Moreno Valley City Council
February 17, 2026

A project location map is provided in Exhibit A.

1.2 Project Description
The proposed project consists of constructing thirty-seven (37) single-family detached homes with a density of 7.90 dwelling units per acre. Access to the project is proposed via two (2) unsignalized driveways located along Bradshaw Circle.

Construction activities are expected to consist of site preparation, grading, building construction, paving, and architectural coating. No demolition is expected to be required during construction.

The project will require the export of approximately 8,000 cubic yards of earthwork material for grading purposes.

The site plan used for this analysis, provided by RC HOBBS COMPANY, INC., is illustrated in Exhibit B. Table 1 summarizes the land use assumptions used for this analysis. r:,-n engine~ring
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Table 1
Project Land Use Summary
Project Land Use CalEEMod Land Use Category Quantity Metric1 Single-Family Housing Single Family Housing 37 DU
On-Site Paved Surfaces Parking Lot 58.8 TSF
1 DU = Dwelling Unit
TSF = Thousand Square Feet

1.3 Sensitive Receptors
Sensitive receptors are considered land uses or other types of population groups that are more sensitive to air pollution exposure. Sensitive population groups include children, the elderly, the acutely and chronically ill, and those with cardio-respiratory diseases.

For CEQA purposes, the SCAQMD considers a sensitive receptor to be a location where a sensitive individual could remain for 24 hours or longer, such as residences, hospitals, and schools (etc), as described in the Localized Significance Threshold Methodology (SCAQMD 2008a, page 3-2). There are several sensitive land uses adjacent to the project site, including the following:

Northern Receptors Existing residential land uses located along the northern boundary of the project site, approximately 663 feet north of the centerline of Cactus Avenue.

Eastern Receptors Existing residential land uses located approximately 661 feet (~202 meters) east of the project site’s eastern boundary, approximately 54 feet north of the centerline of Cactus Avenue.

Southern Receptors Existing residential land uses located approximately 90 feet (~27 meters) south of the project site’s southern boundary, approximately 58 feet south of the centerline of Cactus Avenue.

Western Receptors Existing residential land uses located approximately 50 feet (~16 meters) west of the project site’s western boundary, approximately 44 feet north of the centerline of Cactus Avenue.

For the purposes of this analysis, sensitive receptors are conservatively assumed to be less than 25 meters from the project site. A project site location map, including sensitive receptor locations, is provided in Exhibit A.
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1.4 Summary of Analysis Results
Table 2 provides a summary of the CEQA air quality impact analysis results.

Table 2
CEQA Air Quality Impact Criteria
Air Quality Impact Criteria Potentially
Significant
Potentially
Significant
Unless
Mitigated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with, or obstruct implementation of, the
applicable air quality plan? X
c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
in non-attainment under an applicable Federal or
State ambient air quality standard?
X
d) Expose sensitive receptors to substantial pollutant
concentrations? X
e)
Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
X
Table 3 provides a summary of the CEQA GHG impact criteria analysis results. r:,-n engine~ring
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Table 3
CEQA GHG Impact Criteria
GHG Impact Criteria Potentially
Significant
Potentially
Significant
Unless
Mitigated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on
the environment?
X
b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing emissions of
greenhouse gases?
X
Table 4 provides a summary of the CEQA energy impact criteria analysis results.

Table 4
CEQA Energy Impact Criteria
Energy Impact Criteria Potentially
Significant
Potentially
Significant
Unless
Mitigated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy?
X
b) Conflict with or obstruct a State and/or local plan for renewable energy or energy efficiency? X

1.5 Project Design Features (DF)
The following design features include several standard rules and requirements, best practices and building code requirements for reducing air quality and GHG emissions. Design features are assumed to be integrated into the project design and required as part of the conditions of approval of the project. Design features are not considered to be mitigation under CEQA. r:,-n engine~ring
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Construction Design Features:

DF-1 The project will follow the SCAQMD rules and requirements for fugitive dust control, which includes, but are not limited to the following:

1. All active construction areas shall be watered two (2) times daily.

2. Speed on unpaved roads shall be reduced to less than 15 mph.

3. Any visible dirt deposition on any public roadway shall be swept or washed at the site access points within 30 minutes.

4. Any on-site stockpiles of debris, dirt or other dusty material shall be covered or watered twice daily.

5. All operations on any unpaved surface shall be suspended if winds exceed 15 mph.

6. Access points shall be washed or swept daily.

7. Construction sites shall be sandbagged for erosion control.

8. Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more).

9. Cover all trucks hauling dirt, sand, soil, or other loose materials, and maintain at least 2 feet of freeboard space in accordance with the requirements of California Vehicle Code (CVC) section 23114.

10. Pave or gravel construction access roads at least 100 feet onto the site from the main road and use gravel aprons at truck exits.

11. Replace the ground cover of disturbed areas as quickly possible.

DF-2 Construction equipment shall be maintained in proper tune.

DF-3 All construction vehicles shall be prohibited from excessive idling. Excessive idling is defined as five (5) minutes or longer.

DF-4 Establish staging areas for the construction equipment that are as distant as possible from adjacent residential homes.

Operational Design Features:

DF-5 The project will comply with the mandatory requirements of the California Building Standards Code, Title 24, Part 6 (Energy Code) and Part 11 (CALGreen), including, but not limited to:
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• Install low flow fixtures and toilets, water efficient irrigation systems, drought tolerant/native landscaping, on-site storm water capture, and reduce the amount of turf.
• Provide the necessary infrastructure to support electric vehicle charging. • Provide solar installations per the prescribed Energy Design Ratings.

DF-6 Participate in the local waste management recycling and composting programs. r:,-n enuine~ring L.U,,,U group, me.
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2.0 Air Quality Setting
The Federal Clean Air Act (§ 7602) defines air pollution as any agent or combination of such agents, including any physical, chemical, biological, or radioactive substance which is emitted into or otherwise enters the ambient air. Household combustion devices, motor vehicles, industrial facilities and forest fires are common sources of air pollution. Air pollution can cause disease, allergies and death. It affects soil, water, crops, vegetation, manmade materials, animals, wildlife, weather, visibility, and climate. It can also cause damage to and deterioration of property, present hazards to transportation, and negatively impact the economy.

This section provides background information on criteria air pollutants, the applicable federal, state and local regulations concerning air pollution, and the existing physical setting of the project within the context of local air quality.

2.1 Description of Air Pollutants
The following section describes the air pollutants of concern related to the project. Criteria air pollutants are defined as those pollutants for which the federal and state governments have established air quality standards for outdoor or ambient concentrations to protect public health.

The following descriptions of criteria air pollutants have been provided by the SCAQMD. • Carbon Monoxide (CO) is a colorless, odorless, toxic gas produced by incomplete combustion of carbon-containing fuels (e.g., gasoline, diesel fuel, and biomass). Sources include motor vehicle exhaust, industrial processes (metals processing and chemical manufacturing), residential wood burning, and natural sources. CO is somewhat soluble in water; therefore, rainfall and fog can suppress CO conditions. CO enters the body through the lungs, dissolves in the blood, and competes with oxygen, often replacing it in the blood, thus reducing the blood's ability to transport oxygen to vital organs in the body. The ambient air quality standard for carbon monoxide is intended to protect persons whose medical condition already compromises their circulatory system's ability to deliver oxygen. These medical conditions include certain heart ailments, chronic lung diseases, and anemia. Persons with these conditions have reduced exercise capacity even when exposed to relatively low levels of CO. Fetuses are at risk because their blood has an even greater affinity to bind with CO. Smokers are also at risk from ambient CO levels because smoking increases the background level of CO in their blood. The South Coast basin has recently achieved attainment status for carbon monoxide by both USEPA and CARB.

• Nitrogen Dioxide (NO2) is a byproduct of fuel combustion. The principal form of nitrogen oxide produced by combustion is nitric oxide (NO), but NO reacts quickly to form NO2, creating the mixture of NO and NO2 commonly called NOx. NO2 acts as an acute irritant and, r:,-n engine~ring
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in equal concentrations, is more injurious than NO. At atmospheric concentrations, however, NO2 is only potentially irritating. There is some indication of a relationship between NO2 and chronic pulmonary fibrosis. Some increase in bronchitis in young children has also been observed at concentrations below 0.3 parts per million (ppm). NO2 absorbs blue light which results in a brownish red cast to the atmosphere and reduced visibility. Although NO2 concentrations have not exceeded national standards since 1991 and the state hourly standard since 1993, NOx emissions remain of concern because of their contribution to the formation of O3 and particulate matter.

• Ozone (O3) is one of a number of substances called photochemical oxidants that are formed when volatile organic compounds (VOC) and NOx react in the presence of ultraviolet sunlight. O3 concentrations in the South Coast basin are typically among the highest in the nation, and the damaging effects of photochemical smog, which is a popular name for a number of oxidants in combination, are generally related to the concentrations of O3.

Individuals exercising outdoors, children, and people with preexisting lung disease, such as asthma and chronic pulmonary lung disease, are considered to be the subgroups most susceptible to O3 effects. Short-term exposures (lasting for a few hours) to O3 at levels typically observed in southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes. In recent years, a correlation between elevated ambient O3 levels and increases in daily hospital admission rates, as well as mortality, has also been reported. The South Coast Air Basin is designated by the USEPA as an extreme nonattainment area for ozone. Although O3 concentrations have declined substantially since the early 1990s, the South Coast basin continues to have peak O3 levels that exceed both state and federal standards.
• Fine Particulate Matter (PM10) consists of extremely small suspended particles or droplets 10 microns or smaller in diameter that can lodge in the lungs, contributing to respiratory problems. PM10 arises from such sources as re-entrained road dust, diesel soot, combustion products, tire and brake abrasion, construction operations, and fires. It is also formed in the atmosphere from NOx and SO2 reactions with ammonia. PM10 scatters light and significantly reduces visibility. Inhalable particulates pose a serious health hazard, alone or in combination with other pollutants. More than half of the smallest particles inhaled will be deposited in the lungs and can cause permanent lung damage. Inhalable particulates can also have a damaging effect on health by interfering with the body’s mechanism for clearing the respiratory tract or by acting as a carrier of an absorbed toxic substance. The South Coast basin has recently achieved federal attainment status for PM10, but is non-attainment based on state requirements.
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• Ultra-Fine Particulate Matter (PM2.5) is defined as particulate matter with a diameter less than 2.5 microns and is a subset of PM10. PM2.5 consists mostly of products from the reaction of NOx and SO2 with ammonia, secondary organics, finer dust particles, and the combustion of fuels, including diesel soot. PM2.5 can cause exacerbation of symptoms in sensitive patients with respiratory or cardiovascular disease, declines in pulmonary function growth in children, and increased risk of premature death from heart or lung diseases in the elderly. Daily fluctuations in PM2.5 levels have been related to hospital admissions for acute respiratory conditions, school absences, and increased medication use in children and adults with asthma. The South Coast basin is designated as non-attainment for PM2.5 by both federal and state standards.
• Sulfur dioxide (SO2) is a colorless, pungent gas formed primarily by the combustion of sulfur-containing fossil fuels. Health effects include acute respiratory symptoms and difficulty in breathing for children. Individuals with asthma may experience constriction of airways with exposure to SO2. Though SO2 concentrations have been reduced to levels well below state and federal standards, further reductions in SO2 emissions are needed because SO2 is a precursor to sulfate and PM10. The South Coast basin is considered a SO2 attainment area by USEPA and CARB.
• Lead (Pb) is a toxic heavy metal that can be emitted into the air through some industrial processes, burning of leaded gasoline and past use of lead-based consumer products. Lead is a neurotoxin that accumulates in soft tissues and bones, damages the nervous system, and causes blood disorders. It is particularly problematic in children, in that permanent brain damage may result, even if blood levels are promptly normalized with treatment.

Concentrations of lead once exceeded the state and federal air quality standards by a wide margin, but as a result of the removal of lead from motor vehicle gasoline, ambient air quality standards for lead have not been exceeded since 1982. Though special monitoring sites immediately downwind of lead sources recorded localized violations of the state standard in 1994, no violations have been recorded since. Consequently, the South Coast basin is designated as an attainment area for lead by both the USEPA and CARB. This report does not analyze lead emissions from the project, as it is not expected to emit lead in any significant measurable quantity.
• Volatile Organic Compounds (VOC), although not actually a criteria air pollutant, VOCs are regulated by the SCAQMD because they cause chemical reactions which contribute to the formation of ozone. VOCs are also transformed into organic aerosols in the atmosphere, contributing to higher PM10 and lower visibility levels. Sources of VOCs include combustion engines, and evaporative emissions associated with fuel, paints and solvents, asphalt paving, and the use of household consumer products such as aerosols. Although health-based standards have not been established for VOCs, health effects can occur from exposures to r:,-n enuine~ring L.U,,,U group, me.
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high concentrations of VOC. Some hydrocarbon components classified as VOC emissions are hazardous air pollutants. Benzene, for example, is a hydrocarbon component of VOC emissions that are known to be a human carcinogen. The term reactive organic gases (ROG) are often used interchangeably with VOC.
• Toxic Air Contaminants (TACs) are defined as air pollutants which may cause or contribute to an increase in mortality or serious illness, or which may pose a hazard to human health, and for which there is no concentration that does not present some risk. This contrasts with the criteria pollutants, in that there is no threshold level for TAC exposure below which adverse health impacts are not expected to occur. The majority of the estimated health risk from TACs can be attributed to a relatively few compounds, the most common being diesel particulate matter (DPM) from diesel engine exhaust. In addition to DPM, benzene and 1,3-butadiene are also significant contributors to overall ambient public health risk in California.

2.2 Federal and State Ambient Air Quality Standards
The Federal Clean Air Act, which was last amended in 1990, requires the EPA to set National Ambient Air Quality Standards (NAAQS) for criteria pollutants considered harmful to public health and the environment. The State of California has also established additional and more stringent California Ambient Air Quality Standards (CAAQS) in addition to the seven criteria pollutants designated by the federal government.

AAQS are designed to protect the health and welfare of the populace with a reasonable margin of safety. The standards are divided into two categories, primary standards and secondary standards.

Primary standards are implemented to provide protection for the “sensitive” populations such as those with asthma, or the children and elderly. Secondary standards are to provide protection against visible pollution as well as damage to the surrounding environment, including animals, crops, and buildings.

Table 5 shows the Federal and State Ambient Air Quality Standards. r:,-n engine~ring
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Table 5
Federal and State Ambient Air Quality Standards (AAQS)1 Air Pollutant Averaging Time 2
Federal Standard
(NAAQS)2
California Standard
(CAAQS)2
Ozone
1 Hour -- 0.09 ppm
8 Hour 8 Hour 0.070 ppm
Carbon Monoxide
(CO)
1 Hour 35 ppm 20 ppm
8 Hour 9 ppm 9 ppm
Nitrogen Dioxide
(NO2)
1 Hour 0.100 ppm 0.18 ppm
Annual 0.053 ppm 0.030 ppm
Sulfur Dioxide
(SO2)
1 Hour 0.075 ppm 0.25 ppm
3 Hour 0.5 ppm3 --
24 Hour -- 0.04 ppm
Particulate Matter
(PM10)
24 Hour 150 µg/m³ 50 µg/m³
Mean -- 20 µg/m³
Particulate Matter
(PM2.5)
24 Hour 35 µg/m³ --
Annual 12 µg/m³ 12 µg/m³
Lead
30-day -- 1.5 µg/m
Quarter 1.5 µg/m --
3-month average 0.15 µg/m --
Visibility reducing
particles 8 Hour --

0.23/km extinction coefficient. (10-
mile visibility standard)
Sulfates 24 Hour -- 25 µg/m
Vinyl chloride 24 Hour -- 0.01 ppm
Hydrogen sulfide 24 Hour -- 0.03 ppm
1 Source: USEPA: https://www.epa.gov/criteria-air-pollutants/naaqs-table and CARB: https://ww2.arb.ca.gov/resources/california-ambient-air-quality-standards 2 ppm = parts per million of air, by volume; μg/m3 = micrograms per cubic meter; Annual = Annual Arithmetic Mean; 30-day = 30-day average; Quarter = Calendar quarter. 3 Secondary standards
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Several pollutants listed in Table 5 are not addressed in this analysis. Lead is not included because the project is not anticipated to emit lead. Visibility-reducing particles are not explicitly addressed in this analysis because particulate matter is addressed. The project is not expected to generate or be exposed to vinyl chloride because proposed project uses do not utilize the chemical processes that create this pollutant and there are no such uses in the project vicinity. The proposed project is not expected to cause exposure to hydrogen sulfide because it would not generate hydrogen sulfide in any substantial quantity.

2.3 Attainment Status
The Clean Air Act requires states to prepare a State Implementation Plan (SIP) to ensure air quality meets the NAAQS. The California Air Resources Board (CARB) provides designations of attainment for air basins where AAQS are either met or exceeded. If the AAQS are met, the area is designated as being in “attainment”, if the air pollutant concentrations exceed the AAQS, than the area is designated as being “nonattainment”. If there is inadequate or inconclusive data to make a definitive attainment designation, the area is considered “unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards. Each standard has a different definition, or ‘form’ of what constitutes attainment, based on specific air quality statistics. For example, the Federal 8-hour CO standard is not to be exceeded more than once per year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air monitoring values exceeds the threshold per year. In contrast, the federal annual PM2.5 standard is met if the threeyear average of the annual average PM2.5 concentration is less than or equal to the standard.

When a state submits a request to the EPA to re-designate a nonattainment area to attainment, the Clean Air Act (CAA) section 175A(a) requires that the state (or states, if the area is a multistate area) submit a maintenance plan ensuring the area can maintain the air quality standard for which the area is to be re-designated for at least 10 years following the effective date of redesignation. Table 6 lists the attainment status for the criteria pollutants in the South Coast Air Basin (SCAB).
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Table 6
South Coast Air Basin Attainment Status1
Pollutant State Status National Status
Ozone Nonattainment Nonattainment (Extreme)2
Carbon monoxide Attainment Attainment
(Maintenance)
Nitrogen dioxide Attainment Attainment
(Maintenance)
PM10 Nonattainment Attainment
(Maintenance)
PM2.5 Nonattainment Nonattainment
Lead Attainment Nonattainment (Partial)3
1 Source: California Air Resources Board. http://www.arb.ca.gov/desig/adm/adm.htm 2 8-Hour Ozone.
3 Partial Nonattainment designation – Los Angeles County portion of Basin only.

2.4 South Coast Air Quality Management District (SCAQMD) The agency responsible for air pollution control for the South Coast Air Basin (SCAB) is the South Coast Air Quality Management District (SCAQMD). SCAQMD is responsible for controlling emissions primarily from stationary sources. SCAQMD maintains air quality monitoring stations throughout the SCAB. SCAQMD, in coordination with the Southern California Association of Governments, is also responsible for developing, updating, and implementing the Air Quality Management Plan (AQMP) for the SCAB. An AQMP is a plan prepared and implemented by an air pollution district for a county or region designated as nonattainment of the federal and/or California ambient air quality standards. The term nonattainment area is used to refer to an air basin where one or more ambient air quality standards are exceeded.

The latest version is the 2022 AQMP, adopted in December 2022. The 2022 AQMP is a regional blueprint for achieving the federal air quality standards and healthful air. While air quality has dramatically improved over the years, the SCAB still exceeds federal public health standards for both ozone and particulate matter (PM) and experiences some of the worst air pollution in the nation. The 2022 AQMP includes both stationary and mobile source strategies to ensure that rapidly approaching attainment deadlines are met, that public health is protected to the maximum extent feasible, and that the region is not faced with burdensome sanctions if the Plan is not approved or if the NAAQS are not met on time.

According to the 2022 AQMP, the most significant air quality challenge in the SCAB is to reduce nitrogen oxide (NOx) emissions sufficiently to meet the upcoming ozone standard deadlines.

Based on the inventory and modeling results, the 2022 AQMP projects that 184 tons per day (tpd) r:,-n engine~ring
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of NOx will be emitted in the year 2037 as a result of continued implementation of already adopted regulatory actions (“baseline emissions”). The analysis suggests that in order to meet the ozone standard of 60 tpd, NOx emissions need to be reduced about 67 percent beyond the projected 2037 baseline emissions and about 83 percent below current levels1.

2.4.1 SCAQMD Rules and Regulations
The SCAQMD establishes a program of rules and regulations to obtain attainment of the state and federal standards in conjunction with the AQMP. Several of the rules and regulations that may be applicable to this project include, but are not limited to, the following:
• SCAQMD Rule 402 prohibits a person from discharging from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. • SCAQMD Rule 403 governs emissions of fugitive dust during construction and operation activities. Compliance with this rule is achieved through application of standard Best Management Practices, such as application of water or chemical stabilizers to disturbed soils, covering haul vehicles, restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access roadways, cessation of construction activity when winds exceed 25 mph, and establishing a permanent ground cover on finished sites.
• SCAQMD Rule 445 restricts wood burning devices from being installed into any new development and is intended to reduce the emissions of particulate matter for wood burning devices.
• SCAQMD Rule 1113 governs the sale, use, and manufacturing of architectural coating and limits the VOC content in paints and paint solvents. This rule regulates the VOC content of paints available during construction. Therefore, all paints and solvents used during construction and operation of project must comply with Rule 1113. • SCAQMD Rule 1143 governs the manufacture, sale, and use of paint thinners and solvents used in thinning of coating materials, cleaning of coating application equipment, 1 Source: 2022 Air Quality Management Plan, South Coast Air Quality Management District, Adopted December 2, 2022.
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and other solvent cleaning operations by limiting their VOC content. This rule regulates the VOC content of solvents used during construction. Solvents used during the construction phase must comply with this rule.
• SCAQMD Rule 1186 limits the presence of fugitive dust on paved and unpaved roads and sets certification protocols and requirements for street sweepers that are under contract to provide sweeping services to any federal, state, county, agency or special district such as water, air, sanitation, transit, or school district.

2.5 Local Climate and Meteorology
The weather station closest to the project site is a National Weather Service Cooperative weather station located at Riverside Fire Station 3, California (047470). Climatological data from the National Weather Service at this station is summarized in Table 7.

Table 7
Meteorological Summary1
Month
Temperature (˚F) Mean Precipitation
Max. Min. Mean (inches)
January 66.8 39.1 53.0 2.01
February 68.3 41.1 54.7 2.20
March 71.3 43.2 57.3 1.84
Total 75.6 46.7 61.2 0.77
May 80.0 51.1 65.6 0.23
June 87.0 54.8 70.9 0.05
July 94.2 59.5 76.9 0.04
August 94.4 59.6 77.0 0.13
September 90.9 56.2 73.6 0.19
October 82.9 50.0 66.5 0.44
November 74.5 42.8 58.7 0.84
December 67.8 39.2 53.5 1.46
Annual 79.5 48.6 64.1 10.21
1 Source: Western Regional Climate Center. Averages derived from measurements recorded between 1893 and 2016 at Riverside Fire Sta. 3, CA (047470).

2.6 Local Air Quality
The air quality at any site is dependent on the regional air quality and local pollutant sources.

Regional air quality is determined by the release of pollutants throughout the air basin. r:,-n engine~ring
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The SCAQMD has divided the SCAB into fourteen general forecasting areas and thirty eight Source Receptor Areas (SRA) for monitoring and reporting local air quality. The SCAQMD provides daily reports of the current air quality conditions in each general forecast area and SRA. The monitoring areas provide a general representation of the local meteorological, terrain, and air quality conditions within the SCAB.

The project is located within the Hemet/Elsinore Area general forecasting area and Perris Valley air monitoring area (SRA-24). Table 8 summarizes the published air quality monitoring data for SRA24 for the most recent 3-year period available. For pollutant data that is not available in SRA-24, air quality data is derived from the nearest adjacent stations available, including Lake Elsinore (SRA-25) and Metropolitan Riverside (SRA-23).

The data provided in the table below is used to comprise a “background” for the proposed project location and existing local air quality.
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Table 8
Local Air Quality
Air Pollutant
Location
Averaging
Time Item 2022 2023 2024
Carbon
Monoxide
--
Lake Elsinore
1 Hour
Max 1-Hour (ppm) 0.9 1.3 1.8
Exceeded State Standard (20 ppm) No No No
Exceeded National Standard (35 ppm) No No No
8 Hour
Max 8 Hour (ppm) 0.6 0.7 1.0
Days > State Standard (9 ppm) No No No
Days >National Standard (9 ppm) No No No
Ozone
--
Perris Valley
1 Hour
Max 1-Hour (ppm) 0.121 0.120 0.117
Days > State Standard (0.09 ppm) 17.0 10.0 21.0
8 Hour
Max 8 Hour (ppm) 0.091 0.103 0.099
Days > State Standard (0.070 ppm) 37 35 51
Days >National Standard (0.070 ppm) 37 31 49
Nitrogen Dioxide
--
Lake Elsinore
1 Hour
Max 1-Hour (ppm) 0.037 0.042 0.045
Exceeded State Standard (0.18 ppm) No No No
Annual
Annual Average (ppm) 0.007 0.007 0.007
Exceeded State Standard (0.030 ppm) No No No
Exceeded National Standard (0.053 ppm) No No No
Sulfur Dioxide
--
Metropolitan
Riverside County 1
1 Hour
Max 1 Hour (ppm) 0.0067 0.0031 0.0020
Exceeded State Standard (0.25 ppm) No No No
Exceeded National Standard (0.075 ppm) No No No
Suspended
Particles (PM10)
--
Lake Elsinore
24 Hour
Max 24-Hour (µg/m³) 91 186 81
Days > State Standard (50 µg/m³) 1 5 16
Days >National Standard (150 µg/m³) 0 1 0 (0%)
Annual
Annual Average (µg/m³) 19.80 20.80 25.50
Exceeded State Standard (20 µg/m³) No Yes Yes
Fine Particulates
(PM2.5)
--
Metropolitan
Riverside County 1
24 Hour
Max 24-Hour (µg/m³) 38.50 48.70 63.50
Days >National Standard (35 µg/m³) 1 1 5
Annual
Annual Average (µg/m³) 10.80 10.47 12.09
Exceeded State Standard (12 µg/m³) No No Yes
Exceeded National Standard (15 µg/m³) No No No
Source: https://www.aqmd.gov/home/air-quality/historical-air-quality-data/historical-data-by-year µg/m³ = micrograms per cubic meter
ppm = part per million
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3.0 Global Climate Change Setting
Global climate change is the change in the average weather of the earth that is measured by such things as alterations in temperature, wind patterns, storms, and precipitation.

Current data shows that the recent period of warming is occurring more rapidly than past geological events. The average global surface temperature has increased by approximately

1.4° Fahrenheit since the early 20th Century. 1.4° Fahrenheit may seem like a small change, but it's an unusual event in Earth's recent history, and as we are seeing, even small changes in temperature can cause enormous changes in the environment.

