7.0_TCMV SP_Draft EIR.pdf — Moreno Valley City Council, June 3, 2025 (part 2 of 6)

Cottonwood Avenue, Nason Street, Alessandro Boulevard, and Bay Avenue adjacent to the Project site would be associated with the construction of sidewalks, curbs, and gutters; roadway extensions (Bay Avenue); landscaping within the public right -of-way; and any other roadway repairs/improvements required for the Project. The total Project impact area, including the Project site and off-site improvement areas (referred to in this EIR as the “Project site” or “Project area”) encompasses 70.27 acres and includes approximately 63.24 acres within the Project site (including public roadways that will be constructed as part of the Project) and 7.03 acres associated with site - adjacent roadway improvements.

In addition to the identified construction areas, a staging area is needed to receive, lay down, and prepare materials for use during construction. Construction staging would occur within the Project impact limits and would be located the furthest distance feasible from existing residential uses.

Additionally, perimeter screening would be installed to obstruct views from adjacent roadways and uses into the Project construction area from ground-level vantage points.

3.6 PROJECT OPERATIONAL CHARACTERISTICS
As described in Section 3.4.3, Town Center at Moreno Valley Specific Plan, the proposed TCMV Specific Plan involves a mixed-use development consisting of residential, commercial/civic, and open spaces uses. Below is a summary of operational characteristics relevant to the analysis presented in this EIR.

A. Residential Population
Based on the estimated maximum number of residential units for analysis purposes (up to 800 residential units), it is estimated that buildout of the TCMV Specific Plan could generate up to 3,080 residents. This is based on the estimated population generation factor of 3.85 people per unit presented in the City’s 2021-2029 Housing Element (adopted by the City on June 15, 2021, and certified on October 11, 2022).

B. Commercial Use Employment Generation
Future tenants for the proposed commercial spaces are not currently known; however, as identified in Section 3.4.3.A, for purposes of analysis in this EIR, it is anticipated that the uses would include office, civic center, library, hotel, high turnover (sit-down) restaurant, fast-foot restaurant with drive-thru, and commercial retail. For purposes of analysis in this EIR, employment generation numbers have been estimated by proposed use based on employment generation factors obtained from the County of Riverside and the Institute of Transportation Engineers (ITE), and are presented in Table 3 -7, Estimated Employment Generation. As shown, it is estimated that the non-residential development within the TCMV Specific Plan area would generate up to 421 employment opportunities.

LEGEND AND ABBREVIATIONS

PROPERTY LINE

RIGHT-OF-WAY

EASEMENT/SETBACK

STREET CENTERLINE
CURB

CURB & GUTTER

EDGE OF PAVEMENT

WATER MAIN

SANITARY SEWER LINE

STORM DRAIN LINE

GAS LINE
EDISON

TELEPHONE
OIL

CITY OF MORENO VALLEY
TV
ACRE

SQUARE FEET

CENTERLINE
CURB

EXISTING

FLOW LINE
MEDIAN

OPEN SPACE

PUBLIC FACILITY

PRIVATE ACCESS EASEMENT

PROPERTY LINE

RIGHT OF WAY

STORM DRAIN

SANITARY SEWER

TOP OF CURB

TOP OF GRATE

BOTTOM OF WALL

TOP OF WALL

UNLESS NOTED OTHERWISE

NOT A PART OF THIS PLAN

EXISTING PROPOSED
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NOT TO SCALE
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NO INDICATIONS OF FAULTING OR FAULT RELATED

FISSURING OR FRACTURING IS KNOWN TO EXIST OR
OBSERVED ONSITE. THIS SITE IS NOT LOCATED WITHIN A

CURRENTLY DESIGN A TED ALQUIST-PRIOLO EARTHQUAKE
§ FAULT ZONE OR COUNTY OF RIVERSIDE FAULT ZONE.
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BY CANNON CORP., FIELD DATA 3/18/22
3 .0 Project Description
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Figure 3-l l
Conceptual Grading Plan

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Town Center at Moreno Valley Specific Plan
Environmental Impact Report 3.0 Project Description
City of Moreno Valley

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Table 3-7 Estimated Employment Generation
Proposed Use Size Conversion Factor Estimated Employment Generation Office 15,000 sf 300 sf/employeea 50 employees
Civic Center 30,000 sf
500 sf/employeea
60 employees
Restaurant 20,160 sf 40 employees
Commercial Retail 105,890 sf 212 employees
Hotelb 106 rooms/848 trips 14.33 trips/employee 59 employees Total Estimated Employment Generation 421 employees
a Employee density factor was obtained from the County of Riverside General Plan Appendix E -2: Socioeconomic Build-Out Assumptions and Methodology (Table E-5, Commercial Employment Factors). b Employee generation factor was obtained from the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11 th Edition, 2021.

C. Trip Generation
During operation, residents, employees, and visitors would travel to and from the Project site on a daily basis. Based on the anticipated development identified in Section 3.4.3.A , Project operations are estimated to generate 12,010 daily trips, taking into consideration internal capture and/or pass -by trip reductions (refer to Section 4.16, Transportation).

3.7 SUMMARY OF REQUESTED ACTIONS
The City of Moreno Valley has primary approval responsibility for the Project. As such, the City serves as the Lead Agency for this EIR pursuant to CEQA Guidelines Section 15050. This EIR is intended to cover all State and local government approvals which may be needed to construct or implement the Project, whether or not such approvals are explicitly listed in the EIR. A list of the current discretionary and anticipated subsequent actions under City of Moreno Valley jurisdiction is provided in Table 3-8, Project Related Actions/Permits . Chapter 6, Implementation and Administration, of the proposed TCMV Specific Plan , describes the procedures for the processing of discretionary development applications to implement the terms of the Specific Plan. The City would review all development within the Specific Plan area , including uses permitted by right, to ensure compliance with the provisions of the Specific Plan. Additional discretionary and/or administrative actions would be necessary from other government agencies to fully implement the TCMV Specific Plan. Table 3-8 lists the government agencies that may use this EIR during their consultation and review of the Project and its implementing actions.
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Table 3-8 Project Related Actions/Permits
Public Agency Action/Permit
Proposed Project – City of Moreno Valley Discretionary Approvals City of Moreno Valley
Planning Commission
• General Plan Amendment (PEN25-0007)
• Change of Zone (PEN21-0335)
• TCMV Specific Plan (PEN21-0334)
• TTM No. 38421 (PEN22-0077)
• Certification of this EIR along with appropriate
CEQA Findings and Statement of Overriding
Considerations
City of Moreno Valley
City Council
• General Plan Amendment (PEN 25-0007)
• Change of Zone (PEN21-0335)
• TCMV Specific Plan (PEN21-0334)
• TTM No. 38421 (PEN22-0077)
• Certification of this EIR along with appropriate
CEQA Findings and Statement of Overriding
Considerations
Subsequent City of Moreno Valley Actions/Permits
City of Moreno Valley
• Plot plan(s) and landscaping/irrigation plan (s), and tree removal permit(s), as may be appropriate
• Grading Permits
• Building Permits
• Road Improvement Plans
• Encroachment Permits
• Public right-of-way dedications
• Stormwater Pollution Prevention Plan (SWPPP) and
Water Quality Management Plan (WQMP)
• Future amendments to land use, zoning, or specific
plans, if proposed
Other Agencies – Subsequent Approvals and Permits
Eastern Municipal Water District
• Administrative approvals for construction of water
and sewer infrastructure and connection to the water
and sewer distribution and conveyance systems.

Santa Ana Regional Water Quality Control Board
• Issuance of a Construction Activity General
Construction Permit.
• Issuance of a National Pollutant Discharge
Elimination System (NPDES) Permit.

Riverside County Flood Control & Water
Conservation District (RCFC&WCD)
• Approval of storm drain plans for public storm
drain(s).

South Coast Air Quality Management District
(SCAQMD)
• Permits to construct and/or permits to operate new
stationary sources of equipment that emit or control
air contaminants, such as the proposed gas station.

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4.0 ENVIRONMENTAL ANALYSIS

4.0.1 SUMMARY OF EIR SCOPE
In accordance with CEQA Guidelines , Sections 15126-15126.4, this Environmental Impact Report (EIR) Section includes analyses of potential direct, indirect, and cumulatively considerable impacts that could result from the planning, construction, and/or operation of the Project.

As further discussed in EIR Section 1.0, Introduction, the City prepared a Notice of Preparation (NOP) that identified the scope of environmental analysis for this EIR (refer to Technical Appendix A). The City made the NOP available on its website for review and mailed the NOP to public agencies and interested individuals to solicit input on the scope of study for this EIR. The City also held an EIR Scoping Meeting to inform the public of the Project and the environmental review process and provide additional information on how to submit public comments . Taking all known information and public comments into consideration, 20 environmental subject areas are evaluated in detail in this EIR Section

4.0, as listed below . Each subsection evaluates several specific topics related to the primary environmental subject. The title of each subsection is not limiting; therefore, refer to each subsection for a full account of the specific subject matters addressed therein.

4.1 A esthetics

4.2 Agriculture and Forestry Resources

4.3 Air Quality

4.4 Biological Resources

4.5 Cultural Resources

4.6 Energy

4.7 Geology and Soils

4.8 Greenhouse Gas Emissions

4.9 Hazards and Hazardous Materials

4.10 Hydrology and Water Quality

4.11 Land Use and Planning

4.12 Mineral Resources

4.13 Noise

4.14 Population and Housing

4.15 Public Services and Recreation

4.16 Transportation

4.17 Tribal Cultural Resources

4.18 Utilities & Services Systems

4.19 Wildfire

4.0.2 SCOPE OF CUMULATIVE EFFECTS ANALYSIS
CEQA Guidelines Section 15130 states that cumulative impacts of a project shall be discussed whe n the projects’ incremental effect is cumulatively considerable , and further states that this discussion shall reflect the level and severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. Section 15355 of the CEQA Guidelines defines cumulative impacts as “. . . two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15355(b) of the CEQA Guidelin es states that “cumulative impacts from sever al projects is the change in the environment which results from the incremental impact of a project when added to other closely related past, present, and reasonably foreseeable probable future projects.”

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Section 15130(b)(1) of the CEQA Guidelines states that the information utilized in an analysis of cumulative impacts should come from one of two sources, either:

A. A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency, or B. A summary of projections contained in an adopted local, regional, or Statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect.

Cumulative impacts are addressed for each topic analyzed in Section 4.1 through Section 4.19 of this EIR. Because of the nature of individual environmental factors, the cumulative area for each topical issue is not the same. The individual cumulative areas for the issues addressed in this EIR are provided in the respective impact sections . The cumulative analysis for individual topical areas may consider specific cumulative study areas designated by respective agencies for regional or area-wide conditions.

For instance, topic-specific cumulative study areas have been developed (e.g., South Coast Air Basin for air quality and the Santa Ana River Watershed for hydrology and water quality). Also, this EIR considers regional programs directed at mitigating cumulative impacts of development such as those instituted for urban runoff.

Finally, and where appropriate to the analysis in question, cumulative impacts are assessed with reference to a list of cumulative projects as specified in Section 15130(b)(1)(A ) of the CEQA Guidelines. A comprehensive cumulative project list was compiled based on information provided by the City of Moreno Valley Planning and Engineering Departments. Figure 4.0-1, Cumulative Projects Location Map, illustrates the location of identified cumulative development with respect to the Project site. A summary of cumulative development projects and their proposed land uses are provided in Table 4.0-1, List of Cumulative Projects, below.

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Environmental Impact Report
Source(s): Urban Crossroads (December 2024)
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4.0 Environmental Analysis
Figure 4.0- l
Cumulative Projects Location Map

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Table 4.0-1 List of Cumulative Projects
1 Rocas Grandes II Multifamily Housing (Low-Rise) 460 DU 2 Alessandro Walk
Single Family Detached Residential 227 DU
Office 3.150 TSF
3 TTM38480 Single Family Housing 37 DU
4 World Logistics Center
High-Cube Logistics Center 40,400.000 TSF
Light Logistics 200.000 TSF
SCG Valve/Metering Station 0.150 TSF
SDG&E Gas Compression Station 30.800 TSF
Fire Station 1 Site
Gas Station w/ Market 12 VFP
Convenience Store 3.000 TSF
5 Tract 38123 Single Family Housing 195 DU
6 Cottonwood and Nason Residential 177 DY
7 Village at Moreno Valley
Gas Station w/ Market 18 VFP
Retail 33.000 TSF
Fast-Food Restaurant w/ Drive-Thru 9.956 TSF
Fast-Food Restaurant w/o Drive-Thru 4.500 TSF
High Turnover Sit-Down Restaurant 4.500 TSF
8 Rocas Grandes Multifamily Housing (Low-Rise) 420 DU
9 TR38236 Single Family Detached Residential 204 DU
10 TR38237 Single Family Detached Residential 67 DU
11 Rancho Bella Vista Specific Plan Single Family Detached Residential 745 DU 12 Moreno Beach Gas Station Gas Station w/ Market 16 VFP 13 PM 37942 - 7 Commercial Lots
Medical-Dental Office 32.000 TSF
General Office 40.000 TSF
Gas Station w/ Market 12 VFP
Fast-Food w/ Drive-Thru 5.600 TSF
High Turnover Sit-Down Restaurant 3.500 TSF
Retail 4.500 TSF
14 Aquabella Specific Plan
Multifamily Housing (Low-Rise) 7,500 DU
Multifamily Housing (Mid-Rise) 7,500 DU
Hotel 300 RM
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Commercial 49.900 TSF
Park 40.0 AC
Elementary School 3,995 ST
Middle School/Junior High School 2,049 ST
15 Tract 32408 Single Family Housing 80 DU
16 Alessandro/Lasselle Commercial
Convenience market/gas station 16 VFP
Fast-Food Restaurant w/ Drive-Thru 6.640 TSF
High-Turnover Sit-Down Restaurant 7.250 TSF
Shopping Center 3.200 TSF
General Office Bldg. 9.900 TSF
Car Wash 3.850 TSF
Bank w/ Drive-Thru 3.775 TSF
17 Dracaea and Nason Development Single Family Detached Residential 146 DU 18 TTM38443 Single Family Residential 133 DU
19 Crystal Windows West Coast
Headquarter Project
Light Industrial Building 196.800 TSF
Light Industrial Building 168.600 TSF
20 Beyond Food Mart
Gas Station w/ Market 16 VFP
Automated Car Wash 1.790 TSF

1.DU=dwelling units; TSF=thousand square feet; VFP=vehicle fueling position; STU=students

4.0.3 ANALYSIS FORMAT
EIR Section 4.1 through Section 4.19 evaluate the 20 environmental subjects warranting analysis as identified by the City of Moreno Valley in consideration of preliminary research findings, public comments, and technical study. The format of discussion is standardized as much as possible in each section for ease of review. Each topical section includes the following information:
• A description of the existing setting.
• A discussion of the applicable regulatory criteria (laws, policies, regulations) that the Project and its implementing actions are required to comply with (if any). • Identification of thresholds of significance based on the thresholds included in Appendix G of the CEQA Guidelines.
• Analysis of potential Project impacts that would result from implementation of the Project based on specified thresholds of significance.
• Evaluation of potential cumulative impacts.
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• Identification of level of significance of Project impacts before mitigation. • Identification of Project -specific Mitigation Measures (MMs), if required, to reduce the identified Project impacts; these MMs will be included in the Project’s Mitigation Monitoring and Reporting Program (MMRP).
• Identification of the level of significance of impacts after mitigation, including unavoidable significant adverse impacts.

As required by CEQA Guidelines Section 15126.2(a), Project -related effects on the environment are characterized in this EIR as direct, indirect, cumulatively considerable, short-term, long-term, on-site, and/or off-site impacts. Serving as the CEQA Lead Agency for this EIR, the City of Moreno Valley is responsible for determining whether an adverse environmental effect identified in this EIR should be classified as significant or less than significant. The standards of significance used in this EIR are based on the independent judgment of the City of Moreno Valley, taking into consideration the City of Moreno Valley Rules and Procedures for the Implementation of the California Environmental Quality Act (July 2019), the General Plan, the Moreno Valley Municipal Code and adopted City policies, the judgment of the technical experts that prepared this EIR’s technical appendices, performance standards adopted, implemented, and monitored by regulatory agencies, and significance standards recommended by regulatory agencies.

The “Project” evaluated in this Draft EIR includes development of the approximately 69.6-gross-acre Project site pursuant to the proposed Town Center at Moreno Valley Specific Plan, construction of new north-south and east-west public roadways on-site, and minor off-site improvement areas adjacent to the Project site primarily for driveway/access improvements and utility connections (site -adjacent improvement areas).

For any impact identified as significant and unavoidable, the City of Moreno Valley would be required to adopt a S tatement of Overriding Considerations pursuant to CEQA Guidelines Section 15093 in order to approve the Project despite its significant impact(s) to the environment . The Statement of Overriding Considerations would list the specific economic, legal, social, technological, and other benefits of the Project, supported by substantial evidence in the Project’s administrative record, that outweigh the unavoidable impacts.
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4.1 AESTHETICS
This section describes the aesthetic qualities and visual resources present on the Project site and in the site’s vicinity and evaluates the potential effects that the Project may have on these resources .

Descriptions of existing visual characteristics, both onsite and in the vicinity of the Project site, and the analysis of potential impacts to aesthetic resources are based on field observations and site photographs; analysis of aerial photography, and the Project application materials submitted to the City described in Section 3.0, Project Description, of this EIR. References used in this section are listed in EIR Section 7.0, References.

4.1.1 EXISTING CONDITIONS
A. Scenic Vistas and Scenic Resources
The City generally defines a scenic vista as a view of undisturbed natural lands that exhibit unique or unusual features that comprise an important or dominant portion of the viewshed (City of Moreno Valley 2021a).1 Scenic vistas may consist of distant views that provide visual relief from less attractive views of nearby features . Designated federal and State lands, and local open space and recreational areas also offer scenic vistas if these resources represent a valued aesthetic view within the surrounding landscape.

According to the 2006 General Plan Conservation Element and as shown on 2006 General Plan Map Figure 7-2, Major Scenic Resources, and the City-proposed 2040 General Plan Map OSRC-3, Scenic Resources and Ridgelines, principal scenic resources in the City, which include Box Spring Mountain to the north and Bernasconi Hills to the south, are visible from S tate Route (SR)-60, which extends east-west through the northern portion of the C ity. At the eastern edge of the City, SR-60 passes through the Badlands area , which is characterized by steep and eroded hillsides . Expanses of open land, San Jacinto Valley, and Mystic Lake are found throughout this area and allow for uninterrupted views from SR-60, Gilman Springs Road, and other roadways . Distant views of the San Bernardino, Box Spring, San Jacinto, and San Gabriel Mountains are visible from the valley floor. Additionally, within the City’s limits, Moreno Peak is a prominent landform located south of SR-60 along Moreno Beach Drive, approximately 0.5-mile northeast of the Project site. 2040 General Plan Map OSRC -3 also identifies view corridors along portions of SR-60, Moreno Beach Drive, and Gilman Springs Road.

There are no State-designated or eligible scenic highways in the City. The closest eligible State scenic highway is SR-74, located approximately 8.0 miles south of the City (approximately 11 miles south of the Project site), and the nearest officially designated segment of a S tate scenic highway is a portion of SR-74 located approximately 20 miles southeast of the City (approximately 22 miles southeast of the Project site) (Caltrans 2022).

1 The aesthetics information provided in the Final Environmental Impact Report for the MoVal 2040: Moreno Valley Comprehensive Plan Update, Housing Element Update, and Climate Action Plan remains applicable to the discussion of the existing environmental setting for aesthetics in the City. The court decision did not address this topical issue. ■■
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B. Project Site and Surrounding Areas
The Project site is located within a developing area, and as previously shown on Figure 2-1, Existing Onsite and Surrounding Land Uses , is surrounded by single-family residences , places of worship, public facilities (e.g., schools and EMWD facility), and vacant lots . Refer to EIR S ection 2.3, Surrounding Land Uses, for a description of uses in proximity to the Project site.

Topographically, the Project site gently slopes to the south with elevations ranging from approximately 1,640 feet above mean sea level (amsl) in the northern portion of the site to 1,590 feet amsl in the southern portion of the site . There are no rock outcroppings or unique topographical features onsite ; however, there are soil stockpiles in the southeastern portion of the Project site. The soil was generated during construction for street improvements in the City. The smaller of the two stockpiles is approximately 90 feet wide, 410 feet long, and three feet high. The larger stockpile is approximately 160 feet wide, 975 feet long, and 20 feet high at its highest point.

A viewshed as an area that is seen from a vantage point and viewing direction and is composed of foreground items (items closer to the viewer) that are seen in detail and background items (items at some distance from the viewer) that frame the view. The on-site stockpiles obstruct views into the Project site from Nason Street near Alessandro Boulevard, but views of the site are accessible from other segments of this roadway and the other roadways adjacent to the site. Due to the relatively flat topography of the Project site and surrounding areas, views of the site from distant vantage points are limited.

Figure 4.1-1 through Figure 4.1-6 provide a representative visual depiction of the Project site and surrounding area’s visual characteristics as seen from surrounding public viewing areas, which consist of public roadways adjacent to the Project site. A brief description of the viewshed is provided below. • Views 1 through 4 – Views from the West and North. Views 1 through 4, shown in Figure

4.1-1 and Figure 4.1-2, represent existing views from vantage points west and north of the Project site generally looking east and south, respectively. Views from these vantage points are representative of views that would be experienced from pedestrians, passenger vehicles, and bicyclists traveling east along Bay Avenue (View 1) and Cottonwood Avenue (Views 2 through 4). As illustrated in View 1, the Project site , which is in the foreground, is relatively flat and is covered with limited low vegetation. Existing uses east of Nason Street, and Moreno Peak are visible in the background along with distant mountain views . Views of the San Bernardino Mountain and San Jacinto Mountains are partially obstructed by closer landforms.

As illustrated in Views 2 and 4, e xisting residences and other existing uses are visible in the background from Cottonwood Avenue looking south. Additionally, partially obstructed views of the Bernasconi Hills are provided in Views 2 and 4 and distant views of the Santa Ana Mountains are provided in View 4. As shown in View 3, ornamental trees line the Cottonwood Avenue corridor, and partial views of the Bernasconi Hills and San Jacinto Mountains are provided in the background looking southeast. There are streetlights installed on the north side of Cottonwood Avenue.
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View 2 - From the Northwest Corner of the Project Site along Cottonwood Avenue looking Southeast.

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4.1 Aesthetics
Figure 4. l -l
Site Photos - Views 1 & 2
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View 3 - From the Northwest Corner of the Project Site
along Cottonwood Avenue looking East.

View 4 - From the Northeast Corner of the Project Site along Cottonwood Avenue looking Southwest.

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4.1 Aesthetics
Figure 4.1-2
Site Photos - Views 3 & 4
Town Center at Moreno Valley Specific Plan
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• Views 5 through 9 – Views from the East. Views 5 through 9, shown in Figure 4.1-3 and Figure 4.1-4, represent existing views from vantage points generally east of the Project site looking towards the west. Views from these vantage points are representative of views that would be experienced from pedestrians, bicyclists, and passenger vehicles traveling along Nason Street and Alessandro Boulevard. Views 5 and 6 (refer to Figure 4.1-3) depict the relatively flat Project site in the foreground, with existing residences, partial views of the Box Spring Mountains , and distant partial views of the San Gabriel Mountains and Santa Ana Mountains visible in the background. As shown on View 7 (refer to Figure 4.1-4), there is chain-link fencing at the southeast corner of the site, along with ornamental trees, and the soil stockpile. Streetlights and ornamental trees are located along both sides of Nason Street; partial views of natural landforms are visible in the background. Views 8 and 9 (refer to Figure 4.1- 4) depict the views looking north along Nason Street and west along Alessandro Boulevard , the current streetscapes, existing land uses, and current site conditions along the eastern and southern portions of the Project site. Distant mountain views are available from these vantage points.
• Views 10 through 13 – Views from the South. Views 10 through 13, shown in Figure 4.1-5 and Figure 4.1-6, represent existing views from vantage points generally south of the Project site looking north. Views from these vantage points are representative of views that would be experienced by pedestrians, bicyclists, and passenger vehicles traveling along Alessandro Boulevard. As illustrated in the photographs , the southern portion of the Project site is relatively flat with limited vegetation, and existing development surrounding the site is visible.

There are distant mountain views in the background from the respective vantage points.

C. Light and Glare
Currently, the Project site is undeveloped and does not include any uses that generate light or glare.

Lighting sources occur in the immediate vicinity of the Project site, with the most notable sources of light emanating from streetlights along Cottonwood Avenue and Nason Street, automobile headlights from vehicles traveling along adjacent roads, and from the existing developed areas surrounding the Project site.
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View 5 - Northeast of the Project Site along Nason Street looking Southwest.

View 6 - East of the Project Site at the Intersection of Bay Avenue and Nason Street looking East.

4.1 Aesthetics
Figure 4. l -3
Site Photos - Views 5 & 6
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View 7 - From the Southeast Corner of the Project Site at the intersection of Nason Street and Alessandro Blvd looking North.

View 9 - From the Southeast Corner of the Project Site at the intersection of Nason Street and Alessandro Blvd looking West.

City of Moreno Valley
View 8 - From the Southeast Corner of the Project Site at the intersection of Nason Street and Alessandro Blvd looking Northwest.

4.1 Aesthetics
Key Map
Figure 4.1 -4
Site Photos - Views 7 - 9

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View l O - South of the Project Site alongAlessandro Blvd looking North.

View l l - From the Southwest Corner of the Project Site along Alessandra Blvd looking East.

4.1 Aesthetics
Figure 4. l -5
Site Photos - Views 1 0 & 1 1
City of Moreno Valley

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View l 2 - From the Southwest Corner of the Project Site along Alessandro Blvd looking North.

View 13 - From the Southwest Corner of the Project Site along Alessandro Blvd looking Northeast.

