CITY OF
MORENO VALLEY
INITIAL STUDY/MITIGATED NEGATIVE
DECLARATION FOR THE BRADSHAW
COLLECTION PROJECT (TTM 37858)
Bradshaw Collection Project (TTM 37858)
Case Numbers: PEN24-0021 (Tentative Tract Map No. 37858), PEN24-0022 (Conditional Use Permit for Planned Unit Development), PEN24-0023 (General Plan Amendment), and PEN24-0024 (Change of Zone)
October 2025
Lead Agency
CITY OF MORENO VALLEY
14177 Frederick Street
Moreno Valley, CA
92552
Prepared By EPD Solutions, Inc.
3333 Michelson Drive, Suite 500
Irvine, CA 92612
(949) 794-1180
WHE R E OR AM.\ .\OAR
This page intentionally left blank.
Bradshaw Collection Project Page iii City of Moreno Valley
TABLE OF CONTENTS
MITIGATED NEGATIVE DECLARATION ........................................................................ 1 BACKGROUND INFORMATION AND PROJECT DESCRIPTION .................................. 1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ......................................... 32 DETERMINATION (To be completed by the Lead Agency) ........................................... 32 EVALUATION OF ENVIRONMENTAL IMPACTS ......................................................... 33 ISSUES & SUPPORTING INFORMATION SOURCES ................................................. 34 I. AESTHETICS ........................................................................................... 34 II. AGRICULTURE AND FOREST RESOURCES ........................................ 37 III. AIR QUALITY ........................................................................................... 38 IV. BIOLOGICAL RESOURCES .......................................................................... 43 V. CULTURAL RESOURCES ............................................................................. 46 VI. ENERGY .................................................................................................. 50 VII. GEOLOGY AND SOILS ........................................................................... 54 VIII. GREENHOUSE GAS EMISSIONS .......................................................... 59 IX. HAZARDS AND HAZARDOUS MATERIALS ........................................... 61 X. HYDROLOGY AND WATER QUALITY .................................................... 65 XI. LAND USE AND PLANNING.................................................................... 71 XII. MINERAL RESOURCES ......................................................................... 74 XIII. NOISE ...................................................................................................... 75 XIV. POPULATION AND HOUSING ................................................................ 79 XV. PUBLIC SERVICES ................................................................................. 80 XVI. RECREATION .......................................................................................... 83 XVII. TRANSPORTATION ................................................................................ 83 XVIII. TRIBAL CULTURAL RESOURCES ......................................................... 86 XIX. UTILITIES AND SERVICE SYSTEMS ..................................................... 91 XX. WILDFIRE ................................................................................................ 93 XXI. MANDATORY FINDINGS OF SIGNIFICANCE ........................................ 95 DOCUMENT PREPARERS AND CONTRIBUTORS ..................................................... 97
Bradshaw Collection Project Page iv City of Moreno Valley
TABLES
Table AES-1: Project Development Standard Consistency. ....................................................... 35 Table AQ-1: SCAQMD Regional Daily Emissions Thresholds .................................................... 39 Table AQ-2: Construction Emissions Summary .......................................................................... 39 Table AQ-3: Summary of Peak Operational Emissions ............................................................... 40 Table AQ-4: Localized Significance Summary of Construction ................................................... 41 Table AQ-5: Localized Significance Summary of Operations ...................................................... 41 Table E-1: Estimated Construction Equipment Diesel Fuel Consumption ................................... 50 Table E-2: Estimated Construction Vehicle Trip Related Fuel Consumption .............................. 51 Table E-3: Estimated Annual Operational Energy Consumption ................................................. 51 Table E-4: 2006 General Plan Consistency ................................................................................ 52 Table E-5: 2024 General Plan Consistency ................................................................................ 53 Table GHG-1: Greenhouse Gas Emissions ................................................................................ 60 Table WQ-1: Total Retail Water Supply (AFY) ............................................................................ 67 Table LU-1: Consistency with RS10 District Development Standards ........................................ 72 Table N-1: City of Moreno Valley Maximum Continuous Sound Levels ...................................... 75 Table N-2: Existing Ambient Noise Level Measurements ........................................................... 75 Table N-3: Construction Noise Levels at the Nearest Sensitive Receptor .................................. 76 Table N-4: Roadway Noise Impacts – Existing Conditions ......................................................... 76 Table N-5: Roadway Noise Impacts – 2040 Conditions .............................................................. 77 Table N-6: Onsite Operational Noise Levels ............................................................................... 77 Table N-7: Typical Vibration Source Levels for Construction Equipment .................................... 78 Table N-8: Construction Vibration Impacts ................................................................................. 78 Table T-1: Project Trip Generation .............................................................................................. 84
FIGURES
Figure 1. Regional Location .......................................................................................................... 7 Figure 2. Local Vicinity .................................................................................................................. 9 Figure 3. Aerial View .................................................................................................................. 11 Figure 4a. Existing General Plan Designation ............................................................................ 13 Figure 4b. Proposed General Plan Designation ........................................................................ 15 Figure 5a. Existing Zoning ........................................................................................................... 17 Figure 5b. Proposed Zoning ........................................................................................................ 19 Figure 6: Conceptual Site Plan .................................................................................................... 21 Figure 7: Wall and Fence Plan .................................................................................................... 23 Figure 8: Offsite Improvements ................................................................................................... 25 Figure 9: Conceptual Landscape Plan ......................................................................................... 27
MITIGATION MONITORING AND REPORTING PROGRAM (Separate Document)
APPENDICES (Separate Documents)
A Air Quality, Greenhouse Gas, and Energy Impact Study
B Biological Resources Technical Report
C Focused Burrowing Owl Surveys and MSHCP Consistency
D Phase I Cultural Resources Investigation and Paleontological Overview E Preliminary Soil Investigation
F Phase I Environmental Site Assessment
G Preliminary Hydrology Report
H Preliminary Project Specific Water Quality Management Plan I Noise Impact Analysis
J Trip Generation and VMT Screening Analysis
Bradshaw Collection Project Page 1 City of Moreno Valley
INITIAL STUDY/MITIGATED
NEGATIVE DECLARATION
(IS/MND) FOR BRADSHAW
COLLECTION PROJECT
(TTM 37858)
MITIGATED NEGATIVE DECLARATION
Project Name: Bradshaw Collection Project (TTM 37858)
Findings: It is hereby determined that, based on the information contained in the attached Initial Study, the Project would not have a significant adverse effect on the environment.
Mitigation measures necessary to avoid the potentially significant effects on the environment are included in the attached Initial Study, which is hereby incorporated and fully made part of this Mitigated Negative Declaration. The City of Moreno Valley has hereby agreed to implement each of the identified mitigation measures, which would be adopted as part of the attached Mitigation Monitoring and Reporting Program.
BACKGROUND INFORMATION AND PROJECT DESCRIPTION:
1. Project Case Number(s): PEN24-0021 (Tentative Tract Map No. 37858), PEN24- 0022 (Conditional Use Permit for Planned Unit Development), PEN24- 0023 (General Plan Amendment), PEN24- 0024 (Change of Zone)
2. Project Title: Bradshaw Collection Project (TTM 37858)
3. Public Comment Period: October 17, 2025, through November 17, 2025
4. Lead Agency: City of Moreno Valley
Grace Espino-Salcedo, Planning Department
14177 Frederick Street
Moreno Valley, California 92552
(951) 413-3206
[email protected]
Documents Posted At: http://www.moval.org/cdd/documents/about-projects.html
6. Prepared By: Konnie Dobreva, JD
Meaghan Truman
Lauren Battle
EPD Solutions, Inc.
3333 Michelson Drive, Suite 500, Irvine, California 92612 (949) 794-1180
7. Project Sponsor:
Applicant/Developer
WHERE OREAM .I .\OAR
Bradshaw Collection Project Page 2 City of Moreno Valley RC Hobbs Company
1428 Chapman Avenue
Orange, CA 92866
8. Project Location: The Project site is approximately 4.81 acres at the northeast corner of the intersection of Bradshaw Circle and Cactus Avenue in the eastern portion of the City of Moreno Valley (Project S ite). Offsite improvements would include approximately 0.19 acres. The City of Moreno Valley (City) encompasses approximately 52 square miles of land within Riverside County and is bounded by the City of Riverside to the east; the City of Perris and Lake Perris State Recreation Area to the south; the Badlands mountain range and City of Beaumont to the east; and the Box Springs Mountains range and the City of Redlands (within San Bernardino County) to the north. See Figure 1, Regional Location.
Regional access to the Project S ite is provided by State Route 60 (SR -60) and Interstate 215 (I-215). Local access to the Project Site is provided by Moreno Beach Drive and Cactus Avenue. The Project S ite is located within the U.S.
Geological Survey (USGS) Sunnymead 7.5 Minute Series Topographic Quadrangle.
9. General Plan Designation: Residential (5 du/ac)
Residential 5: The primary purpose of areas designated Residential 5 is to provide for single-family detached housing on standard sized suburban lots at a density of 5 dwelling units per net acre.
10. Specific Plan Name and Designation: N/A
11. Existing Zoning: Residential 5 District (R5)
Residential 5 District: The primary purpose of the R5 district is to provide for residential development on common sized suburban lots. This district is intended as an area for development of single-family residential and mobile home subdivisions at a maximum allowable density of 5 dwelling units per net acre, as indicated in Section
9.03.020 of the Moreno Valley Municipal Code (MVMC).
12. Surrounding Land Uses and Setting:
Land Use General Plan Zoning
Project
Site Vacant Residential 5 Residential 5 (R5) District
North Single-Family Residential Residential 5 Residential 5 (R5)
South Single-Family Residential Residential 10 Suburban Residential (SP 193 ML)
East Vacant/Undeveloped
Residential
10 Residential 10 (R10)
West
Vacant/Undeveloped,
Single-family Residential Residential 5 Residential 5 (R5)
13. Description of the Site and Project:
Environmental Setting
Bradshaw Collection Project Page 3 City of Moreno Valley Existing Project Site
The Project Site consists of 4.81 acres and 0.19 acres of offsite improvements to make for a total disturbance area of 5 acres. The Project consists of nine parcels (onsite APNs 478-090-018, 478-090-024, 478-090-025) (offsite APNs 478-090-020, 478-090-021, 478-090-022, 478-090-023, 478-090-012 and 478-090-015) and is comprised of vacant and graded lots. Vehicular access to the site is provided by Bradshaw Circle and Cactus Avenue as shown on Figure 2, Local Vicinity, and Figure 3, Aerial View. The perimeter of the site is partially secured by a chain-link fence along the perimeter of the site.
Existing vegetation at the Project Site consists of a dense cover of grasses as well as one Palo Verde and one Palm tree. The topography of the Project site is relatively flat with a gentle slope of less than one percent across the site.
Existing Land Use and Zoning Designations
As shown on Figure 4a, Existing General Plan Designation, the Project Site currently has a General Plan land use designation of Residential: Max. 5 du/ac (R5). The primary purpose of areas designated Residential 5 is to provide for single- family detached housing on standard sized suburban lots. The maximum allowable density is 5 dwelling units per net acre.
As shown on Figure 5a, Existing Zoning, the Project Site is currently zoned Residential 5 District (R5). The primary purpose of the R5 district is to provide for residential development on common sized suburban lots. This district is intended as an area for development of single-family residential and mobile home subdivisions at a maximum allowable density of five dwelling units per net acre, as indicated in MVMC Section
9.03.020.
Project Description
Introduction
The proposed Project would develop 37 single-family residential lots, onsite roadways with sidewalks, drainage infrastructure, and open space lots on the 4.81-acre Project Site (Project). The proposed Project would also contain offsite improvements within Brawshaw Circle. The improvements would repave Bradshaw Circle within parcels 478- 090-012, 478-090-015, 478- 090-022, 478- 090-023, 478- 090-020, and 478- 090-021 and provide new curbs, gutters and street lighting. Figure 6, Conceptual Site Plan , illustrates the proposed site configuration following Project implementation, Figure 7, Wall and Fence Plan, shows the proposed walls and fencing for the Project, and Figure 8, Offsite Improvements, shows the proposed offsite improvements for the Project.
As the Project proposes a residential density of 7.9 dwelling units per acre, the Project requires a General Plan Amendment to change the site’s land use designation from Residential: Max. 5 du/ac (R5) to Residential: Max. 10 du/ac (R10) and a Change of Zone from Residential 5 District (R5) to Residential Single- Family 10 (RS10) District. The Project also requires approval of a Tentative Tract Map (TTM 37858) to consolidate existing parcels and establish 37 residential and open space lots , as well as a Conditional Use Permit (CUP) for a Planned Unit Development (PUD).
Project Characteristics
The single-family residences would range in size from 1,864 SF to 2,526 SF with a
Bradshaw Collection Project Page 4 City of Moreno Valley minimum lot size of 3,095 SF. The Project proposes three distinct floor plans, private yards, and two-car garages for the residential lots. In addition, the Project proposes lots designated for open space and drainage purposes. Two bioretention drainage basins (Lot A and Lot B) are located along the western portion of the Project site and a linear 3- foot-wide drainage ditch (Lot C) is located along the eastern property line. An approximately 10,983 SF recreation– open space lot (Lot D) is located near the center of the residential development, which would include landscaping, walkways, playground, basketball court , and seating areas. New walkways are also proposed throughout the residential development. The Project would provide private yards within the single-family residential lots. The Project would include a total of 15,961 SF of open space.
Architectural Design
The proposed single-family residences would be designed with Spanish, French, and Traditional architectural elements, multi -level rooflines, and an earth tone color scheme. In addition, the residences would incorporate stucco finishes, detailed roof elements, and decorative windows and doors in the exterior design. All units will be designed with four-sided architecture using the details from the front elevation. . The tallest roofline of the two-story residences would be less than 30 feet in height.
The proposed two-story single-family residences would include three different floor plans and two different architectural styles to provide aesthetic variation throughout the community. Plan 1, Plan 2, and Plan 3 homes would include a traditional two-story home design with either Spanish, French, or Traditional architectural elements.
Access and Circulation
Vehicular access to the Project site would be provided via two driveways on Bradshaw Circle, which would provide access to the community’s internal roadways. The single- family residences would be accessed by private driveways along the internal roadways, as shown on Figure 6, Conceptual Site Plan. The Project also includes pedestrian paths to provide for non-vehicular onsite circulation and for connection to existing sidewalks and bike lanes adjacent to the proposed Project.
The proposed Project would provide garage, driveway, and on -street parking. Each residence would have a two car garage with two driveway parking spaces.
Bradshaw Circle would be improved with new paving, curbs, gutters and street lighting along parcels 478-090-015, 478-090-022, 478-090-023, 478-090-020, and 478-090- 021.
This offsite street improvement would provide improved access to the Project site and surrounding properties. The Project would include dedication of the Bradshaw Circle right- of-way to the City of Moreno Valley.
Landscaping
Landscaping proposed as part of the Project would consist of drought-tolerant ornamental trees, shrubbery, and groundcover. Turf would be provided in active use areas in common open spaces. The landscape plan would be consistent with the City’s landscape and irrigation design standards, as provided in MVMC Section 9.17.030.
Bradshaw Collection Project Page 5 City of Moreno Valley Figure 9, Conceptual Landscape Plan, illustrates the proposed landscaping for the Project.
Lighting
Outdoor lighting included as part of future development on the Project S ite would be typical of single-family residential PUDs and would consist of wall-mounted lighting as well as pole- mounted lights along the proposed internal roadways. Nighttime lighting would be used as accent/security lighting in the park area. The Project’s outdoor lighting would be directed downward and shielded to minimize offsite spill. The location of all exterior lighting would comply with lighting standards established in the MVMC.
Infrastructure Improvements
Water and Sewer
The proposed Project would install a new 8-inch diameter sewer line and 8-inch diameter water line within the Project’s proposed onsite private streets and within Bradshaw Circle where these new lines would connect to an existing 21-inch diameter sewer line and 12-inch diameter water line, respectively, within Cactus Avenue.
Drainage
In the existing condition, the topography of the Project Site is relatively flat with a small elevation change towards Bradshaw Circle. The Project site’s current surface runoff generally sheet flows to the southwest. In the developed condition, onsite flows would be conveyed to one of two onsite water quality bioretention basins (Lots A and B), and both of these basin lots would connect to a new 24- inch diameter storm drain in Bradshaw Circle that would connect to the existing Storm Drain Line F-4 within Cactus Avenue that is operated by the Riverside County Flood Control and Water Conservation District (RCFC).
Parcel Consolidation
The Project would consolidate the three existing parcels (onsite APNs 478-090-018, 478- 090-024, 478- 090-025) into one Tentative Tract Map with 37 residential lots . This consolidation would not affect the surrounding parcels in the project vicinity.
GENERAL PLAN AND ZONING
As discussed, the Project requires a General Plan Amendment to change the designation of the site to Residential: Max. 10 du/ac (R10) and Change of Zone to Residential Single- Family 10 (RS10) District in order to implement the Project, which proposes single-family residential uses at a density of 7.9 dwelling units per acre. MVMC Section 9.03.020 states that the primary purpose of the Residential Single-Family 10 (RS10) District is to provide for residential development on small single-family lots with amenities not generally found in suburban subdivisions. The district is intended for subdivisions at a maximum allowable density of ten (10) dwelling units per net acre.
Following approval of the General Plan Amendment and Change of Zone, the Project would be consistent with the land use designation and zoning classification associated with the Project Site.
As a result of Project implementation, all other offsite land use designations and zoning
Bradshaw Collection Project Page 6 City of Moreno Valley classifications in the Project vicinity would remain the same as under existing conditions.
Bradshaw Collection Project Page 7 City of Moreno Valley
CONSTRUCTION DURATION
Construction activities include demolition of the existing structures, pavement, and the existing utility infrastructure; grubbing, grading, excavation and re-compaction of soils; utility and infrastructure installation; building construction; roadway pavement; and architectural coatings. Approximately 8,097 cubic yards of soil are proposed to be exported during grading activities.
Construction activities for the Project would occur over 12 months and would begin in 2026 with the opening for Project occupancy in 2027. Construction activities would occur in the following stages: site preparation, grading, building construction, architectural coating, and paving. Pursuant to the MVMC Chapter 8.14.040, construction activities would be limited to between the hours of 7:00 a.m. to 7:00 p.m. Monday through Friday, excluding holidays and from 8:00 a.m. to 4:00 p.m. on Saturday, unless written approval is obtained from the City building official or City engineer.
DISCRETIONARY APPROVALS
In accordance with Sections 15050 and 15367 of the State CEQA Guidelines, the City is the designated Lead Agency for the proposed Project and has principal authority and jurisdiction for CEQA actions and project approval. Responsible Agencies are those agencies that have jurisdiction or authority over one or more aspects associated with the development of a proposed Project and/or mitigation. Trustee Agencies are State agencies that have jurisdiction by law over natural resources affected by a proposed Project.
The following discretionary approvals by the City, as Lead Agency, are anticipated to be necessary for implementation of the proposed Project:
CITY OF MORENO VALLEY
• General Plan Amendment to change the site’s land use designation from Residential 5: Max. 5 du/ac (R5) to Residential 10: Max. 10 du/ac (R10)
• Change of Zone from Residential 5 District (R5) to Residential Single-Family 10 (RS10) District
• Approval of Tentative Tract Map (TTM 37858)
• Approval of a Conditional Use Permit (CUP) for a Planned Unit Development (PUD)
Bradshaw Collection Project Page 8 City of Moreno Valley
Regional Location
Bradshaw Collection Project (TTM 37858) Figure 1
Co lt o n
ff'<-; Gr., 1-.:I T e r r.,ce
rand
____ ::~~-----
Jtg rove
BOX
0 SPRINGS
MEAD
VALLEY
General
old Golf
Course
1.25 2.5
l.:0ma 11L!iAda
MOUNTAINS
f\llenton e
B ry nl...,IA:lw r r - - -
..
--~~~oj ~S~!_B:~~l!l.<?. ____ . --- ___ • ______ . ,
Count l'of' Riv e rs ide C 1. 't,.., a 1mesa o<c;,
l
Norto l
Youngl
......
Moreno Valley G)
l,l oreno Valley
March A ir
Reserve
Ba&e
I""•
~~
<!c o-
re .,,
~
PE
5 M iles
Perris
LEY
Project Site
•
Sacr.:im ento
0 Sa n
r.:t n c1sco 0
C.A LIF OR 111 'I,
0 Fr es no
I
G R E A T
B A S I N
NEVADA
Los Vegas
0 N
A
Bradshaw Collection Project Page 9 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 10 City of Moreno Valley
Local Vicinity
Project Site
Bradshaw Collection Project (TTM 37858) Figure 2
~
C
.c
()
., ..
a:,
0 C ..
~
0 ::
~
0 .c .,
'I .,
a:,
0 C
~
0 :E
C]
;;; ,, ..
:::,
:E
Brodiaea Ave
0 Bradshaw Ci r
Cactus Av e
Arborg l enn Dr
Belleterre "'""
Brodi a ea
Cactu s A ve
l,1~re110 V~li"Y
Rane h Co Ir Club
Grandvie"' I;
City of Moreno Valley, City of Riverside, County of Riverside, San Bernard ino County, Bureau o f Land M anageme nt, Esti, HERE, Garmi n, INCREM ENT P, NGA.
USGS
N
A
Bradshaw Collection Project Page 11 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 12 City of Moreno Valley
Aerial View
Project Site
Bradshaw Collection Project (TTM 37858) Figure 3
D N
A
Bradshaw Collection Project Page 13 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 14 City of Moreno Valley
Existing General Plan Designation
Bradshaw Collection Project (TTM 37858) Figure 4a
RS
p
R3
R/0
R/0
R/0
RS
c::::J Residential : M ax. I du/ac
Mixed Use
c::::J Residential : Max. 2 du/ac
R3 I
R3 □□□ □□
R3
RS OS RlO RS
- Residential: Max . 5 or 15 du/ac - Planned Residential - Residential: Max. 10 du/ac Residenti al/Office
- Resid ential: Max . 15 du/ac - Office
c::::J Rural Residential: M ax 2.5 du/ac - Residential: Max. 20 du/ac - Co1nm erc ial - Business Park/Li ght Indu str ial
iiiiii Residential: Max . 3 du/ac
- Residential: Max. 5 du/ac
- Re sident ia l: Max . 30 du/ac
- Hillside Residenti a l
- Ope n Space
- Public Faci lities
Bradshaw Collection Project Page 15 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 16 City of Moreno Valley
Proposed General Plan Designation
Bradshaw Collection Project (TTM 37858) Figure 4b
R3
R2
R3
R3
-----=--R
3 ______J DB B
RS
D Rcsidcntia.1: Max. 1 du/ac
□ M i xed Use
D Residential: Max. 2 du/ac
R3 R3
R/O
R/O
RS
OS
D Residential: Max. 5 or 15 du/ac D Planned Residential D Residential: Max. IO du/ac D Residential/Office
• Residential: Max. I 5 du/ac D Office
D Rural Residential: Max 2.5 du/ac • Residential: Max. 20 du/ac • Commercial c=
D Residential: Max. 3 du/ac • Residential: Max. 30 du/ac D Residential: Max. 5 du/ac D Hillside Residential
D Business Park/Light Industrial
□ Open Space
RlO
D Public Facilities
D Floodplain
Bradshaw Collection Project Page 17 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 18 City of Moreno Valley
Existing Zoning
Bradshaw Collection Project (TTM 37858) Figure 5a
Residential S Distriet
Residential Single Family IO District
D
Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community
Residential 3 District
Open Space
Bradshaw Collection Project Page 19 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 20 City of Moreno Valley
Proposed Zoning
Bradshaw Collection Project (TTM 37858) Figure 5b
HR
R5
R5
f-
Cl)
a:: RA2 w > I
:J
R3
BAY AVE
R3
R5
RS
SP 207
Rl-7200
Zoning - Large Lot Residential
R3
RA2
R3
R3
RS IO
R5 RSIO
~o
SP 193 GC
491) Commercial Residential Agriculture 2 DU/AC
- lndusttial/Bus.incss Park Rcsidcmlal 2 DU/AC
- Public Facilities Suburban Residential
- Offi<e - Multi-l,imily
- Planned Development - Open Space/Park
" "
WL:C
SP-LD
R3
~ RA2 2
R3 R3 R3
R3 R3
0 R3 R3
R3 R3
R3 fR3 J [R3_ ]
R3 It : 2 ] I RAfl
R5 ~~O O~ I R~O J
p
I
SP 193 NO
Bradshaw Collection Project Page 21 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 22 City of Moreno Valley
Conceptual Site Plan
Bradshaw Collection Project (TTM 37858) Figure 6
Ar•o
HAD. W
....
iM>-01V""
.,. 0
C
.A 11822
55/84
:r wide PCC
lnl..-~.J.~8 - ch,
PM 1753'
PMS 96/5
1:566
O°M'LR: ZABI
TSAI, T M..
Lot C l>PN 479-
)'- ------156 E
PARCEL
\ ,J?M 1753E
> PMB,,96,/~7-
J ~
OW'iER: CUZAB
TSAI. CT Ai..
APN 478-090-
Bradshaw Collection Project Page 23 City of Moreno Valley This page intentionally left blank.
Bradshaw Collection Project Page 24 City of Moreno Valley
Wall and Fence Plan
Wall Plan Key
5’ High Tan Vinyl Fence
5’ High Masonry Block Walls
5’ High Tan Vinyl Gate
Powder Coated Wrought Fencing with Iron Gate
Combo Retaining/ block wall
Water Quality (WQMP) Basin Walls
Bradshaw Collection Project (TTM 37858) Figure 7
ir I
I] □ 1:1
I
i
I
Bradshaw Collection Project Page 25 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 26 City of Moreno Valley
Offsite Improvements
Bradshaw Collection Project (TTM 37858) Figure 8
Bradshaw Collection Project Page 27 City of Moreno Valley
This page intentionally left blank.
Bradshaw Collection Project Page 28 City of Moreno Valley
Conceptual Landscape Plan
Cactus & Bradshaw Collection Project (TTM 37858) Figure 9 • Area
~in
RCEL 1
I 11822
55/8
OWNER; EUZ1'8E
TSAI, ET AL
APN 4 78-090--0
Bradshaw Collection Project Page 29 City of Moreno Valley This page intentionally left blank.
Bradshaw Collection Project Page 30 City of Moreno Valley
14. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Note: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See Public Resources Code section 21080.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.