The planet’s climate record, preserved in tree rings, ice cores, and coral reefs, shows that the global average temperature has been stable over long periods of time. For example, at the end of the last ice age, when the Northeast United States was covered by more than 3,000 feet of ice, average global temperatures were only 5° to 9° Fahrenheit cooler than today. The Intergovernmental Panel on Climate Change (IPCC), which includes more than 1,300 scientists from the United States and other countries, forecasts a temperature rise of

2.5° to 10° Fahrenheit over the next century. Therefore, significant changes to the environment are expected in the near future.

The consequences of global climate change include more frequent and severe weather, worsening air pollution by increasing ground level ozone, higher rates of plant and animal extinction, more acidic and oxygen depleted oceans, strain on food and water resources, and threats to densely populated coastal and low lying areas from sea level rise.

The impacts of climate change are already visible in the Southwest United States. In California, the consequences of climate change include; • A rise in sea levels resulting in the displacement of coastal businesses and residencies
• A reduction in the quality and supply of water from the Sierra snowpack • Increased risk of large wildfires
• Exacerbation of air quality problems
• Reductions in the quality and quantity of agricultural products • An increased temperature and extreme weather events
• A decrease in the health and productivity of California’s forests

3.1 Greenhouse Gases
GHGs comprise less than 0.1 percent of the total atmospheric composition, yet they play an essential role in influencing climate. Greenhouse gases include naturally occurring r::,-r.:a engineering l.i.J.Li greuP. Inc. rken11ineeu::om 518
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compounds such as carbon dioxide (CO2), methane (CH4), water vapor (H2O), and nitrous oxide (N2O), while others are synthetic. Man-made GHGs include the chlorofluorocarbons (CFCs), hydrofluorocarbons (HFCs) and Perfluorocarbons (PFCs), as well as sulfur hexafluoride (SF6). Different GHGs have different effects on the Earth's warming. GHGs differ from each other in their ability to absorb energy (their "radiative efficiency") and how long they stay in the atmosphere, also known as the "lifetime".

The Global Warming Potential (GWP) was developed to allow comparisons of the global warming impacts of different gases. Specifically, it is a measure of how much energy the emissions of 1 ton of a gas will absorb over a given period of time, relative to the emissions of 1 ton of CO2. The larger the GWP, the more that a given gas warms the Earth compared to CO2 over that time period. The time period usually used for GWPs is 100 years. GWPs provide a common unit of measure, which allows analysts to add up emissions estimates of different gases and allows policymakers to compare emissions reduction opportunities across sectors and gases.

Table 9 lists the 100-year GWP of GHGs from the Intergovernmental Panel on Climate Change (IPCC) fifth assessment report (AR5) and IPCC sixth (6th) assessment report (AR6). r::,-r.:a engineering l.i.J.Li UrtUP. Inc.
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Table 9
Global Warming Potential of Greenhouse Gases1, 2
Gas Name Formula Lifetime (years) GWP
Carbon Dioxide CO2 1
Methane
CH4 (Fossil Origin)
12 29.8
CH4 (Non-Fossil Origin) 27.2
Nitrous Oxide N2O 114 273
Sulphur Hexafluoride SF6 3200 23,500
Nitrogen Trifluoride NF3 740 16,100
Chlorofluorocarbon (CFC-11) CFC-11 52 8,321
Hexafluoroethane (PFC-116) C2F6 10,000 11,100
Octafluoropropane (PFC-218) C3F8 2,600 8,900
Octafluorocyclobutane (PFC-318) C4F8 3,200 9,540
Tetrafluoromethane (PFC-14) CF4 50,000 5,301
Hydrofluorocarbon 125 HFC-125 29 3,170
Hydrofluorocarbon 134a HFC-134a 14 1,526
Hydrofluorocarbon 143a HFC-143a 52 4,800
Hydrofluorocarbon 152a HFC-152a 1 138
Hydrofluorocarbon 227ea HFC-227ea 34 3,350
Hydrofluorocarbon 23 HFC-23 270 12,400
Hydrofluorocarbon 236fa HFC-236fa 240 8,060
Hydrofluorocarbon 245fa HFC-245fa 8 858
Hydrofluorocarbon 32 HFC-32 5 771
Hydrofluorocarbon 365mfc HFC-365mfc 9 804
Hydrofluorocarbon 43-10mee HFC-43-10mee 16 1,650
1Source: IPCC Sixth Assessment Report (AR6),
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf & https://www.ipcc.ch/site/assets/uploads/2018/02/WG1AR5_Chapter08_FINAL.pdf 2 GWPs are used to convert GHG emission values to "carbon dioxide equivalent" (CO2e) units r::,-r.:a engineering l.i.J.Li greuP. Inc. rken11ineeu::om 520
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3.2 GHG Regulatory Setting – State of California
The State of California has been a leader in climate change legislation and has passed numerous bills to reduce greenhouse gas emissions across all sectors of the economy.

Some of the key climate legislation and regulation in the State include the following:
• Assembly Bill (AB) 32, California Global Warming Solutions Act of 2006. AB 32 set the stage for the State’s transition to a sustainable, low-carbon future. AB 32 was the first program in the country to take a comprehensive, long-term approach to addressing climate change.2
• Senate Bill (SB) 375, Sustainable Communities & Climate Protection Act of 2008. SB 375 requires the Air Resources Board to develop regional greenhouse gas emission reduction targets for passenger vehicles GHG reduction targets for 2020 and 2035 for each region covered by the State's 18 metropolitan planning organizations.3
• Senate Bill (SB) 100, California Renewables Portfolio Standard Program. SB 100 established a landmark policy requiring renewable energy and zero-carbon resources supply 100 percent of electric retail sales to end-use customers by 2045.4 • California Building Standards Code – Title 24. The California Building Standards Code Title 24 Part 6 (Energy Code) and Title 24 Part 11 (CALGreen) requires multiple building provisions to reduce energy usage and GHG emissions and is updated on a triennial basis.

3.3 GHG Emissions Inventory
Table 10 shows the latest GHG emission inventories at the national, state, regional and local levels.
2 California Air Resources Board. AB 32 Global Warming Solutions Act of 2006. https://ww2.arb.ca.gov/resources/fact-sheets/ab-32-global-warming-solutions-act-2006 3 California Air Resources Board. Sustainable Communities and Climate Protection Program. https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-climate-protection-program/about 4 California Energy Commission. SB 100 Joint Agency Report. https://www.energy.ca.gov/sb100 r::,-r.:a engineering l.i.J.Li greuP. Inc. rken11ineeu::om 521
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Table 10
GHG Emissions Inventory1
United States
(2019)2
State of California
(2019)3
SCAG
(2020)4
City of Moreno Valley
(2018)5
6,558 MMTCO2e 418 MMTCO2e 216.4 MMTCO2e 0.866 MMTCO2e
1 MMTCO2e = Million Metric Tons of Carbon Dioxide Equivalent 2 https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks 3 https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-19.pdf 4 http://www.scag.ca.gov/programs/Pages/GreenhouseGases.aspx. Projected Emission from SCAG - Regional GHG Inventory and Reference Case Projections, 1990-2035, dated May 30, 2012. 5 Source: City of Moreno Valley Climate Action Plan, dated 2021. https://www.moval.org/city_hall/generalplan2040/MV-CAP.pdf. ======================= r::,-r.:a engineering l.i.J.Li greuP. Inc. rken11ineeu::om 522
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4.0 Modeling Parameters and Assumptions
The California Emissions Estimator Model Version 2022.1.1 (CalEEMod) was used to calculate criteria air pollutants and GHG emissions from the construction and operation of the project.

CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify criteria air pollutant and GHG emissions.

The model quantifies direct emissions from construction and operation activities (including vehicle use), as well as indirect emissions, such as GHG emissions from off-site energy generation, solid waste disposal, vegetation planting and/or removal, and water use. The model also identifies design features to reduce criteria pollutant and GHG emissions. The model was developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with the California air districts.

4.1 Construction Assumptions
Construction of the project is estimated to begin in the year 2025 or 2026 and to consist of site preparation, grading, building construction, paving, and architectural coating. For the purposes of this analysis, construction phases are not expected to overlap.

No demolition is expected to be required during construction. The project will require the export of approximately 8,000 cubic yards of earthwork material for grading purposes.

The CalEEMod default construction equipment list is based on survey data and the size of the site.

The parameters used to estimate construction emissions, such as the worker and vendor trips and trip lengths, utilize the CalEEMod defaults. The construction equipment list is shown in Table 11.

The project will be required to comply with several standard fugitive dust control measures, per SCAQMD Rule 403. The following key inputs are utilized in CalEEMod and are based upon data provided from SCAQMD5:
• Water exposed area – 61% PM10 and PM2.5 reduction.
• Water demolished area – 36% PM10 and PM2.5 reduction. • Water unpaved roads twice daily – 55% PM10 and PM2.5 reduction. • Limit vehicle speeds on unpaved roads to 25 mph – 44% PM10 and PM2.5 reduction. • Sweep paved roads once per month – 9% PM10 and PM2.5 reduction. 5 SCAQMD. Fugitive Dust Mitigation Measures. http://www.aqmd.gov/home/rules-compliance/ceqa/air-qualityanalysis-handbook/mitigation-measures-and-control-efficiencies/fugitive-dust r::Tr.l engineering I..U.lJI gn,uP. Inc. rken11ineer.c::om 523
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Table 11
Construction Equipment Assumptions1
Phase Equipment Number
Hours
Per
Day
Soil
Disturbance
Rate
(Acres/
8hr-Day)
Off-Road
Equipment
Daily
Disturbance
Footprint
(Acres)
Total Daily
Disturbance
Footprint
(Acres)
Site
Preparation
Rubber Tired Dozers 3 8 0.50 1.50

3.50 Tractors/Loaders/Backhoes 4 8 0.50 2.00
Grading
Graders 1 8 0.50 0.50

3.00 Excavators 1 8 0.50 0.50
Tractors/Loaders/Backhoes 3 8 0.50 1.50
Rubber Tired Dozers 1 8 0.50 0.50
Building
Construction
Cranes 1 7 0.00 0.00

1.31 Forklifts 3 8 0.00 0.00
Generator Sets 1 8 0.00 0.00
Welders 1 8 0.00 0.00
Tractors/Loaders/Backhoes 3 7 0.50 1.31
Paving
Tractors/Loaders/Backhoes 1 8 0.50 0.50

0.50 Cement and Mortar
Mixers 2 6 0.00 0.00
Pavers 1 8 0.00 0.00
Paving Equipment 2 6 0.00 0.00
Rollers 2 6 0.00 0.00
Architectural
Coating Air Compressors 1 6 0.00 0.00 0.00
1 CalEEMod Defaults
It should be noted that this air quality analysis was originally prepared in April 2024 and assumed that construction would start in the year 2024. Since then, the anticipated construction schedule has shifted, and project construction is now expected to begin in September 2026 with the project opening in 2027.

4.2 Localized Construction Analysis Modeling Parameters CalEEMod calculates construction emissions based on the number of equipment hours and the maximum daily disturbance activity possible for each piece of equipment. This report identifies the following parameters in the project design or applicable mitigation measures in order to compare CalEEMod reported emissions against the localized significance threshold lookup tables:
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1) The off-road equipment list (including type of equipment, horsepower, and hours of operation) assumed for the day of construction activity with maximum emissions. 2) The maximum number of acres disturbed on the peak day. 3) Any emission control devices added onto off-road equipment. 4) Specific dust suppression techniques used on the day of construction activity with maximum emissions.

4.3 Operational Assumptions
Operational emissions occur over the life of the project and are considered “long-term” sources of emissions. Operational emissions include both direct and indirect sources. This section briefly describes the operational sources of emissions analyzed for the project.

4.3.1 Mobile Source Emissions
Mobile source emissions are the largest source of long-term air pollutants from the operation of the project. Mobile sources are direct sources of project emissions that are primarily attributed to tailpipe exhaust and road dust (tire, brake, clutch, and road surface wear) from motor vehicles traveling to and from the site.

Estimates of mobile source emissions require information on four parameters: trip generation, trip length, vehicle/fleet mix, and emission factors (quantity of emission for each mile traveled or time spent idling by each vehicle).

The trip generation rates used for this analysis are based on the Cactus Avenue and Bradshaw Circle Residential Project Trip Generation and VMT Screening Analysis, City of Moreno Vally, prepared by RK. For trip lengths, the CalEEMod defaults are used.

The Emission Factors 2021 (EMFAC2021) model and off-model adjustments factors to account for the SAFE Vehicle Rule are used to estimate the mobile source emissions embedded in the CalEEMod emissions model. No adjustments have been made to default emission factors.

The project’s total vehicle miles traveled is shown in Table 12.

Table 12
Operational Vehicle Miles Traveled1
Land Use Annual Home-Based Vehicle Miles Traveled
(VMT)
Single Family Residential 1,136,007
1 CalEEMod defaults.
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To be conservative, this analysis has assumed that 2% of the total trips associated with the project will be heavy trucks with a gross vehicle weight rating (GVWR) of 10,000 pounds or greater. This includes LHD2, MHD, HHD, OBUS, UBUS, and SBUS vehicles. The adjusted vehicle mix is proportioned according to the default CalEEMod vehicle mix.

Table 13 summarizes adjusted vehicle mix used for the project.

Table 13
Operational Vehicle Mix1
YUY Vehicle Mix (%)
Light Duty Automobile (LDA) 51.11%
Light Duty Truck (LDTI) 4.02%
Light Duty Truck (LDT2) 20.72%
Medium Duty Truck (MDV) 16.44%
Light Heavy Truck (LHD1) 3.30%
Light Heavy Truck (LHD2) 0.38%
Medium Heavy Truck (MHD) 0.60%
Heavy Heavy Truck (HHD) 0.66%
Other Bus (OBUS) 0.03%
Urban Bus (UBUS) 0.02%
Motorcycle (MCY) 2.41%
School Bus (SBUS) 0.06%
Motor Home (MH) 0.27%
Total 100%
1 Adjusted fleet mix to include 2% total trucks over 10,000 lbs. GVWR. (LHD2, MHD, HHD, OBUS, UBUS, SBUS, MH).

4.3.2 Energy Source Emissions
Energy usage includes both direct and indirect sources of emissions. Direct sources of emissions include on-site natural gas usage (non-hearth) for heating, while indirect emissions include electricity generated by offsite power plants. Natural gas use is measured in units of thousand British Thermal Units (kBTU) per size metric for each land use subtype and electricity use is measured in kilowatt hours (kWh) per size metric for each land use subtype.

CalEEMod divides building electricity and natural gas use into uses that are subject to Title 24 standards and those that are not. Lighting electricity usage is also calculated as a separate category in CalEEMod. For electricity, Title 24 uses include the major building envelope systems r::Tr.l engineering I..U.lJI gn,uP. Inc. rken11ineer.c::om 526
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covered by Part 6 (California Energy Code) of Title 24, such as space heating, space cooling, water heating, and ventilation. Non-Title 24 uses include all other end uses, such as appliances, electronics, and other miscellaneous plug-in uses. Because some lighting is not considered as part of the building envelope energy budget, and since a separate mitigation measure is applicable to this end use, CalEEMod makes lighting a separate category.

For natural gas, uses are likewise categorized as Title 24 or Non-Title 24. Title 24 uses include building heating and hot water end uses. Non-Title 24 natural gas uses include cooking and appliances (including pool/spa heaters).

The baseline values are based on the California Energy Commission (CEC) sponsored California Commercial End Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies.

The project will be required to provide on-site renewable energy photovoltaic installations (solar panels), as prescribed by the 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings.

In order to assess the project’s future energy usage, RK has performed a quantitative energy impact analysis using CEQA energy impact criteria. The energy impact analysis is provided in Section 8.0 of this report.

4.3.3 Area Source Emissions
Area source emissions are direct sources of emissions that fall under four categories: hearths, consumer products, architectural coatings, and landscaping equipment. Per SCAQMD rule 445, no wood burning devices are allowed in new developments; therefore, no wood hearths are included in this project.

Consumer products are various solvents used in non-industrial applications which emit ROGs during their product use. These typically include cleaning supplies, kitchen aerosols, cosmetics, and toiletries.

4.3.4 Other Sources of Operational Emissions
Water. Greenhouse gas emissions are generated from the upstream energy required to supply and treat the water used on the project site. Indirect emissions from water usage are counted as part of the project’s overall impact.

Waste. CalEEMod calculates the indirect GHG emissions associated with waste that is disposed of at a landfill. The program uses annual waste disposal rates from the California Department of Resources Recycling and Recovery (CalRecycle) data for individual land uses. The program r::Tr.l engineering I..U.lJI UrtUP. Inc.
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quantifies the GHG emissions associated with the decomposition of the waste which generates methane based on the total amount of degradable organic carbon.

The project’s estimated water usage and waste generation is reported in Table 14, and an analysis of the associated energy usage is provided in Section 8.0 of this report.

Table 14
Operational Water Usage and Waste Generation1
Land Use
Water Usage
(gallons/year) Waste Generation
(tons/year)1
Indoor Outdoor Total
Single Family Housing 1,504,929.68 443,531.80 1,948,461.48 34.02 Parking Lot -- -- -- --
Total 1,504,929.68 443,531.80 1,948,461.48 34.02
1 CalEEMod default estimates.
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5.0 Significance Thresholds

5.1 Air Quality Regional Significance Thresholds
The SCAQMD has established air quality emissions thresholds for criteria air pollutants for the purposes of determining whether a project may have a significant effect on the environment per Section 15002(g) of the Guidelines for implementing CEQA. By complying with the thresholds of significance, the project would be in compliance with the SCAQMD Air Quality Management Plan (AQMP) and the federal and state air quality standards.

Table 15 lists the air quality significance thresholds for the six air pollutants analyzed in this report.

Lead is not included as part of this analysis as the project is not expected to emit lead in any significant measurable quantity.

Table 15
SCAQMD Regional Significance Thresholds
Pollutant Construction (lbs/day) Operation (lbs/day)
NOX 100 55
VOC 75 55
PM10 150 150
PM2.5 55 55
SOX 150 150
CO 550 550
1Source: http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf

5.2 Air Quality Localized Significance Thresholds
Air quality emissions were analyzed using the SCAQMD’s Mass Rate Localized Significant Threshold (LST) Look-up Tables.

Table 16 lists the Localized Significance Thresholds (LST) used to determine whether a project may generate significant adverse localized air quality impacts. LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard. LSTs are developed based on the ambient concentrations of four applicable air pollutants for source receptor area (SRA-24) – Perris Valley.
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The nearest existing sensitive receptors are located along the northern boundary of the project site, less than 25 meters from potential areas of on-site construction and operational activity.

Although receptors are located closer than 25 meters to the site, SCAQMD LST methodology states that projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.

The daily disturbance area is calculated to be 3.5 acres, hence the LSTs for 5-acre sites are used.

Table 16
SCAQMD Localized Significance Thresholds1(LST)
Pollutant Construction (lbs/day) Operational (lbs/day)
NOX 216.8 216.8
CO 1,221.4 1,221.4
PM10 9.8 2.9
PM2.5 6.1 1.6
1 Source: SCAQMD Mass Rate Localized Significance Thresholds for 3.5 acres/day in SRA-24 at 25 meters.

5.3 GHG Significance Thresholds

5.3.1 SCAQMD GHG Interim Significance Thresholds
The SCAQMD has published the Interim CEQA Greenhouse Gas (GHG) Significance Thresholds, December 2008, to assist local agencies with determining the impact of a project’s GHG emissions. SCAQMD’s objective in providing the GHG guidelines is to establish a performance standard that will ultimately contribute to reducing GHG emissions below 1990 levels, and thus achieve the requirements of the California Global Warming Solutions Act (AB 32).

In the absence of a formal threshold established by the State, SCAQMD’s interim GHG threshold has been established for use by lead agencies in determining significance of GHG emissions in CEQA. SCAQMD guidance describes a five-tiered approach for determining significance. Tier 3 is the primary method used for development projects of this size and is the approach used in this analysis. The Tier 3 approach limits the amount of GHG emissions from residential and commercial development projects to 3,000 metric tons of CO2 equivalents per year (MTCO2e/yr).

The City of Moreno Valley utilizes the SCAQMD GHG Interim Significance Threshold for CEQA purposes. Therefore, if the project exceeds 3,000 MTCO2e/yr, then the impact is considered significant, and mitigation measures would be required to reduce emissions below the threshold. r::Tr.l engineering I..U.lJI gn,uP. Inc. rken11ineer.c::om 530
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6.0 Air Quality Impact Analysis

6.1 Short-Term Air Quality Impacts – Construction

6.1.1 Regional Emissions – Construction
Regional air quality emissions include both on-site and off-site emissions associated with construction of the project. As shown in Table 17, regional daily emissions of criteria pollutants are expected to be below the allowable thresholds of significance.

CalEEMod emissions outputs are provided in Appendix A.

Table 17
Regional Construction Emissions
Maximum Daily Emissions (lbs/day)1
Activity VOC NOx CO SO2 PM10 PM2.5
Site Preparation 3.73 36.05 34.03 0.05 9.49 5.47
Grading 2.10 28.64 22.20 0.09 6.25 2.96
Building Construction 1.27 11.44 14.11 0.02 0.71 0.51
Paving 1.00 6.61 10.39 0.01 0.55 0.32
Architectural Coating 26.14 0.90 1.30 0.00 0.06 0.03
Maximum1 26.14 36.05 34.03 0.09 9.49 5.47
SCAQMD Threshold 75 100 550 150 150 55
Exceeds Threshold (?) No No No No No No
1 Maximum daily emission during summer or winter; includes both on-site and off-site project emissions.

The project must follow mandatory SCAQMD rules and requirements with regards to fugitive dust control, as described in Section 6.1.3. Compliance with the standard dust control measures is considered to be part of the conditions of approval for the project and built into the design features.

Table 17 shows that the project’s daily construction emissions will be below the applicable SCAQMD air quality standards and thresholds of significance. As a result, the project would not contribute substantially to an existing or projected air quality violation.

Furthermore, by complying with the SCAQMD standards, the project would not contribute to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonr:,-n engine~ring L.U,,,U group, me.
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attainment under an applicable Federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors).

The project’s short-term construction impact on regional air resources will be less than significant.

6.1.2 Localized Emissions – Construction
Table 18 illustrates the construction-related localized emissions and compares the results to SCAQMD LST thresholds. The project must follow all standard SCAQMD rules and requirements with regards to fugitive dust control, as described in Section 6.1.3. Compliance with the dust control is considered a standard requirement and included as part of the project’s design features.

Table 18
Localized Construction Emissions
Maximum Daily Emissions (lbs/day)1
Activity NOx CO PM10 PM2.5
On-site Emissions 35.95 32.93 9.27 5.41
SCAQMD Construction Threshold2 216.8 1,221.4 9.8 6.1
Exceeds Threshold (?) No No No No
1 Maximum daily emission during summer or winter; includes on-site project emissions only. 2 Source: SCAQMD Mass Rate Localized Significance Thresholds for 3.5 acres/day in SRA-24 at 25 meters.

As shown in Table 18, the emissions will be below the SCAQMD thresholds of significance for localized construction emissions. Therefore, the project’s localized construction emissions impact is considered less than significant.
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6.1.3 Fugitive Dust – Construction
The Project is required to comply with standard SCAQMD rules that assist in reducing short-term air pollutant emissions associated with suspended particulate matter, also known as fugitive dust.

Fugitive dust emissions are commonly associated with land clearing activities, cut-and-fill grading operations, and exposure of soils to the air and wind. SCAQMD Rule 403 requires that fugitive dust is controlled with best-available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emission source. In addition, SCAQMD Rules 402 and 403 require implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off site.

To ensure full compliance with the fugitive dust control measures and to reduce potential exposure of sensitive receptors to substantial pollution concentrations, the following design feature will be implemented during construction:

DF-1 Follow the standard SCAQMD rules and requirements with regards to fugitive dust control, which includes, but are not limited to the following:

1. All active construction areas shall be watered two (2) times daily.

2. Speed on unpaved roads shall be reduced to less than 15 mph.

3. Any visible dirt deposition on any public roadway shall be swept or washed at the site access points within 30 minutes.

4. Any on-site stockpiles of debris, dirt or other dusty material shall be covered or watered twice daily.

5. All operations on any unpaved surface shall be suspended if winds exceed 15 mph.

6. Access points shall be washed or swept daily.

7. Construction sites shall be sandbagged for erosion control.

8. Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more).

9. Cover all trucks hauling dirt, sand, soil, or other loose materials, and maintain at least 2 feet of freeboard space in accordance with the requirements of California Vehicle Code (CVC) section 23114.

10. Pave or gravel construction access roads at least 100 feet onto the site from the main road and use gravel aprons at truck exits.

11. Replace the ground cover of disturbed areas as quickly possible. r:,-n enuine~ring L.U,,,U group, me.
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6.1.4 Odors – Construction
Heavy-duty equipment in the project area during construction will emit odors; however, the construction activity would cease to occur after individual construction is completed. The project is required to comply with Rule 402 during construction, which states that a person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. No other sources of objectionable odors have been identified for the proposed Project.

Therefore, the project impact from odor emissions will be less than significant.

6.1.5 Asbestos – Construction
Asbestos is a carcinogen and is categorized as a hazardous air pollutant by the Environmental Protection Agency (EPA) and regulated through the National Emissions Standards for Hazardous Air Pollutants (NESHAP). Asbestos fibers imbedded within construction materials become a health hazard once they are disturbed and rendered airborne, such as through physical contact like building renovation and demolition activities.

SCAQMD is the local enforcement authority for asbestos. SCAQMD Rule 1403 establishes the survey requirements, notification, and work practices to prevent asbestos emissions from emanating during building renovation and demolition activities. Since the project does not require the demolition of any existing structures, the impact from asbestos contained in building products is considered less than significant.

Asbestos also occurs naturally in serpentine and ultramafic rock. Based on the California Division of Mines and Geology General Location Guide for Ultramafic Rocks in California - Areas More Likely to Contain Naturally Occurring Asbestos, naturally occurring asbestos has not been shown to occur within in the vicinity of the project site. Therefore, the potential risk for naturally occurring asbestos (NOA) during project construction is small. However, in the event NOA is found on the site, the project will be required to comply with SCAQMD and NESHAP standards.

By following the required asbestos abatement protocols, the project impact will be less than significant.
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6.1.6 Diesel Particulate Matter – Construction
The project will generate diesel particulate matter (DPM) during construction from off-road diesel equipment and trucks. The California Office of Environmental Health Hazard Assessment (OEHHA) adopted the Guidance Manual for Preparation of Health Risk Assessments (HRA Guidelines) to provide procedures for use in the Air Toxics Hot Spots Program or for the permitting of existing, new, or modified stationary sources.6
The HRA Guidelines provide risk factors based on exposure to toxic substances over a 30-year lifetime span. The proposed project’s construction activity is not expected to be a long-term (i.e., 30 years) source of toxic air contaminant emissions and short-term risk factors have not been developed. Due to the significantly reduced risk from short-term exposure, SCAQMD does not typically require the evaluation of long-term cancer risk or chronic health impacts for construction operations from a project such as the one being proposed.

