Final Environmental Impact Report
Heritage Valley Business Center Project
SCH No. 2025051051
LEAD AGENCY
City of Menifee
29844 Haun Road
Menifee, CA 92586
(951) 769-8520
CONSULTANT
Kimley-Horn and Associates, Inc.
Kari Cano, Project Manager
3801 University Avenue, Suite 300
Riverside, CA 92501
May 2026
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Table of Contents
Section 1: Introduction
1.1 Introduction .......................................................................................................................... 1-3
1.2 Organization of EIR ............................................................................................................... 1-4
1.3 CEQA Process Summary ........................................................................................................ 1-4
1.4 Changes to the Draft EIR ....................................................................................................... 1-4 Section 2: Comments and Responses to Draft EIR
2.1 Introduction to Comments and Responses .......................................................................... 2-1 Comment Letter A1 – Southern California Gas Company ............................................................ 2-2 Responses to Comment Letter A1 ............................................................................................ 2-5 Comment Letter A2 – South Coast Air Quality Management District .......................................... 2-6 Responses to Comment Letter A2 ............................................................................................ 2-7 Comment Letter A3 – South Coast Air Quality Management District .......................................... 2-8 Responses to Comment Letter A3 .......................................................................................... 2-13 Comment Letter A4 – City of Perris ............................................................................................ 2-19 Responses to Comment Letter A4 .......................................................................................... 2-21 Comment Letter A5 – California Department of Transportation ............................................... 2-25 Responses to Comment Letter A5 .......................................................................................... 2-30 Comment Letter A6 – Riverside Transit Agency ......................................................................... 2-32 Responses to Comment Letter A6 .......................................................................................... 2-33 Comment Letter A7 – Riverside County Flood Control and Water Conservation District .......... 2-34 Responses to Comment Letter A7 .......................................................................................... 2-40 Comment Letter O1 – Advocates for the Environment .............................................................. 2-41 Responses to Comment Letter O1 .......................................................................................... 2-46 Comment Letter O2 – Adams Broadwell Joseph and Cardozo ................................................... 2-52 Responses to Comment Letter O2 .......................................................................................... 2-56 Comment Letter I1 – Alex Munoz ............................................................................................... 2-57 Responses to Comment Letter I1 ............................................................................................ 2-58 Section 3.0: Errata to the Draft EIR
3.1 Introduction to the Errata ..................................................................................................... 3-1
3.2 Changes to the Draft EIR………………………………………………………………………………………………………3-1
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1.0 INTRODUCTION
1.1 INTRODUCTION
The City of Menifee (City) has prepared this Final Environmental Impact Report (FEIR) in compliance with the California Environmental Quality Act (CEQA) for the Heritage Valley Business Center Project (Project).
The City is required, after completion of a Draft EIR (DEIR) (State Clearinghouse No. 2025051051), to consult with and obtain comments from public agencies having jurisdiction by law with respect to the Project and provide the general public with an opportunity to comment on the DEIR. This FEIR has been prepared to respond to comments received on the DEIR, which was circulated for public review from March 18, 2026, through May 1, 2026 (45 days). The preceding Table of Contents provides a list of all persons, organizations, and public agencies who commented on the DEIR.
The City will evaluate comments on environmental issues from persons who reviewed the DEIR and will prepare a written response, pursuant to CEQA Guidelines Section 15088(a). The written response must address any significant environmental issues raised. In addition, there must be a good faith and reasoned analysis in the written response. However, lead agencies need only respond to significant environmental issues associated with the Project and do not need to provide all the information requested by commenters, as long as a good faith effort at full disclosure is made in the EIR (State CEQA Guidelines Section 15204, Section 15088). Those comments are responded to in Section 2.0: Comments on the Draft EIR and Responses to Comments.
State CEQA Guidelines Section 15088 recommends that where a response to comment makes important changes in the information contain in the text of the DEIR, that the Lead Agency either revise the text of the DEIR or include marginal notes showing that information. Added or modified text is shown in Section
3.0: Errata, by underlining (example) while deleted text is shown by striking (example). The additional information, corrections, and clarifications are not considered to substantively affect the conclusions within the EIR and therefore the City has determined that recirculation of the DEIR is not required as none of the criteria for recirculation under CEQA Guidelines Section 15088.5 have been met.
CEQA Guidelines Section 15132 indicates that the contents of a FEIR shall consist of:
a) The DEIR or a revision of the draft.
b) Comments and recommendations received on the DEIR either verbatim or in summary. c) A list of persons, organizations, and public agencies commenting on the DEIR. d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
e) Any other information added by the Lead Agency.
Pursuant to CEQA Guidelines Section 15088(b), the City will provide written responses to comments to any public agency that commented on the DEIR, at least ten (10) days prior to the Planning Commission City of Menifee
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consideration of certifying the EIR as adequate under CEQA. Written responses to comments will also be provided to non-public agency individuals, organizations, and entities that commented on the DEIR. In addition, the FEIR will be made available to the general public at the City’s Planning Division office and on the City’s website a minimum of 10 days prior to the Planning Commission public hearing.
The FEIR, along with other relevant information and public testimony at the Planning Commission hearing, will be considered by the City’s Planning Commission.
1.2 ORGANIZATION OF EIR
This FEIR provides the requisite information required under CEQA and is organized as follows:
Section 1.0: Introduction . This section provides an introduction to the FEIR, including the requirements under CEQA, the organization of the document, as well as a brief summary of the CEQA process activities to date.
Section 2.0: Comments on the Draft EIR and Responses to Comments. This section provides a list of public agencies, organizations, and individuals commenting on the DEIR, provides a copy of each written comment received, and any response required under CEQA. Section 3.0: Errata to the Draft EIR . This section presents clarifications, amplifications, and insignificant modifications to the EIR, identifying revisions to the text of the document.
1.3 CEQA PROCESS HISTORY
The City has complied with relevant Public Resources Code provisions and CEQA Guidelines regarding the preparation and processing of the Project EIR. A brief summary of the Project’s CEQA process is as follows:
A Notice of Preparation (NOP) informing interested parties and agencies of the Project was distributed on May 23, 2025, with a minimum 30-day public review period ending on June 23, 2025.
No comments were given at the public scoping meeting held for the Project on June 3, 2025, at 5:30 pm at City Council Chambers located at 29844 Haun Road, Menifee, CA 92586. No members of the public attended the scoping meeting.
Following a Notice of Completion (NOC), the DEIR and Notice of Availability was distributed for public review and comment for a 45-day period, beginning March 18, 2026. The public review period closed on May 1, 2026.
1.4 CHANGES TO THE DRAFT EIR
As previously stated, Section 3.0: Errata to the Draft EIR, details the changes to the DEIR. In response to public comments, text changes have been made to DEIR sections to clarify and amplify the analysis or mitigation measures, and to make insignificant modifications to the DEIR. This information does not rise to the level of significant new information as the resulting impact analysis and alternatives considered remain essentially unchanged, and no new or more severe impacts have been identified. These changes do not warrant DEIR recirculation pursuant to California Public Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5. As discussed herein and as elaborated upon in the respective Response to City of Menifee
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Comments, none of the clarifications or changes made in the Errata reflect a new significant environmental impact, a “substantial increase” in the severity of an environmental impact for which mitigation is not proposed, or a new feasible alternative or mitigation measure that would clearly lessen significant environmental impacts but is not adopted, nor do the Errata reflect a “fundamentally flawed” or “conclusory” DEIR. In all cases, as discussed in individual responses to comments and DEIR Errata, these minor clarifications and modifications do not identify new or substantially more severe environmental impacts that the City has not committed to mitigate. Therefore, the public has not been deprived of a meaningful opportunity to comment upon a substantial adverse environmental effect of the Project or an unadopted feasible Project alternative or mitigation measure. Instead, the information added supports the existing analysis and conclusions, and responds to inquiries made from commenters. Therefore, this FEIR is not subject to recirculation prior to certification.