The City of Moreno Valley initiated AB 52 consultation on August 22, 2024 for a 30-day period. It also initiated Tribal Consultation on Oc tober 24, 2024 under SB18 for a period of 90 days. The City sent notices regarding the Project to the following California Native American tribes that may have knowledge regarding tribal cultural resources in the Project vicinity:
• Agua Caliente Band of Cahuilla Indians
• Agustine Band of Cahuilla Indians
• Cabazon Band of Cahuilla Indians
• Cahuilla Band of Indians
• Desert Cahuilla Indians
• Quechan Tribe of Fort Yuma Reservation
• Los Coyotes Band of Cahuilla Indians
• Morongo Band of Mission Indians
• Pala Band of Mission Indians
• Pechanga Band of Luiseño Indians
• Ramona Band of Cahuilla Indians
• Rincon Band of Luiseño Indians
• Yuhaaviatam of San Manuel Nation (formerly the San Manuel Band of Mission Indians) • Santa Rosa Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseño Indians
The Pechanga Band of Luiseño Indians, Agua Caliente Band of Cahuilla Indians, Morongo Band of Cahuilla Indians, Rincon Band of Cahuilla Indians, Yuhaaviatam of San Manuel Nation (formerly the San Manuel Band of Mission Indians) and Soboba Band of Luiseño Indians requested consultation regarding the proposed Project, under Assembly Bill (AB52). The City received correspondence from the Pala Band of Mission Indians on behalf of Tribal Chairman, Robert Smith, declining AB52 consultation, stating that it determined that the project as described was not within the boundaries of the Pala Indian Reservation. The Agua Caliente Band of Cahuilla Indians, Morongo Band of Cahuilla Indians, Pechanga Band of Luiseño Indians and Yuhaaviatam of San Manuel Nation, also consulted under Senate Bill 18 (SB18).
The consulting tribes consider the area sensitive for archaeological and cultural resources as several sites are located nearby. Although no information for site-specific tribal cultural resources was provided (and there are no known tribal cultural resources on or adjacent to the Project site), the consulting tribes requested inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal archaeological and cultural resources during construction. These mitigation measures are incorporated in this Initial Study.
City staff completed formal tribal consultation under AB52 and SB18 on September 10, 2025. Any further input from the tribes will be through the 30-day public review period for CEQA.
Bradshaw Collection Project Page 31 City of Moreno Valley
15. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):
None applicable.
16. Other Technical Studies Referenced in this Initial Study (Provided as Appendices):
A. Air Quality, Greenhouse Gas, and Energy Impact Study B. Biological Technical Report
C. Focused Burrowing Owl Surveys and MSHCP Consistency
D. Phase I Cultural Resources Investigation and Paleontological Overview E. Preliminary Soil Investigation
F. Phase I Environmental Site Assessment
G. Preliminary Hydrology Report
H. Preliminary Project Specific Water Quality Management Plan I. Noise Impact Analysis
J. Trip Generation and VMT Screening Analysis
17. Acronyms:
ADA Americans with Disabilities Act
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
AQMP Air Quality Management Plan
CEQA California Environmental Quality Act
CIWMD California Integrated Waste Management District
CMP Congestion Management Plan
DTSC Department of Toxic Substance Control
DWR Department of Water Resources
EIR Environmental Impact Report
EMWD Eastern Municipal Water District
EOP Emergency Operations Plan
FEMA Federal Emergency Management Agency
FMMP Farmland Mapping and Monitoring Program
GIS Geographic Information System
GHG Greenhouse Gas
GP General Plan
HCM Highway Capacity Manual
HOA Homeowners Association
IS Initial Study
LHMP Local Hazard Mitigation Plan
LOS Level of Service
LST Localized Significance Threshold
MARB March Air Reserve Base
MARB/IPA March Air Reserve Base/Inland Port Airport
MSHCP Multiple Species Habitat Conservation Plan
MVFP Moreno Valley Fire Department
MVPD Moreno Valley Police Department
MVUSD Moreno Valley Unified School District
MWD Metropolitan Water District
NCCP Natural Communities Conservation Plan
NPDES National Pollutant Discharge Elimination System
Bradshaw Collection Project Page 32 City of Moreno Valley OEM Office of Emergency Services
OPR Office of Planning & Research, State
PEIR Program Environmental Impact Report
PPP Plans, Programs, or Policies
PW Public Works
QSD Qualified SWPPP Developer
QSP Qualified SWPPP Practitioner
RCEH Riverside County Environmental Health
RCFCWCD Riverside County Flood Control & Water Conservation District RCP Regional Comprehensive Plan
RCTC Riverside County Transportation Commission
RCWMD Riverside County Waste Management District
RTA Riverside Transit Agency
RTIP Regional Transportation Improvement Plan
RTP Regional Transportation Plan
SAWPA Santa Ana Watershed Project Authority
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCH State Clearinghouse
SKRHCP Stephen’s Kangaroo Rat Habitat Conservation Plan SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
USFWS United States Fish and Wildlife
USGS United States Geologic Survey
VMT Vehicle Miles Traveled
VVUSD Valley Verde Unified School District
WQMP Water Quality Management Plan
WRCOG Western Riverside Council of Governments
Bradshaw Collection Project Page 33 City of Moreno Valley ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:
The environmental factors checked below would be potentially affected by this Project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Agriculture & Forestry
Resources ☐ Air Quality
☒ Biological Resources ☒ Cultural Resources ☐ Energy
☒ Geology and Soils ☐ Greenhouse Gas
Emissions ☐ Hazards & Hazardous
Materials
☐ Hydrology & Water
Quality ☐ Land Use & Planning ☐ Mineral Resources
☐ Noise ☐ Population & Housing ☐ Public Services
☐ Recreation ☐ Transportation ☒ Tribal Cultural
Resources
☐ Utilities & Service
Systems ☐ Wildfire ☒ Mandatory Findings of
Significance
DETERMINATION (To be completed by the Lead Agency):
On the basis of this initial evaluation:
☐ I find that the proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
☒
I find that although the proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the Project have been made by or agreed to by the Project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
☐ I find that the proposed Project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
☐
I find that the proposed Project MAY have a "potentially significant" or "potentially significant unless mitigated" impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
☐
I find that although the proposed Project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed Project, nothing further is required.
Signature Date
City of Moreno Valley
Printed Name For
Bradshaw Collection Project Page 34 City of Moreno Valley EVALUATION OF ENVIRONMENTAL IMPACTS:
1) A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a Lead Agency cites in the parentheses following each question. A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g. the project falls outside a fault rupture zone).
A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g. the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
2) All answers must take account of the whole action involved, including offsite as well as onsite, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3) Once the Lead Agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect is significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required.
4) Less Than Significant with Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less than Significant Impact." The Lead Agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Section XVII, "Earlier Analyses," may be cross- referenced).
5) Earlier analyses may be used where, pursuant to the tiering, program EIR, or another CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a) Earlier Analyses Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis.
c) Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. 6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7) Supporting Information Sources. A source list should be attached, and other sources used, or individuals contacted should be cited in the discussion. 8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project's environmental effects in whatever format is selected.
9) The explanation of each issue should identify:
a) the significance criteria or threshold, if any, used to evaluate each question; and b) the mitigation measure identified, if any, to reduce the impact to less than significance.
Bradshaw Collection Project Page 35 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
I. AESTHETICS – Except as provided in Public Resources Code §21099 – Modernization of Transportation Analysis for Transit-Oriented Infill Projects – Would the project:
a) Have a substantial adverse effect on a scenic vista?
Response:
Less than Significant Impact. Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual features that are seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting. A scenic vista can be impacted in 2 ways: a development Project can have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view corridors or “vista” of the scenic resource. Important factors in determining whether the proposed Project would block scenic vistas include the Project’s proposed height, mass, and location relative to surrounding land uses and travel corridors.
The Project site is located within a partially developed area of the City and is not within or adjacent to a scenic vista. The site is adjacent to roadways and existing residential land uses. The Moreno Valley General Plan Figure 7-2, Major Scenic Resources identifies the scenic resources within the City that include: Box Springs Mountains, Moreno Peak, Russell Mountains, Reche Mountains, and the Badlands.
The site is located approximately one mile south of the Moreno Peak. However, only partial views of the Moreno Peak are present on the Project site between the existing single-family residences to the north and there is no view protection ordinance within the City. The proposed single-family residences would be 30 feet in height, which is in compliance with City of Moreno Valley of a 35-foot maximum, Additionally, the proposed Project would be the same height or similar to existing single-family residences to the north and south.
Figure 7-2, Major Scenic Resources of the General Plan designates various view corridors throughout the City. The proposed Project is not within or adjacent to a designated view corridor. Thus, redevelopment of the Project site with single-family residence s would not obstruct, interrupt, or diminish a scenic vista; and impacts would be less than significant.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
Response:
No Impact. There are no designated State scenic highways in the City. The closest eligible State scenic highway is State Route (SR) 74, which travels east/west and is approximately 11.5 miles to the south of the Project site. The closest officially designated State scenic highway is SR 243 from Interstate 10 (I-10) south of the city of Banning limits (Caltrans 2021), which is located approximately 17 miles east of the Project site. Neither of the scenic highways discussed above are visible from the Project site, therefore, no impacts to State scenic highways would occur from implementation of the proposed Project.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Response:
Less than Significant Impact. As described previously, the Project site is located in a developing portion of Moreno Valley and is adjacent to roadways to the south and west, vacant land to the east, and single- family residences to the north. Nearby parcels are developed with single-family residential uses. The Project site is vacant. The existing character of the site and surrounding area is neither unique nor of special aesthetic value or quality. Thus, for the purposes of this threshold, the analysis considers whether the Project would conflict with applicable zoning or other regulations governing scenic quality.
The Project would develop the Project site to provide 37 new single-family residences, which would be similar to the single- family residential uses that are adjacent to the west, north, and south of the Project site. □ □ C><l LJ
□ □ □ ~
□ □ ~ □
Bradshaw Collection Project Page 36 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Zoning. The Project site is currently zoned as Residential 5 District (R5). The Project includes a zone change to Residential Single-Family 10 (RS10) District to implement the proposed single-family residential uses. MVMC Section
9.03.020 states that the primary purpose of the Residential Single -Family 10 (RS10) District is to provide for residential development on small single- family lots with amenities not generally found in suburban subdivisions. The district is intended for subdivisions at a maximum allowable density of ten (10) dwelling units per net acre.
The proposed development would also require approval of a Conditional Use Permit (CUP) for a Planned Unit Development (PUD), which allows for a development to establish unique criteria for such things as setbacks, lot width and depth, building separation, and lot size. This is allowed in exchange for a higher level of detail and amenities within the Project than typically required for standard residential development. The Project would be consistent with the standards for approval of a PUD listed in MVMC Section 9.03.060.
The proposed Project would be consistent with the development standards for the Residential Single-Family 10 (RS10) District listed in Municipal Code Section 9.03.040 with approval of a PUD. Thus, the proposed Project would not conflict with applicable zoning regulations governing scenic quality.
Table AES-1: Project Development Standard Consistency
Standard Municipal Code Requirement Proposed Project
Minimum lot size 4,500 Square Feet (SF) 3,095 SF*
Lot width 45 ft. 43 ft.*
Lot depth 85 ft. 72 ft.*
Maximum density 10 du/acre 7.9 du/acre
Height limit 35 feet 30 feet/2 stories
General Plan. The Project site currently has a General Plan land use designation of Residential: Max. 5 du/ac (R5). The proposed Project includes a General Plan Amendment to change the designation of the site to Residential: Max. 10 du/ac (R10). According to the General Plan Land Use Element, the Residential: Max. 10 du/ac (R10) General Plan land use designation allows for development of residential uses to a maximum density of 10 dwelling units per acre. The Project’s proposed density of approximately 7.9 du/ac would be consistent with the maximum allowable density of 10 du/ac with the approval of a PUD. In addition, the Project would be consistent with the General Plan Land Use Element goals and policies related to scenic quality, as shown in Table LU-1 in the Land Use section.
Overall, the proposed Project would be consistent with development standards required by the RS10 zoning district with the approval of a CUP for a PUD, the Residential: Max. 10 du/ac (R10) General Plan land use designation, as well as the Land Use Element goals and policies related to scenic quality. Thus, the Project would not conflict with applicable zoning and other regulations governing scenic quality. Furthermore, the Project would increase the visual cohesion between the Project site and the surrounding single-family residential area. The proposed Project would develop a vacant site with single- family residences which would be consistent with the existing zoning and surrounding land uses. The single-family residences would include a traditional two- story home design with either Spanish, French, or Traditional architectural elements. Hence, the proposed Project would not degrade the visual character of the Project site and surrounding area; and impacts would be less than significant.
Bradshaw Collection Project Page 37 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Response:
Less Than Significant Impact.
Construction Impacts
Project construction could result in temporary glare impacts as a result of construction equipment and materials present at the site. However, construction lighting would be shielded downward to limit the spill of light onto adjacent properties.
Additionally, the construction of the proposed Project would be restricted to the City’s permitted construction hours set forth in the Moreno Valley Municipal Code Chapter 8.14.040. Construction in Moreno Valley is permitted from 7 AM to 7 PM Monday through Friday, excluding holidays and from 8 AM to 4PM on Saturday, unless written approval is obtained from the City Building Official or City Engineer . As a result, the construction of the proposed Project would have a less - than-significant impact on light and glare.
Operational Impacts
The Project site is undeveloped and has no existing source of nighttime lighting. However, the Project site is surrounded by sources of nighttime lighting including streetlights along Cactus Avenue, illumination from vehicle headlights, offsite exterior re
sidential related lighting, and interior illumination passing through windows. Sensitive receptors relative to lighting and glare include residents, motorists, and pedestrians.
The proposed Project would include the provision of street lighting and nighttime lighting for security purposes around all of the residences. Implementation of the proposed Project would result in a higher intensity development on the Project Site than currently exists, which would contribute additional sources to the overall ambient nighttime lighting conditions.
However, all outdoor lighting would be hooded, appropriately angled away from adjacent land uses, and would comply with the MVMC Section 9.16.28
0 that will highlight building features and add emphasis to important spaces and entryways, while limiting glare and light trespass onto adjacent properties. Furthermore, the proposed project would adhere to the California Green Building Standards Code (CAL Green), as outlined in Article IV of the Moreno Valley Municipal Code, including the provisions for lighting in Chapter 9.16.280, General Requirements. Because the Project site is within an urban area with various sources of existing nighttime lighting, and the Project would be required to comply with the City’s lighting regulations that would be verified by the City’s Building and Safety Division during the permitting process, the lighting increase in light that would be generated by the Project would not adversely affect day or nighttime views in the area. Overall, lighting impacts would be less than significant.
Reflective light (glare) can be caused by sunlight or artificial light reflecting from finished surfaces such as window glass or other reflective materials. Generally, darker or mirrored glass would have a higher visible light reflectance than clear glass. Buildings constructed of highly reflective materials from which the sun reflects at a low angle can cause advers e glare. The proposed Project would not use highly reflective surfaces, or glass sided buildings. Although the residences would contain windows, the windows would be separated by stucco and architectural elements, which would limit the potential of glare. In addition, as described previously, onsite lighting would be angled down and shielded, which would avoid the potential on onsite lighting to generate glare. Therefore, the Project would not generate substantial sources of glare, and impacts would be less than significant.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.3 – Community Design • Chapter 7 – Conservation Element – Section 7.8 – Scenic Resources - Figure 6-2 – Major Scenic Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.11 – Aesthetics
- Figure 4.11-1 – Major Scenic Resources
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.10.110 – Light and Glare of the Moreno Valley Municipal Code. • Chapter 9.16 – Design Guidelines
• Section 9.17.030 G – Heritage Trees
4. California Department of Transportation, California Scenic Highway Mapping System. 2021. Accessed: at https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic- highways □ □ [X] □
Bradshaw Collection Project Page 38 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. AGRICULTURE AND FOREST RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps
prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-
agricultural use?
Response:
Less than Significant Impact. The State of California Department of Conservation’s Farmland Mapping and Monitoring Program is responsible for producing maps for analyzing impacts on the state’s agricultural resources. California’s agricultural lands are rated based on soil quality and irrigation status. The Project S ite is identified by the California Department of Conservation Important Farmland Finder as “Farmland of Local Importance” (CDC, 2020). Farmland of Local Importance is farmland important to the local agricultural economy as determined by the County Board of Supervisors and a local advisory committee. The Project Site is vacant and does not contain any existing farmland. Per Section 21060.1 of the CEQA Guidelines, Farmland of Local Importance is not considered Farmland. No surrounding areas are designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) by the Farmland Mapping and Monitoring Program. Per Section 21060.1 of the State CEQA Guidelines, Farmland of Loc al Importance is not considered Prime, Unique, or of Statewide Importance. Because there is no Prime Farmland, Unique Farmland, or Farmland of Statewide Importance at the Project site, impacts would be less than significant. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
Response:
No Impact. The Project Site has an existing zoning designation of Residential 5 District (R5). The Project site is not zoned for agricultural use and is not subject to a Williamson Act contract, based on the California Department of Conservation Williamson Act Enrollment Finder (DOC, 2022). Thus, the proposed Project would not result in impacts related to conflict with an existing agricultural zoning or Williamson Act contract. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as
defined by Government Code section 51104(g))?
Response:
No Impact. No forest land exists on or adjacent to the Project Ste. The Project Site has a zoning designation for residential and is not zoned for forest land or timberland uses. Thus, the proposed Project would not result in impacts related to conflict with an existing forest land or timberland zoning. d) Result in the loss of forest land or conversion of forest land to non-forest use?
Response:
No Impact. No forest land exists on the Project site. Thus, the proposed Project would not result in the loss of forest land or conversion of forest land to non-forest use, and impacts would not occur. e) Involve other changes in the existing environment which, due to their location or nature, could result in the conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
Response:
No Impact. As described in the responses above, the Project area does not include farmland or forest land; thus, implementation of the proposed Project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland, to non-agricultural use or conversion of forest land to non-forest use. Impacts would not occur.
Existing Plans, Programs, or Policies
None.
□ □ ~ □
□ □ □ ~
□ □ □ ~
-
□ □ □ ~
□ □ □ ~
Bradshaw Collection Project Page 39 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Mitigation Measure
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.7 – Agricultural Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.8 – Agricultural Resources
- Figure 4.8-1 – Important Farmlands
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. California Department of Conservation, Important Farmland Finder. 2022. Available:
https://maps.conservation.ca.gov/dlrp/WilliamsonAct/ (Accessed February 19, 2024).
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan?
Response:
Less Than Significant Impact. The Project site is located in the South Coast Air Basin (SCAB), which is under the jurisdictional boundaries of the South Coast Air Quality Management District (SCAQMD). The SCAQMD and Southern California Association of Governments (SCAG) are responsible for preparing the Air Quality Management Plan (AQMP), which addresses federal and State Clean Air Act (CAA) requirements. The AQMP details goals, policies, and programs for improving air quality in the Basin. In preparation of the AQMP, SCAQMD and SCAG uses regional growth projections to forecast, inventory, and allocate regional emissions from land use and development-related sources.
As described in Chapter 12, Section 12.2 and Section 12.3 of the SCAQMD’s CEQA Air Quality Handbook (1993), for purposes of analyzing consistency with the AQMP, if a proposed Project would result in growth that is substantially greater than what was anticipated, then the proposed Project would conflict with the AQMP. On the other hand, if a Project’s density is within the anticipated growth of a jurisdiction, its emissions would be consistent with the assumptions in the AQMP, and the Project would not conflict with SCAQMD’s attainment plans. In addition, the SCAQMD considers projects consistent with the AQMP if the project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation.
The proposed Project is a residential development project on a currently vacant site. The site is located within a residential area of Moreno Valley. The proposed Project would develop 37 single-family residences on the site. As further described in Section 14, Population and Housing, would result in the addition of approximately 143 new residents, which would represent a population increase of approximately 0.07 percent and a 0.06 percent increase in residential units within the City. This limited level of growth on a site that has been previously developed would not exceed growth projections and would be consistent with the assumptions in the AQMP.
In addition, emissions generated by construction and operation of the proposed Project would not exceed thresholds. As described in the analysis below, the Project would not result in an increase in the frequency or severity of existing air quality violations or cause a new violation. Therefore, impacts related to conflict with the AQMP from the proposed Project would be less than significant.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Response:
Less Than Significant Impact. The SCAB is in a non- attainment status for federal ozone standards, federal carbon monoxide standards, and State and federal particulate matter standards. Any development in the SCAB, including the proposed Project, could cumulatively contribute to these pollutant violations. The methodologies from the SCAQMD CEQA Air Quality Handbook are used in evaluating Project impacts. SCAQMD has established daily mass thresholds for regional pollutant emissions, which are shown in Table AQ -1. Should construction or operation of the proposed Project exceed these thresholds a significant impact could occur; however, if estimated emissions are less than the thresholds, impacts would be considered less than significant.
□ □ [g] □
□ □ [g] □
Bradshaw Collection Project Page 40 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table AQ-1: SCAQMD Regional Daily Emissions Thresholds
Pollutant Construction Operations
(lbs/day) (lbs/day)
NOx 100 55
VOC 75 55
PM-10 150 150
PM-2.5 55 55
SOx 150 150
CO 550 550
Source: RK Engineering, 2025 (Appendix A)
Construction
Construction activities associated with the proposed Project would generate pollutant emissions from the following: (1) demolition and removal of the existing onsite improvements and recycling debris; (2) grading and excavation; (3) construction workers traveling to and from Project site; (4) delivery and hauling of construction supplies to, and debris from, the Project site; (5) fuel combustion by onsite construction equipment; (6) building construction; application of architectural coatings; and paving. The amount of emissions generated on a daily basis would vary, depending on the intensity and types of construction activities occurring.
It is mandatory for all construction projects to comply with several SCAQMD Rules, including Rule 403 for controlling fugitive dust, PM-10, and PM-2.5 emissions from construction activities. Rule 403 requirements include, but are not limited to: applying water in sufficient quantities to prevent the generation of visible dust plumes, applying soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the site, covering all trucks hauling soil with a fabric cover and maintaining a freeboard height of 12-inches, and maintaining effective cover over exposed areas. Compliance with Rule 403 was accounted for in the construction emissions modeling for the Project. In addition, implementation of SCAQMD Rule 1113 that governs the VOC content in architectural coating, paint, thinners, and solvents, was accounted for in the construction emissions modeling for the Project. As shown in Table AQ -2, CalEEMod results indicate that construction emissions generated by the proposed Project would not exceed SCAQMD regional thresholds.
Therefore,
emissions from construction activities would be less than significant.
Table AQ-2: Construction Emissions Summary
Construction Activity
Maximum Daily Regional Emissions1
(pounds/day)
VOC NOX CO SOX 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
Maximum Daily
Emissions
26.14 36.05 34.03 0.09 9.49 5.47
SCAQMD Significance
Thresholds
75 100 550 150 150 55
Emissions Exceed
Thresholds?
No No No No No No
1 Maximum daily emission during summer or winter; includes both onsite and offsite Project emissions Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A) Bradshaw Collection Project Page 41 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Operation
Operation of the 37 single -family residences would result in long- term regional emissions of criteria air pollutants and ozone precursors associated with area sources, such as natural gas consumption, landscaping, applications of architectural coatings, an d consumer products. However, vehicular emissions would generate a majority of the operational emissions from the Project.
Operational emissions associated with the proposed Project were modeled using CalEEMod and are presented in Table AQ-3. As shown, the proposed Project would result in long -term regional emissions of the criteria pollutants that would be below the SCAQMD’s applicable thresholds. Therefore, operation of the Project would not result in a cumulatively considerable net increase of any criteria pollutant impacts, and operational impacts would be less than significant.
Table AQ-3: Summary of Peak Operational Emissions
Construction Activity
Maximum Daily Regional Emissions1
(pounds/day)
VOC NOX CO SOX PM10 PM2.5
Mobile Sources 1.24 1.90 10.15 0.02 2.21 0.57
Area Sources 1.89 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 Significance
Thresholds
55 55 550 150 150 55
Emissions Exceed
Thresholds?
No No No No No No
1 Maximum daily emission during summer or winter; includes both onsite and offsite Project emissions Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
c) Expose sensitive receptors to substantial pollutant
concentrations?
Response:
Less Than Significant Impact. The SCAQMD’s Final Localized Significance Threshold Methodology (SCAQMD, 2008) recommends the evaluation of localized NO2, CO, PM-10, and PM-2.5 construction-related impacts to sensitive receptors in the immediate vicinity of the Project site. Such an evaluation is referred to as a localized significance threshold (LST) analysis. According to the SCAQMD’s Final Localized Significance Threshold Methodology, “off -site mobile emissions from the Project should not be included in the emissions compared to the LSTs” (SCAQMD, 2008). SCAQMD has developed LSTs that 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 standards, and thus would not cause or contribute to localized air quality impacts. LSTs are developed based on the ambient concentrations of NOx, CO, PM - 10, and PM-2.5 pollutants for each of the 38 source receptor areas (SRAs) in the SCAB. The Project site is located within SRA 24, Perris Valley. The LSTs for this SRA were applied to the Project.
Sensitive receptors can include residences, schools, playgrounds, childcare centers, athletic facilities. The nearest sensitive receptors are existing residences located adjacent to the Project site. The distance between the Project site boundary and the closest existing residential structure is located north of the Project site boundary approximately 10-feet from the property line. Therefore, the distance for sensitive receptors in the LST assessment was set at 25 meters, the shortest distance contained in the SCAQMD LST emission look-up tables (RK Engineering, 2025).
Constaruction
The localized thresholds from the mass rate look- up tables in SCAQMD’s Final Localized Significance Threshold Methodology document, were developed for use on projects that are less than or equal to 5 acres in size or have a disturbance of less than or equal to 5 acres daily. Project construction would disturb a maximum area of 3.5 acres during the site preparation phase. Therefore, the localized significance thresholds for 3.5 acres were used (RK Engineering, 2025).
Table AQ-4 identifies the localized impacts at the nearest receptor location in the vicinity of the Project. As shown, Project construction-source emissions would not exceed the applicable SCAQMD LSTs for emissions of any criteria pollutant.
Thus, implementation of the Project would not result in a localized air quality impact.
