Moreno Valley City Council
September 1, 2026

ATTACHMENT A
Section 5. DESIGNATION OF THE FEE ASSESSMENT AREA.

All those certain lands located in the unincorporated areas of the County of Riverside, State of California, as hereinafter particularly described, are hereby designated as the Fee Assessment Area. Said Fee Assessment Area is described as follows:

Beginning at the intersection of the West line of the Northeast 1/4 of the Northeast 1/4 of Section 11, Township 2 South, Range 5 West with the northerly boundary line of the County of Riverside, California.

Thence Southerly along the West line of the Northeast 1/4 of the Northeast 1/4 of said Section 11 to the Southwest corner thereof.

Thence Easterly along the South line of the Northeast 1/4 of the Northeast 1/4 of said Section 11 to the Southeast corner thereof.

Thence Southerly along the West line of Sections 12 and 13, Township 2 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of said Section 13 and the South line of Sections 18 and 17, Township 2 South, Range 4 West to the Southeast corner thereof.

Thence Southerly along the West line of Sections 21, 28 and 33, Township 2 South, Range 4 West to the Southwest corner thereof.

Thence Westerly along the North line of Section 5, Township 3 South, Range 4 West to the Northwest corner thereof.

Thence Southerly along the West line of said Section 5 to the Southwest corner thereof.

Thence Westerly along the North line of Section 7, Township 3 South, Range 4 West and the North line of Sections 12, 11 and 10, Township 3 South, Range 5 West to its intersection with the centerline of Victoria Avenue in the City of Riverside, California.

Thence Southwesterly along said centerline of Victoria Avenue to its intersection with the North line of Section 19, Township 3 South, Range 5 West.

Thence Westerly along the North line of said Section 19 and the North line of Section 24, Township 3 South, Range 6 West to the Northwest corner thereof. Thence Southerly along the West line of said Section 24 to the Southwest corner thereof.

Thence Westerly along the North line of Sections 26 and 27, Township 3 South, Range 6 West to the Northwest corner thereof.
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Thence Southerly along the West line of the Northwest 1/4 of said Section 27 to the Southwest corner thereof.

Thence Westerly along the North line of the Southeast 1/4 of Section 28, Township 3 South, Range 6 West to the Northwest corner thereof.

Thence Southerly along the West line of the Southeast 1/4 of said Section 28 and the West line of the East 1/2 of Section 33, Township 3 South, Range 6 West to the Southwest corner thereof.

Thence Southerly along the West line of the East 1/2 of the West 1/2 of Section 4, Township 4 South, Range 6 West to the Southwest corner thereof.

Thence Easterly along the South line of the East 1/2 of the West 1/2 and the South line of the West 1/2 of the East 1/2 of said Section 4 to the Southeast corner thereof.

Thence Southerly along the West line of the East 1/2 of the East 1/2 of Section 9, Township 4 South, Range 6 West to the Southwest corner thereof.

Thence Easterly along the South line of the East 1/2 of the East 1/2 of said Section 9 to the Southeast corner thereof.

Thence Southerly along the West line of Section 15, Township 4 South, Range 6 West to the centerline of Cajalco Road.

Thence Southwesterly along the said centerline of Cajalco Road to its intersection with the centerline of Interstate 15.

Thence Southeasterly along said centerline Interstate 15 to its intersection with the West line of Section 1, Township 5 South, Range 6 West.

Thence Southerly along the West line of said Section 1 and the West line of the Northwest 1/4 of Section 12, Township 5 South, Range 6 West to the Southwest 1/4 thereof.

Thence Easterly along the South line of the Northwest 1/4 of said Section 12 to the Southeast corner thereof.

Thence Southerly along the West line of the Southeast 1/4 of said Section 12 to the Southwest corner.

Thence Easterly along the South line of said Section 12 to the Southeast corner thereof.

Thence Southerly along the West line of the North 1/2 of the North 1/2 of Section 18, Township 5 South, Range 5 West to the Southwest corner thereof. 2334

Thence Easterly along the South line of the North 1/2 of the North 1/2 of said Section 18 to the Southeast corner thereof.

Thence Southerly along the West line of the South 1/2 of the North 1/2 of Section 17, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the South 1/2 of the North 1/2 of said Section 17 to the Southeast corner thereof.

Thence Southerly along the West line of the South 1/2 of Section 16, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of said Section 16 to the Southeast corner thereof.

Thence Southerly along the West line of the North 1/2 of Section 2, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the North 1/2 of said Section 22 to the Southeast corner thereof.

Thence Southerly along the West line of the Southwest 1/4 of Section 23, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the Southwest 1/4 of said Section 23 to the Southeast corner thereof.

Thence Southerly along the West line of the Northeast 1/4 of Section 26, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the Northeast 1/4 of said Section 26 to the Southeast corner thereof.

Thence Southerly along the West line of the Southwest 1/4 of Section 25, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the Southwest 1/4 of said Section 25 to the Southeast corner thereof.

Thence Southerly along the West line of the East 1/2 of Section 36, Township 5 South, Range 5 West to the Southwest corner thereof.

Thence Easterly along the South line of the East 1/2 of said Section 36 to the Southeast corner thereof.

Thence Southerly along the West line of the Northwest 1/4 of Section 6, Township 6 South, Range 4 West to the Southwest corner thereof.
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Thence Easterly along the South line of the Northwest 1/4 of said Section 6 to the Southeast corner thereof.

Thence Southerly along the West line of the Southeast 1/4 of said Section 6 to the Southwest corner thereof.

Thence Easterly along the South line of the Southeast 1/4 of said Section 6 to the Southeast corner thereof.

Thence Southerly along the West line of the Northwest 1/4 of Section 8, Township 6 South, Range 4 West to the Southwest corner thereof.

Thence Easterly along the South line of the Northwest 1/4 of said Section 8 to the Southeast corner thereof.

Thence Southerly along the West line of the Southeast 1/4 of said Section 8 to the Southwest corner thereof.

Thence Easterly along the South line of the Southeast 1/4 of said Section 8 to the Southeast corner thereof.

Thence Southerly along the West line of Section 16, Township 6 South, Range 4 West to the Southwest corner thereof.

Thence Easterly along the South line of said Section 16 to the Southeast corner thereof.

Thence Southerly along the West line of the West 1/2 of Section 22, Township 6 South, Range 4 West to the Southwest corner thereof.

Thence Easterly along the South line of the West 1/2 of said Section 22 of the Southeast corner thereof.

Thence Southerly along the West line of the Northeast 1/4 of Section 27, Township 6 South, Range 4 West to the Southwest corner thereof.

Thence Easterly along the South line of the Northeast 1/4 of said Section 27 to the Southeast corner thereof.

Thence Southerly along the West line of the Southwest 1/4 of Section 26 and the West line of the Northwest 1/4 of Section 35, Township 6 South, Range 4 West to the Southwest corner thereof.

Thence Easterly along the South line of the Northwest 1/4 of said Section 35 to the Southeast corner thereof.

ThenceWesterly along the South line of projected Section 35 and Section 34, Township 2336

6 South, Range 4 West to its intersection with the Northerly Boundary Line of The Santa Rosa Rancho.

Thence Southerly along the West line of the Southeast 1/4 of said Section 35 to the Southwest corner thereof.

Thence Northwesterly and Southwesterly along said boundary line to its intersection with the centerline of Via Serreno.

Thence Southwesterly along said centerline of Via Serreno and the centerline of Hombre Lane to its intersection with the centerline of Avenida La Cresta.

Thence Southeasterly along said centerline of Avenida La Cresta to its intersection with the centerline of Sierra Maria Road.

Thence Northerly along the centerline of Sierra Maria Road to its intersection with the centerline of Buenos Tiempos Road.

Thence Northwesterly along said centerline of Buenos Tiempos Road to its intersection with the centerline of Via Caballos.

Thence Southwesterly and Northwesterly along said centerline of Via Caballos to its intersection with the centerline of Avenida Castilla.

Thence Northeasterly along said centerline of Avenida Castilla to its intersection with the centerline of Avenida La Cresta.

Thence Northwesterly along said centerline of Avenida La Cresta to its intersection with Calle Centro.

Thence Northerly along said centerline of Calle Centro to its intersection with Avenida Arbolos.

Thence Easterly along said centerline of Avenida Arbolos to its intersection with the centerline of Via Majorca.

Thence Northeasterly along said centerline of Via Majorca ot its intersection with Via Vista Grande.

Thence Northeasterly along said centerline of Via Vista Grande to the most Westerly corner of Parcel 7 of Record of Survey recorded in Book 54, Page 59, in The County of Riverside, California.

Thence North 74 Degrees 38'39" East a distance of 532.45'.

Thence North 04 Degrees15'22" East a distance of 800.00'. Thence South 85 Degrees 44'38" East a distance of 4011.73'.
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Thence North 54 Degrees 49'53" East a distance of 1308.88' to the Northeasterly boundary line of The Santa Rosa Rancho.

Thence Southeasterly along said Northeasterly boundary line to the most Easterly corner of Parcel 3 of a Parcel Map recorded in Book 106, Pages 29 through 36, in The County of Riverside, California.

Thence continuingSouth 47 Degrees 19'01" East along said Northeasterly boundary line a distance of 8883.69'.

Thence leaving said boundary line South 41 Degrees 42'23" West a distance of 185.62'. Thence South 13 Degrees 07'27" East a distance of 185.97'.

Thence South 43 Degrees 24'26" West a distance of 1230.44'. Thence South 11 Degrees 33'09" West a distance of 1121.89'.

Thence South 64 Degrees 12'10" West a distance of 1753.24" to an angle point in the boundary of Parcel Map No. 19515 recorded in Book 119, Pages 27 and 28, in the County of Riverside, California.

Thence Southwesterly along said boundary South 85 Degrees 50'07" West a distance of 1083.42'.

Thence North 02 Degrees 26'46" East a distance of 1171.03'. Thence North 51 Degrees 08'17" East a distance of 311.41'.

Thence North 42 Degrees 05'20" West a distance of 443.63'.

Thence North 17 Degrees 33'08" West a distance of 556.92'.

Thence North 03 Degrees 11'26" East a distance of 751.38'.

Thence North 47 Degrees 40'31" West a distance of 226.42'.

Thence South 49 Degrees 25'04" West a distance of 740.54'.

Thence North 54 Degrees 33'51" West a distance of 1187.10'.

Thence North 30 Degrees 57'50" East a distance of 870.64'.

Thence North 79 Degrees 18'05" West a distance of 584.42'.

Thence North 39 Degrees 00'28" West a distance of 386.67'.

Thence South 60 Degrees 08'58" West a distance of 358.06'. 2338

Thence South 35 Degrees 51'19" West a distance of 1063.12'.

Thence North 12 Degrees 26'34" West a distance of 858.58'.

Thence North 30 Degrees 44'33" East a distance of 481.79'.

Thence North 68 Degrees 19'30" West a distance of 462.92'.

Thence South 72 Degrees 55'47" West a distance of 418.38'.

Thence North 79 Degrees 18'03" West a distance of 397.36'.

Thence North 08 Degrees 58'06" East a distance of 701.96'.

Thence North 79 Degrees 34'51" West a distance of 817.94'.

Thence South 69 Degrees 36'06" West a distance of 329.91'.

Thence South 26 Degrees 53'49" West a distance of 580.01'.

Thence South 79 Degrees 38'43" West a distance of 785.06'.

Thence leaving said Parcel Map boundary in a Northwesterly direction North 52 Degrees 24'41" West a distance of 4453.07' to an angle point in the boundary line of Parcel Map No. 19516, recorded in Book 119, Pages 22 through 26, in the County of Riverside, California.

Thence continuing Northwesterly along said boundary line North 69 Degrees 45'26" West a distance of 661.92' to the centerline of Clinton Keith Road as shown on said Parcel Map.

Thence Southerly along said centerline of Clinton Keith Road South 15 Degrees 58'45" West a distance of 1167.82' to the beginning of a tangent curve, concave to the East, and having a radius of 3600.00'.

Thence Southerly along said curve through a central angle of 14 Degrees 21'20" and having a length of 901.99'.

Thence South 01 Degrees 37'25" West a distance of 1010.95' to the beginning of a tangent curve, concave to the East, and having a radius of 6000.00'.

Thence Southerly along said curve through a central angle of 05 Degrees 03'33" and having a length of 529.79'.

Thence South 03 Degrees 26'08" East a distance of 456.53' to the beginning of a tangent curve, concave to the West, and having a radius of 2000.00'.

Thence Southerly along said curve through a central angle of 15 Degrees 40'22" and having a length of 547.08'.
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Thence leaving said centerline in a Westerly direction North 74 Degrees 25'38" West a distance of 7844.89' to an angle point on the most Westerly boundary line of Parcel Map No. 22375, recorded in Book 144, Pages 7 through 10, in The County of Riverside, California.

Thence Southerly along said boundary line South 12 Degrees 47'19" West a distance of 1707.19'.

Thence South 21 Degrees 58'58" West a distance of 3527.68' to a point on the centerline of Sierra Allena as shown on said Parcel Map.

Thence Easterly and Southeasterly along said centerline to its intersection with the centerline of Tenaja Road as shown on said Parcel Map.

Thence Southwesterly and Southerly along said centerline to a point, said point also being an intersection with the centerline of Avocado Mesa as shown on Parcel Map 19516, recorded in Book 77, Page 77, in the County of Riverside, California. Said point also being the beginning of a non-tangent curve, concave to the North, and having a radius of 1400.00'. A radial line from said point bears South 00 Degrees 22'28" West.

Thence Easterly along said curve and said centerline of Avocado Mesa through a central angle of 10 Degrees 04'02" and having a length of 245.99'.

Thence North 80 Degrees 18'26" East a distance of 559.10'.

Thence leaving said centerline along the Southerly boundary line of said Parcel Map South 01 Degrees 58'18" East a distance of 1125.46'.

Thence North 55 Degrees 45'24" East a distance of 819.60'.

Thence South 75 Degrees 03'27" East a distance of 797.86'.

Thence South 47 Degrees 33'58" East a distance of 608.30'.

Thence North 35 Degrees 37'25 East a distance of 978.34'. Thence North 87 Degrees 44'52" East a distance of 839.89'.

Thence North 62 Degrees 38'14" East a distance of 2703.03'.

Thence South 54 Degrees 15'29" East a distance of 617.25'. Thence North 78 Degrees 40'27" East a distance of 1462.83'. Thence South 69 Degrees 27'30" East a distance of 2370.44'. Thence South 20 Degrees 06'29" East a distance of 1570.29'.

Thence North 56 Degrees 07'25" East a distance of 777.48'. Thence North 15 Degrees 23'24" East a distance of 906.54'. Thence North 86 Degrees 25'18" East a distance of 1321.76'. Thence North 65 Degrees 36'25" East a distance of 300.23'. Thence North 19 Degrees 24'52" West a distance of 4974.39'. Thence North 01 Degrees 51'13" East a distance of 785.93'. Thence North 32 Degrees 04'45" West a distance of 380.82'.

Thence North 61 Degrees 22'38" West a distance of 669.33'. 2340

Thence leaving the boundary of said Parcel Map North 45 Degrees 01'03" East a distance of 5251.91' to an angle point in the Northwesterly boundary line said Parcel Map No. 19516.

Thence Southeasterly along said boundary line South 15 Degrees 08'17" East a distance of 1653.19'.

Thence South 27 Degrees 02'39" West a distance of
368.26'. Thence South 02 Degrees 47'23" East a
distance of 742.67'. Thence South 53 Degrees 14'19"
East a distance of 720.31'. Thence South 19 Degrees
31'44" East a distance of 916.70'.

Thence North 84 Degrees 07'41" East a distance of 711.71'.

Thence South 11 Degrees 22'53" East a distance of 424.06'.

Thence South 54 Degrees 58'53" East a distance of 179.72'.

Thence North 61 Degrees 33'54" East a distance of 396.56'.

Thence South 18 Degrees 51'58" East a distance of 636.64'.

Thence North 52 Degrees 26'17" East a distance of
1090.83'. Thence South 54 Degrees 33'49" East a distance of 612.68'. Thence South 13 Degrees 02'07" East a distance of 1024.25'. Thence South 36 Degrees 58'48" East a
distance of 526.98'. Thence South 76 Degrees 34'31" East a distance of 681.25'. Thence South 54 Degrees 54'12" East a distance of 941.25'. Thence North 69 Degrees 28'21" East a distance of 553.52'. Thence South 74 Degrees 21'23" East a distance of 653.97'. Thence North 38 Degrees 52'12" West a distance of 2216.15'. Thence North 28 Degrees 21'03"
East a distance of 456.68'. Thence North 81 Degrees 12'02" East a distance of 709.99'.

Thence leaving the boundary line of said Parcel Map South 24 Degrees 58'52" East a distance of 405.02' to the most westerly corner of Parcel 84 of Parcel Map recorded in Book 2, pages 42 through 68, in The County of Riverside, California.

Thence Northeasterly along the Northwesterly boundary line of said Parcel 84 North 43 Degrees 04'23" East a distance of 1355.03'to the most Westerly corner of Parcel 85 of said Parcel Map.

Thence Northeasterly along the Northwesterly boundary line of said Parcel 85 North 65 Degrees 35'21" East a distance of 1437.56' to the centerline of DeLuz Road.

Thence Northerly and Northeasterly along said centerline to its intersection with the Northeasterly boundary line of The Santa Rosa Rancho.

Thence along said boundary line South 47 Degrees 19'01" East a distance of 6731.56'. Thence South 47 Degrees 18'54" East a distance of 2168.17'.

Thence South 39 Degrees 48'45" East a distance of 5192.67'.

Thence leaving said boundary line North 44 Degrees 52 56" East a distance of 2341

2590.77'. Thence South 45 Degrees 05'53" East a distance of 1431.39'.

Thence South 44 Degrees 55'54" West a distance of 793.37'.

Thence South 38 Degrees 21'30" East a distance of 2638.92' to the beginning of a non-tangent curve, concave to the North, and having a radius of 4550.00'. A radial line bears North 00 Degrees 37'07" West.

Thence Northwesterly along said curve through a central angle of 06 Degrees 19'00" and having a length of 501.62'.

Thence North 83 Degrees 03'53" East a distance of
1140.23'. Thence South 06 Degrees 56'07" East a
distance of 44.00'.

Thence South 26 Degrees 16'04" East a distance of
369.98'. Thence South 00 Degrees 43'59" West a
distance of 259.98'. Thence South 71 Degrees 46'11"
East a distance of 305.00'. Thence South 54 Degrees
16'11" East a distance of 380.00'. Thence South 85
Degrees 16'27" East a distance of 439.97'. Thence
South 53 Degrees 46'16" East a distance of 269.99'.

Thence South 33 Degrees 59'30" East a distance of
348.67'. Thence South 45 Degrees 28'43" East a
distance of 300.81'. Thence South 45 Degrees 30'01"
East a distance of 226.24'. Thence South 45 Degrees
28'43" East a distance of 1954.04'. Thence South 44
Degrees 31'14" West a distance of 206.39'.

Thence South 15 Degrees 39'21" East a distance of
1945.58'. Thence South 45 Degrees 26'04" East a distance 2342

of 1495.92'. Thence South 19 Degrees 54'54" East a
distance of 235.93'. Thence South 70 Degrees 12'40" West a distance of 1495.31'. Thence South 33 Degrees 28'43"
East a distance of 543.70'. Thence South 39 Degrees 45'49" East a distance of 408.24'. Thence South 49 Degrees 04'11" East a distance of 1528.81'. Thence South 50 Degrees
07'21" West a distance of 2306.79'.

Thence North 39 Degrees 47'24" West a distance of 370.04' to the Southeasterly boundary line of The Santa Rosa Rancho.

Thence Southwesterly along said Southeasterly boundary line of the Santa Rosa Rancho to its intersection with the West line of Section 24, Township 8 South, Range 3 West.

Thence Southerly along the West line of said Section 24 and the West line of Sections 25 and 36, Township 8 South, Range 3 West to the Southwest corner thereof. Said corner also being a point on the Southerly boundary line of the County of Riverside, California.

Thence Easterly along said Southerly boundary line to its intersection with the East line of the West 1/2 of the West 1/2 of Section 33, Township 8 South, Range 2 West.

Thence Northerly along the East line of the West 1/2 of the West 1/2 of said Section 33 to the Northeast corner thereof.

Thence Easterly along the South line of the East 1/2 of the West 1/2 of Section 28, Township 8 South, Range 2 West to the Southeast corner thereof.

Thence Northerly along the East line of the East 1/2 of the West 1/2 of said Section 28 to its intersection with the Southeasterly boundary line of the Little Temecula Rancho.

Thence from said intersection Northeasterly to the intersection of the centerline of De Portola Rd. and the centerline of Butterfield Stage Rd.

Thence along said centerline of De Portola Rd. a distance of 1110.00' said point being on a line between the Southeast corner of Section 14, Township 7 South, Range 2 West and the intersection of the North-South quarter section line of Section 28, Township 8 South, Range 2 West with the Southerly boundary line of The Little 2343

Temecula Rancho. Said line hereinafter referred to as Line "A".

Thence along said line "A" South 21 Degrees 03'43" West a distance of 3503.49'.

Thence leaving said line "A" North 83 Degrees 52'28" East a distance of 1391.95' to the beginning of a tangent curve concave to the Northeast and having a radius of 2000.00.

Thence Northwesterly along said curve through a central angle of 01 Degrees 07'57" a distance of 39.53'.

Thence North 22 Degrees 56'22" West a distance of 295.47' to the beginning of a tangent curve concave Southerly and having a radius of 3000.00'.

Thence Easterly along said curve through a central angle of 01 Degrees 24'38" a distance of 73.86'.

Thence tangent from said curve North 81 Degrees 39'22" East a distance of 2497.32' to the beginning of a tangent curve concave Northwesterly and having a radius of 4200.00'.

Thence Easterly along said curve Through a central angle of 10 Degrees 54'22" a distance of 799.46'.

Thence tangent from said curve North 70 Degrees 45'00" East a distance of 51147.52' to the beginning of a tangent curve concave Southerly and having a radius of 4200.00'.

Thence Northeasterly along said curve through a central angle of 17 Degrees 00'24" a distance of 1246.29'.

Thence tangent from said curve North 87 Degrees 45'06" East a distance of 1635.73' to the beginning of a curve concave Northwesterly and having a radius of 6250.00'.

Thence Easterly along said curve through a central angle of 36 Degrees 39'21" a distance of 3998.53'.

Thence tangent from said curve North 51 Degrees 05'45" East a distance of 2355.02' to the beginning of a tangent curve concave Southeasterly and having a radius of 10540.00'.

Thence Easterly along said curve through a central angle of 15 Degrees 30'13" a distance of 2852.04'.

Thence South 20 Degrees 58'19" East a distance of 325.30' to the beginning of a non-tangent curve concave Southerly and having a radius of 3000.00'. A radial line bears North 23 Degrees 23'40" West.
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Thence Southerly along said curve through a central angle of 57 Degrees 07'25" a distance of 2991.74'.

Thence South 86 Degrees 39'42" East a distance of 284.32'.

Thence South 46 Degrees 49'32" East a distance of 555.37'.

Thence South 38 Degrees 39'35" East a distance of 224.11'.

Thence South 51 Degrees 24'55" East a distance of 185.07'.

Thence South 80 Degrees 50'16" East a distance of 157.00'.

Thence North 88 Degrees 31'25" East a distance of 194.06'.

Thence North 62 Degrees 25'22" East a distance of 632.91'.

Thence North 38 Degrees 17'25" East a distance of 435.73'.

Thence North 22 Degrees 28'46" East a distance of 156.92' Thence North 40 Degrees 01'49" East a distance of 163.25'.

Thence South 65 Degrees 57'21" East a distance of 142.35'.

Thence North 10 Degrees 10'09" East a distance of 226.56'.

Thence North 61 Degrees 41'57" East a distance of 295.30'.

Thence North 88 Degrees 27'06" East a distance of 185.07'.

Thence South 66 Degrees 48'05" East a distance of 228.47'.

Thence South 15 Degrees 27'30" East a distance of 420.20'.

Thence South 29 Degrees 10'58" East a distance of 303.53'.

Thence South 43 Degrees 59'42" East a distance of 201.56'.

Thence South 56 Degrees 18'36" East a distance of 246.33'.

Thence South 78 Degrees 06'41" East a distance of 97.08'.

Thence South 01 Degrees 58'03" East a distance of 145.09'.

