Within a year, a status review report will be provided to the commission to be considered at another commission meeting. The commission will then decide whether the listing is warranted. If not, the process ends, and the species will be removed from the list of candidate species. If the commission finds the listing is warranted, the species will be added to the list of endangered species in California Fish and Game Code Section 670.5 (animals) through a regulation change. Notice of this change will be given and the regulation change filed with the California Office of Administrative Law, which has up to 30 business days to review it. Thereafter, the regulation will be filed with the California Secretary of State and becomes effective. The listing process ultimately takes approximately 1.5 to 2 years to complete. For additional information, please visit https://fgc.ca.gov/cesa.
The Draft SEIR did evaluate potential impacts to burrowing owl and adopted mitigation. Refer to responses to comments O4-5 to O4-6, below.
O4-5 The comment states that the Draft SEIR acknowledges the potential presence of burrowing owls in the construction zone. It excerpts a quote from Mitigation Measure (MM) BIO-1: “following the fledging of young from any active burrows, or if active burrows are detected outside of the nesting season, or during the nesting season but it has been determined that the burrow is not being used as a nest burrow, burrowing owls can be excluded from use of the burrow following CDFW protocols” (Draft SEIR Section 4.4, p. 4.4-33). The comment states this language implies that passive relocation of owls will occur. It asserts this method does not mitigate habitat loss, habitat fragmentation, and reduced owl survivorship caused by development. It questions the effectiveness of passive and active relocation as mitigation for impacts to burrowing owl.
In response, first, as discussed in the Draft SEIR (Section 4.4, pp. 4.4-8 and 4.4-24) and the Biological Technical Report (Draft SEIR Appendix E), extensive protocol surveys for burrowing owl were conducted on the Project site in accordance with the Western Riverside MSHCP requirements. Initially, a Step 1 habitat assessment was conducted per the Burrowing Owl Survey Instructions for the Western Riverside MSHCP Area (RCA 2006). Based on this assessment, focused protocol-level burrowing owl surveys were conducted in 2023 following MSHCP guidance and the CDFW Staff Report on Burrowing Owl Mitigation (CDFG 2012; Draft SEIR Appendix E, pp. 13–14). These surveys included multiple survey passes for burrowing owl individuals, suitable burrows or burrow surrogates (artificial openings such as pipes, culverts, rock piles, etc.), and any signs indicating owl presence (i.e., owl pellets, molted feathers, abundant insect remains, and whitewash).
As indicated in the Biological Technical Report and as summarized in the Draft SEIR (Section 4.4.4.2, pp. 4.4-23 through 4.4-31), no burrowing owl individuals, indicative signs, or active burrows were observed during the 2023 focused owl survey effort (Draft SEIR Section 4.4, pp. 4.4-8, 4.4-24). One 2 - RESPONSE TO COMMENTS
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burrowing owl was incidentally observed within the central portion of the Project site on January 13, 2023, during fairy shrimp protocol surveys. Since this individual was not observed during the breeding season, it was concluded that this individual was likely using the Project site temporarily during the winter months for foraging and potential roosting, which is typical during the non-breeding season when owls are relatively nomadic. No burrowing owls were observed in this area of the site or elsewhere on the site during the subsequent 4 months of fairy shrimp surveys. Additionally, no owls or recent signs were observed at or near this burrow during the focused burrowing owl survey effort in the summer (Draft SEIR Section 4.4, pp. 4.4-24 through 4.4-25).
Second, the Project site is generally considered low-quality habitat for burrowing owls. The site’s soils are compacted and not as friable due to the extensive grading since the 1999 EIR, limiting the species’ potential to occur in most areas. Roughly 70% of the Project site is characterized as highly disturbed due to past grading and other activities (Draft SEIR Section 4.4.1, pp. 4.4-1 through 4.4-14; see also Figure 3-4, p. 3-35). Consequently, the Project site is low-quality habitat for burrowing owls.
Third, the burrowing owl is a covered species under the Western Riverside MSHCP (Draft SEIR Sections
4.4.2, pp. 4.4-15 through 4.4-21, and 4.4.4.2, pp. 4.4-23 through 4.4-31). Any impacts to individual owls or related to habitat loss are authorized and mitigated by the take coverage, reserve assembly, and various conservation measures included in the MSHCP. The MSHCP’s reserve assembly will form a 500,000-acre habitat reserve to benefit regional animal species, including at least 27,470 acres of suitable primary habitat and 22,120 acres of suitable secondary habitat for burrowing owl.16 The Regional Conservation Authority is on track to meet this goal with over 347,000 acres conserved (RCA 2024). Burrowing owl survey and reporting requirements ensure adequate monitoring and implementation of adaptive management strategies, as appropriate, by the Regional Conservation Authority.17 The Western Riverside MSHCP and related Final MSHCP EIR/EIS (SCH No. 2001101108) are incorporated by reference. Please refer to the following links for the MSHCP Volume 1 (Plan) and the Final EIR/EIS:
▪ https://www.wrc-rca.org/Permit_Docs/MSHCP/MSHCP-Volume%201.pdf ▪ https://www.wrc-rca.org/Permit_Docs/MSHCP/MSHCP-Volume4.pdf As discussed above, the Project complied with MSHCP burrowing owl protocol survey requirements.
The Project also complies with pre-construction survey, nest avoidance, and passive relocation requirements of the MSHCP, California Fish and Game Code, and the federal Migratory Bird Treaty Act (Draft SEIR Sections 4.4.4.2, pp. 4.4-23 through 4.4-31, and 4.4.6.2, pp. 4.4-32 through 4.4-36).
MSCHP conservation objective 5 for burrowing owls states that, if protocol surveys identify fewer than 3 pairs of burrowing owls, “then the on-site burrowing owls will be passively or actively relocated following accepted protocols” (County of Riverside 2003, p. B-65). Conservation objective 6 requires 30-day pre-construction surveys for burrowing owls. If owls are found, “Take of active nests will be avoided. Passive relocation (use of one-way doors and collapse of burrows) will occur when owls are present outside the nesting season” (County of Riverside 2003, p. B-65). California Fish and Game Code (Sections 3503 and 3513) and the federal Migratory Bird Treaty Act prohibit the take of active nests of most raptor and other avian species.
16 Refer to MSHCP burrowing owl conservation objectives (County of Riverside 2003, p. B-64). 17 Refer to MSHCP burrowing owl conservation objectives (County of Riverside 2003, pp. B-63 to B-65). 2 - RESPONSE TO COMMENTS
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No burrowing owls were observed during the MSHCP protocol surveys and only one owl was incidentally observed during fairy shrimp protocol surveys. Thus, per the MSHCP, passive or active relocation would be appropriate for any burrowing owls found on site.
Draft SEIR MM-BIO-1 and MM-BIO-3 require 30-day pre-construction surveys and avoidance of active nests (Draft SEIR Section 4.4.6.2, pp. 4.4-32 through 4.4-36). These measures include (1) preconstruction surveys for burrows or suitable artificial openings that may support roosting or nesting burrowing owls; (2) steps to be taken if active burrows/surrogate burrows are located during the surveys, including avoidance of active nests and establishment of 500-foot no-disturbance buffers until the burrows are determined to be no longer active; (3) monitoring by a qualified biologist when construction or ground disturbance activities will occur within 600 feet of an active nest burrow to ensure no impacts; (4) daily inspection of on the ground pipes, tubes, or other artificial openings associated with construction activities to ensure that no burrowing owls are temporarily utilizing them for shelter; and (5) exclusion from burrows following CDFW protocols for owls found on site outside the nesting season and/or for burrows determined not to be nest burrows. CDFW exclusion protocols provide for passive relocation through the use of one-way doors and collapse of burrows (CDFG 2012).
These measures are explained in more detail in Draft SEIR Section 4.4.6.2, pp. 4.4-32 through 4.4-36.
Accordingly, the Draft SEIR concluded that impacts to burrowing owls, including through habitat modification, would be less than significant. Additionally, the mitigation measures for burrowing owl pre-construction surveys and passive relocation are consistent with the MSHCP, the federal Migratory Bird Treaty Act, and Sections 3503 and 3513 of the California Fish and Game Code.
O4-6 The comment states that all remaining burrowing owl habitat must be protected and, if the Project would result in the loss of burrowing owl habitat, mitigation lands should be required at a 5:1 mitigation ratio.
Refer to Response to Comment O4-5, above. No further mitigation is required or appropriate for this less than significant impact. Further, the burrowing owl is a covered species under the Western Riverside MSHCP, and extensive mitigation lands are already provided or are in the process of being completed per targets established by the Regional Conservation Authority. As stated, no further mitigation is required.
O4-7 The comment states that protected habitat for Stephens’ kangaroo rat (Dipodomys stephensi) occurs within 0.5 miles of the Project site, suggesting that Stephens’ kangaroo rat may have re-colonized the site since its agricultural use. It criticizes the Draft SEIR for concluding there is low potential for Stephens’ kangaroo rat presence based on surveys associated with past CEQA approvals. The comment asserts that this does not adequately represent existing conditions or provide an accurate baseline regarding Stephens’ kangaroo rat.
In response, first, the Draft SEIR correctly discloses that the property is located outside of the SKR HCP Core Reserve Area and that the nearest mapped Stephens’ kangaroo rat occurrence is approximately
0.5 miles south of the Project site, within an SKR HCP Core Reserve Area. The Draft SEIR explains the Project site is “essentially surrounded by urban development, which may limit the ability of the species to access the site from known regional populations” (Draft SEIR Section 4.4, pp. 4.4-12 through 4.4- 13). This urban barrier supports the conclusion that there is low potential for Stephens’ kangaroo rat 2 - RESPONSE TO COMMENTS
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presence on the site, particularly since no Stephens’ kangaroo rat were observed during previous surveys conducted as part of the 1999 EIR (Draft SEIR Section 4.4, p. 4.4-22).
Second, no Stephens’ kangaroo rat were incidentally observed during any of the most recent on-site biological surveys and assessments discussed in the Draft SEIR, including those associated with site vegetation mapping, fairy shrimp, burrowing owl, least Bell’s vireo (Vireo bellii pusillus), Crotch’s bumble bee (Bombus crotchii), and bats.
Third, the Draft SEIR explains that the Project site falls within the SKR HCP Fee Area, which means that it is covered by the comprehensive mitigation measures contained in the SKR HCP. Established in 1996, this plan includes the creation of Core Reserves and a Development Mitigation Fee that supports the management and preservation of Stephens’ kangaroo rat habitats (RCHCA 1996; Draft SEIR Section 4.4, p. 4.4-7). The Project site is located outside of the SKR HCP Core Reserve Area but is within the SKR HCP Fee Area (Draft SEIR Section 4.4, p. 4.4-7). Compliance with the SKR HCP, through the payment of the mitigation fee, ensures that any potential impacts to Stephens’ kangaroo rat are fully mitigated; provides take coverage under CEQA, the National Environmental Policy Act, CESA, and the federal Endangered Species Act; and contributes to the acquisition/preservation of Stephens’ kangaroo rat habitat. Even if the species does not occur on the Project site, the developer is required to pay the SKR HCP fee to the City. This fee was paid in full to the City in 2006 prior to the initial grading of the Specific Plan Area (Draft SEIR Section 4.4, pp. 4.4-7, 4.4-22, 4.4-30). 18 As such, any potential
impacts to the species have been mitigated through payment of the SKR HCP fee and would be further mitigated through compliance with the MSHCP.
Fourth, the comment misinterprets the “baseline” for this SEIR; the site has undergone comprehensive environmental review in the 1999 Final EIR, 2001 SEIR, and 2005 Addendum. This Draft SEIR has been prepared in accordance with CEQA Guidelines Section 15162, which states that additional CEQA review is not required unless there are substantial project changes, new circumstances, or new information showing significant impacts not previously addressed (Draft SEIR Chapter 1, Introduction, p. 1-2). The Draft SEIR describes the Project’s urban surroundings, which make it unlikely for Stephens’ kangaroo rat to inhabit the site. Further, as stated with prior approvals, compliance with the SKR HCP through payment of the mitigation fee provides sufficient mitigation for any potential impacts to Stephens’ kangaroo rat and its habitat. Thus, impacts would be similar to the prior project—less than significant with the previously completed mitigation. The Draft SEIR’s conclusions are well-supported and consistent with regulatory requirements.
O4-8 The comment states that the California Natural Diversity Database has identified two bat Species of Special Concern on the Project site, namely, the California mastiff bat (Eumops perotis californicus), and the western yellow bat (Lasiurus xanthinus). It asserts the Draft SEIR did not include needed bat surveys, which should be addressed in the Final SEIR. The comment states that buildings and light 18 The SKR HCP provides an important planning tool to protect Stephens’ kangaroo rat, while streamlining review of local projects that may impact the species or its habitat. Completed in 1996 by the Riverside County Habitat Conservation Agency (RCHCA), CDFW, and U.S. Fish and Wildlife Service, the SKR HCP established seven “core reserves,” totaling more than 41,000 acres, within a planning area of 533,000 acres. The RCHCA is responsible for “completing” the reserves through the addition of land in fee simple or through the acquisition of easements (RCHCA 1996). Participants of the SKR HCP can incorporate projects into the incidental “take” permit for Stephens’ kangaroo rat if the project complies with the requirements of the SKR HCP. Payment of the mitigation fees for projects located within the Stephens’ kangaroo rat mitigation fee area provides full mitigation under CEQA, the National Environmental Policy Act, and the CESA and federal Endangered Species Act for impacts to Stephens’ kangaroo rat (RCHA 1996).
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pollution may negatively impact these species and requests a full analysis and mitigation measures in the Final SEIR if these bats are present on the Project site.
In response, the Draft SEIR explains that generally the site lacks existing natural habitat, including bat roosts, that would support these bat species (Draft SEIR Section 4.4, p. 4.4-30). However, comments from CBD on the Notice of Preparation, dated December 4, 2023, requested surveys for these bats.
Consequently, Dudek biologists were retained to perform the necessary bat surveys. Protocols indicate that surveys should occur between March 1 and July 31, outside the winter hibernation period and during the maternity period when colonies form and flightless young are present. Surveys conducted during migratory or winter hibernation seasons may yield less accurate results.
The surveys took place from March 19 to March 26, 2024, but the results, analysis, and final report were not available at the time of the Draft SEIR’s circulation. The surveys confirm and clarify the Draft SEIR’s conclusion that no special-status bat species roost or occur on site or within a 100-foot buffer of the Project boundary. The Results of Bat Roost and Acoustic Monitoring Surveys for the Aquabella Project, Riverside County, California, dated June 7, 2024, is attached to the Final EIR as Attachment D. 19 These protocol-level surveys completed by Dudek biologists focused on identifying bat species that may be roosting or otherwise utilizing the Project site for breeding or foraging. The surveys particularly looked for special-status bat species that may occur in the region, including California mastiff bat and the western yellow bat, as cited by CBD.
The survey effort included a field habitat assessment for maternity and shelter/hibernaculum roost sites, emergence surveys for visual signs of bat emergence, and passive acoustic surveys to collect and analyze acoustic signatures to the species level. Acoustic monitoring used Wildlife Acoustics SM4BAT full spectrum acoustic detectors at designated locations within the Project site for 1 week (7 consecutive nights). These recordings were processed and analyzed with the use of Sonobat
4.3.0 software.
No suitable bat roosting habitat was determined to be present within the Project site or immediately adjacent to the Project site. The disturbed habitat that dominates the site, primarily non-native grassland, does not support bat roosting. No bats were observed emerging from any of the on-site or off-site trees or vegetation (located primarily within the riparian revegetation area within the drainage channel) during the survey period. Active acoustic monitoring during the emergence survey found an absence of roosting bats in this channel. Passive acoustic analysis did not detect any foliage-roosting bats within the Project site during the survey period.
Passive acoustic monitoring results did not indicate any roosting at the site and did not identify any special-status bat species. Monitoring showed low bat diversity and low-to-moderate activity, with 19 The addition of the bat survey report to the Final SEIR does not require recirculation. The Draft SEIR stated the site lacks bat habitat, including bat roosts (Draft SEIR Section 4.4, p. 4.4-30). The bat survey report confirms, clarifies, amplifies, and makes insignificant modifications to the Draft SEIR’s analysis (14 CCR 15088.5[a] and [b]; Draft SEIR Section 4.4, p. 4.4-30). The focused surveys were performed in response to comments from CBD. The surveys affirmed the lack of habitat, lack of roosts, and lack of special-status bat species on site. No new or more severe significant impacts have been identified. Thus, recirculation is not required (14 CCR 15088.5).
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1,263 bat passes20 identified to the species level during the 7-night monitoring period. These passes come from just two common species: Brazilian free-tailed bat (Tadarida brasiliensis) (1,214 passes;
96.1%) and California myotis (Myotis californicus) (49 passes; 3.9%). No special-status bat species were identified based on the acoustic analysis.
The low-to-moderate level of activity is not representative of a colony of bats that would be emerging from a roost, which can generate thousands of calls in a single night. Thus, the monitoring indicated that common bats may forage within the study area, but no bats are roosting on site, and no specialstatus species were detected.
In conclusion, no suitable bat roosting habitat was identified within the Project site or vicinity. Only two common bat species were detected, and no state or federally listed special-status bat species were found. No bats were observed to be roosting within the study area. Thus, the Project would not result in significant adverse impacts to roosting bats, special-status bat species, or their habitat.
Additionally, Project lighting will be designed to minimize spillover and comply with dark sky consideration and policies (see PDF-AQ/GHG-5). This includes compliance with Section 9.08.100, Lighting, of the City’s Municipal Code. Lighting impacts to common nocturnal species would be thereby minimized.
O4-9 This response addresses concluding comments, expresses the opinions of the commenter, and does not raise an issue related to the adequacy of any specific section of the Draft SEIR. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision. No further response is required or necessary. 20 Total bat passes indicate two or more echolocation calls, not the total number of individual bats found, as one bat can record multiple calls.
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Response to Comment Letter O5
Organization
Riverside University Health System
July 15, 2024
O5-1 This comment includes a description of the Riverside University Health System (RUHS). The comment does not identify any specific issue with respect to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O5-2 The comment includes a brief description of the Project and an introduction to comments to follow. The comment does not identify any specific issue with respect to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O5-3 The comment expresses concern regarding air quality during construction, specifically related to dust and air pollution during construction. Air quality impacts from Project construction were analyzed as part of Draft SEIR Section 4.3, Air Quality. The South Coast Air Quality Management District (SCAQMD) identifies sensitive receptors as residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes (SCAQMD 1993). The Draft SEIR identifies three existing sensitive receptors in proximity to the Project site, including the RUHS. More specifically, Threshold 3 addresses exposure of sensitive receptors to substantial pollutant concentrations. As determined under Threshold 3, the Project would result in lessthan-significant construction impacts associated with exposure of sensitive receptors to substantial pollutant concentrations with the incorporation of MM-AQ-2 (Draft SEIR Section 4.3.4.2, pp. 4.3-50 through 4.3-57). The Project will be required to comply with SCAQMD Rule 403 to control dust emissions during any dust-generating activities. SCAQMD Rule 403 requires implementation of various best available fugitive dust control measures for different sources for all construction activity sources within its jurisdictional boundaries.
O5-4 The comment expresses concern about construction noise and vibration impacting testing equipment and instruments. Noise and vibration impacts were analyzed in Draft SEIR Section 4.13, Noise. As concluded in the Draft SEIR, impacts related to a temporary increase in ambient noise levels as a result of construction noise would be less than significant with incorporation of MM-NOI-1 and MM-NOI-2. As discussed under Threshold 2, groundborne vibration generated from construction equipment would be attenuated to 0.2 inches per second peak particle velocity (the threshold for human annoyance) at a distance of no greater than 60 feet from construction activity (Draft SEIR Section 4.13.4.2, pp. 4.13- 20 through 4.13-21). Existing structures are no closer than approximately 70 feet from the boundary of any future Project construction zones. Impacts related to vibration would be less than significant.
O5-5 The comment expresses concern regarding potential impacts related to glare from solar panels on patients at the medical center. As discussed in Draft SEIR Section 4.1, Aesthetics, photovoltaic solar panels would be provided at the site; however, such panels are designed to absorb light, not reflect it, and would be coated with anti-reflective materials to maximize light absorption. Therefore, the Project would result in less-than-significant impacts related to glare.
O5-6 The comment expresses concern about emergency and patient access to the medical center during road improvements. The comment further requests coordination with RUHS during improvement 2 - RESPONSE TO COMMENTS
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activities that could impact emergency vehicle access. As discussed in Draft SEIR Section 4.17, Transportation, any Project construction activities that could potentially impact adjacent roadways, and thereby interfere with emergency access, would be subject to the City’s Traffic Control Plan Guidelines & Checklist, including its Temporary Traffic Control Requirements (City of Moreno Valley 2022). These requirements address applicable temporary traffic controls for all construction activities within the City public rights-of-way. This would include mandatory compliance with the latest California Manual on Uniform Traffic Control Devices and compliance with the requirement that emergency access to all nearby properties be maintained at all times. The Temporary Traffic Control Requirements also include requirements related to preparation of a custom Traffic Control Plan that addresses work on arterials, nighttime/weekend work, temporary changes to signal timing, work with any road closures, major encroachment, and major street improvements associated with commercial/residential developments.
O5-7 The comment request collaboration on street, signal, and flood control improvements. The Project applicant will work with RUHS to collaborate on off-site improvements. The comment does not identify any specific issue with respect to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O5-8 The comment requests noticing prior to construction for activities that are within 500 feet of the medical centers’ property boundary. The Project applicant and City will work to ensure noticing in advance of construction within 500 feet of the medical center. The comment does not any identify specific issue with respect to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O5-9 The comment requests additional time to review the Draft SEIR and for additional coordination between RUHS and the Project applicant. The comment does not any identify specific issue with respect to the adequacy of the Draft SEIR; therefore, no further response is required or necessary. 2 - RESPONSE TO COMMENTS
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Response to Comment Letter O6
Organization
Sierra Club – San Gorgonio Chapter, Moreno Valley Group July 15, 2024
O6-1 The comment states that in the Notice of Availability (NOA) project description, there is only one sentence about the 2006 General Plan.
The City acknowledges the comment, which restates information in the NOA and does not raise an environmental issue or procedural error under CEQA. The purpose of the NOA is to provide notice to the public that the Draft SEIR is available for public review and inform them of when and where they can provide comments. California Public Resources Code Section 21092(b)(1) and the CEQA Guidelines state that the NOA shall specify the following:
▪ the period during which comments will be received on the draft environmental impact report ▪ the date, time, and place of any public meetings or hearings on the proposed project ▪ a brief description of the proposed project and its location ▪ the significant effects on the environment, if any, anticipated as a result of the project ▪ the address where copies of the draft EIR and all documents referenced in the draft EIR are available for review
▪ a description of how the draft EIR can be provided in an electronic format In compliance with CEQA, the NOA provides this information, describing the Project, its location, significant environmental effects, Draft SEIR availability (including electronically), and the 45-day comment period. The brief project description appropriately outlines the discretionary actions under consideration, which include a General Plan Amendment to the operative General Plan.
Please also see Topical Response 1, SB 330 and General Plan Consistency Analysis, which discusses the Project’s proposed General Plan Amendment and the Draft SEIR’s evaluation of Project consistency with the 2040 and 2006 General Plans.
The City will include the comment as part of the Final SEIR for review and consideration by the decisionmakers. No further response is required or necessary.
O6-2 Referring to the sentence in the NOA that reads "If the 2006 General Plan is operative at the time of approval, the Project would require a GPA [General Plan Amendment] to amend the 2006 General Plan Land Use Map, Figure 2-2 to accommodate the Project,” the comment states Figure 2-2 in the Draft SEIR is not a land use map and, thus, the reference must be to Figure 2-2 of the 2006 General Plan.
The comment asserts the 2006 General Plan needs to be made available to the public and appended to the Draft SEIR. The comment states that footnotes about the 2006 General Plan being effective do not cure inconsistencies with major sections of the 2006 General Plan, which is “now the General Plan that must be used in our City.”
In response, the NOA reference is to Figure 2-2 of the 2006 General Plan. Documents referenced, incorporated by reference, and relied upon in the Draft SEIR are listed in Section 8.0, SEIR References, 2 - RESPONSE TO COMMENTS
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Consultation, and Preparation, with links to respective documents, where available. Chapter 8, SEIR References, Consultation, and Preparation, with links to respective documents, where available. The 2006 General Plan is made available at https://www.moval.org/city_hall/generalplan/06gpfinal/gp/gp-tot.pdf.
Please see Topical Response 1, which discusses the Project’s proposed General Plan Amendment and the Draft SEIR’s evaluation of Project consistency with the 2040 and 2006 General Plans.
Project consistency with the goals, objectives, and policies of the 2006 General Plan is thoroughly evaluated in Appendix A, Specific Plan Amendment, of the Draft SEIR. The Project is shown to be consistent with the 2006 General Plan. See also Response to Comment O6-3 below.
The City acknowledges the comment is an introduction to comments that follow. It is included in the Final SEIR for review and consideration by the decision-makers prior to a final decision.
O6-3 The comment states Appendix A, pages 8-85 through 8-160, is a “poor attempt to convince the public and decision-makers that the other 1,000’s of pages designed for the 2040 General Plan (GP) also applies to the General Plan of 2006.”
Please see Topical Response 1, which discusses the Project’s proposed General Plan Amendment and the Draft SEIR’s evaluation of Project consistency with the 2040 and 2006 General Plans.
As detailed therein, the Project’s Senate Bill (SB) 330 preliminary application was submitted on September 6, 2023, at a time when the following regulatory documents were in effect: the 2040 General Plan (adopted by Resolution No. 2021-47 in June 2021), the Climate Action Plan, and related zone changes (adopted by Ordinance No. 981 in June and August 2021). However, the 2040 General Plan was the subject of litigation, and in May 2024, the Riverside County Superior Court issued a Judgment and Writ directing that the City set aside certification of the 2040 General Plan EIR and approval of the 2040 General Plan, Climate Action Plan, and related Zoning Amendments until those errors are corrected (Sierra Club v. City of Moreno Valley, CVRI2103300, May 6, 2024, Writ).