4.1 Aesthetics
Figure 4. l -6
Site Photos - Views 12 & 1 3
City of Moreno Valley

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Town Center at Moreno Valley Specific Plan
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City of Moreno Valley

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4.1.2 REGULATORY SETTING
A. Local Plans, Policies, and Regulations

1. City of Moreno Valley General Plan
The General Plan guides future development within the City. The City’s current 2006 General Plan Community Development Element and Conservation Element and City-proposed 2040 General Plan Land Use and Community Character Element and Open Space and Resource Element identify attributes that contribute form, character, and quality of life in the communities and neighborhoods where people live and provide goals, policies , and programs that are intended to preserve the City’s character and scenic resources while improving overall community design. The Project’s consistency with applicable policies from the City’s 2006 General Plan is addressed in Table 4.1-1, General Plan Consistency Analysis.

2. Moreno Valley Municipal Code
Specific plans supersede the City’s zoning and development standards/regulations. Moreno Valley Municipal Code (MVMC) Chapter 9.13, Specific Plans, outlines the City’s regulations relevant to the preparation and use of specific plans . As identified in MVMC Section 9.13.010, specific plans are a tool for the systematic implementation of the General Plan. MVMC Section 9.13.050 outlines specific plan requirements, which include identification of standards and criteria by which development will proceed and standards for the conservation, development , and utilization of natural resources, where applicable. MVMC Section 9.13.060 specifically outlines minimum design standards to be included in specific plans and identifies that “[a]ll specific plans shall provide for development which exceeds the minimum standards and quality, as determined by the city council over the whole of the project, of development commensurate with what would be permitted under the existing district classification that most closely resembles the type and density of development proposed.” Minimum design standards are related: lot development; protection of natural features; building placement; access and circulation; parking; landscape design; fences and walls; lighting; screening for utilities and equipment ; grading; design theme; architecture; mass and scale of buildings; colors, textures, and materials; and, signage.

MVMC Section 9.08 establishes regulations and standards for outdoor lighting which will reduce light pollution and trespass generated by residential and non-residential lighting fixtures and devices, while maintaining dark skies. It is also the intent of this section to encourage, through the regulation of the types, construction, installation and uses of outdoor illuminating devices, lighting practices and systems to conserve energy without decreasing safety, security and productivity.

MVMC Section 9.10.110 regulates light and glare within the City. Pursuant to this section, no operation, activity, sign or lighting fixture shall create illumination which exceeds 0.5 footcandles minimum maintained on any adjacent property, whether the illumination is direct or indirect light from the source. All lighting is required to be designed to project downward and not create glare on adjacent properties.

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4.1.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates aesthetic impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact related to aesthetics would occur if the Project would:
a) Have a substantial adverse effect on a scenic vista. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

4.1.4 IMPACT ANALYSIS
Threshold a: Would the Project have a substantial adverse effect on a scenic vista? If the Project would block or otherwise substantially and adversely affect a unique view of a scenic vista(s) as seen from a public viewing location(s), such as a public road, park, trail, and/or other publicly owned property at which the general public is legally authorized to use or congregate, the impact would be regarded as significant. Effects to scenic vistas from private properties would not be considered significant because the City does not have any ordinances or policies in place that protect views from privately-owned properties. T he Project site is on the valley floor of the City and is not part of a scenic resource.

As previously discussed, the City identifies various local and distant mountains and other natural features as scenic resources: Box Spring Mountains (approximately 5.3 miles northwest of the Project site), Bernasconi Hills (approximately 2.0 miles south of the Project site) , San Jacinto Valley (approximately 10 miles southeast of the Project site), Moreno Peak (approximately 0.5-mile northeast of the Project site), the Badlands (approximately 6.0 miles northeast of the Project site), Mystic Lake (approximately 6.0 miles to the southeast of the Project site), San Bernardino Mountains (approximately 21 miles northeast of the Project site), San Jacinto Mountains (approximately 30 miles southeast of the Project site), and San Gabriel Mountains (approximately 25 miles northwest of the Project site). The public roadways surrounding the Project site are not identified as being within a view corridor, including the view corridor for Moreno Peak, which is approximately 0.5-mile northeast of the Project site. Additionally, the Project site is not visible from identified view corridors; the nearest view corridors are approximately 0.5-mile southwest of the Project site (generally from Moreno Beach Road), and approximately 0.9-mile northeast of the Project site (generally from Eucalyptus Avenue).

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As shown in the site photographs, views of the Box Spring Mountains and Bernasconi Hills are available to motorists, cyclists and pedestrians as they look down site-adjacent roadways (e.g., Nason Street, Alessandro Boulevard, and Cottonwood Avenue ). The San Bernardino, San Jacinto, and San Gabriel mountains are visible on clear days; however, these landforms are not prominently visible on days with high levels of atmospheric haze, which is common throughout the year. Distant views are also partially obstructed by existing development and mature landscaping in the vicinity of the Project site.

Implementation of the Project would result in development of the Project site , which is currently undeveloped and void of natural lands and landforms, with residential, commercial/civic, and open space/recreational uses. The Project does not involve any development within or adjacent to any scenic resources that define a scenic vista. Although not identified as view corridors in the City’s current 2006 General Plan or proposed 2040 General Plan, the views available from existing roadways that extend north-south (Nason Street), and east-west (Alessandro Boulevard and Cottonwood Avenue) adjacent to the Project site would largely be retained. The proposed development would obstruct distant views currently available across the vacant site; however, the east-west extension of Bay Avenue through the site, and implementation of a new north-south roadway connecting Cottonwood Avenue and Alessandro Boulevard would provide additional access to mountain views for the public traveling through the site. Further, the proposed public open space/park areas would be located along the proposed east-west and north-south roadways , which would further expand the view sheds from the vantage points.

Therefore, implementation of the Project would not result in significant impacts to scenic resources and would not have a substantial adverse impact on scenic vistas . Impacts would be less than significant.

Threshold b: Wo
uld the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? There are no trees, rock outcroppings, or historic buildings located onsite. Moreover, the Project site is not within or in proximity to a State designated scenic highway. The closest eligible state scenic highway is SR-74, located approximately 11 miles south of the Project site, and the nearest officially designated segment of a state scenic highway is a portion of SR-74 located approximately 22 miles southeast of the Project site (Caltrans 2022). Due to distance and intervening topography, the Project site would not be visible from SR-74. Accordingly, the Project would not damage scenic resources within a State scenic highway. No impact would occur.

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Threshold c: In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
The United States Census Bureau defines “urbanized area” as a densely settled core of census tracts and/or census blocks that have 50,000 or more residents and meet minimum population density requirements while also being adjacent to territory containing non- residential urban land uses . The Project site is located in an urbanized area and is within the boundaries of the Census -defined Riverside-San Bernardino urban area (USCB 2012); therefore, for the analysis of Threshold “c,” the Project would result in a significant adverse impact if the Project design conflicts with applicable zoning and other applicable regulations governing scenic quality.

A. Construction-Related Activities
Heavy equipment would be used during Project construction and would be visible from vantage points adjacent to the Project site. Construction activities are a common occurrence in the developing Inland Empire region of southern California, including the City. Construction activities do not inherently or substantially degrade an area’s visual quality. Except for the short-term use of cranes during building construction and lifts during the architectural coating phase, the construction equipment used on the Project site is expected to be low in height and not particularly visible to the surrounding area. Project- related construction activities would be temporary in nature and all construction equipment would be removed from the Project site following completion of Project -related construction activities .

Furthermore, there are no City zoning requirements or other regulations governing scenic quality that specifically address construction activities. Therefore, this impact would be less than significant.

B. Post-Development Impacts

1. City of Moreno Valley General Plan
As discussed in EIR Section 3.0, Project Description, the Project involves the proposed Town Center at Moreno Valley (TCMV) Specific Plan to establish the zoning, development, and design standards for implementing projects within the Project site. Implementation of the proposed TCMV Specific Plan would involve development of residential, open space/recreational, and commercial/civic land uses on the currently undeveloped Project site. Therefore, the visual character of the Project site would change with implementation of the Project. Pursuant to Threshold “c,” below is an analysis of the Project’s consistency with General Plan policies addressing scenic quality. Table 4.1-1, Current 2006 General Plan Consistency Analysis , addresses the Project’s consisten cy with the current 2006 General Plan policies and Table 4.1 -2, City Proposed 2040 General Plan Consistency Analysis , addresses the Project’s consistency with the City’s proposed General Plan 2040, which the City is in the process of readopting. As identified, the Project would not conflict with policies governing scenic quality, resulting in a less than significant impact.
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Table 4.1-1 Current 2006 General Plan Consistency Analysis General Plan Objective/Policy Consistency Analysis
Community Development Element
Objective 2.3: Promote a sense of community and pride within residential areas through increased neighborhood interaction and enhanced project design.

Policy 2.3.1: Within individual residential
projects, a variety of floor plans and elevations
should be offered.

Consistent. The Project would be a walkable community,
with interconnected plazas, urban niches, landscaped open spaces, and walkable corridors to enhance the quality of life and visual appeal of the proposed TCMV development.

Pursuant to the proposed TCMV Specific Plan, new
development would be organized around an interconnected grid of streets with appropriate block sizes that provide convenient, safe bicycle and pedestrian linkages within the area. The proposed TCMV Specific Plan includes flexible development standards to encourage a range of housing types, which enable options in floor plans and elevations. The development standards include required setbacks from
adjacent roadways and buildings, and parking requirements.

Further, the proposed TCMV Specific Plan Design
Guidelines encourage high quality architectural design that embodies visual interest through articulation, elevation styles, color, and materials. The Design Guidelines also address lighting, streetscape design and landscape
requirements. The proposed TCMV Specific Plan requires a combination of public and private open space for each
residential unit (a minimum of 100 sf per unit). Additionally, approximately 4.9 acres of public open space would be
provided with the central public park and linear park.

Policy 2.3.2: Encourage building placement
variations, roofline variations, architectural
projections, and other embellishments to enhance
the visual interest along residential streets.

Policy 2.3.3: Discourage the development of
single-family residences with a bulk (building
mass) that is out of scale with the size of the
parcels on which they are located.

Policy 2.3.5: Ensure that all multiple family
housing is well-designed, attractive and livable
by:
a. Ensuring all structures are architecturally
compatible and include decorative
architectural features and articulation in walls
and roofs;
b. Providing adequate parking, walkways,
lighting, landscaping, amenities and open
space areas;
c. Providing private open space areas such as
patios and balconies.

Objective 2.8: The 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 in residential building types, land use mixes, site design, and development concepts.

Policy 2.8.2: To the extent that development
policies, land use standards, design guidelines,
and other provisions of the adopted specific plans
are, by their content, intended to address issues
contained in the objectives, policies, and
implementation programs of the Moreno Valley
General Plan, and are inconsistent with the
provisions of the General Plan, then the
provisions of those specific plans shall be
controlling; otherwise, all other provisions of the
Moreno Valley General Plan shall remain in
effect.

Consistent. The proposed TCMV Specific Plan includes
development standards and design guidelines. The proposed Specific Plan identifies that where discrepancies occur between the proposed Specific Plan and the City’s
Development Code, the Development Standards contained in the Specific Plan shall prevail. Additionally, it identifies that the MVMC shall supplant any standard or regulation not
explicitly covered by the Specific Plan.

Objective 2.10: Ensure that all development within the City of Moreno Valley is of high quality, yields a pleasant living and working environment for existing and future residents, and attracts business as the result of consistent exemplary design.
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General Plan Objective/Policy Consistency Analysis
Policy 2.10.1: Encourage a design theme for each
new development that is compatible with
surrounding existing and planned developments.

Consistent. The proposed TCMV Specific Plan Design
Guidelines encourage high quality development that focuses eyes on the street, promotes lively streetscape, and enables a mix of uses. Further, a specific plan is proposed to guide development of the Project site to, among other purposes, address compatibility with surrounding development, which primarily includes residential, school and religious uses. The proposed TCMV Specific Plan provides appropriate setbacks and buffering for smooth transitions and better compatibility.

Policy 2.10.2: Screen trash storage and loading
areas, ground and roof mounted mechanical
equipment, and outdoor storage areas from public
view as appropriate.

Consistent. The proposed TCMV Specific Plan requires the screening of mechanical equipment from public review
through the use of landscaping and/or low walls and parapets.

Trash storage areas for residential uses are required to be enclosed, consistent with the City’s Zoning Code
requirements. Additionally, service loading areas and refuse enclosures for commercial uses and required to be screened by a solid wall with materials of appropriate color and texture compatible to the adjoining building.

Policy 2.10.3: Require exterior elevations of
buildings to have architectural treatments that
enhance their appearance.
a. A design theme, with compatible materials and
styles should be evident within a development
project;
b. Secondary accent materials, colors and lighting
should be used to highlight building features;
c. Variations in roofline and setbacks (projections
and recesses) should be used to break up the
building mass;
d Industrial buildings shall include architectural
treatments on visible facades that are
aesthetically pleasing.

Consistent. The proposed TCMV Specific Plan Design
Guidelines encourage high quality architectural design for residential and commercial uses that embodies visual interest through articulation, elevation styles, color, and materials.

The proposed TCMV Specific Plan does not allow industrial buildings.

Policy 2.10.4: Landscaping and open spaces
should be provided as an integral part of project
design to enhance building design, public views,
and interior spaces; provide buffers and
transitions as needed; and facilitate energy and
resource conservation.

Consistent. In addition to the proposed public open
space/park areas, which would be surrounded by commercial and residential uses, the proposed TCMV Specific Plan
requires landscaping that is integrated with the architecture.

The proposed landscape would soften the built environment, enhance gathering spaces and plazas and provide shade
opportunities.

Policy 2.10.6: Buildings should be designed with
a plan for adequate signage. Signs should be
highly compatible with the building and site
design relative to size, color, material, and
placement.

Consistent. The proposed TCMV Specific Plan Design
Guidelines outline the allowed signage and building
architecture, including for commercial uses. Signage installed within the Specific Plan area would comply with the Design Guidelines, and/or City regulations related to signage, and would be integrated into the architectural design and
character of buildings.

Policy 2.10.7: On-site lighting should not cause
nuisance levels of light or glare on adjacent
properties.

Consistent. To reduce light pollution, and in adherence to MVMC Section 9.08.100, exterior lighting would be
unobtrusive, reduce off-site glare, and light only the intended area. Additionally, pursuant to MVMC Section 9.10.110
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General Plan Objective/Policy Consistency Analysis
illumination from the Project would not exceed 0.5
footcandles on any adjacent property, whether the
illumination is direct or indirect light from the source, and lighting would be designed to project downward and not
create glare on adjacent properties.

Policy 2.10.8: Lighting should improve the visual
identification of structures. Within commercial
areas, lighting should also help create a festive
atmosphere by outlining buildings and
encouraging nighttime use of areas by
pedestrians.

Consistent. The proposed TCMV Specific Plan Design
Guidelines address exterior lighting and indicate that exterior lighting would be part of the architectural and landscape design concept. The Commercial Design Guidelines include the use of accent or festive lighting to enhance nighttime ambiance.

Policy 2.10.9: Fences and walls should
incorporate landscape elements and changes in
materials or texture to deter graffiti and add visual
interest.

Consistent. The proposed TCMV Specific Plan includes
Design Guidelines for walls and fences and includes
requirements for landscape treatments and varying materials and textures and anti-graffiti elements to prevent vandalism.

Policy 2.10.10: Minimize the use and visibility of
reverse frontage walls along streets and freeways
by such treatments as landscaping, berming, and
"side-on" cul-de-sacs.

Consistent. The proposed TCMV Specific Plan area is
located in an area of the City where the concept is to have higher density homes in close proximity to parks and
commercial uses. In some conditions, community walls may be used to provide privacy for residents, however, landscape such as shrubs and trees are envisioned to be planted along the public rights-of-way sides of the walls to soften the appearance. The proposed commercial and park uses would not include reverse frontage walls.

Policy 2.10.11: Screen and buffer nonresidential
projects from adjacent residential property and
other sensitive land uses when necessary to
mitigate noise, glare and other adverse effects on
adjacent uses.

Consistent. The proposed TCMV Specific Plan land use plan is designed so that there are no commercial uses adjacent to residential uses. The proposed commercial area is bound by roadways and the public park areas. The proposed TCMV
Specific Plan Design Guidelines require that commercial areas be visually attractive and cohesive with the surrounding uses.

Policy 2.10.12: Screen parking areas from streets
to the extent consistent with surveillance needs
(e.g. mounding, landscaping, low profile walls,
and/or grade separations).

Consistent. The proposed TCMV Specific Plan area is
bound by Nason Street to the east and Alessandro Boulevard to the south. Residential parking would typically occur in private garages, on-street, or in small clusters within the residential planning area. Where commercial uses are
proposed, parking areas would be located at the interior of the parcel area encouraging street frontage for buildings.

Where parking lots are visible from the public right-of-way, landscape elements such as trees, shrubs and low walls, would create a buffer between the street and the parking field with the intention of softening the streetscape and
maintaining visibility for pedestrian safety.

Policy 2.10.13: Provide landscaping in
automobile parking areas to reduce solar heat and
glare.

Consistent. The proposed TCMV Specific Plan Commercial
Design Guidelines require that shade trees be installed in parking areas to reduce solar heat and glare.

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Table 4.1-2 City Proposed 2040 General Plan Consistency Analysis Proposed 2040 General Plan Goal/Policy Consistency Analysis Land Use and Community Character Element
Goal LCC-1: Establish an identifiable city structure and a flexible land use framework that accommodates growth and development over the planning horizon.

Policy LCC.1-5: Encourage mixed-use
development in either a vertical or horizontal
configuration in the Downtown Center, the
Moreno Valley Mall/ Towngate Center area, and
at key intersections along major transit routes.

Consistent. The Project site is located within the City’s proposed Downtown Center and is proposed to include a mix of residential, commercial, civic and park uses.

Goal LCC-2: Foster vibrant gathering places for Moreno Valley residents and visitors Policy LCC.2-1: Create a Downtown
Center with a vibrant mix of uses that will
serve as the primary hub and focal point of
Moreno Valley economic and cultural
engine in the region.

Consistent. The Project site is located at the northwest corner of Nason Street and Alessandro Boulevard within the City’s proposed Downtown Center. The proposed TCMV Specific Plan land use plan includes a mix of residential, commercial, civic, and park uses, which offer the ability for placemaking and a focal point of the City. Pursuant to the proposed TCMV
Specific Plan Design Guidelines, buildings would be oriented toward Nason Street and accessible to Alessandro Boulevard, creating a sense of arrival to the proposed Downtown Center area. The architecture would be visually pleasing and
welcoming, and streets and pedestrian pathways would be enhancing the aesthetic of the area and encouraging residents and visitors to spend time at the site.

Policy LCC.2-8: Transform Nason Street and
Alessandro Boulevard into grand boulevards with
a distinctive, inviting character that announces
arrival in Downtown Moreno Valley.

Policy LCC.2-10: Create an attractive, safe
environment for bicycles and pedestrians that
promotes “micro-mobility” and connectivity
within the Downtown Center as well as encourage
electric and autonomous vehicles.

Consistent. Pursuant to the proposed TCMV Design
Guidelines, the proposed streets would have a planting design that reinforces the community’s character. Where possible, curb-separated sidewalks and off-street paseos would be implemented to provide for a pleasant and safe pedestrian and bicycling environment. Class III bike routes would be implemented along proposed Street A and Bay Avenue. The circulation network would provide connectivity onsite and to the adjacent roadways.

Policy LCC.2-20: Encourage site designs that
create an active street frontage and screen parking
from the frontages of Alessandro,
Sunnymead and Perris.

Consistent. Alessandro Boulevard forms the southern
boundary of the Project site, and as shown on Figure 3-6, Conceptual Land Plan, residential uses are proposed along Alessandro Boulevard west of the new north-south public street, and commercial uses are proposed east of the new public street. As identified above, buildings would be
accessible to Alessandro Boulevard, creating a sense of arrival to the proposed Downtown Center area. Parking areas would be screened, as appropriate.

Policy LCC.2-22: Encourage new mixed-use and
commercial development to incorporate visual
quality and interest in architectural design on all
visible sides of buildings through the following
approaches:
• Utilizing varied massing and roof
types, floor plans, detailed planting
design, or color and materials;
Consistent. The proposed TCMV Design Guidelines
specify building and design practices that encourage
visual interest and quality architecture. The
development standards within the TCMV Specific Plan
promote flexibility and the ability to develop a mixed- use community with varying density ranges and product
types.
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Proposed 2040 General Plan Goal/Policy Consistency Analysis • Maintaining overall harmony while
providing smaller-scale variety; and
• Articulating building facades with distinctive
architectural features like awnings, windows,
doors, and other such elements.

Policy LCC.2-23: Ensure that commercial uses
are designed to incorporate ground floor
transparency and pedestrian activity.

Consistent. The proposed TCMV Specific Plan Commercial
Design Guidelines encourage windows and “eyes” on the
street. Furthermore, streetscape elements and building
frontages are intended to be designed for visual interest, pedestrian comfort, and safety.

Policy LCC.2-28: Encourage landscaped common
public spaces to be incorporated into new mixed-
use development
Consistent. The proposed TCMV Specific Plan Design
Guidelines promote landscape in public spaces. Landscape design would address the use it is accompanying as well as climate appropriateness.

Policy LCC.2-29: Design of public spaces
should ensure they are: Lined with active uses at
grade and located near building entrances,
windows, outdoor seating, patios, or balconies
that overlook park spaces, and other areas with
strong pedestrian activity.
• Be completely visible from at least one
street frontage and as feasible, be at least
50% visible from a secondary street
frontage.
• Primarily defined by adjacent buildings,
which will contribute to the unity and
environmental quality of the space.
• Be located at the same grade level as the
public sidewalk when possible. Where
changes in grade are an important element of
the overall design and programming, clear
and direct access from the public sidewalk
should be accommodated, and universal
accessibility provided.
• Reflect the design and placemaking
elements of the surrounding area through
the use of architectural styles, signage,
colors, textures, materials and other
elements.
• Be constructed with low impact and
permeable paving materials to efficiently
manage the stormwater and minimize the
area’s heat island effect.
• Connect to bike and pedestrian facilities
and be a part of an interconnected pathway
or parkway system where feasible.

Consistent. The proposed TCMV Specific Plan Design
Guidelines encourage strong connections to public spaces, visibility from and into public spaces, and appropriate design to encourage use. The Project site is relatively flat and public spaces would be located at the same grade level as adjacent pedestrian and bicycle facilities. Pedestrian and bicycle facilities would be provided within the Specific Plan area to facilitate connectivity, including Class III bike routes along Bay Avenue and Street A. Pedestrian and
bicycle activity is encouraged throughout the open spaces with connectivity to the surrounding uses. Architectural styling is encouraged to enhance visual interest and a
vibrant atmosphere. Further, the proposed storm water and water quality management system would include
implementation of low impact design features to
efficiently manage storm water and minimize the area’s
heat island effect.

Goal LCC-3: Build a distinctive sense of place and pride in Moreno Valley.

Policy LCC.3-1: Insist on high-quality
development that is sensitive to surrounding
context throughout the city and particularly in
Consistent. The proposed TCMV Specific Plan Design
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Proposed 2040 General Plan Goal/Policy Consistency Analysis centers and corridors. mix of uses. Further, a specific plan is proposed to guide development of the Project site to, among other purposes, address compatibility with surrounding development, which primarily includes residential, school and religious uses.

Structures over four stories in height would be located, designed, and oriented to ensure compatibility with existing residential land uses. This would also be accomplished with adherence to the proposed TCMV Specific Plan building
setbacks. The proposed TCMV Specific Plan provides
appropriate setbacks and buffering for smooth transitions and better compatibility.

Policy LCC.3-2: Use development standards to
ensure smooth transitions for areas that border
one another so that neighborhoods and districts
maintain their unique qualities while being
compatible with one another.

Policy LCC.3-4: Strengthen the sense of arrival
into Moreno Valley and the Downtown Center
with gateway design at the locations shown on
Map LCC-3. Gateway design elements shall
include streetscape design, signage, building
massing, and similarly themed design elements.

Consistent. The Project site is located at the proposed gateway at the intersection of Nason Street and Alessandro Boulevard. Pursuant to the proposed TCMV Specific Plan
Design Guidelines, the Project would include design elements that are representative of an activated mixed-use area in the overall design, and that include signage, landscaping, and architectural features. Monuments, entry features, and
signage are an important element of community design and are fundamental in creating a sense of place. Project icons, thematic pilasters, and specialty landscaping would be used to create strong entry statements.

Policy LCC.3-5: Incorporate prominent corner
architectural features, such as prominent entries or
corner towers, on new development at key
intersections or gateways.

Policy LCC.3-8: Encourage development and
display of public art to promote the history,
heritage, culture and contemporary identity of
Moreno Valley.

Consistent. Pursuant to the proposed TCMV Specific Plan, public art would be included as part of the development within the Specific Plan area.

Policy LCC.3-14: Within individual residential
projects, a variety of floor plans and elevations
should be offered.

Consistent. The proposed TCMV Specific Plan includes
flexible development standards to encourage a range of
housing types, which enable options in floor plans and
elevations.

Policy LCC.3-15: Encourage building placement
variations, roofline variations, architectural
projections, and other embellishments to enhance
the visual interest along residential streets.

Consistent. The proposed TCMV Specific Plan Design
Guidelines encourage high quality architectural design that embodies visual interest through articulation, elevation styles, color, and materials.

Policy LCC.3-16: Design large-scale small lot
single family and multiple family residential
projects to group dwellings around individual
open space and/or recreational features.

Consistent. As shown on EIR Figure 3-5, Conceptual Land Use Plan, the proposed TCMV Specific Plan includes a large central park and linear park with proposed residential uses adjacent to the north and west. Further, individual residential planning areas would incorporate landscaping elements,
which may include, among other amenities, small gathering areas.

