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

b. If special-status bat species or a maternity roost of any bat species is present and direct removal of habitat (roost location) will occur, then a qualified bat biologist experienced in developing bat mitigation and exclusion plans shall develop a mitigation plan to compensate for the lost roost site. Removal of the roost shall only occur when bats are not present in the roost. The mitigation plan shall detail the methods of excluding bats from the roost and the plans for a replacement roost in the vicinity of the project site. The plan shall include:
(1) a description of the species targeted for mitigation; (2) a description of the existing roost or roost sites; (3) methods to be used to exclude the bats if necessary; (4) methods to be used to secure the existing roost site to prevent its reuse prior to removal; (5) the location for a replacement roost structure; (6) design details for the construction of the replacement roost; (7) monitoring protocols for assessing replacement roost use; (8) a schedule for excluding bats, demolishing of the existing roost, and construction of the replacement roost; and (9) contingency measures to be implemented if the replacement roosts do not function as designed.
c. All potential roost trees shall be removed in a manner approved by a qualified bat biologist, which may include presence of a biological monitor. d. All construction activity in the vicinity of an active maternity roost shall be limited to daylight hours.
e. Results of the survey shall be submitted to the City prior to removal of the trees.

If additional measures are required under (a) through (d), the submittal to the City will include those additional measures.

MM 4.4-4 Prior to any removal of trees potential ly regulated by the City of Moreno Valley Municipal Code, a qualified arborist shall conduct a tree survey in the area of the Project site in which regulated trees are proposed to be removed. Dat a to be collected on appropriate data forms include s the exact location of the tree, species, diameter at breast height, and information on the general character and health of the tree. All regulated trees to be removed shall be flagged in the field and entered into a GIS database. This information shall be included in an arborist report to be submitted to the City.

Pursuant to Section 9.17.03 of the City of Moreno Valley Municipal Code, the removal of existing trees with four-inch or greater trunk diameters at breast heigh (dbh) shall be replaced at a 3:1 ratio, with a minimum 24-inch box size tree of the same species or a minimum 36-inch box for a 1:1 replacement, in locations approved by the City.

4.4.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Thresholds a, d, and f : Less than Significant Impact with Mitigation. Implementation of MM 4.4 -1 would ensure that a survey for nesting avian species be conducted if any removal of trees, shrubs, or any other potential nesting and foraging habitat for avian species occurs during the nesting season (September 1 to February 14 for songbirds; September 1 to January 14 for raptors ). If present, the ■■
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mitigation measure provides performance criteria that requires avoidance of active nests. With implementation of the required mitigation, potential to impact nesting avian species would be reduced to a level considered less than significant.

Implementation of MM 4.4-2 would ensure that pre-construction surveys are conducted for BUOW to determine the presence or absence of the species in the Project area. If present, the mitigation measure provides performance criteria that require compliance with the MSHCP and CESA, and avoidance of BUOW in accordance with CDFW protocol. With implementation of the required mitigation, potential impacts to BUOW would be reduced to a level considered less than significant.

Implementation of MM 4.4 -2 ensures that pre-construction surveys are conducted to determine the presence or absence of active roosts within the Project area. With implementation of the required mitigation, potential impacts to the sensitive bat species and active bat roosts would be reduced to a level considered less than significant.
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4.5 CULTURAL RESOURCES
The analysis in this section is based, primarily, on the Phase I Cultural Resources Assessment for the Moreno Valley Town Center Project (Cultural Resources Assessment) prepared by VCS Environmental (VCS) (VCS, 2024). The Cultural Resources A ssessment is included as Technical Appendix D to this EIR. Under existing law, environmental documents must not include information about the location of archaeological sites or sacred lands or any other information that is exempt from public disclosure pursuant to the Public Records Act (California Code of Regulations Section 15120[d]). Accordingly, confidential information was redacted from Techncial Appendix D for purposes of public review.

4.5.1 EXISTING CONDITIONS
The following is a summary of information presented in the Cultural Resources Assessment regarding the prehistory and ethnography of California and the region, the history of California and the City of Moreno Valley (City), and the Project area (including the Project site and off-site improvement areas).

A. Prehistoric Cultural Resources
The Project area is within the Western Riverside County region. The prehistory of Western Riverside County is understood as the transition area between coastal and desert subsistence patterns. The following chronology describes cultural traits in the southern California Bight (extending from Point Conception to the Mexican border), from ocean to desert. Refer to the Cultural Resources Assessment in EIR Technical Appendix D for a detailed discussion of each prehistoric cultural period. • Early Holocene (11,600 – 7,600 Before Present [BP] ). California’s first inhabitants have traditionally been thought of as big game hunters who lived at the end of the last ice -age. As the environment warmed and dried, the large Ice Age fauna vanished, marking the end of the Western Pluvial Lakes Tradition ( WPLT) characterized by large pluvial (rainfall-fed) lakes, streams, marshes, and grasslands exploited by native populations whose sites are generally found along their shores. Populations responded by exploiting a much wider range of flora and fauna to rep lace the large mammals. The Paleocoastal Tradition (PCT) reflects a coastal adaptation of the WPLT. PCT sites are also located along bays and estuaries, exploiting mollusks, sea mammals, sea birds, and fish in addition to land plants and animals. Habitation on San Miguel Island has been identified as early as approximately11,300 BP at Daisy Cave and approximately 8,500 BP at Eel Point on San Clemente Island. • Middle Holocene (7,600 – 3,650 BP). The Middle Holocene has been thought of as a time of cultural change where Early Holocene cultures morphed over time into the Late Holocene cultures. This “Millingstone Horizon” in coastal southern California suggests a shift in subsistence strategies - to the gathering and processing of plant seeds, grasses, and shellfish as the primary dietary staple, with fishing and the hunting of smaller animals playing a less important role. Characteristics of the middle Holocene sites include ground stone artifacts (manos and metates) used for processing plant material and shellfish, flexed burial beneath rock or milling stone cairns, flaked core or cobble tools, dart points, cogstones, discoidals, and crescentics.
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• Late Holocene (3,650 – 233 BP). Traditional models of this period maintained that the cultural systems encountered by European explorers in the late 18th century were formed during this time. These cultures were said to have access to rich resources (particularly the acorn), invented the bow and arrow, the mortar and pestle, introduced ceramics, and altered mortuary behaviors from inhumations to cremations. These groups were often elevated to utopian levels by earlier researchers. This period is now also revealed to have been one of more complex local and regional patterns of change that occurred at differing times within the region. Cultures in southern California over- exploited high-ranked food items such as shellfish, fish, terrestrial and marine mammals, and plant remains. This, and climatic fluctuations, led to resource depression, which necessitated a shift to less desirable, more costly resources. The “Takic Wedge” migration of Takic speakers from the Great Basin into southern California occurred during this period.

B. Ethnography
The Project area is within or near the traditional territory of the Luiseño, Cahuilla, and Gabrielino. This area was likely occupied or at least visited by all three tribes.

1. Luiseño
The Luiseño are Takic speakers and are descended from Late Prehistoric populations of the region.

Takic is part of the larger Uto-Aztecan language stock which migrated west from the Great Basin. The Luiseño lived in sedentary and independent village groups, each with specific subsistence territories encompassing hunting, food gathering, and fishing areas. Villages were usually located in valley basins, along creeks and streams adjacent to mountain ranges where water was available and where the villages would be protected from environmental conditions and potential enemies. Most inland populations had access to fishing and food-gathering sites on the coast.

Luiseño economic and subsistence practices centered upon the seasonal gathering of acorns and seeds; the hunting of deer and small mammals such as rabbits, wood rats, ground squirrels, and birds. Coastal foods included sea mammals, fish, and shellfish. Tool technologies were organized around food collection, storage, and preparation strategies, which was reflected in the type, size, and quantity of food items gathered. Stone (lithic) tools included two types: ground stone and flaked stone tools.

Utilitarian tools were constructed from wood, animal bones, skins, and/or woven from flora materials depending on need. Hunting activities were conducted both on an individual basis and/or organized into group activities, depending on seasonal factors and the game hunted. Acorns encompassed as much as 50% of the Luiseño diet, and acorn collection was a central tenant in the lives of the Luiseños and dominated their economic and social structure.

Villages were organized around an inherited chief who exerted sole control over the economy, religious rituals, and territorial matters within the village. The chief at times would consult with a council of elders and shamans on matters of religious practices and on environmental conditions affecting village life. Large villages may have had a complex behavioral and political structure due to their territorial size and economic control, while the smaller villages’ political complexity was limited by their territorial size.

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2. Cahuilla
The Cahuilla are an ethnographic Native American group descended from Late Prehistoric Takic - speaking inhabitants of the region. The Cahuilla were hunter-gatherers who followed a seasonal round of utilizing various floral and faunal resources occurring in their territory. Because Cahuilla territory was comprised of high mountains and arid lowlands, their seasonal round has been characterized as vertical rather than horizontal, with people moving upward and downward in layers of ecological zones ordered by elevation. Settled villages were located near reliable water sources and within range of various resources (food, wood for fuel, and lithic materials for tools). Each village was composed of a group of individuals that were related by blood or marriage, and which retained its own specific hunting and resource collecting areas. Cahuilla lineage groups were linked together in a complex interaction sphere of trade, alliance, intermarriage, and ceremonial exchange with neighboring groups including the Luiseño.

Major villages were fully occupied during winter, but during other seasons, task groups headed out in periodic forays to collect available plant foods, with larger groupings from several villages organizing for annual acorn harvests . Major plant foods emphasized during late prehistory included acorns, mesquite, screwbean, pinyon nuts, and various seed-producing legumes that were complemented by agave, wild fruits and berries, tubers, cactus bulbs, roots, and greens. Hunting was accomplished with the throwing stick and bow and arrow; nets and traps were also used for small animals . Stone tools consisted of two general types: ground stone tools (e.g., mortars, pestles, manos, and metates for pounding and grinding) and flaked stone tools (e.g., knives, drills, and projectile points for cutting and piercing). Ground stone tools were typically made from granite or other coarse stone. Flaked stone tools were typically made from chert, jasper, basalt, quartz, quartzite, obsidian, and other fine-grained stone in which breakage patterns could be controlled and sharp edges would result.

3. Gabrielino/Tongva/Kizh
At the time of European contact in 1769, when Gaspar de Portolá’s expedition crossed the Los Angeles Basin, what were to be named the Gabrielino Native Americans by the Spanish occupied the area to the west of the Project area. While the term Gabrielino identifies those Native Americans who were under the control of the Spanish Mission San Gabriel Archángel, the overwhelming number of people in these areas were of the same ethnic nationality and language (Takic) group. Their territory extended from northern Orange County north to the San Fernando Valley in Los Angeles County and eastward to the San Bernardino area.

This and the following ethnographic information relate to currently surviving native peoples still living in Los Angeles, Orange, San Bernardino, and Riverside Counties. They maintain their cultural practices and customs. The current Gabrielino Tribe comprises at least five bands that are recognized Tribes by the State of California (they do not, however, enjoy Federal recognition). They include the Gabrieleño Band of Mission Indians – Kizh Nation; the Gabrielino Tongva Indians of California Tribal Council; the Gabrieleno-Tongva San Gabriel Band of Mission Indians; the Gabrielino-Tongva Tribe; and the Gabrielino/Tongva Nation. The terms the Native Americans in Southern California used to identify themselves have, for the most part, been lost; therefore, the names do not necessarily identify ■■
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specific ethnic or Tribal groups. Some currently refer to themselves as Tongva, while others prefer the term Kizh. For the sake of clarity and consistency, the term Gabrielino will be used for the remainder of this section.

As described above, from an archaeological perspective, the Gabrielino arrived in the Los Angeles Basin possibly as early as 1,500 BCE as part of the so-called Shoshonean (Takic speaking) Wedge from the Great Basin region. The Gabrielino gradually displaced the indigenous peoples, who were probably Hokan speakers. Large, permanent villages were established in the fertile lowlands along rivers and streams and in sheltered areas along the coast. Eventually, Gabrielino territory encompassed the greater Los Angeles Basin, coastal regions from Topanga Canyon in the north to perhaps as far south as Aliso Creek, and the islands of San Clemente, San Nicholas, and Santa Catalina. Recent studies suggest the population may have numbered as many as 10,000 individuals at their peak in the Precontact Period.

C. History
In California, the historic era is generally divided into three periods: the Spanish or Mission Period, the Mexican or Rancho Period, and the American Period. These historic eras are described below .

Refer to the Cultural Resources Assessment in EIR Technical Appendix D for a detailed discussion of each historic era.
• Spanish/Mission Period (1769 to 1821). The Spanish Period is represented by exploration of the region; establishment of the San Diego Presidio and missions at San Gabriel and San Luis Rey; and the introduction of livestock, agricultural goods, and European architecture and construction techniques. Early exploration of the Riverside County area began in 1772, and permanent settlement began about the turn of the century through the issuance of land grants and grazing permits, and Spanish influence continued to some extent after 1821 due to the continued implementation of the mission system.
• Mexican/Rancho Period (1821 to 1848). The Mexican Period began with Mexican independence from Spain and continued until the end of the Mexican American War. The Secularization Act resulted in the transfer, through land grants (called ranchos) of large mission tracts to politically prominent individuals. Sixteen ranchos were granted in Riverside County, the first to Juan Bandini in 1838. The Project area is located in what was the Rancho La Laguna, also known as Laguna Grande and La Laguna de Temecula. The r ancho consisted of three leagues that included the lakebed and the shoreline. At that time, cattle ranching was a more substantial business than agricultural activities, and trade in hides and tallow increased during the early portion of this period. Until the Gold Rush of 1849, livestock and horticulture dominated California's economy.
• American Period (1848 to present). The American Period began with the Treaty of Guadalupe Hidalgo, and in 1850, California was accepted into the Union of the United States primarily due to the population increase created by the Gold Rush of 1849. The cattle industry reached its greatest prosperity during the first years of the American Period. Mexican Period land grants had created large pastoral estates in California, and demand for beef during the Gold Rush led to a cattle boom that lasted from 1849–1855. However, beginning about 1855, the demand for beef began to decline due to imports of sheep from New Mexico and cattle from the Mississippi ■■
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and Missouri Valleys. When the beef market collapsed, many California ranchers lost their ranchos through foreclosure. A series of disastrous floods in 1861–1862, followed by two years of extreme drought, which continued to some extent until 1876, altered ranching forever in the southern California area.

The Moreno Valley area began to develop in the late 1880s with the establishment of the Alessandro and Moreno settlements. The community of Moreno was built around the intersection of Redlands Boulevard and Alessandro Boulevard and named in honor of Frank Brown (Moreno in Spanish), a civil engineer, who had visions of a successful agricultural community like he had established in Redlands to the north of the Valley. The Alessandro Aviation Field was established in 1918 and then renamed to March Field. March Field closed in 1922 after World War I (WWI) and re-opened in 1927 as a flight training school. The name was changed to March Air Force Base in 1948. The unincorporated community of Sunnymead was established in 1922 and was followed by the unincorporated community of Edgemont in 1940. The development of March Air Force Base post-WWII aided in the continued growth of Edgemont and Sunnymead. The Eastern Municipal Water District began to supply water to the Valley in 1954. The dam at Lake Perris was completed in 1970. In 1984, the communities of Edgemont, Sunnymead, and Moreno came together to form the City of Moreno Valley, and the first general plan was adopted in 1986 to guide future growth and development . (City of Moreno Valley, 2021a)
1 D. Project Area
VCS conducted an archaeological records search through the Eastern Information Center (EIC) at the University of California, Riverside (UCR) on August 19, 2021. The records search provided data on known archaeological and built environment resources as well as previous studies within one-half mile of the Project area. The results of the EIC records search notes that 18 cultural resources studies were completed within one -half mile of the Project area and one of those studies (RI-02171) included a portion of the Project area. Additionally, the EIC information notes that 14 cultural resources were recorded within one-half mile of the Project area. Eight prehistoric milling slicks are recorded within one-half mile of the Project area, attesting to the prehistoric presence of indigenous populations in the vicinity.

The Pechanga Cultural Resources Department provided additional information regarding cultural resources within one mile of the Project area. This list includes 13 prehistoric and 3 historic -era resources.

One historic resource (P -33-007277) was recorded within the Project area . Historic resource site number P-33-007277 was the Mellor House, which is recorded at 26960 Alessandro Boulevard, in the extreme southeast corner of the Project area. The Mellor House was built by the Mellor family around 1915 and was a good example of rural architecture in the Sunnymead area, but the house has since been removed. The Mellor House exhibited a vernacular wood frame house, rectangular in plain view, with wood shingle siding. Tall, shade pepper trees associated with the house remain in the Project area

1 The cultural resources information provided in the City of Moreno Valley General Plan 2040 (2040 General Plan) remains applicable to the discussion of the City’s history. The court decision did not address this topical issue. ■■
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in the southeast corner near the intersection of Alessandro Boulevard and Nason Street. These trees are not considered a significant resource because the house with which these non-native trees are associated has been removed and the integrity of the resource destroyed.

VCS conducted a pedestrian survey of the Project area on June 29, 2021. The pedestrian survey utilized transects spaced approximately 10 to 15 meters apart and the entire Project area was examined for the presence of cultural resources. The southeast corner of the property has a large mound of fill sediment/soil placed there sometime after 1978 and before 1997. The site has been subjected to various episodes of dumping (furniture, appliances, and other trash), especially in the southeast corner of the site. A light scatter of trash is present along the margins of the site, especially along the south ern and eastern borders. No other cultural resources were observed. No prehistoric resource sites were identified on the Project area during the pedestrian survey. (VCS, 2024)

4.5.2 REGULATORY SETTING
Following is a summary of federal, S tate, and local regulations addressing cultural resources .

Regulations addressing tribal cultural resources are addressed in EIR Section 4.17, Tribal Cultural Resources.

A. Federal Plans, Policies, and Regulations

1. National Historic Preservation Act
The National Historic Preservation Act (NHPA) of 1966, as amended, promotes the preservation, enhancement, and productive use of historic resources. The NHPA established the Advisory Council on Historic Preservation (ACHP) and provided procedures for the ACHP and federal agencies in promoting historic preservation. Section 106 of the NHPA requires that federal actions and the use of federal funds take into account their potential effects on historic properties or those listed in or eligible for listing in the National Register of Historic Places (NRHP).

2. National Register of Historic Places (NRHP)
The NRHP is the official list of the Nation's historic places worthy of preservation. Authorized by the NHPA of 1966, the NPS’s NRHP is part of a national program to coordinate and support public and private efforts to identify, evaluate, and protect America's historic and archaeological resources. To be considered eligible, a property must meet the National Register Criteria for Evaluation. This involves examining the property’s age, integrity, and significance, as follows:
1) Age and Integrity. Is the property old enough to be considered historic (generally at least 50 years old) and does it still look much the way it did in the past? 2) Significance. Is the property associated with events, activities, or developments that were important in the past? With the lives of people who were important in the past? With significant architectural history, landscape history, or engineering achievements ? Does it have the potential to yield information through archaeological investigation about our past?

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B. State Plans, Policies, and Regulations

1. California Code of Regulations, Title 14, Division 3, Section 4308 Section 4308, Archaeological Features , of Title 14 of the California Code of Regulations provides that: “No person shall remove, injure, disfigure, deface, or destroy any object of archaeological, or historical interest or value.”

2. California Code of Regulations, Title 14, Section 1427 California Code of Regulations , Title 14, Section 1427 provides that: “ No person shall collect or remove any object or thing of archaeological or historical interest or value, nor shall any person injure, disfigure, deface or destroy the physical site, location or context in which the object or thing of archaeological or historical interest or value is found.”

3. California Register of Historic Resources
The State Historical Resources Commission has designed the California Register of Historic Resources (CRHR) for use by state and local agencies, private groups, and citizens to identify, evaluate, register, and protect California’s historical resources. The CRHR is the authoritative guide to the state's significant historical and archaeological resources . The CRHR encourages public recognition and protection of resources of architectural, historical, archaeological, and cultural significance; identifies historical resources for state and local planning purposes; determines eligibility for state historic preservation grant funding; and affords certain protections under CEQA. In order for a resource to be included on the CRHR, the resources must meet one of the following criteria:
1) Associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States (Criterion 1). 2) Associated with the lives of persons important to local, California or national history (Criterion 2).
3) Embodies the distinctive characteristics of a type, period, region, or method of construction or represents the work of a master or possesses high artistic values (Criterion 3). 4) Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation (Criterion 4).

Historical resources eligible for listing in the CRHR must also retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. For resources included on the CRHR, environmental review may be required under CEQA if property is threatened by a project.

4. California Health and Safety Code (Sections 7050.5, 7051, and 7054) These sections of the California Health and Safety Code collectively address the illegality of interference with human burial remains (except as allowed under applicable sections of the California Public Resources Code [PRC]). These sections also address the disposition of Native American burials ■■
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in archaeological sites and protect such remains from disturbance, vandalism, or inadvertent destruction. Procedures to be implemented are established for (1) the discovery of Native American skeletal remains during construction of a project; (2) the treatment of the remains prior to, during, and after evaluation; and (3) reburial.

Section 7050.5 of the California Health and Safety Code specifically provides for the disposition of accidentally discovered human remains. Section 7050.5 states that, if human remains are found, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined the appropriate treatment and disposition of the human remains.

5. California Public Resources Code Section 5097.8
As identified in Section 15064.5(d) of the CEQA Guidelines, when the existence of, or the probable likelihood, of Native American human remains within the project is identified, a lead agency is required to work with the appropriate Native Americans as identified by the Native American Heritage Commission (NAHC) as provided in PRC Section 5097.98. PRC Section 5097.98 states that, if remains are determined by the Coroner to be of Native American origin, the Coroner must notify the NAHC within 24 hours. When the NAHC receives notification of a discovery of Native American human remains from a County Coroner, it shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permiss ion of the owner of the land, or his or her authorized representative, inspect the site of the discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. This regulation also requires that, upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human re mains are located, is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the most likely descendants regarding their recommendations and all reasonable options regarding the descendants' preferences for treatment. This section of the PRC has been incorporated into Section 15064.5(e) of the CEQA Guidelines.

6. California Code of Regulations Section 15064.5
California Code of Regulations , Title 14, Chapter 3, Section 15064.5 (the State CEQA Guidelines) establishes the procedure for determining the significance of impacts to archa eological and historical resources, as well as classifying the type of resource. Cultural resources are aspects of the environment that require identification and assessment for potential significance . The evaluation of cultural resources under CEQA is based upon the definitions of resources provided in CEQA Guidelines Section 15064.5, as follows:
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1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 4850 et seq.).
2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 4852) including the following:

A. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
B. Is associated with the lives of persons important in our past; C. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
D. Has yielded, or may be likely to yield, information important in prehistory or history. 4) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code sections 5020.1(j) or 5024.1.

C. Local Plan, Policies, and Regulations

1. Moreno Valley General Plan
The current City of Moreno Valley General Plan (2006 General Plan) was adopted on July 11, 2006.

As further addressed in EIR Section 4.11, Land Use and Planning, the General Plan Conservation Element includes policies addressing cultural resources. The Project’s consistency with these policies is discussed in Table 4.11-1, General Plan Consistency Analysis.

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2. Moreno Valley Municipal Code (MVMC)
MVMC Title 7, Cultural Preservation, promotes public health, safety, and general welfare by providing for the preservation, identification, protection, enhancement , and perpetuation of existing improvements, buildings, structures, signs, objects, features, sites, places, areas, districts, neighborhoods, streets , and natural features having special cultural, historical, archaeological, architectural, or community value in the City. Per Chapters 7.05, Landmarks and Structures of Merit, and 7.07, Preservation Districts and Neighborhood Conservation Areas , of the MVMC, landmarks and structures of merit can be designated by a committee or by the City Council on appeal. Section

7.09.010, Permit Required, of the MVMC requires a permit to restore, rehabilitate, alter, develop, construct, demolish, remove, or change the appearance of any landmark, landmark structure, landmark site, or any structure or site within a preservation district.