Thus, Project consistency with the 2006 General Plan is evaluated in Appendix A of the Draft SEIR in the event it is the operative General Plan at the time of Project consideration for approval. Indeed, the City’s Resolution 2024-37 (approved June 25, 2024) rescinding the previous approvals of the 2040 General Plan and associated documents due to the referenced litigation states that “the 2006 General Plan, associated zoning, and associated EIR are no longer superseded and that the 2006 General Plan, Zoning, and associated EIR remain in place pending reconsideration and re-approval of the MoVal 2040 General Plan and associated zoning, and that the Housing Element (October 2022) remains in effect.” The Draft SEIR evaluates Project consistency with the City’s 2040 General Plan, Climate Action Plan, zoning, and up-to-date regional planning documents because the Project is an SB 330 preliminary application housing development project. As such, upon the Project applicant’s submittal of the SB 330 application and payment of the required fee, the 2040 General Plan, Climate Action Plan, and zoning for the Project were locked in place (vested) and operate as the City’s valid regulations governing this SB 330 Project (despite the litigation) (see Topical Response 1). 2 - RESPONSE TO COMMENTS
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Further, General Plan consistency is not generally a CEQA issue. Instead, a General Plan inconsistency is a significant impact under CEQA only if it results in a significant physical impact (14 CCR 15064.7[d]; The Highway 68 Coalition v. County of Monterey [2017] 14 Cal.App.5th 883, 894).
The City acknowledges the comment as an introduction to comments that follow and notes it expresses the opinions of the commenter. To the extent the comments that follow address political issues that do not appear to relate to any physical effect on the environment, the City will include the comments as part of the Final SEIR for consideration by the decision-makers prior to a final decision. However, no further response is required where the comments do not raise an environmental issue.
The final determination of consistency with the General Plan will be made by City Council. The Council’s determination has been constrained by state housing law revisions in recent years to limit housing disapprovals. These revisions to the Housing Accountability Act (Government Code Section 65589.5) provide that only inconsistencies with objective (not subjective) standards can serve as the basis for housing disapproval and that these standards must be applied to facilitate and accommodate housing (Government Code Sections 65589.5[f][1], [f][4], [j]). Further, a project need not rigidly conform with every detail of the General Plan. It must only be “compatible with” the objectives, policies, general land uses, and programs specified in the General Plan (Bankers Hill 150 v. City of San Diego [2022] 74 Cal.App.5th 755, 776). A consistency finding is supported if there is any substantial evidence in the record that would allow a reasonable person to conclude it complies with objective standards, even if reasonable minds could differ or there is evidence to the contrary (Government Code Sections 65589.5 [f][4], [j]).
O6-4 The comment recites 2006 General Plan Goal 2.1 to organize future growth, minimize land use conflicts, and promote the rational utilization of underdeveloped and undeveloped parcels. It states the Project significantly conflicts with existing single-family and detached homes and the land use designation under the 2006 General Plan Land Use map. It also states height, mass, and density will destroy viewsheds.
Refer to Responses to Comments O5-2 and O5-3 and Topical Response 1. Goal 2.1 is included in the Draft EIR. Refer to Appendix A of the Draft SEIR.
Section 3.4.1 of the Draft SEIR (pp. 3-27 through 3-28) explains that a General Plan Amendment would be needed to accommodate the Project. The Draft SEIR describes the General Plan Amendment proposed to both the 2040 General Plan and 2006 General Plan, in the event the 2006 General Plan is operative at the time of Project consideration for approval for the reasons described in Topical Response 1. With this amendment, the Project would no longer conflict with the 2006 General Plan Land Use map.
The City notes that the comment expresses the opinion of the commenter concerning subjective language regarding minimizing land use conflicts. The 2006 General Plan Consistency Table in Appendix A of the Draft SEIR describes the facts and substantial evidence supporting consistency with this goal. These include that the Project will focus development in the City’s downtown center in an area that is complementary to adjacent residential densities, education, medical, school, and other uses. The Project will develop a vacant, undeveloped, and already graded site in a manner that would discourage sprawl into open space areas surrounding the City and integrate into the land use pattern of the existing community. Conflicts between land uses would be minimized. 2 - RESPONSE TO COMMENTS
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The Project would support the demand for workforce, education, and other housing by developing homes proximate to major job centers in the City and region (e.g., Riverside University Health System Medical Center, the Kaiser Permanente Hospital and medical complex, Moreno Valley College, and the World Logistics Center). This would allow residents to live and work locally, cutting commute times and improving air quality. The Project site is also located along major transit routes and would support frequent and reliable transit service and other multimodal transportation measures, including walking and biking. The Riverside Transit Agency (RTA) provides existing bus routes close to the site. Route 31 runs along Nason Street to the Riverside University Medical Center. Route 20 also serves the site along Alessandro, Nason, and Moreno Beach Drive to Riverside University Medical Center, Kaiser Permanente Hospital, and Moreno Valley College, as well as along Nason and Lasselle Street. Route 41 serves the site from the Medical Center to Moreno Valley College and areas to the south. Route 20 bus service also connects passengers to the Moreno Valley/March Field Metrolink Station across Interstate 215.
The comment asserts there are conflicts related to aesthetic impacts. Section 4.1.4.2 of the Draft SEIR (pp. 4.1-7 through 4.1-12) evaluates Project impacts concerning aesthetics and visual changes, including as relates to height, massing, density, scenic vistas, and visual character and quality. Project impacts were determined to be less than significant. The CEQA thresholds focus on impacts to scenic vistas, scenic resources within a state scenic highway, and conflicts with regulations governing scenic quality in urban areas, not view impacts to individual residents from private property. Further, under CEQA, “the question is whether a project will affect the environment of persons in general, not whether a project will affect particular persons. Additionally, California landowners do not have a right of access to air, light and view over adjoining property” (Mira Mar Mobile Community v. City of Oceanside [2004] 119 Cal.App.4th 477, 492–493).
21 However, the City acknowledges that residential views across the site would change with Project development. Refer to Draft SEIR Section 4.1.4.2 (pp. 4.1-7 through
4.1-12) and Figures 4.1-1 through 4.1-2h (pp. 4.1-15 through 4.1-31), depicting changes that would be anticipated from residential viewers located to the west, south, and east of the site.
Draft SEIR Section 4.1.4.2 (pp. 4.1-7 through 4.1-12) further explains that varied massing and roof types, planting design, color, articulated features, and materials are envisioned to establish a distinct visual identity, heighten visual interest, and break down the apparent scale of development. The Specific Plan Amendment, Appendix A to the Draft SEIR, includes design standards and guidelines to ensure intelligently designed massing, density, and height of buildings to achieve a cohesive yet varied community vision, retain pedestrian-scale features, and compliment adjacent uses.
O6-5 The comment recites 2006 General Plan Policy 2.2.7, which provides that the primary purpose of the Residential 5 designation is single-family homes at 5 dwelling units per acre. The comment states that the only way the Project would be consistent with this is a Specific Plan Amendment. The comment states a General Plan Amendment leads to the General Plan being internally inconsistent. 21 The state legislature has specified that impacts on aesthetics are not required to be evaluated under CEQA for infill projects located within transit priority areas (TPAs) (California Public Resources Code, Section 21099[d][1]). While the Project is not currently considered to be within a TPA, it is anticipated that with Project buildout and implementation of the proposed bus rapid transit along Alessandro and mobility hub on site, the Project could qualify as a TPA (see Draft SEIR Section 4.17, pp. 4.17-32 through 4.17-33).
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Refer to Responses to Comments O5-2, O5-3, and O5-4 and Topical Response 1. 2006 General Plan Policy 2.2.7 is included in the Draft SEIR. Refer to Appendix A of the Draft SEIR.
Further, the comment does not explain why the General Plan Amendment would make the General Plan internally inconsistent.
O6-6 The comment recites 2006 General Plan Objective 2.8, which provides that a major purpose of specific plans is to encourage and promote the development of larger-scaled mixed-use developments for the purpose of providing adequate flexibility and innovation. The comment states the Project will have more people than many California cities, and to reduce pollution, more than 25 acres of commercial needs to be provided within walking distance without reducing smaller units, open space, parks, or water features. It states that the Project alternative that proposes to increase commercial would still maintain 15,000 units and suggests an alternative with 14,000 units and increased commercial to reduce greenhouse gases (GHGs) and other impacts.
Refer to Responses to Comments O5-2 and O5-3 and Topical Response 1. Objective 2.8 is included in the Draft EIR. Refer to Appendix A of the Draft SEIR.
The City notes that the comment expresses the opinion of the commenter concerning subjective language regarding specific plans. The comment is also contradicted by analysis supported by substantial evidence in the Draft SEIR. The 2006 General Plan Consistency Table in Appendix A of the Draft SEIR describes the facts and substantial evidence supporting consistency with this goal. The Specific Plan Amendment, Appendix A to the Draft SEIR, proposes flexible and innovative design to implement a large-scale development in alignment with the cited Objective.
The additional alternative to the Project suggested by the commenter is substantially similar to alternatives already considered in the Draft SEIR. CEQA Guidelines Section 15126.6(a) requires that an EIR “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” Section 15126.6(a) also provides that an EIR need not consider every conceivable alternative to a project; rather, an EIR must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.
Further, an EIR need not include multiple variations of alternatives considered in the EIR or those that do not offer environmental advantages (14 CCR 15126.6[b]; Villages of Laguna Beach, Inc. v. Board of Supervisors [1982] 134 Cal.App.3d 1022, 1028; Cherry Valley Pass Acres & Neighbors v. City of Beaumont [2010] 190 Cal.App.4th 316, 355; Tracy First v. City of Tracy [2009] 177 Cal.App.4th 912, 929).
The Draft SEIR presented seven alternatives based on the Project’s identified significant environmental impacts, the objectives established for the Project (Draft SEIR Section 7.1.2, p. 7-2), feasibility, and consideration of public input. These included the following:
1 Alternative 1: No Project - No Development (Zero Units/No Development) 2 Alternative 2: Previously Approved Aquabella 2005 Specific Plan Amendment (2,702 Units) 3 Alternative 3: 2040 General Plan Downtown Center (2,702 Units/1,804,000 sf commercial/retail) 2 - RESPONSE TO COMMENTS
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4 Alternative 4: Reduced Density – 10,000 Units
5 Alternative 5: Reduced Density – 7,500 Units
6 Alternative 6: Increased Commercial
7 Alternative 7: Increased Density – 20,000 Units
Thus, the Draft SEIR evaluated reduced density and increased commercial alternatives. Alternative 3 considered lower density and higher commercial square footage. Alternative 6 considered 150,000 square feet of commercial compared to the Project’s 49,900 square feet. Alternatives 2, 3, 4, and 5 all considered reduced density. These alternatives are substantially similar to that proposed by the commenter and allow for the evaluation of the commenter’s suggested alternative.
In evaluating Alternative 6, the Draft SEIR explains that increased commercial square footage does not, in fact, result in the reduced vehicle miles traveled (VMT) benefit being sought by the commenter to reduce GHGs and other impacts. To the contrary, per the Project’s expert transportation consultant and as summarized the alternatives analysis, increased commercial uses would be anticipated to draw or induce increased VMT from visitors and employees of the additional commercial buildings from outside the Project site, which would increase air quality and GHG emissions (Draft SEIR Chapter 7, pp. 7-20 to 7-21).
The Project’s 49,900 square feet of commercial/retail use contributed to the Project’s trip generation estimate, which is the amount of vehicular traffic a project would add to the surrounding roadway system (see Draft SEIR Appendix K1, Aquabella Master Plan Development Project Trip Generation Assessment [prepared by Fehr & Peers], pp. 1–6). Trip generation estimates for the Project were created for the daily condition and for the peak hour during the morning and evening commutes when traffic volumes on the adjacent streets are typically the highest (Draft SEIR Appendix K1, see Table 1, ITE Trip Generation Rates, and Table 2, Total Trip Generation).
Given the residential and mixed-use nature of the Project, the traffic analysis prepared by Fehr & Peers evaluated the combined effects of the Project’s mix of uses, regional location, demographics, and development scale. These factors contribute to “internalization” or “internal capture,” which account for trips beginning and ending on the Project site due to the mix of land uses (Draft SEIR Appendix K1, p. 6). This analysis used the U.S. Environmental Protection Agency’s MXD (mixed-use development) methodology to determine internalization, which is robust for considering these combined effects that may contribute in a reduction in off-site average weekday vehicle trips (Draft SEIR Appendix K1, pp. 6– 9, including Tables 3 and 4). The MXD model is also refined for the study area because it accounts for various attributes, such as density of the site, distance to transit, density of intersections, employment, household size, and variables that reduce vehicle trip-making behavior (Draft SEIR Appendix K1, p. 7).
Fehr & Peers estimated a reduction in trips with implementation of the Project due to the proximity of complementary land uses within the development (e.g., residential-to-retail, residential-to-parks, residential-to-schools). In addition to trip reductions within the Project site due to the mix of land uses, Fehr & Peers anticipated that trips would be captured between the Project and neighboring complimentary uses at the existing high school and medical centers (Draft SEIR Appendix K1, pp. 7–8).
In contrast, and based on consultation with Fehr & Peers, if the Project were to increase the commercial/retail square footage, the increased use would function as a draw, attracting trips from 2 - RESPONSE TO COMMENTS
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surrounding or more distant areas. This would induce additional vehicle trips to the site by visitors and employees from such locales, and thus, increase VMT compared to the Project. The increase in VMT would then increase operational emissions of criteria pollutants (volatile organic compounds, oxides of nitrogen, carbon monoxide, and coarse and fine particulate matter) when compared to the Project.
Additionally, GHG emissions may increase compared to the Project, depending upon the amount of increased commercial usage. Traffic-related noise would also increase compared to the Project (Draft SEIR Section 7.4.6, pp. 7-20 through 7-22). Thus, increased commercial uses are anticipated to worsen—not improve—GHGs and other project impacts.
Regarding reducing unit count to offset increased impacts of commercial uses, even reducing the Project density to 10,000 units would result in similar impacts compared to the Project. Air quality impacts would remain significant and unavoidable. GHG emissions would be slightly reduced, but GHG impacts would remain less-than-significant, as with the Project. Accordingly, an alternative that increases commercial uses and reduces the unit count to 14,000 is not anticipated to result in reduced impacts to GHGs or air quality. Further, it would be anticipated to increase or induce VMT, worsening transportation impacts.
The Project’s proposed 49,900 square feet of retail is intended to be “right sized” for the site, offering retail, restaurant, and other uses in addition to Project’s planned recreational uses and amenities provided with the residential development. The Project’s Town Center would support a mix of options, including a small grocery/neighborhood market, a pharmacy/drug store, dry cleaner, tailor, nail/hair salon or barber shop, spa, sit-down and full-service restaurants, fast casual restaurant or carry-out, ice cream shop, coffee shop or café, apparel store or clothing store, furniture store, pet store, book store, sports store, music store, and other boutique retail and food and beverage opportunities.
The Project’s commercial uses would complement existing retail near the Project site, which includes shopping, grocery, pharmacy, big box stores, and restaurants. Additional retail may result in excess commercial uses and result in adverse impacts to an existing community that already has 10.5% commercial vacancy rates, approximately 8.2 million square feet of retail built, and another one million square feet of retail under production.
The City acknowledges that the comment expresses the opinion of the commenter in favor of an alternative that incorporates additional commercial square footage and limits housing to 14,000 units.
The City will include the comment as part of the Final SEIR for review and consideration by the decisionmakers prior to a final decision.
O6-7 The comment recites 2006 General Plan Policy 2.10.1, which encourages a design theme compatible with surrounding development. It asserts that the large/tall buildings proposed by the Project will not be compatible with surround development. It also states that the planned buffering with the existing school needs to be revisited and improved. Policy 2.10.1 is included in the Draft SEIR. Refer to Appendix A of the Draft SEIR.
The City notes that the comment expresses the opinion of the commenter concerning subjective language regarding specific plans. However, the City does not concur with the comment for the following reasons. The 2006 General Plan consistency table in Appendix A of the Draft SEIR describes the facts and substantial evidence supporting consistency with this policy. Specifically, the Specific Plan Amendment envisions development of a series of villages, each with an individual theme and identity 2 - RESPONSE TO COMMENTS
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carried throughout that village’s architectural style, landscaping, fencing, entry monumentation, and use of streets and open spaces. The individual themes will comply with the broader design guidelines established for the Specific Plan Area, which have been informed by the existing residential and medical uses, size and massing, color palettes, landscaping, and traditional and contemporary architectural style and character of the surrounding community. Refer to the Design Standards and Design Guidelines of the Specific Plan Amendment (Draft SEIR Appendix A) for additional information on height limits, architectural design, landscape design, massing, and streetscape design.
Additionally, Draft SEIR Section 4.1.4.2 (pp. 4.1-7 through 4.1-12) evaluates Project impacts concerning aesthetics and visual changes, including as relates to height, massing, density, scenic vistas, and the visual character and quality. Project impacts were determined to be less than significant.
As to buffers from existing schools, generally schools are considered compatible with residential uses.
Further, Vista Del Lago High School and its associated impacts were also considered in the 1999 EIR as part of the original Specific Plan 218. The Project proposes to continue John F. Kennedy Drive adjacent to the high school to provide a potential access point to the Project site. Street improvements would include landscaping, a landscape setback, and a perimeter trail. The Project is separated from Landmark Middle School by existing Oliver Street. The Project proposes a landscape median, landscape setback on the development side, and multi-use trail on the development side of Oliver Street. Refer to Draft SEIR Appendix A Chapters 4 and 6, as well as Figure 6-4. Further, during Project construction, mitigation related to air quality and noise impacts would apply to reduce air quality and noise at school receptors. Refer to Sections 4.3, Air Quality, and 4.13, Noise, of the Draft SEIR. These comments will be included in the Final SEIR for consideration by decision-makers.
Finally, the portion of the General Plan referred to does not involve a physical impact on the environment. Refer to Response to Comment O6-3.
O6-8 The comment recites 2006 General Plan Policy 2.10.7, which provides lighting should not cause nuisance or glare on adjacent properties. The comment states that unless exterior lighting is at 2700 Kelvin or below, it is not consistent and will be a nuisance to adjacent properties. 2006 General Plan Policy 2.10.7 is included in the Draft EIR. Refer to Appendix A of the Draft SEIR.
See Draft SEIR, Section 4.1.4.2 (pp. 4.1-7 through 4.1-12). The Draft SEIR evaluates Project impacts concerning light and glare and finds impacts would be less than significant:
The Project site is currently undeveloped and is surrounded by residences and two medical centers/hospitals. Surrounding residential and institutional land uses contain lighting typical of an urban setting, including, but not limited to, street lighting, signage lighting, and security lighting. Similar to the previously approved 2005 Aquabella SPA, development of the Project site would introduce new sources of light and glare to the Project site.
Sources of lighting associated with the Project would be typical of residential and commercial uses, including streetlights, interior roadway and walkway/pathway lighting, and exterior mounted and interior lighting. Potential sources of glare would include windows on the Project’s residential and commercial uses. As described in the Specific Plan, lighting fixtures on site would be properly shielded to prevent off-site glare and minimize light pollution. Spot fixtures would be directed downward and/or upward to illuminate specific items or areas within the site, not outward from the Project area. The 2 - RESPONSE TO COMMENTS
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Project would be required to present exterior lighting plans for parking and other site areas are to demonstrate compliance with Section 9.08.100, Lighting, of the City’s Municipal Code. Therefore, Project lighting sources would be similar to existing sources in the surrounding area and would comply with regulations governing lighting to confine light within the site and prevent glare onto adjacent properties.
To minimize the impacts of glare and reflectivity as a result of the new development, the Specific Plan design guidelines provide for clear glazing of windows and limited use of reflective materials for accent elements. Photovoltaic solar panels would be provided at the site. However, such panels are designed to absorb light, not reflect it, and would be coated with anti-reflective materials to maximize light absorption. In addition, solar panels face upward, resulting in a small likelihood of affecting nearby residents on the ground or in surrounding developments. Accordingly, the Project would not introduce a new substantial source of light or glare compared to the prior approvals, and impacts would remain less than significant.
Among other things, the Project will be required to comply with Municipal Code Section 9.08.100 standards for street lighting, exterior light shielding, lighting prohibitions, lighting curfew, and light spillover or trespass.
The comment will be included in the Final SEIR for consideration by decision-makers.
O6-9 The comment recites 2006 General Plan Policy 2.14.3, which provides that projects should be reviewed for their impacts on public services and facilities. It states that traffic alone makes the Project inconsistent with the General Plan. The comment states that paying the Riverside County Transportation Uniform Mitigation Fee (TUMF), the City’s development impact fees (DIFs), and other fees will not mitigate Project impacts when all existing, proposed, and foreseeable projects are factored in.
In response, the comment does not raise an environmental issue for CEQA purposes. Draft SEIR Section
4.17, Transportation, specifically Section 4.17.2, Regulatory Framework (pp. 4.17-9 through 4.17-16), explains that level of service (LOS) is no longer the CEQA metric used to evaluate transportation impacts.
In 2013, the state adopted SB 743, which mandated alternative metrics replace LOS for determining impacts relative to transportation in CEQA documents. In the past, environmental review focused on LOS and the delay vehicles experienced at intersections, which resulted in mitigation that involved increasing capacity. This, in turn, encouraged more vehicular travel and greater pollutant emissions.
Additionally, improvements to increase vehicular capacity often discourage alternative forms of transportation, such as biking and walking.
Thus, in December 2018, the CEQA Guidelines were updated to add new Section 15064.3, which provides that transportation impacts under CEQA should be evaluated using a VMT metric, not LOS.
This new VMT methodology has been required for use with land use projects since July 1, 2020. Project transportation impacts were therefore assessed using the VMT metric pursuant to state law in Draft SEIR Section 4.17. Impacts would be less than significant under this metric, and no mitigation is therefore required (Draft SEIR Section 4.17.5.2, pp. 4.17-29 through 4.17-46). 2 - RESPONSE TO COMMENTS
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The Draft SEIR further explains that the City required a summary of the Project’s traffic analysis using the LOS metric consistent with City General Plan requirements and for informational purposes and Policy 2.14.3. This LOS traffic analysis is provided as part of this Draft SEIR in Appendix K3 and considers the following scenarios:
▪ Existing (2023)
▪ Horizon Year (2045) Without Project (Approved SP), with World Logistics Center (WLC) Buildout ▪ Horizon Year (2045) With Project, with WLC Buildout
As explained in Section 1.2 of Appendix K3, the horizon year analysis utilized Riverside County’s travel demand forecasting model (RIVCOM) updated to fully account for WLC buildout. This appendix provides the information requested by the commenter and also allows for a direct comparison to the prior LOS analyses competed for the prior projects.
The Horizon Year (2045) With Project scenario is utilized in the LOS analysis to determine the framework of ultimate improvement needs with completion of the Project. Subsequent traffic analyses will be conducted at each Project phase to determine the actual phasing of circulation improvements.
The 2045 roadway network includes roadway connections consistent with the 2006 General Plan.
Exhibits 4-5, 4-7, 4-8, and 4-10 of Appendix K3 show the Project contributions to intersection volumes along Nason Street during AM and PM peak hours. Exhibits 4-11 and 4-13 show Project-only average daily traffic trips on Nason Street. Exhibits 6-1, 6-3, 6-4, and 6-6 of Appendix K3 show the Horizon Year (2045) plus Project intersection volumes along Nason Street during AM and PM peak hours. Exhibits 6-7 and 6-9 show Horizon Year (2045) plus Project daily traffic trips on Nason Street. Appendix K Table 6-2 provides an Intersection Analysis for Horizon Year (2045) with Project, including at intersections along Nason Street, with and without improvements. With improvements, all intersections evaluated along Nason Street are anticipated to meet the LOS standard at Horizon Year with Project, with the exception of Nason Street/Cottonwood Avenue in the AM peak hour.
Section 7 of Appendix K3 identifies that the Project would be subject to compliance with the City’s DIF program, the Riverside County TUMF, and fair share contributions for traffic signal and other transportation improvements, which are all aimed at ensuring that Project area roadways and intersection expansions keep pace with the projected population increases. Table 7-1 provides the Project’s fair share calculations for intersection improvements.
Section 8 of Appendix K3 summarizes the Project roadway and intersection improvements that will be completed, including those that will be completed as part of the Project on and off-site or that the Project will support through the payment of fair share fees. The recommended improvements needed to address the cumulative deficiencies identified under Horizon Year (2045) Without Project (Approved SP) and Horizon Year (2045) With Project traffic conditions are shown in Table 8-1 of Appendix K3. For those improvements listed in the Without Project (Approved SP) column of Table 8-1 and not already included in an adopted fee program (DIF, TUMF, etc.) or not already fully funded by a previously approved project (WLC, Kaiser Permanente Medical Center, etc.), the Project applicant’s responsibility for the Project’s contributions towards cumulatively deficient intersections will be fulfilled through payment of fair share fees that would be assigned to construction of the identified cumulative improvements.
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In some cases, direct construction of the cumulative improvement by the Project may be eligible for fee credit or reimbursement through an applicable program where appropriate (to be determined at the City’ discretion).
2006 General Plan Objective and Policies related to the target LOS are as follows (emphasis added):
▪ Objective 5.3: “Maintain Level of Service (LOS) ‘C’ on roadway links, whenever possible, and LOS ‘D’ in the vicinity of SR 60 and high employment centers.” ▪ Policy 5.3.5: “Ensure that new development pays a fair share of costs to provide local and regional transportation improvements and to mitigate cumulative traffic impacts. For this purpose, require new developments to participate in Transportation Uniform Mitigation Fee Program (TUMF), the Development Impact Fee Program (DIF) and any other applicable transportation fee programs and benefit assessment districts.”
▪ Policy 5.3.6: “Where new developments would increase traffic flows beyond the LOS C (or LOS D, where applicable), require appropriate and feasible mitigation measures as a condition of approval.
Such measures may include extra right-of-way and improvements to accommodate left-turn and right-turn lanes at intersections, or other improvements.” ▪ Policy 5.3.7: “Provide consideration to projects that have overriding regional or local benefits that would be desirable even though the LOS standards cannot be met. These projects would be required to analyze traffic impacts and mitigate such impacts to the extent that it is deemed feasible.”
The LOS Traffic Analysis (Draft SEIR Appendix K3) and resulting framework of improvements are thus also consistent with Objective 5.3 and Policies 5.3.5, 5.3.6, and 5.3.7 of the 2006 General Plan. Table 6-1 of the LOS Traffic Analysis lists cumulative projects addressed in the traffic study, which include Village at Moreno Valley, Town Center at Moreno Valley Specific Plan, and WLC.