Policy LCC.3-17: Screen and buffer
nonresidential projects to protect adjacent
residential property and other sensitive land uses
when necessary to mitigate noise, glare and other
adverse effects on adjacent uses.

Consistent. As shown on EIR Figure 3-5, Conceptual Land Use Plan, the proposed non-residential (commercial/civic) land use area would be located in the southeast portion of the Project site and would not be located adjacent to existing residential uses to the west. The proposed residential areas provide a buffer between existing residential and proposed non-residential uses. Additionally, screening and setbacks appropriate to the development conditions would be
implemented, as outlined in the proposed TCMV Specific
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Proposed 2040 General Plan Goal/Policy Consistency Analysis Plan Development Standards.

Policy LCC.3-20: Rely on strong landscape
treatments, setbacks, sign controls, and, where
feasible, underground utilities and street
improvements to prevent visual chaos where
businesses are competing for attention.

Consistent. The proposed TCMV Specific Plan, including
the Design Guidelines and Development Standards, address quality site design to encourage a successful development that is visually pleasing, safe, and vibrant. Appropriate setbacks would create separation where needed and utilities would be implemented in accordance with applicable
requirements established by the City and/or utility providers.

Dry utility infrastructure would be placed underground.

Landscape treatments pursuant to the proposed TCMV
Specific Plan would enhance the community, and
monuments, entry features and signage would be used to
assist with wayfinding. Notably, the proposed TCMV
Specific Plan identifies that commercial monuments may be placed at or near the entries and/or major street intersections.

These monuments may feature the names of stores, and
would be written clearly for easy identification, especially by drivers. Adherence to the proposed Design Guidelines and Development Standards would establish a consistent design concept that produces a cohesive (not chaotic) appearance and strong sense of place and would ensure that businesses are not competing for attention.

LCC.3-21: Ensure that neighborhood shopping
centers conform to regulations limiting the size,
location, and general character of signage and
facades so as not to disrupt the residential
character of the neighborhood.

Consistent. The proposed TCMV Specific Plan is proposed to guide development of the Project site to, among other purposes, address compatibility with surrounding
development, which primarily includes existing and proposed residential uses, schools and religious uses. The proposed TCMV Specific Plan Design Guidelines outline the allowed signage and building architecture, including for commercial uses. Signage installed within the Specific Plan area would comply with the proposed Design Guidelines, and/or City regulations related to signage, as applicable. The Design Guidelines require that monuments and signage be consistent with and reflect the overall character of the neighborhood.

2. Moreno Valley Municipal Code
Consistent with the provisions of the MVMC Section 9.07.010(B)(3), the Project involves the proposed TCMV Specific Plan to establish the zoning, development, and design standards for implementing projects within the Project site. As described in Section 3.0, Project Description, the proposed TCMV Specific Plan includes required Design Guidelines and Development Standards to guide development of the Project site in a manner consistent with the General Plan and MVMC.

The proposed TCMV Specific Plan D evelopment Standards, which apply to residential, retail, commercial, and civic uses are outlined in EIR Table 3-1. In some instances, existing general City standards are modified by the proposed TCMV Specific Plan to facilitate use of innovative development.

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Chapter 5 of the proposed TCMV Specific Plan includes Design Guidelines, which are summarized in EIR Section 3.4.3 and serve as the design basis for future development within the Specific Plan area.

The community character would be captured through carefully integrating architecture and landscape.

The Design Guidelines are intended to help ensure a high level of design quality while providing the flexibility necessary to encourage creativity. The Design Guidelines are also meant to promote development which is pedestrian-oriented, interconnected, and encourages sustainable neighborhood design principles. Key elements outlined in the Design Guidelines include streetscape design; monuments, entry features, and signage; walls and fences; lighting and mechanical equipment; and design of residential and non-residential uses.

As described in EIR Section 3.7, Summary of Requested Actions , Plot Plans would be processed for future development implementing the proposed TCMV Specific Plan. The City would review the proposed site plans, building design/architecture, landscape plans, etc. for consistency with the proposed TCMV Specific Plan Development Standards and Design Guidelines. With adherence to the proposed TCMV Specific Plan Development Standards and Design Guidelines, future development would not conflict with applicable zoning and other regulations governing scenic quality, resulting in a less than significant impact.

Threshold d: Wo
uld the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
A. Light
If the Project would directly expose the Project area with bright lights or create unwanted light in the night sky including light trespass sky glow, or over-lighting, the Project would adversely affect day or nighttime views in the area.

1. Construction-Related Lighting
As further discussed in EIR Section 3.5, Project Construction Characteristics, construction activities would comply with applicable provisions in MVMC Section 8.14.040(e), which limits construction activity to 7:00 a.m. to 7:00 p.m. on Mondays through Fridays, and 8:00 a.m. to 4:00 p.m. on Saturdays, unless otherwise approved by the City. While the hours of construction may be limited, nighttime lighting would likely be used within the construction areas to provide security for construction equipment and construction materials. This type of temporary security lighting is often unshielded and may shine onto adjacent properties and roadways. Even though construction staging areas would be located as far as possible from adjacent residential uses, such security lighting may cause a significant impact in the form of a nuisance to the res idents, resulting in a potentially significant impact prior to mitigation. MM 4.1-1 requires that construction staging areas be located as far as possible from the residential development adjacent to the Project site to minimize light intrusion and also re quires that any temporary nighttime lighting that is installed be downward facing and hooded or shielded to prevent security lighting from spilling outside the staging area or from directly broadcasting security lighting into the sky or onto adjacent residential properties. With implementation of MM 4.1-1, potential lighting impacts during construction would be reduced to a less than significant level. ■■
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2. Operational Lighting
Although implementation of uses allowed by the proposed TCMV Specific Plan would introduce new development to the Project site, the site is located in an area that is already subject to nighttime lighting, primarily associated with surrounding residential and non-residential uses, and streetlights along Nason Street and Alessandro Boulevard. Additionally, “sky glow,” which is the illumination of the night sky from urban uses, already occurs.

With implementation of the proposed residential, commercial/civic, and park uses at the Project site, lighting would be utilized within the public realm (commercial center and public open space areas) and in residential areas for security and aesthetics. To reduce light pollution, and in adherence to MVMC Section 9.08.100, exterior lighting would be unobtrusive, reduce off-site glare, and light only the intended area. Additionally, pursuant to MVMC Section 9.10.110, illumination from the Project would not exceed 0.5 footcandles on any adjacent property, whether the illumination is direct or indirect light from the source, and lighting would be designed to project downward and not create glare on adjacent properties. As part of the development review process, a comprehensive lighting plan would be prepared. Adherence to the lighting design requirements outlined in the lighting plan and proposed TCMV Specific Plan would ensure that the proposed lighting would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Therefore, this impact would be less than significant.

B. Glare
Glare is caused by light reflections from pavement, vehicles, and building materials such as reflective glass and polished surfaces. During daylight hours, the amount of glare depends on intensity and direction of sunlight. Exterior building materials that are expected be used at ground level to form the building base would include, but not be limited to: stucco, hardboard type siding, aluminum storefronts with vision glass, metal/faux metal panels/sidings (painted and/or faux metallic look finishes), cultured stone veneer, brick type veneer, precast concrete/CMU veneer/caps, backlit translucent glass elements, factory finished (painted) metal canopies, expressed painted steel columns/elements, painted/perforated and/or cut metal panels, tile/paint accents, tenant signage including exposed “neon,” internally lit signs, and face-lit signs. These low- and non-reflective building materials would not result in substantial glare impacts within the Project site or surrounding areas, and notably at the street level . A dherence to the D evelopment Standards and Design G uidelines (architectural and landscape) outlined in the proposed TCMV Specific Plan, which require finishes that reduce reflection and glare, would ensure that these materials would not result in substantial light or glare that adversely affects day or nighttime views in the area. Therefore, this impact would be less than significant.

4.1.5 CUMULATIVE IMPACT ANALYSIS
The study area for cumulative aesthetic impacts for the Project includes areas in the same viewshed as the Project. If the projects are not visible from the same vantage point, the viewer would not perceive them at the same time and they would not result in a cumulative chan ge in the visual character or quality. As shown on Figure 4.0-1, Cumulative Development Location Map, there are cumulative ■■
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projects in the vicinity of the Project, including projects along Alessandro Boulevard and Nason Street that would be in the same viewshed as the Project. Specifically, a residential development is proposed adjacent to and northeast of the Project (south of Cottonwood Avenue and west of Nason Street ; MV 6), and a residential and office (live/work units) development is planned adjacent to the southern portion of the Project site (north of Alessandro Boulevard; MV2).

The Project site is not within a designated view corridor, and the Project does not involve any development within or adjacent to any scenic resources that define a scenic vista. The public views available from Nason Street, Alessandro Boulevard, and Cottonwood Avenue adjacent to the Project site would largely be retained, and the Project’s potential impacts to scenic views of the Box Springs Mountains, San Gabriel Mountains , San Bernardino Mountains , Bernasconi Hills, and Moreno Peak would be less than significant. Planned development adjacent to the Project site would be in the same viewshed as the Project from vantage points along Nason Street and Alessandro Boulevard; however, as with the Project site, these sites are not within a view corridor and development of these sites would not have a substantial adverse impact on a scenic vista. Therefore, the Project would not contribute to cumulatively significant aesthetic impacts related to scenic vistas.

The Project site and nearby cumulative project sites within the same viewshed are not within a State scenic highway corridor and do not contain any scenic resources . Therefore, the Project would not contribute to cumulatively significant impacts on scenic resources within a designated State scenic highway.

The Project and cumulative projects in the same viewshed are within an area planned to be developed with a mix of business, residential, public, and civic uses. The Project would be required to adhere to the proposed Development Standards and Design Guidelines established in the TCMV Specific Plan, which address architecture, landscaping, walls/fences, and other elements of the physical environment.

Additionally, the cumulative projects would be required to adhere to established development standards addressing scenic quality as outlined in the General Plan and MVMC, resulting in a less than significant impact. Therefore, the Project would not result in a cumulatively considerable contribution to a significant aesthetic impact related to scenic quality.

Implementing projects would adhere to proposed TCMV Specific Plan Development Standards and Design Guidelines related to exterior lighting and reflective building materials and would incorporate MM 4.1-1 (to minimize light impacts during construction) and would result in less than significant light and glare impacts. Cumulative development projects with the potential to generate light and glare would be required to comply with regulations established to reduce light and glare impacts from new development, including MVMC Section 9.08.100 and Section 9.10.110, and would also result in less than significant light and glare impacts. Therefore, the Project would not result in a cumulatively considerable contribution to a significant aesthetic impact related to light and glare.

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4.1.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact . The Project site is not within a City -designated view corridor, and the Project does not involve any development within or adjacent to any scenic resources that define a scenic vista. The public views available from Nason Street, Alessandro Boulevard, and Cottonwood Avenue adjacent to the Project site would largely be retained, and the Project’s potential impacts to scenic views of distant mountains and Moreno Peak would be less than significant.

Threshold b: N
o Impact . The Project site is not within the viewshed of a State scenic highway; therefore, the Project would not degrade scenic resources within a State scenic highway. No impact would occur.

Threshold c: L ess than Significant Impact. Future development implementing the proposed TCMV Specific Plan would adhere to the established Development Standards and Design Guidelines included in the TCMV Specific Plan and would not conflict with goals or policies outlined in the General Plan or MVMC requirements that regulate scenic quality. This impact would be less than significant.

Threshold d: P otentially Significant Impact (Construction)/Less than Significant Impact (Operation).

Construction-related lighting has the potential to create substantial light, which could adversely affect adjacent residential uses, resulting in a potentially significant temporary impact.

F
uture development implementing the proposed TCMV Specific Plan would adhere to established Development Standards and Design Guidelines related to lighting and non-reflective building materials and would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. Impacts would be less than significant.

4.1.7 MITIGATION
MM 4.1-1 Prior to the issuance of grading permits, the Property Owner/Developer shall provide evidence to the City that the contractor s pecifications require that the construction staging area be located as far as possible from the existing residential development surrounding the Project site to minimize light intrusion. Temporary nighttime lighting installed during construction for security or any other purpose shall be downward- facing and hooded or shielded to prevent light from spilling outside the staging area and from directly broadcasting security light into the sky or onto adjacent residential properties. Compliance with this measure shall be verified by the City during inspections of the construction site.

4.1.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold d: Less than Significant Impact with Mitigation. Implementation of MM 4.1-1 w ould ensure that construction-related nighttime lighting does not spill onto adjacent residential uses, and potential impacts would be reduced to a level considered less than significant.

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4.2 AGRICULTURE AND FORESTRY RESOURCES
This subsection describes the agricultural resources present on the Project site and in the site’s vicinity and evaluates the potential effects that the Project may have on these resources. References used in this subsection are listed in EIR Section 7.0, References.

4.2.1 EXISTING CONDITIONS
A. Farmland and Agricultural Resources
The City of Moreno Valley (City) has a long history of agricultural use dating back to the 19th century; however, a variety of economic factors ha ve caused farming to decrease substantially over recent decades. The City has transitioned from primarily agricultural to urban uses. Nevertheless, the California Department of Conservation (CDC) has identified approximately 157 acres of land within the City as “Prime Farmland,” meaning that these acres have among the best combination of characteristics for crop production. Additionally, the City has identified approximately 9,689 acres of land within the City as “Farmland of Local Importance ” (City of Moreno Valley 2021b). 1 These farmland classification s are further discussed in Subsection 4.2.2, Regulatory Setting. The Prime Farmland and Farmland of Local Importance are concentrated within the eastern portion of the City .

There are very limited areas of Unique Farmland (approximately 20.2 acres) and Farmland of Statewide Importance (approximately 8 acres) in the City, north of State Route (SR)-60. T he nearest Important Farmland to the Project site is designated Prime Farmland located approximately 2.1 miles northeast of the Project site (CDC 2020a).

Based on review of historic aerial photographs, agricultural activities occurred at the Project site from the 1930s to the late 1960s (Leighton 2025a). There are no existing agricultural activities at the Project site. Further, there is no agricultural irrigation source or infrastructure available to serve the Project site. According to the CDC’s 2020 Important Farmland Finder Map, the latest available mapping for the City, the Project site is identified as Farmland of Local Importance (refer to Figure 4.2-1, Farmland Classification) (CDC 2020a).

The Project site does not include any land under an active Williamson Act Contract (CDC 2025).

Additionally, the City’s General Plan land use and zoning designations do not include agricultural uses; the current 2006 General Plan land use designat ion and zoning for the Project site allows Public Facilities uses. The City’s proposed 2040 General Plan and Zoning Update allow for a mix of business, entertainment, residential, cultural, and civic uses pursuant to the Downtown Center (DC) District.

As described in EIR Section 2.0, Environmental Setting, existing single-family residences are adjacent to the Project site to the west, and roadways border the Project site to the north, east, and south. There are single-family residences north of Cottonwood Avenue; vacant land south of Alessandro Boulevard; and existing residential, school, and religious uses, and vacant/undeveloped land east of Nason Street.

1 The agricultural resources information provided in the proposed 2040 General Plan, which the City is in the process or readopting, remains applicable to the discussion of the existing environmental setting for agricultural resources in the City. The court decision did not address this topical issue. ■■
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As shown on Figure 4.2 -1, Farmland Classification, the areas surrounding the Project site are designated Farmland of Local Importance, Urban and Built-up Land, and Other Land.

B. Soils
The Project site consists of the following soil map units, which are classified as Class IIIe: Greenfield sandy loam (GyC2) (2 to 8% slopes, eroded); Hanford coarse sandy loam (HcC) (2 to 8% slopes); and Ramona sandy loam (RaB2) (2 to 5% slopes, eroded) (refer to Figure 7, Soils Map, of the Biological Report included in EIR Technical Appendix C) (VCS 2025). Class III soils have severe limitations that reduce the choice of plants or require special conservation practice, or both, and subclass “e” is made up of soils for which the susceptibility to erosion is the dominant problem or hazard affecting their use (USDA 2022).

C. Forest Land
The City does not contain forest land and there are no areas within the City, including the Project site, that are zoned forest land (City of Moreno Valley 2024).

4.2.2 REGULATORY SETTING
A. State Plans, Policies, and Regulations

1. California Land Conservation Act (CLCA)
The California Land Conservation Act (CLCA) of 1965, better known as the Williamson Act (California Administrative Code Section 51200 et seq.), creates an arrangement whereby private landowners contract with local governments to voluntarily restrict land to agricultural or related open space uses. In return, restricted parcels are assessed for property tax purposes at a rate consistent with their actual use rather than potential market value, which saves landowners from 20 to 75% in property tax liability e ach year. Local governments receive an annual subvention of forgone property tax revenues from the state via the Open Space Subvention Act of 1971 (California Government Code Section 16140-16154). Review of CDC, Division of Land Resource Protection, Conservation Program Support mapping data determined that there are no parcels protected by Williamson Act Contracts within the City. Four contiguous parcels totaling 144.75 acres located within the southeasternmost portion of the City’s sphere of influence are protected by a Williamson Act Contract (CDC 2025).

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■ D Environmental Impact Report 4.2 Agriculture and Forestry Resources Legend
I I Farmland of Local Importance (L)
~~
~I~ ______ ~~I Urban Built-Up Land (D)
l~~I Other Land (X)
[: : Project Boundary
GOTT0NW0OD AVE
ir- ··1 -· I
I
L __ _

BAY AVE
J\LESSANDR0 BLVD L--------.1
Source(s): ESRI, NearMap Imagery {February 2024), RCTLMA {2021), FMMP {2020} Figure 4.2- l • i ~ 0 250 500
tu~
1,000
Feet Farmland Classification
City of Moreno Valley

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2. Farmland Mapping and Monitoring Program (FMMP)
The goal of the CDC ’s Farmland Mapping and Monitoring Program (FMMP) (CDC 2020b) is to provide consistent, timely, and accurate data to decision makers for use in planning for the present and future of California's agricultural land resources. To meet this goal, FMMP’s objective is to provide maps and statistical data to the public, academia, and local, State, and federal governments to assist them in making informed decisions for the best utilization of California’s farmland. Government Code Section 65570 mandates the FMMP to biennially report to the Legislature on the conversion of farmland and grazing land, and to provide maps and data to local government and the public. The FMMP was also directed to prepare and maintain an automated map and database system to record and report changes in the use of agricultural lands. It was the intent of the Legislature and a broad coalition of building, business, government, and conservation interests that FMMP be non-regulatory and provide a consistent and impartial analysis of agricultural land use and change in California. The FMMP provides basic data from which observations and analyses can be made in the land use planning process.

Pursuant to the FMMP, all lands within California are classified into one of seven map categories. The minimum mapping unit is generally 10 acres , except as otherwise noted . Provided below is a description of the various map categories established by the FMMP:
• Prime Farmland (P): Farmland with the best combination of physical and chemical features able to sustain long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
• Farmland of Statewide Importance (S): Farmland similar to Prime Farmland but with minor shortcomings, such as greater slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
• Unique Farmland (U) : Farmland of lesser quality soils used to produce the state's leading agricultural crops. This land is usually irrigated but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Land must have been cropped at some time during the four years prior to the mapping date.
• Farmland of Local Importance (L): Land of importance to the local agricultural economy as determined by each county’s board of supervisors and a local advisory committee. • Grazing Land (G): Land on which the existing vegetation is suited to the grazing of livestock.

This category was developed in cooperation with the California Cattlemen's Association, University of California Cooperative Extension, and other groups interested in the extent of grazing activities. The minimum mapping unit for Grazing Land is 40 acres. • Urban and Built-Up Land (D): Land occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10-acre parcel . This land is used for ■■
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residential, industrial, commercial, institutional, public administrative purposes, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes. • Other Land (X): Land not included in any other mapping category. Common examples include low-density rural developments; brush, timber, wetland, and riparian areas not suitable for livestock grazing; confined livestock, poultry, or aquaculture facilities; strip mines, borrow pits; and water bodies smaller than 40 acres. Vacant and nonagricultural land surrounded by urban development and greater than 40 acres is mapped as Other Land.

4.2.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts to agriculture and forestry resources based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact to agricultural resources would occur if the Project would:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)).
d) Result in the loss of forest land or conversion of forest land to non-forest use. e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non- forest use.

4.2.4 IMPACT ANALYSIS
Threshold a: Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
CEQA Guidelines Appendix G (Threshold a ) defines three of the FMMP’s Important Farmland categories – “Prime Farmland,” “Unique Farmland,” and “Farmland of Statewide Importance” – as “Farmland” for purposes of CEQA analysis and acknowledge that their conversion to nonagricultural uses may be considered a significant impact. The Project site does not have any lands mapped by the CDC as Farmland (Prime Farmland, Unique Farmland, or Farmland of Statewide Importance). As previously identified, the CDC classifies the entire Project site as Farmland of Local Importance and there are no existing agricultural operations at the Project site . The Project site consist s of the Class ■■
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IIIe soils, which have limitation s relative to agricultural production. Further, there is no agricultural irrigation source or infrastructure available to serve the Project site. For these reasons, implementation of the Project would not convert Farmland, so no impact would occur.

Threshold b: Wo uld the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
The City does not have any exclusive agricultural zones; t he Project site is zoned Public (P) District .

Additionally, there are no lands on site under a Williamson Act Contract (CDC 2025). Thus, the Project would not conflict with zoning for agricultural uses or a Williamson Act Contract . No impact would occur.

Threshold c: Wo uld the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
The City does not have any exclusive forest land, timberland, or timberland production zones (City of Moreno Valley 2024). Thus, the Project would not conflict with zoning for forest land, timberland, or timberland production uses. No impact would occur.

Threshold d: Wo
uld the Project result in the loss of forest land or conversion of forest land to non- forest use?
The City does not possess any forest land (City of Moreno Valley 2024). Thus, the Project would not result in the loss of forest land or the conversion of forest land to non-forest use . No impact would occur.

Threshold e: Wo uld the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
As shown on Figure 4.2-1, Farmland Classification, there is no Farmland (i.e., Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) onsite or in the area surrounding the Project site. The areas surrounding the Project site are designated as Farmland of Local Importance, Urban and Built-up Land, and Other Land, and consist of developed areas and vacant land. There are no existing agricultural activities onsite or on the undeveloped parcels in the vicinity of the Project site.

Therefore, implementation of residential, commercial/civic, and park uses at the Project site, as anticipated by the proposed TCMV Specific Plan, would not result in the conversion of Farmland to non-agricultural uses. Additionally, the City does not contain forest land and implementation of the Project would not result in the conversion of forest land to non-forest use. No impact would occur.

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4.2.5 CUMULATIVE IMPACT ANALYSIS
This cumulative impact analysis for agricultural and forest land resources considers development of the Project site in conjunction with other development projects and planned development pursuant to the City’s General Plan. The Project would not directly convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) to non-agricultural use . As discussed previously, t he nearest Important Farmland is designated Prime Farmland located approximately 2.1 miles northeast of the Project site (CDC 2020a). Therefore, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact related to loss of Farmland or conversion of Farmland to non-agricultural use.

The City does not contain any areas with General Plan land use or zoning designations for agricultural uses. Therefore, the Project would not conflict with existing zoning for agricultural use nor contribute to a cumulative impact to agriculturally zoned properties . The Project site and adjacent sites are not under a Williamson Act Contract and, therefore, would not contribute to a cumulatively significant impact to Williamson Act lands.

There are no forest lands, timberlands, or Timberland Production zones within the Project site or in the City, nor are any lands in the City under active production as forest land. Therefore, cumulatively significant impacts to forest land would not occur and the Project would not contribute to a cumulatively significant impact related to the loss of these lands.

The Project does not involve any changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use; therefore, the Project would not contribute to a cumulative impact related to the conversion of land to non-agricultural or non-forest uses.

4.2.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: No Impact. The Project site does not contain Farmland (Prime Farmland, Unique Farmland, or Farmland of Statewide Importance ) and there are no agricultural activities onsite. The Project would not convert Farmland to non-agricultural uses and no impact would occur.

Threshold b: N o Impact. The City does not contain areas zoned for agricultural uses and t he Project site does not contain land under a Williamson Act Contract . The Project would not conflict with a Williamson Act Contract or agricultural zoning and no impact would occur.

Threshold c: N
o Impact. The City does not have a forest land zone; therefore, the Project would not conflict with any forest land zoning and no impact would occur.

Threshold d: N o Impact. There is no forest land within the City; therefore, the Project would not result in the loss of forest land or conversion of forest land to non-forest uses and no impact would occur.

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Threshold e: No Impact. The Project would not result in any other changes that would result in the conversion of farmland to non-agricultural uses or the conversion of forest land to non-forest use and no impact would occur.

4.2.7 MITIGATION
Impacts would be less than significant, and no mitigation is required.

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4.3 AIR QUALITY
This subsection is based on the Town Center at Moreno Valley Specific Plan Air Quality Impact Analysis (AQIA) prepared by Urban Crossroads, Inc. (Urban Crossroads 2025a) to evaluate the potential for Project-related construction and operational activities to result in adverse effects on local and regional air quality. This technical study is included as EIR Technical Appendix B. All references used in this subsection are listed in EIR Section 7.0, References.

4.3.1 EXISTING CONDITIONS
A. Atmospheric Setting
The Project site is in the South Coast Air Basin (SoCAB), which is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The SoCAB encompasses approximately 6,745 square miles and includes portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County. The SoCAB is bound by the Pacific Ocean to the west; the San Gabriel, San Bernardino, and the San Jacinto Mountains to the north and east, respectively; and the San Diego County line to the south.

B. Regional Climate and Methodology
The regional climate, temperature, wind, humidity, precipitation, and the amount of sunshine , has a substantial influence on air quality. The annual average temperatures throughout the SoCAB vary from the low- to mid-60s (in degrees Fahrenheit [°F]). Due to a decreased marine influence, the eastern portion of the S oCAB shows greater variability in average annual minimum and maximum temperatures. January is the coldest month throughout the S oCAB, with average minimum temperatures of 47°F in downtown Los Angeles and 36°F in San Bernardino. Although the climate of the SoCAB can be characterized as semi-arid, the air near the land surface is quite moist on most days because of the presence of a marine layer . Humidity restricts visibility in the S oCAB and the conversion of sulfur dioxide (SO
2) to sulfates (SO4) is heightened in the air with high relative humidity.