4.5.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts to cultural resources based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact to cultural resources would occur if the Project or any Project-related component would:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5;
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5;
c) Disturb any human remains, including those interred outside of formal cemeteries.

4.5.4 IMPACT ANALYSIS
Threshold a : Would the Project c ause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5
PRC Sections 21084.1, 21084.2, and 5020.1(q) state that a project that may cause a substantial adverse change (i.e., demolition, destruction, relocation, or alteration such that the significance of a historical resource would be impaired) in the significance of a “historical resource” is a project that may have a significant effect on the environment. Currently, there are no structures located within the Project area.

The southeast portion of the Project area was previously developed with a rural residential structure, the Mellor House (P-33-007277), that was recorded as a historic site. However, the Mellor House was previously removed. Soil has been stockpiled at the location of the former on-site structure. Pepper trees related to the house location remain on site but are not considered a significant resource because the house with which these non-native trees are associated has been removed and the integrity of the resource destroyed. Therefore, the Project would not result in a substantial adverse change in the significance of a historical resource. No impact would occur.

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Threshold b: Would the Project c ause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
No archaeological resources have been recorded within the Project area and, according to the pedestrian survey, no archaeological resources were observed within the Project area. However, cultural resources have been found within one mile of the Project area. Thus, there is a potential for archaeological resources to be present beneath the Project area’s surface. The anticipated depth of excavation would vary for the Project components but would likely extend to maximum depths of approximately 10 feet below the ground surface (bgs) for the installation of utility infrastructure. If any archaeological resources are unearthed during construction that meet the definition of an archaeological resource cited in CEQA Guidelines Section 15064.5 and are disturbed/damaged by Project construction activities, impacts to archaeological resources would be potentially significant.

Mitigation measures (MM) 4.5-1 through 4.5-5 presented below require that an archaeological monitor and Native American Tribal R epresentative be present during excavations into native, Holocene -age sediments, and identify steps to be taken to protect any resources encountered. With the implementation of MM 4.5-1 through MM 4.5-5, potential impacts to archaeological resources would be reduced to a less than significant level.

Threshold c: Wo
uld the Project disturb any human remains, including those interred outside of formal cemeteries?
The Project area is not a cemetery and there are no known formal cemeteries located within the immediate vicinity. Additionally, the pedestrian survey conducted did not identify the presence of any human remains and no human remains are known to exist beneath the surface of the Project area .

Nevertheless, there is a remote potential for human remains to be unearth ed during grading and excavation activities associated with Project construction, which would result in a potentially significant impact.

If human remains are unearthed during Project construction, the construction contractor would be required by law to comply with California Health and Safety Code Section 7050.5 “Disturbance of Human Remains.” According to Section s 7050.5(b) and (c), if human remains are discovered, the County Coroner must be contacted and if the Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner is required to contact the NAHC by telephone within 24 hours . Pursuant to PRC Section 5097.98, whenever the NAHC receives notification of a discovery of Native American human remains from a county coroner, the NAHC is required to immediately notify those persons it believes to be most likely descended from the deceased Native American . The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of the discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods . The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site .

According to PRC Section 5097.94(k), the NAHC is authorized to mediate disputes arising between ■■
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landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials. With mandatory compliance to California Health and Safety Code Section 7050.5 and PRC Section 5097.98, any potential impacts to human remains, including human remains of Native American ancestry, that may result from development of the Project would be less than significant.

4.5.5 CUMULATIVE IMPACT ANALYSIS
The cumulative impact area for cultural resources is the City. The potential for implementation of the Project to contribute to cumulative impacts to historical resources was analyzed in conjunction with other projects located in areas that were once similarly influenced by the historical agricultural industry of the City and the region. Record searches and field surveys indicate the absence of significant historic cultural resource sites and resources on and abutting the Project area; therefore, implementation of the Project would not contribute towards a cumulative impact to significant historical sites and/or resources.

Direct impacts to on -site cultural resources are site -specific and would not result in significant cumulative impacts; however, the Project, in conjunction with cumulative development in the City could lead to accelerated degradation of previously unknown archaeological resource sites. Each development proposal received by the City undergoes environmental review and would be subject to the same resource protection requirements as the Project. If there is a potential for significant impacts on cultural resources, an investigation will be required to determine the nature and extent of the resources and to identify appropriate mitigation measures, including requirements such as those identified in this section. Based on the information presented in the required site -specific cultural resource studies, construction activities associated with the Project would not impact any known prehistoric archaeological resources ; however, there is a potential to encounter previously unknown archaeological resources during construction of the Project and other development project sites in the City. Therefore, without mitigation, the Project would result in a potentially cumulatively considerable contribution to a significant cumulative impact to archaeological resources, if such resources are unearthed during Project construction. With implementation of MM 4. 5-1 through MM 4.5-5, t he Project’s impacts would be less than significant. The City requires incorporation of similar measures in each development Project. As such, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact to archaeological resources.

Mandatory compliance with the provisions of California Health and Safety Code Section 7050.5 as well as PRC Section 5097 et seq. would assure that, as with the Project, future development projects within the City treat human remains that may be uncovered during development activities in accordance with prescribed, respectful , and appropriate practices, thereby avoiding significant cumulative impacts.

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4.5.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: No Impact. No historic resources as defined by CEQA Guidelines Section 15064.5 are present within the Project area ; therefore, no historic resources would be altered or destroyed by construction or operation of the Project.

Threshold b: P otentially Significant Direct and Cumulatively Considerable Impact. No known archaeological resources are present on the Project site. Nonetheless, the potential exists for Project - related construction activities to result in a direct and cumulatively considerable impact to significant subsurface prehistoric archaeological resources should such resources to be discovered during Project- related construction activities.

Threshold c: Les s than Significant Impact. In the unlikely event that human remains are discovered during Project grading or other ground-disturbing activities, the Project would be required to comply with the applicable provisions of California Health and Safety Code Section 7050.5 and PRC Section 5097 et seq. Mandatory compliance with State law would ensure that human remains, if encountered, are appropriately treated and would preclude the potential for significant impacts to human remains.

4.5.7 MITIGATION MEASURES
MM 4.5-1 Prior to the issuance of a grading permit, the Developer shall retain a professional archaeologist to conduct monitoring of all mass grading and trenching activities. The Project Archaeologist shall have the authority to temporarily redirect earthmoving activities in the event that suspected archaeological resources are unearthed during Project construction. The Project Archaeologist, in consultation with the Consulting Tribe(s), the contractor, and the City, shall develop a Cultural Resources Management Plan (CRMP) in consultation pursuant to the definition in AB 52 to address the details, timing, and responsibility of all archaeological and cultural activities that will occur on the Project site. A Consulting Tribe is defined as a tribe that initiated the AB 52 tribal consultation process for the Project, has not opted out of the AB 52 consultation process, and has completed AB 52 consultation with the City as provided for in California Public Resources Code Section 21080.3.2(b)(1) of AB 52. Details in the Plan shall include:
a. Project grading and development scheduling;
b. The Project Archeologist and the Consulting Tribes(s) as defined above shall attend the pre -grading meeting with the City, the construction manager , and any contractors , and will conduct a mandatory Cultural Resources Worker Sensitivity Training for those in attendance. The Training will include a brief review of the cultural sensitivity of the Project and the surrounding area; what resources could potentially be identified during earthmoving activities; the requirements of the monitoring program; the protocols that apply in the event inadvertent discoveries of cultural resources are identified, including who to contact and appropriate avoidance measures until the find(s) can be properly ■■
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evaluated; and any other appropriate protocols. All new construction personnel that will conduct earthwork or grading activities that begin work on the Project following the initial Training must take the Cultural Sensitivity Training prior to beginning work and the Project Archaeologist and Consulting Tribe(s) shall make themselves available to provide the training on an as needed basis; c. The protocols and stipulations that the contractor, City, Consulting Tribe(s), and Project archaeologist shall follow in the event of inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits that shall be subject to a cultural resources evaluation.

MM 4.5-2 Prior to the issuance of a grading permit, the Developer shall secure an agreement with the Pechanga Band of Luiseño Indians regarding monitoring during ground-disturbing activities. The Developer is also required to provide a minimum of 30 days ’ advance notice to the tribe of all mass grading and trenching activities. The Native American Tribal Representative shall have the authority to temporarily halt and redirect earth - moving activities in the affected area in the event that suspected archaeological resources are unearthed. If the Native American Tribal Representative suspects that an archaeological resource may have been unearthed, the Project Archaeologist or the Tribal Representative shall immediately redirect grading operations in a 100-foot radius around the find to allow identification and evaluation of the suspected resource.

In consultation with the Native American Tribal Representative, the Project Archaeologist shall evaluate the suspected resource and make a determination of significance pursuant to California Public Resources Code Section 21083.2.

MM 4.5-3 In the event that Native American cultural resources are discovered during the course of grading (inadvertent discoveries), the following procedures shall be carried out for final disposition of the discoveries:
a. One or more of the following treatments, in order of preference, shall be employed with the tribes. Evidence of such shall be provided to the City of Moreno Valley Planning Department:
i. Preservation-In-Place of the cultural resources, if feasible. Preservation in place means avoiding the resources, leaving them in the place they were found with no development affecting the integrity of the resources. ii. On-site reburial of the discovered items as detailed in the treatment plan required pursuant to Mitigation Measure (MM) 4.5-1. This shall include measures and provisions to protect the future reburial area from any future impacts in perpetuity. Reburial shall not occur until all legally required cataloging and basic recordation have been completed. No recordation of sacred items is permitted without the written consent of all Consulting Native American Tribal Governments as defined in MM 4.5-1.

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MM 4.5-4 The City shall verify that the following note is included on the Grading Plan:

If any suspected archaeological resources are discovered during ground-disturbing activities and the Project Archaeologist or Native American Tribal Representative are not present, the construction supervisor is obligated to halt work in a 100 -foot radius around the find and call the Project Archaeologist and the Tribal Representative to the site to assess the significance of the find.

MM 4.5-5 If potential historic or cultural resources are uncovered during excavation or construction activities at the project site, work in the affected area must cease immediately and a qualified person meeting the Secretary of the Interior’s standards (36 CFR 61), Tribal Representatives, and all site monitors per the Mitigation Measures, shall be consulted by the City to evaluate the find, and as appropriate recommend alternative measures to avoid, minimize or mitigate negative effects on the historic, or prehistoric resource. Determinations and recommendations by the consultant shall be immediately submitted to the Planning Division for consideration and implemented as deemed appropriate by the Community Development Director and any and all Consulting Native American Tribes as defined in MM 4.5 -1 before any further work commences in the affected area.

4.5.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold b: Less than Significant Impact with Mitigation. Implementation of MM 4.5-1 through MM

4.5-5 would ensure the proper identification and subsequent treatment of any significant archaeological resources that may be encountered during ground-disturbing activities associated with Project construction. With implementation of the required mitigation, the potential Project impacts and the Project’s contribution to significant cumulative impacts to important archaeological resources would be reduced to a less than significant level.
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4.6 ENERGY
The analysis in this subsection is based on the Town Center at Moreno Valley Specific Plan Energy Analysis (Energy Analysis) pre pared by Urban Crossroads (Urban Crossroads 2025b). The report is included as EIR Technical Appendix E to this Environmental Impact Report (EIR). In accordance with the California Environmental Quality Act (CEQA), the Project is evaluated for its potential to result in wasteful, inefficient, or unnecessary consumption of energy resources or to conflict with applicable plans for renewable energy and energy efficiency. Refer to Section 7.0, References, for a complete list of reference sources used in this subsection.

4.6.1 EXISTING CONDITIONS
A. Electricity Consumption
Electricity is currently provided to the Project site and surrounding development by Moreno Valley Utility (MVU). MVU provides electric power to more than 6,500 customers within its service area .

MVU provides customer service, meter reading, billing, emergency response , and other services to new commercial and residential developments. As identified in Table 2-2, MVU 2022 Power Context Mix, of the Energy Analysis included in EIR Technical Appendix E , MVU derives 33.4 % of its electricity from e ligible renewable sources (solar power generation), and the remainder from unspecified sources of power.

Currently, the Project site is undeveloped and there are no existing uses or activities that consume electricity.

B. Natural Gas Consumption
As further described in Section 2.3 of the Energy Analysis included in EIR Technical Appendix E, the California Public Utilities Commis sion (PUC) regulates natural gas utility service for approximately

10.8 million customers that receive natural gas from Pacific Gas and Electric (PG&E), Southern California Gas (SoCalGas), San Diego Gas & Electric (SDG&E), Southwest Gas, and several smaller natural gas utilities. The CPUC also regulates independent storage operators. SoCalGas serves the City of Moreno Valley (City).

Natural gas is available from various in‐state and out‐of‐state sources and is provided throughout the state in response to market supply and demand. The gas transported to California gas utilities via the interstate pipelines, as well as some of the California -produced gas, is delivered into the PG&E and SoCalGas intrastate natural gas transmission pipelines systems (commonly referred to as California' s "backbone" pipeline system). Natural gas on the utilities' backbone pipeline systems is then delivered to the local transmission and distribution pipeline systems, or to natural gas storage fields. Some large volume noncore customers take natural gas delivery directly off the high-pressure backbone and local transmission pipeline systems, while core customers and other noncore customers take delivery off the utilities' distribution pipeline systems.

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In 2023, about 32% of the natural gas delivered to consumers went to the state's industrial sector, and about 31% was delivered to the electric power sector. Natural gas fueled more than two-fifths of the state's utility -scale electricity generation in 20 23. The residential sector, where three -fifths of California households use natural gas for home heating, accounted for 23% of natural gas deliveries.

The commercial sector received 1 3% of the deliveries to end users and the transportation sector consumed the remaining 1%.

Currently, the Project site is undeveloped and does not consume natural gas.

C. Transportation Energy/Fuel Consumption
Gasoline (and other vehicle fuels) are commercially provided commodities and would be available to Project patrons and employees via commercial outlets . The Department of Motor Vehicles (DMV) identified 36.2 million registered vehicles in California and those vehicles consume an estimated 17.2 billion gallons of fuel each year

1. Gasoline (and other vehicle fuels) are commercially provided commodities and would be available to Project patrons and employees via commercial outlets.

4.6.2 REGULATORY SETTING
A. Federal Plans, Policies, and Regulations

1. Intermodal Surface Transportation Efficiency Act (ISTEA) The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of inter‐modal transportation systems to maximize mobility as well as address national and local interests in air quality and energy. ISTEA contained factors that Metropolitan Planning Organizations (MPOs) were to address in developing transportation plans and programs, including some energy‐related factors. To meet the ISTEA requirements, MPOs adopted explicit policies defining the social, economic, energy, and environmental values guiding transportation decisions.

2. The Transportation Equity Act for the 21
st Century (TEA-21)
The TEA‐21 was signed into law in 1998 and builds upon the initiatives established in the ISTEA legislation, discussed above. TEA‐21 authorizes highway, highway safety, transit, and other efficient surface transportation programs. TEA‐21 continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of good transportation decisions. TEA‐21 also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of Intelligent Transportation Systems, to help improve operations and management of transportation systems and vehicle safety.

1 Fuel consumptions estimated utilizing information from EMissions FACtor model EMFAC 2021. ■■
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B. State Plans, Policies, and Regulations

1. Integrated Energy Policy Report (IEPR)
Senate Bill 1389 (Bowen, Chapter 568, Statutes of 2002) requires the California Energy Commission (CEC) to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the state’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety (Public Resources Code Section 25301[a]). The CEC prepares these assessments and associated policy recommendations every two years, with updates in alternate years, as part of the Integrated Energy Policy Report.

The 2023 IEPR was adopted in February 2024, and continues to work towards improving electricity, natural gas, and transportation fuel energy use in California. The 2023 IEPR builds on the 2022 IEPR’s framework for embedding equity and environmental justice at the CEC and the California Energy Planning Library which allows for easier access to energy data and analytics for a wide range of users.

Additionally, energy reliability, western electricity integration, gasoline cost factors and price spikes, the role of hydrogen in California’s clean energy future, fossil gas transition and distributed energy resources are topics discussed within the 2023 IEPR.

2. State of California Energy Plan
The CEC is responsible for preparing the State Energy Plan, which identifies emerging trends related to energy supply, demand, conservation, public health and safety, and the maintenance of a healthy economy. The Plan calls for the state to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies several strategies, including assistance to public agencies and fleet operators and encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate pedestrian and bicycle access.

3. California Code of Regulations, Title 24, Part 6 and Part 11 California Code of Regulations (CCR ) Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24 Energy 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.

CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect on August 1, 2009, and is administered by the California Building Standards Commission (CBSC).

CALGreen improves public health, safety, and general welfare through enhanced design and sustainable construction of buildings while conserving natural resources. Local jurisdictions are permitted to adopt more stringent requirements, as state law provides methods for local enhancements. ■■
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The State Building Code provides the minimum standard that buildings must meet in order to be certified for occupancy, which is generally enforced by the local building official.

The 2022 Title 24 Energy Standards and 2022 CALGreen Code have been approved by the CEC and CBSC went into effect on January 1, 2023

2. The Project would be required to comply with the
applicable standards in place at the time plan check submittals are made. Current requirements include, among other items:

Residential Mandatory Measures
• Electric vehicle (EV) charging stations. New construction shall comply with Section 4.106.4.1,

4.106.4.2, 4.106.4.3, to facilitate future installation and use of EV chargers. Electric vehicle supply equipment (EVSE) shall be installed in accordance with the California Electrical Code, Article 625. (4.106.4).
o New one- and two-family dwellings and town-houses with attached private garages.

For each dwelling unit, install a listed raceway to accommodate a dedicated 208/240- volt branch circuit. The raceway shall not be less than trade size 1 (nominal 1-inch inside diameter). The raceway shall originate at the main service or subpanel and shall terminate into a listed cabinet, box or other enclosure in close proximity to the proposed location of an EV charger. Raceways are required to be continuous at enclosed, inaccessible, or concealed areas and spaces. The service panel and/or subpanel shall provide capacity to install a 40-ampere 208/240-volt minimum dedicated branch circuit and space(s) reserved to permit installation of a branch circuit overcurrent protective device.
o New hotels and motels. All newly constructed hotels and motels shall provide EV spaces capable of supporting future installation of EVSE. The construction documents shall identify the location of the EV spaces. The number of required EV spaces shall be based on the total number of parking spaces provided for all types of parking facilities in accordance with Table 4.106.4.3.1.
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with Sections 4.303.1.1, 4.303.1.2,

4.303.1.3, and 4.303.1.4.
• Outdoor potable water use in landscape areas. Residential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resource M odel Water Efficient Landscape Ordinance (MWELO), whichever is more stringent.

2 The 2022 California Energy and Green Building Standard 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 the Energy Code and CALGreen provisions are currently being updated, with the most recent draft update consisting of the 2025 California Energy and Green Building Code Standards that will be effective on January 1, 2025. As construction of the Project is anticipated to be completed in 2028, it is presumed that the Project would be required to comply with the Title 24 standards in place at that time. ■■
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• Operation and maintenance manual. At the time of final inspection, a manual, compact disc, web-based reference or other media acceptable to the enforcing agency which includes all of the following shall be placed in the building:
o Directions to the owner or occupant that the manual shall remain with the building throughout the life cycle of the structure.
o Operations and maintenance instructions for the following:
 Equipment and appliances, including water-saving devices and systems, HVAC systems, photovoltaic systems, EV chargers, water-heating systems , and other major appliances and equipment.
 Roof and yard drainage, including gutter and downspouts.  Space conditioning systems, including condensers and air filters.  Landscape irrigation systems.
 Water reuse systems.
o Information from local utility, water, and waste recovery providers on methods to future reduce resource consumption, including recycle programs and locations. o Public transportation and/or carpool options available in the area. o Educational material on the positive impacts of an interior relative humidity between 30-60% and what methods an occupants may use to maintain the relative humidity level in that range.
o Information about water- conserving landscape and irrigation design and controllers which conserve water.
o Instructions for maintaining gutters and downspouts and the importance of diverting water at least 5 feet away from the foundation.
o Information about state solar energy and incentive programs available. o A copy of all special inspection verifications required by the enforcing agency of this code.
o Information from CALFIRE on maintenance of defensible space around residential structures.
• Any installed gas fireplace shall be direct -vent sealed -combustion type. Any installed woodstove or pellet stove shall comply with U.S. EPA New Source Performance Standards (NSPS) emission limits as applicable, and shall have a permanent label indicating t hey are certified to meet the emission limits. Woodstoves, pellet stoves , and fireplaces shall also comply with applicable local ordinances.
• Paints and coatings. Architectural paints and coatings shall comply with VOC limits in Table 1 of the CARB Architectural Suggested Control Measure, as shown in Table 4.504.3, unless more stringent local limits apply. The VOC content limit for coatings that do not meet the ■■
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definitions for the specialty coatings categories listed in Table 4.504.3 shall be determined by classifying the coating as a Flat, Nonflat, or Nonflat-high Gloss coating, based on its glass, as defined in subsections 4.21, 4.36, and 4.37 of the 2007 CARB, Suggested Control Measure, and the corresponding Flat, Nonflat, Nonflat -high Gloss VOC limit in Table 4.504.3 shall apply.

Non-residential Mandatory Measures
• Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with a minimum of one two-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant-occupants, provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility (5.106.4.1.2). • EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. The number of spaces to be provided for is contained in Table 5.106. 5.3.1 (5.106.5.3). Alternatively, the power allocation method may be used as an alternative to the requirements mentioned in Section

5.106.5.1, and associated Table 5.106.5.3. Use of Table 5.106.5.3.6 to can be used to determine the total power in kVA required based on the total number of actual parking spaces. Additionally, Table 5.106.5.5.1 specifies requirements for the installation of raceway conduit and panel power requirements for medium - and heavy-duty EV supply equipment for warehouses, grocery stores, and retail stores. • Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per Table 5.106.8 (5.106.8). • Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste in accordance with Section

5.408.1.1. 5.405.1.2, or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more stringent (5.408.1). • Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled.

For a phased project, such material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully enacted local recycling ordinance, if more restrictive (5.410.1).
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• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per flush (5.303.3.1).
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed 0.125 gallons per flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed 0.5 gallons per flush (5.303.3.2.2). o Showerheads. Single showerheads shall have a minimum flow rate of not more than

1.8 gallons per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the combined flow rate of all showerheads and/or other shower outlets controlled by a single valve shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).
o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5). • Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or additions in excess of 50,000 sf or for excess consumption where any tenant within a new building or within an addition that is projected to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and 5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 sf.

Rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 sf requiring a building or landscape permit (5.304.3). • Commissioning. For new buildings 10,000 sf and over, building commissioning shall be included in the design and construction processes of the building project to verify that the building systems and components meet the owner’s or owner representative’s project requirements (5.410.2)

4. California Renewable Portfolio Standards (RPS)
First established in 2002 under Senate Bill (SB) 1078, California’s Renewables Portfolio Standards (RPS) required retail sellers of electric services to increase procurement from eligible renewable resources to 44% of total retail sales by 2024.
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5. Pavley Fuel Efficiency Standards (AB 1493)
California AB 1493, enacted on July 22, 2002, required the California Air Resources Board (CARB) to develop and adopt regulations that reduce GHGs emitted by passenger vehicles and light-duty trucks. Under this legislation, CARB adopted regulations to reduce GHG emissions from non- commercial passenger vehicles (cars and light -duty trucks). Although aimed at reducing GHG emissions, specifically, a co-benefit of the Pavley standards is an improvement in fuel effici ency and consequently a reduction in fuel consumption.

