7.0_TCMV SP_Draft EIR.pdf — Moreno Valley City Council, June 3, 2025 (part 5 of 6)

The Project would not result in the result in the need for new or physically altered fire protection facilities and no physical environmental impacts would result. Impacts would be less than significant.

B. Police Protection Services
As identified above, implementation of the proposed TCMV Specific Plan would involve the development of residential, commercial/civic, and park uses, and would result in an associated increase in residents and employment opportunities in the City. This would increase existing demands for police protection services at the Project site, which is currently undeveloped.

Anticipated crime and safety issues during construction at the Project site include theft of building materials and construction equipment, malicious mischief, graffiti, and general vandalism. During operation, the Project could create the typical range of police service calls that other similar uses in the City experience. The primary types of crimes experienced in non-residential areas are property crimes (e.g., burglary, larceny, theft/auto theft, arson, shoplifting, vandalism). In addition to property crimes, “crimes against persons” are typically associated with residential uses. These include, but are not limited to, assault, battery, domestic violence, sexual and child abuse, and robberies. The increase in vehicle trips on public roadways resulting from the Project could also increase the potential for traffic accidents and violations.

Residents, employees, visitors, patrons, and other individuals that would come to the Project site would have to comply with the regulations in the MVMC and the California Penal and Vehicle Codes, as monitored and enforced by the MVPD. However, based on the proposed land uses, and the anticipated increase in calls for service in the area compared to existing conditions, implementation of the Project would require additional police protection services. As individual projects are proposed in the City, MVPD service levels and staffing requirements are evaluated to determine if additional staffing and/or facilities would be required. The MV PD would ultimately determine the timing and number of new officers hired as part of its standard staffing practices based on the amount and type of land uses ultimately developed.

The Project would not require the construction of new or expanded off-site police protection facilities; however, a police substation, could be accommodated within the TCMV Specific Plan area, if required by the City in the future. Any onsite facilities to support the MV PD would occur in the impact area analyzed in this EIR and would not result in additional environmental impacts.

Additionally, the Project Applicant would be required to comply with the provisions of MVMC Title 3 related to DIF payments, which would be used for the purpose of acquiring, designing, constructing, improving, providing, and maintaining, police services facilities provided for in the General Plan and CIP, and would ensure the contribution of the Project’s fair share of the cost of these facilities. The required DIF payments for police services facilities are applicable to residential and commercial uses anticipated in the proposed TCMV Specific Plan.

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The Project would not result in the result in the need for new or physically altered police facilities and no physical environmental impacts would result. Impacts would be less than significant.

C. School Services
Impacts to school services are primarily driven by increases in permanent population; therefore, student generation is estimated based on the number of proposed residential units. The development of additional dwelling units has the potential to place a greater demand on the existing public school system by generating additional students to be served by the MVUSD . As indicated in Table 4.15 -3, Project-Related Student Generation , the development of up to 800 dwelling units would generate approximately 265 elementary school-aged students, 136 middle school-aged students, and 182 high school-aged students (583 total students).

Table 4.15-3 Project-Related Student Generation
School Type Dwelling Units Student Generation Rate Project Generated Students Elementary 800 0.3314 265
Middle 800 0.1702 136
High 800 0.2281 182
Total 583
Source: (City of Moreno Valley 2021a)

Based on the overall reduction in students in the MVUSD since 2009, it is anticipated that the Project’s generation of elementary, middle, and high school students would be accommodated by existing and planned facilities, including the new Moreno Elementary School east of the Project site (across Nason Street), with capacity to accommodate 850 students.

The need for additional school facilities and related services is addressed through compliance with payment of required school impact fees. SB 50 sets forth a state school facilities construction program that includes restrictions on a local jurisdiction’s ability to condition a project on mitigation of impacts on school facilities in excess of fees set forth in Section 17620 of the California Education Code. These fees are collected by school districts at the time of issuance of building permits for commercial, industrial, and residential projects. The MVUSD would be able to collect these school impact fees for proposed development implementing the proposed TCMV Specific Plan. The State Legislature has declared that the payment of school impact fees constitutes full mitigation for the impacts generated by new development, per Section 65995 of the California Government Code . Since required impact fees would be paid, each future development project implementing the proposed TCMV Specific Plan would mitigate the impacts associated with its activities. Thus, the Project would not result in the need for new or physically altered school facilities and no physical environmental impacts would result.

Impacts from implementation of the Project on school services in the MVSUD would be less than significant.

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D. Library Services
The Project would result in an increase in the City’s residential population; thus, the Project has the potential to increase the demand for other public facilities, including library services. Although the residents in the City are able to use any of the branches throughout the City’s library system, the Main Branch is closest to the Project site (located approximately 1.4 miles to the west). In accordance with MVMC Chapter 3.38, the Project Applicant would be required to pay library improvement DIFs to contribute its fair share of costs for acquiring, designing, constructing, improving, providing and maintaining, the library facilities and improvements provided for in the General Plan and adopted CIP, and the library materials necessary or appropriate to serve residential development. The City does not require payment of library fees for non-residential uses ; therefore, t he required DIF payments for library services facilities and materials are applicable to residential uses anticipat ed in the proposed TCMV Specific Plan. The construction of new or physically altered library facilities is not required as a result of the Project and no physical impacts would occur. Impacts would be less than significant.

Threshold a: Wo
uld the Project result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
iv. Parks

Threshold b: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Implementation of the proposed TCMV Specific Plan would result in the development of up to 800 residential units and would generate a population of approximately 3,080 residents. Based on the City’s established parkland ratio of 3.0 acres per 1,000 residents, the Project would generat e a demand for approximately 9.2 acres of parkland. The proposed TCMV Specific Plan includes approximately 4.9 acres of designated park area , including an approximately 3.5-acre area to be centrally located and open to the public, and an approximately 1.3- acre linear park. The open space areas wo uld provide recreational opportunities for the community. The location of parks near the commercial/civic uses would add an enhanced visitor and resident experience to the community as people can conveniently spend time in both the commercial and the park spaces. The parks would be constructed by the Project Applicant and operated/maintained by the City of Moreno Valley. The proposed onsite park facilities alone do not meet the parkland standards established in the General Plan. Therefore, in compliance with the MVMC Chapter 3.40, the parkland requirement for the Project would be met through a combination of dedication of land, provision of onsite recreational facilities, and payment of in-lieu fees. The provision of onsite private open space and recreational facilities may be credited against the parkland dedication and/or fee requirement at the discretion of the City. Until the onsite facilities are further defined and considered in the context of public outdoor spaces, the calculation of the “credit” for parkland cannot be made.
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The provisions of the Quimby Act only apply to land acquisition and not park improvements. In compliance with MVMC Chapter 3.38, the Project Applicant would also pay the required DIF for residential uses, which are collected for the purposes of acquiring, designing, constructing, improving, providing, and maintaining, to the extent permitted by law, park improvements and recreation/community center facilities provided for in the General Plan and adopted CIP, or an adopted Master Plan of Parks and Recreation Facilities. The City does not require payment of park fees for non-residential uses. Therefore, the required DIF payments for park and recreation/community center facilities are applicable to residential uses anticipated in the proposed TCMV Specific Plan.

In summary, the proposed TCMV Specific Plan includes the implementation of park and recreational facilities into the proposed development; these facilities would be further defined in coordination with the City and included in the City’s Master Plan of Parks and Recreation Facilities. Additionally, the Project Applicant would be required to pay required DIF for proposed residential uses. Therefore, the Project would result in a less than significant impact related to the need to provide new or expanded park and recreational facilities, and the potential for substantial physical deterioration of park and recreation facilities due to increased use would be less than significant.

Threshold c: Wo
uld the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
As discussed above, the proposed TCMV Specific Plan includes approximately 4.9 acres of designated park area . Additionally, recreation al amenities would be provided onsite within residential neighborhoods for future residents. The potential impacts associated with construction and operation of onsite park and recreational facilities are addressed under the relevant issue area identified throughout this EIR (e.g., air quality, biological resources, cultural resources, etc.). Implementation of the Project would not require the expansion of any existing recreational facilities outside of the TCMV Specific Plan area; therefore, no physical impacts associated with development of park facilities would result beyond those identified in this EIR for the Project, which includes onsite recreational facilities.

Impacts to park and recreational facilities would be less than significant.

4.15.5 CUMULATIVE IMPACT ANALYSIS
Based on their inherent purpose, the provision of public services takes into consideration a larger service area than just individual project boundaries. Public services to the proposed TCMV Specific Plan area are provided by the MVFD, MVPD, MVUSD, Moreno Valley Public Library, and the Moreno Valley Park and Community Services Department . Implementation of t he proposed TCMV Specific Plan would involve the development of up to 800 residential units and commercial/civic and park uses. This would result in an increase in the population (approximately 3,080 new residents) and employment opportunities for the City. The increase in population and employment would incrementally increase existing demands for public services.

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A. Fire and Emergency Services
Future development in the City such as the proposed TCMV Specific Plan and cumulative development projects identified in EIR Section 4.0, Environmental Analysis, is expected to increase demand for fire protection services within the MVFD service area and would contribute to the need to expand facilities and operate such services. Pursuant to MVMC Title 3, each development project in the City would be required to pay applicable DIFs for fire protection facilities. By maintaining a consistent level of service through expansion or facility improvements, the MVFD would be able to ensure that its performance objectives are consistently met. As increases in demand would be incremental over time, the City and the MVFD would continue to regularly monitor resources to ensure that adequate facilities, staffing, and equipment are available to serve existing and future development and population increases.

Additionally, new development in the City, would be required to comply with all applicable codes, ordinances and regulatory requirements, including the current edition of the CFC , regarding fire prevention and suppression measures, fire hydrants, automatic fire extinguishing systems, fire access, and water availability, among other measures. Future development in the City, including development and uses anticipated by the proposed TCMV Specific Plan, would also have to comply with applicable fire safety and fire access requirements to prevent fire incidents; to facilitate emergency response; and to reduce the demand for fire protection services. Individual projects would be reviewed by the MVFD to determine the specific fire requirements applicable to the development and to ensure compliance with these requirements. This further ensures an adequate level of service for fire protection and emergency services to residents in the MVFD service area.

Therefore, the Project’s increased demand for fire protection services would not result in a cumulatively considerable contribution to a significant cumulative impact related to fire protection.

B. Police Services
As with fire protection services, future projects in the City, including development anticipated by the proposed TCMV Specific Plan, are expected to increase demand for police protection services and would contribute to the need to expand facilities and operate such services. Police staffing levels are in constant need of evaluation as the City population grows. Individual projects may not result in the need to increase staffing levels; however, combined development may result in a cumulative increase in police protection service requirements. Pursuant to MVMC Title 3, each development project in the City would be required to pay applicable DIFs for polices services facilities. By maintaining a consistent level of service through expansion or facility improvements, the MVP D would be able to ensure that its performance objectives are consistently met. As increases in demand would be incremental over time, the City and the MVPD would continue to regularly monitor resources to ensure that adequate facilities, staffing, and equipment are available to serve existing and future development and population increases. Therefore, the P roject’s increased demand for police protection services would not result in a cumulatively considerable contribution to a significant cumulative impact related to police protection.

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C. Schools
Cumulative development in the MVUSD service area would generate an increase in student population in MVUSD schools. As school districts’ enrollments expand, administrators must seek short-term and long-term remedies to accommodate those additional students. In recognition of these conditions, the State Legislature provided authority for school districts to assess impact fees for both residential and nonresidential development projects. Those fees, as authorized under Section 65995 of the California Government Code, are collected by municipalities at the time building permits are issued and conveyed to the affected school district in accordance with a defined fee structure. The Legislature has declared that the payment of these fees constitutes full mitigation for the impacts generated by new development, per Section 65995 of the California Government Code . Since all development implemented pursuant to the proposed TCMV Specific Plan and other development proposed in the City and surrounding areas must pay its appropriate impact fees, each project would mitigate the impacts associated with its activities. Therefore, the Project’s increased demand for school services would not result in a cumulatively considerable contribution to a significant cumulative impact related to schools.

D. Library Services
Future projects in the City, including development anticipated by the proposed TCMV Specific Plan, would increase the demand for library services and would contribute to the need to expand facilities and operate such services. Pursuant to MVMC Chapter 3.38, residential developments would be required to pay established DIFs for library facilities. Through adherence to requirements for payment of library impact fees, residential developments in the City would meet their demands for library services. Since individual development projects, including the Project, would mitigate their incremental impact on library services, the Project’s increased demand for library services would not result in a cumulatively considerable contribution to a significant cumulative impact related to library services.

E. Parks and Recreation
Future residential development in the City and, including other proposed residential development such as that anticipated by the proposed TCMV Specific Plan, would contribute to the cumulative need for more recreational open space and park facilities generated by the increase in residents. As previously discussed, based on the estimated population generation for the proposed project (3,080 residents), approximately 9.2 acres of parkland would be needed to meet the City’s established standard of 3.0 acres per 1,000 residents. Cumulative development within the City would generate a need for additional parkland.

The City has a number of regulations in place to address funding from new residential development for additional parkland and park improvements. Pursuant to the Quimby Act, MVMC Chapter 3.40 requires the dedication of land, payment of an in-lieu fee, or a combination of both for the provision of parks and recreational facilities for new residential developments. Additionally, pursuant to MVMC Title 3, residential developers would be required to pay established DIFs for community and recreation ■■
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center, and park facilities. Through adherence to requirements for provision of parkland and/or payment of fees, residential developments in the City would provide parks and recreational facilities to meet their demands.

Since individual development projects, including that anticipated by the proposed TCMV Specific Plan, would mitigate their incremental impact on parks and recreational facilities, the Project’s increased demand for park and recreational facilities would not result in a cumulatively considerable contribution to a significant cumulative impact related to park and recreational facilities.

4.15.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact . The proposed TCMV Specific Plan would generate new residents and employees at the Project site, which is currently undeveloped, and would increase the demand for public services compared to existing conditions . With payment of mandatory DIFs pursuant to MVMC Title 3, payment of school impact fees, and adherence to requirements for the provision of parkland, the Project’s potential impacts related to public services and facilities would be less than significant and the Project would not result in or require the construction of new or physically altered facilities. No physical impacts would occur and Project impacts related to fire , police, school, park and other public facilities would be less than significant.

Threshold b: Les
s Than Significant Impact. The total parkland demand for the Project (approximately

8.9 acres) would be accommodated by the park and recreational facilities anticipated by the proposed TCMV Specific Plan, and through mandatory compliance with the MVMC Chapter 3.40 of the MVMC, which requires the payment of park in -lieu fees in the event a project does not provide adequate parkland onsite. With adherence to requirements for the provision of parkland or payment of in-lieu fees, and payment of the required DIFs for park and community/recreation center facilities, which ensure that adequate park and recreational facilities are provided to serve Project residents, the Project would not result in the substantial physical deterioration or accelerate the deterioration of existing parks or recreational facilities and impacts would be less than significant.

Threshold c : Less Than Significant Impact. The proposed TCMV Specific Plan anticipates the development of park and recreational uses, and t he physical impacts resulting from construction and operational of these uses is evaluated for each environmental topic in this EIR. No additional physical impacts would result and this impact would be less than significant.

4.15.7 MITIGATION
Impacts would be less than significant, and mitigation is not required.

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4.16 TRANSPORTATION
This section assesses transportation impacts resulting from the implementation of the Project. In accordance with Senate Bill (SB) 743, further discussed under Section 4.16.2, Regulatory Setting, below, the California Natural Resources Agency (CNRA ) adopted changes to the California Environmental Quality Act (CEQA) Guidelines in December 2018, which identify that starting on July 1, 2020, vehicle miles traveled (VMT) is the appropriate metric to evaluate a project’s transportation impacts. As of December 2018, when the revised CEQA Guidelines were adopted, automobile delay, as measured by “level of service” (LOS) and other similar metrics, no longer constitutes a significant environmental effect under CEQA. The City of Moreno Valley (City) has prepared the Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment (June 2020), which were the basis for the analysis of transportation impacts conducted for the Project. With respect to the CEQA -required VMT analysis, the Town Center at Moreno Valley Vehicle Miles Traveled (VMT) Analysis (VMT Analysis), prepared by Urban Crossroads (Urban Crossroads 2024a), is provided in EIR Technical Appendix L.

Notwithstanding the VMT method of analysis for CEQA purposes, the City’s traffic study guidelines require a traffic analysis based on LOS, which the City uses in part to determine transportation improvement obligations of development projects. However, CEQA Guidelines Section 15064.3, effective January 1, 2019, “describes specific considerations for evaluating a project’s transportation impacts” and provides that, except for roadway capacity projects, “a project’s effect on automobile delay (or LOS)” shall not constitute a significant environmental impact” (CEQA Guidelines Section 15064.3[a]). As required by the City, the Town Center at Moreno Valley Specific Plan (PEN21-0334 and PEN22-0077) Traffic Analysis, City of Moreno Valley (TIA), prepared by Urban Crossroads (Urban Crossroads 2025e), has been prepared for the Project. Information from the TIA has also been used to support the analysis of potential impacts related to other topical issues (e.g., air quality and health risk, greenhouse gas emissions, noise, etc.), as discussed in the respective sections of this EIR.

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

4.16.1 EXISTING CONDITIONS
A. Existing VMT
Currently, the Project site is undeveloped; thus, the Project site does not generate VMT.

B. Existing Roadway System
Regional access to the City is provided by Interstate (I)-215, which generally extends in a north-south direction and is located west of the City, and State Route (SR)-60, which extends east -west through the northern portion of the City. These highways are accessed by multiple on- and off-ramps throughout the City. The Project site is located approximately 1.1-mile south of the Nason Street/SR- 60 interchange and approximately 5.3 miles east of the Alessandro Boulevard/ I-215 interchange.

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The Project is bound by Alessandro Boulevard to the south, Cottonwood Avenue to the north, and Nason Street to the east; Bay Avenue terminates west of the Project site. Figure 4.16-1, Existing Number of Through Lanes and Intersection Controls , identifies intersections located near the Project site, the number of through traffic lanes for existing roadways , and the intersection traffic controls .

Existing traffic on nearby roadways consists of both passenger vehicles and trucks passing through the area.

C. Existing Transit Services
Transit service to the Project site and surrounding areas is primarily provided by the Riverside Transit Agency (RTA), a public transit agency serving various jurisdictions within Riverside County. RTA Routes 21, 31 and 40 run along portions of Alessandro Boulevard and Nason Street with bus stops along Nason Street (Route 31) and Alessandro Boulevard (Routes 21 and 40) adjacent to the Project site. Transit service is reviewed and updated by RTA periodically to address ridership, budget, and community demand needs. Changes in land use can affect these periodic adjustments which may lead to either enhanced or reduced service where appropriate.

The City is also served by Metrolink, a commuter rail service operated by the Southern California Regional Rail Authority (SCRRA). Metrolink train service is available between the counties of Ventura, Los Angeles, San Bernardino, Orange, Riverside, and north San Diego. The City is served by the Moreno Valley/March Field Metrolink Station, at 14160 Meridian Parkway, located approximately

5.3 miles west of the Project site.

D. Existing Bicycle and Pedestrian Facilities
The City’s existing and planned bicycle and pedestrian network in the vicinity of the Project site is shown in Figure 4.16-2, Existing and Planned Bicycle and Pedestrian Network . As shown, Nason Street, Cactus Avenue, Eucalyptus Avenue, Moreno Beach Drive, Alessandro Boulevard (west of Kitching Street), and Lasselle Street (south of Alessandro Boulevard) currently provide Class II bikeways (on-road, striped). Alessandro Boulevard along the Project site frontage is identified as a future Class II bikeway. Cottonwood Avenue provides an existing Class III bike route (signed, but not striped) west of Nason Street, and a planned Class III bike route east of Nason Street.

Figure 4.16-3, Existing Pedestrian Facilities, illustrates the existing crosswalks and existing sidewalks throughout the study area . T o the north of the Project site , there is a sidewalk on both sides of Cottonwood Avenue between Morrison Avenue and Nason Street , and to the east of the Project site, there is a sidewalk on both sides of Nason Street between Cottonwood Avenue and Alessandro Boulevard. The sidewalks along Nason Street extend north and south of the Project site and crosswalks for each leg of the intersections at Cottonwood Avenue and Alessandro Boulevard. There are no sidewalks along either side of Alessandro Boulevard adj acent to the Project site (Urban Crossroads 2025e).
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"' LEGEND:
8 = Existing Intersection
Analysis Location
® = Future Intersection
Analysis Location
~ = Existing Traffic Signal
..&. = Existing Stop Sign
J__ = Existing Lane
RTO = Right Turn Overlap
DEF = Defacto Right Turn
4 = Number of Lanes
D/U = Divided/ Undivided
Source(s): Urban Crossroads (February 202S}
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Figure 4.16- l A
Existing Number of Through Lanes
and Intersection Controls
■■ Town Center at Moreno Valley Specific Plan
■ D Environmental Impact Report 4.16 Transportation
Perris Bl.
& Alessandro Bl.

Letterman St.
& Cottonwood Av.
6 Nason St.
& SR-60 EB Ramps
Nason St.
& Dwy. 1 I Larkmead Av.
16 ◄
+ + L L_
>-----<
t~
2 7
Kitching St.
& Alessandro Bl.

L_RTO
--
Street A
& Cottonwood Av.

Future
Intersection
Nason St.
& Fir Av.

Nason St.
& Alessandro Bl.

Source(s): Urban Crossroads (February 2025)
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Lasselle St.
& Cottonwood Av.

Street A
& Bay Ave.
8 Future
Intersection
Nason St.
& Eucalyptus Av.

Nason St.
& Cactus Av.

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Lasselle St.
& Bay Av.

Street A I Country Squire Dr.
9 & Alessandro Bl.
--' ----r ·r
..&.

Nason St.
& Cottonwood Av.

Nason St.
& Iris Av.

Lasselle St.
& Alessandro St.
----RTO-,
Nason St.
& SR-60 WB Ramps
10 ~+L
L_RTO
--'
15 Nason St.
& Bay Av.

Moreno Beach Bl.
& Alessandro Bl.