Thence South 25 Degrees 13'16" East a distance of 152.54'. 2345

Thence North 27 Degrees 26'06" East a distance of 206.19'.

Thence South 49 Degrees 53'57" East a distance of
248.39'. Thence North 87 Degrees 03'51" East a distance of 390.51'. Thence North 68 Degrees 38'01" East a
distance of 397.40'. Thence North 56 Degrees 46'06" East a distance of 173.35'. Thence North 62 Degrees 06'10"
East a distance of 288.53'. Thence North 53 Degrees
23'34" East a distance of 218.00'. Thence South 04
Degrees 23'55" West a distance of 130.38". Thence South 26 Degrees 33'54" West a distance of 368.95'. Thence
South 36 Degrees 09'30" West a distance of 322.02'.

Thence South 27 Degrees 19'26" West a distance of
337.68'.

Thence South 22 Degrees 30'46" West a distance of 445.19' to the beginning of a tangent curve concave Northeasterly and having a radius of 250.00'.

Thence Southeasterly along said curve through a central angle of 112 Degrees 58'16" a distance of 492.93'.

Thence tangent to said curve North 89 Degrees 32'30" East a distance of 247.52'.

Thence South 81 Degrees 07'09" East a distance of 161.94'.

Thence South 13 Degrees 14'26" West a distance of

87.32'. Thence South 73 Degrees 14'15" East a distance of

86.68'. Thence North 19 Degrees 17'24" East a distance of 127.14'. Thence North 77 Degrees 49'43" East a distance of 260.86'. Thence South 85 Degrees 41'60" East a
distance of 133.38'. Thence North 62 Degrees 51'01" East 2346

a distance of 131.49'. Thence North 78 Degrees 41'24"
East a distance of 127.48' Thence South 69 Degrees 26'38" East a distance of 128.16'.

Thence South 42 Degrees 46'03" East a distance of
544.89'. Thence North 25 Degrees 38'28" East a distance of 544.89'. Thence South 49 Degrees 53'57" East a
distance of 248.39'. Thence South 17 Degrees 06'10" East a distance of 136.01'. Thence North 11 Degrees 04'13"
East a distance of 234.36'. Thence South 86 Degrees
54'21" East a distance of 185.27'. Thence South 09
Degrees 51'57" East a distance of 116.73'. Thence North 46 Degrees 32'54" East a distance of 130.86'. Thence
North 82 Degrees 114'05" East a distance of 111.02'.

Thence South 71 Degrees 33'54" East a distance of
110.68'. Thence South 20 Degrees 11'39" East a distance of 92.70'.

Thence South 00 Degrees 58'16" West a distance of
118.02'. Thence South 17 Degrees 44'41" West a distance of 131.24'. Thence North 71 Degrees 04'31" East a
distance of 185.00'. Thence North 23 Degrees 11'55" East a distance of 190.39'. Thence South 75 Degrees 57'50"
East a distance of 103.08'. Thence South 23 Degrees
57'45" East a distance of 147.73'. Thence South 33
Degrees 18'38" East a distance of 209.40'. Thence North 2347

58 Degrees 14'26" East a distance of 123.49'. Thence
South 72 Degrees 05'22" East a distance of 276.39'.

Thence South 06 Degrees 52'54" West a distance of
292.10'. Thence South 22 Degrees 39'34" West a distance of 111.62'. Thence South 44 Degrees 20'02" West a
distance of 121.63'.

Thence South 16 Degrees 14'20" East a distance of
107.28'. Thence South 06 Degrees 28'59" West a distance of 132.85'. Thence South 38 Degrees 13'13" West a
distance of 101.83'. Thence South 02 Degrees 07'16" East a distance of 270.19'. Thence South 34 Degrees 31'41"
West a distance of 303.45'. Thence South 29 Degrees
21'28" West a distance of 91.79'. Thence South 11
Degrees 33'36" East a distance of 224.56'. Thence South 04 Degrees 05'08" West a distance of 140.36'. Thence
South 41 Degrees 11'09" West a distance of 106.30'.

Thence South 11 Degrees 46'06" West a distance of
122.58'. Thence South 23 Degrees 11'55" West a distance of 114.24'. Thence South 53 Degrees 07'48" West a
distance of 125.00'.

Thence South 38 Degrees 59'28" West a distance of 96.30' to the beginning of a tangent curve concave Northwesterly and having a radius of 325.00'.

Thence Westerly along said curve through a central angle of 56 Degrees 17'56" a distance of 319.35'.

Thence tangent to said curve North 84 Degrees 42'36" West a distance of 97.26'. 2348

Thence South 78 Degrees 53'13" West a distance of 130.45' to the beginning of a tangent curve concave Southeasterly and having a radius of 75.00'.

Thence Southerly along said curve through a central angle of 128 Degrees 19'41" a distance of 167.98'.

Thence tangent to said curve South 49 Degrees 26'28" East a distance of 137.31'.

Thence South 86 Degrees 33'09" East a distance of 83.15'.

Thence South 31 Degrees 13'35" West a distance of
187.11'. Thence North 82 Degrees 14'05" East a distance of 111.02'.

Thence South 36 Degrees 42'10" West a distance of 205.80'.

Thence South 78 Degrees 115'57" West a distance of 255.34 to the beginning of a tangent curve concave Easterly and having a distance of 30.00'.

Thence Southerly along said curve through a central angle of 142 Degrees 41'04" a distance of 74.71'.

Thence tangent to said curve South 64 Degrees 25'07" East a distance of 223.80'.

Thence South 59 Degrees 02'10" East a distance of 145.77'.

Thence South 39 Degrees 02'08" East a distance of
238.17'. Thence West a distance of 170.00'.

Thence South 25 Degrees 12'04" East a distance of 187.88'.

Thence South 36 Degrees 52'12" East a distance of 102.01' to the beginning of a tangent curve concave Westerly and having a radius of 95.00'.

Thence Southerly along said curve through a central angle of 91 Degrees 46'27" a distance of 152.17'.

Thence tangent to said curve South 54 Degrees 54'15" West a distance of 128.12'.

Thence South 68 Degrees 27'32" West a distance of 204.27'.

Thence South 41 Degrees 11'09" West a distance of
2349

106.30'. Thence South 81 Degrees 01'39" West a distance of 96.28'. Thence South 03 Degrees 00'46" East a distance of 95.13'. Thence South 39 Degrees 59'13" West a distance of 202.30'. Thence South 07 Degrees 07'30" East a
distance of 241.87'. Thence South 55 Degrees 29'29" West a distance of 291.25'.

Thence South 77 Degrees 04'26" West a distance of 120.28' to the beginning of a tangent curve concave Southeasterly and having a radius of 300.00'.

Thence Westerly along said curve through a central angle of 65 Degrees 24'53" a distance of 342.51'.

Thence North 65 Degrees 00'00" East a distance of
125.00'. Thence North 55 Degrees 00'29" East a
distance of 122.07'. Thence North 72 Degrees 53'50"
East a distance of 204.02'. Thence North 81 Degrees
42'51" East a distance of 416.35'. Thence East a
distance of 50.00'.

Thence North 19 Degrees 39'14" West a distance of
193.26'. Thence North 39 Degrees 48'20" East a
distance of 101.53'. Thence North 17 Degrees 39'00"
East 115.43'.

Thence North 32 Degrees 32'30" East 124.56'.

Thence North 47 Degrees 24'48" East a distance of
184.72'. Thence South 04 Degrees 21'25" West a distance of 105.30'. Thence South 30 Degrees 52'00" East a
distance of 101.36'. Thence South 47 Degrees 45'22" East 2350

a distance of 145.78'. Thence North 55 Degrees 26'15"
East a distance of 109.29'. Thence South 89 Degrees
27'16" East a distance of 210.01'. Thence South 27
Degrees 12'58" East a distance of 393.57'. Thence South 33 Degrees 41'24" East a distance of 108.17'. Thence
South 66 Degrees 48'05" East a distance of 114.24'.

Thence South 27 Degrees 17'58" East a distance of
174.43'. Thence North 16 Degrees 41'57" East a distance of 104.40'. Thence North 74 Degrees 49'38" East a
distance of 183.39'. Thence South 74 Degrees 11'51" East a distance of 110.16'. Thence North 10 Degrees 18'17"
East a distance of 134.16'.

Thence South 86 Degrees 11'09" West a distance of
120.27'. Thence South 76 Degrees 33'05" West a distance of 94.59'. Thence North 66 Degrees 22'14" West a distance of 174.64'. Thence North 43 Degrees 34'04" West a
distance of 113.17'. Thence North 00 Degrees 46'27" West a distance of 148.01'. Thence East a distance of 110.00'.

Thence North 73 Degrees 47'28" East a distance of 83.84' to the beginning of a tangent curve concave Northwesterly and having a radius of 180.00'.

Thence Easterly along said curve through a central angle of 55 Degrees 47'13" a distance of 175.26'.

Thence tangent to said curve North 18 Degrees 00'15" East 157.08'. Thence East a distance of 130.00'.

Thence North 06 Degrees 37'57" West a distance of
2351

173.16'. Thence North 66 Degrees 25'31" West a
distance of 120.02'. Thence North 24 Degrees 05'15"
West a distance of 93.11'.

Thence North 40 Degrees 47'41" East a distance of

96.43'. Thence North 01 Degrees 28'08" West a
distance of 117.04'.

Thence North 75 Degrees 41'20" East a distance of
101.14'. Thence North 34 Degrees 59'31" West a
distance of 122.07'. Thence South 87 Degrees 16'25"
East a distance of 210.24'. Thence North 15 Degrees
51'22" West a distance of 277.22'. Thence North 15
Degrees 56'43" West a distance of 109.20'. Thence
North 19 Degrees 08'01" West a distance of 259.33'.

Thence South 87 Degrees 47'51" East a distance of
130.10'. Thence South 68 Degrees 11'55" East a
distance of 107.70'.

Thence South 51 Degrees 20'25" East a distance of
192.09'. Thence North 13 Degrees 12'04" West a distance of 166.40'. Thence South 80 Degrees 45'52" East a
distance of 124.62'. Thence North 33 Degrees 10'43" West a distance of 155.32'. Thence North 53 Degrees 15'09"
East a distance of 93.60'. Thence North 85 Degrees 06'03" East a distance of 140.51'. Thence South 72 Degrees
53'50" East a distance of 136.02'. Thence North 76
Degrees 51'10" East a distance of 140.69'. Thence North 2352

80 Degrees 52'11" West a distance of 113.44'. Thence
North 52 Degrees 07'30" West a distance of 114.02'.

Thence North 76 Degrees 45'34" West a distance of
174.64'. Thence South 86 Degrees 03'17" West a distance of 145.34'. Thence North 40 Degrees 54'52" East a
distance of 99.25'.

Thence North 50 Degrees 11'40" East a distance of
195.26'. Thence North 03 Degrees 10'47" East a distance of 90.14'. Thence North 48 Degrees 07'20" East a distance of 194.74'. Thence South 79 Degrees 02'45" East a
distance of 157.88'. Thence North 14 Degrees 51'01" West a distance of 136.56'. Thence North 83 Degrees 22'45"
East a distance of 112.75'. Thence North 25 Degrees
10'25" West a distance of 110.49'. Thence North 36
Degrees 28'09" West a distance of 143.00'. Thence North 57 Degrees 59'41" East a distance of 94.34'. Thence North 29 Degrees 03'17" East a distance of 102.96'.

Thence North 59 Degrees 02'10" West a distance of 87.46' Thence North 01 Degrees 47'24" East a distance of
160.08'. Thence North 14 Degrees 11'37" West a distance of 265.09'. Thence North 22 Degrees 55'56" West a
distance of 141.16'. Thence North 03 Degrees 24'23" West a distance of 168.30'. Thence South 67 Degrees 54'46"
2353

East a distance of 372.32'. Thence South 80 Degrees
13'03" East a distance of 176.57'. Thence South 42
Degrees 17'14" East a distance of 283.87'. Thence South 41 Degrees 49'13" West a distance of 127.48'. Thence
South 30 Degrees 22'45" West a distance of 168.08'.

Thence South 65 Degrees 39'32" West a distance of
230.49'. Thence South 79 Degrees 27'58" East a distance of 246.15'. Thence South 20 Degrees 28'20" East a
distance of 80.06' Thence South 27 Degrees 00'46" West a distance of 286.23'. Thence South 11 Degrees 53'19" West a distance of 194.16'. Thence South 03 Degrees 21'59"
East a distance of 170.29'. Thence South 28 Degrees
26'34" East a distance of 272.95'. Thence South 05
Degrees 48'24" East a distance of 296.52'. Thence South 39 Degrees 28'21" East a distance of 110.11'. Thence
South 71 Degrees 33'54" East a distance of 94.87'. Thence South 04 Degrees 23'55" East a distance of 130.38'.

Thence South 21 Degrees 20'13" East a distance of
343.55'. Thence North 43 Degrees 31'52" East a distance of 137.93'.

Thence South 62 Degrees 14'29" East a distance of
107.35'. Thence South 14 Degrees 02'10" East a distance of 144.31'. Thence South 26 Degrees 33'54" East a
2354

distance of 122.98'. Thence North 19 Degrees 39'14" East a distance of 222.99'. Thence South 80 Degrees 32'16"
East a distance of 91.24'. Thence South 23 Degrees 52'06" East a distance of 123.57'. Thence North 49 Degrees
23'55" East a distance of 92.20'. Thence South 85 Degrees 06'03" East a distance of 140.51'. Thence South 02
Degrees 43'35" West a distance of 105.12'. Thence North 59 Degrees 32'04" East a distance of 98.62'.

Thence South 56 Degrees 18'36" East a distance of 90.14'.

Thence North 87 Degrees 42'34" East a distance of
125.10'. Thence North 80 Degrees 04'26" East a distance of 203.04'. Thence North 74 Degrees 21'28" East a
distance of 129.81'. Thence South 33 Degrees 16'30" East a distance of 191.38'. Thence South 31 Degrees 25'47"
West a distance of 105.48'. Thence South 08 Degrees
52'51" West a distance of 129.55'. Thence North 73
Degrees 18'03" East a distance of 167.04'. Thence South 01 Degrees 35'28" East a distance of 180.07'. Thence
South 17 Degrees 01'14" West a distance of 102.49'.

Thence South 80 Degrees 44'39" East a distance of
136.78'. Thence South 19 Degrees 42'51" West a distance of 127.47'. Thence South 61 Degrees 36'25" West a
distance of 252.36'.
2355

Thence North 79 Degrees 37'27" East a distance of 228.72' to the beginning of a tangent curve concave Southwesterly and having a radius of 80.00'.

Thence Southerly along said curve through a central angle of 117 Degrees 37'57" a distance of 164.25'.

Thence tangent to said curve South 17 Degrees 15'24" West a distance of 113.90'.

Thence North 67 Degrees 02'10" East a distance of 128.16'.

Thence South 11 Degrees 46'06" West a distance of
122.58'. Thence South 72 Degrees 38'46" West a distance of 167.63'. Thence South 67 Degrees 53'26" East a
distance of 172.70'. Thence South 21 Degrees 02'15" East a distance of 139.28'. Thence South 46 Degrees 50'51"
West a distance of 109.66'. Thence South 69 Degrees
08'44" East a distance of 112.36'. Thence North 38
Degrees 17'25" East a distance of 242.07'. Thence South 43 Degrees 52'36" East a distance of 180.35'. Thence
North 41 Degrees 59'14" East a distance of 134.54'.

Thence South 49 Degrees 14'11" East a distance of
191.44'. Thence South 03 Degrees 41'29" West a distance of 155.32'. Thence South 26 Degrees 33'54" West a
distance of 111.80'. Thence South 03 Degrees 34'35" East a distance of 160.31'. Thence North 50 Degrees 37'51"
East a distance of 252.24'. Thence South 74 Degrees
03'17" East a distance of 109.20'. Thence North 27
Degrees 33'10" East a distance of 103.77'. Thence North 2356

32 Degrees 44'07" West a distance of 199.72'. Thence
North 26 Degrees 33'54" East a distance of 100.62'.

Thence North 88 Degrees 21'48" East a distance of
105.04'. Thence North 72 Degrees 04'56" East a
distance of 315.29'. Thence South 60 Degrees 15'18"
East a distance of 161.25'. Thence East a distance of

72.00'.

Thence South 20 Degrees 15'57" East a distance of
138.58'. Thence South 33 Degrees 10'43" West a distance of 155.32'. Thence North 87 Degrees 36'51" East a
distance of 120.10'. Thence South 05 Degrees 54'22" West a distance of 145.77'. Thence South 30 Degrees 15'23"
West a distance of 138.92'. Thence South 04 Degrees
45'49" East a distance of 120.42'. Thence South 15
Degrees 25'20" West a distance of 150.42'. Thence South a distance of 235.00'.

Thence South 06 Degrees 34'55" East a distance of
130.86'. Thence South 08 Degrees 58'21" West a distance of 192.35'. Thence South 51 Degrees 48'33" East a
distance of 95.43'. Thence South 28 Degrees 47'12" West a distance of 103.83'. Thence South 14 Degrees 02'10"
East a distance of 103.08'. Thence South 05 Degrees
11'40" West a distance of 165.68'. Thence South 22
2357

Degrees 50'01" East a distance of 103.08'. Thence South 61 Degrees 11'21" West a distance of 114.13'. Thence
South 71 Degrees 33'54" East a distance of 126.49'.

Thence South 05 Degrees 26'25" East a distance of
105.48'. Thence South 46 Degrees 32'54" East a distance of 130.86'.

Thence South 41 Degrees 20'52" East a distance of
133.21'. Thence South 50 Degrees 49'15" East a distance of 292.84'. Thence South 10 Degrees 00'29" East a
distance of 86.31'. Thence South 45 Degrees 00'00" East a distance of 205.06'. Thence South a distance of 130.00'.

Thence North 86 Degrees 25'25" East a distance of
320.62'. Thence South 60 Degrees 01'06" East a distance of 150.08'. Thence South 24 Degrees 26'38" East a
distance of 120.83'. Thence South 49 Degrees 41'09" East a distance of 216.39'. Thence North 55 Degrees 42'47"
East a distance of 266.27'. Thence North 62 Degrees
02'56" East a distance of 277.35'. Thence North 72
Degrees 21'00" East a distance of 230.87'. Thence North 59 Degrees 02'10" East a distance of 204.08'. Thence
North 77 Degrees 00'19" East a distance of 133.42'.

Thence North 47 Degrees 07'16" East a distance of 95.52'.

Thence North 24 Degrees 13'40" East a distance of
2358

109.66'. Thence North 43 Degrees 09'09" East a distance of 219.32'. Thence North 55 Degrees 00'29" East a
distance of 122.07'. Thence North 49 Degrees 11'06" West a distance of 145.34'. Thence North 68 Degrees 37'46"
East a distance of 123.49'.

Thence North 82 Degrees 41'39" East a distance of
196.60'. Thence South 63 Degrees 26'06" East a
distance of 212.43'. Thence South 49 Degrees 23'55"
East a distance of 92.20'.

Thence South 71 Degrees 50'02" East a distance of
336.79'. Thence South 43 Degrees 15'51" East a
distance of 233.45'. Thence South 47 Degrees 01'17"
East a distance of 300.71'. Thence South 42 Degrees
11'04" East a distance of 215.93'. Thence South 48
Degrees 53'16" East a distance of 365.00'. Thence
South 47 Degrees 47'51" East a distance of 280.00'.

Thence South 71 Degrees 42'59" East a distance of 500.00' to the beginning of a tangent curve concave Southwesterly and having a radius of 2500.00'.

Thence Easterly along said curve through a central angle of 17 Degrees 31'51" to a point on the East boundary line of The Pauba Rancho.

Thence Southwesterly along said rancho boundary line to the most Southeasterly corner thereof.

Thence Westerly along said rancho boundary line to the Northwest corner of Section 24, Township 8 South, Range 1 West.

Thence Southerly along the West line of said Section 24 to the Southwest corner thereof. Thence Easterly along the South line of said Section 24 to the Southeast corner thereof.

Thence Southerly along the West line of Section 30, Township 8 South, Range 1 2359

East to the Southwest corner thereof.

Thence Easterly along the South line of said Section 30 and the South line of Section 29, Township 8 South, Range 1 East to the Southeast corner thereof.

Thence Southerly along the West line of Section 33, Township 8 South, Range 1 East to the Southwest corner thereof. Said corner also being a point in the Southerly boundary line of the County of Riverside, California.

Thence Easterly along said Southerly boundary line to its intersection with the East line of Section 35, Township 8 South, Range 1 East.

Thence Northerly along the East line of said Section 35 to the Northeast corner thereof.

Thence Westerly along the North line of said Section 35 to the Northwest corner thereof.

Thence Northerly along the East line of Sections 27 and 22, Township 8 South, Range 1 East to the Northeast corner thereof.

Thence Easterly along the South line of the West 1/2 and the West 1/2 of the East 1/2 of Section 14, Township 8 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the West 1/2 of the East 1/2 of said Section 14 to the Northeast corner thereof.

Thence Westerly along the North line of said Section 14 and the North line of Section 15, Township 8 South, Range 1 East to the Northwest corner thereof.

Thence Southerly along the West line of said Section 15 and the West line of Section 22, Township 8 South, Range 1 East to the Southwest corner thereof.

Thence Westerly along the North line of Sections 28 and 29, Township 8 South, Range 1 East to the Northwest corner thereof.

Thence Northerly along the East line of Section 19, Township 8 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of said Section 19 to the Northwest corner thereof.

Thence Northerly along the East line of Section 13, Township 8 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of said Section 13 to its intersection with the Easterly boundary line of the Pauba Rancho.

Thence Southwesterly along said rancho boundary line a distance of 3800.00'.

Thence leaving said rancho boundary line South 77 Degrees 12'23" West a distance of 1542.24' to the beginning of a non-tangent curve concave Northeasterly and having a radius of 600.00'. A radial line bears North 03 Degrees 16'45" East.
2360

Thence Westerly along said curve through a central angle of 35 Degrees 39'40" a distance of 373.44'.

Thence leaving said curve North 33 Degrees 45'20" East a distance of 484.24'. Thence North 47 Degrees 46'03" East a distance of 700.84'.

Thence North 54 Degrees 32'56" East a distance of
152.89'. Thence North 82 Degrees 13'56" East a
distance of 187.36'. Thence North 87 Degrees 54'05"
East a distance of 390.53'. Thence North 78 Degrees
01'53" East a distance of 201.31'.

Thence South 80 Degrees 36'13" East a distance of 353.91' to a point on the Easterly boundary line of The Pauba Rancho.

Thence along said rancho boundary line North 13 Degrees 35'32" East a distance of 224.85'.

Thence North 80 Degrees 21'04" West a distance of 630.44'.

Thence South 87 Degrees 33'13" West a distance of
511.46'. Thence South 72 Degrees 43'11" West a distance of 184.78'. Thence South 59 Degrees 31'31" West a
distance of 429.17'. Thence South 67 Degrees 09'37" West a distance of 577.07'. Thence South 29 Degrees 09'59"
West a distance of 480.00'. Thence South 46 Degrees
38'12" West a distance of 123.79'. Thence North 85
Degrees 01'49" West a distance of 230.87'. Thence North 55 Degrees 48'50" West a distance of 120.00'. Thence
North 19 Degrees 42'53" East a distance of 191.37'.

Thence North 39 Degrees 18'41" East a distance of
406.86'. Thence North 41 Degrees 53'28" East a distance of 609.71'. Thence North 37 Degrees 14'26" East a
distance of 60.83'.
2361

Thence North 52 Degrees 27'24" West a distance of 80.09'.

Thence South 60 Degrees 33'10" West a distance of
553.62'. Thence South 37 Degrees 53'43" West a distance of 800.00'. Thence South 54 Degrees 41'20" West a
distance of 147.05'. Thence West a distance of 160.00'.

Thence South 78 Degrees 31'05" West a distance of
326.53'. Thence South 72 Degrees 33'10" West a distance of 183.44'. Thence North 59 Degrees 32'04" West a
distance of 98.62'. Thence South 80 Degrees 32'16" West a distance of 121.66'. Thence North 78 Degrees 13'54"
West a distance of 122.58'. Thence North 60 Degrees
15'18" West a distance of 161.25'. Thence North 34
Degrees 17'13" West a distance of 133.14'. Thence North 12 Degrees 05'41" East a distance of 143.18'. Thence
North 79 Degrees 00'41" West a distance of 104.92'.