The marine layer provides an environment for that conversion process, especially during the spring and summer months. The annual average relative humidity within the SoCAB is 71% along the coast and 59% inland. Since the ocean effect is dominant, periods of heavy early morning fog are frequent and low stratus clouds are a characteristic feature. These effects decrease with distance from the coast.

More than 90 % of the SoCAB ’s rainfall occurs between November and April . The annual average rainfall within the SoCAB varies between approximately 9 inches in Riverside to 14 inches in downtown Los Angeles . Monthly and yearly rainfall totals are extremely variable . Summer rainfall usually consists of widely scattered thunderstorms near the coast and slightly heavier shower activity in the eastern portion of the SoCAB. Due to its generally clear weather, about three -quarters of available sunshine is received in the SoCAB; the remaining one -quarter is absorbed by clouds . The abundant amount of sunshine (and its associated ultraviolet radiation) is a key factor to the photochemical reactions of air pollutants in the SoCAB.

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The importance of wind to air pollution is considerable. The direction and speed of the wind determines the horizontal dispersion and transport of the air pollutants . During the late autumn to early spring rainy season, the SoCAB is subjected to wind flows associated with storms moving through the region from the northwest. This period also brings five to ten periods of strong, dry offshore winds, locally termed “Santa Anas,” each year. During the dry season, which coincides with the months of maximum photochemical smog concentrations, the wind flow is bimodal, typified by a daytime onshore sea breeze and a nighttime offshore drainage wind. Summer wind flows are created by the pressure differences between the relatively cold ocean and the unevenly heated and cooled land surfaces that modify the general northwesterly wind circulation over southern California . During the nighttime, heavy, cool air descends mountain slopes and flows through the mountain passes and canyons as it follows the lowering terrain toward the ocean . Wind patterns across the south coastal region are characterized by westerly and southwesterly onshore winds during the day and easterly or northeasterly breezes at night. Winds are characteristically light although the speed is somewhat greater during the dry summer months than during the rainy winter season.

In the SoCAB, there are two distinct temperature inversion structures that control the vertical mixing of air pollution. During the summer, warm high-pressure descending (subsiding) air is undercut by a shallow layer of cool marine air. The boundary between these two layers of air is a persistent marine subsidence/inversion. This boundary prevents vertical mixing which effectively acts as an impervious lid to pollutants over the entire SoCAB. The mixing height for the inversion structure is normally situated 1,000 to 1,500 feet above mean sea level. A second inversion-type forms in conjunction with the drainage of cool air off the surrounding mountains at night followed by the seaward drift of this pool of cool air. The top of this layer forms a sharp boundary with the warmer air aloft and creates nocturnal radiation inversions. These inversions occur primarily in the winter, when nights are longer and onshore flow is weakest. They are typically only a few hundred feet above mean sea level. These inversions effectively trap pollutants, such as nitrogen oxides and carbon monoxide, as the pool of cool air drifts seaward. Winter is therefore a period of high levels of primary pollutants along the coastline.

C. Air Quality Pollutants and Associated Human Health Effects Criteria pollutants are pollutants that are regulated through the development of human health based and/or environmentally based criteria for setting permissible levels. Criteria pollutants, their typical sources, and health effects are identified below in Table 4.3-1, Criteria Pollutants.

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Table 4.3-1 Criteria Pollutants
Criteria
Pollutant Description Sources Health Effects
Carbon
Monoxide
(CO)
CO is a colorless, odorless gas
produced by the incomplete
combustion of carbon-containing
fuels, such as gasoline or wood. CO
concentrations tend to be the highest
during the winter morning, when
little to no wind and surface-based
inversions trap the pollutant at
ground levels. Because CO is
emitted directly from internal
combustion engines, unlike ozone
(O
3), motor vehicles operating at
slow speeds are the primary source
of CO in the SoCAB. The highest
ambient CO concentrations are
generally found near congested
transportation corridors and
intersections.

Any source that burns
fuel such as
automobiles, trucks,
heavy construction
equipment, farming
equipment and
residential heating.

Individuals with a deficient blood
supply to the heart are the most
susceptible to the adverse effects of
CO exposure. The effects observed
include earlier onset of chest pain
with exercise, and
electrocardiograph changes
indicative of decreased oxygen
(O
2) supply to the heart. Inhaled
CO has no direct toxic effect on the
lungs but exerts its effect on tissues
by interfering with O2 transport and
competing with O2 to combine with
hemoglobin present in the blood to
form carboxyhemoglobin (COHb).

Hence, conditions with an
increased demand for O
2 supply
can be adversely affected by
exposure to CO. Individuals most
at risk include fetuses, patients with
diseases involving heart and blood
vessels, and patients with chronic
hypoxemia (O
2 deficiency) as seen
at high altitudes.

Sulfur
Dioxide
(SO2)
SO2 is a colorless, extremely
irritating gas or liquid. It enters the
atmosphere as a pollutant mainly as
a result of burning high sulfur-
content fuel oils and coal and from
chemical processes occurring at
chemical plants and refineries.

When SO
2 oxidizes in the
atmosphere, it forms SO4.

Collectively, these pollutants are
referred to as sulfur oxides (SOX).

Coal or oil burning
power plants and
industries, refineries,
diesel engines
A few minutes of exposure to low
levels of SO2 can result in airway
constriction in some asthmatics, all
of whom are sensitive to its effects.

In asthmatics, increase in resistance
to air flow, as well as reduction in
breathing capacity leading to
severe breathing difficulties, are
observed after acute exposure to
SO

2. In contrast, healthy
individuals do not exhibit similar
acute responses even after exposure
to higher concentrations of SO

2. Animal studies suggest that despite
SO
2 being a respiratory irritant, it
does not cause substantial lung
injury at ambient concentrations.

However, very high levels of
exposure can cause lung edema
(fluid accumulation), lung tissue
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Criteria
Pollutant Description Sources Health Effects
damage, and sloughing off of cells
lining the respiratory tract.

Some population-based studies
indicate that the mortality and
morbidity effects associated with
fine particles show a similar
association with ambient SO2
levels. In these studies, efforts to
separate the effects of SO2 from
those of fine particles have not
been successful. It is not clear
whether the two pollutants act
synergistically, or one pollutant
alone is the predominant factor.

Nitrogen
Oxides
(NO
X)
NOX consist of nitric oxide (NO),
nitrogen dioxide (NO2) and nitrous
oxide (N2O) and are formed when
nitrogen (N2) combines with O2.

Their lifespan in the atmosphere
ranges from one to seven days for
nitric oxide and nitrogen dioxide, to
170 years for nitrous oxide. NO
X is
typically created during combustion
processes and are major contributors
to smog formation and acid
deposition. NO2 is a criteria air
pollutant and may result in
numerous adverse health effects; it
absorbs blue light, resulting in a
brownish-red cast to the atmosphere
and reduced visibility. Of the seven
types of nitrogen oxide compounds,
NO
2 is the most abundant in the
atmosphere. As ambient
concentrations of NO
2 are related to
traffic density, commuters in heavy
traffic may be exposed to higher
concentrations of NO
2 than those
indicated by regional monitoring
station.

Any source that burns
fuel such as
automobiles, trucks,
heavy construction
equipment, farming
equipment and
residential heating.

Population-based studies suggest
that an increase in acute respiratory
illness, including infections and
respiratory symptoms in children
(not infants), is associated with
long-term exposure to NO
2 at
levels found in homes with gas
stoves, which are higher than
ambient levels found in Southern
California. Increase in resistance to
air flow and airway contraction is
observed after short-term exposure
to NO
2 in healthy subjects. Larger
decreases in lung functions are
observed in individuals with
asthma or chronic obstructive
pulmonary disease (e.g., chronic
bronchitis, emphysema) than in
healthy individuals, indicating a
greater susceptibility of these sub-
groups.

In animals, exposure to levels of
NO2 considerably higher than
ambient concentrations result in
increased susceptibility to
infections, possibly due to the
observed changes in cells involved
in maintaining immune functions.

The severity of lung tissue damage
associated with high levels of O3
exposure increases when animals
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Criteria
Pollutant Description Sources Health Effects
are exposed to a combination of O3
and NO2.

Ozone
(O3)
O3 is a highly reactive and unstable
gas that is formed when VOCs and
NOX, both byproducts of internal
combustion engine exhaust, undergo
slow photochemical reactions in the
presence of sunlight. O
3 concentrations are generally highest
during the summer months when
direct sunlight, light wind, and warm
temperature conditions are favorable
to the formation of this pollutant.

Formed when reactive
organic gases (ROG)
and NOX
react in the presence of
sunlight. ROG sources
include any source that
burns fuels, (e.g.,
gasoline, natural gas,
wood, oil) solvents,
petroleum processing
and storage and
pesticides.

Individuals exercising outdoors,
children, and people with
preexisting lung disease, such as
asthma and chronic pulmonary
lung disease, are considered to be
the most susceptible sub-groups for
O3 effects. Short-term exposure
(lasting for a few hours) to O3 at
levels typically observed in
Southern California can result in
breathing pattern changes,
reduction of breathing capacity,
increased susceptibility to
infections, inflammation of the
lung tissue, and some
immunological changes. Elevated
O
3 levels are associated with
increased school absences. In
recent years, a correlation between
elevated ambient O
3 levels and
increases in daily hospital
admission rates, as well as
mortality, has also been reported.

An increased risk for asthma has
been found in children who
participate in multiple outdoor
sports and live in communities with
high O
3 levels.

O3 exposure under exercising
conditions is known to increase the
severity of the responses described
above. Animal studies suggest that
exposure to a combination of
pollutants that includes O
3 may be
more toxic than exposure to O3
alone. Although lung volume and
resistance changes observed after a
single exposure diminish with
repeated exposures, biochemical
and cellular changes appear to
persist, which can lead to
subsequent lung structural changes.
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Criteria
Pollutant Description Sources Health Effects
Particulate
Matter (PM)
PM10: A major air pollutant
consisting of tiny solid or liquid
particles of soot, dust, smoke,
fumes, and aerosols. Particulate
matter pollution is a major cause of
reduce visibility (haze) which is
caused by the scattering of light and
consequently the significant
reduction air clarity. The size of the
particles (10 microns or smaller,
about 0.0004 inches or less) allows
them to easily enter the lungs where
they may be deposited, resulting in
adverse health effects. Additionally,
it should be noted that PM
10 is
considered a criteria air pollutant.

PM2.5: A similar air pollutant to
PM10 consisting of tiny solid or
liquid particles which are 2.5
microns or smaller (which is often
referred to as fine particles). These
particles are formed in the
atmosphere from primary gaseous
emissions that include SO
4 formed
from SO2 release from power plants
and industrial facilities and nitrates
that are formed from NO
X release
from power plants, automobiles, and
other types of combustion sources.

The chemical composition of fine
particles highly depends on location,
time of year, and weather
conditions. PM

2.5 is a criteria air
pollutant.

Sources of PM10
include road dust,
windblown dust and
construction. Also
formed from other
pollutants (acid rain,
NO
X, SOX, organics).

Incomplete
combustion of any
fuel.

PM2.5 comes from fuel
combustion in motor
vehicles, equipment,
and industrial sources,
residential and
agricultural
burning. Also formed
from reaction of other
pollutants (acid rain,
NO
X, SOX, organics).

A consistent correlation between
elevated ambient fine particulate
matter (PM
10 and PM2.5) levels and
an increase in mortality rates,
respiratory infections, number and
severity of asthma attacks and the
number of hospital admissions has
been observed in different parts of
the United States and various areas
around the world. In recent years,
some studies have reported an
association between long-term
exposure to air pollution dominated
by fine particles and increased
mortality, reduction in lifespan, and
an increased mortality from lung
cancer.

Daily fluctuations in PM2.5
concentration levels have also been
related to hospital admissions for
acute respiratory conditions in
children, to school and
kindergarten absences, to a
decrease in respiratory lung
volumes in normal children, and to
increased medication use in
children and adults with asthma.

Recent studies show lung function
growth in children is reduced with
long-term exposure to particulate
matter.

The elderly, people with pre-
existing respiratory or
cardiovascular disease, and
children appear to be more
susceptible to the effects of high
levels of PM10 and PM2.5.

Volatile
Organic
Compounds
(VOC)
VOCs are hydrocarbon compounds
(any compound containing various
combinations of hydrogen and
carbon atoms) that exist in the
ambient air. VOCs contribute to the
formation of smog through
atmospheric photochemical
reactions and/or may be toxic.

Compounds of carbon (also known
Organic chemicals are
widely used as
ingredients in
household products.

Paints, varnishes, and
wax all contain organic
solvents, as do many
cleaning, disinfecting,
cosmetic, degreasing
Breathing VOCs can irritate the
eyes, nose, and throat, can cause
difficulty breathing and nausea,
and can damage the central nervous
system as well as other organs.

Some VOCs can cause cancer. Not
all VOCs have all these health
effects, though many have several.
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Criteria
Pollutant Description Sources Health Effects
as organic compounds) have
different levels of reactivity; that is,
they do not react at the same speed
or do not form O3 to the same extent
when exposed to photochemical
processes. VOCs often have an odor,
and some examples include
gasoline, alcohol, and the solvents
used in paints. Exceptions to the
VOC designation include CO,
carbon dioxide, carbonic acid,
metallic carbides or carbonates, and
ammonium carbonate. VOCs are a
criteria pollutant since they are a
precursor to O
3, which is a criteria
pollutant. The terms VOC and ROG
(see below) interchangeably.
and hobby products.

Fuels are made up of
organic chemicals. All
of these products can
release organic
compounds while you
are using them, and, to
some degree, when
they are stored.

Reactive
Organic
Gases
(ROG)
Similar to VOC, ROGs are also
precursors in forming O3 and consist
of compounds containing methane,
ethane, propane, butane, and longer
chain hydrocarbons, which are
typically the result of some type of
combustion/decomposition process.

Smog is formed when ROG and
NO
X react in the presence of
sunlight. ROGs are a criteria
pollutant since they are a precursor
to O3, which is a criteria pollutant.

The terms ROG and VOC (see
previous) interchangeably.

Sources similar to
VOCs.

Health effects similar to VOCs.

Lead (Pb) Pb is a heavy metal that is highly
persistent in the environment and is
considered a criteria pollutant. In the
past, the primary source of Pb in the
air was emissions from vehicles
burning leaded gasoline. The major
sources of Pb emissions are ore and
metals processing, particularly Pb
smelters, and piston-engine aircraft
operating on leaded aviation
gasoline. Other stationary sources
include waste incinerators, utilities,
and lead-acid battery manufacturers.

It should be noted that the Project
does not include operational
Metal smelters,
resource recovery,
leaded gasoline,
deterioration of Pb
paint.

Fetuses, infants, and children are
more sensitive than others to the
adverse effects of Pb exposure.

Exposure to low levels of Pb can
adversely affect the development
and function of the central nervous
system, leading to learning
disorders, distractibility, inability
to follow simple commands, and
lower intelligence quotient. In
adults, increased Pb levels are
associated with increased blood
pressure.

Pb poisoning can cause anemia,
lethargy, seizures, and death;
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Criteria
Pollutant Description Sources Health Effects
activities such as metal processing
or Pb acid battery manufacturing. As
such, the Project is not anticipated to
generate a quantifiable amount of Pb
emissions.
although it appears that there are no
direct effects of Pb on the
respiratory system. Pb can be
stored in the bone from early age
environmental exposure, and
elevated blood Pb levels can occur
due to breakdown of bone tissue
during pregnancy, hyperthyroidism
(increased secretion of hormones
from the thyroid gland) and
osteoporosis (breakdown of bony
tissue). Fetuses and breast-fed
babies can be exposed to higher
levels of Pb because of previous
environmental Pb exposure of their
mothers.

Odor Odor means the perception
experienced by a person when one
or more chemical substances in the
air come into contact with the
human olfactory nerves.

Odors can come from
many sources
including animals,
human activities,
industry, nature, and
vehicles.

Offensive odors can potentially
affect human health in several
ways. First, odorant compounds
can irritate the eye, nose, and
throat, which can reduce
respiratory volume. Second, studies
have shown that the VOCs that
cause odors can stimulate sensory
nerves to cause neurochemical
changes that might influence
health, for instance, by
compromising the immune system.

Finally, unpleasant odors can
trigger memories or attitudes linked
to unpleasant odors, causing
cognitive and emotional effects
such as stress.

Source: (Urban Crossroads 2025a)

D. Existing Air Quality
Existing air quality is measured at established SCAQMD air quality monitoring stations. Monitored air quality is evaluated in the context of ambient air quality standards. These standards are the levels of air quality that are considered safe, with an adequate margin of safety, to protect the public health and welfare. National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) currently in effect are shown in Table 2-2, Ambient Air Quality Standards, of the AQIA provided in EIR Technical Appendix B.

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The determination of whether a region’s air quality is healthful or unhealthful is determined by comparing contaminant levels in ambient air samples to the S tate and federal standards. At the time the AQIA was prepared, the most recent S tate and federal standards were updated by the California Air Resources Board (CARB) on July 16, 2024, and are also presented in Table 2 -2, Ambient Air Quality Standards, of the AQIA provided in EIR Technical Appendix B. The air quality in a region is considered to be in attainment by the state if the measured ambient air pollutant levels for O3, CO, SO2 (1 and 24 hour), NO 2, PM10, and PM 2.5 are not to be exceeded. All others are not to be equaled or exceeded. It should be noted that the three -year period is presented for informational purposes and is not the basis for how the State assigns attainment status. Attainment status for a pollutant means that SCAQMD meets the standards set by the EPA or the California EPA (CalEPA). Conversely, nonattainment means that an area has monitored air quality that does not meet the NAAQS or CAAQS standards. In order to improve air quality in nonattainment areas, a State Implementation Plan (SIP) is drafted by CARB. The SIP outlines the measures that the state will take to improve air quality. Once nonattainment areas meet the standards and additional redesignation requirements, the EPA will designate the area as a maintenance area.

1. Regional Air Quality
Air pollution contributes to a wide variety of adverse health effects. The EPA has established NAAQS for six of the most common air pollutants: CO, Pb, O
3, particulate matter (PM10 and PM2.5), NO2, and
SO2 which are known as criteria pollutants. SCAQMD monitors levels of various criteria pollutants at 37 permanent monitoring stations and 5 single-pollutant source Pb air monitoring sites throughout the air district. On January 25, 2024, CARB posted the proposed 2023 amendments to the state and national area designations. See Table 4.3-2, Attainment Status of Criteria Pollutants in the SoCAB , for attainment designations for the S oCAB. Appendix 2.1 of EIR Technical Appendix B provides a geographic representation of the state and federal attainment status for applicable criteria pollutants within the SoCAB.

2. Local Air Quality
SCAQMD has designated general forecast areas and air monitoring areas (referred to as Source Receptor Areas [SRAs]) throughout the SoCAB in order to provide Southern California residents with information on the air quality conditions. The Project site is located within SRA 24. Within SRA 24, SCAQMD Perris Valley monitoring station, located approximately 8.7 miles southwest of the Project site, is the nearest air quality monitoring station; however, data is not available for the past three years.

As the Perris Valley monitoring station does not provide data for air quality conditions, the next nearest monitoring stations will be utilized. Data for CO, NO
2, and PM10 was obtained from the Elsinore Valley
monitoring station, located in SRA 25, approximately 18.34 miles southwest of the Project site . The nearest station for PM2.5 data was obtained from the Metropolitan Riverside County monitoring station, which is located approximately 14.0 miles northwest of the Project site. It should be noted that the data from the Elsinore Valley and Metropolitan Riverside County monitoring stations were utilized in lieu of the Perris Valley monitoring station only in instances where data was not available.

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Table 4.3-2 Attainment Status of Criteria Pollutants in the SoCAB Criteria Pollutant State Designation Federal Designation O3 – 1-hour standard Nonattainment --
O3 – 8-hour standard Nonattainment Nonattainment
PM10 Nonattainment Attainment
PM2.5 Nonattainment Nonattainment
CO Attainment Unclassifiable/Attainment
NO2 Attainment Unclassifiable/Attainment
SO2 Attainment Unclassifiable/Attainment
Pb1 Attainment Unclassifiable/Attainment
Note: See Appendix 2.1 of EIR Technical Appendix B for a detailed map of State/National Area Designations within the SoCAB
“-” = No standard.

Source: (Urban Crossroads 2025a)

The most recent three years of data available are shown in Table 4.3 -3, Project Area Air Quality Monitoring Summary 2021-2023, which identifies the number of days ambient air quality standards were exceeded for the study area and is considered to be representative of the local air quality at the Project s ite. Data for O 3, CO, NO 2, PM 10, and PM 2.5 for 2021 through 2023 was obtained from SCAQMD Air Quality Data Tables. Additionally, data for SO 2 has been omitted as attainment is regularly met in the SoCAB and few monitoring stations measure SO2 concentrations.

E. Sensitive Receptors
Receptor locations are off-site locations where individuals may be exposed to emissions from Project activities.

1. Residential Receptors
Some people are especially sensitive to air pollution and are given special consideration when evaluating air quality impacts from projects. These groups of people include children, the elderly, individuals with pre-existing respiratory illness, athletes, and others who engage in frequent exercise.

Structures that house these persons or places where they gather to exercise are defined as “sensitive receptors.” These structures typically include residences, hotels, hospitals, etc. as they are also known to be locations where an individual can remain for 24 hours. Consistent with SCAQMD Final Localized Significance Threshold Methodology (LST Methodology), the nearest land use where an individual could remain for 24 hours to the Project site (in this case the nearest residential land use) has been used to determine construction and operational air quality impacts for emissions of PM 10 and
PM2.5, since PM10 and PM2.5 thresholds are based on a 24-hour averaging time.

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Table 4.3-3 Project Area Air Quality Monitoring Summary 2021-2023 Pollutant Standard Year
2021 2022 2023
O3
Maximum Federal 1-Hour Concentration (ppm) 0.117 0.121 0.120 Maximum Federal 8-Hour Concentration (ppm) 0.094 0.091 0.103 Number of Days Exceeding State 1-Hour Standard > 0.09 ppm 25 17 10 Number of Days Exceeding State/Federal 8-Hour Standard > 0.070 ppm 60 37 35 CO
Maximum Federal 1-Hour Concentration > 35 ppm 0.9 0.9 1.3 Maximum Federal 8-Hour Concentration > 20 ppm 0.8 0.6 0.7 NO2
Maximum Federal 1-Hour Concentration > 0.100 ppm 0.044 0.037 0.042 Annual Average 0.007 0.007 0.007
PM10
Maximum Federal 24-Hour Concentration (µg/m3) > 150 µg/m3 89 91 186 Annual Federal Arithmetic Mean (µg/m3) 21.4 19.8 20.8
Number of Days Exceeding Federal 24-Hour Standard > 150 µg/m3 0 0 1 Number of Days Exceeding State 24-Hour Standard > 50 µg/m3 4 1 5 PM2.5
Maximum Federal 24-Hour Concentration (µg/m3) > 35 µg/m3 82.10 38.50 48.70 Annual Federal Arithmetic Mean (µg/m3) > 12 µg/m3 12.58 10.80 10.47 Number of Days Exceeding Federal 24-Hour Standard > 35 µg/m3 10 1 1 Note: ppm = Parts Per Million; µg/m3 = Microgram per Cubic Meter Data for O3, CO, NO2, PM10, and PM2.5 was obtained from SCAQMD Air Quality Data Tables Source: (Urban Crossroads 2025a)

2. Non-Residential Receptors
As per the LST Methodology, commercial and industrial facilities are not included in the definition of sensitive receptor because employees and patrons do not typically remain on site for a full 24 hours but are typically on site for 8 hours or less. The LST Methodology explicitly states that “ LSTs based on shorter averaging periods, such as the NO2 and CO LSTs, could also be applied to receptors such as industrial or commercial facilities since it is reasonable to assume that a worker at these sites could be present for periods of one to eight hours.” For purposes of analysis, if an industrial/commercial use is located at a closer distance to the Project site than the nearest residential use, the nearest industrial/commercial use will be utilized to determine construction and operational LST air impacts for emissions of NO
2 and CO because an individual could be present at these sites for periods of 1 to 8 hours.

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3. Project-Related Sensitive Receptors
Sensitive receptors in the Project study area are described below and are depicted in Figure 4.3-1, Sensitive Receptor Locations:

R1: Location R1 represents the existing residence at 26873 Campus Point Drive, approximately 92 feet north of the Project site. R1 is placed in the private outdoor living areas (backyard) facing the Project site.

R2: Location R2 represents the existing residence at 13760 Nason Street, approximately 164 feet east of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R2 is placed at the building façade.

R3: Location R3 represents the existing residence at 13980 Nason Street, approximately 211 feet east of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R3 is placed at the building façade R4: Location R4 represents the existing residence at 26871 Alessandro Boulevard, approximately 453 feet south of the Project site. R4 is placed in the private outdoor living areas (backyard) facing the Project site.

R5: Location R5 represents the Valley Christian Academy located at 26755 Alessandro Boulevard, approximately 163 feet south of the Project site . Since there are no private outdoor living areas facing the Project site, receptor R5 is placed at the building façade.

R6: Location R6 represents the existing residence at 26606 Danube Way, approximately 675 feet west of the Project site . R6 is placed in the private outdoor living areas (backyard) facing the Project site.

R7: Location R7 represents the existing residence at 26722 Bay Avenue, approximately 26 feet west of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R7 is placed at the building façade.

R8: Location R8 represents the Moreno Valley Unified School District Early Learning Academy located at 26700 Cottonwood Avenue, approximately 296 feet northwest of the Project site. R8 is placed at the closest classroom.

R9: Location R9 represents the relocated Moreno Elementary School located at 13700 Nason Street, approximately 220 feet east of the Project site. R9 is placed at the building façade facing the Project.