Figure 4.16- l B
Existing Number of Through Lanes
and Intersection Controls
■■
■ □
Town Center at Moreno Valley Specific Plan
Environmental Impact Report
Source(s): Urban Crossroads (February 202S}
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r
Riverside
Rir:,side
Natrona/
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Parks and Recreation
L~~ City of Moren o Valley
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Mr..-i::hAr
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Ba.,e
---, ;
I
i
i_r·,
i L. ____________ _
Calimesa
r I ., ____ , ____ _
Perris - Existing Class I (Multi-Use Path) - Existing Class Ill (Bike Route) ffi 0
2 •••••• Proposed Class I (Multi-Use Path) ••n•• Proposed Class Ill (Bike Route) Miles - Existing Class II (Bike Lane)
Data Source:City of Moreno Valley, 201 9;·Riverside •••••• Proposed Class II (Bike Lane) County G IS, 2019; Dyett & Bhatia.2019,
- Existing Class IV (Bike Boulevard)
•• ••• • Proposed Class IV (Bike Boulevard)
•• ••• • Proposed Bike Facility {Unidentified Class)
Fehr & Peers, 2021.
• Schools
• Public Facilities
(!) Metrolink Station
~ Metrolink Commuter Rail

4.16 Transportation
Figure 4.16-2
Existing and Planned Bicycle and Pedestrian Network

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■■ Town Center at Moreno Valley Specific Plan
■ D Environmental Impact Report
LEGEND:
0 = 1 Approach
0 = 2 Approaches
0 = 3 Approaches
0 = All Approaches
=Sidewalks
Source(s): Urban Crossroads (February 202S}
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4.16 Transportation
Figure 4.16-3
Existing Pedestrian Facilities
Town Center at Moreno Valley Specific Plan
Environmental Impact Report 4.16 Transportation
City of Moreno Valley

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

1. Senate Bill 743 and VMT-Based Analysis
Senate Bill 743, which was codified in Public Resources Code (PRC) Section 21099, required changes to the CEQA Guidelines regarding the analysis of transportation impacts. Pursuant to PRC Section 21099, the criteria for determining the significance of transportation impacts must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” To that end, in developing the criteria, the Office of Planning and Research (OPR) proposed, and the CNRA certified and adopted changes to the CEQA Guidelines in December 2018, which entailed changes to the thresholds of significance for the evaluation of impacts to transportation.

The updated CEQA Guidelines include the addition of CEQA Guidelines Section 15064.3, of which Subdivision b establishes criteria for evaluating a project’s transportation impacts based on project type and using automobile VMT as the metric. As identified in Section 15064.3(b)(4) of the CEQA Guidelines, a lead agency has the discretion to choose the most appropriate methodology to evaluate a project's VMT. The City adopted its VMT thresholds of significance and published its updated Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment on June 18, 2020. Pursuant to SB 743 and PRC Section 21099, the requirement for analyzing congestion impacts (i.e., LOS) for CEQA purposes was eliminated in December 2018.

Therefore, an analysis of congestion impacts, including analysis of impacts related to the LOS of the circulation system is not provided in this EIR, and the metric for determining a significant impact under CEQA is based on VMT.

B. Regional Plans, Policies, and Regulations

1. SCAG Regional Transportation Plan/Sustainable Communities Strategy As further discussed in EIR Section 4.11, Land Use and Planning, the Southern California Association of Governments (SCAG) is a regional agency established pursuant to California Government Code Section 6500, also referred to as the Joint Powers Authority law. SCAG is designated as a Council of Governments (COG), a Regional Transportation Planning Agency (RTPA), and a Metropolitan Planning Organization (MPO). The Project site is within SCAG’s regional authority. On April 4, 2024, SCAG adopted the 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS; also referred to as Connect SoCal 2024) with goals to: 1) build and maintain an integrated multimodal transportation network; 2) develop, connect and sustain communities that are livable and thriving; 3) create a healthy region for the people of today and tomorrow; and 4) support a sustainable, efficient and productive regional economic environment that provides opportunities for all residents .

Connect SoCal 2024 represents the vision for Southern California’s future, including policies, strategies, and projects for advancing the region’s mobility, economy, and sustainability through 2050.

The plan details how the region will address its transportation and land use challenges and opportunities to achieve its regional emissions standards and GHG reduction targets. Connect SoCal 2024 builds ■■
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from the policy direction established in Connect SoCal 2020 as well as more recent policy direction from SCAG’s Regional Council policy committees and special subcommittees to reflect emerging issues such as equity, resilience, and the economy. To achieve the goals of Connect SoCal 2024 (identified in EIR Section 4.11, Land Use and Planning, Table 4.11-2, SCAG Connect SoCal Consistency Analysis), a wide range of regional land use and transportation policies are included in Connect SoCal 2024. Connect So Cal 2024 identifies that the regional planning policies are a resource for County Transportation Commissions and local jurisdictions, who can refer to specific policies to demonstrate alignment with the RTP/SCS when seeking resources from state or federal programs.

However, since there are no one-size-fits-all solutions in such a diverse region, it is up to local agencies to identify which policies are the most applicable regional planning policies. (SCAG 2024b)

2. Transportation Uniform Mitigation Fee (TUMF) Program In 2000, the Western Riverside Council of Governments (WRCOG) established the Transportation Uniform Mitigation Fee (TUMF) Program to mitigate the cumulative regional impacts of projected future growth and new development on the region’s arterial highway system . The TUMF Program applies a uniform mitigation fee to new development projects that is collected by each WRCOG member agency, including the City. The collected funds are pooled and used by WRCOG to fund transportation network improvements, including roads, bridges, interchanges, and railroad grade separations, identified by the public works departments of WRCOG member agencies and listed in the Regional System of Highways and Arterials (RS HA). The TUMF program is administered by the WRCOG based upon a regional Nexus Study, which is intended to satisfy the requirements of the California Mitigation Fee Act ( California Government Code, Sections 66000 et seq.) that mandates procedures for the administration of impact fee programs, including collection and accounting, reporting, and refunds. The Nexus Study is periodically reviewed and updated; the most recent update occurred in September 2024.

C. Local Plans, Policies and Regulations

1. City of Moreno Valley General Plan Circulation Element The City’s current (2006) General Plan Circulation Element is intended to guide the development of the City’s circulation system in a manner that is compatible with the City’s General Plan Land Use Element. The current Circulation Element addresses existing roadways, regional plans, the bikeway system, public transit, truck circulation, traffic LOS, and issues and opportunities.1

To help meet traffic demands and achieve balanced growth, the City adopts specific goals and policies.

The goals and policies addressing the City’s circulation system, and the Project ’s consistency with these goals and policies are addressed in Table 4.16-3, 2006 General Plan Consistency Analysis -

1 The City’s proposed 2040 General Plan Circulation Element, which the City is in the process of readopting, addresses Complete Streets, Roadway Classifications and the City’s Circulation Diagram, LOS and VMT, Technology and the Future of Transportation, Intelligent Transportation Systems, Curbside Management, Parking, Local Issues (such as bypass traffic and school drop-offs/pick-ups), Emergency Access, Pedestrian and Bicycle Circulation, Public Transit, Transportation Demand Management, and Goods Movement.
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Circulation, and Table 4.16-4, Proposed 2040 General Plan Consistency Analysis - Circulation .

Following is a summary description of t he roadway classifications for the major roadways within the area surrounding the Project site:
• Divided Major Arterial: Alessandro Boulevard (west of Nason Street), Moreno Beach Drive, and Iris Avenue
• Divided Major Arterial - Reduced Cross Section: Nason Street (south of Alessandro Boulevard)
• Arterial: Nason Street (north of Alessandro Boulevard, Eucalyptus Avenue and Lasselle Street • Minor Arterial: Fir Avenue (east of Nason Street), Cottonwood Avenue, Kitching Street, and Cactus Avenue

The proposed General Plan 2040 Circulation Element, which the City is in the process of readopting , has updated classifications for certain roadways. Notably, adjacent to the Project site, Alessandro Boulevard (east of Nason Street) and Nason Street are proposed to be designated Divided Arterials, and within the Project site Bay Avenue is proposed to be designated a Neighborhood Collector. (City of Moreno Valley 2021b)

2. Moreno Valley Municipal Code (MVMC)
MVMC Title 12, Chapter 12.36, Truck Routes, identifies portions of streets within the City that are designated as truck routes. In proximity to the Project site, the City has designated Alessandro Boulevard as a truck route from I-215 to the easterly City limits, including the segment adjacent to the project site. However, pursuant to MVMC Section 12.36.050, the MVMC does not prohibit vehicle s exceeding the various maximum gross weights that are coming from a truck route from having ingress and egress by direct route to and from restricted streets when necessary for the purpose of making pickups or deliveries of goods, wares or merchandise from or to any building or structure located on such restricted streets or for the purpose of delivering materials to be used for construction of any building or structure upon such restricted streets for which a building permit has previously been obtained.

3. City of Moreno Valley Bicycle Master Plan
The City’s Bicycle Master Plan, adopted in January 2015, is intended to bring City ’s plan into conformance with WRCOG’s Non-motorized Transportation Plan , bring the City’s bicycle planning up to date with the state of the practice to take advantage of the latest innovations, and to identify deficiencies and opportunities in the City’s existing bicycle facility system . The Bicycle Master Plan presents a long-range plan for the provision of a safe, convenient, and efficient environment for bicycle travel in the City. As with the City’s Circulation Element, the Bicycle Master Plan identifies an existing Class III bike route along Cottonwood Avenue and recommends a Class II bikeway along Nason Street and Alessandro Boulevard. As previously identified, the bikeway s along both sides of Nason Street adjacent to the Project site have been completed.
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4. City of Moreno Valley Development Impact Fee (DIF) Program The City created its Development Impact Fee (DIF) program to impose and collect fees from new residential, commercial, and industrial development for the purpose of funding local improvements necessary to accommodate City growth as identified in the City’s General Plan Circulation Element.

The identification of specific roadway and intersection improvement projects and the timing to use the DIF fees are established through periodic capital improvement programs which are overseen by the City’s Public Works Department.

The City’s DIF program includes facilities that are not part of, or which may exceed improvements identified and covered by the TUMF program . As a result, the pairing of the regional and local fee programs provides a more comprehensive funding and implementation plan to ensure an adequate and interconnected transportation system. Under the City’s DIF program, the City may grant to developers a credit against specific components of fees when those developers construct certain facilities and landscaped medians identified in the list of improvements funded by the DIF program.

4.16.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates transportation impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact would occur if the Project would:
a) Conflict with a program, plan, ordinance , or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; b) Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b); c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); d) Result in inadequate emergency access.

4.16.4 PROJECT VEHICLE TRIP GENERATION AND DISTRIBUTION As previously identified, information from the TIA has been used in this EIR to support the analysis of potential impacts related to vehicle trips generated by the Project (e.g., air quality emissions, greenhouse gas emissions, traffic-related noise, etc.), as discussed in the respective sections of this EIR. This supporting information includes Project vehicle trip generation and distribution. Vehicle trip generation represents the amount of traffic that is associated with a development project. Determining traffic generation for a specific project is, therefore, based upon forecasting the amount of traffic that is expected to be both attracted to and produced by the specific land uses proposed by a given project.

Project vehicle trips were calculated using the Institute of Transportation Engineers (ITE) Trip Generation Manual (11
th Edition, 2021). The applicable trip generation rates by land use category for the Project are presented in Table 4.16-1, Trip Generation Rates , and the estimated trip generation summary for the Project are presented in Table 4.16-2, Trip Generation Summary.

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As the Project is proposed to include shopping center and restaurant uses, pass -by percentages were used from the ITE Trip Generation Handbook (3 rd Edition 2017). Pass-by trips account for trips that are currently on the existing roadway network that would stop by uses within the proposed Project on their way to their ultimate destination. Patrons of the uses may also visit other uses on site, including the restaurants, and retail uses, without leaving the site. The National Cooperative Highway Research Program’s (NCHRP Report 684) internal capture trip capture estimation tool has been utilized to determine the internal capture for the Project. The traffic reducing potential of public transit, walking, and/or bicycling have not been considered in the trip generation estimates . Essentially, the traffic projections are “conservative” in that these alternative travel modes might be able to reduce the forecasted traffic volumes. As shown in Table 4.16-2, the Project is anticipated to generate a total of 12,010 two-way trips per day with 1,000 AM peak hour trips and 1,189 PM peak hour trips (Urban Crossroads 2025e).

Table 4.16-1 Trip Generation Rates
Land Use1 ITE
Code
AM Peak Hour PM Peak Hour
Daily
Units2 In Out Total In Out Total
Single Family Detached Residential 210 DU 0. 18 0.52 0.70 0.59 0.35 0.94 9.43 Hotel 310 Rooms 0. 26 0.20 0.46 0.30 0.29 0.59 7.99
Park 411 AC 0. 01 0.01 0.02 0.06 0.05 0.11 0.78
Library 590 TSF 0. 71 0.29 1.00 3.92 4.24 8.16 72.05
General Office3 710 TSF 1.62 0.30 1.92 0.32 1.55 1.87 12.70 Shopping Center (without Grocery) 821 TSF 1.07 0.66 1.73 2.54 2.65 5.19 67.52 Supermarket 850 TSF 1.69 1.17 2.86 4.48 4.47 8.95 93.84 High Turnover (Sit-Down) Restaurant 932 TSF 5. 26 4.31 9.57 5.52 3.53 9.05 107.20 Fast-Food Restaurant w/ Drive-Thru
Window 934 TSF 22. 75 21.86 44.61 17.18 15.85 33.03 467.48 Source: (Urban Crossroads 2025e)
1 Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual, Eleventh Edition (2021). 2 DU = dwelling units; TSF = thousand square feet; AC = acres

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Table 4.16-2 Trip Generation Summary
Land Use Quantity Units1 In Out Total In Out Total Daily Single Family Detached Residential 800 DU 146 414 560 474 278 752 7,544 Park 4.8 AC 0 0 0 0 0 0 4
Internal Capture -39 -9 -48 -72 -118 -190 -1,908
Residential Subtotal 107 405 512 402 160 562 5,640
Hotel 106 Rooms 27 21 48 32 31 63 848
Internal Capture -6 -1 -7 -13 -17 -30 -404
Hotel Subtotal 21 20 41 19 14 33 444
General Office 15.000 TSF 24 5 29 5 23 28 192
City Library 30.000 TSF 21 9 30 118 127 245 2,162
Internal Capture -13 -10 -23 -35 -21 -56 -484
Office Subtotal 32 4 36 88 129 217 1,870
High Turnover (Sit-Down) Restaurant 16.660 TSF 88 72 160 92 59 151 1,786 Fast-Food Restaurants w/ Drive-Thru
Window 3.500 TSF 80 77 157 60 55 115 1,636
Internal Capture -24 -57 -81 -79 -76 -155 -1,996
Sit-Down Pass-by Reduction
(43% PM/Daily)
0 0 0 -14 -14 -28 -468
Fast-Food Pass-by Reduction
(50% AM; 55% PM/Daily)
-10 -10 -20 -3 -3 -6 -186
Restaurant Subtotal 134 82 216 56 21 77 772
Commercial Retail 60.890 TSF 65 40 105 155 161 316 4,112 Supermarket 45.000 TSF 76 53 129 202 201 403 4,224
Pass-by Reduction (40% PM/Daily) 0 0 0 -43 -43 -86 -1,020 Pass-by Reduction (24% PM/Daily) 0 0 0 -33 -33 -66 -556 Commercial Retail Subtotal 124 71 195 131 169 300 3,284 Project Buildout Total 418 582 1,000 696 493 1,189 12,010 Source: (Urban Crossroads 2025e)
1 DU = dwelling units; TSF = thousand square feet; AC = acres Note: Internal capture is per the NCHRP 684.

The Project trip distribution represents the directional orientation of traffic to and from the Project site.

Trip distribution is the process of identifying the probable destinations, directions, or traffic routes that will be utilized by Project traffic. The potential interaction between the planned land uses and surrounding regional access routes are considered to identify the route where Project traffic would distribute. The Project’s trip distribution patterns are presented in Figure 4.16-4, Residential Trip Distribution, Figure 4.16-5, Non-Residential Trip Distribution , and Figure 4.16-6, Hotel Trip Distribution.

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-- = Trip Distribution
Figure 4.16-4
Residential Trip Distribution

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Figure 4.16-5
Non-Residential Trip Distribution

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10 = Percent To/From Project
-- = Trip Distribution
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4.16 Transportation
Figure 4.16-6
Hotel Trip Distribution
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4.16.5 IMPACT ANALYSIS
Threshold a: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? A. Regional

1. Connect SoCal 2024 (2024-2050 RTP/SCS)
The fundamental goals of SCAG’s Connect SoCal are to make the SCAG region a better place to live, work, and play for all residents regardless of race, ethnicity, or income class. EIR S ection 4.11, Land Use and Planning, addresses the Project’s consistency with Connect SoCal 2024. As demonstrated through that analysis, implementation of the Project would be consistent with applicable regional planning goals of SCAG’s Connect SoCal 2024, including policies related to complete streets, transit and multimodal i ntegration, transportation demand management, safety, priority development areas, housing the region, and 15-minute communities.

B. Local

1. 2006 General Plan
The State’s general rule for a General Plan consistency determination is that “an action, program, or project is consistent with the General Plan if considering all its aspects, it will further the objectives and policies of the General Plan and not obstruct their attainment” (OPR 2017). Table 4.16-3, 2006 General Plan Consistency Analysis - Circulation, provides an analysis of the Project’s consistency with applicable current 2006 General Plan Circulation Element policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and related policies provided in other General Plan elements. Table 4.16-4, Proposed 2040 General Plan Consistency Analysis - Circulation, addresses the Project’s consistency with applicable transportation/circulation related policies outlined in the City’s proposed 2040 General Plan Circulation Element, which the City is in the process of readopting.

As identified, the Project does not conflict with any policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

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Table 4.16-3 2006 General Plan Consistency Analysis - Circulation Goals/Policies Project Consistency
Circulation Element
Objective 5.1: Create a safe, efficient and neighborhood friendly street system.

Policy 5.1.1: Plan access and circulation of each
development project to accommodate vehicles
(including emergency vehicles and trash trucks),
pedestrians, and bicycles.

No Conflict. Site plans and associated circulation plans for projects implementing the proposed TCMV Specific
Plan would be designed in accordance with applicable
City requirements for accommodating turning
movements, and non-vehicular modes of transportation.

As required by the proposed TCMV Specific Plan,
driveway access to parcels would provide safe vehicular movement and prevent traffic congestion by minimizing
pedestrian/bicycle, as well as vehicular conflicts, and providing safe and thoughtful pedestrian paths of travel through parking lots. Where possible, curb- separated
sidewalks, on-street bicycle lanes, and off-street paseos would be implemented.

Policy 5.1.2: Plan the circulation system to reduce
conflicts between vehicular, pedestrian and bicycle
traffic.

Policy 5.1.3: Require adequate off-street parking for all developments.

No Conflict. The proposed TCMV Specific Plan
includes parking standards for the proposed residential and commercial uses to ensure there is sufficient
parking provided within the Specific Plan area for
proposed use s. To facilitate traffic calming, on -street parking would be allowed along the on -site public
roadways (Bay Avenue and the new north-south street),
as allowed by the City.

Policy 5.1.4: Driveway placement shall be designed for
safety and to enhance circulation wherever possible.

No Conflict. As identified in EIR Section 3.0, Project Description, and shown in Figure 3 -7, Project Access,
the primary access to the Project site would be limited to the new public roadway extending between
Cottonwood Avenue and Alessandro Boulevard, Bay
Avenue, Letterman Street, and a driveway access for the commercial area from Nason Street
that would align
with Larkmead Court on the east side of Nason Street.

The new public roadways would provide access to the
residential, commercial /civic
, and park uses, and site
adjacent roadways and access improvements are
described in EIR Section 3.0. The site plans for
developments implementing the proposed TCMV
Specific Plan would be designed in compliance with
TCMV Specific Plan design standards, City
requirements, and City’s policies for access, as
applicable. To ensure compliance with established
requirements, and consistent with the City’s standard
practice, future site plans would include detailed
information about proposed access locations based on
the actual location of proposed uses, and the access
studies would be required through cond itions of
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Goals/Policies Project Consistency
approval to confirm sufficient capacity, stacking, and
safety measures.

Policy 5.1.5: Incorporate American Disability Act
(ADA) and Title 24 requirements in roadway
improvements as appropriate.

No Conflict. The proposed on -site roadways and off -
site roadway improvements would be designed in
accordance with applicable ADA and Title 24
requirements.

Policy 5.1.6: Design new developments to provide
opportunity for access and circulation to future adjacent developments.

No Conflict. The Project a llows access from existing
development to the east via Bay Avenue and for future
development along Alessandro Boulevard. Access from
future development to the north is provided along A
Street and Nason Street.

Objective 5.2: Implement access management policies.

Policy 5.2.1: Locate residential units with access from local streets. Minimize direct residential access from
collectors. Prohibit direct single-family driveway access on arterials and higher classification roadways.

No Conflict. As identified in EIR Section 3.0, Project
Description, and shown in Figure 3 -7, Project Access,
the primary access to the proposed residential areas
would be limited to the new public roadway extending
between Cottonwood Avenue and Alessandro
Boulevard, Bay Avenue, and Letterman Street. There
would not be direct access to residential units from these roadways or from Alessandro Boulevard, Nason Street,
or Cottonwood Avenue.

Policy 5.2.2: Feed short local streets into collectors. No Conflict. To ensure compliance with established requirements, and consistent with the City’s standard
practice, future site plans would include detailed
information about proposed access locations based on
the actual location of
proposed uses, and the access
studies would be required through conditions of
approval to confirm sufficient capacity, stacking, and
safety measures.

Policy 5.2.3: Encourage the incorporation of traffic
calming design into local and collector streets to
promote safe vehicle speeds.

No Conflict. To facilitate traffic calming, on -street
parking would be allowed along the on -site public
roadways (Bay Avenue and the new north-south street),
as allowed by the City, and a roundabout is proposed at the intersection of these new streets. Additional traffic calming measures would be incorporated into site plans
for development projects implementing the proposed
TCMV Specific Plan, as required by the City during site plan review.

Policy 5.2.4: Design new subdivisions to minimize the
disruptive impact of motor vehicles on local streets.

Long, broad and linear streets should be avoided.

Residential streets should be no wider than 40 feet, and should have an uninterrupted length of less than one half mile. Curvilinear streets and cul- de-sacs are preferred.

Streets within the subdivision should be designed to
facilitate access to residences and to discourage through traffic.

No Conflict. The site plans for developments
implementing the proposed TCMV Specific Plan,
including street design, would be designed in
compliance with TCMV Specific Plan design standards,
City requirements, and City policies.
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Goals/Policies Project Consistency
Objective 5.3: Maintain Level of Service (LOS) “C” on roadway links, wherever possible, and LOS “D” in the vicinity of SR 60 and high employment centers. Figure 9 -2 depicts the LOS standards that are applicable to all segments of the General Plan Circulation Element Map.