□ □ [g] □
Bradshaw Collection Project Page 42 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table AQ-4: Localized Significance Summary of Construction Construction Activity Maximum Daily Localized Emissions (pounds/day)1 NOX CO PM10 PM2.5
Onsite Emissions 35.95 32.93 9.27 5.41
SCAQMD Significance
Thresholds2
216.8 1,221.4 9.8 6.1
Emissions Exceed Thresholds? No No No No
1 Maximum daily emission during winter or summer; includes onsite Project emissions only Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
As described in Response 4.3(b), the proposed Project would not significantly increase long -term emissions within the Project area. Construction of the proposed Project may expose nearby residential sensitive receptors to airborne particulates as well as a small quantity of construction equipment pollutants (i.e., usually diesel -fueled vehicles and equipment). However, construction contractors would be required to implement measures to reduce or eliminate emissions by following SCAQMD’s standard construction practices (Rules 402 and 403, as included as PPP AQ -1 and PPP AQ-2). Rule 402 requires implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off site. Rule 403 requires that fugitive dust be 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.
Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations during const ruction, and impacts would be less than significant.
Operation
For operational LSTs, onsite passenger car and truck travel emissions were modeled. The SCAQMD has established that impacts to air quality are significant if there is a potential to contribute or cause localized exceedances of the federal and/or State Ambient Air Quality Standards. As shown on Table AQ -5, operational emissions would not exceed the SCAQMD’s localized significance thresholds for any criteria pollutant at the nearest sensitive receptor. Therefore, localized air quality impacts from operational activities would be less than significant.
Table AQ-5: Localized Significance Summary of Operations Operational Activity Maximum Daily Localized Emissions (pounds/day) NOX CO PM10 PM2.5
Onsite Emissions 0.40 2.75 0.14 0.06
SCAQMD Significance
Threshold
216.8 1,221.4 2.9 1.6
Exceed Threshold? No No No No
Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
Response:
No Impact. The proposed Project would not emit other emissions, such as those generating objectionable odors, that would affect a substantial number of people. The threshold for odor is identified by SCAQMD Rule 402, Nuisance, which states:
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.
The provisions of this rule shall not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals.
The type of facilities that are considered to result in other emissions, such as objectionable odors, include wastewater treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass manufacturing facilities, paint/coating ope rations (e.g., auto body shops), dairy farms, petroleum refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities.
The proposed Project would implement residential development within the Project area that does not involve the types of uses that would emit objectionable odors affecting a substantial number of people. In addition, odors generated by non- □ □ □ ~
Bradshaw Collection Project Page 43 City of Moreno Valley residential land uses are required to be in compliance with SCAQMD Rule 402, which would prevent nuisance odors.
During construction, emissions from construction equipment, architectural coatings, and paving activities may generate odors. However, these odors would be temporary, intermittent in nature, and would not affect a substantial number of people. The noxious odors would be confined to the immediate vicinity of the construction equipment. Also, the short - term construction-related odors would cease upon the drying or hardening of the odor -producing materials. Thus, the proposed Project would not result in impacts associated with other emissions, such as odors, would not adversely affect a substantial number of people and there would be no impact.
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Existing Plans, Programs, or Policies (PPP)
PPP AQ-1: Rule 402. The Project is required to comply with the provisions of South Coast Air Quality Management District (SCAQMD) Rule 402. The Project 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.
PPP AQ-2: Rule 403. The Project is required to comply with the provisions of South Coast Air Quality Management District (SCAQMD) Rule 403, which includes the following:
• All clearing, grading, earth-moving, or excavation activities shall cease when winds exceed 25 mph per SCAQMD guidelines in order to limit fugitive dust emissions.
• The contractor shall ensure that all disturbed unpaved roads and disturbed areas within the Project are watered, with complete coverage of disturbed areas, at least 3 times daily during dry weather; preferably in the mid- morning, afternoon, and after work is done for the day. • The contractor shall ensure that traffic speeds on unpaved roads and Project site areas are reduced to 15 miles per hour or less.
PPP AQ-3: Rule 1113. The Project is required to comply with the provisions of South Coast Air Quality Management District Rule (SCAQMD) Rule 1113. Only “Low-Volatile Organic Compounds” paints (no more than 50 gram/liter of VOC) and/or High Pressure Low Volume (HPLV) applications shall be used.
Mitigation Measure
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 5 – Circulation Element
• Chapter 6 – Safety Element – Section 6.6 – Air Quality
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.3 – Air Quality
- Figure 4.3-1 – South Coast Air Basin
• Appendix C – Air Quality Analysis, P&D Consultants, July 2003
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.10.050 – Air Quality of the Moreno Valley Municipal Code • Section 9.10.150 – Odors of the Moreno Valley Municipal Code • Section 9.10.170 – Vibration of the Moreno Valley Municipal Code
4. Moreno Valley Municipal Code Section 12.50.040 – Limitations on Engine Idling
5. TTM 37858 Single Family Residential Project Air Quality, Greenhouse Gas, and Energy Impact Study. RK Engineering. April 22, 2025 (Appendix A).
6. South Coast Air Quality Management District Final Localized Significance Threshold Methodology (SCAQMD 2008). Accessed: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance- thresholds/final-lst-methodology-document.pdf (Accessed May 26, 2021).
Bradshaw Collection Project Page 44 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a
candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife
Service?
Response:
Less Than Significant Impact with Mitigation Incorporated. The Project Site is vacant and undeveloped and has been previously disturbed. The Project’s offsite improvement area contains Bradshaw Circle, a developed roadway. A Biological Habitat Assessment was prepared for the proposed Project, which included a literature search to identify special status plants, wi ldlife, and habitats known to occur in the vicinity of the Project site. General plant and wildlife surveys were also conducted to identify any biological resources on or adjacent to the Project site. The Project site is within the Western Riverside County MSHCP (Multiple Species Habitat Conservation Plan) Reche Canyon/Badlands Area Plan.
The Habitat Assessment identified 12 special -status plant species that have the potential to occur within the Project vicinity; however, all listed plant species were determined to have no potential and be absent from the Project site (CADRE Environmental, 2024).
The Habitat Assessment identified 55 special -status wildlife species that have the potential to occur within the Project vicinity. Five MSHCP species were determined to have moderate to low potential of occurring onsite including the sharp- shinned hawk, grasshopper sparrow, California horned lark, northern harrier, and the white-tailed kite. The MSHCP has determined that these sensitive species with potential to occur onsite have been adequately covered through the payment of the MSHCP Local Development Mitigation Fee, included herein as PPP BIO-1.
It was determined that potentially suitable habitat for burrowing owls (Athene cunicularia) is present onsite. The burrowing owl is a State species of special concern and MSHCP Group 3 species that is commonly found in open, dry grasslands, agricultural and range lands, as well as desert habitats with low-growing vegetation. The burrowing owl resides in burrows primarily created, then abandoned, by species such as California ground squirrels (Spermophilus beecheyi) and coyotes (Canis latrans). Therefore, protocol burrowing owl surveys were conducted to determine the presence and use of the site by burrowing owls.
Burrowing owl habitat assessment surveys and focused surveys were conducted in 2024 according to the Burrowing Owl Survey Instructions for the Western Riverside Multiple Species Habitat Conservation Plan Area. The surveys were completed in three steps; Habitat Assessment (Step 1), Focused Burrow Surveys (Step 2A), and Focused Owl Surveys (Step 2B).
In Step 1, habitat within the Project area was assessed for burrowing owl presence, use, and potential use. Areas with potential burrowing owl habitat, including pasture and debris piles were surveyed by CADRE Environmental for potential burrows. Biologists walked areas of potential habitat while searching for the presence of burrowing owls, potential and active burrows, and owl sign, such as white-wash, feathers, pellets, and prey items. Step 1 of the survey identified suitable burrowing owl habitat onsite due to the presence of low-growing vegetation.
In Step 2A, focused burrow surveys were conducted, which included surveys of natural burrows or suitable debris piles.
Transect surveys for burrows, including owl signs, were conducted by walking or being escorted through suitable habitat over the entire survey area. The locations of all potential owl burrows, observed owl sign, and observed burrowing owls were recorded and mapped.
In Step 2B, focused burrowing owl surveys consisted of four site visits covering all Project areas and adjacent areas.
Surveys were conducted in the morning 1 hour before sunrise to 2 hours after sunrise. Upon arrival at the survey area and prior to initiating the walking surveys, surveyors used binoculars and/or spotting scopes to scan all suitable habitats, as well as the location of mapped burrows, owl sign, and owls, including perch locations to ascertain owl presence. A survey for owls and owl sign was then conducted by walking through suitable habitat over the entire Project site and within the adjacent 150- meter (500- foot) buffer zone. Results of the Step 2A surveys found no owl burrows on the proposed Project Site or in adjacent areas. In addition, Step 2B found no burrowing owls on the proposed Project Site or adjacent to the Project Site (CADRE Environmental, 2024). Although no impacts to this species are anticipated as a result of construction activities, Mitigation Measure BIO-2 has been included to require a preconstruction burrowing owl survey □ ~ □ □
Bradshaw Collection Project Page 45 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
to be conducted at least 30 -days immediately prior to the start of ground disturbance activities. With implementation of Mitigation Measures BIO-2, impacts related to burrowing owls would be less than significant.
The Habitat Assessment performed by CADRE Environmental identified suitable habitat and substrate for raptors that are protected under the MSHCP, as well as migratory birds that are protected under the Migratory Bird Treaty Act and Section 3503.5 of the California Department of Fish and Wildlife (CDFW) code (CADRE Environmental, 2024). Mitigation Measure BIO-2 has been included to require a qualified biologist to survey the project impact area for the presence of any active raptor nests no more than 3 days prior to the onset of construction activities during the raptor nesting season.
Mitigation Measure BIO -2 has been included to require pre -construction nesting bird surveys, as well as recommendations for vegetation removal outside of the nesting bird season. With implementation of Mitigation Measure BIO-1 and Mitigation Measure BIO -2, impacts related to protected bird species would also be reduced to a less than significant level.
The Habitat Assessment further describes that the special-status wildlife and plant species with the potential to occur on the Project site are covered by compliance with the MSHCP, which requires payment of fees, included as PPP BIO-1.
Thus, through adherence to the recommendations provided in the Habitat Assessment, payment of the MSHCP mitigation fees (included as PPP BIO -1), and implementation of pre- construction nesting bird surveys, the Project would be fully consistent with the MSCHP, CDFW, and USFWS, and impacts would be less than significant with implementation of MM BIO-1 and MM BIO-2.
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 Game or U.S. Fish and Wildlife Service?
Response:
No Impact. The Project Site consists of vacant land that has been heavily disturbed by grading. The assessment done by CADRE Environmental identified there are no State or federal streambed resources on the Project Site. In addition, MSHCP Section 6.12 riverine resources are not located on the Project Site, and as such the Project does not require permits from Army Corps of Engineers, California Department of Fish and Wildlife, or the Regional Water Quality Control Board. In addition, the Project does not contain any vernal pools, wetland habitats, creeks, or rivers (CADRE Environmental, 2024). Thus, impacts to riparian habitat or other sensitive natural community would not occur from implementation of the proposed Project.
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Response:
No Impact. As described in the response above, the Project Site does not contain any drainages, creeks, rivers, or other wetland areas (CADRE Environmental, 2024). The Project site does not contain any jurisdictional areas that would be subject to Section 404 of the Clean Water Act, and the proposed Project does not involve any hydrological interruption on any existing water resources. Thus, impacts to federally protected wetlands as defined by Section 404 of the Clean Water Act would not occur from implementation of the proposed Project. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with an established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Response:
Less Than Significant Impact with Mitigation Incorporated. The Project Site is vacant and undeveloped but is adjacent to roadways, disturbed, and developed land uses. Due to the existing conditions of the Project site and the surrounding land uses, the Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors (CADRE Environmental, 2024). There are no native wildlife nursery sites. However, as described previously, the site includes areas that are suitable for nesting birds that are protected under the Migratory Bird Treaty Act and Section 3503.5 of the CDFW code. Therefore, Mitigation Measure BIO-2 has been included to require pre -construction nesting bird surveys. With implementation of Mitigation Measure BIO-2, impacts to native wildlife nursery sites would not occur and impacts would be less than significant. □ □ □ ~
□ □ □ ~
□ ~ □ □
Bradshaw Collection Project Page 46 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Response:
No Impact. There are no local biological related policies or ordinances, such as a tree preservation policy or ordinance that is applicable to the proposed Project. The Project Site is adjacent to existing non-native ornamental trees that are on the right-of-way on Cactus Avenue, adjacent to the single-family residential areas to the north, and are not subject to any ordinances. The Project Site contains non-protected native shrubs and herbs as well as non-native grasses and shrubs and one nonnative palm tree. Therefore, implementation of the proposed Project would not conflict with local polices or ordinances protecting trees and no impact would occur.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or another
approved local, regional, or state habitat
conservation plan?
Response:
Less than Significant Impact. The Project S ite occurs within the Western Riverside County MSHCP. As described previously, the Project site is located within the Reche Canyon/Badlands Area Plan of the MSHCP, but is not located within a Criteria Area Cell, Core, or Linkage. Furthermore, a habitat survey and surveys for burrowing owl have been conducted as outlined in response 4(a) and further preconstruction surveys and payment of fees would be conducted prior to construction as required by Mitigation Measures BIO-1 through BIO-2. Additionally, the Project is required to pay applicable MSHCP fees prior to grading permit approval as outlined in PPP BIO-1 and PPP BIO-2. With implementation of PPP BIO -1, PPP BIO -2, MM BIO-1, and MM BIO-2, development of the Project site would not conflict with local, regional, or State resource preservation and/or conservation policies. Therefore, with the inclusion of MM BIO-1 and BIO- 2 impacts would be less than significant with mitigation.
Existing Plans, Programs, or Policies
PPP BIO-1: MSHCP Development Impact Fees. Prior to issuance of a grading or building permit, the project applicant will be required to pay relevant City of Moreno Valley mitigation fees to the City.
PPP BIO-2: 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.
Mitigation Measures
Mitigation Measure BIO -1: Preconstruction Burrowing Owl Surveys. Pursuant to the MSHCP Objective 6, for burrowing owl, a preconstruction burrowing owl survey shall be conducted at least 30 days prior to the initiation of construction activity to verify the presence/absence of the owl on the Project site. Within thirty days of the onset of construction activities, a qualified biologist shall survey within 500 feet of the Project site for the presence of any active owl burrows. Any active burrow found during survey efforts shall be mapped on the construction plans. If no active burrows are found, no further mitigation would be required. Results of the surveys shall be provided to the City of Moreno Valley.
If nesting activity is present at an active burrow, the active site shall be protected until nesting activity has ended to ensure compliance with Section 3503.5 of the California Fish and Game Code. Nesting activity for burrowing owl in the region normally occurs between March and August. To protect the active burrow, the following restrictions to construction activities shall be required until the burrow is no longer active as determined by a qualified biologist: (1) clearing limits shall be established within a 500- foot buffer around any active burrow, unless otherwise determined by a qualified biologist, and (2) access and surveying shall be restricted within 300 feet of any active burrow, unless otherwise determined by a qualified biologist. Any encroachment into the buffer area around the active burrow shall only be allowed if the biologist determines that the proposed activity will not disturb the nest occupants. Construction can proceed when the qualified biologist has determined that fledglings have left the nest. If an active burrow is observed during the non - nesting season, the nest site shall be monitored by a qualified biologist, and when the raptor is away from the nest, the biologist will either actively or passively relocate the burrowing owl based on direction from the WRC RCA. The biologist shall then remove the burrow so the burrowing owl cannot return to the burrow. Therefore, based on the described construction activities and implementation of mitigation measures as identified, impacts to BUOW would not be significant.
Mitigation Measure BIO-2: Preconstruction Raptor and Bird Surveys. Three days prior to the onset of construction activities during the raptor nesting season (February 1 to June 30) and MBTA nesting cycle (February 1 to September 15), a qualified biologist shall survey all areas within 500 feet of the Project impact area for the presence of any active raptor or bird nests (common or special status). Any nest found during survey efforts shall be mapped on the construction plans. If no active nests are found, no further mitigation would be required. Results of the surveys shall be provided to □ □ □ ~
□ ~ □ □
Bradshaw Collection Project Page 47 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
the CDFW. If nesting activity is present at any raptor or bird nest site, the active site shall be protected until nesting activity has ended to ensure compliance with Section 3503.5 of the California Fish and Game Code. To protect any nest site, the following restrictions to construction activities are required until nests are no longer active as determined by a qualified biologist: (1) clearing limits shall be established within a 500- foot buffer around any occupied nest, unless otherwise determined by a qualified biologist, and (2) access and surveying shall be restricted within 300 feet of any occupied nest, unless otherwise determined by a qualified biologist. Any encroachment into the buffer area around the known nest shall only be allowed if the biologist determines that the proposed activity will not disturb the nest occupants. Construction can proceed when the qualified biologist has determined that fledglings have left the nest. If an active nest is observed during the non-nesting season, the nest site shall be monitored by a qualified biologist, and when the raptor or bird is away from the nest, the biologist will flush any raptor to open space areas. A qualified biologist, or construction personnel under the direction of the qualified biologist, shall then remove the nest site so raptors and birds cannot return to a nest.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.1 – Biological Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.9 – Biological Resources
- Figure 4.9-1 – Planning Area Biological Geographic Sections - Figure 4.9-2 – Planning Area Vegetation Community
- Figure 4.9-3 – Project Site Location within the MSHCP Area - Figure 4.9-4 – Reche Canyon/Badlands Area Plan
• Appendix E – Biological Resources Study, Appendix E
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.17.030 G – Heritage Trees
4. Moreno Valley Municipal Code Chapter 8.60 – Threatened and Endangered Species
5. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), http://www.wrc-rca.org/about- rca/multiple-species-habitat-conservation-plan/
6. Habitat Assessment. March 2024. Prepared by CADRE Environmental (Appendix B).
7. Focused Survey for Burrowing Owl. March 18, 2024. Prepared by CADRE Environmental (Appendix C).
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Response:
Less than Significant Impact. According to the State CEQA Guidelines, a historical resource is defined as something that meets one or more of the following criteria:
1) Listed in, or determined eligible for listing in, the California Register of Historical Resources; 2) Listed in a local register of historical resources as defined in Public Resources Code (PRC) Section 5020.1(k); 3) Identified as significant in a historical resources survey meeting the requirements of PRC Section 5024.1(g); or 4) Determined to be a historical resource by the project’s Lead Agency.
As described previously, the Project site is currently vacant. Historic aerial photographs and maps of the Project site showed no development in the general vicinity of the Project area until after 1976. All improvements, therefore, are less than 45 years of age and considered modern and of no historical consequence (McKenna, 2020). Therefore, the Project would not cause a substantial adverse change in the significance of a historical resource, and impacts would be less than significant.
□ □ ~ □
Bradshaw Collection Project Page 48 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Response:
Less than Significant Impact with Mitigation Incorporated. The Phase I Cultural Resources Investigation and Paleontological Overview prepared for the Project Site included an archaeological records search that was completed at the University of California, Riverside, Eastern Information Center (UCR-EIC). All pertinent data was researched, including previous studies for a one-mile radius surrounding the Project area and the identification of recorded resources within one mile. In addition, the research included review of the current listings (federal, State, and local) for evaluated resources and reviewed historic maps. The records search indicated that the nearest recorded resources are located more than one-half mile from the Project site. There are no known significant cultural resources within the Project area and any future development will not adversely impact any significant resources (McKenna, 2020).
As required for compliance with CEQA guidelines and the data requirements of the Office of Historic Preservation (OHP), an intensive field survey was conducted to adequately identify, describe, report, and, if possible, evaluate any cultural resources identified within the Project area boundaries. This intensive field survey was conducted on March 7, 2020. No evidence of any prehistoric archaeological sites, prehistoric isolates, historic archaeological sites and/or historic isolates was found within the Project area boundaries. In addition, no historic landscape or suggestion of ethic resources or associations were found. Overall, the property was clear of any evidence of surface cultural resources and the potential for buried resources was determined to be extremely low to nonexistent (McKenna, 2020). Furthermore, the offsite improvement area is currently developed with Bradshaw Circle.
Based on the negative findings presented above, there are no known cultural resources, significant or not, within or adjacent to the Project area. In addition, as discussed previously, based on the results of the cultural resources search and survey, evidence of surface cultural resources and the potential for buried resources was determined to be extremely low to nonexistent (McKenna, 2020). Nevertheless, due to archaeological sensitivity in the City and Project vicinity, Mitigation Measures CR-1 through CR-9 would be implemented by the Project and require archaeological monitoring, a Cultural Resource Monitoring Plan (CRMP), measures for inadvertent finds, and Archaeology Reports. With the implementation of Mitigation Measures CR-1 through CR-9, impacts to archaeological and cultural resources would be less than significant.
c) Disturb any human remains, including those interred outside of formally dedicated cemeteries?
Response:
Less than Significant Impact with Mitigation Incorporated. The Project S ite has not been previously used as a cemetery. Thus, human remains are not anticipated to be uncovered during Project construction. In addition, procedures of conduct following the discovery of human remains on non-federal lands have been mandated by California Health and Safety Code Section 7050.5, CEQA Section 15064.5, and Public Resources Code Section 5097.98, which has been included as Mitigation Measure CR -7. Specifically, California Health and Safety Code Section 7050.5 requires that if human remains are discovered, disturbance of the site shall remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death, and made recommendations concerning the treatment and disposition of the human remains to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or her authority and if the coroner has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.
Thus, with compliance with Mitigation Measure CR-7, impacts would be less than significant.
Existing Plans, Programs, or Policies
None.
□ ~ □ □
I □ I ~ I □ I □
Bradshaw Collection Project Page 49 City of Moreno Valley Mitigation Measures:
CR 1 Archaeological Monitoring. Prior to the issuance of a grading permit, the Developer shall retain a professional archaeologist to conduct monitoring of all ground-disturbing activities at Bradshaw Collection (Tentative Tract Map 37858).
The Project Archaeologist shall have the authority to temporarily redirect earthmoving activities in the event that suspected archaeological resources are unearthed during Project construction. The Project Archaeologist, in consultation with the Consulting Tribe(s), Agua Caliente Band of Cahuilla Indi ans, Yuhaaviatam of San Manuel Nation, Pechanga Band of Indians, Morongo Band of Mission Indians, Soboba Band of Luiseño Indians, and Rincon Band of Luiseño Indians, including the contractor, and the City, shall develop a CRMP as defined in CR-3. The Project archeologist shall attend the pre-grading meeting with the City, the construction manager, and any contractors and will conduct a mandatory Cultural Resources Worker Sensitivity Training to those in attendance. The archaeological monitor shall have the authority to temporarily halt and redirect earth-moving activities in the affected area in the event that suspected archaeological resources are unearthed.
CR 2 Native American Monitoring. Prior to the issuance of a grading permit, the Developer shall secure agreements with the Pechanga Band of Indians, Morongo Band of Mission Indians, Soboba Band of Luiseño Indians, and/or Rincon Band
of Luiseño Indians for tribal monitoring. The Developer is also required to provide a minimum of 30 days’ advance notice to the tribes of all ground -disturbing activities. The Native American Tribal Representatives shall have the authority to temporarily halt and redirect earth -moving activities in the affected area in the event that suspected archaeological and cultural resources are unearthed. The Native American Monitor(s) shall attend the pre -grading meeting with the Project Archaeologist, the City, the construction manager, and any contractors and will conduct the Tribal Perspective of the mandatory Cultural Resources Worker Sensitivity Training to those in attendance.
CR 3 Cultural Resource Monitoring Plan (CRMP). The Project Archaeologist, in consultation with the Consulting Tribe(s), the contractor, and the City, shall develop a CRMP in consultation pursuant to the definition in AB52 to address the details, timing, and responsibility of all archaeological and cultural activities that will occur on the project site. A consulting Tribe is defined as a Tribe that initiated the AB52 tribal consultation process for the Project, has not opted out of the AB52 consultation process, and has completed AB52 consultation with the City as provided for in Cal Pub Res Code Section 21080.3.2(b)(1) of AB52. Details in the Plan shall include:
a. Project description and location;
b. Project grading and development scheduling;
c. Roles and responsibilities of individuals on the Project; d. The pre-grading meeting and Cultural Resources Worker Sensitivity Training details; e. The protocols and stipulations that the contractor, City, Consulting Tribe (s), and Project archaeologist will follow in the event of inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits that shall be subject to a cultural resources evaluation; f. The type of recordation needed for inadvertent finds and the stipulations of recordation of sacred items; g. Contact information of relevant individuals for the Project.
CR 4 Cultural Resource Disposition . In the event that Native American cultural resources are discovered during the course of ground disturbing activities (inadvertent discoveries), the following procedures shall be carried out for final disposition of the discoveries:
a. One or more of the following treatments, in order of preference, shall be employed with the tribes.
Evidence of such shall be provided to the City of Moreno Valley Planning Department:
i. Preservation-In-Place of the cultural resources, if feasible. Preservation in place means avoiding the resources, leaving them in the place they were found with no development affecting the integrity of the resources. ii. On-site reburial of the discovered items as detailed in the treatment plan required pursuant to Mitigation Measure CR 1. This shall include measures and provisions to protect the future reburial area from any future impacts in perpetuity. Reburial shall n ot occur until all legally required cataloging and basic recordation have been completed. No recordation of sacred items is permitted without the written consent of all Consulting Native American Tribal Governments as defined in CR 3. The location for t he future reburial area shall be identified on a confidential exhibit on file with the City, and concurred to by the Consulting Native American Tribal Governments prior to certification of the environmental document.
CR 5 The City shall verify that the following note is included on the Grading Plan:
“If any suspected archaeological and cultural resources are discovered during ground– disturbing activities and the Project Archaeologist or Native American Tribal Representatives are not present, the construction supervisor is obligated to halt work in a 100- foot radius around the find and call the Project Archaeologist and the Tribal Representatives to the site to assess the significance of the find."
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Bradshaw Collection Project Page 50 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
CR 6 Inadvertent Finds. If potential historic or cultural resources are uncovered during excavation or construction activities at Bradshaw Collection (Tentative Tract Map 37858) that were not assessed by the archaeological report(s) and/or environmental assessment conducted prior to Project approval , all ground-disturbing activities in the affected area within 100 feet of the uncovered resource must cease immediately and a qualified person meeting the Secretary of the Interior's standards (36 CFR 61), Tribal Representatives, and all site monitors per the Mitigation Measures, shall be consulted by the City to evaluate the find, and as appropriate recommend alternative measures to avoid, minimize or mitigate negative effects on the historic, or prehistoric resource. Further ground disturbance shall not resume within the area of the discovery until an agreement has been reached by all parties as to the appropriate mitigation. Work shall be allowed to continue outside of the buffer area and will be monitored by additional archeologists and Tribal Monitors, if needed. Determinations and recommendations by the consultant shall be immediately submitted to the Planning Division for consideration and implemented as deemed appropriate by the Community Development Direct or, in consultation with the State Historic Preservation Officer (SHPO) and any and all Consulting Native American Tribes as defined in CR 2 before any further work commences in the affected area. If the find is determined to be significant and avoidance of the site has not been achieved, a Phase III data recovery plan shall be prepared by the Project Archeologist, in consultation with the Tribe, and shall be submitted to the City for their review and approval prior to implementation of the said plan.