Thence North 11 Degrees 18'36" West a distance of
112.18'. Thence North 21 Degrees 48'05" West a distance of 107.70'. Thence North 08 Degrees 07'48" West a
distance of 282.84'. Thence North 70 Degrees 33'36" East a distance of 90.14'. Thence North 49 Degrees 45'49" West a distance of 170.29'. Thence North 15 Degrees 22'35"
West a distance of 207.42'. Thence North 51 Degrees
50'34" East a distance of 178.04'. Thence South 58
Degrees 23'13" East a distance of 152.64'. Thence South 85 Degrees 36'05" East a distance of 130.38'. Thence
North 45 Degrees 00'00" West a distance of 169.71'.

Thence North 40 Degrees 36'05" East a distance of 92.20'. 2362

Thence North 59 Degrees 20'57" West a distance of
156.92'. Thence South 83 Degrees 39'35" East a distance of 90.55'. Thence North 70 Degrees 20'46" West a distance of 148.66'. Thence South 34 Degrees 22'49" West a
distance of 115.11'. Thence South 54 Degrees 09'44" West a distance of 111.02'. Thence North 69 Degrees 08'44"
West a distance of 112.36'. Thence North 39 Degrees
24'03" East a distance of 362.35'. Thence South 70
Degrees 01'01" West a distance of 117.05'. Thence South 54 Degrees 14'46" West a distance of 154.03'. Thence
North 34 Degrees 59'31" West a distance of 122.07'.

Thence North 09 Degrees 39'36" East a distance of
238.38'. Thence North 77 Degrees 35'33" East a distance of 255.98'. Thence North 35 Degrees 32'16" West a
distance of 86.02'. Thence North 55 Degrees 42'47" East a distance of 266.27'. Thence North 87 Degrees 08'15" East a distance of 200.25'. Thence North 63 Degrees 26'06"
East a distance of 223.61'.

Thence South 86 Degrees 59'14" West a distance of
190.26'. Thence North 74 Degrees 28'33" West a distance of 280.22'. Thence North 11 Degrees 53'19" West a
distance of 97.08'. Thence South 15 Degrees 49'09" West a distance of 187.09'. Thence South 67 Degrees 22'48"
West 130.00'.

Thence South 61 Degrees 23'22" West a distance of
125.30'. Thence North 06 Degrees 06'56" East a distance of 140.80'. Thence North 07 Degrees 07'30" West a
2363

distance of 120.93'. Thence South 29 Degrees 03'17" West a distance of 102.96'. Thence South 68 Degrees 11'55"
West a distance of 107.70'. Thence North 20 Degrees
00'15" East a distance of 149.03'. Thence North 13
Degrees 11'26" East a distance of 328.67'. Thence North 00 Degrees 40'56" West a distance of 420.00'. Thence
North 50 Degrees 42'38" West a distance of 142.13'.

Thence North 22 Degrees 50'01" West a distance of
103.08'. Thence North 43 Degrees 01'30" West a distance of 102.59'. Thence North 21 Degrees 48'05" West a
distance of 107.70'. Thence North 47 Degrees 36'09" West a distance of 155.72'.

Thence North 77 Degrees 28'16" West a distance of 58.37' to the beginning of a tangent curve concave Northeasterly and having a radius of 125.00'.

Thence Northerly along said curve through a central angle of 90 Degrees 27'57" a distance of 197.37'.

Thence tangent to said curve North 12 Degrees 59'41" East a distance of

74.10'. Thence North 85 Degrees 14'10" East a distance of 120.42'.

Thence South 79 Degrees 06'52" East a distance of
132.38'. Thence East a distance of 120.00'.

Thence North 77 Degrees 28'16" East a distance of 507.70'.

Thence South 88 Degrees 05'27" East a distance of
300.17'. Thence South 51 Degrees 20'25" East a distance of 96.05'. Thence North 81 Degrees 24'59" East a distance of 268.00'. Thence North 52 Degrees 07'30" West a
distance of 171.03'. Thence North 31 Degrees 15'49" East a distance of 163.78'. Thence North 52 Degrees 48'55"
East a distance of 182.00'. Thence North 41 Degrees
2364

49'13" East a distance of 127.48'. Thence North 27
Degrees 17'59" East a distance of 174.43'. Thence North 43 Degrees 36'10" East a distance of 145.00'. Thence
North 72 Degrees 07'17" East a distance of 162.86'.

Thence North 51 Degrees 50'34" West a distance of 89.02'.

Thence North 05 Degrees 11'40" East a distance of
110.45'. Thence North 15 Degrees 04'07" East a distance of 134.63'. Thence North 72 Degrees 28'28" East a
distance of 99.62'. Thence North 54 Degrees 27'44" West a distance of 86.02'. Thence North 11 Degrees 00'13" West a distance of 183.37'. Thence North 79 Degrees 54'29"
East a distance of 228.54'. Thence South 68 Degrees
33'08" East a distance of 150.42'. Thence North 03
Degrees 56'43" East a distance of 145.34'. Thence North 56 Degrees 18'36" East a distance of 144.22'. Thence
South 37 Degrees 18'14" East a distance of 132.00'.

Thence South 46 Degrees 07'24" East a distance of
180.35'. Thence South 47 Degrees 38'33" East a distance of 230.05'. Thence North 03 Degrees 21'59" East a
distance of 85.15'. Thence North 17 Degrees 21'14" East a distance of 83.82'. Thence North 22 Degrees 46'57" West a distance of 271.15'. Thence North 61 Degrees 41'57"
East a distance of 147.65'.

Thence South 21 Degrees 58'28" East a distance of 196.17' to the beginning of a tangent curve concave Northeasterly and having a radius of 120.00'.

Thence Easterly along said curve through a central angle of 85 Degrees 37'05" a distance of 179.32'.

Thence tangent to said curve North 72 Degrees 24'27" East a distance of 103.90'. 2365

Thence North 56 Degrees 18'36" East a distance of 90.14'.

Thence South 58 Degrees 40'17" East a distance of
134.63'. Thence South 39 Degrees 17'22" East a distance of 142.13'. Thence North 10 Degrees 07'29" East a
distance of 142.21'. Thence North 08 Degrees 21'57" West a distance of 171.83'. Thence North 36 Degrees 15'14"
West a distance of 186.01'. Thence North 59 Degrees
32'04" East a distance of 98.62'. Thence North 82 Degrees 05'34" East a distance of 181.73'. Thence North 65
Degrees 43'32" East a distance of 279.73'. Thence North 46 Degrees 23'50" East a distance of 145.00'. Thence
North 35 Degrees 50'16" East a distance of 111.02'.

Thence North 59 Degrees 02'10" East a distance of
204.08'. Thence North 35 Degrees 45'14" East a distance of 154.03'. Thence North 55 Degrees 55'22" East a
distance of 205.24'. Thence North 75 Degrees 46'26" East a distance of 366.23'. Thence North 68 Degrees 11'55"
East a distance of 188.48'. Thence North 74 Degrees
57'44" East a distance of 346.88'. Thence North 66
Degrees 15'02" East a distance of 136.57'. Thence North 30 Degrees 34'45" East a distance of 127.77'. Thence
North 11 Degrees 58'34" West a distance of 168.67'.

Thence South 60 Degrees 38'32" East a distance of 91.79'.

Thence South 34 Degrees 59'31" East a distance of
122.07'.

Thence South 41 Degrees 38'01" East a distance of 120.42' .

Thence North 12 Degrees 31'44" West a distance of 92.20'. 2366

Thence South 81 Degrees 28'09" East a distance of
101.12'. Thence North 67 Degrees 50'01" West a distance of 145.77'.

Thence South 75 Degrees 59'45" East a distance of 915.00' to a point on the Easterly boundary line of The Pauba Rancho.

Thence along said rancho boundary line North 13 Degrees 35'32" East a distance of 655.26'.

Thence leaving said rancho boundary line North 44 Degrees 20'36" West a distance of
114.98' to the beginning of a tangent curve concave Easterly and having a radius of 150.00'.

Thence Northerly along said curve through a central angle of 105 Degrees 00'00 a distance of 274.89'.

Thence tangent from said curve North 60 Degrees 39'24" East a distance of 150.00'. Thence North 06 Degrees 50'36" West a distance of 92.39'.

Thence North 74 Degrees 20'36" West a distance of
300.00'. Thence North 70 Degrees 45'43" West a distance of 491.69'. Thence North 48 Degrees 04'02" West a
distance of 505.79'. Thence North 18 Degrees 21'47" East a distance of 458.89'. Thence South 87 Degrees 10'09"
West a distance of 1250.40'. Thence South 08 Degrees
12'01" West a distance of 385.08'. Thence South 27
Degrees 12'07" East a distance of 223.45'. Thence South 13 Degrees 42'18" West a distance of 120.01'. Thence
South 77 Degrees 25'51" West a distance of 631.86'.

Thence North 45 Degrees 05'45" West a distance of
178.80'. Thence North 23 Degrees 39'02" West a distance of 724.70'. Thence North 34 Degrees 49'03" West a
distance of 211.87'. Thence North 62 Degrees 41'17" West a distance of 254.81.' Thence North 86 Degrees 37'15"
West a distance of 334.80'.
2367

Thence South 66 Degrees 05'48" West a distance of
261.74'. Thence South 67 Degrees 10'15" West a distance of 293.59'. Thence South 85 Degrees 01'36" West a
distance of 375.77'. Thence North 85 Degrees 49'14" West a distance of 446.34'. Thence North 57 Degrees 51'27"
West a distance of 292.38'. Thence North 29 Degrees
42'26" West a distance of 214.87'. Thence North 07
Degrees 53'17" East a distance of 210.39'. Thence North 35 Degrees 38'42" East a distance of 394.07'. Thence
North 86 Degrees 55'06" West a distance of 417.69'.

Thence South 43 Degrees 16'41" West a distance of
211.99'. Thence South 15 Degrees 17'49" West a distance of 573.11'. Thence South 41 Degrees 49'02" West a
distance of 255.56'. Thence South 38 Degrees 27'42" East a distance of 391.47'. Thence South 13 Degrees 21'05"
East a distance of 767.66'.

Thence South 14 Degrees 02'10" East a distance of 176.87' to the beginning of a tangent curve concave Westerly and having a radius of 140.00'.

Thence Southerly along said curve through a central angle of 39 Degrees 14'14" a distance of 95.88'.

Thence tangent to said curve South 25 Degrees 12'04" West a distance of 17.44' to the beginning of a tangent curve concave Northerly and having a radius of

50.00'.

Thence Westerly along said curve through a central angle of 134 Degrees 56'37" a distance of 117.76'.

Thence tangent to said curve North 19 Degrees 51'19" West a distance of

70.84'. Thence West a distance of 80.00'.

Thence South a distance of 130.00'.

Thence North 70 Degrees 01'01" West a distance of
117.05'. Thence South 22 Degrees 14'56" West a distance 2368

of 118.85'. Thence South 62 Degrees 06'10" East a
distance of 96.18'. Thence South 16 Degrees 18'50" West a distance of 213.60'.

Thence South 72 Degrees 28'28" West a distance of

99.62'. Thence North 48 Degrees 48'51" West a distance
of 106.30'. Thence South 41 Degrees 11'09" West a
distance of 159.45'. Thence North 23 Degrees 57'45" West a distance of 98.49'. Thence South 71 Degrees 33'54"
West a distance of 94.87'. Thence North 53 Degrees 36'56" West a distance of 118.00'. Thence North 23 Degrees
25'43" East a distance of 163.48'. Thence North 06
Degrees 20'25" West a distance of 90.55'. Thence North
23 Degrees 11'55" East a distance of 76.16'.

Thence South 48 Degrees 48'51" West a distance of
106.30'. Thence South 33 Degrees 41'24" West a distance of 108.17'. Thence South 48 Degrees 10'47" West a
distance of 127.48'. Thence North 12 Degrees 31'44" West a distance of 138.29'. Thence South 82 Degrees 24'19"
West a distance of 75.66'. Thence North 11 Degrees 18'36" West a distance of 50.99'. Thence North 71 Degrees 33'54" West a distance of 63.25'. Thence North 08 Degrees 07'48" West a distance of 70.71'. Thence South 75 Degrees
04'07" West a distance of 155.24'. Thence North 81
Degrees 52'12" West a distance of 106.07'. Thence South 34 Degrees 41'43" West a distance of 79.06'. Thence
South 69 Degrees 26'38" West a distance of 128.016'.

Thence North 80 Degrees 32'16" West a distance of 91.24'. 2369

Thence South 63 Degrees 26'06" West a distance of

67.08'. Thence North 33 Degrees 41'24" West a
distance of 72.11'. Thence West a distance of
130.00'.

Thence North 18 Degrees 26'06" East a distance of 73.99' to the beginning of a tangent curve concave Southeasterly and having a radius of 150.00'.

Thence Easterly along said curve through a central angle of 58 Degrees 34'13" a distance of 153.34'.

Thence tangent to said curve North 77 Degrees 00'19" East a distance of 182.70'.

Thence North 40 Degrees 36'05" East a distance of 92.20'.

Thence North 66 Degrees 02'15" West a distance of 98.49'.

Thence North 29 Degrees 21'28" West a distance of 91.79'.

Thence North 77 Degrees 54'19" West a distance of 71.59'.

Thence South 62 Degrees 21'14" West a distance of
118.53'. Thence North 02 Degrees 12'09" East a distance of 130.10'. Thence North 17 Degrees 39'00" West a
distance of 115.43'. Thence North a distance of 85.00'.

Thence South 62 Degrees 06'10" West a distance of

96.18'. Thence South 16 Degrees 59'27" West a distance
of 188.22'. Thence South 36 Degrees 01'39" West a
distance of 136.02'. Thence South 15 Degrees 56'43" West a distance of 145.60'. Thence South 37 Degrees 34'07"
West a distance of 82.01'. Thence South 18 Degrees
26'06" West a distance of 79.06'. Thence North 83 Degrees 36'35" West a distance of 135.83'. Thence South 62
Degrees 06'10" West a distance of 96.18'. Thence North
26 Degrees 33'54" West a distance of 78.26'. Thence North 38 Degrees 59'28" East a distance of 135.09'. Thence
2370

North 54 Degrees 46'57" East a distance of 104.04'.

Thence North 20 Degrees 19'23" East a distance of
143.96'. Thence North 05 Degrees 21'21" East a distance of 321.40'. Thence South 31 Degrees 49'39" West a
distance of 170.66'. Thence South 12 Degrees 31'34" West a distance of 92.20'. Thence South 40 Degrees 06'03" West a distance of 124.20'.

Thence South 76 Degrees 36'27" West a distance of
107.94'. Thence South 55 Degrees 29'29" West a distance of 97.08'. Thence South 19 Degrees 39'14" West a
distance of 74.33'. Thence North 82 Degrees 52'30" West a distance of 80.62'. Thence South 12 Degrees 05'41" West a distance of 143.18'. Thence South 86 Degrees 43'46"
West a distance of 175.29'. Thence South 46 Degrees
16'23" West a distance of 159.14'. Thence West a distance of 70.00'.

Thence North 42 Degrees 16'25" West a distance of 74.33'.

Thence North a distance of 105.00'.

Thence North 78 Degrees 01'26" West a distance of
168.67'. Thence North 56 Degrees 18'36" West a distance of 126.10'. Thence North 60 Degrees 15'18" East a
distance of 120.93'. Thence South 87 Degrees 30'37" East a distance of 115.11'. Thence North 60 Degrees 38'32"
East a distance of 183.58'. Thence North 73 Degrees
00'33" East a distance of 188.22'. Thence North 76
Degrees 45'34" West a distance of 174.64'. Thence North 01 Degrees 38'12" West a distance of 175.07'. Thence
2371

North 08 Degrees 31'51" West a distance of 303.36'.

Thence South 39 Degrees 48'20" West a distance of

78.10'. Thence South 05 Degrees 26'25" East a distance of 105.48'. Thence South 15 Degrees 38'32" West a distance of 129.81'. Thence South 03 Degrees 34'35" West a
distance of 80.16'. Thence South 31 Degrees 25'47" West a distance of 105.48'. Thence North 43 Degrees 09'09"
West a distance of 109.66'. Thence South 25 Degrees
27'48" West a distance of 116.30'.

Thence North 59 Degrees 44'37" West a distance of
138.92'. Thence North 80 Degrees 04'26" West a distance of 203.04'. Thence South 51 Degrees 20'25" West a
distance of 96.05'. Thence South 20 Degrees 33'22" West a distance of 85.44'. Thence South 82 Degrees 38'51" West a distance of 312.57'. Thence South 57 Degrees 22'51"
West a distance of 148.41'. Thence North 29 Degrees
14'56" East a distance of 143.27'. Thence North 10
Degrees 26'15" East a distance of 193.20'. Thence South 41 Degrees 25'25" West a distance of 113.36'. Thence
South 33 Degrees 01'26" West a distance of 119.27'.

Thence South 83 Degrees 17'25" West a distance of
171.17'. Thence North 40 Degrees 21'52" West a distance of 131.24'. Thence North 04 Degrees 34'10" East a
distance of 125.45'. Thence North 07 Degrees 35'45" West a distance of 75.61'. Thence North 36 Degrees 23'04" East a distance of 118.00'. Thence South 71 Degrees 01'47"
West a distance of 169.19'. Thence South 36 Degrees
2372

52'12" West a distance of 100.00'. Thence North 05
Degrees 42'38" East a distance of 100.50'. Thence 38
Degrees 22'03" East a distance of 153.05'.

Thence North 31 Degrees 40'32" East a distance of
276.13'. Thence North a distance of 125.00'.

Thence North 14 Degrees 02'10" East a distance of
144.31'. Thence North 45 Degrees 00'00" East a distance of 141.42'. Thence North 06 Degrees 50'34" West a
distance of 125.90'. Thence South 45 Degrees 00'00" West a distance of 113.14'. Thence South 21 Degrees 02'15"
West a distance of 69.64'. Thence North 75 Degrees 04'07" West a distance of 77.62'.

Thence North 11 Degrees 46'05" West a distance of
122.58'. Thence North 27 Degrees 45'31" West a distance of 107.35'. Thence South 02 Degrees 07'16" West a
distance of 135.09'. Thence South 06 Degrees 34'55" West a distance of 130.86'. Thence South 04 Degrees 34'26"
East a distance of 125.40'. Thence South 11 Degrees
00'13" West a distance of 183.37'. Thence South 63
Degrees 26'06" West a distance of 145.34'. Thence South 38 Degrees 39'35" West a distance of 96.35'. Thence
South 70 Degrees 42'36" West a distance of 105.95'.

Thence South 25 Degrees 38'28" West a distance of
138.65'. Thence North 33 Degrees 41'24" West a distance of 108.17'. Thence North 09 Degrees 43'39" East a
distance of 177.55'. Thence North 18 Degrees 26'06" East a distance of 110.68'. Thence North 49 Degrees 05'08"
2373

West a distance of 99.25'. Thence South 12 Degrees
31'44" West a distance of 92.20'. Thence North 71 Degrees 33'54" West a distance of 94.87'. Thence South 02
Degrees 43'35" East a distance of 105.12'. Thence South 57 Degrees 22'51" West a distance of 148.41'. Thence
North 59 Degrees 02'10" West a distance of 87.46'.

Thence South 89 Degrees 07'55" West a distance of 174.53' to the beginning of a tangent curve concave Easterly and having a radius of 25.00'.

Thence Southerly along said curve through a central angle of 161 Degrees 44'04" a distance of 70.57'.

Thence tangent to said curve North 70 Degrees 51'59" East a distance of 103.82'.

Thence North 32 Degrees 44'07" East a distance of 83.22'.

Thence North 10 Degrees 05'51" West a distance of 74.15'.

Thence North 33 Degrees 00'11" East a distance of
115.66'.

Thence North 19 Degrees 21'32" East a distance of
196.09'. Thence North 23 Degrees 57'45" West a distance of 98.49'. Thence North 20 Degrees 51'16" East a distance of 112.36'. Thence South 67 Degrees 45'04" West a
distance of 118.85'. Thence South 10 Degrees 32'21" West a distance of 218.69'. Thence South 87 Degrees 08'15"
West a distance of 100.12'. Thence South 08 Degrees
44'46" East a distance of 65.75'. Thence South 49 Degrees 05'08" West a distance of 99.25'. Thence North 30 Degrees 57'50" West a distance of 145.77'. Thence South 14
Degrees 32'04" West a distance of 139.46'. Thence North 67 Degrees 50'01" West a distance of 145.77'. thence
South a distance of 90.00'.
2374

Thence South 25 Degrees 51'59" West a distance of
183.37'. Thence North 54 Degrees 09'44" West a distance of 111.02'. Thence North 02 Degrees 56'09" West a
distance of 195.26'. Thence North 27 Degrees 45'31" East a distance of 107.35'. Thence North 23 Degrees 29'55"
West a distance of 125.40'. Thence South 20 Degrees
37'48" West a distance of 454.12'. Thence South 07
Degrees 18'21" East a distance of 196.60'. Thence North 78 Degrees 13'54" West a distance of 122.58'. Thence
North 12 Degrees 59'41" West a distance of 200.12'.

Thence North 08 Degrees 58'21" East a distance of
192.35'. Thence North a distance of 205.05'.

Thence North 29 Degrees 44'42" West a distance of
241.87'. Thence South 02 Degrees 17'26" East a
distance of 125.10'. Thence South 10 Degrees 29'29"
East a distance of 137.30'. Thence South 15 Degrees
56'43" West a distance of 145.60'.

Thence South 33 Degrees 41'24" West a distance of
108.17'. Thence South 23 Degrees 57'45" West a distance of 98.49'. Thence South 16 Degrees 35'14" West a distance of 245.20'. Thence South 68 Degrees 57'45" West a
distance of 139.28'. Thence North a distance of 95.01'.

Thence South 54 Degrees 27'44" West a distance of

86.02'. Thence North 10 Degrees 18'17" West a distance
of 111.80'. Thence North 02 Degrees 23'09" East a
distance of 120.10'. Thence North 04 Degrees 23'55" West a distance of 130.38'. Thence North 38 Degrees 39'35"
2375

West a distance of 128.06'. Thence South 07 Degrees
54'26" East a distance of 181.73'. Thence South 16
Degrees 41'57" West a distance of 156.60'. Thence South 08 Degrees 31'51" West a distance of 202.24'. Thence
South 82 Degrees 52'30" West a distance of 80.62'.

Thence North 26 Degrees 33'54" East a distance of
111.80'. Thence North 05 Degrees 42'38" West a distance of 100.50'. Thence North 32 Degrees 37'09" West a
distance of 148.41'. Thence North 47 Degrees 38'33" West a distance of 230.05'. Thence North 84 Degrees 41'08"
West a distance of 215.93'. Thence North a distance of

90.03'.

Thence South 30 Degrees 34'45" West a distance of
127.77'. Thence South 59 Degrees 32'04" East a distance of 197.23'. Thence South 12 Degrees 31'44" East a
distance of 92.20'. Thence South 66 Degrees 22'14" East a distance of 87.32'. Thence South 39 Degrees 33'35" East a distance of 119.16'. Thence South 26 Degrees 33'54"
West a distance of 167.71'.

Thence South 10 Degrees 18'17" West a distance of
111.80'. Thence South 45 Degrees 00'00" East a distance of 98.99'. Thence East a distance of 100.00'.

Thence South 23 Degrees 57'45" East a distance of 98.49'.

Thence South 45 Degrees 00'00" East a distance of
113.14'. Thence South 41 Degrees 38'01" West a distance of 120.42'. Thence South 77 Degrees 28'16" West a
distance of 138.29'. Thence South 87 Degrees 56'17" West 2376

a distance of 139.09'. Thence South 30 Degrees 57'55"
West a distance of 93.29'. Thence North 82 Degrees 45'20" West a distance of 118.95'. Thence South 37 Degrees
34'07" West a distance of 246.02'. Thence North 54
Degrees 09'44" West a distance of 111.02'. Thence North 86 Degrees 25'25" West a distance of 160.31'. Thence
South 49 Degrees 45'49" West a distance of 85.15'.