Policy 5.3.1: Obtain right -of-way and construct
roadways in accordance with the designations shown on
the General Plan Circulation Element Map and the City
street improvement standards.

No Conflict. As described in EIR Section 3.0, Project
Description, the on -site public roadways would be
constructed to their full width. The southern portion of Cottonwood Avenue would be constructed to its
ultimate half -width as a Minor Arterial; the northern
portion of Cottonwood Avenue is already constructed.

Alessandro Boulevard would be constructed to its
ultimate half -width as a Divided Major Arterial. The
ultimate half -width of Nason Street as a Divided
Arterial has been constructed; however, any cur b and
gutter and sidewalk modifications to accommodate site
access along Nason Street would be implemented as part
of the Project.

Policy 5.3.2: Wherever feasible, promote the
development of roadways in accordance with the City
standard roadway cross-sections, as shown in Figure 9-

3. Cross -sections range from two-
lane undivided
roadways to 8-lane divided facilities.

Policy 5.3.5: Ensure that new development pays a fair
share of costs to provide local and regional
transportation improvements and to mitigate cumulative
traffic impacts. For this purpose, require new
developments to participate in Transportation Uniform
Mitigation Fee Program (TUMF),
the Development
Impact Fee Program (DIF) and any other applicable
transportation fee programs and benefit assessment
districts.

No Conflict. As required by the City, the Project
Applicant would pay the required TUMF, DIF, and fair
share improvement fees as a condition of Project
approval.

Policy 5.3.6: Where new developments would increase
traffic flows beyond the LOS C (or LOS D, where
applicable), require appropriate and feasible mitigation measures as a condition of approval. Such measures
may include extra right -of-way and improvements to
accommodate left -turn and right -turn lanes at
intersections, or other improvements.

No Conflict. As previously identified, LOS is no longer the metric for determining a project’s transportation
impacts pursuant to CEQA; however, the City’s traffic
study guidelines require a traffic analysis based on LOS, which the City uses in part to determine trans portation improvement obligations of development projects. The
required traffic study has been prepared and required
improvements to address deficiencies have been
identified. Implementation of required improvements
would be a condition of approval.

Objective 5.5: Maximize efficiency of the local circulation system by using appropriate policies and standards to design, locate and size roadways.

Policy 5.5.1: Space Collectors between higher
classification roadways within development areas at
appropriate one-quarter mile intervals.

No Conflict. Bay Avenue, which would be constructed
east-west through the Project site as a Neighborhood
Collector, is located between Cottonwood Avenue (a
designated Minor Arterial) and Alessandro Boulevard (a
designated Divided Major Arterial adjacent to the
Project site. Bay Avenue is approximately 0.25 mile
from each of these roadways.

Policy 5.5.2: Provide dedicated left -turn lanes at all major intersections on minor arterials and higher
classification roadways.

No Conflict. As required by the City, a traffic study has been prepared for the Project. The traffic study identifies intersection improvements needed to accommodate site
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Goals/Policies Project Consistency
access and maintain acceptable peak hour operations for the Project. This includes recommendations for
intersection improvements, including left -turn lanes, as needed.

Policy 5.5.3: Prohibit points of access from conflicting with other existing or planned access points. Require
points of access to roadways to be separated sufficiently to maintain capacity, efficiency, and safety of the traffic flow. No Conflict. Refer to the consistency analysis for Policy 5.1.4 above, which addresses site access. Policy 5.5.4: Wherever possible, minimize the frequency of access points along streets by the
consolidation of access points between adjacent
properties on all circulation element streets, excluding collectors.

Policy 5.5.5: Design streets and intersections in
accordance with the Moreno Valley Municipal Code.

No Conflict. As identified in the proposed TCMV
Specific Plan, except as otherwise approved, the on-site private roadway system would be constructed to meet
City requirements. Alternative residential street sections may be approved by the City Engineer provided the
alternate designs are functional through supportive
analysis provided by a qualified traffic consultant.

Further, site -adjacent roadway and intersection
improvements would be designed in accordance with
the Moreno Valley Municipal Code.

Policy 5.5.6: Consider the overall safety, efficiency and capacity of street designs as more important than the
location of on-street parking.

No Conflict. To facilitate traffic calming, on -street
parking would be allowed along the on -site public
roadways (Bay Avenue and the new north-south street),
as allowed by the City.

Policy 5.5.7: For developments fronting both sides of a street, require that streets be constructed to full width.

Where new developments front only one side of a street, require that streets be constructed to half width plus an additional 12 -foot lane for opposing traffic, whenever possible. Additional width may be needed for medians
or left and/or right turn lanes.

No Conflict. Refer to the consistency analysis provided for Policy 5.3.1, which addresses the roadway
improvements that would be constructed as part of the
Project.

Policy 5.5.8: Whenever possible, require private and
public land developments to provide on-site and off-site improvements necessary to mitigate any development -
generated circulation impacts. A review of each
proposed land development project shall be undertaken
to identify project impacts to the circulation system. The City may require developers to provide traffic impact
studies prepared by qualified professionals to identify the impacts of a development.

No Conflict. Refer to the consistency analysis provided for Policy 5.3.6, which addresses the traffic study
prepared for the Project.

Policy 5.5.10: Provide adequate sight distances for safe vehicular movement at all intersections and driveways.

No Conflict. Sight distance at each project access point would be reviewed with respect to standard Caltrans and City of Moreno Valley sight distance standards in effect ■■
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Goals/Policies Project Consistency
at the time of preparation of final grading, landscape, and street improvement plans.

Objective 5.8: Encourage development of an efficient public transportation system for the entire community.

Policy 5.8.4: Ensure that all new developments make
adequate provision for bus stops and turnout areas for
both public transit and school bus service.

No Conflict . RTA would serve the proposed
development. Currently, there are bus stops on Nason
Street (at Cottonwood Avenue and Alessandro
Boulevard) as well as a stop on Alessandro Boulevard
(toward the southwest corner of the Specific Plan area).

Potential new bus routes and bus stops may be
implemented within the Project site with the specific
locations to be determined in coordination with RTA
during the processing of site development plans. Bus
stops would incorporate features to encourage transit
use such as lighting, shading, ample seating s paces,
landscaping and would be reviewed and approved by
RTA and the City.

Policy 5.8.5: Continue on -going coordination with
transit authorities toward the expansion of transit
facilities into newly developed areas.

Objective 5.9: Support and encourage development of safe, efficient and aesthetic pedestrian facilities.

Policy 5.9.1: Encourage walking as an alternative to
single occupancy vehicle travel, and help ensure the
safety of the pedestrian as follows:
(a) All new developments shall provide sidewalks in
conformance with the City’s streets cross -section
standards, and applicable policies for designated
urban and rural areas.
(b) The City shall actively pursue funding for the infill of sidewalks in developed areas. The highest priority
shall be to provide sidewalks on designated school
routes.

No Conflict. The proposed TCMV Specific Plan
encourages multi -modal circulation system s with an
internal focus on pedestrian activity. Driveway access to parcels would provide safe vehicular movement and
prevent traffic congestion by minimizing
pedestrian/bicycle and vehicular conflicts, and
providing safe and thoughtful pedestrian paths of travel through parking lots. Where possible, curb- separated
sidewalks, on-street bicycle lanes, and off-street paseos would be implemented. The proposed linear park alon g
A Street would be an extension of the proposed central
park; would have pathways for pedestrian travel; and
would offer the ability to recreate, picnic, socialize in the open air.

Policy 5.9.2: Walkways shall be designed to minimize
conflicts between vehicles and pedestrians.

Policy 5.9.3: Where appropriate, provide amenities such as, but not limited to, enhanced paving, seating, and
landscaping to enhance the pedestrian experience.

Policy 5.9.4: Require the provision of convenient and
safe pedestrian access to buildings from the public
sidewalk.

Objective 5.10: Encourage bicycling as an alternative to single occupant vehicle travel for the purpose of reducing fuel consumption, traffic congestion, and air pollution. The Moreno Bikeway Plan is shown in Figure 9-4.

Policy 5.10.1: Bikeways shall link residential
neighborhood areas with parks, employment centers,
civic and commercial areas, and schools.

No Conflict. There is an existing Class II bikeway and
sidewalk along Nason Street adjacent to the Project site, and a planned Class II bikeway and sidewalk along
Alessandro Boulevard, which would be constructed as
part of the Project. A Class III bikeway and sidewalk are planned along Cottonwood Avenue, which would also
be constructed as part of the Project. The proposed on- Policy 5.10.2: Integrate bikeways, consistent with the
Bikeway Plan, with the circulation system and maintain
Class II and III bikeways as part of the City's street
system.
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Policy 5.10.4: Link local bikeways with existing and
planned regional bikeways.
site circulation system would provide direct connections to these bikeways and sidewalks to encourage and
facilitate bicycle and pedestrian travel within the area.

Objective 5.11: Eliminate obstructions that impede safe movement of vehicles, bicyclists, and pedestrians.

Policy 5.11.1: Landscaping adjacent to City streets,
sidewalks and bikeways shall be designed, installed and maintained so as not to physically or visually impede
public use of these facilities.
(a) The removal or relocation of mature trees, street
trees and landscaping may be necessary to construct
safe pedestrian, bicycle and street facilities.
(b) New landscaping, especially street trees shall be
planted in such a manner to avoid overhang into
streets, obstruction of traffic control devices or sight distances, or creation of other safety hazards.

No Conflict. Sight distance at each project access point would be reviewed with respect to standard Caltrans and City of Moreno Valley sight distance standards at the
time of preparation of final grading, landscape, and
street improvement plans.

Policy 5.11.2: Driveways shall be designed to avoid
conflicts with pedestrian and bicycle travel.

No Conflict. Refer to the consistency analysis for
Policy 5.1.1, which addresses driveway access design.

Objective 5.12: Promote efficient circulation planning for all school sites that will maximize pedestrian safety, and minimize traffic congestion and neighborhood impacts.

Policy 5.12.1: Coordinate with school districts to
identify suggested pedestrian routes within existing and new subdivisions for school children to walk to and
from schools and/or bus stops.

No Conflict. The Project site is located south of the
Moreno Valley Unified School District Early Learning
Academy (located north of Cottonwood Avenue) and
west of Moreno Elementary School (located east of
Nason Street). The Project’s roadway improvements
would be desi gned to ensure safe access to these
schools. Further, as discussed above, the Project would include sidewalks on site
that would provide
connections to site -adjacent roadways and nearby bus
stops.

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Table 4.16-4 Proposed 2040 General Plan Consistency Analysis - Circulation Goals/Policies Project Consistency
Circulation Element
Goal C-2: Plan design, construct, and maintain a local transportation network that provides safe and efficient access throughout the City and optimizes travel by all modes.

C.2-1: Design, plan, maintain, and operate streets using complete streets principles for all types of transportation projects including design, planning, construction,
maintenance, and operations of new and existing streets and facilities. Encourage street connectivity that aims to create a comprehensive, integrated, connected network
for all modes.

C.2-2: Implement a layered network approach by
prioritizing conflicting modes, such as trucks and
bicyclists, on alternative parallel routes to provide safe facilities for each mode.

No Conflict. While these policies are intended to guide City actions and are not particularly applicable to
individual development projects, the Project would not
conflict with these policies. As discussed in EIR Section

3.0, Project Description, the Project would involve the construction of public roadways within the Project site (extension of Bay Avenue and construction of a north -
south road between Cottonwood Avenue and
Alessandro Boulevard), and completion of roadway
improvements for site adjacent roadways. The roadway
improvements would be implemented in accordance
with City standards for the respective General Plan
roadway classifications as outlined in the Circulation
Element and Circulation Diagram and would provide
connectivity in the area for vehicular and non-vehicular modes of travel.

C.2-4: Space Collectors between higher classification
roadways within development areas at appropriate one -
quarter mile intervals.

C.2-5: Prohibit points of access from conflicting with
other existing or planned access points. Require points of access to roadways to be separated sufficiently to
maintain capacity, efficiency, and safety of the traffic flow.

C.2-6: Wherever possible, minimize the frequency of
access points along streets by the consolidation of
access points between adjacent properties on all
circulation element streets, excluding collectors.

No Conflict. As identified in EIR Section 3.0, Project
Description, and shown in Figure 3-7, Project Access,
the primary access to the Project site would be limited to the new public roadway extending between
Cottonwood Avenue and Alessandro Boulevard, Bay
Avenue, Letterman Street, and a driveway access for the commercial area from Nason Street that would align
with Larkmead Court on the east side of Nason Street.

The new public roadways would provide access to the
residential, commercial /civic, and park uses
, and site
adjacent roadways and access improvements are
described in EIR Section 3.0. The site plans for
developments implement ing the proposed TCMV
Specific Plan wo uld be designed in compliance with
TCMV Specific Plan design standards, City
requirements, and City’s policies for access, as
applicable. To ensure compliance with established
requirements, and consistent with the City’s standard
practice, future site plans would include detailed
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information about proposed access locations based on
the actual location of proposed use s, and the access
studies would be required through conditions of
approval to confirm sufficient capacity, stacking, and
safety measures. Therefore, there would not be any
conflicts related to site access and circulation.

C.2-7: Plan access and circulation of each development
project to accommodate vehicles (including emergency
vehicles and trash trucks), pedestrians, and bicycles.

No Conflict. Site plans and associated circulation plans for projects implementing the proposed TCMV Specific
plan would be designed in accordance with applicable
City requirements for accommodating turning
movements, and non-vehicular modes of transportation.

C.2-8: For developments fronting both sides of a street, require that streets be constructed to full width. Where new developments front only one side of a street, require that streets be constructed to half width plus an
additional 12 -foot lane for opposing traffic, whenever possible. Additional width may be needed for medians
or left and/or right turn lanes.

No Conflict. As described in EIR Section 3.0, Project
Description, the on-site public roadways would be
constructed to their full width . The southern portion of Cottonwood Avenue would be constructed to its
ultimate half -width as a Minor Arterial ; the northern portion of Cottonwood Avenue is already constructed.

A
lessandro Boulevard would be constructed to its
ultimate half -width as a Divided Major Arterial. The
ultimate half -width of Nason Street as a Divided
Arterial has been constructed; however, any cur b and
gutter and sidewalk modifications to accommodate site
access along Nason Street would be implemented as part
of the Project.

C.2-9: Require connectivity and accessibility to a mix of land uses that meets residents’ daily needs within
walking distance. Typically, this means creating
walkable neighborhoods with block lengths between
330 feet and 660 feet in length, based on divisions of the square mile grid on which the city is laid out.

No Conflict. The proposed TCMV Specific Plan
promotes a mixed-use environment that encourages
walking. Blocks and buildings would be designed to
encourage pedestrian activity rather than discourage it.

Such methods include appropriate block and building
length, streetscape, and proximity to commercial/ civic and park uses from the proposed residential uses.

C.2-10: Ensure that complete streets applications
integrate the neighborhood and community identity into
the street design and retrofits. This can include special provisions for pedestrians and bicycles that complement the context of each community.

No Conflict. The proposed TCMV Specific Plan Design
Guidelines promote development , which is pedestrian -
oriented, interconnected, and encourages sustainable
neighborhood design principles. There is an existing
Class II bikeway and sidewalk along Nason Street
adjacent to the Project site, and a planned Class II
bikeway and sidewalk along Alessandro Boulevard,
which would be constructed as part of the Project. A
Class III bikeway and sidewalk are planned along
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Cottonwood Avenue, which would also be constructed
as part of the Project. The proposed on-site circulation system would provide direct connections to these
bikeways and sidewalks to encourage and facilitate
bicycle and pedestrian travel within the area.

C.2-11: Incorporate traffic calming design into local and collector streets to promote safer streets.

No Conflict. To facilitate traffic calming, on -street parking would be allowed along the on -site public
roadways (Bay Avenue and the new north-south street),
as allowed by the City, and a roundabout is proposed at the intersection of these new streets . Additional traffic calming measures would be incorporated into site plans
for development projects implementing the proposed
TCMV Specific Plan, as required by the City during site plan review.

Goal C -3: Manage the City’s transportation system to minimize congestion, improve flow and improve air quality.

C.3-3: Where new developments would increase traffic
flows beyond the LOS C (or LOS D, where applicable),
require appropriate and feasible improvement measures
as a condition of approval. Such measures may include
extra right-of-way and improvements to accommodate
additional left-turn and right-turn lanes at intersections, or other improvements
C.3-4: Require development projects to complete traffic impact studies that conduct vehicle miles traveled
analysis and level of service assessment as appropriate per traffic impact study guidelines.

No Conflict. As previously identified, LOS is no longer the metric for determining a project’s transportation
impacts pursuant to CEQA; however, the City’s traffic
study guidelines require a traffic analysis based on LOS, which the City uses in part to determine transportation improvement obligations of development projects. The
required traffic stu dy has been prepared and required
improvements to address deficiencies have been
identified. Implementation of required improvements
would be a condition of approval.

Further, the required VMT assessment has been
prepared and is included in EIR Technical Appendix L.

The required studies were prepared in accordance with
City guidelines.

C.3-6: Require new developments to participate in
Transportation Uniform Mitigation Fee Program
(TUMF), the Development Impact Fee Program (DIF) ,
and any other applicable transportation fee programs
and benefit assessment districts.

C.3-8: Ensure that new development pays a fair share of costs to provide local and regional transportation
improvements and to mitigate cumulative traffic
deficiencies and impacts.

No Conflict. As required by the City, the Project
Applicant would pay the required TUMF, DIF, and fair
share improvement fees as a condition of Project
approval.

Goal C-4: Provide convenient and safe connections between neighborhoods and destinations within Moreno Valley.

C.4-3: Support the establishment of a Transit
Center/Mobility Hub in the Downtown Center.

No Conflict. The Project site is not the anticipated
location of a Transit Center/Mobility Hub within the
Downtown Center; that facility is expected to be located near the hospital uses to the south. However, the
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proposed TCMV Specific Plan may accommodate bus
stops within the Specific Plan area. The ultimate
location of on-site bus stops would be determined in
coordination with the City and RTA.

C.4-4: All new developments shall provide sidewalks in
conformance with the City’s streets cross -section
standards, and applicable policies for designated urban and rural areas.

No Conflict. The Project Applicant proposes curb
adjacent sidewalks to encourage and enhance pedestrian
activity throughout the Project site . The proposed
sidewalks would be constructed in conformance with
the City’s and TCMV Specific Plan design standards.

C.4-5: Recognize that high -speed streets, high-volume
streets, and truck routes can increase pedestrian and
bicycle stress levels and decrease comfortability.

Provide increased buffers and protected bicycle lanes in high-stress areas, where feasible. Provide landscaped
buffers where feasible to separate pedestrian
environments from the travel way adjacent to motor
vehicles. Provide convenient and high -visibility
crossings for pedestrians.

No Conflict. As identified in the General Plan
Circulation Element, arterials carry the majority of
traffic traveling through the City. Adjacent to the Project site, Alessandro Boulevard is identified as a Divided
Major Arterial, and Nason Street is a Divided Arterial.

Alessandro Boulevard is also a designated truck route.

There are existing Class II (on -street) bikeways along Nason Street, and a planned Class II bikeway along
Alessandro Boulevard would be implemented as part of
the Project. The required roadway
and streetscape
improvements along these roadways would be
implemented in accordance with the City requirements
for the identified roadway classifications. As identified in the proposed TCMV Specific Plan, where possible,
curb-separated sidewalks, on -street bicycle lanes, and off-street paseos would be implemented to provide for a pleasant and safe pedestrian and bicycling environment.

Goal C-5: Enhance the range of transportation operations in Moreno Valley and reduce vehicle miles travelled.

C.5-1: Work to reduce VMT through land use planning,
enhanced transit access, localized attractions, and access to nonautomotive modes.

No Conflict. As discussed under the analysis of
Threshold “b, ” the Project’s commercial uses would
include local serving retail/restaurant uses, hotel, office, and civic uses that meet the City’s requirements for
project-type screening, as the City has determined that these types of uses would not result in significant VMT impacts. Further, with respect to the proposed
residential uses, the Project’s VMT per capita was found to be less than the City’s significance threshold in either the base year or cumulative year. Therefore, the
potential impact of the Project’s residential component on VMT is less than significant.

C.5-3: Encourage bicycling as an alternative to single occupant vehicle travel for the purpose of reducing fuel consumption, traffic congestion, and air pollution.

No Conflict. Refer to the consistency analysis for
Policy C.2-10 above, which addresses the construction
of bikeways as part of the Project. Additionally, as
described in EIR Section 3.0, Project Description ,
bicycle facilities, including bicycle parking in
compliance with the California Green Building
Standards Code (CalGreen), would be provided within
the TCMV Specific Plan area.
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Goals/Policies Project Consistency
C.5-4: Particularly in corridors and centers, work with transit service providers to provide first-rate amenities to support pedestrian, bicycle, and transit usage, such as bus shelters and benches, bike racks on buses, high-
visibility crossings, and modern bike storage.

No Conflict. As previously discussed, RTA serves the
TCMV Specific Plan area. Currently, there are bus stops on Nason Street (at Cottonwood Avenue and
Alessandro Boulevard) as well as a stop on Alessandro
Boulevard (toward the southwestern corner of the
Specific Plan area). Additionally, a Metrolink Station is located just south of Alessandro Boulevard/I -215
intersection, and TCMV Specific Plan residents would
be able to travel to and from the Metrolink station via the RTA Alessandro bus route. Consistent w
ith this
policy, the Project Applicant and the City would
continue to coordinate with RTA regarding t he
provision of amenities at existing and future RTA
facilities within and adjacent to the Project site
. The
proposed bicycle and pedestrian facilities would provide connectivity to and would support use of transit
facilities.

Land Use and Community Character Element
Goal LCC -1: Establish an identifiable city structure and a flexible land use framework that accommodates growth and development over the planning horizon.

LCC.1-4: Focus new development in centers and
corridors so as to support the vitality of existing
businesses, optimize the use of utility infrastructure, and reduce vehicle trip frequency, length, and associated
emissions.

No Conflict. The Project site is located in the City’s designated Downtown Center along Alessandro
Boulevard and Nason Street. The mixed -use nature of
the Project reduces the trip frequency, the trip length , and associated emissions. Refer to the consistency
analysis for Policy C.5 -1 above. With the reduced trip frequency and less than significant VMT impacts, the
associated emissions would be less than that
experienced by development that does not meet the
development principles established for the Downtow n
Center areas (discussed below and in EIR Section 4.11,
Land Use and Planning).

Goal LCC-2: Foster vibrant gathering places for Moreno Valley residents and visitors.