CR 7 Human Remains. If human remains are discovered, no further disturbance shall occur in the affected area until the County Coroner has made necessary findings as to origin. If the County Coroner determines that the remains are potentially Native American, the California Native American Heritage Commission shall be notified within 24 hours of the published finding to be given a reasonable opportunity to identify the “most likely descendant”. The “most likely descendant” shall then make recommendations and engage in consultations concerning the treatment of the remains (California Public Resources Code 5097.98). (GP Objective 23.3, CEQA). No photographs are to be taken except by the coroner, with written approval by the consulting Tribe(s).
CR 8 Non-Disclosure of Reburial Locations. It is understood by all parties that, unless otherwise required by law, the site of any reburial of Native American human remains or associated grave goods shall not be disclosed and shall not be governed by public disclosure requirements of the Califor nia Public Records Act. The Coroner, pursuant to the specific exemption set forth in California Government Code 6254 (r), parties, and Lead Agencies, will be asked to withhold public disclosure information related to such reburial, pursuant to the specific exemption set forth in California Government Code 6254 (r).
CR 9 Archaeology Report - Phase III and IV. Prior to final inspection, the developer/permit holder shall prompt the Project Archaeologist to submit two (2) copies of the Phase III Data Recovery report (if required for the Project) and the Phase IV Cultural Resources Monitoring Report that complies with the Community Development Department's requirements for such reports. The Phase IV report shall include evidence of the required cultural/historical sensitivity training for the construction staff held during the pre-grade meeting. The Community Development Department shall review the reports to determine adequate mitigation compliance. Provided the reports are adequate, the Community Development Department shall clear this condition. Once the report(s) are determined to be adequate, two (2) copies shall be submitted to the South Coastal Information Center (SCIC) at the San Diego State University (SDSU), and one (1) copy shall be submitted to each of the Consulting Tribe(s) Cultural Resources Department(s).
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.2 – Cultural and Historical Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.10 – Cultural Resources
• Figure 4.10-1 – Locations of Listed Historic Resource Inventory Structures
3. Phase I Cultural Resources Investigation and Paleontological Overview for Tentative Tract Map No. 37858, City of Moreno Valley, Riverside County, California. March 18, 2020. Prepared by McKenna et al. (Appendix D).
Bradshaw Collection Project Page 51 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VI. Energy – Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than Significant Impact. The Project Site is currently vacant. The Southern California Gas Company provides natural gas to the surrounding area. Additionally, Moreno Valley Utility currently provides electricity services to the surrounding area. The proposed Project would install onsite electrical and natural gas infrastructure that would connect to the existing offsite lines.
Construction
During construction of the proposed Project, energy would be consumed in three general forms:
1. Petroleum-based fuels used to power off-road construction vehicles and equipment on the Project sites, construction worker travel to and from the Project sites, as well as delivery truck trips;
2. Electricity associated with providing temporary power for lighting and electric equipment; and
3. Energy used in the production of construction materials, such as asphalt, steel, concrete, pipes, and manufactured or processed materials such as lumber and glass.
Construction activities related to the proposed building and the associated infrastructure would not be expected to result in demand for fuel greater on a per-unit-of-development basis than other development projects in southern California. In addition, the extent of construction activities that would occur is limited to a 12- month period, and the demand for construction-related electricity and fuels would be limited to that time frame.
Construction contractors are required to demonstrate compliance with applicable California Air Resources Board (CARB) regulations governing the accelerated retrofitting, repowering, or replacement of heavy -duty diesel on - and off -road equipment as part of the City’s construction permitting process. In addition, compliance with existing CARB idling restrictions would reduce fuel combustion and energy consumption. The energy modeling shows that Project construction electricity usage over the 12-month construction period is estimated to use 28,877.75 gallons of diesel fuel, as shown in Table E-1.
Table E-1: Estimated Construction Equipment Diesel Fuel Consumption Phase Phase
Duration
Equipment Amount Horsepower Load
Factor
Horsepower
Hours
Diesel Fuel
Consumption
(gal)
Site Preparation 5 Rubber Tired Dozers 3 367 0.40 17,616 952.2 Tractors/Loaders/
Backhoes
4 84 0.37 4,972.8 268.8
Grading 8 Graders 1 148 0.41 3,883.5 209.9
Excavators 1 36 0.38 875.5 47.3
Tractors/Loaders/Ba
ckhoes
3 82 0.37 5,967.4 322.6
Rubber Tired Dozers 1 367 0.40 9,395.2 507.8
Building
Construction
230 Cranes 1 367 0.29 171,352.3 9,262.3
Forklifts 3 82 0.20 90,528 4,893.4
Generator Sets 1 14 0.74 19,062.4 1,030.4
Welders 1 46 0.45 38,088 2,058.8
Tractors/Loaders/Ba
ckhoes
3 84 0.37 150,116.4 8,114.4
Paving 18 Tractors/Loaders/Ba
ckhoes
1 84 0.37 4,475.5 241.9
Cement and Mortar
Mixers
2 10 0.56 1,209.6 65.4
Pavers 1 81 0.42 4,898.9 264.8
Paving Equipment 2 89 0.36 6,920.6 374.1
Rollers 2 36 0.38 2,954.9 159.7
Architectural
Coating
18 Air Compressors 1 37 0.48 1,918.1 103.7
Total Diesel Fuel Consumption 28,877.57
Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
□ □ ~ □
Bradshaw Collection Project Page 52 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
Table E-2 shows that construction workers would use approximately 3,166.47 gallons of fuel to travel to and from the Project site, and haul trucks and vendor trucks would use approximately 4,261.63 gallons of diesel fuel.
Table E-2: Estimated Construction Vehicle Trip Related Fuel Consumption Construction Source Gallons of Diesel Fuel Gallons of Gasoline Fuel Haul Trucks 3,128.35 1.76
Vendor Trucks 1,130.39 219.81
Worker Vehicles 2.89 2,944.90
Construction Vehicles Total 4,261.63 3,166.47
Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
Overall, construction activities would comply with all existing regulations, and would therefore not be expected to use fuel in a wasteful, inefficient, and unnecessary manner. Thus, impacts related to construction energy usage would be less than significant.
Operation
Once operational, the Project would generate demand for electricity, natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of the residences, water heating, operation of electrical systems and plug-in appliances, and outdoor lighting, and the transport of electricity, natural gas, and water to the residences where they would be consumed. This use of energy is typical for urban development, no additional energy infrastructure would be required to be built to operate the Project, and no operational activities would occur that would result in extraordinary energy consumption.
The proposed Project would be required to meet the current Title 24 energy efficiency standards. The City’s administration of the Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. Typical Title 24 measures include insulation; use of energy-efficient heating, ventilation and air conditioning equipment (HVAC); solar -reflective roofing materials; energy - efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, etc. In complying with the Title 24 standards, impacts to peak energy usage periods would be minimized, and impacts on statewide and regional energy needs would be reduced. As detailed in Table E -3, operation of the proposed Project is estimated to result in the annual use of approximately 48,035. gallons of gasoline, 2,939.11 gallons of diesel fuel, approximately 230,684.62 kilowatt-hour (kWh) of electricity, and approximately 1,315.88 million British thermal units (MBTU) of natural gas. Thus, operation of the Project would not use large amounts of energy or fuel in a wasteful manner, and operational energy impacts would be less than significant.
Table E-3: Estimated Annual Operational Energy Consumption Operational Source (value per year)
Energy Source Annual VMT Gallons of
Gasoline Fuel
Gallons of
Diesel Fuel
Transportation – Project 1,136,007 48,035.94 2,939.11
Thousands Kilowatt-Hours
Electricity – Project 230,684.62
Million British Thermal Units
Natural Gas – Project 1,315.88
Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
Bradshaw Collection Project Page 53 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Response:
Less than Significant Impact. The proposed Project would be required to meet the C ALGreen energy efficiency standards in effect during permitting of the Project. The City’s administration of the requirements includes review of design components and energy conservation measures during the permitting process, which ensures that all requirements are met.
In addition, the Project would not conflict with or obstruct opportunities to use renewable energy, such as solar energy.
Further, the Project would be consistent with policies set forth in the City’s General Plan related to renewable energy, as outlined in Tables E-4 and E-5. As discussed, the Project proposes to use photovoltaic (PV) solar panels on each of the residences to offset their energy demand in accordance with Title 24. As such, the Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and impacts would be less than significant.
Table E-4: 2006 General Plan Consistency
Policy Consistency
Goal 2.5: Maintenance of systems for water supply and
distribution; wastewater collection, treatment, and
disposal; solid waste collection and disposal; and energy distribution which are capable of meeting the present and future needs of all residential, commercial, and industrial customers within the City of Moreno Valley.
Consistent. As detailed in Section 19, Utilities and
Service Systems, the supply of water listed in Table
WQ-1 would be sufficient during both normal years
and multiple dry year conditions between 2020 and
2045 to meet all of the City’s estimated needs,
including the proposed Project
Policy 2.2.15: Encourage the use of innovative and cost effective building materials, site design practices and energy and water conservation measures to conserve
resources and reduce the cost of residential development.
Consistent. The proposed Project would be required
to comply with Title 24 Building Standards. Typical
Title 24 measures include insulation; use of energy-
efficient heating, ventilation and air conditioning
equipment (HVAC); solar-reflective roofing materials;
energy- efficient indoor and outdoor lighting systems;
and incorporation of skylights, etc.
Objective 6.7: Reduce mobile and stationary source air
pollutant emissions.
Policy 6.7.6: Require building construction to comply with the energy conservation requirements of Title 24 of the California Administrative Code.
Objective 7.5: Encourage efficient use of energy
resources.
7.5.1: Encourage building, site design, and landscaping techniques that provide passive heating and cooling to
reduce energy demand.
Consistent. The proposed Project would comply with
Title 24 Building Standards. Typical Title 24
measures include insulation; use of energy-efficient
heating, ventilation and air conditioning equipment
(HVAC); solar -reflective roofing materials; energy -
efficient indoor and outdoor lighting systems; and
incorporation of skylights, etc. In complying with the
Title 24 standards, impacts to peak energy usage
periods would be minimized, and impacts on
statewide and regional energy needs would be
reduced
7.5.2: Encourage energy efficient modes of transportation and fixed facilities, including transit, bicycle, equestrian, and pedestrian transportation. Emphasize fuel efficiency in the acquisition and use of City-owned vehicles.
Consistent. The proposed Project includes
pedestrian paths to provide for non- vehicular onsite
circulation and for connection to existing sidewalks
and bike lanes adjacent to the proposed Project.
7.5.5 Encourage the use of solar power and other
renewable energy systems.
Consistent. The proposed Project would be
consistent with Title 24 Building Standards and would
include photovoltaic (PV) solar panels to offset the
energy demand.
□ □ [:g] □
Bradshaw Collection Project Page 54 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table E-5: 2024 General Plan Consistency
Policy Consistency
Goal OSRC-3: Use energy and water wisely and
promote reduced consumption.
Consistent. The proposed Project would comply with
Title 24 Building Standards. Typical Title 24 measures
include insulation; use of energy -efficient heating,
ventilation and air conditioning equipment (HVAC);
solar-reflective roofing materials; energy -efficient
indoor and outdoor lighting systems; and incorporation
of skylights, etc. In complying with the Title 24
standards, impacts to peak energy usage periods
would be minimized, and impacts on statewide and
regional energy needs would be reduced
OSRC 3.1: Promote energy conservation throughout
the community and encourage the use of renewable
energy systems and technologies to supplement or
replace traditional building energy systems.
Consistent. The proposed Project would include
photovoltaic (PV) solar panels to offset the energy
demand and would be in compliance with the Title 24
California Building Standards.
OSRC 3.5: Promote the retention and reuse of
rainwater onsite and promote the use of rain barrels or other rainwater reuse systems throughout the community.
Consistent. The proposed Project would include a
series of catch basins which would collect all
stormwater onsite.
OSRC 3.6: Encourage new development to
incorporate as many water -wise practices as feasible in their design and construction.
Consistent. The proposed Project would comply with
Title 24 Building Standards which require the inclusion of efficient water features.
OSRC 3.8: Conserve water through the planting and
maintenance of trees, which will provide for the capture of precipitation and runoff to recharge groundwater, in
addition to providing shading for other landscaping to
reduce irrigation requirements. Ensure that any
‘community greening’ projects utilize water -efficient
landscape
Consistent. As detailed in Section 19, Utilities and
Service Systems, the supply of water listed in Table
WQ-1 would be sufficient during both normal years
and multiple dry year conditions between 2020 and
2045 to meet all of the City’s estimated needs,
including the proposed Project.
Existing Plans, Programs, or Policies
PPP GHG-1: CALGreen Compliance, provided in Section 8, Greenhouse Gas Emissions.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.6 – Energy Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. TTM 37858 Single Family Residential Project Air Quality, Greenhouse Gas, and Energy Impact Study. RK Engineering. April 22, 2025 (Appendix A).
5. City of Moreno Valley Energy Efficiency and Climate Action Strategy. Accessed at:
http://www.moval.org/pdf/efficiency-climate112012nr.pdf (Accessed May 27, 2021).
Bradshaw Collection Project Page 55 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant Impact No Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?
Response:
No Impact. The Project Site is not located within a designated Alquist-Priolo Earthquake Fault Zone or County of Riverside Fault zone. As described by the Preliminary Soil Investigation prepared for the proposed Project, the nearest known active fault zone is the San Jacinto fault zone located approximately 2.78 miles from the Project site (Soil Exploration Company Inc., 2020). Thus, the proposed Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist -Priolo Earthquake Fault Zoning Map, and impacts would not occur.
ii) Strong seismic ground shaking?
Response:
Less Than Significant Impact. The Project Site is located within a seismically active region of Southern California. As mentioned previously, the San Jacinto Fault is located approximately 2.78 miles from the site (Soil Exploration Company Inc., 2020). Thus, moderate to strong ground shaking can be expected at the site. The amount of motion can vary depending upon the distance to the fault, the magnitude of the earthquake, and the local geology. Greater movement can be expected at sites located closer to an earthquake epicenter, that consists of poorly consolidated material such as alluvium, and in response to an earthquake of great magnitude.
Structures built in the City are required to be built in compliance with the California Building Code (CBC [California Code of Regulations, Title 24, Part 2]), included in the Municipal Code as Chapter 8.20. In addition, PPP GEO- 1 has been included to provide provisions for earthquake safety based on factors including occupancy type, the types of soils onsite, and the probable strength of the ground motion. PPP GEO -1 requires that the Project must comply with the California Building Code and include geologist or civil engineer specifications in its grading plans to address seismic hazards as a condition of approval. Compliance with the CBC would include the incorporation of: 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structures so that it would withstand the effects of strong ground shaking. Because the proposed Project would be constructed in compliance with the CBC, the proposed Project would result in a less than significant impact related to strong seismic ground shaking.
iii) Seismic-related ground failure, including liquefaction?
Response:
Less Than Significant Impact. Soil liquefaction is a phenomenon in which saturated, cohesionless soils layers, located within approximately 50 feet of the ground surface, lose strength due to cyclic pore water pressure generation from seismic shaking or other large cyclic loading. During the loss of stress, the soil acquires “mobility” sufficient to permit both horizontal and vertical movements. Soil properties and soil conditions such as type, age, texture, color, and consistency, along with historical depths to ground water are used to identify, characterize, and correlate liquefaction susceptible soils.
Soils that are most susceptible to liquefaction are clean, loose, saturated, and uniformly graded fine- grained sands that lie below the groundwater table within approximately 50 feet below ground surface. Lateral spreading is a form of seismic ground failure due to liquefaction in a subsurface layer.
According to the Preliminary Soil Investigation for the proposed Project, the site is located within an area of moderate liquefaction potential. Liquefaction is a process in which strong ground shaking causes saturated soils to lose their strength and behave as a fluid. The potential for and magnitude of lateral spreading is dependent upon many conditions, including the presence of a relatively thick, continuous, potentially liquefiable sand layer and high slopes. Subsurface information obtained from the Preliminary Soil Investigation indicates that after compaction onsite soils, settlement of saturated sands is 0 inches and unsaturated sands is 1.14 inches. Based on currently available procedures, the site does not appear to be susceptible to lateral spread during a moderate seismic event. In addition, the Preliminary Soil
Investigation determined that groundwater, seepage or wet soils were not encountered in exploratory borings drilled to a maximum depth of 50 feet (Soil Exploration Company Inc., 2020).
□ □ □ [:8J
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 56 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
In addition, as described previously, structures built in the City are required to be built in compliance with the CBC, as included in the City’s Municipal Code as Chapter 8.20 (and herein as PPP GEO-1), which implements specific requirements for seismic safety, excavation, foundations, retaining walls and site demolition. Compliance with the CBC, as included as PPP GEO-1, would require specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that Project structures would withstand the effects of seismic ground movement, including liquefaction and settlement. Compliance with the requirements of the CBC and City’s municipal code for structural safety (included as PPP GEO-1) would reduce hazards from seismic-related ground failure, including liquefaction and settlement to a less than significant level. iv) Landslides?
Response:
No Impact. Landslides and other slope failures are secondary seismic effects that are common during or soon after earthquakes. Areas that are most susceptible to earthquakes induced landslides are steep slopes underlain by loose, weak soils, and areas on or adjacent to existing landslide deposits.
As described above, the Project site is located in a seismically active region subject to strong ground shaking. However, the Project site is flat and does not contain any hills or any other areas that could be subject to landslides. In addition, the local vicinity is flat and does not contain any hills. Therefore, the Project would not cause potential substantial adverse effects related to slope instability or seismically induced landslides and no impact would occur. b) Result in substantial soil erosion or the loss of topsoil?
Response:
Less Than Significant Impact. Construction of the Project has the potential to contribute to soil erosion and the loss of topsoil. Grading and excavation activities that would be required for the proposed Project would expose and loosen topsoil, which could be eroded by wind or water.
The City’s Municipal Code Section 8.21.170 implements all applicable requirements of the State Water Resources Control Board (SWRCB) and the Santa Ana Regional Water Quality Control Board (SARWQCB), and all projects in the City are required to conform to the permit requirements. This includes installation of Best Management Practices (BMPs) in compliance with the National Pollution Discharge Elimination System (NPDES) permit , which establishes minimum stormwater management requirements and controls that are required to be implemented for the proposed Project. To reduce the potential for soil erosion and the loss of topsoil, a Stormwater Pollution Prevention Plan (SWPPP) is required by the Regional Water Quality Control Board (RWQCB) regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site- specific conditions related to specific grading and construction activities such as, potential sources of erosion and sedimentation loss of topsoil during construction, and identification of erosion control BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags, stabilized construction entrance/exit, hydroseeding. With compliance with the City’s Municipal Code, RWQCB requirements, and the BMPs in the SWPPP that are required to be prepared to implement the Project (included as PPP WQ-1), construction impacts related to erosion and loss of topsoil would be less than significant.
In addition, the proposed Project includes installation of landscaping, such that during operation of the Project substantial areas of loose topsoil that could erode would not exist. In addition, as described in Section 10, Hydrology and Water Quality, the onsite drainage features that would be installed by the Project have been designed to slow, filter, and slowly discharge stormwater into the offsite drainage system, which would also reduce the potential for stormwater to erode topsoil during Project operations. Furthermore, implementation of the Project requires City approval of a site specific Water Quality Management Plan (WQMP), which would ensure that the City’s Municipal Code, RWQCB requirements, and appropriate operational BMPs would be implemented to minimize or eliminate the potential for soil erosion or loss of topsoil to occur. As a result, potential impacts related to substantial soil erosion or loss of topsoil would be less than significant.
□ □ □ I l6J
□ □ l6J I □
Bradshaw Collection Project Page 57 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Response:
Less Than Significant Impact. As described above, the Project site is flat, and does not contain nor is adjacent to any slope or hillside area. The Project would not create slopes. Thus, onsite or offsite landslides would not occur from implementation of the Project.
Lateral spreading, a phenomenon associated with seismically induced soil liquefaction, is a display of lateral displacement of soils due to inertial motion and lack of lateral support during or post liquefaction. It is typically exemplified by the formation of vertical cracks on the surface of liquefied soils, and usually takes place on gently sloping ground or lev el ground with nearby free surface such as drainage or stream channel. According to the Preliminary Soil Investigation, subsurface information indicates that high slopes are not anticipated. In addition, based on currently available procedures, the site does not appear to be susceptible to (lateral spread) ground surface disruption during a moderate seismic event (Soil Exploration Company Inc, 2020). Thus, the soils are not susceptible to lateral spreading and impacts related to liquefaction and lateral spreading would be less than significant.
Differential settlement or subsidence could occur if buildings or other improvements are built on low-strength foundation materials (including imported fill) or if improvements straddle the boundary between different types of subsurface materials (e.g., a boundary between native material and fill). Although differential settlement generally occurs slowly enough that its effects are not dangerous to inhabitants, it can cause building damage over time. Seismic settlement in dry soils generally occurs in loose sands and silty sands, with cohesive soils being less prone to significant settlement.
The Preliminary Soil Investigation determined that overexcavation and recompaction of loose surficial soils are anticipated to provide adequate and uniform support for the proposed structures (Soil Exploration Company Inc, 2020). Project design and implementation would comply with the recommendations of the required Preliminary Soil Investigation prepared for the Project site, which would ensure impacts related to settlement and subsidence would be less than significant.
In summary, with implementation of the recommendations in the Project’s Preliminary Soil Investigation, potentially significant impacts related to unstable soils or geologic units that would become unstable as a result of the Project, resulting in onsite or offsite landslides, lateral spreading, subsidence, liquefaction, or collapse, would be reduced to a less than significant level, and no mitigation would be required. d) Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Response:
Less Than Significant Impact. Expansive soils contain certain types of clay minerals that shrink or well as the moisture content changes; the shrinking or swelling can shift, crack, or break structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture experiences, such as southern California, have a higher potential of expansive soils than areas with higher rainfall and more constant soil moisture.
The Preliminary Soil Investigation performed an evaluation of the potential for expansive soils at the site, which determined that the expansion potential of onsite near surface silty sands is expected to be very low (El<20) (Soil Exploration Company Inc, 2020). However, as described previously, compliance with the CBC, included as PPP GEO-1, would require specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval to ensure that Project structures would withstand the effects of related to ground movement, including expansive soils. Thus, impacts would be less than significant. e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Response:
No Impact. The Project would not use septic tanks or alternative methods for disposal of wastewater into subsurface soils. Furthermore, the proposed Project would connect to existing public wastewater infrastructure. Therefore, the Project would not result in any impacts related to septic tanks or alternative wastewater disposal methods.
□ □ ~ □
□ □ ~ □
□ □ □ ~
Bradshaw Collection Project Page 58 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Response:
Less than Significant Impact with Mitigation Incorporated. The Phase 1 Cultural and Paleontological Resources Assessment prepared for the Project included a locality search through the Natural History Museum of Los Angeles County (LACM) to identify any previously identified paleontological resources near the Project site.
The Phase 1 Cultural and Paleontological Overview determined that the Project area consists of surficial deposits of younger Quaternary deposits overlying older Quaternary deposits. The younger deposits are not conducive to yielding paleontological specimens. However, the deeper, older alluvial deposits may, in fact, yield such resources. The Project area should be considered sensitive for buried paleontological resources (McKenna, 2020).
Therefore, based on the results of the Phase I Paleontological Resources Assessment, the Project area is considered to have high sensitivity for the potential to impact paleontological resources during construction activities at or below 5 feet in undisturbed sedimentary deposits. McKenna recommends preparation of a Paleontological Resources Impact Mitigation Plan (PRIMP) prior to construction excavation. Thus, Mitigation Measure PAL-1 has been included to require preparation of a PRMP and that a professional paleontologist be hired to oversee monitoring. With implementation of Mitigation Measure PAL-1, impacts to paleontological resources would be less than significant.
Existing Plans, Programs, or Policies
PPP GEO-1: California Building Code. The Project is required to comply with the California Building Code as included in the City’s Municipal Code Chapter 8.20 to preclude significant adverse effects associated with seismic hazards.
California Building Code related and geologist and/or civil engineer specifications for the Project are required to be incorporated into grading plans and specifications as a condition of Project approval.
PPP WQ-1: Stormwater Pollution Prevention Plan, provided in Section 10, Hydrology and Water Quality.
PPP WQ-2: Water Quality Management Plan, provided in Section 10, Hydrology and Water Quality.
Mitigation Measures
Mitigation Measure PAL -1: Paleontological Resources. A paleontologist selected from the roll of qualified paleontologists maintained by the City shall be retained to provide spot -check monitoring services for the Project. The paleontologist shall develop a Paleontological Resources Impact Mitigation Plan (PRIMP) to mitigate the potential impacts to unknown buried paleontological resources that may exist onsite. The PRIMP shall require that the paleontologist be present at the pre-grading conference to establish procedures for paleontological resource surveillance. The PRIMP shall require paleontological spot-check monitoring of excavation that exceeds depths of 5 feet. The PRIMP shall state that the Project paleontologist shall re-evaluate the necessity for paleontological monitoring after 50 percent or greater of the excavations deeper than 5 feet have been completed.
In the event that paleontological resources are encountered, ground-disturbing activity within 50 feet of the area of the discovery shall cease. The paleontologist shall examine the materials encountered, assess the nature and extent of the find, and recommend a course of action to further investigate and protect or recover and salvage those resources that have been encountered.
Criteria for discard of specific fossil specimens will be made explicit. If a qualified paleontologist determines that impacts to a sample containing significant paleontological resources cannot be avoided by Project planning, then recovery may be applied. Actions may include recovering a sample of the fossiliferous material prior to construction, monitoring work and halting construction if an important fossil needs to be recovered, and/or cleaning, identifying, and cataloging specimens for curation and research purposes. Recovery, salvage and treatment shall be done at the applicant’s expense. All recovered and salvaged resources shall be prepared to the point of identification and permanent preservation by the paleontologist. Resources shall be identified and curated into an established accredited professional repository. The paleontologist shall have a repository agreement in hand prior to initiating recovery of the resource.