Thence North 61 Degrees 36'25" West a distance of
210.30'. Thence South 84 Degrees 30'28" West a distance of 261.20'. Thence North 75 Degrees 57'50" West a
distance of 268.00'. Thence South 71 Degrees 06'50" West a distance of 200.81'. Thence North 59 Degrees 25'15"
West a distance of 127.77'. Thence North 45 Degrees
00'00" West a distance of 212.13'. Thence North 78
Degrees 41'24" West a distance of 127.48'. Thence North 49 Degrees 14'11" West a distance of 114.87'. Thence
South 85 Degrees 42'00" West a distance of 133.38'.

Thence North 86 Degrees 22'01" West a distance of
315.63'. Thence South 47 Degrees 36'09" West a distance of 155.72'. Thence North 74 Degrees 44'42" West a
distance of 114.02'. Thence South 67 Degrees 22'48" West a distance of 260.00'.

Thence North 11 Degrees 00'13" West a distance of
183.37'. Thence North 14 Degrees 55'53" East a
distance of 155.24'. Thence North 67 Degrees 45'04"
East a distance of 118.85'. Thence South 73 Degrees
29'44" East a distance of 140.80'. Thence North 34
2377

Degrees 35'32" West a distance of 176.14'. Thence
North 19 Degrees 32'12" East a distance of 164.47'.

Thence North 75 Degrees 10'25" East a distance of
175.86'. Thence North 25 Degrees 16'40" West a
distance of 199.06'. Thence North 33 Degrees 30'12"
East a distance of 425.73'. Thence North 03 Degrees
30'50" East a distance of 571.07'. Thence North 47
Degrees 02'43" West a distance of 198.12'. Thence
South 78 Degrees 41'24" West a distance of 356.93'.

Thence South 86 Degrees 59'14" West a distance of
380.53'. Thence South 63 Degrees 26'06" West a
distance of 301.87'. Thence South 58 Degrees 46'54"
West a distance of 192.94'. Thence South 39 Degrees
33'35" West a distance of 149.16'. Thence South 75
Degrees 15'23" West a distance of 196.47'. Thence
North 77 Degrees 11'45" West a distance of 225.61'.

Thence North 65 Degrees 53'52" West a distance of
208.15'. Thence North 31 Degrees 14'21" West a
distance of 356.72'. Thence North 25 Degrees 36'56"
West a distance of 809.57'. Thence North 55 Degrees
05'51" West a distance of 262.15'. Thence North 82
Degrees 28'03" West a distance of 244.11'. Thence
South 60 Degrees 10'08" West a distance of 164.84'.

Thence South 71 Degrees 43'56" West a distance of
542.33'. Thence South 37 Degrees 24'19" West a
distance of 214.01'.

Thence South 47 Degrees 21'12" West a distance of
2378

206.65'. Thence South 34 Degrees 23'22" West a
distance of 545.31'. Thence South 47 Degrees 29'23"
West a distance of 162.79'. Thence North 87 Degrees
13'47" West a distance of 310.36'. Thence North 50
Degrees 11'40" West a distance of 117.15'. Thence
North 69 Degrees 46'30" West a distance of 202.48'.

Thence North 38 Degrees 59'28" West a distance of
135.09'. Thence North 23 Degrees 47'35" West a
distance of 240.44'. Thence North 01 Degrees 38'12"
West a distance of 280.10'. Thence North 40 Degrees
36'05" East a distance of 92.20'.

Thence North 03 Degrees 04'44" East a distance of 181.92'.

Thence North 54 Degrees 46'57" West a distance of 1546.13' to the beginning of a tangent curve concave Southerly and having a radius of 1000.00'.

Thence Northwesterly and westerly along said curve through a central angle of 29 Degrees 44'48" a distance of 519.18'.

Thence tangent to said curve North 84 Degrees 31'45" West a distance of 492.72' to the Southeasterly corner of Parcel 7 of Parcel Map 38 as recorded in Book 4, Pages 12 through 13, records of Riverside County, California.

Thence Northeasterly to a turning point in the boundary line of The Pauba Rancho.

Said point lies in the North 1/2 of Section 5, Township 8 South, Range 1 West.

Thence leaving said boundary line on a Northeasterly bearing to a point. Said point being an intersection of the East line of Section 8, Township 7 South, Range 1 West with the Northerly boundary line of the Pauba Rancho.

Thence Northerly along the East line of said Section 8 and the East line of Section 5, Township 7 South, Range 1 West to the Northeast corner thereof.

ThenceWesterly along the North line of said Section 5 and the North line of the East 1/2 of Section 6, Township 7 South, Range 1 West to the Northwest corner thereof.

Thence Northerly along the East line of the West 1/2 of Sections 31 and 30, Township 6 South, Range 1 West to the Northeast corner thereof.

Thence Easterly along the South line of the East 1/2 of Section 19, Township 6 South, Range 1 West to the Southeast corner thereof.
2379

Thence Northerly along the East line of said Section 19 to the Northeast corner thereof.

Thence Easterly along the South line of the West 1/2 of the West 1/2 of Section 17, Township 6 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the West 1/2 of the West 1/2 of said Section 17 to the Northeast corner thereof.

Thence Easterly along the South line of the East 1/2 of the West 1/2 of Section 8, Township 6 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the East 1/2 of the West 1/2 of said Section 8 to the Northeast corner thereof.

Thence Easterly along the South line of the Southeast 1/4 of Section 5, Township 6 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the Southeast 1/4 of said Section 5 to the Northeast corner thereof.

Thence Easterly along the South line of the Northwest 1/4 of Section 4, Township 6 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the Northwest 1/4 of said Section 4 to the Northeast corner thereof.

Thence Easterly along the South line of the Southeast 1/4 of Section 33 and the South line of the Southwest 1/4 of Section 34, Township 5 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the Southwest 1/4 of said Section 34 to the Northeast corner thereof.

Thence Easterly along the South line of the Northeast 1/4 of said Section 34 and the South line of the South 1/2 of the North 1/2 of Section 35, Township 5 South, Range 1 West to the Southeast corner thereof.

Thence Northerly along the East line of the South 1/2 of the North 1/2 of said Section 35 to the Northeast corner thereof.

Thence Easterly along the South line of the North 1/2 of the North 1/2 of Section 36, Township 5 South, Range 1 West and the South line of the North 1/2 of the North 1/2 of Section 31, Township 5 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the North 1/2 of the North 1/2 of said Section 31 to the Northeast corner thereof.

Thence Easterly along the South line of the South 1/2 of Section 29 and 28, Township 5 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the South 1/2 of said Section 28 to the Northeast corner thereof.
2380

Thence Easterly along the South line of the Northwest 1/4 of Section 27, Township 5 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the Northwest 1/4 of said Section 27 to the Northeast corner thereof.

Thence Easterly along the South line of the East 1/2 of Section 22 and the South line of the West 1/2 of the West 1/2 of Section 23 to the Southeast corner thereof.

Thence Northerly along the East line of the West 1/2 of the West 1/2 of said Section 23 to the Northeast corner thereof.

ThenceWesterly along the North line of theWest 1/2 of theWest 1/2 of said Section 23 to the Northwest corner thereof.

Thence Northerly along the East line of the East 1/2 of Section 15, Township 5 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the East 1/2 of said Section 15 to the Northwest corner thereof.

Thence Northerly along the East line of the West 1/2 of Sections 10 and 3, Township 5 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the West 1/2 of said Section 3 to the Northwest corner thereof.

Thence Northerly along the East line of the East 1/2 of Section 33, Township 4 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the East 1/2 of said Section 33 to the Northwest corner thereof.

Thence Northerly along the East line of the Southwest 1/4 of Section 28, Township 4 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the Southwest 1/4 of said Section 28 to the Northwest corner thereof.

Thence Northerly along the East line of the Northeast 1/4 of Section 29, Township 4 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the Northeast 1/4 of said Section 29 to the Northwest corner thereof.

Thence Northerly along the East line of the Southwest 1/4 of Section 20, Township 4 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the Southwest 1/4 of said Section 20 to the Northwest corner thereof.

Thence Northerly along the East line of the Northeast 1/4 of Section 19, Township 4 2381

South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the Northeast 1/4 of said Section 19 to the Northwest corner thereof.

Thence Northerly along the East line of the Southwest 1/4 of Section 18, Township 4 South, Range 1 East to the Northeast corner thereof.

Thence Westerly along the North line of the Southwest 1/4 of said Section 18 and the North line of the Southeast 1/4 of Section 13, Township 4 South, Range 1 West to the Northeast corner thereof.

Thence Northerly along the East line of the Northwest 1/4 of said Section 13 to the Northeast corner thereof.

Thence Westerly along the North line of the Northwest 1/4 of said Section 13 to the Northwest corner thereof.

Thence Northerly along the East line of the South 1/2 of Section 11, Township 4 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of the South 1/2 of said Section 11 to the Northwest corner thereof.

Thence Northerly along the East line of the Northeast 1/4 of Section 10, Township 4 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of the Northeast 1/4 of said Section 10 to the Northwest corner thereof.

Thence Northerly along the East line of the Southwest 1/4 of Section 3, Township 4 South, Range 1 West to the Northeast corner thereof.

Thence Easterly along the South line of the South 1/2 of the Northeast 1/4 of said Section 3 to the Southeast corner thereof.

Thence Northerly along the East line of the South 1/2 of the Northeast 1/4 of said Section 3 to the Northeast corner thereof.

Thence Easterly along the South line of the North 1/2 of the North 1/2 of Sections 2 and 1, Township 4 South, Range 1 West and the South line of the Northwest 1/4 of the Northwest 1/4 of Section 6, Township 4 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the Northwest 1/4 of the Northwest 1/4 of said Section 6 to the Northeast corner thereof.

Thence Easterly along the South line of the West 1/2 and the South line of the West 1/2 of the East 1/2 of Section 31, Township 3 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of the West 1/2 of the East 1/2 of said Section 31 to the Northeast corner thereof.
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Thence Easterly along the South line of the East 1/2 of the East 1/2 of Section 30,
Township 3 South, Range 1 East to the Southeast corner thereof.

Thence Northerly along the East line of said Section 30 to the Northeast corner thereof. Thence Westerly along the North line of said Section 30 to the Northwest corner thereof.

Thence Northerly along the East line of the North 1/2 of Section 25 and the East line of the South 1/2 of Section 24, Township 3 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of the South 1/2 of said Section 24 and the North line of the Southeast 1/4 of Section 23, Township 3 South, Range 1 West to the Northwest corner thereof.

Thence Southerly along the West line of the Southeast 1/4 of said Section 23 and the West line of the East 1/2 of Section 26 and the West line of the Northeast 1/4 of Section 35, Township 3 South, Range 1 West to the Southwest corner thereof.

Thence Westerly along the North line of the Southwest 1/4 of said Section 35 and the North line of the Southeast 1/4 and the North line of the East 1/2 of the Southwest 1/4 of Section 34, Township 3 South, Range 1 West to the Northwest corner thereof.

Thence Westerly along the North line of the West 1/2 of the Northwest 1/4 of Section 3 and the North line of Section 4, Township 3 South, Range 1 West to the Northwest corner thereof.

Thence Northerly along the East line of the Section 32, Township 3 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of said Section 32 to the Northwest corner thereof.

Thence Northerly along the East line of Section 30, Township 3 South, Range 1 West to the Northeast corner thereof.

Thence Westerly along the North line of the said Section 30 to the Northwest corner thereof.

Thence Northerly along the East line of the East 1/2 of Section 24, Township 3 South, Range 2 West to the Northeast corner thereof.

Thence Westerly along the North line of the East 1/2 of said Section 24 to the Northwest corner thereof.

Thence Northerly along the East line of the West 1/2 of Sections 13 and 12, Township 3 South, Range 2 West to the Northeast corner thereof.

Thence Westerly along the North line of the West 1/2 of said Section 12 and the North line of Sections 11 and 10, Township 3 South, Range 2 West to the 2383

Northwest corner thereof.

Thence Northerly along theEast line of Section 4, Township 3South, Range 2West to the Northeast corner thereof.

Thence Westerly along the North line of said Section 4 to the Northwest corner thereof.

Thence Northerly along the East line of the South 1/2 of Section 32, Township 2 South, Range 2 West to the Northeast corner thereof.

Thence Westerly along the North line of the South 1/2 of said Section 32 of the Northwest corner thereof.

Thence Northerly along the East line of the North 1/2 of Section 31, Township 2 South, Range 2 West to the Northeast corner thereof.

Thence Westerly along the North line of said Section 31 to the Northwest corner thereof.

Thence Northerly along the East line of the Southeast 1/4 of Section 25, Township 2 South, Range 3 West to the Northeast corner thereof.

Thence Westerly along the North line of the Southeast 1/4 of said Section 25 to the Northwest corner thereof.

Thence Northerly along the East line of the Northwest 1/4 of said Section 25 to the Northeast corner thereof.

Thence Westerly along the North line of the Northwest 1/4 of said Section 25 to the Northwest corner thereof.

Thence Northerly along the East line of the South 1/2 of Section 23, Township 2 South, Range 3 West to the Northeast corner thereof.

Thence Westerly along the North line of the South 1/2 of said Section 23 to the Northwest corner thereof.

Thence Northerly along the East line of the North 1/2 of Section 22, Township 2 South, Range 3 West to the Northeast corner thereof.

Thence Westerly along the North line of the North 1/2 of said Section 22 to the Northwest corner thereof.

Thence Northerly along the East line of the South 1/2 of Section 16, Township 2 South, Range 3 West to the Northeast corner thereof.

Thence Westerly along the North line of the South 1/2 of said Section 16 to the Northwest corner thereof.

Thence Northerly along the East line of the North 1/2 of Section 17, Township 2 South, Range 3 West to the Northeast corner thereof. Said point also being a point in the Northerly boundary line of the County of Riverside, California. 2384

Thence following said boundary line Westerly, Northerly and Westerly to the TRUE POINT OF BEGINNING.
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1 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
ORDINANCE NO. 2026-XX

AN ORDINANCE OF THE CITY OF MORENO VALLEY AMENDING
CHAPTER 8.60 – THREATENED AND ENDANGERED SPECIES, OF

THE MORENO VALLEY MUNICIPAL CODE, TO ADOPT AND
IMPLEMENT THE UPDATED 2026 STEPHENS’ KANGAROO RAT
(SKR) HABITAT CONSERVATION PLAN MITIGATION FEE

ESTABLISHED BY THE RIVERSIDE COUNTY HABITAT

CONSERVATION AGENCY (RCHCA)
The City Council of the City of Moreno Valley Ordains as Follows:

Section 1. TITLE.

This ordinance shall be known as the 2026 Stephens' Kangaroo Rat Mitigation Fee Ordinance.

Section 2. FINDINGS.

The City of Moreno Valley finds and determines that:
(a) The Stephens' Kangaroo Rat is listed as a threatened species by the State of California Department of Fish and Wildlife.
(b) The U.S. Fish and Wildlife Service has listed the Stephens' Kangaroo Rat as an endangered species, effective October 31, 1988, pursuant to the Federal Endangered Species Act of 1973, 16 U.S.C. Section 1531 et. seq., which was downlisted to threatened on March 21, 2022. (c) Following the federal listing of the Stephens' Kangaroo Rat as a threatened species, occupied habitat of the species may not be altered without a Section 10(a) permit issued by the Secretary of the Interior. All requests for a Section 10(a) permit must be accompanied by a Habitat Conservation Plan approved by the U.S. Fish and Wildlife Service. Said permit will then allow for the loss of occupied habitat due to development on the basis that the Habitat Conservation Plan will provide protection for the species and guarantee its survival.
(d) Development within the historic range of the Stephens' Kangaroo Rat has resulted in loss and degradation of occupied Stephens' Kangaroo Rat habitat, increased isolation of Stephens' Kangaroo Rat populations, reduction of potential habitat areas for future colonization, and elimination of corridors which allow the species to relocate as environmental conditions warrant.
(e) The Stephens' Kangaroo Rat's survival cannot be insured on small, isolated acreages surrounded by, or in close proximity to, development or human populations.
(f) Impacts to the Stephens' Kangaroo Rat are not limited to loss or degradation of actually occupied habitat only.
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2 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
(g) The successful completion and implementation of a Habitat Conservation Plan for the Stephens' Kangaroo Rat would be jeopardized by not implementing a procedure that requires review of each proposed development within the Fee Assessment Area to determine the best means of mitigating impacts to the Stephens' Kangaroo Rat.
(h) Each proposed development project shall be reviewed to determine the most appropriate course of action to ensure the survival of the species through one or more of the following: (1) on-site mitigation of impacts to the Stephens' Kangaroo Rat through the reservation or addition of lands included within or immediately adjacent to a potential habitat reserve site, or (2) payment of the Mitigation Fee set by this ordinance or (3) any combination of (1) and (2) consistent with the intent and purpose of this ordinance. A proposed development project may be referred, for review, to Federal and State resource agencies based upon criteria which may be established and agreed upon by the City and said agencies. (I) A program providing for off-site project mitigation in accordance with the development of a Habitat Conservation Plan will provide a mechanism for establishing sufficient habitat areas which can be effectively protected and managed for the Stephens' Kangaroo Rat's survival and recovery. (j) The Stephens’ Kangaroo Rat Habitat Conservation Plan provides a regional conservation and permitting framework necessary to allow development within the SKR Plan Area. All Mitigation Fees collected pursuant to the provisions of this ordinance shall be used for the development, preparation and implementation of a Habitat Conservation Plan for the Stephens' Kangaroo Rat, including, but not limited to, the management of habitat reserve sites, and for the application of a Section 10(a) permit under the Federal Endangered Species Act of 1973, as well as authorization to take the species pursuant to the California Endangered Species Act.
(k) Adoption of this ordinance will provide mitigation for projects within the historical range of the Stephens' Kangaroo Rat allowing said projects to proceed during the implementation of the updated Habitat Conservation Plan for the Stephens' Kangaroo Rat, provided said projects are not located in areas identified as and meeting the criteria for potential habitat reserve sites needed for the conservation of the species. The approval of such development projects could jeopardize the survival of the species and therefore would be inconsistent with a Habitat Conservation Plan, even if the Mitigation Fee is paid.
(l) Adoption and implementation of this ordinance demonstrates the City’s intent to cooperate with federal and state agencies to provide for the survival of the Stephens' Kangaroo Rat.
(m) The passage of this ordinance is intended to be consistent with the requirements of state and federal environmental legislation, including the California Environmental Quality Act.
(n) The Riverside County Habitat Conservation Agency Board of Directors adopted the 2026 SKR Habitat Conservation Plan Nexus Study on July 9, 2387
3 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
2026.
(o) The Nexus Study was made publicly available at least 30 days prior to the public hearing in compliance with Government Code section 66016. (p) The Nexus Study establishes the reasonable relationship and proportionality required under Government Code section 66001. (q) The City of Moreno Valley has reviewed and considered the Nexus Study and incorporates it herein by reference.

Section 3. PURPOSE.

The purpose of this Ordinance is to fund implementation of the Updated Stephens’ Kangaroo Rat Habitat Conservation Plan to maintain incidental take authorization for development within the SKR Plan Area. It is the further purpose of this ordinance to provide a method for mitigation of impacts to the Stephens' Kangaroo Rat caused by the loss of its habitat due to development during the implementation of the Updated Habitat Conservation Plan and provide for habitat mitigation to be identified in the Habitat Conservation Plan. Mitigation of impacts to the Stephens' Kangaroo Rat will be accomplished through the review of each proposed development project within the Fee Assessment Area to determine whether on-site mitigation through the reservation or addition of lands included within or immediately adjacent to a potential habitat reserve site or payment of the Mitigation Fee or a combination of both is appropriate and furthers the ultimate Habitat Conservation Plan objectives. A proposed development project may be referred, for review, to Federal and State resource agencies based upon criteria which may be established and agreed upon by the City and said agencies.

This ordinance provides for the establishment of this review process and satisfaction of on-site mitigation to protect potential habitat reserve sites or payment of the Mitigation Fee or a combination of both, which upon implementation will satisfy U.S. Fish and Wildlife Service, California Department of Fish and Wildlife.

Section 4. DEFINITIONS.

As used in this ordinance, the following terms shall have the following meanings:
(a) CITY COUNCIL. The City Council for the city of Moreno Valley. (b) CERTIFICATE OF OCCUPANCY. "Certificate of Occupancy" shall mean a certificate of occupancy as defined by Ordinance No. 457 or state law.
(c) CITY. The city of Moreno Valley
(d) DEVELOPMENT PERMIT. City approval of a tentative tract map, tentative parcel map, conditional use permit, public use permit, plot plan, surface mining permit, or grading permit pursuant to the provisions of all applicable city ordinances. Where a development project has been previously reviewed and approved pursuant to the provisions of this ordinance, any subsequent implementing development permit shall not be 2388
4 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
subject to further review under this ordinance.
(e) FEE ASSESSMENT AREA. All real property located within the area as described in Section 5 of this ordinance.
(f) FINAL INSPECTION. "Final Inspection" shall mean a final inspection as defined by Ordinance No. 457 or state law.
(g) HABITAT CONSERVATION PLAN. A plan prepared pursuant to Section 10(a) of the Federal Endangered Species Act of 1973, 16 U.S.C. Section 1539.
(h) MITIGATION FEE. The fee imposed pursuant to the provisions of this ordinance.
(i) PARCEL. All real property for which a development permit is applied for. (j) RESIDENTIAL UNIT. A building or portion thereof used by one (1) family and containing but one (1) kitchen and designed for single family residential purposes only.
(k) SECTION 10(a) PERMIT. A permit issued by the Secretary of the Interior pursuant to Section 10(a) of the Federal Endangered Species Act of 1973, 16 U.S.C. Section 1539.
(l) STEPHENS' KANGAROO RAT. An animal species known as Dipodomys Stephensi.
(m) GRADING PERMIT. "Grading Permit" shall mean a grading permit as defined by Ordinance No. 457, provided, however, that for purposes of this ordinance, 'grading permit' shall not include the following:
(1) A grading permit wherein grading was previously performed pursuant to a grading permit issued within one (1) year prior to November 15, 1988, and subsequently inspected and approved by the City of Moreno Valley Building and Safety. In addition, the area to be graded pursuant to said permit shall be the same or substantially the same area previously graded.
(2) A grading permit for real property upon which a detached or attached second unit will be constructed pursuant to Sections 18.28a and

18.28b of Ordinance 348.

Section 5. DESIGNATION OF THE FEE ASSESSMENT AREA.
(SEE ATTACHMENT A TO THIS ORDINANCE)
Section 6. MITIGATION FEE.

All applicants for development permits within the boundaries of the Fee Assessment Area who cannot satisfy mitigation requirements through on-site mitigation as determined through the environmental review process shall pay a Mitigation Fee of $900.00 per gross acre of the parcels proposed for development. However, for singlefamily residences on a single legally created lot, where the building permit is issued to an individual property owner and is not part of a subdivision, tract development, or any coordinated multi-unit residential development, a Mitigation Fee of $250.00 shall be paid; 2389
5 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
and for agricultural development which requires a development permit excluding the construction of single family residences in connection with said agricultural development, a Mitigation Fee of $500 per gross acre shall be paid.

Section 7. IMPOSITION OF FEE.

No development permit for real property located within the boundaries of the Fee Assessment Area shall be issued or approved except upon the condition that on-site mitigation will be provided as determined through the environmental review process or the Mitigation Fee required by this ordinance be paid, and it is determined that said development will not jeopardize the implementation of a Habitat Conservation Plan for the Stephens' Kangaroo Rat.

Section 8. PAYMENT OF FEE.

The Mitigation Fee shall be paid upon issuance of a grading permit or a certificate of occupancy or upon final inspection, whichever occurs first. Payment of the Mitigation Fee shall satisfy City conditions of approval previously placed on development permits with regard to impact mitigation for the Stephens' Kangaroo Rat which have not been previously satisfied and no further review and approval pursuant to the provisions of this ordinance shall be required.

For a parcel subject to a surface mining permit, the Mitigation Fee due pursuant to the provisions of this ordinance shall be paid prior to the commencement of the mining operation or in the alternative, may be paid in increments upon submission of an application for a special inspection permit under Ordinance No. 555 prior to the commencement of each phase of the mining operation authorized by the surface mining permit. Each increment of payment shall be equal to $1,950.00 multiplied by the sum of (1) the total number of surface acres of land within the applicable phase pursuant to the surface mining permit and (2) the quotient which results from dividing the total number of acres of land covered by the surface mining permit and subject to this ordinance, which are prohibited from disturbance or designated as setback or buffer areas pursuant to the surface mining permit, by the total number of approved phases. The total number of surface acres of land within each phase shall be determined through a physical survey prepared by a licensed surveyor or registered civil engineer.