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

No Conflict. The circulation network within the
Specific Plan area would be designed to accommodate
various mobility and modes and would improve
connectivity in the area. Residents would have the
ability to access proposed commercial and retail uses by foot, bicycle, or neighborhood electric vehicle (NEV).

LCC.2-24: At intersections on the mixed use corridors, prioritize retail and other uses that promote pedestrian activity on the ground floor of buildings.

No Conflict. As shown in Figure 3-5, Conceptual Land
Use Plan, the proposed commercial land uses, including
retail, would be located along Nason Street and
Alessandro Boulevard, which promote pedestrian
activity on the ground floor of the buildings.

LCC.2-25: Encourage the development of bicycle,
pedestrian, and transit access that reduces the need for on-site parking. Improve the pedestrian experience
No Conflict. The proposed TCMV Specific Plan
encourages multimodal design with a focus on
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within these corridors through street trees and
landscaping.
pedestrian’s comfort, as well as pleasing visual
experience.

LCC.2-26: Provide streetscape improvements along the
mixed use corridors of Alessandro, Sunnymead, and
Perris to enhance livability, vitality, and safety for all modes of travel.

No Conflict. The Project would improve Alessandro
Boulevard to its ultimate half-width adjacent the
southern boundary of the Project. This would include
roadway and other streetscape improvements required
by the City (e.g., bikeway, sidewalk, landscaping).

LCC.2-27: Where possible, require that adjacent uses
share driveways in order to limit the number of curb cuts along Alessandro, Sunnymead, Nason, and Perris.

No Conflict. Refer to the consistency analysis for
Policies C.2 -5 and C.2- 6 above, which address es site access.

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

LCC.3-18: Design internal roadways so that direct
access is available to all structures visible from a
particular parking area entrance in order to eliminate
unnecessary vehicle travel, and to improve emergency
response.

No Conflict. The proposed commercial area would be
bound by the proposed extension of Bay Avenue to the
north and the proposed north -south public road to the
west. These roadways would provide direct access to the proposed commercial area and parking areas .

Commercial monuments along roadways would feature
the names of st ores for easy identification by drivers , and roadways internal to the commercial area would be
designed to ensure adequate visibility.

LCC.3-22: Preserve and encourage neighborhood stores
that enable shoppers to walk or bike for everyday needs, provide access to healthy foods, and promote a sense of community.

No Conflict. The proposed commercial land use would
have pedestrian and bicycle facilities, which would be
designed to address the new surrounding neighborhoods
plaza areas for recreation. Further, the commercial use would be adjacent to the proposed open space , which
would further enhance the experience. The proposed
residential uses are within walking distance and thereby, residents can use the commercial center for convenience and entertainment.

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In addition to the policies identified in Table 4.16-4, the Land Use and Community Character Element Policy LCC.2-2 states: “Require that proposed projects in the Downtown Center prepare an area plan demonstrating consistency with the principles outlined in Table LCC -2…”.

Table LCC-2 identifies Downtown Center development principles related to land use and urban design, parks and open space, and circulation. As required, and as demonstrated through the consistency analysis presented in Table 4.16-4, the proposed TCMV Specific Plan has been developed to implement or facilitate future implementation of the following development principles that address circulation:

Downtown Center Development Principles: Circulation
• Create a layered network of roadways with segments assigned for different travel modes in order to provide for both roadway safety and efficient traffic flow. • Create smaller urban blocks to promote walkability. Block sizes should range between 330 and 660 linear feet. Blocks over 500 feet should feature mid-block connections such as pedestrian pathways or alleys.
• Provide a grid of interconnecting streets with designated bicycle and pedestrian routes lined with sidewalks and furnished with pedestrian amenities throughout the area. Grade-separated connections across arterial roadways should also be considered. Mid-block connections created as new developments are built would provide additional pedestrian and bicycle paths. • Accommodate and encourage electric and autonomous vehicles with appropriate design and infrastructure.
• Design the interconnecting streets that break up the superblocks with reduced street widths, street parking, consistent trees, and landscaping to control traffic speed and create a more intimate feel and comfort through shading.

2. Moreno Valley Municipal Code (MVMC)
In accordance with MVMC Title 12, Chapter 12.36, Truck Routes, trucks exceeding the maximum gross weights traveling to/from the Project site, including during construction, would use designated truck routes. Alessandro Boulevard adjacent to the Project site is a designated truck route. As required, other roadways within and surrounding the Project site would only be used by truck traffic as necessary for the purpose of making pickups or deliveries of goods, wares, or merchandise from or to any building or structure located on such restricted streets or for the purpose of delivering materials to be used for construction. The Project would not conflict with MVMC truck route requirements.

3. City of Moreno Valley Bicycle Master Plan
The City’s Bicycle Master Plan, adopted in January 2015, guides the design and implementation of bicycle transportation infrastructure. As previously discussed, there is an existing Class III bikeway along Cottonwood Avenue and Class II bikeways along Nason Street ; Class II bikeways are also planned along Alessandro Boulevard. The Project would implement the planned Class II bikeway along the north side of Alessandro Boulevard adjacent to the Project site. Additionally, in accordance ■■
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with CALGreen requirements , bicycle parking would be provided on the Project site for use by employees and visitors to the Project site. The Project would not conflict with the City’s Bicycle Master Plan.

Based on the foregoing analysis, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

A less than significant impact would occur.

Threshold b: Wo
uld the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
As previously discussed, SB 743 was intended to change the way transportation impacts are determined according to CEQA. Updates to the State CEQA Guidelines that were approved in December 2018 included the addition of CEQA Guidelines Section 15064.3, of which Subdivision “b” establishes criteria for evaluating a project’s transportation impacts based on project type and using automobile VMT as the metric. As a component of OPR’s revisions to the CEQA Guidelines, lead agencies were required to adopt VMT thresholds of significance by July 1, 2020. The City adopted its Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment in June 2020, which has been used to determine the significance of Project-related VMT.

A. VMT Screening Analysis
To aid in the project-level VMT screening process, the City utilizes the WRCOG VMT Screening Tool (Screening Tool). The web-based Screening Tool allows a user to select an assessor’s parcel number (APN) to determine if a project’s physical location meets one or more of the land use screening methods documented in the City Guidelines. The City’s VMT Guidelines provide details on appropriate “screening thresholds” that can be used to identify when a proposed land use project is anticipated to result in less than significant impacts without conducting a more detailed analysis.

Screening thresholds are broken into three types: Transit Priority Area (TPA) (i.e., within ½ mile of an existing “major transit stop”
or an existing stop along a “high-quality transit corridor ”)2, Low VMT Area, and Project Type. A land use project need only meet one of these screening methods to result in a less than significant VMT impact. As identified in the VMT Analysis included in EIR Technical Appendix L, and summarized below, the Project site is not located within a TPA and is not eligible for low VMT area screening.

2 Pub. Resources Code, § 21064.3 (“‘Major transit stop’ means a site containing any of the following: (a) An existing rail or bus rapid transit station. (b) A ferry terminal served by either a bus or rail transit service. (c) The intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.”) Pub. Resources Code, § 21155(b) (“[…] For purposes of this section, a high- quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours. […]”).
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1. TPA Screening
Projects located within a TPA may be presumed to have a less than significant impact absent substantial evidence to the contrary. However, the presumption may not be appropriate if a project:
• Has a Floor Area Ratio (FAR) of less than 0.75;
• Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); • Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization); or • Replaces affordable residential units with a smaller number of moderate - or high-income residential units.

Based on the Screening Tool results presented in the VMT Analysis, t he Project site is not located within ½ mile of an existing major transit stop or along a high-quality transit corridor. Therefore, the TPA screening threshold is not met.

2. Low VMT Screening
The City Guidelines state that, “residential and office projects located within a low VMT -generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary.

In addition, other employment -related and mixed -use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area.” The Project’s physical location is selected in the Screening Tool to determine project generated VMT as compared to the City’s impact threshold. The parcels containing the proposed Project were selected within the Screening Tool. Based on the Screening Tool results, the Project resides within transportation analysis zone (TAZ) 1236 and was shown to generate 15.7 VMT per employee (for employment generating uses of the Project) and 15.1 VMT per capita (for the residential component of the Project), whereas the City’s impact threshold (i.e., City of Moreno Valley net VMT per employee and VMT per capita) is 16.3 VMT per employee and 13.4 VMT per capita (resident) respectively. The Project’s employment generating component is located in a low VMT area and the Project’s residential component is not located in a low VMT area. However, the Project’s TAZ was further evaluated in the Riverside County Model (RIVCOM) traffic model, and the proposed employment uses were not found to be consistent with existing socioeconomic data found in the Project’s TAZ. The Project is therefore not eligible for low VMT area screening.

3. Project Type Screening
The City Guidelines identify that small projects are anticipated to generate low traffic volumes (i.e., fewer than 400 daily trips), and by association low GHG emissions, which are also assumed to cause a less than significant impact.
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The City Guidelines provide a list of development potentials for typical uses. For office uses, the City Guidelines state that 41,000 square feet or below would generate less than 400 daily vehicle trips. For purposes of analysis in this EIR, the potential development scenario for implementation of the proposed TCMV Specific Plan anticipates the development of 15,000 square feet of professional business office uses and is therefore below the typical development threshold and meets the Project Type screening criteria. Additionally, local serving retail buildings with less than 50,000 square feet or other local serving essential services (e.g., daycare centers, public schools, etc.) are presumed to have a less than significant impact absent substantial evidence to the contrary. The potential development scenario for implementation of the proposed TCMV Specific Plan anticipates the development of a civic use, which is an essential service that would serve the local community. The anticipated commercial retail an d restaurant uses are assumed to be below the 50,000 square feet individual building threshold. The anticipated hotel is also considered locally serving as it provides lodging for visitors that seek services and activities within the local area. In other words, the hotel component is not a resort nor a destination hotel. Consistent with the City Guidelines , these components of the Project meet the screening criteria. Therefore, project type screening is met for the local essential uses, retail, office, and hotel uses (development in the Commercial land use area).

As identified above, 800 residential units would generate 5,640 vehicle trip-ends per day and would exceed the 400 daily trip threshold. Therefore, the residential component is not eligible for screening, and a VMT Analysis is required, pursuant to the City Guidelines.

B. VMT Analysis
The City Guidelines identify the RIVCOM traffic model as the appropriate tool for conducting VMT Analysis for land development projects in the City. RIVCOM was developed by WRCOG and initially released in June 2021. The most current version of RIVCOM is version 4.0.1, released in February 2024, representing the most current sub-regional transportation modeling tool for Western Riverside County. RIVCOM is a useful tool to estimate VMT as it considers interaction between different land uses ba sed on socio- economic data such as population, households, and employment. As further described in the VMT Analysis included in EIR Technical Appendix L, for the purposes of the analysis, Project-generated VMT has been estimated using the Production/Attraction (PA) method. Consistent with City Guidelines, VMT has been presented as home -based (HB) VMT per capita. HB VMT per capita is an efficiency metric representing VMT generated exclusively from HB trips on a typical weekday per resident. City Guidelines note that VMT per capita should be used to evaluate residential projects (i.e., single family, multi-family housing).

The City describes the following significance thresholds for project-level VMT analyses:
• A project would have a significant VMT impact if, in the Existing Plus Project, its net VMT per capita (for residential projects) or per employee (for office and industrial projects) exceeds the per capita or per employee VMT threshold for Moreno Valley. For all other uses, a net increase in VMT would be considered a significant impact.

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The City’s VMT per capita was calculated utilizing the RIVCOM base year (2018) traffic model and the horizon year (2045) traffic model. Using straight -line interpolation, baseline (2024) VMT per capita is obtained from the base year and horizon year results, which results in the City of Moreno Valley baseline year average VMT per capita of 15.8 and a horizon year average of 15.4 VMT per capita, as presented in Table 4 of the VMT Analysis included in EIR Technical Appendix L.

In order to evaluate the Project VMT, standard land use information must first be converted into a RIVCOM-compatible dataset. The RIVCOM model utilizes socio -economic data (SED) (e.g., population, households, employment, etc.) as key inputs for the purposes of vehicle trip estimation.

Project land use information such as dwelling units must first be converted to SED for input into RIVCOM. To isolate Project-generated VMT, as recommended by City Guidelines, the existing SED data within the Project’s TAZ (TAZ 1236) was moved to an adjacent TAZ (TAZ 1182). Based on a population factor of 3.85 people per household as identified in the City’s 2021-2029 Housing Element, it is estimated that a maximum of 800 units would generate a residential population of 3,080 people at the Project site.

The RIVCOM model was then run inclusive of the Project and VMT estimates were extracted from RIVCOM. As shown in Table 4.16-5, Project Generated VMT, the Project-generated VMT per capita is not estimated to exceed the City’s threshold in baseline or horizon year conditions. Therefore, the potential VMT impact of the Project’s residential component would be less than significant.

Table 4.16-5 Project Generated VMT
Baseline Horizon
Home-Based VMT 17,969 31,234
Population 3,080 3,080
VMT per Capita 5.8 6.9
City Threshold VMT per Capita 15.8 15.4
Exceeds City Threshold? No No
Source: (Urban Crossroads 2024a)

Threshold c: Wo uld the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
C. Construction-Related Transportation Hazards
Construction traffic resulting from the Project would primarily be associated with construction workers commuting to and from the Project site; delivery of building materials; and transport of construction equipment (including large equipment). Construction workers would travel to the site by passenger vehicle and construction equipment and building materials deliveries would arrive by medium - and heavy-duty trucks. The amount of construction traffic would vary daily depending on the nature of the activity. Construction workers do not typically commute during peak hours as they arrive prior to ■■
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morning peak hours and leave prior to the evening peak hours. The use of heavy trucks for the transport and disposal of building materials, equipment, and soils would occur periodically throughout the workday but largely outside of peak hours.

During construction, t rucks traveling to and from the Project site would adhere to applicable regulations associated with truck travel, as previously discussed in EIR Section 4.16.2 above, including the use of Alessandro Boulevard, which is a designated truck route. Construction activities associated with the Project would result in the temporary closure of traffic lanes and/or roadway segments along the site’s adjacent roadways during various construction activities, including, but not limited to, construction of previously identified roadway improvements and access driveways, and installation of utility infrastructure (including utility connections). The reduction of roadway capacity, the narrowing of traffic lanes, and the occasional interruption of traffic flow on streets associated with Project-related construction act ivities could pose hazards to vehicular traffic due to localized traffic congestion, decreased turning radii, or the condition of roadway surfaces. However, Project-related construction traffic would be required to comply with a temporary traffic control plan that meets the applicable requirements of the California Manual on Uniform Traffic Control Devices. Preparation and implementation of the required traffic control plan, and adherence to City requirements, including the use of designated truck routes, would ensure that potential hazards to transportation during construction would be less than significant.

D. Operational Transportation Hazards
As described in EIR Section 3.0, Project Description, implementation of the proposed TCMV Specific Plan would involve the development of the Project site with residential, commercial /civic, and park uses,. The roadway classifications for the roadways adjacent to the Project site were established in consideration of this development, and the development of the surrounding area. Roadway and site improvements incorporated into the Project to ensure that adequate ingress and egress to the Project site would be provided as described in EIR Section 3.0, Project Description. Access would be provided from Cottonwood Avenue, Nason Street, Alessandro Boulevard, and new on-site public roadways (extension of Bay Avenue and the new north-south road between Cottonwood Avenue and Alessandro Boulevard).

The type of traffic generated by the Project (i.e., passenger cars) would be compatible with the type of existing traffic on the roadways in the area, as the surrounding areas are primarily developed with residences, public facilities, and places of worship. Additionally, proposed improvements within the public right-of-way would be installed in conformance with City design standards . The City Public Works Department reviewed the Project’s application materials and determined that no hazardous transportation design features would be introduced by the Project. Accordingly, the Project would not create or substantially increase safety hazards due to a design feature or incompatible use . Impacts would be less than significant.

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Threshold d: Would the Project result in inadequate emergency access? As described in EIR Section 4.9, Hazards and Hazardous Materials, the City adopted its current Local Hazard Mitigation Plan (LHMP) in 2017. The LHMP contains a map of emergency evacuation routes, which include I-215, SR-60, and major roadways through the City. 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-south street connecting Alessandro Boulevard and Cottonwood Avenue, which would enhance emergency access.

The Project would not substantially impede emergency response in the local area. Further, future development plans/plot plans would be reviewed by the City to ensure adherence to City requirements for emergency vehicle access , including street width and turnaround requirements . Therefore, the Project would not result in inadequate emergency access and this impact would be less than significant.

4.16.6 CUMULATIVE IMPACT ANALYSIS
A comprehensive cumulative project list was compiled based on information provided by the City. A summary of cumulative development projects and their proposed land uses is provided in EIR Section

4.0, Environmental Analysis.

As identified in the analysis presented under Threshold “a ,” the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Cumulative development projects would be reviewed for consistency with adopted programs, plans, ordinances, or policies, including but not limited to the SCAG RTP/SCS, the General Plan, and the MVMC, as applicable. Even if cumulative development projects are in conflict, the Project would not contribute to a cumulative impact and thus would not be cumulatively considerable because the Project does not conflict with a program, plan, ordinance, or policy addressing the circulation system, as identified through the analysis presented in this section.

The City describes the following significance thresholds for cumulative VMT analyses:
• If a project is consistent with the regional RTP/SCS, then the cumulative impacts shall be considered less than significant subject to consideration of other substantial evidence. If it is not consistent with the RTP/SCS, then it would have a significant VMT impact if:
o For residential projects , the project’s net VMT per capita exceeds the average VMT per capita for Moreno Valley in the RTP/SCS horizon year.

The City’s VMT analysis guidelines indicate an evaluation on a project’s cumulative effect on VMT, which uses the boundary method to compare how the project changes VMT on the network looking at Citywide VMT per service population (i.e., population and employees) and comparing it to the “N o Project” condition and a net increase in VMT per service population would result in a cumulative VMT impact. Therefore, the Project’s cumulative effect on VMT has been calculated using the boundary method. Land use information representing the proposed land use changes contemplated by the Project ■■
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was coded into the Project TAZ to represent the “With Project” condition. Table 7 of the VMT Analysis included in EIR Technical Appendix L summarizes the Boundary VMT under the No Project and With Project for both baseline year and horizon year conditions. The VMT per service population was not found to increase in the With Project using the City’s boundary (9.6 VMT per service population under the baseline year and 10.2 VMT per service population under the horizon year). Therefore, the Project’s cumulative effect on VMT does not exceed the City’s impact threshold and the Project would result in a less than significant cumulative impact.

The Project would have less than significant impacts related to hazards from design or incompatible uses during construction and operation, and with respect to emergency access, with adherence to applicable requirements. Cumulative projects in proximity to the Project site would also be required to comply with applicable regulations related to the use of designated truck routes for construction , roadway and access design, and emergency access, which are in place to ensure impacts are less than significant. Therefore, the Project would not result in a considerable contribution to cumulative impacts for these issues, when considered with the cumulative projects that are planned, proposed, or under construction in the vicinity of the Project site.

4.16.7 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact. The Project, which includes roadway improvements, and features to encourage non-vehicular travel and use of transit, would not conflict with a program, plan, ordinance, and/ or policy addressing the circulation system , including SCAG’s Connect SoCal, the General Plan, and the MVMC resulting in a less than significant impact.

Threshold b: L ess than Significant Impact . The Project’s proposed commercial/ civic uses meet the Project Type Screening for VMT, and the Project’s proposed residential uses would not exceed the City’s per capita VMT threshold for the base year and the cumulative year. Therefore, VMT impacts would be less than significant.

Threshold c: L ess than Significant Impact . The Project would not introduce traffic safety hazards through Project design features or incompatible uses resulting in a less than significant impact.

Threshold d: Les s than Significant Impact. Adequate emergency access would be provided to the Project site during construction and long-term operation and this impact would be less than significant.

4.16.8 MITIGATION
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4.17 TRIBAL 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, 2024). The Cultural Resources Assessment is included as Technical Appendix D to this Environmental Impact Report (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 EIR Techncial Appendix D for purposes of public review.

In addition, much of the written and oral communication between Native American tribes and the City of Moreno Valley (C ity), is considered confidential in respect to places that have traditional tribal cultural significance (California Government Code Section 65352.4), and although relied upon in part to inform the preparation of this EIR section, those communications are treated as confidential and are not available for public review.

4.17.1 EXISTING CONDITIONS
Refer to EIR S ection 4.5, Cultural Resources , for a description of the prehistoric period. The ethnographic setting for the region is restated below.

A. Ethnography
The Project site 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 ■■
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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 effecting 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.

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 site. 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 ■■
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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 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.

B. Tribal Cultural Resources
As discussed in EIR Section 4.5, Cultural Resources, VCS conducted an archaeological records search through the Eastern Information Center (EIC) at the University of California, Riverside (UCR) on August 19, 2021. The EIC information notes that 14 cultural resources were recorded within one-half mile of the Project site. Eight prehistoric milling slicks are recorded within one-half mile of the Project site, attesting to the prehistoric presence of indigenous populations in the vicinity. During the consultation process with the City, t he Pechanga Cultural Resources Department provided additional information regarding cultural resources within one -mile of the Project site . This list includes 13 prehistoric and 3 historic-era resources.

VCS also conducted a pedestrian survey of the Project site on June 29, 2021. The pedestrian survey utilized transects spaced approximately 20 meters apart and the entire Project site was examined for the presence of cultural resources. No prehistoric resource sites were identified on the Project site during the pedestrian survey.

During preparation of the Cultural Resources Assessment, and as further discussed under Threshold “a.ii,” below, VCS requested a records search of the Sacred Lands Files (SLFs) from the Native American Heritage Commission (NAHC). Further, the City provided a notification of the Project as ■■
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required by Assembly Bill (AB) 52 and Senate Bill (SB) 18, and entered into consultation with Tribes that requested consultation, as discussed below. The results of this Native American outreach/consultation did not reveal the presence of any tribal cultural resources within the proposed Town Center at Moreno Valley Specific Plan area (Project area).

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

1. Traditional Tribal Cultural Places Act (Senate Bill 18 [SB18]) Senate Bill 18 (SB 18) requires local (city and county) governments to consult with California Native American tribes to aid in the protection of traditional tribal cultural places (“cultural places”) through local land use planning. SB 18 also requires the Governor’s Office of Planning and Research (OPR) to include in the General Plan Guidelines advice to local governments for how to conduct these consultations.

The intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places . The purpose of involving tribes at these early planning stages is to allow consideration of cultural places in the context of broad local land use policy, before individual site- specific, project-level land use decisions are made by a local government.