□ ~ □ □
Bradshaw Collection Project Page 59 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.5 – Geologic Hazards - Figure 5-3 – Geologic Faults & Liquefaction
• Chapter 7 – Conservation Element – Section 7.4 -- Soils
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.6 – Geology and Soils
- Figure 4.6-1 – Geology
- Figure 4.6-2 – Seismic Hazards
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. Moreno Valley Municipal Code Chapter 8.21 – Grading Regulations
5. Local Hazard Mitigation Plan, City of Moreno Valley Fire Department, adopted October 4, 2011, amended 2017, http://www.moval.org/city_hall/departments/fire/pdfs/haz-mit-plan.pdf • Chapter 4 – Earthquake
- Figure 3-1 – Right-Lateral Strike -Slip Fault
- Figure 3-1.1 – Moreno Valley Geologic Faults and Liquefaction 2016 - Figure 3-1.2 – Moreno Valley Area Ground Shaking Map
• Chapter 8 – Landslide
- Figure 7-1 – Moreno Valley Slope Analysis 2016
6. Emergency Operations Plan, City of Moreno Valley, March 2024, chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.moval.org/departments/fire/pdf/MV-EOP- 2024.pdf
• Threat Assessment 1 –Earthquakes
- Figure 10 – California Earthquake Faults
- Figure 13 – City Liquefaction Map
7. Phase I Cultural Resources Investigation and Paleontological Overview for Tentative Tract Map No. 37858, City of Moreno Valley, Riverside County, California. March 18, 2020. Prepared by McKenna et al. (Appendix D).
8. Preliminary Soil Investigation, Infiltration Test and Liquefaction Evaluation Report, Proposed Residential Development Site (41 Lots), Cactus Avenue and Bradshaw Circle (APN 478 -090-018, -024 and - 025), City of Moreno Valley, California. January 21, 2020. Prepared by Soil Exploration Company, Inc. (Appendix E).
Bradshaw Collection Project Page 60 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
GHG Thresholds
The City of Moreno Valley has not adopted a numerical significance threshold to evaluate greenhouse gas (GHG) impacts. SCAQMD does not have approved thresholds; however, it does have draft thresholds that provides a tiered approach to evaluate GHG impacts, which includes the following:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA. • Tier 2 consists of determining whether the project is consistent with a GHG reduction plan. If a project is consistent with a qualifying local GHG reduction plan, it does not have significant GHG emissions. • Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to the project’s operational emissions. If a project’s emissions are below one of the following screening thresholds, then the project is less than significant:
o Residential and Commercial land use: 3,000 MTCO2e per year o Industrial land use: 10,000 MTCO2e per year
o Based on land use type: residential: 3,500 MTCO2e per year; commercial: 1,820 MTCO2e per year; or mixed use: 3,000 MTCO2e per year
The SCAQMD’s draft threshold uses the Executive Order S -3-05 year 2050 goal as the basis for the Tier 3 screening level. Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations at 450 ppm, thus stabilizing global climate. Therefore, for purposes of examining potential GHG impacts from implementation of the proposed Project, and to provide a conservative analysis of potential impacts, the Tier 3 screening level for all land use projects of 3,000 MTCO2e was selected as the significance threshold (Vince Mirabella, 2020).
In addition, SCAQMD methodology for project’s construction are to average them over 30 -years and then add them to the project’s operational emissions to determine if the project would exceed the screening values listed above (Vince Mirabella, 2020).
Climate Action Plan
The City of Moreno Valley adopted an Energy Efficiency and Climate Action Strategy document in 2012. The Energy Efficiency and Climate Action Strategy is a policy document which identifies ways that the City can reduce energy and water consumption and GHG emissions as an organization (its employees and the operation of its facilities) and outlines the actions that the City can encourage and community members can employ to reduce their own energy and water consumption and GHG emissions. The Project involves the construction and operation of 37 single- family residences that would fall under the scope of these policies.
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
Response:
Less Than Significant Impact. Construction activities produce GHG emissions from various sources, such as site excavation, grading, utility engines, heavy-duty construction vehicles onsite, equipment hauling materials to and from the site, asphalt paving, and motor vehicles transporting the construction crew.
In addition, operation of the proposed residences would result in area and indirect sources of operational GHG emissions that would primarily result from vehicle trips, electricity and natural gas consumption, water transport (the energy used to pump water), and solid waste generation. GHG emissions from electricity consumed by the residences would be generated offsite by fuel combustion at the electricity provider. GHG emissions from water transport are also indirect emissions resulting from the energy required to transport water from its source.
The estimated operational GHG emissions that would be generated from implementation of the proposed Project are shown in Table GHG-1.
Additionally, in accordance with SCAQMD recommendation, the Project’s amortized construction related GHG emissions are added to the operational emissions estimate in order to determine the Project’s total annual GHG emissions.
□ □ ~ □
Bradshaw Collection Project Page 61 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table GHG-1: Greenhouse Gas Emissions
Source: Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A)
As shown on Table GHG -1, the combined construction and operation of the Project would result in a total increase in GHG emissions of 519.99 MTCO2e per year, which would not exceed the significance threshold of 3,000 MTCO2e per year.
Therefore, impacts related to greenhouse gas emissions would be less than significant.
Activity Annual GHG
Emissions (MTCO2e)
Project Operational Emissions
Area
Energy
Mobile
Waste
Water
Refrigerant
0.64 114.91
377.25
10.62 4.65
0.09 Project Construction Emissions 11.83
Project Construction and
Operation
519.99
Significance Threshold 3,000
Project Exceeds Threshold? No
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse
gases?
Response:
No Impact. The proposed Project would redevelop the site with single-family residences that would comply with State programs that are designed to be energy efficient. The proposed Project would comply with all mandatory measures under the California Title 24, California Energy Code, and the CALGreen Code, which would provide efficient energy and water consumption. The City’s administration of the requirements includes review of the energy conservation measures during the permitting process, which ensures that all requirements are met. In addition, the Project includes photovoltaic (PV) solar panels to offset the energy demand. Therefore, the proposed Project would not conflict with existing plans, policies, and regulations adopted for the purpose of reducing the emissions of greenhouse gas.
Existing Plans, Programs, or Policies
PPP GHG-1: CALGreen Compliance. The Project is required to comply with the CALGreen Building Code as included in the City’s Municipal Code to ensure efficient use of energy. CALGreen specifications are required to be incorporated into the building plans as a condition of building permit approval.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. California’s 2017 Climate Change Scoping Plan, prepared by the California Air Resources Board, November 2017, https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf, (Accessed May 27, 2021)
5. TTM 37858 Single Family Residential Project Air Quality, Greenhouse Gas, and Energy Impact Study. RK Engineering. April 22, 2025 (Appendix A).
6. City of Moreno Valley Energy Efficiency and Climate Action Strategy. Accessed at:
http://www.moval.org/pdf/efficiency-climate112012nr.pdf (Accessed May 27, 2021)
□ □ □ ~
Bradshaw Collection Project Page 62 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Response:
Less Than Significant Impact. A hazardous material is defined as any material that, due to its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous wastes, and any material that regulatory agencies have a reasonable basis for believing would be injurious to the health and safety of persons or harmful to the environment if released into the home, workplace, or environment. Hazardous wastes require special handling and disposal because of their potential to damage public health and the environment.
Construction
The proposed construction activities would involve the routine transport, use, and disposal of hazardous materials such as paints, solvents, oils, grease, and caulking during construction activities. In addition, hazardous materials would routinely be needed for fueling and servicing construction equipment on the site. These types of materials are not acutely hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and State regulations that are implemented by the City during building permitting for construction activities. Construction would also include temporary dewatering during excavation for utility installations if the excavation is deep enough to encounter groundwater.
If such excavations are in the vicinity of the impacted groundwater in the northeast portion of the site, the water would either be contained and transported to a licensed offsite treatment facility or treated on site before discharge under a county permit to the sanitary sewer. As a result, construction of the Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, and impacts would be less than significant.
Operation
The Project involves operation of 37 new single -family residences. Residential uses typically do not present a hazard associated with the accidental release of hazardous substances into the environment because residents are not anticipated to use, store, dispose, or transport large volumes of hazardous materials. Hazardous substances associated with residential uses are typically limited in both amount and use. Project operation would involve the use of potentially hazardous materials (e.g., solvents, cleaning agents, paints, fertilizers, and pesticides) typical of residential uses that, when used correctly and in compliance with existing laws and regulations, would not result in a significant hazard to people in the vicinity of the proposed Project. Therefore, impacts associated with the disposal of hazardous materials and/or the potential release of hazardous materials that could occur with the implementation of the proposed Project would be less than significant.
□ □ [g] □
Bradshaw Collection Project Page 63 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident
conditions involving the release of hazardous materials into the environment?
Response:
Less Than Significant Impact. A Phase I ESA was prepared by Robin Environmental Management (REM) in January 2024 for the Project site. The purpose of the Phase I analysis was to evaluate the Project site for potential Recognized Environmental Concerns (RECs) that may be present, offsite conditions that may impact the subject property, and/or conditions indicative of releases or threatened releases of hazardous substances on, at, in, or to the Project site. ASTM defines a Recognized Environmental Condition (REC) as “the presence or likely presence of an hazardous substance or petroleum products in, on, or at a property: 1) due to release to the environment; 2) under conditions indicative of a release to the environment; or 3) under conditions that pose a material threat of a future release to the environment.”
The Phase I ESA was performed in conformance with the scope and limitations of ASTM Practice E-1527-21 with a field survey of the subject site and adjacent properties on January 27, 2024.
According to the Phase I, the subject property was not recognized being listed on the following environmental regulatory database record research (NETR database): NPL, RCRA -TSD, CERCLIS, NFRAP, RCRA- G, ERNS, CORRACTS, CORTESE, CALSITES, LUST, UST, SWF , and DTSC (REM, 2024) . In addition, based on the government records search, there are no active cleanup sites, Underground Storage Tanks (LUST), or any sites identified as potential environmental concerns within the immediate area of the Project site.
Based on site observations, interviews and review of available documents and the database records search, the Phase I concluded that there is no evidence of recognized environmental conditions in connection with the property and no Phase II (subsurface investigation) environmental assessment would be required (REM, 2024). Thus, the proposed Project would not create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment and impacts would be less than significant.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-
quarter mile of an existing or proposed school?
Response:
Less Than Significant Impact. The proposed residential Project would not produce hazardous emissions or handle acutely hazardous materials, substances, or wastes. The nearest school to the Project site is Ridge Crest Elementary School, which is located approximately 0.3 miles southeast of the Project site. Thus, the proposed Project is not within one-quarter mile of an existing school. In addition, the proposed Project is not anticipated to release hazardous emissions or handle hazardous or acutely hazardous materials, substances, or wastes in significant quantities. Construction activities associated with the proposed Project would use a limited amount of hazardous and flammable substances/oils during heavy equipment operation for site excavation, grading, and construction. The amount of hazardous chemicals present during construction is limited and would be contained in compliance with existing government regulations.
Residences would not require the use, storage, disposal, or transport of large volumes of hazardous materials that could cause serious environmental damage in the event of an accident. Although hazardous substances would be present and utilized at these residences, such substances are generally present now in the existing development, are typically found in small quantities, and can be cleaned up without affecting the environment. Therefore, impacts related to hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or wastes within one-quarter mile of an existing or proposed school would be less than significant.
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 64 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government C ode
section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Response:
No Impact. The Phase I Environmental Site Assessment (REM, 2024 ) prepared for the Project conducted a database search to determine if the Project site or any nearby properties are identified as having hazardous materials. The Phase I record search determined that the Project site was not recognized being listed on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (REM, 2024). As a result, impacts related to hazards from being located on or adjacent to a hazardous materials site would not occur from implementation of the proposed Project. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
Response:
Less than Significant Impact. The Project Site is not within 2 miles of an airport. The nearest airport is the March Air Reserve Base that is located approximately 5.2 miles west of the Project Site. According to the March Air Reserve Base Land Use Compatibility Plan, the proposed Project is not located in a compatibility zone. Additionally, the residential development would not be of a sufficient height to require modifications to the existing air traffic patterns at the airport and, therefore, would not affect aviation traffic levels or otherwise result in substantial aviation -related safety risks.
Therefore, the proposed Project would not result in impacts to an airport land use plan, or where such a plan has not been adopted, and would not result in a safety hazard or excessive noise for people residing or working in the Project area. As such, impacts would be less than significant.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Response:
Less Than Significant Impact. The proposed Project would not physically interfere with an adopted emergency response plan or emergency evacuation plan.
Construction
Short-term construction activities would occur within the Project Site and would not restrict access of emergency vehicles to the Project Site or adjacent areas. In addition, travel along surrounding roadways would remain open and would not interfere with emergency access in the site vicinity. Any temporary lane closures needed for utility connections to Bradshaw Circle or Cactus Avenue, or d riveway access construction would be implemented consistent with the recommendations of the California Joint Utility Traffic Control Manual (Caltrans, 2014), as incorporated into the construction permits. Thus, impacts related to an emergency response or evacuation plan during construction would be less than significant.
Operation
Direct access to the Project Site would be provided from Bradshaw Circle by two driveways. The Project is required to provide internal streets and fire suppression facilities (e.g., hydrants and sprinklers) that conform to the California Fire Code requirements, included as Municipal Code Chapter 8.36, as verified through the City’s permitting process. As such, the Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan, and impacts would be less than significant.
□ □ □ ~
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 65 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Response:
No Impact. The Project Site is not within an area identified as a Fire Hazard Area that may contain substantial fire risk or a Very High Fire Hazard Severity Zone (VHFHSZ) (CAL FIRE, 2025). Therefore, the Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires and impact s would not occur.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.2.8 – Wildland Urban Interface • Chapter 6 – Safety Element – Section 6.9 – Hazardous Materials • Chapter 6 – Safety Element – Section 6.10 – Air Crash Hazards - Figure 5-5 – Air Crash Hazards
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.5 – Hazards and Hazardous Materials
- Figure 4.5-1 – Hazardous Materials Sites
- Figure 4.5-2 – Floodplains and High Fire Hazard Areas - Figure 4.5-3 – City Areas Affected by Aircraft Hazard Zones
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. March Air Reserve Base (MARB)/March Inland Port (MIP) Airport Land Use Compatibility Plan (ALUCP) on November 13, 2014, (chrome-
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://rcaluc.org/sites/g/files/aldnop421/files/2023-06/March.pdf
5. Local Hazard Mitigation Plan, City of Moreno Valley Fire Department, adopted October 4, 2011, amended 2017, http://www.moval.org/city_hall/departments/fire/pdfs/haz-mit-plan.pdf • Chapter 5 – Wildland and Urban Fires
- Figure 4-2 – Moreno Valley High Fire Area Map 2016
• Chapter 12 – Dam Failure/Inundation
- Figure 12-2 Moreno Valley Evacuation Routes Map 2015
• Chapter 13 – Pipeline
- Figure 13-1 – Moreno Valley Pipeline Map 2016
• Chapter 14 – Transportation
- Figure 14-1.1 – Moreno Valley Air Crash Hazard Area Map 2016 • Chapter 16 – Hazardous Materials Accident
- Moreno Valley Hazardous Materials Site Locations Map 2016
6. Emergency Operations Plan, City of Moreno Valley, March 2024 chrome- extension://efaidnbmnnnibpcajpcglclefindmkaj/https://moval.gov/departments/fire/pdf/MV-EOP-2024.pdf
7. California Department of Forestry and Fire Protection (CAL FIRE). 2025. Fire Hazard Severity Zone Map.
Accessed: https://moval.gov/departments/fire/HighFireMap-Review.html
8. Phase I Environmental Site Assessment, APN 478-090-018, 024, & 025, Moreno Valley, CA. January 27, 2024.
Prepared by Robin Environmental Management (REM) (Appendix F).
9. March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan. November 13, 2014. Adopted by the Riverside County Airport Land Use Commission (RCALUC). Accessed: http://www.rcaluc.org/Portals/13/17%20- %20Vol.%201%20March%20Air%20Reserve%20Base%20Final.pdf (Accessed May 26, 2021).
□ □ □ ~
Bradshaw Collection Project Page 66 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Response:
Less Than Significant Impact.
Construction
Implementation of the proposed Project includes site preparation, construction of new buildings, and infrastructure improvements. Grading, stockpiling of materials, excavation, construction of new structures, and landscaping activities would expose and loosen sediment and building materials, which would have the potential to mix with stormwater and urban runoff and degrade surface and receiving water quality.
Additionally, construction generally requires the use of heavy equipment and construction- related materials and chemicals, such as concrete, cement, asphalt, fuels, oils, antifreeze, transmission fluid, grease, solvents, and paints. In the absence of proper controls, these potentially harmful materials could be accidentally spilled or improperly disposed of during construction activities and could wash into and pollute surface waters or groundwater, resulting in a significant impact to water quality.
Pollutants of concern during construction activities generally include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. In addition, chemicals, liquid products, petroleum products (such as paints, solvents, and fuels), and concrete -related waste may be spilled or leaked during construction, which would have the potential to be transported via storm runoff into nearby receiving waters and eventually may affect surface or groundwater quality. During construction activities, excavated soil would be exposed, thereby increasing the potential for soil erosion and sedimentation to occur compared to existing conditions. In addition, during construction, vehicles and equipment are prone to tracking soil and/or spoil from work areas to paved roadways, which is another form of erosion that could affect water quality.
However, the use of BMPs during construction implemented as part of a SWPPP as required by the NPDES General Construction Permit and included as PPP WQ -1 would serve to ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant. Furthermore, an Erosion and Sediment Transport Control Plan prepared by a qualified SWPPP developer (QSD) is required to be included in the SWPPP for the Project, and typically includes the following types of erosion control methods that are designed to minimize potential pollutants entering stormwater during construction:
• Prompt revegetation of proposed landscaped areas;
• Perimeter gravel bags or silt fences to prevent offsite transport of sediment; • Storm drain inlet protection (filter fabric gravel bags and straw wattles), with gravel bag check dams within paved roadways;
• Regular sprinkling of exposed soils to control dust during construction and soil binders for forecasted wind storms; • Specifications for construction waste handling and disposal; • Contained equipment wash-out and vehicle maintenance areas; • Erosion control measures including soil binders, hydro mulch, geotextiles, and hydro seeding of disturbed areas ahead of forecasted storms;
• Construction of stabilized construction entry/exits to prevent trucks from tracking sediment on City roadways; • Construction timing to minimize soil exposure to storm events; and • Training of subcontractors on general site housekeeping.
□ □ [g] □
Bradshaw Collection Project Page 67 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Therefore, compliance with the Statewide General Construction Activity Stormwater Permit requirements, included as PPP WQ-1, which would be verified during the City’s construction permitting process, would ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant.
Operation
The proposed Project includes operation of single -family residential uses. Potential pollutants associated with the proposed uses include various chemicals from cleaners, pathogens from pet wastes, nutrients from fertilizer, pesticides and sediment from landscaping, trash and debris, and oil and grease from vehicles. If these pollutants discharge into surface waters, it could result in degradation of water quality.
In the existing condition, site drainage sheet flows across the property to the west towards Bradshaw Circle. A portion of the site’s drainage, identified as Area 1, flows southerly to Cactus Avenue where it is collected by a series of catch basins within Cactus Avenue, and is ultimately directed into an offsite storm drain. Onsite drainage flows within Area 2 flow offsite towards Bradshaw Circle and Cactus Avenue where the flows are collected by a series of existing catch basins along Cactus Avenue. (Hydrology 2021)
In the developed condition, onsite flows would be conveyed to one of two onsite bioretention basins (Lots A and B), and these basins would connect to a new 24-inch diameter storm drain in Bradshaw Circle which would connect to the existing RCFC Storm Drain Line F-4 in Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted. (Hydrology 2021) As described previously, the WQMP is required to be approved prior to the issuance of a building or grading permit. The Project’s WQMP would be reviewed and approved by the City to ensure it complies with the Santa Ana RWQCB MS4 Permit regulations. In addition, the City’s permitting process would ensure that all BMPs in the WQMP would be implemented with the Project. Overall, implementation of the WQMP pursuant to the existing regulations (included as PPP WQ-2), would ensure that operation of the proposed Project would not violate any water quality standards, waste discharge requirements, or otherwise degrade water quality; and impacts would be less than significant. b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the
basin?
Response:
Less Than Significant Impact. EMWD’s 2020 Urban Water Management Plan (UWMP) describes that EMWD’s local supplies include groundwater, desalinated groundwater, and recycled water. 1 Groundwater is pumped from the Hemet/San Jacinto and West San Jacinto areas of the San Jacinto Groundwater Basin. Groundwater in portions of the West San Jacinto Basin is high in salinity and requires desalination for potable use. EMWD owns and operates tw o desalination plants that convert brackish groundwater from the West San Jacinto Basin into potable water. EMWD also owns, operates, and maintains its own recycled water system that consists of four Regional Water Reclamation Facilities and several storage ponds spread throughout EMWD’s service area that are all connected through the recycled water system.
As detailed on Table WQ -1, the EMWD’s 2020 Urban Water Management Plan (UWMP) shows that the anticipated production of groundwater and desalinated water would remain the same between 2020 and 2045. In 2045, groundwater and desalinated groundwater would provide 12.8 percent of the District’s water supply.
1 As of February 2025, EMWD’s 2020 UWMP has not been adopted. □ □ ~ □
Bradshaw Collection Project Page 68 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table WQ-1: Total Retail Water Supply (AFY)
Source 2025 2030 2035 2040 2045 2045
Percentage
Purchased or Imported Water 66,447 72,147 70,247 74,747 78,847 42.14% Groundwater (not desalinated)
pumped from the Hemet/ San
Jacinto Basin
7,303 7,303 7,303 7,303 7,303 3.90%
Groundwater (not desalinated)
pumped from the West San Jacinto
Basin
11,450 11,450 11,450 11,450 11,450 6.12%
Desalinated Water- Groundwater 13,400 13,400 13,400 13,400 13,400 7.16% Recycled Water 43,330 49,020 54,500 59,800 64,100 34.26% Purified Water Replenishment (IPR) 4,000 4,000 12,000 12,000 12,000 6.41% Total Retail Supply 145,930 157,320 168,900 178,700 187,100 100% Source: 2020 UWMP
As detailed in Section 19, Utilities and Service Systems , the supply of water listed in Table WQ -1 would be sufficient during both normal years and multiple dry year conditions between 2020 and 2045 to meet all of the City’s estimated needs, including the proposed Project. Therefore, the Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. Thus, impacts related to groundwater supplies would be less than significant.
Based on low soil infiltration test results at the Project S ite, onsite bioretention basins are proposed as the preferred method for treating onsite flows. After completion of Project construction, the Project would convey stormwater drainage into landscaped areas and the two onsite water quality bioretention basins, which would route runoff to a new 24- inch diameter storm drain in Bradshaw Circle that connects to RCFC Storm Drain Line F -4 in Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted (Robert M. Beers, 2021). Therefore, impacts related to interference with groundwater recharge would be less than significant.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or off-site?
Response:
Less than Significant Impact.
Construction
Construction of the Project would require grading and excavation of soils, which would loosen sediment and could result in erosion or siltation. However, the Project site does not include any slopes, which reduces the erosion potential and the large majority of soil disturbance would be related to excavation and backfill for installation of building foundations and underground utilities.
The NPDES Construction General Permit requires preparation and implementation of a SWPPP by a Qualified SWPPP Developer for the proposed construction activities (included as PPP WQ -1). The SWPPP is required to address site- specific conditions related to potential sources of sedimentation and erosion and would list the required BMPs that are necessary to reduce or eliminate the potential of erosion or alteration of a drainage pattern during construction activities.
In addition, a Qualified SWPPP Practitioner (QSP) is required to ensure compliance with the SWPPP through regular monitoring and visual inspections during construction activities. The SWPPP would be amended and BMPs revised, as determined necessary through field inspections, in order to protect against substantial soil erosion, the loss of topsoil, or alteration of the drainage pattern. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) would prevent construction-related impacts related to potential alteration of a drainage pattern or erosion from development activities. With implementation of the existing construction regulations that would be verified by the City during the permitting approval process, impacts related to alteration of an existing
□ □ ~ □
Bradshaw Collection Project Page 69 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
drainage pattern during construction that could result in substantial erosion, siltation, and increases in stormwater runoff would be less than significant.
Operation
After completion of Project construction, impervious area would increase on the Project site. However, the impervious areas would not be subject to erosion and the pervious areas would be landscaped with groundcovers that would inhibit erosion.
As discussed previously, in the existing condition, site drainage sheet flows across the property to the west towards Bradshaw Circle. A portion of the site’s drainage, identified as Area 1, flows southerly to Cactus Avenue where it is collected by a serie s of catch basins within Cactus Avenue, and is ultimately placed into an offsite storm drain. Onsite drainage flows within Area 2 flow offsite towards Bradshaw Circle and Cactus Avenue, where the flows are collected by a series of existing bioretention basins along Cactus Avenue (Robert M. Beers, 2021).
In the developed condition, onsite flows would be conveyed to one of two onsite bioretention basins (Lots A and B), and these basins would connect to a new 24-inch diameter storm drain in Bradshaw Circle which would connect to the existing RCFC Storm Drain Line F-4 in Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted (Robert M. Beers, 2021).
Additionally, the MS4 permit requires new development projects to prepare a WQMP (included as PPP WQ -2) that is required to include BMPs to reduce the potential of erosion and/or sedimentation through site design and structural treatment control BMPs. A Preliminary WQMP has been completed and included as Appendix H. As part of the permitting approval process, the proposed drainage and water quality design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the site- specific design limits the potential for erosion and siltation. Overall, the proposed drainage system and adherence to the existing regulations would ensure that Project impacts related to alteration of a drainage pattern and erosion/siltation from operational activities would be less than significant. ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite?
Response:
Less Than Significant Impact.
The Project Site does not include, and is not adjacent to, a stream or river. Implementation of the Project would not alter the course of a stream or river.
Construction
Construction of the Project would require grading and excavation of soils. These activities could temporarily alter the existing drainage pattern of the site and change runoff flow rates. However, as described previously, implementation of the Project requires a SWPPP (included as PPP WQ -1) that would address site specific drainage issues related to construction of the Project and include BMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction activities. This includes regular monitoring and visual inspections during construction activities.
Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the City through the construction permitting process would prevent construction-related impacts related to potential alteration of a drainage pattern or flooding on site or offsite from development activities. Therefore, construction impacts would be less than significant.