CEQA Guidelines Section 15088.5 describes when an EIR requires recirculation prior to certification, stating in part:
(a) “A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term "information" can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to apply it. (4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043). (b) Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” City of Menifee
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2.0 COMMENTS AND RESPONSES TO DRAFT EIR
This section includes all comments received by the City on the Draft Environmental Impact Report (DEIR), including written comments and comments submitted online via email to the City. The City circulated the DEIR for a 45-day review period as required by CEQA. The review period ran from March 18, 2026, through May 1, 2026.
2.1 Introduction to Comments and Responses
In accordance with CEQA Guidelines Section 15132, Table 2-1: Comments from Public Agencies, Organizations, and Individuals below provides a list of those parties that provided written comments on the DEIR during the public review period. Copies of the written comments are provided in this section and have been annotated with the assigned letter along with a number for each comment. Each comment is followed by a written response which corresponds to each commenter.
Table 2-1: Comments from Public Agencies, Organizations, and Individuals Reference Commenter Date
Agency 1 (A1) Southern California Gas Company March 18, 2026 Agency 2 (A2) South Coast Air Quality Management District March 24, 2026 Agency 3 (A3) South Coast Air Quality Management District May 1, 2026 Agency 4 (A4) City of Perris May 1, 2026
Agency 5 (A5) California Department of Transportation May 1, 2026 Agency 6 (A6) Riverside Transit Agency April 30, 2026
Agency 7 (A7) Riverside County Flood Control and Water Conservation District April 13, 2026 Organization 1 (O1) Advocates for the Environment March 30, 2026 Organization 2 (O2) Adams Broadwell Joseph and Cardozo April 14, 2026 Individual 1 (I1) Alex Munoz March 23, 2026
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Comment Letter A1 – Southern California Gas Company
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Responses to Comment Letter A1 – Southen California Gas Company A1-1 Comment noted, no further response is warranted.
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Comment Letter A2 – South Coast Air Quality Management District
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Responses to Comment Letter A2 – South Coast Air Quality Management District A2-1 Comment noted. South Coast Air Quality Management District was provided the requested files on March 25, 2026 and no further response is warranted.
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Comment Letter A3 – SCAQMD
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Responses to Comment Letter A3 – SCAQMD
A3-1 The comment summarizes the Project and acknowledges the City of Menifee as Lead Agency under CEQA. The comment’s description of the Project is materially consistent with the information presented in the Draft EIR. This comment does not raise specific environmental concerns or request revisions to the analysis. Findings and conclusions of the EIR are not affected. Revision to the EIR is nor required.
A3-2 The DEIR acknowledges and addresses applicable SCAMD Rules and requirements. DEIR Section 5.2 Air Quality identifies and discusses applicable South Coast AQMD rules and regulations that govern Project construction and operation (DEIR pp. 5.2-19 to 5.2-23).
Specifically, the DEIR analyzes compliance with Rule 402 (Nuisance), Rule 403 (Fugitive Dust), Rule 1113 (Architectural Coatings), and Rule 2305 (Warehouse Indirect Source Rule) (DEIR pp.
5.2-19 to 5.2-20). These requirements are incorporated as Laws, Ordinances, and Regulations (LOR-1 through LOR-8), which are enforceable independent of CEQA and apply to all construction and operational activities (DEIR pp. 5.2-31 to 5.2-32).
With respect to stationary and portable equipment requiring South Coast AQMD permits (including emergency generators, fire pumps, boilers, and similar equipment), the City acknowledges that such equipment would be subject to permit requirements under Rule 201 (Permit to Construct), Rule 203 (Permit to Operate), and operational rules governing emissions, toxic air contaminants, and diesel-fueled engines. The DEIR's air quality and greenhouse gas analyses employ South Coast AQMD-approved methodologies and significance thresholds to evaluate construction and operational emissions, including those from stationary sources (DEIR pp. 5.2-23 to 5.2-26). As demonstrated in the DEIR, with implementation of Mitigation Measure MM AQ-1, the Project would not exceed regional or localized significance thresholds for criteria pollutants, or health risks (DEIR pp. 5.2-26 to 5.2- 44). DEIR Section 5.7 Greenhouse Gases considers and addresses all Project GHG emissions sources including stationary sources subject to SCAQMD Rules. Even with application of mitigation, Project GHG emissions impacts are disclosed as significant and unavoidable. This is due primarily to infeasibility of fully mitigating mobile source GHG emissions (DEIR pp. 5.7- 23 to 5.7-29).
The City recognizes South Coast AQMD's role as a Responsible Agency under CEQA for purposes of issuing discretionary air quality permits and will consult with South Coast AQMD pursuant to CEQA Guidelines Section 15086, if the Project requires any such discretionary air quality permits. The EIR is hereby revised by reference to formally identify South Coast AQMD as a possible Responsible Agency.
This Final EIR, together with the EIR Air Quality Analysis and Health Risk Assessment (DEIR Appendices B1 and B2) and Greenhouse Gas Analysis (DEIR Appendix G) were prepared in accordance with South Coast AQMD guidance. Collectively, these documents provide sufficient Project description and environmental analysis, including evaluation of air quality and GHG impacts from stationary and portable equipment, to support South Coast AQMD's permit decisions. The City will coordinate with South Coast AQMD's Engineering and Permitting staff during the permit application process to ensure all equipment requiring air permits is properly identified and evaluated consistent with South Coast AQMD requirements.
Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
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A3-3 The comment asserts that the analysis underestimated mobile source emissions by applying truck trip lengths derived from SCAG's 2016 Regional Transportation Plan, and recommends instead using 40 miles for local trips and 80 miles for port-related trips based on the project's approximate distance from the Ports of Los Angeles and Long Beach. The City disagrees with the comment assertions. The comment provides not substantial evidence regarding why the DEIR trip length assumptions are not valid.
This comment conflates two analytically distinct contexts and mischaracterizes the basis for the trip lengths used. The 15.3-mile, 14.2-mile, and 40-mile trip lengths referenced in the DEIR analysis originate from SCAQMD's own Rule 2305 (WAIRE Program) regulatory framework.
More specifically, the vehicle class-specific trip lengths developed by SCAQMD for use in calculating regional emission burdens under that indirect source rule. These values therefore reflect SCAQMD's own determination of representative truck trip lengths applicable to warehouse land uses within the South Coast Air Basin. It would be inconsistent for SCAQMD staff to criticize the use of trip lengths that their own agency developed and codified into a regulatory program. The DEIR's air quality analysis appropriately incorporated SCAQMD- recommended truck trip lengths for emissions modeling.
Importantly, these trip lengths were not applied as flat, basin-wide averages. Rather, they were weighted against project-specific traffic percentages from the Heritage Valley Business Center Traffic Analysis (DEIR Appendix K1), the development-specific traffic study conducted for this Project. This weighting approach produced composite average truck trip lengths of
30.41 miles for the warehouse land use and 28.58 miles for the high cube cold storage land use. These results are notably higher than the underlying light- and medium-duty class defaults, precisely because the Project-specific fleet mix incorporates the proportional contribution of longer-haul HHDT trips already assigned a 40-mile trip length.
The regional trip lengths reflected in the DEIR analyses are consistent with standard air quality modeling practice and SCAQMD methodology, which recognizes that warehouse and distribution facilities serve diverse markets and generate trips to varied destinations throughout the region, not exclusively to the Ports of Los Angeles and Long Beach. While the Project site is located approximately 80 miles from the Ports, the comment's assumption that all or most truck trips would be Port-related is speculative and unsupported by substantial evidence regarding the Project's anticipated tenant operations or goods movement patterns.