SB 18 requires local governments to consult with tribes prior to making certain planning decisions and to provide notice to tribes at certain key points in the planning process. These consultation and notice requirements apply to adoption and amendment of both general plans (defined in Government Code Section 65300 et seq.) and specific plans (defined in Government Code Section 65450 et seq.).

Although SB 18 does not specifically mention consultation or notice requirements for adoption or amendment of specific plans, existing state planning law requires local governments to use the same processes for adoption and amendment of specific plans as for general plans (see Government Code Section 65453). Therefore, where SB 18 requires consultation and/or notice for a general plan adoption or amendment, the requirement extends also to a specific plan adoption or amendment.

2. Assembly Bill 52 (AB 52)
California Assembly Bill 52 (AB 52) (2014) Chapter 532 amended Section 5097.94 of, and added Sections 21073, 21074, 21080.3.1, 21080.3.2, 21802.3, 21083.09, 21084.2, and 21084.3 to the California Public Resources Code (PRC), relating to Native Americans . AB 52 was approved on September 25, 2014. By including tribal cultural resources early in the California Environmental Quality Act (CEQA) process, the legislature intended to ensure that local and Tribal governments, public agencies, and project proponents would have information available, early in the project planning process, to identify and address potential adverse impacts to tribal cultural resources . By taking this proactive approach, the legislature also intended to reduce the potential for delay and conflicts in the environmental review process.

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The PRC now establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” (PRC Section 21084.2) To help determine whether a project may have such an effect, the PRC requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project.

That consultation must take place prior to the determination of whether a negative declaration, mitigated negative declaration, or environmental impact report is required for a project. (PRC Section 21080.3.1.) If a lead agency determines that a project may cause a substantial adverse change to tribal cultural resources, the lead agency must consider measures to mitigate that impact. These rules apply to projects that have a notice of preparation for an environmental impact report or negative declaration or mitigated negative declaration filed on or after July 1, 2015.

PRC Section 21074 defines “tribal cultural resources.” In brief, in order to be considered a “tribal cultural resource,” a resource must be either:
1) listed, or determined to be eligible for listing, on the national, state, or local register of historic resources, or
2) a resource that the lead agency chooses, in its discretion, to treat as a tribal cultural resource.

In the latter instance, the lead agency must determine that the resource meets the criteria for listing in the state register of historic resources. In applying those criteria, a lead agency must consider the value of the resource to the tribe.

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 s tate'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). ■■
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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 PRC ).

These sections also address the disposition of Native American burials 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.

4.17.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts to tribal cultural resources based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact to tribal cultural resources would occur if the Project or any Project-related component would:
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a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

4.17.4 IMPACT ANALYSIS
Threshold a.i.: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? As discussed above, a records search and literature review of the Project area was undertaken at the EIC at UCR. Based on this search and review of existing literature related to cultural and historic resources within the Project area, no tribal cultural resources listed or eligible for listing in the CRHR or in a local register of historical resources were identified. Further, there were no tribal cultural resources eligible for listing in the CRHR or in a local register of historical resources identified during the AB 52 and SB 18 consultation process. Accordingly, no impact would occur.

Threshold a.ii.: Would the project cause a substantial adverse change in the significance of a tribal cultural resource…and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?
As part of the SB 18/AB 52 consultation process required by State law, the City sent notification of the Project to Native American tribes with possible traditional or cultural affiliation to the Project area on January 12, 2022. The following tribes were sent a Project notification pursuant to AB 52.:
• Cahuilla Band of Indians
• Los Coyotes Band of Cahuilla and Cupeño Indians.
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• Pechanga Band of Luiseno Indians
• Rincon Band of Luiseño Indians
• San Manuel Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseño Indians

The following tribes were sent a Project notification pursuant to SB 18:
• Agua Caliente Band of Cahuilla Indians
• Cahuilla Band of Indians
• Desert Cahuilla Indians
• Los Coyotes Band of Cahuilla and Cupeño Indians.
• Morongo Band of Mission Indians
• Pechanga Band of Luiseno Indians
• Rincon Band of Luiseño Indians
• San Manuel Band of Mission Indians
• Santa Rosa Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseño Indians

The City received responses from the San Manuel Band of Mission Indians (SMBMI), the Rincon Band of Luiseño Indians (Rincon), the Pechanga Band of Luiseño Indians (Pechanga), and the Agua Caliente Band of Cahuilla Indians (Agua Caliente). Requested information was provided to each tribe including, but not limited to, the Cultural Resources Assessment and Project information.

The Rincon tribe indicated concurrence with the mitigation measures presented in the Cultural Resources Assessment, and the SMBMI indicated they had no concern with implementation of the Project but requested refinement to the mitigation measures identified. Neither of these tribes requested consultation and the City has determined that the mitigation recommendations provided by the SMBMI are effectively addressed through the City’s standard mitigation requirements, which were agreed to by the tribes that engaged in consultation with the City.

The Agua Caliente and Pechanga tribes requested consultation. The Agua Caliente tribe found the mitigation measures included in the Cultural Resources Assessment to be sufficient. The Pechanga tribe provided comments on the Cultural Resources Assessment and met with the City multiple times.

The Cultural Resources Assessment has been revised to address the comments from the Pechanga tribe.

None of the tribes provided information to the City indicating the presence of tribal cultural resources within the Project area; therefore, no impacts to known tribal cultural resources would result . ■■
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Notwithstanding, there is a potential for tribal cultural resources to be present beneath the Project site’s surface. The anticipated depth of excavation would vary for the Project components but would likely extend to maximum depths of 10 feet below the ground surface (bgs) for the installation of utility infrastructure. If any unanticipated tribal cultural resources are unearthed during construction and are disturbed/damaged by Project construction activities, impacts would be potentially significant.

Mitigation measure (MM) 4.5-1 through MM 4.5-5 from EIR Section 4.5, Cultural Resources, are restated below and require that a Native American Tribal Representative be present during excavations into native, Holocene -age sediments, and identif y steps to be taken to protect any resources encountered. Additionally, California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097 et seq outlines requirements for the protection of human remains if encountered during construction. With the implementation of MM 4.5-1 through MM 4.5-5, and compliance with established regulations related to human remains, potential impacts to tribal cultural resources would be reduced to a less than significant level.

4.17.5 CUMULATIVE IMPACT ANALYSIS
The cumulative impact area for tribal cultural resources is the City. Direct impacts to any tribal 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 tribal cultural 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 tribal 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 Resources Assessment and during consultation with Native American tribes, construction activities associated with the Project would not impact any known tribal cultural resources . However, there is a potential to encounter previously unknown tribal cultural 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 tribal cultural resources, if such resources are unearthed during Project construction. With implementation of MMs 4.5-1 through 4.5- 6, the 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 tribal cultural resources.

4.17.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a.i: No Impact. The Project site does not contain any known tribal cultural resources listed or eligible for listing in the CRHR or a local register of historical resources . Therefore, no impact would result.

Threshold a.ii: Significant Direct and Cumulatively -Considerable Impact. The Project s ite does not contain known tribal cultural resource sites; therefore, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource. Nonetheless, because the Project site is within ■■
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a Native American traditional use area, the Project construction activities have the potential to unearth and adversely impact tribal cultural resources that may be buried at the Project site.

4.17.7 MITIGATION
MM 4.5-1 through MM 4.5-5 from the Cultural Resources section of this EIR are restated below.

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 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 ■■
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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.

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 ■■
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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.

4.17.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold a.ii: 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 tribal cultural resources that may be encountered during ground-disturbing activities associated with Project development. With implementation of the required mitigation, the Project’s potential impacts on tribal cultural resources would be less than significant.
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4.18 UTILITIES AND SERVICE SYSTEMS
This section addresses the topics of water service and supply, wastewater collection and treatment, stormwater drainage facilities, dry utilities, and solid waste collection and disposal . The information contained in this section is based on information contained in the Water Supply Assessment Report, Town Center at Moreno Valley (WSA) prepared by Eastern Municipal Water District (EMWD) and included in EIR Technical Appendix M (EMWD 2022b), and publicly available information provided by local service providers and State oversight agencies . References used in this section are listed in EIR Section 7.0, References.

4.18.1 EXISTING CONDITIONS
A. Water Service
EMWD provides potable water and recycled water to an area of approximately 555 square miles in Western Riverside County, including the City of Moreno Valley ( City) (EMWD 2022b). Currently, domestic water mains are installed beneath Nason Street, Alessandro Boulevard, Bay Avenue, and Cottonwood Avenue. Due to the undeveloped nature of the Project site, there is no existing demand for potable water services, and the Project site is not connected to the potable water network.

B. Water Supply and Demand
The WSA prepared by EMWD for the Project, included in EIR Technical Appendix M , includes a detailed discussion of the EMWD’s water supply and projected water demands. In summary, the 2020 UWMP was adopted by the EMWD Board of Directors on June 30, 2021. This plan documents EMWD’s projected supplies and demands in five -year increments through the year 2045, certifies EMWD’s compliance with water use efficiency targets defined in the Water Conservation Act of 2009, and demonstrates EMWD’s supply reliability, even under dry year hydrologic conditions lasting multiple years. Approximately half of EMWD’s existing and future retail demand will be supplied through local sources such as groundwater, brackish groundwater desalination, and recycled water, with the balance coming from imported water delivered by the Metropolitan Water District ( MWD).

Demands shown in the 2020 UWMP are not project-specific , but rather, projected in aggregate using best available current and planned land use information over EMWD’s entire service area. The 2020 UWMP relies heavily on information and assurances contained within MWD’s 2020 Urban Water Management Plan (MWD UWMP) when evaluating service area supply reliability.

Consistent with the significant percentage of undeveloped land within EMWD’s service area, growth is anticipated to continue throughout the 2020 UMWP’s 25-year planning horizon; approximately 40% of EMWD’s service area is currently built out. EMWD has four sources of water supply: imported water purchased from MWD, potable groundwater, desalinated brackish groundwater, and recycled water. An annual breakdown of EMWD’s supplies between 2017 and 2021 is shown in Table 2 of the WSA included in EIR Technical Appendix M. On average from 2017 through 2021, EMWD’s water supply portfolio averaged approximately 49% of imported water, 11% groundwater, 6% desalinated brackish groundwater, and 34% recycled water, as further discussed below. As future development increases the water demands within EMWD’s service area, it is anticipated that the majority of the new ■■
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demands will be met through a combination of additional imported water from MWD and the development of local supply projects including increased production of potable groundwater, desalination of brackish groundwater, and use of recycled water. EMWD also plans to continue its efforts to enhance water use efficiency within its service area, which include requirements focused on the installation of lower water use landscape and interior fixtures. Water use efficiency is mandated statewide through existing ordinances, plumbing codes, and legislation.

1. Imported Water
EMWD is a member agency of MWD and relies on MWD to provide approximately half of its potable water supply. The northern portion of EMWD’s service area is supplied by MWD’s Mills Water Filtration Plant (WFP), while the south ern portion of EMWD’s service area is supplied by MWD’s Skinner WFP. Untreated water from MWD is primarily treated at EMWD’s Perris and Hemet WFPs, with a small quantity that is delivered directly to agricultural customers. EMWD also imports water from MWD to supply wholesale customers.

EMWD plans to supply new water demands through a combination of additional imported water purchases from MWD, as well as ongoing projects and programs expanding EMWD’s local water supply portfolio. The 2020 MWD UWMP provides information about MWD’s supply reliability and projected demands. In this document, MWD states that it will be able to reliably supply projected member agency demands through 2045 even under historic single -dry and multiple -dry years.

Unprecedented shortages are addressed in the Water Shortage Contingency Analysis and Catastrophic Supply Interruption Planning portions of the 2020 MWD UWMP.

2. Groundwater
EMWD’s service area overlies the San Jacinto Groundwater Basin. The San Jacinto Groundwater Basin is managed under two groundwater management plans. The Hemet/San Jacinto Groundwater Management Plan (HSJ Management Plan) covers the Hemet South, Canyon, San Jacinto Upper Pressure, and Hemet North portion of the Lakeview/Hemet North Groundwater Management Zones (GMZ). The West San Jacinto Groundwater Basin Management Plan (WSJ Management Plan) covers the Perris North, Perris South, San Jacinto Lower Pressure, Menifee, and the Lakeview portion of the Lakeview/Hemet North Management Zones. EMWD produces water for potable use or blending in four of the GMZs: Perris North, Hemet South, San Jacinto Upper Pressure, and Canyon. Desalter wells are located in the Perris South and Lakeview/Hemet North GMZs. Protecting the groundwater supply available to EMWD is an important part of EMWD’s planning efforts. EMWD is actively working with other agencies and groups to ensure that groundwater will continue to serve as a relia ble water resource in the future. This effort includes the replacement of groundwater extracted beyond a given basin’s safe yield.

EMWD extracts groundwater within its service area under the HSJ and WSJ Management Plans.

EMWD’s has the right to a long-term adjusted base production of 7,303-acre feet per year (AFY) of groundwater under the HSJ Management Plan. Both EMWD’s adjusted base production right and unused recharge water right can be carried over into future years. At the end of 2020, EMWD’s balance ■■
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of carry over credits exceeded 25,000 AF. Under the HSJ Management Plan, imported water will be recharged in the Hemet/San Jacinto area to support groundwater extractions, while pumping in the WSJ area, where groundwater levels have been rising, is planned to increase in the future as EMWD constructs new wells as part of the Perris North Groundwater Contamination Prevention and Remediation Program.

EMWD also owns and operates two desalination plants that convert brackish groundwater from the WSJ Basin into potable water. These plants not only provide a reliable source of potable water, but they also protect potable sources of groundwater and support EMWD’s groundwater salinity management program. EMWD operates potable wells in the Moreno Valley/North Perris area as well as brackish wells that feed EMWD’s desalination facilities. These wells are located outside of the Hemet/San Jacinto area and will be managed by EMWD as the Groundwater Sustainability Agency (GSA) under the San Jacinto Groundwater Basin Groundwater Sustainability Plan (GSP). Pumping in the GSA area is currently not subject to any restrictions.

3. Recycled Water
Recycled water is used extensively in EMWD’s service area in place of potable water. This offset to municipal demand comes from recycled water use to irrigate landscape and for industrial purposes.

The majority of EMWD’s agricultural customers also use recycled water, in some cases, in lieu of groundwater production. EMWD’s recycled water supply will expand as the population within EMWD’s service area continues to grow. EMWD generally uses all of its recycled water and is limited only by the amount available to serve during peak demands and by system losses. EMWD stores recycled water during low-demand periods and does not typically discharge recycled water. EMWD anticipates that this will continue even as the supply grows via programs to retrofit additional landscape customers currently using potable water and future recharge for indirect potable reuse.

Table 6 of the WSA included in EIR Technical Appendix M identifies the historic and projected customer distribution and water use by the various potable/raw retail customer types. EMWD’s primary retail customers for potable/raw water can be divided into residential, commercial, industrial, institutional, landscape, and agricultural sectors. The residential sector is EMWD’s largest customer segment; however, each sector plays a role in the growth and development of EMWD’s service area.

Based on the water delivery information presented in Table 6 of the WSA, the residential and commercial sectors represented 84% of the overall potable water use in the EMWD’s service area (63,000 AFY of the 75,000 AFY delivered). This trend is projected to continue with these sectors representing 90% of the potable water projected to be delivered in 2045 (102,200 AFY of the 113,800 AFY projected to be delivered).

EMWD also provides wholesale water service to a number of sub-agencies, serves recycled water, and imports water for recharge purposes.

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C. Wastewater Service
EMWD provides wastewater services to the area and is responsible for all wastewater collection and treatment in its service area. Wastewater generated in the vicinity of the Project is treated at the Moreno Valley Regional Water Reclamation Facility (MVRWRF) located in the southwestern portion of the City near Kitching Street and Mariposa Avenue. As of January 2021, the MVRWRF treats an average of 11.5 million gallons per day (mgd) with a current capacity of 16 mgd. (EMWD 2021c) There are existing sewer lines located in Bay Avenue (east and west of the Project site) and along the Project site’s northwestern boundary. Currently, the primary trunk sanitary sewer line that would serve the Project site is installed beneath Iris Avenue, approximately 1.6 miles south of the Project site . Due to the undeveloped nature of the Project site, the re is no wastewater generated and no existing demand for wastewater conveyance and treatment services and the Project site is not connected to the municipal sewer conveyance network.

D. Stormwater Conveyance Facilities
The Riverside County Flood Control and Water Conservation District (RCFC& WCD) is the County agency responsible for keeping County residents, including the residents of the City, safe from flood hazards. RCFC&WCD developed four master drainage plans (MDPs), which consist of Sunnymead Area, West End, Perris Valley, and Moreno; the City adopted the Moreno MDP.

Currently, the Project site discharges into Moreno MDP Storm Drain L ine “I” within Nason Street .

Flows from the Moreno MDP are carried to the Perris Valley Storm Drain system, which ultimately drains into the Santa Ana River.

E. Dry Utilities

1. Electrical Power
Southern California Edison (SCE) and the Moreno Valley Electric Utility (MVU) provide electricity to the City. MVU serves over 6,500 customers within its service are a, which includes the Project site (EMWD 2022b). There are existing electrical lines installed within the site adjacent streets. Due to the undeveloped nature of the Project site, there is no existing demand for electrical power, and the Project site is not connected to the electrical power network.

2. Natural Gas
Southern California Gas Company (SoCalGas) provides natural gas services to the City, including the Project site. The So Cal Gas service area covers approximately 24,000 square miles and more than 500 communities (SoCalGas 2022). There are existing natural gas lines installed within the site adjacent streets. Due to the undeveloped natur e of the Project site, the re is not an existing demand for natural gas and the Project site is not connected to the natural gas network.

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3. Telecommunications
Frontier Communications and Charter Communications supply communications and data to the Project site vicinity. There is existing infrastructure within the site adjacent streets. Due to the undeveloped nature of the Project site, there is not an existing demand for telecommunications, and the Project site is not connected to the telecommunications network.

F. Solid Waste Collection and Disposal
The City provides trash, recycling, and special waste handling services to residences and businesses through a contract with Waste Management. No other haulers are authorized to operate within the City.

Most of the City’s solid waste is disposed of at the Badlands Sanitary Landfill located north of SR-60 and west of I-10 off Ironwood Avenue . Other landfills within Riverside County, which include El Sobrante Landfill and Lamb Canyon Landfill, have the capacity to serve the City. A detailed description of these 3 landfills is provided below (City of Moreno Valley 2021a).

1. Badlands Landfill
Badlands Landfill is located at 31125 Ironwood Avenue in the City of Moreno Valley and is owned and operated by the Riverside County Department of Waste Resource s. The Badlands Landfill is permitted to accept 5,000 tons of solid waste per day. The Badlands Landfill is permitted to accept the following waste types : wood waste, tires, sludge, mixed municipal, metals, liquid waste, inert, industrial, green materials, dead animals, contaminated soil, construction/demolition, ash, asbestos, and agricultural.

It should be noted that the Riverside County Board of Supervisors approved the liner expansion of the Badlands Landfill on September 1, 2020. The expansion of the Badlands Landfill extended the cease operation date of the landfill, which was previously estimated to be January 1, 2022, to January 1, 2059. In December 2023, the Bad lands Landfill receives an average of 3,666.15 tons of solid waste per day, which represents approximately 73.3% of the landfill’s total permitted tonnage per day (CalRecycle 2024c).

2. El Sobrante Landfill
El Sobrante Landfill is located at 10910 Dawson Canyon Road in the City of Corona and is owned and operated by USA Waste Services of California, Inc . The El Sobrante Landfill is permitted to accept 16,054 tons of solid waste per day. The El Sobrante Landfill is permitted to accept the following waste types: tires, mixed municipal, contaminated soil, and construction/demolition. The landfill has a cease operation date of January 1, 2051. As of January 2024, the El Sobrante Landfill received an average of 10,622.8 tons of solid waste per day, which represents approxi mately 66.2% of the landfill’s total permitted tonnage per day (CalRecycle 2024c).

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3. Lamb Canyon Landfill
Lamb Canyon Landfill is located at 16411 State Highway 79 in the City of Beaumont and is owned and operated by Riverside County Department of Waste Resources . The Lamb Canyon Landfill is permitted to accept 5,000 tons of solid waste per day. The Lamb Canyon Landfill is permitted to accept the following waste types: wood waste, tires, sludge, mixed municipal, metals, liquid waste, inert, industrial, green materials, dead animals, contaminated soil, construction/demolition, ash, asbestos, and agricultural. The landfill has a cease operation date of April 1, 2032. As of November 2023, Lamb Canyon received an average of 2,166.5 tons of solid waste per day, which represents approximately

43.3% of the landfill’s total permitted tonnage per day (CalRecycle 2024c).

In 2022 (the last year data was approved), the City implemented 45 programs to reduce solid waste generation and achieve the increased solid waste diversion required. According to the California Department of Resources Recycling and Recovery (CalRecycle), these programs involve composting, facility recovery, household hazardous waste (HHW), policy incentives, public education, recycling, source reduction, special waste materials, and transformation (CalRecycle 2024b).

Due to the undeveloped nature of the Project site, there is no solid waste gene ration under existing conditions.

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

1. Water Conservation in Landscaping Act
The Water Conservation in Landscaping Act of 2006 was established to ensure adequate water supplies are available for future uses. To promote the conservation and efficient use of water, the Act requires local agencies to adopt a water -efficient landscape ordinance. When such an ordinance ha s not been adopted, a finding as to why (based on the climatic, geologic, or topographical conditions) such an ordinance is not necessary, must be adopted. In the absence of such an ordinance or findings, the policies and requirements contained in the “model” ordinance drafted by the State of California shall apply within the affected jurisdiction.

2. Urban Water Management Planning Act
The Urban Water Management Planning Act (UWMP Act) was proposed and adopted to ensure that water planning is conducted at the local level, as the State of California recognized that two water agencies in the same region could have very different impacts from a drought. The UWMP Act requires water agencies to develop Urban Water Management Plans (UWMPs) over a 20-year planning horizon and further require s UWMPs to be updated every five years . UWMPs are exempt from compliance with CEQA.

The UWMPs provide a framework for long-term water planning and inform the public of a supplier’s plans for long-term resource planning that ensures adequate water supplies for existing and future demands. This part of the California Water Code requires urban water suppliers to report, describe, ■■
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and evaluate water deliveries and uses, water supply sources, efficient water uses, demand management measures, and water shortage contingency planning. As such, UWMPs serve an important role in documenting water supply availability and reliability for purposes of compliance with Senate Bills 610 and 221, which link water supply sufficiency to large land use development project approvals. The EMWD adopted its 2020 UWMP in July 2021.