Pedestrian, bicycle, and transit access routes to/from the Project site are also addressed in the LOS Traffic Analysis with the goal of providing convenient and direct access for those users, consistent with 2006 General Plan Objectives 5.1 (safe, efficient, environmentally and financially sound provision of access and mobility), 5.2 (safe and adequate pedestrian and bicycle and public transit), 5.5 (efficiency of local circulation), 5.8 (accommodate efficient public transit), 5.9 (safe, efficient, and aesthetic pedestrian facilities), 5.10 (accommodate bicycling as an alternative), and 5.12 (efficient circulation at school sites).
Existing and planned transit routes, pedestrian facilities, and bikeways are identified for the Project area, and incorporation of the planned facilities into the proposed Project is discussed in Section 8.4 of the LOS Traffic Analysis. The internal street network will include a comprehensive sidewalk network to facilitate walking. The Project has begun coordination with RTA to implement transit improvements that are anticipated to improve transit access and connectivity for the Project and broadly the rest of the City of Moreno Valley.
In sum, the Draft SEIR contains a thorough analysis of impacts to roadways and 2006 General Plan standards related to roadways.
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Further, consistent with 2006 General Plan Policy 2.14.3, the Draft SEIR contains an analysis of Project impacts to public services and facilities including, roadways, water, sewer, fire, police, parks, and libraries and other public services or facilities in Sections 4.15, 4.17, 4.19, 5.3.15, 5.3.17, and 5.3.19, as well as Appendix A of the Draft SEIR. The City has accordingly reviewed this development Project for its impacts to public services and facilities.
O6-10 The comment recites 2006 General Plan Policy 2.18.4, which encourages the development of senior living and congregate care facilities. It states that there is no commitment to build senior housing as part of the Project and that it would be good if at least 4% of the Project would be designed for people with physical disabilities that come with age or because of military service.
Refer to Topical Response 6: Affordable Housing. As noted in Draft SEIR Appendix A and in the comment, this residential mixed-use Project would allow for uses that may include senior living and similar facilities, but does not require they be developed. The Project would also comply with all applicable laws, including Americans with Disabilities Act (ADA) and Title 24 building code requirements related to accommodating physical disabilities.
The City notes that the comment raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. The portion of the General Plan referred to does not involve a physical impact on the environment. Refer to Response to Comment O6-3. The purpose of the SEIR is to evaluate potential impacts on the environment resulting from the Project and to identify mitigation measures and alternatives that would avoid or substantially lessen significant environmental impacts while attaining most of the objectives of the Project. The SEIR is required to focus on physical impacts on the environment. Issues that are socio-economic or political in nature are generally not required to be addressed within a CEQA document. Thus, the City will include the comment as part of the Final SEIR for review and consideration by the decision-makers. However, no further response is required because the comment does not raise an environmental issue.
O6-11 The comment recites 2006 General Plan Policy 4.2.8, which encourages the development of recreational facilities with appropriate mechanisms to ensure they are maintained and remain available. It states City parkland standards are inadequate and the Project does not meet the standard on site. The commenter requests the location where off-site parkland would be acquired and maintained. The comment asserts that the water features (lakes) are not available for recreation and asks where active recreation and playground equipment will be located. It asserts that Lake Perris and the San Jacinto Wildlife Area cannot be considered viable choices for recreation and that more park acreage is needed to reduce VMT.
In response, parks and recreational facilities are discussed at length in Sections 4.15, Public Services, and 4.16, Recreation, of the Draft SEIR. The City has a parkland standard of 3 acres per 1,000 residents, which may be met through the provision of parkland, park facilities, the payment of in-lieu fees, or some combination of these actions. Here, 129.15 acres of parkland would be required for the Project to meet this standard for its residents; this acreage is proposed to be met on site and through payment of in-lieu fees.
The Project proposes the development of 80 acres of public parks on site, composed of 40 acres of lakes, a 15-acre lake promenade, and 25 acres of additional parks. The lake and lake promenade will offer a variety of recreational opportunities, including walking, biking, hiking, picnicking, meditating, 2 - RESPONSE TO COMMENTS
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canoeing and kayaking, swimming, paddle boarding, and other passive and active recreational uses.
Thus, contrary to the comment, the lakes would provide for active and passive recreational opportunities.
Neighborhood parks would provide passive and active recreational amenities as well, such as grass lawns, game courts (e.g., pickleball and basketball), children’s play facilities, group shade structures, picnic and cooking facilities, restrooms, seating, and trails. Landscaped, multi-use trails and walkways will traverse the site, connecting active and passive open space and parkland to the Town Center and neighborhoods. Appendix A of the Draft SEIR provides additional information concerning these on-site recreational facilities.
The Project would also include private amenities and open space, such as pools, gyms, common areas, rooftops, and private courtyards/plazas. The schools proposed at the Project site would provide recreational facilities for students residing within the Project, to be determined in coordination with the school district.
Section 7.3.7 of the Specific Plan Amendment, Appendix A to the Draft SEIR, addresses the financing and maintenance of improvements on site. The exact financing method would be determined in conjunction with phasing of development.
The Draft SEIR acknowledges an additional 49.15 acres of park facilities are needed, which are proposed off site. The site is envisioned as an urban core for the City, where the mixed uses of housing, schools, parks, lake, retail, and commerce strike a balance to create a vibrant and successful downtown. Thus, off-site park facilities are seen as appropriate. The need for an additional 49.15 acres of park facilities would be met by the Project through payment of an in-lieu fee in compliance with Municipal Code Sections 3.38 and 3.40. The City Council annually adjusts park fees. The City would use the In-lieu fees to maintain, improve, expand, or build new park facilities. Thus, parkland impacts were determined to be less than significant. The precise location of off-site park improvements would be determined by the City and subject to future CEQA compliance, including environmental analysis and mitigation, as appropriate. The 2040 General Plan identifies a number of potential future park locations throughout the City, including one at Redlands Boulevard and Cactus Avenue (approximately 2 miles from the Project site), one at Cottonwood Avenue (approximately 1.25 miles from the Project site), and one at Alessandro Boulevard and Perris Avenue (approximately 2 miles from the Project site).22
Section 4.16, Recreation, of the Draft SEIR also describes existing parkland and recreation in the vicinity of the Project. This includes five neighborhood parks (Woodland Park, Parque Amistad, Vista Lomas Park, Celebration Park, and Fairway Park) located close to the Project site. As described in Table
4.15-4 (p. 4.15-5) in Draft SEIR Section 4.15, Public Services, these parks include barbecues, basketball courts, pickleball courts, an athletic field, playgrounds, tennis courts, softball/baseball fields, a soccer field, a tot lot, a volleyball court, walking paths, and other amenities (City of Moreno Valley 2021a). In addition, the Vista del Lago High School, Landmark Middle School, and La Jolla Elementary School provide indoor and outdoor recreational facilities for area students, including a football field, baseball/softball fields, tennis courts, track and field facilities, basketball courts, blacktop 22 The 2040 General Plan was not set aside on issues related to parkland. The City has identified approximately 67.69 acres of land for new parks.
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courts, and playground facilities. The private Rancho del Sol Golf Club is located about 0.5 miles east of the Project site. The club includes an 18-hole golf course and disc golf course.
Approximately 0.5 miles south of the Project site is the 8,800-acre Lake Perris State Recreation Area, which provides a myriad of recreational activities, including hiking, bicycling, rock climbing, horseback riding, camping, picnicking, fishing, swimming, water sports, and boating. Improved trails are provided along the boundaries of and throughout the Lake Perris State Recreation Area. Other regional facilities include the 3,400-acre Box Springs Mountain Reserve Park (approximately 5.25 miles from the Project site), Norton Younglove Reserve (approximately 4 miles from the Project site), and the 19,000-acre San Jacinto Wildlife Area (approximately 3 miles from the Project site. The Draft SEIR does not rely on these off-site facilities, but nevertheless notes they will be available to serve Project and area residents.
In sum, the Project incorporates development of recreational facilities with appropriate mechanisms to ensure they are maintained and remain available and incorporates payment of in-lieu fees for appropriate off-site parkland acquisition and maintenance. The comment asserts the City’s parkland standard of 3 acres per 1,000 residents or payment of an in-lieu fee is inadequate, but City notes the comment raises general economic, social, or political issues that are beyond the scope of this Project’s Draft SEIR. However, the City will include the comment for consideration by the decision-makers.
O6-12 The comment recites 2006 General Plan Goal 5.1, which aims to develop a safe, efficient, environmentally and financially sound, integrated vehicular circulation system consistent with Circulation Element Map, Figure 9-1. The comment objects to citing prior improvements where there has been a change in dwelling unit quantity. It requests redesign of Nason Street as a Complete Street with many forms of urban transportation (specifically with bus turnout curb cuts).
In response, overall the Project will implement an efficient, environmentally and fiscally sound, and integrated circulation system as set forth in Chapter 4, Infrastructure, of the Specific Plan Amendment (Draft SEIR Appendix A). Improvements already completed consistent with the 2006 General Plan Circulation Element related to prior project approvals include the realignment and development of fourlane Nason Street and other improvements along Cactus Avenue.
Within the Project area, Nason Street is a four-lane road with bicycle lanes and sidewalks on both sides.
Nason Street is served by RTA Routes 20, 41, and 31 (see Section 3.1 of the LOS Traffic Analysis, Draft SEIR Appendix K3). Figure 6-5 of the Specific Plan Amendment (Draft SEIR Appendix A) shows Nason Street will be further improved to include a landscape median, landscape setback, and meandering Class I multi-use trail on the Project site. Nason Street terminates at the southern portion of the Project site.
Table 6-2 of the LOS Traffic Study (Draft SEIR Appendix K3) indicates that for Horizon Year 2045 With Project conditions, intersections along Nason Street within the Project boundary are anticipated to operate at LOS A, B, or C with improvements. Thus, four-lane Nason Street is anticipated to adequately serve the 15,000-unit Project.
Also, as explained in Section 4.17.7.2 of the Draft SEIR (p. 4.17-47), PDF-TRANS-1 through PDF-TRANS12 (project design features), in addition to land use design features, would reduce the Project’s trips and VMT. Project design features include the following:
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Residential Trip Reduction Measures:
▪ Community-based travel planning
▪ Unbundle residential parking costs from property costs Employee Commute Trip Reduction Measures:
▪ Commute Trip Reduction Program marketing
▪ Rideshare Program
▪ End-of-trip bicycle facilities
▪ Discounted Transit Program for work trips
Project-Generated Trip Reduction Measures:
▪ Micromobility on site and connecting to adjacent uses, such as schools and medical centers:
- Non-Electric Bikeshare Program
- Electric Scootershare Program
Transit Network Improvements:
▪ Extend transit network coverage to existing and future employment centers, such as WLC - Extend transit hours for all shift times, such as the midnight shift change at WLC - Increase transit service frequency
- Bus rapid transit along Alessandro Boulevard
- A state-of-the-art mobility hub is proposed on site to bolster the effectiveness of active transportation options
Curb cuts for bus turnouts will not be provided. According to the Federal Transit Administration, buses often experience substantial delays when reentering the traffic stream after a curbside stop in a bus turnout. This type of delay does not occur if the bus travels and stops in a curb lane (where on-street parking is not permitted). As far as bus passengers and operators are concerned, it is often best to avoid the use of bus bays if possible. Thus, the Project does not propose such curb cutouts. Transit network improvements would be coordinated with the RTA.
O6-13 The comment recites 2006 General Plan Objective 5.3, which is to maintain LOS C on roadway links wherever possible and LOS D in the vicinity of State Route (SR) 60 and high employment centers. The comment states LOS C or D cannot be maintained along all Nason Street intersections or at the SR-60 interchange. The comment also references 2006 General Plan Policies 5.3.2, 5.3.4, 5.3.5, and 5.3.6.
The comment asserts that TUMF and DIF fees are known to be inadequate, and that all mitigation measures are required to be implemented to achieve LOS D.
Refer to Response to Comment O6-9, which explains the comment does not raise an environmental issue for CEQA purposes as LOS is no longer the CEQA metric used to evaluate transportation impacts.
Thus, the Project’s CEQA transportation impact analysis in the Draft SEIR uses the VMT metric to 2 - RESPONSE TO COMMENTS
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evaluate and disclose Project impacts in a manner consistent with CEQA and current state laws and policies.
Nonetheless, Response to Comment O6-9 also addresses the locations where the analysis of impacts and proposed improvements can be found in Appendix K3 of the Draft SEIR. The recommended improvements needed to address the cumulative deficiencies identified under Horizon Year (2045) Without Project (Approved SP) and Horizon Year (2045) With Project traffic conditions are shown in Table 8-1 of the LOS Traffic Analysis (SEIR Appendix K3).
For those improvements listed in the Without Project (Approved SP) column of Table 8-1 and not already included in an adopted fee program (DIF, TUMF, etc.) or not already fully funded by a previously approved project (WLC, Kaiser Permanente Medical Center, etc.), the Project applicant’s responsibility for the Project’s contributions towards cumulatively deficient intersections will be fulfilled through payment of fair share fees that would be assigned to construction of the identified cumulative improvements.
Table 6-2 of SEIR Appendix K3 indicates that Nason Street at the SR-60 interchange ramps would experience acceptable operations with the following improvements:
▪ Provide one northbound right turn lane
▪ Modify eastbound approach to provide the following:
- One shared left/through lane
- Two right turn lanes
With all feasible improvements at the Nason Street/Cottonwood Avenue intersection, operations at this one Nason Street intersection would not achieve LOS C operations for Horizon Year (2045) without or with project conditions.
The Project is not inconsistent with 2006 General Plan Objective 5.3. Furthermore, the Project is shown to be consistent with Policies 5.3.5 (pay fair share costs and participate in TUMF and DIF Programs) and 5.3.6 (include mitigation measures where appropriate and feasible) of the 2006 General Plan.
In response to the comment that the TUMF and DIF fees are known to be inadequate, the City and County regularly review these programs and adjust these fees to demonstrate adequate nexus between the fee imposed, development proposed, and need for capital improvements. Requiring the Project to pay more than its fair share for certain cumulative impacts would be inconsistent with state and federal law. Nonetheless, the City will include the comment as part of the Final SEIR for consideration by the decision-makers.
O6-14 The comment recites 2006 General Plan Policy 5.8.1, which seeks to support the development of highspeed transit and express routes. The comment states that the Project needs to find a way to allow Delphinium Avenue and John F Kennedy Drive to continue unimpeded east to west through the Project.
It suggests impediments restrict transit, buses, and cars, increasing traffic. The comment asks where the curb cuts are along Nason to accommodate buses, and asserts the Project is inconsistent with Policy 5.8.1 for those reasons.
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In response, the Project is consistent with the 2006 General Plan Circulation Element Map, which does not include the extension of Delphinium Avenue and John F Kennedy Drive east–west through the Project site.
As noted in Response to Comment O6-12 above, curb cuts for bus turnouts will not be provided along Nason Street. Nason Street from Alessandro Boulevard to Cactus Avenue is currently a four-lane road with bicycle lanes and sidewalks on both sides. The stretch of Nason Street from Alessandro Boulevard to Cactus Avenue is served by RTA Routes 20, 41, and 31. From Cactus Avenue to Iris Avenue, Nason Street is a four-lane road with bicycle lanes and an east side sidewalk.
Table 6-2 of the LOS Traffic Study (SEIR Appendix K3) indicates that for Horizon Year 2045 With Project conditions, intersections along Nason Street within the Project boundary are anticipated to operate at LOS A, B, or C with improvements.
According to the Federal Transit Administration, buses often experience substantial delays when reentering the traffic stream after a curbside stop in a bus turnout. This type of delay does not occur if the bus travels and stops in a curb lane (where on-street parking is not permitted). As far as bus passengers and operators are concerned, it is often best to avoid the use of bus bays if possible. Thus, the Project does not propose such curb cutouts. Transit network improvements would be coordinated with the RTA.
The Project is generally consistent with Policy 5.8.1 for the reasons described in Draft SEIR Appendix A:
Residents will be able to make use of RTA bus routes and on-demand connections to the Metro and Amtrak station west of I-215. RTA may determine to implement additional highspeed transit and express routes in the City in the future. Enhanced transit/a tram, ridesharing, electric bicycles and vehicles, use of transportation network companies (Uber and Lyft), and intelligent transportation systems, transportation demand management measures will be provided as part of the Project. In addition, shuttles provided as part of the Project would connect the site, Downtown Center, and its adjacent hospital complex to the World Logistics Center, benefitting citizens and employers in the City.
See also Response to Comment O6-12, describing the transit network and other transportation related improvements proposed as Project design features (PDF-TRANS-1 through PDF-TRANS-12), outlined in Section 4.17.7.2 (p. 4.17-47) of the Draft SEIR.
O6-15 The comment recites 2006 General Plan Objective 6.6, which seeks to promote land use patterns that reduce VMT and trip distance to work, shopping, schools, and recreation. The comment states 25 acres of commercial is insufficient and there needs to be a unit reduction. The comment cites Policies 6.6.1,
6.6.2, and 7.5.2 and Objective 6.7, and also states the Project can reduce mobile source air pollutant emissions.
In response, please see Response to Comment O6-6. This addresses the request for a greater commercial or reduced density alternative to the Project.
Section 4.17 of the Draft SEIR evaluates Project impacts related to VMT. The Draft SEIR found the Project would result in less than significant VMT impacts. 2 - RESPONSE TO COMMENTS
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The Project proposes to develop a new commercial Town Center, which will provide a vibrant mix of business, entertainment, and other uses consistent with 2006 General Plan Policies 6.6.1 and 6.6.2, which address encouraging commercial uses near residential uses (and vice versa) and encouraging pedestrian travel. The surrounding hospitals and employment centers (e.g., Riverside University Health System Medical Center, the Kaiser Permanente Hospital and medical complex, Moreno Valley College, and the WLC) allow for reduced trips to work, consistent with Objective 6.6 and Policy 6.6.2. 2006 General Plan Objective 6.7 is related to reducing mobile and stationary source air pollutant emissions, while Policy 7.5.2 encourages energy efficient modes of transportation and fixed facilities.
The commenter is referred to Sections 4.3, 4.8, and 4.17 of the Draft SEIR. The Project would implement numerous PDFs to reduce air quality and GHG emissions, particularly those related to transportation. These include PDF-AQ/GHG-1 through PDF-AQ/GHG-15, PDF-TRANS-1 through PDFTRANS-15, and PDF-LU-1 through PDF-LU-11. Transportation and land use PDFs would reduce vehicle use and associated air pollutant emissions.
More specifically, on land use planning, PDF-LU-1 through PDF-LU-11 address how the Project’s land use pattern reduces VMT and promotes walkability/bikability. The Project incorporates mixed-use design, an urban core, short walkable blocks of 600 feet in length, increased residential density, walkable/bikeable improvements (including to off-site job centers), transit benefits, integrated design and multi-modal programs, integrated project features, complete streets, traffic calming, and roundabouts to support multimodal transit and pedestrian, bike, and scooter travel. Concerning transportation and transit improvements, see Response to Comment O6-12, above, and Responses to Comments I1-13 to I1-15.
Mitigation was further identified for significant air quality impacts in MM-AQ-1 through MM-AQ-11.
Despite the incorporation of all feasible mitigation, impacts to air quality would be significant and unavoidable. See Topical Response 2, Air Quality, for additional information.
See also Draft SEIR Appendix A, which provides additional reasons the Project would be consistent with the policies referenced. For each of these reasons, the City has determined the Project would be consistent with 2006 General Plan Objectives 6.6 and 6.7 and Policies 6.6.1, 6.6.2, and 7.5.2.
O6-16 The comment recites 2006 General Plan Goal 7.1, which aims to achieve the wise use of natural resources in the City. The comment states that special-status species may occur on site and require mitigation and that the proposed lakes and parks are insufficient. The comment states that the riparian area within the Riverside Flood Control channel needs to be mitigated at a 3:1 ratio and that there are
31.1 acres of riparian habitat, of which 13.1 acres are being protected. The comment asks how this will be managed and protected. It states the Project is also inconsistent with 2006 General Plan Objective 7.4.
Objective 7.4 is to “Maintain, protect, and preserve biologically significant habitats where practical, including the San Jacinto Wildlife Area, riparian areas, habitats of rare and endangered species, and other areas of natural significance.” The Project is not inconsistent with Goal 7.1 or Objective 7.4 because the Project would develop an infill site that is 70% disturbed and was previously graded. This would prevent urban sprawl into areas with greater natural resources and would avoid sensitive habitats including the San Jacinto Wildlife Area, riparian areas, and habitats of rare and endangered species.
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The Draft SEIR, pages 4.4-1 to 4.4-2 explains as follows:
Currently, approximately 70% of the Project site is characterized as highly disturbed due to historical agricultural operations and as a result of the initial grading of much of the site associated with earlier project approvals, particularly with contouring for a planned artificial lake feature. A total of 24% of the site is dominated by non-native grasses that have established following past agriculture and grading activities. As a result of the high level of historical disturbances, the Project site does not support the original natural landscape or soil surfaces that occurred prior to disturbance. As shown in Table 4.4-1, only approximately 6% of the site supports areas of native vegetation, most of which is within a riparian revegetation area extending along the Line F channel along the southern edge of the existing Riverside County flood control channel (Figure 4.4-1). This channel was established as a riparian restoration site to mitigate impacts to existing aquatic features under California Department of Fish and Wildlife (CDFW) and/or federal U.S. Army Corps of Engineers (USACE) jurisdiction associated with earlier project approvals in the early 2000s.
A total of 11.9 acres of riparian vegetation was planted along this channel to satisfy CDFW/USACE mitigation requirements. In addition to serving as mitigation for impacts to aquatic resources, the Line F riparian mitigation channel was also intended to serve a number of resource-related purposes, including providing for short-term flood water retention and water flow energy dissipation; providing long-term storage of urban stormwater runoff; improving nutrient cycling and retention of soil particulates; and serving as important wildlife habitat for a number of common and sensitive wildlife species. The Line F riparian mitigation channel will be preserved in perpetuity.
Thus, the riparian area within the existing Riverside County flood control channel has already been mitigated and preserved in perpetuity as part of prior approvals.
The Draft SEIR also explains that while 81 species of plants were identified on site, none of the non-listed special-status plant species reported in the California Natural Diversity Database, U.S. Fish and Wildlife Service, and California Native Plant Society databases as occurring within the vicinity of the Project site were determined to have a potential to occur on the Project site. There are three listed special-status plant species—San Jacinto valley crownscale (Atriplex coronata var. notatior) (federally endangered), thread-leaved brodiaea (Brodiaea filifolia) (state endangered, federally threatened), and spreading navarretia (Navarretia fossalis)—that were determined to have a low potential to occur within the Project site; however, the Project is not within a Criteria Area Species Survey Area or Narrow Endemic Plant Species Survey Area, and therefore these species are considered fully covered by the Western Riverside Multiple Species Habitat Conservation Plan (MSHCP) following payment of the Local Development Mitigation Fee (Draft SEIR Section 4.4.1, pp. 4.4-4 through 4.4-5).
The Draft SEIR also explains that a total of 16 special-status wildlife species reported in the California Natural Diversity Database and U.S. Fish and Wildlife Service databases as occurring within the vicinity of the Project site were determined to have some potential (albeit low) to nest/breed or otherwise occur on the Project site in its current condition (Draft SEIR Section 4.4.1, pp. 4.4-6 through 4.4-14, including Table 4.4-2). Of these species, 14 are considered “covered species” under the MSHCP (i.e., potential impacts or “take” of these species are addressed and mitigated for by various provisions in the MSHCP). Nine of these covered species require no additional surveys or analysis is required. Five of these species, burrowing owl (Athene cunicularia), least Bell’s vireo (Vireo bellii pusillus), Riverside fairy 2 - RESPONSE TO COMMENTS
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shrimp (Streptocephalus woottoni), San Diego fairy shrimp (Branchinecta sandiegonensis), and vernal pool fairy shrimp (Branchinecta lynchi), though covered by the MSHCP, are subject to additional surveys that were prepared, the results of which are provided in Appendix E of the Draft SEIR. Two species— long-eared owl (Asio otus) and Crotch’s bumble bee (Bombus crotchii)—are not listed as covered species. Long eared owl has low potential to occur. Surveys were prepared for Crotch’s bumble bee, and the species was not found (Draft SEIR, Appendix E).
Mitigation was incorporated in the Draft SEIR for potential impacts to nesting birds, including lease Bell’s vireo and burrowing owl.
As for on-site riparian habitat, the Draft SEIR explains that only two vegetation communities are sensitive and that the riparian habitat is generally small and fragmented, such that the loss of these small patches of habitat is not considered a substantial effect on a riparian or sensitive natural community. It continues in Section 4.4.2, page 4.4-28, of the Draft SEIR :
While the cottonwood–red willow/arroyo willow/mulefat association occurring within the Line F mitigation channel will be preserved in perpetuity, the black willow/mulefat association occurring within the riparian area at the eastern terminus of the Riverside County flood control channel is just outside the Line F mitigation channel. Because the Black Willow/Mulefat Association in this area is relatively small, is fragmented from any other similar vegetation in the area, is essentially surrounded by residential development, and is disturbed through ongoing human activity (off-road vehicles and pedestrian traffic), the loss of this community, in and of itself, resulting from any proposed development within this area would not be considered a substantial adverse effect on any riparian habitat or other sensitive natural community. As such, these impacts would be less than significant.
As previously noted, because least Bell’s vireo is a covered species under the MSHCP, any loss of occupied habitat or direct take of this species in this riparian area would be mitigated through the conservation measures incorporated into the MSHCP.
Thus, the Draft SEIR found that impacts related to riparian habitat would be less than significant.
Mitigation is not required for this less than significant impact.
O6-17 The comment recites 2006 General Plan Goal 8.7, related to affordable rental units. The comment states the Project only encourages, but does not require, senior or low-income housing. It states 4% of housing units should be senior housing. It states this comment also applies to 2006 General Plan Goal
8.8 and Policy 8.7.1.
Goal 8.8 is to create affordable housing for seniors, while Policy 8.7.1 is to eliminate substandard housing for low-income renters. Refer to Response to Comment O6-10 and Topical Response 6. As explained therein and in Draft SEIR Appendix A, while the Project homes would not be income restricted, the Project would be affordable by design, as the Project’s home types and sizes would be within the financial means of most people in the Project area, including seniors and others.
Additionally, the portion of the General Plan referred to does not involve a physical impact on the environment. Refer to Response to Comment O6-3.
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O6-18 The comment states since the Project is planned to be constructed over phases, compliance with current Title 24 should be required.