The Project is a speculative warehouse development without identified tenants, and trip origins and destinations cannot be predetermined with certainty.
The DEIR's emissions analysis using SCAQMD-recommended trip lengths provides a reasonable and conservative assessment of regional air quality impacts. Even using these trip lengths, the analysis demonstrates that with implementation of Mitigation Measure MM AQ- 1, the Project would not exceed SCAQMD regional or localized significance thresholds for criteria pollutants or health risk (DEIR pp. 5.2-26 to 5.2-44). The Project would also be required to comply with SCAQMD Rule 2305 (Warehouse Indirect Source Rule), which independently requires warehouse operators to track and reduce emissions from mobile sources (DEIR p.
5.2-20).
For these reasons, the DEIR's use of SCAQMD-recommended regional truck trip lengths is appropriate, supported by substantial evidence, and provides a conservative basis for City of Menifee
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evaluating air quality impacts. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A3-4 The comment requests that the DEIR evaluate emissions impacts from the emergency standby diesel generator assuming up to 200 operating hours per year to reflect maximum potential emissions under a worst-case operational scenario. CEQA does not require an assumption of worst-case scenarios.
The DEIR's air quality and greenhouse gas analyses appropriately evaluate emissions from the Project's stationary equipment, including the emergency standby diesel generator. The air quality analysis (DEIR Appendix B1) includes stationary source emissions in the operational emissions calculations, which demonstrate that the Project would not exceed SCAQMD regional significance thresholds for criteria pollutants (DEIR Table 5.2-11, pp. 5.2-30–5.2-31).
Similarly, the greenhouse gas analysis (DEIR Appendix G ) includes stationary equipment emissions within the Project's total annual GHG emissions inventory.
The DEIR analysis is appropriately based on the likely maximum impact operational condition, consistent with CEQA guidance requiring evaluation of reasonably foreseeable impacts rather than speculative worst-case scenarios. The analysis assumes routine maintenance and testing operations consistent with typical industrial practice and regulatory limits for emergency standby equipment. In this regard, the DEIR assumed testing schedule is consistent with industry standard practice under National Fire Protection Association (NFPA) 110, the governing standard for emergency power supply systems, which requires diesel generator sets to be exercised at least once monthly for a minimum of 30 minutes. A weekly 15-minute test cycle is more frequent than the NFPA 110 minimum, and therefore represents a conservative assumption that, if anything, overstates testing-related emissions relative to what would be minimally required.
The comment suggests that analysis of emergency generator operations should assume the maximum permitted limit of 200 hours annually. However, this is a recommendation, not a CEQA requirement or regulatory mandate, and adopting it would produce a result inconsistent with reasonably foreseeable operations. SCAQMD permit conditions for emergency internal combustion engines cap maintenance and testing at no more than 50 hours per year, with hours beyond that threshold permitted only during actual loss-of-grid power events. Modeling generators at the full 200-hour annual limit would therefore assume sustained, large-scale grid outages. This is a speculative scenario that is neither reasonably foreseeable nor appropriate for inclusion in a CEQA analysis under CEQA Guidelines Section 15145. The analysis conservatively evaluated routine periodic testing, which is the only component of generator operation that can be considered reasonably foreseeable during normal Project operations. Emergency operation scenarios are speculative by definition and are appropriately excluded.
Further, the comment assumes extended generator operation during prolonged power outage conditions. Under such emergency conditions, it is unlikely that the Project would be fully operational as assumed in the DEIR operational analyses. During an extended power outage, warehouse operations including truck trips, transport refrigeration units, cargo handling equipment, and other mobile and stationary sources would be substantially reduced or curtailed. Any incremental increase in emergency generator emissions during such periods City of Menifee
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would be more than offset by the overall reduction in Project emissions under emergency power outage conditions, resulting in no net increase in environmental impacts beyond those evaluated in the DEIR.
Nonetheless, the City acknowledges South Coast AQMD's recommendation regarding permit conditions and recognizes that South Coast AQMD, as the Responsible Agency for stationary source permitting, has authority to establish permit conditions based on potential to emit (PTE). While the Project's environmental analysis is based on likely maximum impacts and reasonably foreseeable operational conditions (maintenance and testing operations consistent with typical practice), any permits issued by South Coast AQMD for the emergency standby generator may include operational limits based on PTE. Such permit conditions would be enforceable independent of CEQA and would ensure that actual emissions do not exceed levels evaluated in the DEIR.
The City will coordinate with South Coast AQMD during the permit application process to ensure that all applicable permit conditions, including operational hour limits, are properly incorporated into the air quality permit for the emergency generator. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A3-5 To clarify for the commenter, TRU emissions associated with the Heritage Valley Business Center Project were modeled for both on-site and off-site truck activity using a consistent methodology based on CARB's EMFAC2021 emissions inventory, as described at DEIR Appendix B1 Air Quality Analysis (pp. 42–43). Detailed assumptions and methodologies are presented below.
TRU Fleet Characterization and Operating Assumptions: The Project includes up to 80,000 square feet of high-cube cold storage use within the 829,755-square-foot industrial building (Appendix B1, p. 4). To account for refrigerated uses, trucks associated with the cold-storage land use are assumed to be equipped with TRUs (Appendix B1, p. 42). For modeling purposes, 33 trucks (66 two-way truck trips per day) have the potential to include TRUs, and TRUs are accounted for during both on-site and off-site travel (Appendix B1, p. 42).
TRU Emission Rate Calculation Methodology: TRU emission calculations are based on CARB's EMFAC2021, which provides emission inventories in tons per day based on annual activity levels, fuel consumption, and horsepower hours ( Appendix B1, p. 42). EMFAC2021 does not directly provide emission rates per hour or per mile as with the on-road emission model; therefore, the emission inventory was converted into emission rates to accurately calculate emissions from TRU operation associated with project-level details (Appendix B1, p. 42).
This conversion was accomplished by converting the annual horsepower hours to daily operational characteristics and converting the daily emission levels into hourly emission rates based on the total emission of each criteria pollutant by equipment type and the average daily hours of operation ( Appendix B1, p. 42). These project-specific hourly TRU emission rates were then applied to both on-site truck movement (including travel within the Project site to and from loading docks) and off-site roadway segments (Sherman Road, Ethanac Road, and Encanto Drive) to calculate total TRU emissions for air quality modeling purposes.
Application to On-Site and Off-Site Sources: The CalEEMod operational emissions model incorporates TRU emissions for all mobile source activity, including both on-site circulation and off-site roadway travel (Appendix B1, pp. 42 to 43, Table 4-10). For localized significance City of Menifee
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threshold (LST) analysis, on-site mobile emissions were modeled using a trip length of 1 mile for both trucks and passenger cars to establish a likely maximum impact scenario ( Appendix B1, p. 47). TRU emissions are included as a separate source category in the operational emissions summary and contribute 9.72 pounds per day of ROG, 10.19 pounds per day of NOX,
1.17 pounds per day of CO, 0.33 pounds per day of PM 10, and 0.30 pounds per day of PM 2.5 (Draft EIR, Table 5.2-11; Appendix B1, Table 4-10).
The methodology for calculating TRU emission rates, converting EMFAC2021 annual emission inventories to hourly rates based on equipment-specific horsepower hours and daily operating assumptions, is consistent with CARB guidance and provides a conservative estimate of TRU emissions for air quality modeling purposes. The Draft EIR's approach ensures that TRU emissions are accounted for across all truck activity (both stationary at loading docks and in transit on-site and off-site), and the resulting emissions do not exceed SCAQMD regional or localized significance thresholds. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A3-6 The DEIR recognizes Rule 2305's annual WAIRE Points Compliance Obligation upon occupancy (Draft EIR pp. 5.2–20). The DEIR addresses Rule 2305 compliance through LOR-7, which requires Project tenants to comply with SCAQMD Rule 2305 (Draft EIR p. 5.2–32).