6. Senate Bill 350 (SB 350) – Clean Energy and Pollution Reduction Act of 2015 In October 2015, the legislature approved, and the Governor signed, SB 350, which reaffirms California’s commitment to reducing its GHG emissions and addressing climate change. Key provisions include an increase in the renewables portfolio standard (RPS), higher energy efficiency requirements for buildings, initial strategies towards a regional electricity grid, and improved infrastructure for electric vehicle charging stations. Specifically, SB 350 requires the following to reduce statewide GHG emissions:
• Increase the amount of electricity procured from renewable energy sources from 33% to 50% by 2030, with interim targets of 40% by 2024, and 45% by 2027. • Double the energy efficiency in existing buildings by 2030. This target will be achieved through the California Public Utility Commission (CPUC), the CEC, and local publicly owned utilities.
• Reorganize the Independent System Operator (ISO) to develop more regional electrify transmission markets and to improve accessibility in these markets, which will facilitate the growth of renewable energy markets in the western United States.

C. Local Plans, Policies, and Regulations

1. Moreno Valley Building Code
The City’s Building Code regulates and controls the design, construction, quality of materials, grading, use, occupancy, location, and maintenance of all buildings or structures within the City. The City adopted the California Building Standards Code (CBSC) (2022 Edition), including its Building Code, Energy Code, and CALGreen components, and codified in Moreno Valley Municipal Code (MVMC) Title 8.20.

4.6.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts related energy based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact related to energy would occur if the Project would:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. ■■
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b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

In addition, Appendix F of the CEQA Guidelines states that the means of achieving the goal of energy conservation includes the following:
• Decreasing overall per capita energy consumption;
• Decreasing reliance on fossil fuels such as coal, natural gas, and oil; and • Increasing reliance on renewable energy sources.

Regarding the determination of significance under Threshold “a,” if energy consumed by the Project’s construction and/or operation cannot be accommodated with existing available resources and energy delivery systems and requires and/or consumes more energy than industrial uses in California of similar scale and intensity, the Project would result in wasteful, inefficient, or unnecessary consumption of energy.

4.6.4 IMPACT ANALYSIS
Threshold a: Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Information from the California Emissions Estimator Model (CalEEMod) Version 2022 outputs for the Town Center at Moreno Valley Specific Plan Air Quality Impact Analysis (AQIA) was utilized in this analysis, detailing Project-related construction equipment, transportation energy demands, and facility energy demands. Refer to the AQIA included in EIR Technical Appendix B, for a discussion of the methods and assumptions used in the analysis. This information is also summarized in EIR Section 3.0, Project Description, and Section 4.3, Air Quality. The Energy Analysis also utilized the different fuel types for each vehicle class from the annual EMFAC 2021 emission inventory in order to derive the average vehicle fuel economy which is then used to determine the estimated annual fuel consumption associated with vehicle usage during Project construction and operational activities. For purposes of analysis , the 2025 through 2028 analysis years were utilized to determine the average vehicle fuel economy used throughout the duration of the Project.

A. Construction-Related Energy Use
The Project’s construction process is estimated to occur over approximately 36 months and would consume electrical energy and fuel. Fuel consumed by construction equipment would be the primary energy resource expended over the course of Project construction. Consistent with industry standards and typical construction practices, and for purposes of analysis, each piece of equipment is estimated to operate up to a total of eight hours per day, or approximately two-thirds of the period during which construction activities are allowed pursuant to the MVMC. It should be noted that most pieces of equipment would likely operate for fewer hours per day. Diesel fuel would be supplied by existing ■■
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commercial fuel providers serving the region3. Project-related construction would represent a “single- event” electric energy and fuel demand and would not require on‐going or permanent commitment of energy or diesel fuel resources for this purpose.

The MVU’s general service rate schedule was used to determine the Project’s electrical usage. The estimated power cost of on-site electricity usage during the construction of the Project is assumed to be approximately $234,374 (refer to Table 4-2 of the Energy Analysis included in EIR Technical Appendix E). Based on the assumed power cost, it is estimated that the total electricity usage from on- site Project construction-related activities would be approximately 943,894.98 kWh (refer to Table 4- 3 of the Energy Analysis included in EIR Technical Appendix E). Construction equipment use would result in single event consumption of approximately 187,803 gallons of diesel fuel (refer to Table 4-5 of the Energy Analysis included in EIR Technical Appendix E).

Project construction activities would also generate on -road vehicle emissions from vehicle usage for workers, hauling, and vendors commuting to and from the site. The number of worker and vendor trips are presented in Table 4 -6 of the Energy Analysis included in EIR Technical Appendix E. Project construction worker trips are estimated to generate an estimated 4,855,473 VMT, and result in an estimated fuel consumption of 162,654 gallons of fuel (refer to Table 4 -7 of the Energy Analysis included in EIR Technical Appendix E). Additionally, fuel consumption from construction vendor and hauling trips would total approximately 102,705 gallons (refer to Table 4-8 of the Energy Analysis included in EIR Technical Appendix E).

Starting in 2014, CARB adopted the nation's first regulation aimed at cleaning up off-road construction equipment such as bulldozers, graders, and backhoes. These requirements ensure fleets gradually turnover the oldest and dirtiest equipment to newer, cleaner models and prevent fleets from adding older, dirtier equipment. As such, the equipment used for Project construction would conform to CARB regulations and California emissions standards. It should also be noted that there are no unusual Project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment employed for construction of the Project would therefore not result in inefficient, wasteful, or unnecessary consumption of fuel.

Construction contractors would be required to comply with applicable CARB regulation regarding retrofitting, repowering, or replacement of diesel off-road construction equipment . Additionally, CARB has adopted the Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other Toxic Air Contaminants.

Compliance with anti -idling and emissions regulations would result in a more efficient use of construction-related energy and the minimization or elimination of wasteful or unnecessary consumption of energy. Idling restrictions and the use of newer engines and equipment would result in less fuel combustion and energy consumption.

3 Based on Appendix A of the CalEEMod User’s Guide, construction consists of several types of off-road equipment. Since the majority of the off- road construction equipment used for construction projects are diesel fueled, CalEEMod assumes all of the equipment operates on diesel fuel. ■■
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Additional construction‐source energy efficiencies would occur due to required California regulations and best available control measures (BACM). For example, CCR Title 13, Motor Vehicles, section 2449(d)(2) Idling, limits idling times of construction vehicles to no more than five minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Section 2449(d)(2) requires medium and large fleets adopt a written idling policy informing operators that idling is limited to 5 consecutive minutes or less. Equipment rental agreements must also inform renters/lessees of this idling restriction. In this manner, construction equipment operators are required to be informed that engines are to be turned off at or prior to five minutes of idling.

Enforcement of idling limitations is realized through periodic site inspections conducted by City building officials, and/or in response to citizen complaints.

A full analysis related to the energy needed to form construction materials is not included in this subsection due to a lack of detailed Project-specific information on construction materials. At this time, an analysis of the energy needed to create Project -related construction materials would be extremely speculative and thus has not been prepared.

In general, the construction processes promote conservation and efficient use of energy by reducing raw materials demands, with related reduction in energy demands associated with raw materials extraction, transportation, processing, and refinement. Use of materials in bulk reduces energy demands associated with preparation and transport of construction materials as well as the transport and disposal of construction waste and solid waste in general, with corollary reduced demands on area landfill capacities and energy consumed by waste transport and landfill operations.

As supported by the preceding discussions, Project construction energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary. Impacts would be less than significant.

B. Operational-Related Energy Use
Project operations would include transportation energy demands (e nergy consumed by passenger car vehicles accessing the Project site) and facilities energy demands (energy consumed by building operations and site maintenance activities).

Project operations would result in an annual VMT of 48,830,915, and an estimated 1,882,112 gallons of fuel (refer to Table 4-9 of the Energy Analysis included in EIR Technical Appendix E). Fuel would be provided by current and future commercial vendors. Trip generation and VMT generated by the Project are consistent with other residential/commercial uses of similar scale and configuration, as reflected respectively in the Institute of Transportation Engineers (ITE) Trip Generation Manual (11th Ed., 2021); and CalEEMod. As such, Project operations would not result in excessive and wasteful vehicle trips and VMT, nor excess and wasteful vehicle energy consumption compared to other residential/commercial land uses. Additionally, enhanced fuel economies realized pursuant to federal and state regulatory actions, and related transition of vehicles to alternative energy sources would likely decrease future gasoline fuel demands per VMT. Location of the Project proximate to regional and local roadway systems tends to reduce VMT within the region, acting to reduce regional vehicle energy ■■
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demands. As further addressed in EIR Section 3.0, Project Description , and EIR Section 4.16, Transportation, the Project would include pedestrian and bicycle facilities , facilitating and encouraging pedestrian and bicycle access. For residential areas, pedestrian/bicycle access and connections to public sidewalks and bikeways, paseos, and open space systems would be emphasized.

The proposed residential uses are within walking distance of the proposed commercial uses and residents can use the commercial center for convenience and entertainment. The proposed commercial area would have pedestrian and bicycle facilities, including short- and long-term bicycle parking in compliance with CALGreen. The on-site circulation system would provide direct connections to the bikeways on site-adjacent roadways to encourage and facilitate bicycle travel. Facilitating pedestrian and bicycle access would reduce VMT and associated energy consumption.

Project facility operational energy demands are estimated to be 35,314,575 kBTU/year of natural gas, and 11,823,952 kWh/year of electricity (refer to Table 4-10 of the Energy Analysis included in EIR Technical Appendix E). The Project proposes conventional residential/commercial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. As required by CALGreen, renewable energy features would be incorporated into the Project design, including solar panels. and the Project would include required electric vehicle (EV) parking stalls and conduits for EV charging stations. Energy efficiency/energy conservation attributes of the Project would be complemented by increasingly stringent state regulatory actions addressing enhanced building/utilities energy efficiencies mandated under California building codes (e.g., Title 24 E nergy Standards and CALGreen). Compliance itself with applicable Title 24 Energy Standards would ensure that the Project energy demands would not be inefficient, wasteful, or otherwise unnecessary. The P roject does not propose uses that are inherently energy intensive and the energy demands in total would be comparable to other residential/commercial land use projects of similar scale and configuration.

As supported by the preceding discussions, Project transportation, and facility energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary. Impacts would be less than significant.

Threshold b: Wo
uld the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The Project’s consistency with the applicable state and local plans is discussed below.

1. Consistency with ISTEA
Transportation and access to the Project site is provided by the local and regional roadway systems.

The Project would not interfere with, nor otherwise obstruct intermodal transportation plans or projects that may be realized pursuant to the ISTEA because the Southern California Association of Governments (SCAG) is not planning for intermodal facilities on or through the Project site.

Consistency with ISTEA supports decreasing overall per capita energy consumption and decreased reliance on fossil fuels, consistent with State CEQA Guidelines Appendix F as residents, workers and ■■
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customers traveling to and from the site can use public transportation which would decrease fuel and overall VMT.

2. Consistency with TEA-21
The Project site is located along major transportation corridors with proximate access to the Interstate freeway system. The site selected for the Project facilitates access, acts to reduce VMT , takes advantage of existing infrastructure systems, and promotes land use compatibilities through collocation of similar uses. The Project supports the strong planning processes emphasized under TEA‐21. The Project is therefore consistent with, and would not otherwise interfere with, nor obstruct implementation of TEA‐21.

Consistency with TEA-21 supports decreasing overall per capita energy consumption and decreased reliance on fossil fuels, consistent with State CEQA Guidelines Appendix F as residents, workers and customers traveling to and from the site can use public transportation which would decrease fuel and overall VMT.

3. Consistency with IEPR
Electricity would be provided to the Project by MVU. MVU’s Energy Efficiency Programs builds on existing state programs and policies. As such, the Project is consistent with, and would not otherwise interfere with, nor obstruct implementation the goals presented in the 2023 IEPR.

Additionally, the Project would comply with the applicable Title 24 standards which would ensure that the Project energy demands would not be inefficient, wasteful, or otherwise unnecessary. As such, development of the proposed Project would support the goals presented in the 2023 IEPR.

Consistency with IEPR supports decreasing overall per capita energy consumption, decreased reliance on fossil fuels and increased reliance on renewable energy sources, consistent with State CEQA Guidelines Appendix F.

4. Consistency with State of California Energy Plan
The Project site is located along major transportation corridors with proximate access to the Interstate freeway system. The site selected for the Project facilitates access, takes advantage of existing infrastructure systems, and promotes land use compati bilities. The Project, therefore, supports urban design and planning processes identified under the State of California Energy Plan, is consistent with, and would not otherwise interfere with, nor obstruct implementation of the State of California Energy Plan.

Consistency with the State of California Energy Plan IEPR supports decreasing overall per capita energy consumption and reliance on fossil fuels, consistent with State CEQA Guidelines Appendix F as residents, workers and customers traveling to and from the site can use public transportation which would decrease fuel and overall VMT.
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5. Consistency with California Code of Regulations Title 24, Part 6 and Part 11 As previously discussed, the 2022 Title 24 Energy Standards and 2022 CALGreen have been approved by the CEC and CBSC and went into effect on January 1, 2023. T he Project would be required to comply with the Title 24 Energy Standards and CALGreen requirements in effect at the time building permit applications are submitted.

Consistency with Title 24 standards support decreasing overall per capita energy consumption, decreased reliance on fossil fuels and increased reliance on renewable energy sources consistent with State CEQA Guidelines Appendix F as the Project would need to incorporate energy efficiency standards as discussed in Section 3.2.3 of the Energy Analysis included in EIR Technical Appendix E.

6. Consistency with California Code of Regulations Title 24, Par 11, CALGreen As previously stated, CALGreen is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect on January 1, 2009, and is administered by the California Building Standards Commission. CALGreen is updated on a regular basis, with the most recent approved update consisting of the 2022 California Green Building Code Standards that were published on July 1, 2022, and became effective on January 1, 2023

4. The Project would be required
to comply with the applicable standards in place at the time building permit document submittals are made.

7. Consistency with AB 1493
AB 1493 is not applicable to the Project as it is a statewide measure establishing vehicle emissions standards. No feature of the Project would interfere with implementation of the requirements under AB 1493.

This would also ensure consistency with State CEQA Guidelines Appendix F as the P roject would interfere with implementation of AB 1493, therefore, decreasing reliance on fossil fuels.

8. Consistency with RPS
California’s Renewable Portfolio Standard is not applicable to the Project as it is a statewide measure that establishes a renewable energy mix. No feature of the Project would interfere with implementation of the requirements under RPS.

4 The 2022 California Energy and Green Building Standard 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 the Energy Code and CALGreen provisions are currently being updated, with the most recent draft update consisting of the 2025 California Energy and Green Building Code Standards that will be effective on January 1, 202 6. As construction of the Project is anticipated to be completed in 2028, it is presumed that the Project would be required to comply with the Title 24 standards in place at that time. ■■
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This would also ensure consistency with State CEQA Guidelines Appendix F as the Project would not interfere with implementation of the RPS, therefore, increasing reliance on renewable energy sources.

9. Consistency with SB 350
The proposed Project would use energy from MVU, which has committed to diversify its portfolio of energy sources by increasing energy from wind and solar sources. No feature of the Project would interfere with implementation of SB 350. Additionally, the Project would be designed and constructed to implement the energy efficiency measures for new residential/commercial developments and would include several measures designed to reduce energy consumption.

This would also ensure consistency with State CEQA Guidelines Appendix F as the Project would not interfere with implementation of SB350, therefore, increasing reliance on renewable energy sources.

10. Consistency with CEQA Appendix F
The Project would achieve the goals of energy conservation as identified in State CEQA Guidelines Appendix F. The Project would decrease overall per capita energy consumption by being consistent with the ISTEA, TEA -21, 2023 IEPR, State of California Energy Plan, and Title 24 Standards. The Project would decrease reliance on fossil fuels such as coal, natural gas and oil by being consistent with the ISTEA, TEA -21, 2023 IEPR, State of California Energy Plan, Title 24 Standards and AB 1493. The Project would increase reliance on renewable energy sources by being consistent with the 2023 IEPR, Title 24 Standards, RPS and SB 350.

Additionally, pursuant to MM 4.3-2 through MM 4.3-6 in EIR Section 4.3, Air Quality, the Project would further decrease overall per capita energy consumption, decrease reliance on fossil fuels such as coal, natural gas and oil and increase reliance on renewable energy sources. Specifically, MM 4.3 - 2, MM 4.3-5, and MM 4.3 -6 revolve around reductions in VMT by increasing efficiency of on-site circulation through signs and paintings, weatherproof signs that identify applicable CARB anti-idling regulations, and building energy efficiency, solid waste reduction, recycling, and water conservation.

MM 4.3-3 and MM 4.3-4 address the utilization of electric equipment, and MM 4.3-4 would also decrease reliance on fossil fuels.

Additionally, pursuant to MM 4.8-1 through MM 4.8-4 in EIR Section 4.8, Greenhouse Gas Emissions, the Project would further decrease overall per capita energy consumption, decrease reliance on fossil fuels such as coal, natural gas and oil and increase reliance on renewable energy sources. MM 4.8-1 requires the non-residential portion of the Project to incorporate energy efficiency requirements, utilize renewable energy sources such as solar and incorporate measures meant to reduce potable water use within the building by 12%. MM 4.8-2 supports reduced energy consumption for the residential portion of the Project, through measures regarding no wood fire places, primarily electric buildings where electricity is the primary source of energy for water heating, heating, ventilation and air conditioning as well as all major appliances shall be electric powered and energy star rated. MM 4.8-3 supports ■■
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electric charging for electric landscaping equipment and MM 4.8-4 requires light color roofing and building materials to minimize heat island effect and reduce lighting, heating, and cooling needs.

As such, based on the preceding discussion and supporting evidence, a less than significant impact is expected with respect to State CEQA Guidelines Appendix F criteria.

11. Consistency with Moreno Valley Building Code
The City would require the Project to be designed, constructed, and operated to meet or exceed all applicable components of the California Building Standards Code (which is adopted as the City’s Building Code pursuant to MVMC Title 8). The City would confirm the Project’s compliance with the Building Code as part of the building permit review process . On this basis, the Project is determined to be consistent with, and would not interfere with, nor otherwise obstruct implementation of the California Building Standards Code.

12. Conclusion
As supported by the preceding analysis, the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency and impacts would be less than significant.

4.6.5 CUMULATIVE IMPACT ANALYSIS
Project construction and operations would not result in the inefficient, wasteful, or unnecessary consumption of energy. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservation goals within California. Other cumulative developments within the region would be required to demonstrate that wasteful , inefficient, or unnecessary energy consumption would not occur. Additionally, other cumulative developments would be subject to the same regulatory requirements as the Project, including compliance with the Title 24 Energy Standards and CALGreen, and the MVMC, which would ensure that cumulative development does not result in wasteful, inefficient, or unnecessary consumption of energy. The Project and other cumulative developments also inherently would be consistent with the IEPR, State of California Energy Plan, AB 1493 (Pavley), and SB 350, as discussed herein. As such, there is a le ss than significant cumulative impact related to energy.

4.6.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact. The amount of energy and fuel consumed by construction and operation of the Project would not be inefficient, wasteful, or unnecessary . Furthermore, the Project would not cause or result in the need for additional energy facilities or energy facilities or energy delivery systems.

Threshold b: Les
s than Significant Impact . The Project would not cause or result in the need for additional energy production or transmission facilities, the Project would not conflict with or obstruct the achievement of energy conservation goals identified in State and local plans for renewable energy and energy efficiency.
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4.6.7 MITIGATION
Impacts would be less than significant, and mitigation is not required. However, air quality mitigation measures MM 4.3-2 through MM 4.3-6 and GHG mitigation measures MM 4.8-1 through MM 4.8-4 would also assist in the reduction of fuel and energy usage. ■■
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4.7 GEOLOGY AND SOILS
The analysis in this subsection is based, primarily, on information contained in the following site- specific technical reports: 1) Geotechnical Exploration Town Center at Moreno Valley Northwest Corner of Alessandro Blvd and Nason Street, Moreno Valley , California (Geotechnical Report) prepared by Leighton and Assoc iates, Inc. (Leighton) (Leighton 2025a), and the associated Geotechnical Addendum #1, Town Center at Moreno Valley Northwest Corner of Alessandro Boulevard and Nason Street, Moreno Valley California (Leighton 2024); and, 2) the Phase I Cultural Resources Assessment for the Moreno Valley Town Center Project (Cultural Resources Assessment) prepared by VCS Environmental (VCS), which addresses paleontological resources (VCS, 2024) .

These reports are provided as Technical Appendices F and D, respectively, to this EIR. All references used in this subsection are listed in EIR Section 7.0, References.

4.7.1 EXISTING CONDITIONS
A. Regional Geology
The Project site is within the natural geomorphic province in southwestern California known as the Peninsular Ranges, which is characterized by steep, elongated ranges and valleys that trend northwestward. Specifically, the Project site is within the Perris Block, an eroded mass of Cretaceous and older crystalline rock. The Perris Block, approximately 20 miles by 50 miles in extent, is bounded by the San Jacinto Fault Zone to the northeast, the Elsinore Fault Zone to the southwest, the Cucamonga Fault Zone to the northwest, and the Temecula Basin to the southeast. The sou theast boundary of the Perris block is poorly defined. The Perris Block has had a complex tectonic history, apparently undergoing relative vertical land movements of several thousand feet in response to movement on the Elsinore and San Jacinto Fault Zones. Thin sedimentary and volcanic materials locally mantle the crystalline bedrock. Alluvial and colluvial deposits fill the lower valley areas . T he Project site is underlain by young and very old fan deposits (Leighton 2025a).

B. Soils
During preparation of the Geotechnical Report , excavation of eight geotechnical borings and four percolation/infiltration tests were conducted to explore the subsurface condit ions within the Project site. As described below, artificial fill (stockpile) and alluvial deposits were encountered on site.

1. Artificial Fill (Stockpile)
A large stockpile of artificial fill was observed at the southeastern corner of the Project site.1 The soils appear to be substantially similar to the soils explored in the boring. Additionally, artificial fill was encountered in the upper 12 to 24 inches of site soils, which is likely the result of previous site grading or agricultural activities.

1 Based on input provided by the City during preparation of the Phase I Environmental Site Assessment (ESA), the City owned the Project site since 1985 and the large soil stockpiles in the southeastern portion of the Project site were generated during street improvements in the City (Leighton 2025b). ■■
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2. Alluvial Deposits
Alluvial fan deposits were observed throughout the Project site to the depths explored of 51 feet below ground surface (bgs). These soils typically consisted of brown to reddish brown, medium dense to very dense, moist silty sand (SM) , and well -graded sand with variable amounts of silt (SW -SM) and interbedded low-plasticity sandy silt (ML) layers. This alluvium is expected to generally possess a very low expansion potential (EI<21).

C. Groundwater
Groundwater was not encountered during the field exploration to the depths explored (51 feet bgs).

Recent groundwater level was measured in March 2021 at approximately 1,470 feet mean sea level (MSL) (approximately 40 feet bgs) at well EMWD 25695, which is located approximately one mile south of the Project site. Therefore, groundwater is not anticipated to be encountered at the Project site.

It should be noted that locally perched water conditions can occur and may fluctuate seasonally, depending on rainfall. No surface water was observed on site during the field visit.

D. Seismic Hazards
The Project site is in an area of S outhern California that is subject to strong ground motions due to seismic events (i.e., earthquakes). The geologic structure of Southern California is dominated mainly by northwest-trending faults associated with the San Andreas system. As depicted on Figure 4.1-1, City Geologic Faults and Liquefaction – Rev. August 31, 2022, of the Moreno Valley Local Hazard Mitigation Plan (LHMP), the San Jacinto fault zone traverses the northeastern and eastern boundary of the City, and is approximately 3.2 miles northeast of the Project site (City of Moreno Valley 2022a).