Section 8.1. DEFERRAL OF PAYMENT OF THE FEE.

At the option of the applicant for a grading permit, payment of the Mitigation Fee may be deferred until the issuance of the first building permit within the parcels proposed for development. Prior to issuance of the grading permit, an instrument shall be recorded by the applicant in the City of Moreno Valley Public Works / Engineering Department which gives notice that prior to issuance of the first building permit, the entire Mitigation Fee as calculated prior to issuance of the grading permit shall be required to be paid.
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6 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
Section 9. REDUCTION FOR NON-PROFIT ENTITIES.

The fees required pursuant to Section 6 shall be reduced by 75 percent for non-profit entities. For purposes of this section, non-profit entities shall be defined as those entities identified in 26 U.S.C. Section 501(c)(3).

Section 10. EXEMPTIONS.

For purposes of this ordinance, the following types of development shall not be required to pay the Mitigation Fee unless such development voluntarily participates in order to mitigate the disturbance of occupied Stephens' Kangaroo Rat habitat:
(a) Reconstruction of any structure damaged or destroyed by fire or other natural causes;
(b) Rehabilitation or remodeling of existing structures, or additions to existing structures;
(c) Development of any parcel for which the California Department of Fish and Wildlife and United States Fish and Wildlife Service has approved other mitigation procedures;
(d) Development of any parcel used by local, state or federal entities for governmental purposes (i.e. public works, schools);
(e) Development of any parcel for which the Mitigation Fee has been previously paid. However, in instances where the fee previously paid was the fee for single family residential development, wherein all lots within the development were greater than 1/2 gross acre in size, and the applicant for a development permit subsequently requests an increase in residential density or a change from a residential to a non-residential use, or in instances where the fee previously paid was the fee for agricultural development and the applicant for a development permit subsequently requests a change from an agricultural to a residential, commercial or industrial use, the fee shall be recalculated for the new density or use pursuant to the provisions of this ordinance. Any difference between the recalculated fee and the previously paid fee shall be required to be paid by the applicant. Development of any parcel for which approval of an amendment, minor change or revision to a tentative tract map or tentative parcel map is sought; or development of any parcel for which approval of a request for substantial conformance or a revised conditional use permit, public use permit or plot plan is sought; or development of any parcel for which approval of an application for substantial conformance or a minor change to a surface mining permit is sought; and all grading permits necessary for the development of the parcel have previously been issued.
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7 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
Section 11. REFUND.
(1) In the event that the fee provided for by the final Habitat Conservation Plan is Less than the Mitigation Fee paid, the current property owner of record may apply for a partial refund of said fee. The amount of any refund due shall be determined by the City in its sole discretion after review of said application and shall be limited to the funds collected in excess of any amount received as a credit against the Habitat Conservation and Open Space Land Bank Fee pursuant to the provisions of Ordinance No. 659. (2) If an applicant for a grading permit has paid the Mitigation Fee pursuant to the provisions of this ordinance and said fee would not have been required to be paid, had Subsections (m)(l) and (2) of Section 4 of Ordinance No. 663 been in effect at the time of payment, the applicant may apply for a refund of the Mitigation Fee paid. The Building Director shall make the determination as to whether the applicant is entitled to a refund of the fee paid and shall provide a refund, if appropriate.

Section 12. FEE ADJUSTMENT.

The Mitigation Fee shall be that amount established by the Riverside County Habitat Conservation Agency Board of Directors, as may be amended from time to time, consistent with Government Code sections 66000 et seq. The Board of Supervisors hereby authorizes implementation of such fee as adopted by the RCHCA Board.

Beginning July 1, 2027, and annually thereafter, the fee shall be adjusted automatically based on the Consumer Price Index for All Urban Consumers (CPI-U) for the Los Angeles-Riverside-Orange County region, or a successor index.

Any adjustment to the mitigation fee that increases the fee beyond an authorized annual inflation adjustment shall be supported by findings consistent with Government Code section 66001 and shall be based upon an adopted or updated nexus study where required by law. Prior to adoption of any such adjustment, the nexus study and supporting data shall be made publicly available in accordance with Government Code section 66016, including posting at least thirty (30) days before the public hearing. Any substantive increase in the mitigation fee shall become effective no earlier than sixty (60) days following adoption, consistent with Government Code section 66017.

Adjustments to the Mitigation Fee shall be prospective only and shall become effective on the date specified in the adopting resolution, consistent with Government Code section 66017. The amount of the Mitigation Fee applicable to any development permit shall be the fee in effect at the time of payment. 2392
8 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
Nothing herein shall preclude the Board from considering changes in projected development levels, anticipated revenues, availability of other funding sources, or updated cost information in determining the appropriate Mitigation Fee amount.

Section 13. FEE ADMINISTRATION.

All Mitigation Fees collected pursuant to the provisions of this ordinance shall be deposited into a Mitigation Fee Account.

Funds in said account shall be expended solely for the development, preparation and implementation of a Habitat Conservation Plan for the Stephens' Kangaroo Rat, including the acquisition of habitat reserve sites, and for the application for a Section 10(a) permit under the Federal Endangered Species Act of 1973.

Section 14. VALIDITY.

This ordinance and the various parts, sections and clauses thereof are hereby declared to be severable. If any part, sentence, paragraph, section or clause is adjudged unconstitutional or invalid, the remainder of this ordinance shall not be affected thereby. If any part, sentence, paragraph, section or clause of this ordinance, or its application to any person or entity is adjudged unconstitutional or invalid, such unconstitutionality or invalidity shall affect only such part, sentence, paragraph, section or clause of this ordinance, or person or entity; and shall not affect or impair any of the remaining provisions, parts, sentences, paragraphs, sections or clauses of this ordinance, or its application of other persons or entities. The Board of Supervisors hereby declares that this ordinance would have been adopted had such unconstitutional or invalid part, sentence, paragraph, section or clause of this ordinance not been included herein; or had such person or entity been expressly exempted from the application of this ordinance.

Section 15. CREDIT.

Where a development project is subject to the provisions of a Development Agreement entered into with the City pursuant to the provisions of Government Code Section 65864 et seq. and the project involves the construction of residential units, the Mitigation Fee required to be paid pursuant to the provisions of this ordinance shall be reduced by $175.00 per residential unit.

Section 16. EFFECTIVE DATE.

Pursuant to Government Code section 66017, this Ordinance shall take effect sixty (60) days following adoption. The Mitigation Fee is a required component of the Updated Habitat Conservation Plan for the Stephens' Kangaroo Rat. Any development permit previously issued pursuant to Moreno Valley Municipal Code Chapter

8.60 – Threatened and Endangered Species and complying therewith shall be deemed to comply with this ordinance.
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9 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
Section 17. SEVERABILITY
That the City Council declares that, should any provision, section, paragraph, sentence or word of this Ordinance be rendered or declared invalid by any final court action in a court of competent jurisdiction or by reason of any preemptive legislation, the remaining provisions, sections, paragraphs, sentences or words of this ordinance as hereby adopted shall remain in full force and effect.

Section 18. REPEAL OF CONFLICTING PROVISIONS
That all the provisions of the Municipal Code as heretofore adopted by the City of Moreno Valley that are in conflict with the provisions of this Ordinance are hereby repealed.

Section 19. CERTIFICATION
That the City Clerk shall certify to the passage and adoption of this Ordinance, enter the same in the book for original ordinances of the City, and make a minute of passage and adoption thereof in the records of the proceedings of the City Council, in the minutes of the meeting at which this Ordinance is passed and adopted. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
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10 Ordinance No. 2026-XX
Date Adopted: September 01, 2026
APPROVED AND ADOPTED this _____ day of _______________, 2026. _________________________________
Ulises Cabrera
Mayor
City of Moreno Valley
ATTEST:
______________________________
M. Patricia Rodriguez, MMC, City Clerk
APPROVED AS TO FORM:
______________________________
Steven B. Quintanilla, City Attorney
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11 Ordinance No. 2026-XX
Date Adopted: September 01, 2026

ORDINANCE JURAT

STATE OF CALIFORNIA )
COUNTY OF RIVERSIDE ) ss.

CITY OF MORENO VALLEY )
I, M. Patricia Rodriguez, MMC, City Clerk of the City of Moreno Valley, California, do hereby certify that Ordinance No. 2026-XX was duly and regularly adopted by the City Council of the City of Moreno Valley at a regular meeting thereof held on the 1st day of September, 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
(Council Members, Mayor Pro Tem and Mayor)
_________________________________________
M. PATRICIA RODRIGUEZ, MMC, CITY CLERK
(SEAL)
2396
Exhibit A

RCHCA SKR HCP NEXUS STUDY
2397
STEPHENS’ KANGAROO

RAT HABITAT

CONSERVATION PLAN

NEXUS STUDY
REPORT
Prepared for: Prepared by:

Riverside County Habitat Conservation Agency Economic & Planning Systems, Inc.

June 4, 2026
EPS #244054
2398
Table of Contents

1. Introduction and Summary of Findings 1
SKR HCP Background ............................................................................................................................................1 Recommended Fee Program Updates ................................................................................................................ 2 Summary of Technical Findings ...........................................................................................................................3

2. Technical Analysis 5

3. Legal Context and Nexus Findings 11
Legal Context.........................................................................................................................................................11 Mitigation Fee Act ................................................................................................................................................11 Purpose of Fee.......................................................................................................................................................12 Use of Fee Revenues............................................................................................................................................12 Relationship............................................................................................................................................................13 Need ........................................................................................................................................................................13 Proportionality.......................................................................................................................................................13 2399
List of Tables
Table 1 Summary of Existing and Proposed SKR Mitigation Fees...................................................................3 Table 2 Ongoing Annual RCHCA Expenditures (2025 Dollars)........................................................................5 Table 3 Potential Non-Fee Ongoing Revenues ...................................................................................................6 Table 4 Annual Fee Funding Required ..................................................................................................................7 Table 5 Historical and Projected Growth Metrics...............................................................................................8 Table 6 Annual Fee Funding Required ..................................................................................................................9 2400
List of Figures
Figure 1 Map of SKR Plan Area ................................................................................................................................2 2401
Economic & Planning Systems, Inc. 1 Introduction and Summary of Findings

1. Introduction and Summary of Findings
This report provides the technical documentation required to update the Stephens’ Kangaroo Rat (SKR) mitigation fee under the State of California’s Mitigation Fee Act (MFA). The SKR fee is a critical component of the funding approach for SKR Habitat Conservation Plan (Plan) implementation. The fee has not been updated since 1996 and this update will help ensure the continued successful implementation of the plan and the associated benefits of the streamlined incidental take permitting it provides to new development.

This first chapter includes background on the SKR HCP, the recommended updated fee schedule, and a summary of the technical findings. The subsequent chapters provide detailed technical analysis and the required nexus findings for fee updates under the Mitigation Fee Act.

SKR HCP Background
The Riverside County Habitat Conservation Agency (RCHCA) was formed as a Joint Powers Authority to implement the SKR HCP. Today, there are eleven member jurisdictions in the SKR Plan Area (see Figure 1). RCHCA’s activities include managing approximately 46,000 acres of reserve lands in Riverside County and biological research to study and protect the SKR population. As of 2022, the SKR is considered a federal and state threatened species, downlisted from its original federal endangered status. The SKR mitigation fee is a critical funding source for RCHCA’s ongoing activities.

The original SKR mitigation fee was set at $1,950 per acre in 1988 and was decreased to $500 per acre in 1996 at the time of completion and approval of the Plan. Unlike many mitigation fees, no adjustments have been made for inflation, reducing the fee level in inflation-adjusted terms over time. 2402
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 2 Introduction and Summary of Findings Figure 1 Map of SKR Plan Area
Source: Riverside County Habitat Conservation Agency
Recommended Fee Program Updates
This technical analysis indicates that the SKR fee on most forms of new private development should be increased from $500 per acre to $900 per acre. The fees on the development of large lot single family residences and on new agriculture uses would remain unchanged. Fees on the development of single homes on single lots by individual households would also pay the lower fee. Table 1 summarizes the proposed changes, where applicable, between the current fee and the recommended updated fee.
2403
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 3 Introduction and Summary of Findings Table 1 Summary of Existing and Proposed SKR Mitigation Fees As a point of reference, the cumulative level of inflation based on the Consumer Price Index for All Urban Consumers in the United States (CPI-U) between 1996 and 2025 was 106 percent, equivalent to an average annual inflation rate of about 2.5 percent. If automatic annual inflationary adjustments had been integrated into the fee, the $500 per acre SKR mitigation fee would have been over $1,000 per acre in today’s dollar terms. To avoid falling behind in the future, it is recommended that the RCHCA update the fee annually and automatically based on an inflation index.

Summary of Technical Findings

1. The revised, required SKR Mitigation Fee is calculated at $900 per acre. This is the mitigation fee estimated required to ensure new development in the SKR Plan area provides sufficient average annual funding to cover the annual HCP implementation costs. This represents an 80 percent increase from the current fee set in 1996, an increase which remains below the overall level of inflation since that time.

2. RCHCA requires approximately $1.9 million annually (in 2025 dollars) in funding to cover its ongoing activities and obligations under the Plan. The RCHCA is responsible for a broad range of ongoing reserve management activities and biological research under the Plan and has annual costs associated with staffing, consultants, services, and supplies.

Use Type Fee Basis Existing Fee Proposed Fee
Individual Single-Family Home Construction (Single Parcel)1 per dwelling unit $250 $250 Agriculture2 per gross acre $100 $500
All Other Development3 per gross acre $500 $900
[1] This fee category applies only to the construction of a single-family residence on a single legally created lot, where the building permit is issued to an individual property owner and is not part of a subdivision, tract development, or any coordinated multi-unit residential development.

This category may include one accessory dwelling unit (ADU) constructed in conjunction with the primary residence. This category shall not apply to any subdivision or parcel map creating multiple residential lots, tract or master-planned developments, or any development involving multiple residential units constructed pursuant to a common development plan, whether built simultaneously or in phases. All such developments shall be subject to the applicable per gross acre fee.
[2] Agriculture developments pay an existing fee of $100 per development 1% of the valuation of a building, whichever is greater and not to exceed $500 per gross acre.. The proposed updated mitigation fee is simplified to $500 per gross acre of development. [3] This fee category applies to all development not otherwise classified as agricultural development or qualifying under Footnote 1. Nonprofit development projects may qualify for a fee reduction of up to seventy-five (75) percent, as determined by the implementing jurisdiction, provided that the reduction is supported by findings that the remaining mitigation costs are funded through other available sources and that the reduction does not create a funding shortfall for implementation of the Habitat Conservation Plan. 2404
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 4 Introduction and Summary of Findings

3. The required annual funding from the SKR mitigation fee is about $1.6 million annually. Through interest revenues from its funding balances and payments for contract services, the RCHCA accrues about $300,000 annually in non-fee revenues. As a result, the net annual funding required from SKR fees to ensure the HCP can cover its implementation obligations is about $1.6 million annually.

4. The required $900 per acre fee level is derived from the required fee funding and the expected level of annual development. Within the Plan Area, the forecast, average annual development is estimated to be about 1,770 acres per year. Spreading the net HCP implementation costs evenly and proportionately across this expected level of development results in a required fee of $900 per acre. The level of future development and fee payment should be tracked carefully by the RCHCA. Variations by year are to be expected, but systematic differences from the forecasts may require further review and update of the nexus study.

5. To keep up with the effects of cost inflation on annual HCP implementation costs, the SKR mitigation fee should be automatically updated annually based on an inflation index. The updated fee level is expected to provide the necessary fee revenues in 2025 dollar terms. Inflation will increase the costs of Plan implementation annually and to keep pace, the SKR fee should be updated automatically each year based on an inflation index. 2405
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 5 Technical Analysis

2. Technical Analysis
This chapter provides the more detailed technical analysis and associated process, assumptions, and calculations that were used to derive the updated SKR fee. The fee analysis is designed to reflect the need for and planned use of fee revenues as well as to establish their reasonableness and proportionality with the impacts of new development consistent with the Mitigation Fee Act. It also helps establish the “essential nexus” and “rough proportionality” under the US Supreme Court Nollan/ Dolan decisions. The legal context and specific nexus findings are described in more detail on Chapter 3.

Step 1. Determine RCHCA Ongoing Plan Implementation Costs The RCHCA undertakes a broad set of reserve management and oversight activities each year as required by the HCP. EPS reviewed the most recent RCHCA budget from FY 2024-2025 and worked with District staff to determine which of the 2024/2025 costs are ongoing HCP implementation costs (versus one-time costs). As shown in Table 2, the estimated annual ongoing costs of implementing the HCP are $1.925 million. This includes the personnel, consultant, services, supplies and other expenditures requires to ensure plan implementation. About 70 percent of these costs are associated with Plan implementation as a whole, while the other 30 percent are reserve-specific costs associated with the Lake Matthews Reserve Fund.

Table 2 Ongoing Annual RCHCA Expenditures (2025 Dollars) General Lake Matthews FY2025
Expenditure Item Fund (3) Reserve Fund (3) Total %
Ongoing 2025 Expenditures (1)
RCHCA Salaries and Wages $315,310 $364,619 $679,929 35% Fringe Benefits $152,726 $172,338 $325,064 17%
Overhead (2) $351,495 $0 $351,495 18%
Consulting Labor $250,000 $0 $250,000 13%
Insurance $65,000 $0 $65,000 3%
Weed Abatement $27,500 $0 $27,500 1%
All Other $201,650 $25,000 $226,650 12%
(Services, Supplies, etc.)
Total $1,363,681 $561,957 $1,925,638 100%
(1) Excludes $84,612 one-off expenditure on field equipment funded by a grant. (2) Overhead encompasses payments to WRCOG for overhead services, including HR/ admin etc. (3) Lake Matthews costs are reserve-specific and include reserve manager and techs.

General Fund covers administrative and management personnel and other costs.

Source: RCHCA Fiscal Year 2024/2025 Budget; Economic & Planning Systems, Inc. 2406
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 6 Technical Analysis
Step 2. Identify Consistent Ongoing Non-Fee Revenues
To the extent that the RCHCA has consistent sources of other non-fee revenues to help fund some of the implementation costs estimated in Step 1, these revenues are subtracted from the overall HCP implementation costs to determine the net fee revenue required.

RCHCA currently has two secure funding sources that it can apply to help fund a portion of the ongoing HCP implementation costs. These include interest revenues from the General Fund and Lake Matthews reserve funds as well as payment for contract services by the Metropolitan Water District for RCHCA work efforts on their reserves. To fill funding gaps in the past, RCHCA has competed for and, in some cases, won grant funding. However, because of the uncertainty of grant funding, the regulatory agencies do not accept grant funding when reviewing funding assurances for HCPs.

As shown in Table 3, based on the average annual interest rate over the last 10 years and the expected reserves at the start of the 2025/2026 fiscal year, an average annual of about $183,400 in interest revenues is estimated. The payments for contract services can fluctuate by year and are assumed to average about 75 percent of the total allowable charge, or $150,000 each year. Together, these revenue sources are expected to provide about $333,400 in annual revenues to cover a portion of the HCP implementation costs.

Table 3 Potential Non-Fee Ongoing Revenues
General Lake Matthews
Item Fund Fund Total
Annual Interest Revenues
2023/2024 Fund Balance $11,006,233 $2,914,748 $13,920,981 2024/2025 Proposed Use of Fund Balance $518,715 $304,961 $823,676 2025/2026 Remaining Fund Balance $10,487,518 $2,609,787 $13,097,305 Annual Interest Revenues [1] 1.4% $146,825 $36,537 $183,362 (nominal dollars)
Contract Services
Contract Services 75% of Max $105,000 $45,000 $150,000
(nominal dollars) Contract
Total Non-Fee Ongoing Revenue $251,825 $81,537 $333,362 (nominal dollars)
[1] Interest rate represents historical 10-year average (for 2014-2024) annual interest rate for the state's Local Agency Investment Fund (LAIF) in which RCHCA funds are invested.

Source: RCHCA Fiscal Year 2024/2025 Budget; Economic & Planning Systems, Inc.

Assumption
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STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 7 Technical Analysis
Step 3. Annual Fee Funding Required
The calculation of the required habitat mitigation fee is based on the level of fee revenue required. As shown in Table 4, the average annual fee revenue required is about $1.6 million, representing the total annual costs ($1.925 million) minus the estimated annual non-fee revenues ($333,400). This is the level of fee funding required from new development to ensure the RCHCA can implement the HCP and provide new development with incidental take permitting.

Table 4 Annual Fee Funding Required
Step 4. Forecast of Annual Fee-Paying Development
Like all habitat mitigation fees, the fee revenues collected from new development will depend on the level of new development each year. Annual development in the SKR Fee Area (like other areas) will fluctuate based on economic cycles, the availability of developable land, and a host of other factors. To establish a mitigation fee, it is necessary to forecast an average annual pace of development and then track it over time to see if it is generating sufficient revenues and/or whether any refinements in the fee program are appropriate.

As shown in Table 5, EPS developed an annual forecast of about 1,770 acres of new development in the SKR Plan Area based on a combination of historical fee revenue generation and SCAG household/ job projections and development density assumptions.

Historical data provided by the RCHCA indicated an average annual fee revenue collection of about $950,000 over the last four (4) fiscal years. Divided by the current fee level of $500/ acre on most development, this implies an average of about 1,900 acres paid the fee each year.

General Lake Matthews
Item Fund Fund Total
Annual Expenditures $1,363,681 $561,957 $1,925,638
Potential Non-Fee Funding
Interest Revenues $146,825 $36,537 $183,362
Contract Services Revenues $105,000 $45,000 $150,000
Subtotal $251,825 $81,537 $333,362
Fee Funding Required $1,111,856 $480,420 $1,592,276
Source: RCHCA Fiscal Year 2024/2025 Budget; Economic & Planning Systems, Inc. 2408
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 8 Technical Analysis
To provide a forward-looking perspective, EPS reviewed the SCAG forecasts of households and jobs in the SKR Plan Area. As shown, an average of 5,200 new households and 6,800 new jobs are forecast annually in the SKR Plan Area. The developed area required to support these forecasts depends on the development densities of new housing and new workspaces. Using 4 dwelling units/acre for residential development and 20 jobs/acre for non-residential development suggests an average annual development of about 1,640 acres annually, comprised of 1,300 acres of residential development and 340 acres on nonresidential. To the extent the average densities vary from these estimates, the level of fee-paying development will vary.

Table 5 Historical and Projected Growth Metrics
Item Total
Historical Fee Revenues
Average Annual Migitation Fee Revenues $953,090
(FY 2021 - 2024)
Implied Developed Mitigation Acres 1,906
(assume $500/ acre)
SCAG Growth Projections
SKR Plan Area: SCAG Annual Household Projections
(2019 - 2045) 5,191
SKR Plan Area: SCAG Annual Job Projections 6,784
(2019 - 2045)
Residential Acres (4 units/ Acre) 1,298
Non-Residential Acres (20 jobs/ Acre) 339
1,637
Average Growth Projection
Developed Acres (1) 1,772
the historical and projected growth estimates.

Source: SCAG; Economic & Planning Systems, Inc.
(1) For purposes of this fee calculation, developed acres average 2409
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 9 Technical Analysis
To develop a reasonable forecast of future fee-paying development in the SKR Plan Area, this analysis takes the average of the developed acre estimates from the recent history and from available forecasts. This results in a forecast of about 1,770 acres of development each year.

Step 5. Mitigation Fee Calculation and Inflator
The updated mitigation ratio is about $900 per acre in 2025 dollar terms as shown in Table 6. This is the fee level required for the forecasted 1,772 annual average developed acres to generate the $1.59 million in fee revenue required to ensure the RCHCA, in combination with the other revenues sources noted, can cover the annual costs of implementing the HCP.

Table 6 Annual Fee Funding Required
Similar to most fee programs, it is recommended that an automatic annual inflation index is integrated into the fee program so the fee level is adjusted for inflation each year and avoids falling behind implementation costs.

As noted above, fluctuations in the level of development are likely each year and it is important for the RCHCA to track revenue levels to make sure sufficient revenues are generated on average over time. The RCHCA could use its reserve balances in cases where fee revenues drop below the average required (for example, during economic or development downturns) though this is not a sustainable approach over the long term and any ongoing under-provision of fee revenues would require a fee update. Mitigation fee programs are typically expected to do periodic fee program updates (typically every 5 to 8 years) to confirm or refine the fee program, though more frequent updates are undertaken when there is a significant change in circumstances.