4.3 Air Quality
[:] Site Boundary il} Receptor Locations -• Distance from receptor to Project site boundary (in feet) Source(s): Urban Crossroads (March 2024) Figure 4.3- l
mnJ Wffltw WWW Sensitive Receptor Locations
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4.3.2 REGULATORY SETTING
A. Federal Plans, Policies, and Regulations

1. Federal Clean Air Act (CAA)
The Environmental Protection Agency (EPA) is responsible for setting and enforcing the NAAQS for O3, CO, NOX, SO2, PM10, and Pb. The EPA has jurisdiction over emissions sources that are under the authority of the federal government including aircraft, locomotives, and emissions sources outside State waters (Outer Continental Shelf). The EPA also establishes emission standards for vehicles sold in states other than California. Automobiles sold in California must meet the stricter emission requirements of CARB.

The Clean Air Act (CAA ; 42 U.S.C. Section 7401 et seq.) was first enacted in 1955 and has been amended numerous times in subsequent years (1963, 1965, 1967, 1970, 1977, and 1990). The CAA establishes the federal air quality standards and the NAAQS and specifies future dates for achieving compliance. The CAA also mandates that states submit and implement SIPs for local areas not meeting these standards. These plans must include pollution control measures that demonstrate how the standards will be met.

The 1990 amendments to the CAA that identify specific emission reduction goals for areas not meeting the NAAQS require a demonstration of reasonable further progress toward attainment and incorporate additional sanctions for failure to attain or to meet interim milestones. The sections of the CAA most directly applicable to the development of the Project site include Title I (Non- Attainment Provisions) and Title II (Mobile Source Provisions). Title I provisions were established with the goal of attaining the NAAQS for the following criteria pollutants O
3, NO2, SO2, PM10, CO, PM2.5, and Pb. The NAAQS
were amended in July 1997 to include an additional standard for O3 and to adopt a NAAQS for PM2.5.

Table 2 -2, Ambient Air Quality Standards , of the AQIA provided in EIR Technical Appendix B provides the NAAQS within the SoCAB.

Mobile source emissions are regulated in accordance with Title II provisions. These provisions require the use of cleaner burning gasoline and other cleaner burning fuels such as methanol and natural gas.

Automobile manufacturers are also required to reduce tailpipe emissions of hydrocarbons and NO X.

NOX is a collective term that includes all forms of NO X which are emitted as byproducts of the combustion process.

B. State Plans, Policies, and Regulations

1. California Air Resources Board
The California Clean Air Act (CCAA) establishes numerous requirements for district plans to attain state ambient air quality standards for criteria air contaminants. California Air Resources Board (CARB), which became part of California Environmental Protection Agency (CalEPA) in 1991, is responsible for ensuring implementation of the CCAA , responding to the federal CAA, and for regulating emissions from consumer products and motor vehicles. The CCAA mandates achievement of the maximum degree of emissions reductions possible from vehicular and other mobile sources in ■■
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order to attain the state ambient air quality standards by the earliest practical date . CARB established the CAAQS for all pollutants for which the federal government has NAAQS and, in addition, establishes standards for SO 4, visibility, hydrogen sulfide (H 2S), and vinyl chloride (C 2H3Cl).

However, at this time H 2S and C 2H3Cl are not measured at any monitoring stations in the SoCAB because they are not considered to be a regional air quality problem. Generally, the CAAQS are more stringent than the NAAQS. For districts with serious air pollution, its attainment plan should include no net increase in emissions from new and modified stationary sources and best available retrofit technology for existing sources.

Local air quality management districts, such as SCAQMD , regulate air emissions from stationary sources such as commercial and industrial facilities . All air pollution control districts have been formally designated as attainment or non-attainment for each CAAQS.

2. Air Quality Management Plans
Serious non-attainment areas are required to prepare Air Quality Management Plans (AQMP) that include specified emission reduction strategies in an effort to meet clean air goals . These plans are required to include:
• Application of Best Available Retrofit Control Technology to existing sources; • Developing control programs for area sources (e.g., architectural coatings and solvents) and indirect sources (e.g. motor vehicle use generated by residential and commercial development); • A District permitting system designed to allow no net increase in emissions from any new or modified permitted sources of emissions;
• Implementing reasonably available transportation control measures and assuring a substantial reduction in growth rate of vehicle trips and miles traveled; • Significant use of low-emissions vehicles by fleet operators; and • Sufficient control strategies to achieve a 5% or more annual reduction in emissions or 15% or more in a period of three years for ROGs, NO
X, CO, and PM10. However, air basins may use
alternative emission reduction strategy that achieves a reduction of less than 5% per year under certain circumstances.

AQMPs are updated regularly in order to more effectively reduce emissions, accommodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy.

3. California Air Resources Board Rule 2449
CARB enforces rules related to air pollutant emissions in the State of California. CARB Rule 2449 (13 CCR 2449), In-Use Off-Road Diesel Idling Restricts, limits nonessential idling to five minutes or less for diesel-powered off-road equipment.

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4. Senate Bill 535 – Disadvantaged Communities
Senate Bill 535 (SB 535; De León, Chapter 830, 2012) recognizes the potential vulnerability of low- income and disadvantaged communities to poor air quality. Disadvantaged communities in California are specifically targeted for investment of proceeds from the State’s cap- and-trade program. These investments are aimed at improving public health, quality of life , and economic opportunity in California’s most burdened communities while at the same time reducing pollution that causes climate change. Authorized by the California Global Warming Solutions Act of 2006 (AB 32), the State’s cap- and-trade program is one of several strategies that California uses to reduce greenhouse gas emissions that cause climate change. The funds must be used for programs that further reduce emissions of greenhouse gases. SB 535 requires that 25% of the proceeds from the Greenhouse Gas Reduction Fund go to projects that provide a benefit to disadvantaged communities . CalEPA is charged with the duty to identify disadvantaged communities. CalEPA bases its identification of these communities on geographic, socioeconomic, public health, and environmental hazard criteria (Health and Safety Code, Section 39711, Subsection [a]). In this capacity, CalEPA currently defines a disadvantaged community, from an environmental hazard and socioeconomic standpoint, as a community that scores within the top 25% of the census tracts, as analyzed by the California Communities Environmental Health Screening Tool Version 4 .0 (CalEnviroScreen). While portions of the City of Moreno Valley (City) are identified as SB 535 Disadvantaged Communities, the Project site is not. The nearest SB 535 Disadvantaged Community is approximately 0.75 mile to the west of Project site at the intersection of Lasselle Street and Alessandro Boulevard (Census Tract 6065042517). (CalEPA 2022)

5. Title 24 Energy Efficiency Standards and California Green Building Standards California Code of Regulations (CCR) Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Building Energy Efficiency Standards) was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy-efficient technologies and methods. Energy-efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases greenhouse gas (GHG) emissions.

CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen Code) is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect in 2009, and is administered by the California Building Standards Commission. The purpose of the CALGreen Code is to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices in the following categories:
(1) planning and design; (2) energy efficiency; (3) water efficiency and conservation; (4) material conservation and resource efficiency; and (5) environmental air quality.

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The Title 24 Building Energy Efficient Standards and CALGreen Code are updated on a regular basis, with the most recent approved updates consisting of the 2022 Building Energy Efficiency Standards and 2022 CALGreen Code, which became effective on January 1, 2023. 2

C. Regional Plans, Policies, and Regulations

1. South Coast Air Quality Management District
The Project is in Riverside County, in the SoCAB, where SCAQMD is the agency principally responsible for comprehensive air pollution control. As a regional agency, SCAQMD works directly with the Southern California Association of Governments (SCAG), County transportation commissions, and local governments, as well as State and federal agencies to reduce emissions from stationary, mobile, and indirect sources to meet S tate and federal ambient air quality standards .

SCAQMD develops comprehensive plans and regulatory programs for the region to attain federal standards by dates specified in federal law. The agency is also responsible for meeting state standards by the earliest date achievable, using reasonably available control measures.

SCAQMD rule development through the 1970s and 1980s resulted in dramatic improvement in SoCAB air quality. Nearly all control programs developed through the early 1990s relied on (i) the development and application of cleaner technology; (ii) add-on emission controls; and (iii) uniform CEQA review throughout the SoCAB. Industrial emission sources have been significantly reduced by this approach and vehicular emissions have been reduced by technologies implemented at the state level by CARB.

Air Quality Management Plan
As discussed previously, the NAAQS and CAAQS are exceeded in most parts of the S oCAB. The CAAQS designate the SoCAB, including the Project site, as non -attainment for O3, PM10, and PM2.5 while the NAAQS designate the SoCAB as nonattainment for O 3 and PM2.5. In response, SCAQMD has adopted a series of AQMPs to meet the state and federal ambient air quality standards. AQMPs are updated regularly to ensure an effective reduction in emissions, accommodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy. The AQMP control measures and related emission reduction estimates are based on emissions projections for a future development scenario derived from land use, population, and employment characteristics defined in consultation with local governments. Accordingly, conformance with the AQMP for development projects is determined by demonstrating compliance with local land use plans and/or population projections.

On December 2, 2022, SCAQMD adopted the 2022 AQMP, which is a regional and multi -agency effort (SCAQMD, CARB, SCAG, and EPA). The 2022 AQMP continues to evaluate current integrated strategies and control measures to meet the CAAQS, as well as explore new and innovative methods to reach its goals. Some of these approaches include utilizing incentive programs, recognizing existing

2 The 2022 California Green Building Standards Code became effective on January 1, 2023, however; it has since been amended on July 1, 2024, with the Intervening Code Cycle Update which is reflected in this report. Additionally, it should be noted that CALGreen is currently being updated, with the most recent draft update consisting of the 2025 California Green Building Code Standards that will be effective on January 1, 2026.
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co-benefit programs from other sectors, and developing a strategy with fair- share reductions at the federal, state, and local levels. Similar to the 2016 AQMP, the 2022 AQMP incorporates scientific and technological information and planning assumptions, including the SCAG 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), a planning document that supports the integration of land use and transportation to help the region meet the federal CAA requirements .

The AQMP’s control measures and related emission reduction estimates are based upon emissions projections for a future development scenario derived from land use, population, and employment characteristics defined in consultation with local governments. Analysis of the Project’s consistency with the AQMP is provided in Section 4.3.4 under the discussion of Threshold “a” below.

SCAQMD Rules
SCAQMD has established various rules/regulatory requirements applicable to development projects.

Following is a discussion of SCAQMD rules particularly relevant to the Project, which address construction-related and operational activities.

SCAQMD Rule 402, Nuisance, identifies that a project shall not discharge from any source whatsoever such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health, or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.

SCAQMD Rule 403, Fugitive Dust, is intended to reduce the amount of particulate matter entrained in the ambient air due to anthropogenic (human- made) fugitive dust sources by requiring actions to prevent and reduce fugitive dust emissions. Rule 403 applies to any activity or human-made condition capable of generating fugitive dust and requires that best available control measures to be applied to earthmoving and grading activities.

SCAQMD Rule 445, Low Sulfur Fuel , requires installation of only gaseous -fueled fireplaces and stoves, and is applicable to any new residential or commercial development that begins construction on or after March 9, 2009.

SCAQMD Rule 1113, Architectural Coatings , limits the VOC content of architectural coatings used on projects in SCAQMD . Any person who supplies, sells, offers for sale, or manufactures any architectural coating for use on projects in SCAQMD must comply with the current VOC standards set in this rule.

D. Local Plans, Policies, and Regulations

1. City of Moreno Valley General Plan
The City of Moreno Valley General Plan currently in effect was adopted July 11, 2006 (2006 General Plan) and is a policy document that reflects the City’s vision for the future of Moreno Valley prior to adoption of the proposed 2040 General Plan, which the City is in the process of readopting. As further ■■
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discussed in EIR Section 4.11, Land Use and Planning, the current 2006 General Plan and the proposed 2040 General Plan include policies addressing air quality. The Project’s consistency with these policies is discussed in Table 4.11-1, 2006 General Plan Consistency Analysis , and Table 4.11-2, City- Proposed General Plan 2040 Consistency Analysis.

4.3.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts related to air quality based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact related to air quality would occur if the Project would:
a) Conflict with or obstruct implementation of the applicable air quality plan; b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard;
c) Expose sensitive receptors to substantial pollutant concentrations; d) Result in other emissions (such as those leading to odors ) adversely affecting a substantial number of people.

The Project would result in a significant impact under Threshold “a” if the Project were determined to conflict with SCAQMD 2022 AQMP. Pursuant to Chapter 12, Sections 12.2 and 12.3 of SCAQMD CEQA Air Quality Handbook, a project would conflict with the AQMP if either of the following conditions were to occur:
• The Project would increase the frequency or severity of existing NAAQS and/or CAAQS violations, cause or contribute to new air quality violations, or delay the attainment of interim air quality standards; or
• The Project would exceed the 2022 AQMP’s future year buildout assumptions.

For evaluation under Threshold “b,” implementation of the Project would result in a cumulatively- considerable net increase of a criteria pollutant for which the project region is non-attainment if the Project’s construction and/or operational activities exceed one or more of SCAQMD ’s Regional Thresholds for criteria pollutant emissions . The Regional Thresholds established by SCAQMD for criteria pollutants are summarized in Table 4.3 -4, SCAQMD Maximum Daily Emissions Regional Thresholds.
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Table 4.3-4 SCAQMD Maximum Daily Emissions Regional Thresholds Pollutant Construction Regional
Thresholds
Operational Regional
Thresholds
NOX 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOX 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
Pb 3 lbs/day 3 lbs/day
Source: (Urban Crossroads 2025a)

For evaluation under Threshold “c,” the Project would result in a significant impact if any of the following were to occur:
• The Project’s localized criteria pollutant emissions would exceed one or more of SCAQMD “Localized Thresholds” listed in Table 4.3 -5, SCAQMD Maximum Daily Emissions Construction Localized Thresholds.
• The Project would cause or contribute to a CO “Hot Spot.”

Table 4.3-5 SCAQMD Maximum Daily Emissions Construction Localized Thresholds Construction Localized Thresholds
NOX CO PM10 PM2.5
270 lbs/day 1,577 lbs/day 13 lbs/day 8 lbs/day
Localized Thresholds presented in this table are based on SCAQMD LST Methodology, July 2008 Source: (Urban Crossroads 2025a)

For evaluation under Threshold “d,” a significant impact would occur if the Project’s construction and/or operational activities result in air emissions leading to an odor nuisance pursuant to SCAQMD Rule 402.

4.3.4 IMPACT ANALYSIS
Threshold a: Would the Project conflict with or obstruct implementation of the applicable air quality plan?
SCAQMD 2022 AQMP, which is the applicable air quality plan for the Project area, addresses long- term air quality conditions for the SoCAB. The criteria for determining the Project’s consistency with the 2022 AQMP are analyzed below.

Consistency Criterion No. 1: The proposed Project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay the timely ■■
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attainment of air quality standards or the interim emissions reductions specified in the AQMP.

Consistency Criterion No. 1 refers to violations of the CAAQS and NAAQS. CAAQS and NAAQS violations would occur if LSTs or regional significance thresholds were exceeded. As evaluated under Threshold “b” and “c,” below, the Project’s regional and localized construction-source emissions would not exceed applicable regional significance thresholds or LST thresholds after implementation of mitigation measure (MM) 4.3-1. As evaluated under Threshold “ c,” below, the Project would not exceed the applicable LSTs for operational activity. However, as evaluated under Threshold “b,” the Project’s operational-source emissions are anticipated to exceed the regional thresholds of significance for VOC, NO
X, and CO emissions. VOC and NOX are precursors for ozone; thus, Project operational activities could contribute a substantial volume of pollutants to the S oCAB that could delay the attainment of federal and State ozone standards. As discussed under Threshold “b,” although the Project would implement MM 4.3-2 through MM 4.3-6, which are designed to reduce Project operational-source VOCs, NOX, CO, PM 10, and PM 2.5 emissions, there is no way to meaningfully quantify these reductions in CalEEMod. Therefore, the implementation of mitigation would not reduce emissions to less than significant levels resulting in a significant and unavoidable impact. As such, the Project is determined to be inconsistent with Consistency Criterion No. 1.

Consistency Criterion No. 2: The proposed Project will not exceed the assumptions in the AQMP based on the years of Project build-out phase.

The 2022 AQMP demonstrates that the applicable ambient air quality standards can be achieved within the timeframes required under federal law. Growth projections from local general plans adopted by cities in the SCAQMD are provided to the SCAG, which develops regional growth forecasts that are then used to develop future air quality forecasts for the AQMP. Development consistent with the growth projections in the General Plan is consistent with the AQMP.

Peak day emissions generated by construction activities are largely independent of land use assignments but rather are a function of development scope and maximum area of disturbance.

Irrespective of the Project site’s land use designation, development of the site to its maximum potential would likely occur, with disturbance of the entire site occurring during construction activities.

While the 2006 General Plan designates the Project site for Public Facilities land uses, the 2022 AQMP was adopted subsequent to the City’s prior adoption of the 2040 General Plan and is , therefore, assumed to include the City’s growth projections associated with the 2040 General Plan, which the City is in the process of readopting, as discussed below.

The proposed 2040 General Plan designates the Project site as Downtown Center (DC) District, which allows for a vibrant mix of business, entertainment, residential, cultural, and civic uses to activate the area throughout the day and into the evening. The proposed TCMV Specific Plan is consistent with the City’s proposed Downtown Center (DC) District land use and zoning designations and is consistent with the City’s growth assumptions in the proposed 2040 General Plan.

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The 2040 General Plan was originally adopted in 2021, before adoption of the 2022 AQMP; therefore, the City’s growth projections are presumed to be included in the 2022 AQMP. As such, the Project is consistent with the 2022 AQMP and reflects the proposed land uses for the Project site as anticipated in the 2040 General Plan. As such, the Project would not result in the exceedance of assumptions within the AQMD and would not result in a conflict with Consistency Criterion No. 2.

AQMP Consistency Conclusion
The Project has the potential to result in or cause NAAQS or CAAQS violations because operational- source emissions would exceed the applicable SCAQMD regional thresholds for VOC, NO X, and CO.

As such, the Project is conservatively considered to have the potential to conflict with the AQMP and a potentially significant impact would occur with respect to this threshold.

Threshold b: Wo uld the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
The Project has been evaluated to determine if it would violate an air quality standard, contribute to an existing or projected air quality violation, or if it would result in a cumulatively considerable net increase of a criteria pollutant for which the SoCAB is non-attainment under an applicable NAAQS and CAAQS.

Land uses such as the Project affect air quality through construction-source and operational -source emissions. In May 2022, SCAQMD in conjunction with the California Air Pollution Control Officers Association (CAPCOA) and other California air districts, released CalEEMod 2022; the latest version available (2022.1.1.29) was utilized for the Project analysis. The purpose of this model is to calculate construction- and operational-source criteria pollutant (VOCs, NOX, SOX, CO, PM10, and PM2.5) and GHG emission s from direct and indirect sources , and to quantify applicable air quality and GHG reductions achieved from mitigation measures. Accordingly, the latest version of CalEEMod has been used for this Project t o determine construction and operational air quality emissions, as further discussed below. Output from the model runs for both construction and operational activity are provided in Appendices 5.1 through 5.3 of the AQIA included in EIR Technical Appendix B.

A. Construction-Related Impacts
Construction activities associated with the Project (i.e., site preparation, grading, building construction, paving, and architectural coatings) would result in emissions of VOCs, NO X, SOX, CO, PM 10, and
PM2.5. The construction assumptions for the Project are detailed in Section 5.3 of the AQIA included in EIR Technical Appendix B, and summarized in EIR Section 3.0, Project Description.

CalEEMod calculates maximum daily emissions for summer and winter periods and the estimated unmitigated maximum daily construction emissions for both summer and winter periods are summarized in Table 4.3 -6, Summary of Construction Activity Emissions (Without Mitigation).

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included in the analysis. As shown, emissions resulting from Project construction would exceed the regional criteria pollutant thresholds established by SCAQMD for VOC and mitigation is required.

The Project would implement MM 4.3-1, which requires use of “Super-Compliant” VOC paints to reduce the severity of the VOC impacts. Table 4.3-7, Summary of Construction Activity Emissions (With Mitigation), summarizes the Project’s estimated maximum daily construction emissions with mitigation for both summer and winter periods. It should be noted that the emissions estimates conservatively assume use of Tier 3 off-road equipment. Use of Tier 4 equipment as encouraged by the City, would also be incorporated into the Project to further reduce construction- related pollutant emissions.

With respect to installation of utility infrastructure, the on-site utilities would be trenched and installed within the Project site. With the exception of the storm drain infrastructure, the on-site utilities would connect to the existing utilities within the site-adjacent roadways. As shown on Figure 3-6, Conceptual Utility Plan, the Project would require the construction of an off-site storm drain along Alessandro Boulevard, which forms the southern boundary of the Project site. The new storm drain would extend between proposed Street A and the existing storm drain located approximately 650 feet to the west of the Project site westerly boundary. Off -site impacts along Cottonwood Avenue, Nason Street, Alessandro Boulevard, and Bay Avenue adjacent to the Project site would be associated with the construction of sidewalks, curbs, and gutters; roadway extensions (Bay Avenue); landscaping within the public right-of-way; and any other roadway repairs/improvements required for the Project. The off- site construction activities would not take place at one location for the entire duration of construction.

The pollutant emissions associated with construction of the off-site storm drain and roadway improvements are not expected to exceed the peak daily emissions identified for Project -related construction activities due to the limited amount of construction activities associated with these Project components. The physical limits of these off-site improvements would limit the amount of construction equipment that could be used, and any off-site and utility infrastructure construction would not use equipment totals that would exceed the equipment totals in Table 4.3-7. As such, no impacts beyond what has already been identified in this report are expected to occur.

With implementation of MM 4.3-1, construction-related emissions would be reduced to levels below SCAQMD Regional Thresholds of Significance, resulting in a less than significant impact.

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Table 4.3-6 Summary of Construction Activity Emissions (Without Mitigation) Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer1
2026
Grading
Construction Equipment 0.00 0.00 0.00 0.00 0.00 0.00
Worker, Vendor, Hauling Trips 0.00 0.00 0.00 0.00 0.00 0.00 Grading Construction Emissions Totals 0.00 0.00 0.00 0.00 0.00 0.00 Building Construction
Construction Equipment 2.14 19.63 25.19 0.05 0.75 0.69
Worker, Vendor, Hauling Trips 1.64 4.90 27.80 0.02 5.83 1.44 Building Construction Emissions Totals 2.39 22.30 25.50 0.05 0.98 0.90 Paving
Construction Equipment 1.20 7.12 9.94 0.01 0.32 0.29
Worker, Vendor, Hauling Trips 0.06 0.06 1.08 0.00 0.20 0.05 Paving Emissions Totals 1.27 7.18 11.02 0.01 0.52 0.34
Total Summer 2026 Emissions 5.05 31.71 64.00 0.09 7.10 2.47 2027
Building Construction
Construction Equipment 2.06 18.73 25.13 0.05 0.67 0.62
Worker, Vendor, Hauling Trips 1.56 4.60 25.77 0.02 5.83 1.44 Building Construction Emissions Totals 3.62 23.33 50.90 0.07 6.50 2.06 Total Summer 2027 Emissions 3.62 23.33 50.90 0.07 6.50 2.06 2028
Building Construction
Construction Equipment 1.98 17.77 25.12 0.05 0.60 0.55
Worker, Vendor, Hauling Trips 1.51 4.43 24.06 0.02 5.83 1.44 Building Construction Emissions Totals 3.50 22.20 49.18 0.07 6.43 2.00 Architectural Coating
Construction Equipment 189.68 1.08 1.49 0.00 0.02 0.02
Worker, Vendor, Hauling Trips 0.29 0.26 4.61 0.00 0.97 0.23 Architectural Coating Emissions Totals 189.97 1.33 6.10 0.00 0.99 0.25 Total Summer 2028 Emissions 193.46 23.54 55.28 0.07 7.43 2.24 ■■
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Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Winter
2025
Site Preparation
Construction Equipment 4.05 37.46 32.43 0.05 7.59 4.46
Worker, Vendor, Hauling Trips 0.08 0.19 1.05 0.00 0.26 0.06 Site Preparation Emissions Totals 4.13 37.65 33.48 0.05 7.85 4.52 Grading
Construction Equipment 3.57 32.59 29.44 0.06 4.19 2.38
Worker, Vendor, Hauling Trips 0.09 0.55 1.31 0.00 0.38 0.10 Grading Emissions Totals 3.66 33.14 30.74 0.06 4.56 2.47 Total Winter 2025 Emissions 7.79 70.80 64.23 0.12 12.41 7.00 2026
Grading
Construction Equipment 3.39 29.95 28.67 0.06 4.05 2.25
Worker, Vendor, Hauling Trips 0.09 0.52 1.22 0.00 0.38 0.10 Grading Construction Emissions Totals 3.48 30.47 29.89 0.06 4.43 2.35 Building Construction
Construction Equipment 2.14 19.63 25.19 0.05 0.75 0.69
Worker, Vendor, Hauling Trips 1.55 5.22 21.37 0.02 5.83 1.44 Building Construction Emissions Totals 3.69 24.85 46.56 0.07 6.58 2.13 Paving
Construction Equipment 1.20 7.12 9.94 0.01 0.32 0.29
Worker, Vendor, Hauling Trips 0.06 0.07 0.82 0.00 0.20 0.05 Paving Emissions Totals 1.26 7.18 10.75 0.01 0.52 0.34
Total Winter 2026 Emissions 8.43 62.51 87.20 0.15 11.53 4.82 2027
Building Construction
Construction Equipment 2.06 18.73 25.13 0.05 0.67 0.62
Worker, Vendor, Hauling Trips 1.47 4.92 19.76 0.02 5.83 1.44 Building Construction Emissions Totals 3.53 23.65 44.89 0.07 6.50 2.06 Total Winter 2027 Emissions 3.53 23.65 44.89 0.07 6.50 2.06 ■■
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Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
2028
Building Construction
Construction Equipment 1.98 17.77 25.12 0.05 0.60 0.55
Worker, Vendor, Hauling Trips 1.42 4.75 18.47 0.02 5.83 1.44 Building Construction Emissions Totals 3.41 22.52 43.60 0.07 6.43 2.00 Architectural Coating
Construction Equipment 189.68 1.08 1.49 0.00 0.02 0.02
Worker, Vendor, Hauling Trips 0.27 0.29 3.49 0.00 0.97 0.23 Architectural Coating Emissions Totals 189.95 1.37 4.98 0.00 0.99 0.25 Total Winter 2028 Emissions 193.36 23.89 48.57 0.07 7.43 2.24 Maximum Daily Emissions
Construction Maximum Total Daily Emissions (2025) 7.79 70.80 64.23 0.12 12.41 7.00 Construction Maximum Total Daily Emissions (2026) 8.43 62.51 87.20 0.15 11.53 4.82 Construction Maximum Total Daily Emissions (2026) 3.62 23.65 50.90 0.07 6.50 2.06 Construction Maximum Total Daily Emissions (2027) 193.46 23.89 55.28 0.07 7.43 2.24 Maximum Daily Emissions 193.46 70.80 87.20 0.15 12.41 7.00 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? YES NO NO NO NO NO
lbs/day= pounds per day

1. It should be noted that because construction starts in November 2025 during the winter season, emissions would occur during the winter season and not for summer season for 2025.