The San Jacinto fault zone is composed of several parallel faults that together constitute the zone.

Secondary hazards associated with earthquakes include surface rupture, ground failure, unstable soils, and slopes. Each of these hazards is briefly described below.

1. Fault Rupture
Fault rupture can occur along pre -existing, known active fault traces; however, fault rupture also can splay from known active faults or rupture along unidentified fault traces. According to the Geotechnical Report, no indications of faulting or fault -related fissuring or fractures were observed on site.

Additionally, the Project site is not within a designated Alquist-Priolo earthquake fault zone or County of Riverside fault zone. The San Jacinto fault zone is the nearest Alquist-Priolo fault zone to the Project site.

2. Liquefaction
Liquefaction is a phenomenon in which loose, saturated, relatively cohesion- less soil deposits lose shear strength during strong ground motions, which causes the soil to behave as a viscous liquid.

Liquefaction is generally limited to the upper 50 feet of subsurface soils . As depicted in Figure 4, Liquefaction Susceptibility, of the Geotechnical Report, the Project site is within an area of the City ■■
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with a low to moderate susceptibility for liquefaction. The Project site also has a low to moderate potential for liquefaction.

3. Landslides
No evidence of on-site landslides/debris flow or rock fall was observed during the field investigation conducted during preparation of the Geotechnical Report . Elevated topography and thick deposits of surficial soils typically associated with land sliding or debris flows are not present . Additionally, as depicted on Figure 8-1, Moreno Valley Slope Analysis – Revised August 16, 2022, of the City of Moreno Valley LHMP, the Project site is within an areas with a less than 10% slope angle, and is not within an area that is susceptible to landslides (City of Moreno Valley 2022a).

4. Settlement Potential
Settlement refers to unequal compression of a soil foundation, shrinkage, or undue loads being applied to a building after its initial construction that affect the soil foundation. The on-site soils have the potential to experience settlement during a seismic event.

5. Unstable Soils and Slopes
The Project site is generally flat and does not contain, nor is it adjacent to any, steep natural or manufactured slopes and there is no evidence of historical landslides or rockfalls on the site.

E. Slope and Instability Hazards

1. Soil Erosion
Erosion is the process by which the upper layers of the ground surface (such as soils) are worn and removed by the movement of water or wind. Soils with characteristics such as low permeability and/or low cohesive strength are more susceptible to erosion than those soils having higher permeability and cohesive strength. Additionally, the slope gradient on which a given soil is located also contributes to the soil’s resistance to erosive forces . Because water flows faster down steeper gradients, the steeper the slope on which a given soil is located, the more readily it will erode . The Project site has soil that exhibits a low cohesive strength.

Wind erosion can damage land and natural vegetation by removing soil from one place and depositing it in another. It mostly affects dry, sandy soils in flat, bare areas, but wind erosion may occur wherever soil is loose, dry, and finely granulated. Under existing conditions, the Project site has the potential to contribute windblown soil and sand because the Project site is undeveloped with loose and dry topsoil conditions.

2. Shrinkage/Subsidence Potential
Subsidence is a gradual settling or sudden sinking of the ground surface (i.e., loss of elevation) . The principal causes of subsidence are aquifer-system compaction, drainage of organic soils, underground ■■
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mining, and natural compaction. Shrinkage is the reduction in volume in soil as the water content of the soil drops (i.e., loss of volume). The on-site alluvial soils have the potential to experience shrinkage.

3. Soil Expansion
Expansive soils are soils that exhibit cyclic shrink and swell patterns in response to variations in moisture content. Based on soil testing conducted during preparation of the Geotechnical Report, the near surface soils possess a very low expansion potential.

F. Paleontological Setting

1. Regional Setting
According to the Final Environmental Impact Report for the MoVal 2040: Moreno Valley Comprehensive Plan Update, Housing Element Update, and Climate Action Plan, the City has sedimentary rock units with potential to contain significant nonrenewable paleontological (fossil) resources (City of Moreno Valley 2021a).2 Sensitivity ratings are based on the California Department of Transportation (Caltrans) Standard Environmental Reference guidelines for paleontology, which classifies geologic units and formations as having high, low, or no potential for paleontological resources. Sensitivity is also based on the depth of excavation. Some geologic units and formations have low potential at a depth of excavation ranging from 0 to 10 feet but have high sensitivity when the depth of excavation exceeds 10 feet.

2. Project Site Conditions
Based on the paleontological records search conducted by the Western Science Center to support preparation of the site -specific Cultural Resources Assessment , the Project site does not have any paleontological resource localities on site; however, three fossil localities were found within two miles of the Project site in the same sedimentary deposits as exist on the Project site. Additionally, the Project area is mapped as fluvial fan deposits dating from the early Pleistocene to Holocene era. The presence of Pleistocene fossil localities within alluvial sediments indicate s that the Project area is paleontologically sensitive. No paleontological resources were discovered during the site visit conducted by VCS in June 2021.

4.7.2 REGULATORY SETTING
The following is a brief description of the federal, S tate, and local environmental laws and related regulations governing issues related to geology, soils, and paleontological resources.

2 The paleontological resources 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 paleontological resources in the City. The court decision did not address this topical issue.
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A. Federal Plans, Policies, and Regulations

1. Clean Water Act
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters . The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, but the Act was substantially reorganized and expanded in 1972. "Clean Water Act" became the Act's common name with amendments in 1972 . Under the CWA, the Environmental Protection Agency (EPA) has implemented pollution control programs such as setting wastewater standards for industry and also has set water quality standards for all contaminants in surface waters . The CWA made it unlawful to discharge any pollutant from a point source into navigable waters unless a permit was obtained. EPA's National Pollutant Discharge Elimination System (NPDES) permit program controls discharges. Point sources are discrete conveyances such as pipes or man -made ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES pe rmit; however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.

B. State Plans, Policies, and Regulations

1. Alquist-Priolo Earthquake Fault Zoning Act (A-P Act) The Alquist-Priolo Earthquake Fault Zoning Act (A-P Act) was passed in 1972 to mitigate the hazard of surface faulting to structures for human occupancy. The A-P Act’s main purpose is to prevent the construction of buildings used for human occupancy on the surface trace of active faults. The A-P Act only addresses the hazard of surface fault rupture and is not directed toward other earthquake hazards.

The A-P Act requires the State Geologist to establish regulatory zones (known as Earthquake Fault Zones) around the surface traces of active faults and to issue appropriate maps. ["Earthquake Fault Zones" were called "Special Studies Zones" prior to January 1, 1994.] The maps are distributed to all affected cities, counties, and State agencies for their use in planning and controlling new or renewed construction. Local agencies must regulate most development projects within the zones. Projects include all l and divisions and most structures for human occupancy. Single -family wood-frame and steel-frame dwellings up to two stories which are not part of a development of four units or more are exempt. However, local agencies can be more restrictive than State law requires.

Before a project can be permitted, cities and counties must require a geologic investigation to demonstrate that proposed buildings will not be constructed across active faults. An evaluation and written report of a specific site must be prepared by a licensed geologist. If an active fault is found, a structure for human occupancy cannot be placed over the trace of the fault and must be set back from the fault (generally 50 feet).

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2. Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (SHMA) of 1990 (Public Resources Code , Chapter 7.8, Sections 2690-2699.6) directs the Department of Conservation, California Geological Survey to identify and map areas prone to liquefaction, earthquake -induced landslides, and amplified ground shaking. The purpose of the SHMA is to minimize loss of life and property through the identification, evaluation, and mitigation of seismic hazards.

Staff geologists in the Seismic Hazard s Program gather existing geological, geophysical , and geotechnical data from numerous sources to produce the Seismic Hazard Zone Maps. They integrate and interpret these data regionally in order to evaluate the severity of the seismic hazards and designate as Zones of Required Investigation (ZORI) those areas prone to liquefaction and earthquake –induced landslides. Cities and counties are then required to use the Seismic Hazard Zone Maps in their land use planning and building permit processes.

The SHMA requires site -specific geotechnical investigations to be conducted within the Z ORI to identify and evaluate seismic hazards and formulate mitigation measures prior to permitting most developments designed for human occupancy.

3. Natural Hazards Disclosure Act
The Natural Hazards Disclosure Act, effective June 1, 1998 (as amended June 9, 1998), requires that sellers of real property and their agents provide prospective buyers with a "Natural Hazard Disclosure Statement" when the property being sold lies within one or more state-mapped hazard areas, including a Seismic Hazard Zone.

The law requires the State Geologist to establish regulatory zones (Zones of Required Investigation) and to issue appropriate maps (Seismic Hazard Zone maps). These maps are distributed to all affected cities, counties, and S tate agencies for their use in planning and controlling construction and development. Single-family frame dwellings up to two stories not part of a development of four or more units are exempt from the State requirements. However, local agencies can be more restrictive than State law requires.

Before a development permit can be issued or a subdivision approved, cities and counties must require a site -specific investigation to determine whether a significant hazard exists at the site and, if so, recommend measures to reduce the risk to an acceptable level. The investigation must be performed by State-licensed engineering geologists and/or civil engineers.

4. California Building Standards Code (Title 24)
California Code of Regulations (CCR) Title 24 is reserved for State regulations that govern the design and construction of buildings, associated facilities, and equipment. These regulations are also known as building standards (reference California Health and Safety Code Section 18909). California Health ■■
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and Safety Code (State law) Section 18902 gives CCR Title 24 the name California Building Standards Code (CBSC).

The CBSC in CCR Title 24 is published by the California Building Standards Commission and it applies to all building occupancies (see California Health and Safety Code Sections 18908 and 18938) throughout the State of California. Cities and counties are required by State law to enforce CCR Title 24 (reference California Health and Safety Code Sections 17958, 17960, 18938(b), and 18948). Cities and counties may adopt ordinances making more restrictive requirements than provided by CCR Title 24, because of local climatic, geological, or topographical conditions. Such adoptions and a finding of need statement must be filed with the California Building Standards Commission (reference California Health and Safety Code Sections 17958.7 and 18941.5).

Title 24 Part 2 includes the California Building Code (CBC), which contains general building design and construction requirements relating to fire and life safety, structural safety, and access compliance.

C. Local Plans, Policies, and Regulations

1. City of Moreno Valley General Plan
The current 2006 City of Moreno Valley General Plan (2006 General Plan) Safety Element provides information about natural and human-made hazards in the City and establishes goals, objectives, and policies to prepare and protect the community from such risks (City of Moreno Valley 2006). The Safety Element states that the City shall reduce the risk of geologic hazards to the community by enforcing building codes and State and local regulations.

2. Moreno Valley Municipal Code
The City of Moreno Valley Building Code is provided in City of Moreno Valley Municipal Code (MVMC) Chapter 8.20, CBC, and is based on the CBC, as supplemented with local amendments. The Building Code regulates the construction, alteration, repair, moving, demolition, conversion, occupancy, use, and maintenance of all buildings and structures in the City.

MVMC Chapter 8.21, Grading Regulations, requires development projects to prepare geologic engineering reports to identify site-specific geologic and seismic conditions and provide site -specific recommendations to preclude adverse impacts from unstable soils and strong seismic ground-shaking (refer to MVMC Section 8.21.050). These reports shall recommend corrective action to preclude any structural damage/hazards that may be caused by geological hazards or unstable soils which the City will require to be incorporated into the Project via conditions of approval. In addition, this chapter of the MVMC required the implementation of an erosion control plan during grading activities (refer to Section 8.21.160).

MVMC Chapter 8.10, Stormwater/Urban Runoff Management and Discharge Controls, requires the City to participate in the improvement of water quality and comply with federal requirements for the control of urban pollutants, including sediment, in stormwater runoff. ■■
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3. SCAQMD Rule 403 (Fugitive Dust)
SCAQMD Rule 403 (Fugitive Dust) requires the implementation of best available dust control measures (BACMs) during active operations capable of generating fugitive dust . The purpose of this Rule is to minimize the amount of particulate matter in the ambient air as a result of anthropogenic fugitive dust sources.

4.7.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates geology and soils impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact would occur if the Project would:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
ii. Strong seismic ground shaking
iii. Seismic-related ground failure, including liquefaction iv. Landslides.
b) Result in substantial soil erosion or the loss of topsoil. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property. e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

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4.7.4 IMPACT ANALYSIS
Threshold a: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42;
ii) strong seismic ground shaking;
iii) seismic-related ground failure, including liquefaction; iv) landslides?
A. Rupture of a Known Earthquake Fault
There are no known active or potentially active faults on or trending toward the Project site and the Project site is not located within a mapped Alquist -Priolo Earthquake Fault Zone (Leighton 2025a).

Therefore, the Project would not directly or indirectly expose people or structure to substantial adverse effect related to fault rupture. No impacts would occur.

B. Strong Seismic Ground Shaking
The Project site is in a seismically active area of S outhern California and is expected to experience moderate to severe ground shaking during the lifetime of the Project. This risk is not considered substantially different than that of other similar properties in the Southern California area . As a mandatory condition of Project approval, future b uildings to be developed pursuant to the proposed Town Center at Moreno Valley (TCMV) Specific Plan would be constructed in accordance with the applicable version of the CBC and the City of Moreno Valley Building Code , which is based on the CBC with local amendments . The CBC and City of Moreno Valley Building Code (MVMC Chapter

8.20) provide standards that must be met to safeguard life or limb, health, property, and public welfare by regulating and controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of all buildings and str uctures, and have been specifically tailored for California earthquake conditions . In addition, the CBC (Chapter 18) and the City of Moreno Valley Building Code (MVMC Chapter 8.21) require development projects to prepare geologic engineering reports to identify site -specific geologic and seismic conditions and implement the site -specific recommendations contained therein to preclude adverse effects involving unstable soils and strong seismic ground-shaking, including, but not limited to, recommendations related to ground stabilization, selection of appropriate foundation type and depths, selection of appropriate structural systems.

The Project Applicant retained a professional geotechnical firm, Leighton, to prepare a geotechnical report for the Project site, which is included as EIR Technical Appendix F . The site-specific Geotechnical Report complies with the requirements of Chapter 18 of the CBC and MVMC Chapter

8.21. In conformance with MVMC, the City will condition the Project to comply with the site-specific ground preparation and construction recommendations contained in EIR Technical Appendix F. With ■■
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mandatory compliance with building code standards and site -specific design and construction measures, implementation of the Project would not directly or indirectly expose people or structures to substantial adverse effects, including loss, injury or death, involving seismic ground shaking.

Impacts would be less than significant.

C. Seismic-Related Ground Failure
Due to the observed soil characteristics on the Project site and the lack of shallow groundwater beneath the site, there is a low to moderate potential for liquefaction. Regardless, as noted above, the City will require the Project site to be developed in accordance with the latest applicable seismic safety guidelines, including the standard requirements of the CBC and the City’s Building Code, to minimize potential liquefaction hazards. Additionally, the Project would be required (via conditions of approval) to comply with the recommendation identified in the Geotechnical Report , which recommends remedial grading of the on -site soils to reduce the potential for liquefaction. If remedial grading is performed, total dynamic densification settlement would be less than 2 inches globally with anticipated differential settlement of 1-inch in 40 feet (Leighton 2025a). Therefore, implementation of the Project would not directly or indirectly expose people or structure s to substantial hazards associated with seismic-related ground failure and/or liquefaction hazards. Impacts would be less than significant.

D. Landslides
The Project site and surrounding area are relatively flat. No evidence of on-site landslides/debris flow or rock fall was observed during the field investigation and review of referenced reports conducted during preparation of the Geotechnical Report. Elevated topography and thick deposits of surficial soils typically associated with landsliding or debris flows are not present (Leighton 2025a) .

Accordingly, the Project would not directly or indirectly expose people or structures to substantial risks from landslides. Impacts would be less than significant.

Threshold b: Wo
uld the Project result in substantial soil erosion or the loss of topsoil? A. Construction-Related Erosion Impacts
The Project site is undeveloped with vegetative cover and has loose and dry topsoil conditions (due to routine maintenance activities); thus, there is a potential to contribute windblown soil and sand under existing conditions. Development of the Project would result in the grading of the entire Project site .

Disturbed soils would be subject to potential erosion during rainfall events or high winds due to the removal of stabilizing vegetation and building materials (e.g., existing concrete foundations) and exposure of these erodible materials to wind and water.

Pursuant to the requirements of the State Water Resources Control Board, the Project Applicant would be required to obtain coverage under the State’s General Construction Storm Water Permit for Construction Activities (NPDES permit). The NPDES permit is required for all development projects that include construction activities, such as clearing, grading, and/or excavation, that disturb at least one acre of total land area . In addition, the Project would be required to comply with the Santa Ana Regional Water Quality Control Board’s (RWQCB’s) Santa Ana River Basin Water Quality Control ■■
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Program. Compliance with the NPDES permit and the Santa Ana River Basin Water Quality Control Program involves the preparation and implementation of a stormwater pollution prevention plan (SWPPP) for construction-related activities. The SWPPP will specify the Best Management Practices (BMPs) required to be implemented during construction activities to ensure that waterborne pollution, including erosion/sedimentation, is prevented, minimized, and/or otherwise appropriately treated prior to surface runoff being discharged from the Project site. Examples of BMPs that may be utilized during construction include, but are not limited to, sandbag barriers, geotextiles, storm drain inlet protection, sediment traps, rip rap soil stabilizers, and hydro-seeding. Lastly, implementation of an erosion control plan would be required to minimize water and windborne erosion pursuant to MVMC Section 8.21.160 (and to ensure compliance with SCAQMD Rule 403). Mandatory compliance with the SWPPP and the erosion control plan would ensure that the Project’s implementation does not violate any water quality standards or waste discharge requirements during construction activities . Therefore, water quality impacts associated with construction activities would be less than significant.

B. Post-Development Erosion Impacts
Upon Project buildout, the Project site would be covered by buildings, landscaping, and impervious surfaces. Stormwater runoff from the Project site would be captured, treated to reduce waterborne pollutants (including sediment), and conveyed off site via an on-site storm drain system. Accordingly, the amount of erosion that occurs on the Project site would be minimized upon buildout of the Project and would be reduced relative to existing conditions.

To meet the requirements of the City’s Municipal Storm Water Permit, and in accordance with MVMC Section 8.10.050, preparation and implementation of a Water Quality Management Plan (WQMP) would be required, which is a site -specific post -construction water quality management program designed to minimize the release of potential waterborne pollutants. The WQMP is required to identify an effective combination of erosion control and sediment control measures (i.e., BMPs) to reduce or eliminate sediment discharge to surface water from stormwater and non-stormwater discharges. The WQMP also is required to establish a post -construction implementation and main tenance plan to ensure on-going, long-term erosion protection. Compliance with the WQMP will be required as a condition of approval for the Project, as will the long-term maintenance of erosion and sediment control features. The preliminary WQMP for the Project is provided as EIR Technical Appendix I. Because the Project would be required to implement erosion and sediment control measures to preclude substantial, long-term soil erosion and loss of topsoil, the Project would result in less than significant impacts related to soil erosion.

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Threshold c: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? A. On- or Off-Site Landslide
The Project site is not within an area of the City that is susceptible to landslides . As noted in the response to Threshold a above, the Project site does not have any geotechnical conditions associated with landslides. The Project would not result in any impacts associated with landslide hazards.

B. Lateral Spreading/Liquefaction
Lateral spreading is primarily associated with liquefaction hazards. As noted, the Project site has a low to moderate susceptibility for liquefaction (Leighton 2025a). The Project would be required (via conditions of approval) to comply with the recommendation identified in the Geotechnical Report, which recommends remedial grading of the on-site soils to reduce the potential for liquefaction. If remedial grading is performed, total dynamic densification settlement would be less than 2 inches globally with anticipated differential settlement of 1-inch in 40 feet. Potential impacts related to lateral spreading and liquefaction would be less than significant.

C. Subsidence/Collapse
Subsidence is the gradual settling or sudden shrinking of the Earth’s surface due to removal or displacement of subsurface earth materials . The on-site soils have a slight to moderate potential for collapse (Leighton 2025a). The volume of change of excavated on-site soils upon re -compaction is anticipated to vary with materials, density, moisture content, location, and compaction effort . The Geotechnical Report recommends that site grading include a balance area or ability to adjust grades slightly to accommodate some variation. The Project would comply (via conditions of approval) with the site-specific ground preparation and construction recommendations contained in the Project site’s geotechnical report . P otential impacts related to soil subsidence and collapse would be less than significant.

Threshold d: Wo
uld the Project be located on expansive soil, as defined in Table 18-1- B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Based on the expansion index testing of the soil samples conducted during preparation of the Geotechnical Report, the near -surface soils on the Project site have a very low expansion potential (Leighton 2025a). Therefore, the Project would not be located on expansive soil and would not create substantial direct or indirect risks to life or property associated with the presence of expansive soils .

No impacts would occur.

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Threshold e: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The Project does not propose the use of septic tanks or alternative wastewater disposal systems. The Project would construct an on-site sewer system that would connect to the existing sewer system in the surrounding roadways. No impacts would occur.

Threshold f: Wo uld the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The Project site does not contain any known unique geologic features and no paleontological resources or localities were observed during the pedestrian survey conducted during preparation of the site - specific Cultural Resources Assessment (VCS, 2024). However, as previously discussed, the Project site is underlain by fluvial fan deposits dating from the early Pleistocene to Holocene , which have yielded fossil localities within two miles of the Project site . Therefore, due to the Project site’s proximity to recorded fossil localities, the Project’s fluvial fan deposits have the potential to yield paleontological resources . Therefore, there is potential to encounter previously unknown unique paleontological resources during construction activities (e.g., grading, trenching, and excavation activities), resulting in a significant impact. Mitigation Measure (MM) 4.7-1 requires paleontological monitoring during ground disturbing activities in order to mitigate any adverse impacts (loss or destruction) to potential nonrenewable paleontological resources to a less than significant level.

4.7.5 CUMULATIVE IMPACT ANALYSIS
Except for erosion hazards, potential hazardous effects related to geologic and soil conditions addressed under Thresholds “a,” “c,” “d,” and “e” are unique to the Project site, and inherently restricted to the specific property proposed for development . That is, issues including fault rupture, seismic ground shaking, liquefaction, landslides, and expansive soils would involve effects to (and not from) a proposed development project, are specific to conditions on the Project site , and are not influenced or exacerbated by the geologic and/or soils hazards that may occur on other, off-site properties. Further, the Project and any future development projects would be required to comply with applicable State and local requirements, such as the City’s Building Code, and grading requirements outlined in the MVMC. As with the Project, future development would be required to have site-specific geotechnical investigations prepared to identify the geologic and seismic characteristics on a site and to provide recommendations for engineering design and construction to ensure the structural integrity of proposed development; these recommendations would be incorporated into Project design.

Compliance of individual projects with the recommendations of the applicable geotechnical investigation would prevent hazards associated with unstable soils, landslide potential, lateral spreading, liquefaction, soil collapse, expansive soil, and other geologic issues. Because of the site- specific nature of these potential hazards and the measures to address them, there would be no direct or indirect connection to similar potential issues or cumulative effects to or from other properties.

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As discussed under Threshold “b,” regulatory requirements mandate that the Project incorporate design measures during construction and long-term operation to ensure that significant erosion impacts do not occur. Other development projects in the vicinity of the Project site would be required to comply with the same regulatory requirements as the Project to preclude substantial adverse water and wind erosion impacts. Because the Project and other projects within the cumulative study area would be subject to similar mandatory regulatory requirements to control erosion hazards during construction and long - term operation, cumulative impacts associated with wind and water erosion hazards would be less than significant.