Note further that the Project incorporates design features and mitigation measures that directly support future Rule 2305 compliance by aligning with WAIRE Points menu options.
These include MM GHG-4, which requires installation of conduits for electric vehicle charging at a ratio of one charging station for every 50 dock-high doors to accommodate future EV trucks (Draft EIR p. 5.7-27); MM GHG-7 , which requires installation of solar photovoltaic systems to offset at least 20 percent of the Project's energy demand (Draft EIR p. 5.7-27); and MM GHG-2, which requires all on-site outdoor cargo-handling equipment to be electric or non-diesel fueled (Draft EIR p. 5.7-27). Additional measures include LOR-6, requiring compliance with CALGreen electric vehicle charging standards (Draft EIR p. 5.2-32), and MM GHG-3, requiring documentation to tenants regarding clean truck funding programs such as the Carl Moyer Program (Draft EIR p. 5.7-27).
These measures facilitate warehouse operator compliance with Rule 2305 by providing infrastructure for zero-emission charging, on-site renewable energy, and zero-emission yard equipment—all of which are WAIRE Points menu options. Compliance with Rule 2305 is enforced by SCAQMD through their reporting process (Draft EIR p. 5.2-32). It is noted that future warehouse operators may contact SCAQMD staff for implementation guidance at (909) 396-3140 or [email protected]. Findings and conclusions of the EIR are not affected.
Revision to the EIR is not required.
A3-7 The City of Menifee acknowledges South Coast AQMD's comment letter and has herein provided written Responses to all comments as required by Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b). The Responses address each substantive environmental issue raised and are supported by factual information and analysis contained in the Draft EIR, technical appendices, and administrative record. Where the Lead Agency's position differs from SCAQMD recommendations, the Responses explain the basis for the City's conclusions with reference to substantial evidence in the record, consistent with CEQA Guidelines Section 15088(c). The City appreciates SCAQMD's technical expertise and will City of Menifee
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contact SCAQMD at the noted point of contact should additional questions arise. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
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Comment Letter A4 – City of Perris
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Responses to Comment Letter A4 – City of Perris
A4-1 The City of Menifee acknowledges and appreciates the City of Perris' comments on the Project and the DEIR. Responses to topical areas of concern expressed by the City of Perris are presented below.
Truck Access on Trumble Road
Per the DEIR Traffic Analysis (DEIR Appendix K1), it is assumed that truck traffic would not access the site via Trumble Road. As shown in Exhibit 1-2 and Exhibit 4-2 of the TA, the two driveways proposed along Trumble Road (Driveway 1 and Driveway 2) are designated as passenger vehicle access only, while truck ingress/egress is assumed to occur exclusively via Sherman Road through Driveway 3 and Driveway 4. The Project’s truck trip assignment and operational analyses were prepared consistent with this assumption, and the Heritage Valley Business Center Truck Routing Plan. The Truck Routing Plan would include physical signage to identify the path of travel for the trucks and note restricted movements. Furthermore, Section 1.6 of the TA evaluated truck access and circulation specifically at the Sherman Road driveways and intersection improvements necessary to accommodate heavy truck turning movements, reflecting the Project design intent to route truck traffic to Sherman Road rather than Trumble Road. No truck turning analyses were prepared for the Trumble Road driveways because trucks are not anticipated to utilize those access points. There is no indication at this time that the Project would result in or cause potentially significant environmental impacts due to truck traffic along Trumble Road. The City may impose conditions of approval formalizing prohibition of Project truck access to Trumble Road.
Project Landscaping
Regarding landscape screening, the Project applicant proposes approximately 263,583 square feet of landscaping including landscape improvements within the Trumble Road right-of-way, consisting of approximately 528 trees including property line screen trees and evergreen screen trees (DEIR page 3-5). The Project complies with Menifee North Specific Plan landscape standards, Menifee General Plan Community Design policies requiring landscaping to reduce land use conflicts and soften wall appearance (DEIR pages 5.1-6 to 5.1-7), and the Menifee Industrial Good Neighbor Policies requiring landscape buffers and berming for tall walls (DEIR page 5.1-8). The building is setback approximately 223 feet from Trumble Road (DEIR page
5.1-10). The Draft EIR concluded that with compliance with applicable development standards and design guidelines, the Project aesthetic impacts would be less than significant (DEIR pages
5.1-9 to 5.1-14).
The City of Perris comments do not provide substantial evidence of potentially significant environmental impacts requiring additional mitigation beyond the Project's current designs and compliance with applicable City of Menifee standards. The City of Menifee would, through established design review and permitting processes, ensure that the Project final designs conform materially to the Project described and evaluated in the DEIR. The Project Applicant will continue to coordinate with City of Perris staff on design considerations along the Project’s Trumble Road boundary. Findings and conclusions of the EIR are not affected.
Revisions to the EIR is not required.
City of Menifee
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A4-2 Coordination with City of Perris and Project Traffic Improvements The DEIR Traffic Analysis (TA) was prepared in coordination with both the City of Menifee and the City of Perris, with the TA Study Area (Study Area) reviewed and approved by both agencies. The Study Area includes nine intersections, of which five (Intersections 1, 2, 3, 4, and 7) are either fully or partially within City of Perris jurisdiction, including I-215 SB/NB Ramps at Ethanac Road, Encanto Drive/Ethanac Road, Trumble Road/Ethanac Road, and Sherman Road/Ethanac Road.
TA Table 1-4 identifies all recommended improvements by TA Analysis Scenario:
Existing (2025) Conditions (TA Section 3)
Existing plus Project (E+P) Conditions (TA Section 5) Existing plus Ambient Growth plus Cumulative (EAC) (2028) Conditions (TA Section 6) Existing plus Ambient Growth plus Project plus Cumulative (EAPC) (2028) Conditions (TA Section 6)
The Project would either construct the recommended improvements, or contribute fees toward the improvements via TUMF and DIF or fair-share contributions. Please refer to TA Section 1.5 Recommendations.
Signal phasing, timing, and turn-pocket design are addressed through the TA queuing and capacity evaluations. Please refer to the detailed analyses provided at TA Sections 5, 6, and 7 for each of the TA Analysis Scenarios. Final design, engineering and construction would be coordinated with the City of Perris and the City of Menifee for shared-jurisdiction facilities.
This would occur during the improvements permitting phase consistent with standard practices.
VMT Analysis: Employment Density and Land Use Factor
The DEIR VMT Analysis (DEIR Appendix K2 ) documents that the 829,755-square-foot warehouse was assigned an employment density factor of 1 employee per 1,030 square feet based on the Riverside County General Plan (there are no employment density factors identified in the City of Menifee General Plan), which is used by Menifee for calculating employees, resulting in 806 employees (VMT Analysis page 4). The DEIR VMT Analysis employment density factor is consistent with Riverside County General Plan factors and standard warehouse employment ratios. These results are summarized at DEIR Table 5.13-4 Project VMT per Employee.
This socioeconomic data input was then appropriately coded into the RIVCOM transportation model to isolate Project-generated VMT under both baseline (2018) and cumulative (2045) conditions.
The comment does not provide substantial evidence demonstrating that this employment density factor is inappropriate for the Project warehouse use or that an alternative factor would materially change the DEIR VMT significance conclusion.