In response, the Project will be required to comply with current, updated Title 24 standards in effect at the time of submittal of the building permit application for the various phases of Project development.
Thus, the Project is anticipated to become more energy efficient in future years.
O6-19 Citing the “significant irreversible effects” discussion in the Draft SEIR, the comment states that Project solar requirements are limiting and that the Project should include backup battery storage and otherwise mitigate the “wasteful use of energy.” The comment asks whether the proposed buildings will have covered parking and whether such parking includes solar. The comment says the Project must continually increase solar to meet energy demands.
In response, while the Draft SEIR explains the Project would consume more energy than is currently consumed on site, it would consume less than prior approvals due to the many federal and state regulations that have been adopted that require the use of renewable resources and substantially reduced building energy consumption. Further, while a portion of the energy used would be provided by nonrenewable sources during operation, the commitment of nonrenewable resources would be modest and expected to continue to decline during Project operation.
The Project would implement numerous PDFs that reduce energy use, air pollutant emission, and GHGs, including PDF-AQ/GHG-1 through PDF-AQ/GHG-15, PDF-TRANS-1 through PDF-TRANS-15, and PDF-LU-1 through PDF-LU-11. These features provide for building electrification, solar photovoltaic, efficient energy use and reduced energy demand, reduced water use and demand, reduced solid waste generation, tree planting, and reduced vehicle trips and VMT. Thus, the Project would not result in the wasteful use of energy, and no mitigation is required.
Project PDF-AQ/GHG-4 requires the Project provide rooftop photovoltaic solar panels on all residential and non-residential buildings in accordance with Title 24. Annual solar production is identified at 48,122,091 kilowatt hours. Pools’ and spas’ heating demands will also be served by a minimum 50% solar water heating.
Remaining electricity needs would be provided by the Moreno Valley Electric Utility (MVU). MVU does not provide the option of opting into clean electricity. According to the 2022 power content label for MVU, renewable solar energy accounts for 33.4% of the utility’s overall energy resources; this percentage is anticipated to increase over time in compliance with state law (MVU 2023; Draft SEIR Section 4.6, p. 4.6-1). The state Regional Portfolio Standard program, as expanded and updated, currently requires the following percentage of retail sales of electricity to California end-use customers to come from eligible renewable energy resources and zero-carbon resources: 90% by December 31, 2035; 95% by December 31, 2040; and 100% by December 31, 2045. Because MVU is required to meet the state Regional Portfolio Standard milestones, the Project would benefit from this cleaner electricity provided by MVU. See Section 4.6.2 of the Draft SEIR (pp. 4.6-2 through 4.6-11) for discussion of Regional Portfolio Standard standards and milestones.
As for battery storage, the Project would comply with Title 24 standards, including those related to battery storage. The City further notes that battery storage does not reduce energy usage, but merely 2 - RESPONSE TO COMMENTS
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diverts the timing of energy use. Connecting to MVU’s electricity grid will similarly provide for the efficient—and progressively more renewable—use of energy.
Concerning Project garages and parking structures, Aquabella residential and Town Center parking will be provided in public and private multi-car parking garages as an integral part of the building architecture. Some projects may have open parking areas, which will be landscaped with hedges or decorative walls to screen the parking from adjacent streets. Exterior parking lots will incorporate shade trees in planters to reduce heat and provide visual relief. PDF-AQ/GHG-4 would apply to residential and non-residential parking structures. The Project would also be subject to Title 24 solar requirements, which factors in solar roof access area, which is the total of a building’s roofs, covered parking, carports, and other structures that can support solar.
O6-20 The comment states recycling must be included near stairs and elevators for people with disabilities and organic waste bins at each building. As detailed in Section 4.19.4.2 of the Draft SEIR (p. 4.19-23), the Project would be required to comply with the City’s Municipal Code regarding solid waste and recyclable material storage areas (Municipal Code, Section 6.02.050). Additionally, the City’s building code requires development projects to complete and submit a waste management and recycling plan for approval prior to issuance of building permits. The waste management and recycling plan would identify the project type and estimate the amount of materials to be recycled during construction.
Finally, the Project would comply with the current California Green Building Code (Title 24), which requires construction waste recycling. Chapter 6.03 of the City’s Municipal Code similarly provides for waste reduction and recycling, and Section 6.03.130 requires compliance with the California Green Building Code (Title 24) recycling requirements or more stringent requirements of the City for new construction. This includes providing access for “three container” collection services, which includes blue container recyclables and green container organics collection. Waste handling services within the City are provided under contract by Waste Management of Inland Valley, which provides trash, recycling, and green waste pickup (Draft SEIR Appendix A, Section 4.6). Accordingly, the Project will provide ample opportunities for residents to recycle, and would include organic waste bins.
O6-21 The comment states the San Jacinto Wildlife Area and Lake Perris are world class birding areas and states it is important for the Project to provide off-site mitigation for loss of riparian habitat. See Response to Comment O6-16 regarding riparian habitat. Regarding raptor foraging, as described in Section 4.6.1 of the Draft SEIR (pp. 4.6-1 through 4.6-2), the Project site has been substantially disturbed due to historical agricultural activities and previous grading (associated with earlier Project approvals) that has occurred over the entire Project site over the past two decades. Currently, approximately 70% of the Project site is characterized as highly disturbed and unvegetated due to these past activities, with another 23% of the Project site dominated by non-native grasses that have established following the previous historical activities; the remaining 6% of the Project site supports areas of native scrub and riparian vegetation, most of which is within a riparian revegetation area extending along the southern edge of the existing County Flood Control Channel that was established and preserved as mitigation associated with previously acquired state and federal wetland permits.
As a result of the high level of historical disturbances, the approximately 668-acre Project site that would be impacted due to Project implementation does not support the original natural landscape or soil surfaces that occurred prior to such disturbance, thus providing limited habitat suitability for the prey base (small mammals) preferred by most raptor species in the Project area. In addition, the Project 2 - RESPONSE TO COMMENTS
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site is surrounded by dense residential and commercial development. As such, the Project site is considered to be low quality foraging habitat for raptor species known to occur in the region.
Further, as the comment notes, approximately 27,800 acres of protected areas occur to the south and east of the Project (including 8,800 acres associated with Lake Perris State Recreation Area and 19,000 acres associated with the San Jacinto Wildlife Area). These large-scale areas include extensive areas of natural raptor foraging and nesting habitat for a variety of raptor species. Extensive undeveloped land also occurs east of Gilman Springs Road to the east of the Project site.
As such, given the heavily disturbed nature of the land within the Project site and its consequent low value as raptor foraging habitat, and given the extensive amount of high quality foraging habitat in the vicinity of the Project site, the loss of 668 acres of land associated with Project implementation does not give rise to a significant Project impact under CEQA; therefore, no mitigation for the loss of this acreage as potential raptor foraging habitat is necessary or required at the Project level.
O6-22 The comment states that cities and counties require buildings to include techniques to reduce bird strikes, largely focused on windows and lighting. The comment asks how the Project will protect birds from striking buildings.
As discussed in Section 4.1, Aesthetics, of the Draft SEIR and Section 6, Design Guidelines, of the Specific Plan Amendment (Draft SEIR Appendix A), the Project incorporates numerous design features that would minimize bird strikes. The Project would be designed to minimize glare and reflective materials and finishes. Use of highly reflective building materials, such as polished metal or reflective glass, are discouraged and permitted only as accent elements. Glass would not be continuous. Lighting would be appropriately focused and shielded (see Response to Comment O6-8). Please refer to the Design Guidelines for further details on exterior materials and lighting, which complies with the suggested techniques to reduce bird strikes.
O6-23 The comment notes the Project would result in significant and unavoidable impacts to air quality. The comment states the commenter believes more can be done to reduce significant and unavoidable impacts. Refer to Topical Response 2. As described in the Draft SEIR, health risk impacts would be reduced to below significance.
The comment otherwise addresses general subject areas, which received extensive analysis in the Draft SEIR. The Draft SEIR found impacts related to air quality would be significant and unavoidable.
As the comment does not raise any specific issue regarding that analysis, no more specific response can be provided or is required. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision on the Project.
O6-24 The City acknowledges the comment and notes it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft SEIR. For that reason, the City provides no further response to this comment. The City notes the Sierra Club’s request for notices and will add Sierra Club to its mailing list.
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Response to Comment Letter O7
Organization
Mitchell M. Tsai- Western States Regional Council of Carpenters July 15, 2024
O7-1 The comment states that the letter is written on behalf of the Western States Regional Council of Carpenters, formerly the Southwest Mountain States Regional Council of Carpenters (labor union). The letter is submitted as comments in response to the City of Moreno Valley’s Draft SEIR for the Project.
The City acknowledges the comment as an introduction to comments that follow. This comment is included in the Final SEIR for review and consideration by the decision-makers prior to a final decision on the Project. No further response is required or necessary because the comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR.
O7-2 The comment includes general background information about the labor union. The City acknowledges the comment as a further introduction to comments that follow. This comment is included in the Final SEIR for review and consideration by the decision-makers prior to a final decision on the Project. No further response is required or necessary because the comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR.
O7-3 The comment provides a general summary of the Project and its description. For a complete description, please refer to Draft SEIR Chapter 1A, Executive Summary, Section 1A.2, pp. 1A-1 through 1A-7. This section describes the Project and includes the Project overview, objectives, location, and summary. This comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O7-4 The comment states that individual members of the labor union live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts. No facts or information is provided to support the comment. The City acknowledges the comment as a further introduction to comments that follow. This comment is included in the Final SEIR for review and consideration by the decision-makers prior to a final decision on the Project; however, no further response is required or necessary because the comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR.
O7-5 The comment states that the labor union reserves the right to supplement its comments at or prior to hearings on the Project. The comment does not raise any specific environmental issues regarding the adequacy of the Draft SEIR; therefore, no further response is necessary or required.
O7-6 The comment states that the labor union incorporates by reference all comments raising issues regarding the Draft SEIR that were submitted “prior to certification” of the Draft SEIR for the Project.
The comment does not raise any specific environmental issues related to the adequacy of the Draft SEIR; therefore, no further response is necessary or required.
O7-7 The comment requests that the City provide the labor union with all notices related to the Project issued under CEQA and the California Planning and Zoning Law. The City acknowledges the request and will continue to provide public notices in compliance with CEQA and the Planning and Zoning law. The 2 - RESPONSE TO COMMENTS
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comment does not raise any specific environmental issues related to the adequacy of the Draft SEIR; therefore, no further response is necessary or required.
O7-8 The comment states that the City should require the Project to be built using local workers who have graduated from a joint labor-management apprenticeship program approved by the State of California.
The comment further cites various sources to support the general statement that local hire requirements benefit the community, reduce environmental impacts, and would improve the positive economic impact of the Project. Additionally, the comment refers to an attached 2021 letter from Soil Water Air Protection Enterprise (SWAPE), dated March 8, 2021, the subject of which is “local hiring requirements and considerations for greenhouse gas modeling.” The SWAPE letter, which is more than 3 years old, is signed by Matt Hagemann, PG, C. Hg, and Paul E. Rosenfeld, PhD. Forfurtherinformation, please see Response to Comment O7-12. The comment further states that workforce policies have significant environmental benefits given that they improve an area’s jobs–housing balance, decrease the amount and length of job commutes and associated greenhouse gas (GHG) emissions, and reduce vehicle miles traveled, citing in part a voluntary hiring program encouraged by the City of Berkeley in Northern California.
First, requiring the Project to be built using local workers from an approved apprenticeship program does not raise any specific environmental issues related to the adequacy of the Draft SEIR; therefore, no further response is necessary or required.
Second, there is no CEQA or City code requirement that Project applicants must hire local construction labor through an approved apprenticeship program on a mixed-use/housing development project.
Consistent with CEQA, the Legislature’s intent is that courts, consistent with accepted rules of statutory interpretation, shall not interpret CEQA or the CEQA Guidelines in a manner that imposes procedural or substantive requirements beyond those explicitly stated in CEQA or the CEQA Guidelines (California Public Resources Code, Section 21083.1).
Third, the City has no legal authority over the hiring practices of private businesses as part of a discretionary development review process.
23 Additionally, there is no known feasible or enforceable mechanism for the City to utilize in order to accommodate the local hire requirement referenced in this comment. The City, through its environmental consultant, has reviewed publications regarding enforceability of local hire preference programs and related strategies for requiring contractors to establish jobs training or apprenticeship programs (Cantrell and Jain 2013; Gadbois et al. 2012). The publications have identified various legal issues associated with such programs, including various constitutional challenges to their validity under the Privileges and Immunities Clause, the Commerce Clause, and the Equal Protection Clause of the U.S. Constitution. Given such legal hurdles, local agencies have sometimes turned to contract-based tools, such as project labor agreements, development agreements, and community benefit agreements; however, those agreements require 23 The City acknowledges that local workforce hiring and training programs are used by public agencies on public works projects; in general, these programs encourage or require contractors on such projects to use local labor as part of the workforce. Other local agencies have used these programs to encourage local employment on public construction projects, which they say infuses public dollars back into the local workforce. However, other jurisdictions have experienced backlash against these policies because they are sometimes difficult to enforce, can be difficult to maintain compliance with, and can stifle competition and cause contractor costs to increase, which negatively impacts the production of housing. For these and other reasons stated herein, the City does not desire to require such programs.
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case-by-case negotiations and implementation. In this case, neither the City nor the Project applicant has shown an interest in such agreements, negotiations, or implementation.
Further, as shown in Draft SEIR Section 4.14, Population and Housing (p. 4.14-13), there is an existing and considerable pool of local construction workers within both the City and the County. This substantial pool can and should be used by contractors to complete construction of various phases of the Project.
Fourth, the comment does not provide any substantial evidence of a project-specific significant unavoidable project or cumulative impact related to GHG emissions, vehicle miles traveled, or transportation effects. Indeed, the Draft SEIR confirms that all such impacts have been reduced to lessthan-significant levels by applying applicable laws and regulations,requiring project design features, and imposing mitigation measures (e.g., Draft SEIR Chapter 1A, Tables 1A-2 and 1A-3, pp. 1A-12 through 1A-68).
For example, the Project’s required compliance with the measures included in the current California Energy Code (24 CCR Part 6) and the California Green Building Code standards requires the Project to include energy efficiency and green building standards such as solar, water efficient landscaping, construction material diversion, low-polluting construction finishing materials, and electric charging station installation. Additionally, as discussed in the Draft SEIR, the Project must comply with all mandatory measures to ensure that energy-related impacts would be less than significant. As discussed in Draft SEIR Section 4.8, Greenhouse Gas Emissions, the Project is also consistent with applicable strategies, actions, project design features, and mitigation for reducing GHG emissions (see also Draft SEIR Appendix K1, Trip Generation Assessment). Draft SEIR Section 4.17, Transportation, also confirms that the Project would not result in any significant unavoidable traffic or transportation-related impacts.
Fifth, as to air quality, Draft SEIR Section 4.3, Air Quality (p. 4.3.-68), confirms that all feasible and enforceable mitigation measures have been identified and included in the CEQA document and that construction-related air quality impacts associated with the potential for cumulatively considerable net increases in criteria pollutants have been reduced to less than significant with identified mitigation.
Sixth, the comment does not cite or refer to any “local workforce use” requirement or hiring program imposed by any city or county, regional regulatory agency, or state agency. While the comment provides source material suggesting that the City of Berkeley encourages businesses to hire local residents and sponsor training programs, no cited source mandates “local workforce use” or “training” for discretionary mixed-use development projects under CEQA review. The Project applicant will encourage contractors to hire locally, and the City also encourages, similarly to Berkeley, businesses to hire local residents, students, veterans, and unsheltered individuals using incentives. Additionally, the local Supervisorial District also encourages local hiring using incentives.
Seventh, while the comment states that local hire and training requirements could have environmental benefits, such as improving an area’s jobs–housing balance and decreasing the amount and length of job commutes and associated GHG emissions, the comment provides no project-specific data to support such claims, nor does it contest the adequacy of the Draft SEIR’s environmental analysis of transportation, air quality, and GHG impacts, including reductions in vehicle miles traveled. Based on a review of the Draft SEIR as a whole, the City has also determined that upon operation of the Project, it 2 - RESPONSE TO COMMENTS
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would facilitate a more balanced job–housing profile for the City by adding more housing and jobs to the City.
Additionally, Draft SEIR Section 4.14 determined that construction activities at the Project site would lead to the temporary need for construction workers, which may come from the City and the County.
Moreover, the City has determined that the Project would involve fairly common construction requirements that would not regularly require a highly specialized labor force to permanently relocate from otherregions. Due to the short-term demand and the Project site’s location within an urban region with a high volume and diversity of available skilled labor, a permanent need for newworkers to relocate is not anticipated. The comment doesnot contain any other or specific concerns related to the adequacy of the environmental analysis in the Draft SEIR; therefore, no further response is necessary or required.
O7-9 The comment refers to Assembly Bill 2011, which amended the Planning and Zoning Law in California.
The comment states that Assembly Bill 2011 “verified” the state’s commitment to workforce development. The Project is not proposed under the provisions outlined in Assembly Bill 2011; therefore, it is inapplicable. Further, the comment does not raise any specific environmental issues related to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O7-10 The comment summarizes the request that the City consider utilizing local workforce policies and requirements, again suggesting that such requirements would benefit the local area economically and mitigate environmental impacts. The City refers to the above responses addressing the comments summarized herein. The comment also does not raise any specific environmental issue related to the adequacy of the Draft SEIR; therefore, no further response is required or necessary.
O7-11 The comment raises concern regarding COVID-19 spread during construction activities and provides recommendations to the City to reduce risk during on-site construction work and practices. As described in Section 15064(d) of the CEQA Guidelines, CEQA requires the evaluation of physical changes in the environment that may be caused by a project and does not require analysis of the impacts of the existing environmental conditions on a project or its future residents or users.
Additionally, neither CEQA nor the CEQA Guidelines expressly require the analysis or mitigation of public health effects from COVID-19 or any other communicable virus (e.g., influenza, legionnaires disease) as potential project impacts to the environment. Further, such viruses are not caused or exacerbated by construction or development projects. If approved, the Project’s construction contractors can impose requirements for construction personnel to minimize the spread of COVID-19 or other viruses consistent with company policies and any local or state requirements that may be in place at the time.
Compliance with existing protocols from federal, state, and local public health agencies would address workplace health and safety. Finally, the comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR; therefore, no further response is required or necessary. The comment and recommendations, however, will be provided to the City’s decision-makers as part of the Final SEIR review process.
O7-12 The comment states that the Draft SEIR “should be revised and recirculated.” However, the immediate comment that follows simply provides background as to the scope of an SEIR, which is the type of document that has been prepared for the Project. The background is generally accurate. In summary, under CEQA and the CEQA case law, an SEIR, as was prepared for this Project, is required to evaluate only the changes in the Project, its circumstances, or significant new information that led to preparation of the 2 - RESPONSE TO COMMENTS
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later EIR. The Draft SEIR adheres to these CEQA requirements and summarizes the SEIR process (see Draft SEIR Section 1A.3, pp. 1A-7 through 1A-8).
Further, the comment does not identify any reason the Draft SEIR should be revised and recirculated.
Nonetheless, the City has considered the recirculation request, and finds that recirculation is not required by CEQA or the CEQA Guidelines for the reasons that follow.
CEQA Guidelines Section 15088.5 provides the legal criteria that a lead agency is to consider when deciding whether it is required to recirculate an EIR. Recirculation is required when “significant new information” is added to the EIR after public notice of the availability of the draft EIR is given, but before certification (14 CCR 15088.5[a]). “Significant new information” is defined in CEQA Guidelines Section 15088.5(a) to mean information added to an EIR that changes the EIR so as to deprive the public of a meaningful opportunity to comment on a “substantial adverse environmental effect” 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.”
An example of significant new information provided by the CEQA Guidelines is the disclosure showing that a “new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented” (14 CCR 15088.5[a][1]). Other examples involve a “substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted to reduce the impact to a level of insignificance” (14 CCR 15088.5[a][2]). Further examples involve a setting where a “feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it” (14 CCR 15088.5[a][3]).
Recirculation is not required where “the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR” (14 CCR 15088.5[b]). Recirculation also is not required simply because new information is added to the EIR—indeed, new information is regularly added given CEQA’s public/agency comment and response process and CEQA’s requirement to circulate proposed responses to comments submitted by public agencies to those agencies before certifying the final EIR. In short, recirculation is “intended to be an exception rather than the general rule” (Laurel Heights Improvement Assn. v. Regents of University of California [1993] 6 Cal.4th 1112, 1132).
These background comments do not raise any specific environmental issue related to the adequacy of the Draft SEIR nor do the comments explain why recirculation is required; therefore, no further response is required or necessary.
O7-13 The comment claims that the Draft SEIR “improperly labels mitigation measures as ‘Project Design Features’” (sometimes referred to as “PDFs”). The comment also states that the Draft SEIR’s use of project design features “violates CEQA because such measures would not be included” in the CEQArequired Project Mitigation Monitoring and Reporting Program to ensure enforcement. For that reason, the comment states that using project design features “in lieu of mitigation measures violates CEQA.” The City points out that the Project’s project design features are required by both the SEIR and Project conditions and are to be explicitly included in the Project’s Mitigation Monitoring and Reporting Plan.
These added requirements are expressly intended to ensure enforcement of all project design features.
Specifically, the Draft SEIR provides that, “All PDFs would be required as City-imposed Conditions of 2 - RESPONSE TO COMMENTS
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Approval to ensure they are implemented during construction and operation of the project” (Draft SEIR Section 4.6, p. 4.6-13). Further, “To ensure enforcement, the PDFs will be included in the Project’s Mitigation Monitoring and Reporting Plan (MMRP)” (Draft SEIR Section 1A.6, p. 1A-12).
For additional information, please refer to Topical Response 3, Project Design Features.
O7-14 The comment states that the Draft SEIR is “flawed” for relying on the City’s 2040 General Plan and its Climate Action Plan because the two documents are currently not in effect pursuant to the Riverside County Superior County’s writ of mandate issued in the City’s General Plan Update litigation. See Topical Response 1, SB 330 and General Plan Consistency Analysis.
O7-15 The comment provides concluding remarks and summarizes the comments referenced above. The responses provided herein address the concluding comments, respond to the opinions of the labor union, and do not raise any issue related to the adequacy of any specific section of the Draft SEIR. The City will include the comment as part of the Final SEIR for review and consideration by the decisionmakers prior to a final decision on the Project. No further response is required or necessary because the comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR.
O7-16 The comment refers to three attachments to the comment letter. Two of the attachments are the resumes of Paul Rosenfeld and Matt Hagemann. These resumes do not raise any specific environmental issue related to the adequacy of the Draft SEIR; therefore, no further response is necessary or required.
The third attachment is the March 8, 2021, SWAPE letter to Mitchell Tsai regarding local hire requirements and considerations for GHG modeling. The SWAPE letter is more than 3 years old, and it does not reference this particular Project, its impacts, or mitigation. The City and its consultants have thoroughly reviewed the SWAPE letter. It explains how the California Emissions Estimator Model (CalEEMod) calculates emissions from construction-related vehicle trips and discusses the relationship between trip length and GHG emissions. It is a generalized discussion, not made applicable to this Project. The SWAPE letter also provides an example of a local hire requirement for an example project.
However, the example is not applicable to this Project in the City of Moreno Valley; therefore, while considered, it is inapplicable and does not raise any specific environmental issue related to the adequacy of the Draft SEIR. The SWAPE letter also conducts an exercise using its sample project and the potential impacts of local hire requirements on estimated sample project-level GHG emissions, though it does not state that local hire requirements would result in reduced construction-related GHG emissions for all projects in all geographic areas. In short, the SWAPE letter is general and not applicable to the Project. Finally, the comment includes a disclaimer by SWAPE—the technical preparer.
The disclaimer provides that as additional information is made available, SWAPE may amend its technical report. The comment does not raise any specific environmental issue related to the adequacy of the Draft SEIR; therefore, no further response is required or necessary. 2 - RESPONSE TO COMMENTS
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Response to Comment Letter I1
Individual
Oscar A. Alvarez
July 15, 2024
I1-1 The comment is an introduction to comments that follow. The commenter also requests to be notified of future documents and meetings related to the Project.
The City acknowledges the comment as an introduction to comments that follow. The City will include the commenter to the list of people to receive public notices concerning the Project and its public hearings. This comment will be included in the Final SEIR for review and consideration by the decisionmakers prior to a final decision. Because the comment does not raise any environmental issues regarding the adequacy of the Draft SEIR, no further response is required or necessary.
I1-2 The comment states that the City has “one of the worst air quality conditions in the country” and that any new project will impact health if not designed properly. The comment also identifies various greenhouse gas (GHG) emission reduction objectives of the State of California and the federal government. It continues that the City’s 2006 General Plan is not up to date as it pertains to the climate crisis.
In response, Draft SEIR Sections 4.3.1 and 4.3.2 (pp. 4.3-1 through 4.3-20) describe the existing air quality conditions in the Southern California Air Basin (SCAB) and City. In summary, the SCAB is designated as a nonattainment area for national and California ozone standards and national and California standards for particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5). The SCAB also is designated as a nonattainment area for California standards for particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10); however, it is designated as an attainment area for national PM10 standards. The Riverside County portion of the SCAB is designated as an attainment area for national and California carbon monoxide (CO) standards, national and California nitrogen dioxide standards, national and California lead standards, and national and California sulfur dioxide standards (EPA 2023; CARB 2022c).
Despite the current nonattainment status, air quality in the SCAB has generally improved since the inception of air pollutant monitoring in 1976. This improvement is mainly a result of lower-polluting onroad motor vehicles, more stringent regulation of industrial sources, and the implementation of emission reduction strategies by the South Coast Air Quality Management District. This trend toward cleaner air has occurred despite continued population growth. PM10 levels have declined almost 50% since 1990, and PM2.5 levels have also declined 50% since measurements began in 1999 (SCAQMD 2013). Similar improvements are observed with ozone, although the rate of ozone decline has slowed in recent years.
The Draft SEIR evaluated potential Project impacts to air quality and health risks. Please refer to Topical Response 2, Air Quality; Draft SEIR Sections 4.3 and 5.3.3; and Draft SEIR Appendix D, Air Quality, Greenhouse Gases, and Energy Technical Report, for additional information. Impacts to health risks were determined to be less than significant with mitigation incorporated (Mitigation Measure [MM] AQ2) during construction and less than significant during operation. Accordingly, the Project has been designed to avoid significant impacts to human health.