Operation
As described previously, the proposed Project would result in an increase of impervious surfaces that would result in an increase of stormflows. The Project would maintain the existing drainage pattern and convey runoff to bioretention basins which connect to a new 24- inch diameter storm drain in Bradshaw Circle, which then connects to the existing RCFC Storm Drain Line F -4 in Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted. (Robert M. Beers, 2021) Moreover, as part of the permitting approval process, the proposed preliminary drainage design and engineering plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Overall, the proposed drainage system and adherence to the existing MS4 permit regulations would ensure that Project impacts related to alteration of a drainage pattern or flooding from operational activities would be less than significant.
□ □ ~ □
Bradshaw Collection Project Page 70 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Response:
Less Than Significant Impact.
As described previously, the Project Site does not include, and is not adjacent to, a stream or river. Implementation of the Project would not alter the course of a stream or river.
Construction
As described in the previous response, construction of the proposed Project would require grading and excavation activities that could temporarily alter the existing drainage pattern of the site and could result in increased runoff and polluted runoff if drainage is not properly controlled. However, implementation of the Project requires a SWPPP (included as PPP WQ-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ -1) as verified by the City through the construction permitting process would prevent construction- related impacts related to increases in run -off and pollution from development activities. Therefore, impacts would be less than significant.
Operation
As described previously, the proposed Project would result in an increase of impervious surfaces that would generate increased runoff. However, the Project would manage the increased flow with bioretention basins that route runoff to a new 24-inch diameter storm drain in Bradshaw Circle which then connects to the existing RCFC Storm Drain Line F-4 on Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted (Robert M. Beers, 2021).
Moreover, as part of the permitting approval process, the proposed preliminary drainage design and grading plans would be reviewed by the City’s Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. The proposed Project would increase the impervious surface area on the Project site compared to the existing condition, and the proposed Project would convey and treat all potential stormwater runoff from the Project site. Therefore, the Project would not create or contribute additional runoff water to the downstream storm drain system that would exceed the storm drain system’s capacity, and impacts would be less than significant. iv) Impede or redirect flood flows?
Response:
Less Than Significant Impact. According to the Federal Emergency Management Agency (FEMA) Map 06065C0770G, the Project site is designated as zone X, meaning it is in an area of minimal flood hazard (FEMA, 2020). As detailed in the previous responses, implementation of the Project would result in an increase of impermeable surfaces on the site.
The Project would maintain the existing drainage pattern, and drainage would be conveyed to onsite bioretention basins that would route runoff to a new 24 -inch diameter storm drain in Bradshaw Circle which would connect to the existing RCFC Storm Drain Line F-4 in Cactus Avenue. The Project would result in a net incremental increase of 0.49 cubic feet per second of flow to the storm drain in Cactus Avenue; however, the storm drain would be able to accommodate this increase without impact nor would offsite properties be impacted (Robert M. Beers, 2021). Therefore, the Project would not result in impeding or redirecting flood flows by the addition of the impervious surfaces. As detailed previously, the City’s permitting process would ensure that the drainage system specifications adhere to the existing MS4 permit regulations, and compliance with existing regulations would ensure that impacts would be less than significant.
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 71 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Response:
No Impact. According to the Federal Emergency Management Agency (FEMA) Map 06065C0770G, the Project site not within a flood zone (FEMA, 2020). Thus, the Project Site is not located within a flood hazard area that could be inundated with flood flows and result in release of pollutants. Impacts related to flood hazards and pollutants would not occur from the Project.
Tsunamis are generated ocean wave trains generally caused by tectonic displacement of the sea floor associated with shallow earthquakes, sea floor landslides, rock falls, and exploding volcanic islands. The proposed Project is approximately 43 miles from the ocean shoreline. Based on the distance of the Project S ite to the Pacific Ocean, the Project Site is not at risk of inundation from tsunami. Therefore, the proposed Project would not risk release of pollutants from inundation from a tsunami. No impact would occur.
Seiching is a phenomenon that occurs when seismic ground shaking induces standing waves (seiches) inside water retention facilities (e.g., reservoirs and lakes). Such waves can cause retention structures to fail and flood downstream properties. The Project site is not located adjacent to any water retention facilities. For this reason, the Project site is not at risk of inundation from seiche waves. Therefore, the proposed Project would not risk release of pollutants from inundation from seiche. No impact would occur.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Response:
Less Than Significant Impact. As described previously, use of BMPs during construction implemented as part of a SWPPP as required by the NPDES Construction General Permit and PPP WQ -1 would serve to ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant. Thus, construction of the Project would not conflict or obstruct implementation of a water quality control plan.
Also, as described previously, new development projects are required to implement a WQMP (per PPP WQ-2) that would comply with the Santa Ana RWQCB MS4 Permit regulations. The WQMP and applicable BMPs are verified as part of the City’s permitting approval process, and construction plans would be required to demonstrate compliance with these regulations. Therefore, operation of the proposed Project would not conflict of obstruct with a water quality control plan.
The proposed Project is within the San Jacinto groundwater basin, which is classified as a high priority basin within the California Department of Water Resources SGMA Basin Prioritization Dashboard (SGMA, 2025). In addition, as detailed previously, the EMWD manages basin water supply and the anticipated production of groundwater would remain steady from 2025 through 2040 (as shown in Table WQ-1). As described previously and further detailed in Section 19, Utilities and Service Systems, the City’s supply of water listed in Table WQ-1 would be sufficient during both normal years and multiple dry year conditions between 2020 and 2045 to meet all of the City’s estimated needs, including the proposed Project. Therefore, the Project would be consistent with the groundwater management plan and would not conflict with or obstruct its implementation. Thus, impacts related to water quality control plan or sustainable groundwater management plan would be less than significant.
Existing Plans, Programs, or Policies
PPP WQ-1: Stormwater Pollution Prevention Plan. Prior to grading permit issuance, the Project developer shall have a Stormwater Pollution Prevention Plan (SWPPP) prepared by a Qualified SWPPP Developer (QSD) in accordance with the City’s Municipal Code Chapter 8.10 and the Santa Ana Regional Water Quality Control Board National Pollution Discharge Elimination System (NPDES) Storm Water Permit Order No. R4-2012-0175 (MS4 Permit). The SWPPP shall incorporate all necessary Best Management Practices (BMPs) and other NPDES regulations to limit the potential of erosion and polluted runoff during construction activities. Project contractors shall be required to ensure compliance with the SWPPP and permit periodic inspection of the construction site by the City of Moreno Valley staff or its designee to confirm compliance.
PPP WQ-2: Water Quality Management Plan, Prior to grading permit issuance, the Project applicant shall have a Water Quality Management Plan (WQMP) approved by the City for implementation. The Project shall comply with the City’s Municipal Chapter 8.10 and the Municipal Separate Storm Sewer System (MS4) permit requirements in effect for the Regional Water Quality Control Board (RWQCB) at the time of grading permit to control discharges of sediments and other pollutants during operations of the Project.
□ □ □ ~
□ □ ~ □
Bradshaw Collection Project Page 72 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.7 – Water Quality - Figure 5-4 – Flood Hazards
• Chapter 7 – Conservation Element – Section 7.5 – Water Resources - Figure 6-1 Water Purveyor Service Area Map
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.5 – Hazards and Hazardous Materials
- Figure 4.5-2 – Floodplains and High Fire Hazard Areas • Section 5.7 – Hydrology and Water Quality
- Figure 4.7-1 – Storm Water Flows and Major Drainage Facilities - Figure 4.7-2 – Groundwater Basins
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.10.080 – Liquid and Solid Waste
4. Moreno Valley Municipal Code Chapter 8.12 – Flood Damage Prevention
5. Moreno Valley Municipal Code Chapter 8.21 – Grading Regulations
6. Eastern Municipal Water District (EMWD) Groundwater Reliability Plus, http://gwrplus.org/
7. Eastern Municipal Water District (EMWD) 2015 Urban Water Management Plan
8. Preliminary Hydrology Report. April 15, 2020; Revised September 24, 2021. Prepared by Robert M. Beers (Appendix G).
9. Project Specific Water Quality Management Plan. August 2024. Prepared by Adkan Engineers (Appendix H).
10. FEMA Flood Map Service Center. 2021. Available at: https://msc.fema.gov/portal/search (Accessed May 26, 2021).
11. SGMA Basin Prioritization Dashboard. 2025. Available at: https://gis.water.ca.gov/app/bp-dashboard/final/ (Accessed February 18, 2025).
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established community?
Response:
No Impact. The Project Site is currently vacant and is surrounded by a roadway to the south followed by single- family residences; single-family residences to the north; vacant land to the east; and single- family residences and commercial uses to the west. The proposed Project would redevelop the site to provide 37 single- family residential units, which are consistent with the existing single- family residences to the north, west, and south of the site. Therefore, the change of the Project site from a vacant site to single- family residential would not physically divide an established community. In addition, the Project would not change roadways or install any infrastructure that would result in a physical division. Thus, the proposed Project would not result in impacts related to physical division of an established community. b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Response:
Less Than Significant Impact. As described previously, the Project S ite is currently vacant and offsite improvement areas are developed with Bradshaw Circle. The Project would redevelop the Project site to provide 37 new single-family residences, which would be similar to the single-family residential uses that are located adjacent to the west of the site, to the south of the site beyond Cactus Avenue, and to the north of the site.
□ □ □ lXJ
□ □ ~ □
Bradshaw Collection Project Page 73 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
General Plan
The Project site currently has a General Plan land use designation of Residential: Max. 5 du/ac (R5), which does not have the purpose of avoiding or mitigating an environmental effect. The proposed Project includes a General Plan Amendment to change the land use designation of the site to Low Residential: Max. 10 du/ac (R10), which would allow the proposed single-family residences at a density of 10 units per net acre. The General Plan Land Use Element states that the Residential: Max. 10 du/ac (R10) designation allows for development of residential uses to a maximum density of 10 dwelling units per acre. As the Project would develop residences at a density of 7.9 units per gross acre, it would be consistent with the proposed land use designation, and the proposed change in land use would be less than significant.
Further, the Project would be consistent with City General Plan goals and policies, as discussed in Table LU-1.
Table LU-1: Consistency with General Plan Goals & Policies Goal or Policy Project Consistency
Goal 2.1: A pattern of land uses, which organizes future growth, minimizes conflicts between land uses, and
which promotes the rational utilization of presently
underdeveloped and undeveloped parcels.
Consistent. The proposed Project would redevelop the
vacant site with 37 new single-family residences on an
existing vacant site in the City, which would promote the rational utilization of a presently undeveloped parcel.
Therefore, the Project would be consistent with Goal 2.1.
Goal 2.4: A supply of housing in sufficient numbers
suitable to meet the diverse needs of future residents
and to support healthy economic development without
creating an oversupply of any particular type of housing.
Consistent. The proposed Project would redevelop the
vacant site with 37 new single-family residences, which would assist in meeting the diverse needs of future
residents. In addition, the Project would provide 3
different plans and architectural styles for the single-family residences, which would support healthy economic
development and an oversupply of a particular type of
housing would not occur. Therefore, the Project would be consistent with Goal 2.4.
Policy 2.2.8: The primary purpose of areas
designated Residential 10 is to provide for a variety of residential products and to encourage innovation in
housing types. Developments within Residential 10
areas are typically expected to provide amenities not
generally found in suburban subdivisions, such as
common open space and recreational areas. The
maximum allowable density shall be 10.0 dwelling
units per acre.
Consistent. The proposed Project would
redevelop the Project site with single-family residences at a density of 7.9 dwelling unit per acre, which would be consistent with the maximum allowable density of 10
dwelling units per acre. Therefore, the Project would be consistent with Policy 2.2.8.
Policy 2.2.12: Planned Unit Developments (PUD) shall
be encouraged for residential construction in order to
provide housing that is varied by type, design, form of ownership, and size. PUD’s shall also provide
opportunities to cluster units to protect significant
environmental features and/or provide unique
recreational facilities.
Consistent. As described in the Project Description, the proposed Project would provide 3 different plans and 3
different architectural styles for the single-family
residences to provide housing that is varied by type,
design, and size. In addition, the Project would provide sidewalks and landscaping along the streets and within
common
areas. Therefore, the Project would be
consistent with Policy 2.2.12.
Policy 2.2.14: Encourage a diversity of housing types,
including conventional, factory built, mobile home, and multiple family dwelling units.
Consistent. As described in the previous response, the
proposed Project would provide 3 different plans and 3
different architectural styles for
the single-family
residences to provide a diversity of housing types.
Therefore, the Project would be consistent with Policy
2.2.14. Policy 2.3.1: Within individual residential projects, a variety of floor plans and elevations should be offered.
Consistent. As described in the previous response, the
proposed Project would provide 3 different plans and 3
different architectural styles for the single-family
residences. Therefore, the Project would be consistent
with Policy 2.3.1.
Policy 2.3.2: Encourage building placement variations,
roofline variations, architectural projections, and other embellishments to enhance the visual interest along
residential streets.
Consistent. The proposed residential development
would be designed with contemporary architectural
elements, multi -level rooflines, and a complementary
color scheme. Architectural elements in the exterior
Bradshaw Collection Project Page 74 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
design would include stucco finish, stone veneer accents, metal awnings and deck railings, and vinyl window and
door trim. The Project would be designed with Spanish,
French, and Cottage style architectural elements. When complete, the development would be representative of a
modern residential community. In addition, landscaping improvements associated with the proposed Project are
anticipated to improve the existing visual character of the Project site and would serve to provide increased visual interest along residential streets. Therefore, the Project would be consistent with Policy 2.3.2.
Policy 2.3.3: Discourage the development of single -
family residences with a bulk (building mass) that is out of scale with the size of the parcels on which they are located.
Consistent. The proposed Project would construct the
proposed single-family residences with 3 different plans designed to conform to the size of the parcel on which
they are located. Therefore, the Project would be
consistent with Policy 2.3.3.
Policy 2.3.4: Design large -scale small lot single family and multiple family residential projects to group
dwellings around individual open space and/or
recreational features.
Consistent. The proposed Project would construct the
proposed single-family residences with private open
space. 10,983 SF The single- family residences would be grouped around a 10,983 SF community recreation area.
Therefore, the Project would be consistent with Policy
2.3.4. Zoning
The Project S ite is currently zoned Residential 5 District (R5). The primary purpose of the R5 district is to provide for residential development on common sized suburban lots. This district is intended as an area for the development of single- family residential and mobile home subdivisions at a maximum allowable density of 5 DUs per net acre, as indicated in Section 9.03.020 of the Municipal Code. As described previously, the Project would develop single-family residences at a density of 7.9 units per gross acre and would require a zone change to Residential Single-Family 10 (RS10) District. In addition, the Project is requesting approval of a Conditional Use Permit (CUP) for a Planned Unit Development (PUD), which allows for a development to establish unique criteria for such things as setbacks, lot width and depth, building separation, lot size, etc. This arrangement is made in exchange for a greater level of detail, including more open space and diverse housing options, surpassing the typical requirements of standard residential development. Thus, the proposed Project would not conflict with any applicable zoning regulations adopted for the purpose of avoiding or mitigating an environmental effect.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.1 – Land Use - Figure 1-1 – Neighboring Lands Uses
- Figure 1-2 – Land Use Map
• Chapter 8 – 2014 – 2021 Housing Element
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.12 – Population and Housing
- Attachments #1 - #10 – Housing Sites Inventory
- Exhibits A1 – A11, C, D, and E – Maps of Housing Sites
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code Bradshaw Collection Project Page 75 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Response:
No Impact. The Project Site is located in Mineral Resource Zone 3 (MRZ-3), according to the Mineral Land Classification Map provided by the California Department of Conservation. The MRZ -3 zone within the Significant Mineral Aggregate Resource Area (SMARA) Study Area is defined as areas containing mineral deposits of which the significance cannot be evaluated from available data. The City’s General Plan EIR states that no locally, regionally, or statewide significant mineral resources are located within the City . Therefore, development of the site would not result in the loss of availability of a known mineral resource that would be of value to the region, and impacts would not occur. b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?
Response:
No Impact. As described in the previous response, the City’s General Plan EIR states that no locally, regionally, or statewide significant mineral resources are located within the City. Therefore, implementation of the Project would not result in the loss of locally important mineral resources, and impacts would not occur.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.9 – Mineral Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.14 – Mineral Resources
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.02.120 – Surface Mining Permits
4. Moreno Valley Municipal Code Section 8.21.020 A 7 – Permits Required
5. The Surface Mining and Reclamation Act of 1975 (SMARA, Public Resources Code, Sections 2710-2796), https://www.conservation.ca.gov/dmr/lawsandregulations
6. California Department of Conservation. 2020. Mineral Land Classification. Accessed:
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc (Accessed May 26, 2021).
□ □ □ ~
□ □ □ ~
Bradshaw Collection Project Page 76 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIII. NOISE – Would the project result in:
City of Moreno Valley Municipal Code
Sound level limits: Chapter 11.80.030 of the City’s Municipal Code establishes maximum noise levels permitted within the city, which are listed in Table N-1:
Table N-1: City of Moreno Valley Maximum Continuous Sound Levels Duration per Day
(Continuous Hours)
Sound Level (dBA)
8 90
6 92
4 95
3 97
2 100
1.5 102
1 105
.5 110
.25 115
Source: City of Moreno Valley Municipal Code
Sensitive Receptor Noise Levels: Chapter 11.80.030 of the City’s Municipal Code establishes the permissible noise level that may be received at nearby sensitive uses (e.g., residential). For noise-sensitive residential properties 200 feet from the source, the exterior noise level shall not exceed 60 dBA during daytime hours (8:00 a.m. to 10:00 p.m.) and shall not exceed 55 dBA during the nighttime hours (10:01 p.m. to 7:59 a.m.) (Municipal Code, Chapter 11.80).
Construction Noise: Section 8.14.040.E of the City’s Municipal Code also provides construction noise standards, which state that any construction within the city shall only be completed between the hour of seven a.m. to eight p.m. Monday through Friday, excluding holidays, unless written approval is obtained from the city building official or city engineer.
Sensitive Receptors
The nearest existing sensitive receptors to the Project Site are the single-family homes located directly north of the Project site. There are also single-family homes located approximately 50 feet to the west and 90 feet south of the Project Site.
The nearest school to the Project Site is Ridge Crest Elementary School, which is located approximately 0.3 miles southeast of the Project Site.
Existing Ambient Noise Levels
To identify the existing ambient noise levels in the Project area, noise level measurements were taken on and adjacent to the Project site on March 26, 2024. As shown on Table N-2, the average noise levels in the Project area range from
58.8 dBA to 88.8 dBA. Table N -2 also shows that both the daytime and nighttime noise levels at the nearby sensitive receptors currently exceeds the City’s residential noise standards of 60 dBA Leq during the daytime and 55 dBA Leq during the nighttime.
Table N-2: Existing Ambient Noise Level Measurements
Site
No. Site Description
1-hr Average
(dBA Leq/Time)
Average
(dBA CNEL)
Minimum Maximum
L-1
Located on the western boundary of the
Project Site, approximately 276 feet
north of the centerline of Cactus Avenue
42.1 2:00 a.m.
59.1 4:00 p.m. 57.1
L-2
Located near the northeast corner of the
Project Site, approximately 645 feet
north of the centerline of Cactus Avenue
38.3 1:00 a.m.
57.5 12:00 p.m. 53.8
Source: Noise Impact Analysis (Appendix I)
Bradshaw Collection Project Page 77 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Response:
Less Than Significant Impact.
Construction
The construction activities for the proposed Project are anticipated to include site preparation and grading of the Project Site, construction of the 37 single- family residences, paving of the onsite driveways and parking areas, application of architectural coatings, and repaving of Bradshaw Circle. Noise impacts from construction activities associated with the proposed Project would be a function of the noise generated by construction equipment, equipment location, sensitivity of nearby land uses, and the timing and duration of the construction activities. The nearest sensitive receptors to the Project Site are the single-family residences located along the Project Site’s northern property line.
Table N-3 shows the noise levels from construction at the closest sensitive receptors. As shown, In addition, the Project would comply with the allowable construction times pursuant to the City’s Municipal Code, the construction‐related noise levels would not exceed any standards. Therefore, construction noise impacts would be less than significant.
Table N-3: Construction Noise Levels at the Nearest Sensitive Receptor Phase Equipment Quantity Equipment Noise
Level at Sensitive
Receptor1 (dBA Leq)
Combined Noise
Level (dBA Leq)
Site Preparation Tractors/Loaders/ Backhoes 2 72.3 75.3 Grading Graders 1 73.3 75.9
Tractors/Loaders/ Backhoes 1 72.3
Building Construction Tractors/Loaders/ Backhoes 2 72.3 75.3 Paving Tractors/Loaders/ Backhoes 1 72.3 73.8
Rollers 1 68.3
Architectural Coating Air Compressors 1 66.0 66.0
Worst Case Construction Phase Noise Level (dBA Leq) 75.9 FTA Daytime General Assessment Construction Noise Criteria (dBA Leq) 80.0 Noise levels exceed threshold? No
1 Noise levels measured from center of site
Source: Noise Impact Analysis (Appendix I)
Operation
Development of the proposed Project would generate approximately 26 trips during the a.m. peak hour and 35 trips during the p.m. peak hour, for a total of 349 daily trips.
The noise generated from these vehicular trips has been identified through a comparison of noise generated by traffic volumes with and without the Project, provided in Table N -4. In addition, Table N-5 shows roadway noise level increases due to the Project in 2040 conditions.
Table N-4: Roadway Noise Impacts – Existing Conditions
Roadway Segment
Roadway Noise Levels at Nearest Receptors to Centerline (dBA CNEL)
Significant
Impact?1
Existing without
Project
Conditions
Existing with
Project
Conditions
Increase as a
Result of the
Project
Cactus Avenue Moreno Beach Drive to
Redlands Boulevard 76.5 76.5 0.0 No
1 A significant impact would occur if Without Project noise levels are 65.0 dBA CNEL or lower, and the Project causes noise lev els to increase above 65.0 dBA CNEL or without Project noise levels are above 65.0 dBA CNEL and the Project results in an increase of 3.0 dBA or more above Without Project conditions.
Source: Noise Impact Analysis (Appendix I)
□ □ ~ □
Bradshaw Collection Project Page 78 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Table N-5: Roadway Noise Impacts – 2040 Conditions
Roadway Segment
Roadway Noise Levels at Nearest Receptors to Centerline (dBA CNEL)
Significant
Impact?1
Existing without
Project
Conditions
Existing with
Project
Conditions
Increase as a
Result of the
Project
Cactus Avenue Moreno Beach Drive to
Redlands Boulevard 78.1 78.1 0.0 No
1 A significant impact would occur if Without Project noise levels are 65.0 dBA CNEL or lower, and the Project causes noise lev els to increase above 65.0 dBA CNEL or without Project noise levels are above 65.0 dBA CNEL and the Project results in an increase of 3.0 dBA or more above Without Project conditions.
Source: Noise Impact Analysis (Appendix I)
Objective 6.5 of the City’s General Plan Noise Element requires the City to minimize noise impacts from significant noise generators including roadway noise impacts. Based on the City’s General Plan, noise levels up to 65.0 dBA CNEL are considered normally acceptable for single-family residential uses. A significant impact would occur if the without Project noise levels are 65.0 dBA CNEL or lower and the Project causes noise levels to increase above 65.0 dBA CNEL or if the without Project noise levels are above 65.0 dBA CNEL and the Project results in an increase of 3.0 dBA or more. As shown in Tables N-4 and N-5 above, the Project traffic would result in an increase of 0.0 dBA, which is below the noise increase thresholds. Therefore, impacts related to operational noise would be less than significant.
Onsite Operational Noise Levels
The main sources of potential onsite noise would include motor vehicle activity and HVAC equipment. These types of onsite stationary noises would not typically be categorized as loud, unnecessary, or unusual noise. In order to ensure that onsite noise levels do not exceed the City of Moreno Valley noise standards, a stationary noise analysis was conducted. The City of Moreno Valley Municipal Code establishes maximum noise level thresholds of 60.0 dBA Lmax during daytime hours (8:00 a.m. to 10:00 p.m.) and 55.0 dBA Lmax during nighttime hours (10:01 p.m. to 7:59 a.m.), as measured at a distance of 200 feet or more from the real property line of the source of the sound. Therefore, for a conservative analysis, this study assesses n oise impacts at a distance of 200 feet from the noise source location. The analysis considers continuous operation of HVAC units during both daytime hours (8:00 a.m. to 10:00 p.m.) and nighttime hours (10:01 p.m. to 7:59 a.m.). The result is a worst -case assessment of impacts, as HVAC units would likely operate only intermittently throughout the day. The analysis also takes into account the noise attenuation effects of the six -to- eight-foot-tall property line wall along the northern, southern, eastern, and western boundary of the proposed project site.
Table N-6 shows the expected noise levels of HVAC operation at the nearest receptors along the northern property line.
As shown in Table N -6, onsite HVAC units are expected create a noise level of approximately 44.8 dBA Lmax at a distance of 200 feet from the noise source, which does not exceed the City’s daytime and nighttime noise level thresholds of 60.0 dBA Lmax and 55.0 dBA Lmax, respectively. Therefore, operational noise impacts would be less than significant.
Table N-6: Onsite Operational Noise Levels
Source
Equipment Noise Level at 200 feet from Noise Source
(dBA Lmax)
Daytime (8 am to 10 pm) Nighttime (10 pm to 8 am)
HVAC Equipment 44.8 44.8
Municipal Code Noise
Thresholds
60.0 55.0
Exceeds Threshold? No No
Source: Noise Impact Analysis (Appendix I)
Bradshaw Collection Project Page 79 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Generation of excessive groundborne vibration or
groundborne noise levels?
Response:
Less Than Significant Impact.
Construction
Construction activities associated with the proposed Project would require the operation of off-road equipment and trucks that are known sources of vibration. Construction activity can result in varying degrees of ground vibration, depending on the equipment used on the site. Operation of construction equipment causes ground vibrations that spread through the ground and diminish in strength with distance. Vibrations at buildings could produce results that range from no perceptible effects at the low levels to damage at the highest levels. To determine the vibratory impacts during construction, reference construction equipment vibration levels were utilized and then extrapolated to the façade of the nearest adjacent structures. The nearest adjacent structures to the Project Site are the residences located along the northern boundary of the Project Site. The nearest structures are located approximately 34 feet from the nearest expected area of bulldozer and truck activity and approximately 95 feet from the nearest expected area of vibratory roller activity. All structures surrounding the project site are new structures. No historical or fragile buildings are known to be located within the vicinity of the site.
Construction of the Project is not expected to require the use of substantial vibration- inducing equipment or activities, such as pile driving or blasting. The main sources of vibration during construction would be from operation of equipment such as a bulldozer during site preparation and loading trucks during grading and excavation. The construction vibration assessment utilizes the referenced vibration levels and methodology set within the FTA’s Transit Noise and Vibration Impact Assessment Manual.