VMT Analysis: VMT Mitigation Measures
DEIR mitigation measures MM TRA-1 through MM TRA-3 represent the feasible range of VMT mitigation for this speculative warehouse project, located in a suburban (semi-rural) context City of Menifee
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for several reasons that are grounded in Project type, locational context, and the structure of the California Air Pollution Control Officers Association (CAPCOA) Handbook.
Project Type and Applicable CAPCOA Subsectors: The CAPCOA Handbook organizes VMT reduction measures into seven transportation subsectors: Land Use, Neighborhood Design, Parking or Road Pricing/Management, Transit, Trip Reduction Programs, Clean Vehicles and Fuels, and School Programs. Of these seven subsectors, only the Trip Reduction Programs subsector is applicable to an employment-generating warehouse development such as the Project. Measures in the Land Use and Neighborhood Design subsectors apply to residential or mixed-use development projects with control over street patterns, building orientation, and neighborhood-scale amenities. These elements are not applicable to a single-use industrial warehouse. Parking pricing measures are infeasible for warehouse operations where employees require vehicle access and where shift-based operations limit transit alternatives. The Transit subsector requires proximity to high-quality transit service, which the Project lacks, as confirmed by the VMT screening analysis showing the Project does not qualify as a Transit Priority Area (VTA Analysis page 2). Clean Vehicles and Fuels measures address vehicle fleet operations controlled by the tenant/operator, not the developer of a speculative development such as the Project. School Programs are categorically inapplicable to industrial uses.
Locational Context—Suburban (Semi-Rural) Setting: The VMT Analysis confirms that the Project's locational context is suburban, defined by the CAPCOA Handbook as "an area characterized by dispersed, low-density, single-use, automobile dependent land use patterns, usually outside of the central city." The Project is not located within a Transit Priority Area (within one-half mile of an existing major transit stop or high-quality transit corridor), does not qualify as a Low VMT Area, and is situated in a location where existing transit service and alternative transportation infrastructure are limited. These locational constraints eliminate the feasibility of measures that depend on urban density, mixed-use proximity, or robust transit infrastructure. The suburban context also explains why measures such as neighborhood-scale bikeway networks, pedestrian-oriented street design, and transit pass subsidies would at best achieve minimal VMT reduction, as employees are dispersed across the region and commute patterns are automobile-dependent.
Speculative Project Nature and Tenant Control: The DEIR and VMT Analysis recognize that "the building is speculative in nature" (DEIR page 1-3) and that "generally, trip reduction programs are more appropriate for the occupant/tenant (i.e., employer) to implement and monitor rather than the building owner or developer" (VMT Analysis page 7). These constraints are critical because many potential VMT reduction strategies, such as employer-based telecommuting policies, compressed work week schedules, shift-time flexibility, or operational changes to reduce truck trips, are under the control of the future tenant, not the developer. The CAPCOA methodology requires that mitigation measures be enforceable and within the project applicant's control. MM TRA-1 through MM TRA-3 address this limitation by requiring the developer to provide the physical infrastructure and programmatic framework (commute marketing, TMA establishment, end-of-trip facilities) that future tenants must implement, with 90 percent employee eligibility assumed based on typical warehouse shift operations.
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Maximum Subsector Reduction and Calculation Methodology: The CAPCOA Handbook states that the Trip Reduction Programs subsector has a maximum allowable reduction of 45 percent, and that measure reductions within a subsector must be multiplied (not added) unless substantial evidence shows independence. The combined reduction from MM TRA-1 (3.6 percent), MM TRA-2 (3.6 percent), and MM TRA-3 (0.1 percent) totals 7.2 percent using the multiplicative formula: 1 - [(1-0.036) × (1-0.036) × (1-0.001)] = 7.2 percent (VMT Analysis page 9).
Absence of Other Feasible VMT Mitigation: The Draft EIR appropriately concludes that "given the nature of operations of warehouse uses and location of the site, there are no other feasible mitigation measures that would further reduce employee-generated VMT associated with Project operations” (DEIR Page 5.13-26). This conclusion is supported by the systematic CAPCOA analysis, which demonstrates that measures outside the Trip Reduction Programs subsector are categorically inapplicable, and that additional measures within that subsector either require tenant-level control or depend on infrastructure (e.g., proximate transit, urban density, mixed-use context) that does not exist in the Project suburban location. CEQA does not require implementation of mitigation to reduce all impacts to less-than-significant levels if no feasible measures exist. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A4-3 CEQA Noticing
Pursuant to CEQA Guidelines Section 15086(a), the City of Menifee has provided the Draft EIR to the City of Perris for review during the public review period. The City of Menifee will continue to provide CEQA notices to the City of Perris consistent with applicable requirements, including notices of public hearings and the EIR Notice of Determination.
Collaborative Resolution
The Draft EIR and these Responses address the City of Perris's comments regarding truck access, landscape/screening edge treatments, traffic signal coordination, VMT employment density assumptions, and VMT mitigation measures. The DEIR TA identifies all recommended improvements at shared-jurisdiction intersections and establishes the Project's responsibility for constructing improvements and contributing TUMF fees or fair-share funding for required improvements. The City of Menifee will continue coordinate with the City of Perris during subsequent Project review and development stages. The City of Menifee appreciates the City of Perris's constructive engagement in the Project and environmental review processes.
Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
City of Menifee
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Comment Letter A5 - California Department of Transportation
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Responses to Comment Letter A5 – California Department of Transportation A5-1 Caltrans review of the DEIR is recognized. The Project and its discretionary actions as summarized by Caltrans are materially correct. The Applicant or successor in interest will timely coordinate with Caltrans regarding any work within Caltrans right-of-way. The Applicant or successor in interest will acquire all requisite Caltrans encroachment permits prior to construction and/or Project operations begin. Findings and conclusions of the DEIR are not affected. Revision to the DEIR is not required.
A5-2 The comment is acknowledged. The Lead Agency and Applicant will continue to coordinate with Caltrans LDR, and will submit any revised plans and a written response to all LDR comments in conjunction with any Caltrans encroachment permit application(s).
Based on the timing of filing the application for the proposed Project, the Project is exempt from Assembly Bill 98 requirements. Findings and conclusions of the DEIR are not affected.
Revision to the DEIR is not required.
A5-3 The comment correctly identified the DEIR conclusion that the Project's VMT impacts would be significant and unavoidable. The Lead Agency recognizes and appreciates Caltrans stated support of the DEIR proposed VMT mitigation measures. Findings and conclusions of the DEIR are not affected. Revision to the DEIR is not required.
A5-4 In conjunction with development of final designs, the Applicant or successor in interest will provide verification of sufficient right-of-way for proposed improvements, and layout recommended improvements within State right-of-way. Findings and conclusions of the DEIR are not affected. Revision to the DEIR is not required.
A5-5 The comment is acknowledged. The applicant will pay fair share and any required studies will take place during the planning of the offsite imrovements.
A5-6 The comment is acknowledged. Any required studies will take place during the planning of the offsite imrovements.
A5-7 The comment states that the City of Menifee (Lead Agency) shall evaluate whether Terminal Access approval is required if Surface Transportation Assistance Act1 (STAA) trucks access the State Highway System via the on- and off-ramps from the proposed development.
A5-8 Right-of-way requirements for Trumble Road, Sherman Road, and Ethanac Road listed by Caltrans are noted. The Applicant of its successor interest will provide all required information in conjunction with Caltrans Encroachment Permit application(s). Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A5-9 The Lead Agency has considered Caltrans’ request to omit certain cumulative projects from the TA cumulative analysis. The comment is noted, but the requested change is not necessary and would not alter the conclusions of the analysis.
1 Under federal law, STAA trucks are truck tractor/semitrailer or double trailer combinations that meet national size standards (such as 102 inch width and up to 53 foot semitrailers) established by the Surface Transportation Assistance Act of 1982. In states like California, “STAA Vehicle (Truck)” is defined as any truck that exceeds the usual state legal length limits but complies with these federal STAA dimension standards.
