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 EIR.
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 driveways and adjacent streets. Sight distance is the continuous length of street ahead visible to the driver. At unsignalized intersections, comer 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 Russell Brown
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this analysis is the American Association of State Highway and Transportation Officials (AASHTO) Stopping Sight Distance requirements. 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 Proposed 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 project's significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision 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 impacts to a less than significant level, and a mixed-use project that provides affordable housing and exclusively local-serving commercial uses that may reduce VMT, GHG emissions and simultaneously improve Air Quality.
6.2 Growth-Inducing Effects
The EIR has not provided an adequate or accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. SCAG's Connect SoCal Demographics and Growth Forecast24 notes that the City will add 8,500 jobs 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 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 projects25 such as Menifee Commerce Center (2,885 employees), Menifee 24 SCAG 2024 Connect SoCal Demographics and Growth Forecast https://scag.ca.gov/sites/default/files/2024-05/23-29g7-tr-demographics-growth-fo.i:ecast -final-040424.pdf 25 Data for listed projects via City of Menifee Land Development Projects Map https: //cityofmenifee .maps.arcgis .com/apps/instant/minimalist/index.html?appid =55fc56d4eee94e588a28 a958cebac908 and Accela Menifee https://aca
prod .accela.com/MENIFEE/Cap/CapHome.aspx?module=Planning&TabName=Planning&TabList=Hom Russell Brown
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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 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 of 0.46, 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 e%7C0%7CPermits%7Cl%7CEngineering%7C2%7CPlanning%7C3%7CFire%7C4%7CCurrentTablnde x%7C3
26 Menifee General Plan Land Use Element
https://www.cityofinenifee.us/DocumentCenterNiew /1470 I/FINAL Land-Use-Element 1 1322 Russell Brown
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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 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:
1. SWAPE Technical Analysis