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The Draft SEIR finds the Project would result in exceedances of South Coast Air Quality Management District thresholds for criteria air pollutants during Project construction and operation without mitigation. However, these impacts would be mitigated below significance during construction through implementation of MM-AQ-2 through MM-AQ-7. Operational impacts were determined to be significant and unavoidable for emissions of volatile organic compounds and oxides of nitrogen (both of which are precursors to the formation of ozone), CO, PM10, and PM2.5. Please see Appendix D of the Draft SEIR, pages 108–111, and its Appendix C for a discussion of health effects associated with criteria air pollutant emissions and why such effects cannot be reliably quantified given existing scientific constraints.
Responding to the comment about the state’s climate goals, Section 4.8.2 of the Draft SEIR (pp. 4.8-7 through 4.8-25) explains that the California Air Resources Board (CARB) adopted the 2022 Scoping Plan Update in December 2022, which outlines the state’s plan to reach carbon neutrality by 2045 or earlier, while also assessing the progress the state is making toward achieving its 2030 GHG reduction goal. Section 4.8.2 also describes the current regulatory framework concerning renewable energy and energy procurement, which requires the following percentage of retail sales of electricity to California end-use customers to come from eligible renewable energy resources and zero-carbon resources: 90% by December 31, 2035; 95% by December 31, 2040; and 100% by December 31, 2045.
The City notes the comment about the 2006 General Plan being outdated as relates to climate change.
Refer to Topical Response 1, SB 330 and General Plan Consistency Analysis, and Topical Response 4, GHG Emissions. As detailed therein, the Project’s Senate Bill (SB) 330 preliminary application was submitted on September 6, 2023, at a time when the following regulatory documents were in effect:
the 2040 General Plan (adopted by Resolution No. 2021-47 in June 2021), the Climate Action Plan, and related zone changes (adopted by Ordinance No. 981 in June and August 2021). However, the 2040 General Plan was the subject of litigation, and in May 2024, the Riverside County Superior Court issued a Judgment and Writ directing that the City set aside certification of the 2040 General Plan EIR and set aside approval of the 2040 General Plan, Climate Action Plan, and related Zoning Amendments until those errors are corrected (Sierra Club v. City of Moreno Valley, CVRI2103300, April 12, 2024, Minute Order).
Thus, Project consistency with the 2006 General Plan is evaluated in Appendix A, Specific Plan Amendment, of the Draft SEIR in the event it is the operative General Plan at the time of Project consideration for approval. Indeed, the City’s Resolution 2024-37 rescinding the previous approvals of the 2040 General Plan and associated documents due to the referenced litigation makes clear that “the 2006 General Plan, associated zoning, and associated EIR are no longer superseded and that the 2006 General Plan, Zoning, and associated EIR remain in place pending reconsideration and reapproval of the MoVal 2040 General Plan and associated zoning, and that the Housing Element (October 2022) remains in effect.”
However, the Draft SEIR also evaluates Project consistency with the City’s 2040 General Plan, Climate Action Plan, zoning, and up-to-date regional planning documents because the Project is an SB 330 preliminary application project. As such, upon the Project applicant’s submittal of the SB 330 application and payment of the required fee, the 2040 General Plan, Climate Action Plan, and Zoning were “frozen” in place (vested) for purposes of Project consideration and operate as the City’s valid regulations governing this SB 330 Project (despite the litigation) (see Topical Response 1). 2 - RESPONSE TO COMMENTS
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As to GHG emissions specifically, the significance determination methodology used in the Draft SEIR includes a three-pronged analysis comprised of the following:
▪ Consistency with the City’s Climate Action Plan: The SEIR evaluated the Project’s consistency with the City’s Climate Action Plan.
▪ Consistency with CARB’s Scoping Plan: The SEIR evaluated the Project’s consistency with the Scoping Plan and specifically Appendix D therein, which identifies “key project attributes” for residential and mixed-use projects to demonstrate alignment with the state’s GHG reduction objectives.
▪ Consistency with the Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS): The SEIR assessed the Project’s alignment with the GHG-related goals of the SCAG RTP/SCS.
Please refer to Topical Response 4 for a summary of the GHG analysis and refer to Section 4.8, Greenhouse Gas Emissions, of the Draft SEIR for the analysis.
The comment addresses general subject areas, which, as shown here, received extensive analysis in the Draft SEIR. The comment does not raise any specific issue regarding that analysis and, therefore, no more specific response can be provided or is required. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision.
I1-3 The comment states the Project’s Draft SEIR adds to the existing pollution problem and fails to contribute positively to state and federal goals. Please refer to Response to Comment I1-2 above, Topical Response 2, and Topical Response 4. The comment provides a general comment and unsupported opinion regarding the Draft SEIR and its significance findings. The analysis in the Draft SEIR is based on scientific and factual data, which has been reviewed by the City and reflects its independent judgement and conclusions.
Because the comment only generally questions the adequacy of the Draft SEIR, only a general response can be provided. No further response is needed or required. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision.
I1-4 The comment states the Final SEIR must have additional mitigation to reduce its GHG impacts and provide analysis that the Project becomes a “sink” rather than a “source” of new pollution. Please refer to Topical Response 4. To briefly summarize, Section 4.8 of the Draft SEIR describes that the Project would result in less-than-significant GHG impacts with mitigation incorporated, as evaluated pursuant to a three-part methodology. The Project’s sustainable design within an urban, infill area will minimize GHG impacts. Section 6.2.5 of the Specific Plan Amendment (Appendix A to the Draft SEIR) also explains that the size and scale of the Project allows an integrated, connected community that maximizes walkability and complements surrounding uses. Solar roofs, renewable building materials, water conservation, recycled water, smart irrigation, drought tolerant plants, and extensive tree planting and landscaping are all part of the Project’s sustainable design. Circulation and mobility elements will provide electric vehicle (EV) charging, bike, e-bikes, scooters, transit, bus/tram, multimodal, and walking transportation options.
The Project would implement numerous project design features (PDFs) to reduce GHGs, including PDFAQ/GHG-1 through PDF-AQ/GHG-15, PDF-TRANS-1 through PDF-TRANS-15, and PDF-LU-1 through PDF- 2 - RESPONSE TO COMMENTS
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LU-11. These features provide for building electrification, efficient energy use and reduced energy demand, reduced water use and demand, reduced solid waste generation, tree planting, and reduced vehicle trips and vehicle miles traveled (VMT). Please see Draft SEIR Section 4.8, pages 4.8-28 through
4.8-41, for further discussion of the Project’s GHG-reducing PDFs. MM-GHG-1 additionally requires that 56% of Project parking spaces, amounting to 13,074 spaces, will either be pre-wired for EV charging or equipped with Level 1 or Level 2 chargers. With this mitigation, impacts related to GHGs would be less than significant and consistent with federal, state, and local goals.
Refer also to Responses to Comments I1-13 through I1-15.
I1-5 The comment asks what environmental baseline in the Project area was used for comparison purposes.
The Draft SEIR explains that the document has been prepared as a “subsequent” EIR in accordance with CEQA Guidelines Section 15162, which states that additional CEQA review is not required unless there are substantial project changes, new circumstances, or new information showing significant impacts not previously addressed (14 CCR 15162; Draft SEIR Chapter 1, Introduction, p. 1-2). The Project site has undergone comprehensive environmental review in the 1999 EIR, 2003 Supplemental EIR, and 2005 Addendum. Thus, the effective “baseline” is the Project previously studied.
The Draft SEIR provides comparisons to the prior environmental documents, in light of the prior environmental review completed in contemplation of the prior projects. The Draft SEIR also evaluates impacts compared to existing conditions. Refer to Chapter 2, Environmental Setting, and Chapter 4, Environmental Impact Analysis, which provides the existing conditions, regulatory environment, and summary of previous impact analyses for each environmental issue area.
I1-6 The comment states the Draft SEIR fails to fully consider and calculate Project increases in GHG emissions and other air pollutants. Refer to Topical Response 4 and Topical Response 2 for a summary of the evaluation and calculations for air pollutant emissions and GHG emissions.
While the Project GHG impacts are not evaluated pursuant to a quantitative threshold of significance in the SEIR, emissions were quantified and provided in Draft SEIR Section 4.8 in Tables 4.8-7 through
4.8-11 (pp. 4.8-70 through 4.8-73). Table 4.8-11, Estimated Annual Operational Greenhouse Gas Emissions – Full Buildout - 2037, provides a summary of estimated annual GHG emissions with and without PDFs. MM-GHG-1 would further reduce GHG emissions by 76 metric tons of carbon dioxide equivalent per year.
As the comment does not raise a specific issue related to the adequacy of the Draft SEIR’s GHG analysis, no further response can be provided or is needed. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers.
I1-7 The comment asks for the location of the Draft SEIR’s analysis on air quality direct, indirect, growth inducing, and cumulative impacts on children and the elderly, and states the Draft SEIR is inadequate in evaluating this area. Refer to Topical Response 2; Topical Response 5, Growth Inducement; and Response to Comment I1-2. The Draft SEIR thoroughly evaluated these impacts in Section 4.3, Section
4.14.4.2, Section 5.3.3., Section 5.3.11, Section 6.2, and Appendix D. The analysis considers impacts to sensitive receptors, including children and the elderly and locations including schools and nearby medical facilities.
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The City notes the comment provides an unsupported opinion regarding the Draft SEIR analysis, which was the subject of detailed analysis based on scientific and factual data. This analysis has been reviewed by the City and reflects its independent judgement and conclusions. Because the comment only asserts the Draft SEIR is inadequate without supporting substantial evidence, no further response is needed or required. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision.
I1-8 The comment asks how the increase in GHGs and other pollutants impact Nason Street and its intersections at Nason and Iris and Nason and the State Route 60 interchange. It asks how the Project will reduce GHGs to meet state and federal goals.
Greenhouse Gas Emissions
As discussed in the Draft SEIR, GHG emissions contribute to an inherently global cumulative effect, not a localized air quality impact that would impact Nason Street and its intersections. “GHGs” refer to gases that absorb infrared radiation in the atmosphere. These GHGs accumulate and trap heat in the atmosphere (a “greenhouse effect”), contributing to global climate change, which has the potential to impact the environment related to air temperature and precipitation patterns. While climate impacts may be experienced locally, GHGs are not a localized pollutant that would accumulate at Nason Street intersections and impact human health (see Section 4.8 and Section 5.3.8 of the Draft SEIR and Center for Biological Diversity v. Department of Fish & Wildlife [2015] 62 Cal.4th 204, 219-220).
As to how the Project will reduce GHGs and meet state and federal goals, please refer to Topical Response 4. To briefly summarize, Section 4.8 of the Draft SEIR describes that the Project would result in less-than-significant GHG impacts with mitigation incorporated, as evaluated pursuant to a threepart methodology. The Project would implement numerous PDFs to reduce GHGs including PDFAQ/GHG-1 through PDF-AQ/GHG-15, PDF-TRANS-1 through PDF-TRANS-15, and PDF-LU-1 through PDFLU-11. Among other things, these features provide for building electrification (except for restaurant uses), efficient energy use and reduced energy demand, reduced water use and demand, reduced solid waste generation, tree planting, and reduced vehicle trips and VMT. Please see Draft SEIR Section 4.8, pages 4.8-28 through 4.8-41, for discussion of the Project’s GHG reducing PDFs.
The Project will also satisfy the “key attributes” identified by the California Air Resources Board’s 2022 Scoping Plan, Appendix D, Local Actions, for residential and mixed-use projects. Refer to Draft SEIR Section 4.8, Table 4.8-6 (pp. 4.8-61 through 4.8-66).
This Project includes providing EV charging infrastructure, being located on an infill site served by existing utilities and public services, not converting natural lands, developing transit supportive densities, reducing parking requirements, providing housing that would have VMT similar to 20% deedrestricted housing and be naturally affordable to lower-income residents, not eliminating existing affordable units, and incorporating building decarbonization measures. Because the Project would allow natural gas in restaurants, MM-GHG-1 requires that 56% of Project parking spaces, amounting to 13,074 spaces, will either be pre-wired for EV charging or equipped with Level 1 or Level 2 chargers.
With this mitigation, impacts would be less than significant and consistent with federal, state, and local goals.
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Refer to Responses to Comments I1-13 through I1-15 for additional information concerning Project features specifically raised by the commenter that would result in reduced GHG emissions.
Air Quality
Refer to Topical Response 2.
Localized impacts to area roadways are evaluated in Section 4.3 and Section 5.3.3 of the Draft SEIR.
Specifically, the Draft SEIR evaluates whether the Project would expose sensitive receptors to localized high concentrations of CO or contribute to traffic volumes at intersections that would cause a CO hotspot during construction or operation, either individually or cumulatively. The Draft SEIR found the Project would not expose sensitive receptors to localized CO concentrations above thresholds. Note that, because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily decreasing.
I1-9 The comment states the draft SEIR is inadequate for a large project and not consistent with the 2006 General Plan for its project size. The City acknowledges the comment about the size of the Project and Draft SEIR analysis and notes it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft SEIR. The Draft SEIR acknowledges the size of the Project. As no specific environmental issues is raised, no further response can be provided or is needed. The City will include the comment as part of the Final EIR for review and consideration by the decision-makers prior to a final decision.
The City notes the comment concerning consistency with the 2006 General Plan and notes that it expresses the opinion of the commenter on issues that received thorough analysis in the Draft SEIR.
Section 3.4.1 of the Draft SEIR (pp. 3-27 through 3-28) explains that a General Plan Amendment would be needed to accommodate the Project. The Draft SEIR describes the General Plan Amendment proposed to both the 2040 General Plan and 2006 General Plan, in the event the 2006 General Plan is operative at the time of Project consideration for approval for the reasons described in Topical Response 1.
To summarize, on September 6, 2023, the Project applicant submitted an SB 330 preliminary application “vesting” or locking in the then-effective standards applied to the Project. Refer to Topical Response 1: SB 330 and General Plan Consistency Analysis. Thereafter, in May 2024, the Riverside County Superior Court issued a Judgment and Writ directing that the City set aside certification of the 2040 General Plan EIR due to inadequacies identified in the Final Program EIR as to the issues of baseline GHG emissions, air quality, and energy use and set aside approval of the 2040 General Plan and related Zoning Amendments until those errors are corrected. Other than the Climate Action Plan, the 2040 General Plan itself was not found defective. Further, the Court did not prohibit the City from acting with respect to land use issues (Sierra Club v. City of Moreno Valley, CVRI2103300, April 12, 2024, Minute Order).
Accordingly, state housing law—including SB 330 and the Housing Accountability Act—requires the City to process and consider approval of this Project, a housing development project, based on the 2040 General Plan, Zone Amendments, and related approvals.
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The Project entitlements propose amendments to both the 2040 General Plan and the Aquabella Specific Plan, as well as a change of zone (rezone), to allow for the development of the Project’s 15,000 residences and related mixed-uses and non-residential uses. In addition, if the prior 2006 General Plan and Final EIR is the effective General Plan when the Project is considered for approval by the City Council, Draft SEIR Section 3.4.1 (pp. 3-27 through 3-28) explains that an amendment to the 2006 General Plan land use map, Figure 2-2, would be required to accommodate the Project.
As a result, the Draft SEIR describes the discretionary approvals sought if either the 2040 General Plan or the 2006 General Plan (and their related zoning) is in effect when the City Council considers Project approval (refer to Draft SEIR Section 1.2, pp. 1-3 through 1-4, and Appendix A). Project consistency with the 2040 General Plan is evaluated in the Draft SEIR in Section 4.11, Land Use and Planning, and Appendix A, with the Draft SEIR concluding the Project would be consistent with the 2040 General Plan.
The 2006 General Plan is also evaluated in Draft SEIR Appendix A. The analysis finds that, with the General Plan Amendment, the Project would be consistent with the 2006 General Plan.
Further, under CEQA, a conflict or inconsistency with an applicable plan is not, by itself, considered a significant environmental impact. Instead, the inconsistency must result in a significant physical impact for there to be a significant impact under CEQA (14 CCR 15064.7[d]). Here, no such impact is shown.
The final determination of consistency with the General Plan will be made by City Council.
As the comment does not raise any more specific issue regarding the Draft SEIR analysis, no more specific response can be provided. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision.
I1-10 The comment states the Final EIR must use roadway operating conditions and level of service (LOS) to demonstrate how traffic increases will impact Nason Street and various intersections along Nason Street. It asserts this analysis and mitigation must be provided or the Draft SEIR analysis is inadequate.
The comment does not raise an environmental issue for CEQA purposes. Draft SEIR Section 4.17, Transportation, specifically Section 4.17.2, Regulatory Framework (pp. 4.17-9 through 4.17-16), explain that LOS is no longer the CEQA metric used to evaluate transportation impacts. Thus, The Project’s CEQA transportation impact analysis in the Draft SEIR uses the VMT metric to evaluate and disclose Project impacts in a manner consistent with CEQA and current state laws and policies.
Specifically, in 2013, the state adopted SB 743, which mandated alternative metrics replace LOS for determining impacts relative to transportation in CEQA documents. In the past, environmental review focused on LOS and the delay vehicles experienced at intersections, which resulted in mitigation that involves increasing capacity. This, in turn, encouraged more vehicular travel and greater pollutant emissions. Additionally, improvements to increase vehicular capacity often discourage alternative forms of transportation, such as biking and walking.
Thus, in December 2018, the CEQA Guidelines were updated to add new Section 15064.3, which provides that transportation impacts under CEQA should be evaluated using a VMT metric, not LOS.
This new VMT methodology has been required for use with land use projects since July 1, 2020. Project transportation impacts have therefore been assessed using the VMT metric pursuant to state law in Draft SEIR Section 4.17. Impacts would be less than significant under this metric, and no mitigation is therefore required (see Draft SEIR Section 4.17.5.2, pp. 4.17-29 through 4.17-46). 2 - RESPONSE TO COMMENTS
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Further, Section 4.17.5.2 of the Draft SEIR (pp. 4.17-40 to 4.17-45) and Section 6.5 of Draft EIR Appendix K3, LOS Traffic Analysis, address off-ramp queuing. This analysis finds Nason Street/State Route 60 eastbound and westbound ramps are anticipated to experience acceptable levels of queuing.
The off-ramp lane has sufficient storage lengths available to accommodate queuing without spilling back and affecting the freeway mainline. Impacts related to queuing would be less than significant, and no mitigation is required.
The Draft SEIR further explains that the City required a summary of the Project’s traffic analysis using the LOS metric consistent with City General Plan requirements and for informational purposes. This LOS traffic analysis is provided as part of this Draft SEIR in Appendix K3. This appendix provides the information requested by the commenter, and also allows for a direct comparison to the prior LOS analyses completed for the prior projects.
For informational purposes, Exhibits 4-5, 4-7, 4-8, and 4-10 of Appendix K3 show the Project contributions to intersection volumes along Nason Street during AM and PM peak hours. Exhibits 4-11 and 4-13 show Project-only average daily traffic trips on Nason Street. Exhibits 6-1, 6-3, 6-4, and 6-6 of Appendix K3 show the Horizon Year (2045) plus Project intersection volumes along Nason Street during AM and PM peak hours. Exhibits 6-7 and 6-9 show Horizon Year (2045) plus Project daily traffic trips on Nason Street. Table 6-2 in Appendix K3 provides an Intersection Analysis for Horizon Year (2045) with Project, including at intersections along Nason Street, with and without improvements.
With improvements, all intersections evaluated along Nason Street are anticipated to meet the LOS standard at Horizon Year with Project, with the exception of Nason Street/Cottonwood Avenue in the AM peak hour.
Section 7 of Appendix K3 identifies that the Project would be subject to compliance with the City’s development impact fee program, the Riverside County Transportation Uniform Mitigation Fee, and fair share contributions for traffic signal and other transportation improvements, which are all aimed at ensuring that study area roadways and intersection expansions keep pace with the projected population increases. Appendix K3 Table 7-1 provides the Project’s fair share calculations for intersection improvements.
Section 8 of Appendix K3 summarizes the Project roadway and intersection improvements that will be completed, including those that will be completed as part of the Project on and off site or that the Project will support through the payment of fair share fees. The commenter is directed to these sections of the Traffic Analysis, Appendix K3, as relates to roadway operating conditions and traffic improvements.
I1-11 The commenter asks how the Project will reduce or eliminate impacts to air quality, traffic, noise, glare, and others since the Moreno Valley General Plan did not envision so much congestion (people, buildings, and cars) in only 771 acres. In response, note the Project site is 668.6 acres, not 771 acres (which was the size of the original Specific Plan 218). Refer to Draft SEIR Chapter 3, Project Description.
Draft SEIR Section 4.11, Land Use and Planning; Section 4.14, Population and Housing; and Section
6.2, Growth Inducing Impacts, discuss General Plan consistency, population and housing, and growth.
As discussed therein, the Project aligns with local and regional land use plans, including the City’s 2040 General Plan and SCAG’s regional planning documents. The Project does not stimulate population 2 - RESPONSE TO COMMENTS
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growth beyond what is projected in these plans. Instead, it accommodates the anticipated population and housing needs in the City of Moreno Valley.
California is experiencing a long-standing shortage of housing supply (see SB 330; SCAG 2020b, 2023).
SCAG’s 6th Cycle Regional Housing Needs Assessment (2021–2029) estimates a need for 1,341,827 housing units in the region, including 167,351 units in Riverside County and 13,627 units in the City during this 8-year period. If unmet, the housing deficit will increase future housing needs. Past housing undersupply is expected to drive similar needs through at least 2035. After that, a gradual “catch up” in housing supply may occur. This housing demand is expected regardless of the Project, and state housing law mandates that the City plan for housing.
Despite slowed regional growth, Riverside County and the City are projected to grow significantly. SCAG forecasts that, from 2019 to 2050, Riverside County’s population will increase by 606,000 residents (25.4% growth) and households will increase by 318,000 households (42.7% growth) (SCAG 2023).
The City is anticipated to grow by 21,900 households (40% growth) in the same time period (SCAG 2023). The City’s population is expected to grow by 64,900 new City residents (31% growth) by 2045 (SCAG 2020a). This population and household growth would occur regardless of the Project.
The Project proposes 15,000 residences, 49,900 square feet of commercial and retail space, parks, schools, open space, and amenities on an infill site previously approved for housing (Draft SEIR Chapter 3). Development is phased over 12-15 years, with an estimated 1,200 units built annually.
During the current 6th Cycle Regional Housing Needs Assessment, the Project will add approximately 4,800 units, fitting within the City’s projected need of 13,627 units. Upon completion between 2037 and 2040, the Project’s 15,000 units would be within SCAG’s forecast of an additional 21,900 households by 2050 (SCAG 2023). The Project would house 43,050 people, accommodating some of the projected population increase of 64,900 in the City. Accordingly, the Project is anticipated to accommodate housing and population growth outlined in SCAG’s regional plans and the City’s adopted Housing Element.
The Project is consistent with the 2040 General Plan, which estimates the City will need 22,052 new dwelling units to house 47,162 new residents by 2040. The Project’s construction timeline anticipates that 15,000 units, housing 43,050 people, will be completed by 2040, helping to meet expected and planned growth needs on a site planned for housing development.
The comment restates information explained in the Draft SEIR, which describes that the Project will result in a denser urban pattern than considered in the 2040 General Plan by concentrating additional housing in the City’s Downtown Center on an infill site. This would help prevent urban sprawl by maximizing development on an infill site, rather than inducing growth or causing an expansion into undeveloped areas. Infrastructure and services would be developed as part of Project and “right sized” to the Project to minimize impacts. The Draft SEIR evaluates the Project impact related to this densification, including air quality, noise, transportation, glare, and other effects.
Additionally, the Project is requesting a General Plan Amendment so as to better reflect that the Project would have a denser urban pattern than that considered in the 2040 General Plan. The General Plan Amendment would entail, among other things, a change/update in 2040 General Plan Land Use & Community Character Element Table LCC-1 and related text, to update projected housing and job 2 - RESPONSE TO COMMENTS
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numbers with the Project in place, and changes to 2040 General Plan Table LCC-3 to reflect the updated Downtown Center development program by including the Project. These changes/updates would also help to ensure Project consistency with the 2040 General Plan.
To the extent the comment addresses general subject areas, the areas received extensive analysis in the Draft SEIR. The commenter is directed to the following locations in the Draft SEIR for where these general subject areas cited by the comment were addressed.
Air Quality
The Draft SEIR evaluated Project air quality impacts in Section 4.3. Numerous project design features (PDFs) will reduce impacts to air quality, including PDF-AQ/GHG-1 through PDF-AQ/GHG-15.
Transportation and land use PDFs would also reduce vehicle use and associated emissions (see Responses to Comments I1-13 to I1-15, below). Mitigation was identified for significant air quality impacts at MM-AQ-1 through MM-AQ-11. Despite the incorporation of all feasible mitigation, impacts to air quality are identified as significant and unavoidable. See Topical Response 2 for additional information.
Transportation
The Draft SEIR evaluated Project transportation impacts in Section 4.17. Transportation and land use PDFs promote alternative transportation and minimize VMT. See Response to Comment I1-14, below.
Transportation impacts were determined to be less than significant such that mitigation is not required.
Noise
The Draft SEIR evaluated Project noise impacts in Section 4.13. Noise impacts were found to be less than significant with mitigation incorporated. Resident noise is not a noise impact under CEQA (California Public Resources Code Section 21085). MM-NOI-1 and MM-NOI-2 address construction noise barriers and equipment noise controls. MM-NOI-3 provides traffic calming features along certain street segments during Project operation to reduce traffic noise. With these measures incorporated, noise impacts would be less than significant.
Glare
The Draft SEIR evaluated Project glare impacts in Section 4.1, Aesthetics. Glare impacts were found to be less than significant such that mitigation is not required. The Draft SEIR explains that, to minimize the impacts of glare and reflectivity, the Specific Plan design guidelines provide for clear glazing of windows and limited use of reflective materials for accent elements. Photovoltaic (PV) solar panels on site are designed to absorb light, not reflect it, and would be coated with anti-reflective materials to maximize light absorption. Accordingly, the Project would not introduce a new substantial source of glare, and impacts would be less than significant.
As the comment does not raise any specific issue regarding these analyses, no more specific response can be provided or is required. The City will include the comment as part of the Final EIR for review and consideration by the decision-makers prior to a final decision. 2 - RESPONSE TO COMMENTS
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I1-12 The comment states mitigation must be sufficient and enforceable related to impacts during construction and operation to Native-American relics, biological protected species, nearby schools, existing residents, and air quality.