Table N-7: Typical Vibration Source Levels for Construction Equipment Equipment Peak Particle Velocity (PPV)
(inches/second) at 25 feet
Approximate Vibration
Level at 25 feet
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Caison Drill 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Noise Impact Analysis (Appendix I)
Table N-8 shows the Project’s construction vibration levels at the nearest structures to the Project construction area.
Construction impacts are assessed at 34 feet from the nearest expected location of a bulldozer and truck activity and 95 feet from the nearest expected location of vibratory roller activity based on where this equipment would be utilized onsite.
As shown in Table N-8, Project construction is not anticipated to cause any potential damage to the nearest residences.
Therefore, impacts related to construction vibration would be less than significant.
Table N-8: Construction Vibration Impacts
Construction
Activity
Distance to Nearest
Structure (ft)
Duration Calculated Vibration
Level (PPV)
Damage Potential
Large Bulldozer 34 Continuous/Frequent 0.063 None
Loaded Trucks 34 Continuous/Frequent 0.054 None
Vibratory Rollers 95 Continuous/Frequent 0.048 None
Source: Noise Impact Analysis (Appendix I)
Operation
Operation of the proposed single -family uses would include heavy trucks for residents moving in and out of the residences, large deliveries, and garbage trucks for solid waste disposal. Truck vibration levels are dependent on vehicle characteristics, load, speed, and pavement conditions. However, typical vibration levels for the heavy truck activity at normal traffic speeds would be approximately 0.006 in/sec PPV, based on the FTA Transit Noise Impact and Vibration Assessment. Truck movements on site would be travelling at very low speed, so it is expected that truck vibration at nearby sensitive receivers would be less than the vibration threshold of 0.08 in/sec PPV for fragile historic buildings and
0.04 in/sec PPV for human annoyance, and therefore, would be less than significant.
□ □ ~ □
Bradshaw Collection Project Page 80 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Response:
Less Than Significant Impact. The proposed Project would not expose people residing or working in the Project area to excessive noise levels from aircraft. The nearest airport is March Air Reserve Base that is located approximately 5.2 miles west of the Project site. The Project site is located outside of the 60 dBA CNEL noise contours of the March Air Reserve Base (March ARB). Thus, impacts would be less than significant.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.4 – Noise
- Figure 5-2 – Buildout Noise Contours
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.4 – Noise
- Figure 4.4-1 – March Air Reserve Base Noise Impact Area - Figure 4.4-2 – Buildout Noise Contours – Alternative 1 - Figure 4.4-3 -- Buildout Noise Contours – Alternative 2 - Figure 4.4-4 -- Buildout Noise Contours – Alternative 3 • Appendix D – Noise Analysis, Wieland Associates, Inc., June 2003.
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.10.140 Noise and Sound
4. Moreno Valley Municipal Code Chapter 11.80 Noise Regulations
5. March Air Reserve Base (MARB)/March Inland Port (MIP) Airport Land Use Compatibility Plan (ALUCP) on November 13, 2014, (http://www.rcaluc.org/Portals/13/17%20- %20Vol.%201%20March%20Air%20Reserve%20Base%20Final.pdf?ver=2016-08-15-145812-700)
6. Noise Impact Analysis, Tentative Tract Map No. 37858, City of Moreno Valley. December 31, 2020. Prepared by Vista Environmental (Appendix I).
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure)?
Response:
Less Than Significant Impact. The Project would construct 37 single- family residences on the Project site. According to data from the California Department of Finance (CDF) published in January 2024, the City of Moreno Valley has a residential population of207,146 persons and 58,713 total housing units. Of these, 47,088 (approximately 80 percent) are single-family detached units. In addition, it is estimated that the City has an average of 3.53 persons per household.
Based on this information, the proposed Project would result in a net increase of approximately 130 new residents.
Therefore, the Project would represent a population increase of approximately 0.07 percent and a 0.06 percent increase in residential units within the City. This limited level of growth on a site that has been previously developed would not constitute substantial growth.
The proposed Project is located in an urbanized residential area of the City and is surrounded by residential and commercial uses and is already served by the existing roadways and infrastructure systems. No infrastructure would be extended or constructed to serve areas beyond the Project site, which could reduce further population growth, and indirect impacts related to growth would not occur from implementation of the proposed Project. Therefore, potential impacts related to inducement of unplanned population growth, either directly or indirectly, would be less than significant. □ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 81 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing
elsewhere?
Response:
No Impact. As described above, the Project Site is vacant and undeveloped land and does not contain any housing or people on the Project site. The proposed Project would construct 37 new single-family residences and would not displace any existing housing or people and would not necessitate the construction of housing elsewhere. Thus, impacts would not occur.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.1 – Land Use - Figure 1-1 – Neighboring Lands Uses
- Figure 1-2 – Land Use Map
• Chapter 8 – 2014 – 2021 Housing Element
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.12 – Population and Housing
- Attachments #1 - #10 – Housing Sites Inventory
- Exhibits A1 – A11, C, D, and E – Maps of Housing Sites
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. California Department of Finance. January 2024. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2021-2024 with 2020 Census Benchmark. Accessed:
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities- counties-and-the-state-2020-2024/ (Accessed July 29, 2024).
XV. PUBLIC SERVICES – Would the project:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i) Fire protection?
Response:
Less Than Significant Impact. The City of Moreno Valley Fire Department provides fire protection to the Project area.
The City’s Fire Department is the primary response agency to fires, emergency medical service, hazardous materials incidents, traffic accidents, terrorist acts, catastrophic weather events, and technical rescues. Additionally, the City’s Office of Emergency Management is located within the Fire Department allowing for a well-coordinated response to both natural and man-made disasters. The Moreno Valley Fire Department (MVFD) is part of the CAL FIRE/Riverside County Fire Department’s regional, integrated, cooperative fire protection organization, which provides access to other regional fire and emergency equipment and/or services, as needed.
There are two existing fire stations within two miles of the Project Site. Fire Station 58 is located 2.4 miles from the Project site at 28040 Eucalyptus Avenue. This fire station is a three-bay facility that can house two engine companies, a truck company, and additional resources as needed. This fire station currently houses one paramedic engine company and a type 3 fire engine. Fire Station 99 is 2.8 miles from the Project site at 13400 Morrison Street. This fire station is a two-bay facility that houses one paramedic engine company (MVFD, 2020).
The proposed Project could potentially increase the demand for MVFD services due to the construction of the new residential units. As discussed in previously, the Project would generate approximately 130 new residents.
The Project would develop 37 single-family residences in an area already served by the City’s Fire Department and within close proximity to two existing fire stations. The Project would be adequately served by the two fire stations that currently serve the Project area. Additionally, the Project would be required to adhere to the California Fire Code (included in the City’s Municipal Code Chapters 8.36) and would be reviewed by the Fire Department during the Project permitting process to ensure that the Project plans meet the fire protection requirements. Therefore, impacts would be less than significant.
Additionally, the Developer would be required to pay development fees (including permit and inspection fees) that would be applied to the City’s public services including fire protection services. □ □ □ [g]
□ □ [L] □
Bradshaw Collection Project Page 82 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
ii) Police protection?
Response:
Less Than Significant Impact. The City of Moreno Valley receives policing services through a contract for services with the Riverside County Sheriff’s Office. The City’s police station is located at 22850 Calle San Juan De Los Lagos, which is approximately 5.7 miles from the Project site. Because the Project site is currently vacant and undeveloped, implementation of the Project would result in an onsite population that would create the need for police services. Calls for police service during Project construction may include: theft of building materials and construction equipment, malicious mischief, graffiti, and vandalism. Operation of the Project could generate a typical range of police service calls, such as burglaries, thefts, and disturbances. To reduce the potential for these types of crimes, security concerns are addressed in the Project design by providing low- intensity security lighting for the purposes of wayfinding, safety, and building structure security.
Although an incremental increase could result from implementation of the Project, the need for law enforcement services from the proposed Project would be limited and within an area that is currently served. Thus, the need for policing services generated by the Project would not require the construction or expansion of police department facilities. Therefore, impacts would be less than significant. Additionally, the Developer would be required to pay development fees (including permit and inspection fees) that would be applied to the City’s public services including police protection services. iii) Schools?
Response:
Less Than Significant Impact. The Project Site is located within the Moreno Valley Unified School District, which operates and maintains 43 schools, including 23 elementary schools (K‐5), 6 middle schools (7‐8), 5 high schools (9‐12), and 9 specialized schools. The site is currently located within the attendance area boundaries of Ridgecrest Elementary School, Mountain View Middle School, and Valley View High School.
The Project would develop 37 single-family residences. The Moreno Valley Unified School District’s April 2020 Developer Fee Justification Report indicates that there are over 53,581 residential dwelling units existing within the District. It is anticipated that a total of 13,156 additional units will be constructed by 2040. Based on the District’s Student Generation Rate of 0.6041, this will generate over 7,947 additional K-12 students during that period (MVUSD 2020). With the Student Generation Rate of 0.6041 per residential unit, the Project will generate approximately 23 additional K-12 students upon implementation.
Pursuant to Government Code Section 65995 et seq., the need for additional school facilities is addressed through compliance with school impact fee assessment. SB 50 (Chapter 407 of Statutes of 1998) sets forth a State school facilities construction program that includes restrictions on a local jurisdiction’s ability to condition a project on mitigation of a project’s impacts on school facilities in excess of fees set forth in the Government Code. These fees are collected by school districts at the time of issuance of building permits for development projects. Pursuant to Government Code Section 65995 applicants shall pay developer fees (included as PPP PS-1) to the appropriate school districts at the time building permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts. As a result, impacts related to school facilities would be less than significant with the Government Code required fee payments.
iv) Parks?
Response:
Less Than Significant Impact. Based on Map 3.1, Existing Parks and Community Facilities, in the City of Moreno Valley Parks, Recreation and Open Space Comprehensive Plan, the City operates and maintains six parks within the Project’s vicinity: Rock Ridge Park, approximately 2.9 miles to the northwest; Morrison Park, approximately 2.9 miles to the northwest; Ridgecrest Park, approximately 1.6 miles to the southeast; Weston Park, approximately 3.6 miles to the northwest; the Moreno Valley Community Park, approximately 6.4 miles to the west; and Celebration Park, approximately
1.2 miles to the southwest.
□ □ ~ □
f l I l l6l □
□ □ l6l □
Bradshaw Collection Project Page 83 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
The Project includes the construction of 37 single-family residences, including 10,983 SF at the recreation – open space lot, which would provide recreational facilities for the new residents. In addition, Section 3.38.080 and Chapter 3.40 of the City’s Municipal Code include requirements for mitigation fees in favor of park improvements and/or parkland dedication; where applicable, these fees would be included as a condition of the approval of the residential development (included as PPP PS -2). These fees would be used in the City of the purpose of acquiring, designing, constructing, improving, providing and maintaining, to the extent permitted by law, park improvements provided for in the City’s General Plan and its adopted capital improvement program or an adopted master plan of parks and recreation facilities, as amended from time to time. Therefore, as the Project would provide sufficient onsite open space for its residents, impacts related to the need to provide new or altered park and recreation facilities in order to maintain acceptable service ratios would be less than significant. Additionally, the developer would be required to pay park fees described above. v) Other public facilities?
Response:
Less Than Significant Impact. The proposed Project would develop 37 single-family residential units within an area that already contains single-family residential. The additional residences would result in a limited incremental increase in the need for additional services, such as public libraries and post offices, etc. Because the Project area is already served by other services and the Project would result in a limited increase in residences, the Project would not result in the need for new or physically altered facilities to provide other services, the construction of which could cause significant environmental impacts. Therefore, impacts would be less than significant.
Existing Plans, Programs, or Policies
PPP PS-1: The Project will be required to pay applicable development fees levied by the Moreno Valley Unified School District pursuant to the School Facilities Act (Senate Bill [SB] 50, Stats. 1998, c.827) to offset any effects on school facilities resulting from new development.
PPP PS-2: Park Fees. As a condition of the approval of a residential development, the Project shall pay applicable park related fees and/or dedicate parkland pursuant to Municipal Code Section 3.38.080 and Chapter 3.40.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.5 – Schools - Figure 1-3 – School District Boundaries
• Chapter 2 – Community Development Element – Section 2.6 – Library Services • Chapter 2 – Community Development Element – Section 2.7 – Special Districts • Chapter 2 – Community Development Element – Section 2.5 – Other City Facilities • Chapter 4 – Parks, Recreation and Open Space Element – Section 4.3 – Parks and Recreation - Figure 3-2 – Future Parklands Acquisition Areas
- Figure 3-3 – Master Plan of Trails
• Chapter 6 – Safety Element – Section 6.1 – Police Protection and Crime Preventions • Chapter 6 – Safety Element – Section 6.2 – Fire and Emergency Services - Figure 5-1 – Fire Stations
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.13 – Public Services
- Figure 4.13-1 – Location of Public Facilities
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. City of Moreno Valley Fire Department Website. Accessed: http://www.moreno- valley.ca.us/city_hall/departments/fire/index-fire.shtml (Accessed May 11, 2020).
5. City of Moreno Valley Police Department Website. Accessed: http://www.moreno- valley.ca.us/city_hall/departments/police/index-police.shtml (Accessed May 11, 2020).
6. City of Moreno Valley Parks, Recreational, and Open Spaces Comprehensive Master Plan. Accessed: April 21, 2025
7. http://www.ci.moreno-valley.ca.us/resident_services/park_rec/pdfs/park-mp0910.pdf (Accessed May 11, 2020).
8. Moreno Valley Unified School District Fee Justification Report for New Residential and Commercial/Industrial Development. 2020.
□ □ ~ □
Bradshaw Collection Project Page 84 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVI. RECREATION – Would the project:
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Response:
Less Than Significant Impact. As described previously, the Project would develop 37 single- family residences and 10,983 SF of recreation/ open space area would be provided for its residents. As discussed previously, residential developments are subject to Section 3.38.080 and Chapter 3.40 of the City’s Municipal Code, which include requirements for mitigation fees in favor of park improvements and/or parkland dedication; where applicable, these fees would be included as a condition of the approval of the residential development (included as PPP PS-2). These fees would be used in the City of the purpose of acquiring, designing, constructing, improving, providing and maintaining, to the extent permitted by law, park improvements provided for in the City’s General Plan and its adopted capital improvement program or an adopted master plan of parks and recreation facilities, as amended from time to time. Therefore, as the Project would provide sufficient onsite open space for its residents, impacts related to the increase the use of existing parks and recreational facilities, such that physical deterioration of the facility would be accelerated would be less than significant.
Additionally, the developer would be required to pay park fees described above. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which have an adverse physical effect on the environment?
Response:
Less Than Significant Impact. As described above, while the Project would contribute park development fees pursuant to Municipal Code 3.38.080 (included as PPP PS-2) to be used towards the future expansion or maintenance parks and recreational facilities, these fees are standard with every residential development, and the proposed Project would not require the construction or expansion of other recreational facilities that might have an adverse physical effect on the environment. The Project includes 10,983 SF of recreation – open space for residents and the impact of this recreational feature is included as part of the overall Project analysis contained in this Initial Study. Therefore, impacts specific to recreation would be less than significant. Additionally, the developer would be required to pay park fees described above.
Existing Plans, Programs, or Policies
PPP PS-2: Park Fees, provided in Section 15, Public Services.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 4 – Parks, Recreation and Open Space Element – Section 4.3 – Parks and Recreation - Figure 3-1 Open Space
- Figure 3-2 – Future Parklands Acquisition Areas
- Figure 3-3 – Master Plan of Trails
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.13 – Public Services
- Figure 4.13-1 – Location of Public Facilities
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code XVII.TRANSPORTATION – Would the project:
a) Conflict with program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Response:
Less Than Significant Impact.
Construction
Construction activities associated with the Project would generate vehicular trips from construction workers traveling to and from Project site, delivery of construction supplies and import materials to, and export of debris from, the Project Site.
However, these activities would only occur for a period of 12 months. The increase of trips during construction activities would be limited and is not anticipated to exceed the number of operational trips described below. The short-term vehicle trips from construction of the Project would generate less than significant traffic related impacts.
□ □ ~ □
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 85 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Operation
As shown in Table T-1 below, the proposed Project would generate approximately 26 trips during the a.m. peak hour, 35 trips during the p.m. peak hour, and a total of 349 daily trips.78
Table T-1: Project Trip Generation
Notes: DU = Dwelling Units
1 Trip rates from the Institute of Transportation Engineers, Trip Generation, 11th Edition, 2021 Source: RK Engineering Group, Inc. 2024 (Appendix J)
According to Exhibit A of the City of Moreno Valley Traffic Impact Analysis Preparation Guide, projects that generate fewer than 100 vehicle trips during the peak hours are generally exempt from the requirement to prepare a traffic impact analysis. Operation of the Project would not generate over 100 AM or PM peak hour trips. Therefore, the Project would not result in a conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, and impacts would be less than significant.
The Project area is currently served by the Riverside Transit Authority (RTA). The RTA provides both local and regional services throughout the region with 38 fixed routes, 9 commuter link routes, and Dial-A-Ride services. The existing RTA bus stop for Route 20, located approximately 0.3 miles from the Project site on Moreno Beach Drive, is the closest existing route to the Project. Operation of the Project would not affect the operation of the bus route. Thus, no impacts would occur. In addition, both sidewalks and bicycle lanes are located adjacent to the Project site on Cactus Avenue. The proposed Project would not alter any of the existing bicycle or sidewalk facilities. Thus, impacts related to bicycle or pedestrian circulation would not occur from implementation of the Project. b) Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Response:
Less than Significant Impact. Section 15064.3 of the State CEQA Guidelines codifies that project related transportation impacts are typically best measured by evaluating the project’s vehicle miles travelled (VMT). Specifically, subdivision (b) focuses on specific criteria related to transportation analysis and is divided into four subdivisions: (1) land use projects, (2) transportation projects, (3), qualitative analysis, and (4) methodology. Subdivision (b)(1) provides guidance on determining the significance of transportation impacts of land use projects using VMT; projects located within 0.5 mile of transit should be considered to have a less than significant impact. Subdivision (b)(2) addresses VMT associated with transportation projects and states that projects that reduce VMT, such as pedestrian, bicycle, and transit projects, should be presumed to have a less than significant impact. Subdivision (b)(3) acknowledges that Lead Agencies may not be able to quantitatively estimate VMT for every project type; in these cases, a qualitative analysis may be used. Subdivision (b)(4) stipulates that Lead Agencies have the discretion to formulate a methodology that would appropriately analyze a project’s VMT.
The City of Moreno Valley has prepared updated Traffic Impact Analysis Guidelines (Guidelines) for Land Use Projects in June 2020 to address changes to CEQA pursuant to SB -743 to include VMT analysis methodology and thresholds.
The Moreno Valley Traffic Impact Analysis Guidelines provide several screening thresholds for determining if a VMT analysis is required. A project VMT analysis would not be required if a project is located in a Transit Priority Area (TPA) or a low VMT area, or if the project is a local serving retail project or other neighborhood use, including projects that generate fewer than 400 daily trips, which corresponds to a typical development of 42 single family housing units. As shown on Table T-1, the Project proposes less than the 42 dwelling units discussed in the guidelines and generates 349 daily vehicle trips, fewer than the 400 daily vehicle trips threshold. Therefore, based on the Moreno Valley Traffic Impact Analysis Guidelines, the Project would be presumed to have a less than significant impact on VMT.
Land Use
Units
Daily
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Trip Rates
Single-Family
Detached
Housing1
DU 9.43 0.25 0.75 0.70 0.63 0.37 0.94
Project Trip Generation
Detached
Single Family
37 DUa 349 6 20 26 22 13 35
I
I I
I I I I I I I I
-
□ □ ~ □
Bradshaw Collection Project Page 86 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Response:
Less Than Significant Impact. The Project includes development of single- family residences. The Project includes community type uses and does not include any incompatible uses, such as farm equipment. The proposed Project area would be accessed from Bradshaw Circle, as well as through the onsite streets to each residence.
The Project would also not increase any hazards related to a design feature. All of the onsite streets would be developed in conformance with City design standards. The City’s construction permitting process includes review of Project plans to ensure that no potentially hazardous transportation design features would be introduced by the Project. For example, the design of the Project streets would be reviewed to ensure fire engine accessibility and turn around area is provided to the fire code standards. As a result, impacts related to vehicular circulation design features would be less than significant.
d) Result in inadequate emergency access?
Response:
Less than Significant Impact.
Construction
The proposed construction activities, including equipment and supply staging and storage, would occur within and adjacent to the Project area on Bradshaw Circle, and would not restrict access of emergency vehicles to the Project site or adjacent areas. The installation of driveways and connections to existing infrastructure systems that would be implemented during construction of the proposed Project could require the temporary closure of Bradshaw Circle and Cactus Avenue. In addition, repaving of Bradshaw Circle could result in the temporary closure of the street. However, Traffic detours are not expected to be necessary. In addition, the construction activities would be required to ensure emergency access in accordance with Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9), which would be ensured through the City’s permitting process. Thus, implementation of the Project through the City’s permitting process would ensure existing regulations are adhered to and would reduce potential construction related emergency access impacts to a less than significant level.
Operation
As described previously, the proposed Project area would be accessed from Bradshaw Circle, as well as through the onsite streets to each residence. Permitting of these roadways would provide adequate and safe circulation to, from, and through the Project are and would provide two routes for emergency responders to access different portions of the Project area. Because the Project is required to comply with all applicable City codes, as verified by the City, potential impacts related to inadequate emergency access would be less than significant.
Existing Plans, Programs or Policies
None.
Mitigation Measures
None.
□ □ ~ □
□ □ lLJ □
Bradshaw Collection Project Page 87 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 5 Circulation Element
- Figure 8-1 – Circulation Plan
- Figure 8-2 – LOS Standards
- Figure 8-3 – Roadway Cross-Sections
- Figure 8-4 – Bikeway Plan
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.2 – Traffic/Circulation
- Figure 4.2-1 – Circulation Plan
- Figure 4.2-2 – General Plan Roadway Cross-Sections
- Figure 4.2-3 – Year 2000 Number of Through Lanes
- Figure 4.2-4 – Year 2000 Daily Volume/Capacity (V/C) Ratios - Figure 4.2-5 – Year 2000 Average Daily Traffic Volumes - Figure 4.2-6 – Proposed Circulation Plan
- Figure 4.2-7 – LOS Standards
• Appendix B – Traffic Analysis, City of Moreno Valley General Plan Traffic Study, Urban Crossroads, June 2004.
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. Moreno Valley Municipal Code Chapter 3.18 Special Gas Tax Street Improvement Fund
5. Moreno Valley Master Bike Plan, adopted January 2015
6. Riverside County Transportation Commission, Congestion Management Program, December 14, 2011
7. City of Moreno Valley Transportation Engineering Division, Traffic Impact Analysis Preparation Guide. 2007.
8. Trip Generation and VMT Screening Analysis for Cactus and Bradshaw Circle Residential Project. March 22, 2024. Prepared by RK Engineering Group, Inc. (Appendix J).
XVIII. TRIBAL CULTURAL RESOURCES – Would the project:
AB 52 and SB 18 Requirements
The Project would be required to comply with AB 52 and SB 18 regarding tribal consultation. Chapter 532, Statutes of 2014 (i.e., AB 52), requires that Lead Agencies evaluate a project’s potential to impact “tribal cultural resources.” Such resources include sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California Register or included in a local register of historical resources (PRC Section 21074). AB 52 also gives Lead Agencies the discretion to determine, supported by substantial evidence, whether a resource falling outside the definition stated above nonetheless qualifies as a “tribal cultural resource.”
SB 18 requires cities and counties acting as Lead Agency to contact and consult with California Native American tribes before adopting or amending a General Plan. The intent of SB 18 is to establish meaningful consultation between tribal governments and local governments at the earliest possible point in the planning process and to enable tribes to manage “cultural places.” Cultural places are defined as a Native American sanctified cemetery, place of worship, religious or ceremonial site, or sacred shrine (PRC Section 5097.9), or a Native American historic, cultural, or sacred site, that is listed or may be eligible for listing in the California Register, including any historic or prehistoric ruins, any burial ground, or any archaeological or historic site (PRC Section 5097.993).
In compliance with these requirements, the City sent out to the following Native American tribes that may have knowledge regarding tribal cultural resources in the Project vicinity. • Agua Caliente Band of Cahuilla Indians
• Agustine Band of Cahuilla Indians
• Cabazon Band of Cahuilla Indians
• Cahuilla Band of Indians
• Desert Cahuilla Indians
• Los Coyotes Band of Cahuilla Mission Indians
• Quechan Tribe of Fort Yuma Reservation
• Morongo Band of Mission Indians
Bradshaw Collection Project Page 88 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
• Pala Band of Mission Indians
• Pechanga Band of Luiseño Indians
• Ramona Band of Cahuilla Indians
• Rincon Band of Luiseño Indians
• Yuhaaviatam of San Manuel Nation (formerly the San Manuel Band of Mission Indians) • Santa Rosa Band of Mission Indians
• Serrano Nation of Mission Indians
• Soboba Band of Luiseño Indians
The Agua Caliente Band of Cahuilla Indians, Yuhaaviatam of San Manuel Nation, Pechanga Band of Indians, Morongo Band of Mission Indians, Soboba Band of Luiseño Indians, and Rincon Band of Luiseño Indians requested consultation regarding the proposed Project. The consulting tribes consider the area sensitive for archaeological and cultural resources as several sites are located nearby. Although no information for site specific tribal cultural resources was provided, the consulting tribes requested the inclusion of mitigation due to the potential of the Project to unearth previously undocumented tribal cultural resources during construction. As such, Mitigation Measures TCR-1 through TCR-9 are included, which require Native American monitoring, and procedures for artifact disposition and inadvertent finds.
a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or
Response:
Less than Significant Impact. As detailed previously in Section 5, Cultural Resources , the Project S ite is currently vacant. Historic aerial photographs and maps of the Project site showed no development in the general vicinity of the Project area until after 1976. All improvements, therefore, are less than 45 years of age and considered modern and of no historical consequence (McKenna, 2020).
The Phase I Resources Investigation and Paleontological Overview prepared for the Project included a search of the California Historical Resource Information System (CHRIS) at the Eastern Information Center (EIC), located at the University of California, Riverside, Riverside County. The records search indicated that the nearest recorded resources are more than one-half mile distant. It was also determined that there are no known significant cultural resources within the Project area and any future development will not adversely impact any significant resources. Furthermore, the Sacred Lands File search completed by the NAHC stated that there are no known/known sacred lands within a 1 mile of the Project site (McKenna, 2020). Therefore, no substantial evidence exists that tribal cultural resources are present in the Project site, and impacts would be less than significant.