Source: (Urban Crossroads 2025a)

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Table 4.3-7 Summary of Construction Activity Emissions (With Mitigation) Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer1
2026
Grading
Construction Equipment 0.00 0.00 0.00 0.00 0.00 0.00
Worker, Vendor, Hauling Trips 0.00 0.00 0.00 0.00 0.00 0.00 Grading Construction Emissions Totals 0.00 0.00 0.00 0.00 0.00 0.00 Building Construction
Construction Equipment 0.93 6.25 29.58 0.05 0.21 0.20
Worker, Vendor, Hauling Trips 1.64 4.90 27.80 0.02 5.83 1.44 Building Construction Emissions Totals 2.58 11.15 57.38 0.07 6.04 1.64 Paving
Construction Equipment 0.82 2.35 10.60 0.01 0.10 0.09
Worker, Vendor, Hauling Trips 0.06 0.06 1.08 0.00 0.20 0.05 Paving Emissions Totals 0.89 2.41 11.67 0.01 0.29 0.14
Total Summer 2026 Emissions 3.46 13.56 69.05 0.09 6.34 1.78 2027
Building Construction
Construction Equipment 0.91 6.17 29.55 0.05 0.20 0.19
Worker, Vendor, Hauling Trips 1.56 4.60 25.77 0.02 5.83 1.44 Building Construction Emissions Totals 2.47 10.77 55.32 0.07 6.03 1.63 Total Summer 2027 Emissions 2.47 10.77 55.32 0.07 6.03 1.63 2028
Building Construction
Construction Equipment 0.89 6.09 29.53 0.05 0.19 0.18
Worker, Vendor, Hauling Trips 1.51 4.43 24.06 0.02 5.83 1.44 Building Construction Emissions Totals 2.40 10.52 53.59 0.07 6.02 1.62 Architectural Coating
Construction Equipment 56.15 1.08 1.49 0.00 0.02 0.02
Worker, Vendor, Hauling Trips 0.29 0.26 4.61 0.00 0.97 0.23 Architectural Coating Emissions Totals 56.44 1.33 6.10 0.00 0.99 0.25 Total Summer 2028 Emissions 58.84 11.86 59.69 0.07 7.01 1.87 ■■
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Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Winter
2025
Site Preparation Construction Equipment 0.52 2.71 29.96 0.05 5.77 2.79 Worker, Vendor, Hauling Trips 0.08 0.19 1.05 0.00 0.26 0.06 Site Preparation Emissions Totals 0.60 2.90 31.01 0.05 6.02 2.85 Grading Construction Equipment 0.80 4.82 36.23 0.06 2.84 1.15 Worker, Vendor, Hauling Trips 0.09 0.55 1.31 0.00 0.38 0.10 Grading Emissions Totals 0.89 5.37 37.53 0.06 3.22 1.25 Total Winter 2025 Emissions 1.49 8.27 68.55 0.12 9.24 4.10 2026
Grading Construction Equipment 0.80 4.80 36.23 0.06 2.84 1.14 Worker, Vendor, Hauling Trips 0.09 0.52 1.22 0.00 0.38 0.10 Grading Construction Emissions Totals 0.88 5.32 37.45 0.06 3.22 1.24 Building Construction Construction Equipment 0.93 6.25 29.58 0.05 0.20 0.20 Worker, Vendor, Hauling Trips 1.55 5.22 21.37 0.02 5.83 1.44 Building Construction Emissions Totals 2.48 11.47 50.95 0.07 6.03 1.64 Paving Construction Equipment 0.82 2.35 10.60 0.01 0.10 0.09 Worker, Vendor, Hauling Trips 0.06 0.07 0.82 0.00 0.20 0.05 Paving Emissions Totals 0.88 2.42 11.41 0.01 0.29 0.14
Total Winter 2026 Emissions 4.25 19.21 99.81 0.15 9.54 3.02 2027 Building Construction Construction Equipment 0.91 6.17 29.55 0.05 0.20 0.19 Worker, Vendor, Hauling Trips 1.47 4.92 19.76 0.02 5.83 1.44 Building Construction Emissions Totals 2.38 11.09 49.31 0.07 6.03 1.63 Total Winter 2027 Emissions 2.38 11.09 49.31 0.07 6.03 1.63 2028 Building Construction Construction Equipment 0.89 6.09 29.53 0.05 0.19 0.18 Worker, Vendor, Hauling Trips 1.42 4.75 18.47 0.02 5.83 1.44 Building Construction Emissions Totals 2.32 10.84 48.00 0.07 6.02 1.62 ■■
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Year Construction Activity Source
Total Construction-Source Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Architectural Coating Construction Equipment 56.15 1.08 1.49 0.00 0.02 0.02 Worker, Vendor, Hauling Trips 0.27 0.29 3.49 0.00 0.97 0.23 Architectural Coating Emissions Totals 56.42 1.37 4.98 0.00 0.99 0.25 Total Winter 2028 Emissions 58.74 12.21 52.98 0.07 7.01 1.87 Maximum Daily Emissions
Construction Maximum Total Daily Emissions (2025) 1.49 8.27 68.55 0.12 9.24 4.10 Construction Maximum Total Daily Emissions (2026) 4.25 19.21 99.81 0.15 9.54 3.02 Construction Maximum Total Daily Emissions (2026) 2.47 11.09 55.32 0.07 6.03 1.63 Construction Maximum Total Daily Emissions (2027) 58.84 12.21 59.69 0.07 7.01 1.87 Maximum Daily Emissions 58.84 19.21 99.81 0.15 9.54 4.10 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
lbs/day= pounds per day

1. It should be noted that because construction starts in November 2025 during the winter season, emissions would occur during the winter season and not for summer season for 2025.

Source: (Urban Crossroads 2025a)

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B. Operational-Related Impacts
Operational activities associated with the Project would result in emissions of VOCs, NOX, SOX, CO, PM10, and PM2.5. Operational emissions would be expected from the following primary sources: area source emissions, energy source emissions, and mobile source emissions, as further described in Section 5.4 of the AQIA included in EIR Technical Appendix B. The majority of the Project’s operational emissions are from mobile sources (passenger car and truck vehicle trips generated by the Project). As identified in EIR Section 4.16, Transportation, the Project would generate approximately 12,010 two-way vehicular trips per day (6,005 trips inbound and 6,005 trips outbound)

The estimated operational-source emissions for the proposed Project are summarized on Table 4.3-8, Summary of Operational Activity Emissions . As shown, the Project would exceed the applicable SCAQMD thresholds for VOC, NO
X, and CO and would result in a cumulatively considerable net increase of a criteria pollutant for which the Project region is in nonattainment, resulting in a significant impact. MM 4.3-2 through MM 4.3-6 w ould reduce the operational emissions. However, s ince the majority of the operational emissions are from vehicle trips and neither the Project Applicant nor the City have regulatory authority to control tailpipe emissions, no feasible mitigation measures beyond the measures identified herein exist that would reduce emissions to levels that are less than significant.

Table 4.3-8 Summary of Operational Activity Emissions
Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Mobile Source 85.85 55.30 501.37 1.19 107.17 27.78
Area Source 45.07 13.78 61.09 0.09 1.11 1.10
Energy Source 0.52 9.03 4.61 0.06 0.72 0.72
Total Maximum Daily Emissions 131.43 78.11 567.07 1.34 109.01 29.61 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? YES YES YES NO NO NO
Winter
Mobile Source 80.24 59.11 440.56 1.12 107.17 27.79
Area Source 39.47 13.27 5.65 0.08 1.07 1.07
Energy Source 0.52 9.03 4.61 0.06 0.72 0.72
Total Maximum Daily Emissions 120.23 81.41 450.81 1.26 108.97 29.58 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? YES YES NO NO NO NO
lbs/day= pounds per day
Source: (Urban Crossroads 2025a)

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MM 4.3-2 through MM 4.3-6 are designed to reduce Project operational -source VOCs, NO X, CO, PM10, and PM2.5 emissions. There is no way to meaningfully quantify these reductions in CalEEMod, and therefore no numeric emissions credit has been taken in the operational air quality modeling. As such, even with application of MM 4.3 -2 through MM 4.3-6, Project operational -source emissions impacts would be significant and unavoidable.

C. Health Consequences
In December 2018, in the case of Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, the California Supreme Court held that an Environmental Impact Report’s (EIR) air quality analysis must meaningfully connect the identified air quality impacts to the human health consequences of those impacts or meaningfully explain why that analysis cannot be provided.

Most local agencies, including the City of Moreno Valley, lack the data to do their own assessment of potential health impacts from criteria air pollutant emissions, as would be required to establish customized, locally -specific thresholds of significance based on potential health impacts from an individual development project. The use of national or “generic” data to fill the gap of missing local data would not yield accurate results because such data does not capture local air patterns, local background conditions, or local population characteristics, all of which play a role in how a population experiences air pollution. Because it is impracticable to accurately isolate the exact cause of a human disease (for example, the role a particular air pollutant plays compared to the role of other allergens and genetics in causing asthma), existing scientific tools cannot accurately estimate health impacts of the Project’s air emissions without undue speculation. Instead, the Project’s air quality impact analysis above provides extensive information concerning the quantifiable and non-quantifiable health risks related to the Project’s construction and long-term operation.

Notwithstanding, the proposed Project’s localized impact to air quality for emissions of CO, NOX, PM10, and PM2.5 have been evaluated by comparing the Project’s on-site emissions to the SCAQMD’s applicable LST thresholds. The LST analysis under Threshold “c” below concludes that the Project would not result in emissions exceeding SCAQMD’s LSTs . Therefore, the Project would not be expected to exceed the most stringent applicable federal or state ambient air quality standards for emissions of CO, NO
X, PM10, and PM2.5.

As the Project’s emissions would comply with federal, state, and local air quality standards, the Project’s emissions are not sufficiently high enough to use a regional modeling program to correlate health effects on a basin- wide level and would not provide a reliable indicator of health effects if modeled.

Threshold c:

Would the Project expose sensitive receptors to substantial pollutant concentrations? A. Localized Significance Thresholds
SCAQMD recommends that the nearest sensitive receptor be considered when determining the Project’s potential to cause an individual a cumulatively significant impact. The nearest land use where ■■
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an individual could remain for 24 hours to the Project site has been used to determine localized construction and operational air quality impacts for emissions of PM10 and PM2.5 (since PM10 and PM2.5 thresholds are based on a 24-hour averaging time). The nearest receptor used for evaluation of localized impacts of PM
10 and PM2.5 is represented by location R7 which represents the existing residence at 26722 Bay Avenue, approximately 26 feet/8 meters west of the Project site.

The nearest industrial/commercial use to the Project site can be used to determine construction and operational LST air impacts for emissions of NOX and CO as the averaging periods for these pollutants are shorter (8 hours or less) and it is reasonable to assume that an individual could be present at these sites for periods of one to 8 hours. As there are no industrial/commercial receptors located at a closer distance than the nearest residential home, the same residence located at 26722 Bay Avenue (location R7) was used for evaluation of localized impacts of NO X and CO. It should be noted that the LST Methodology explicitly states that “It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.” As such a 25-meter receptor distance was used for evaluation of localized PM10, PM2.5, NOX, and CO.

For this Project, the appropriate SRA for the LST analysis is Perris Valley (SRA 24). SCAQMD produced look-up tables for projects less than or equal to 5 acres in size, however, the look-up tables can be applied as a screening criterion for larger projects (see additional discussion in Section 4.2.2 of the AQIA included in EIR Technical Appendix B ). Use of the 5-acre disturbance area thresholds can be used to show that even if the daily emissions from all construction activity were emitted within a 5- acre area, and therefore concentrated over a smaller area , which would result in greater site adjacent concentrations, the impacts would still be less than significant if the applicable 5-acre thresholds are utilized.

1. Construction-Related Impacts
As shown on Table 4.3-9, LST Construction Activity Emissions (Without Mitigation), Project localized construction source -emissions would not exceed the applicable LSTs for emissions of any criteria pollutants. Although mitigation is not required for LSTs because the Project results in a less than significant impact without mitigation, MM 4.3-1 is required for regional construction emissions and would also address localized construction emissions. As shown on Table 4.3-10, LST Construction Activity Emissions (With Mitigation) , with implementation of mitigation, the Project’s localized construction-source emissions would be further reduced. Outputs from the model runs for construction LSTs with and without mitigation are provided in Appendix 5.1 and Appendix 5.2 of the AQIA included in EIR Technical Appendix B.

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Table 4.3-9 LST Construction Activity Emissions (Without Mitigation) Construction
Activity Year Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Site
Preparation
2025
Summer 0.00 0.00 0.00 0.00
Winter 37.46 32.43 7.59 4.46
Maximum Daily Emissions 37.46 32.43 7.59 4.46
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Grading
2025
Summer 0.00 0.00 0.00 0.00
Winter 32.59 29.44 4.19 2.38
2026
Summer 0.00 0.00 0.00 0.00
Winter 29.95 28.67 4.05 2.25
Maximum Daily Emissions 32.59 29.44 4.19 2.38
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Building
Construction
2026
Summer 19.63 25.19 0.75 0.69
Winter 19.63 25.19 0.75 0.69
2027
Summer 18.73 25.13 0.67 0.62
Winter 18.73 25.13 0.67 0.62
2028
Summer 17.77 25.12 0.60 0.55
Winter 17.77 25.12 0.60 0.55
Maximum Daily Emissions 19.63 25.19 0.75 0.69
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Paving
2026
Summer 7.12 9.94 0.32 0.29
Winter 7.12 9.94 0.32 0.29
Maximum Daily Emissions 7.12 9.94 0.32 0.29
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Architectural
Coating
2028
Summer 1.08 1.49 0.02 0.02
Winter 1.08 1.49 0.02 0.02
Maximum Daily Emissions 1.08 1.49 0.02 0.02
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Source: (Urban Crossroads 2025a)

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Table 4.3-10 LST Construction Activity Emissions (With Mitigation) Construction
Activity Year Scenario
Emissions (lbs/day)
NOX CO PM10 PM2.5
Site
Preparation
2025 Summer 0.00 0.00 0.00 0.00
Winter 2.71 29.96 5.77 2.79
Maximum Daily Emissions 2.71 29.96 5.77 2.79
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Grading
2025 Summer 0.00 0.00 0.00 0.00
Winter 4.82 36.23 2.84 1.15
2026 Summer 0.00 0.00 0.00 0.00
Winter 4.80 36.23 2.84 1.14
Maximum Daily Emissions 4.82 36.23 2.84 1.15
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Building
Construction
2026 Summer 6.25 29.58 0.21 0.20
Winter 6.25 29.58 0.20 0.20
2027 Summer 6.17 29.55 0.20 0.19
Winter 6.17 29.55 0.20 0.19
2028 Summer 6.09 29.53 0.19 0.18
Winter 6.09 29.53 0.19 0.18
Maximum Daily Emissions 6.25 29.58 0.21 0.20
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Paving
2026 Summer 2.35 10.60 0.10 0.09
Winter 2.35 10.60 0.10 0.09
Maximum Daily Emissions 2.35 10.60 0.10 0.09
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Architectural
Coating
2028 Summer 1.08 1.49 0.02 0.02
Winter 1.08 1.49 0.02 0.02
Maximum Daily Emissions 1.08 1.49 0.02 0.02
SCAQMD Localized Threshold 270 1,577 13 8
Threshold Exceeded? NO NO NO NO
Source: (Urban Crossroads 2025a)

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2. Operational-Related Impacts
According to SCAQMD LST methodology, LSTs would apply to the operational phase of a proposed project, if the project includes stationary sources, or attracts mobile sources that may spend long periods queuing and idling at the site (e.g., transfer facilities and warehouse buildings). The Project does not include such uses, and thus, due to the lack of significant stationary source emissions, no long- term localized significance threshold analysis is needed. Impacts would be less than significant.

B. CO “Hot Spot”
An adverse CO concentration, known as a “hot spot ,” would occur if an exceedance of the state one - hour standard of 20 parts per million (ppm) or the eight -hour standard of 9 ppm were to occur. A Project-specific CO “hot spot” analysis was not performed because CO attainment in the SoCAB was thoroughly analyzed as part of SCAQMD’s 2003 AQMP and the 1992 Federal Attainment for Carbon Monoxide Plan (1992 CO Plan). As identified in SCAQMD’s 2003 AQMP and the 1992 CO Plan, peak CO concentrations in the SoCAB were the byproduct of unusual meteorological and topographical conditions and were not the result of traffic congestion. As evidence of this, for example, of the 8.4 ppm 8-hr CO concentration measured at the Long Beach Boulevard and Imperial Highway intersection (highest CO generating intersection within the “hot spot” analysis), only 0.7 ppm was attributable to the traffic volumes and congestion at this intersection; the remaining 7.7 ppm were due to the ambient air measurements at the time the 2003 AQMP was prepared. In contrast, an adverse CO concentration, known as a “hot spot,” would occur if an exceedance of the state 1-hour standard of 20 ppm or the 8-hour standard of 9 ppm were to occur. The ambient 1-hr and 8-hr CO concentration within the Project study area is estimated to be 0.9 ppm and 0.6 ppm, respectively (data from Lake Elsinore monitoring station for 2022). Therefore, even if the traffic volumes for the Project were double or even triple of the traffic volumes generated at the Long Beach Boulevard and Imperial Highway intersection, coupled with the on-going improvements in ambient air quality, the Project would not be capable of resulting in a CO “hot spot” at any study area intersections.

Similar considerations are also employed by other Air Districts when evaluating potential CO concentration impacts. More specifically, the BAAQMD concludes that under existing and future vehicle emission rates, a given project would have to increase traffi c volumes at a single intersection by more than 44,000 vehicles per hour (vph), or 24,000 vph where vertical and/or horizontal air does not mix , in order to generate a significant CO impact. Traffic volumes generating the CO concentrations for the “hot spot” analysis is shown on Table 5-10 of the AQIA. The busiest intersection evaluated was at Wilshire Boulevard and Veteran Avenue, which has a daily traffic volume of approximately 100,000 vph and AM/PM traffic volumes of 8,062 vph and 7,719 vph respectively.

When considering maximum traffic volumes in the Project study area (as summarized in Table 5-11 of the AQIA), the total traffic volumes at the intersections considered are less than the traffic volumes identified in the 2003 AQMP. As such, the Project along with background and cumulative development would not produce the volume of traffic required to generate a CO “hot spot” either in the context of the 2003 Los Angeles hot spot study or based on representative BAAQMD CO threshold considerations. Therefore, CO “hot spots” are not an environmental impact of concern for the Project, and this impact would be less than significant.
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Threshold d: Would the Project result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
The potential for the Project to generate objectionable odors has also been considered. Potential odor sources associated with the Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction and is thus considered less than significant. It is expected that Project -generated refuse would be stored in covered containers and removed at regular intervals. The proposed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances.

Therefore, odors associated with the proposed Project construction would be less than significant and no mitigation is required.

According to SCAQMD, land uses generally associated with odor complaints include agricultural uses (livestock and farming), w astewater treatment plants , food processing plants, c hemical plants , composting operations, refineries, landfills, dairies, and fiberglass molding facilities. The Project does not include any uses identified by SCAQMD as being associated with emitting objectionable odors.

As the Project operational activities do not include these sources of odors, potential odor impacts would be less than significant.

4.3.5 CUMULATIVE IMPACT ANALYSIS
The 2022 AQMP evaluates regional conditions within the SoCAB and sets regional emission significance thresholds for both construction and operation of development projects that apply to project-specific impacts and cumulatively-considerable impacts. Thus, if a project exceeds SCAQMD regional emissions thresholds, project -specific impacts would also result in a cumulatively - considerable increase in emissions for those pollutants for which the basin in is non- attainment. As described under the analysis for Threshold “a,” Project implementation would have the potential to conflict with SCAQMD’s 2022 AQMP because the Project would contribute to existing regional air quality violations . Based on SCAQMD ’s regional emissions thresholds, the Project’s potential to conflict with the AQMP is determined to be a significant cumulatively-considerable impact.

As previously discussed, the CAAQS designate the SoCAB as nonattainment for O 3, PM10, and PM2.5
while the NAAQS designates the SoCAB as nonattainment for O3 and PM2.5. SCAQMD has published a report on how to address cumulative impacts from air pollution: White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution. In this report, SCAQMD clearly states (Page D-3):
…the AQMD uses the same significance thresholds for project-specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR.

The only case where the significance thresholds for project-specific and cumulative impacts differ is the Hazard Index (HI) significance threshold for TAC emissions. The project-specific (project increment) significance threshold is HI > 1.0 while the ■■
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cumulative (facility-wide) is HI > 3.0. It should be noted that the HI is only one of three TAC emission significance thresholds considered (when applicable) in a CEQA analysis. The other two are the maximum individual cancer risk (MICR) and the cancer burden, both of which use the same significance thresholds (MICR of 10 in 1 million and cancer burden of 0.5) for project-specific and cumulative impacts.

Projects that exceed the project -specific significance thresholds are considered by SCAQMD to be cumulatively considerable. This is the reason project -specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project-specific thresholds are generally not considered to be cumulatively significant.

Therefore, this analysis assumes that individual projects that do not generate operational or construction emissions that exceed SCAQMD’s recommended daily thresholds for Project-specific impacts would also not cause a cumulatively considerable increase in emissions for those pollutants for which the SoCAB is in nonattainment, and, therefore, would not be considered to have a significant, adverse air quality impact. Alternatively, individual Project-related construction and operational emissions that exceed SCAQMD thresholds for Project-specific impacts would be considered cumulatively considerable.

As discussed in the response to Threshold “b,” Project construction criteria air pollutant emissions would not exceed the applicable SCAQMD regional thresholds with mitigation; however, SCAQMD regional thresholds for VOC, NO
X, and CO emissions would be exceeded during Project operation even with mitigation. Therefore, the Project’s operational VOC, NO X, and CO emissions would be cumulatively considerable resulting in a significant and unavoidable impact.

As discussed under the analysis for “Threshold c,” all Project -related construction- and operational localized air pollutant emissions would be less than significant; therefore, impacts are not considered cumulatively considerable. Additionally, the Project would not result in the formation of or contribute to a CO “hot spot.” As such, impacts are not considered cumulatively-considerable.

As indicated in the analysis of Threshold “d,” above, there are no Project components that would expose a substantial number of sensitive receptors to objectionable odors. There are no known sources of offensive odors in the Project area . Because the Project’s construction and operation would not create substantial and objectionable odors and because there are no sources of objectionable odors in the areas immediately surrounding the Project site, odors from the Project site would not commingle with odors from nearby development projects and expose nearby sensitive receptors to substantial, offensive odors. Accordingly, implementation of the Project would result in a less than significant cumulative impact related to odors.
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4.3.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Significant Project and Cumulative Impact. The Project could result in or cause NAAQS or CAAQS violations because operational-source emissions would exceed the applicable SCAQMD regional thresholds for VOC, NOX, and CO. As such, the Project is considered to have the potential to conflict with the AQMP and a significant impact would occur with respect to this threshold.

Threshold b: S ignificant Project and Cumulative Impact . T he Project would exceed the applicable SCAQMD regional thresholds for VOC during construction, and VOC, NOX, and CO during operation.

Therefore, construction and operation of the Project would contribute to existing violations of the O 3 standard (VOC and NOX are O3 precursors) and would result in a significant cumulatively considerable net increase of a criteria pollutant for which the P roject region is nonattainment under an applicable federal or State ambient air quality standard.

Threshold c: Les s than Significant Impact. During construction, the Project would not expose nearby sensitive receptors to substantial pollutant concentrations because the Project’s localized emissions would not exceed SCAQMD LSTs and impacts would be less than significant. Additionally, the Project does not propose uses that include stationary sources or attract mobile sources that may spend long periods of time queuing and idling at the site; thus, no long- term localized significance threshold analysis is needed. Impacts would be less than significant. Under long-term operating conditions, the Project’s contributions to CO “Hot Spots” would also be less than significant.

Threshold d: Les s than Significant Impact. The Project would not produce air emissions that would lead to unusual or substantial construction-related or operational odors. The Project is required to comply with SCAQMD Rule 402, which prohibits the discharge of odorous emissions that would create a public nuisance.

4.3.7 MITIGATION MEASURES
Construction-Source
Mitigation measure MM 4.3-1 identified below, is incorporated into the Project to reduce construction- related emissions.