City of Menifee
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The list of cumulative projects and the associated Cumulative Development Map (Exhibit 4-5) were developed in coordination with, and reviewed and approved by, the City of Menifee as Lead Agency. Although certain of the listed projects may have limited potential to affect the study area intersection operations, retaining these projects in the cumulative scenario provides a conservative and robust evaluation of potential traffic conditions within the study area. Including these projects ensures that cumulative traffic impacts are not understated and that the analysis reasonably captures potential variability in driver route choice and network usage over time.
Even if the referenced projects were removed from the TA Cumulative Development Land Use Summary, the resulting reduction in cumulative traffic volumes at the study area intersections would be modest and would not meaningfully affect the TA findings or the EIR's conclusions regarding the significance of cumulative traffic impacts. For this reason, and given that the current cumulative project list reflects the Lead Agency's direction and provides a conservative basis for analysis, no revisions to the cumulative project list, map, or traffic analysis are proposed at this time.
The Project TA fair-share fee contribution(s) for area improvements are planning-level estimates only and are subject to refinement and final determination by the Lead Agency through its adopted fee programs, conditions of approval, and/or subsequent implementation agreements. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A5-10 The Lead Agency requires that all Project improvements, including those affecting Caltrans facilities, be designed and constructed consistent with applicable ADA Standards. The Lead Agency will ensure maintenance of bicycle and pedestrian access throughout the Project construction phase. These requirements are implemented and enforced through established City development review, building permit, and site inspection processes. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
A5-11 Caltrans' encroachment permit requirements and the provided contact information are acknowledged. The City, as Lead Agency, will coordinate with Caltrans through completion of the entitlement and environmental review process; subsequent Caltrans involvement will occur through the encroachment permit process. The City appreciates Caltrans participation in the Project and environmental review processes. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
City of Menifee
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Comment Letter A6 – Riverside Transit Agency
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Responses to Comment Letter A6 – Riverside Transit Agency A6-1 Comment noted, no further response is warranted.
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Comment Letter A7 – Riverside County Flood Control Water Conservation District
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Responses to Comment Letter A7 – Riverside County Flood Control and Water Conservation District
A7-1 The comment is introductory and no further response is warranted.
A7-2 Comment noted. No substantial environmental impacts are mentioned. No further response is warranted.
A7-3 Comment noted. No substantial environmental impacts are mentioned. Please refer to Section 5.9: Hydrology and Water Quality of the Draft EIR for information regarding compliance with applicable regulations and Section 5.3: Biological Resources of the Draft EIR for discussion of compliance with the MSHCP. No further response is warranted.
A7-4 Comment noted. The City will continue to coordinate with Riverside County Flood Control and Water Conservation District on the Project. No further response is warranted.
A7-5 Comment noted. Please refer to Response A7-3 above regarding compliance with applicable regulations. Regarding the referenced comment letter dated June 9, 2025, please see Response A7-7 below. No substantial environmental impacts are mentioned and no further response is warranted.
A7-6 The comment is conclusionary and does not mention substantial environmental impacts. See Section 5.9: Hydrology and Water Quality of the Draft EIR for information regarding compliance with applicable regulations. No further response is warranted.
A7-7 The letter dated June 9, 2025 is outside of the comment period, however it is included for informational purposes. The letter contains similar information to the comment received on April 13, 2026. Please refer to Responses A7-2 through A7-6, above. No further response is warranted.
City of Menifee
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Comment Letter O1 – Advocates for the Environment
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Responses to Comment Letter O1 – Advocates for the Environment O1-1 The City acknowledges Advocates for the Environment's (AFE) comment letter. The comment description of the Project conforms materially to the Project as presented in the Draft EIR.
AFE comments regarding greenhouse gas emissions are addressed in the responses that follow. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
O1-2 The City disagrees with the comment assertions. The City acknowledges the comment’s advocacy for a net zero greenhouse gas (GHG) significance threshold and the references to global building sector emissions, state climate policy, and CARB’s Climate Change Scoping Plans. However, CEQA does not require a lead agency to adopt a net zero numerical threshold for project level GHG analysis, nor does any state agency mandate that individual discretionary projects be evaluated against a net zero standard at this time. Instead, CEQA Guidelines direct lead agencies to exercise careful judgment, based on scientific and factual data, in selecting thresholds and methodologies appropriate to the agency’s jurisdiction and the type of project under review (Draft EIR, Section 5.7.4).
As described at DEIR Section 5.7, the City relied on the South Coast Air Quality Management District’s (SCAQMD’s) recommended Tier 3 screening concepts and substantial evidence in the SCAQMD Interim GHG Significance Threshold guidance to select a numeric threshold of 3,000 MTCO2e per year for industrial/warehouse projects. Notably, this is more conservative than the 10,000 MTCO 2e per year industrial threshold adopted by the SCAQMD Governing Board for projects where SCAQMD is the lead agency (Draft EIR, pp. 5.7-18 to 5.7-22). The City has not adopted a net zero GHG significance threshold, and there is no requirement under CEQA or any applicable state regulation that the City do so for this Project. The comment’s preference for a more stringent, net zero threshold represents a policy view rather than a CEQA obligation.
The comment cites CARB’s 2017 and 2022 Scoping Plans and Appendix D to the 2022 Scoping Plan as support for a net zero threshold. As the Draft EIR explains, Appendix D to the 2022 Scoping Plan focuses primarily on climate action plans and local authority over new residential and mixed use residential development projects; CARB expressly states that the recommendations in this section “apply only to residential and mixed use development project types” and that it “plans to continue to explore new approaches for other land use types in the future” (Draft EIR, p. 5.7-12). Industrial warehouse uses, such as the Project, are not within the land use categories covered by Appendix D’s recommended local “net zero” strategies. Accordingly, it would be inappropriate and unsupported by CARB’s own language to treat Appendix D as requiring or even directly endorsing a net zero project level threshold for this industrial/warehouse use.
The Draft EIR further documents that the Project has been evaluated against the existing regulatory framework designed to achieve statewide climate targets, including AB 32, SB 32, AB 1279 (carbon neutrality by 2045), SB 100, and CARB’s Cap and Trade Program and transportation-sector rules, among others (Draft EIR, pp. 5.7-13 to 5.7-21, 5.7-28, 5.7-29). The GHG analysis uses CalEEMod (2022.1) to quantify construction and operational emissions, incorporates applicable laws, ordinances, and regulations (LOR 1 through LOR 8), and imposes Project specific mitigation measures ( MMs GHG-1 through GHG-7) such as electrification of on site cargo handling equipment, EV ready infrastructure, and installation of a photovoltaic City of Menifee
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system sized to offset at least 20 percent of the Project’s projected energy demand (Draft EIR, pp. 5.7-25 to 5.7-27). With these measures, the Project would be consistent with applicable elements of the 2022 Scoping Plan and the City’s General Plan policies OSC 9.5, OSC 10.1 through OSC 10.4, and C 1.5 (Draft EIR, pp. 5.7-20, 5.7-28, 5.7-29).
Despite implementation of all feasible measures, the Project’s net annual GHG emissions (approximately 6,492 MTCO2e per year) would exceed the City’s adopted 3,000 MTCO 2e per year threshold, and the Draft EIR transparently discloses this as a significant and unavoidable impact (Draft EIR, pp. 5.7-23 to 5.7-29). The analysis also explains that approximately 87 percent of the Project’s GHG emissions are from mobile sources, which the City cannot directly regulate beyond enforcing applicable state and regional requirements; even if all other source categories were reduced to zero, mobile emissions alone would exceed the numeric threshold (Draft EIR, p. 5.7-24). Under CEQA, the appropriate course where all feasible mitigation has been imposed and a significant impact remains is to disclose the impact and, if the project is approved, adopt a Statement of Overriding Considerations, not to impose an infeasible requirement that the project achieve net zero emissions.