Impacts to existing residents from Project construction and operation are considered throughout the Draft SEIR. The comment addresses general subject areas, which received extensive analysis in the Draft SEIR. As the comment does not raise any specific issue regarding that analysis, no more specific response can be provided.
The commenter is directed to the following locations in the Draft SEIR for consideration for the general subject areas cited by the comment. Each adopted mitigation measure will be included in the Project’s Mitigation Monitoring and Reporting Program to ensure enforcement (Draft SEIR Section 1A.6, p. 1A-12).
Tribal Cultural Resources
The Draft SEIR evaluated Project construction and operational impacts concerning cultural and tribal cultural resources in Sections 4.5, Cultural Resources, and 4.18, Tribal Cultural Resources. The Project site has been substantially graded and disturbed in the past, such that the likelihood of encountering tribal cultural resources is low. The City also has engaged in consultation with California Native American Tribes pursuant to SB 18 and Assembly Bill 52. Impacts were identified as less than significant with mitigation incorporated. Refer to MM-CUL-1 through MM-CUL-9, which provide for archaeological and tribal monitoring throughout Project grading and proper treatment should unknown cultural or tribal cultural resources be discovered.
Biological Resources
The Draft SEIR evaluated Project construction and operational impacts concerning biological resources in Section 4.4. Impacts were identified as less than significant with mitigation incorporated. Mitigation measures address burrowing owl (Athene cunicularia), least Bell’s vireo (Vireo bellii pusillus), and nesting birds and provide for compliance with the City’s Municipal Code as to City-regulated trees. Refer to MM-BIO-1 through MM-BIO-4.
Schools
The proposed development of 40 acres of schools was considered as part of the Project in the Draft SEIR’s assessment of construction and operation impacts. In addition, any nearby schools were evaluated as part of the existing community (for example, in the noise or air quality health risk analysis).
Operational impacts concerning schools also are evaluated in Section 4.15, Public Services, of the Draft SEIR. As explained in Section 4.15.4.2 (pp. 4.15-14 through 4.15-20), the Project site would be served by La Jolla Elementary, Landmark Middle School, and Vista Del Lago High School. In addition, the Project proposes development of 40 acres of schools, including up to three elementary schools and one middle school, at the site. The Project would be conditioned to pay the required development impact fees/school impact fees in accordance with SB 50 at the time of building permit issuance.
Pursuant to state law, payment of fees in accordance with SB 50 fully mitigates impacts to school facilities that may result from the Project (Government Code Section 65995[h]). Thus, public servicerelated impacts associated with schools would be less than significant. 2 - RESPONSE TO COMMENTS
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Air Quality
The Draft SEIR evaluated Project construction and operational impacts concerning air quality in Section
4.3. MM-AQ-1 through MM-AQ-11 were identified to help mitigate significant air quality impacts. Despite the incorporation of all feasible mitigation, impacts to air quality are identified as significant and unavoidable. Please see Topical Response 2 for additional information.
I1-13 The comment states homes and buildings should be 100% electrified and must include smart technology for the efficient usage of energy and electric charging stations for cars/bikes/scooters available in parking lots, parks, and other public facilities. The comment also states the Project applicant must request that the municipal utility provide carbon-free electric energy to cover energy supply gaps.
In response, please see Topical Response 4. Regarding electrification, PDF-AQ/GHG-3 requires allelectric development for all Project-related residential and non-residential development, except for approximately 14,970 square feet of restaurant uses within the Project’s Town Center. Thus, the Project’s 15,000 residential units and most of the retail space would be all-electric. To address and offset the limited consumption of natural gas by on-site restaurant space, MM-GHG-1 increases the amount of EV charging on site above project design and regulatory requirements.
Regarding electric vehicle charging, PDF-AQ/GHG-1 and MM-GHG-1 require the installation of ample on-site charging opportunities, with the infrastructure available to grow to meet any added future need.
The Project consists of 15,000 residential units, necessitating approximately 23,000 parking spaces, including garages and surface spots. Additionally, another 772 spaces are planned for the Town Center to support commercial uses, bringing the total number of parking spaces to 23,772 (Draft SEIR Section
3.3.5, PDF-AQ/GHG-1, p. 3-15). To support the growing need for EV charging and align with the GHG analysis and MM-GHG-1, approximately 56% of these parking spaces, amounting to 13,074 spaces, will either be pre-wired for EV charging or equipped with Level 1 or Level 2 chargers. The details are as follows:
▪ Pre-Wired Spaces: These spaces will be equipped with the necessary electrical infrastructure to facilitate easy installation of EV chargers in the future, thereby promoting flexibility and futureproofing the Project against increasing demand for EV charging. Pursuant to PDF-AQ/GHG-1, the Project shall equip 9,509 parking spaces (40% of the Project’s total number of parking spaces) in Project parking structures with Level 2, 240-volt EV receptacles (Draft SEIR Section 3.3.5, pp. 3-15 through 3-16; Draft SEIR Section 4.8, pp. 4.8-28 through 4.8-29, 4.8-68). ▪ Level 1 Chargers: These chargers provide a basic charging option, suitable for overnight or longduration parking situations, ensuring that residents and visitors with EVs can conveniently charge their vehicles. The Project shall install 2,377 Level 1 EV capable outlets to meet EV charging needs (Draft SEIR Section 4.8, p. 4.8-68).
▪ Level 2 Chargers: These chargers offer faster charging capabilities, catering to shorter parking durations and enhancing the convenience for EV users. Pursuant to PDF-AQ/GHG-1 and MM-GHG-1, a total of 3,746 fully equipped Level 2 charging stations would be provided at Project buildout (Draft SEIR Section 4.8, pp. 4.8-28 through 4.8-29, 4.8-68, 4.8-75). 2 - RESPONSE TO COMMENTS
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Integration of EVs into the market will occur progressively over time. While Executive Order N-79-20 and CARB’s Advanced Clean Cars II Regulations plan for 100% of new cars and light trucks sold in California to be zero-emission vehicles by 2035, this includes plug-in hybrid EVs. Gasoline-fueled vehicles also will still be in use on the roads beyond this time, and gasoline-fueled vehicles may continue to be purchased used in-state or new from out-of-state sources (Draft SEIR Section 4.6, pp.
4.6-8 through 4.6-9). The Project’s phased approach to EV infrastructure takes this market integration and gradual vehicle change-over into account, providing an adequate supply of charging facilities that can be scaled up as EV ownership increases. This ensures that the infrastructure will grow in tandem with demand, thereby optimizing resource allocation and minimizing potential underuse in the initial stages.
Further, public spaces and EV chargers in commercial areas will be designed for shared use, allowing multiple vehicles to access charging facilities throughout the day. This shared use model enhances the efficiency of the charging infrastructure, maximizing the utility of each charger and ensuring that more vehicles can benefit from the available resources.
The Project’s significant provision of EV charging infrastructure, representing over half of the total parking spaces, underscores the Project’s proactive approach to environmental sustainability and GHG reduction. It ensures that residents and visitors have ample access to EV charging facilities, thereby encouraging the purchase of use of EVs and contributing to cleaner air and a healthier environment.
Thus, the Project exceeds current requirements for EV infrastructure by pre-wiring or equipping 13,074 spaces with EV charging capabilities. This robust approach surpasses regulatory requirements and is anticipated to meet or exceed community needs.
PDF-TRANS-8 and PDF-TRANS-13 set forth the Project’s electric scooter-share program and electric bikeshare program, which provide users on-demand access to charged scooters and electric bikes.
PDF-TRANS-5 includes end-of-trip bicycle facilities. Scooters and electric bike batteries can generally be charged either attached or detached to the scooter/bike by plugging into a common wall outlet, which would be plentiful within the development.
Title 24 and numerous PDFs address the use of smart technology for the efficient consumption of energy. These include PDF-AQ/GHG-5 requiring use of LED lighting; PDF-AQ/GHG-6 requiring use of ENERGY STAR-rated appliances for residential refrigerators, dishwashers, clothes washers, ceiling fans, and non-residential commercial refrigerators; and, PDF-AQ/GHG-7 requiring installation of energy smart meters within all residential and non-residential development.
Regarding the request that the municipal utility provide carbon free electric energy to cover energy supply gaps, PDF-AQ/GHG-4 requires the Project provide rooftop PV solar panels on all residential and non-residential buildings in accordance with Title 24. Annual solar production is identified at 48,122,091 kilowatt hours. Pools’ and spas’ heating demand will also be served by a minimum 50% solar water heating.
Remaining electricity needs would be provided by the Moreno Valley Electric Utility (MVU). MVU does not provide the option of opting into a clean electricity. According to the 2022 power content label for MVU, renewable solar energy accounts for 33.4% of the utility’s overall energy resources—a renewable energy number that is anticipated to increase over time in compliance with state law (MVU 2023; Draft SEIR Section 4.6, p. 4.6-1). The state Regional Portfolio Standard program, as expanded and updated, 2 - RESPONSE TO COMMENTS
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currently requires the following percentage of retail sales of electricity to California end-use customers to come from eligible renewable energy resources and zero-carbon resources: 90% by December 31, 2035; 95% by December 31, 2040; and 100% by December 31, 2045. Because MVU is required to meet the state Regional Portfolio Standard milestones, the Project would benefit from this cleaner electricity provided by MVU. See Section 4.6.2 (pp. 4.6-2 through 4.6-11) of the Draft SEIR for discussion of Regional Portfolio Standard standards and milestones.
I1-14 The comment states the Final SEIR must include 20% affordable or senior housing. It states Project design must also include pedestrian-only streets and bicycling lanes; design for transit access; sidewalks/crosswalks designed with safety in mind (including sufficient lighting and other features); streets with heat reflecting materials; and high-solar radiation reflecting materials for new walls, surfaces, driveways, parking lots, and roofs in housing and building construction.
Affordable Housing
Please refer to Topical Response 6, Affordable Housing, regarding the comment about including 20% affordable housing.
Bicycle, Pedestrian, And Transit
Concerning bike facilities, pedestrian facilities, and transit, the City notes that the Project is located in an infill area such that transit service, bike lanes, and pedestrian access (i.e., sidewalks and crosswalks) currently provide access to the site and surrounding community (see Draft SEIR Section
4.17.1, pp. 4.17-3 through 4.17-9; Draft SEIR Appendix A, Section 4.1.1). The Project site is located in an area with an average VMT that is below that of the City of Moreno Valley and the region and that is close to major area job centers, including World Logistics Center, Riverside University Health System Medical Center, Kaiser Permanente Moreno Valley campus, University of California Riverside, Moreno Valley College, and regional and local shopping and commercial centers, which would allow residents to live and work locally (Draft SEIR Section 3.3.5, p. 3-24).
Existing Transit
Riverside Transit Agency (RTA) routes provide service near the Project site (see Draft SEIR Section 4.17, p. 4.17-6). These include Route 20 south of the Project site, Route 31 north of the Project site, and Route 41 west of the Project site. There are bus stops along Lasselle Street west of the Project site, along Iris Avenue south of the Project site, at the Riverside University Medical Center north of the Project site and along Alessandro Boulevard 0.5 miles north of the Project site.
Route 20 operates Monday to Friday between 4:00 a.m. and 11:00 p.m. and Saturday to Sunday between 7:00 a.m. and 9:00 p.m. with 1-hour headways. Route 20 provides service to Moreno Valley/March Field Metrolink Station and Moreno Valley College.
Route 31 operates Monday to Friday between 5:30 a.m. and 9:00 p.m. and Saturday to Sunday between 7:00 a.m. and 8:30 p.m. with 1-hour headways. Route 31 provides service to Moreno Valley Mall and Mt. San Jacinto College.
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Route 41 operates Monday to Friday between 6:00 a.m. and 7:00 p.m. and Saturday to Sunday between 7:00 a.m. and 7:00 p.m. with 1-hour headways. Route 41 provides service to Mead Valley Community Center.
In addition, the Moreno Valley/March Field Metrolink Station is located approximately 5 miles west of the Project site, providing rail connection.
Existing Bike and Pedestrian Facilities
Existing Class II bike lanes that would serve the community are provided on Cactus Avenue, Nason Street, Moreno Beach Drive/Iris Avenue, Lasselle Street, and John F. Kennedy Drive (see Draft SEIR Section 4.17, pp. 4.17-5 through 4.17-6). Class II bike lanes are what people may conventionally think of when picturing bike lanes, providing striped lanes designated for the use of bicycles on a street or highway. Vehicle parking and vehicle/pedestrian cross flow are permitted at designated locations.
The City’s pedestrian network surrounding the Project includes sidewalks along most arterial roadways and crosswalks at intersections designed to ensure safe walking opportunities. Sidewalks are currently provided along at least one side of Cactus Avenue, Nason Street, Moreno Beach Drive/Iris Avenue, Lasselle Street, and John F. Kennedy Drive.
Project Mobility Plan and Project Design
The Project Mobility Plan integrates and builds upon the existing bike, pedestrian, and transit network to improve and enhance active transportation and transit access. Section 3.3.2 of the Draft SEIR (pp. 3-7 through 3-14), under the subsection Mobility Plan, describes the Project Mobility Plan, found in Section 4.1.2 of the Specific Plan Amendment (Draft SEIR Appendix A). As summarized, Project intersection density would help facilitate shorter trips, including by walking, biking, and scooter.
The internal street network would also contain an extensive bike network with Class II, buffered Class II, and off-street bike paths, and would connect to the broader Moreno Valley bike network and support proposed non-automobile mobility modes (e.g., bikeshare, electric scooter). Further, the internal street network would include a comprehensive sidewalk and trail network to facilitate walking.
The Project also proposes design features to help reduce the vehicle trips generated by the Project. These features, known as transportation demand management (TDM) features, promote non-automotive modes of transportation such as walking, biking, scooter, public transit, and ridesharing. The TDM features used in the Project are documented by the California Air Pollution Control Officers Association (CAPCOA) in its Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA 2021).
Figure 4-3 of the Specific Plan Amendment (Draft SEIR Appendix A) identifies existing and potential bike lanes to be determined during the development process.
Draft SEIR Section 4.17.5.2, also summarizes project design features related to bike facilities, pedestrian facilities, and transit (pp. 4.17-30 through 4.17-31):
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The Project would improve and enhance active transportation and transit access and facilities in the focus traffic study area, consistent with 2040 General Plan Circulation Element policies. The Project would improve the adjacent streets with continuous sidewalks, along with providing an extensive walkable network of sidewalks, promenades, and trails within the Project site. The internal street network would follow a grid pattern with approximately 600-foot block lengths to provide a street network similar to a downtown, urban area. Intersection density is a proxy for street connectivity, which helps to facilitate a greater number of shorter trips including those made by walking, biking, and scooter. The internal street network will include a comprehensive sidewalk network to facilitate walking. The Project would promote the use of the existing bike network along circulation element roadways in the focus study area and construct a Class III bike route along Brodiaea Avenue. Internal streets within the Project would facilitate bike routes and connectivity to the existing bike network. Access to all existing trails would be provided.
The internal street network would contain an extensive bike network with Class II, buffered Class II, and off-street paths, and would connect to the broader Moreno Valley bike network and support proposed micromobility modes. PDF-TRANS-5 and PDF-TRANS-7 would further promote bike use through a bikeshare program and end-of-route facilities such as bike lockers and showers.
The Project proposes to work with RTA to improve existing route frequencies, service hours and routes that would expand the transit system throughout the Project, surrounding school, medical uses, nearby industrial employment centers, and the broader Moreno Valley. The Project recognizes that a major future employer of the City will be the WLC and that providing transit access from the Project to WLC during hours of operation is a primary focus of coordination with RTA. See PDF-TRANS-9 through PDF-TRANS-12 in Section
4.17.5. In total, 15 PDFs are designed to reduce Project traffic and make the development more walkable, bikeable, and transit-user friendly. These include PDF-TRANS-1 through PDF-TRANS-15. In addition, land use PDFs address aspects of Project design that promote walkability and bike-ability. These include PDF-LU-1 through PDF-LU-11. The commenter is encouraged to refer to Section 3.3.5 of the Draft SEIR (pp. 3-15 through 3-26) for a full description of these features.
These PDFs show the Project will provide a tram connection to job centers; enhanced transit, pedestrian and bicycle routes; ridesharing; non-electric bikes; electric bikes; electric scooters; a mobility hub; access to transportation network companies (Uber and Lyft); intelligent transportation systems; and numerous other transportation demand management measures. Complete streets will accommodate the needs of bicyclists, pedestrians, and transit riders, as well as motorists. Design features include multi-use trails and sidewalks, crosswalks, shared roads, landscaping, and pedestrian bridges across arterials and the on-site drainage. Traffic calming design will include chokers (curb extensions that narrow a street by widening the sidewalks or planting strips, effectively creating a pinch point along the street), crosswalks, roundabouts landscaped medians, and shared street design to promote safer streets. Lighting will include street lighting, walkway and pathway lighting, and security lighting that is appropriately directed and shielded in compliance with City Municipal Code standards (Draft SEIR Section 4.1.4, pp. 4.1-7 through 4.1-12).
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In sum, the Project design thoroughly and thoughtfully addresses pedestrian, bicycle, and transit use.
Please refer to Sections 4 and 6 of the Specific Plan Amendment (Draft SEIR Appendix A) for further information.
Design with Heat/Solar Radiation Reflective Materials
PDF-AQ/GHG-8, Cool Pavements (Draft SEIR Section 3.3.5, p. 3-17), requires that the Project install cool pavements to reduce the potential for the urban heat island effect. Outdoor pavements, such as internal walkways and patios, shall use paving materials with a 3-year Solar Reflectance Index of 0.28 or an initial Solar Reflectance Index of 0.33. The ample tree planting, shade coverage, and 40-acre lake feature will further reduce any heat island effect.
Project building materials would comply with current California Green Building Code (Title 24, Part 11) and California Building Energy Efficiency Standards (Title 24, Part 6), which govern window and door materials, lighting, electrical panels, insulation, PV installation, and more, which would further minimize any urban heat island impacts. Solar PV panels installed on roofs or parking areas are designed to absorb light and solar radiation. The Project would use light-colored, semi-reflective, or cool-roof technology for all roofing.
I1-15 The comment states Project homes and buildings must include the latest water conservation features including ultra-low-flow fixtures, drought tolerant and/or native landscaping, and low-water use for areas served with recycled water. It states the Final EIR should propose to plant more trees than envisioned for parks, streets, and other public areas to provide shade and buffer pollution. The commenter also states the Project should provide opportunities for residents to recycle.
Efficient Water Use
In response, Section 4.19.4.2 of the Draft SEIR (pp. 4.19-14 through 4.19-23) summarizes that the Project would be designed with the latest water-efficient plumbing systems, fixtures, and faucets.
Drought-tolerant landscaping would reduce the demand for irrigation water. Irrigation systems would use smart controllers to automatically adjust the amount and frequency of water based on current weather and soil conditions, and recycled water would be used for landscape irrigation.
More specifically, PDF-AQ/GHG-12, Water Use Efficiency and Conservation Plan (Draft SEIR Section
3.3.5, pp. 3-18 through 3-19), requires the following water use efficiency and conservation plan features:
Indoor Conservation Features and Operations:
▪ Install low-flow fixtures: In the residential units, install low-flow toilets at 1.28 gallons per flush, faucets at 1.2 gallons per minute, showerheads at 1.8 gallons per minute, and kitchen faucets at
1.8 gallons per minute. In common areas, install faucets at O.5 gallons per minute and urinals at max of 0.25 gallons per minute/flush. (These fixtures use less water while maintaining efficient performance.)
▪ Install dual-flush toilets: These toilets offer two flush options—one for liquid waste at less than 1 gallons per minute and another for solid waste at 1.28 gallons per minute. (This allows the appropriate use of water for flushing needs.)
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▪ Use water-efficient appliances: The Project applicant or designee shall install energy-efficient and water-saving appliances like dishwashers and washing machines with the ENERGY STAR label only. ▪ Implement hot water recirculation system: The Project applicant or designee shall implement a recirculation system for hot water systems to ensuring low to no wasted water while waiting for water to reach desired temperature.
▪ Incorporate leak detection on each residential building: Leak detection will be incorporated into residential structures to detect water leaks typical of residential uses such as irrigation and plumbing.
▪ Capture and reuse heating, ventilation, and air conditioning condensation: The Project applicant or designee shall direct condensation from air conditioning units to water plants or for other nonpotable uses. ▪ Implement good housekeeping and regular maintenance: The Project applicant or designee shall regularly (daily, weekly, monthly, etc. as applicable) check and maintain plumbing fixtures, irrigation systems, and appliances to ensure they are functioning efficiently and not wasting water.
Outdoor Conservation Features and Operations:
▪ Install only “Smart Irrigation Systems” for community landscaping: The Project applicant or designee shall utilize smart sprinkler systems that adjust watering schedules based on weather conditions, soil moisture, and plant needs to avoid overwatering or wasteful watering. The Project applicant or designee shall also incorporate seasonal specific controls to ensure watering occurs during the most efficient times of day.
▪ Install adjustable water pressure regulator: The Project applicant or designee shall install pressure regulators to maintain optimal water pressure, preventing overuse and leaks. ▪ Incorporate leak detection into each master landscape meter complex. Leak detection will be incorporated into residential structures to detect water leaks from landscaping. ▪ Include drought-tolerant landscaping: The Project applicant or designee shall include native and drought-tolerant vegetation that requires less water to thrive and is known to survive in the greater Moreno Valley area. The Project applicant or designee shall replace drought-tolerant landscaping if it dies through enforceable Project covenants, conditions, and restrictions for 30 years after initial planting.
▪ Harvest and reuse rainwater and drainage water: The Project’s lake shall be part of a water retention and reuse program.
▪ Use permeable pavement surfaces: The Project applicant or designee shall use permeable materials in parking areas, internal walkways, and public areas. (These surfaces will allow water to infiltrate the ground rather than running off, reducing runoff and promoting groundwater recharge.) ▪ Include community education and outreach: The Project applicant or designee shall educate employers, employees, and residents about water conservation practices and encourage them to implement mindful water usage habits through enforceable Project covenants, conditions, and restrictions.
▪ Place educational signage: The Project applicant or designee shall place informational signs and notices at appropriate locations on the Project site to encourage water-saving behaviors among residents and guests.
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PDF-AQ/GHG-13, Use Recycled Water for Irrigation (Draft SEIR Section 3.3.5, p. 3-19), further requires use of recycled water for irrigation areas including the school irrigated areas, Town Center irrigation, parks, parkways, and urban landscape. See also Section 4.4.2 and Figure 4-6 of the Specific Plan Amendment, Appendix A of the Draft SEIR, which outlines the Project’s Recycled Water Plan and depicts future recycled water improvements and potential connections. Thus, the Project homes and buildings include the latest water conservation features, drought tolerant landscaping, and use of recycled water as requested by the commenter.
Tree Planting
Concerning tree planting, PDF-AQ/GHG-11 (Draft SEIR Section 3.3.5, p. 3-17), requires that 30,000 trees be planted on site at Project buildout and any die-offs replaced for 30 years to ensure their success in providing shade and buffering pollutants. Species would include, but not be limited to, southern magnolia, California sycamore, American elm, slash pine, and white ash, which are well-suited to the climate and provide shade canopy cover.
The Project will be developed consistent with the Design Guidelines in the Specific Plan Amendment, Draft SEIR Appendix A, which states that the Project design, including street landscaping, will contribute to an “urban forest” character of leafy canopy trees to create cooling against the summer temperatures, with tree cover expected to reduce ambient temperatures by several degrees. The Specific Plan further provides that street landscaping will focus on creating a “veil” of trees along buildings and that neighborhood streets will incorporate extensive canopy, leafy trees for maximum shading and cooling effect. The backbone of the street landscape will be evergreen trees in sufficient density of planting to establish street character. Neighborhood street tree plantings will comprise a mix of coniferous and broad leaf evergreen to offer screening of the medium height buildings, together with broad canopy trees to provide ample shade coverage within the neighborhood areas. See, for example, Specific Plan Amendment Section 6.2.7, Street System; Section 6.3.2, Streetscape Landscaping; and Figures 6-1 to 6-17 for depictions of the street tree planting/landscape design.
Thus, the Project already plans for dense tree planting to create an “urban forest” feel. However, this comment is included in the Final SEIR for review and consideration by the decision-makers prior to a final decision on the project.
Solid Waste Recycling
Concerning opportunities to recycle, as detailed in Section 4.19.4.2 of the Draft SEIR (p. 4.19-23), the Project would be required to comply with the City’s Municipal Code regarding solid waste and recyclable material storage areas (Municipal Code, Section 6.02.050). Additionally, the City’s building code requires development projects to complete and submit a waste management and recycling plan for approval prior to issuance of building permits. The waste management and recycling plan would identify the project type and estimate the amount of materials to be recycled during construction. Finally, the Project would comply with the current California Green Building Code (Title 24), which requires construction waste recycling. Chapter 6.03 of the City’s Municipal Code similarly provides for waste reduction and recycling, and Section 6.03.130 requires compliance with California Green Building Code (Title 24) recycling requirements or more stringent requirements of the City for new construction. This includes providing access for “three container” collection services, which includes blue container recyclables and green container organics collection. Waste handling services within the City are 2 - RESPONSE TO COMMENTS
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provided under contract by Waste Management of Inland Valley, which provides trash, recycling, and green waste pickup (Draft SEIR Appendix A, Section 4.6). Accordingly, the Project will provide ample opportunities for residents to recycle.
I1-16 The comment states about 60% of Moreno Valley residents are Hispanic and it is important to provide translation of documents into Spanish to provide equal opportunity for residents to participate.
The City acknowledges the comment and notes it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. The City will include the comment as part of the Final SEIR for review and consideration by the decision-makers prior to a final decision. 2 - RESPONSE TO COMMENTS
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2.3 References
Blumenberg, E., and M. Wander. 2023. “Housing Affordability and Commute Distance.” Urban Geography 44(7):
1454–1473. https://doi.org/10.1080/02723638.2022.2087319.
Cantrell, J.D., and S. Jain. 2013. “Enforceability of Local Hire Preference Programs.” Legal Research Digest 59.
Accessed July 3, 2024. https://nap.nationalacademies.org/read/22591/chapter/1.
CAPCOA (California Air Pollution Control Officers Association). 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. Available:
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf CAPCOA. 2022. “CalEEMod User Guide.” April 2022. https://www.caleemod.com/documents/userguide/01_User%20Guide.pdf.
CARB (California Air Resources Board). 2022a. “Appendix D: Local Actions.” In 2022 Scoping Plan. November 2022. https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf.