The following design features will reduce diesel exhaust emissions and are recommended to be included as part of the conditions of approval. With the recommended project design features, the potential DPM exposure to adjacent sensitive receptors is considered less than significant.

DF-2 Require all construction equipment to have Tier 4 low emission “clean diesel” engines (OEM or retrofit) that include diesel oxidation catalysts and diesel particulate filters that meet the latest CARB best available control technology.

DF-3 Construction equipment shall be maintained in proper tune.

DF-4 All construction vehicles shall be prohibited from excessive idling. Excessive idling is defined as five (5) minutes or longer).

DF-5 Minimize the simultaneous operation of multiple construction equipment units, to the maximum extent feasible.

DF-6 The use of heavy construction equipment and earthmoving activity shall be suspended during Air Alerts when the Air Quality Index reaches the “Unhealthy” level.

DF-7 Establish an electricity supply to the construction site and use electric-powered equipment instead of diesel-powered equipment or generators, where feasible. 6 OEHHA. Air Toxics Hot Spots Program. Risk Assessment Guidelines. Guidance for Preparation of Health Risk Assessments. February 2015.
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DF-8 Establish staging areas for the construction equipment that are as distant as possible from adjacent residential homes.

6.2 Long-Term Air Quality Impacts – Operation

6.2.1 Regional Emissions – Operation
Long-term operational air pollutant impacts from the project are shown in Table 19. CalEEMod emissions outputs are provided in Appendix A.

The project’s daily operational emissions will be below the applicable SCAQMD regional air quality standards and thresholds of significance, and the project would not contribute substantially to an existing or projected air quality violation. Furthermore, by complying with the SCAQMD standards, the project would not contribute to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable Federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors).

The project related long-term regional air quality impacts will be less than significant.

Table 19
Regional Operational Emissions
Maximum Daily Emissions (lbs/day)1,2
Activity VOC NOx CO SO2 PM10 PM2.5
Mobile Sources 1.24 0.90 10.15 0.02 2.21 0.57
Area Sources 1.86 0.02 2.10 0.00 0.00 0.00
Energy Sources 0.02 0.33 0.14 0.00 0.03 0.03
Total 3.12 1.25 12.39 0.02 2.24 0.60
SCAQMD Threshold 55 55 550 150 150 55
Exceeds Threshold (?) No No No No No No
1 Maximum daily emission during summer or winter; includes both on-site and off-site project emissions.

6.2.2 Localized Emissions – Operations
Table 20 shows the localized operational emissions and compares the results to SCAQMD LST thresholds of significance. As shown in Table 20, the emissions will be below the SCAQMD r:,-n engine~ring
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thresholds of significance for localized operational emissions. Therefore, the project will result in less than significant localized operational emissions impacts.

Table 20
Localized Operational Emissions
Maximum Daily Emissions (lbs/day)1
LST Pollutants
NOx CO PM10 PM2.5
(lbs/day) (lbs/day) (lbs/day) (lbs/day)
On-site Emissions2 0.40 2.75 0.14 0.06
SCAQMD Operation Threshold3 216.8 1,221.4 2.9 1.6
Exceeds Threshold (?) No No No No
1 Maximum daily emission in summer or winter.
2 Mobile source emissions include on-site vehicle emissions only. It is estimated that approximately 5% of mobile emissions will occur on the project site.
3 Source: SCAQMD Mass Rate Localized Significance Thresholds for 5 acres/day in SRA-24 at 25 meters.

6.2.3 Odors – Operation
Land uses that commonly receive odor complaints include agricultural uses (farming and livestock), chemical plants, composting operations, dairies, fiberglass molding facilities, food processing plants, landfills, refineries, rail yards, and wastewater treatment plants. The proposed project does not contain land uses that would typically be associated with significant odor emissions.

The project will be required to comply with standard building code requirements related to exhaust ventilation, as well as comply with SCAQMD Rule 402. Rule 402 requires that a person may not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. Project related odors are not expected to meet the criteria of being a nuisance. The project’s operation would result in less than significant odor impacts.

6.2.4 Toxic Air Contaminants – Operations
The proposed project consists of residential land use and does not include major sources of toxic air contaminants (TAC) emissions that would result in significant exposure of sensitive receptors to substantial pollutant concentrations. Examples of land uses that are major sources of TACs include r:,-n engine~ring
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distribution centers with heavy truck traffic, rail yards, ports, refineries, chrome plating facilities, dry cleaners, and gasoline dispensing stations. The project does not include any of these uses, hence the project impact is considered less than significant. r:,-n enuine~ring L.U,,,U group, me.
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7.0 Greenhouse Gas Impact Analysis

7.1 Greenhouse Gas Emissions – Construction
Greenhouse gas emissions are estimated for on-site and off-site construction activity using CalEEMod. Table 21 shows the construction greenhouse gas emissions, including equipment and worker vehicle emissions for all phases of construction. Construction emissions are averaged over 30 years and added to the long-term operational emissions, pursuant to SCAQMD recommendations.

CalEEMod GHG output calculations are provided in Appendix A.

Table 21
Construction Greenhouse Gas Emissions
Activity
Emissions (MTC02e)1
On-site Off-site Total
Site Preparation 12.05 0.54 12.59
Grading 10.77 34.08 44.86
Building Construction 251.00 31.85 282.85
Paving 11.06 2.17 13.24
Architectural Coating 1.09 0.29 1.38
Total 285.97 68.93 354.92
Amortized over 30 years2 9.53 2.30 11.83
1 MTCO2e = metric tons of carbon dioxide equivalents (includes carbon dioxide, methane, nitrous oxide, and/or hydrofluorocarbon).
2 GHG emissions are amortized over 30 years and added to the operational emissions, pursuant to SCAQMD recommendations.

Because impacts from construction activities occur over a relatively short period of time, they contribute a relatively small portion of the overall lifetime project GHG emissions. However, SCAQMD recommends that construction emissions be amortized over a 30-year project lifetime and added to the overall project operational emissions. In doing so, construction GHG emissions are included in the overall contribution of the project, as further discussed in the following section.
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7.2 Greenhouse Gas Emissions – Operations
Greenhouse gas emissions are estimated for on-site and off-site operational activity using CalEEMod. Greenhouse gas emissions from mobile sources, area sources and energy sources are shown in Table 22. CalEEMod GHG output calculations are provided in Appendix A.

Table 22
Operational Greenhouse Gas Emissions
Emission Source GHG Emissions (MTCO2e)1
Mobile Source 377.25
Area Source 0.64
Energy Source 114.91
Water 4.65
Waste 10.62
Refrigerant 0.09
Construction (30-year amortization) 11.83
Total Annual Emissions 519.99
SCAQMD Tier 3 Significance Threshold 3,000 MTCO2e/year
Exceeds Threshold? No
1 MTCO2e = metric tons of carbon dioxide equivalents.

As shown in Table 22, the proposed project’s GHG emissions are not expected to exceed the SCAQMD GHG emissions threshold of 3,000 MTCO2e. Therefore, the proposed project’s impact from GHG emissions will be less than significant. r:,-n engine~ring
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8.0 Energy Impact Analysis

8.1 Study Objectives
The purpose of this energy conservation analysis is to review the energy implications of the proposed project and provide recommendations to reduce wasteful, inefficient, and unnecessary consumption of energy during the operation of the project. This analysis has been prepared within the context of the California Environmental Quality Act (CEQA, California Public Resources Code Sections 21000, et seq.).

CEQA Guidelines, Appendix F, Energy Conservation, describes the framework within which energy conservation should be analyzed. Conserving energy implies the wise and efficient use of energy through decreasing overall per capita energy consumption, decreasing reliance on fossil fuels (such as coal, natural gas, and oil), and increasing reliance on renewable energy sources.

8.2 Utility Providers
The proposed project would be served by the following utility providers, as shown in Table 23.

Table 23
Utility Providers
Utility Provider
Electricity Moreno Valley Utility
Natural Gas Southern California Gas Company

8.3 Project Energy Consumption
The three (3) main types of energy expected to be consumed by the project include electricity, natural gas, and petroleum products in the form of gasoline and diesel fuel.

CalEEMod is used to calculate energy usage associated with the construction and operation of the project. The CalEEMod calculation sheets for the project are provided in Appendix A.

8.3.1 Electricity Consumption
The project will use electricity for operational activities including, but not limited to, building heating and cooling, lighting, appliances, electronics, mechanical equipment, and parking lot lighting. Indirect electricity usage will also be required to supply, distribute, and treat water and wastewater. Electricity will be provided to the site by Southern California Edison. r:,-n engine~ring
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Temporary electricity usage for construction activities may include lighting, electric equipment, and mobile office uses. However, CalEEMod does not calculate electricity usage during construction. Electricity usage during construction is expected to be short-term and relatively minor compared to the operational demand. Therefore, construction-related electricity usage is not included in this analysis.

Table 24 shows the project’s estimated operational electricity consumption in kilowatt-hours per year (kWh/yr) and millions of BTU per year (MBTU/yr).

Table 24
Project Electricity Consumption1
Land Use/Activity
Electricity Consumption
(kWh/yr)2(MBTU/yr)3
Single Family Housing 165,912.64 566.09
Parking Lot 51,508.80 175.75
Water Supply and Treatment 13,263.18 45.25
Total 230,684.62 787.09
1 Source: CalEEMod defaults.
2 kWh/yr = Kilowatt hours per year
MBTU/yr = Million British Thermal Units per year

8.3.2 Natural Gas Consumption
The project will use natural gas for such things as building heating and cooling and gas water heaters. Natural gas is not expected to be used during construction in any significant quantities and is not included in the overall calculation of the project’s natural gas consumption.

Table 25 shows the project’s estimated operational natural gas consumption in MBTU/yr. r:,-n engine~ring
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Table 25
Project Natural Gas Consumption1
Land Use/Activity Natural Gas Consumption
(MBTU/yr)2
Single Family Housing 1,315.88
Parking Lot -
Total 1,315.88
1 Source: CalEEMod Defaults.
2 MBTU/yr = Million British Thermal Units per year

8.3.3 Petroleum Consumption
The project’s energy consumption from petroleum products is primarily associated with transportation-related activities. This includes gasoline and diesel fuel usage for auto and truck trips during construction and operation and off-road equipment usage during construction.

Petroleum Consumption – Construction
Construction of the project is expected to consist of site preparation, grading, building construction, paving, and architectural coating phases. Construction activities will consume energy in the form of motor vehicle fuel (gasoline and diesel) for off-road construction equipment and on-road vehicle trips. Vehicle trips include workers and vendors traveling to and from the project site.

Tables 26 and 27 show the project’s energy consumption for all off-road and on-road equipment during construction, respectively. For the purposes of this analysis, all off-road equipment is assumed to run on diesel fuel.
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Phase1
Phase
Duration
(Days)1
Equipment1 Amount1 Hours/ Day1 Horspower (HP)1 Load Factor1 HP-hrs2 Fuel
Consumption
Rate3
(hp-hr/gal)
Diesel Fuel
Consumption
(gal.)
Diesel Fuel
Consumption
by Phase
(gal.)
MBtu4
Rubber Tired Dozers 3 8 367 0.40 17,616.0 952.2
Tractors/Loaders/Backhoes 4 8 84 0.37 4,972.8 268.8
Graders 1 8 148 0.41 3,883.5 209.9
Excavators 1 8 36 0.38 875.5 47.3
Tractors/Loaders/Backhoes 3 8 84 0.37 5,967.4 322.6
Rubber Tired Dozers 1 8 367 0.40 9,395.2 507.8
Cranes 1 7 367 0.29 171,352.3 9,262.3
Forklifts 3 8 82 0.20 90,528.0 4,893.4Generator Sets 1 8 14 0.74 19,062.4 1,030.4 Welders 1 8 46 0.45 38,088.0 2,058.8Tractors/Loaders/Backhoes 3 7 84 0.37 150,116.4 8,114.4 Tractors/Loaders/Backhoes 1 8 84 0.37 4,475.5 241.9
Cement and Mortar Mixers 2 6 10 0.56 1,209.6 65.4
Pavers 1 8 81 0.42 4,898.9 264.8
Paving Equipment 2 6 89 0.36 6,920.6 374.1
Rollers 2 6 36 0.38 2,954.9 159.7
Architectural Coating 18 Air Compressors 1 6 37 0.48 1,918.1 103.7 103.68 14.24 28,877.57 3,967.22
1 Source: CalEEMod Defaults (CalEEMod v.2022.1.1)2 HP-hrs = Horsepower Hours.3 Source: Carl Moyer Program Guidelines. 2017 Revisions. Table D-21. https://www.arb.ca.gov/msprog/moyer/guidelines/current.htm4 Mbtu = Millions of Btu; assuming 1 gallon of diesel fuel = 137,381 Btu. 25,359.30
Table 26
Construction Off-Road Equipment Energy Consumption
167.74
1,087.65 149.42
3,483.89
1,105.92 151.93
Total Energy Requirements

18.5 Site Preparation 5 1,221.02
Grading 8
Building Construction
Paving 18
230
544
Fuel Split2
Fuel
Consumption
by Veh. Class
(gal.)
Fuel
Consumption
by Phase
(gal.) Fuel Split2
Fuel
Consumption
by Veh. Class
(gal.)
Fuel
Consumption
by Phase
LDA 0.50 26.25 0.9987 0.00 0.0013 0.00
LDT1 0.25 22.26 0.9998 0.00 0.0002 0.00LDT2 0.25 22.37 0.9987 0.00 0.0013 0.00 LDA 0.50 26.25 0.9987 31.67 0.0013 0.04
LDT1 0.25 22.26 0.9998 18.69 0.0002 0.00LDT2 0.25 22.37 0.9987 18.58 0.0013 0.02 LDA 0.50 26.25 0.9987 42.23 0.0013 0.05
LDT1 0.25 22.26 0.9998 24.93 0.0002 0.00LDT2 0.25 22.37 0.9987 24.77 0.0013 0.03 LDA 0.50 26.25 0.9987 1,133.23 0.0013 1.46
LDT1 0.25 22.26 0.9998 668.83 0.0002 0.11
LDT2 0.25 22.37 0.9987 664.79 0.0013 0.86
LDA 0.50 26.25 0.9987 126.70 0.0013 0.16
LDT1 0.25 22.26 0.9998

74.78 0.0002 0.01
LDT2 0.25 22.37 0.9987

74.32 0.0013 0.10
LDA 0.50 26.25 0.9987 19.00 0.0013 0.02
LDT1 0.25 22.26 0.9998

11.22 0.0002 0.00
LDT2 0.25 22.37 0.9987 11.15 0.0013 0.01
2,944.90 2.89 355.04
MHDT 0.50 7.62 0.3562 219.81 0.6438 396.48
HHDT 0.50 6.39 0.0006 0.41 0.9994 733.91
219.81 1,130.39 181.77
Grading 8 125 20.0 20000 HHDT 1.00 6.39 0.0006 1.76 1.76 0.9994 3,128.35 3,128.35 429.99

1.76 3,128.35 429.99
3,166.47 4,261.63 966.80
1 Source: CalEEMod Defaults (CalEEMod v.2022.1.1)2 Source: EMFAC2021 Web Database. https://www.arb.ca.gov/emfac/2021/. (See Appendix C for more details.)3 Mbtu = Millions of Btu; assuming 1 gallon of gasoline fuel = 120,429 Btu and 1 gallon of diesel fuel = 137,381 Btu Sub-Total Hauling Trips Energy Consumption Gasoline (gal.) Diesel (gal.) Table 27
Construction On-Road Trips Energy Consumption
Total On-Road Construction Trips Energy Consumption Gasoline (gal.) Diesel (gal.) 1,130.39 181.77
Hauling Trips
Vendor TripsWorker Trips
Building
Construction 230 4 10.2
Sub-Total Worker Trips Energy Consumption Gasoline (gal.) Architectural
Coating 18 3 18.5 999

0.27 33.25. 4.99
Diesel (gal.)

41.37 0.04

11.08 Building
Construction 230 14 18.5 59,570 2,466.85

18.5 2.42 297.41
Phase
Duration
(Days)1
Gasoline Diesel
Construction
Phase1
Grading 8 15
Trips /Day1
Demolition 0 0
Site Preparation 5 18

0.090.00
Trip Length Phase VMT 1

0.07 8.31

0.00 0.00
Total MBtu3
Average Fuel
Economy
(MPG)2
Vehicle
Mix1 Vehicle Class1
Sub-Total Vendor Trips Energy Consumption Gasoline (gal.) Diesel (gal.) 0 0

18.5 1,665 68.95
2,220 91.93
Paving 18 20 18.5 6,660 275.80
9,384 219.81

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Petroleum Consumption – Operation
The project is expected to consume energy from auto and truck trips generated by the proposed land uses. Operational vehicle trips are associated with workers, customers, and vendors/nonworkers (i.e., delivery, service, maintenance, etc.) traveling to and from the site.

Table 28 shows the project’s annual petroleum energy consumption for all operational trips. r:,-n enuine~ring L.U,,,U group, me.
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Fuel Split
Fuel
Consumption
(gal.) Fuel Split
Fuel
Consumption
(gal.)
LDA 26.25 0.0013 28.36
LDT1 22.26 0.0002 0.33LDT2 22.37 0.0013 13.57
MDV 18.35 0.0251 255.69
LHD1 15.69

0.2487 594.11
LHD2 16.25 0.6259 165.78
MHD 7.62 0.6438 576.88
HHD 6.39 0.9994 1,168.22
OBUS 6.14 0.4294 20.24
2,664.14
247.17
1,267.221,230.26
297.75

34.71 117.70160.57

6.02 UBUS 5.11 0.0153 0.55
MCY 39.10 0.0000 0.00
SBUS 8.50 0.3776 28.19
MH

51.11%

4.02%

20.72%16.44%

3.30%

0.38%0.60%0.66%0.03%0.02%2.41%0.06%0.27% 5.72

0.9987 22,089.75

0.9998 2,052.02

0.9987 10,507.080.9749 9,923.99

0.7513 1,794.710.3741 99.10

0.3562 319.22

0.0006 0.66

0.5406 26.89

0.9847 35.581.0000 700.99

0.6224 46.45

0.8345 439.50 0.1655 87.19

4.36 84.42

9.47 64.91
Gasoline
Consumption
(gal.)
48,035.94
Diesel
Consumption
(gal.)
2,939.11 6,188.70
Table 28
Operational Trips Energy Consumption - Annual
Total Operational Trips Energy Usage
Diesel
MBtu
Annual
VMT
Vehicle
Class Vehicle Mix
Average
Fuel
Economy
(MPG)
Gasoline
1,136,007
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8.4 Summary of Project Energy Consumption
Table 29 provides a summary of the project’s annual operational energy consumption.

Table 29
Annual Energy Consumption
Activity Energy Consumption
(MBTU/yr)1
Electricity 787.09
Natural Gas 1,315.88
Petroleum 6,134.89
Total 8,237.86
1 MBTU/yr = Million British Thermal Units per year.

8.5 Energy Impacts
This analysis has been prepared within the context of the CEQA Guidelines, Appendix F, Energy Conservation, and Appendix G, Environmental Checklist Form. According to CEQA, the goal of conserving energy includes the wise and efficient use of energy through decreasing overall per capita energy consumption, decreasing reliance on fossil fuels (such as coal, natural gas, and oil), and increasing reliance on renewable energy sources.

A significant environmental impact would result if the project would:
a) Result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation, or; b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

8.5.1 Energy Impact – A
Would the project result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation?
The project will implement the mandatory requirements of California’s Building Efficiency Standards (Title 24, Part 6) to reduce energy consumption. California’s building standards are some of the strictest in the nation and the project’s compliance with the Building Code would r:,-n engine~ring
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ensure that wasteful, inefficient, or unnecessary consumption of energy is minimized. The California Building Code is designed to reduce the amount of energy needed to heat or cool a building, reduce energy usage for lighting and appliances, and promote usage of energy from renewable sources.

In particular, the project will provide solar installations (or other sources of on-site renewable energy) to satisfy the prescribed Energy Design Ratings from the Energy Code.

By providing renewable sources of energy, the project satisfies recent court rulings which indicate that when determining if a project would have a potentially significant impact to energy conservation, the analysis should discuss whether any renewable energy features could be incorporated into the project7. Furthermore, by including rooftop solar panels, the proposed project ensures that wasteful, inefficient, or unnecessary consumption of energy is minimized.

Therefore, the project impact is considered less than significant under Criterion A.

8.5.2 Energy Impact – B
Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The project is not expected to conflict with or obstruct a state or local plan for renewable energy or energy efficiency. The project will purchase electricity through Southern California Edison which is subject to the requirements of California Senate Bill 100 (SB 100). SB 100 is the most stringent and current energy legislation in California, requiring that renewable energy resources and zerocarbon resources supply 100% of retail sales of electricity to California end-use customers and 100% of electricity procured to serve all state agencies by December 31, 20458.

The project will also comply with the mandatory requirements of California’s Green Building and Building Energy Efficiency standards that promote renewable energy and energy efficiency. Hence, the project impact is considered less than significant under Criterion B. 7 League to Save Lake Tahoe Mountain Area Preservation Foundation, et al. v. County of Placer, et al. 8 SB-100 California Renewables Portfolio Standard Program. http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100 r:,-n engine~ring
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Exhibits
550
engineering group, inc. TTM 37858 SINGLE GAMILY RESIDENTIAL PROJECT AIR QUALITY, GREENHOUSE GAS, AND ENERGY IMPACT STUDY, City of Moreno Valley, CA 1742-2024-03 Location Map Exhibit A Legend: = Project Site = Project Site Boundary N Northern Receptors Eastern Receptors Southern Receptors Western Receptors 551 Exhibit B
Site Plan
N
engineering
group, inc.
1742-2024-03
TTM 37858 SINGLE FAMILY RESIDENTIAL PROJECT AIR QUALITY, GREENHOUSE GAS, AND ENERGY IMPACT STUDY, City of Moreno Valley, CA
Obscured Area
~ ·
I ,- PARCEL 4 1 PM 81 14
, _PM_~_ 3N28 .
c.
~'--...... __

OWNER MJCHAEL W
DE LA 1'0RBK APN 478-090-0nr------
Tract Boundar
1569
552
Appendices
553
Appendix A
Emissions Calculations Outputs
(CalEEMod)
554
TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 1 / 39
TTM 37858 Single Family Residential Project Custom Report Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Site Preparation (2024) - Unmitigated

3.3. Grading (2024) - Unmitigated

3.5. Building Construction (2024) - Unmitigated

3.7. Building Construction (2025) - Unmitigated

3.9. Paving (2025) - Unmitigated
555
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3.11. Architectural Coating (2025) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type
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4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
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5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name TTM 37858 Single Family Residential Project Construction Start Date 9/1/2026
Operational Year 2027
Lead Agency City of Moreno Valley
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 24.0
Location 33.91120365283811, -117.1704668389395
County Riverside-South Coast
City Moreno Valley
Air District South Coast AQMD
Air Basin South Coast
TAZ 5583
EDFZ 11
Electric Utility Moreno Valley Utility
Gas Utility Southern California Gas
App Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Single Family
Housing

37.0 Dwelling Unit 3.46 72,150 22,887 0.00 120 —
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Parking Lot 58.8 1000sqft 1.35 0.00 0.00 0.00 — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.42 1.19 10.6 14.1 0.02 0.43 0.26 0.64 0.40 0.06 0.45 — 2,706 2,706 0.11 0.04 1.04 2,723 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 26.2 26.1 36.1 34.0 0.09 1.60 7.89 9.49 1.47 3.99 5.47 — 11,916 11,916 0.29 1.44 0.50 12,354 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.03 1.91 5.52 7.28 0.01 0.23 0.25 0.37 0.21 0.11 0.23 — 1,390 1,390 0.06 0.04 0.26 1,398 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.37 0.35 1.01 1.33 < 0.005 0.04 0.05 0.07 0.04 0.02 0.04 — 230 230 0.01 0.01 0.04 231

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
-------------------
-------------------
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2025 1.42 1.19 10.6 14.1 0.02 0.43 0.26 0.64 0.40 0.06 0.45 — 2,706 2,706 0.11 0.04 1.04 2,723 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2024 4.43 3.73 36.1 34.0 0.09 1.60 7.89 9.49 1.47 3.99 5.47 — 11,916 11,916 0.29 1.44 0.50 12,354 2025 26.2 26.1 10.6 13.9 0.02 0.43 0.21 0.64 0.40 0.05 0.45 — 2,691 2,691 0.11 0.04 0.03 2,707 Average
Daily
— — — — — — — — — — — — — — — — — —
2024 0.34 0.28 2.80 3.02 0.01 0.12 0.25 0.37 0.11 0.11 0.21 — 733 733 0.03 0.04 0.26 746 2025 2.03 1.91 5.52 7.28 0.01 0.23 0.11 0.34 0.21 0.03 0.23 — 1,390 1,390 0.06 0.02 0.24 1,398 Annual — — — — — — — — — — — — — — — — — —
2024 0.06 0.05 0.51 0.55 < 0.005 0.02 0.05 0.07 0.02 0.02 0.04 — 121 121 < 0.005 0.01 0.04 123 2025 0.37 0.35 1.01 1.33 < 0.005 0.04 0.02 0.06 0.04 < 0.005 0.04 — 230 230 0.01 < 0.005 0.04 231