The comment references large mixed use developments (Newhall Ranch/FivePoint Valencia and Centennial) that ultimately advanced as net zero communities after CEQA litigation.
Those projects involved different lead agencies, land use types, sizes, and regulatory/policy contexts, and their negotiated settlement outcomes do not establish a statewide CEQA requirement that all new projects, particularly industrial warehouse projects such as this one, must be net zero to avoid significant GHG impacts. CEQA allows, but does not mandate, lead agencies to adopt different thresholds and mitigation approaches based on substantial evidence and local circumstances. The City’s selection of a conservative 3,000 MTCO 2e per year threshold, coupled with robust regulatory compliance and mitigation, is supported by substantial evidence in the record (Draft EIR Section 5.7 Greenhouse Gas Emissions , DEIR Appendix G Greenhouse Gas Analysis).
Finally, as discussed at DEIR Section 5.7.6, GHG impacts are inherently cumulative, and an individual project of this size is of insufficient magnitude by itself to substantially influence global climate conditions; instead, the Project’s contribution is considered in the context of the State’s comprehensive programmatic framework for achieving long term climate targets.
The City has analyzed the Project’s consistency with that framework, disclosed that the Project would exceed the numeric threshold and could impede achievement of interim statewide GHG reduction goals. The City has identified mitigation that would reduce these impacts to the extent feasible. CEQA does not require the City to deny the Project or to require net zero emissions when doing so has not been shown in the record to be feasible for this particular industrial warehouse use. For these reasons, the City declines to revise its GHG significance threshold to a net zero standard for this Project, and the Draft EIR’s GHG analysis and conclusions remain unchanged. Findings and conclusions of the EIR are not affected.
Revision to the EIR is not required.
O1-3 The City disagrees with the comment assertions. As described in the Draft EIR and within these Responses, the Project’s net annual GHG emissions, including amortized construction emissions, are estimated at approximately 6,492 MTCO 2e per year. Project GHG emissions would therefore exceed the City’s adopted 3,000 MTCO 2e per year significance threshold derived from SCAQMD’s recommended Tier 3 screening levels. In response, the Draft EIR City of Menifee
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identifies a combination of existing laws, ordinances, and regulations (LOR 1 through LOR 8) and project level Mitigation Measures MM GHG-1 through MM GHG-7 to reduce GHG emissions, while transparently disclosing that a significant and unavoidable impact would remain (Draft EIR, pp. 5.7-23 to 5.7-29).
Contrary to the comment’s assertion, CEQA does not require that each mitigation measure’s quantitative GHG reduction be individually modeled, so long as the lead agency uses a reasonable methodology and explains, based on substantial evidence, why impacts remain significant even with feasible mitigation. Aggregate GHG emissions reductions from the EIR GHG mitigation measures are modeled per accepted CalEEMod protocols and are reflected in the total Project GHG emissions. However, precise reductions for these measures are limited and would not meaningfully reduce emissions as discussed in the greenhouse gas report (see Pg 49-50). The Draft EIR uses the most current version of CalEEMod available at the time (2022.1) to quantify construction and operational GHG emissions and recognizes that some regulatory and technological measures (e.g., future EV usage and Rule 2305 implementation) are not easily or reliably quantified at the project level (DEIR p. 5.7-25, DEIR Appendix G). The analysis explains that even if emissions from all non mobile source categories were reduced to zero, mobile source emissions alone would still exceed the 3,000 MTCO 2e per year threshold, and therefore, even aggressive mitigation would not avoid a significant impact (Draft EIR, pp. 5.7-22 to 5.7-29).
The comment characterizes MM GHG-3 as “unlikely to be effective” because it requires only that the Applicant provide information on funding opportunities, such as the Carl Moyer Program, to tenants. However, this measure is merely part of a broader package of GHG mitigation that includes mandatory operational controls and infrastructure commitments directly imposed on the Applicant, such as anti idling signage and enforcement (MM GHG-1), full electrification or non diesel fueling of on site cargo handling equipment ( MM GHG-2), installation of EV truck conduit and hookups ( MM GHG-4), EV ready passenger car parking (MM GHG-5 ), exclusive use of electric landscaping equipment ( MM GHG-6 ), and a photovoltaic system sized to offset at least 20 percent of the Project’s projected energy demand ( MM GHG-7 ) (Draft EIR, p. 5.7-27). MM GHG-3 is intended as a supplemental mechanism to encourage voluntary accelerated turnover to cleaner than required equipment by tenants, over and above regulatory baselines and the other, more directly enforceable mitigation measures already committed to by the Applicant.
With respect to the comment’s suggested revisions to MM GHG-3 and additional lease based requirements (e.g., contractual mandates to apply for incentive programs, categorical limits on diesel truck use, wholesale replacement of diesel with alternative fuels, or binding commitments to future zero emission commercial vehicle fleets and on site charging powered exclusively by solar), the Draft EIR explains why further mobile source reductions beyond those embedded in statewide and regional programs and that would result from the EIR mitigation measures are not feasible at this time. As discussed in the DEIR, approximately 87 percent of the Project’s GHG emissions are from vehicle usage that is controlled principally through state and regional mobile source standards and CARB programs; the City does not regulate truck fleet procurement or engine technology and cannot ensure that future tenants’ regionally distributed truck fleets will be subject to project specific conditions (Draft EIR, pp.
5.7-24 to 5.7-25, 6-8 to 6-9). The EIR explicitly states that “Neither the Project Applicant nor City of Menifee
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the Lead Agency can substantively or materially affect reductions in project related vehicular source emissions beyond regulatory requirements imposed by the federal or state governments or the SCAQMD, and mitigation measures identified herein” and concludes that “there are no feasible mitigation measures that would reduce vehicular emissions” beyond those already incorporated (Draft EIR, pp. 5.7-24 to 5.7-25, 6-8 to 6-9).
The comment’s suggested measures would also conflict with or duplicate comprehensive statewide programs that already govern the transition of medium and heavy duty fleets to zero emission technologies, such as CARB’s Advanced Clean Trucks, Advanced Clean Fleets, Low Carbon Fuel Standard, and other off road and on road rules identified in the Draft EIR’s discussion of 2022 Scoping Plan consistency (Draft EIR, pp. 5.7-11 to 5.7-12, 5.7-28). CEQA does not require a local land use agency to impose project specific fleet procurement mandates on private tenants where such requirements would be speculative with respect to future operators, could conflict with ongoing regulatory programs, and would be impracticable to monitor and enforce over the multi decade life of a warehouse facility. The City reasonably relies instead on the combination of statewide mobile source regulations, SCAQMD Rule 2305 (Warehouse ISR), and the Project’s infrastructure and operational commitments to support future emission reductions (Draft EIR, pp. 5.7-20 to 5.7-25, 5.7-27 to 5.7-29).
Regarding the comment’s suggestion that the City adopt additional transportation demand management (TDM) measures as GHG mitigation, the Draft EIR already requires TDM type trip reduction measures through MM TRA-1 , MM TRA-2 , and MM TRA-3 , which together implement commute trip reduction marketing, a ridesharing program with a permanent transportation management association, and end of trip bicycle facilities (Draft EIR, pp. 5.13- 25 to 5.13-27). These measures are anticipated to reduce the Project’s total vehicle miles traveled (VMT) by approximately 7.2 percent, but, even with implementation of all feasible transportation mitigation, the Project cannot achieve the 30.6 percent VMT reduction needed to meet the City’s VMT significance threshold and therefore results in a significant and unavoidable VMT impact (Draft EIR, pp. 5.13-25 to 5.13-27, pp. 6-8, 6-9). Because GHG emissions are strongly correlated with VMT, the same practical and enforceability constraints that limit further VMT reduction also constrain the extent to which additional TDM measures could feasibly and demonstrably reduce project level GHG emissions. Please refer also to FEIR Comment A4-2 Response.
