties that directly border the Project site.
Project
Applicant
City
Construction
Inspector(s)
During all
construction
activities
5.1-12 Final Environmental Impact Report
October 30, 2025
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
B. Restrict Work Hours: Unless otherwise
authorized by the City, all construction-related
work activities, including material deliveries,
shall be conducted 6:30 AM through 7:00 PM
on Mondays through Saturdays. Construction
is prohibited on Sundays and nationally
recognized holidays. The Project shall post a
sign at all entrances to the work site informing
contractors, subcontractors, other workers,
etc. of this requirement.
C. Construction Staging and Equipment Noise
Control Measures:
1. Construction site access and staging activities
such as receipt of deliveries, equipment and
material storage, etc., shall occur as far away
from adjacent residential land uses as
possible given site and active work
constraints.
2. All stationary noise generating equipment
shall be shielded and located as far as
possible from residential land uses given site
and active work constraints. Shielding may
consist of trailers, stored materials, or a three-
or four -sided enclosure provided the
structure/barrier breaks the line of sight
between the equipment and the receptor,
provides for proper equipment ventilation and
operations, and complies with all other
applicable occupational safety and health
requirements.
3. Heavy equipment shall include standard noise
suppression devices such as mullers, engine
Table 5-1: Mitigation Monitoring and Reporting Program
Menifee Business Park Project 5.1-13
City of Menifee
IDENTIFIED
IMPACT
RELATED MITIGATION MEASURE1
CITY MONITORING VERIFICATION
Implementation
Entity
Monitoring
and
Verification
Entity
Timing
Requirements Initials Date
covers, and engine/mechanical isolators,
mounts, etc. Equipment and noise
suppression devices shall be maintained in
accordance with manufacturer’s
recommendations while on-site.
4. Pneumatic tools shall include a suppression
device on the compressed air exhaust
5. Connect to existing electrical service to power
stationary and portable equipment (e.g.,
pumps, generators, compressors, and
welding sets). This measure shall be subject
to the approval of the local electric utility. If it
is not feasible to connect to ele ctrical service
and/or extend electrical service to all work
sites, Mitigation Measure NOI -1, section C.2,
shall be implemented.
6. No radios or other amplified sound devices
shall be audible beyond the property line of the
construction site.
1 Any changes to the measures identified in the Draft EIR that were changed as outlined in Section 3, Errata, of the Final EIR are shown as underlined text (for additions) or strike-through text (for deletions)
5.1-14 Final Environmental Impact Report
October 30, 2025
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