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.24 3.12 1.19 12.4 0.03 0.04 2.19 2.23 0.04 0.56 0.60 21.2 3,094 3,115 2.28 0.10 8.18 3,209 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.98 2.87 1.24 8.76 0.02 0.04 2.19 2.23 0.04 0.56 0.60 21.2 2,930 2,951 2.29 0.10 0.72 3,039 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.10 2.98 1.27 10.5 0.02 0.04 2.16 2.20 0.04 0.55 0.59 21.2 2,957 2,978 2.29 0.10 3.83 3,069 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.57 0.54 0.23 1.92 < 0.005 0.01 0.39 0.40 0.01 0.10 0.11 3.51 490 493 0.38 0.02 0.63 508 -------------------
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2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.33 1.24 0.84 10.1 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,381 2,381 0.09 0.09 7.66 2,417 Area 1.87 1.86 0.02 2.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 5.61 5.61 < 0.005 < 0.005 — 5.63 Energy 0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 692 692 0.06 < 0.005 — 694 Water — — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1 Waste — — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1 Refrig. — — — — — — — — — — — — — — — — 0.52 0.52
Total 3.24 3.12 1.19 12.4 0.03 0.04 2.19 2.23 0.04 0.56 0.60 21.2 3,094 3,115 2.28 0.10 8.18 3,209 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.26 1.17 0.90 8.62 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,223 2,223 0.10 0.09 0.20 2,252 Area 1.68 1.68 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Energy 0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 692 692 0.06 < 0.005 — 694 Water — — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1 Waste — — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1 Refrig. — — — — — — — — — — — — — — — — 0.52 0.52
Total 2.98 2.87 1.24 8.76 0.02 0.04 2.19 2.23 0.04 0.56 0.60 21.2 2,930 2,951 2.29 0.10 0.72 3,039 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 1.25 1.16 0.92 8.92 0.02 0.01 2.16 2.17 0.01 0.55 0.56 — 2,246 2,246 0.10 0.09 3.31 2,279 Area 1.81 1.80 0.01 1.44 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 3.84 3.84 < 0.005 < 0.005 — 3.86 Energy 0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 692 692 0.06 < 0.005 — 694 Water — — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1 Waste — — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1 -------------------
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Refrig. — — — — — — — — — — — — — — — — 0.52 0.52
Total 3.10 2.98 1.27 10.5 0.02 0.04 2.16 2.20 0.04 0.55 0.59 21.2 2,957 2,978 2.29 0.10 3.83 3,069 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.23 0.21 0.17 1.63 < 0.005 < 0.005 0.39 0.40 < 0.005 0.10 0.10 — 372 372 0.02 0.02 0.55 377 Area 0.33 0.33 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.64 0.64 < 0.005 < 0.005 — 0.64 Energy 0.01 < 0.005 0.06 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 115 115 0.01 < 0.005 — 115 Water — — — — — — — — — — — 0.48 2.59 3.07 0.05 < 0.005 — 4.65 Waste — — — — — — — — — — — 3.04 0.00 3.04 0.30 0.00 — 10.6 Refrig. — — — — — — — — — — — — — — — — 0.09 0.09
Total 0.57 0.54 0.23 1.92 < 0.005 0.01 0.39 0.40 0.01 0.10 0.11 3.51 490 493 0.38 0.02 0.63 508

3. Construction Emissions Details

3.1. Site Preparation (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

4.34 3.65 36.0 32.9 0.05 1.60 — 1.60 1.47 — 1.47 — 5,296 5,296 0.21 0.04 — 5,314 Dust
From
Material
Movement
— — — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
-------------------
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Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.06 0.05 0.49 0.45 < 0.005 0.02 — 0.02 0.02 — 0.02 — 72.5 72.5 < 0.005 < 0.005 — 72.8 Dust
From
Material
Movement
— — — — — — 0.11 0.11 — 0.05 0.05 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.09 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.0 12.0 < 0.005 < 0.005 — 12.1 Dust
From
Material
Movement
— — — — — — 0.02 0.02 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.10 1.10 0.00 0.00 0.23 0.23 0.00 0.05 0.05 — 231 231 0.01 0.01 0.03 234 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 565
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Average — — — — — — — — — — — — — — — — — —
Daily
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.21 3.21 < 0.005 < 0.005 0.01 3.26 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.53 0.53 < 0.005 < 0.005 < 0.005 0.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.26 1.90 18.2 18.8 0.03 0.84 — 0.84 0.77 — 0.77 — 2,958 2,958 0.12 0.02 — 2,969 Dust
From
Material
Movement
— — — — — — 2.78 2.78 — 1.34 1.34 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
-------------------
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Off-Roa 0.05 0.04 0.40 0.41 < 0.005 0.02 — 0.02 0.02 — 0.02 — 64.8 64.8 < 0.005 < 0.005 — 65.1 d
Dust
From
Material
Movement
— — — — — — 0.06 0.06 — 0.03 0.03 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.07 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 — 10.8 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.09 0.95 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 198 198 0.01 0.01 0.02 201 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.35 0.13 10.3 2.43 0.06 0.17 2.26 2.43 0.17 0.63 0.80 — 8,759 8,759 0.16 1.41 0.48 9,184 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.40 4.40 < 0.005 < 0.005 0.01 4.47 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.23 0.05 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 192 192 < 0.005 0.03 0.17 201 Annual — — — — — — — — —567 — — — — — — — — —
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Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.73 0.73 < 0.005 < 0.005 < 0.005 0.74 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.04 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 31.8 31.8 < 0.005 0.01 0.03 33.3

3.5. Building Construction (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.44 1.20 11.2 13.1 0.02 0.50 — 0.50 0.46 — 0.46 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.21 0.18 1.65 1.92 < 0.005 0.07 — 0.07 0.07 — 0.07 — 352 352 0.01 < 0.005 — 353 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.04 0.03 0.30 0.35 < 0.005 0.01 — 0.01 0.01 — 0.01 — 58.3 58.3 < 0.005 < 0.005 — 58.5 -------------------
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Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.08 0.84 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 176 176 0.01 0.01 0.02 178 Vendor 0.01 < 0.005 0.15 0.04 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 123 123 < 0.005 0.02 0.01 128 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 26.2 26.2 < 0.005 < 0.005 0.05 26.6 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 18.0 18.0 < 0.005 < 0.005 0.02 18.9 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.34 4.34 < 0.005 < 0.005 0.01 4.40 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.98 2.98 < 0.005 < 0.005 < 0.005 3.12 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
------------------- — — — — — — — — — — — — — — — — — — 569
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Off-Roa 1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 d
Equipm
ent
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.65 0.54 5.05 6.30 0.01 0.21 — 0.21 0.19 — 0.19 — 1,159 1,159 0.05 0.01 — 1,163 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.92 1.15 < 0.005 0.04 — 0.04 0.04 — 0.04 — 192 192 0.01 < 0.005 — 193 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 1.03 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 188 188 0.01 0.01 0.69 191 Vendor 0.01 < 0.005 0.13 0.04 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 121 121 < 0.005 0.02 0.34 127 570
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.78 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 173 173 0.01 0.01 0.02 175 Vendor 0.01 < 0.005 0.14 0.04 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 121 121 < 0.005 0.02 0.01 127 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.03 0.40 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 84.5 84.5 < 0.005 < 0.005 0.14 85.7 Vendor < 0.005 < 0.005 0.07 0.02 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 58.5 58.5 < 0.005 0.01 0.07 61.3 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 < 0.005 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 14.0 14.0 < 0.005 < 0.005 0.02 14.2 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.69 9.69 < 0.005 < 0.005 0.01 10.1 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.85 0.71 6.52 8.84 0.01 0.29 — 0.29 0.26 — 0.26 — 1,351 1,351 0.05 0.01 — 1,355 Paving 0.20 0.20 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 -------------------
571
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.04 0.04 0.32 0.44 < 0.005 0.01 — 0.01 0.01 — 0.01 — 66.6 66.6 < 0.005 < 0.005 — 66.8 Paving 0.01 0.01 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.06 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.0 11.0 < 0.005 < 0.005 — 11.1 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.11 0.09 0.09 1.54 0.00 0.00 0.26 0.26 0.00 0.06 0.06 — 282 282 0.01 0.01 1.04 286 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 12.9 12.9 < 0.005 < 0.005 0.02 13.1 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 572
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.14 2.14 < 0.005 < 0.005 < 0.005 2.17 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

26.0 26.0 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 6.58 6.58 < 0.005 < 0.005 — 6.61 -------------------
573
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Architect 1.28 1.28 — — — — — — — — — — — — — — — —
ural
Coating
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.09 1.09 < 0.005 < 0.005 — 1.09 Architect
ural
Coating
s

0.23 0.23 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.16 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 34.5 34.5 < 0.005 < 0.005 < 0.005 35.0 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.72 1.72 < 0.005 < 0.005 < 0.005 1.75 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.29 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 574 TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 21 / 39
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

1.33 1.24 0.84 10.1 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,381 2,381 0.09 0.09 7.66 2,417 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.33 1.24 0.84 10.1 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,381 2,381 0.09 0.09 7.66 2,417 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

1.26 1.17 0.90 8.62 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,223 2,223 0.10 0.09 0.20 2,252 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.26 1.17 0.90 8.62 0.02 0.01 2.19 2.21 0.01 0.56 0.57 — 2,223 2,223 0.10 0.09 0.20 2,252 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.23 0.21 0.17 1.63 < 0.005 < 0.005 0.39 0.40 < 0.005 0.10 0.10 — 372 372 0.02 0.02 0.55 377 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 575
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Total 0.23 0.21 0.17 1.63 < 0.005 < 0.005 0.39 0.40 < 0.005 0.10 0.10 — 372 372 0.02 0.02 0.55 377

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 206 206 0.02 < 0.005 — 207
Parking
Lot
— — — — — — — — — — — — 64.0 64.0 < 0.005 < 0.005 — 64.2 Total — — — — — — — — — — — — 270 270 0.02 < 0.005 — 271 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 206 206 0.02 < 0.005 — 207
Parking
Lot
— — — — — — — — — — — — 64.0 64.0 < 0.005 < 0.005 — 64.2 Total — — — — — — — — — — — — 270 270 0.02 < 0.005 — 271 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 34.1 34.1 < 0.005 < 0.005 — 34.3 Parking
Lot
— — — — — — — — — — — — 10.6 10.6 < 0.005 < 0.005 — 10.6 Total — — — — — — — — — — — — 44.7 44.7 < 0.005 < 0.005 — 44.9 576
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4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 422 422 0.04 < 0.005 — 423 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 422 422 0.04 < 0.005 — 423 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 422 422 0.04 < 0.005 — 423 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.04 0.02 0.33 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 422 422 0.04 < 0.005 — 423 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.01 < 0.005 0.06 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 69.8 69.8 0.01 < 0.005 — 70.0 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.01 < 0.005 0.06 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 69.8 69.8 0.01 < 0.005 — 70.0

4.3. Area Emissions by Source

4.3.1. Unmitigated
577
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Product
s

1.55 1.55 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.13 0.13 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.19 0.18 0.02 2.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 5.61 5.61 < 0.005 < 0.005 — 5.63 Total 1.87 1.86 0.02 2.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 5.61 5.61 < 0.005 < 0.005 — 5.63 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Product
s

1.55 1.55 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.13 0.13 — — — — — — — — — — — — — — — —
Total 1.68 1.68 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 -------------------
578
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Consum 0.28 0.28 — — — — — — — — — — — — — — — —
er
Product
Architect
ural
Coating
s

0.02 0.02 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.02 0.02 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.64 0.64 < 0.005 < 0.005 — 0.64 Total 0.33 0.33 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.64 0.64 < 0.005 < 0.005 — 0.64

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1
579
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Parking — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Lot
Total — — — — — — — — — — — 2.88 15.6 18.5 0.30 0.01 — 28.1 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 0.48 2.59 3.07 0.05 < 0.005 — 4.65 Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.48 2.59 3.07 0.05 < 0.005 — 4.65

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
580
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Total — — — — — — — — — — — 18.3 0.00 18.3 1.83 0.00 — 64.1 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 3.04 0.00 3.04 0.30 0.00 — 10.6
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 3.04 0.00 3.04 0.30 0.00 — 10.6

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 0.52 0.52
Total — — — — — — — — — — — — — — — — 0.52 0.52
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 0.52 0.52
Total — — — — — — — — — — — — — — — — 0.52 0.52
Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 0.09 0.09
Total — — — — — — — — —581 — — — — — — — 0.09 0.09
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4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — —582 — — — — — — — — —
TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 29 / 39
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
583
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
-------------------
584
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Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data
585
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5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 10/1/2024 10/7/2024 5.00 5.00 — Grading Grading 10/8/2024 10/17/2024 5.00 8.00 —
Building Construction Building Construction 10/18/2024 9/4/2025 5.00 230 — Paving Paving 9/5/2025 9/30/2025 5.00 18.0 —
Architectural Coating Architectural Coating 10/1/2025 10/24/2025 5.00 18.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 7.00 84.0 0.37
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
586
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Paving Cement and Mortar Diesel Average 2.00 6.00 10.0 0.56 Mixers
Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 17.5 18.5 LDA,LDT1,LDT2
Site Preparation Vendor — 10.2 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 18.5 LDA,LDT1,LDT2
Grading Vendor — 10.2 HHDT,MHDT
Grading Hauling 125 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 13.3 18.5 LDA,LDT1,LDT2
Building Construction Vendor 3.96 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 18.5 LDA,LDT1,LDT2
Paving Vendor — 587 10.2 HHDT,MHDT
TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 34 / 39
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 2.66 18.5 LDA,LDT1,LDT2
Architectural Coating Vendor — 10.2 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%
Limit vehicle speeds on unpaved roads to 25 mph 44% 44% Sweep paved roads once per month 9% 9%

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 146,104 48,701 0.00 0.00 3,528

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation 0.00 0.00 7.50 0.00 —
Grading 0.00 8,000 8.00 0.00 —
588
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Paving 0.00 0.00 0.00 0.00 1.76

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Single Family Housing 0.41 0%
Parking Lot 1.35 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2024 0.00 453 0.03 < 0.005
2025 0.00 453 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Single Family
Housing
349 349 349 127,352 3,112 3,112 3,112 1,136,007
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources
589
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5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Single Family Housing —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 37
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
146103.75 48,701 0.00 0.00 3,528

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
590
TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 37 / 39
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 165,913 453 0.0330 0.0040 1,315,880 Parking Lot 51,509 453 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 1,504,930 443,532
Parking Lot 0.00 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Single Family Housing 34.0 —
Parking Lot 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Single Family Housing Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00
591
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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
592
TTM 37858 Single Family Residential Project Custom Report, 9/19/2025 39 / 39

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

8. User Changes to Default Data
Screen Justification
Land Use Project consists of 37 single-family detached homes and approximately 58.8 TSF of paved surfaces on a total site of approximately 4.81 acres.

Construction: Construction Phases The project site is currently vacant, and no demolition will be required.

Operations: Vehicle Data Trip generation rates are adjusted to reflect 349 daily trips, based on the Cactus Avenue and Bradshaw Circle Residential Project Trip Generation and VMT Screening Analysis, City of Moreno Valley, prepared by RK.

Operations: Fleet Mix Fleet mix is adjusted to reflect a total of 2% heavy trucks (GVWR > 10,000 lbs.).

Operations: Hearths Per SCAQMD Rule 445, no wood-burning devices shall be allowed. The project will not include any gas fireplaces.

Operations: Energy Use Energy usage is adjusted to account for electricity generated by onsite solar panels.

Construction: Off-Road Equipment Project will utilize Tier 4 low emission engines (OEM or retrofit) that include diesel oxidation catalysts and diesel particulate filters that meet the latest CARB best available control technology.
593
Appendix B
EMFAC2021 Vehicle Fuel Consumption Data
594
Source: EMFAC2025 (v2.0.0) Emissions Inventory
Region Type: Air District
Region: South Coast AQMD
Calendar Year: 2027
Season: Annual
Vehicle Classification: EMFAC2007 Categories
Units: miles/day for Combustion VMT and Electric VMT, trips/day for Trips, tons/day for Emissions, 1000 gallons/day for Fuel Consumption, kWh/day for Energy Consumption, kg/day for Hydrogen Consumption Region Calendar Year Vehicle Category Model Year Speed Fuel Population Total VMT Fuel Consumption Fuel Split
(Gas:Diesel)
MPG,
by Fuel Type
MPG,
Average
South Coast AQMD 2027 HHDT Aggregate Aggregate Gasoline 119.9786149 5039.865379 1.292650238 0.000563395 3.898862376 6.389554723 South Coast AQMD 2027 HHDT Aggregate Aggregate Diesel 104694.0021 14655111.19 2293.100573 0.999436605 6.390958758 South Coast AQMD 2027 LDA Aggregate Aggregate Gasoline 4365511.132 122279941.4 4660.5255 0.998717608 26.23737203 26.24952527 South Coast AQMD 2027 LDA Aggregate Aggregate Diesel 9374.916105 213725.4271 5.984296501 0.001282392 35.71437796 South Coast AQMD 2027 LDT1 Aggregate Aggregate Gasoline 459882.6443 13188498.87 592.399392 0.999836848 22.2628501 22.2628013 South Coast AQMD 2027 LDT1 Aggregate Aggregate Diesel 100.2449672 2123.159791 0.096666669 0.000163152 21.96372153 South Coast AQMD 2027 LDT2 Aggregate Aggregate Gasoline 2600590.744 87049580.58 3892.623714 0.998710425 22.36270109 22.37298592 South Coast AQMD 2027 LDT2 Aggregate Aggregate Diesel 4676.709905 152488.5502 5.026311659 0.001289575 30.33806111 South Coast AQMD 2027 LHDT1 Aggregate Aggregate Gasoline 191914.015 6082376.492 432.8421995 0.751295699 14.05217999 15.68707413 South Coast AQMD 2027 LHDT1 Aggregate Aggregate Diesel 90403.37187 2955380.11 143.2854155 0.248704301 20.62582643 South Coast AQMD 2027 LHDT2 Aggregate Aggregate Gasoline 39728.80291 1417530.56 108.3207185 0.374131726 13.08642133 16.2498921 South Coast AQMD 2027 LHDT2 Aggregate Aggregate Diesel 78414.06531 3287229.466 181.2048979 0.625868274 18.14095261 South Coast AQMD 2027 MCY Aggregate Aggregate Gasoline 254728.5887 1430122.847 36.57939924 1 39.09640062 39.09640062 South Coast AQMD 2027 MDV Aggregate Aggregate Gasoline 1618820.697 53179824.35 2922.694912 0.974882352 18.19547574 18.34514026 South Coast AQMD 2027 MDV Aggregate Aggregate Diesel 47020.27838 1818861.373 75.30264779 0.025117648 24.15401618 South Coast AQMD 2027 MH Aggregate Aggregate Gasoline 33466.17076 288683.0254 59.46696905 0.834461628 4.854510495 5.719692219 South Coast AQMD 2027 MH Aggregate Aggregate Diesel 13701.47309 118924.4054 11.79690586 0.165538372 10.08098283 South Coast AQMD 2027 MHDT Aggregate Aggregate Gasoline 32148.25779 1407853.777 264.8952811 0.356230844 5.314755971 7.61846648 South Coast AQMD 2027 MHDT Aggregate Aggregate Diesel 116061.9004 4257281.212 478.7104043 0.643769156 8.893228919 South Coast AQMD 2027 OBUS Aggregate Aggregate Gasoline 5068.871427 139612.4062 27.61773216 0.570608264 5.05517272 6.138127489 South Coast AQMD 2027 OBUS Aggregate Aggregate Diesel 2755.436213 157476.1075 20.78277992 0.429391736 7.577239816 South Coast AQMD 2027 SBUS Aggregate Aggregate Gasoline 2717.237286 100365.3766 10.92072148 0.622377463 9.190361344 8.495522141 South Coast AQMD 2027 SBUS Aggregate Aggregate Diesel 2489.694284 48703.69586 6.626060217 0.377622537 7.35032497 South Coast AQMD 2027 UBUS Aggregate Aggregate Gasoline 822.035363 51797.79747 10.18350243 0.984652985 5.086442293 5.106599397 South Coast AQMD 2027 UBUS Aggregate Aggregate Diesel 13.70031546 1015.80099 0.158722274 0.015347015 6.399864133 595
CADRE
Environmental October 2025
Bradshaw Collection Tentative Tract Map 37858
City of Moreno Valley, California
Prepared for:

RC Hobbs Companies
1428 East Chapman Avenue
Orange, CA 92866
Contact: Shay Mueller (714) 633-8100
Prepared by:

Cadre Environmental
701 Palomar Airport Road, Suite 300
Carlsbad, CA 92011
Contact: Ruben Ramirez, (949) 300-0212

FINAL REPORT
Biological Resources Technical Report
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Biological Resources Technical Report TTM 37858
Cadre Environmental October 2025
i

TABLE OF CONTENTS
PAGE
INTRODUCTION 1
PROJECT LOCATION & DESCRIPTION 1
METHODOLOGY 1
LITERATURE REVIEW 1
FIELD SURVEYS 2
EXISTING ENVIRONMENTAL SETTING 6
SURROUNDING LAND USES/TOPOGRAPHY/SOILS 6
VEGETATION COMMUNITIES 6
GENERAL WILDLIFE SPECIES 14
JURISDICTIONAL RESOURCES 14
SENSITIVE BIOLOGICAL RESOURCES 15
FEDERAL PROTECTION AND CLASSIFICATIONS 16
STATE PROTECTION AND CLASSIFICATIONS 17
SENSITIVE HABITATS 20
SENSITIVE PLANTS 20
SENSITIVE WILDLIFE 23
REGIONAL CONNECTIVITY/WILDLIFE MOVEMENT CORRIDORS 37
REGIONAL AND REGULATORY SETTING 38
MSHCP COMPLIANCE ANALYSIS 38
LOCAL 42
FEDERAL 45
STATE 47
ENVIRONMENTAL IMPACTS 49
THRESHOLD OF SIGNIFICANCE 49
DIRECT IMPACTS 51
INDIRECT IMPACTS 56
CUMULATIVE IMPACTS 57
CONSERVATION MEASURES 58
LITERATURE CITED 60
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ii

LIST OF FIGURES
PAGE
1 – Regional Location Map 7
2 – Project Site Map 8
3 – MSHCP Relationship Map 9
4 – Vegetation Communities Map 10
5 – Current Project Site Photographs 11
6 – Current Project Site Photographs 12
7 – Soils Association Map 13
8 – Vegetation Communities Impact Map 54

LIST OF TABLES
PAGE
1 – Vegetation Communities Acreages 14
2 – Sensitive Plant Species with Potential to Occur Onsite 21 3 – Sensitive Wildlife Species with Potential to Occur Onsite 24 4 – Project Site Vegetation Community Impacts 55
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Cadre Environmental October 2025
iii

GLOSSARY
AMSL Above Mean Sea Level
APN Assessor’s Parcel Number
BMPs Best Management Practices
CAPSA Criteria Area Plant Survey Areas
CDFG California Department of Fish and Game (CDFW effective Jan 1st 2013) CDFW California Department of Fish and Wildlife
CESA California Endangered Species Act
CEQA California Environmental Quality Act
CNDDB California Natural Diversity Database
CNPS California Native Plant Society
CRPR California Rare Plant Ranking
CWA Clean Water Act
DBESP Determination of Biological Equivalent or Superior Preservation FESA federal Endangered Species Act
GIS Geographic Information System
HANS Habitat Acquisition and Negotiation Strategy
JPR Joint Project Review
MBTA Migratory Bird Treaty Act
MND Mitigated Negative Declaration
MSHCP Multiple Species Habitat Conservation Plan
NCCP Natural Communities Conservation Plan
NEPS Narrow Endemic Plant Species
NEPSA Narrow Endemic Plant Survey Areas
NPDES National Pollutant Discharge Elimination System
NPPA Native Plant Protection Act
NWPR Navigable Water Protection Rule
OHWM Ordinary High-Water Mark
RCA Western Riverside County Regional Conservation Authority RCIP Riverside County Integrated Project
ROW Right of Way
RWQCB Regional Water Quality Control Board
SAA Streambed Alteration Agreement
SF Square Feet
SSC California Species of Special Concern
SWRCB State Water Resources Control Board
USACE United States Army Corps of Engineers
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
WDR Waste Discharge Requirements
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Biological Resources Technical Report TTM 37858
Cadre Environmental October 2025
1 INTRODUCTION
The following biological technical report describes a detailed assessment of potential sensitive natural resources located within and immediately adjacent to the Bradshaw Collection Tentative Tract Map (TTM) 37858 Project Site. Specifically, the report has been prepared to support the California Environmental Quality Act (CEQA), Mitigated Negative Declaration (MND) and Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) documentation, compliance, and review process conducted by the City of Moreno Valley. As discussed below, the assessment includes a thorough literature review, site reconnaissance characterizing baseline conditions (including floral and faunal and dominate vegetation communities), focused sensitive species surveys, impact analysis, and proposed mitigation/conservation measures.

PROJECT LOCATION & DESCRIPTION
The 4.81-acre Project Site (0.19-acre offsite impact area) is located within Assessor’s Parcel Numbers (APNs) 478-090-018, 478-090-024, and 478-090-025 (including rightsof-ways). The Project Site is located within United States Geological Survey (USGS) 7.5’ Series Sunnymead Quadrangle, Riverside County, Township 3 South, Range 3 West, Section 14. Specifically, the Project Site is located north of Cactus Avenue and east of Bradshaw Circle, City of Moreno Valley, Riverside County, California, as shown in Figure 1, Regional Location Map, and Figure 2, Project Site Map.

The Project Site is located within the Western Riverside County MSHCP Reche Canyon/Badlands Plan Area and is not located within an MSHCP Criteria Area Cell, Cell Group, or Linkage Area, as shown in Figure 3, MSHCP Relationship Map (Western Riverside County Regional Conservation Authority (RCA) Geographic Information System (GIS) Data Downloads 2024).

The Project Site is generally flat and dominated by ruderal/disturbed and non-native grassland.

The Project proposes thirty-seven (37) single family residential homes totaling 124,753 square feet (SF), including two (2) water quality management plan basins, and open space recreational area.

METHODOLOGY

LITERATURE REVIEW
Existing biological resource conditions within and adjacent to the Project Site were initially investigated through review of pertinent scientific literature. Federal register listings, protocols, and species data provided by the United States Fish and Wildlife Service (USFWS) were reviewed in conjunction with anticipated federally listed species potentially occurring within the Project Site. The California Natural Diversity Database (CNDDB 2024a), a California Department of Fish and Wildlife (CDFW) Natural Heritage Division species account database, was also reviewed for all pertinent information regarding the locations of known occurrences of sensitive species in the vicinity of the property. In 600
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2 addition, numerous regional floral and faunal field guides were utilized in the identification of species and suitable habitats. Combined, the sources reviewed provided an excellent baseline from which to inventory the biological resources potentially occurring in the area.

Other sources of information included the review of unpublished biological resource letter reports and assessments. Other CDFW reports and publications consulted include the following:
• Special Animals (CDFW 2024b);
• State and Federally Listed Endangered and Threatened Animals of California (CDFW 2024c);
• Endangered, Threatened, and Rare Plants of California (CDFW 2024d); • Special Vascular Plants and Bryophytes List (CDFW 2024e).

FIELD SURVEYS
Initial reconnaissance surveys of the Project Site were conducted by Gonzales Environmental Consulting, LLC on February 7th, 18th, 26th, March 1st, April 17th, May 17th, June 17th and Cadre Environmental on March 12th, 13th, 14th, and 15th, 2024 in order to characterize and identify potential wildlife habitats, sensitive resources, and to establish the accuracy of the data identified in the literature search and previous surveys.

Geologic and soil maps were examined to identify local soil types that may support sensitive taxa. Aerial photograph, topographic maps, and vegetation and rare plant maps prepared by previous studies in the region were used to determine community types and other physical features that may support sensitive plants/wildlife, uncommon taxa, or rare communities that occur within the Project Site.