Because the alluvial soils present on the Project site have paleontological sensitivity and because this geologic layer is present throughout the City and southern California, the re is a potential to impact paleontological resources. The Project’s potential to result in cumulative impacts to paleontological resources is similar to that of other projects located in the region that are underlain by Pleistocene and Holocene alluvial soils . However, each development proposal received by the City undergoes environmental review and would be subject to the same resource protection requirements as the Project.

If there is a potential for significant impacts on paleontological resources, an invest igation would be required to determine the nature and extent of the resources and to identify appropriate mitigation measures, including requirements such as those identified in this subsection related to construction monitoring, and salvage, sampling, identification, evaluation, and recording of resources (refer to MM

4.7-1). With implementation of mitigation , impacts to paleontological resources would be less than significant. The Project’s contribution to cumulative geology and soils impacts would be less than significant, with mitigation.

4.7.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact. Implementation of the Project would not expose people or structures to substantial direct or indirect adverse effects related to fault rupture . The Project site is subject to seismic ground shaking associated with earthquakes and has a low to moderate susceptibility to liquefaction; however, mandatory compliance with local and State regulatory requirements and building codes, and adherence to recommendations from site -specific geotechnical report(s) (via conditions of approval), would ensure that the Project minimizes potential hazards related to seismic ground shaking and seismic-related ground failure, including liquefaction, to less than significant levels.

Threshold b: Les
s t han Significant Impact. Implementation of the Project would not result in substantial soil erosion or loss of topsoil . Construction activities would be conducted in compliance with regulations addressing erosion during construction (e.g., NPDES permit and preparation of a SWPPP), and preparation of an erosion control plan is required to minimize water and wind erosion .

Following completion of development, implementation of a WQMP during operation is required (via conditions of approval), which would preclude substantial long-term erosion impacts.

Threshold c: Le
ss than Significant Impact. T here is no potential for the Project’s construction or operation to cause, or be impacted by, on- or off-site landslides . Potential hazards associated with ■■
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unstable soils would be precluded through mandatory adherence (via conditions of approval) to the recommendations contained in the site-specific geotechnical report(s) during Project construction.

Threshold d: N o Impact. The Project site does not contain expansive soils. As such, the Project is not located on a geologic unit with a high expansion potential.

Threshold e: N o Impact. The Project does not propose the use of septic tanks or alternative wastewater disposal system.

Threshold f: P otentially Significant Impact . T he Project site contains sediment deposits with a sensitivity for paleontological resources. Accordingly, construction activities on the Project site have the potential to unearth and adversely impact paleontological resource that may be buried beneath the ground surface.

4.7.7 MITIGATION
MM 4.7-1 Prior to the issuance of grading permits and/or action that would permit Project site disturbance, the Project Applicant shall provide written evidence to the City of Moreno Valley that the Project Applicant has retained a qualified Paleontologist to observe grading activities into the paleontologically sensitive fluvial fan deposits and to conduct salvage excavation of paleontological resources as necessary. Sediment samples should also be recovered to determine the small-fossil potential of the site. The Paleontologist shall be present at the pre-grading conference; shall establish procedures and a schedule for paleontological resources surveillance; and shall establish, in cooperation with the City, procedures for temporarily halting or redirecting work t o permit the sampling, identification, and evaluation of the fossils as appropriate. These actions, as well as final mitigation and disposition of the resources, shall be subject to the approval of the City of Moreno Valley.

The Project Paleontologist shall prepare a final paleontological resource monitoring and mitigation report of findings and significance, including lists of all fossils recovered and necessary maps and graphics to accurately record their original location(s). All recovered fossils will be offered for curation in perpetuity to the Western Science Center in Hemet, the principal fossils repository in Riverside County.

A letter documenting receipt and acceptance of all fossil collections by the receiving institution must be included in the final report. The report, when submitted to (and accepted by) the City of Moreno Valley, shall signify satisfactory completion of the project program to mitigate impacts to any nonrenewable paleontological resources.

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4.7.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold f: Less t han Significant Impact with Mitigation . MM 4.7 -1 w ould ensure proper identification and subsequent treatment of any paleontological resources that could be encountered during ground-disturbing activities associated with the implementation of the Project. Therefore, with implementation of MM 4.7-1
, the Project’s potential impacts on paleontological resources would be reduced to less than significant levels.
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4.8 GREENHOUSE GAS EMISSIONS
The analysis provided in this subsection evaluates the Project’s potential to generate greenhouse gas (GHG) emissions that could contribute to global climate change (GCC) and its associated environmental effects . The analysis in this subsection is based, primarily, on the Town Center at Moreno Valley Specific Plan Greenhouse Gas Analysis (GHG Analysis) prepared by Urban Crossroads (Urban Crossroads 2025c). This report is included as EIR Technical Appendix G. References used in this subsection are listed in EIR Section 7.0, References.

4.8.1 EXISTING CONDITIONS
A. Introduction to Global Climate Change
GCC is defined as the change in average meteorological conditions on the earth with respect to temperature, wind patterns, precipitation, and storms. The majority of scientists believe that the climate shift taking place since the Industrial Revolution is occurring at a quicker rate and magnitude than in the past. Scientific evidence suggests that GCC is the result of increased concentrations of GHGs in the earth’s atmosphere, including carbon dioxide (CO
2), methane (CH 4), nitrous oxide (N 2O), and
fluorinated gases. Global temperatures are regulated by naturally occurring atmospheric gases such as water vapor, CO 2, N 2O, CH 4, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These particular gases are important due to their residence time (duration they stay) in the atmosphere, which ranges from 10 years to more than 100 years. These gases allow solar radiation into the earth’s atmosphere but prevent radiative heat from escaping, thus warming the earth’s atmosphere.

The effects of climate change in California related to public health, water resources, agriculture, forests and landscapes, rising sea levels, and human health are described in Section 2.6 of the GHG Analysis included in EIR Technical Appendix G.

B. Greenhouse Gases
Gases that trap heat in the atmosphere are often referred to as GHGs. GHGs are released into the atmosphere by both natural and anthropogenic activity. Without the natural GHG effect, the earth’s average temperature would be approximately 61 degrees Fahrenheit (°F) cooler than it is currently.

The cumulative accumulation of these gases in the earth’s atmosphere is considered to be the cause for the observed increase in the earth’s temperature. CO
2, CH4, and N2O are the primary contributors to
GCC from devel opment projects . GHGs have varying global warming potential (GWP) values .

Although there are other substances such as fluorinated gases that also contribute to GCC, these fluorinated gases were not evaluated as their sources are not well-defined and do not contain accepted emissions factors or methodology to accurately calculate these gases.

GWP of a GHG indicates the amount of warming a gas causes over a given period of time and represents the potential of a gas to trap heat in the atmosphere. CO 2 is utilized as the reference gas for
GWP and thus has a GWP of 1. Carbon dioxide equivalent (CO 2e) is a term used for describing the difference GHGs in a common unit. CO2e signifies the amount of CO2 which would have the equivalent ■■
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GWP. The GWP for the 2nd Assessment Report, the Intergovernmental Panel on Climate Change (IPCC)’s scientific and socio-economic assessment on climate change, range from 1 for CO2 to 23,900 for SF6, and GWP for the IPCC’s 6th Assessment Report range from 1 for CO2 to 25,200 for SF6. The atmospheric lifetime and GWP of selected GHGs are summarized in Table 4.8-1, GWP and Atmospheric Lifetime of Select GHGs.

Table 4.8-1 GWP and Atmospheric Lifetime of Select GHGs Gas Atmospheric Lifetime
(years)
GWP (100-year time horizon)
2nd Assessment Report 6th Assessment Report
CO2 Multiple 1 1
CH4 11.8 21 28
N2O 109 310 273
HFC-23 228 11,700 14,600
HFC-134a 14 1,300 1,526
HFC-152a 1.6 140 164
SF6 3,200 23,900 25,200
Source: (Urban Crossroads 2025c)

Provided below is a description of the various gases that contribute to GCC. The potential health effects related directly to the emissions of CO2, CH4, and N2O as they relate to development projects are still being debated in the scientific community. Their cumulative effects to GCC have the potential to cause adverse effects to human health. For more information about these gases and their associated human health effects, refer to Section 2.3 of EIR Technical Appendix G and the reference sources cited therein. • Water Vapor (H 2O) is the most abundant and variable GHG in the atmosphere . The main source of water vapor is evaporation from the oceans (approximately 85%). Changes in the concentration of water vapor in the atmosphere are considered to be a result of climate feedbacks related to the warming of the atmosphere rather than a direct result of industrialization. As the temperature of the atmosphere rises, more water is evaporated from ground storage (rivers, oceans, reservoirs, soil). Because the air is warmer , the relative humidity rises (in essence, the air is able to ‘hold’ more water when it is warmer), leading to more water vapor in the atmosphere. The higher concentration of water vapor in the atmosphere is then able to absorb more indirect thermal energy radiated from the earth, further warming the atmosphere and causing the evaporation cycle to perpetuate . This is referred to as a “positive feedback loop.” The extent to which this positive feedback loop will continue is unknown as there are also dynamics that hold the positive feedback loop in check. As an example, when water vapor increases in the atmosphere, more of it will eventually also condense into clouds which are able to reflect incoming solar radiation and thereby allow less energy to reach the earth’s surface and heat it up. There are no human health effects from water vapor at this time. However, when some pollutants react with water vapor, the reaction forms a transport mechanism for some of these pollutants to enter the human body through wat er vapor.
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• Carbon Dioxide (CO2) is an odorless and colorless GHG that is emitted from natural and man- made sources . Natural CO 2 sources include: the decomposition of dead organic matter; respiration of bacteria, plants, animals , and fungus; evaporation from oceans; and volcanic outgassing. Man-made CO2 sources include the burning of coal, oil, natural gas, and wood.

Since the industrial revolution began in the mid-1700s, human activities that produce CO2 have increased dramatically in scale and distribution . As an example, prior to the industrial revolution, CO2 concentrations in the atmosphere were fairly stable at 280 parts per million (ppm). Currently, they are around 370 ppm, an increase of more than 30%. Exposure to CO2 in high concentrations (i.e., at exposure levels of 5,000 ppm averaged over 10 hours in a 40- hour workweek and short-term reference exposure levels of 30,000 ppm averaged over a 15- minute period) can cause adverse human health effects, but outdoor (atmospheric) levels are not high enough to result in negative health effects.
• Methane (CH4) absorbs thermal radiation extremely effectively (i.e., retains heat). Over the last 50 years, human activities such as rice cultivation, cattle ranching, using natural gas, and coal mining have increased the concentration of methane in the atmosphere. Other man-made sources include fossil -fuel combustion and biomass burning. CH 4 is extremely reactive with oxidizers, halogens, and other halogen-containing compounds. Exposure to high levels of CH4 can cause asphyxiation, loss of consciousness, headache and dizziness, nausea and vomiting, weakness, loss of coordination, and an increased breathing rate. • Nitrous Oxide (N2O) concentrations began to rise in the atmosphere at the beginning of the industrial revolution. N2O can be transported into the stratosphere, be deposited on the earth’s surface, and be converted to other compounds by chemical reaction. N 2O is produced by microbial processes in soil and water, including reactions that occur in nitrogen-containing fertilizer. In addition to agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid product ion, and vehicle emissions) also contribute to its atmospheric load. N
2O also is used as an aerosol spray propellant, as a preservative in potato chip bags, in rocket engines, and in race cars. Also known as laughing gas, N2O is a colorless GHG that can cause dizziness, euphoria, and sometimes slight hallucinations. In small doses, it is considered harmless; however, heavy and extended use can cause brain damage. • Chlorofluorocarbons (CFCs) are gases formed synthetically by replacing all hydrogen atoms in CH 4 or ethane (C 2H6) with chlorine and/or fluorine atoms . CFCs are non-toxic, non- flammable, insoluble , and chemically unreactive in the troposphere (the level of air at the earth’s surface). CFCs were first synthesized in 1928 and have no natural source . CFCs were used for refrigerants, aerosol propellants, and cleaning solvents. Due to the discovery that they are able to destroy stratospheric ozone, a global effort to halt their production was undertaken and has been extremely successful, so much so that levels of CFCs are now remaining steady or declining. However, due to their long atmospheric lifetime, some of the CFCs will remain in the atmosphere for over 100 years. In confined indoor locations, working with CFC-113 or other CFCs is thought to result in death by cardiac arrhythmia (heart frequency too high or too low) or asphyxiation.
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• Hydrofluorocarbons (HFCs) are synthetic, man-made chemicals that are used as a substitute for CFCs and have one of the highest global warming potential ratings. No human health effects are known to result from exposure to HFCs, which are man-made and used for applications such as automobile air conditioners and refrigerants.
• Perfluorocarbons (PFCs) are primarily produced for aluminum production and semiconductor manufacture. PFCs have stable molecular structures and do not break down through chemical processes in the lower atmosphere . Because of this, PFCs have very long lifetimes, between 10,000 and 50,000 years. Two common PFCs are tetrafluoromethane (CF4) and hexafluoroethane (C2F6). No human health effects are known to result from exposure to PFCs.
• Sulfur Hexafluoride (SF6) is an inorganic, odorless, colorless, nontoxic, nonflammable gas .

Sulfur hexafluoride is used for insulation in electric power transmission and distribution equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas for leak detection. In high concentrations in confined areas, the gas presents the hazard of suffocation because it displaces the oxygen needed for breathing. • Nitrogen Trifluoride (NF
3). NF3 is a colorless gas with a distinctly moldy odor. It is used in industrial processes and is produced in the manufacturing of semiconductors, Liquid Crystal Display (LCD) panels, types of solar panels, and chemical lasers. Long- term or repeated exposure may affect the liver and kidneys and may cause fluorosis.

C. Greenhouse Gas Emissions Inventory

1. Global and National
Worldwide anthropogenic GHG emissions are tracked by the IPCC for industrialized nations (referred to as Annex I) and developing nations (referred to as Non-Annex I). Human GHG emissions data for Annex I nations are available through 2021. Based on the latest available data, the sum of these emissions totaled approximately 28,272,940 gigagram (Gg) CO2e as summarized in Table 4.8-2, Top GHG Producing Countries and the European Union. As noted in Table 4.8-2, the United States (U.S.) as a single country, was the number two producer of GHG emissions in 2021.

2. State of California
California has significantly slowed the rate of growth of GHG emissions due to the implementation of energy efficiency programs as well as adoption of strict emission controls but is still a substantial contributor to the U.S. emissions inventory total. The California Air Resources Board (CARB) compiles GHG inventories for the State of California. Based upon the 2023 GHG inventory data (i.e., the latest year for which data are available) for the 2000 -2021 GHG emissions period, California emitted an average 381.3 million metric tons of CO
2e per year (MMTCO 2e/yr) or 381,300 Gg CO 2e
(6.01% of the total U.S. GHG emissions). California’s per capita (9.12 metric tons) GHG emissions are much less than the nationwide per capita (15.8 metric ton) average.

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Table 4.8-2 Top GHG Producing Countries and the European Union Emitting Countries GHG Emissions (Gg CO2e)
China 12,300,200
United States 6,340,228
European Union (27-member countries) 3,468,394
India 2,839,425
Russian Federation 2,156,599
Japan 1,168,094
Total 28,272,940
Source: (Urban Crossroads 2025c)

3. Project Site
The Project site is undeveloped and there are no existing uses or activities that produce GHG emissions under existing conditions.

4.8.2 REGULATORY SETTING
The following is a brief description of the federal, S tate, and local environmental laws and related regulations related to GHG emissions that are particularly relevant to the Project or analysis of GHG emissions. Climate change is a global issue involving GHG emissions from all around the world; international efforts to reduce GHG emissions are also discussed in the GHG Analysis included in EIR Technical Appendix G.

A. Federal Plans, Policies, and Regulations

1. Clean Air Act
Coinciding with the 2009 meeting of international leaders in Copenhagen, on December 7, 2009, the U.S. Environmental Protection Agency (EPA) issued an Endangerment Finding under Section 202(a) of the Clean Air Act (CAA), opening the door to federal regulation of GHGs . The Endangerment Finding notes that GHGs threaten public health and welfare and are subject to regulation under the CAA. To date, the EPA has not promulgated regulations on GHG emissions, but it has begun to develop them.

Previously the EPA had not regulated GHGs under the CAA because it asserted that the CAA did not authorize it to issue mandatory regulations to address GCC and that such regulation would be unwise without an unequivocally established causal link between GHGs and the increase in global surface air temperatures. In Massachusetts v. Environmental Protection Agency et al. (127 S. Ct. 1438 [2007]), however, the U.S. Supreme Court held that GHGs are pollutants under the CAA and directed the EPA to decide whether emissions of GHGs from new motor vehicles cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. The EPA Administrator signed two distinct findings regarding GHGs under Section 202(a) of the CAA:
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• Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well-mixed GHGs— CO2, CH4, N2O, HFCs, PFCs, and SF6—in the atmosphere threaten the public health and welfare of current and future generations. • Cause or Contribute Finding: The Administrator finds that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution, which threatens public health and welfare.

These findings do not impose requirements on industry or other entities. However, this was a prerequisite for implementing GHG emissions standards for vehicles, as discussed below . After a lengthy legal challenge, the Supreme Court declined to review an Appeals Court ruling that upheld the EPA Administrator’s findings.

2. Light-Duty Vehicle Greenhouse Gas Emission and Corporate Average Fuel Economy Standards
The EPA and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) have been working together on developing a National Program of regulations to reduce GHG emissions and to improve fuel economy of light-duty vehicles for model years 2017 and beyond.

On April 1, 2010, the EPA and NHTSA announced a joint Final Rulemaking establishing standards for 2012 through 2016 model-year vehicles. This was followed up in August 2012, when the agencies issued a Final Rulemaking with standards for model years 2017 through 2025. The final standards are projected to result in an average industry fleetwide level of 163 grams/mile of CO 2 in model year 2025,
which is equivalent to 54.5 mpg if achieved exclusively through fuel economy improvements.

On April 2, 2018, the EPA signed the Mid-term Evaluation Final Determination, which declared that the model year 2022-2025 GHG standards are not appropriate and should be revised. This Final Determination serves to initiate a notice to further consider appropriate standards for model year 2022- 2025 light-duty vehicles. On August 2, 2018, the NHTSA in conjunction with the EPA , released a notice of proposed rulemaking, the Safer Affordable Fuel -Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule). The SAFE Vehicles Rule was proposed to amend existing Corporate Average Fuel Economy (CAFE) and tailpipe CO 2 standards
for passenger cars and light trucks and to establish new standards covering model years 2021 through 2026. As of March 31, 2020, the NHTSA and EPA finalized the SAFE Vehicle Rule which increased the stringency of CAFE and CO
2 emissions standards by 1.5% each year through model year 2026. On December 21, 2021, after reviewing all the public comments submitted on NHTSA’s April 2021 Notice of Proposed Rulemaking, NHTSA finalized the CAFE Preemption rulemaking to withdraw its portions of the so-called SAFE I Rule. The final rule concludes that the SAFE I Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interests. The final rule ensures that the SAFE I Rule will no longer form an improper barrier to states exploring creative solutions to address their local communities’ environmental and public health challenges.

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On March 31, 2022, NHTSA finalized CAFE standards for model years (MYs) 2024-2026. The standards for passenger cars and light trucks for MYs 2024-2025 were increased at a rate of 8% per year and then increased at a rate of 10% per year for MY 2026 vehicles. NHTSA currently projects that the revised standards would require an industry fleet-wide average of roughly 49 mpg in MY 2026 and would reduce average fuel outlays over the lifetimes of affected vehicles that provide consumers hundreds of dollars in net savings. These standards are directly responsive to the agency’s statutory mandate to improve energy conservation and reduce the nation’s energy dependence on foreign sources.

B. State Plans, Policies, and Regulations
State policies, regulations, and laws related to GHG emissions are briefly discussed below. Additional information about state regulations pertaining to GHG emissions is presented in Section 3.4 of the GHG Analysis included in EIR Technical Appendix G.

1. California Assembly Bill No. 1493 (AB 1493)
Enacted on July 22, 2002, California AB 1493, also known as the Pavley Fuel Efficiency Standards, required CARB to develop and adopt regulations that reduce GHGs emitted by passenger vehicles and light-duty trucks. The second phase of the implementation for the Pavley bill was incorporated into Amendments to the Low -Emission Vehicle Program (LEV III) or the Advanced Clean Cars (ACC) program. The ACC program combines the control of smog-causing pollutants and GHG emissions into a single coordinated package of requirements for model year 2017 through 2025. The regulation will reduce GHGs from new cars by 34% from 2016 levels by 2025. The new rules will clean up gasoline and diesel-powered cars and deliver increasing numbers of zero-emission technologies, such as full- battery electric cars, newly emerging plug-in hybrid EV and hydrogen fuel cell cars. The package will also ensure adequate fueling infrastructure is available for the increasing numbers of hydrogen fuel cell vehicles planned for deployment in California.

On March 9, 2022, the EPA reinstated California’s authority under the CAA to implement its own GHG emission standards for cars and light trucks, which other states can also adopt and enforce. With this authority restored, EPA will continue partnering with states to advance the next generation of clean vehicle technologies.

2. Executive Order S-3-05
California Governor Arnold Schwarzenegger announced on June 1, 2005, through Executive Order S- 3-05, the following reduction targets for GHG emissions: reduce GHG emissions to 2000 levels by 2010, reduce GHG emissions to 1990 levels by 2020, and reduce GHG emissions to 80% below 1990 levels by 2050. The 2050 reduction goal represents what some scientists believe is necessary to reach levels that will stabilize the climate. The 2020 goal was established to be a mid -term target. Because this is an executive o rder, the goals are not legally enforceable for local governments or the private sector.

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3. California Assembly Bill 32 – Global Warming Solutions Act of 2006 The California State Legislature enacted AB 32 in 2006, which required that GHGs emitted in California be reduced to 1990 levels by the year 2020 (this goal has been met). GHGs as defined under AB 32 include CO2, CH4, N2O, HFCs, PFCs, and SF6. Since AB 32 was enacted, a seventh chemical, NF3, has also been added to the list of GHGs. CARB is the state agency charged with monitoring and regulating sources of GHGs. Pursuant to AB 32, CARB adopted regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions.

4. Senate Bill 97and the CEQA Guidelines Update
Passed in August 2007, SB 97 added Section 21083.05 to the Public Resources Code. The code states “(a) On or before July 1, 2009, the Office of Planning and Research (OPR) shall prepare, develop, and transmit to the Resources Agency guidelines for the mitigation of GHG emissions or the effects of GHG emissions as required by this division, including, but not limited to, effects associated with transportation or energy consumption. (b) On or before January 1, 2010, the Resources Agency shall certify and adopt guidelines prepared and developed by the OPR pursuant to subdivision (a).”

In 2012, Public Resources Code Section 21083.05 was amended to state:

The Office of Planning and Research and the Natural Resources Agency shall periodically update the guidelines for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions as required by this division, including, but not limited to, effects associated with transportation or energy consumption, to incorporate new information or criteria established by the State Air Resources Board pursuant to Division 25.5 (commencing with Section 38500) of the Health and Safety Code.

On December 28, 2018, the Natural Resources Agency announced the OAL approved the amendments to the CEQA Guidelines for implementing CEQA. The CEQA Amendments provide guidance to public agencies regarding the analysis and mitigation of the effects of GHG emissions in CEQA documents. The CEQA Amendments fit within the existing CEQA framework by amending existing CEQA Guidelines to reference climate change.