3. California Senate Bill 610
The California Water Code (Water Code) Sections 10910 through 10915 were amended by the enactment of SB 610 in 2002. SB 610 requires an assessment of the sufficiency of available water supplies to serve the demand generated by a proposed project, as well as the reasonably foreseeable cumulative demand in the region over the next 20 years under average normal year, single dry year, and multiple dry year conditions. Under SB 610, water assessments must be furnished to local governments for inclusion in any environmental documentation for certain projects (as defined in Water Code Section 10912 [a]) subject to CEQA. For the purposes of SB 610, “project” means any of the following:
(1) A proposed residential development of more than 500 dwelling units. (2) A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space.
(3) A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.
(4) A proposed hotel or motel, or both, having more than 500 rooms. (5) A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area.
(6) A mixed-use project that includes one or more of the projects specified in this subdivision. (7) A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling unit project.

A water supply assessment (WSA) is required for the Project and is included in EIR Technical Appendix M.

4. Government Code Section 66473.7(b)(2) (Senate Bill 221) Under Senate Bill (SB) 221, approval by a city or county of residential subdivisions of more than 500 units requires an affirmative written verification of sufficient water supply. SB 221 is intended as a ‘fail safe’ mechanism to ensure that collaboration on finding the needed water supplies to serve a new large subdivision occurs before construction begins . SB 221 requires the legislative body of a city or county or the advisory agency, to the extent that it is authorized by local ordinance to approve, conditionally approve, or disapprove a tentative map, to include as a condition in any tentative map that includes a subdivision a requirement that a sufficient water supply shall be available . A water ■■
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supply verification is required for the Project and is provided through the WSA provided in EIR Technical Appendix M.

5. California Solid Waste Integrated Waste Management Act (AB 939) The California Integrated Waste Management Act was enacted by the California Legislature in 1989 with the goal of reducing dependence on landfills for the disposal of solid waste and to ensure an effective and coordinated system for the safe management of all solid waste generated within the state.

Assembly Bill (AB) 939 mandated a reduction in the amount of solid waste disposed of by jurisdictions and required diversion goals of 25% by 1995 and 50% by the year 2000. The Integrated Waste Management Act established a hierarchy of preferred waste management practices, which include (1) source reduction, (2) recycling and composting, and (3) environmentally safe disposal by transformation or landfilling. It addresses all aspects related to solid waste regulation, including the details regarding the lead enforcement agency's requirements and responsibilities; the permit process, including inspections and denials of permits; enforcement; and site clean-up and maintenance. It requires that each county prepare a countywide integrated waste management plan that is reviewed at least once every five years to assure that waste management practices remain consistent with the practices defined in the California Public Resources Code (PRC).

6. Waste Reuse and Recycling Act (AB 1327)
The Waste Reuse and Recycling Act (WRRA) required the California Integrated Waste Management Board (CIWMB) to approve a model ordinance for adoption by any local government for the transfer, receipt, storage, and loading of recyclable materials in development projects by March 1, 1993. The WRRA also required local agencies to adopt a local ordinance by September 1, 1993, or allow the model ordinance to take effect . The WRRA requires all development projects that are commercial, industrial, institutional, or marina in nature and where solid waste is collected and loaded, to provide an adequate area for collecting and loading recyclable materials over the lifetime of the project. The area is required to be provided before building permits are issued.

7. Solid Waste Disposal Measurement Act of 2008
The purpose of the Solid Waste Disposal Measurement Act of 2008 (SB 1016) is to make the process of goal measurement (as established by AB 939) simpler, timelier, and more accurate. SB 1016 builds on AB 939 compliance requirements by implementing a simplified measure of jurisdictions’ performance. SB 1016 accomplishes this by changing to a disposal -based indicator, the per capita disposal rate , which uses only two factors: (1) a jurisdiction’s population (or in some cases employment) and (2) its disposal, a s reported by disposal facilities. Each year CalRecycle calculates each jurisdiction’s per capita (per resident or employee) disposal rates. If a business is the dominant source of a jurisdiction’s waste generation, CalRecycle may use the per-employee disposal rate. Each year’s disposal rate will be compared to that jurisdiction’s 50 % per capita disposal target. As such, jurisdictions will not be compared to other jurisdictions or the statewide average, but they will only be compared to their own 50% per capita disposal target. Among other benefits, per capita disposal is an indicator that allows for jurisdiction growth because, as residents or employees increase, report -year disposal tons can increase and still be consistent with the 50% per capita disposal target. A comparison ■■
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of the reported annual per capita disposal rate to the 50% per capita disposal target will be useful for indicating progress or other changes over time.

8. Mandatory Commercial Recycling Program (AB 341)
Assembly Bill (AB) 341 (Chapter 476, Statutes of 2011 [Chesbro, AB 341]) directed CalRecycle to develop and adopt regulations for mandatory commercial recycling. The final regulation was approved by the Office of Administrative Law on May 7, 2012. AB341 was designed to help meet California’s recycling goal of 75% by the year 2020. AB 341 requires all commercial businesses and public entities that generate four cubic yards (cy) or more of waste per week to have a recycling program in place. In addition, multi-family apartments with five or more units are also required to form a recycling program.

9. Assembly Bill 1826
AB 1826 requires jurisdictions to implement an organic waste recycling program for businesses, including outreach, education, and monitoring of affected businesses. Additionally, each jurisdiction is to identify a multitude of information, including barriers to siting organic waste recycling facilities, as well as closed or abandoned sites that might be available for new organic waste recycling facilities.

AB 1826 defines “organic waste” as food waste, green waste, landscape and pruning waste, non- hazardous wood waste, and food-soiled paper waste that is mixed in with food waste. It also defines a “business” as a commercial or public entity, including, but not limited to, a firm, partnership, proprietorship, joint stock company, corporation, or association that is organized as a for-profit or nonprofit entity, or a multifamily residential dwelling consisting of five or more units. As of January 1, 2017, businesses that generate four cy or more of organic waste per week are subject to this requirement. Commencing January 1, 2019, businesses that generate four cy or more of commercial solid waste per week also are required to arrange for organic waste recycling services.

10. Senate Bill 1383
SB 1383 (2016) requires a 50% reduction in disposal of organic waste from the 2014 level by 2020, and a 75% reduction by 2025. The law grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20% of currently disposed edible food is recovered for human consumption by 2025. Increasing food waste prevention, encouraging edible food rescue, and expanding the composting and in-vessel digestion of organic waste throughout the state will help reduce methane emissions from organic waste disposed in California's landfills. Additionally, compost has numerous benefits including water conservation, improved soil health, and carbon sequestration.

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

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

The Title 24 Building Energy Efficient Standards and CALGreen Code are updated on a regular basis (every three years), with the most recent approved update s consisting of the 2022 Building Energy Efficiency Standards and 2022 CALGreen Code, which became effective on January 1, 2023.

B. Local Plans, Policies, and Regulations

1. EMWD Urban Water Management Plan
The Eastern Municipal Water District 2020 Urban Water Management Plan (2020 UWMP) (EMWD 2021b) is the current UWMP for the EMWD . The 2020 UWMP includes a water system analysis, identifies improvements to correct existing deficiencies and serve projected future growth, and presents the estimated cost and phasing of the recommended improvements. As concluded in the 2020 UWMP, EMWD anticipated that it will be able to meet projected demand for water within its service boundaries through the year 2045 in all types of climate conditions including normal, dry, and multiple consecutive dry weather years using imported water from MWD with existing supply resources.

Even with highly reliable supplies, events such as statewide water use restrictions or a catastrophic natural disaster (such as an earthquake) that disrupts imported water supplies may require EMWD to temporarily reduce water demands. EMWD’s Water Shortage Contingency Plan (WSCP), included as Appendix I of the 2020 UWMP, defines the actions that EMWD could take to conserve water during a shortage. The WSCP describes how EMWD would communicate these requirements to customers, and it describes how the restrictions on use would be enforced. Further, as required by Executive Order N-7-22, and as outlined in the WSCP, EMWD will be required to prepare an Annual Water Supply and Demand Assessment (Annual Assessment) and submit it to the California Department of Water Resources (DWR) each year, beginning July 1, 2022. The Annual Assessment is intended to meet requirements of Water Code Section 10632.1 and present an assessment of the likelihood of a water shortage occurring during the next 12 months.

2. Moreno Master Drainage Plan (MDP)
The Project site is located within the RCFC&WCD’s Moreno MDP. The Moreno MDP was prepared by the RCFC&WCD, to identify master-planned drainage and flood control facilities that are needed ■■
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in the area to safely convey the peak runoff of a 100-year frequency storm. The Project site discharges into Moreno MDP storm drain facilities.

3. Moreno Valley Municipal Code (MVMC)
MVMC Section 6.02.050, Containers, provides standards for the provision of solid waste (refuse) and recyclable material storage areas in compliance with state law (California Solid Waste Reuse and Recycling Access Act, PRC Sections 42900 through 42911).

MVMC Chapter 8.80, Recycling and Diversion of Construction and Demolition Waste , requires at least 50% of waste tonnage from construction, demolition, and remodeling debris be diverted from the landfill. Additionally, the City’s Building Code requires development projects to complete and submit a Waste Management Plan for approval prior to issuance of permits. The Waste Management Plan would identify the material type and estimate the amount of materials to be recycled during construction. The P roject would also be required to complete a Diversion Report for review by the City’s Building Department to demonstrate that the Project recycled a minimum of 50% of its construction waste.

MVMC Chapter 9.17, Landscape and Water Efficiency Requirements , provides landscape development requirements consistent with the goals and policies of the General Plan, and implements landscape-related General Plan objectives and compliance with California Model Water Efficiency Ordinance. Relative to water conservation, t he purpose of the landscape requirements is to identify landscape design issues and provide standards to create water -conserving landscape areas. These requirements apply to landscape development in public rights -of-way, areas adjacent to the public right-of-way, easements, setbacks, slopes, parking areas, public, quasi-public, commercial, industrial, and specified residential on-site landscape areas.

4.18.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates impacts to utilities and service systems based on thresholds of significance included in Appendix G of the CEQA Guidelines. A significant impact related to utilities and service systems would occur if the Project:
a) Would require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects; b) Would not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years; c) Would result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments; d) Would generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; ■■
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e) Would not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

4.18.4 IMPACT ANALYSIS
Threshold a: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
A. Water
The Project is not a candidate for reclaimed water use due to the lack of existing or planned reclaimed water lines in the area. Therefore, the Project would use only potable water. The Project’s water demand (indoor and outdoor uses) as reported in the Project-specific WSA included in EIR Technical Appendix M, is estimated to be approximately 279,498 gallons per day (GPD) (313.39 AFY). This includes 232,000 GPD for the proposed residential uses (260.05 AFY); 36,784 GPD (41.23 AFY) for the proposed commercial uses, and 10,714 GPD (12.01 AFY) for the proposed park uses (EMWD 2022b).

The Project would include the installation of on-site water lines to provide domestic water to the proposed uses, and for fire flow and irrigation. The on-site water lines would connect to existing lines beneath Cottonwood Avenue, Nason Street, Bay Avenue (west of the Project site), and Alessandro Boulevard (refer to Figure 3-8, Conceptual Utility Plan, in EIR Section 3.0, Project Description). No expansion, extension, re-construction, or other modifications to existing off-site water lines would be required to serve the Project. The Project’s water system would be designed to ensure sufficient fire flow to the proposed buildings.

Construction activities associated with installation of new water lines on site and connections to existing water lines in the site-adjacent roadways would be within the physical impact area identified for the Project and evaluated throughout this EIR (refer to the construction and physical impact discussions in EIR Section 4.1 through Section 4.19). As identified, the installation of utility lines has the potential to cause construction-related environmental effects (e.g., short-term air pollutant emissions, noise, impacts to biological, cultural and paleontological resources, and traffic movement disruptions), which are an inherent part of the Project’s construction process . The proposed w ater facilities would be installed in compliance with applicable City Engineering Standards, which incorporate EMWD standards. No additional impacts associated with construction /installation of on- site water lines or connections to existing water facilities would occur. There are no significant environmental impacts specifically related to installation of the proposed water lines.

B. Wastewater and Wastewater Treatment Facilities
The Project’s estimated wastewater generation entering EM WD’s sewer system is conservatively estimated to be approximately 279,498 GPD based on the estimated increase in water demand. ■■
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The Project would involve the installation of sewer lines on site, a connection to the existing sewer line in Bay Street (west of the Project site), and the installation of a 10-inch sewer line in Alessandro Boulevard (east of the proposed new north-south public street), which would connect to the existing sewer line in Nason Street (refer to Figure 3-8, Conceptual Utility Plan, in EIR Section 3.0). Besides the site -adjacent sewer line to be installed in Alessandro Boulevard, no expansion, extension, re - construction, or other modifications to existing off-site sewer lines would be required to serve the Project.

Construction activities associated with installation of new sewer lines on and off site and connections to existing sewer lines in the site-adjacent roadways would be within the physical impact area identified for the Project and evaluated throughout this EIR (refer to the construction and physical impact discussions in EIR Section 4.1 through Section 4.19). As identified, the installation of utility lines has the potential to cause construction-related environmental effects (e.g., short-term air pollutant emissions, noise, impacts to biological, cultural, and paleontological resources, and traffic movement disruptions), which are an inherent part of the Project’s construction process. The proposed sewer facilities would be installed in compliance with applicable City Engineering Standards, which incorporate EMWD standards. No additional impacts associated with construction/installation of sewer lines or connections to existing sewer facilities would occur. There are no significant environmental impacts specifically related to installation of the proposed sewer lines.

While the Project would result in an increase d demand for wastewater treatment services, the Project wastewater treatment demand, which is further discussed under the response to Threshold “c” below, would not result in or require new or expanded wastewater treatment facilities.

C. Stormwater Drainage Facilities
The Project would involve the construction of on-site infrastructure (e.g., catch basins and underground storm drain pipes to capture and convey stormwater runoff to water quality treatment facilities and then ultimately to off-site storm drains. As shown in Figure 3-8, Conceptual Utility Plan, in EIR Section

3.0, the on-site drainage system would connect to an existing storm drain line in Nason Street at the intersection with Alessandro Boulevard and the intersection with Bay Avenue, and an existing storm drain line in Bay Avenue (west of the Project site). A dditionally, a new storm drain line would be constructed in Alessandro Boulevard extending from Street A to the west (approximately 650 feet west of the Project site’s westerly boundary) where it would connect to an existing storm drain in Alessandro Boulevard. The storm drain and water quality management system is further described in EIR Section

4.10, Hydrology and Water Quality.

Construction activities associated with installation of new on- and off-site storm drain and water quality management facilities, and connections to existing storm drain lines in the site -adjacent roadways would be within the physical impact area identified for the Project and evaluated throughout this EIR (refer to the construction and physical impact discussions in EIR Section 4.1 through Section 4.19). As identified, the installation of utility lines has the potential to cause construction-related environmental effects (e.g., short-term air pollutant emissions, noise, impacts to biological, cultural , and ■■
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paleontological resources, and traffic movement disruptions ), which are an inherent part of the Project’s construction process. The proposed storm drain and water quality management facilities would be installed in compliance with applicable City Engineering Standards. No additional impacts associated with construction/installation of storm drain and water quality management facilities lines or connections to existing stormwater facilities would occur. There are no significant environmental impacts specifically related to installation of the proposed storm drain and water quality management facilities.

D. Dry Utilities (Electrical Power, Natural Gas, and Telecommunications) The Project would be served by MVU (electricity), SoCalGas (natural gas), Frontier Communications (telephone and data), and Charter Communications (cable television and data). On-site utility infrastructure would be installed and would connect to existing infrastructure in the site-adjacent streets (Cottonwood Avenue, Nason Street, and Alessandro Boulevard). The construction activities associated with the installation of proposed on-site dry utility infrastructure, any off-site connections to existing dry utility infrastructure, and relocation of existing facilities adjacent to the Project site, as needed, would be within the physical impact area identified for the Project and evaluated throughout this EIR.

No additional impacts associated with construction/installation of dry utilities lines or connections to existing dry utilities infrastructure would occur. There are no significant environmental impacts specifically related to installation of the proposed dry utilities infrastructure.

E. Conclusion
In summary, the installation of the utility and service system infrastructure improvements proposed as part of the Project would result in physical environmental impacts inherent in the Project’s construction process; however, these impacts have already been included in the analyses of construction-related effects presented throughout this EIR. In instances where the Project’s construction phase would result in specific, significant impacts, feasible mitigation measures are provided. The construction of infrastructure necessary to serve the Project would not result in any significant physical effects on the environment that are not already identified and disclosed elsewhere in this this EIR. Accordingly, impacts would be less than significant and additional mitigation measures beyond those identified throughout other subsections of this EIR would not be required.

Threshold b: Wo
uld the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years?
As previously discussed in Section 4.18.1, EMWD would provide potable water to the Project. Present and future water supplies available to the EMWD to provide water service within its service area include potable groundwater, desalination of brackish groundwater, and use of recycled water.

A WSA was prepared by EMWD to assess the Project’s effect on the EMWD’s ability to provide adequate water service to its customers during normal, dry, and multiple dry years . The WSA, which is provided as EIR Technical Appendix M, was prepared in accordance with SB 610 and ■■
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SB 221. According to the WSA, in the 2020 UWMP, the demand projections for the parcels covering the Project site were estimated based on Medium Density Residential land use, with a total demand of 134.43 AFY (average day demand of 119,929 GPD). As shown in Table 11 of the WSA, the total estimated water demand for the Project is estimated to be 279,498 GPD (313.39 AFY). This includes 232,000 GPD for the proposed residential uses (260.05 AFY); 36,784 GPD (41.23 AFY) for the proposed commercial uses, and 10,714 GPD (12.01 AFY) for the proposed park uses . This estimated water demand represents an increase in the limits of estimated demand considered in the 2020 UWMP.

However, EMWD has planned for this possibility by including a planning buffer in the 2020 UWMP and projecting future water use at lower levels of water efficiency compared to present-day water use.

After accounting for the cumulative demands from the Project and other developments in EMWD’s service area (including other WSAs), over 11,000 AFY of buffer remains. This buffer is expected to grow in the future due to factors such as ongoing water use efficiency legislation and potable water offsets from recycled water conversions. Accordingly, demands from new development in EMWD’s service area, including the Project, ultimately fall within the levels of demand considered in the 2020 UWMP (EMWD 2022b).

EMWD relies on MWD and local resources to meet the needs of its growing population. MWD indicated in the 2020 UWMP – MWD that it has the ability to meet all of its member agencies’ projected supplemental demand through 2045, under normal, historic single-dry and historic multiple- dry year conditions (EMWD 2021b). Based on present information and the assurance that MWD is engaged in identifying solutions that, when combined with the rest of its supply portfolio, will ensure a reliable long-term water supply for its member agencies, EMWD has determined that it will be able to provide adequate water supplies to meet the potable water demand for this Project as part of its existing and future demands (EMWD 2022b).

As with all new development in the City and in the EMWD service area, and as required by the proposed Project requirements, and applicable local and state regulations, the Project would install water-efficient plumbing fixtures in buildings. Additionally, water -conserving irrigation as well as climate-appropriate landscaping would be utilized . Further as discussed under Threshold “a,” the Project would include the installation of water infrastructure needed to serve the Project, as required by EMWD.

Based on the foregoing, EMWD has adequate existing water entitlements and resources to serve the Project. Implementation of the Project would not cause EMWD to be unable to meet the demands of existing and future service obligations during normal, dry, and multiple dry years. The Project’s impact to water supply would be less than significant and mitigation is not required.

Threshold c: Wo
uld the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Wastewater generated by the Project would be treated at the MVRWRF . Under existing conditions, the MVRWRF has an excess treatment capacity of approximately 5.0 million gallons per day, while ■■
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Project operations are conservatively estimated to generate approximately 279,498 gallons of wastewater per day (0.28 million gallons per day). Implementation of the Project would utilize approximately 5.6% of the excess daily treatment capacity at the MVRWR F. Accordingly, the MVRWRF has sufficient excess capacity to treat wastewater generated by the Project in addition to existing commitments. Because there is adequate capacity at existing treatment facilities to serve Project demands, impacts would be less than significant and mitigation is not required.

Threshold d: W ould the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
The Project would be required to comply with mandatory waste reduction requirements discussed in Section 4.18.2. Notwithstanding, construction and operation of the Project would result in the generation of solid waste requiring disposal at a landfill.

A. Construction Impact Analysis
Solid waste is anticipated to be generated by the Project’s construction process, primarily comprising discarded materials and packaging. The CALGreen Code, which is implemented through the MVMC Chapter 8.38, California Green Building Code , requires that at least 65 % of construction and demolition debris be diverted from landfills through recycling, reuse, and/or salvage . The non - recyclable construction debris generated during Project construction would be disposed of at the Badlands Landfill, El Sobrante Landfill, or the Lamb Canyon Landfill . As described previously, the Badland Landfill, El Sobrante Landfill, and Lamb Canyon Landfill receive below their maximum permitted daily tonnage; thus, the Project’s construction waste is not anticipated to result in these landfills exceeding their maximum permitted daily disposal volume . Furthermore, these landfills are not anticipated to reach their total maximum capacities during the Project’s construction period. The Badlands Landfill, El Sobrante Landfill, and Lamb Canyon Landfill have sufficient daily capacity to accept solid waste generated by the Project’s construction phase; thus, impacts to landfill capacity associated with near-term Project construction activities would be less than significant.

B. Operational Impact Analysis
As shown in Table 4.18-1, Estimated Solid Waste Generation , it is estimated that the Project would generate approximately 16,437.74 pounds per day (lbs/day)/ 8.2 tons per day of solid waste. A minimum of 75% of all solid waste would be required to be recycled pursuant to AB 341, consistent with the State’s solid waste reduction goals; therefore, Project operation would generate approximately

2.1 tons per day of solid waste requiring disposal at a landfill. Non-recyclable waste generated by the Project would be disposed at the Badlands Landfill, El Sobrante Landfill, or the Lamb Canyon Landfill.

The Project’s estimated solid waste generation represents approximately 0.09% of the remaining permitted daily capacity of these landfills (9409.9 tons of solid waste per day).