The MSHCP has determined that the majority of sensitive species potentially occurring within the Project Site have been adequately covered (MSHCP Table 2-2 Species Considered for Conservation Under the MSHCP Since 1999, 2004). However, additional surveys may be required for narrow endemic plant, criteria area, and specific wildlife species if suitable habitat is documented onsite and/or if the property is located within a predetermined “Survey Area” (MSHCP 2004). Based on the initial MSHCP review of predetermined Survey Areas, habitat assessments and focused surveys (as warranted) were conducted for the following six (6) species.

Section 6.1.2 Riparian, Riverine, Vernal Pool Species
• Riverside fairy shrimp (Streptocephalus woottoni) [Federal Endangered FE]; • vernal pool fairy shrimp (Branchinecta lynchi) [Federally Threatened (FT)]; • least Bell's vireo (Vireo bellii pusillus) [FE/State Endangered (SE)]; • southwestern willow flycatcher (Empidonax traillii extimus) [FE/SE]; • western yellow-billed cuckoo (Coccyzus americanus occidentalis) [SE].

Wildlife Species
• burrowing owl (Athene cunicularia) [California Species of Special Concern (SSC)]. 601
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3 Vegetation Communities/Habitat Classification Mapping Natural community names and hierarchical structure follows the CDFW “List of California Terrestrial Natural Communities” and/or Holland (1986) classification systems, which have been refined and augmented where appropriate to better characterize the habitat types observed onsite when not addressed by the MSHCP classification system.

Floristic Plant Inventory
A general plant survey was conducted throughout the Project Site during the initial reconnaissance in a collective effort to identify all species occurring onsite. All plants observed during the survey efforts were either identified in the field or collected and later identified using taxonomic keys. Plant taxonomy follows Hickman (1993). Scientific nomenclature and common names used in this report generally follow Roberts et al. (2004) or Baldwin et al. (2012) for updated taxonomy. Scientific names are included only at the first mention of a species; thereafter, common names alone are used.

Wildlife Resources Inventory
All animals identified during the reconnaissance survey by sight, call, tracks, scat, or other characteristic sign were recorded onto a 1:200 scale orthorectified color aerial photograph or documented using a global positioning system (GPS). In addition to species actually detected, expected use of the site by other wildlife was derived from the analysis of habitats on the site, combined with known habitat preferences of regionally occurring wildlife species.

Vertebrate taxonomy followed in this report is according to the Center for North American Herpetology (2024 for amphibians and reptiles), the American Ornithologists’ Union (1988 and supplemental) for birds, and Baker et al. (2003) for mammals. Both common and scientific names are used during the first mention of a species; common names only are used in the remainder of the text.

Regional Connectivity/Wildlife Movement Corridors
The analysis of wildlife movement corridors associated with the Project Site and immediate vicinity is based on information compiled from literature, analysis of the aerial photograph and direct observations made in the field during the reconnaissance site visit.

A literature review was conducted that includes documents on island biogeography (studies of fragmented and isolated habitat “islands”), reports on wildlife home range sizes and migration patterns, and studies on wildlife dispersal. Wildlife movement studies conducted in southern California were also reviewed. Use of field-verified digital data, in conjunction with the GIS database, allowed proper identification of regional vegetation communities and drainage features. This information was crucial to assessing the relationship of the Project Site to large open space areas in the immediate vicinity and was also evaluated in terms of connectivity and habitat linkages. Relative to corridor issues, the discussions in this report are intended to focus on wildlife movement associated within the Project Site and the immediate vicinity. 602
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4 MSHCP Focused Burrowing Owl Survey Area
The Project Site is located almost completely within an MSHCP Survey Area for burrowing owl, as shown in Figure 3, MSHCP Relationship Map. Therefore, in accordance with the MSHCP Burrowing Owl Survey Instructions (2006), survey protocol consists of two steps, Step I – Habitat Assessment and Step II – Locating Burrows and Burrowing Owls. Step II is comprised of two parts, Part A: Focused Burrow Surveys and Part B: Focused Burrowing Owl Surveys. Each step is briefly outlined below, followed by the methodology and results of each survey conducted within the Project Site.

Step I – Habitat Assessment
Step 1 of the MSHCP habitat assessment for burrowing owl consists of a walking survey to determine if suitable habitat is present onsite. Initial habitat assessments were conducted by Gonzales Environmental Consulting ,LLC on February 7th, 2020 (Gonzales Environmental Consulting ,LLC 2020a). An updated habitat assessment was conducted by Cadre Environmental on March 12th, 2024. Upon arrival at the Project Site, and prior to initiating the assessment survey, Cadre Environmental used binoculars to scan all suitable habitats on and adjacent to the property, including perch locations, to ascertain owl presence.

All suitable areas of the Project Site were surveyed on foot by walking slowly and methodically while recording/mapping areas that may represent suitable owl habitat onsite. Primary indicators of suitable burrowing owl habitat in western Riverside County include, but are not limited to, native and non-native grassland, interstitial grassland within shrub lands, shrub lands with low density shrub cover, golf courses, drainage ditches, earthen berms, unpaved airfields, pastureland, dairies, fallow fields, and agricultural use areas. Burrowing owls typically use burrows made by fossorial mammals, such as California ground squirrels (Otospermophilus beecheyi) or American badgers (Taxidea taxus), but they often utilize man-made structures, such as earthen berms, cement culverts, cement, asphalt, rock, or wood debris piles, or openings beneath cement or asphalt pavement. Burrowing owls are often found within, under, or in close proximity to man-made structures.

According to the MSHCP guidelines, if suitable habitat is present the biologist should also walk the perimeter of the property, which consists of a 150-meter (approximately 500 feet) buffer zone around the Project Site boundary. If permission to access the buffer area cannot be obtained, the biologist shall not trespass, but visually inspect adjacent habitats with binoculars. Results from the habitat assessment indicated that suitable burrowing owl burrows potentially utilized for refugia and/or nesting were documented within and immediately adjacent to the property including foraging habitat documented throughout the Project Site. Accordingly, if suitable habitat is documented onsite, both Step II surveys and the 30-day pre-construction surveys are required in order to comply with the MSHCP guidelines for the species.

Step II – Locating Burrows and Burrowing Owls
Concurrent with the initial habitat assessments, a detailed focused burrow survey was conducted and included documentation of appropriately sized natural burrows or suitable 603
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5 man-made structures that may be utilized by burrowing owl - as part of the MSHCP protocol, which is described below under Part A. Focused Burrow Survey.

Part A: Focused Burrow Survey
A systematic survey for burrows, including burrowing owl sign, was conducted by walking across all suitable habitats mapped within the Project Site by Gonzales Environmental Consulting, LLC on February 7th, 2020 and Cadre Environmental on March 12th, 2024.

Pedestrian survey transects were spaced to allow 100% visual coverage of the ground surface. The distances between transect centerlines were no more than 20 meters (approximately 66 ft.) apart to the extent possible. Transect routes were also adjusted to account for topography and in general ground surface visibility. All observations of suitable burrows or dens, natural or man-made, or sightings of burrowing owl, were recorded and mapped during the survey.

Part B: Focused Burrowing Owl Surveys
Four (4) focused burrowing owl surveys were conducted during the spring of 2024 on March 12th, 13th, 14th, and 15th, 2024 from one hour before sunrise to two hours after sunrise as outlined in Table 1, Burrowing Owl Survey Schedule. Initial focused surveys were conducted by Gonzales Environmental Consulting, LLC on February 7th, 18th, 26th, March 1st, April 17th, May 17th, June 17th 2020 (Gonzales Environmental Consulting, LLC 2020b). During visual surveys, all potentially suitable burrow or structure entrances were investigated for signs of owl occupation, such as feathers, tracks, or pellets, and carefully observed to determine if burrowing owls utilize these features, when present. All burrows are monitored at a short distance from the entrance, and at a location that would not interfere with potential owl behavior, when present. In addition to monitoring potential burrow locations, all suitable habitats in the Project Site were walked along travel routes which allowed for visual assessments of all suitable habitats Jurisdictional Resources Assessment
A jurisdictional resources assessment was conducted by Gonzales Environmental Consulting, LLC on February 7th (Gonzales Environmental Consulting, LLC 2020a). An updated jurisdictional resources assessment was conducted by Cadre Environmental on March 12th, 2024. The assessment determined the boundaries or absence of potential wetland and non-wetland waters of the United States subject to the regulatory jurisdiction of the U.S. Army Corps of Engineers (USACE) pursuant to Clean Water Act (CWA) Section 404; wetland and non-wetland waters of the State subject to the regulatory jurisdiction of the Regional Water Quality Control Board (RWCQB) pursuant to CWA Section 401 and State Porter-Cologne Water Quality Control Act (Porter-Cologne); streambed and riparian habitat subject to the regulatory jurisdiction of the CDFW pursuant Sections 1600 et seq. of the California Fish and Game Code (CDFG Code); and MSHCP Section 6.1.2 Riparian, Riverine and Vernal Pool resources. All resources delineated as CDFW jurisdictional features were also defined as Western Riverside County MSHCP Section 6.1.2 resources. Wetlands are identified by the presence of three characteristics:
hydrophytic vegetation, wetland hydrology, and hydric soils. If any of these criteria were met, one or more transects were run to determine the extent of the wetland. Specifically, the presence of wetland hydrology was evaluated throughout the Project Site by recording 604
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6 the extent of observed surface flows, depth of inundation, depth to saturated soils, and depth to free water in the soil pits, where applicable. In addition, indicators of wetland or riverine hydrology were recorded, including water marks, drift lines, rack, debris, and sediment deposits, as warranted. Any indicators of hydric soils, such as redoximorphic features, buried organic matter, organic streaking, reduced soil conditions, gleyed or lowchroma soils, or sulfidic odor were also recorded.

MSHCP Riparian/Riverine/Vernal Pool Resources
Regulated activities within inland streams, wetlands and riparian areas in Western Riverside County California fall under the jurisdiction of the MSHCP. The MSHCP requires, among other things, assessments for riparian/riverine and vernal pool resources. As projects are proposed within the MSHCP Plan Area, an assessment of the potentially significant effects of those projects on riparian/riverine areas, and vernal pools are required, as currently mandated by CEQA, using available information augmented by project-specific mapping provided to and reviewed by the permittee’s biologist(s).

Riparian/riverine areas and vernal pools are defined for this section as follows in accordance with Section 6.1.2, Vol. I, of the Final MSHCP Plan: Riparian/Riverine Areas are lands which contain habitat dominated by trees, shrubs, persistent emergents, or emergent mosses and lichens, which occur close to or which depend upon soil moisture from a nearby fresh water source; or areas with fresh water flow during all or a portion of the year.” (MSHCP 2004). It is assumed the first part of the definition defines riparian habitat, and the second part defines riverine areas. Vernal pools are defined as:
“…seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season. Obligate hydrophytes and facultative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season”. (MSHCP 2004)

EXISTING ENVIRONMENTAL SETTING

SURROUNDING LAND USES/TOPOGRAPHY/SOILS
The Project Site is generally flat and primarily characterized as ruderal/disturbed and nonnative grassland habitats as illustrated in Figure 4, Vegetation Communities Map and Figures 5 and 6, Current Project Site Photographs. The Soil Survey of Western Riverside Area has the following soils mapped within the boundary of the Project Site as shown on Figure 7, Soils Association Map: SeC2 - San Emigdio fine sandy loam, 2 to 8 precent slopes eroded, SgC - San Emigdio loam, 2 to 8 percent slopes

VEGETATION COMMUNITIES
Natural community names follow the CDFW “List of California Terrestrial Natural Communities” and/or Holland (1986) classification system, which have been refined and where appropriate to better characterize the habitat types onsite when not addressed by the MSHCP classification system. Acreage totals for vegetation communities documented onsite and offsite are listed in Table 1. Vegetation Communities Acreages. 605
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Biological Resources Technical Report
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Tentative Tract Map 37858 - City of Moreno Valley, California # Photo Point & Direction
1 2
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Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARY
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CADRE
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Figure 3 - MSHCP Relationship Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California 4 Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
RW
MSHCP Burrowing Owl
Survey Area
(red hatch)
608
1 inch = 80 feet
CADRE
Environmental
Figure 4 - Vegetation Communities Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
RW
Sources: Cadre Environmental 2024
Vegetation Communities
Non-native Grassland
Developed
NNG
DEV
RUD Ruderal/Disturbed
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PHOTOGRAPH 1 - Southeast view of Project Site from
northwest corner.

PHOTOGRAPH 2 - Southwest view of Project Site from
northeast corner.

CADRE
Environmental
Refer to Figure 2 - Project Site Map for Photographic Key Figure 5 - Current Project Site Photographs
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California 610 PHOTOGRAPH 3 - Northwest view of Project Site from
southeast corner near Cactus Avenue.

PHOTOGRAPH 4 - Northeast view of Project Site from
southwest corner near Cactus Avenue/Bradshaw Circle
Intersection.

CADRE
Environmental
Refer to Figure 2 - Project Site Map for Photographic Key Figure 6 - Current Project Site Photographs
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California 611 1 inch = 80 feet
CADRE
Environmental
Figure 7 - Soils Association Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle

OFFSITE IMPACT BOUNDARY

PROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
RW
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
SgC
San Emigdio loam
2 to 8 percent slopes
SeC2
San Emigdio fine
sandy loam
2 to 8 percent slopes
eroded
47MNIC-018
612
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14 Table 1.

Vegetation Communities Acreages
Vegetation Type
Acres
(onsite)
Acres
(offsite)
Acres
TOTAL
Ruderal/Disturbed 3.11 0.00 3.11
Non-native Grassland 1.65 0.10 1.75
Developed 0.05 0.09 0.14
TOTAL 4.81 0.19 5.00
Source: Cadre Environmental 2024.

Ruderal/Disturbed
Ruderal/Disturbed habitat was documented in the northern region of the Project Site and adjacent to the existing roadways generally devoid of vegetation. Dominant species documented within this vegetation community include cheeseweed (Malva parviflora), stinknet (Oncosiphon piluliferum), tocalote (Centaurea melitensis), tumbling pigweed (Amaranthus albus), red-stemmed filaree (Erodium cicutarium), white-stemmed filaree (Erodium moschatum), prickly lettuce (Lactuca serriola), shortpod mustard (Hirschfeldia incana), and prickly sow thistle (Sonchus asper).

Non-native Grassland
The southern region of the Project Site is characterized as non-native grassland. Species documented within this vegetation community include wild oat (Avena fatua), wall barley (Hordeum murinum), ripgut grass (Bromus diandrus), common fiddleneck (Amsinckia intermedia), silverleaf nightshade (Solanum elaeagnifolium), Russian thistle (Salsola tragus), horseweed (Erigeron canadensis) and a single Mexican fan palm (Washingtonia robusta).

Developed
The developed regions of the Project Site include the paved reach of Cactus Avenue and Bradshaw Circle.

GENERAL WILDLIFE SPECIES
General wildlife species documented on site include but are not limited to northern mockingbird (Mimus polyglottos), Anna’s hummingbird (Calypte anna), mourning dove (Zenaida macroura), Say’s phoebe (Sayornis saya), European starling (Sturnus vulgaris), lesser goldfinch (Spinus psaltria), house finch (Haemorhous mexicanus), and pocket gopher (Thomomys bottae).

JURISDICTIONAL RESOURCES
No wetlands or jurisdictional resources regulated by the USACE, CDFW, or RWQCB were documented within or adjacent to the Project Site.

The project will comply with all applicable water quality regulations, including complying with a NPDES regulations and MS4 permit requirements. The MS4 permit places pollution 613
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15 prevention requirements on planned developments, construction sites, commercial and industrial businesses, municipal facilities and activities, and residential communities.

Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activities and the installation and proper maintenance of structural BMPs to ensure adequate long-term treatment of water before entering into any stream course or municipal system.

MSHCP Riparian/Riverine/Vernal Pool Resources
No MSHCP Section 6.1.2 riparian scrub, forest or woodland habitat is located within or adjacent to the Project Site.

No evidence of MSHCP Section 6.1.2 vernal pools, seasonal depressions, seasonally inundated road ruts or other wetland features were recorded on the Project Site. Vernal pools are depressions in areas where a hard-underground layer prevents rainwater from draining downward into the subsoils. When rain fills the pools in the winter and spring, the water collects and remains in the depressions. In the springtime, the water gradually evaporates away, until the pools became completely dry in the summer and fall. Vernal pools tend to have an impermeable layer that results in ponded water. The soil texture (the amount of sand, silt, and clay particles) typically contains higher amounts of fine silts and clays with lower percolation rates. Pools that retain water for a sufficient length of time will develop hydric cells. Hydric cells form when the soil is saturated from flooding for extended periods of time and anaerobic conditions (lacking oxygen or air) develop.

Consistent with conditions documented onsite and as previously stated, the Project Site is characterized as San Emigdio fine sandy loam possessing well drained substrates (drainage class). No indication of clay substrates or hydric soils were documented within the Project Site. A review of historic aerials was conducted to determine if inundated features were present during years of high rainfall when features would certainly be documented. Historic aerials taken in 2011 and 2023 represent an ideal baseline during which know (previously documented) inundated vernal pools, seasonal depressions and road ruts can easily be seen. No sign or indication of inundation was documented within the Project Site during a review of historic aerials. In summary, none of the conditions (i.e., no inundated depressions including road ruts, hydric soils, historic inundation, etc.) were observed on documented within the Project Site. No features are present that would support fairy shrimp. No standing water or other sign of areas that pond water was recorded.

SENSITIVE BIOLOGICAL RESOURCES
The following discussion describes the plant and wildlife species present, or potentially present within the property boundaries, that have been afforded special recognition by federal, state, or local resource conservation agencies and organizations, principally due to the species’ declining or limited population sizes, usually resulting from habitat loss.

Also discussed are habitats that are unique, of relatively limited distribution, or of particular value to wildlife. Protected sensitive species are classified by state and/or federal resource management agencies, or both, as threatened or endangered, under provisions of the state and federal endangered species act. Vulnerable or “at-risk” 614
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16 species that are proposed for listing as threatened or endangered (and thereby for protected status) are categorized administratively as "candidates" by the USFWS. CDFW uses various terminology and classifications to describe vulnerable species. There are additional sensitive species classifications applicable in California. These are described below.

Sensitive biological resources are habitats or individual species that have special recognition by federal, state, or local conservation agencies and organizations as endangered, threatened, or rare. The CDFW, USFWS, and special groups like the California Native Plant Society maintain watch lists of such resources. For the purpose of this assessment sources used to determine the sensitive status of biological resources are:

Plants: USFWS (2024), CNDDB (CDFW 2024a), CDFW (2024d, 2024e), California Native Plant Society (CNPS 2024), and Skinner and Pavlik (1994),
Wildlife: California Wildlife Habitat Relationships (2008), USFWS (2024), CNDDB (CDFW 2024a), and CDFW (2024b, 2024c).

Habitats: CNDDB (CDFW 2024a, 2024f).

FEDERAL PROTECTION AND CLASSIFICATIONS
The Federal Endangered Species Act of 1973 (FESA) defines an endangered species as “any species that is in danger of extinction throughout all or a significant portion of its range...” Threatened species are defined as “any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” Under provisions of Section 9(a)(1)(B) of the FESA it is unlawful to “take” any listed species. “Take” is defined as follows in Section 3(18) of the FESA: “...harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” Further, the USFWS, through regulation, has interpreted the terms “harm” and “harass” to include certain types of habitat modification as forms of a “take.” These interpretations, however, are generally considered and applied on a case-by-case basis and often vary from species to species. In a case where a property owner seeks permission from a federal agency for an action that could affect a federally listed plant and animal species, the property owner and agency are required to consult with USFWS.

Section 9(a)(2)(b) of the FESA addresses the protections afforded to listed plants.

Recently, the USFWS instituted changes in the listing status of former candidate species.

Former C1 (candidate) species are now referred to simply as candidate species and represent the only candidates for listing. Former C2 species (for which the USFWS had insufficient evidence to warrant listing at this time) and C3 species (either extinct, no longer a valid taxon or more abundant than was formerly believed) are no longer considered as candidate species. Therefore, these species are no longer maintained in list form by the USFWS, nor are they formally protected. However, some USFWS field offices have issued memoranda stating that former C2 species are henceforth to be considered Federal Species of Concern. This term is employed in this document but carries no official protections. All references to federally protected species in this report (whether listed, proposed for listing or candidate) include the most current published status or candidate category to which each species has been assigned by USFWS. For purposes of this assessment, the following acronyms are used for federal status species:
615
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17 FE Federal Endangered
FT Federal Threatened
FPE Federal Proposed Endangered
FPT Federal Proposed Threatened
FC Federal Candidate for Listing
The designation of critical habitat can also have a significant impact on the development of land designated as “critical habitat.” The FESA prohibits federal agencies from taking any action that will “adversely modify or destroy” critical habitat (16 U.S.C. § 1536(a)(2)).

This provision of the FESA applies to the issuance of permits by federal agencies. Before approving an action affecting critical habitat, the federal agency is required to consult with the USFWS who then issues a biological opinion evaluating whether the action will “adversely modify” critical habitat. Thus, the designation of critical habitat effectively gives the USFWS extensive regulatory control over the development of land designated as critical habitat.

The federal Migratory Bird Treaty Act (MBTA) makes it unlawful to “take” any migratory bird or part, nest, or egg of such bird listed in wildlife protection treaties between the United States and Great Britain, the Republic of Mexico, Japan, and the Union of Soviet States. For purposes of the MBTA, “take” is defined as to pursue, hunt, capture, kill, or possess or attempt to do the same.

The Bald Eagle and Golden Eagle Protection Act explicitly protects the bald eagle and golden eagle and imposes its own prohibition on any taking of these species. As defined in this act, take means to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, or molest or disturb. Current USFWS policy is not to refer the incidental take of bald eagles for prosecution under the Bald Eagle and Golden Eagle Protection Act (16 U.S.C. 668-668d).

STATE PROTECTION AND CLASSIFICATIONS
California's Endangered Species Act (CESA) defines an endangered species as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant which is in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease.” The State defines a threatened species as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that, although not presently threatened with extinction, is likely to become an endangered species in the foreseeable future in the absence of the special protection and management efforts required by this chapter. Any animal determined by the commission as rare on or before January 1, 1985 is a threatened species.” Candidate species are defined as “...a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for which the commission has published a notice of proposed regulation to add the species to either list.” Candidate species may be afforded temporary protection as though they were already listed as threatened or endangered at the discretion of the Fish and Game 616
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18 Commission. Unlike FESA, CESA does not include listing provisions for invertebrate species.

Article 3, Sections 2080 through 2085, of CESA addresses the taking of threatened or endangered species by stating “No person shall import into this state, export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product thereof, that the commission determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise provided...” Under CESA, “take” is defined as “...hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” Exceptions authorized by the state to allow “take” require “...permits or memorandums of understanding...” and can be authorized for “...endangered species, threatened species, or candidate species for scientific, educational, or management purposes.” Sections 1901 and 1913 of the California Fish and Game Code provide that notification is required prior to disturbance.

Additionally, some sensitive mammals and birds are protected by the State as Fully Protected Mammals or Fully Protected Birds, as described in the California Fish and Game Code, Sections 4700 and 3511, respectively. California Species of Special Concern (SSC) listings include special status species, including all state and federal protected and candidate taxa, Bureau of Land Management and US Forest Service sensitive species, species considered to be declining or rare by the National Audubon Society, and a selection of species which are considered to be under population stress but are not formally proposed for listing. This list is primarily a working document for the CDFW's CNDDB project. Informally listed taxa are not protected per se but warrant consideration in the preparation of biotic assessments. For some species, the CNDDB is only concerned with specific portions of the life history, such as roosts, rookeries, or nest sites. For the purposes of this assessment, the following acronyms are used for State status species:

SE State Endangered
ST State Threatened
SCE State Candidate Endangered
SCT State Candidate Threatened
SFP State Fully Protected
SP State Protected
SR State Rare
SSC California Species of Special Concern
CWL California Watch List
Nesting birds, including raptors, are protected under California Fish and Game Code Section 3503, which reads, “It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto.” In addition, under California Fish and Game Code Section 3503.5, “it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant 617
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19 thereto”. Passerines and non-passerine land birds are further protected under California Fish and Game Code 3513. As such, CDFW typically recommends surveys for nesting birds that could potentially be directly (e.g., actual removal of trees/vegetation) or indirectly (e.g., noise disturbance) impacted by project-related activities. Disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “take” by CDFW.

California Native Plant Society
The CNPS is a private plant conservation organization dedicated to the monitoring and protection of sensitive species in the State. This organization has compiled an inventory comprised of the information focusing on geographic distribution and qualitative characterization of rare, threatened, or endangered vascular plant species of California (Tibor 2001). The list serves as the candidate list for listing as threatened and endangered by CDFW. The CNPS has developed five categories of rarity references as California Rare Plant Ranks (CRPR):

CRPR 1A Presumed extinct in California.

CRPR 1B Rare, threatened, or endangered in California and elsewhere.

CRPR 2A Plants presumed extirpated in California but common elsewhere CRPR 2B Plants rare, threatened, or endangered in California but more common elsewhere
CRPR 3 Plants about which we need more information – a review list.

CRPR 4 Species of limited distribution in California (i.e., naturally rare in the wild), but whose existence does not appear to be susceptible to threat.

As stated by the CNPS:
“Threat Rank is an extension added onto the California Rare Plant Rank and designates the level of endangerment by a 1 to 3 ranking with 1 being the most endangered and 3 being the least endangered. A Threat Rank is present for all California Rare Plant Rank 1B's, 2's, 4's, and the majority of California Rare Plant Rank 3's. California Rare Plant Rank 4 plants are seldom assigned a Threat Rank of 0.1, as they generally have large enough populations to not have significant threats to their continued existence in California; however, certain conditions exist to make the plant a species of concern and hence be assigned a California Rare Plant Rank. In addition, all California Rare Plant Rank 1A (presumed extinct in California), and some California Rare Plant Rank 3 (need more information) plants, which lack threat information, do not have a Threat Rank extension.” (CNPS 2010)

0.1 Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat)

0.2 Fairly threatened in California (20-80% occurrences threatened / moderate degree and immediacy of threat)
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20 0.3 Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known)

SENSITIVE HABITATS
As stated by CDFW:
“One purpose of the vegetation classification is to assist in determining the level of rarity and imperilment of vegetation types. Ranking of alliances according to their degree of imperilment (as measured by rarity, trends, and threats) follows NatureServe’s Heritage Methodology, in which all alliances are listed with a G (global) and S (state) rank. For alliances with State ranks of S1-S3, all associations within them are also considered to be highly imperiled” (CDFW 2012)
No vegetation communities listed by CDFW as sensitive were documented within or adjacent to the Project Site.