□ □ ~ □
Bradshaw Collection Project Page 89 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code section 5024.1. In applying the criteria set forth in subdivision (c) of Public R esources Code section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
Response:
Less Than Significant Impact with Mitigation Incorporated. As detailed previously, due to the Project sites proximity to previously noted archeological districts, the Tribal Historic Preservation Office (THPO) believes potential remains for encountering subsurface cultural deposits in areas not previously studied or visibly marked. Archeological and Tribal monitoring during ground-disturbing activities, the preparation of a monitoring report, and the implementation of protocols for the discovery of cultural materials and human remains is recommended. These protocols would include the notification of, and consultation with, tribes regarding all significant finding of Native American origin and are included in Mitigation Measures TCR-1 through TCR-9. Mitigation Measures TCR-1 through TCR-9 require Native American and archaeological monitoring of excavation and grading activities to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities. No information has been provided to the Lead Agency indicating any likelihood of uncovering tribal cultural resources on the Project site, there are no known tribal cultural resources on or adjacent to the Project site, and no potentially significant impacts are anticipated. Mitigation Measures TCR-1 through TCR-9 are included in the event of any inadvertent discoveries of human remains during construction activities.
Additionally, as described previously and included as Mitigation Measure T CR-7, California Health and Safety Code, Section 7050.5 requires that if human remains are discovered in the Project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation. If the coroner determines that the remains are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.
Therefore, with implementation of Mitigation Measures TCR-1 through TCR-9, impacts to tribal cultural resources would be less than significant.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
TCR 1 Archaeological Monitoring. Prior to the issuance of a grading permit, the Developer shall retain a professional archaeologist to conduct monitoring of all ground-disturbing activities at Bradshaw Collection (Tentative Tract Map 37858).
The Project Archaeologist shall have the authority to temporarily redirect earthmoving activities in the event that suspected archaeological resources are unearthed during Project construction. The Project Archaeologist, in consultation with the Consulting Tribe(s), Agua Caliente Band of Cahuilla Indi ans, Yuhaaviatam of San Manuel Nation, Pechanga Band of Indians, Morongo Band of Mission Indians, Soboba Band of Luiseño Indians, and Rincon Band of Luiseño Indians, including the contractor, and the City, shall develop a CRMP as defined in TCR-3. The Project archeologist shall attend the pre- grading meeting with the City, the construction manager, and any contractors and will conduct a mandatory Cultural Resources Worker Sensitivity Training to those in attendance. The archaeological monitor shall have the authority to temporarily halt and redirect earth -moving activities in the affected area in the event that suspected archaeological resources are unearthed.
TCR 2 Native American Monitoring. Prior to the issuance of a grading permit, the Developer shall secure agreements with the Pechanga Band of Indians, Morongo Band of Mission Indians, Soboba Band of Luiseño Indians, and /or Rincon Band of Luiseño Indians for tribal monitoring. The Developer is also required to provide a minimum of 30 days’ advance notice to the tribes of all ground -disturbing activities. The Native American Tribal Representatives shall have the authority to temporarily halt and redirect earth-moving activities in the affected area in the event that suspected archaeological and cultural resources are unearthed. The Native American Monitor(s) shall attend the pre -grading meeting with the Project Archaeologist, the City, the construction manager, and any contractors and will cond uct the Tribal Perspective of the mandatory Cultural Resources Worker Sensitivity Training to those in attendance.
TCR 3 Cultural Resource Monitoring Plan (CRMP). The Project Archaeologist, in consultation with the Consulting Tribe(s), the contractor, and the City, shall develop a CRMP in consultation pursuant to the definition in AB52 to address the details, timing, and responsibility of all archaeological and cultural activities that will occur on the project site. A consulting Tribe is defined as a Tribe that initiated the AB52 tribal consultation process for the Project, has not opted out of the AB52 consultation process, and has completed AB52 consultation with the City as provided for in Cal Pub Res Code Section 21080.3.2(b)(1) of AB52. Details in the Plan shall include:
-
□ ~ □ □
-
Bradshaw Collection Project Page 90 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a. Project description and location;
b. Project grading and development scheduling;
c. Roles and responsibilities of individuals on the Project; d. The pre-grading meeting and Cultural Resources Worker Sensitivity Training details; e. The protocols and stipulations that the contractor, City, Consulting Tribe (s), and Project archaeologist will follow in the event of inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits that shall be subject to a cultural resources evaluation; f. The type of recordation needed for inadvertent finds and the stipulations of recordation of sacred items; g. Contact information of relevant individuals for the Project.
TCR 4 Cultural Resource Disposition . In the event that Native American cultural resources are discovered during the course of ground disturbing activities (inadvertent discoveries), the following procedures shall be carried out for final disposition of the discoveries:
a. One or more of the following treatments, in order of preference, shall be employed with the tribes.
Evidence of such shall be provided to the City of Moreno Valley Planning Department:
i. Preservation-In-Place of the cultural resources, if feasible. Preservation in place means avoiding the resources, leaving them in the place they were found with no development affecting the integrity of the resources. ii. On-site reburial of the discovered items as detailed in the treatment plan required pursuant to Mitigation Measure TCR 1. This shall include measures and provisions to protect the future reburial area from any future impacts in perpetuity. Reburial shall not occur until all legally required cataloging and basic recordation have been completed. No recordation of sacred items is permitted without the written consent of all Consulting Native American Tribal Governments as defined in TCR 3. The location for the future reburial area shall be identified on a confidential exhibit on file with the City, and concurred to by the C onsulting Native American Tribal Governments prior to certification of the environmental document.
TCR 5 The City shall verify that the following note is included on the Grading Plan:
“If any suspected archaeological and cultural resources are discovered during ground– disturbing activities and the Project Archaeologist or Native American Tribal Representatives are not present, the construction supervisor is obligated to halt work in a 100- foot radius around the find and call the Project Archaeologist and the Tribal Representatives to the site to assess the significance of the find." TCR 6 Inadvertent Finds . If potential historic or cultural resources are uncovered during excavation or construction activities at Bradshaw Collection (Tentative Tract Map 37858) that were not assessed by the archaeological report(s) and/or environmental assessment conducted pri or to Project approval , all ground-disturbing activities in the affected area within 100 feet of the uncovered resource must cease immediately and a qualified person meeting the Secretary of the Interior's standards (36 CFR 61), Tribal Representatives, and all site monitors per the Mitigation Measures, shall be consulted by the City to evaluate the find, and as appropriate recommend alternative measures to avoid, minimize or mitigate negative effects on the historic, or prehistoric resource. Further ground disturbance shall not resume within the area of the discovery until an agreement has been reached by all parties as to the appropriate mitigation. Work shall be allowed to continue outside of the buffer area and will be monitored by additional archeologist s and Tribal Monitors, if needed. Determinations and recommendations by the consultant shall be immediately submitted to the Planning Division for consideration and implemented as deemed appropriate by the Community Development Director, in consultation wi th the State Historic Preservation Officer (SHPO) and any and all Consulting Native American Tribes as defined in TCR 2 before any further work commences in the affected area. If the find is determined to be significant and avoidance of the site has not be en achieved, a Phase III data recovery plan shall be prepared by the Project Archeologist, in consultation with the Tribe, and shall be submitted to the City for their review and approval prior to implementation of the said plan.
TCR 7 Human Remains. If human remains are discovered, no further disturbance shall occur in the affected area until the County Coroner has made necessary findings as to origin. If the County Coroner determines that the remains are potentially Native American, the California Native American Heritage Commission shall be notified within 24 hours of the published finding to be given a reasonable opportunity to identify the “most likely descendant”. The “most likely descendant” shall then make recommendations and engage in consultations concerning the treatment of the remains (California Public Resources Code 5097.98). (GP Objective 23.3, CEQA). No photographs are to be taken except by the coroner, with written approval by the consulting Tribe(s).
Bradshaw Collection Project Page 91 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
TCR 8 Non-Disclosure of Reburial Locations. It is understood by all parties that, unless otherwise required by law, the site of any reburial of Native American human remains or associated grave goods shall not be disclosed and shall not be governed by public disclosure requirements of the California Public Records Act. The Coroner, pursuant to the specific exemption set forth in California Government Code 6254 (r), parties, and Lead Agencies, will be asked to withhold public disclosure information related to such reburial, pursuant to the specific exemption set forth in California Government Code 6254 (r).
TCR 9 Archaeology Report - Phase III and IV. Prior to final inspection, the developer/permit holder shall prompt the Project Archaeologist to submit two (2) copies of the Phase III Data Recovery report (if required for the Project) and the Phase IV Cultural Resources Monitoring Report that complies with the Community Development Department's requirements for such reports. The Phase IV report shall include evidence of the required cultural/historical sensitivity training for the construction staff held during the pre-grade meeting. The Community Development Department shall review the reports to determine adequate mitigation compliance. Provided the reports are adequate, the Community Development Department shall clear this condition. Once the report(s) are determined to be adequate, two (2) copies shall be submitted to the South Coastal Information Center (SCIC) at the San Diego State University (SDSU), and one (1) copy shall be submitted to each of the Consulting Tribe(s) Cultural Resources Department(s).
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 7 – Conservation Element – Section 7.2 – Cultural and Historical Resources
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.10 – Cultural Resources
- Figure 4.10-1 – Locations of Listed Historic Resource Inventory Structures - Figure 4.10-2 – Location of Prehistoric Sites
- Figure 4.10-3 – Paleontological Resource Sensitive Areas • Appendix F – Cultural Resources Analysis, Study of Historical and Archaeological Resources for the Revised General Plan, City of Moreno Valley, Archaeological Associates, August 2003.
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. Moreno Valley Municipal Code Title 7 – Cultural Preservation
5. Cultural Resources Inventory for the City of Moreno Valley, Riverside County, California, prepared by Daniel F.
McCarthy, Archaeological Research Unit, University of California, Riverside, October 1987 (This document cannot be provided to the public due to the inclusion of confidential information pursuant to Government Code Section 6254.10.)
6. Phase I Cultural Resources Investigation and Paleontological Overview for Tentative Tract Map No. 37858, City of Moreno Valley, Riverside County, California. March 18, 2020. Prepared by McKenna et al. (Appendix D).
Bradshaw Collection Project Page 92 City of Moreno Valley
ISSUES & SUPPORTING INFORMATION
SOURCES:
Potentially
Significant Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water
drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Response:
Less than Significant.
Water Infrastructure
The proposed Project would install a new 8-inch water pipeline in Bradshaw Circle that would connect to an existing 12- inch water pipeline in Cactus Avenue. The new onsite water system would convey water supplies to the proposed residences and landscaping through plumbing/landscaping fixtures that are compliant with the CALGreen Code for
efficient use of water.
The proposed Project would continue to receive water supplies through the existing water line located within the Cactus Avenue rights-of-way that has the capacity to provide the increased water supplies needed to serve the proposed Project, and no extensions or expansions to the water pipelines that convey water to the Project site would be required. The installation of onsite water distribution lines would only serve the proposed Project and would not provide water to any offsite areas.
The construction activities related to the onsite water infrastructure that would be needed to serve the proposed single- family residences is included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout this Initial Study. For example, an analysis of construction emissions for excavation and installation of the water infrastructure is included in Sections 3, Air Quality and 8, Greenhouse Gas Emissions .
Therefore, the proposed Project would not result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects, and impacts would be less than significant.
Wastewater Infrastructure
The Project includes installation of onsite sewer lines within the proposed onsite streets that would connect to the existing sewer line in Cactus Avenue. These wastewater flows will be further transported to the Moreno Valley Regional Water Reclamation Facility. The construction activities related to installation of the onsite sewer infrastructure that would serve the proposed Project is included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout this Initial Study. For example, an analysis of construction emissions for excavation and installation of the sewer infrastructure is included in Section 3, Air Quality and 8, Greenhouse Gas Emissions , and noise volumes from these activities are evaluated in Section 13, Noise. As the proposed Project includes facilities to serve the
proposed development, it would not result in the need for construction of other new wastewater facilities or expansions, the construction of which could cause significant environmental effects. Therefore, impacts would be less than significant.
□ □ ~ □
Bradshaw Collection Project Page 93 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry and multiple dry years?
Response:
Less Than Significant Impact. The proposed Project would result in an increased demand for water supplies from the 37 single-family residential units. Water supplies to the Project area are provided by EMWD, which serves 555 square miles of western Riverside County and includes the Project area (UWMP, 2020). In 2020, EMWD had a water demand of 153,615 AF, and based on land use and growth projections it anticipates a demand of 208,900 AF in 2025, which is a 74 percent increase over 2020 demands (an increase of 55,285 AF) (UWMP, 2020). The UWMP details that the district has water supply to meet the projected demands over the next 25 years and beyond (UWMP, 2020). The UWMP describes that the district has a projected supply of 161,983 AF in 2020, and a predicted supply of 251,500AFY in 2045.
To provide a conservative estimate of Project water use, a generation rate of 176 gallons per capita per day was used to estimate water demand from the proposed Project (UWMP, 2020). As described in Section 14, Population and Housing, the proposed Project would result in 130 additional residents at full occupancy. Based on the district’s 2020 water use target of 176 gallons per capita per day, the 1 30 additional residents would generate a water demand of 22,880 gallons per day. The Project would limit water demand by inclusion of low -flow plumbing and irrigation fixtures, pursuant to the California Title 24 requirements.
As detailed previously, the district has the water supply to meet the projected demands over the next 25 years and beyond.
In addition, the 2015 UWMP details the available supply, including groundwater, imported water, and recycled water would meet the projected demand during normal, single dry and multiple dry years (UWMP, 2015). Therefore, impacts related to water supplies from the proposed Project would be less than significant. c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments?
Response:
Less than Significant Impact. As described above, wastewater flows would be conveyed to the Moreno Valley Regional Water Reclamation Facility. The treatment facility has a current daily capacity of 17,900 acre-feet per year (AFY) (UWMP, 2020). EMWD’s 2015 Wastewater Collection System Master Plan uses a wastewater generation rate of 235 gallons per day (GPD) per residential unit. With the anticipated 37 households, the proposed Project would produce a total of 8,695 GPD. 8,695 GPD would equate to approximately 3,618 AFY, which is within the daily capacity of the Moreno Valley Regional Water Reclamation Facility. Additionally, through the city’s plan check process, the city’s engineering department would confirm that the wastewater generated from the Project would be accommodated within this capacity. Thus, the wastewater treatment plant has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments, and impacts would be less than significant. d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction
goals?
Response:
Less Than Significant Impact. The closest landfill to the vacant Project site is the Badlands Sanitary Landfill, which is located approximately 6 miles northeast from the Project site at 31125 Ironwood Avenue in Moreno Valley. The landfill is permitted to accept 5,000 tons per day of solid waste and is permitted to operate through 2059 (CalRecycle, 2024). In 2024, the landfill had a highest volume of 4,030.41 tons per day. As such, on average, the landfill would have a remaining capacity of 969.59 tons per day. As of July 2024, the landfill has a remaining capacity of 7,800,000 cubic yards (CalRecycle, 2024).
The CalEEMod solid waste generation rate for single- family residential land use is 0.41 tons per resident per year. As described previously, full occupancy of the proposed Project would generate approximately 130 new residents. Thus, operation of the Project would generate approximately 53.3 tons per solid waste per year; or 1.03 tons per week. However, at least 75 percent of the solid waste is required by AB 341 to be recycled, which would reduce the volume of landfilled solid waste to approximately 0.26 tons per week or 0.04 tons per day, which is within the Badlands Sanitary Landfill’s average remaining capacity of 2,372 tons per day. Thus, the proposed Project would be served by a landfill with sufficient permitted capacity to accommodate the Project’s solid waste disposal needs and the Project would not impair the attainment of solid waste reduction goals. Impacts related to landfill capacity would be less than significant. □ □ ~ □
□ □ ~ □
□ □ ~ □
Bradshaw Collection Project Page 94 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Response:
No Impact. The proposed Project would result in new development that would generate an increased amount of solid waste. All solid waste-generating activities within the City are subject to the requirements set forth in Section 4.408 of the 2022 California Green Building Standards Code that requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste, and AB 341 that requires diversion of a minimum of 75 percent of operational solid waste. Implementation of the proposed Project would be consistent with all State regulations, as ensured through the City’s development Project permitting process. Therefore, the proposed Project would comply with all solid waste statute and regulations; and impacts would not occur.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Conservation Element – Section 2.4 – Utilities • Chapter 6 – Safety Element – Section 6.7 – Water Quality • Chapter 7 – Conservation Element – Section 7.3 – Solid Waste • Chapter 7 -- Conservation Element – Section 7.5—Water Resources, Figure 6-1 – Water Purveyor Service Area Map
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.7 – Hydrology and Water Quality
- Figure 4.7-1 – Strom Water Flows and Major Drainage Facilities - Figure 4.7-2 – Groundwater Basins
• Section 5.13 – Public Services
- Figure 4.13-1 – Locations of Public Facilities
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. Moreno Valley Municipal Code Chapter 8.10 Stormwater/Urban Runoff Management and Discharge Controls
5. Moreno Valley Municipal Code Section 8.21.170 National Pollutant Discharge Elimination System (NPDES).
6. Moreno Valley Municipal Code Chapter 8.80 – Recycling and Diversion of Construction and Demolition Waste
7. California Emissions Estimator Model Appendix D Default Data Tables. Table 10.1 Solid Waste Disposal Rates. Accessed: http://www.aqmd.gov/docs/default-source/caleemod/upgrades/2016.3/05_appendix-d2016-3-
1.pdf
?sfvrsn=2
8. CalRecycle Solid Waste Information System. Accessed at:
https://www2.calrecycle.ca.gov/SWFacilities/Directory (Accessed May 12, 2020).
9. CalRecycle Disposal Reporting System: Jurisdiction Tons by Facility. Accessed at:
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility (Accessed May 12, 2020).
10. Eastern Municipal Water District 2015 Urban Water Management Plan. June 2016. Prepared by RMC. Available:
https://www.emwd.org/what-we-do/water-supply/urban-water-management-plan(Accessed February 14, 2025).
11. Eastern Municipal Water District Moreno Valley Regional Water Reclamation Facility Fact Sheet. Accessed:
https://www.emwd.org/sites/main/files/file-attachments/mvrwrffactsheet.pdf (Accessed May 12, 2020).
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
Response:
No Impact. The Project site is vacant and within an urbanized residential area of Moreno Valley. The Project site is surrounded by developed and urban areas. The Project site is not adjacent to any wildland areas. According to the CAL FIRE Hazard Severity Zone map, the Project site is not within a fire hazard zone. The proposed Project area would be accessed from two driveways on Bradshaw Circle. Permitting of these roadways would provide adequate and safe circulation to, from, and through the Project area and would provide two routes for emergency responders to access different portions of the Project area. Because the Project is required to comply with all applicable City codes, as verified by the City potential impacts related to an emergency response or evacuation would be less than significant. □ □ □ ~
□ □ □ ~
Bradshaw Collection Project Page 95 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Response:
No Impact. As discussed previously, the Project site is developed and within an urbanized residential area of Moreno Valley. The Project site is surrounded by developed and urban areas. The Project site is not adjacent to any wildland areas, and as determined by the CAL FIRE Hazard Severity Zone map, the Project site is not within a fire hazard zone.
In addition, the Project site is flat and within a flat area. The site is adjacent to roadways and residential developments.
There are no factors on or adjacent to the Project site that would exacerbate wildfire risks. Thus, no impact related to other factors that would expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire would occur from the Project.
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Response:
No Impact. As described previously, the Project site is developed and within a developed and urban area that is not within a wildfire hazard zone. The Project does not include any infrastructure that would exacerbate fire risks. In addition, the Project would provide internal streets and fire suppression facilities (e.g., hydrants and sprinklers) that conform to the California Fire Code requirements, included as Municipal Code Chapter 8.36, as verified through the City’s permitting process. Therefore, impacts related to infrastructure that could exacerbate fire risks would not occur with the proposed Project.
d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
Response:
No Impact. As described previously, the Project site is developed and within a developed and urban area that is not within a wildfire hazard zone. In addition, the Project site is flat and surrounded by flat areas. There are no slope or hillsides that would become unstable. In addition, the Project would install onsite drainage that would be conveyed to the existing flood control channel, which is consistent with the existing condition. Therefore, impacts related to flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes would not occur from the proposed Project.
Existing Plans, Programs, or Policies
None.
Mitigation Measures
None.
Sources:
1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.2- Fire and Emergency Services – 6.2.8—Wildland Urban Interface
2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.5 – Hazards and Hazardous Materials
• Figure 4.5-2 – Floodplains and High Fire Hazard Areas
3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code
4. Local Hazard Mitigation Plan, City of Moreno Valley Fire Department, adopted October 4, 2011, amended 2017, http://www.moval.org/city_hall/departments/fire/pdfs/haz-mit-plan.pdf • Chapter 5 – Wildland and Urban Fires
• Figure 4-2 – Moreno Valley High Fire Area Map 2016
• Chapter 8 – Landslide
• Figure 7-1 – Moreno Valley Slope Analysis 2016
5. Emergency Operations Plan, City of Moreno Valley, March 2009, http://www.moval.org/city_hall/departments/fire/pdfs/mv-eop-0309.pdf • Threat Assessment 3 – Wildfire
6. California Department of Forestry and Fire Protection (CAL FIRE). 2020. Fire Hazard Severity Zone Map.
Accessed:
https://forestwatch.maps.arcgis.com/apps/Styler/index.html?appid=5e96315793d445419b6c96f89ce5d153 • (Accessed May 12, 2020).
□ □ □ ~
□ □ □ ~
□ □ □ ~
Bradshaw Collection Project Page 96 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major
periods of California history or prehistory?
Response:
Less Than Significant with Mitigation Incorporated. The Habitat Assessment describes that the special-status wildlife and plant species with the potential to occur on the Project site are covered by compliance with the MSHCP, which requires payment of fees, included as PPP BIO -1. In addition, because the site supports suitable habitat for burrowing owl the MSHCP requires focused surveys pursuant to the Western Riverside County Regional Conservation Authority (RCA) Burrowing Owl Survey Instructions for the MSHCP area. Hence, Mitigation Measure BIO - 1 requires a
preconstruction burrowing owl survey to be conducted pursuant to the RCA Survey Instructions prior to start of ground disturbance activities. With implementation of Mitigation Measures BIO-1, impacts related to burrowing owl would be less than significant.
In addition, the Habitat Assessment identified suitable habitat and substrate for raptors and migratory birds that are protected under the Migratory Bird Treaty Act and Section 3503.5 of the California Department of Fish and Wildlife (CDFW) code. Therefore, Mitigation Measures BIO -2 is included to require raptor and migratory nesting bird surveys if construction activities begin during the nesting season. With implementation of Mitigation Measures BIO -2, impacts related to protected bird species would also be reduced to a less than significant level.
As described in Section 5, Cultural Resources, the Project site does not contain any buildings or structures that meet any of the California Register of Historical Resources criteria or qualify as “historical resources” as defined by CEQA.
Therefore, the proposed Project would not cause a substantial adverse change in the significance of a historical resource.
In addition, the Phase I Cultural Resources Investigation and Paleontological Overview determined that the potential for archaeological resources to be located within the Project site is extremely low to nonexistent. However, the Project area is considered moderately sensitive for paleontological resources. Thus, MM PAL- 1 has been included to require paleontological monitoring during all future excavations that would exceed a relative depth of five feet below the present surface. Thus, implementation of MM PAL-1 would reduce potential impacts to important examples of California prehistory to a less than significant level.
As described in Section 18, Tribal Cultural Resources, to avoid potential adverse effects to tribal cultural resources, Mitigation Measures TCR -1 through TCR -9 have been included to provide for Native American and archaeological monitoring of excavation and grading activities to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities.
□ ~ □ □
Bradshaw Collection Project Page 97 City of Moreno Valley
ISSUES & SUPPORTING
INFORMATION SOURCES:
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are
considerable when viewed in connection with the effects of past projects, the effects of other current project, and the effects of probable future projects.)?
Response:
Less than Significant with Mitigation Incorporated. The Project would redevelop the Project site for single-family residences within a developed area. The Project would provide land uses that are consistent with the adjacent single- family residential uses. As described above, all of the potential impacts related to implementation of the Project would be less than significant or reduced to a less than significant level with implementation of mitigation measures that are imposed by the City that effectively reduce environmental impacts.
The other cumulative effects of the proposed Project taken into consideration with these other Projects would be limited, because the Project site has already been developed and disturbed and the new uses onsite would not result in substantial change in the urban use of the area. As discussed in Section 19, Utilities and Service Systems, public services and utility infrastructure are in place to serve the Project and would not result in cumulatively considerable increases in service and utility needs to serve the Project. In addition, the Project would not result in substantial effects to any environmental resource topic, as described throughout this document.
Overall, the proposed Project would develop an area that has been subject to previous grading, and is surrounded by consistent development and roadways. Impacts to environmental resources or issue areas would not be cumulatively considerable; and cumulative impacts would be less than significant with implementation of the previously identified mitigation measures related to biological resources, paleontological resources, noise, and tribal cultural resources. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Response:
Less than Significant with Mitigation Incorporated. The Project proposes development of the Project site for single- family residential uses. As described previously, the Project site is within an urban area and surrounded by consistent land uses. The Project would not consist of any use or any activities that would result in a substantial negative affect on persons in the vicinity. All resource topics associated with the proposed Project have been analyzed in accordance with CEQA and the State CEQA Guidelines and were found to pose no impacts or less -than-significant impacts with implementation of mitigation measures related to biological resources, paleontological resources, noise, and tribal cultural resources; and existing plans, programs, or policies that are required by the City. Consequently, the proposed Project would not have environmental effects that would cause substantial adverse effects on human beings directly or indirectly, and impacts would be less than significant with mitigation.
□ ~ □ □
□ ~ □ □
Bradshaw Collection Project Page 98 City of Moreno Valley
DOCUMENT PREPARERS AND CONTRIBUTORS
Lead Agency:
City of Moreno Valley
Community Development Department
Planning Division
14177 Frederick Street
Moreno Valley, California 92552
CEQA Document Preparer:
EPD Solutions, Inc.
Konnie Dobreva, JD
Meaghan Truman
Lauren Battle
Bradshaw Collection Project Page 99 City of Moreno Valley