CARB. 2022b. 2022 Scoping Plan Update. December 2022. Last Accessed June 2023. https://ww2.arb.ca.gov/ our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents CARB. 2022c. “Area Designation Maps/State and National.” Last updated November 2022. Accessed April 2023. http://www.arb.ca.gov/desig/adm/adm.htm.
CARB. 2024. Cars and Light-Trucks are Going Zero - Frequently Asked Questions. https://ww2.arb.ca.gov/resources/documents/cars-and-light-trucks-are-going-zero-frequently-askedquestions#:~:text=As%20part%20of%20the%20Advanced,Advanced%20Clean%20Cars%20II%20regulati ons.
CDC (U.S. Centers for Disease Control and Prevention). 2024a. “Valley Fever (Coccidioidomycosis).” Last updated April 4, 2024. Accessed July 19, 2024. https://www.cdc.gov/valley-fever/areas/index.html.
CDC. 2024b. “Valley Fever Prevention for Workers.” Last updated January 19, 2024. Accessed July 19, 2024. https://www.cdc.gov/niosh/valley-fever/about/index.html.
CDFG (California Department of Fish and Game) 2012. “Staff Report on Burrowing Owl Mitigation.” Accessed July 2024. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843&inline.
CDIR (California Department of Industrial Relations). 2024. “Protection from Valley Fever.” February 2024.
Accessed July 19, 2024. https://www.dir.ca.gov/dosh/valley-fever-home.html.
CDPH (California Department of Public Health). 2013. “Preventing Work-Related Coccidioidomycosis (Valley Fever).” June 2013. Accessed July 19, 2024.
https://www.cdph.ca.gov/Programs/CCDPHP/DEODC/OHB/HESIS/CDPH%20Document%20Library/Cocci Fact.pdf.
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CDPH. 2023. Epidemiologic Summary of Valley Fever (Coccidioidomycosis) in California, 2022. November 2023.
Accessed July 19, 2024.
https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciEpiSummary2022. pdf.
CDPH. 2024a. “Valley Fever.” Last updated June 25, 2024. Accessed July 19, 2024. https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/ValleyFeverBasics.aspx.
CDPH. 2024b. “Valley Fever in California Dashboard.” Last updated January 2024. Accessed July 19, 2024. https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/ValleyFeverDashboard.aspx.
CDPH. 2024c. “Health Advisory. TO: Healthcare Providers. Substantial Rise in Coccidioidomycosis in California:
Recommendations for California Healthcare Providers.” January 18, 2024. Accessed July 19, 2024. https://www.cdph.ca.gov/Programs/OPA/Pages/CAHAN/Substantial-Rise-in-Coccidioidomycosis-inCalifornia-Recommendations-for-California-Healthcare-Providers.aspx.
Chapple, K. 2015. Assessing the Travel Demand and Co-Benefit Impacts of Affordable Transit Oriented Developments. Available: https://www.urbandisplacement.org/wpcontent/uploads/2021/08/assessing_travel_demand.pdf Chatman, D. 2013. Does TOD need the T? On the importance of factors other than rail access. Journal of the American Planning Association 79(1). https://trid.trb.org/view/1243004.
City of Moreno Valley. 2021. “Housing Element.” In City of Moreno Valley General Plan 2040. Adopted June 15, 2021. Accessed March 23, 2023. http://www.moval.org/city_hall/general-plan2040/ HousingElement.pdf.
City of Moreno Valley. 2022. Traffic Control Plan Guidelines and Checklist. http://moval.org/city_hall/forms/landdev/TCP-GuidelineChecklist.pdf County of Riverside. 2003. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP):
Volume II. Prepared by Dudek & Associates. Approved June 17, 2003. https://www.wrcrca.org/Permit_Docs/MSHCP/MSHCP-Volume2.pdf.
EPA (U.S. Environmental Protection Agency). 2023. Details of Criteria Pollutant Nonattainment Area Summary Report. Last updated October 31, 2022. Accessed November 2022. https://www3.epa.gov/airquality/greenbook/ancl2.html.
EPA. 2024. “Regulations for Emissions from Heavy Equipment with Compression-Ignition (Diesel) Engines.” Last updated February 1, 2024. https://www.epa.gov/regulations-emissions-vehicles-andengines/regulations-emissions-heavy-equipment-compression.
Ewing, R., K. Bartholomew, S. Winkelman, J. Walters, and D. Chen. 2007. Growing Cooler: The Evidence on Urban Development and Climate Change. October.
https://www.nrdc.org/sites/default/files/cit_07092401a.pdf. 2 - RESPONSE TO COMMENTS
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Gabbe, C. J., & Pierce, G. 2017. Hidden Costs and Deadweight Losses: Bundled Parking and Residential Rents in the Metropolitan United States. Housing Policy Debate, 27(2), 217–229. https://doi.org/10.1080/10511482.2016.1205647.
Gadbois, B.R., T.L. Senet, and K.J. Smith. 2012. “Constitutional Issues Relating to “Buy Local” and Local Hiring and Contractor Preferences.” May 3, 2012. Accessed July 3, 2024. https://www.cacities.org/getattachment/6f1574a4-d13b-4888-bee7-8b9dcc5ff14d/5-2012-SpringKristi-J-Smith-Barbara-R-Ga-Senet-Co.aspx.
Handy, S., S. Glan-Claudia, and M. Boarnet. 2014. Impacts of Pedestrian Strategies on Passenger Vehicle Use and Greenhouse Gas Emissions: Policy Brief. https://ww2.arb.ca.gov/sites/default/files/2020- 06/Impacts_of_Pedestrian_Strategies_on_Passenger_Vehicle_Use_and_Greenhouse_Gas_Emissions_Po licy_Brief.pdf.
ITE (Institute of Transportation Engineers). 2019. Parking Generation Manual. 5th Edition. February. https://ecommerce.ite.org/IMIS/ItemDetail?iProductCode=PG5-ALL.
ITE. 2021. Trip Generation Manual. 11th Edition. https://www.wrcog.us/DocumentCenter/View/9317/StrategicPlan-2022-through-2027.
Kollath, D.R., J.R. Mihaljevic, and B.M. Barker. 2022. “PM10 and Other Climatic Variables Are Important Predictors of Seasonal Variability of Coccidioidomycosis in Arizona.” Microbiology Spectrum 10(2):
e01483-21.
LADPH (County of Los Angeles Department of Public Health). 2019. Coccidioidomycosis (Valley Fever) Management Plan: Guidelines for Employers. August 2019. http://publichealth.lacounty.gov/acd/docs/valleyfeverplan2019.pdf.
LADPH. 2022. “COCCIDIOIDOMYCOSIS.” In Acute Communicable Disease Control Manual (B-73). Revised September 22, 2022.
http://publichealth.lacounty.gov/acd/procs/b73/DiseaseChapters/B73Coccidioidomycosis.pdf.
LAO (Legislative Analyst Office). 2016a. The 2016-2017 Budget: Considering Changes to Streamline Local Housing Approvals. May 18, 2016.
LAO. 2016b. Perspective on Helping Low-Income Californians Afford Housing, Mac Taylor, Legislative Analyst.
February 9, 2016. https://www.lao.ca.gov/Reports/2016/3345/Low-Income-Housing-020816.pdf.
Litman, T. 2020. Parking Requirement Impacts on Housing Affordability. June. https://www.vtpi.org/park-hou.pdf.
Manville, M. 2013. Parking Requirements and Housing Development Journal of the American Planning Association, Winter 2013, Vol. 79, No. 1. https://www.accessmagazine.org/wpcontent/uploads/sites/7/2015/10/access-44-Parking-Requirements.pdf.
Mokhtarian, P. et al. 2017. Modeling Household Vehicle and Transportation Choice and Usage Part A: Factors Related to Voluntary Choice of Low Vehicle Ownership and Usage. University of California, Davis.
Available: https://ww2.arb.ca.gov/sites/default/files/classic/research/apr/past/11-322a.pdf. 2 - RESPONSE TO COMMENTS
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MVU (Moreno Valley Utility). 2023. About MVU. https://www.moval.org/mvu/about-mvu.html.
Newsom, G. 2017. “The California Dream Starts at Home.” Medium. October 20, 2017. https://medium.com/@GavinNewsom/the-california-dream-starts-at-home-9dbb38c51cae.
OEHHA (Office of Environmental Health Hazard Assessment). 2022. Indicators of Climate Change in California (4th ed.). November 2022. Accessed July 19, 2024. https://oehha.ca.gov/media/downloads/climatechange/document/2022caindicatorsreport.pdf.
OSHA (Occupational Safety and Health Administration). n.d. “Valley Fever (Coccidioidomycosis).” Accessed July 19, 2024. https://www.osha.gov/valley-fever/control-prevention.
OSHA. 2022. Indicators of Climate Change in California (4th ed.). November 2022. Accessed July 19, 2024. https://oehha.ca.gov/media/downloads/climate-change/document/2022caindicatorsreport.pdf.
Phillips, S. 2024. Modeling Inclusionary Zoning’s Impact on Housing Production in Los Angeles: Tradeoffs and Policy Implications. https://www.lewis.ucla.edu/research/modeling-inclusionary-zonings-impact-onhousing-production-in-los-angeles-tradeoffs-and-policy-implications/.
Pinski, M.J. 2018. Does Bundled Parking Influence Travel Behavior? University of California, Los Angeles. https://escholarship.org/uc/item/24f521mp.
RCA (Regional Conservation Authority). 2006. Burrowing Owl Survey Instructions For the Western Riverside Multiple Species Habitat Conservation Plan Area. March 29, 2006. Accessed December 2022. https://www.rctlma.org/Portals/3/EPD/
consultant/burrowing_owl_survey_instructions.pdf.
RCA. 2024. “Habitat Conservation.” https://www.wrc-rca.org/habitat-conservation/.
RCHCA (Riverside County Habitat Conservation Agency). 1996. Habitat Conservation Plan for the Stephens’ Kangaroo Rat in Western Riverside County California. March 1996. https://www.rchca.us/DocumentCenter/View/549/SKR-Habitat-Conservation-Plan.
RUHS (Riverside University Health System). 2015. Coccidioidomycosis: Yearly Summary Report. Accessed July 19, 2024. https://www.ruhealth.org/sites/default/files/2020-08/Cocci_Report_for_Publish_FINAL.pdf.
RUHS. 2024. “Data Report & Statistics.” Accessed July 19, 2024. https://www.ruhealth.org/publichealth/epidemiology-program-evaluation/data-report-statistics.
SCAG (Southern California Association of Governments). 2020a. The 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments, Connect SoCal. https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocalplan_0.pdf?1606001176.
SCAG. 2020b. Final RHNA Allocation Methodology. March 5, 2020. https://scag.ca.gov/sites/main/files/fileattachments/scag-final-rhna-methodology-030520.pdf?1602189316. 2 - RESPONSE TO COMMENTS
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SCAG. 2023. Demographics and Growth Forecast. November 2, 2023. https://scag.ca.gov/sites/main/files/fileattachments/23-2987-tr-connect-socal-2024-demographics-growth-forecast-draft110223.pdf?1698263165.
SCAQMD (South Coast Air Quality Management District). n.d. “Dust Control in the South Coast AQMD.” Accessed July 19, 2024. https://www.aqmd.gov/docs/default-source/compliance/rule-403-dust-controlforms/403-presentation.pdf.
SCAQMD. 1993. CEQA Air Quality Handbook.
SCAQMD. 2013. Final 2012 Air Quality Management Plan. February 2013. Accessed June 2023. https://www.aqmd.gov/home/air-quality/clean-air-plans/air-quality-mgt-plan/final-2012-airquality-management-plan.
SCAQMD 2023. “Working Group Meeting #4: Cumulative Impacts from Air Toxics for CEQA Projects”.
June 6, 2023. Accessed December 2023. http://www.aqmd.gov/docs/default-source/ceqa/ documents/wgm-4_20230602_final.pdf?sfvrsn=10.
Stevens, M. 2016. Does Compact Development Make People Drive Less? Journal of the American Planning Association 83:1(7–18), DOI: 10.1080/01944363.2016.1240044. November. https://www.researchgate.net/publication/309890412_Does_Compact_Development_Make_People_Dri ve_Less.
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INTENTIONALLY LEFT BLANK
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3 Errata
Some commenters have suggested grammatical corrections. The City is grateful to the commenters for their careful attention to detail. Corrections and suggestions will be incorporated into the final document as appropriate. In addition to minor formatting and clarifying edits, the following edits were made to the EIR; these edits did not alter the content or conclusions.
Changes are shown in strikeout/underline format (additions are underlined, deletions stricken out) and their page numbers in the Draft EIR are indicated. Footnotes within text brought over from the EIR have not retained their original numbering and are numbered consecutively within this document. The changes made to the draft are minor corrections and clarifications. None of the changes are substantial in nature. Additionally, no impact determinations have been changed and no mitigation measures have been added or substantially revised.
3.1 Edits made to Chapter 1, Introduction
Pages 1-3 through 1-4
The Project consists of the following discretionary approvals, which would be submitted and processed concurrently:
▪ Specific Plan Amendment (SPA) (PEN 23-0109) – The Aquabella SPA would update and modify previous Specific Plan No. 218 to take advantage of the “center city” location and to establish a prominent destination for area residents and workers to live and recreate within a vibrant hub for the City and region.
The SPA is needed to provide additional housing opportunities for residents and area workers and families seeking to take advantage of the site’s location within central Moreno Valley, proximity to major job centers, efficient transportation network, sustainable lake features, and other amenities. The SPA would provide updated development standards and design guidelines for the further proposed development within the Project site and add one approximately 10-acre parcel to the eastern boundary of the Project site (APN:
486-310-014).
▪ General Plan Amendment (GPA) (PEN 23-0127) – Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 General Plan, which was “locked” in place as the general plan and land use standards applied to the Project. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). The A GPA would be required to (a) change the 2040 General Plan Land Use & Community Character Element Table LCC–1, Development Potential and Jobs-Housing Balance, and related text to update projected housing and job numbers to include the Aquabella Specific Plan Amendment Project; (b) change the 2040 General Plan Table LCC-3, Downtown Center Illustrative Development Program (Net New Development 2020-2040), to reflect the updated Downtown Center development program by including the Aquabella Specific Plan Amendment Project; and (c) change 2040 General Plan Map LCC-4, General Plan Land Use, to reflect the land use designation change of the approximately 10-acre parcel on the eastern boundary of the Project site (APN: 486-310-014) from R5 Residential to Downtown Center (Aquabella Specific Plan).
If Because the 2006 General Plan is would be operative at the time of approval and pursuant to the City’s request, the Project wouldrequire include a GPA to also amend the 2006 General Plan Land Use Map, Figure 2-2, to accommodate the Project., which would designate the entire Project site “Specific Plan.” The 2006 GPA would be concurrently processed with the 2040 GPA, which would become effective upon re- 3 - ERRATA
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adoption of the 2040 General Plan. The accompanying 2040 General Plan EIR is currently undergoing correction.
▪ Change of Zone (CZ) (PEN 24-0041) - Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 Zoning that was adopted and in effect to implement the 2040 General Plan. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). TheA proposed change of zone would rezone the approximately 10-acre parcel on the eastern boundary of the Project site from R5 Residential (R5) District to DC-SP (SP 218) in order to incorporate the parcel into the Project boundary so it will be subject to the zoning, design, and development requirements therein. Assuming the 2006 Zoning is operative at the time of Project approval, the Project would concurrently process this 2040 change of zone to become effective upon re-adoption of the 2040 Zoning.
Because the 2006 Zoning would be operative at the time of Project approval, and pursuant to the City’s request, the Project would also include a change of zone to rezone the entire site to Specific Plan (SP) 218 on the 2006 Zoning Map.
▪ Subsequent Environmental Impact Report (SEIR) Certification (PEN 23-0111) – Certification of this SEIR (State Clearinghouse Schedule No. 2023100145) prepared in conformance with CEQA would ensure that the incremental environmental impacts between the Project and the previous approvals are analyzed and considered and that all feasible and reasonable mitigation measures or alternatives are implemented to reduce the identified significant impacts. Overriding considerations will be considered by the City. The SEIR preparation and review process requires public notification, stakeholder input, and community participation.
▪ Tentative Tract Map No. 38850 (PEN 23-0118) - The Tentative Tract Map would provide the subdivision plans for the Aquabella Specific Plan Area for finance and conveyance purposes. The Tentative Tract Map would consolidate the existing 10 parcels and create an estimated 26 new parcels. ▪ Development Agreement (PEN 23-0119) - The Development Agreement would be a written agreement between the Project applicant and the City in order to specify the respective obligations of the parties.
3.2 Edits made to Chapter 1A, Executive Summary
Pages 1A-6 through 1A-8
The Project would require approval of the following discretionary actions by the Moreno Valley City Council, which are submitted and processed concurrently:
1. Specific Plan Amendment (SPA) (PEN 23-0109) – The Aquabella Specific Plan Amendment (SPA) (Appendix A) would update and modify previous Specific Plan No. 218 to take advantage of the “center city” location, and to establish a prominent destination for area residents and workers to live and recreate within a vibrant hub for the City and region. The SPA is needed to provide additional housing opportunities for residents and area workers and families seeking to take advantage of the site’s location within central Moreno Valley, proximity to major job centers, efficient transportation network, sustainable lake features, and other amenities. The SPA would provide updated development standards and design guidelines for the further proposed development within the Project site, and add one approximately 10-acre parcel to the eastern boundary of the Project site.
2. General Plan Amendment (GPA) (PEN 23-0127) – Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 General Plan, which was “locked” in place as the general plan 3 - ERRATA
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and land use standards applied to the Project. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). The A GPA would be required to (a) change the 2040 General Plan Land Use & Community Character Element Table LCC-1, Development Potential and Jobs Housing Balance, and related text to update projected housing and job numbers to include the Project; (b) change the 2040 General Plan Table LCC-3, Downtown Center Illustrative Development Program (Net New Development 2020-2040), to reflect the updated Downtown Center development program by including the Project; and (c) change 2040 General Plan Map LCC-4, General Plan Land Use, to reflect the land use designation change of the approximately 10-acre parcel on the eastern boundary of the Project site (Assessor’s Parcel No. 486310014) from Residential (R5) District to Downtown Center (Aquabella Specific Plan).
BecauseIf the 2006 General Plan would beis operative at the time of approval and pursuant to the City’s request, the Project would include require a GPA to also amend the 2006 General Plan Land Use Map, Figure 2-2, to accommodate the Project, which would designate the entire Project site “Specific Plan.” The 2006 GPA would be concurrently processed with the 2040 GPA, which would become effective upon readoption of the 2040 General Plan. The accompanying 2040 General Plan EIR is currently undergoing correction.
3. Change of Zone (CZ)(PEN 24-0041)– Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 Zoning that was adopted and in effect to implement the 2040 General Plan. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). TheA proposed change of zone would rezone the approximately 10-acre parcel on the eastern boundary of the Project site from Residential 5 (R5) District to DC-SP (SP 218) in order to incorporate the parcel into the Project boundary and be subject to the zoning, design, and development requirements therein. Assuming the 2006 Zoning is operative at the time of Project approval, the Project would concurrently process this 2040 change of zone to become effective upon re-adoption of the 2040 Zoning.
Because the 2006 Zoning would be operative at the time of Project approval, and pursuant to the City’s request, the Project would also include a change of zone to rezone the entire site to Specific Plan (SP) 218 on the 2006 Zoning Map.
4. Subsequent Environmental Impact Report (SEIR) Certification (PEN 23-0111) – Certification of this SEIR prepared in conformance with CEQA to ensure that the incremental environmental impacts between the Project and the previous Specific Plan are analyzed and considered, and that all feasible and reasonable mitigation measures or alternatives are implemented to reduce the identified significant impacts.
Overriding considerations will be considered by the City. The processing of the SEIR requires public notification, stakeholder input, and community participation throughout the SEIR preparation and review process.
5. Tentative Tract Map No. 38850 (PEN 23-0118) - The Tentative Tract Map would provide the subdivision plans for the Aquabella Specific Plan area for finance and conveyance purposes. The Tentative Tract Map will consolidate the existing ten (10) parcels and create an estimated twenty-six (26) new parcels.
6. Development Agreement (PEN 23-0119) - The Development Agreement would be a written agreement between the Project applicant and the City in order to specify the respective obligations of the parties Pages 1A-10 through 1A-13
Table 1A-21 provides a comparison of the potential impacts of the project alternatives by indicating for each environmental issue area if the Alternative would result in a similar, increased, slightly reduced, or reduced impact.
Table 1A-2.1 also provides a comparison to the potential impacts resulting from the proposed project. 3 - ERRATA
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Table 1A-27-1. Comparison of the Environmental Impacts of Alternatives Environmental
Topic Project
Alternative
11 Alternative
2 Alternative
3 Alternative
4 Alternative
5 Alternative
6 Alternative
7 Air Quality Significant and
Unavoidable
(Project and
Cumulative)
Reduced Slightly
reduced (Still
Significant
and
unavoidable)
Similar Reduced
(Still
Significant
and
Unavoidable)
Slightly
reduced (Still
Significant
and
unavoidable)
Greater Greater
Biological
Resources
Less Than
Significant with
Mitigation
Reduced Similar Similar Similar Similar Similar Similar …
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Based on the above analysis and the summary of impacts presented in Table 1A-27.1, the environmentally superior alternative would be Alternative 1: No Project - No Development, because this alternative would consist of no physical development of the Project site and reduce the level of impacts for all environmental impacts that are either less than significant with mitigation or significant and unavoidable with implementation of the Project.
However, Alternative 1 is the CEQA “No Project” alternative, and therefore, the environmentally superior alternative is Alternative 5: Reduced Density, Alternative 2 (7,500 Units). 1A.6 Summary of Environmental Impacts and
Mitigation Measures
Table 1A-32 provides the list of all Project Design Features (PDFs) incorporated into the Aquabella Specific Plan Amendment and the design of the Project in order to minimize potential environmental effects of the Project. To ensure enforcement, the PDFs will be included in the Project’s Mitigation Monitoring and Reporting Plan (MMRP).
Table 1A-43 summarizes the results of the environmental analysis, including the potentially significant environmental impacts of the Project, the proposed mitigation measures required to reduce or avoid these impacts, and the level of significance after mitigation. Each adopted mitigation measure also will be included in the Project’s MMRP to ensure enforcement. Impacts and mitigation measures in Table 1A-43 are organized by issue areas addressed in Chapter 4, Environmental Analysis. Chapter 5, Cumulative Impacts, includes an analysis of the cumulative impacts of the Project for each issue. Chapter 6, Other CEQA Considerations, includes a brief analysis of the effects found not to be significant.
Table 1A-32. Project Design Features
Air Quality
PDF-AQ/GHG-1: Electric Vehicle Charging Infrastructure. The Project applicant or designee shall provide electric vehicle (EV) charging infrastructure that meets or exceeds 2022 California Green Building Standards Code Tier 2 standards to encourage use of EVs, consistent with Appendix D, Table 3, of the 2022 CARB Scoping Plan. The Project provides a total of 23,772 parking spaces. Of that amount, the Project shall install (a) 9,509 (or 40%) Level 2 240-volt (v) electric vehicle receptacles in Project parking structures and (b) 3,566 (or 15%) Level 2 240 v electric vehicle supply equipment (or stations) in Project parking lots or remaining garages.
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[PROJECT NUMBER] 6
[MONTH YEAR]
Pages 1A-23 through 1A-26
Table 1A-43. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
Air Quality
Would the project conflict with
or obstruct implementation of
the applicable air quality plan?
Potentially
Significant
MM-AQ-1: Update the Regional
Growth Forecast. The applicant has
informed the Southern California
Association of Governments (SCAG) of
the Project so that SCAG’s next
Regional Transportation
Plan/Sustainable Communities
Strategy, Connect SoCal 2024, can
appropriately reflect residential
housing, population, and employment
locations and forecasts in Moreno
Valley. The updated information
provided to SCAG is anticipated to be
used by the South Coast Air Quality
Management District (SCAQMD) to
update the Air Quality Management
Plan (AQMP). The applicant shall
prepare and submit a letter notifying
SCAQMD of this revised forecast for
use in the future updates to the plan
as required.
MM-AQ-2: Construction Equipment
Exhaust Minimization. Prior to the
commencement of any construction
activities, the Applicant or its
designee shall provide evidence to
the City of Moreno Valley (City) that
(1) for off-road equipment with
engines rated at 25 horsepower or
greater, no construction equipment
shall be used that is less than Tier 4
Final, and (2) for off-road equipment
with engines rated less than 25
horsepower, all construction
equipment used shall be electrically
powered. In the event of changed
circumstances related to the
availability of specific types of
construction equipment, the
applicant may submit a request to the
City of Moreno Valley’s Community
Development Department to apply an
equivalent method of achieving
Project-generated construction
Significant and
Unavoidable
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Table 1A-43. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
emissions that fall below the criteria
pollutant mass daily thresholds for
construction, the applicable localized
significance thresholds (LSTs), and
the numeric cancer risk standards
established by the South Coast Air
Quality Management District
(SCAQMD). An exemption from this
requirement may be granted if (1) the
applicant documents equipment with
Tier 4 Interim engines are not
reasonably available, and (2) the
required corresponding reductions in
criteria air pollutant emissions can be
achieved for the project from other
combinations of construction
equipment. Before an exemption may
be granted, the Applicant’s
construction contractor shall: (1)
demonstrate that at least 3
construction fleet owners/operators
in Riverside County were contacted
and that those owners/operators
confirmed Tier 4 Final equipment
could not be located within Riverside
County during the desired
construction schedule; and (2) the
proposed replacement equipment
has been evaluated using California
Emissions Estimator Model
(CalEEMod) or other industry
standard emission estimation method
and documentation provided to the
City to confirm that Project-generated
construction emissions would remain
below the applicable criteria pollutant
mass daily thresholds for
construction, the LSTs, and the
cancer risk threshold established by
SCAQMD necessary project-generated
emissions reductions are achieved.
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Pages 1A-52 through 1A-56
Table 1A-3. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
Hazards and Hazardous Materials
Would the project create a
significant hazard to the public
or the environment through
reasonably foreseeable upset
and accident conditions
involving the release of
hazardous materials into the
environment?