SENSITIVE PLANTS
The following discussion is presented in three (3) parts:

I) MSHCP Narrow Endemic and Criteria Area Plant Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment and Not Found or Expected to Occur Onsite;
II) Species that can be Excluded from the Project Site Based on Lack of Suitable Habitat Onsite; and
III) Special-Status Species Potentially Occurring Onsite.

I: MSHCP Narrow Endemic and Criteria Area Plant Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment and Not Found or Expected to Occur Onsite
The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

II: Sensitive Species that can be Excluded from the Project Site Based on Lack of Suitable Habitat Onsite
No state or federally listed threatened or endangered plant species were documented or expected to occur onsite based on a lack of suitable habitat, as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite. 619
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21 III. Special-Status Species Potentially Occurring Onsite No potential habitat and/or substrates was detected onsite for CNPS special-status plants not covered under the MSHCP, as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite.

Table 4.

Sensitive Plant Species with Potential to Occur Onsite.

Species Name
(Scientific Name)
Status
Habitat Description Comments
Chaparral sand-verbena
(Abronia villosa var. aurita)
CRPR 1B.1
Sandy soils in sage-scrub,
chaparral.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

San Diego sagewort
(Artemisia palmeri)
CRPR 4.2
Found in sandy and mesic
soils within chaparral, coastal
scrub, riparian forest, riparian
scrub, and riparian woodland.

Found at elevations ranging
from 49 to 3,002 feet.

Blooming period is from
February to September.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Plummer's mariposa lily
(Calochortus plummerae)
CRPR 1B.2
MSHCP Covered
Granitic, rock soils within
chaparral, cismontane
woodland, coastal sage
scrub, lower montane
coniferous forest, and valley
and foothill grassland.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Payson’s jewelflower
(Caulanthus simulans)
CRPR List 4.2
MSHCP Covered
Annual herb generally
blooming from February to
June within chaparral and
costal scrub habitats in
association with granitic and
sandy substrates (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Smooth tarplant
(Centromadia pungens ssp.
laevis)
CRPR 1B.1
MSHCP Covered
Alkaline soils in chenopod
scrub, meadows and seeps,
playas, and disturbed
habitats.

No Potential. No suitable
habitat or alkaline substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.
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22 Species Name
(Scientific Name)
Status
Habitat Description Comments
Peninsular spine flower
(Chorizanthe leptotheca)
CRPR 4.2
Annual herb generally
blooming from May to August
within alluvial fan, granitic
chaparral, coastal scrub and
lower montane coniferous
forest habitats (CNPS 2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Parry's spineflower
(Chorizanthe parryi var.
parryi)
CRPR 3.2
MSHCP Covered
Sandy or rocky soils in open
habitats of chaparral and
coastal sage scrub.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

White-bracted spineflower
(Chorizanthe xanti var.
leucotheca)
CRPR 1B.2
Annual herb generally
blooming from April to June
within coastal scrub (alluvial
fans), Mojavean desert scrub
and pinyon and juniper
woodland habitats (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Paniculate tarplant
(Deinandra paniculata)
CRPR 4.2
Usually vernally mesic,
sometimes sandy, coastal
scrub, valley and foothill
grasslands, and vernal pools;
25-940m.

Apr-Nov
No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Coulter’s goldfields
(Lasthenia glabrata ssp.
coulteri)
CRPR List 1B.1

MSHCP CAPSA
Coulter’s goldfields is
associated with low-lying
alkali and saline habitats
along the coast and inland
valleys. The majority of the
populations are associated
with coastal salt marsh. In
Riverside County, Coulter’s
goldfields primarily grow in
highly alkaline, silty clays
associated with the TraverDomino-Willows soils, and
usually in the wet areas in
the alkali vernal plain
community.

No Potential. No suitable
habitat or alkaline substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

Robinson’s pepper-grass
(Lepidium virginicum var.
robinsonii)
CRPR 4.3
Annual herb generally
blooming from January to
July within chaparral and
coastal scrub habitats (CNPS
2024).

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.
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23 Species Name
(Scientific Name)
Status
Habitat Description Comments
San Bernardino aster
(Symphyotrichum defoliatum)
CRPR 1B.2
Occurs in cismontane
woodland, coastal scrub,
lower montane coniferous
forest, meadows and seeps,
marshes and swamps, and
valley and foothill grassland
(vernally mesic)/near ditches,
streams springs.

No Potential. No suitable
habitat or substrates
detected onsite. The Project
Site is heavily disturbed and
dominated by ruderal nonnative vegetation.

California Native Plant Society (CNPS): California Rare Plant Rank (CRPR) CRPR 1A – plants presumed extinct in California
CRPR 1B – plants rare, threatened, or endangered in California, but more common elsewhere CRPR 2A – plants presumed extirpated in California but common elsewhere CRPR 2B – plants rare, threatened, or endangered in California but more common elsewhere CRPR 3 – plants about which we need more information, a review list CRPR 4 – plants of limited distribution, a watch list
.1 – Seriously endangered in California
.2 – Fairly endangered in California
.3 – Not very endangered in California
Federal (USFWS) Protection and Classification
FE – Federally Endangered
FT – Federally Threatened
FC – Federal Candidate for Listing
State (CDFW) Protection and Classification
SE – State Endangered
ST – State Threatened
Source : Cadre Environmental 2024.

SENSITIVE WILDLIFE
The following discussion is presented in two (2) parts:

I) MSHCP Wildlife Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment;
II) Special-Status Species Potentially Occurring Onsite.

I: MSHCP Wildlife Species Subject to Focused Surveys or Evaluated by Habitat Suitability Assessment
The Project Site is not located within an MSHCP Amphibian Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Mammal Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site occurs almost completely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map. Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused 622
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24 burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2024 focused survey efforts (Gonzales Environmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non-native vegetation as shown in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat.

An MSHCP preconstruction survey will be required at least 30-days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction survey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of the burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2.

II. Special-Status Species Potentially Occurring Onsite Moderate to low potential habitat was documented onsite for five (5) MSHCP covered species including sharp-shinned hawk (Accipiter striatus) - foraging, grasshopper sparrow (Ammodramus savannarum), California horned lark (Eremophila alpestris actia), northern harrier (Circus cyaneus) - foraging, and white-tailed kite (Elanus leucurus) - foraging, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite. As previously stated, the MSHCP has determined that these sensitive species potentially occurring within Project Site have been adequately covered (MSHCP Table 2-2 Species Considered for Conservation Under the MSHCP Since 1999, 2004).

No suitable habitat was documented onsite for wildlife species not covered under the MSHCP, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite.

Table 5.

Sensitive Wildlife Species with Potential to Occur Onsite.

Species Name
(Scientific Name)
Status
Habitat Description Comments

INVERTEBRATES
Crotch’s bumble bee
(Bombus crotchii)
SCE
Range extends from
southern to northern
California within a variety
of habitats including
grassland, scrub,
chaparral and desert
habitats. Food plants
include but are not limited
to the following genera:

Antirrhinum, Phacelia,
Clarkia, Cordylanthus,
No Potential. No suitable
food plants were documented
within or adjacent to the
Project Site. The Project Site
is heavily disturbed and
dominated by ruderal nonnative vegetation.
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25 Species Name
(Scientific Name)
Status
Habitat Description Comments
Dendromecon,
Eschscholzia, Eriogonum,
Hypericum, Lantana,
Lupinus, Salvia,
Asclepias, Cirsium,
Monardella, Keckiella,
Acmispon, Euthamia,
Ehrendorferia, Vicia,
and/or Trichostema.

Vernal pool fairy shrimp
(Branchinecta lynchi)
FT
MSHCP Covered Species
Vernal pool fairy shrimp is
restricted to seasonal
vernal pools (Eng, Belk,
and Eriksen 1990;
USFWS 1994). The vernal
pool fairy shrimp prefers
cool-water pools that have
low to moderate dissolved
solids, are unpredictable,
and often short lived
(Eriksen and Belk 1999,
MSHCP 2004).

No Potential. No suitable
habitat including vernal
pools, seasonal depressions
or indication of inundation
was documented within or
adjacent to the Project Site.

Riverside fairy shrimp
(Streptocephalus woottoni)
FE
MSHCP Covered Species
S. woottoni is restricted to
deep seasonal vernal
pools/ephemeral ponds,
and stock ponds and
other human modified
depressions (Eng, Belk,
and Eriksen 1990,
USFWS 1993, USFWS
2001). Riverside fairy
shrimp prefer warm-water
pools that have low to
moderate dissolved
solids, are less
predictable, and remained
filled for extended periods
of time (MSHCP 2004).

No Potential. No suitable
habitat including vernal
pools, seasonal depressions
or indication of inundation
was documented within or
adjacent to the Project Site.

AMPHIBIANS
Arroyo toad
(Anaxyrus californicus)
FE/SSC
MSHCP Covered Species
Shallow, slow moving
active and braided stream
channels with sandy
substrates for breeding,
bench and terrace
habitats for foraging and
aestivation, willow scrub,
coastal sage scrub and
riparian/oak woodlands.

No Potential. No suitable
breeding or upland habitat
documented within or
adjacent to the Project Site.
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26 Species Name
(Scientific Name)
Status
Habitat Description Comments
Western spadefoot
(Spea hammondii)
SSC
MSHCP Covered Species
The western spadefoot
population is patchily but
widely distributed
throughout the Riverside
Lowlands and San Jacinto
Foothills Bioregions.

Habitat for this species
includes suitable breeding
habitat below 1500 meters
(i.e., vernal pools or other
standing water is free of
exotic species) secondary
habitats including
adjacent chaparral, sage
scrub, grassland, and
alluvial scrub habitats
(MSHCP 2004).

No Potential. No suitable
breeding habitat including
vernal pools, seasonal
depressions or indication of
inundation was documented
within or adjacent to the
Project Site.

REPTILES
Southern California legless
lizard
(Anniella stebbinsi)
SSC
Occurs in moist warm
loose soil with plant cover.

Moisture is essential.

Occurs in sparsely
vegetated areas of beach
dunes, chaparral, pineoak woodlands, desert
scrub, sandy washes, and
stream terraces with
sycamores, cottonwoods,
or oaks.

No Potential. No suitable
habitat was documented
within the Project Site based
on a lack of mesic conditions.

Orange-throated whiptail
(Aspidoscelis hyperythra)
CWL
MSHCP Covered Species
The orange-throated
whiptail occurs primarily in
a wide variety of habitats
but is more closely tied to
coastal sage scrub and
chaparral habitats with
less than 90 percent
vegetative cover.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coastal western whiptail
(Aspidoscelis tigris stejnegeri)
SSC
MSHCP Covered Species
The coastal western
whiptail occurs in a wide
variety of habitats
including coastal sage
scrub, desert scrub,
Riversidean alluvial fan
scrub, woodlands,
grasslands, playas, and
respective ecotones
between these habitats
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.
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27 Species Name
(Scientific Name)
Status
Habitat Description Comments
San Diego banded gecko
(Coleonyx variegatus abbotti)
SSC
MSHCP Covered Species
San Diego banded gecko
is a microhabitat
generalist and also occurs
in habitats ranging from
cismontane chaparral and
desert scrub to open sand
dunes and arid tropical
forests (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Red-diamond rattlesnake
(Crotalus ruber)
SSC
MSHCP Covered Species
The red-diamond
rattlesnake is often found
in areas with dense
vegetation especially
chaparral and sage scrub
up to 1,520 meters in
elevation (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Western pond turtle
(Actinemys marmorata)
SSC
MSHCP Covered Species
The western pond turtle
inhabits slow moving
permanent or intermittent
streams, small ponds,
small lakes, reservoirs,
abandoned gravel pits,
permanent and ephemeral
shallow wetlands, stock
ponds, and sewage
treatment lagoons
(Rathbun et al., 1992;
Holland, 1994). Pools are
the preferred habitat
within streams (Bury,
1972, MSHCP 2004)
No Potential. No suitable
habitat was documented
within the Project Site.

Coast horned lizard
(Phrynosoma blainvillii)
SSC
MSHCP Covered Species
The horned lizard occurs
primarily in scrub,
chaparral, and grassland
habitats. The species is
common in most areas of
the Plan Area except
where adjacent to urban
situations (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coast patch-nosed snake
(Salvadora hexalepis virgultea)
SSC
The coast patch-nosed
snake prefers brushy
coastal sage scrub/
chaparral habitats.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.
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28 Species Name
(Scientific Name)
Status
Habitat Description Comments
BIRDS
Cooper's hawk
(Accipiter cooperii)
SSC
MSHCP Covered Species
Cooper’s hawk is most
commonly found within or
adjacent to riparian/oak
forest and woodland
habitats. This uncommon
resident of California
increases in numbers
during winter migration.

No Potential. No suitable
breeding or foraging habitat
was documented within the
Project Site. The Project Site
is heavily disturbed and
dominated by ruderal nonnative vegetation.

Sharp-shinned hawk
(Accipiter striatus)
SSC
MSHCP Covered Species
For the purpose of the
conservation analysis,
potential habitat for the
sharp-shinned hawk
includes montane
coniferous forest for
potential breeding areas
(none have been
documented) and riparian
scrub, woodland, and
forest habitat, oak
woodland and forest,
chaparral, coastal sage
scrub, desert scrub, and
Riversidean alluvial fan
sage scrub for foraging.
(MSHCP 2004)
Moderate Potential. Suitable
foraging habitat is present
on-site. This species does
not nest in southern
California. This species is
adapted to urban
environments and occurs
commonly.

Tri-colored blackbird
(Agelaius tricolor)
ST/SSC
MSHCP Covered Species
Marshes and grasslands.

Breeding colonies require
nearby water, nesting
substrate, and open range
foraging habitat of natural
grassland, woodland, or
agricultural cropland.

No Potential. No suitable
breeding or foraging habitat
was documented within the
Project Site.

Southern California rufouscrowned sparrow
(Aimophila ruficeps canescens)
CWL
MSHCP Covered Species
Southern California
rufous-crowned sparrow is
a non-migratory bird
species that primarily
occurs within sage scrub
and grassland habitats
and to a lesser extent
chaparral subassociations (Unitt 2004).

This species generally
breeds on the ground
within grassland and
scrub communities in the
western and central
regions of California.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.
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29 Species Name
(Scientific Name)
Status
Habitat Description Comments
Grasshopper sparrow
(Ammodramus savannarum)
SSC
MSHCP Covered Species
The grasshopper sparrow
generally prefers
moderately open
grasslands and prairies
with patchy bare ground
(MSHCP 2004).

Low Potential. The patches
of non-native grassland
documented onsite provides
suitable habitat for the
species.

Golden eagle
(Aquila chrysaetos)

CWL, SFP
MSHCP Covered Species
Within southern California,
the species prefers
grasslands, brushlands
(coastal sage scrub and
chaparral), deserts, oak
savannas, open
coniferous forests, and
montane valleys (MSHCP
2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Bell's sage sparrow
(Artemisiospiza belli belli)
CWL
MSHCP Covered Species
Bell's sage sparrow is an
uncommon to fairly
common but localized
resident breeder in dry
chaparral and coastal
sage scrub along the
coastal lowlands, inland
valleys, and in the lower
foothills of local mountains
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Short-eared owl
(Asio otus)
SSC
Suitable habitats include
salt- and freshwater
marshes, irrigated alfalfa
or grain fields, and
ungrazed grasslands and
old pastures. Tule marsh
or tall grasslands with
cover 30 to 50 cm in
height can support nesting
pairs.

No Potential.

Lack of suitable habitat.

Long-eared owl
(Asio otus)
SSC
Deciduous and evergreen
forests, orchards, wooded
parks, farm woodlots, river
woods, desert oases.

Wooded areas with dense
vegetation needed for
roosting and nesting,
open areas for hunting.

Often associated with
deciduous woods near
water.

No Potential.

Lack of suitable habitat.
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30 Species Name
(Scientific Name)
Status
Habitat Description Comments
Burrowing owl
(Athene cunicularia)
SSC
MSHCP Covered Species
The burrowing owl uses
predominantly open land,
including grassland,
agriculture (e.g., dry-land
farming and grazing
areas), playa, and sparse
coastal sage scrub and
desert scrub habitats
(Garrett and Dunn 1981).

Some breeding burrowing
owls are year-round
residents and additional
individuals from the north
may winter throughout the
MSHCP Area Plan
(MSHCP 2004).

No Potential. The Project Site
does not currently provide
suitable foraging habitat and
burrows larger than 4 inches
in diameter were not
detected within and adjacent
to the property boundaries.

The species was not
detected within or adjacent to
the property following
focused surveys conducted
in 2020 and 2024 (Gonzales
Environmental Consulting,
LLC. 2020b, Cadre
Environmental 2024)
Ferruginous hawk
(Buteo regalis)
CWL
MSHCP Covered Species
Range-wide, within
California, ferruginous
hawks winter in open
terrain and grasslands of
plains and foothills
(Grinnell and Miller 1944).

Within southern California,
including the ferruginous
hawks typically winter in
open fields, grasslands,
and agricultural areas.

No Potential. No suitable
habitat was documented
within the Project Site.

Swainson’s hawk
(Buteo swainsoni)
ST
MSHCP Covered Species
Typical habitat is open
desert, grassland, or
cropland containing
scattered, large trees or
small groves. Breeds in
stands with few trees in
juniper-sage flats, riparian
areas, and in oak
savannah in the Central
Valley. Forages in
adjacent grassland or
suitable grain or alfalfa
fields or livestock
pastures.

No Potential. No suitable
habitat was documented
within the Project Site.

Vaux’s swift
(Chaetura vauxi)
SSC
refers redwood and
Douglas-fir habitats with
nest-sites in large hollow
trees and snags,
especially tall, burned-out
snags. Fairly common
migrant throughout most
of the state in April and
May, and August and
September.

No Potential. No suitable
habitat was documented
within the Project Site.
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31 Species Name
(Scientific Name)
Status
Habitat Description Comments
Northern harrier
(Circus cyaneus)
SSC
The northern harrier
frequents open wetlands,
wet/lightly grazed
pastures, fields, dry
uplands/prairies, mesic
grasslands, drained
marshlands, croplands,
meadows, grasslands,
open rangelands, fresh
and saltwater emergent
wetlands.

Low Potential. May
occasionally forage onsite.

Western yellow-billed cuckoo
(Coccyzus americanus
occidentalis)
FT/SE
MSHCP Covered Species
Although the preferred
habitat, riparian scrub and
forest, is well distributed
at scattered locations
within the Plan Area in the
Riverside Lowland
Bioregions, the western
yellow-billed cuckoo
apparently no longer
inhabits much of this
habitat (MSHCP 2004).

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

White-tailed kite
(Elanus leucurus)
SFP
MSHCP Covered Species
The white-tailed kite is
found in riparian, oak
woodlands adjacent to
large open spaces
including grasslands,
wetlands, savannahs and
agricultural fields. This
non-migratory bird
species occurs throughout
the lower elevations of
California and commonly
nests in coast live oaks
(Unitt 2004).

Low Potential. May
occasionally forage onsite.

Southwestern willow
flycatcher
(Empidonax traillii extimus)
FE/SE
MSHCP Covered Species
The southwestern willow
flycatcher is narrowly
distributed at few
locations within the Plan
Area. Although the
preferred habitat, riparian
woodland and select other
forests, is well distributed
within all bioregions and
spread over the entire
Plan Area, few current
locations for the willow
flycatcher have been
documented (MSHCP
2004).

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.
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32 Species Name
(Scientific Name)
Status
Habitat Description Comments
California horned lark
(Eremophila alpestris actia)
SWL
MSHCP Covered Species
Habitat for the California
horned lark includes
agriculture (field
croplands), grassland,
cismontane alkali marsh,
playa and vernal pool
habitat, Riversidean
alluvial fan sage scrub,
and coastal sage scrub
(Garrett and Dunn 1988).

It has been recorded in
chaparral and riparian
habitat - however these
are not typical habitats
used by the species.

Moderate Potential. May
occasionally forage onsite.

Merlin
(Falco columbarius)
CWL
MSHCP Covered Species
The merlin has a sparse
and widespread
distribution throughout the
MSHCP Plan Area within
almost every habitat that
occurs within the Plan
Area. It occurs within the
Plan Area as a transient in
the spring and fall and
may occasionally winter
within the area. It does not
require specific conditions
or locations for nesting
because it does not nest
in the region. (MSHCP
2004)
No Potential. No suitable
habitat was documented
within the Project Site.

Prairie falcon
(Falco mexicanus)
CWL
MSHCP Covered Species
Habitat use of the prairie
falcon includes annual
grasslands to alpine
meadows. The prairie
falcon is associated
primarily with perennial
grasslands, savannahs,
rangeland, some
agricultural fields during
the winter season, and
desert scrub areas, all
typically dry environments
of western North
American where there are
cliffs or bluffs for nest
sites (MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.
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33 Species Name
(Scientific Name)
Status
Habitat Description Comments
American peregrine falcon
(Falco peregrinus anatum)
SFP
MSHCP Covered Species
Throughout the species'
range, peregrine falcons
are found in a large
variety of open habitats,
including tundra, marshes,
seacoasts, savannahs
and high mountains (AOU
1998, MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site.

Yellow-breasted chat
(Icteria virens)
SSC
MSHCP Covered Species
The yellow-breasted chat
is associated with riparian
woodland and riparian
scrub habitats (MSHCP
2004)
No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Loggerhead shrike
(Lanius ludovicianus)
SSC
MSHCP Covered Species
Loggerhead shrike prefer
open ground for foraging
and thick trees and shrubs
including sage scrub,
chaparral, and desert
scrub habitats for nesting.

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Coastal California gnatcatcher
(Polioptila californica californica)
FT/SSC
MSHCP Covered Species
The coastal California
gnatcatcher is a nonmigratory bird species that
primarily occurs within
sage scrub habitats in
coastal southern
California dominated by
California sagebrush
(Artemisia californica),
and California buckwheat
(Eriogonum fasciculatum).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Yellow warbler
(Setophaga petechia)
SSC
MSHCP Covered Species
Habitat characteristics of
the yellow warbler are well
known to include riparian
scrub and forest and
woodland (MSHCP 2004)
No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Least Bell's vireo
(Vireo bellii pusillus)
FE/SE
MSHCP Covered Species
Least Bell’s vireo resides
in riparian habitats with a
well-defined understory
including southern willow
scrub, mule fat, and
riparian forest/woodland
habitats.

No Potential. No suitable
riparian scrub, forest or
woodland habitat was
documented within or
adjacent to the Project Site.

Yellow-headed blackbird
(Xanthocephalus
xanthocephalus)
SSC
Prefers freshwater
marshes habitat
dominated by cattails and
tule.

No Potential. No suitable
marsh habitat was
documented within or
adjacent to the Project Site.
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34 Species Name
(Scientific Name)
Status
Habitat Description Comments

MAMMALS
Pallid bat
(Antrozous pallidus)
SSC
In California, the species
as occurring in a variety of
habitats, including
coniferous forests, oak
woodlands, brushy terrain,
rocky canyons, open
farmland, and desert.

Roosts are selected on
the basis of
temperature/proximity to
foraging habitat. They are
generalists in their
roosting requirements,
using a variety of
structures including rock
crevices, tree hollows,
mines/caves, structures.

No Potential. No suitable
roosting habitat documented
within Project Site.

Northwestern San Diego
pocket mouse
(Chaetodipus fallax fallax)
SSC
MSHCP Covered Species
The northwestern San
Diego pocket mouse
occurs throughout the
Plan Area in coastal sage
scrub (including Diegan
and Riversidean upland
sage scrubs and alluvial
fan sage scrub), sage
scrub/grassland ecotones,
chaparral at all elevations
up to 6,000 feet (MSHCP
2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

San Bernardino kangaroo rat
(Dipodomys merriami parvus)
FE
MSHCP Covered Species
Alluvial sage scrub on
alluvial fans, flood plains,
along washes, in adjacent
upland areas, and in
areas with historic braided
stream channels; these
habitats characterized by
sand, loam, sandy loam,
or gravelly soils. Prefers
the more open early and
intermediate phases of
alluvial sage scrub, but
mature sage scrub is
important as refugia
during floods.

No Potential. No suitable
habitat documented onsite.

Stephens' kangaroo rat
(Dipodomys stephensi)
FE/ST
MSHCP Covered Species
The Stephens' kangaroo
rat is found almost
exclusively in open
grasslands or sparse
shrublands with cover of
less than 50 percent
No Potential. No suitable
open grassland habitat
documented onsite.
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35 Species Name
(Scientific Name)
Status
Habitat Description Comments
during the summer
(MSHCP 2004).

Western mastiff bat
(Eumops perotis californicus)
SSC
Western mastiff bats are
found in a variety of biotic
environments from low
desert scrub to chaparral,
oak woodland and
ponderosa pine.

No Potential. No suitable
roosting habitat documented
onsite.

Western yellow bat
(Lasiurus xanthinus)
SSC
Although formerly
associated only with the
desert palm oasis in
California (Bond, 1970),
yellow bats appear to be
expanding their range to
the coast and northward,
possibly as a result of the
planting of ornamental
palms.

No Potential. No suitable
roosting habitat documented
onsite.

San Diego black-tailed
jackrabbit
(Lepus californicus bennettii)
SSC
MSHCP Covered Species
The San Diego blacktailed jackrabbit in open
habitats, primarily
including grasslands,
sage scrub, alluvial fan
sage scrub, and Great
Basin sage scrub.

No Potential. Not detected
onsite.

Bobcat
(Lynx rufus)
MSHCP Covered Species
The bobcat requires large
expanses of relatively
undisturbed brushy and
rocky habitats near
springs or other perennial
water sources.

No Potential. No suitable
habitat documented onsite.

Pocketed free-tailed bat
(Nyctinomops femorosaccus)
SSC
Usually associated with
rugged canyons, high
cliffs, and rock
outcroppings. Roosts in
rock crevices and caves
during the day; may also
roost in buildings or under
roof tiles (Ziener et al.
1988-1990).

No Potential. No suitable
roosting habitat documented
onsite.

Big free-tailed bat
(Nyctinomops macrotis)
SSC
Desert habitats. Roosts in
rock crevices in cliffs
No Potential. No suitable
roosting habitat documented
onsite.

Townsend’s big-eared bat
(Corynorhinus townsendii)
SSC
A wide variety of habitats
including woodlands and
arid grasslands. Roosts in
mines and caves.