Item Total
Fee-Funding Required $1,592,276
Development Forecast scenarios
Annual Development Forecast (acres) 1,772
Mitigation Fee per Acre $900
Source: Economic & Planning Systems, Inc.
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STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 10 Technical Analysis Step 6. Per Acre Mitigation Fee Basis
Recent updates to the Mitigation Fee Act due to the passage of AB 602 require that new and updated fee programs consider whether it is possible and appropriate to adopt fees on new residential development on a per square foot basis. For habitat mitigation fees, a per acre of development approach is typically the preferred approach. For these fees, the scale of land development provides a more direct and proportional connection/ nexus to impacts (on habitat) while also ensuring smaller developments pay lower fees. The square footage of new residential development on the land can vary substantially even for the same amount of land development, making it a less strong basis for the nexus and fee collection.
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STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 11 Legal Context and Nexus Findings

3. Legal Context and Nexus Findings
This chapter provides the legal context for this fee update and describes the nexus findings required to support the update to the SKR mitigation fee under the Mitigation Fee Act.

Legal Context
Riverside County’s Ordinance No. 663 Section 12 states that: “The Board of Supervisors may periodically review and cause an adjustment to be made to the Mitigation Fee. By amendment to this ordinance, the fee may be increased or decreased to reflect changes in estimated costs for the development, preparation and implementation of a Habitat Conservation Plan. The adjustment in the fee may also reflect changes in estimated revenues received pursuant to this ordinance, as well as the availability or lack thereof of other funds with which to prepare and implement the Habitat Conservation Plan”.

The SKR mitigation fee can be adjusted under the Mitigation Fee Act (MFA) through the development of a nexus study. Recent court cases (Sheetz case) have also concluded that mitigation fees must be consistent with the US Supreme Court’s Nollan and Dolan tests. Overall, the nexus study must describe the need for and use of the fee revenues as well as the relationships between the fee amount and fee need/ use. The nexus study/ findings should also establish the “essential nexus” under the US Supreme Court’s Nollan test and the “rough proportionality” required under the US Supreme Court’s Dolan test.

Mitigation Fee Act
Mitigation fees are utilized in California to finance public facilities necessary to mitigate impacts stemming from new development. In 1987, the California Legislature adopted the Mitigation Fee Act to provide a framework for the application and administration of such fees. Current prevailing practice among the majority of approved and permitted regional Habitat Conservation Plans is that any habitat mitigation fees are to be adopted by the relevant jurisdictions consistent with the Mitigation Fee Act. The adoption of fees under the Mitigation Fee Act includes a number of auditing and reporting requirements.

The Mitigation Fee Act, defined in California Government Code Sections 66000 to 66025, requires all public agencies to document five findings when establishing or increasing a fee as a condition for new development.

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STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 12 Legal Context and Nexus Findings This section describes how the proposed increase in the fee is based on the appropriate nexus between new development and the imposition of a mitigation fee and satisfies the five statutory findings required by the Mitigation Fee Act.

The nexus findings also indicate the essential nexus and rough proportionality as required under Nollan/ Dolan. These nexus findings are summarized below and supported by the technical analysis in Chapter 2.

Purpose of Fee
Identify the purpose of the fee.

The purpose of the SKR mitigation fee is to contribute to the funding required to implement the SKR Plan and, as a result, help maintain the incidental take permits for new private and public development in the SKR Plan Area under the federal and State Endangered Species Acts. Maintaining the incidental take permit is necessary to allow for future development, and without the development community paying for the cost of the SKR HCP, individual applicants would need to apply independently for development approval under federal and State law if the project impacts a threatened or endangered species. The federal Endangered Species Act specifically requires that the applicant for incidental take permit “ensure that adequate funding for the plan will be provided.” In addition, the Mitigation Fee helps provide the regional benefit of streamlined economic development in the SKR Plan Area as well as the management of the contiguous open spaces that serve as a community amenity.

Use of Fee Revenues
Identify the use to which the fee is to be put.

The SKR HCP is the public document that outlines the actions required as a whole and the particular set of actions required by the local permittees (and RCHCA as their agent) to obtain incidental take permits—associated with State and federal Endangered Species Act requirements—for new public and private development in the SKR Plan Area. The actions required by the SKR Plan remain the same.

Failure to meet the requirements of the SKR HCP will result in an inability to obtain or maintain incidental take permits through the SKR HCP, which would require future development to secure individual take authorization if the project impacts the SKR.

Revenues from the SKR Mitigation Fee will be used, in conjunction with other sources of revenue, to fund the reserve management actions identified as the responsibility of local permittees in the SKR HCP. The specific cost components of these actions are summarized in Chapter 2 and based on published budget documents.
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STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 13 Legal Context and Nexus Findings Relationship
Determine how there is a reasonable relationship between the fee’s use and the type of development project on which the fee is imposed.

The implementation of the MSHCP, and the mitigation fee as a fundamental part of it, will benefit all new development by mitigating their collective impacts on the protected Stephens’ kangaroo rat species and associated habitat. All new public and private development in the Plan Area will affect habitat and species either directly, indirectly, or as a cumulative effect. All new development in the Plan Area will also benefit from the incidental take permits obtained through the SKR HCP and via the use of the mitigation fee revenues.

Need
Determine how there is a reasonable relationship between the need for the public facility and the type of development project on which the fee is imposed.

Without new development, no SKR HCP would be necessary and no further habitat conservation would be required under the federal and State Endangered Species Acts. To allow for any future development under the Plan, the SKR HCP must be fully funded. New development in the Plan Area, as noted above, will directly, indirectly, or cumulatively affect the species and its habitat in Riverside County. Because of this, development of the SKR HCP was undertaken to provide an approach to benefit future development in the Plan Area. The requirements of the SKR HCP are a direct result of the mitigation that is engendered by all new development in the Plan Area under the pertinent environmental regulations. Meeting the requirements of the SKR HCP is necessary to obtain the necessary federal authorization to develop within the Plan Area. Together, purpose, need, and relationship findings also indicate a clear “essential nexus” under the Nollan test.

Proportionality
Determine how there is a reasonable relationship between the amount of the fee and the cost of the public facility or portion of the public facility attributable to the development on which the fee is imposed.

The SKR HCP includes detailed conservation requirements based on the scientific evaluations that form the basis of the SKR HCP. Based on these evaluations, local permittee conservation responsibilities were identified. The mitigation fee provides funding towards the fulfillment of the local permittee conservation requirements. After subtracting out non-fee funding sources from the implementation costs, the remaining implementation costs are all allocated to new development and allocated proportionately between new development on an acreage basis. As such, the mitigation fee calculations (as laid out in Chapter 2) are 2414
STEPHENS’ KANGAROO RAT HABITAT CONSERVATION PLAN NEXUS STUDY Economic & Planning Systems, Inc. 14 Legal Context and Nexus Findings carefully calibrated to fund only the proportionate share of costs attributable to the new development on which the fee is imposed and to allocate the fee levels proportionally across all new development. This proportionality finding also establishes the required “rough proportionality” under the Dolan test. 2415
Report to City Council
ID: 26-0348 Page 1
TO: Mayor and City Council
FROM: Angelica Frausto-Lupo, Community Development
Director
AGENDA DATE: September 1, 2026
TITLE: APPEAL OF PLANNING COMMISSION’S ACTION TO

NOT APPROVE CONDITIONAL USE PERMIT FOR
SELF-STORAGE FACILITY (PEN24-0154) (REPORT
OF: COMMUNITY DEVELOPMENT) (DISTRICT 3)
TITLE SUMMARY: Appeal Of Planning Commission’s Action To Not Approve Conditional Use Permit (PEN24-0154) For The Development Of A 130,764 Square-Foot Self-Storage Facility
DISTRICT: District 3
Recommendation(s)
That the City Council:

1. Uphold the Planning Commission's decision to not approve the Proposed Project with articulated findings to support a decision to deny the Proposed Project; or

2. Adopt Resolution No. 2026-XX approving and adopting the Initial Study/Mitigated Negative Declaration and the Mitigation Monitoring and Reporting Program prepared for the Proposed Project; and Adopt Resolution No. 2026-XX approving Conditional Use Permit (PEN24-0154) based on the Recitals. Evidence contained in the Administrative Records and Findings as set forth in Resolution No. 2026-XX. 2416
ID: 26-0348 Page 2

SUMMARY
The Applicant is appealing the Planning Commission’s decision not to approve the Conditional Use Permit (PEN24-0154) for the development of a self-storage facility with 1,134 storage units within a 130,764-square-foot 3-story building, 52 outdoor recreational vehicle parking spaces, 12 vehicular parking stalls, landscape improvements, and a trash enclosure (“Proposed Project”) on an approximately 3-acre vacant parcel, situated on the east side of Indian Street, north of Alessandro Boulevard and south of Bay Avenue (APN:
482-190-022) (“Project Site”), within the Corridor Mixed-Use (COMU) zone.

Background - Project Description
On June 11, 2026, the Planning Commission considered the Proposed Project at a duly noticed public hearing. The Planning Commission voted 2 ayes and 3 noes on a motion to approve the requested Conditional Use Permit (PEN24-0154), which effectively resulted in the Proposed Project not being approved, since no alternative motion was offered nor was any alternative action taken.

An appeal was filed by Kristofer Golder of Public Storage (the “Applicant”) within the required 10-day appeal period, challenging the Planning Commission’s decision to not approve the Appellant’s Proposed Project. The Proposed Project consists of a Conditional Use Permit for the development of a self-storage facility with 1,134 storage units within a 130,764-square-foot 3-story building, 52 recreational vehicle outdoor parking spaces, 12 vehicular parking stalls, landscape improvements, and a trash enclosure on a 3-acre vacant parcel situated on the east side of Indian Street north of Alessandro Boulevard (“Project Site”), within the Corridor Mixed-Use (COMU) zone.

A self-storage facility, located within 300 feet of a residential zone or use, is permitted in the Corridor Mixed-Use (COMU) zone, subject to the approval of a Conditional Use Permit (CUP). The CUP is required to ensure that the self-storage facility does not result in an adverse impact on surrounding properties.

The site and storage spaces will be accessible to customers from 6 a.m. to 9 p.m., seven days a week. The rental office will be open from 9 a.m. to 6 p.m., seven days a week. It is expected that one to two employees will staff the facility during each shift.

Pursuant to Moreno Valley Municipal Code (MVMC) Section 9.02.240 (Appeals), the Appellant has submitted a letter attached to this staff report that sets forth the specific reasons for the appeal and provides justification for: 1) the Proposed Project’s consistency with the goals, objectives, policies, and programs of the General Plan; and 2) the Proposed Project’s lack of adverse effect on public health, safety, or general welfare.
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ID: 26-0348 Page 3
Site and Surrounding Area
The vacant Project Site is approximately 3 acres and is located on the east side of Indian Street, north of Alessandro Boulevard and south of Bay Avenue. Surrounding land uses include existing single-family residential homes zoned Residential 5 (R5) to the east; an existing fuel station and auto parts store to the south; an existing self-storage facility to the north; and the Food 4 Less commercial shopping center across Indian Street to the west. All of these commercial uses are within the Corridor Mixed-Use (COMU) zone.

Access/Parking
Access to the Project Site is provided via a 27-foot-wide two-way shared driveway from Indian Street. Pedestrian walkways are provided throughout the Project Site to ensure adequate pedestrian circulation.

The Proposed Project provides a total of 12 on-site parking spaces. The number and type of parking spaces comply with the requirements of the Municipal Code. There is also a large loading area on the east side of the building for tenants to move their belongings in and out of the building.

Design/Landscaping
The site plan has been thoughtfully designed to minimize potential impacts on the adjoining single-family residential uses. The building has been set back approximately 196 feet from the shared property line with the existing residential uses. The required setback is 15 feet from the referenced property line. The setback provided is almost thirteen times the amount required by the Municipal Code.

The Proposed Project features a modern commercial design with a mix of high-quality materials and distinctive architectural elements. The self-storage building is approximately 42 feet, 8 inches in height. The building's exterior surfaces will be finished with stucco, decorative masonry block, and metal panel siding, all painted in a coordinated color scheme of brand colors labeled Winter Mood, Moth Grey, Roller Coaster, and PS Orange. The building will incorporate decorative windows, doors, metal awnings, and a flat roof, resulting in a unified and visually appealing façade.

A 6-foot-tall decorative block wall will be installed along the easterly property line, which abuts single-family residential homes, and along portions of the northerly and southerly property lines adjacent to the outdoor RV storage and parking spaces, for added security and screening. The entrance to the RV storage will be secured by two vehicular gates.

In addition, the landscape design includes landscaped setbacks, parking lot landscaping, street trees, and perimeter plantings around the Project Site. The proposed landscape is designed to enhance the overall experience of the development and to comply with the Municipal Code’s landscape requirements.
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ID: 26-0348 Page 4

DISCUSSION
The Applicant is appealing the Planning Commission’s decision not to approve the Conditional Use Permit (PEN24-0154) for the development of a self-storage facility. The City Council can uphold the Planning Commission’s action to not approve the Proposed Project by articulating findings to support a decision to deny the Proposed Project.

Alternatively, the City Council can reverse the Planning Commission’s action to not approve the Proposed Project by approving the Conditional Use Permit (PEN25-0154) via adoption of the corresponding Resolutions.

Since the Appeal was filed, the Applicant informed City staff that they were considering to offer a voluntary community benefit.

The Appellant’s legal counsel confirmed on August 21, 2026, that “[t]he following item has been offered as a condition of approval by the property owner/applicant as a community benefit:
a) A $250,000 donation to the Moreno Valley Community Foundation (Prior to Certificate of Occupancy issuance).”
The Moreno Valley Community Foundation was created by the City in 2007 as a California nonprofit public benefit corporation for the following purposes: (i) to lessen the burdens of government by aiding and assisting in the implementation, improvement, and maintenance of public services that preserve and promote the health and welfare and education of local citizenry of the City; (ii) to provide for unincorporated divisions responsible for furtherance of one or more of such public services as deemed appropriate by the Board of Directors of the Nonprofit; and (iii) to receive, invest, and utilize funds and property acquired through the solicitation of contributions, donations, grants, gifts, bequests and the like for the purposes for which the Nonprofit was formed. The Board of Directors consists of the City Council. This means that if the City Council, acting in its capacity as the Foundation’s Board of Directors, accepts the donation, it may determine which “public services” to fund, with the caveat that the public services must be associated with the Proposed Project, since California law requires that donations to cities must be used for the purposes they were made. The City Council’s determination on the use of funds can be made at a future date, if necessary.

Review Process
As part of the standard review process, all appropriate outside agencies have considered the Proposed Project. The Proposed Project’s application materials were circulated and reviewed by all appropriate City Departments and Divisions. Following subsequent revisions and staff review, the Project was deemed complete. 2419
ID: 26-0348 Page 5
Scope And Standard Of Review
Pursuant to MVMC Section 9.02.060 (Conditional Use Permits), the Planning Commission is vested with the authority to approve conditional use permits. However, Section 9.02.240 (Appeals) further provides that the Planning Commission’s action on a proposed Conditional Use Permit shall be final unless appealed to the City Council within ten (10) consecutive calendar days after the Planning Commission’s decision not to approve the Proposed Project. The Planning Commission’s action was taken on June 11, 2026, and the Appellant filed their appeal on June 18, 2026, which falls within the 10-day appeal period.

Section 9.02.240 (Appeals) provides that any affected person may appeal a Planning Commission decision to the City Council. The City Council may approve, approve with modifications, or disapprove any proposed CUP.

Should the City Council be inclined to approve the Proposed Project, it must make the following findings pursuant to 9.02.060 (Conditional Use Permits):

1. That the Proposed Project is consistent with the goals, objectives, policies, and programs of the General Plan;

2. That the Proposed Project complies with all applicable zoning and other regulations;

3. That the Proposed Project will not be detrimental to the public health, safety, or welfare or materially injurious to properties or improvements in the vicinity; and

4. The location, design, and operation of the Proposed Project will be compatible with existing and planned land uses in the vicinity.

Staff has made the objective determination that, based on all the evidence known by staff at the time the Planning Commission staff report was prepared, the above findings may be made with respect to the merits of the Proposed Project.

Environmental
An Initial Study was prepared by LSA Associates, Inc., in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines. The Initial Study examined the potential impacts of the Proposed Project. The Initial Study/Mitigated Negative Declaration (IS/MND) provides information supporting the finding that a Mitigated Negative Declaration (MND) is the appropriate CEQA documentation for the Proposed Project. With the implementation of the proposed mitigation measures, the Proposed Project will not have a significant effect on the environment, as all potential impacts, as mitigated, will be reduced to levels of insignificance. Technical studies prepared in support of the IS/MND include the following: Air Quality, Energy and Greenhouse Gas Technical Memorandum; Health Risk Assessment; Western Riverside County Multiple Species Habitat Conservation Plan Consistency Analysis and Biology Report; Cultural Resources Assessment; Geotechnical Engineering Exploration and Analysis; Phase I Environmental Site Assessment; Water Quality Management Plan; Hydrology Study; Noise and Vibration Impact Analysis; and Trip Generation and Vehicle Miles Traveled 2420
ID: 26-0348 Page 6
Analysis.

Mitigation measures are recommended for the Proposed Project in the following areas:

Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Noise, and Tribal Cultural Resources. These measures are incorporated into the Mitigation Monitoring and Reporting Program (MMRP), which will be used to identify and track the implementation of the mitigation measures. The measures for cultural resources have been included to address input from the Tribal governments. The measures are intended to ensure that potential cultural resources that might be discovered are protected. Based on the Initial Study and the proposed mitigation measures, the Proposed Project will not have a significant impact on the environment.

The 30-day public comment period for the Notice of Intent (NOI) of the Initial Study/Mitigated Negative Declaration commenced on April 21, 2026, and ended on May 21, 2026 (State Clearing House Number 2026040798). Comment letters received from SoCal Gas are attached to this Staff Report.

ALTERNATIVES

1. Affirm and uphold the Planning Commission’s action to not approve the Proposed Project by articulating findings to support a decision to deny the proposed project.

Staff does not recommend this alternative.

2. Reverse the Planning Commission’s action to not approve the Proposed Project by adopting the Resolution adopting the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program and adopting the Resolution approving Conditional Use Permit (PEN24-0154) based on the findings set forth in the above-referenced Resolutions and the Administrative Record. Staff prefer this alternative.

NOTIFICATION
Consistent with the applicable Municipal Code provisions and exceeding the posting and distance requirements of applicable state law, a public hearing notice was sent to all property owners of record within 600 feet of the Project Site, and notices were posted at the Project Site and published in the Press Enterprise Newspaper at least 10 days prior to the Appeal Hearing. As of the preparation of this Staff Report, no public comment outside the scope of the Planning Commission public hearing has been received regarding the Proposed Project.

FISCAL IMPACT
There is no fiscal impact associated with the proposed Project. All Project-related costs are borne by the Developer and/or Applicant.
2421
ID: 26-0348 Page 7

PREPARATION OF STAFF REPORT
Prepared By: Department Head Approval:

Gabriel Diaz Angelica Frausto-Lupo
Associate Planner Community Development Director
Concurred By:

Sergio Madera
Planning Division Manager/Planning Official

CITY COUNCIL GOALS
Community Image, Neighborhood Pride and Cleanliness: Promote a sense of community pride and foster an excellent image about our City by developing and executing programs which will result in quality development, enhanced neighborhood preservation efforts, including home rehabilitation and neighborhood restoration.

Positive Environment: Create a positive environment for the development of Moreno Valley's future.

CITY COUNCIL STRATEGIC PRIORITIES

1. Economic Development

2. Public Safety

3. Library

4. Infrastructure

5. Beautification, Community Engagement, and Quality of Life

6. Youth Programs
2422
ID: 26-0348 Page 8
Report Approval Details
Document Title: STAFFREPORT_CDD_APPEAL_PAA26-0003.docx
Attachments: - RESOLUTION NO. 2026-XX_Adopting ISMND_MMRP.docx - Exhibit A_Reso 2026-XX_ISMND.pdf
- Exhibit B_Reso 2026-XX_IMMRP.pdf
- Exhibit C_Reso 2026-XX_NOI.pdf
- APPX A-Draft AQ_E_GHG Memo.pdf
- APPX B- Health Risk Assessment.pdf
- APPX C- Western Riverside MSHCP Bio Report.pdf
- APPX D-Draft Cultural Resources Assessment.pdf
- APPX E-PS Geo Exploration Analysis Report Moreno Valley CA 5-23-24.pdf
- APPX F-Public Storage - Moreno Valley, CA Phase I ESA.pdf - APPX G-24-077 PWQMP 2025-10-14.pdf
- APPX H-24-077 Hydrology Report 2025-01-02.pdf
- APPX I-Noise and Vibration Memo.pdf
- APPX J-Moreno Valley PS Trip Gen and VMT memo.pdf
- RESOLUTION NO. 2026-XX_Approving Appeal PAA26-
0003.docx
- Exhibit A_Reso 2026-XX_COA's.pdf
- Project Plans.pdf
- Comment Letter SoCalGas Email 4.23.26.pdf
- Comment Letter SoCalGas Email 4.29.26.pdf
- Public Comment Letters.pdf
Final Approval Date: Aug 26, 2026
This report and all of its attachments were approved and signed as outlined below:

Angelica Frausto-Lupo
Sean Kelleher
Anna Chacon
Felicia London, MPA
Launa Jimenez
Brian Mohan
Patty Rodriguez
2423
Resolution No. 2026-
Date Adopted: September 1, 2026
RESOLUTION NO. 2026-XX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MORENO

VALLEY, CALIFORNIA, ADOPTING A MITIGATED NEGATIVE

DECLARATION AND MITIGATION MONITORING AND REPORTING
PROGRAM FOR CONDITIONAL USE PERMIT (PEN24-0154) FOR A
130,764 SQUARE FOOT 3-STORY SELF-STORAGE FACILITY

LOCATED EAST OF INDIAN STREET NORTH OF ALESSANDRO
BOULEVARD (APN: 482-190-022) IN THE CORRIDOR MIXED-USE
(COMU) ZONE
WHEREAS, the City of Moreno Valley (“City”) is a general law city and a municipal corporation of the State of California, and the lead agency for the preparation and consideration of environmental documents for projects that are subject to requirements of the California Environmental Quality Act (CEQA1) and CEQA Guidelines2; and WHEREAS, Kristofer Golder of Public Storage (“Applicant”) submitted an application for a Conditional Use Permit (PEN24-0154) for the development of a selfstorage facility with 1,134 storage units within a 130,764 square foot 3-story building, 52 recreational vehicle outdoor parking spaces, on-site parking, landscape improvements, and a trash enclosure (“Proposed Project”) on an approximate 3-acre vacant parcel located east of Indian Street and north of Alessandro Boulevard (APNs:482-190-022) (“Project Site”); and
WHEREAS, Planning Division Staff (“Staff”) completed an Initial Study (“IS”) (Environmental Assessment) for the Proposed Project and based on the environmental assessment, recommends adoption of a Mitigated Negative Declaration (“MND”) and a Mitigation Monitoring and Reporting Program (“MMRP”) in accordance with Section 6 (ND Procedures) of the City’s Rules and Procedures for the Implementation of the California Environmental Quality Act and the requirements of the CEQA Guidelines Sections 15070- 15075; and
WHEREAS, a Notice of Intent to Adopt a Mitigated Negative Declaration was duly noticed and circulated for public review for a period of 30 days commencing on April 21, 2026, through May 21, 2026; and
WHEREAS, in compliance with CEQA and the CEQA Guidelines, a Mitigation Monitoring and Reporting Program (“MMRP”), which is a program for reporting and monitoring the Proposed Project’s mitigation measures, was prepared for the Proposed Project and circulated with the Mitigated Negative Declaration; and 1Public Resources Code §§ 21000-21177
2California Code of Regulations §§15000-15387
WHEREAS, on June 11, 2026, a duly noticed Public Hearing was conducted by the Planning Commission to consider the approval of the Proposed Project; and 2424
2 Resolution No. 2026-XX
Date Adopted: September 1, 2026
WHEREAS, on June 11, 2026, the Planning Commission voted 2 ayes and 3 noes on a motion to approve the requested Conditional Use Permit (PEN24-0154), which effectively resulted in the Proposed Project not being approved, since no alternative motion was offered nor was there any alternative action taken by the Planning Commission; and
WHEREAS, the Applicant filed a timely Appeal Application (PAA26-0003) appealing the Planning Commission’s action to not approve Conditional Use Permit (PEN24-0154); and
WHEREAS, on September 1, 2026, a duly noticed Appeal Hearing was conducted by the City Council to consider the Appeal Application (PAA26-0003) along with Conditional Use Permit (PEN24-0154) and the Initial Study/Mitigated Negative Declaration, Mitigation Monitoring and Reporting Program prepared for the Proposed Project; and
WHEREAS, at the conclusion of the public hearing, in the exercise of its own independent judgment, the City Council determined that the Initial Study/Mitigated Negative Declaration and the Mitigation Monitoring and Reporting Program prepared for the Proposed Project has reduced the potential impacts of the Proposed Project to levels of insignificance and there is no substantial evidence supporting a fair argument that the Project will have a significant effect on the environment in a manner that otherwise would require the preparation and certification of an Environmental Impact Report.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF MORENO VALLEY, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

Section 1. Recitals and Exhibits
That the foregoing Recitals and attached exhibits are true and correct and are hereby incorporated by this reference.