Section 15064.4 was added to the CEQA Guidelines and states that in determining the significance of a project’s GHG emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. A project ’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes. Additionally, a lead agency may use a model or methodology to estimate GHG emissions resulting from a project. The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. The lead ■■
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agency must support its selection of a model or methodology with substantial evidence. The lead agency should explain the limitations of the particular model or methodology selected for use.

5. California Senate Bill No. 375 - Sustainable Communities and Climate Protection Act of 2008
On September 30, 2008, SB 375 was signed by Governor Schwarzenegger. According to SB 375, the transportation sector is the largest contributor of GHG emissions, which emits over 40% of the total GHG emissions in California. SB 375 states, “Without improved land use and transportation policy, California will not be able to achieve the goals of AB 32.” SB 375 does the following: (1) requires metropolitan planning organizations (MPOs) to include sustainable community strategies in their regional transportation plans for reducing GHG emissions, (2) aligns planning for transportation and housing, and (3) creates specified incentives for the implementation of the strategies.

SB 375 requires MPOs to prepare a Sustainable Communities Strategy (SCS) within the Regional Transportation Plan (RTP) that guides growth while taking into account the transportation, housing, environmental, and economic needs of the region. The Southern California Association of Governments (SCAG) is the MPO for the City. In April 2024, SCAG’s Regional Council adopted the 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Connect SoCal 2024).

SB 375 uses CEQA streamlining as an incentive to encourage residential projects, which help achieve AB 32 goals to reduce GHG emissions. Although SB 375 does not prevent CARB from adopting additional regulations, such actions are not anticipated in the for eseeable future. Concerning CEQA, SB 375, as codified in Public Resources Code Section 21159.28, states that CEQA findings for certain projects are not required to reference, describe, or discuss (1) growth-inducing impacts, or (2) any project-specific or cumulative impacts from cars and light-duty truck trips generated by the project on global warming or the regional transportation network, if the project:

1. Is in an area with an approved sustainable communities strategy or an alternative planning strategy that CARB accepts as achieving the GHG emission reduction targets.

2. Is consistent with that strategy (in designation, density, building intensity, and applicable policies).

3. Incorporates the mitigation measures required by an applicable prior environmental document.

6. Executive Order B-30-15
On April 29, 2015, Governor Brown issued an executive order to establish a California GHG reduction target of 40% below 1990 levels by 2030 in order to ensure California meets its target of reducing GHG emissions to 80% below 1990 levels by 2050. This executive order directs CARB to update the 2017 Scoping Plan to express the 2030 target in terms of MMTCO 2e and also requires the state’s
climate adaptation plan to be updated every three years, and for the State to continue its climate change research program, among other provisions. As with Executive Order S-3-05, Executive Order B-30-15 is not legally enforceable as to local governments and the private sector. ■■
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7. Senate Bill 32
On September 8, 2016, Governor Brown signed SB 32 and its companion bill, AB 197. SB 32 requires the state to reduce statewide GHG emissions to 40% below 1990 levels by 2030, a reduction target that was first introduced in Executive Order B-30-15. The new legislation builds upon the AB 32 goal and provides an intermediate goal to achieving S -3-05, which sets a statewide GHG reduction target of 80% below 1990 levels by 2050. AB 197 creates a legislative committee to oversee regulators to ensure that CARB not only responds to the Governor, but also the Legislature.

8. 2022 CARB Scoping Plan
On December 15, 2022, CARB released the Final 2022 Scoping Plan Update, which builds on the 2017 Scoping Plan as well as the requirements set forth by AB 1279, which directs the S tate to become carbon neutral no later than 2045. To achieve this statutory objective, the 2022 Scoping Plan lays out how California can reduce GHG emissions by 85% below 1990 levels and achieve carbon neutrality by 2045. The Scoping Plan scenario to do this is to “deploy a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with statutes, Executive Orders, Board direction, and direction from the governor.” The 2022 Scoping Plan sets one of the most aggressive approaches to reach carbon neutrality in the world. Unlike the 2017 Scoping Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a local GHG reduction strategy (CAP) consistent with CEQA Guidelines Section 15183.5.

The key elements of the 2022 CARB Scoping Plan focus on transportation. The regulations that will impact this sector are adopted and enforced by CARB on vehicle manufacturers and outside the jurisdiction and control of local governments. Included in the 2022 Scoping Plan is a set of Local Actions (Appendix D to the 2022 Scoping Plan) aimed at providing local jurisdictions with tools to reduce GHGs and assist the state in meeting the ambitious targets set forth in the 2022 Scoping Plan.

Appendix D to the 2022 Scoping Plan includes a section on evaluating plan- level and project -level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development to determine consistency with the 2022 Scoping Plan. CARB’s primary recommendation for determining consistency with the 2022 Scoping Plan and determining a less than significant impact is for projects to rely on a CEQA-qualified CAP.

In Appendix D of the 2022 Scoping Plan, CARB states: “When jurisdictions have a CEQA -qualified CAP, an individual project that complies with the strategies and actions within a CEQA-qualified CAP can tier and streamline its project -specific CEQA GHG analys is to make a determination “that a project’s incremental contribution to a cumulative [GHG] effect is not cumulatively considerable” (CEQA Guidelines Sections 15064.4[b][3] and 15183.5). CARB states that CEQA -qualified CAPs serve to assist the state with its long-term carbon neutrality goals. As such, it follows that a Project that is consistent with a CEQA -qualified CAP would also be consistent with meeting the 2022 Scoping Plan goals.

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Additionally, in Appendix D, CARB states: “The recommendations outlined in this section apply only to residential and mixed-use development project types. California currently faces both a housing crisis and a climate crisis, which necessitates prioritizing recommendations for residential projects to address the housing crisis in a manner that simultaneously supports the State’s GHG and regional air quality goals. CARB plans to continue to explore new approaches for other land use types in the future.” As such, it would be inappropriate to apply the requirements contained in Appendix D of the 2022 Scoping Plan to any land use types other than residential or mixed-use residential development.

9. California Code of Regulations, Title 24, Part 6 and Part 11 California Code of Regulations (CCR) Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24 Energy 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 GHG emissions.

CALGreen recognizes that many jurisdictions have developed existing construction and demolition ordinances and defers to them as the ruling guidance provided they establish a minimum 65% diversion requirement. CALGreen also provides exemptions for areas not served by construction and demolition recycling infrastructure. The State Building Code provides the minimum standard that buildings must meet in order to be certified for occupancy, which is generally enforced by the local building official.

The 2022 Title 24 Energy Standards and 2022 CALGreen have been approved by the CEC and CBSC and went into effect on January 1, 2023. Adopting all of CALGreen's 2022 standards would save more energy and reduce GHGs further than current mandates. GHGs could be reduced on average by 0.2 metric tons per building per year compared to the 2019 Title 24 Energy Code (CEC 2021). EIR Section

4.6, Energy, identifies mandatory residential and non-residential 2022 CALGreen measures applicable to the Project.

Although the 2022 Title 24 Energy Standards and 2022 CALGreen became effective on January 1, 2023, they have since been amended on July 1, 2024, with the Intervening Code Cycle Update.

Additionally, the Energy Code and CALGreen provisions are currently being updated, with the most recent draft update consisting of the 2025 California Energy and Green Building Code Standards that became effective on January 1, 2026.

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10. California Codes of Regulations, Title 20, Sections 1601 et seq. – Appliance Efficiency Regulations
The Appliance Efficiency Regulations regulate the sale of appliances in California . The Appliance Efficiency Regulations include standards for both federally regulated appliances and non- federally regulated appliances . Twenty-three categories of appliances are included in the scope of these regulations. The standards within these regulations apply to appliances that are sold or offered for sale in California, except those sold wholesale in California for final retail sale outside the state and those designed and sold exclusively for use in recreational vehicles (RV) or other mobile equipment.

11. Executive Order S-01-07 – Low Carbon Fuel Standard
Executive Order ( EO) S-01-07 is effectively known as the Low Carbon Fuel Standard (LCFS). The Executive Order seeks to reduce the carbon intensity of California’s passenger vehicle fuels by at least 10% by 2020. CARB adopted LCFS regulations in 2009. In 2018, CARB approved amendments to the regulation, which included strengthening the carbon intensity benchmarks through 2030 in compliance with the SB 32 GHG emissions reduction target for 2030. The amendments included crediting opportunities to promote zero -emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector.

12. Renewable Portfolio Standards
Senate Bill (SB) 1078 established the California Renewables Portfolio Standard (RPS) Program, which required electric utilities and other entities under the jurisdiction of the California Public Utilities Commission to meet 20% of their renewable power by December 31, 2017, for the purposes of increasing the diversity, reliability, public health, and environmental benefits of the energy mix. This was amended by SB 350 which mandated 50% by 2030. Key provisions include an increase in the RPS, higher energy e fficiency requirements for buildings, initial strategies towards a regional electricity grid, and improved infrastructure for EV charging stations. This was further modified by SB 100 and EO B-55-18, which set a target of 60% by 2030 and 100% by 2045.

C. Regional Plans, Policies, and Regulations

1. SCAQMD
The Project site is within the South Coast Air Basin (SoCAB), which is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). SCAQMD is the agency responsible for air quality planning and regulation in the S oCAB. The SCAQMD addresses the impacts to climate change of projects subject to SCAQMD permit as a lead agency if they are the only agency having discretionary approval for the project and acts as a responsible agency when a land use agency must also approve discretionary permits for the project. SCAQMD acts as an expert commenting agency for impacts to air quality. This expertise carries over to GHG emissions, so the agency helps local land use agencies through the development of models and emission thresholds that can be used to address GHG emissions.

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In 2008, SCAQMD formed a Working Group to identify GHG emissions thresholds for land use projects that could be used by local lead agencies in the SoCAB. The Working Group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA GHG Significance Threshold, which could be applied by lead agencies. The Working Group has not provided additional guidance since the release of the interim guidance in 2008 . The SCAQMD Board has not approved the thresholds; however, the Guidance Document provides substantial evidence supporting the approaches to significance of GHG emissions that can be considered by the lead agency in adopting its own threshold. Notably, SCAQMD provides an interim threshold that consists of determining whether the project is consistent with a GHG reduction plan. If a project is consistent with a qualifying local GHG reduction plan, it does not have significant GHG emissions.

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 2040 General Plan, which the City is in the process of readopting. Although the 2006 General Plan and the proposed 2040 General Plan do not identify specific GHG or climate change policies or goals, a number of the measures identified in the proposed 2040 General Plan act to reduce or control criteria pollutant emissions and peripherally reduce GHG emissions. General plan goals and policies are presented in EIR Section 4.11, Land Use and Planning, and EIR Section 4.16, Transportation.

4.8.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates land use and planning impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact related to GHG emissions would occur if the Project would:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The evaluation of an impact under CEQA requires measuring data from a project against both existing conditions and a “threshold of significance.” For establishing significance thresholds, the OPR ’s amendments to the CEQA Guidelines Section 15064.7(c) state “[w]hen adopting thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.”

CEQA Guidelines Section 15064.4(a) further states, “. . . A lead agency shall have discretion to determine, in the context of a particular project, whether to: (1) Use a model or methodology to quantify ■■
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greenhouse gas emissions resulting from a project, and which model or methodology to use . . .; or (2) Rely on a qualitative analysis or performance-based standards.”

CEQA Guidelines Section 15064.4 provides that a lead agency should consider the following factors, among others, in assessing the significance of impacts from greenhouse gas emissions:
• Consideration #1: The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting. • Consideration #2: Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
• Consideration #3: The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions. Such regulations or requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of greenhouse gas emissions . In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the proje ct’s incremental contribution is not cumulatively considerable.

The City of Moreno Valley does not currently have an adopted Climate Action Plan and has not adopted its own numeric threshold of significance for determining impacts with respect to GHG emissions. In the absence of its own numeric threshold, the City of Moreno Valley has elected to use a significance threshold of 3,000 MTCO
2e/yr which is based on the SCAQMD staff’s proposed GHG threshold for mixed use residential -commercial projects, as described in the SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (SCAQMD Interim GHG Threshold).

The 3,000 MTCO
2e/yr threshold is based on a 90% emission “capture” rate methodology. Prior to its use by the SCAQMD, the 90% emissions capture approach was one of the options suggested by the California Air Pollution Control Officers Association (CAPCOA) in their CEQA & Climate Change white paper (2008). A 90% emission capture rate means that unmitigated GHG emissions from the top 90% of all GHG -producing projects within a geographic area , the SCAB in this instance , would be subject to a detailed analysis of potential environmental impacts from GHG emissions, while the bottom 10% of all GHG -producing projects would be excluded from detailed analysis. A GHG significance threshold based on a 90% emission capture rate is appropriate to address the long- term adverse impacts associated with global climate change because medium and large projects will be required to implement measures to reduce GHG emissions, while small projects, which are generally infill development projects that are not the focus of the State’s GHG reduction targets, are allowed to proceed. Further, a 90% emission capture rate sets the emission threshold low enough to capture a substantial proportion of future development projects and demonstrate that cumulative emissions ■■
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reductions are being achieved while setting the emission threshold high enough to exclude small projects that will, in aggregate, contribute approximately 1% of projected statewide GHG emissions in the Year 2050.

In setting the threshold at 3,000 MTCO2e/yr, SCAQMD researched a database of projects kept by the OPR. That database contained 798 projects, 87 of which were removed because they were very large projects and/or outliers that would skew emissions values too high, leaving 711 as the sample population to use in determining the 90th percentile capture rate. The SCAQMD analysis of the 711 projects within the sample population combined commercial, residential, and mixed -use projects.

Emissions from each of these projects were calculated by SCAQMD to provide a consistent method of emissions calculations across the sample population and from projects within the sample population.

In calculating the emissions, the SCAQMD analysis determined that the 90th percentile r anged between 2,983 to 3,143 MTCO
2e/yr. The SCAQMD set their significance threshold at the low -end value of the range when rounded to the nearest hundred tons of emissions (i.e., 3,000 MTCO 2e/yr) to define small projects that are considered less than significant and do not need to provide further analysis.

The City understands that the 3,000 MTCO
2e/yr threshold for residential/commercial uses was
proposed by SCAQMD a decade ago and was adopted as an interim policy; however, no permanent, superseding policy or threshold has since been adopted. The 3,000 MTCO 2e/yr threshold was
developed and recommended by SCAQMD, an expert agency, based on substantial evidence as provided in the Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold (2008) document and subsequent Working Group meetings (latest of which occurred in 2010).

SCAQMD has not withdrawn its support of the interim threshold and all documentation supporting the interim threshold remains on the SCAQMD website on a page that provides guidance to CEQA practitioners for air quality analysis (and where all SCAQMD significance thresholds for regional and local criteria pollutants and toxic air contaminants also are listed). Further, as stated by SCAQMD, this threshold “uses the Executive Order S -3-05 goal [80% below 1990 levels by 2050] as the basis for deriving the screening level” and, thus, remains valid. Lastly, this threshold has been used for hundreds, if not thousands of GHG analyses performed for projects located within the SCAQMD jurisdiction.

Thus, and based on guidance from the S CAQMD, if a mixed-use project would emit GHGs less than 3,000 MTCO
2e per year, the project is not considered a substantial GHG emitter and the GHG impact is less than significant, requiring no additional analysis and no mitigation. On the other hand, if a mixed-use project would emit GHGs in excess of 3,000 MTCO 2e/yr, then the project could be
considered a substantial GHG emitter, requiring additional analysis and potential mitigation.

As previously discussed, a significance threshold of 3,000 MTCO 2e/yr is an acceptable approach for
mixed-use projects such as the TCMV Specific Plan.
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4.8.4 IMPACT ANALYSIS
Threshold a: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
The assessment of GHG emissions is inherently cumulative because climate change is a global phenomenon. GCC occurs as the result of global emissions of GHGs and an individual project like the Project cannot generate enough GHG emissions to affect a discernible change in the global climate.

As further described in EIR Section 4.3, Air Quality, in May 2022, the SCAQMD, in conjunction with CAPCOA and other California air districts, released the latest version of the California Emissions
Estimator Model (CalEEMod) Version 2022. The purpose of this model is to calculate construction- source and operational-source criteria pollutants and GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from mitigation meas ures (MMs).

Accordingly, the l atest version of CalEEMod has been used for this Project to determine GHG emissions. Output from the model runs for construction and operational activity are provided in Appendices 5.1 and 5.2 of the GHG Analysis in EIR Technical Appendix G. CalEEMod includes GHG emissions from the following source categories: construction, area, energy, mobile, water, and waste.

As described in Section 5.2.2 of the GHG Analysis included in EIR Technical Appendix G, a full life‐ cycle analysis (LCA) for construction and operational activity is not included in this analysis as it would be speculative.

Project construction actvities would generate CO
2 and CH4 emissions. For construction phase Project
emissions, GHGs are quantified and amortized over the life of the Project. To amortize the emissions over the life of the Project, the SCAQMD recommends calculating the total GHG emissions for the construction activities, dividing it by a 30-year Project life , then adding that number to the annual operational phase GHG emissions. As such, construction -related GHG emissions from the following construction activities were amortized over a 30-year period and added to the annual operational phase GHG emissions: site preparation, grading, building construction, paving, and architectural coatings.

The construction assumption for the Project (e.g., construction schedule and construction equipment) are outlined in EIR Section 3.0, Project Description, and EIR Section 4.3, Air Quality. The amortized construction emissions are presented in Table 4.8 -3, Amortized Annual Construction Emissions Summary.

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Table 4.8-3 Amortized Annual Construction Emissions Summary Year
Construction Equipment
CO2e Emissions
(MT/yr)
On-Road Vehicle CO2e
Emissions
(MT/yr)
Total
(MT/yr)
2025 118.85 10.35 129.20
2026 676.72 781.09 1,457.81
2027 571.56 953.59 1,525.15
2028 491.47 819.23 1,310.70
Total Annual Construction
Emissions 1,858.60 2,564.26 4,422.87
Amortized Construction Emissions (MTCO2e) 147.43
MT/yr = metric ton per year
Source: (Urban Crossroads 2025c)

Operational activities associated with the Project would result in emissions of CO 2, CH4, N2O, and refrigerants from the following primary sources, which are further described in Section 5.4 of the GHG Analysis included in EIR Technical Appendix G:
• Area Source Emissions
• Energy Source Emissions
• Mobile Source Emissions
• Water Supply, Treatment, and Distribution
• Solid Waste
• Refrigerants

The annual GHG emissions associated with the operation of the proposed Project are estimated to be 22,940.60 MTCO2e/yr as summarized in Table 4.8-4, Project GHG Emissions.

Table 4.8-4 Project GHG Emissions – Without Mitigation
Emission Source CO2e Emissions
(MT/yr)
Annual construction-related emissions amortized over 30 years 147.43 Mobile Source 17,406.70
Area Source 209.69
Energy Source 4,320.48
Water Usage 354.80
Waste 433.55
Refrigerants 67.95
Project Total CO2e Emissions (All Sources) 22,940.60
MT/yr= metric ton per year
Source: (Urban Crossroads 2025c)

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As shown, operation of the Project would generate a total of approximately 22,940.60 MTCO2e/yr, which would exceed the significance threshold of 3,000 MTCO2e/yr; therefore, Project -related GHG emissions are considered potentially significant. The majority of the GHG emissions (76%) are associated with non-construction related mobile sources, as shown in Table 4.8-4. Emissions of motor vehicles are controlled by State and federal standards, and neither the City nor the Project have control over these emissions. Notwithstanding, mitigation measures have been identified to reduce GHG emissions. Additionally, mitigation measures identified in EIR Section 4.3, Air Quality, also serve to reduce GHG emissions.

Threshold b: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? The Project’s consistency with the current 2006 General Plan and the proposed 2040 General Plan goals and policies that serve to reduce GHG emissions is evaluated in EIR Section 4.11, Land Use and Planning, and EIR Section 4.16, Transportation. The Project’s consistency with Connect SoCal goals is evaluated in EIR Section 4.11, Land Use and Planning, and the Project’s consistency with the regional growth projections is evaluated in EIR Section 4.14, Population and Housing. As identified, the Project would not conflict with the General Plan goals and policies, or the Connect SoCal goals and growth projections.

A. City of Moreno Valley CAP
In June 2021, the Moreno Valley City Council approved and adopted the City’s 2040 General Plan Update (2040 General Plan), a Change of Zone and Municipal Code Update, and CAP and certified an EIR, State Clearinghouse No. 2020039022, as having been prepared in compliance with CEQA in connection with the approvals. A lawsuit entitled Sierra Club v. The City of Moreno Valley, Riverside Superior Court Case No. CVRI2103300, challenged the validity of the CAP and the EIR. In May 2024, the City Council set aside the 2021 approvals and certification, based on a March 2024 ruling and judgment of the court. The City is in the process of readopting the 2040 General Plan and issued a Notice of Preparation of a Revised Environmental Impact Report for MoVal 2040: The Moreno Valley Comprehensive General Plan Update, Municipal Code and Zoning (including Zoning Atlas) Amendments, and Climate Action Plan on July 30, 2024.

As such, if the City adopts a qualified CAP and future development is determined to be consistent with that CAP, then impacts for implementing projects would be considered less than significant. However, because at this time there is no adopted CAP, the Project cannot be determined to be consistent and as such a significant and unavoidable impact is expected.

B. CARB 2022 Scoping Plan
Pursuant to CEQA Guideline Section 15604.4, a lead agency may rely on qualitative analysis or performance-based standards to determine the significance of impacts from GHG emissions. As such, the Project’s consistency with the 2022 Scoping Plan is discussed below. It should be noted that the Project’s consistency with the 2022 Scoping Plan also satisfies consistency with AB 32 since the 2022 ■■
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Scoping Plan is based on the overall targets established by AB 32 and SB 32. Consistency with the 2008 and 2017 Scoping Plan is not necessary, since both of these plans have been superseded by the 2022 Scoping Plan.

Included in the 2022 Scoping Plan is a set of Local Actions (Appendix D to the 2022 Scoping Plan) aimed at providing local jurisdictions with tools to reduce GHGs and assist the state in meeting the ambitious targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section on evaluating plan-level and project-level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development in order to determine if a project would conflict with the 2022 Scoping Plan.

The 2022 Scoping Plan includes three priority areas to reduce GHG emissions that would apply to all land use development projects. More specifically, the three priority areas include: (1) transportation electrification, (2) VMT reduction, and (3) Building Decarbonization. The potential for the Project to conflict with these three priority areas is discussed below. As discussed, the Project does not conflict with the 2022 Scoping Plan.
• Transportation Electrification. The Project would include EV charging infrastructure that, at minimum, would equal the Residential and Non-Residential Mandatory Measures in Sections 4.106.4.1, 4.106.4.2, 4.106.4.3 and Section 5.106.5.3 of CALGreen . Therefore, the Project does not conflict with this priority area.
• VMT Reduction. As identified in the Project’s VMT Assessment discussed in EIR Section

4.16, Transportation, the Project’s effect on VMT was found to be less than significant and therefore the Project would not result in a per-capita increase in VMT. Additionally, the Project cumulative effect on VMT was not found to increase VMT per service population in the baseline year or horizon year conditions. As such, based on the VMT Assessment conclusions, the Project would not conflict with this priority area. • Building Decarbonization . Per Title 24 requirements, the Project would be required to incorporate solar for the residential and commercial portion of the buildings. Additionally, the Project would be required to comply with all Title 24 Energy and CALGreen requirements as previously discussed. Further, the required GHG MMs require building electrification features.

As such, the Project does not conflict with this priority area.

Therefore, the Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions and this impact would be less than significant.

4.8.5 CUMULATIVE IMPACT ANALYSIS
As discussed above, the assessment of GHG emissions is inherently cumulative because climate change is a global phenomenon. An individual development project does not have the potential to result in direct and significant GCC-related effects in the absence of cumulative sources of GHGs .