No Potential. No suitable
roosting habitat documented
within Project Site.
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36 Species Name
(Scientific Name)
Status
Habitat Description Comments
Dulzura kangaroo rat
(Dipodomys simulans)
MSHCP Covered Species
The Dulzura kangaroo rat
occurs throughout the
Plan Area in coastal sage
scrub (including Diegan
and Riversidean upland
sage scrubs and alluvial
fan sage scrub), sage
scrub/grassland ecotones,
chaparral, and desert
scrubs at all elevations up
to 2,600 feet (MSHCP
2004)
No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

San Diego desert woodrat
(Neotoma lepida intermedia)
SSC
MSHCP Covered Species
The San Diego desert
woodrat is found
throughout the Plan Area
in sage scrub and
chaparral wherever there
are rock outcrops,
boulders, cactus patches
and dense undergrowth
(MSHCP 2004).

No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

Los Angeles pocket mouse
(Perognathus longimembris
brevinasus)
SSC
MSHCP Covered Species
The Los Angeles pocket
mouse appears to be
limited to sparsely
vegetated habitat areas in
patches of fine sandy soils
associated with washes or
of aeolian (windblown)
origin, such as dunes
(MSHCP 2004)
No Potential. No suitable
habitat was documented
within the Project Site. The
Project Site is heavily
disturbed and dominated by
ruderal non-native
vegetation.

American badger
(Taxidea taxus)
SSC
The American badger
prefers friable soils in
open grassland and scrub
habitat in southern
California.

No Potential. No burrows
documented onsite.

Federal (USFWS) Protection and Classification
FE – Federally Endangered
FT – Federally Threatened
FC – Federal Candidate for Listing
State (CDFW) Protection and Classification
SE – State Endangered
SCE – State Candidate Endangered
ST – State Threatened
SSC – State Species of Special Concern
CWL – California Watch List
SPF – State Fully Protected
Sources: Cadre Environmental 2024.

Critical habitat designations by the USFWS were researched to determine if any of the Project Site is located within USFWS critical habitat. The Project Site does not occur within a designated critical habitat for federally endangered or threatened species. 635
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37 REGIONAL CONNECTIVITY/WILDLIFE MOVEMENT CORRIDORS
Overview
Wildlife corridors link areas of suitable habitat that are otherwise separated by rugged terrain, changes in vegetation, or human disturbance. The fragmentation of open space areas by urbanization creates isolated “islands” of wildlife habitat. In the absence of habitat linkages that allow movement to adjoining open space areas, various studies have concluded that some wildlife species, especially the larger and more mobile mammals, will not likely persist over time in fragmented or isolated habitat areas because they prohibit the infusion of new individuals and genetic information (MacArthur and Wilson 1967; Soule 1987; Harris and Gallager 1989; Bennett 1990). Corridors effectively act as links between different populations of a species. A group of smaller populations (termed “demes”) linked together via a system of corridors is termed a “metapopulation.” The long-term health of each deme within the metapopulation is dependent upon its size and the frequency of interchange of individuals (immigration vs. emigration). The smaller the deme, the more important immigration becomes, because prolonged inbreeding with the same individuals can reduce genetic variability. Immigrant individuals that move into the deme from adjoining demes mate with individuals and supply that deme with new genes and gene combinations that increases overall genetic diversity. An increase in a population’s genetic variability is generally associated with an increase in a population’s health. Corridors mitigate the effects of habitat fragmentation by:
(1) allowing animals to move between remaining habitats, which allows depleted populations to be replenished and promotes genetic diversity; (2) providing escape routes from fire, predators, and human disturbances, thus reducing the risk that catastrophic events (such as fires or disease) will result in population or local species extinction; and
(3) serving as travel routes for individual animals as they move within their home ranges in search of food, water, mates, and other needs (Noss 1983; Fahrig and Merriam 1985; Simberloff and Cox 1987; Harris and Gallagher 1989).

Wildlife movement activities usually fall into one of three movement categories: (1) dispersal (e.g., juvenile animals from natal areas, individuals extending range distributions); (2) seasonal migration; and (3) movements related to home range activities (foraging for food or water, defending territories, searching for mates, breeding areas, or cover). A number of terms have been used in various wildlife movement studies, such as “wildlife corridor”, “travel route”, “habitat linkage”, and “wildlife crossing” to refer to areas in which wildlife moves from one area to another. To clarify the meaning of these terms and facilitate the discussion on wildlife movement in this study, these terms are defined as follows:

Travel Route: A landscape feature (such as a ridge line, drainage, canyon, or riparian strip) within a larger natural habitat area that is used frequently by animals to facilitate movement and provide access to necessary resources (e.g., water, food, cover, den sites). The travel route is generally preferred because it provides the least amount of topographic resistance in moving from one area to another; it contains adequate food, water, and/or cover while moving between habitat areas; and provides a relatively direct link between target habitat areas.
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38 Wildlife Corridor: A piece of habitat, usually linear in nature, that connects two or more habitat patches that would otherwise be fragmented or isolated from one another. Wildlife corridors are usually bounded by urban land areas or other areas unsuitable for wildlife.

The corridor generally contains suitable cover, food, and/or water to support species and facilitate movement while in the corridor. Larger, landscape-level corridors (often referred to as “habitat or landscape linkages”) can provide both transitory and resident habitat for a variety of species.

Wildlife Crossing: A small, narrow area, relatively short in length and generally constricted in nature, that allows wildlife to pass under or through an obstacle or barrier that otherwise hinders or prevents movement. Crossings typically are manmade and include culverts, underpasses, drainage pipes, and tunnels to provide access across or under roads, highways, pipelines, or other physical obstacles. These are often “choke points” along a movement corridor.

Wildlife Movement within Project Site
The Project Site is not located within or adjacent to an MSHCP designated core, extension of existing core, non-contiguous habitat block, constrained linkage, or linkage area.

Specifically, the Project Site is located adjacent (extending east and west) to ruderal vegetation which is collectively bound by high density residential development, high traffic roadways and commercial development. The Project Site does not represent a regional wildlife movement corridor and provides extremely limited cover, food, and no natural unrestricted water courses that would facilitate regional wildlife movement on or through the site.

REGIONAL AND REGULATORY SETTING

MSHCP COMPLIANCE ANALYSIS
Western Riverside County Multiple Species Habitat Conservation Plan Compliance Analysis
The proposed Project Site is located completely within the MSHCP, which is a comprehensive multi-jurisdictional effort that includes western Riverside County and eighteen (18) cities including the County of Riverside. Rather than addressing sensitive species on an individual basis, the MSHCP focuses on conservation of 146 species, including those listed at the federal and state levels and those that could become listed in the future. The MSHCP proposed a reserve system of approximate 500,000 acres, of which 347,000 acres are currently within public ownership and 153,000 acres will need to be assembled from lands currently in private ownership. The MHSCP allows the County and other permittees to issue take permits for listed species so that applicants do not need to receive endangered species incidental take authorization from the USFWS and CDFW.

On June 7th, 2003, the County Board of Supervisors adopted the MSHCP, certified the Environmental Impact Report/Environmental Impact Statement, and authorized the 637
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39 Chairman to sign the Implementing Agreement with the respective wildlife agencies. The Incidental Take Permit was issued by the wildlife agencies on June 22nd, 2004. The City of Moreno Valley is a Permittee under the MSHCP.

MSHCP Reserve Design & Criteria Area Objectives
Regions of the MHSCP have been organized into Area Plans that generally coincide with logical political boundaries, including city limits or long-standing unincorporated communities.

The project is located within the Reche Canyon/Badlands Plan Area. The Reche Canyon/Badlands Plan Area has a target conservation acreage of 30,815 - 35,905 acres; it is composed of approximately 20,295 -acres of existing Public/Quasi-Public Lands and 10,520 - 15,610 acres of Additional Reserve Lands. The target acreage range within the City of Moreno Valley is 10,520 - 15,610 acres (MSHCP 2004).

The Project Site is not located within an MSHCP Criteria Area Cell or Cell Group.

Therefore, no Habitat Evaluation and Acquisition Negotiation Strategy (HANS) or Joint Project Review (JPR) are required.

MSHCP Sensitive Species Surveys
The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.3.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site is not located within an MSHCP Amphibian Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site is not located within an MSHCP Mammal Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2.

The Project Site occurs almost completely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map. Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2024 focused survey efforts (Gonzales Environmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non-native vegetation as shown 638
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40 in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat.

An MSHCP preconstruction survey will be required at least 30-days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction survey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of the burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2.

MSHCP Riparian, Riverine, Vernal Pool Resources (Section 6.1.2) Regulated activities within inland streams, wetlands and riparian areas in Western Riverside County California fall under the jurisdiction of the MSHCP. The MSHCP requires, among other things, assessments for riparian/riverine and vernal pool resources. As projects are proposed within the MSHCP Plan Area, an assessment of the potentially significant effects of those projects on riparian/riverine areas, and vernal pools are required, as currently mandated by CEQA, using available information augmented by project-specific mapping provided to and reviewed by the permittee’s biologist(s).

Riparian/riverine areas and vernal pools are defined for this section as follows in accordance with Section 6.1.2, Vol. I, of the Final MSHCP Plan:
“Riparian/Riverine Areas are lands which contain habitat dominated by trees, shrubs, persistent emergents, or emergent mosses and lichens, which occur close to or which depend upon soil moisture from a nearby fresh water source; or areas with fresh water flow during all or a portion of the year.” (MSHCP 2004)
It is assumed the first part of the definition defines riparian habitat, and the second part defines riverine areas. Vernal pools are defined as:
“…seasonal wetlands that occur in depression areas that have wetlands indicators of all three parameters (soils, vegetation and hydrology) during the wetter portion of the growing season but normally lack wetlands indicators of hydrology and/or vegetation during the drier portion of the growing season. Obligate hydrophytes and facultative wetlands plant species are normally dominant during the wetter portion of the growing season, while upland species (annuals) may be dominant during the drier portion of the growing season”. (MSHCP 2004)
No MSHCP Section 6.1.2 riparian or riverine resources were documented within or adjacent to the Project Site. Specifically, no MSHCP Section 6.1.2 riparian scrub, forest or woodland resources representing suitable habitat for the least Bell’s vireo, southwestern willow flycatcher or western yellow-billed cuckoo was detected within or adjacent to the Project Site; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.2.

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41 No evidence of MSHCP Section 6.1.2 vernal pools, seasonal depressions, seasonally inundated road ruts or other wetland features were recorded on the Project Site. Vernal pools are depressions in areas where a hard-underground layer prevents rainwater from draining downward into the subsoils. When rain fills the pools in the winter and spring, the water collects and remains in the depressions. In the springtime, the water gradually evaporates away, until the pools became completely dry in the summer and fall. Vernal pools tend to have an impermeable layer that results in ponded water. The soil texture (the amount of sand, silt, and clay particles) typically contains higher amounts of fine silts and clays with lower percolation rates. Pools that retain water for a sufficient length of time will develop hydric cells. Hydric cells form when the soil is saturated from flooding for extended periods of time and anaerobic conditions (lacking oxygen or air) develop.

Consistent with conditions documented onsite and as previously stated, the Project Site is characterized as San Emigdio fine sandy loam possessing well drained substrates (drainage class). No indication of clay substrates or hydric soils were documented within the Project Site. A review of historic aerials was conducted to determine if inundated features were present during years of high rainfall when features would certainly be documented. Historic aerials taken in 2011 and 2023 represent an ideal baseline during which know (previously documented) inundated vernal pools, seasonal depressions and road ruts can easily be seen. No sign or indication of inundation was documented within the Project Site during a review of historic aerials. In summary, none of the conditions (i.e., no inundated depressions including road ruts, hydric soils, historic inundation, etc.) were observed on documented within the Project Site. No features are present that would support fairy shrimp. No standing water or other sign of areas that pond water was recorded. The project is consistent with MSHCP Section 6.1.2.

MSHCP Urban/Wildlands Interface Guidelines
The MSHCP Urban/Wildlands Interface guidelines presented in Section 6.1.4 are intended to address indirect effects associated with locating commercial, mixed uses and residential developments in proximity to a MSHCP Conservation Area. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.1.4.

MSHCP Fuels Management Guidelines
The fuels management guidelines presented in Section 6.4 of the MSHCP are intended to address brush management activities around new development within or adjacent to MSHCP Conservation Areas. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.4.

City of Moreno Valley (MSHCP Local Development Mitigation Fee) The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley. Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and 640
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42 Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

Stephens’ Kangaroo Rat Fee
At the time of permit issuance, a fee of $500 per acre is due for all new development.

Single-family residences where lots sizes are greater than ½ acre will only be subject to a flat fee of $500 per unit. Non-profit entities reduced by 75% as defined in 26 U.S.C. section 501 (c) (3).

LOCAL
City of Moreno Valley General Plan 2006
Conservation Element Goals (9.7.1) To achieve the wise use of natural resources within the City of Moreno Valley, its sphere of influence and planning area.

Conservation Element Objectives and Policies (9.7.2)
Objective 7.4 - Maintain, protect, and preserve biologically significant habitats where practical, including the San Jacinto Wildlife Area, riparian areas, habitats of rare and endangered species, and other areas of natural significance.

No sensitive biological resources, sensitive vegetation, riparian habitat, wetlands or endangered species are located within or adjacent to the Project Site. The Project Site is not located within or adjacent to the San Jacinto Wildlife Area. Regardless, implementation of Conservation Measures BIO-CM1 through BIO-CM4, would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements. The proposed action would not conflict with Objective 7.4.

Policy 7.4.1 – Require all development, including roads, proposed adjacent to riparian and other biologically sensitive habitats to provide adequate buffers to mitigate impacts to such areas.

The Project Site is not located adjacent to riparian and other biologically sensitive habitats. No riparian or other biologically sensitive habitats are located onsite. The proposed action would not conflict with Objective 7.4.1.

Policy 7.4.2 - Limit the removal of natural vegetation in hillside areas when retaining natural habitat does not pose threats to public safety.

The Project Site is not located within or adjacent to a hillside. The proposed action would not conflict with Objective 7.4.2.

Policy 7.4.3 - Preserve natural drainage courses in their natural state and the natural hydrology, unless the protection of life and property necessitate improvement as concrete channels.
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43 No resources including drainage courses regulated by the USACE, RWQCB and CDFW are located within or adjacent to the Project Site. The proposed action would not conflict with Objective 7.4.3.

Policy 7.4.4 - Incorporate significant rock formations into the design of hillside developments.

The Project Site is not located within or adjacent to a hillside and no rock outcrops or formations are located within or adjacent to the property. The proposed action would not conflict with Objective 7.4.4.

Policy 7.4.5 - The City shall fulfill its obligations set forth within any agreement(s) and permit(s) that the City may enter into for the purpose of implementing the Western Riverside County Multi Species Habitat Conservation Plan.

The project proposes conservation and avoidance measures to address those adverse impacts determined to be potentially significant or are relevant to the protection of endangered, threatened and sensitive species as part of ensuring compliance and compliance with all MSHCP conservation goals and CEQA guidelines.

The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley. Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside (BIO-CM3 SKR Fee Area).

City of Moreno Valley General Plan 2040
Goal OSRC-1: Preserve, protect, and enhance natural resources, habitats, and watersheds in Moreno Valley and the surrounding area, promoting responsible management practices.

Habitat Conservation and Species Protection
Policy OSRC.1-8: Cooperate with federal, State, and local regulatory agencies as well as non-profit organizations to promote the responsible stewardship of natural resources and habitats within the planning area.

No resources regulated by the USACE, RWQCB and CDFW are located within or adjacent to the Project Site. No sensitive vegetation is located within or adjacent to the Project Site. The proposed action would not conflict with Policy OSRC.1-8. 642
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44 Policy OSRC.1-9: Ensure that adverse impacts on sensitive biological resources, sensitive natural communities, sensitive habitat, and wetlands are avoided or mitigated to the greatest extent feasible as development takes place.

No sensitive biological resources, sensitive vegetation or wetlands are located within or adjacent to the Project Site. Regardless, implementation of Conservation Measures BIOCM1 through BIO-CM4, would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements.

Policy OSRC.1-10: In areas where development (including trails or other improvements) has the potential for adverse effects on special-status species, require project proponents to submit a study conducted by a qualified professional that identifies the presence or absence of special-status species at the proposed development site. If special-status species are determined to be present, require incorporation of appropriate mitigation measures as part of the proposed development prior to final approval.

Implementation of Conservation Measures BIO-CM1 through BIO-CM4, would reduce all potential significant unavoidable impacts special-status species below a level of significance and ensure compliance with MSHCP conservation requirements.

Policy OSRC.1-11: Require all development, including roads, proposed adjacent to riparian and other biologically sensitive habitats to mitigate impacts to such areas.

The Project Site is not located within or adjacent to biologically sensitive habitats including riparian scrub, forest or woodland vegetation. No Impact. The proposed action would not conflict with Policy OSRC.1-11.

Policy OSRC.1-12: Limit to the extent feasible the removal of natural vegetation in hillside areas when retaining natural habitat does not pose threats to public safety.

OSRC.1-13: Promote the use of conservation easements and preserves as means to conserve natural habitats and protect natural resources.

No natural undisturbed vegetation is present within or adjacent to the Project Site. The proposed action would not conflict with Policy OSRC.1-12.

Actions OSRC.1-D: Continue to participate in the implementation of regional habitat conservation and restoration programs, including the Western Riverside County Multiple Species Habitat Conservation Plan and the Stephens’ Kangaroo Rat Habitat Conservation Plan.

The project proposes conservation and avoidance measures to address those adverse impacts determined to be potentially significant or are relevant to the protection of endangered, threatened and sensitive species as part of ensuring compliance and compliance with all MSHCP conservation goals and CEQA guidelines. 643
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45 The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley. Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority.

The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside (BIO-CM3 SKR Fee Area).

City of Moreno Valley Municipal Code
No trees meeting the City of Moreno Valley tree removal ordinance as outlined in Municipal Code Chapter 9.17, Landscape and Water Efficiency Requirements are located within or adjacent to the Project Site. No impact.

FEDERAL
Federal Endangered Species Act
The MSHCP serves as an HCP pursuant to Section 10(a)(1)(B) of the FESA of 1973, allowing participating jurisdictions to authorize "take" of plant and wildlife species. The MSHCP has been issued under this Section and provides incidental take for all covered species.

Clean Water Act
The Clean Water Act, Section 401 provides guidance for the restoration and maintenance of the chemical, physical, and biological integrity of the nation’s waters. Section 401 requires a project operator to obtain a federal license or permit that allows activities resulting in a discharge to waters of the United States to obtain state certification, thereby ensuring that the discharge will comply with provisions of the CWA. The Regional Water Quality Control Board administers the certification program in California. Section 404 establishes a permit program administered by the USACE that regulates the discharge of dredged or fill material into waters of the United States, including wetlands. The USACE implementing regulations are found at 33 CFR 320 and 330. Guidelines for implementation are referred to as the Section 404(b)(1) Guidelines, which were developed by the United States Environmental Protection Agency in conjunction with the USACE (40 CFR 230). The guidelines allow the discharge of dredged or fill material into the aquatic system only if there is no practicable alternative that would have less adverse impacts.
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46 Wetland Definition Pursuant to Section 404 of the Clean Water Act Aquatic resources, including riparian areas, wetlands, and certain aquatic vegetation communities, are considered sensitive biological resources and fall under the jurisdiction of several regulatory agencies. The USACE exerts jurisdiction over waters of the United States, including all waters that are subject to the ebb and flow of the tide; wetlands and other waters such as lakes, rivers, streams (including intermittent or ephemeral streams), mudflats, sandflats, sloughs, prairie potholes, vernal pools, wet meadows, playa lakes, or natural ponds; and tributaries of the above features. The extent of waters of the United States is generally defined as the portion that falls within the limits of the OHWM. The OHWM is defined as the “line on the shore established by the fluctuation of water and indicated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas.”
On April 21, 2020 the U.S. Environmental Protection Agency (EPA) and the USACE published the Navigable Waters Protection Rule to define “Waters of the United States” in the Federal Register. The April 2020 definition includes four simple categories of jurisdictional waters, including: (1) the territorial seas and traditional navigable waters; (2) perennial and intermittent tributaries to those waters; (3) certain lakes, ponds and impoundments; and (4) wetlands adjacent to jurisdictional waters.

The April 2020 definition provides clear exclusions for many water features that traditionally have been regulated, such as ephemeral drainages. The April 2020 definition has been formally adopted by EPA and the USACE and was used for this Jurisdictional Delineation.

Wetlands, including swamps, bogs, seasonal wetlands, seeps, marshes, and similar areas, are defined by USACE as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR 328.3[b]; 40 CFR 230.3[t]). Indicators of three wetland parameters (i.e., hydric soils, hydrophytic vegetation, and wetlands hydrology), as determined by field investigation, must be present for a site to be classified as a wetland by USACE (USACE 1987).

It is important to note that the RWQCB definition of wetland was redefined and the new definition went into effect May 28th, 2020. The definition of a wetland is as follows: An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation. This RWQCB modified three-parameter definition is similar to the federal definition in that it identifies three wetland characteristics that determine the presence of a wetland: wetland hydrology, hydric soils, and hydrophytic vegetation. Unlike the federal definition, however, the RWQCB wetland definition allows for the presence of hydric substrates as a criterion for wetland identification (not just wetland soils) and 645
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47 wetland hydrology for an area devoid of vegetation (less than 5% cover) to be considered a wetland.

However, if any vegetation is present, then the USACE delineation procedures would apply to the vegetated component (i.e., hydrophytes must dominate). Examples of waters that would be considered wetlands by the RWQCB definition, but not by the federal wetland definition, are non-vegetated wetlands, or wetlands characterized by exposed bare substrates like mudflats and playas, as long as they meet the three-parameters as described in the RWQCB definition. It is important to note that while the USACE may not designate a feature as a wetland, that feature could be considered a special aquatic site or other water of the U.S. by the USACE and potentially subject to USACE jurisdiction.

Migratory Bird Treaty and Bald and Golden Eagle Protection Acts Migratory birds including resident raptors and passerines are protected under the federal MBTA. The MBTA of 1918 implemented the 1916 convention between the United States and Great Britain for the protection of birds migrating between the U.S. and Canada.

Similar conventions between the United States and Mexico (1936), Japan (1972) and the Union of Soviet Socialists Republics (1976) further expanded the scope of international protection of migratory birds. Each new treaty has been incorporated into the MBTA as an amendment and the provisions of the new treaty are implemented domestically. These four treaties and their enabling legislation, the MBTA, established Federal responsibilities for the protection of nearly all species of birds, their eggs and nests. The MBTA made it illegal for people to "take" migratory birds, their eggs, feathers or nests. Take is defined in the MBTA to include by any means or in any manner, any attempt at hunting, pursuing, wounding, killing, possessing or transporting any migratory bird, nest, egg, or part thereof. The Bald and Golden Eagle Protection Act affords additional protection to all bald and golden eagles.

STATE
California Endangered Species Act
The CESA is similar to FESA in that it contains a process for listing of species regulating potential impacts to listed species. Section 2081 of the CESA authorizes the CDFW to enter into a memorandum of agreement for take of listed species for scientific, educational, or management purposes. The MSHCP serves as an HCP pursuant the Natural Communities Conservation Plan (NCCP) under the NCCP Act of 2001, allowing participating jurisdictions to authorize "Take" of plant and wildlife species.

As stated by CDFW:
“On June 22, 2004, the Department issued NCCP Approval and Take Authorization for the Western Riverside County MSCHP per Section 2800 et seq. of the California Fish and Game Code. The MSHCP establishes a multiple species conservation program to minimize and mitigate habitat loss and the incidental take of covered species in association with activities covered under the permit.” (CDFG 2004)
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48 California Fish and Game Code 3503 and 3513
As stated by CDFW:
“CHAPTER 1. General Provisions [3500 - 3516] (Chapter 1 enacted by Stats. 1957, Ch. 456.) It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. (Amended by Stats. 1971, Ch. 1470.)”
Native Plant Protection Act
The Native Plant Protection Act (NPPA) enacted a process by which plants are listed as rare or endangered. The NPPA regulates collection, transport, and commerce in plants that are listed. The CESA follows the NPPA and covers both plants and wildlife determined to be threatened with extinction or endangered. Plants listed as rare under the NPPA are designated as threated under the CESA. No plants listed under the CESA occur on the Project Site onsite or offsite impact areas.

Regional Water Quality Control Board
The RWQCB also has jurisdiction over waters deemed “isolated” or not subject to Section 404 jurisdiction under the Solid Waste Agency of Northern Cook County v. Corps decision. Dredging, filling, or excavation of isolated waters constitutes a discharge of waste to waters of the state and prospective dischargers are required to obtain authorization through an Order of Waste Discharge or waiver thereof from the RWQCB and comply with other requirements of Porter-Cologne Act.

Under Section 401 of the CWA, the local RWQCB must certify that actions receiving authorization under Section 404 of the CWA also meet state water quality standards. The RWQCB requires projects to avoid impacts to wetlands if feasible and requires that projects do not result in a net loss of wetland acreage or a net loss of wetland function and values.

CDFW Streambed Alteration Agreement
Waters of the State are regulated by the California Department of Fish and Wildlife (CDFW) through Section 1600 et seq. of the California Fish and Game Code. Section 1600 et seq. requires notifying the CDFW prior to any project activity that might (1) substantially divert or obstruct the natural flow of any river, stream, or lake; (2) substantially change or use any material from the bed, channel, or bank of any river, stream, or lake; or (3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake.

If, after this notification, the CDFW determines that the activity may substantially adversely affect fish and wildlife resources, a Lake or Streambed Alteration Agreement will need to be obtained. CDFW may then place conditions in the Section 1602 Streambed Alteration Agreement to avoid, minimize, and mitigate any potentially significant adverse impacts within CDFW jurisdictional limits. 647
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49 The limits of Waters of the State are defined as the “body of water that flows at least periodically or intermittently through a bed or channel having banks and supports fish or other aquatic life. This includes watercourses having surface or subsurface flow that supports or has supported riparian vegetation." Therefore, the limits extend from the channel bed to the top of the bank, with the addition of the canopy of any riparian habitat associated with the watercourse.

ENVIRONMENTAL IMPACTS
The following sections include an analysis of the direct impacts, indirect impacts, and cumulative effects of the proposed action on sensitive biological resources. This analysis characterizes the project related activities that are anticipated to adversely impact the species, and when feasible, quantifies such impacts. Direct effects are defined as actions that may cause an immediate effect on the species or its habitat, including the effects of interrelated actions and interdependent actions. Indirect effects are caused by or result from the proposed actions, are later in time, and are reasonably certain to occur. Indirect effects may occur outside of the area directly affected by the proposed action.

Cumulative impacts refer to incremental, individual environmental effects of two or more projects when considered together. These impacts taken individually may be minor but may be collectively significant. Cumulative effects include future tribal, local, or private actions that are reasonably certain to occur in the proposal vicinity considered in this report. A cumulative impact to biological resources may occur if a project has the potential to collectively degrade the quality of the environment, substantially reduce the habitat of wildlife species or cause a population to drop below self-sustaining levels, thereby threatening to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal species.