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Table 4.18-1 Estimated Solid Waste Generation
Land Use Type Proposed Development Generation Rate1 Solid Waste Generated (lbs/day)
Residential 800 dwelling units 12.23 lbs/dwelling unit/day 9,784 Commercial Retail 105,890 square feet 0.046 lb/square foot/day 4,870.94 Professional Office 15,000 square feet 0.084 lb/square foot/day 1,260 Civic Center 30,000 square feet 0.007 lb/square foot/day 210 Hotel 106 rooms 2 lbs/room/day 212
High Turnover Restaurant 20,160 square feet 0.005 lb/square feet/day 100.8 Park 4.8 acres --2 --
Total 16,437.74
lbs/day = pounds per day

1. Solid waste generation rates are based on solid waste generation rates compiled by CalRecycle. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates#Service

2. CalRecycle has not established a solid waste generation rate for park uses.

The Project’s long-term solid waste generation is not in excess of State or local disposal standards, or in excess of the local infrastructure capacity to handle the waste disposal. As described above, the Badlands Landfill, El Sobrante Landfill, and the Lamb Canyon Landfill are below their maximum permitted daily disposal volume. Thus, waste generated by the Project’s operation is not anticipated to cause the landfill s to exceed their maximum permitted daily disposal volume. Because the Project would generate a relatively small amount of solid waste per day as compared to the permitted daily capacity of the landfill s, impacts to landfill facilities during the Project’s long-term operational activities would be less than significant.

Threshold e:

Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Federal, State, and local statutes and regulations regarding solid waste generation, transport, and disposal are intended to decrease solid waste generation through mandatory reductions in solid waste quantities (e.g., through recycling and composting of green waste) and the safe and efficient transport of solid waste. Future residents and tenants of the Project would be required to coordinate with the City’s waste hauler (currently Waste Management) to develop a collection program for recyclables (e.g., paper, plastics, glass, and aluminum), and organic materials in accordance with local and State programs.

Additionally, future residents and tenants would be required to comply with applicable practices enacted by the City under the California Integrated Waste Management Act of 1989 (AB 939) and any other applicable local, State, and federal solid waste management regulations. AB 939 required t hat local jurisdictions divert at least 50% of all solid waste generated by January 1, 2000. The diversion goal has been increased to 75% by 2020 by SB 341.

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As previously discussed, in 2022, the City implemented 45 programs to reduce solid waste generation and achieve the increased solid waste diversion required. The City had an average disposal rate of 4.8 pounds per resident per day and 16.5 pounds per employee per day in 2022 (the last year for which information is available). The disposal rate for residents is slightly higher than the established disposal rate target of 4.4 pounds per resident per day, and the disposal rate for employees is less than the established disposal rate of 31.8 pounds per employee per day (CalRecycle 2024a). In other words, the amount of solid waste being generated on a daily basis by residents is greater and the solid waste generated by employees is less. T he City will continue to implement waste diversion programs to ensure future compliance with waste reduction requirements.

Future residents and tenants would participate in the City’s solid waste management programs, and contractors would comply with MVMC Chapter 8.80, Recycling and Diversion of Construction and Demolition Waste. Adherence to the mandatory solid waste management requirements would reduce the amount of solid waste generated by the Project and diverted to landfills, which in turn will aid in the extension of the life of affected disposal sites. Therefore, impacts related to solid waste statutes and regulations would be less than significant.

4.18.5 CUMULATIVE IMPACT ANALYSIS
The geographic context for the cumulative impact analysis for utilities and infrastructure systems for water and sewer collection services is the EMWD service area. The geographic context for the cumulative impact analysis for dry utilities is the service area for the respective service providers (MVU, SoCalGas, Frontier Communications, and Charter Communications). The cumulative impact area for wastewater treatment impacts is the service area for the MVRWRF. The geographic context for the cumulative impact analysis for storm drains and solid waste is the City of Moreno Valley.

As with the Project, individual cumulative development projects would require the construction of necessary infrastructure (water and wastewater lines, storm drain facilities, dry utility infrastructure, and others) to serve the projects. However, the infrastructure needed for the Project would be limited to relatively small distribution and collection lines, which would occur within the Project’s identified construction impact area. With the exception of a new storm drain line to be installed in Alessandro for a short distance, no new or expanded off-site infrastructure is required to be implemented as part of the Project, beyond the utility line connections to existing utilities adjacent to the Project site. T he Project’s proposed utility infrastructure would only serve the Project site and would not facilitate additional development in the area. The environmental impacts associated with construction of utility infrastructure to be installed as part of the Project have been addressed throughout this Draft E IR and would be less than significant with mitigation. The Project and all new development would have to coordinate with service providers to obtain services, and connections to existing utility lines would be made in accordance with the applicable requirements of the utility provider and the City, as applicable.

Further, the payment of service fees to the respective service providers is expected to ensure adequate services to individual developments. The Project in conjunction with cumulative development would not result in significant impacts related to the construction and installation of utility infrastructure and would not result in a cumulative impact. Therefore, the Project would not have a cumulatively ■■
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considerable contribution to a significant cumulative impact associated with construction of utility infrastructure.

As discussed under Threshold “b,” the analysis in the Project’s WSA (included in EIR Technical Appendix M), which is based on the EMWD ’s 2020 UWMP, demonstrates that with implementation of the Project and other cumulative developments, the EMWD would have adequate water supplies through the year 2045 during normal, dry, and multiple dry years. Therefore, there would be a less than significant cumulative impact, and the Project would not have a cumulatively considerable contribution to a significant cumulative impact associated with water supply.

Under long-term, cumulative conditions, EMWD anticipates future increases in the demand for wastewater treatment services as the population within their service area grows . As discussed under Threshold “c,” the Project would not result in the need for expanded wastewater treatment facilities, as the MVRWFRF has sufficient existing capacity to handle wastewater generated by the Project and other cumulative development. Any proposed changes to capacity of the EMWD or any facility maintained by EMWD are reviewed throughout the year by EMWD. For all new development within the EMWD service area, connection and service fees are allocated to assist in the financing of any future collection and disposal facilities and any future new/modified water and sewer treatment plant facilities. Therefore, EMWD would have adequate wastewater treatment capacity for wastewater generation by the Project and cumulative developments in its service area and there would be less than significant cumulative impact. The wastewater generated by the Project would not exceed the capacity of the MVRWRF and the Project would not have a cumulatively considerable contribution to a significant cumulative impact associated with wastewater treatment.

The solid waste generated by construction and operation of the Project would represent nominal portion of the daily disposal capacity at the landfills serving the City. These landfills have sufficient daily capacity to handle solid waste during the Project construction and operation and the Project and would not directly result in the need for expanded solid waste disposal facilities. Further, the Project would adhere to applicable local and State regulations during both construction and long-term operations.

Other cumulative development would also be required to comply with such regulations. Therefore, the Project combined with cumulative projects would not have a cumulative impact, and the Project would not have a cumulatively considerable contribution to a significant cumulative impact related to solid waste disposal and compliance with regulations addressing the reduction of solid waste generation and disposal.

4.18.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Threshold a: Less than Significant Impact. The physical environmental effects associated with installing the Project’s water, wastewater, stormwater drainage, natural gas, electric power , and telecommunications infrastructure is evaluated throughout this EIR and no significant impacts specific to the provision of utilities services have been identified.

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Threshold b: Less than Significant Impact. EMWD would have sufficient water supplies to service the Project. The Project would not exceed the EMWD’s available supply of water during normal years, single-dry years, or multiple-dry years.

Threshold c: Less than Significant Impact. EMWD would provide wastewater treatment services to the Project via the MVRWRF, which would have adequate capacity to service the Project and no new or expanded facilities would be needed.

Threshold d: L ess than Significant Impact . There is adequate capacity available at the Badlands Landfill, El Sobrante Landfill, and Lamb Canyon Landfill to accept the Project’s solid waste during both construction and long-term operation. The Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure to handle the solid waste.

Threshold e: L ess than Significant Impact . The Project would comply all applicable statut es and regulations related to the management and reduction of solid waste and pertaining to waste disposal, reduction, and recycling.

4.18.7 MITIGATION MEASURES
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4.19 WILDFIRE
This subsection analyzes potentially significant impacts related to wildfire that could result from the implementation of the Project. References used to prepare the s ubsection are listed in Environmental Impact Report (EIR) Section 7.0, References.

4.19.1 EXISTING CONDITIONS
A. Wildfire Hazards
Threat from wildfire hazards is determined based on several factors including fuel loading (vegetation), topography, climatic conditions, and the proximity of structures to fire hazards. Most wildfire damage occurs in wildland-urban interface areas, where homes and woodland vegetation are directly adjacent.

The Project site is within a Local Responsibility Area (LRA) within the City limit; the Moreno Valley Fire Department (MVFD) is the primary response agency for fires within the City. 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 FHSZ (City of Moreno Valley 2021b) 1; the nearest Very High Fire Hazard
Severity Zone (VHFHSZ) is located approximately 0.4 mile east of the Project site, north of Cottonwood Avenue.

As further discussed in EIR Subsection 4.4, Biological Resources, the Project site is characterized by a maintained open field comprised of disturbed annual grassland cover vegetated with a variety of non- native and early successional weedy plant species that have been subject to vegetation management activities (mowing) . T he Project site does not contain wildland. 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.

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

1. 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 s in 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

1 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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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.

4.19.3 BASIS FOR DETERMINING SIGNIFICANCE
The City of Moreno Valley evaluates wildfire impacts based on thresholds of significance included in Appendix G of the CEQA Guidelines. Impacts related to wildfire could be significant if the implementation of the Project is located in or near State Responsibility Areas (SRAs) or lands classified as VHFHSZs, and would:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan; b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?

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4.19.4 IMPACT ANALYSIS
If located in or near State Responsibility Areas (SRAs) or lands classified as very high fire hazard severity zones:

Threshold a: Would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
Threshold b: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, would the Project thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Threshold c: Would the Project r equire the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Threshold d: Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
According to the California Department of Forestry and Fire Protection (CalFire) Fire Hazard Severity Zone (FHSZ) Viewer, the Project site is not within a SRA FHSZ; the nearest lands within an SRA are located approximately 2.7 miles north of the Project site (CAL FIRE 2023). Additionally, based on the City’s proposed 2040 General Plan Safety Element, the Project site is not within land classified as a VHFHSZ. The nearest lands classified as VHFHSZ are located approximately 0.4-mile east of the Project site. The Project site is not within or near an SRA, does not have lands classified as VHFHSZ, and is not within or near a VHFHSZ. In addition, developed areas or vacant lots subject to vegetation management activities provide a buffer between the Project site and VHFHSZs. Therefore, the Project would not result in impacts related to wildfires or exacerbate wildfire hazards. No impact would occur.

4.19.5 CUMULATIVE IMPACT ANALYSIS
The Project site is not within an SRA and is not within lands classified as a VHFHSZ. Therefore, no wildfire impacts would occur with implementation of the Project and the Project would not contribute to cumulative wildfire impacts.

4.19.6 SIGNIFICANCE OF IMPACTS BEFORE MITIGATION
Thresholds a, b, c, and d: No Impact. The Project site is not within or near an SRA or a VHFHSZ .

Therefore, the Project would not expose people or structures to wildfire hazards, impair emergency plans, or exacerbate the spread of wildfires. No impact would occur.

4.19.7 MITIGATION
No impact would occur, and mitigation is not required.
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5.0 OTHER CEQA CONSIDERATIONS

5.1 SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE AVOIDED IF THE PROJECT IS

IMPLEMENTED
The California Environmental Quality Act (CEQA ) Guidelines require that an environment impact report (EIR) disclose the significant environmental effects of a project which cannot be avoided if the proposed project is implemented (CEQA Guidelines Section 15126 [b]). As identified through the topical issues analysis provided in EIR Section 4.0, Environmental Analysis , the Town Center at Moreno Valley (TCMV) Specific Plan Project (Project) is anticipated to result in impacts to the environment that cannot be reduced to below a level of significance after the consideration of Project design features, compliance with applicable federal, State, and local regulations, and the application of the feasible mitigation measures identified in this EIR. The significant impacts that cannot be mitigated to a level below thresholds of significance consist of the following:
• Air Quality
o Air Quality Management Plan (AQMP) Conflict. The Project’s operational-source emissions are anticipated to exceed the regional thresholds of significance for volatile organic compounds (VOC ), nitrogen oxides (NO
X), and carbon monoxide (CO)
emissions. VOC and NO X are precursors for ozone (O 3); thus, Project operational activities could contribute a substantial volume of pollutants to the South Coast Air Basin (SoCAB) that could delay the attainment of federal and State ozone standards.

As such, the Project is conservatively considered to have the potential to conflict with the AQMP. Project impacts due to a conflict with the AQMP would be significant and unavoidable.
o Cumulatively Considerable Increase in Criteria Pollutant During Operation.

After the application of mandatory regulatory requirements and feasible mitigation measures, maximum daily emissions from Project operations would exceed the SCAQMD CEQA significance thresholds for NOx, VOC, and CO, and cannot be effectively reduced to a level below the SCAQMD thresholds of significance. Because NOx and VOC are O
3 precursors, this could also result in additional violations of the State and federal O3 standards. O3 is a nonattainment pollutant. There are no additional feasible mitigation measures beyond those identified in EIR Section 4.3, Air Quality, that would reduce the Project’s NOx, VOC, and CO emissions to a less than significant level. Therefore, the Project’s operational air quality impacts are significant and unavoidable, and the Project would result in a cumulatively considerable net increase in a criteria pollutant for which the Project region is in non-attainment, which is a significant and unavoidable impact.
• Greenhouse Gas Emissions. With implementation of the identified mitigation measures in EIR Section 4.8, Greenhouse Gas Emissions, the Project’s operational GHG emissions would be reduced but not to a level below the established significance threshold. Since the majority of the operational emissions are from vehicle trips and neither the Project Applicant nor the ■■
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City have regulatory authority to control vehicle -source emissions, no feasible mitigation measures beyond the measures identified exist that would reduce emissions to levels that are less than significant. Therefore, the Project would result in a significant and unavoidable GHG emissions impact.

5.2 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES WHICH WOULD BE CAUSED BY

THE PROJECT SHOULD IT BE IMPLEMENTED
Section 15126.2(d) of the CEQA Guidelines requires a discussion of any significant irreversible environmental changes that would be caused by a proposed project, and states:

Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible, since a large commitment of such resources makes removal or non- use thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.

Generally, a project would result in significant irreversible environmental changes if the following occurs:
• The primary and secondary impacts would generally commit future generations to similar uses; • The project would involve a large commitment of nonrenewable resources; • The project involves uses in which irreversible damage could result from any potential environmental accidents associated with the project; and • The proposed consumption of resources is not justified (e.g., the project involves the wasteful use of energy).

Determining whether the Project may result in significant irreversible effects requires a determination of whether key non-renewable resources would be degraded or destroyed in such a way that there would be little possibility of restoring them. The Projec t site is undeveloped. The Project site and surrounding area has historically been used for agricultural purposes ; however, agricultural activities at the Project site ceased in the late 1960’s. There are no non-renewable resources present at the Project site; therefore, conversion of the land from its current state to a mixed-use development with residential, commercial/civic, and park uses would have no direct effect on any such resources at the Project site.

Construction and long-term operation of the P roject would require the commitment and reduction of nonrenewable and/or slowly renewable resources, including petroleum fuels and natural gas (for vehicle emissions, construction, lighting, heating, and cooling of structures) as well as lumber, ■■
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sand/gravel, steel, copper, lead, and other metals (for use in building and roadway construction and utility infrastructure). Other resources that are slow to renew and/or recover from environmental stressors would also be impacted by Project implementation; these include air quality (through the combustion of fossil fuels and production of greenhouse gases) and water supply (through the increased potable water demands for drinking, cleaning, landscaping, and general maintenance needs). The Project is required by law to comply with federal, State, and local building requirements addressing energy conservation, and compliance with these requirements reduces a building operation’s energy volume that is produced by fossil fuels. A more detailed discussion of energy consumption is provided in EIR Section 4.6, Energy. The consumption of non-renewable resources to construct and operate the Project over the long-term would likely commit subsequent generations to the same use of the land and similar patterns of energy consumption. It is improbable that the site would revert to permanently undeveloped conditions due to the large capital investment that would al ready have been committed.

However, the Project is not expected to reduce the availability of any natural resources as a result of long-term operational activities.

The General Plan and Moreno Valley zoning ordinance anticipate development of the Project site.

Implementation of the Project would commit the Project site to a mixed-use development consisting of residential, commercial/civic , and park uses. These uses are compatible with the existing and planned uses that surround the Project site. Although the Project would result in unavoidable physical impacts related to air quality, these effects are significant due to their effect on the region, not their local impacts to receptors located near the Project site. The Project and its environmental effects would not compel or commit surrounding properties to land uses other than those that are existing today or those that are planned by the City’s General Plan and zoning ordinance. For this reason, the Project would not result in a significant, irreversible change to nearby, off-site properties.

EIR Section 4.9, Hazards and Hazardous Materials, provides an analysis of the Project’s potential to transport or handle hazardous materials which, if released into the environment, could result in irreversible damage to the environment. As concluded in the analysis, compliance with federal, State, and local regulations related to hazardous materials would be required of all contractors working at the Project site during the Project’s construction and of all occupants that occupy the Project’s buildings.

As such, construction and long-term operation of the Project would not cause significant irreversible damage to the environment that could result if hazardous materials were released from the site , including damage that may result from upset or accident conditions.

Lastly, an increased commitment of public services (e.g., police and fire protection) would also be required. However, as discussed in EIR Section 4.15, Public Services and Recreation , the Project would not require the construction of new or alteration of existing fire or police protection facilities to maintain an adequate level of service to the Project area, and no physical environmental impacts would result.

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5.3 GROWTH-INDUCING IMPACTS OF THE PROJECT
CEQA requires an EIR to include a discussion of ways in which the proposed project could induce growth. The CEQA Guidelines identify a project as growth- inducing if it fosters economic or population growth or if it encourages the construction of additional housing either directly or indirectly in the surrounding environment (CEQA Guidelines, Section 15126.2[e]). New residents and employees from the future residential and non-residential uses proposed by the Project represent direct forms of growth. These direct forms of growth have a secondary effect of expanding the size of local markets and inducing additional economic activity in the area , placing additional demands on public services and infrastructure systems, and in the generation of a variety of environmental impacts, which are addressed in EIR Section 4.1 through Section 4.19.

To address this issue, potential growth-inducing effects are examined through analysis of the following questions:

1. Would this project remove obstacles to growth (e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area or through changes in existing regulations pertaining to land development)?

2. Would this project result in the need to expand one or more public services to maintain desired levels of service?

3. Would this project encourage or facilitate economic effects that could result in other activities that could significantly affect the environment?

4. Would approval of this project involve some precedent-setting action that could encourage and facilitate other activities that could significantly affect the environment? A project could indirectly induce growth by reducing or removing barriers to growth or by creating a condition that attracts additional population or new economic activity. However, a project’s potential to induce growth does not automatically result in growth. Growth can only happen through capital investment in new economic opportunities by the private or public sectors. Under CEQA, growth inducement is not considered necessarily detrimental, beneficial, or of little significance to the environment. This issue is presented to provide additional information on ways in which the Project could contribute to significant changes in the environment beyond the direct consequences of implementing the Project examined in the preceding sections of this EIR.

1. Would this Project remove obstacles to growth (e.g., through the construction or extension of major infrastructure facilities that do not presently exist in the project area or through changes in existing regulations pertaining to land development)? Existing roadways would be extended into the Project site and new roadways built on site would serve the P roject but would not provide additional capacity to induce unplanned growth.

Additionally, the Project would not involve development that would establish an essential public service or utility/service system. The P roject site and surrounding areas are already served by essential public services , an extensive network of utility/service systems , and the ■■
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other infrastructure necessary to accommodate or allow the existing conditions and planned growth.

The existing utility/service systems in the roadways adjacent to the P roject site can serve the development allowed by the proposed TCMV Specific Plan with connections to these existing facilities. The utility infrastructure installed as part of the P roject would be sized and located expressly to serve the on-site uses and, therefore, would not induce growth in the P roject vicinity. Further, future development would be reviewed on a project -by-project basis at the time of proposed construction in order to d etermine the utility/service systems necessary to serve the proposed land uses.

Consistent with the provisions of the Moreno Valley Municipal Code (M VMC), the Project Applicant is proposing a Specific Plan to establish the zoning, development, and design standards for implementing projects within the Project site. The Project would not change existing regulations pertaining to land development and is, therefore, not considered to be growth-inducing with respect to removal of obstacles to growth.

2. Would this Project result in the need to expand one or more public services to maintain desired levels of service? As discussed in EIR Section 4.15, Public Services and Recreation, the Project would increase the demand for public services (police, fire, schools, libraries, and parks and recreational facilities). The Project would create the typical range of service calls for police and fire services that occur with residential, commercial/civic, and park uses . The Project would not necessitate the construction of new or the expansion of existing public service facilities in order to maintain desired levels of service; however, a substation could be accommodated within the commercial area, if required by the City. This facility, should it be implemented, would be available not only to future residents and employees of the Project, but other residents and employees in the City. With respect to parks, the proposed TCMV Specific Plan includes approximately 4.8 acres of public open space area, including an approximately

3.5-acre area to be centrally located within the Project site and an approximately 1.3-acre linear park. Additionally, funding mechanisms are in place through existing regulations and standard practices to accommodate growth in the City, including the P roject. This Project would not, therefore, have significant growth-inducing consequences with respect to public services.

3. Would this P roject encourage or facilitate economic effects that could result in other activities that could significantly affect the environment? During Project construction, a number of design, engineering, and construction-related jobs would be created. This would last until Project construction is completed. This would be an indirect, growth-inducing effect of the Project.

As further described in EIR Section 3.0, Project Description, for purposes of analysis in this EIR it is anticipated the proposed TCMV Specific Plan would result in the development of up to 800 residential units and approximately 230,000 square feet of non-residential uses. It is estimated that this development could generate up to 3,080 new residents and approximately 421 new employment opportunities. As discussed in EIR Section 4.14, Population and ■■
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Housing, the Project would not exceed the growth projections for the City or the region.

Further, it is expected that the short-term construction jobs and new positions during operation would be filled by workers who already reside in the local area or region.

As development occurs on site, Project residents and employees would seek shopping, entertainment, employment, home improvement, auto maintenance, and other economic opportunities in the surrounding area. In addition to the proposed non-residential uses, the Project is located near and within walking distance of existing employment and retail areas in the City, which would help serve the employment and shopping needs of the future residents.

However, the increased demand for such economic goods and services could encourage the creation of new businesses and/or the expansion of existing businesses that address these economic needs. This growth may be experienced in the areas in proximity to the P roject site that are either currently undeveloped or underutilized. However, this type of growth is already anticipated in the City’s General Plan, and as identified on Figure 4.0-1, Cumulative Projects Location Map, is already being proposed. Therefore, implementation of residential and non- residential uses allowed by the proposed TCMV Specific Plan would support existing uses in the area, and could encourage or facilitate the growth envisioned in the General Plan.