MM 4.3-1 The Project shall incorporate the following mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. • Require fugitive -dust control measures that exceed SCAQMD’s Rule 403 requirements, such as:
o Use of nontoxic soil stabilizers to reduce wind erosion. o Apply water every four hours to active soil-disturbing activities. ■■
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o Tarp and/or maintain a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials.
• Encourage the use of construction equipment equal to or greater than 50 horsepower be electrically powered or alternatively fueled. At a minimum, use construction equipment rated by the United States Environmental Protection Agency as having Tier 4 Final (model year 2008 or newer) emission limits .

Include this requirement in applicable bid documents, purchase orders, and contracts.
• Ensure that construction equipment is properly serviced and maintained to the manufacturer’s standards.
• Limit nonessential idling of construction equipment to no more than five consecutive minutes.
• Limit on-site vehicle travel speeds on unpaved roads to 15 miles per hour. • Install wheel washers for all exiting trucks or wash off all trucks and equipment leaving the project area.
• Use Super -Compliant VOC paints for coating of architectural surfaces whenever possible . A list of Super-Compliant architectural coating manufacturers can be found on SCAQMD’s website.

Operational-Source

MM 4.3-2 Legible, durable, weather-proof signs shall be placed at commercial loading docks and truck parking areas that identify applicable CARB anti -idling regulations. At a minimum, each sign shall include: 1) instructions for truck drivers to shut off engines when not in use; 2) instructions for drivers of diesel trucks to restrict idling to no more than five (5) minutes once the vehicle is stopped, the transmission is set to "neutral" or "park," and the parking brake is engaged; and 3) telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City shall conduct a site inspection to ensure that the signs are in place.

MM 4.3-3 Prior to the issuance of each building permit, the Project proponent and its contractors shall provide plans and specifications to the City that demonstrate that electrical service is provided to each of the areas in the vicinity of the buildings that are to be landscaped in order that electrical equipment may be used for landscape maintenance.

MM 4.3-4 Once constructed, the Project proponent shall ensure that all commercial tenants shall utilize only electric or natural gas pallet jacks and forklifts in the loading areas.

MM 4.3-5 Upon occupancy and annually thereafter, the operators of the commercial space shall provide information to all delivery truck drivers, regarding:
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• Building energy efficiency, solid waste reduction, recycling, and water conservation.
• Vehicle GHG emissions, electric vehicle charging availability, and alternate transportation opportunities for commuting.
• Participation in the Voluntary Interindustry Commerce Solutions (VICS) “Empty Miles” program to improve goods trucking efficiencies.
• Health effects of diesel particulates, State regulations limiting truck idling time, and the benefits of minimized idling.
• The importance of minimizing traffic, noise, and air pollutant impacts to any residences in the Project vicinity.

MM 4.3-6 Prior to issuance of a building permit, the Project proponent shall provide the City with an on-site signage program that clearly identifies the required on-site circulation system. This shall be accomplished through posted signs and painting on driveways and internal roadways.

4.3.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold a: Significant and Unavoidable Impact. As discussed under Threshold “b,” above, the Project would incorporate MM 4.3-1, which would reduce construction- related VOC emissions to a less than significant level. MM 4.3-2 through MM 4.3-6 would reduce the Project’s operational-related emissions of VOC, NO X, and CO . However, the mitigation measures would not reduce operational emissions to below the applicable SCAQMD regional thresholds . Therefore, the Project’s potential conflict with the 2022 AQMP represent a significant and unavoidable impact and there are no other feasible mitigation measures for this impact.

Threshold b: S ignificant and Unavoidable Impact. Following the implementation of MM 4.3-1, the Project’s construction-related VOC emissions would be reduced to a less than significant level. W ith implementation of mitigation measure MM 4.3-2 through MM 4.3-6, the Project’s operational related VOC, NO X, and CO emissions would be reduced, but not to a level below SCAQMD’s regional thresholds for these criteria pollutants. Since the majority of the operational emissions are from vehicle trips and neither the Project Applicant nor the City have regulatory authority to control tailpipe emissions, no feasible mitigation measures beyond the measures identified exist that would reduce emissions to levels that are less than si gnificant. Therefore, the Project would result in a significant and unavoidable cumulatively considerable net increase of a criteria pollutant for which the Project region is nonattainment under an applicable federal or State ambient air quality standard.

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4.4 BIOLOGICAL RESOURCES
This subsection evaluates the potential for Project-related activities to impact biological resources. The analysis in this subsection is based, primarily, on information contained in the Biological Technical Report for Town Center at Moreno Valley Project (Biological Report) prepared by VCS Environmental (VCS) (VCS 2025). The technical report is included as Technical Appendix C to this EIR . The Biological Report incorporates the review of relevant literature, field surveys, and geographic information system (GIS)-based analysis of vegetation communities . A detailed discussion of the methodology used for conducting the biological resources assessment is provided in the Biological Report included in EIR Technical Appendix C. All references used in this subsection are listed in EIR Section 7.0, References.

4.4.1 EXISTING CONDITIONS
VCS conducted a general biological survey of the Project site and off-site improvements areas on June 29, 2021, and reverified the conditions on March 8, 2024. Collectively, the Project site and off-site improvements areas encompass approximately 70.27 acres and are referred to as the Project area in this section. VCS biologists walked the entirety of the Project area paying special attention to those areas that could host sensitive vegetation communities or had the potential to provide suitable habitat for special-status plant or wildlife species. The vegetation communities and habitat conditions were inspected to confirm the presence and habitat quality of the vegetation found within the Project area.

A. Vegetation Communities/Plants
Most of the vegetation within the Project area is characterized by a maintained open field comprised of disturbed annual grassland cover vegetated with a variety of non-native and early successional weedy plant species that has been subject to ve getation management activities (mowing). Vegetation communities within the Project area are depicted on Figure 4.4-1, Vegetation/Land Cover .

Approximately 65.85 acres of disturbed/ developed/maintained grassland fields consisting of both paved roadways and maintained grassland fields was mapped within the Project area. This habitat is characterized by weedy non-native annual herbaceous species with a low density of common, weedy native species intermixed. A total of 20 plant species were observed within the Project area, which are listed in Appendix B of EIR Technical Appendix C. Native species throughout this area included common fiddleneck ( Amsinckia intermedia), sunflower (Helianthus annuus ), and sacred datura (Datura wrightii ). Non-native species observed consisted of brome grasses (Bromus madritensis, Bromus diandrus, and Bromus hordeaceus.), silver leaf nightshade (Solanum elaeagnifolium ), short- pod mustard (Hirschfeldia incana), stinknet (Oncosiphon piluliferum ), prickly lettuce (Lactuca serriola), and Russian thistle (Salsola tragus ). Additionally, adjacent to the northern border of the Project area, some non-native ornamental trees are present at a low cover including olive trees (Olea europea) and Mexican fan palms (Washingtonia robusta). This vegetation community appears to be subject to regular disturbance, potentially for weed abatement, based on the short, cut stature of most of the herbaceous plants.
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■ D Environmental Impact Report
□ ROW Improvements
- Offsite Storm Drain
Vegetation I Land Cover (70.27 ac)
□ Disturbed/Developed/Maintained
Grasslands (65.85 ac)
- Herbaceous Non-native Forbs and
Grasses (4.42 ac)
Source(s): VCS (202S}
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4.4 Biological Resources
Figure 4.4- l
Vegetation/Land Cover
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Approximately 4.42 acres of herbaceous non-native forbs and grasses were mapped within the southeastern portion of the Project area. This portion of the site appears to undergo less frequent disturbance. This area has still undergone historical disturbance; however, weed abatement activities appear to occur at less frequent intervals. The vegetation within this area is largely consistent with the vegetation observed in the disturbed/ developed/maintained grassland fields. Additionally, one Peruvian pepper tree cluster (Schinus mole) with multiple trunks was observed within the southeastern portion of the Project area . These veg etation communities are largely consistent with the vegetation observed in the disturbed/developed/maintained grassland field. Sensitive vegetation communities and plant species are discussed below.

B. Wildlife Species
Wildlife species encountered visually or audibly during the field survey were identified and recorded in field notes. Signs of wildlife species including wildlife tracks, burrows, nests, scat , and remains, were also recorded. Binoculars were used to aid in the identification of observed wildlife and in areas not accessible on foot. Wildlife field guides and photographs were used to assist with identification of wildlife species during the field surveys, as necessary. A one-day survey cannot be used to conclusively determine presence or absence of a species; therefore, assessments of presence/absence and potential for occurrence were made based on presence of suitable habitat to support the species, diagnostic signs (burrows, scat, tracks, vocalizations, and nests), known records or occurrence within the area, known distribution and elevation range, and habitat utilization from the relevant literature. A total of 16 wildlife species or signs thereof were observed within the Project area during the 2021 and 2024 biological surveys and are listed in Appendix B of the Biological Report included in EIR Technical Appendix C. Sensitive wildlife species are discussed below.

C. Special-Status Plants and Vegetation Communities
Species of plants are afforded “special status” by federal agencies, State agencies, and/or non- governmental organizations due to their recognized rarity, potential vulnerability to extinction, and local importance. These species typically have a limited geographic range and/or limited habitat and are referred collectively as special -status species. Sensitive vegetation communities ( “sensitive habitats”) are of limited distribution statewide or within a county or region and are often vulnerable to the environmental effects of projects. Sensitive habitats are often threatened with local extirpation and are, therefore, considered valuable biological resources. Vegetation communities are considered “sensitive” by the California Native Plant Society (CNPS) and California Department of Fish and Wildlife (CDFW) if they meet certain criteria as outlined in Section 4.0, Vegetation, of the Biological Report included in EIR Technical Appendix C. Available literature and databases were reviewed regarding sensitive habitats and special-status plant species. The potential for special-status plants and sensitive vegetation communities to occur within the Project area was assessed as part of the biological resources assessment for the Project.

No special-status vegetation communities were observed within the Project area during the field surveys. Additionally, no special -status vegetation communities designated by the CDFW were reported in the California Natural Diversity Database (CNDDB) within two miles of the Project area. ■■
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Sensitive plant species include federally or State -listed threatened or endangered species and those species listed on the CNPS rare and enda ngered plant inventory. No sensitive plant species were identified in the Project area during the field surveys. Sensitive plant species with the potential to occur within the Project area were analyzed based on distribution, habitat requirements, and existing site conditions and are listed in Appendix C of the Biological Report included in EIR Technical Appendix C. Based on the habitat found within the Project area, only one special-status plant species, San Diego tarplant (Deinandra paniculata), was determined to have moderate potential to occur within the Project area. The remaining special -status plant species analyzed have been determined not likely to occur within the Project area, primarily based on the absence of suitable habitat and/or the Project area is well outside known elevations for the species.

The San Diego tarplant is a California Rare Plant Rank (CRPR) 4.2: Plants of limited distribution – A watch list. This species occurs as a dominant or co-dominant plant in the herbaceous layer of grasslands, forblands, openings of coastal sage scrub, and oak woodland habitat. It occurs in elevations ranging from 25 to 950 meters and can be found blooming from March to December. San Diego tarplant is known to occur throughout the City and the Project area contains grassland habitat that has the potential to support the species; however, during the biological surveys the San Diego tarplant was not observed on the Project area.

D. Special-Status Wildlife
Species of wildlife are afforded “special status” by federal agencies, State agencies, and/or non- governmental organization due to their recognized rarity, potential vulnerability to extinction, and local importance as further described in Section 5.0, Wildlife, of the Biological Report included in EIR Technical Appendix C. These species typically have a limited geographic range and/or limited habitat and are referred collectively as special-status species. Sensitive wildlife species include the following classifications: federally or State-listed threatened or endangered species, California species of special concern, Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) covered species, and fully protected and protected species (as designated by CDFW). Special-status wildlife species with the potential to occur within the Project area were analyzed based on distribution, habitat requirements, and existing site conditions.

The location of the Project is within the general distributional range of several special -status wildlife species. Many of the sensitive terrestrial wildlife species that could occur within the Project area are not subject to specific published survey protocols and/or are covered under the MSHCP

1. The purpose
of the general biological assessment s was to note those species observed, ascertain general site conditions, and identify habitat areas that could be suitable for special -status wildlife species. A complete list of sensitive wildlife species analyzed with the potential to occur within the Project area is included in Appendix C of EIR Technical Appendix C. One sensitive species, Cooper’s hawk

1 An MSHCP covered species is a species that is adequately conserved by MSHCP implementation. There are 146 covered species in the MSHCP, of which 40 species are identified that may require additional surveys. A Project receives “take” coverage for these cov ered species when it is determined to be consistent with the MSHCP requirements.
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(Accipiter cooperii), was observed within the Project area . This species is listed as a CDFW Watch List (WL) species. Two additional special -status species were determined to have at least a “low to moderate” potential of occurring within the Project area but were not observed during the biological assessments, including the following: burrowing owl (BUOW) (Athene cunicularia), a candidate species for CESA, a CDFW Species of Special Concern (SSC), a U .S. Fish and Wildlife Service (USFWS) Bird of Conservation Concern (BCC), a U.S. Bureau of Land Management Sensitive species (BLMS), and MSHCP Group 3 species (covered species); and western mastiff bat ( Eumops perotis californicus), a CDFW SSC, Western Bat Working Group Medium Priority, and Bureau of Land Management Sensitive Species. Crotch’s bumble bee (Bombus crotchii) was also analyzed due to the recent protections provided for this species under CESA . Crotch’s bumble bee was petitioned to the State of California in 2018 and the Fish and Game Commission advanced it to a Candidate Endangered species under CESA in June 2019. These special-status species are further described below.

1. Cooper’s Hawk
This hawk species occurs in forest and woodland habitats. These lanky hawks are a regular sight in parks, quiet neighborhoods, over fields, at backyard feeders, and even along busy streets if there are trees around. This species is also known to use urban areas, utility poles as perches, and to occupy mature trees associated with residential development. Some of the mature trees within the Project area, such as the Peruvian pepper trees, provide marginal foraging habitat for Cooper’s hawk; however , higher quality habitat is located within the trees on the adjacent properties to the east of the Project area. No suitable nesting habitat for Cooper’s hawk is present within the Project area.

2. Burrowing Owl
The BUOW is a small, tan, ground‐dwelling owl that occupies and nests in underground burrows. The species is associated with grasslands and other arid open terrain throughout much of the western United States. Due to the characteristic fossorial habits of BUOW , burrows are a critical component of their habitat. In southern California, BUOW are not only found in undisturbed natural areas, but also fallow agricultural fields, margins of active agricultural areas, berms to flood control and creek channels, livestock farms, airports, and vacant lots . Declines in BUOW populations are attributed to loss and degradation of habitat, ongoing residential and commercial development, and rodent control programs.

Suitable BUOW habitat is present within the Project area and surrounding areas. In addition, the Project area is within the MSHCP BUOW Survey Area. Thus, a BUOW habitat assessment was performed during the biological surveys. The BUOW assessment followed the guidelines identified in Burrowing Owl Survey Instructions for the Western Riverside County Multiple Species Habitat Conservation Plan Area. The BUOW habitat assessment involved walking the Project area and accessible areas within a 500-foot buffer to determine if any areas hosted suitable habitat for BUOW . Soil conditions, topography, vegetative communities, and habitat quality were documented. A majority of the 500-foot buffer area surrounding the Project area was inaccessible due to legal access limitations; these areas were viewed through binoculars. No BUOW were observed during the biological surveys; however, due to the presence of suitable habitat for BUOW in the Project area, BUOW focused surveys were conducted by ELMT Consulting (ELMT) on August 5, 12, 18, and 24, 2021. The survey methodology ■■
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is detailed in the Burrowing Owl Focused Survey Report included in Appendix D of the Biological Report included in EIR Technical Appendix C. All suitable burrows/sites including rock piles and non- natural substrates were thoroughly examined for signs of BUOW presence. No BUOW or signs thereof were identified during the four focused surveys.

3. Western Mastiff Bat
The western mastiff bat ranges throughout California in a wide range of habitat types, typically below 9,000 feet in elevation. The western mastiff bat usually forages in open areas such as chaparral, oak woodland, open ponderosa pine forest, flood plains grassland, montane meadows, and agricultural areas, and requires large lakes or ponds at least 100 feet long for drinking. Western mastiff bat generally roosts high above the ground, allowing a clear vertical drop of at least seven feet for flight. Potentially suitable day roosting habitat on the Project area is marginal and consists of palm trees along the northern border. However, no water sources are present within the Project area . Approximately 2.5 miles south of the Project area, rocky mountainous habitat exists and may support populations that could use the Project area as foraging grounds.

4. Crotch’s Bumble Bee
A database review indicates no sightings of Crotch’s bumble bee within a 2- mile radius, which is the common standard assessment area, with the nearest sighting being over 4 miles away. The field review also paid close attention to suitable habitat for this species. Suitable habitat typically includes burrows that would be suitable for nesting and abundant nectar sources from the following plant genera:

Antirrhinum, Phacelia, Clarkia, Cordylanthus, Dendromecon, Eschscholzia, Eriogonum, Hypericum, Lantana, Lupinus, Salvia, Asclepias, Cirsium, Monardella, Keckiella, Acmispon, Euthamia, Ehrendorferia, Vicia, and/or Trichostema. While marginal potential would result from the existence of some rodent burrows, the significant distance to the nearest sighting, the lack of sufficient nectar sources, and the regular disturbance to both the site and the surrounding properties severely limits any potential for Crotch’s bumble bee to occupy the Project site.

E. Avian Nesting and Bat Roosts
There is potential for avian nesting within the Project area. The scattered trees provide suitable habitat for avian species that nest in trees. The disturbed/ developed/maintained grassland fields may provide suitable nesting habitat for ground-nesting avian species. There is low potential for bat roosting to occur within the Project area. The biologist did not observe signs of nesting or roosting activity within the Project area during the biological surveys.

F. Critical Habitat
Critical habitat is habitat needed to support recovery of threatened or endangered species . The USFWS’s online service for information regarding Threatened and Endangered Species Final Critical Habitat designation within California was reviewed during preparation of the Biological Report to determine if the Project occurs within any species designated Critical Habitat. No Critical Habitat occurs on or within two miles of the Project area (refer to Figure 5, CNDDB Occurrences and Critical ■■
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Habitat, of the Biological Report included in EIR Technical Appendix C). The nearest Critical Habitat is designated for the Stephens’ Kangaroo Rat and is located approximately 6.5 miles southeast of the Project area.

G. Wildlife Movement
Wildlife corridors link together areas of suitable habitat that are otherwise separated by rugged terrain, changes in vegetation, or human disturbance . The fragmentation of open space areas by urbanization creates isolated “islands” of wildlife habitat. Corridors effectively act as links between different populations of a species and can mitigate the effect of habitat fragmentation as further described in Section 5.3.3, Wildlife Movement, of the Biological Report included in EIR Technical Appendix C.

An inc rease in a population’s genetic variability is generally associated with an increase in a population’s health.

Wildlife movement activities usually fall into one of three movement categories: dispersal (e.g., juvenile animals from natal areas, individuals extending range distributions); seasonal migration; and movements related to home range activities (foraging for food or water, defending territories, searching for mates, breeding areas, or cover).

The Project area is bordered by roads and urban development. The Project area may play a role in local wildlife dispersal and foraging; however, the site is not likely located within a significant wildlife movement corridor. Common wildlife species such as coyotes, skunks, opossums, and raccoons may travel through the site and neighboring developed areas, but the site does not provide connectivity between large areas of open space on a local or regional scale.

H. Jurisdictional Water and Wetlands
As described in Section 6.0, Jurisdictional Waters, of the Biological Report included in EIR Technical Appendix C, various sources were reviewed to determine the potential presence or absence of jurisdictional streams/drainages, wetlands, lakes, and their location within the watersheds associated with the Project area, and other features that might contribute to federal or State jurisdictional authority located within watersheds associated with the Project area. Additionally, during the biological survey, the VCS biologist assessed the presence or absence of potential jurisdictional streams/drainages and conducted a wetland delineation on the Project area. During the field survey, the Project area was assessed for jurisdictional wetland and non-wetland Waters of the United States (WOUS) and Waters of the State (WOS).

No aquatic features are mapped within the Project area on the USFWS’s National Wetland Inventory.

No drainages are present within the Project area and no potential jurisdictional waters were identified within the Project area.

As defined in Section 6.1.2 of the MSHCP, riparian/riverine resources are lands which contain habitat dominated by trees, shrubs, persistent emergent ( wetland plant species ), or emergent mosses and lichens, which occur close to, or which depend upon moisture from , a nearby freshwater source , or ■■
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areas with freshwater after flow during all or a portion of the year. Vernal pools are seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation, and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season.

To determine the areas where riparian/riverine areas and vernal pools are present, the VCS biologist walked the entire site and reviewed historical aerial imagery. Based on the collective results of these investigations, t here was no evidence of riparian/riverine resources subject to the MSHCP in the Project area. Additionally, no vernal pools or seasonal depressions were observed within the Project area. There was no evidence of ponding water, such as visible surface water, cracked soils, or hydric soils, and no features were identified within the Project area where water might collect and persist, like road ruts or other closed depressions. The soil in the Project area is classified as a well-draining, sandy loam. Based on the lack of typical features that could collect water (e.g., road ruts, depression, vernal pools), the lack of ponding water evidence , and the presence of well-draining soils that are not likely to support retention of water, there are no riparian/riverine areas within the Project area.

4.4.2 REGULATORY SETTING
The Project is subject to State and federal regulations that were developed to protect natural resources, including State- and federally-listed plants and animals; aquatic resources including rivers and creeks, ephemeral streambeds, wetlands, and areas of riparian habitat; other special -status species which are not listed as threatened or endangered by the State or federal governments; and other special -status vegetation communities . Provided below is an overview of the federal, State, and regional laws, regulations, and requirements that are applicable to the Project based on its geographic location and the biological resources observed by VCS.

A. Federal Plans, Policies, and Regulations

1. Endangered Species Act (ESA)
The purpose of the federal Endangered Species Act (ESA) is to protect and recover imperiled species and the ecosystems upon which they depend. It is administered by the USFWS and the Commerce Department’s National Marine Fisheries Service (NMFS). The USFWS has primary responsibility for terrestrial and freshwater organisms, while the responsibilities of NMFS are mainly marine wildlife such as whales and anadromous fish such as salmon. Under the ESA, species may be listed as either endangered or threatened. “Endangered” means a species is in danger of extinction throughout all or a significant portion of its range . “Threatened” means a species is likely to become endangered within the foreseeable future. All species of plants and animals, except pest insects, are eligible for listing as endangered or threatened. The ESA makes it unlawful for a person to take a listed animal without a permit. “Take” is defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” Through regulations, the term “harm” is defined as “an act which actually kills or injures wildlife . Such an act may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering.” Listed plants are not protected from take, although ■■
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it is illegal to collect or maliciously harm them on federal land. Protection from commercial trade and the effects of federal actions do apply for plants (USFWS 2017).

2. Migratory Bird Treaty Act (16 USC Section 703-712)
The Migratory Bird Treaty Act (MBTA) makes it illegal for anyone to take, possess, import, export, transport, sell, purchase, barter, or offer for sale, purchase, or barter, any migratory bird, or the parts, nests, or eggs of such a bird except under the terms of a valid permit issued pursuant to federal regulations. The migratory bird species protected by the MBTA are listed in 50 CFR 10.13. The USFWS has statutory authority and responsibility for enforcing the MBTA (16 U.S.C. 703-712). The MBTA implements Conventions between the United States and four countries (Canada, Mexico, Japan, and Russia) for the protection of migratory birds.

B. State Plans, Policies, and Regulations

1. California Endangered Species Act (CESA)
The California Endangered Species Act (CESA) states that all native species of fishes, amphibians, reptiles, birds, mammals, invertebrates, and plants, and their habitats, threatened with extinction and those experiencing a significant decline which, if not halted, would lead to a threatened or endangered designation, will be protected or preserved (CDFW 2020). The CDFW works with interested persons, agencies, and organizations to protect and preserve such sensitive resources and their habitats . CESA prohibits the take of any species of wildlife designated by the California Fish and Game Commission as endangered, threatened, or candidate species. CDFW may authorize the take of any such species if certain conditions are met.

Section 2081 subdivision (b) of the California Fish and Game Code (CFGC) allows CDFW to authorize take of species listed as endangered, threatened, candidate, or a rare plant if that take is incidental to otherwise lawful activities and if certain conditio ns are met. These authorizations are commonly referred to as incidental take permits (ITPs).

2. Natural Community Conservation Planning Act (NCCP)
CDFW's Natural Community Conservation Planning (NCCP) program takes a broad-based ecosystem approach to planning for the protection and perpetuation of biological diversity. The NCCP program began in 1991 as a cooperative effort to protect habitats and species. It is broader in its orientation and objectives than the California and Federal Endangered Species Acts as these laws are designed to identify and protect individual species that have already de clined in number significantly. An NCCP identifies and provides for the regional protection of plants, animals, and their habitats while allowing compatible and appropriate economic activity. Working with landowners, environmental organizations, and other interested parties, a local agency oversees the numerous activities that compose the development of an NCCP . CDFW and the USFWS provide the necessary support, direction, and guidance to NCCP participants.

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There are currently 17 approved NCCPs (includes 6 subarea plans), including the Western Riverside County MSHCP and more than 9 NCCPs in the various stages of planning (includes 2 subarea plans), which together cover more than 8 million acres and will provide conservation for nearly 400 special - status species and a wide diversity of natural community types throughout California (CDFW 2022).

3. Unlawful Take or Destruction of Nests or Eggs (CFGC, Sections 3503.5-3513) Section 3503.5 of the CFGC specifically protects birds of prey, stating: “It is unlawful to take, possess, or destroy any . . . [birds-of-prey] or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto.” Section 3513 of the CFGC duplicates the federal protection of migratory birds, stating: “It is unlawful to take or possess any migratory nongame bird as designated in the Migratory Bird Treaty Act or any part of suc h migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act.”