Accordingly, the analysis provided in Subsection 4.8.4 reflects a cumulative impact analysis of the ■■
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effects related to the Project’s GHG emissions, which concludes that the Project would not conflict with applicable GHG -reduction plans, policies, or regulations, but would generate cumulatively - considerable GHG emissions that may have a significant impact on the environment because the Project would exceed the SCAQMD’s GHG emissions threshold of 3,000 MTCO 2e/yr.

4.8.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Cumulatively Considerable Impact. The Project would exceed the SCAQMD significance threshold of 3,000 MTCO 2e/yr. As such the Project would generate substantial, cumulatively - considerable GHG emissions that may have a significant impact on the environment.

Threshold b: Less than Significant Impact. The Project would be consistent with or otherwise would not conflict with applicable regulations, policies, plans, and goals that would further reduce GHG emissions.

4.8.7 MITIGATION MEASURES
The following mitigation measures are recommended to specifically reduce GHG emissions.

MM 4.8-1 The project applicant shall design and build future non-residential development to meet/include the following:
• The project will utilize on -site renewable energy sources such as solar, to reduce electrical demand as per Division A5.211, Renewable Energy, of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code.
• The project will incorporate measures to reduce the overall use of potable water within the building by 12% as per Division A5.3, Water Efficiency and Conservation, as outlined under Section A5.303.2.3.1 of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code.

Prior to the issuance of building permits for new development projects within the project site, the project applicant shall provide documentation (e.g., building plans, site plans) to the City of Moreno Valley Planning Division to verify implementation of the applicable design requirements specified in this mitigation measure. Prior to the issuance of the certificate of occupancy, the City shall verify implementation of these design requirements.

MM 4.8-2 The project applicant shall design and build future residential development to meet/include the following:
• No wood-burning fireplaces shall be installed in any of the dwelling units. ■■
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• All buildings shall be electric, to the extent feasible, meaning that electricity is the primary source of energy for water heating; heating, ventilation, and air conditioning (HVAC) within the building, excluding pool heating. • All major appliances provided/installed shall be EnergyStar- certified or of equivalent energy efficiency, where applicable.

MM 4.8-3 Exterior electric receptacles on non-residential buildings shall be provided for charging or powering electric landscaping equipment.

MM 4.8-4 The Project shall use light -color roofing and building materials to minimize the heat island effect and reduce lighting, heating, and cooling needs.

The following Project -specific mitigation measures are included in EIR Section 4.3, Air Quality .

Although these measures are designed to reduce Project air quality emissions, they would also assist in the reduction of GHG emissions. It should be noted that to provide a conservative disclosure of the Project’s GHG emissions, no reductions in emissions are assumed to occur with implementation of these measures.

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.

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MM 4.3-5 Upon occupancy and annually thereafter, the operators of the commercial space shall provide information to all delivery truck drivers, regarding:
• 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.

4.8.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold a: Significant and Unavoidable Impact. Because the majority (76%) of the Project GHG emissions would be generated by Project vehicular sources, the Project cannot feasibly achieve the SCAQMD 3,000 MTCO
2e per year threshold. Because responsibility and authority for regulation of vehicular-source emissions resides with the State of California (CARB, et al.), neither the Applicant nor the Lead Agency can affect or mandate substantial reductions in vehicular-source GHG emissions, much less reductions that would achieve the SCAQMD’s 3,000 MTCO 2e per year threshold. In effect,
all Project traffic (mobile) and energy would need to be eliminated or be “zero GHG emissions sources” to reduce emissions below the SCAQMD’s numeric threshold. There are no feasible means to or alternatives to eliminate all Project traffic or energy to ensure that Project traffic and energy would be zero GHG emissions sources. In terms of its practical application, this would constitute a “no build” condition. While neither the City nor the Project have regulatory authority to control mobile source emissions, it is noted that emissions of motor vehicles are controlled by S tate and federal standards, and these fuel efficiency and emissions standards are becoming more stringent over the years to reduce mobile source emissions.

On this basis, even with implementation of the mitigation measures identified above, the Project would generate direct or indirect GHG emissions that would exceed SCAQMD’s interim numeric threshold and, therefore, are conservatively concluded to result in a significant impact on the environment. As there are no additional feasible mitigation measures that would reduce GHG emissions to levels below the threshold, this is a significant and unavoidable impact. ■■
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4.9 HAZARDS AND HAZARDOUS MATERIALS
This section analyzes the potential impacts of existing hazards that may adversely affect the Project and hazards and hazardous materials that may be introduced by the Project. The information in this subsection is derived in part on the following site -specific study : Phase I and Limited Phase II Environmental Site Assessment NW Corner of Alessandro Boulevard and Nason Street, City of Moreno Valley, Riverside County, California, (Phase I and Limited Phase II ESA) prepared by Leighton and Associates (Leighton) (Leighton 2025b). The purpose of the Phase I and Limited Phase II ESA is to identify recognized environmental conditions (RECs), historical RECs (HRECs), or controlled RECs (CRECs) in connection to the Project site.
1 This report is provide d as EIR Technical Appendix H.

References used in this subsection are listed in EIR Section 7.0, References.

For the purposes of this Draft EIR, the term “toxic substance” is defined as a substance that, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may present an unreasonable risk of injury to human health or the environment. Toxic substances include chemical, biological, flammable, explosive, and radioactive substances. The term “hazardous material” is defined as a substance that, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may: 1) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, disposed of, or otherwise mismanaged; or 2) cause or contribute to an increase in mortality or an increase in irreversible or incapacitating illness.

Hazardous waste is defined in the California Code of Regulations (CCR), Title 22, Section 66261.3.

The defining characteristics of hazardous waste are ignitability (oxidizers, compressed gases, and extremely flammable liquids and solids), corrosivity (strong acids and bases), reactivity (explosives or generates toxic fumes when exposed to air or water), and toxicity (materials listed by the United States Environmental Protection Agency (EPA) as capable of inducing systemic damage to humans or animals). Certain wastes are called “Listed Wastes” and are found in CCR, Title 22, Sections 66261.30 through 66261.35. Wastes appear on the lists because of their known hazardous nature or because the processes that generate them are known to produce hazardous wastes (which are often complex mixtures).

4.9.1 EXISTING CONDITIONS
Currently, the Project site is undeveloped and disturbed, characterized by maintained open fields comprised of disturbed annual grassland cover vegetated with a variety of non-native and early successional weedy plant species . There are ornamental trees located along the northern Project site boundary and in the southeast portion of the Project site . There is a vacant parcel northeast of the

1 A REC is defined as the presence or likely presence of any hazardous substance or petroleum products in, on, or at a property:
(1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under cond itions that pose a material threat of a future release to the environment. An HREC is defined as a past release of any hazardous substances or petroleum product that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or that meets the unrestricted use criteria established by a regulatory authority without subjecting the property to any required controls (i.e., property use restrictions, activity and use limitations, institutional controls, or engineering controls, which would fall under a controlled recognized environmental condition or CREC). ■■
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Project site (southwest of the Nason Street and Cottonwood Avenue intersection), and an Eastern Municipal Water District (EMWD) booster station northwest of the Project site (southeast corner of Cottonwood Avenue and Letterman Street) that are not part of the Project. There are residential uses west of the Project site; residential and educational (Moreno Elementary School) uses to the north and northeast, respectively; vacant land, residential and religious uses to the east; and vacant land, educational (Valley Christian Academy), and residential uses to the south.

A. Historical Review, Regulatory Records Review, and Field Reconnaissance

1. Historical Review
Leighton contracted a search of selected environmental databases, which was completed by Environmental Data Resources, Inc. (EDR). The search was conducted in accordance with requirement of ASTM (formerly known as American Society for Testing and Materials) E1527-13. According to the historical review, from at least the 1930’s through the late 1960’s, the Project site and surrounding properties were used predominantly for agriculture/farmland with associated rural residential housing.

From at least the late 1970’s through present, the Project became vacant and undeveloped with a single rural residence up until the late 1980’s (when it appears it was removed). A large soil stockpile is visible in the southeastern portion of the Project site by 1997 and remains on site. (Leighton 2025b)

2. Regulatory Records Review
EDR also researched federal, State, and local environmental record databases to identify properties within one mile of the Project site with reported environmental issues . A detailed description of the environmental record review results is included in EIR Technical Appendix H. In summary, the Project site is not listed on any environmental record databases. There are two notable off-site listings within one mile of the Project site that are included on environmental record databases: Moreno Valley Unified School District, located at 13636 Nason Street (approximately 132 feet east of the Project site), and Mountain View Middle School Expansion, located at 13130 Morrison Avenue ( approximately 2,485 feet northwest of the Project site). The listings do not indicate any violations or release of hazardous substances or petroleum products and do not indicate a likely REC on the site . (Leighton 2025b)

3. Field Reconnaissance
As identified in the Phase I and Limited Phase II ESA (Leighton 2025b), Leighton conducted a field reconnaissance on June 16, 2021, which consisted of observing and documenting existing conditions on the Project site and adjoining properties. Limitations to the field reconnaissance included weed coverage which prohibited observations of the ground surface in many areas. During the field reconnaissance, Leighton observed the Project site as being vacant, undeveloped, unfenced, and formerly used as agricultural land; no structures exist on site. The Project site contained no hazardous substances, drums, or other chemical container s and there was no evidence of current or former underground storage tanks (USTs) containing hazardous substances or petroleum products.

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Two pad-mounted electrical transformers were observed i n the eastern portion of the Project site; however, no leaking was observed, and they appeared to post -date the ban on polychlorinated biphenyls (PCBs) in the United States (started in 1979). No evidence of likely PCBs was observed on site.

No evidence of significant dumping of hazardous waste, chemicals, hazardous substances, or petroleum products was observed on site. Leighton observed minor inert dumped trash (e.g., washers, couches, rubbish) at a few location s. Three soil stockpiles were observed: one small soil stockpile within the northwestern portion and two large soil stockpiles in the southeastern portion. The presence of undocumented soil stockpiles on site and the former agricultural use of the Project site constitute potential RECs; therefore, further investigation was completed. A Limited Phase II Investigation was completed to assess the potential for residual agricultural chemicals related to former agricultural usage at the Project site, and for certain potential compounds in the stockpiled soils. The results of the Limited Phase II Investigation are presented in Section 7.0 of the Phase I and Limited Phase II ESA included in EIR Technical Appendix H. In summary, soil samples were collected at 18 locations across the formerly agricultural portions of the Project site and at 10 locations in the undocumented soil stockpiles (refer to Figure 4.9-1, Soil Borings). The results of the soil sampling did not identify concentrations of Title 22 metals, organochlorine pesticides (OCPs), petroleum hydrocarbons (TPH ), or PCBs at concentrations exceeding the US EPA Regional Screening Levels (RSLs) for residential land use or the California D epartment of Toxic Substances Control (D TSC)-Modified Scree ning Levels for residential land use, with the exception of arsenic. Arsenic was detected at a maximum concentration of 2.73 milligrams per kilogram (mg/kg). This concentration is well below the DTSC Human Health Risk Assessment (HHRA) Note 11 ambient arsenic screening level of 12 mg/kg. All reported arsenic concentrations are acceptable for residential property usage. Therefore, the previous on-site agricultural operations and existing stockpiles do not represent RECs.

The following conditions were not observed on site: pits, ponds, lagoon, wastewater, drains, cisterns, or sumps; current or past pesticide use; significant discoloration or staining of soil; stressed vegetation; unusual odors; and current or former wells.

B. Airport Hazards
The Project site is located approximately 3.7 linear miles northeast of the March Air Reserve Base/Inland Port (MARB/IP) Airport . Based on review of Map MA -1, Compatibility Map, of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IP ALUCP), the Project site is located outside the MARB/IP Airport Influence Area (AIA) (Riverside County ALUC 2014a). Therefore, the Project site is not subject to review by the Riverside County Airport Land Use Commission for consistency with the MARB/IP ALUCP . Additionally, the Project site is located outside the 60 decibel (dB) community noise equivalence level (CNEL) noise contour and is not within the MARB/IP’s General Approach/Departure Traffic Pattern, or Closed- Circuit Traffic Pattern Envelope (Riverside County ALUC 2014b). The Project is within the identified Federal Aviation Regulation (FAR) Part 77 Military Outer Horizontal Surface Limits, as further discussed under the analysis for Threshold “e” (Riverside County ALUC 2014a). ■■
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Approximate Sample
Location
Photo Location,
Designation, and
Direction
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C. Wildland Fire Hazards
The Project site does not contain any wildlands and is not in proximity to wildlands. Additionally, the City of Moreno Valley General Plan 2040 (2040 General Plan) Map S-5, Fire Hazard Severity Zones, does not identify the Project site within a Fire Hazard Severy Zone (FHSZ ) (City of Moreno Valley 2021b)2. As further discussed in the analysis for Threshold “g” and in EIR Section 4.19, Wildfire, the nearest VHFHSZ is located approximately 0.4-mile east of the Project site, north of Cottonwood Avenue.

4.9.2 REGULATORY SETTING
The following is a brief description of the federal, state, and local environmental laws and related regulations related to hazards and hazardous materials.

A. Federal Plans, Policies, and Regulations

1. Federal Aviation Regulations Part 77
Part 77 of the Federal Aviation Regulations (FAR), Objects Affecting Navigable Airspace, establishes standards for determining obstructions to navigable airspace and the effects of such obstructions on the safe and efficient use of that airspace. The regulations require that the Federal Aviation Administration (FAA) be notified of proposed construction or alteration of objects (whether permanent, temporary, or of natural growth) if those objects would be of a height which exceeds FAR Part 77 criteria. Part 77 regulations define a variety of imaginary surfaces at certain altitudes around airports. Part 77 surfaces include the primary surface, approach surface, transitional surface, horizontal surface, and conical surface. Penetrations of Part 77 surface generally are reviewed on a case -by-case basis. FAA notification serves as the basis for:
• Evaluating the effect of the construction or alteration on operating procedures; • Determining the potential hazardous effect of the proposed construction on air navigation; • Identifying mitigating measures to enhance safe air navigation; and • Charting of new objects.

Notification allows the FAA to identify potential aeronautical hazards in advance to prevent or minimize the adverse impacts to the safe and efficient use of navigable airspace. Any person/organization who intends to sponsor any of the following construction or alterations must notify the Administrator of the FAA:
• Any construction or alteration exceeding 200 feet above ground level. • Any construction or alteration:

2 The fire hazard severity zone information provided in the City of Moreno Valley General Plan 2040 (2040 General Plan), which the City is in the process of readopting, remains applicable to the discussion of the City’s environmental setting regarding fire hazards. The court decision did not address this topical issue. ■■
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o within 20,000 feet of a public use or military airport which exceeds a 100:1 surface from any point on the runway of each airport with at least one runway more than 3,200 feet.
o within 10,000 feet of a public use or military airport which exceeds a 50:1 surface from any point on the runway of each airport with its longest runway no more than 3,200 feet.
o within 5,000 feet of a public use heliport which exceeds a 25:1 surface. • Any highway, railroad, or other traverse way whose prescribed adjusted height would exceed that above noted standards.
• When requested by the FAA.
• Any construction or alteration located on a public-use airport or heliport regardless of height or location.

2. Hazardous Materials Transportation Act (HMTA)
The Hazardous Materials Transportation Act of 1975 (HMTA) empowered the Secretary of Transportation to designate as hazardous material any "particular quantity or form" of a material that "may pose an unreasonable risk to health and safety or property." Hazardous materials regulations are subdivided by function into four basic areas:
• Procedures and/or Policies 49 CFR Parts 101, 106, and 107 • Material Designations 49 CFR Part 172
• Packaging Requirements 49 CFR Parts 173, 178, 179, and 180 • Operational Rules 49 CFR Parts 171, 173, 174, 175, 176, and 177

The HMTA is enforced by use of compliance orders (49 U.S.C. 1808[a]), civil penalties (49 U.S.C. 1809[b]), and injunctive relief (49 U.S.C. 1810). The HMTA (Section 112, 40 U.S.C. 1811) preempts state and local governmental requirements that are inconsistent with the statute, unless that requirement affords an equal or greater level of protection to the public than the HMTA requirement.

3. Hazardous Materials Transportation Uniform Safety Act of 1990 In 1990, Congress enacted the Hazardous Materials Transportation Uniform Safety Act (HMTUSA) to clarify the maze of conflicting state, local, and federal regulations. Like the HMTA, the HMTUSA requires the Secretary of Transportation to promulgate regulations for the safe transport of hazardous material in intrastate, interstate, and foreign commerce. The Secretary also retains authority to designate materials as hazardous when they pose unreasonable risks to health, safety, or property. The statute includes provisions to encourage uniformity among different state and local highway routing regulations, to develop criteria for the issuance of federal permits to motor carriers of hazardous materials, and to regulate the transport of radioactive materials.

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4. Occupational Safety and Health Act
Congress passed the Occupational and Safety Health Act (OSHA) to ensure worker and workplace safety. Their goal was to make sure employers provide their workers with a place of employment free from recognized hazards to safety and health, such as exposure to toxic chemicals, excessive noise levels, mechanical dangers, heat or cold stress, or unsanitary conditions. In order to establish standards for workplace health and safety, the Act also created the National Institute for Occupational Safety and Health (NIOSH) as the research institution for OSHA. OSHA is a division of the U.S. Department of Labor that oversees the administration of the Act and enforces standards in all 50 states.

5. Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) serves as the basis for the proper management of hazardous and non-hazardous solid waste s. The RCRA amended the Solid Waste Disposal Act of 1965 and is implemented through the following programs:
• The Solid Waste Program encourages States to develop comprehensive plans to manage non- hazardous industrial solid wastes and municipal solid wastes; sets criteria for municipal solid waste landfills and other solid waste disposal facilities; and prohibits the open dumping of solid wastes.
• The Hazardous Waste Program establishes a system for controlling hazardous waste from the time it is generated until its ultimate disposal, in effect from “cradle to grave.” • The Underground Storage Tank (UST) Program regulates USTs containing hazardous substances and petroleum products.

In November 1984, the RCRA was amended with the passing of the Federal Hazardous and Solid Waste Amendments (HSWA) to phase out the land disposal of hazardous waste s; to i ncrease the USEPA’s enforcement authority; to set more stringent hazardous waste management standards; and to develop a comprehensive UST program. The RCRA has been further amended by the Federal Facility Compliance Act of 1992 (which strengthened the enforcement of RCRA at federal facilities) and the Land Disposal Program Flexibility Act of 1996 (which provided regulatory flexibility for land disposal of certain wastes).

6. Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) of 1976 provides EPA with authority to require reporting, record-keeping, and testing requirements, and restrictions relating to chemical substances and/or mixtures. Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics, and pesticides. TSCA addresses the production, importation, use, and disposal of specific chemicals including PCBs, asbestos, radon, and lead -based paint. Various sections of TSCA provide authority to:
• Require, under Section 5, pre-manufacture notification for "new chemical substances" before manufacture.
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• Require, under Section 4, testing of chemicals by manufacturers, importers, and processors where risks or exposures of concern are found.
• Issue Significant New Use Rules (SNURs), under Section 5, when it identifies a "significant new use" that could result in exposures to, or releases of, a substance of concern. • Maintain the TSCA Inventory, under Section 8, which contains more than 83,000 chemicals.

As new chemicals are commercially manufactured or imported, they are placed on the list. • Require those importing or exporting chemicals, under Sections 12(b) and 13, to comply with certification reporting and/or other requirements.
• Require, under Section 8, reporting and record-keeping by persons who manufacture, import, process, and/or distribute chemical substances in commerce. • Require, under Section 8(e), that any person who manufactures (including imports), processes, or distributes in commerce a chemical substance or mixture and who obtains information which reasonably supports the conclusion that such substance or mixture pre sents a substantial risk of injury to health or the environment to immediately inform EPA, except where EPA has been adequately informed of such information. EPA screens all TSCA Section 8(e) submissions as well as voluntary "For Your Information" (FYI) submissions. The latter are not required by law, but are submitted by industry and public interest groups for a variety of reasons.

B. State Plan, Policies, and Regulations

1. California Accidental Release Prevention Program
The California Accidental Release Prevention Program (CalARP), managed by the Certified Unified Program Agency (CUPA), discussed below, is a merging of the Federal Accidental Release Prevention Program and State programs for the prevention of accidental release of regulated toxic and flammable substances. It replaced the California Risk Management and Prevention Program and was created t o eliminate the need for two separate and distinct risk management programs. Stationary sources exceeding a threshold quantity of regulated substances are evaluated under this program to determine the potential for and impacts of accidental releases from the source. Depending on the potential hazards, the owner or occupant of a stationary source may be required to develop and submit a risk management plan.

2. Cal/OSHA and the California State Plan
Since 1973, California has operated an occupational safety and health program in accordance with Section 18 of the federal OSHA. The State of California’s Department of Industrial Relations administers the California Occupational Safety and Health Program, commonly referred to as Cal/OSHA. The State of California’s Division of Occupational Safety and Health (DOSH) is the principal agency that oversees plan enforcement and consultation. In addition, the California State program has an independent Standards Board responsible for promulgating State safety and health standards and reviewing variances. It also has an Appeals Board to adjudicate contested citations and ■■
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the Division of Labor Standards Enforcement to investigate complaints of discriminatory retaliation in the workplace.

Pursuant to 29 CFR 1952.172, the California State Plan applies to all public and private sector places of employment in the State, except for federal employees, the United States Postal Service, private sector employers on Native American lands, maritime activities on the navigable waterways of the United States, private contractors working on land designated as exclusively under federal jurisdiction and employers that require federal security clearances. Cal/OSHA is the only agency in the State authorized to adopt, amend, or repeal occupational safety and health standards or orders. The Cal/OSHA enforcement unit conducts inspections of California workplaces in response to a report of an industrial accident, a complaint about an occupational safety and health hazard, or as part of an inspection program targeting industries with high rates of occupational hazards, fatalities, injuries , or illnesses.

3. California Hazardous Waste Control Law
The responsibility for implementing the RCRA was given to California Environmental Protection Agency’s (Cal EPA) DTSC in August 1992. The DTSC is also responsible for implementing and enforcing California’s own hazardous waste laws. The Hazardous Waste Control Law (HWCL) (Health and Safety Code [HSC], Division 20, Chapter 6.5, Article 2, Section 25100, et seq.) is the primary hazardous waste statute in California. The HWCL implements RCRA as a “cradle -to-grave” waste management system in the State. It specifies that generators have the primary duty to determine whether their wastes are hazardous and to ensure its proper management. The HWCL also establishes criteria for the reuse and recycling of hazardous wastes used or reuse d as raw materials. The HWCL exceeds federal requirements by mandating source reduction planning and broadening requirements for permitting facilities that treat hazardous waste . It also regulates several waste types and waste management activities not covered by federal law (RCRA).

4. California Code of Regulations, Titles 5, 17, 22 and 26 A variety of CCR titles address regulations and requirements related to hazardous materials and hazardous waste. Title 5 contains the California Plumbing Code which, in Appendix I, establishes detailed standards for the capping, removal, fill, and disposal of cesspools, septic tanks, and seepage pits (see H 1101.0). CCR Title 17, Division 1, Chapter 8, defines and regulates handling and disposal of lead-based paint. Any detectable amount of lead is regulated. Title 22 contains detailed compliance requirements for hazardous waste generators, transporters, and facilities for treatment, storage, and disposal. Because California is a fully authorized state according to RCRA, most regulations (i.e., 40 CFR 260, et seq.) have been duplicated and integrated into Title 22. However, because the DTSC regulates hazardous waste more stringently than the Cal EPA, the integration of State and federal hazardous waste regulations that makeup Title 22 does not contain as many exemptions or exclusions as does 40 CFR 260. As with the HSC, Title 22 also regulates a wider range of waste types and waste management activities than does RCRA. To aid the regulated community, California has compiled hazardous materials, waste, and toxics -related regulations from CCR, Titles 3, 8, 13, 17, 19, 22, 23, ■■
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24, and 27 into one consolidated listing: CCR Title 26 (Toxics). However, the hazardous waste regulations are still commonly referred to collectively as “Title 22.”