THRESHOLD OF SIGNIFICANCE
The environmental impacts relative to biological resources are assessed using impact significance criteria which mirror the policy statement contained in the CEQA at Section 21001 (c) of the Public Resources Code. This section reflects that the legislature has established it to be the policy of the state to:
“Prevent the elimination of fish and wildlife species due to man’s activities, ensure that fish and wildlife populations do not drop below self-perpetuating levels, and preserve for future generations representations of all plant and animal communities…”
The following definitions apply to the significance criteria for biological resources:
• “Endangered” means that the species is listed as endangered under state or federal law.
• “Threatened” means that the species is listed as threatened under state or federal law. 648
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50 • “Rare” means that the species exists in such small numbers throughout all or a significant portion of its range that it may become endangered if its environment worsens.
• “Region” refers to the area within southern California that is within the range of the individual species.
• “Sensitive habitat” refers to habitat for plants and animals (1) which plays a special role in perpetuating species utilizing the habitat on the property, and (2) without which there would be substantial danger that the population of that species would drop below self-perpetuating levels.
• “Substantial effect” means significance loss or harm of a magnitude which, based on current scientific data and knowledge, (1) would cause a species or a native plant or animal community to drop below self-perpetuating levels on a statewide or regional basis or (2) would cause a species to become threatened or endangered.

Impacts to biological resources may result in a significant adverse impact if one or more of the following conditions would result from implementation of the proposed project. • Have a substantial adverse effect, either directly or through habitat modification, on any endangered, or threatened species, as listed in Tittle 14 of the California Code of Regulations (Sections 670.2 or 670.5) or Title 50, Code of Federal Regulations (Sections 17.11 or 17.12).
• Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS, and meets the definition of Section 15380 (b), (c), or (d) of the CEQA Guidelines. • Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS.
• Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. • Interfere substantially with the movement of any native resident or migratory fish and wildlife species or with established native resident migratory wildlife corridors, or impede the use of native nursery sites.
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
• Conflict with the provisions of an adopted HCP, NCCP, or other approved local, regional, or state conservation plan.
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51 Also, the determination of impacts has been made according to the federal definition of “take”. The federal FESA prohibits the “taking” of a member of an endangered or threatened wildlife species or removing, damaging, or destroying a listed plant species by any person (including private individuals and private or government entities). The FESA defines “take” as “to harass, harm, pursue, hunt, shoot, would, kill, trap, capture or collect” an endangered or threatened species, or to attempt to engage in these activities.

Specifically, the biological resources assessment report addresses the following CEQA Environmental Checklist items.

Environmental Issues Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Less than
Significant
Impact
No
Impact
Would the Project:
a) Have a substantial adverse effect, either
directly or through habitat modification, on
any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations,
or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife
Service?
X
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service?
X
c) Have a substantial adverse effect on
federally protected wetlands as defined by
Section 404 of the Clean Water Act
(including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal,
filling, hydrological interruption, or other
means?
X
d) Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?
X
e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?
X
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Native
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
X

DIRECT IMPACTS
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS? 650
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52 Sensitive Plants
The Project Site is not located within an MSHCP Narrow Endemic Plant Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.3. No Impact.

The Project Site is not located within an MSHCP Criteria Area Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2. No Impact.

No state or federally listed threatened or endangered plant species were documented or expected to occur onsite based on a lack of suitable habitat, as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite. No Impact.

No potential habitat and/or substrates was detected onsite for CNPS special-status plants not covered under the MSHCP, as outlined in Table 4, Sensitive Plant Species with Potential to Occur Onsite. No Impact.

Sensitive Wildlife
No vernal pools, depressions or inundated features are present that would support sensitive fairy shrimp. No Impact.

The Project Site is not located within an MSHCP Amphibian Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2. No Impact.

The Project Site occurs almost completely within a predetermined Survey Area for the burrowing owl, as shown in Figure 3, MSHCP Relationship Map. Updated focused MSHCP burrowing owl surveys were conducted during the spring of 2024. Initial focused burrowing owl surveys were conducted by Gonzales Environmental Consulting, LLC.

During the spring of 2020. No burrowing owls were documented within or adjacent to the Project Site during the 2020 or 2024 focused survey efforts (Gonzales Environmental Consulting, LLC. 2020b, Cadre Environmental 2024). No suitable burrowing owl burrows larger than 4 inches in diameter potentially utilized for refugia and/or nesting were documented within and/or adjacent to the property during the 2024 focused surveys. The Project Site is dominated by a 100% canopy of ruderal/non-native vegetation as shown in Figures 5 and 6, Current Project Site Photographs and does not currently represent suitable foraging habitat. An MSHCP preconstruction survey will be required at least 30- days immediately prior to the initiation of construction to ensure protection for this species and compliance with the conservation goals as outlined in the MSHCP. If burrowing owls are detected onsite during the burrowing owl preconstruction survey, a burrowing owl relocation plan will be developed for the passive/active translocation of individuals as directed by the City of Moreno Valley and MSHCP wildlife agencies. Following completion of the burrowing owl preconstruction survey, and compliance with MSHCP species guidelines, if detected, the project will be consistent with MSHCP Section 6.3.2 (BIO-CM2 MSHCP Burrowing Owl 30-Day Preconstruction Surveys). Less than Significant Impact.
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53 No MSHCP Section 6.1.2 riparian scrub, forest or woodland habitat is located within or adjacent to the Project Site. No suitable habitat for the least Bell’s vireo, southwestern willow flycatcher or western yellow-billed cuckoo was detected within or adjacent to the Project Site; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.1.2. No Impact

The Project Site is not located within an MSHCP Mammal Species Survey Area; therefore, no surveys are required (RCA GIS Data Downloads 2024). The project is consistent with MSHCP Section 6.3.2. No Impact.

Moderate to low potential habitat was documented onsite for five (5) MSHCP covered species including sharp-shinned hawk - foraging, grasshopper sparrow, California horned lark, northern harrier - foraging, and white-tailed kite - foraging, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite. As previously stated, the MSHCP has determined that these sensitive species potentially occurring within Project Site have been adequately covered (MSHCP Table 2-2 Species Considered for Conservation Under the MSHCP Since 1999, 2004). Potential impacts to MSHCP Covered sensitive wildlife species will be mitigated following payment of the MSHCP Local Development Mitigation Fee (BIO-CM1 MSHCP Local Development Mitigation Fee). Less than Significant Impact with Mitigation.

No suitable habitat was documented onsite for wildlife species not covered under the MSHCP, as outlined in Table 5, Sensitive Wildlife Species with Potential to Occur Onsite.

No Impact.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or USFWS?
No riparian scrub, forest or woodlands habitats are located within the Project Site. Also, as previously stated, no vegetation communities listed by CDFW as sensitive were documented within or adjacent to the Project Site. No Impact.

A total of 5.00-acres (4.81-acres onsite, 0.19-acre offsite) ruderal/disturbed, non-native grassland and developed vegetation communities will be directly and permanently impacted as a result of project implementation as summarized in Table 4, Project Site Vegetation Community Impacts, and illustrated on Figure 8, Vegetation Communities Impact Map. Compliance with the City of Moreno Valley MSHCP Local Development Mitigation Fees (Condition of Approval) would ensure direct impacts to all vegetation communities will remain consistent with MSHCP guidelines, BIO-CM1 MSHCP Local Development Mitigation Fee.

652
3 LECRAP
4118 MP
82/83 BMP
1 LECRAP
63661 MP
61/69 BMP
PARCEL 2
63661 MP
61/69 BMP
1 inch = 80 feet
CADRE
Environmental
Figure 8 - Vegetation Communities Impact Map
Biological Resources Technical Report
Tentative Tract Map 37858 - City of Moreno Valley, California Cactus Avenue
Bradshaw Circle

PROJECT SITE BOUNDARY
478-090-018
478-090-024
478-090-025
RW
Sources: Cadre Environmental 2024
Vegetation Communities
Non-native Grassland
Developed
NNG
DEV
RUD Ruderal/Disturbed
RUD
RUD
RUD
NNG
NNG
DEV
Project Site Onsite Impacts
Project Site Offsite Impacts

OFFSITE IMPACT BOUNDARY
® ® l
I ® w I
~~
[-J @ ® I
j
II ~
et)
®
® '
EB
~
CD ffi
1 xJ56L 5 \ ffi @y \
. ---.

I
. ---. fZZZJ
653
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55 Table 4.

Project Site Vegetation Community Impacts
Vegetation Type
Acres
(onsite)
Acres
(offsite)
Impact
Acres
TOTAL
Ruderal/Disturbed 3.11 0.00 3.11
Non-native Grassland 1.65 0.10 1.75
Developed 0.05 0.09 0.14
TOTAL 4.81 0.19 5.00
Source: Cadre Environmental 2024.
c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the CWA (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No wetlands are located within or adjacent to the Project Site. No Impact.

The project will comply with all applicable water quality regulations, including complying with a NPDES regulations and MS4 permit requirements. The MS4 permit places pollution prevention requirements on planned developments, construction sites, commercial and industrial businesses, municipal facilities and activities, and residential communities.

Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activities and the installation and proper maintenance of structural BMPs to ensure adequate long-term treatment of water before entering into any stream course or municipal system. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
The Project Site is not located within or adjacent to an MSHCP designated core, extension of existing core, non-contiguous habitat block, constrained linkage, or linkage area.

Specifically, the Project Site is located adjacent (extending east and west) to ruderal vegetation which is collectively bound by high density residential development, high traffic roadways and commercial development. The Project Site does not represent a regional wildlife movement corridor and provides extremely limited cover, food, and no natural unrestricted water courses that would facilitate regional wildlife movement on or through the site.

The Project Site possess vegetation expected to potentially provide nesting habitat for migratory birds protected under the MBTA and CDFG Code Section 3503, 3503.5, and 3513. Measures for potential direct/indirect impacts to common and sensitive bird and raptor species will require compliance with the MBTA and CDFG Code Section 3503, 3503.5, and 3513. Construction outside the nesting season (between September 1st and January 31
st) does not require preconstruction nesting bird surveys. However, if construction is proposed between February 1st and August 31st, a qualified biologist will conduct a preconstruction nesting bird and raptor survey(s) no more than three (3) days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent to the Project Site. Loss of an active nest would be considered a 654
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56 potentially significant impact. Impacts to nesting birds would be reduced to less than significant with mitigation following the implementation of Conservation Measure BIOCM4: Nesting Bird Preconstruction Surveys. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No trees meeting the City of Moreno Valley tree removal ordinance as outlined in Municipal Code Chapter 9.17, Landscape and Water Efficiency Requirements are located within or adjacent to the Project Site. No impact.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Native Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The Project Site is located within the Western Riverside County MSHCP Reche Canyon/Badlands Plan Area and is not located within an MSHCP Criteria Area Cell, Cell Group, or Linkage Area, as shown in Figure 3, MSHCP Relationship Map. Following implementation of BIO-CM1 MSHCP Local Development Mitigation Fee, BIO-CM2 MSHCP 30-Day Preconstruction Surveys, and BIO-CM4 Nesting Bird Preconstruction Surveys, the project will be in compliance with MSHCP guidelines. Less than Significant Impact with Mitigation.

A detailed summary of MSHCP compliance is presented in the Regional and Regulatory Setting/Western Riverside County Multiple Species Habitat Conservation Plan Compliance Analysis section of the report.

INDIRECT IMPACTS
MSHCP Urban/Wildlands Interface Guidelines
The MSHCP Urban/Wildlands Interface guidelines presented in Section 6.1.4 are intended to address indirect effects associated with locating commercial, mixed uses and residential developments in proximity to a MSHCP Conservation Area. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.1.4.

The fuels management guidelines presented in Section 6.4 of the MSHCP are intended to address brush management activities around new development within or adjacent to MSHCP Conservation Areas. The Project Site is not located adjacent to an existing or proposed MSHCP Conservation Area. The project is compliant with MSHCP Section 6.4.

Water Quality/Hydrology
The project will comply with all applicable water quality regulations, including obtaining and complying with those conditions established in (WDRs) and a NPDES permits. Both of these permits include the treatment of all surface runoff from paved and developed areas, the implementation of applicable BMPs during construction activities and the installation and proper maintenance of structural BMPs to ensure adequate long-term 655
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57 treatment of water before entering into any stream course. No significant impacts are anticipated.

Toxics
Storm water treatment systems will be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant material, or other elements that could degrade or harm downstream biological or aquatic resources. Toxic sources within the Project Site would be limited to those commonly associated with residential development, such as pesticides, insecticides, herbicides, fertilizers, and vehicle emissions. In order to mitigate the potential effects of these toxics, the project will incorporate structural BMPs, as required in association with compliance with the NPDES permit system, in order to reduce or prevent the level of toxins introduced into downstream resources including the San Jacinto River. No significant impacts are anticipated.

Lighting
The Project Site is not located within or adjacent to proposed conserved or sensitive receptor lands. No impact.

Noise
The Project Site is not located within or adjacent to proposed conserved or sensitive receptor lands. No impact.

CUMULATIVE IMPACTS
The direct and/or indirect impacts of the project would not result in cumulative impacts (CEQA Section 15310) to environmental resources within the region of the Project Site.

Cumulative impacts refer to incremental effects of an individual project when assessed with the effects of past, current, and proposed projects. The Project Site is located completely within the City of Moreno Valley, an MSHCP permittee. As stated in the County of Riverside Transportation and Land Management Agency:
”Implementation of the MSHCP and Covered Projects will not result in a cumulative adverse effect, either directly or through habitat modifications, on any of the Covered Species, including the 31 species that are currently listed as threatened or endangered and the one species that is currently proposed for listing. Implementation of the MSHCP will benefit the Covered Species by preserving their habitat in order to address their life cycle needs.

Thus, based on the features of the Plan itself, impacts to Covered Species are mitigated below a level of significance.” (County of Riverside Transportation and Land Management Agency 2003)
Although the project would result in the permanent loss of 5.00-acres (4.81-acre onsite,

0.19-acre offsite) of ruderal/disturbed, non-native grassland and developed vegetation communities, as referenced above, the MSHCP was developed to address the comprehensive regional planning effort and anticipated growth in the City of Moreno Valley.
656
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58 As stated in the County of Riverside Transportation and Land Management Agency:
“The Plan will not cause adverse cumulative effects related to the reduction of sensitive vegetation communities within the Plan Area; rather, the Plan is designed to preserve sufficient acreage of the sensitive vegetation communities present in western Riverside County. Similarly, the Plan will not cause adverse cumulative effects related to interference with the movement of any native resident or migratory fish or wildlife species or obstruction of genetic flow for the identified Planning Species. Part of the purpose and goals of the MSHCP is to use regional planning efforts to assemble a reserve that will preserve contiguous blocks of habitat in large enough areas to ensure that the reserve will allow movement of species and flow of genetic information.

The MSHCP will not cause adverse cumulative impacts by conflicting with the provisions of any adopted Habitat Conservation Plan, Natural Communities Conservation Plan or other approved local, regional, or State habitat conservation plan either within or outside of the Plan area. Rather, the MSHCP has been written specifically to complement existing HCPs, such as the Stephens’ kangaroo rat long-term HCP.” (County of Riverside Transportation and Land Management Agency 2003)
The proposed project has been designed and conservation measures will be implemented to remain in compliance with all MSHCP conservation goals and guidelines and therefore will not result in an adverse cumulative impact. No Impact.

CONSERVATION MEASURES
The following biological conservation measures address those adverse impacts determined to be potentially significant or are relevant to the protection of biological resources to the extent practicable as part of ensuring compliance and consistency with all MSHCP conservation goals and CEQA guidelines.

BIO-CM1 MSHCP Local Development Mitigation Fee
The project applicant shall pay MSHCP Local Development Mitigation fees as established by the RCA and implemented by the City of Moreno Valley. Five categories of the fee are defined, include and are effect till June 30th, 2026: Residential, density less than 8.0 dwelling units per acre $4,486 per dwelling unit; Residential, density between 8.1 and

14.0 dwelling units per acre $1,870 per dwelling unit; Residential, density greater than

14.1 dwelling units per acre $827 per dwelling unit; Commercial $20,191 per acre; and Industrial $20,191 per acre. Annual updated MSHCP fees are available at Permits and Fees | Western Riverside County Regional Conservation Authority. 657
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59 BIO-CM2 MSHCP Burrowing Owl 30-Day Preconstruction Surveys A pre-construction survey for burrowing owls is required within 30-days prior to initial ground-disturbing activities (e.g., vegetation clearing, clearing and grubbing, grading, tree removal, site watering, equipment staging) to ensure that no owls have colonized the site in the days or weeks preceding the ground-disturbing activities. If burrowing owls have colonized the project site prior to the initiation of ground-disturbing activities, the project proponent will immediately inform the City of Moreno Valley and the Wildlife Agencies and will need to coordinate further with City and the Wildlife Agencies, including the possibility of preparing a Burrowing Owl Protection and Relocation Plan, prior to initiating ground disturbance. If ground-disturbing activities occur, but the site is left undisturbed for more than 30 days, a pre-construction survey will again be necessary to ensure that burrowing owl have not colonized the site since it was last disturbed. If burrowing owl is found, the same coordination described above will be necessary. Following completion of the 30-day preconstruction survey in compliance with MSHCP conservation goals for the target species, the project will be consistent with MSHCP Section 6.3.2.

BIO-CM3 SKR Fee Area
The Project Site falls within the SKR Fee Area outlined in the Riverside County SKR HCP.

The project applicant shall pay the fees pursuant to County Ordinance 663.10 for the SKR HCP Fee Assessment Area as established and implemented by the County of Riverside.

BIO-CM4 Nesting Bird Preconstruction Surveys
Regulatory requirement for potential direct/indirect impacts to nesting common and sensitive bird species will require compliance with the MBTA and CDFG Code Section 3503, 3503.5, and 3513. Construction outside the nesting season (between September 1 st and January 31st) do not require pre-removal nesting bird surveys. If construction is proposed between February 1st and August 31st, a qualified biologist will conduct a preconstruction nesting bird and raptor survey(s) no more than three (3) days prior to initiation of grading to document the presence or absence of nesting birds within or directly adjacent to the Project Site.

The survey(s) will focus on identifying any bird nests that would be directly or indirectly affected by construction activities. If active nests are documented, species-specific measures will be prepared by a qualified biologist and implemented to prevent abandonment of the active nest. At a minimum, grading in the vicinity of a nest will be postponed until the young birds have fledged. The perimeter of the nest setback zone will be fenced or adequately demarcated with stakes and flagging at 20-foot intervals, and construction personnel and activities restricted from the area. A survey report by a qualified biologist verifying that no active nests are present, or that the young have fledged, will be submitted to the City of Moreno Valley for review and approval prior to initiation of grading in the nest-setback zone. The qualified biologist will serve as a construction monitor during those periods when construction activities occur near active nest areas to ensure that no inadvertent impacts on these nests occur. A final monitoring report of the findings, prepared by a qualified biologist, will be submitted to the City of Moreno Valley documenting compliance with the CDFG Code. Any nest permanently vacated for the season would not warrant protection pursuant to the CDFG Code. 658
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60 Implementation of Conservation Measures BIO-CM1 through BIO-CM4 would reduce all potential significant unavoidable impacts on biological resources below a level of significance and ensure compliance with MSHCP conservation requirements.

LITERATURE CITED
American Ornithologist Union (AOU). 1998. Check-list of North American Birds. 7th ed.

American Ornithologists’ Union, Washington, DC.

Baker, R. J., L. C. Bradley, R. D. Bradley, J. W. Dragoo, M. D. Engstrom, R. S. Hoffman, C. A. Jones, F. Reid, D. W. Rice, and C. Jones. 2003. Revised checklist of North American mammals north of Mexico. Occasional Papers of the Museum of Texas Tech University. No. 229: 1-23.

Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, eds. 2012. The Jepson manual: vascular plants of California, 2 nd ed. University of
California Press, Berkeley.

Bennett, A. F. 1990. Habitat Corridors: their role in wildlife management and conservation, Department of Conservation and Environment, Melbourne, Australia.

Cadre Environmental. 2024. Focused Burrowing Owl Surveys – TTM 37858.

California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation.

California Department of Fish and Wildlife (CDFW), Natural Diversity Data Base (CNDDB). 2024a. Sensitive Element Record Search for the Sunnymead Quadrangle.

California Department of Fish and Wildlife. Sacramento, California. Accessed June 2024.

California Department of Fish and Wildlife (CDFW). 2024b. Special Animals. Natural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024c. State and Federally Listed Endangered and Threatened Animals of California. Natural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024d. Endangered, Threatened, and Rare Plants of California. Natural Heritage Division, Natural Diversity Data Base.

California Department of Fish and Wildlife (CDFW). 2024e. Special Vascular Plants, Bryophytes, and Lichens. Natural Heritage Division, Natural Diversity Data Base. 659
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61 California Department of Fish and Wildlife (CDFW) 2024f. https://wildlife.ca.gov/Explore/Organization/BDB
California Native Plant Society. 2001. Botanical survey guidelines of the California Native Plant Society. Fremontia 29: 64-65.

California Native Plant Society. 2024. Inventory of Rare and Endangered Plants in California, 8th Edition, http://www.cnps.org/cnps/rareplants/inventory/ Accessed March 2024.

City of Moreno Valley. 2021. General Plan Amendment 2040.

City of Moreno Valley. 2006. General Plan.

County of Riverside. 2006. Burrowing Owl Survey Instructions – Western Riverside Multiple Species Habitat Conservation Plan Area.

Environmental Laboratory. 1987. USACE of Engineers Wetlands Delineation Manual, Technical Report Y-87-1, U.S. Army Engineer Waterways Experimental Station, Vicksburg, Mississippi.

Farhig, L. and G. Merriam. 1985. Habitat patch connectivity and population survival.

Ecology 66:1762-1768.

Ferren, W.R., Jr., P.L. Fiedler, R.A. Leidy, K. D. Lafferty, and L. A. K. Mertes. 1996b.

Wetlands of California. Part III. Key to the catalogue of wetlands of the central California and southern California coast and coastal watershed. Madroño 32:183- 223.

Ferren, W.R., Jr., P.L. Fiedler, and R.A. Leidy. 1996c. Wetlands of California. Part I.

History of wetland habitat. Madroño 32:105-124.

Gonzales Environmental Consulting, LLC. 2020a. Habitat Assessment including the results of Focused Burrowing Owl Survey and Overview MSHCP Consistency Tentative Tract Map 37585.

Gonzales Environmental Consulting, LLC. 2020b. Habitat Assessment and Focused Surveys for Burrowing Owl Tentative Tract Map 37585.

Grinnell, J. 1933. Review of the recent mammal fauna of California. Univ. Calif. Publ. Zool. 40:71-234
Hickman, J. C. 1993. The Jepson Manual: Higher Plants of California. Berkeley:

University of California Press.

Jepson Flora Project. 2024 (v. 1.0 & supplements). Jepson eFlora. http://ucjeps.berkeley.edu/IJM.html. Accessed March 2024. 660
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62 Klein, A., and J. Evens. 2005. Vegetation alliances of western Riverside County, California. Final draft report prepared for California Department of Fish and Game, Habitat Conservation Division, Contract Number P0185404, California Native Plant Society, Sacramento, California.

Knecht, A. 1971. Soil Survey of Western Riverside Area, California. United States Department of Agriculture, Soil Conservation Service, Washington, DC.

McArthur, R. and Wilson, E. O. 1967. The theory of Island Biogeography. Princeton University Press, 1967.

Multiple Species Habitat Conservation Plan (MSHCP), Riverside County Integrated Project (RCIP). March 2004.

Noss, R. F. 1983. A regional landscape approach to maintain diversity. BioScience 33:700-706.

Roberts, F. M., Jr., S. D. White, A. C. Sanders, D. E. Bramlet, and S. Boyd. 2004. The vascular plants of western Riverside County, California: an annotated checklist.

F.M. Roberts Publications, San Luis Rey, California, USA.

Simberloff, D. and J. Cox. 1987. Consequences and cost of conservation corridors.

Conservation Biology 1:63-71.

Skinner, M. W. and B. M. Pavlik. 1994. California Native Plant Society's Inventory of Rare and Endangered Vascular Plants of California. California Native Plant Society. Special Publication, no. 1, 5th ed. Sacramento, California.

Soil Survey Staff, Natural Resources Conservation Service (NRCS), United States Department of Agriculture (USDA). Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed March 2024.

United States Fish and Wildlife Service. 2024. Threatened and Endangered Species.

Pacific Southwest Region. Carlsbad Office. Available online at http://www.fws.gov/carlsbad/SpeciesStatusList/CFWO_Species_Status_List%20. htm Accessed March 2024.

Certification “I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this biological evaluation, and that the facts, statements, and information presented are true and correct to the best of my knowledge.

Author:___________________________________________Date:___October 10, 2025 ______________ 661
Contact: Ruben S. Ramirez, Jr. 949-300-0212, [email protected] 662
701 Palomar Airport Road, Suite 300 – Carlsbad, California 92011 Tel (949) 300-0212, [email protected]

INFORMATION SUMMARY
A. Report Date: March 18th, 2024 (Updated September 19th, 2025) B. Report Title: Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Focused Burrowing Owl Surveys for the 4.81-Acre Bradshaw Collection Tentative Tract Map 37858, City of Moreno Valley, Western Riverside County, California.

C. APN#s: 478-090-018, 478-090-024, and 478-090-025 (offsite right-of-way).

D. Project Location: USGS 7.5’ Series Sunnymead Quadrangle, Riverside County, Township 3 South, Range 3 West, Section 14, Extending North of Cactus Avenue and East of Bradshaw Circle, as shown in
Attachment A, Regional Location Map and Attachment B, Project Site Map.

E. Applicant: RC Hobbs Companies
1428 East Chapman Avenue
Orange, CA 92866
Contact: Shay Mueller (714) 633-8100
[email protected]
F. MOU Principal: Cadre Environmental
701 Palomar Airport Road, Suite 300,
Carlsbad, CA 92011
Contact: Ruben S. Ramirez, Jr. (949) 300-0212
[email protected]
G. Date of Surveys: March 12th, 13th, 14th, and 15th, 2024.

H. Summary: The 4.81-acre property including 0.19-acre offsite impact area (rightof-way), 5.00-acres total is located within the Western Riverside County MSHCP Reche Canyon/Badlands Plan Area and is not located within a Criteria Area, Cell Group or linkage area.

The MSHCP has determined that all of the sensitive species potentially occurring onsite have been adequately covered (MSHCP Table 2-2 Species Considered for Conservation Under the MSHCP Since 1999, 2004). However, additional surveys may be required for narrow endemic plants, criteria area species, and specific wildlife species, if suitable habitat is documented onsite and/or if the property is located within a predetermined “Survey Area” (MSHCP 2004).

CADRE
Environmental
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Bradshaw Collection Tentative Tract Map 37858
MSHCP Focused Burrowing Owl Survey Report