C. Local Plans, Policies, and Regulations

1. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) The Western Riverside County MSHCP is a comprehensive, multi-jurisdictional Habitat Conservation Plan (HCP) focusing on conservation of species and their habitats in Western Riverside County. The Western Riverside County MSHCP was adopted on June 17, 2003, and an Implementing Agreement was executed between the USFWS, CDFW, and participating entities (including the City of Moreno Valley). Rather than focusing on one species at a time, implementation of the Western Riverside County MSHCP Section 10 Permit preserves native vegetation and meets the habitat needs of multiple species.

The Project area is within the boundaries of the Western Riverside County MSHCP; however, the Project area is not identified as being within a Criteria Cell, Public or Quasi -Public Conserved Land, or the following Survey Areas: Narrow Endemic Plant Species, Criteria Area Species, Amphibians, or Mammals. The Project is not located within or near any areas currently identified as or anticipated in the future as MSHCP conservation. The Project area is within the BUOW Survey Area for the MSHCP; thus, a habitat assessment, focused burrow survey, and focused BUOW surveys are required and were conducted for the Project.

2. Stephen’s Kangaroo Rat Habitat Conservation Plan
The Stephens’ Kangaroo Rat HCP is a comprehensive, multi -jurisdictional HCP focusing on the conservation of the endangered Stephens’ Kangaroo Rat and its habitat. The Stephens’ Kangaroo Rat HCP was adopted in August 1990 and an Implementing Agreement was executed between the USFWS, CDFW, and participating entities (including the City of Moreno Valley). The Stephens’ Kangaroo Rat HCP provides for the permanent establishment, mitigation, and monitoring of a reserve network for the Stephens’ Kangaroo Rat. The Project area is not located within the Stephens’ Kangaroo Rat survey area but is located within the Stephens’ Kangaroo Rat mitigation fee area.

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3. Moreno Valley Municipal Code
The Moreno Valley Municipal Code (MVMC) Chapter 3.48, Western Riverside Multi-Species Habitat Conservation Plan Fee Program Ordinance , is a local development mitigation fee program to assist in preserving vegetation communities and natural areas within the City of Moreno Valley and western Riverside County, which are known to support threatened, endangered, or key sensitive populations of plant and wildlife species . Each development project to be constructed within the City is required to pay a local development mitigation fee (based on project acreage).

The MVMC Section 8.60.070, Imposition of Impact and Mitigation Fee , also requires development projects within the boundaries of the Stephens’ Kangaroo Rat HCP to pay an impact and mitigation fee of five hundred dollars ($500.00) per gross acre located within the parcel to be developed and the area disturbed by related off-site improvements.

MVMC Section 9.17.030(g), Heritage Trees, identifies heritage trees as any tree that defines the historical and cultural character of the City including older palm and olive trees, and/or any tree designated as such by official action. The MVMC prohibits any person from removing, destroying, or disfiguring a heritage tree within City limits. Removal of heritage trees designated historically and/or culturally significant by official action shall require review by the Environmental and Historic Preservation Board. The ordinance provides certain exceptions and exemptions from the heritage tree requirements. There are existing pa lm and olive trees adjacent to the Project area along Cottonwood Avenue that have the potential to be considered heritage trees.

4.4.3 BASIS FOR DETERMINING SIGNIFICANCE
The State Legislature has established it to be the policy of the State of California to “[p]revent the elimination of fish or wildlife species due to man’s activities, ensure that fish and wildlife populations do not drop below self-perpetuating levels, and preserve for future generations representations of all plant and animal communities...” (Public Resources Code Section 21001[c]). CEQA Guidelines Section 15065(a) establishes that a project may have a significant effect where: “The project has the potential to substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or wildlife community; reduce the number or restrict the range of an endangered, rare, or threatened species ...”

Appendix G of the CEQA Guidelines is more specific in addressing biological resources and encompasses a broader range of resources to be considered, including candidate, sensitive, or special- status species; riparian habitat or other sensitive natural communities; federally protected wetlands; fish and wildlife movement corridors; local policies or ordinances protecting biological resources; and adopted HCPs.

The City of Moreno Valley evaluates impacts to biological resources based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact to biological resources would occur if the Project or any Project-related component would:
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a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service;
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or US Fish and Wildlife Service;
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites;
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance;
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

4.4.4 IMPACT ANALYSIS
Threshold a: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? A. Direct Impact to Special-Status Plant Species
No special-status plant species were observed within the Project area by VCS during the biological surveys. However, the San Diego tarplant, a CRPR 4.2 species, has a moderate potential to occur within the Project area , which, if found within the Project area , would be complete ly disturbed with implementation of the Project . The CNPS recommends that CRPR 4.2 species be analyzed based on the following reasons (VCS 2025):
• The type locality of CRPR rank 4 plants;
• Occurrences at the periphery of a species’ range;
• Areas where the species is especially uncommon;
• Areas where the species has sustained heavy losses;
• Occurrences exhibiting unusual morphology or occurring on unusual substrates; • Species maintained on BLM, USFWS, or USFS sensitive species lists; and • Species associated with a habitat that is declining in California at a significant rate.

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The Project area is not on the periphery of the range of San Diego tarplant. Additionally, San Diego tarplant is relatively common in Riverside County. Based on the plant’s CRPR 4.2 status (watch list plant of limited distribution and “not very threatened in California [less than 20% of occurrences threatened/low degree and immediacy of threat or no current threats known/species frequently observed in the area]”) and its distribution within Riverside County, this species does not clearly meet CEQA standards and thresholds for impact consideration. Additionally, there is low or no potential for other special-status plant species to occur within the Project area . T herefore, no significant direct impacts to special-status plants are anticipated with Project implementation. Impacts would be less than significant.

B. Direct Impacts to Special -Status Wildlife Species
As previously discussed, one special-status species (Cooper’s hawk) was observed within the Project area during the June 2021 biological survey and two special-status species (BUOW and western mastiff bat) have the potential to occur within the Project area . Potential direct impacts to these species are discussed below. As discussed below, Crotch’s bumble bee is not expected to occur within the Project area.

1. Cooper’s Hawk
Cooper’s hawk was observed within the Project area and is a WL species by CDFW. WL species are species that were previously designated as a species of special concern but no longer merit that status or which do not yet meet the special species of concern criteria but there is a concern and need for additional information to clarify status. The most suitable habitat for the Cooper’s hawk in and adjacent to the Project area is limited to the trees along the northern portion of the Project area, which provide limited potential habitat for Cooper’s hawk. Implementation of the Project would include the removal of existing ornamental trees within the Project area ; thus, construction activities associated with the Project have the potential to result in a significant impact related to the Cooper’s hawk. Mitigation measure (MM) 4.4-1 requires the completion of pre-construction surveys and identifies actions to take if nesting avian species, including Cooper’s hawk, are present and would reduce this potential impact to a less than significant level.

2. Burrowing Owl
No BUOW or signs of BUOW use were observed within the Project area during the biological survey or during the four focused surveys . However, it is possible that the BUOW could migrate into the Project area prior to construction. The BUOW is classified by the MSHCP as a covered species not adequately conserved by the MSHCP; thus, construction activities associated with the Project have the potential to result in a significant impact related to the BUOW. MM 4.4-2 requires the completion of pre-construction BUOW surveys and habitat assessments and identifies actions to take if active BUOW burrows are present, including obtaining an ITP, if required, and would reduce this potential impact to a less than significant level.

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3. Western Mastiff Bat
No western mastiff bats or signs of western mastiff bat use were observed within the Project area during the biological survey; however, the Project area has marginal suitable day roosting habitat in the Project area (palm trees and Peruvian pepper trees). Implementation of the Project would include the removal of the existing trees within the Project area; thus, construction activities associated with the Project have the potential to result in a significant impact to the western mastiff bat . MM 4.4-3 requires the completion of pre-construction bat surveys and identifies actions to be taken if bat roosts are identified.

Implementation of MM 4.4-3 would reduce this potential impact to a less than significant level.

4. Crotch’s Bumble Bee
As previously discussed, while marginal potential would result from the existence of some rodent burrows, the significant distance to the nearest sighting, the lack of sufficient nectar sources, and the regular disturbance to both the Project area and the surrounding properties severely limits any potential for Crotch’s bumble bee to occupy the Project area . Impacts to this species are not anticipated as a result of the Project.

C. Indirect Impacts on Special-Status Biological Resources Development projects adjacent to natural open spaces have the potential to result in indirect effects to biological resources such as light pollution, noise pollution, non-native/ornamental plant invasion, etc.

The Project area is not adjacent to any natural open space areas and would not result in indirect impacts to such resources.

However, the Project has the potential to indirectly impact any western mastiff bats roosting in trees near the Project area due to increased noise levels during construction. Indirect impacts on the western mastiff bat are potentially significant and mitigation is required. MM 4.4-3 requires pre-construction surveys and includes measures to protect off-site roosting bats, if present. Implementation of MM 4.4- 3 would reduce this potential indirect impact to a less than significant level.

Threshold b: Wo
uld the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service?
As discussed previously, t he Project area does not contain riparian habitat or other sensitive natural communities identified in local or regional plans . Vegetation communities within the Project area contain disturbed/developed/ maintained grasslands (approximately 65.85 acres), and herbaceous non- native forbs and grasses habitat (approximately 4.42 acres). The direct removal of these vegetation communities, which are not sensitive communities identified in any local or regional plans, policies, regulations or by CDFW or USFWS , would not result in a significant impact. No impacts to riparian habitat or other sensitive natural communities would occur.

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Threshold c: Would the Project have substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? As discussed previously, no wetlands or features considered WOUS or WOS occur within the Project area. Therefore, the implementation of the Project would not impact any State - or federally-protected wetlands. No impact would occur.

Threshold d: Wo uld the Project i nterfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? As previously identified, t he Project area may play a role in local wildlife dispersal and foraging; however, the Project area is not located within a significant wildlife movement corridor. Common wildlife species may travel through the site and neighboring developed areas, but the site does not provide connectivity between large areas of open space on a local or regional scale. Additional ly, the Project area is not within an MSHCP criteria cell , core habitat, or wildlife movement corridor. The Project area lacks migratory wildlife linkages and there are no native wildlife nurseries in or adjacent to the Project area . Thus, the implementation of the Project would not impede the use of a native wildlife nursery site or interfere with the movement of native migratory fish or wildlife species.

The Project area and surrounding areas have the potential to support nesting birds and/or roosting bats.

The trees within the Project area provide habitat for tree nesting avian species while the herbaceous grassland habitats have potential to support ground nesting species. The palm trees in the northern portion of the Project area have the potential to support roosting bat species. Due to the potential for bird nesting and/or bat roosting within the Project area, Project construction could result in impacts to nesting birds which would be in violation of the MBTA and CFGC and/or result in potentially significant impacts to protected bat maternity roosts if construction activities are to take place during nesting or maternity roosting season. With implementation of MM 4.4 -1, MM 4.4-2, and MM 4.4-3, impacts to nesting birds and roosting bats would be reduced to a level considered less than significant.

Threshold e:

Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? MVMC Title 3, Chapter 3.48, Western Riverside County MSHCP Plan Fee , requires that a local development mitigation fee be paid to assist in the maintenance of biological diversity and the natural ecosystem processes that support this diversity so that the City is in compliance with the MSHCP. The Project Applicant would be required to pay this local mitigation fee to assist the City in implementing the Western Riverside County MSHCP reserve system (including the acquisition, management, and long-term mainten ance of sensitive habitat areas). With mandatory compliance with standard regulatory requirements (i.e., mitigation fee payment), the Project would not conflict with any City policies or ordinances related to the mitigation fee program associated with Western Riverside County MSHCP.
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The MVMC Chapter 8.60, Threatened and Endangered Species , also contains provisions for the protection of the Stephens’ Kangaroo Rat pursuant to the Stephens’ Kangaroo Rat HCP. The Project area is not located within an identified reserve area or critical habitat for the Stephens’ Kangaroo Rat and the species has a low potential to occur in the Project area. In addition, the species was not observed during biological surveys of the Project area. Accordingly, the Project is exempt from the focused survey requirements for the Stephens’ Kangaroo Rat established by the MVMC Section 8.60.060, Biological Surveys. The Project Applicant is required to contribute a local development impact and mitigation fee, which requires a fee payment to assist the City in implementing the habitat conservation plan for the Stephens’ Kangaroo Rat. With mandatory compliance with standard regulatory requirements (i.e., development impact and mitigation fee payment), the Project would not conflict with any City policies or ordinances related to the protection of the Stephens’ Kangaroo Rat.

The MVMC Section 9.17.030(g), Heritage Trees, identifies heritage trees as any tree that defines the historical and cultural character of the City including older palm and olive trees, and/or any tree designated as such by official action. There are existing palm and olive trees within the off-site improvement area along Cottonwood Avenue that have the potential to be considered heritage trees.

These trees would be removed to accommodate site -adjacent roadway improvements along Cottonwood Avenue; however, the tree removal would adhere to the City’s requirements for tree removal, including tree replacement. As discussed in Section 3.0, Project Description, trees would be planted along the on-site and site -adjacent roadways and within landscaped areas. Therefore, the Project would implement MM 4.4-4, which requires that a tree survey be prepared by a qualified arborist for the proposed regulated tree removals and ensures that tree removals would occur in accordance with the provisions of MVMC Section 9.17.030(g). With mandatory adherence to MVMC Section 9.17.030(g) and implementation of MM 4.4-4, the Project would not conflict with any City policies or ordinances related to tree protection.

With mandatory payment of fees and compliance with MVMC Section 9.17.030(g), as required by MM 4.4 -4 (described above ), the Project would not conflict with any local policies or ordinances protecting biological resources. This impact would be less than significant.

Threshold f: Wo
uld the Project c onflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The Project area is within the boundaries of the Western Riverside County MSHCP; however, the Project area is not within a Criteria Cell designated for conservation within the MSHCP. Additionally, the Project area is not within Public or Quasi-Public Conserved Lands, or the Narrow Endemic Plant Species, Amphibian, or Mammal Survey Areas listed by the MSHCP.

The Project area is within the BUOW Overlay of the MSHCP, which requires additional survey protocols. BUOW Surveys were conducted according to MSHCP requirements in August 2021. No BUOW or signs thereof were identified during the focused surveys; therefore, BUOW were considered absent from the Project area. Notwithstanding, the Project area has suitable habitat for BUOW; thus, ■■
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construction activities associated with the Project have the potential to result in a substantial adverse effect on the BUOW . As identified under Threshold a, i mpacts are potentially significant and mitigation is required. With implementation of MM 4.4-1, potential impacts to BUOW would be reduced to a less than significant level.

There are no features within the Project area that would be considered Riverine/Riparian by the MSHCP. Additionally, there are no vernal pools or depressions, such as road ruts, that would provide suitable habitat for fairy shrimp species within the Project area . Thus, the Project would not conflict with MSHCP requirements related to Riverine/Riparian habitat. No impact would occur.

The MSHCP Volume 1, Appendix C outlines standard best management practices (BMPs) intended in part to reduce impacts to plant communities, special-status plant and wildlife species, and jurisdictional waters. As the Project is located within the MSHCP boundary, adherence with applicable standard BMPs found in Appendix C of the MSHCP is required; therefore, the Project would comply with the following BMPs applicable to the Project, which are based on the standard MSHCP BMPs, and would be included as conditions of approval for the Project:

1. A condition shall be placed on grading permits requiring a qualified biologist to conduct a training session for project personnel prior to grading. The training shall include a description of the species of concern and its habitats, the general provisions of the Endangered Species Act (Act) and the MSHCP, the need to adhere to the provisions of the Act and the MSHCP, the penalties associated with violating the provisions of the Act, the general measures that are being implemented to conserve the species of concern as they relate to the project, and the access routes to and Project Footprint boundaries within which the project activities must be accomplished.

2. Water pollution and erosion control plans shall be developed and implemented in accordance with RWQCB requirements.

3. The footprint of disturbance shall be minimized to the maximum extent feasible. Access to sites shall be via pre-existing access routes to the greatest extent possible.

4. To avoid attracting predators of the species of concern, the Project Footprint shall be kept as clean of debris as possible. All food related trash items shall be enclosed in sealed containers and regularly removed from the site(s).

5. Construction employees shall strictly limit their activities, vehicles, equipment, and construction materials to the proposed project footprint and designated staging areas and routes of travel. The construction area(s) shall be the minimal area necessary to complete the project and shall be specified in the construction plans. Construction limits will be fenced with orange snow screen. Exclusion fencing should be maintained until the completion of all construction activities. Employees shall be instructed that their activities are restricted to the construction areas.

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The Project area is within the boundaries of the Stephens’ Kangaroo Rat HCP, which requires a fee be paid for local development . As discussed under Threshold e, i n accordance with the Stephens’ Kangaroo Rat HCP and MVMC Chapter 8.60, the Project Applicant would pay applicable local development impact and mitigation fees. With the payment of applicable fees, the Project would not conflict with the Stephens’ Kangaroo Rat HCP. Impacts would be less than significant.

4.4.5 CUMULATIVE IMPACT ANALYSIS
This cumulative impact analysis for biological resources considers development of the Project area in conjunction with other development projects in the vicinity of the Project area as well as full General Plan buildout in the City of Moreno Valley and other jurisdictions in the region within the boundaries of the Western Riverside County MSHCP.

Anticipated cumulative impacts to biological resources are addressed by the Western Riverside County MSHCP, which, as currently adopted, addresses 146 “Covered Species” that represent a broad range of habitats and geographical areas within western Riverside County, including threatened and endangered species and regionally- or locally-sensitive species that have specific habitat requirements and conservation and management needs. The MSHCP addresses biological impacts for take of Covered Species within the MSHCP area. Impacts to Covered Species and establishment and implementation of a regional conservation strategy and other measures included in the MSHCP are intended to address the federal, State, and local mitigation requirements for these species and their habitats. Specifically, Section 4.4 of the MSHCP states that:

The MSHCP was specifically designed to cover a large geographical area so that it would protect numerous endangered species and habitats throughout the region. It is the projected cumulative effect of future development that has required the preparation and implementation of the MSHCP to protect multiple habitats and multiple endangered species.

CEQA deems a cumulative impact analysis to be adequate if a list of “related projects” is included in the EIR or the proposed project is consistent with an adopted general, specific, master, or comparable programmatic plan (CEQA Guidelines Section 15130[b][1][B]). CEQA also states that no further cumulative impact analysis is necessary for impacts of a proposed project consistent with an adopted general, specific, master, or comparable programmatic plan (CEQA Guidelines Section 15130[d]). The Project site has been anticipated for development by the City of Moreno Valley. Additionally, the Western Riverside Count y MSHCP has set aside areas for conservation in order to address the cumulative impact of development within Riverside County. The Project is consistent with the MSHCP and the Project Applicant would pay the local development impact fees to assist the City in implementing the Western Riverside County MSHCP reserve system (including the acquisition, management, and long- term maintenance of sensitive habitat areas). T he 2040 General Plan EIR concluded that cumulative impacts to biological resources would be less than significant . Therefore, the Project , which would result in less than significant impacts to biological resources after implementation of mitigation, would not contribute to a substantial adverse cumulatively considerable impact to biological resources.
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The Project would not result in significant impacts to any special-status plant species. The San Diego tarplant, a CRPR 4.2 species, has a moderate potential to occur within the Project area ; however, the San Diego tarplant was not observed on the Project area. Additionally, San Diego tarplant is relatively common in Riverside County and this species does not clearly meet CEQA standards and thresholds for impact consideration. Therefore, implementation of the Project would not contribute to a substantial adverse cumulatively considerable impact to special-status plant species.

The Project area does not contain any sensitive or critical habitat or State- or federally-protected wetlands, and is not within a wildlife movement corridor. Therefore, the Project would not contribute to a cumulatively considerable impact on these biological resources.

The Project would result in the removal of vegetation that has the potential to support nesting avian species and roosting bats. A wide range of habitat and vegetation types have the potential to support nesting avian species and roosting bats ; therefore, it is likely that other development projects within the cumulative study area also may impact nesting avian species and roosting bats . However, the Project, like all other development activities in the cumulative study area, would be required to comply with State and federal law to preclude impacts to nesting birds . Therefore, the Project would not contribute to a cumulatively considerable impact on these biological resources.

The Project would not conflict with any local policies or ordinances protecting biological resources .

Other development projects in the cumulative study area would be required to comply with applicable local policies and/or ordinances related to the protection of biological resources as a standard condition of review/approval . Because the Project and cumulative development would be prohibited from violating applicable local policies or ordinances related to the protection of biological resources, a cumulatively considerable impact would not occur.

4.4.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Potentially Significant Impact. No sensitive plant species were detected within the Project area and potential impacts to the San Diego tarplant, a CRPR 4.2 species, would be less than significant.

O
ne special-status species (Cooper’s hawk) was observed within the Project area during the biological survey and has a low potential to nest in the trees within the Project area. The Project area has suitable foraging and nesting habitat for BUOW and roosting habitat for the western mastiff bat. Construction activities also have the potential to result in indirect noise impacts to roosting wester n mastiff bats in trees near the Project area. If any of these species, active nests, or roosts are present within the Project area during construction, impacts to the biological resources would be potentially significant.

Threshold b: N o Impact. The Project area does not contain any riparian habitat, critical habitat, or other sensitive natural communities. T herefore, the Project would have no impacts to these biological resources.

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Threshold c: No Impact. The Project area does not contain State- or federally-protected wetlands; therefore, no impact would occur.

Threshold d: P otentially Significant Impact. The Project would not interfere with the movement of fish or impede the use of a native wildlife nursery site; however, construction activities could result in impacts to nesting avian species, which would be in violation of the MBTA and CFGC and/or would result in impacts to protected bat maternity roosts if construction activities are to take place during nesting or maternity roosting season.

Threshold e: L ess than Significant Impact. The Project would comply with MVMC Chapter 3.48 and Chapter 8.60, which require fee payments for the MSHCP and protection of the Stephens’ Kangaroo Rat. In addition, the Project would comply with MVMC Section 9.17.030(g), as applicable, with regards to tree protection (compliance with this requirement is ensured with implementation of MM

4.4-4). The Project would not conflict with any local policies or ordinances protecting biological resources.

Threshold f: P otentially Significant Impact. The Project area is subject to the Western Riverside County MSHCP and its survey requirements for the BUOW . Although the Project is compliant with all applicable MSHCP provisions, and given the BUOW was not observed during the biological survey or focused surveys, the Project area has suitable habitat for the species. If the species migrates within the Project area and is present at the time the grading permit is issued, impacts on BUOW would be potentially significant.

4.4.7 MITIGATION
MM 4.4-1 Prior to the issuance of grading permits, the Property Owner/Developer shall provide the City with proof of retention of a qualified biologist to implement this mitigation measure. If the removal of any trees, shrubs, or any other potential nesting and foraging habitat for avian species, including sensitive species and raptor nests, is to be conducted within the nesting season (September 1 to February 14 for songbirds; September 1 to January 14 for raptors), a nesting bird survey shall be required within three days prior to start of work. If active nests are identified, the biologist will establish appropriate buffers around the area (typically 500 feet for raptors and sensitive species, and 200 feet for non-raptors/non-sensitive species). All work within these buffers will be halted until the nesting effort is finished (i.e., the juveniles are surviving independent from the nest). The on-site biologist will review and verify compliance with these nesting boundaries and verify the nesting effort has finished. Work can resume within the buffer area when no other active nests are found. Alternatively, a qualified biologist may determine that certain work can be permitted within the buffer areas and develop a monitoring plan to prevent any impacts while the nest continues to be active (eggs, chicks, etc.). If vegetation clearing is not initiated within 72 hours of a negative survey during nesting season, the nesting survey must be repeated to confirm the absence of ■■
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nesting birds. If vegetation removal occurs outside of nesting season or if no nesting birds are found, no further action will be required.

MM 4.4-2 Prior to the issuance of grading permits, the Property Owner/Developer shall provide the City with proof of retention of a qualified biologist to implement this mitigation measure. A pre-construction presence/absence survey for BUOW within the Project area where suitable habitat is present shall be conducted by a qualified biologist within 30 days prior to the commencement of ground-disturbing activities. If active BUOW burrows are detected during the breeding season, all work within an appropriate buffer (typically a minimum of 300 feet) of any active burrow will be halted. If there is an active nest at the burrow, work will not proceed within the buffer until that nesting effort is finished. The on- site biologist will review and verify compliance with these boundaries and will verify the nesting effort has finished. Work can resume in the buffer when there are no occupied/active BUOW burrows found within the buffer area.

If there are occupied burrows within the buffer area and avoidance of burrowing owls is not possible, no work shall occur within the buffer area until the appropriate course of action is determined and implemented in accordance with applicable regulations related to burrowing owl at the time of project construction. CDFW may require an Incidental Take Permit (ITP) or a Burrowing Owl Relocation and Mitigation Plan, in accordance with applicable regulations at the time of project construction. If burrowing owl is no longer a candidate or listed species under CESA at the time of project construction, permits shall not be required.

MM 4.4-3 Prior to the issuance of grading permits, the Property Owner/Developer shall provide the City with proof of retention of a qualified biologist to implement this mitigation measure. Pre-construction surveys shall be conducted by a qualified bat biologist no more than 30 days prior to the initiation of vegetation removal and ground-disturbing activities if within the maternity season (March 1 to August 31). If no active roosts are present, then trees shall be removed within two weeks following the survey. If active bat roosts are found, then then the following shall be implemented, as appropriate:

a. If active bat roosts are present, a qualified bat biologist shall determine the species of bats present and the type of roost (i.e., day roost, night roost, maternity roost). If the biologist determines that the roosting bats are not a special‐status species and the roost is not being used as a maternity roost and direct removal of active roosts is required, then the bats may be evicted from the roost by a qualified bat biologist experienced in developing and implementing bat mitigation and exclusion plans. If special-status bat species or a maternity roost of any bat species is present, but no direct removal of active roosts will occur, a qualified bat biologist shall determine appropriate avoidance measures, which may include implementation of a construction-free buffer around the active roost.
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Moreno Valley City CouncilJune 3, 2025

Moreno Valley City Council
June 3, 2025