5. California Government Code Sections 51178 and 51182
California Government Code (CGC) Section 51178 specifies that the Director of CalFire, in cooperation with local fire authorities, shall identify areas that are VHFHSZ in Local Responsibility Areas (LRAs), based on consistent statewide criteria, and the expected severity of fire hazard. Per CGC Section 51178, a local agency may, at its discretion, exclude from the requirements of Section 51182 an area within its jurisdiction that has been identified as a VHFHSZ, if it provides substantial evidence in the record that the requirements of Section 51182 are not necessary for effective fire protection within the area. Alternatively, local agencies may include areas not identified as VHFHSZ by CalFire, following a finding supported by substantial evidence in the record that the requirements of Section 51182 are necessary for effective fire protection within the new area. According to Section 51182, such changes made by a local agency shall be final and shall not be rebuttable by CalFire.

CGC Section 51182 identifies actions required to be taken by a person who owns, leases, controls, operates, or maintains an occupied dwelling or occupied structure in, upon, or adjoining a mountainous area, forest -covered land, brush-covered land, grass -covered land, or land that is covered with flammable material, which area or land is within a VHFHSZ designated by the local agency pursuant to Section 51179, to protect against wildfires.

C. Local Plans, Policies, and Regulations

1. Local Permitting Requirements
The aforementioned federal and State hazardous materials regulations require all businesses that handle more than a specified amount of hazardous materials or extremely hazardous materials to obtain a hazardous materials permit and submit a business plan to its local Certified Unified Program Agency (CUPA). The CUPA also ensures local compliance with all applicable hazardous materials regulations.

The CUPA with responsibility for the City of Moreno Valley is the Riverside County Department of Environmental Health (DEH). The Riverside County DEH manages and oversees 25 other programs related to hazardous materials/waste, including programs related to the handling and storage of hazardous materials, hazardous materials remediation, petroleum storage tanks, green waste, solid waste, liquid waste, universal waste , and environmental cleanup. The Riverside County DEH also manages and oversees programs related to emergency response and enforcement, vector control and water quality.

2. City of Moreno Valley Local Hazard Mitigation Plan
The City of Moreno Valley Local Hazard Mitigation Plan (LHMP) (adopted 2011 and revised 2022) is designed to identify the City’s hazards, estimate the probability of future occurrences, and set goals to mitigate potential risks to reduce or eliminate long -term natural (e.g., earthquakes, wildland fires, flooding, landslides), or man- made hazard (e.g., terrorist attack, civil unrest) risks to human life and ■■
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property for the city and its residents. The LHMP assesses the risks associated with earthquakes, wildland, and urban fires, insect infestation, extreme weather, severe wind, and dam failure/inundation.

3. Emergency Operations Plan
The purpose of the City’s Emergency Operations Plan (EOP) (2019) is to provide guidance for the City’s response to extraordinary emergency situations associated with natural, man-made , and technological disasters. The EOP does not address ordinary day-to-day emergencies or the established routine procedures used to cope with such incidents. Rather, it focuses on operational concepts and response procedures relative to large -scale emergencies and disasters. The City’s primar y and secondary Emergency Operations Centers are located within the City Hall complex, approximately 3.9 miles west of the Project site.

4.9.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates hazards and hazardous materials impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact would occur if the Project would:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

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4.9.4 IMPACT ANALYSIS
Threshold a: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Threshold b: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Implementation of the Project would involve construction activities and long-term operation of residential, commercial, civic, and park uses on the site. In the event any hazards or hazardous materials were to be present on the Project site or any hazardous materials were to be used or stored on the Project site during construction or long-term operation, the Project would have the potential to expose workers onsite, the public, and/or the environment to a substantial hazard. The analysis below evaluates the potential for the Project to result in a substantial hazard to people or the environment during any stage of the Project.

A. Impact Analysis for RECs
As previously discussed, based on the results of the Phase I and Limited Phase II ESA, the Project site does not have evidence of RECs, USTs, PCBs, or other significant hazardous materials or substances.

Potential RECs were identified due to the Project site’s historical use for agricultural purposes and the presence of stockpiled soils onsite ; however, based on testing of soil samples taken from the Project site (refer to Figure 4.9-1, Soil Borings), the reported concentrations of arsenic concentrations, OCPs, TPH are acceptable for residential land use s (Leighton 2025b). Therefore, the historical agricultural use of the Project site and stockpiled soils do not represent a REC; thus, no human health risk is present and implementation of the Project would not pose a significant hazard to the public or the environment.

This would be a less than significant impact.

B. Impact Analysis for Construction -Related Activities Heavy equipment (e.g., dozers, excavators, tractors) would be operated on the Project site during construction. This heavy equipment likely would be fueled and maintained by petroleum‐based substances such as diesel fuel, gasoline, oil, and hydraulic fluid, which are considered hazardous if improperly stored or handled. In addition, materials such as paints, adhesives, solvents, and other substances typically used in building construction would be located on the Project site during construction. Improper use, storage, or transportation of hazardous materials can result in accidental releases or spills, potentially posing health risks to workers, the public, and the environment. This is a standard risk on all construction sites, and there would be no greater risk for improper handling, transportation, or spills associated with the Project than would occur on any other similar construction sites. Construction contractors would be required to comply with all applicable federal, State, and local laws and regulati ons regarding the transport, use, and storage of hazardous construction‐related materials, including but not limited to, requirements imposed by the Cal EPA, DTSC, and the Santa Ana Regional Water Quality Control Board (RWQCB ). With mandatory compliance with applicable hazardous materials regulations, the Project would not create a significant hazard to the public or the ■■
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environment through routine transport, use, or disposal of hazardous materials during the construction phase. Impacts would be less than significant.

Additionally, construction activities would be completed in compliance with applicable regulatory requirements, including the State Water Resources Control Board (SWRCB ) National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction Activity (Construction General Permit). As required, best management practices (BMPs) identified in the P roject’s Storm Water Pollution Prevention Plan (SWPPP) to control potential construction-related pollutants would be implemented, as further discussed in EIR Section 4. 10, Hydrology and Water Quality.

C. Impact Analysis for Operation al Activities
The operational phase of implementation of the proposed TCMV Specific Plan would occur following the completion of construction and business operators/employees, and residents move in and occupy the structures and facilities on a day-to -day basis. Hazards waste generators in the TCMV Specific Plan area would include businesses, public institutions, and households.

As described in EIR Section 3.0, Project Description, implementation of the proposed TCMV Specific Plan would result in the development of various residential, commercial, civic , and park uses. For purposes of analysis in this EIR, it is anticipated that following types of allowed uses would be developed: single-family and multi-family residential uses, business professional office uses, hotel, civic center, res taurant (sit-down and drive -thru), general retail uses, and parks. These uses would involve the use of materials common to all urban development that are labeled hazardous (e.g., solvents and commercial cleansers; petroleum products; and pesticides, fertilizers, and other landscape maintenance materials). There is the potential for routine use, storage, or transport of other hazardous materials; however, the precise materials are not known, as the actual types of non-residential uses to be developed are not yet known. In the event that hazardous materials, other than those common materials described above, are associated with future operations, the hazardous materials would only be stored and transported to and from the building sites. The Project would not utilize, store, or generate hazardous materials or waste in quantities that may pose a significant hazard to the public.

Manufacturing and other chemical processing are not allowed and would not occur within the proposed uses.

State and federal Community-Right-to -Know laws allow the public access to information about the amounts and types of chemicals that may be used by business on the Project site. Laws also are in place that require businesses to plan and prepare for possible chemical emergencies. Any business that occupies on-site buildings and that handles/stores substantial quantities of hazardous materials (as defined in Section 25500 of HSC, Division 20, Chapter 6.95) would require a permit from the Riverside County Fire Department, Hazardous Materials Division, in order to register the business as a hazardous materials handler. Such businesses also are required to comply with California’s Hazardous Materials Release Response Plans and Inventory Law, which requires immediate reporting to the Riverside County Fire Department and the State Office of Emergency Services regarding any release or ■■
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threatened release of a hazardous material, regardless of the amount handled by the business, and to prepare a Hazardous Materials Business Emergency Plan (HMBEP). An HMBEP is a written set of procedures and information created to help minimize the effects and extent of a release or threatened release of a hazardous material.

With mandatory regulatory compliance, the Project would not pose a significant hazard to the public or the environment through the routine transport, use, storage, emission, or disposal of hazardous materials, nor would the Project increase the potential for accident conditions which could result in the release of hazardous materials into the environment. Impacts would be less than significant.

Threshold c: Wo
uld the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
The following existing and proposed schools are located within one-quarter mile of the Project site:
• Early Learning Academy - 26700 Cottonwood Avenue, the nearest building is approximately 351 feet northwest of the Project site. This school site is occupied by the Moreno Valley Unified School District (MVUSD) Early Learning Academy for infant to kindergarten- aged children.
• Valley Christian Academy - 26755 Alessandro Boulevard, the nearest building is approximately 163 feet south of the Project site.
• Valley View High School – 13135 Nason Street, approximately 0.25-mile north of the Project site (athletic facilities and surface parking are located at the southern portion of the high school).
• Moreno Elementary School - 13700 Nason Street, the nearest building is approximately 220 feet east of the Project site (on the east side of Nason Street).

As previously discussed, the Project has the potential to involve the transport and use of hazardous substances, materials, and/or wastes to-and-from the Project site during construction and long-term operation. However, the Project would not utilize, store, or generate hazardous materials or waste in quantities that may pose a significant hazard to the public. Additionally, construction and operational activities would be required to comply with applicable federal, State, and local regulations which would preclude substantial public safety hazards associated with emissions, handling of, or the routine transport of hazardous substances, materials, and/or wastes to-and-from the Project site. Impacts would be less than significant.

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Threshold d: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? According to the DTSC and the Phase I and Limited Phase II ESA, the Project site is not identified on any list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Leighton 2025b). Further, based on review of the California Environmental Protection Agency (CalEPA) Cortese List Data Resources, the Project site is not located on any list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (CalEPA 2024). As such, the Project would not create a significant hazard to the public or the environment. No impact would occur.

Threshold e: For
a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project result in a safety hazard or excessive noise for people residing or working in the project area?
As previously discussed, the Project site is not located within the MARB/IP ALUCP and is located more than two miles from the MARB/IP Airport. The Project site is not located within the AIA for the MARB/IP Airport and specifically is located outside the 60 dB CNEL noise contour and safety zones identified in the MARB/IP ALUCP. Additionally, while the Project is within the identified FAR Part 77 Military Outer Horizontal Surface Limits , the Project does not involve any construction activi ties that would require FAA notification pursuant to FAR Part 77. Notably, the Project is more than 20,000 feet from the nearest runway (approximately 21,900 feet to the northeast) and would not involve any structures more than 200 feet high (the proposed TCMV Specific Plan has a maximum building height of 75 feet). Accordingly, the Project would not result in a safety hazard or excessive noise related to air travel for people residing or working in the Project area. Impacts would be less than significant.

Threshold f: Wo
uld the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The City adopted its current LHMP in 2022. The LHMP identifies I-215, SR-60, and major roadways through the City as emergency evacuation routes. Currently, the Project site is undeveloped. There are no emergency facilities located at the Project site; however, Alessandro Boulevard and Cottonwood Avenue, which border the Project site to the south and north, respectively, are identified in the LHMP as primary evacuation routes (City of Moreno Valley 2022a). Nason Street, which borders the Project site to the east, is not identified as a primary or alternate evacuation route; however, it is a north-south route, connecting to SR-60 to the north. Additionally, the Morrison Park Fire Station is located at 13400 Morrison Street, approximately 0.25-mile northwest of the Project site. During construction and long-term operation, the proposed Project would be required to maintain adequate emergency access for emergency vehicles. Further, the Project involves the construction of the extension of Bay Avenue from its current terminus west of the Project site east to Nason Street, and a new north-west street connecting Alessandro Boulevard and Cottonwood Avenue, which would enhance emergency access.

The Project would not substantially impede emergency response in the local area. ■■
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The City’s EOP is a preparedness document that provides guidance for the City’s response to extraordinary emergency situations associated with natural, man- made, and technological disasters.

The EOP concentrates on operational concepts and response procedures relative to large -scale emergencies and disasters . City departments are responsible for assuring the preparation and maintenance of Standardized Operating Procedures, resource lists , and checklists that detail how assigned responsibilities are performed and to ensure that they support the implementation of the EOP.

The Project would not interfere with the City’s EOP. Accordingly, implementation of the Project would not impair implementation of or physically interfere with an adopted emergency response plan or an emergency evacuation plan, and no impact would occur.

Threshold g: Wo
uld the Project expose people or structure, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? The Project site does not contain wildlands and is not in proximity to wildlands . Additionally, the Project site is not within a VHFHSZ . As previously discussed, the nearest VHFHSZ is located approximately 0.4-mile east of the Project site. The Project site is surrounded by existing development and undeveloped and disturbed property that is subject to vegetation management activities, similar to the Project site. The Project would not expose people or structures, either directly or indirectly to significant risk of loss, injury, or death involving wildland fires. Impacts would be less than significant.

4.9.5 CUMULATIVE IMPACT ANALYSIS
As discussed above under the responses to Thresholds “a” and “b,” the Project’s construction and operation would be required to comply with all applicable federal, State, and local regulations to ensure proper use, storage, and disposal of hazardous substances. Such uses also would be subject to additional review and permitting requirements by the Riverside County Fire Department . Similarly, any other developments in the area proposing the construction of uses with the potential for use, storage, or transport of hazardous materials also would be required to comply with applicable federal, State, and local regulations, and such uses would be subject to additional review and permits from their local oversight agency. Additionally, based on the laboratory testing results, there were no concentrations of chemicals detected that exceed established regulatory standards for residential uses or that would otherwise pose a hazard to the public. Therefore, the potential for release of toxic substances or hazardous materials into the environment, either through accidents or due to routine transport, use, or disposal of such materials, would be less than significant for the Project and cumulative development.

Accordingly, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact related to hazardous materials.

The Project site is located within one-quarter mile of existing school sites. However, due to the nature of the Project (mixed-use with residential, commercial, civic, and park uses), there would not be any hazardous emissions, and the handling of hazardous materials, substances, or waste would not involve the type or quantity that would pose a significant hazard to school children, resulting in a less than significant impact. Therefore, the Project would not contribute to a cumulatively significant hazards/hazardous materials impact on any public or private schools located within one -quarter mile of the Project site.
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The Project site is not identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; therefore, the Project would not contribute to a cumulatively significant hazardous materials impact associated with a listed hazardous materials site.

The Project site is not within the AIA for the MARB/IP Airport , including established safety zones and areas of excessive noise. Additionally, the Project construction and operations would not exceed established height restrictions requiring FAA notification pursuant to FAR Part 77. Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area and would not contribute to a cumulatively considerable impact associated with airport hazards.

The Project site does not contain any emergency facilities, nor does it serve as an emergency evacuation route. Further, the Project would involve implementation of roadway and site access improvements and would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan area. Similarly, cumulative development in proximity to the Project area would be required to adhere to emergency access requirements. The Project would not contribute to any cumulative impacts associated with an ado pted emergency response plan or emergency evacuation plan.

The Project site does not contain wildlands and is not within a VHFHSZ ; the nearest VHFHSZ is approximately 0.4-mile east of the Project site with intervening development and vacant sites with maintained vegetation. The potential for the P roject to expose people or structure, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires is less than significant.

Cumulative developed proposed within VHFHSZs would be required to meet minimum fire fuel modification and/or clearing requirements in addition to meeting the standards of the various fire codes in effect at the time of building permit issuance, including but not limited to the state fire code, CBC, and MVMC. T he CBC outlines building design requirements related to building materials and construction methods for exterior wildfire exposure. With adherence to applicable requirements, cumulative development within the VHFHSZ would not increase hazards from wildland fires and hazards to adjacent properties. The Project would not contribute to any cumulative impacts associated with wildland fires.

4.9.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a and b: Less than Significant Impact. The Project site does not contain any RECs. During Project construction and operation, mandatory compliance with federal, State, and local regulations would ensure that the Project would not create a significant hazard to the environment due to routine transport, use, disposal, or upset of hazardous substances or materials. Additionally, due to the nature of the Project, routinely used hazardous materials would not be of the type or occur in sufficient quantities to pose a significant hazard to public health and safety or the environment.

Threshold c: L
ess than Significant Impact. The Project site is located within one -quarter mile of existing schools; however , there would be no hazardous emissions, and the handling of hazardous ■■
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materials, substances, or waste would not involve the type or quantity that would pose a significant hazard to public health and safety or the environment. Additionally, the Project would be required to comply with federal, State, and local regulations to ensure that the Project would not create a significant hazard to the public or environment.

Threshold d: N
o Impact. The Project site is not identified on any list of hazardous materials sites complied pursuant to Government Code Section 65962.5.

Threshold e: L ess than Significant Impact. The Project site is located more than two miles northeast of MARB/IP Airport and is not within the AIA . Additionally, the Project does not involve any construction or operations that require FAA notification pursuant to FAR Part 77. As such, the Project would not result in an airport safety hazard for people residing or working in the Project area.

Threshold f: N o Impact. The Project site does not contain any emergency facilities, nor does it serve as an emergency evacuation route. During construction and long-term operation, adequate emergency vehicle access is required to be provided. The Project would involve the construction of new roadways, which would improve local access. Accordingly, implementation of the Project would not impair implementation of or physically interfere with an adopted emergency response plan or an emergency evacuation plan.

Threshold g: Less than Significant Impact. T he Project site does not contain wildlands and is not within a VHFHSZ; the nearest VHFHSZ is approximately 0.4-mile from the Project site . The Project would not expose people or structures to a significant wildfire risk.

4.9.7 MITIGATION
Impacts would be less than significant, and mitigation is not required. ■■
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4.10 HYDROLOGY AND WATER QUALITY
This subsection identifies and evaluates the Project’s potential to have adverse hydrology/drainage and water quality effects during construction and operation. The information presented in this section is primarily based on the following technical reports. References used in this subsection are listed in EIR Section 7.0, References.
• Preliminary Project Specific Water Quality Management Plan, Tentative Tract Map 38421, Town Center at Moreno Valley Specific Plan (Preliminary WQMP) prepared by Cannon, and included in EIR Technical Appendix I (Cannon 2022)
• Drainage Report, Town Center at Moreno Valley Specific Plan, Tentative Tract Map 38421, Moreno Valley, California (Drainage Report) prepared by Cannon, and include d in EIR Technical Appendix J (Cannon 2025)

Information for this subsection also was obtained from the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Plan (updated June 2019) and the Integrated Regional Water Management Plan (IRWMP) for the Santa Ana River Watershed (also referred to as “One Water One Watershed Plan Update 2018,” (February 19, 2019) prepared by the Santa Ana Watershed Project Authority (SAWPA). These documents are herein incorporated by reference and are available for public review at the physical locations and website addresses given in EIR Section 7.0, References.

4.10.1 EXISTING CONDITIONS
A. Regional Hydrology
The Project site is in the San Jacinto Watershed . The 24- mile-long San Jacinto River is the main drainage feature in this watershed and flows from the San Jacinto Mountains, across the San Jacinto Valley, to Canyon Lake, and finally to its terminus in Lake Elsinore, which discharges into Temescal Wash, which is tributary to the Santa Ana River. T he Santa Ana River watershed is under the jurisdiction of the Santa Ana Regional Water Quality Control Board (RWQCB) and drains a 2,840 square-mile area. The Santa Ana River is the principal surface flow water body within the region and includes the upper and lower Santa Ana River watersheds and the San Jacinto River watershed, with several other small drainage areas. The total length of the Santa Ana River and its major tributaries is approximately 700 miles (SAWPA 2019). The Santa Ana River rises in Santa Ana Canyon in the southern San Bernardino Mountains and runs southwesterly across San Bernardino, Riverside, and Orange Counties, where it discharges into the Pacific Ocean at the City of Huntington Beach.

B. Site Hydrology
Under existing conditions, the Project has a subtle topographic north-south aligned ridge on the eastern portion of the Project site that separates the drainage at the site, which flows to existing storm drains along Nason Street, Alessandro Boulevard, and Bay Avenue (refer to Figure 4.10-1, Existing Hydrology Exhibit).

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■ D Environmental Impact Report
~ --i----r-,--~- - -
V.,t- -~ .. t
~~- : .. «"·'-
Source(s): Cannon (2025)
City of Moreno Valley

4.10 Hydrology and Water Quality
EX/ 84" RCP
~
100 200
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1 INCH = 100 FEET
Figure 4.10- l
Existing Hydrology Exhibit

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There is an existing storm drain in Nason Street, located along the eastern portion of the Project, with several stubs to the Project site. Runoff from the eastern portion of the Project site (approximately 17.9 acres) drains across the Project site as sheet flow into the existing storm drain at Nason Street and then is conveyed into the existing field inlet and 36-inch storm drain located at the northwest corner of Alessandro Boulevard and Nason Street. In addition to the Project site, the undeveloped property (approximately 8.2 acres) northeast of the Project site also drains to this storm drain line. This line can receive a maximum of 38.9 c ubic feet per second (cf s), and discharges into the 78- inch and 84-inch reinforced concrete pipe (RCP) within Nason Street, which ultimately flows to the Riverside County Flood Control and Water Conservation District (RCFC&WCD) Line F, which is channelized and no longer subject to hydromodification.

Runoff from the western portion of the Project site drains across the site as sheet flow towards Bay Avenue and Alessandro Boulevard. Runoff from the southwestern portion of the site (approximately

24.6 acres south of the future alignment of Bay Avenue) drains south toward Alessandro Boulevard and flows into the existing 36-inch storm drain within Alessandro Boulevard west of the Project site.

In addition to stormwater from the western portion of the Project site, this drain accepts flow from approximately 18.6 acres immediately west of the site. The drain accepts 94.6 cfs according to the 2011 Moreno Master Drainage Plan (MDP) as built for Line J-6. The 36-inch storm drain stubbed to the roadside discharges into the 48-inch RCP storm drain within Alessandro Boulevard and directed further west.

Runoff from the northwest portion of the Project site (approximately 23.5. acres) primarily flows west towards the Bay Avenue storm drain. The Bay Avenue storm drain accepts 62.5 cfs from the northwest portion of the Project site according to the 2011 Moreno MDP as built for Line J-4.

C. Flooding
According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) No. 06065C0765G, dated August 28, 2008, the Project site is within “Zone X,” which corresponds to areas with minimal flood hazard. No portions of the Project site are within a 100-year floodplain (FEMA 2008).

D. Groundwater
As further discussed in EIR Section 4.18, Utilities and Service Systems , the City of Moreno Valley, including the Project site, is located within the San Jacinto groundwater basin. As further discussed in Section 4.10.2 below, the California State Department of Water Resources (DWR) classifies the San Jacinto groundwater basin as a “high priority” basin.

Groundwater was not encountered during the field exploration of the Project site, which extended to depths of approximately 51 feet below the ground surface (bgs). The groundwater level was measured in March 2021 at approximately 1,470 feet mean sea level (amsl) (40 feet bgs) at well EMWD25695, which is located approximately one mile south of the Project site. It should be noted that locally perched water conditions can occur and may fluctuate seasonally, depending on rainfall. No surface ■■
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Moreno Valley City CouncilJune 3, 2025

Moreno Valley City Council
June 3, 2025