4. Would this Project involve some precedent -setting action that could encourage and facilitate other activities that could significantly affect the environment? As identified above, there are no proposed changes to the type of uses allowed by the General Plan and zoning ordinance as residential, commercial, and park uses are allowed and common uses in the City . Further, no changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, fire codes) are proposed or required to implement this Project. As identified in EIR Section 4.1 through Section 4.19, the Project would be implemented in accordance with applicable regulations and Project-specific mitigation measures, which would ensure there are no conflicts with adopted land development regulations, and environmental impacts are minimized. The Project does not propose any precedent-setting actions that, if approved, would specifically allow or encourage other projects and resultant growth to occur. Furthermore, the Project is not extending any infrastructure or facilitating further development. Accordingly, the Project’s potential influence on other nearby properties to redevelop at greater intensities and/or different uses than the City’s General Plan and zoning ordinance allow is speculative. CEQA does not require the analysis of speculative effects (CEQA Guidelines Section 15145). If any other property owner were to propose development or redevelopment of a property in the Project vicinity or in any part of the City, that project would require evaluation under CEQA based on its own merits, including an analysis of direct and cumulatively considerable effects.

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5.4 EFFECTS FOUND NOT TO BE SIGNIFICANT DURING THE EIR SCOPING PROCESS CEQA Guidelines Section 15128 requires that an EIR “…contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR.” As discussed in EIR Section 1.0, Introduction, and as identified in the Notice of Preparation for this EIR included in EIR Technical Appendix A, the City determined that each of the 20 topical issues identified in Appendix G of the CEQA Guidelines should be evaluated in the Draft EIR. There were no issues for which the City found that impacts would be less than significant and no further analysis in the Draft EIR was warranted.

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6.0 ALTERNATIVES
Pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15126.6(a):

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives . An EIR need not consider every conceivable alternative to a project . Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible . The lead agency is responsible for selection of a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives . There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

As discussed in EIR Section 4.1 through Section 4.19, the Project would result in significant adverse environmental effects under two environmental issue areas (Air Quality and Greenhouse Gas [GHG] emissions) that cannot be mitigated to below a level of significance after the implementation of Project design features, mandatory regulatory requirements, and feasible mitigation measures . The unavoidable significant impacts are:
• Air Quality (Air Quality Management Plan Conflict). While the 2006 General Plan designates the Project site for Public Facilities land uses, the South Coast Air Quality Management District (SCAQMD) 2022 Air Quality Management Plan (AQMP) was adopted subsequent to the prior adoption of the City of Moreno Valley General Plan 2040 General Plan (referred to herein as the “2040 General Plan”) by the City of Moreno Valley (City) and, therefore, includes the City’s growth projections associated with the 2040 General Plan. As such, the Project would not result in the exceedance of assumptions within the AQMP.

However, the Project would emit volatile organic compounds (VOCs) and nitrogen oxides (NO
X), which are ozone (O3) precursors, in exceedance of the SCAQMD regional significance thresholds, resulting in a significant impact even with the identified mitigation measures in EIR Section 4.3, Air Quality. This could contribute to a delay in the attainment of federal and State O3 standards in the South Coast Air Basin (SoCAB ). Additionally, the Project would emit carbon monoxide (CO) in exceedance of the SCAQMD regional significance thresholds . As such, the Project is conservatively considered to have the potential to conflict with the SCAQMD 2022 AQMP. Project impacts due to a conflict with the S CAQMD 2022 AQMP would be significant and unavoidable on both a direct and cumulative basis. • Air Quality (Criteria Pollutant Emissions). With implementation of the identified mitigation measures in EIR Section 4.3, Air Quality, the Project’s operational-related VOC, NOX, and CO emissions would be reduced, but not to a level below SCAQMD’s regional thresholds for these criteria pollutants. Since the majority of the operational emissions are from vehicle trips and ■■
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neither the Project Applicant nor the City have regulatory authority to control tailpipe emissions, no feasible mitigation measures beyond the measures identified exist that would reduce emissions to levels that are less than significant. Therefore, the Project would result in a significant and unavoidable cumulatively considerable net increase of a criteria pollutant for which the Project region is nonattainment under an applicable federal or State ambient air quality standard.
• GHG Emissions. With implementation of the identified mitigation measures in EIR Section

4.8, Greenhouse Gas Emissions, the Project’s operational GHG emissions would be reduced but not to a level below the established significance threshold. Since the majority of the operational emissions are from vehicle trips and neither the Project Applicant nor the City have regulatory authority to control vehicle-source emissions, no feasible mitigation measures beyond the measures identified exist that would reduce emi ssions to levels that are less than significant. Therefore, the Project would result in a significant and unavoidable GHG emissions impact.

6.1 ALTERNATIVES UNDER CONSIDERATION
In compliance with CEQA Guidelines Section 15126.6(a), an EIR must describe “a range of reasonable alternatives to the project, or to the location of the project which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.” The EIR need not consider every conceivable alternative; rather it must consider a reasonable range of potentially feasible alternatives to the project, or to the location of the project, which would avoid or substantially lessen significant effects of the project, even if “these alternatives would impede to some degree the attainment of the project objectives, or would be more costly” (CEQA Guidelines Section 15126.6[b]).

CEQA Guidelines Section 15126.6(e) requires that an EIR include an alternative that describes what would reasonably be expected to occur on the Project site in the foreseeable future if the Project were not approved, based on current plans and consistent with available infrastructure and community services (i.e., “No Project” Alternative). For projects that include a revision to an existing land use plan, the No Project Alternative may be the continuation of the existing land use plan into the future .

For projects other than a land use plan (for example, a development project on an identifiable property), the No Project Alternative is considered to be a circumstance under which the project does not proceed (CEQA Guidelines Section 15126[e][3][A-B]). This EIR includes analysis of both No Project alternative approaches.

The development alternatives evaluated in this section focus on reduced development scenarios that would reduce air pollutants and GHG emissions.

The following alternatives are analyzed in this section. ■■
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6.1.1 NO PROJECT/DEVELOPMENT PURSUANT TO THE EXISTING GENERAL PLAN AND ZONING ALTERNATIVE The existing (2006) General Plan land use designation for the Project site is Public Facilities and the existing zoning district is Public (P) District. The Project requires a General Plan Amendment and zone change to allow for implementation of the residential, commercial, civic, and open space uses proposed to be allowed by the Town Center at Moreno Valley (TCMV) Specific Plan, which would serve as the regulatory document governing the orderly growth and development of the Project site and Tentative Tract Map No. 38421. Therefore , this E IR addresses the “No Project/Development Pursuant to the Existing General Plan and Zoning” Alternative, which represents the No Project alternative under which the Project does not proceed and the Project site is developed pursuant to the existing 2006 General Plan and existing zoning designations, which anticipate the development of public facilities.

6.1.2 NO PROJECT/NO DEVELOPMENT ALTERNATIVE
The “No Project/No Development” Alternative considers no development on the Project site . Under this Alternative, the approximately 69.6 gross acre Project site would remain undeveloped and would be subject to routine maintenance (i.e., discing) for weed abatement . This Alternative was used to compare the environmental effects of the Project with an alternative that would leave the Project site in its existing state.

6.1.3 REDUCED DEVELOPMENT – LESS RESIDENTIAL ALTERNATIVE The “Reduced Development – Less Residential ” Alternative considers a development scenario consistent with the proposed TCMV Specific Plan where the Project site would be developed with fewer residential units as compared to the Project evaluated in this EIR, but the same amount of commercial/civic and open space (park) uses would be developed. In summary, under this Alternative, the Project site would be developed with 300 residential dwelling units (compared to 800 residential units anticipated for the Project in this EIR); 229,459 square feet (sf) of non-residential uses, consistent with the non-residential development square footage anticipated for the Project in this EIR ; and 4. 9 acres of open space, consistent with the Project.

6.1.4 REDUCED DEVELOPMENT – LESS COMMERCIAL ALTERNATIVE The “Reduced Development – Less Commercial” Alternative considers a development scenario where the Project site would be developed with the same number of residential units and the same amount of open space (park) uses as assumed for the Project in this EIR , but a reduced amount of commercial/civic uses. In summary, under this Alternative the Project site would be developed with 800 residential dwelling units , consistent with residential develop ment anticipated for the Project in this EIR; 150,000 sf of non-residential uses (compared to 229,459 sf of non-residential development square footage anticipated for the Project in this EIR); and 4.9 acres of open space, consistent with the Project.

6.1.5 REDUCED DEVELOPMENT – LESS RESIDENTIAL AND LESS COMMERCIAL ALTERNATIVE The “Reduced Development – Less Residential and Less Commercial ” Alternative considers a development scenario where the Project site would be developed with fewer residential units, less ■■
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commercial/civic uses, and the same amount of open space (park) uses. In summary, under this Alternative, the Project site would be developed with 700 residential dwelling units (compared to 800 residential units anticipated for the Project in this EIR); 175,000 sf of non-residential uses (compared to 229,459 sf of non-residential development square footage anticipated for the Project in this EIR) ; and 4.9 acres of open space, consistent with the Project.

6.2 ALTERNATIVES CONSIDERED AND REJECTED
An EIR is required to identify any alternatives that were considered by the Lead Agency but were rejected as infeasible. Among the factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in the EIR are: a) failure to meet most of the basic project objectives, b) infeasibility, or c) inability to avoid significant environmental impacts. With respect to the feasibility of potential alternatives to the Project, CEQA Guidelines Section 15126.6(f)(1) notes:

Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries…and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site…

In determining an appropriate range of alternatives to be evaluated in this EIR, a number of possible alternatives were initially considered and, for a variety of reasons, rejected. Alternatives were rejected because either: 1) they could not accomplish the basic objectives of the Project, 2) they would not have resulted in a reduction of significant adverse environmental impacts, or 3) they were considered infeasible to construct or operate. The alternatives that were considered but rejected are described below.

6.2.1 ALTERNATIVE SITE WITHIN THE CITY-PROPOSED DOWNTOWN CENTER (DC) DISTRICT CEQA does not require that an analysis of alternative sites be included in an EIR. However, if the surrounding circumstances make it reasonable to consider an alternative site, then an alternative site analysis should be considered and analyzed in the EIR. In making the decision to include or exclude an analysis of an alternative site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR” (CEQA Guidelines Section 15126.6[f][2]).

To meet key Project objectives, the a lternative site must be located within an area within the City - proposed Downtown Center (DC) District area, which is generally located south of Cottonwood Avenue, east of Lasselle Street, west of Oliver Street, and north of Iris Avenue. The City envisions this area, which is located around the prominent cross -roads of Nason Street and Alessandro Boulevard and encompasses approximately 1,200 acres near the center of the City, as a mixed-use “Downtown ■■
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Center” district to serve as a focal point of the community and destination for people from around the region. The proposed TCMV Specific Plan has been developed in consideration of the City’s vision for this area as set forth in the proposed 2040 General Plan that the City is in the process of readopting.

Based on review of aerial photography, the City-proposed Downtown Center (DC) District includes vacant land and some sites that are currently developed. There are a limited number of vacant properties in this area that are large enough to support the Project that are not already planned for development (e.g., the Aquabella Specific Plan and individual development projects) or that would have fewer developmental and environmental constraints than the Project site evaluated in this EIR. It is not anticipated that a currently developed site would be redeveloped to accommodate the Project.

Additionally, if removal of existing uses was required to implement the Project at an alternative site, construction-related impacts (including air quality emissions) would be greater than the Project since the Project site is currently undeveloped.

As identified in the analysis presented in EIR Section 4.1 through Section 4.19, with adherence to regulatory requirements and incorporation of Project -level mitigation measures, the Project would result in less than significant impacts or less than significant impacts with mitigation for construction- related, operational, and cumulative impacts related to aesthetics, agricultural and forestry resources, biological resources, cultural resources, energy, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, noise, population and housing, public services, recreation, transportation, tribal cultural resources, and utilities and services systems , as well as construction- related air quality impacts . Under this Alternative, impacts associated with these topics would be similar to the Project, depending on the characteristics of that alternative site, because development of the Project at an alternative site would have a similar physical impact area, type of uses, and project size and would be subject to the same regulatory requirements and mitigation measures.

With respect to the Project’s significant and unavoidable operational air quality impacts and GHG emissions impacts , development of the Project at an alternative site within the City -proposed Downtown Center (DC) District would likely result in similar impacts as would occur with implementation of the Project at its proposed location because the Project’s significant operational air quality impacts and GHG emissions impacts are primarily related to motor vehicles traveling to/from the Project site and not related to the presence of sensitive resources on the Project site or its location near sensitive receptors. Vehicle -related impacts are a direct reflection of the Project’s expected operational characteristics as a residential, commercial/civic, and open space (park) mixed -use development, regardless of the property where the Project is located. Development on another site would not avoid the Project’s significant and unavoidable operational air quality and GHG emissions impacts.

Additionally, the Project Applicant does not own any other land in the City -proposed Downtown Center (DC) District area. CEQA does not require the consideration of sites not owned by the landowner or which could not be reasonably acquired by the landowner as alternatives to the proposed project (CEQA Guidelines Section 15126.6[f][1]).
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In summary, development of the Project or similar development that implements the proposed TCMV Specific Plan on an alternative site in the City-proposed Downtown Center (DC) District would likely meet the Project objectives but would not substantially reduce or avoid significant unavoidable impacts related to operational air quality and GHG emissions that would result from the Project. Additionally, an alternative site is not feasible. Therefore, further analysis of an alternative site or sites in this EIR is not required.

6.2.2 REDUCED DEVELOPMENT AREA ALTERNATIVE
The approximately 69.6 gross acre Project site is currently undeveloped and is subject to periodic ground disturbances related to weed abatement activities and other routine, on-site maintenance activities. As described in EIR Section 2.0 and Section 4.1 through Section 4.19, there are no conditions at the Project site (e.g., sensitive biological resources, cultural resources, etc.) or potential construction- related impacts that warrant preservation of areas on site or consideration of a reduced development area. Further, a “Reduced Development Area” Alternative would delay, but not eliminate, the ultimate development of the entirety of the Project site pursuant to the current 2006 General Plan and the City’s proposed 2040 General Plan, which anticipate the development of the Project site.

6.3 ALTERNATIVE ANALYSIS
This section compares the environmental impacts expected from each alternative considered by the City relative to the environmental impacts of the Project. A conclusion is provided for each topic as to whether the alternative results in one of the following: (1) reduction or avoidance of the Project’s impact, (2) a greater impact than would occur under the Project, (3) the same impact as the Project, or (4) a new impact in addition to the Project’s impacts . Table 6 -4, Alternatives to the Project – Comparison of Environmental Impacts , and Table 6-5, Alternatives to the Project – Comparison of Project Objectives, at the end of this section compare the impacts of the alternatives against the impacts of the Project and identif y the ability of the alternative to meet the objectives of the Project . As previously listed in EIR Section 3.0, the Project’s objectives are:

1. Establish the zoning criteria to guide the orderly development of the Project site with a mixed- use neighborhood composed of residential, open space, and commercial uses.

2. Maximize housing opportunities to further achievement of local housing goals and provide a variety of housing types to meet the needs of various market segments and lifestyle considerations.

3. Create local employment opportunities.

4. Expand economic development in the City by establishing new commercial/civic uses on vacant land in a developing area.

5. Decrease automobile dependency by locating new housing, parks, and commercial/civic uses within walking distance of other business, entertainment, residential, cultural, and civic uses. ■■
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6. Provide a diverse combination of new shopping and dining opportunities for City residents and visitors.

7. Develop an attractive and active community centerpiece for the City.

6.3.1 NO PROJECT/DEVELOPMENT PURSUANT TO THE EXISTING GENERAL PLAN AND ZONING ALTERNATIVE Under the City’s current 2006 General Plan, t he Project site has a land use designation of Public Facilities. The primary purpose of areas designated Public Facilities is to provide property for civic, cultural, and public utility uses including, but not limited to, schools, libraries, fire stations, museums, and government offices. The existing zoning for the Project site is Public (P) District ; the primary purpose of this district is to provide for the conduct of public and institutional activities, including providing protected designated areas for public and institutional facilities. There are various types of allowed uses under the current General Plan land use and zoning designations , and it would be speculative to identify a development scenario that anticipates development of the entire Project site with such uses. Further, as discussed in EIR Section 3.1, Project Background, the City vision for this area as outlined in the Nason Street Corridor Plan (October 2015), the 2016 City of Moreno Valley Strategic Plan, and the Nason Street Corridor Phase II Study Area Plan (May 2019) is for development of a multi-use town center consisting of residential, commercial, office, and civic uses. In addition, the City is in the process of readopting the 2040 General Plan, which would include the Project site within the proposed mixed-use Downtown Center (DC) District to serve as a focal point of the community and destination for people from around the region. Consistent with this vision, the City is in the process of selling the Project site to the Project Applicant for the purpose of developing a mixed-use town center and it is reasonable to anticipate that the Project site would not be developed solely with public facilities. Notwithstanding, it is anticipated that development of the site with public facilities pursuant to the current 2006 General Plan land use designation would reduce the daily trip generation and associated air pollutant and GHG emissions as compared to the Project. However, development of public facilities at the Project site would not meet the Project objectives.

The Project includes a site-specific development proposal as presented in the proposed TCMV Specific Plan, which would serve as the regulatory document governing the orderly growth and development of the Project site and Tentative Tract Map No. 38421. The Project is consistent with the land uses allowed by the proposed 2040 General Plan and associated zoning currently in the process of readoption by the City (Downtown Center [DC] District). The development alternatives evaluated in this section focus on reduced development scenarios that would reduce air pollutant and GHG emissions. As with the Project, each development alternative is consistent with the land uses anticipated by the City’s proposed 2040 General Plan and zoning designations for the Project site and would implement the proposed TCMV Specific Plan.

6.3.2 NO PROJECT/NO DEVELOPMENT ALTERNATIVE
The No Project/No Development Alternative allows decision-makers to compare the environmental impacts of approving the Project to the environmental impacts that would occur if the property were left in its existing conditions for the foreseeable future . Under existing conditions, the Project site is ■■
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undeveloped. Refer to the general description of the Project site’s existing physical conditions provided in EIR Section 2.0, Environmental Setting, and more detailed environmental setting information provided for each topical issue in EIR Section 4.1 through Section 4.19.

A. Aesthetics
The Project site does not contain any unique aesthetic resources, nor does it serve as a prominent scenic vista. In addition, t here are no designated or eligible State scenic highways within the immediate vicinity of the Project site. Under the No Project/No Development Alternative, the visual character and quality of the Project site would be maintained in its existing condition. No new structures, landscaping, or lighting would be introduced on the Project site . The No Project/No Development Alternative would not conflict with plans or regulations addressing scenic quality and would not create a new source of substantial light or glare that would impact nighttime views in the area . There would be no aesthetic impact associated with leaving the Project site in its existing condition. Therefore, the No Project/No Development Alternative would avoid the Project’s less than significant aesthetic impact.

B. Agricultur e and Forestry Resources
The No Project/No Development Alternative would leave the Project site in its existing condition, which includes periodic ground disturbances related to weed abatement activities and other routine, on-site maintenance activities. Under existing conditions, the Project site contains Farmland of Local Importance, but does not contain Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or forestry resources. Therefore, th e No Project/No Development Alternative would not impact Farmland of Local Importance, but the Project’s impact is less than significant. Under both the No Project/No Development Alternative and the Project, impacts to forestry resources would not occur.

C. Air Quality
The No Project/No Development Alternative would leave the Project site in its existing undeveloped condition and would not generate any air quality emissions, nor would it include any land uses with the potential for exposing sensitive receptors to substantial pollutant concentrations . Furthermore, because no new development would occur on site, the No Project/No Development Alternative would avoid the Project’s less than significant impact due to other emissions (such as those leading to odors) that could affect a substantial number of people . Thus, the No Project/No Development Alternative would avoid the Project’s significant and unavoidable impacts related to conflict with the AQMP and operational VOC, NO
X, and CO emissions, and the Project’s less than significant construction-related air quality impacts.

D. Biological Resources
The No Project/No Development Alternative would leave the Project site in its existing condition, which includes periodic ground disturbances related to weed abatement activities and other routine, on-site maintenance activities . No grading would occur under the No Project/No Development ■■
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Alternative and there would be no potential impacts to special status plants or animals with the potential to occur at the Project site. Although there are mitigation measures identified in EIR Section 4.4, Biological Resources, that would reduce the Project’s potential impacts to biological resources to below a level of significance, implementation of the No Project/ No Development Alternative would avoid impacts to biological resources associated with the Project and would require no mitigation.

E. Cultural Resources
The No Project/No Development Alternative would leave the Project site in its existing condition, which includes periodic ground disturbances related to weed abatement activities and other routine, on-site maintenance activities. No grading or other construction activities would occur under the No Project/No Development Alternative and there would be no potential impacts to subsurface archaeological resources or human remains that may exist. Although there are mitigation measures identified in EIR Section 4.5, Cultural Resources, that would reduce the Project’s potential impacts to cultural resources and human remains to below a level of significance, implementation of the No Project/No Development Alternative would avoid impacts to cultural resources associated with the Project and would require no mitigation.

F. Energy
The No Project/No Development Alternative would leave the Project site in its existing undeveloped condition and would not demand any energy beyond the de minimis amount needed for weed abatement and routine maintenance activities . In the absence of construction activities and operation of the proposed uses, the No Project/No Development Alternative would require no new demand for near-term or long-term energy or fuel use on the site. This Alternative would avoid the Project’s near- and long-term energy use and would avoid the Project’s less than significant impacts.

G. Geology and Soils
The No Project/No Development Alternative would leave the Project site in its existing condition, which would include periodic ground disturbances related to weed abatement activities and other routine, on-site maintenance activities. These activities have the potential to result in water and/or wind erosion of exposed soils that would not occur with the Project . The Project site would remain undeveloped under the No Project/No Development Alternative . Accordingly, there would be no potential for this Alternative to expose people or structures to safety risks associated with geologic hazards or result in significant adverse impacts to paleontological resources. This Alternative would avoid the Project’s less than significant impacts related to geology and soils but would have greater impacts associated with potential for erosion.

H. Greenhouse Gas Emissions
Under the No Project/No Development Alternative, no development would occur on the Project site .

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Moreno Valley City CouncilJune 3, 2025

Moreno Valley City Council
June 3, 2025