Potentially
Significant
MM-HAZ-1: Site Characterization and
Remediation. Following Project design
finalization, but prior to the issuance
of a grading permit, the Project
applicant/developer or their
designated contractor shall retain a
qualified environmental consultant to
conduct subsurface investigations to
fully characterize the nature and
extent of contamination at the Project
site. The investigation will include
preparation of a soil sampling and
analysis plan (SAP), which will be
reviewed and signed by a registered
engineer or geologist with experience
in site characterization. The SAP will
take into account final design and
proposed development of each area,
including grading and excavation
depths, building use and occupancy
(commercial vs residential), and other
features which could indicate
applicable screening levels and
screening requirements. The SAP
shall include methods and
procedures to evaluate areas of the
Project site where there are known
soil impacts, including the former
tank storage areas, vehicle
maintenance areas, areas with
elevated metals and pesticides, and
sludge application areas. Soil
sampling shall include at least two
depths at each sample location to
properly characterize potential
subsurface impacts, and will include
analysis for petroleum hydrocarbons,
VOCs, SVOCs, and metals. Samples
from at least two different depths will
be collected from more than two
locations in each area of concern to
properly characterize each area,
including, at a minimum, each former
UST location, each sludge application
area, the vehicle maintenance and
storage area, the wash down area,
Less than
Significant with
Mitigation
Incorporated
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Table 1A-3. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
and areas with elevated metals and
pesticides in surface soil samples
(identified in the 1993 Phase II ESA)
(shown in red and yellow on Figure
4.11-1). Soil vapor samples will be
collected in the UST, maintenance,
washdown, and sludge application
areas, at dual depths, to properly
characterize potential soil and soil
vapor contamination due to historical
site uses. The SAP will include
applicable regulatory screening levels
for both soil and soil vapor based on
proposed site development. Site
investigation will be conducted as
outlined in the SAP.
For soils, based on the results of the
sampling and analysis and
comparison to applicable regulatory
screening levels, a soil management
plan (SMP) shall be prepared by a
qualified environmental consultant.
The SMP will outline the proper
screening, handling, characterization,
transportation, and disposal
procedures for contaminated soils on
the Project site. The SMP will outline
criteria for reuse on site, based on
the final development plan and land
use in each area, including
comparison to regulatory screening
levels. The SMP will include
procedures for removal and disposal
of soils that do not meet reuse
criteria, including transportation,
documentation, and landfilling
requirements. The SMP shall include
health and safety and training
procedures for workers who may
come in contact with contaminated
soils, and will include health and
safety and site control measures to
prevent contaminated material
emissions from the site (such as dust
suppression and vehicle tracking).
The SMP shall be implemented by the
Project applicant or their designated
contractor for all confirmed and
suspected contaminated soils which
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Table 1A-3. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
require excavation and off-site
disposal. The SMP shall also include
procedures for the identification and
proper abandonment of underground
storage tanks, should any be
identified during demolition and
construction activities around the
existing dairies and residences. The
SMP shall include all applicable
federal, state, and local regulations
(including Riverside County
Department of Environmental Health)
associated with handling, excavating,
and disposing of contaminated soils;
the proposed disposal facility that will
accept the contaminated soils; and
appropriate procedures, notifications,
permitting requirements, handling,
and disposal requirements for
decommissioning any underground
storage tanks.
For soil vapor, based on the results of
the sampling and analysis and
comparison to applicable regulatory
screening levels, a soil vapor
mitigation plan (SVMP) shall be
prepared by a qualified
environmental consultant. The SVMP
will outline appropriate vapor
mitigation methods for any proposed
on-site buildings in areas where
elevated soil vapor concentrations
are identified above the applicable
screening levels for the proposed
land use (open space, residences,
schools, etc.). The SVMP will be
prepared with consideration of the
SMP, as excavation of impacted soils
may reduce soil vapor impacts. Vapor
mitigation design features shall be
implemented in accordance with the
DTSC Vapor Intrusion Mitigation
Advisory for all future residential
buildings and enclosed structures in
areas where soil vapor is present
above applicable regulatory screening
levels for the proposed land use. The
construction contractor shall
incorporate vapor mitigation design
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Table 1A-3. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
features into building plans that
reduce potential vapor intrusion in
buildings and enclosed structures on
the Project site to below applicable
screening levels. Vapor mitigation
systems may be passive or active in
nature, so long as they are designed
to prevent vapor contamination in
accordance with applicable DTSC
regulations. Vapor mitigation systems
must be reviewed and approved by
the permitting agency(ies) prior to
construction and prior to issuance of
any certificate of occupancy.
Operation of the Project shall
maintain functionality of these
features as required to ensure
protection from vapor intrusion.
Following completion of construction
and occupancy of the buildings,
indoor air monitoring will occur
semiannually for one year to verify
implemented measures are
functioning properly and adequately
mitigating vapor intrusion to below
residential screening levels. If indoor
air samples indicate vapor intrusion
occurring at levels above applicable
regulatory screening levels,
modifications shall be made, as
necessary, to the designed system to
improve the efficacy in reducing
vapor intrusion to below applicable
screening levels. The SAP, SMP, and
SVMP shall be submitted to the City
for review and approval prior to
issuance of a grading permit. Should
the City require a qualified consultant
to review and make
recommendations prior to City
approval of such plans, the Project
applicant or designee shall pay for
such consultant services.
MM-HAZ-2: Characterization and
Closure of Dump Sites. Following
Project design finalization, but prior to
the issuance of a grading permit,
bBuried and open dump site areas
identified on site will be characterized
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Table 1A-3. Summary of Project Impacts, Mitigation, and Level of Significance Environmental Topic Impact? Mitigation Measure(s)
Level of
Significance
After Mitigation
to define nature and extent of waste
and potential contamination in
surrounding soils and soil vapor. Soil
will be sampled and analyzed for
VOCs, metals, petroleum
hydrocarbons, and SVOCs, while soil
vapor will be analyzed for VOCs and
methane. The full lateral and vertical
extent of the waste will be
characterized and limits of both
waste fill and contamination, if any,
will be determined based on this
sampling and analysis. The results,
along with a proposed closure plan,
will be submitted to Riverside County
DEH Environmental Cleanup Program
for review and approval. Closure
requirements will depend on the
nature and extent of contamination
and will ultimately be approved by
Riverside County DEH in accordance
with their rules and regulations.
Excavation of the dump site area, if
any, including exploration test pits,
will be conducted following SCAQMD
Rule 1150. Final closure
requirements will be included in
grading and development plans. If
excavation is required, excavated
wastes will be appropriately
characterized and landfilled at a
permitted off-site landfill in
accordance with federal, state, and
local rules and regulations. The
excavation will be backfilled with
either on-site soils or clean fill. Should
imported fill be required, it will meet
clean fill requirements established by
DTSC in their 2001 Information
Advisory Clean Imported Fill Material
Fact Sheet.
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3.3 Edits made to Chapter 3, Project Description
Pages 3-14 through 3-15
Development implementation may occur within several areas of the site simultaneously. While some of the infrastructure for the Project is already in place, additional infrastructure improvements would be correlated to correspond to residential development phasing and consider the sequence required by any public financing mechanisms and any Development Agreement between the applicant and City.
Although the Project applicant had previously withdrawn the application for a Development Agreement, it thereafter requested that the application be reinstated to accommodate the City and the applicant’s Development Agreement whereby the Project applicant has agreed to construct a turn-key 24,000 square foot Senior Center (i.e., a designed, constructed, and delivered building) and to dedicate the subject land and improvements to the City. Construction of the Senior Center and the conveyance of the land and improvements to the City must occur no later than 36 months after the occupancy permit (final inspection) is issued for the 8,000th residential unit within the Project. In addition, the Aquabella Development Agreement shall (as agreed to by the City and the applicant) require the applicant to develop 80 acres of land for public park purposes and to dedicate said parkland and improvements to the City, subject to the City providing the applicant with the appropriate Development Impact Fee credits. Also, the applicant acknowledges that a total of 129 acres of parkland is required as a condition of approval of the Project; as such, the applicant acknowledges that it shall be obligated to pay the Quimby Fees and associated Development Impact Fees (for parks) for the remaining 49 acres that are not dedicated by or developed by the applicant.
For the purposes of the preparation of this SEIR, Project phasing is broken down into six total Project phases.
Implementation of each Project phase would occur in separate construction phases.
Pages 3-27 through 3-28
The proposed Project would require approval of the following discretionary actions by the Moreno Valley City Council, which are submitted and processed concurrently:
1. Specific Plan Amendment (SPA) (PEN 23-0109) – The Aquabella SPA (Appendix A) would update and modify previous Specific Plan No. 218 to take advantage of the “center city” location and to establish a prominent destination for area residents and workers to live and recreate within a vibrant hub for the City and region.
The SPA is needed to provide additional housing opportunities for residents and area workers and families seeking to take advantage of the site’s location within central Moreno Valley, proximity to major job centers, efficient transportation network, sustainable lake features, and other amenities. The SPA would provide updated development standards and design guidelines for the further proposed development within the Project site and add one approximately 10-acre parcel to the eastern boundary of the Project site (APN:
486-310-014).
2. General Plan Amendment (GPA) (PEN 23-0127) – Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 General Plan, which was “locked” in place as the general plan and land use standards applied to the Project. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). TheA GPA would be required to (a) change the 2040 General Plan Land Use & Community Character Element Table LCC–1, Development Potential and Jobs-Housing Balance, and related text, to update projected housing and job numbers to include the Project; (b) change the 2040 General Plan Table LCC-3, Downtown Center Illustrative Development Program (Net New Development 2020-2040), to reflect the updated Downtown Center development program by including the Project; and (c) change 2040 General 3 - ERRATA
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Plan Map LCC-4, General Plan Land Use, to reflect the land use designation change of the approximately 10-acre parcel on the eastern boundary of the Project site (Assessor’s Parcel No. 486-310-014) from R5 Residential to Downtown Center (Aquabella Specific Plan).
BecauseIf the 2006 General Plan would beis operative at the time of approval and pursuant to the City’s request, the Project would include require a GPA to also amend the 2006 General Plan Land Use Map, Figure 2-2, to accommodate the Project, which would designate the entire Project site “Specific Plan.” The 2006 GPA would be concurrently processed with the 2040 GPA, which would become effective upon readoption of the 2040 General Plan. The accompanying 2040 General Plan EIR is currently undergoing correction.
3. Change of Zone (CZ) (PEN 24-0041) - Having submitted an SB 330 preliminary application, the Project is being processed under the 2040 Zoning that was adopted and in effect to implement the 2040 General Plan. See Government Code Sections 65941.1(a), 65589.5(o)(1), 65589.5(o)(4). TheA proposed change of zone would rezone the approximately 10-acre parcel on the eastern boundary of the Project site from Residential 5 (R5) District to DC-SP (SP 218) in order to incorporate the parcel into the Project boundary, at which point it would be subject to the zoning, design, and development requirements therein. Assuming the 2006 Zoning is operative at the time of Project approval, the Project would concurrently process this 2040 change of zone to become effective upon re-adoption of the 2040 Zoning.
Because the 2006 Zoning would be operative at the time of Project approval, and pursuant to the City’s request, the Project would also include a change of zone to rezone the entire site to Specific Plan (SP) 218 on the 2006 Zoning Map.
4. Subsequent Environmental Impact Report Certification (PEN 23-0111) – Certification of this SEIR, which has been prepared in conformance with CEQA to ensure that the incremental environmental impact changes between the Project and the previous Specific Plan are analyzed and considered and that all feasible and reasonable mitigation measures or alternatives are implemented to reduce the identified significant impacts. Overriding considerations will be considered by the City. The preparation and review process of the SEIR requires public notification, stakeholder input, and community participation.
5. Tentative Tract Map No. 38850 (PEN 23-0118) - The Tentative Tract Map would provide the subdivision plans for the Aquabella Specific Plan area for finance and conveyance purposes. The Tentative Tract Map will consolidate the existing 10 parcels and create an estimated 26 new parcels.
6. Development Agreement (PEN 23-0119) - The Development Agreement would be a written agreement between the Project applicant and the City in order to specify the respective obligations of the parties.
3.4 Edits made to Section 4.3, Air Quality
MM-AQ-2 Construction Equipment Exhaust Minimization. Prior to the commencement of any construction activities, the applicant or its designee shall provide evidence to the City of Moreno Valley (City) that (1) for off-road equipment with engines rated at 25 horsepower or greater, no construction equipment shall be used that is less than Tier 4 Final, and (2) all generators, welders, and air compressors used during building construction and architectural coating of structures during residential (including combined residential and parking structure), retail, education (school), and hotel phases shall be electrically powered. Notably, generators, welders, and air compressors for parks/recreational and asphalt for circulation and parking phases are excluded from electrification 3 - ERRATA
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requirements in (2) due to feasibility considerations, but still subject to Tier 4 Final requirements in (1).
In the event of changed circumstances related to the availability of specific types of construction equipment, the applicant may submit a request to the City of Moreno Valley’s Community Development Department to apply an equivalent method of achieving Project-generated construction emissions that fall below the criteria pollutant mass daily thresholds for construction, the applicable localized significance thresholds (LSTs), and the numeric cancer risk standards established by the South Coast Air Quality Management District (SCAQMD). An exemption from this requirement may be granted if (1) the applicant documents equipment with Tier 4 Interim engines are not reasonably available, and (2) the required corresponding reductions in criteria air pollutant emissions can be achieved for the project from other combinations of construction equipment.
Before an exemption may be granted, the applicant’s construction contractor shall: (1) demonstrate that at least 3 construction fleet owners/operators in Riverside County were contacted and that those owners/operators confirmed Tier 4 Final equipment could not be located within Riverside County during the desired construction schedule; and (2) the proposed replacement equipment has been evaluated using California Emissions Estimator Model (CalEEMod) or other industry standard emission estimation method and documentation provided to the City to confirm that Project-generated construction emissions would remain below the applicable criteria pollutant mass daily thresholds for construction, the LSTs, and the cancer risk threshold established by SCAQMD necessary project-generated emissions reductions are achieved.
3.5 Edits made to Section 4.8, Greenhouse
Gas Emissions
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period (i.e., decades or longer). The Earth’s temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun’s energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere (EPA 2023ac).
…
The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time scales and that, in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by natural causes such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.
Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that warming since the mid-twentieth century and is the most significant driver of observed climate change (IPCC 2013; EPA 2023bd).
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The descriptions of GHGs are summarized from the Intergovernmental Panel on Climate Change (IPCC) Second Assessment Report (1995), IPCC Fourth Assessment Report (2007), CARB’s “Glossary of Terms Used in GHG Inventories” (2018), and EPA’s “Glossary of Climate Change Terms” (202416d).
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo [reflection of light from the Earth]) (EPA 2023ce).
…
Per the EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2021, total United States GHG emissions were approximately 6,340.2 million metric tons (MMT) CO2e in 2021 (EPA 2023df). Total U.S. emissions have decreased by 2.3% from 1990 to 2021, down from a high of 15.8% above 1990 levels in 2007. Emissions increased from 2020 to 2021 by 5.2% (314.3 MMT CO2e). Net emissions (i.e., including sinks) were 5,586.0 MMT CO2e in 2021. Overall, net emissions increased 6.4% from 2020 to 2021 and decreased 16.6% from 2005 levels.
Between 2020 and 2021, the increase in total GHG emissions was driven largely by an increase in CO2 emissions from fossil fuel combustion due to economic activity rebounding after the height of the COVID-19 pandemic. The CO2 emissions from fossil fuel combustion increased by 6.8% from 2020 to 2021, including a 11.4% increase in transportation sector emissions and a 7.0% increase in electric power sector emissions. The increase in electric power sector emissions was due in part to an increase in electricity demand of 2.4% since 2020. Overall, there has been a decrease in electric power sector emissions from 1990 through 2021, which reflects the combined impacts of long-term trends in many factors, including population, economic growth, energy markets, technological changes including energy efficiency, and the carbon intensity of energy fuel choices (EPA 2023df).
The Inflation Reduction Act authorized the EPA to implement the Greenhouse Gas Reduction Fund Program, which is a historic, $27 billion investment to mobilize financing and private capital to combat the climate crisis and ensure American economic competitiveness. The Greenhouse Gas Reduction Fund will be designed to achieve the following program objectives: reduce GHG emissions and other air pollutants; deliver the benefits of GHG- and air-pollution-reducing projects to American communities, particularly low-income and disadvantaged communities; and mobilize financing and private capital to stimulate additional deployment of GHG and air pollution reducing projects (EPA 2023eg).
The RTP/SCS is updated every four years. On April 4, 2024, SCAG has recently released its draftadopted the 2024– 2050 RTP/SCS, also referred to as “Connect SoCal 2024.” However, Connect SoCal 2024 has not been adopted or approved at this time. CEQA does not require consideration of draft plans not adopted or approved at the time of the EIR (South of Market Community Action Network v. City and County of San Francisco [2019] 33 Cal.App.5th 321, 353; Chaparral Greens v. City of Chula Vista [1996] 50 Cal.App.4th 1134, 1145, fn. 7). For informational purposes, the draft Connect SoCal 2024 builds on the prior RTP/SCS and identifies the following strategy areas to support its 3 - ERRATA
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environmental goals: Sustainable Development, Air Quality, Clean Transportation, Natural and Agricultural Lands Preservation, and Climate Resilience. states goals divided into four categories: (1) Mobility: Build and maintain a robust transportation network; (2) Communities: Develop, connect and sustain communities that are livable and thriving; (3) Environment: Create a healthy region for the people of today and tomorrow; and (4) Economy: support a sustainable, efficient, and productive regional economic environment that provides opportunities for all residents.
Should Connect SoCal 2024 be adopted prior to certification of this SEIR, this section will be updated in the Final SEIR.
This GHG analysis estimates the gain of sequestered carbon that would result from planting and growth of trees on site. The calculation methodology and default values provided in i-Tree Planting were used to estimate the one-time carbon-stock change from planting new trees based on the trees provided in the landscaping plan for the Project (i-Tree 2021USFS 2023).
The CAP establishes a citywide target of increasing alternatives to single-occupant vehicle use by 10% for people employed in Moreno Valley by 2040. If the project involves a business with over 50 employees or tenants with such businesses, will the project implement Transportation Demand Management strategies and programs identified in Connect SoCal 2024, the SCAG Regional Transportation Plan/Sustainable Community Strategy (RTP/SCS), including but not limited to: implementing commuter benefit programs, promoting telecommuting and alternative work schedule options, and other financial incentives?
The Project is also consistent with the goals of the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), “Connect SoCal 2024,” as detailed in Section 4.17, Transportation, and 4.11, Land Use and Planning.
The Project also satisfies the City’s VMT significance criteria, which demonstrates consistency with SCAG’s SCS, as detailed below.
The Project would improve and enhance active transportation and transit access and facilities while diversifying housing in the area, consistent with General Plan Circulation Element policies and Connect SoCal 2024 goals.
Project Potential to Conflict with SCAG’s 2020-2045 and 2024-2050 RTP/SCS The SCAG 2020–2045 RTP/SCS is a regional growth management strategy that targets per-capita GHG reduction from passenger vehicles and light trucks in the Southern California region pursuant to SB 375.
▪ …The proposed Mobility Hub and promotion of micro mobility modes such as bikeshare and electric scooter along internal street network of the Project would leverage new transportation technologies and solutions to efficient travel for the Project occupants. The Project is consistent with the transportation-related goals 3 - ERRATA
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and policies of Connect SoCal 2024, and the does not conflict with anything related to the circulation system.
In addition, as evaluated in detail in the Project’s transportation analysis, per the City’s VMT significance criteria, the Project would have a less than significant VMT impact under Existing (2023) conditions, Horizon Year (2045) conditions with full buildout of WLC and Horizon Year (2045) conditions with partial buildout of WLC. The Project effect on VMT was also determined to be less than significant under all scenarios. Given that the Project would result in a less-than-significant impact related to VMT, the Project would support the transportation-related goals and policies of Connect SoCal 2024.
As noted above, SCAG has released its draft adopted the 2024-2050 RTP/SCS, “Connect SoCal 2024,” on April 4, 2024. “; however, the draft has not been adopted or approved at this time. CEQA does not require consideration of draft plans. (South of Market Community Action Network v. City and County of San Franciso (2019) 33 Cal.App.5th 321, 353; Chaparral Greens v. City of Chula Vista (1996) 50 Cal.App.4th 1134, 1145, fn. 7) For Informational purposes the”As an SB 330 project, the Project is subject to the 2020-2045 RTP/SCS because that regional plan was in effect when the Project’s preliminary application was submitted on September 6, 2023. (Gov. Code, §§ 65589.5(o), 65941.1.) Nonetheless, for informational purposes, an analysis of the Project’s compliance with the applicable strategies of Connect SoCal 2024 is presented below.
The following policies and strategies are intended to be supportive of implementing the 2024–2050 RTP/SCS and reducing GHGs: increasing access to neighborhood amenities, open space and urban greening, job centers and multimodal mobility options. Sustainable Development, Air Quality, Clean Transportation, Natural and Agricultural Lands Preservation, and Climate Resilience. The above analysis regarding consistency with the adopted Connect SoCal 2020 similarly supports Project consistency with these draft strategies. Should Connect SoCal 2024 be adopted prior to the City’s certification of this SEIR, this analysis will be updated in the Final SEIR. ▪ Sustainable Development. The 2024-2050 RTP/SCS identifies sustainable development, including water and energy-efficient building practices and green infrastructure, as a strategy to reduce GHG emissions. As described above, targeted sustainable design strategies of the Project include electrifying all buildings except restaurant spaces (PDF-AQ/GHG-3), providing rooftop solar panels (PDF-AQ/GHG-4), and including electric vehicle charging infrastructure (PDF-AQ/GHG-1). The Project would comply with current energy code requirements for battery storage, which both could help provide the EV chargers with renewable, clean energy in place of grid electricity from MVU. The site would contain 80 acres of recreational uses, and 30,000 trees would be planted on site (PDF-AQ/GHG-11). The Project would further support goals of sustainable development through provision of energy efficient appliances (PDF-AQ/GHG-6), LED lighting (PDF-AQ/GHG-5), energy smart meters (PDF-AQ/GHG-7), cool pavements (PDF-AQ/GHG-8), and a local farmer’s market (PDF-AQ/GHG-10). The Project would implement a water use efficiency and conservation plan for indoor and outdoor water use (PDF-AQ/GHG-12), use of recycled water for irrigation (PDF-AQ/GHG13), and use of local well water for the lake (PDF-AQ/GHG-14). The Project’s mixed-use design providing residential, retail, schools, and recreational facilities combined with the Project’s PDFs help support a connected, sustainable community and a healthy environment, in addition to supporting the sustainable development goal of the 2024-2050 RTP/SCS.
▪ Air Quality. The 2024–2050 RTP/SCS identifies air quality as an environmental strategy because the transportation sector is the predominant source of criteria air pollutant emissions in the region. The 2024– 2050 RTP/SCS states that a comprehensive and coordinated regional solution with integrated land use and transportation planning from all levels of governments will be required to achieve the needed emission 3 - ERRATA
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reductions (SCAG 2024). The Project’s TDM program and intentional Project design supports multimodal mobility options, as explained below in “Clean Transportation”, support the 2024–2050 RTP/SCS regional transportation planning objectives that reduce mobile source emissions. As evaluated in detail in the Project’s transportation analysis, per the City’s VMT significance criteria, the Project would have a less than significant VMT impact under Existing (2023) conditions, Horizon Year (2045) conditions with full buildout of WLC and Horizon Year (2045) conditions with partial buildout of WLC. The Project’s less-than-significant VMT impact supports the SCAG objective to achieve emission reductions within the transportation sector.
The Project’s mix of residential (primarily multi-family and workforce housing), commercial, retail, entertainment, employment, educational, and recreational uses support the 2024-2050 RTP/SCS objective of integrated land use. Overall, the Project supports the 2024-2050 RTP/SCS aim to improve air quality throughout the region though sustainable local and regional land use planning and implementation efforts, which can reduce transportation-related criteria air pollutant emissions on a per capita basis. ▪ Clean Transportation. The 2024–2050 RTP/SCS identifies EV charging infrastructure, adoption of zeroemission vehicles, and clean transit as ways to reduce GHG emissions from mobile sources. As described above, the Project would promote and support low emission technologies for transportation, such as EV charging stations (PDF-AQ/GHG-1), Level 2 ready receptacles, and EV capable outlets. The Project’s TDM program and intentional Project design supports multimodal mobility options, including cars (PDF-TRANS4 Rideshare Program), bus (PDF-TRANS-9 Extend Transit Network Coverage, PDF-TRANS-10 Increase Transit Service Frequency, PDF-TRANS-11 Implement BRT, and PDF-TRANS-12 Mobility Hub), non-electric and electric bicycles (PDF-TRANS-5 End-of-Trip Bicycle Facilities and PDF-TRANS-7 Non-Electric Bikeshare Program), electric scooters (PDF-TRANS-8 Electric Scootershare Program), and walking (PDF-LU-1 MixedUse Project Design, PDF-LU-2 Provision of Urban Core, PDF-LU-3 Short Walkable Blocks, PDF-LU-4 Increased Residential Density, PDF-LU-5 Walkable/Bikeable Community, PDF-LU-9 Complete Streets, and PDF-LU-10 Traffic Calming).
▪ Natural and Agricultural Lands Preservation. The 2024–2050 RTP/SCS promotes the conservation and restoration of natural and agricultural lands through several policies, such as quantifying the carbon sequestration potential of natural and agricultural lands and prioritization of sensitive habitat and wildlife corridors for permanent protection. The Project would develop a residential and mixed-use Specific Plan development on a graded, infill site previously approved for residential mixed-use development. Developing this infill site would discourage sprawl into open space and agricultural areas surrounding the City and integrate into the land use pattern of the existing community. Therefore, the Project would not convert natural and working lands or interfere with this strategy. ▪ Climate Resilience. The 2024–2050 RTP/SCS promotes regional coordination and solutions for effective emergency response for climate-related hazards. Additionally, in the category of climate resilience, SCAG has established the following policies: prioritize the most vulnerable populations and communities subject to climate hazards; support local and regional climate and hazard planning; support nature-based solutions to increase regional resilience; promote sustainable water use planning; and, support an integrated planning approach to help jurisdictions meet housing needs in a drier environment. While the Project does not directly pertain to these regional coordination efforts for climate resilience, the Project would not interfere with this strategy. Further, the Project has appropriately addressed hazard planning, wildfire/evacuation, and sustainable water use in this SEIR, as described in Sections 4.9, 4.19, and 4.20.
Based on the analysis above, the Project would be consistent with the SCAG 2024–2050 RTP/SCS. 3 - ERRATA
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