Section 2. Evidence
That the City Council has considered all of the evidence submitted into the Administrative Record for the MND and MMRP, including, but not limited to, the following:
(a) Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program prepared for the Proposed Project, attached hereto as Exhibits A and B, respectively;
(b) Notice of Intent to Adopt a Mitigated Negative Declaration, attached hereto as Exhibit C;
(c) Staff Reports prepared for the Planning Commission and City Council’s consideration and all documents, records, and references related thereto, and Staff’s presentation at the public hearings; and
(d) Testimony and/or comments from all persons that were provided in written format or correspondence, at or prior to the Public Hearings.

Section 3. Findings
2425
3 Resolution No. 2026-XX
Date Adopted: September 1, 2026
That based on the content of the foregoing Recitals and the Evidence contained in the Administrative Record as set forth above, the City Council makes the following findings:
(a) That all environmental impacts of the Proposed Project, with the mitigation measures set forth in the MMRP, have been reduced to levels of insignificance and there is no substantial evidence supporting a fair argument that the Proposed Project will have a significant effect on the environment that would otherwise require the preparation and certification of an Environmental Impact Report;
(b) That the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program have been completed in compliance with CEQA and CEQA Guidelines and are consistent with the City’s Rules and Procedures for the Implementation of the California Environmental Quality Act; (c) That the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program represent the independent judgment and analysis of the City as lead agency for the Proposed Project; and
(d) That the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program are adequate to serve as the required CEQA environmental documentation for the Proposed Project.

Section 4. Adoption
That, based on the foregoing Recitals and Evidence, Administrative Record and Findings, the City Council hereby adopts the IS/MND attached hereto as Exhibits A, respectively, and the MMRP attached hereto as Exhibit B.

Section 5. Repeal of Conflicting Provisions
That all the provisions as heretofore adopted by the City Council that are in conflict with the provisions of this Resolution are hereby repealed.

Section 6. Severability
That the City Council declares that, should any provision, section, paragraph, sentence or word of this Resolution be rendered or declared invalid by any final court action in a court of competent jurisdiction or by reason of any preemptive legislation, the remaining provisions, sections, paragraphs, sentences or words of this Resolution as hereby adopted shall remain in full force and effect.

Section 7. Effective Date
That this Resolution shall take effect immediately upon the date of adoption.

Section 8. Certification
That the City Clerk shall certify to the passage of this Resolution.

APPROVED AND ADOPTED this 1
st day of September, 2026.
2426
4 Resolution No. 2026-XX
Date Adopted: September 1, 2026
Ulises Cabrera
Mayor
City of Moreno Valley
ATTEST:

M. Patricia Rodriguez, MMC, City Clerk
APPROVED AS TO FORM:

Steven B. Quintanilla, City Attorney
Exhibits:

Exhibit A: Initial Study/Mitigated Negative Declaration Exhibit B: Mitigation Monitoring & Reporting Program
Exhibit C: Notice of Intent to Adopt a Mitigated Negative Declaration 2427
5 Resolution No. 2026-XX
Date Adopted: September 1, 2026

RESOLUTION JURAT

STATE OF CALIFORNIA )
COUNTY OF RIVERSIDE ) ss.

CITY OF MORENO VALLEY )
I, M. Patricia Rodriguez, MMC, City Clerk of the City of Moreno Valley, California, do hereby certify that Resolution No. 2026-XX was duly and regularly adopted by the City Council of the City of Moreno Valley at a regular meeting thereof held on the 1st day of September, 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
(Council Members, Mayor Pro Tem and Mayor)
M. PATRICIA RODRIGUEZ, MMC, CITY CLERK
(SEAL)
2428
6 Resolution No. 2026-XX
Date Adopted: September 1, 2026
Exhibit A

INITIAL STUDY / MITIGATED NEGATIVE DECLARATION
2429
7 Resolution No. 2026-XX
Date Adopted: September 1, 2026
Exhibit B

MITIGATION MONITORING AND REPORTING PROGRAM
2430
8 Resolution No. 2026-XX
Date Adopted: September 1, 2026
Exhibit C

NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION 2431

CITY OF

MORENO VALLEY

DRAFT INITIAL STUDY AND

MITIGATED NEGATIVE DECLARATION FOR

PUBLIC STORAGE MORENO VALLEY
Public Storage Moreno Valley Project (City Case No. PEN24-0154, PEN24-0155) April 2026
Lead Agency

CITY OF MORENO VALLEY
14177 Frederick Street
Moreno Valley, California 92552
Prepared By
LSA ASSOCIATES, INC.
3210 El Camino Real, Suite 100
Irvine, California 92602
(949) 553-0666
W HE R E [)R EAMS S O A R
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Public Storage Moreno Valley i City of Moreno Valley

TABLE OF CONTENTS
MITIGATED NEGATIVE DECLARATION ....................................................................... 1 BACKGROUND INFORMATION AND PROJECT DESCRIPTION:................................ 8 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: ....................................... 18 DETERMINATION (To be completed by the Lead Agency): ......................................... 18 EVALUATION OF ENVIRONMENTAL IMPACTS:........................................................ 19 ISSUES & SUPPORTING INFORMATION SOURCES: ............................................... 21 I. AESTHETICS .......................................................................................... 21 II. AGRICULTURE AND FOREST RESOURCES ....................................... 23 III. AIR QUALITY .......................................................................................... 24 IV. BIOLOGICAL RESOURCES ................................................................... 33 V. CULTURAL RESOURCES ...................................................................... 38 VI. ENERGY.................................................................................................. 40 VII. GEOLOGY AND SOILS........................................................................... 43 VIII. GREENHOUSE GAS EMISSIONS.......................................................... 47 IX. HAZARDS AND HAZARDOUS MATERIALS .......................................... 51 X. HYDROLOGY AND WATER QUALITY ................................................... 56 XI. LAND USE AND PLANNING................................................................... 60 XII. MINERAL RESOURCES ......................................................................... 62 XIII. NOISE...................................................................................................... 62 XIV. POPULATION AND HOUSING ............................................................... 68 XV. PUBLIC SERVICES................................................................................. 69 XVI. RECREATION ......................................................................................... 71 XVII. TRANSPORTATION................................................................................ 72 XVIII. TRIBAL CULTURAL RESOURCES......................................................... 75 XIX. UTILITIES AND SERVICE SYSTEMS..................................................... 79 XX. WILDFIRE................................................................................................ 83 XXI. MANDATORY FINDINGS OF SIGNIFICANCE ....................................... 84 REFERENCES.............................................................................................................. 88 2433
Public Storage Moreno Valley ii City of Moreno Valley

FIGURES
Figure 1: Regional and Project Location ....................................................................... 16 Figure 2: Site Plan......................................................................................................... 17 TABLES
Table A: Short-Term Regional Construction Emissions ................................................ 28 Table B: Long-Term Regional Operational Emissions................................................... 28 Table C: Project Localized Construction and Operational Emissions............................ 30 Table D: Health Risks from Project Construction to Off-Site Receptors........................ 31 Table E: Health Risks from Project Construction to Off-Site Receptors with Mitigation. 32 Table F: Estimated Annual Energy Use of Proposed Project ........................................ 41 Table G: Greenhouse Gas Emissions........................................................................... 48 Table H: Typical Construction Equipment Noise Levels................................................ 63 Table I: Construction Noise Levels by Phase................................................................ 64 Table J: Vibration Source Amplitudes for Construction Equipment Error! Bookmark not defined.

Table K: Project Trip Generation................................................................................... 73 2434
Public Storage Moreno Valley iii City of Moreno Valley
APPENDICES (Separate Documents)
Appendix A: Air Quality, Energy, and Greenhouse Gas Technical Memorandum for the Proposed Moreno Valley Public Storage Project in Moreno Valley, California, LSA, March 2025.

Appendix B: Health Risk Assessment, Public Storage Moreno Valley Project, LSA, March 2025.

Appendix C: Western Riverside County Multiple Species Habitat Conservation Plan Consistency Analysis and Biology Report, Moreno Valley Public Storage Project, MSHCP Permittee: City of Moreno Valley, LSA, January 2025.

Appendix D: Cultural Resources Assessment, Public Storage Moreno Valley Project, City of Moreno Valley, Riverside County, California, LSA, February 2025.

Appendix E: Geotechnical Engineering Exploration and Analysis, Proposed Public Storage Facility SEQ Indian Street and Alessandro Boulevard, Moreno Valley, California, May 2024.

Appendix F: Phase I Environmental Site Assessment conducted on CA24007 Alessandro Boulevard and Indian Street, Moreno Valley, California 92553, Apex Companies, LLC, April 2024.

Appendix G: Project Specific Water Quality Management Plan, DRC Engineering Inc., October 2025.

Appendix H: Preliminary Hydrology Study for Public Storage – Moreno Valley, DRC Engineering Inc., July 2024.

Appendix I: Noise and Vibration Impact Analysis: Proposed Public Storage Moreno Valley Project in the City of Moreno Valley, California, LSA, February 2025.

Appendix J: Trip Generation and Vehicle Miles Traveled Analysis for the Public Storage Moreno Valley Project (LSA Project No. 20241908) City of Moreno Valley, LSA, October 2024.
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Public Storage Moreno Valley Page 1 City of Moreno Valley

MITIGATED NEGATIVE DECLARATION
Project Name: Public Storage Moreno Valley Project
Project Location: The Public Storage Moreno Valley Project (project) site is located in Township 3S, Range 3W, Section 7 of the Sunnymead, California, United States Geological Survey (USGS) 7.5-minute quadrangle map of the San Bernardino Baseline and Meridian. The project site (Assessor’s Parcel Number [APN] 482-190-022) is located along Indian Street, north of Alessandro Boulevard in Moreno Valley, Riverside County, California. The project site is bounded by self-storage uses to the north, residential uses to the east, commercial uses (gasoline station and auto parts store) to the south, and Indian Street and commercial/retail uses to the west. Figure 1 depicts the regional and project locations. State Route 60 (SR-60) is located approximately 1.5 miles north of the project site, and Interstate 215 (I-215) is located approximately 3 miles west of the project site.

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 listed in the table below. These mitigation measures would also be adopted as part of the attached Mitigation Monitoring and Reporting Program.

Mitigation Measures:

No. Mitigation Measure
Air Quality
MM AIR-1 During construction of the proposed project, the project contractor shall ensure all off-road diesel-powered construction equipment of 50 horsepower or more that are used for project construction meet, at a minimum, the California Air Resources Board Tier 2 emissions standards equipped with Level 3 Diesel Particulate Filters or the equivalent.

Biological Resources
MM BIO-1 A nesting bird pre-construction survey shall be conducted by a qualified biologist three days prior to ground-disturbing activities if working within the bird nesting season (January 1 through August 31). Should nesting birds be found, an exclusionary buffer shall be established by the qualified biologist.

The buffer may be up to 500 feet in diameter depending on the species of nesting bird found. This buffer shall be clearly marked in the field by construction personnel under guidance of the qualified biologist and construction or clearing shall not be conducted within this zone until the qualified biologist determines that the young have fledged, or the nest is no longer active. If there is a lapse in construction activities longer than seven days, an additional pre-construction survey shall be conducted. 2436
Public Storage Moreno Valley Page 2 City of Moreno Valley No. Mitigation Measure
Cultural Resources
MM CUL-1 Prior to the start of earth moving activities, the Project Applicant shall retain an archaeologist to conduct cultural resources sensitivity training for all construction personnel. Construction personnel shall be informed of the types of archaeological resources that may be encountered, and of the proper procedures to be enacted in the event of an inadvertent discovery of precontact or historic archaeological resources or human remains. The Project Applicant shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance. This measure shall be implemented to the satisfaction of the City of Moreno Valley, Planning Division.

MM CUL-2 A qualified professional archaeologist (either an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archeology or an archaeologist supervised by such an archaeologist) shall monitor all construction-related ground-disturbing activities. Archaeological monitoring shall occur during these excavation activities until the Project Archaeologist, based on their observations, is satisfied that there is little likelihood of encountering intact archaeological deposits. The Project Archaeologist may also determine that it is appropriate to reduce monitoring to spot-checking on a part-time basis.

Geology and Soils
MM GEO-1 If paleontological resources (fossils) are discovered during project grading, work shall be halted within 100 feet of the find until a qualified paleontologist assesses the significance of the find. Work occurring outside of the 100-foot buffer zone may continue. The project paleontologist shall monitor remaining earthmoving activities at the project site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the State CEQA Guidelines and offered for curation at an accredited facility approved by the City of Moreno Valley. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. This measure shall be implemented to the satisfaction of the City Planning Division.
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Public Storage Moreno Valley Page 3 City of Moreno Valley No. Mitigation Measure
Noise
MM NOI-1 Construction Vibration Assessment. Due to the close proximity to surrounding structures, the City of Moreno Valley (City) Director of Community Development, their designee, and the Developer/Applicant shall verify prior to issuance of grading permits that the approved plans require that the construction contractor shall implement the following reduction measures during project construction activities to ensure that damage does not occur at surrounding structures:
• The first step in the Vibration Assessment should be a determination if any structures are within 15 feet of potential heavy construction activities. If is determined that no structures meet this criteria, no further effort is necessary.
• If heavy construction equipment is necessary, structures that are located within 15 feet of heavy construction activities and that have the potential to be affected by ground-borne vibration should be identified.

This task shall be conducted by a qualified structural engineer as approved by the City’s Director of Community Development, or designee.
• Once the construction equipment list finalized, a comparison of the proposed equipment to be used and the assumed equipment vibration levels presented in Table 7-4 of the Federal Transit Administration’s (FTA) Noise and Vibration Impact Assessment Manual (FTA Report No. 0123) shall be completed. If it is determined that the proposed equipment would generate lower vibration levels than assumed, further vibration assessment would not be necessary. However, if levels would potentially exceed the City’s standard of 0.2 inch per second peak particle velocity (PPV), the project Applicant/Developer shall develop a vibration monitoring and construction contingency plan for approval by the City Director of Community Development, or designee, to identify structures where monitoring would be conducted; set up a vibration monitoring schedule; define structure-specific vibration limits; and address the need to conduct photo, elevation, and crack surveys to document before and after construction conditions.

Construction contingencies would be identified for when vibration levels approached the limits.
• If a vibration monitoring and construction contingency plan is deemed necessary, monitoring of vibration during initial construction activities would be required. Monitoring results may indicate the need for more or less intensive measurements.
• When vibration levels approach limits, suspend construction and implement contingencies as identified in the approved vibration monitoring and construction contingency plan to either lower vibration levels or secure the affected structures.
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Public Storage Moreno Valley Page 4 City of Moreno Valley No. Mitigation Measure
Tribal Cultural Resources
MM 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 the project site. 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 Pechanga Tribe, including the contractor, and the City, shall develop a CRMP as defined in TCR-3, below. 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.

MM TCR-2 Native American Monitoring. Prior to the issuance of a grading permit, the Developer shall secure agreements with the Pechanga Tribe 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.

MM TCR-3 Cultural Resource Monitoring Plan (CRMP). The Project Archaeologist, in consultation with the Pechanga Tribe, 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:
• Project description and location;
• Project grading and development scheduling;
• Roles and responsibilities of individuals on the Project; • The pre-grading meeting and Cultural Resources Worker Sensitivity Training details;
• The protocols and stipulations that the contractor, City, Pechanga Tribe 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;
• The type of recordation needed for inadvertent finds and the stipulations of recordation of sacred items;
• Contact information of relevant individuals for the Project. 2439
Public Storage Moreno Valley Page 5 City of Moreno Valley No. Mitigation Measure
MM 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:
• 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:
o 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.
o 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 CR 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 Consulting Native American Tribal Governments prior to certification of the environmental document.

MM TCR-5 Potential Discovery of Archaeological and Cultural Resources. 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.”
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Public Storage Moreno Valley Page 6 City of Moreno Valley No. Mitigation Measure
MM TCR-6 Inadvertent Finds. If potential historic or cultural resources are uncovered during excavation or construction activities at the project site 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 Director, 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(s), and shall be submitted to the City for their review and approval prior to implementation of the said plan. Pursuant to Calif. Pub. Res. Code § 21083.2(b) avoidance is the preferred method of preservation for archaeological resources and cultural resources.

MM 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 Pechanga Tribe.

MM 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).
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Public Storage Moreno Valley Page 7 City of Moreno Valley No. Mitigation Measure
MM 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 the Pechanga Tribe’s Cultural Resources Department.
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Public Storage Moreno Valley Page 8 City of Moreno Valley

INITIAL STUDY (IS) FOR

PUBLIC STORAGE MORENO
VALLEY
BACKGROUND INFORMATION AND PROJECT DESCRIPTION:

1. Project Case Number(s): PEN24-0154, PEN24-0155

2. Project Title: Public Storage Moreno Valley Project

3. Public Comment Period: April 21, 2026 to May 21, 2026

4. Lead Agency: City of Moreno Valley
Gabriel Diaz, Associate Planner
Community Development Department
14177 Frederick Street
Moreno Valley, California 92553
(951) 413-3226
[email protected]

5. Documents Posted At: https://moval.gov/cdd/documents/about-projects.html

6. Prepared By: Jazmine Estores, Environmental Planner
LSA Associates, Inc.
3210 El Camino Real, Suite 100
Irvine, California 92602
(949) 553-0666
[email protected]

7. Project Sponsor:

Applicant/Developer Property Owner
Kristofer Golder, VP of Development Vinod Kardani
Public Storage 1193 Village Drive
701 Western Avenue
Glendale, California 91201
Chino Hills, California 91709
[email protected]
(818) 230-7234
[email protected]

8. Project Location: The project is located in Township 3S, Range 3W, Section 7 of the Sunnymead, California United States Geological Survey (USGS) 7.5-minute quadrangle map of the San Bernardino Baseline and Meridian. The project site (Assessor’s Parcel Number [APN] 482-190-022) is located along Indian Street, north of Alessandro Boulevard in Moreno Valley, Riverside County. The project site is bounded by self-storage uses to the north, residential uses to the east, commercial uses (gasoline station and auto parts store) to the south, and Indian Street and commercial/retail uses to the west. Figure 1 depicts the regional and project locations. State Route 60 (SR-60) is located approximately 1.5 miles north of the

WHERE OR EAMS SOAR
2443
Public Storage Moreno Valley Page 9 City of Moreno Valley project site, and Interstate 215 (I-215) is located approximately 3 miles west of the project site.

9. General Plan Designation: Commercial: The primary purpose of areas designated Commercial is to provide property for business purposes, including, but not limited to retail stores, restaurants, banks, hotels, professional offices, personal services, and repair services. The zoning regulations identify the specific uses permitted on each parcel of land in the City, which could include compatible noncommercial uses.

Commercial development intensity should not exceed a Floor Area Ratio (FAR) of

1.00 and the average floor area ratio should be significantly less. Further, it should be noted that the City is in the process of finalizing the adoption of its 2040 General Plan Update (GP Update). Land use designations for the project site and surrounding properties are expected to remain the same from the 2006 GP to the 2040 GP Update.

10. Specific Plan Name and Designation: Not Applicable

11. Existing Zoning: Existing: Neighborhood Commercial (NC): The primary purpose of the Neighborhood Commercial (NC) district is to satisfy the daily shopping needs of Moreno Valley residents by providing construction of conveniently located neighborhood centers that provide limited retail commercial services. These centers must be compatible with the surrounding residential communities. 1 Proposed: Community Commercial (CC): The primary purpose of the community commercial (CC) district is to provide for the general shopping needs of area residents and workers with a variety of business, retail, personal and related or similar services. (Ord. 359, 1992; Ord. 590 § 2, 2001).2 The project would provide self-storage services to residents and workers in the City and would be consistent with the current Commercial General Plan land use designation of the project site. The project includes a zone change from Neighborhood Commercial (NC) District to Community Commercial (CC) District in order to facilitate the proposed development. The project site is located south of an existing self-storage facility and in proximity to existing commercial uses west of Indian Street and south of the project site. Due to the uses surrounding the project site, the proposed development would incorporate seamlessly with the existing development pattern of the neighborhood and would serve the residential uses and businesses in the vicinity of the site and provide them with the convenience of storage amenities close to home. As described above, the City is in the process of finalizing and adopting its 2040 GP Update. Under the proposed 2040 GP Update, the project site’s zoning would change from NC to Corridor Mixed Use (CMU). The CMU zone would allow self-storage uses as a permitted use by right. 1 City of Moreno Valley. 2024. City of Moreno Valley Municipal Code, Section 9.04.020, Commercial development districts. 2 Ibid.
2444
Public Storage Moreno Valley Page 10 City of Moreno Valley

12. Surrounding Land Uses and Setting:

Land Use General Plan Zoning
Project
Site Vacant Commercial
Existing: Neighborhood Commercial
(NC) District*; Proposed:

Community Commercial (CC)
District
North Self-storage facility Commercial Community Commercial (CC) District
South Gasoline station and
auto parts store Commercial Neighborhood Commercial (NC) District East Residential uses Residential: Max. 5
dwelling units/acre
Residential 5 District (R5)
West Indian Street and
commercial/retail uses
Commercial Community Commercial (CC)
District
* Under the City’s proposed 2040 General Plan, the project site’s zoning would change to Corridor Mixed Use (CMU).

13. Description of the Site and Project:

Environmental Setting
The project site is located along Indian Street, north of Alessandro Boulevard, and is substantially surrounded by commercial and residential uses. The site itself is vacant and contains ruderal vegetation. The property was previously used for agriculture from 1938 to 1997.

Project Description
The proposed project includes development of a 130,764-square-foot, three-story, self-storage building, 12 passenger vehicle parking spaces, 6 bicycle parking spaces, and 52 recreational vehicle (RV) parking spaces. The proposed project includes up to two employees per shift to operate the facility.3 Office hours would be 9:00 a.m. to 6:00 p.m. Customer access hours would be 6:00 a.m. to 9:00 p.m.

According to the City’s existing Zoning map and the City’s existing General Plan, the project site is zoned Neighborhood Commercial (NC) and has a land use designation of Commercial. Per City Municipal Code Permitted Uses Table 9.02.020-1 in Section

9.02.020,4 self-storage facilities are not permitted uses in the Neighborhood Commercial (NC) zone, so the project includes a zone change to change the zoning designation of the project site from Neighborhood Commercial (NC) to Community Commercial (CC) and a Conditional Use Permit (CUP) to allow development of the proposed project within the Community Commercial (CC) zone. As noted above, under the City’s proposed 2040 GP Update, the project site’s zoning would change from NC to CMU. The CMU zone would allow mini-storage uses as a permitted use with the approval of a Conditional Use Permit (CUP).

The proposed project includes development of an approximately 130,764-squarefoot self-storage building, inclusive of self-storage area and a rental office. The proposed building would consist of three stories above ground level, reaching a maximum height of approximately 42 feet. The on-site rental office would be located 3 Assumes up to two shifts per day.
4 City of Moreno Valley. 2024. Municipal Code, Permitted Uses, Table 9.02.020-1. 2445
Public Storage Moreno Valley Page 11 City of Moreno Valley in the southeastern corner of the building. An approximately 16-foot setback would be provided between the proposed self-storage building and the western property boundary along Indian Street, and a 10-foot setback would be provided between the RV parking lot and the eastern property boundary. Setbacks to the north and south would be approximately 6 feet and 45 feet, respectively. Tubular steel fencing, with attached privacy screening, would be erected 7 feet high along the southern boundaries of the project site in the secured area separating the project site from adjacent commercial uses, and a decorative concrete masonry unit (CMU) wall would be constructed 6 feet high along the southern and eastern property boundaries to separate the project site from adjacent residential uses. Along the northern property line, the existing adjacent buildings located at the property line would secure the site. All on-site drive aisles and passenger vehicle and RV parking would be constructed on the eastern half of the project site.