CEQA requires a lead agency that identifies a significant and unavoidable impact to adopt all feasible mitigation and then, if it approves the project, to adopt a Statement of Overriding Considerations explaining why the project’s benefits outweigh the residual impacts; it does not require the City to prove that every conceivable mitigation concept is infeasible. The Draft EIR identifies specific GHG mitigation measures, explains why mobile source dominated emissions remain above the 3,000 MTCO2e per year threshold even with these measures and regulatory compliance, and expressly concludes that Project GHG emissions impacts would be significant and unavoidable (Draft EIR, pp. 5.7-23 to 5.7-29, 6-8 to 6-9). Given the dominance of mobile sources, the jurisdictional and practical limits on regulating off site truck fleets, and the existence of comprehensive state programs governing vehicle technology, the City’s determination that no additional feasible GHG mitigation is available is supported by substantial evidence in the record. For these reasons, the City declines to revise or add to the City of Menifee
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May 2026 2-50 2.0 | Comments and Responses
EIR GHG mitigation measures. The EIR’s GHG mitigation and significance conclusions remain unchanged. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
O1-4 The City disagrees with the comment’s assertions. The City acknowledges the comment reference to Napa Citizens for Honest Gov’t v. Napa County Board of Supervisors and the suggestion that CEQA requires “fair share” mitigation for cumulative GHG impacts. However, Napa Citizens is mischaracterized by the comment. Contrary to comment assertions, the Napa Citizens decision holds that a lead agency must adopt all feasible, evidence supported mitigation for cumulative impacts and explain its reasoning. The decision does not require that an agency must mathematically eliminate a project’s entire cumulative contribution.
As explained at DEIR Section 5.7, the Draft EIR quantifies the Project’s annual GHG emissions using CalEEMod 2022.1, amortizes construction emissions over a 30 year project life consistent with SCAQMD practice, and compares the resulting net annual emissions (approximately 6,492 MTCO 2e per year) to the City’s 3,000 MTCO 2e per year significance threshold derived from SCAQMD’s Tier 3 screening approach (DEIR, pp. 5.7-22 to 5.7-24).
Because those annual emissions exceed this conservative threshold even with compliance with applicable laws, ordinances, and regulations (LOR 1 through LOR 8) and implementation of MM GHG-1 through MM GHG-7 , the Draft EIR properly discloses a significant and unavoidable GHG impact (DEIR, pp. 5.7-23 to 5.7-25, 5.7-29). CEQA requires the adoption of all feasible mitigation and good faith disclosure of any remaining significant impact; it does not require a single project to offset 100 percent of its modeled lifetime emissions.
The comment’s “fair share” estimate of roughly 195,000 MTCO 2e assumes that CEQA significance must be judged on a 30 year cumulative total, but CEQA Guidelines section 15064.4 instead directs lead agencies to use a reasonable quantitative analysis, such as annual emissions compared to a scientifically and policy supported threshold, together with consideration of statewide climate programs. The City follows that approach here by evaluating amortized construction and operational emissions on an annual basis against the 3,000 MTCO 2e threshold, which itself is designed to capture approximately 90 percent of emissions from future development (DEIR, pp. 5.7-21 to 5.7-24). The fact that the Project still exceeds this benchmark, even with robust mitigation, is the reason the impact is determined to be significant and unavoidable, not, as the comment suggests, because the City views the remaining emissions as “acceptable” or unworthy of consideration.
The comment also makes several conclusory statements that “more” mitigation is available without showing, with facts or analysis, that the suggested concepts are both technically and economically feasible for this specific warehouse project or that they would materially change the Project’s GHG emissions profile. In contrast, the Draft EIR identifies specific, enforceable measures (including Title 24 and CALGreen requirements, SCAQMD Rule 2305 compliance, and MM GHG-1 through MM GHG-7) and explains why, given that approximately 87 percent of GHG emissions are from vehicle usage outside the City’s and the Project applicant’s direct control, no additional feasible measures have been identified that would reduce annual emissions below the adopted threshold (DEIR, pp. 5.7-20 to 5.7-25). Accordingly, the City concludes that the Draft EIR provides the kind of reasoned, evidence based analysis CEQA requires. Please refer also to previous Comment O1-3 Response.
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-51 2.0 | Comments and Responses
The comment does not demonstrate that the City has failed to adopt feasible mitigation or has misapplied Napa Citizens. Further, the City disagrees with the comment assertion that the Draft EIR fails to require all feasible GHG mitigation or that additional measures such as mandatory LEED certification, wholesale electrification of construction equipment, 100 percent rooftop solar, or project specific offset purchases are required or feasible for this Project. The GHG analysis and mitigation program presented in Section 5.7 of the Draft EIR remain adequate and supported by substantial evidence, and no revisions are warranted in response to this comment. The comment’s request to be added to the Project interest list pursuant to Public Resources Code section 21092.2 has been noted and will be honored by the City. Findings and conclusions of the EIR are not affected. Revision to the EIR is not required.
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-52 2.0 | Comments and Responses
Comment Letter O2 – Adams Broadwell Joseph and Cardozo
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-53 2.0 | Comments and Responses
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-54 2.0 | Comments and Responses
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-55 2.0 | Comments and Responses
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-56 2.0 | Comments and Responses
Responses to Comment Letter O2 – Adams Broadwell Joseph and Cardozo O2-1 Comment noted. The commenter is added to the interest list for the Project. No further response is warranted.
O2-2 The comment includes introductory information about the Project and topics unrelated to CEQA or substantial environmental impacts. No further response is warranted.
O2-3 Comment noted. The commenter is added to the interest list for the Project. No further response is warranted.
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-57 2.0 | Comments and Responses
Comment Letter I1 – Alex Munoz
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 2-58 2.0 | Comments and Responses
Responses to Comment Letter 11 – Alex Munoz
I1-1 The comment is noted. Section 5.13: Transportation provides information on potential Project traffic impacts. No further response is warranted.
City of Menifee
Heritage Valley Business Center Project Final Environmental Impact Report
May 2026 3-1 3.0 | Errata
3.0 ERRATA TO THE DRAFT EIR
3.1 INTRODUCTION TO THE ERRATA
In accordance with Section 15132 of the CEQA Guidelines, the FEIR for the Heritage Valley Business Center Project includes the DEIR, dated March 2026, as well as any proposed revisions or changes to the DEIR.
The changes to the DEIR do not affect the overall conclusions of the environmental document, and instead represent changes to the DEIR to provide clarification, amplification and/or insignificant modifications, as needed as a result of public comments on the DEIR, or due to additional information received during the public review period. These clarifications and corrections do not warrant recirculation of the DEIR pursuant to CEQA Guidelines Section 15088.5.
None of the changes or information provided in the comments identify a new significant environmental impact, a substantial increase in the severity of an environmental impact for which mitigation is not proposed, or a new feasible alternative or mitigation measure that would clearly lessen significant environmental impacts but is not adopted. In addition, the changes do not reflect a fundamentally flawed or conclusory DEIR.
Changes to the DEIR are listed by Section, page, paragraph, etc. to best guide the reader to the revision.
Changes are identified as follows:
Deletions are indicated by strikeout text.
Additions are indicated by underlined text.
3.2 CHANGES TO THE DRAFT EIR
No changes to the Draft EIR have been identified.