Vehicular access to the project site would be provided via Indian Street and the existing shared access driveway south of the proposed self-storage building. The access driveway would lead to two access gates, one on the east side of the proposed self-storage building facilitating access to the northern portion of the project site, and the other gate also on the east side of the proposed self-storage building facilitating access to the eastern portion of the project site. The proposed RV parking lot would include 52 RV spaces. Additionally, 12 passenger vehicle parking spaces, including one Americans with Disabilities Act (ADA) compliant space, and 6 bicycle parking spaces would be provided adjacent to the east of the proposed self-storage building. In accordance with Section 9.11.040 of the City’s Municipal Code,5the proposed parking space supply would be adequate to accommodate the proposed project’s parking demand.

The project would include installation of landscaping and trees along the project site frontage of Indian Street, as well as landscaping along the project site setbacks to the north, east, and south. Additionally, the project would interconnect to existing sewer, water, electric, and telecommunications utilities within the Indian Street rightof-way. The building would be all electric and would not include natural gas connections.

Construction would include excavation to depths of at least 5 feet below the proposed grade or 3 feet below the bottom of the proposed foundations and floor slabs, whichever is deeper; grading, paving, and construction of the proposed selfstorage building and parking areas; and the installation of lighting, fencing, and landscaping. The project also includes trenching from the proposed self-storage building into the right-of-way of Indian Street to facilitate utility interconnections.

During grading, on-site soils would be excavated and recompacted in accordance with the California Building Code (CBC) to accommodate the proposed self-storage building and parking areas. Construction equipment anticipated to be used includes rubber-tired dozers, tractors/loaders/backhoes, excavators, graders, scrapers, cranes, forklifts, generators, welders, air compressors, and paving equipment.

Construction parking and staging would occur on the project site. However, it is possible there would be temporary lane closures necessary along Indian Street during project construction. Construction hours would conform to City standards. 5 City of Moreno Valley. 2024. City of Moreno Valley Municipal Code Section 9.11.040, Off-street parking requirements. 2446
Public Storage Moreno Valley Page 12 City of Moreno Valley Grading activities would be limited to between the hours of 7:00 a.m. and 7:00 p.m.

Monday through Friday and between the hours of 8:00 a.m. and 4:00 p.m. on Saturday in accordance with City Municipal Code Section 8.21.050(O). The operation of any tools or equipment used in construction, drilling, repair, alteration or demolition work, would be limited to between the hours of 7:00 a.m. and 8:00 p.m. every day in accordance with City Municipal Code Section 11.80.030(D)(7).

Approximately 4,210 cubic yards of soil export (cut) would be required for excavation, compaction, and rough grading.

Construction of the project will take approximately 12 months and is expected to be completed in Q3 2028.

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.

On March 27, 2025, the City sent Assembly Bill (AB) 52 outreach letters to tribes traditionally and culturally affiliated with the City. The letters, sent via certified mail to the tribal contacts, described the project, provided maps of the proposed project site, and invited the tribes to request consultation should they have any concerns.

Representatives with the Agua Caliente, Pechanga, and Rincon tribes responded with the request to incorporate selected mitigation measures associated with Tribal Cultural Resources as part of this Draft IS/MND.

Per AB 52 requirements, the City is continuing to follow up with the Pechanga Tribe in order to ensure any concerns or comments are captured within the tribal consultation process for the proposed project and also ensuring that the Tribal Cultural Resources mitigation measures included as part of this document reflect the best practices for handling any potential Tribal Cultural Resources that may be encountered during construction activities for the proposed project. Please refer to Section V, Cultural Resources, and Section XVIII, Tribal Cultural Resources, of this Draft IS/MND for more information regarding tribal consultation efforts conducted in association with the proposed project.15. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):
a. City of Moreno Valley: Approval of Change of Zone.
b. City of Moreno Valley: Approval of Conditional Use Permit (CUP). c. City of Moreno Valley: Approval of Grading and Building Permits. d. Santa Ana Regional Water Quality Control Board: National Pollutant Discharge Elimination System (NPDES) authorization.
2447
Public Storage Moreno Valley Page 13 City of Moreno Valley

16. Other Technical Studies Referenced in this Initial Study (Provided as Appendices):
a. Appendix A: Air Quality, Energy, and Greenhouse Gas Technical Memorandum
b. Appendix B: Health Risk Assessment (HRA)
c. Appendix C: Western Riverside County Multiple Species Habitat Conservation Plan Consistency Analysis and Biology Report
d. Appendix D: Cultural Resources Assessment
e. Appendix E: Geotechnical Engineering Exploration and Analysis f. Appendix F: Phase I Environmental Site Assessment
g. Appendix G: Water Quality Management Plan
h. Appendix H: Hydrology Report
i. Appendix I: Noise and Vibration Impact Analysis
j. Appendix J: Trip Generation and Vehicle Miles Traveled Analysis

17. Acronyms:

AB Assembly Bill
ADA American with Disabilities Act
ADT average daily traffic
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
APN Assessor’s Parcel Number
AQMP Air Quality Management Plan
Basin South Coast Air Basin
Basin Plan Water Quality Control Plan for the Santa Ana River Basin BMPs best management practices
CAAQS California Ambient Air Quality Standards
Cal OES Governor’s Office of Emergency Services
CAL FIRE California Department of Forestry and Fire Protection CALGreen Code California Green Building Standards Code
CalEEMod California Emissions Estimator Model
CAP Climate Action Plan
CBC California Building Code
CC Community Commercial
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CFR Code of Federal Regulations
CH4 methane
City City of Moreno Valley
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CO carbon monoxide
2448
Public Storage Moreno Valley Page 14 City of Moreno Valley CO2 carbon dioxide
CO2e carbon dioxide equivalent
CO2e/yr carbon dioxide equivalents per year
CUP Conditional Use Permit
CWA Clean Water Act
dBA A-weighted decibel
DEH (Riverside County) Department of Environmental Health, Hazardous Materials Division
DTSC Department of Toxic Substance Control
DWR Department of Water Resources
EIR Environmental Impact Report
EMWD Eastern Municipal Water District
EO Executive Order
FEMA Federal Emergency Management Agency
FIRM Flood Insurance Rate Map
FMMP Farmland Mapping and Monitoring Program
FTA Federal Transit Administration
GHG greenhouse gas
GWh gigawatt-hours
Gya Greenfield sandy loam
HcA Hanford coarse sandy loam
HRA Health Risk Assessment
HVAC Heating, Ventilation, and Air Conditioning
I-215 Interstate 215
in/sec inches per second
IS Initial Study
ITE Institute of Transportation Engineers
kWh kilowatt-hours
Leq equivalent continuous sound level
LID Low Impact Development
LOS Level of Service
LRA Local Responsibility Area
LST Localized Significance Threshold
LUST Leaking Underground Storage Tank
Lw sound power levels
MARB March Air Reserve Base
MARB/IPA March Air Reserve Base/Inland Port Airport
MBTA Migratory Bird Treaty Act of 1918
MEI maximally exposed individual
MLD Most Likely Descendant
mph miles per hour
MSHCP Multiple Species Habitat Conservation Plan
MT metric tons
MVPD Moreno Valley Police Department
MVU Moreno Valley Electric Utility
MVUSD Moreno Valley Unified School District
MWD Metropolitan Water District
MVRWRF Moreno Valley Regional Water Reclamation Facility NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NC Neighborhood Commercial
NCCP Natural Communities Conservation Plan
NETR Nationwide Environmental Title Research
NOx nitrogen oxides
NPDES National Pollutant Discharge Elimination System
2449
Public Storage Moreno Valley Page 15 City of Moreno Valley O3 ozone
OPR Governor’s Office of Planning & Research
PM10 particulate matter less than 10 microns in size
PM2.5 particulate matter less than 2.5 microns in size
ppm parts per million
PPV peak particle velocity
project Public Storage Moreno Valley Project
PWQMP Preliminary Water Quality Management Plan
R5 Residential 5 District
RCFCWCD Riverside County Flood Control & Water Conservation District RCFD Riverside County Fire Department
REC recognized environmental condition
ROG reactive organic gas
RTA Riverside Transit Agency
RTP Regional Transportation Plan
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy RWQCB Regional Water Quality Control Board
SB Senate Bill
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCIC South Coastal Information Center
SDS Safety Data Sheets
SKR HCP Stephens’ Kangaroo Rat Habitat Conservation Plan SMARA Surface Mining and Reclamation Act
SOx sulfur oxides
SR-60 State Route 60
SRA Source Receptor Area, also State Responsibility Area SSC California Species of Special Concern
SWPPP Storm Water Pollution Prevention Plan
SWRCB State Water Resources Control Board
TACs toxic air contaminants
TCP Traditional Cultural Property
TNW traditional navigable waters
USACE United States Army Corps of Engineers
USC United States Code
USDA United States Department of Agriculture
USDOT United States Department of Transportation
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
V/C Volume/Capacity
VdB vibration velocity in decibels
VHFHSZ Very High Fire Hazard Severity Zone
VMT Vehicle Miles Traveled
VOCs volatile organic compounds
WEAP Worker’s Environmental Awareness Program
WQMP Water Quality Management Plan
2450
LSA
0 FEET
500 1000
SOURCE: Google Maps (2024)
l=l Project Location
l:\2024\20241908\GIS\Pro\Moreno Valley Public Storage\Public Storage Moreno Valley Project.aprx (1/12/2025) FIGURE 1
Public Storage Moreno Valley Project
Regional and Project Location
2451
FD
FDFD
1'
8" 6' 6' 25'-2" 6' 20'-2" 6' 8" 6' 20'-2" 6' 6' 25'-2" 6' 1' T
GATE

DUAL BIN
TRASH
5 OFFICE
LOBBY
17 23
11 3-STORY
130,764 SF

RV PARKING
52 SPACES
GATE

PROPOSED SELF STORAGE
(N) 6' HIGH CMU WALL AT REAR (N) 6' HIGH CMU WALL AT REAR (N) 6' HIGH CMU WALL AT REAR
7' H. FENCING
7' HIGH FENCING
6 BIKES
35'
15'
10' SETBACK
+5' FOR EVERY
10'
BLDG HT.

OVER 30'
6' 311'-4"
29'

FIRE AERIAL

SETBACK
18' 36'
40'BLDG SETBACK

EQUALS HEIGHT OF BLDG
141'-4"
ELEC
3 ACCESS EASEMENT

I N D I A N S T R E E T
18'
TYP
9'
TYP
8' 9'
40' BLDG SETBACK

EQUALS HEIGHT

OF BLDG

ACCESSIBLE PATH

OF TRAVEL FROM

PUBLIC R/W
20'
TYP
5'-6"
58' 33'-9"
40'
TYP
4 4.5% MAX RAMP
16'-4"
36'-1"
10'-10" 34'-11"
26'

FIRE ACCESS
28'-6"
FIRE
AERIAL

SETBACK
26'

FIRE AERIAL

ACCESS ROADWAY
R24'
R46'
32'
30'
TYP
12'
TYP
12'
TYP
TRAVEL DISTANCE = 248'
TRAVEL DISTANCE = 145'
EXIT DISTANCE = 228'
EXIT DISTANCE = 130'
6'
16'
196'-8"

TO PROPERTY LINE
45'-1"

EV CAPABLE SP

EV CAPABLE SP

EV CAPABLE SP

EV CAPABLE SP
10'
LS

UNDERGROUND

INFILTRATION SYSTEM
171'-6"
12'-2" 9'
TYP
10'
LS
18'
TYP
5'-6"
0" CURB ONLY

AT LOBBY
12'
12'
EV VAN
5'
0" CURB

TRANSITION TO

FULL HT CURB

OUTSIDE OF

LOBBY, TYP
0" CURB
F.F. 1581.6
(1579.8 TC)
(1579.3 FS)
2:1 SLOPE 2:1 SLOPE DAS
8'-6"
8'-6"
LOBBY
1 3CY 3CY
7' H. FENCING
40'
SLOPE
86'-7"
18'
6'-6"

EXISTING

SIDEWALK
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

SINGLE FAMILY RESIDENTIAL
R-5 ZONE

CC ZONE

SELF-STORAGE FACILITY

NC ZONE NC ZONE AUTO ZONE STORE GAS STATION

CC ZONE

RETAIL CENTRE
37'-6"
TYP
10'
5'
196'
34'

FIRE DEPARTMENT

DEPLOYMENT AREA
34'-0" x 60'-0" MIN.

PROVIDED
35'-0" x 196'-0"
312'-8" 34'
(E) NEIGHBORS' WOOD FENCE (E) NEIGHBOR'S CONC. WALL
(N) 6' HIGH CMU WALL
(E) NEIGHBOR'S
CONC. WALL

FIRE DEPARTMENT

DEPLOYMENT AREA
34'-0" x 60'-0" MIN.

PROVIDED 35'-0" x 312'-8"
(E) NEIGHBOR'S WOOD FENCE
BLACK "TENNIS
COURT"

PRIVACY FENCE

WINDSCREEN
(BLOCK
VISIBILITY 95%)

ACCESS IN & OUT

KEY PADS

ACCESS IN & OUT

KEY PADS

ALL STEP OUTS

SHALL BE
12"+6" CURB
FIRE
5'
5'-6"
BLACK "TENNIS
COURT"

PRIVACY FENCE

WINDSCREEN
(BLOCK
VISIBILITY 95%)
(N) 6' HIGH

CMU WALL

ENCLOSURE W/ SOLID ROOF COVER
PER CITY STD. MVGF-660B-1
CMU WALL: ANGELUS BLOCK,

PLACER CREEK SPLIT-FACE
(E) NEIGHBOR'S
CONC. WALL
ALESSANDRO & INDIAN STREET | MORENO VALLEY, CA SUBMITTAL 01 SUBMITTAL 02 0
1 CONCEPTUAL SITE PLAN

08.20.25 0 5' 20'10'
scale: 1" = 20'
TYPICAL 6' HIGH CMU WALL SCALE:NONE 1
BLACK "TENNIS

WINDSCREEN (B

WITH GROMME

WIND VENTS AT

AND UV RESISTA
6' HIGH CMU WALL
WITH 4" WALL CAP:

ANGELUS BLOCKS PLACER CREEK

SPLIT-FACE BOTH SIDES, APPLY SEALER

PROPOSED SELF-STORAGE
3-STORY
130,764 SF

RV PARKING
52 SPACES
LEGEND
Site Boundary
Vehicle Parking Spaces (12 Total)
Bicycle Parking Spaces (6 Total)
FEET
0 40 80
FIGURE 2
I:\2024\20241908\G\Site_Plan.ai (9/16/2025)
SOURCE: KSP Studios
Public Storage Moreno Valley
Site Plan
LSA c::::J
-
-
2452
Public Storage Moreno Valley Page 18 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 & 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 ofSignificance 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
Gabriel Diaz
Printed Name
City of Moreno Valley
For
April 9, 2026
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2453
Public Storage Moreno Valley Page 19 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 off-site as well as on-site, 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 crossreferenced). 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 2454
Public Storage Moreno Valley Page 20 City of Moreno Valley 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 significant.
2455
Public Storage Moreno Valley Page 21 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. A scenic vista is defined as a viewpoint that provides expansive views of a highly valued landscape for the benefit of the general public. The City of Moreno Valley does not identify any scenic vistas in its General Plan; however, it considers the Box Springs Mountains and Reche Canyon area to the north, the “Badlands” to the east, and the Mount Russell area to the south to be major scenic resources and generally identifies view corridors in the City that provide views of those resources. 6 The City’s General Plan also notes that views of the San Bernardino and San Gabriel Mountains from the valley floor within the City are evident on clear days.

Of the scenic resources described above, only the views of the Box Springs Mountains to the north are consistently available from Indian Street. Views of the San Bernardino Mountains to the northeast are also visible from Indian Street adjacent to the project site; however, views of those mountains are typically obscured from Indian Street by urban development on the east side of the street.

The project site is located along Indian Street, north of Alessandro Boulevard. The project site is bounded by self-storage uses to the north, residential uses to the east, commercial uses (gasoline station and auto parts store) to the south, and Indian Street and commercial/retail uses to the west. Bay Side Park, which is located 0.17-mile northwest of the project site, provides partial views of the Mount Russell area to the southeast. The proposed project would be partially visible from Bay Side Park; however, the height of the proposed project would be consistent with the City’s height standards and the proposed project would not obstruct views of the Mount Russell area. Following completion of the proposed project, views of the Badlands to the east and the San Bernardino Mountains to the northeast of the project site for motorists traveling northbound along Indian Street would be obscured by the proposed project. However, due to development in the surrounding area and along Indian Street, viewers on the roadway only experience these views periodically while passing by development. While the proposed project would potentially block some views of the San Bernardino Mountains and the Badlands, these views are already partially obstructed because of the distance from these resources and intervening land uses. Given the built-out nature of the surrounding area, the project would not result in a substantial adverse impact on a scenic vista. Overall, the development of the proposed project would have a less than significant impact on scenic vistas due to its limited size and height, and no mitigation is required. b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
Response:

Less Than Significant Impact. According to the California Department of Transportation (Caltrans) Scenic Highway Mapping Program, there are no eligible or designated Scenic Highways in the vicinity of the project site.
7 The closest designated or eligible Scenic Highway is State Route 74 (SR-74), located approximately 9.4 miles south of the project site. Due to its distance from the project site and the presence of intervening topography, the project site is not visible from the eligible segment of SR-74 mentioned above. The project site contains a few scattered trees, none of which are considered to be scenic resources. The project site is highly disturbed, and no rock outcroppings or historic buildings are present on the site. Development of the project would not result in damage to any scenic resources.

Therefore, the development of the project will have a less than significant impact related to scenic resources within a State scenic highway, and no mitigation is required. 6 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 7 – Conservation. July. 7 California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map. Website: https://caltrans. maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa (accessed December 13, 2024). □ □ ~ □
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Public Storage Moreno Valley Page 22 City of Moreno Valley 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. The construction phase of the project would introduce the use of construction equipment such as excavators, graders, and bulldozers, etc. The presence of the construction equipment, as well as the construction activities would temporarily alter the scenic quality of the project site. Construction staging areas, including earth stockpiling, storage of equipment and supplies, and related activities would contribute to a change in scenery at the project site, which would be a short-term visual impact. Because construction activities would be temporary, scenic quality impacts during construction would be less than significant. No mitigation is required.

The proposed project features a variety of architectural elements. It is anticipated that the buildings would utilize a combination of colors and/or materials to establish a mix of textural elements while maintaining visual interest. The proposed landscaping would replace the vacant weedy field with a consistent and integrated vegetation palette. Landscaping on site would be provided in accordance with the City’s Municipal Code Chapter 9.17.30 (Landscape and Irrigation Standards), which requires the installation of landscaping on-site. The project would comply with these requirements by using landscaping throughout the site and visible to the public from the street. Although the visual characteristics of the project site would change, the proposed project would replace the existing vacant lot with an attractive, well-designed development using varied architectural elements and massing, landscaping, and color combinations. In addition, the project would be designed and constructed per applicable City Municipal Code and General Plan standards. Therefore, the project would not result in a negative aesthetic effect to the existing visual character or quality of the project site or surroundings. Impacts would be less than significant, and mitigation is not required.
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. The project site presently does not contain any sources of light. Sources of light in the area include street lighting and signal lighting along Indian Street, as well as from the adjacent residential and commercial uses surrounding the project site. Glare can be both a daytime occurrence resulting from light reflecting off reflective surfaces affecting viewers and a nighttime occurrence from light from headlights on nearby moving vehicles and traffic lights.

At night, the project’s interior and exterior building lights and landscape lighting would be visible from the adjacent residential uses, and to a lesser extent, from the surrounding public streets. However, these light sources would not have a significant impact on the night sky, as they would not exceed existing background light levels already present within the surrounding area. In addition, the proposed project would be required to comply with the City of Moreno Valley’s General Plan and Municipal Code requirements for lighting (Chapter 9.08.100 Lighting). Adherence to the City’s Municipal Code requirements would ensure that project-related lighting impacts would be less than significant. No mitigation is required.

Sources of glare as a result of project implementation include reflective building materials and vehicles parked within and traveling to and from the project site. The amount of glare would depend on the location of the reflective surfaces and the direction of the sun. Any glare produced by the reflective surfaces would be temporary, as the location of the sun would be changing throughout the day. Additionally, the City’s Design Review process includes consideration of material composition and colors to reduce the potential for substantial glare from the proposed on-site structures. Therefore, impacts from glare would be less than significant. No mitigation is required.
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Public Storage Moreno Valley Page 23 City of Moreno Valley 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 7-2 – Major Scenic Resources

2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.11 – Aesthetics
- Figure 5.11-1 – Major Scenic Resources

3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code • Section 9.10.110 – Light and Glare
• Chapter 9.16 – Design Guidelines
• Section 9.17.030 G – Heritage Trees
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:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 nonagricultural use? Response:

No Impact. The California Department of Conservation, Farmland Mapping and Monitoring Program (FMMP) compiles important farmland maps pursuant to the provisions of Section 65570 of the California Government Code. According to the FMMP, the project site lies within “Urban and Built-Up Land.”8 There are two sites southeast of the project site along Alessandro Boulevard that are designated as Farmland of Local Importance; however, the project site and the majority of the surrounding area do not contain any designated Farmland. Therefore, no Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would be impacted, and no impact would occur. No mitigation is required. b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?
Response:

No Impact. The California Land Conservation Act of 1965, commonly known as the Williamson Act, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space uses. In return, landowners are given a lower property tax assessment. The project site does not contain land that is enrolled in a Williamson Act contract.9 According to the City’s General Plan,
10 there are no parcels within the City that are under a Williamson Act contract. In addition, the project site is zoned Neighborhood Commercial (NC) and would be rezoned to Community Commercial (CC). Therefore, the proposed project is not zoned for agricultural 8 California Department of Conservation. 2020. Farmland Mapping and Monitoring Program, California Important Farmland Finder.

Website: https://www.conservation.ca.gov/dlrp/fmmp/Pages/Riverside.aspx (accessed December 16, 2024). 9 California Department of Conservation. 2023. California Williamson Act Enrollment Finder. Website: https://maps.conservation. ca.gov/dlrp/WilliamsonAct/ (accessed December 23, 2024). 10 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 7 – Conservation, Page 7-12. July. □ □ □ ~
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Public Storage Moreno Valley Page 24 City of Moreno Valley uses and is not part of a Williamson Act contract. No impact associated with a Williamson Act contract or agricultural zoning would occur. No mitigation is required. 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. The project site is currently vacant and undeveloped. The site does not contain any forest land or timberland, nor is it zoned for such uses. Therefore, the proposed project will have no impact on forest land, timberland, or timberland zoned Timberland Production. No mitigation is required. d) Result in the loss of forest land or conversion of
forest land to non-forest use?
Response:

No Impact. Please refer to Checklist Response II(c). The project site is located within an urbanized area and does not contain forest land. There is no forest land on the project site and the proposed zoning would not permit such uses. No impact would occur, and no mitigation is required. 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 noted above, the project site is currently vacant and not utilized for agricultural production or timberland production. The project site is not directly adjacent to areas used for or zoned for agriculture or forest uses. Therefore, the proposed project would not result in the conversion of farmland to nonagricultural use or forest land to non-forest uses. No impact would occur, and no mitigation is required.

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 5.8-1 – Important Farmlands

3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code 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:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct implementation of the
applicable air quality plan?
Response:

Less Than Significant Impact. A consistency determination plays an essential role in local agency project review by linking local planning and unique individual projects to the air quality plans. A consistency determination fulfills the California Environmental Quality Act (CEQA) goal of fully informing local agency decision-makers of the environmental costs of the project under consideration at a stage early enough to ensure that air quality concerns are addressed. Only new or amended General Plan elements, Specific Plans, and significantly unique projects need to undergo a consistency review due to the air quality plan strategy being based on projections from local General Plans.

The proposed project would construct a 130,764-square-foot, three-story, self-storage building and associated site improvements including 19,437 square feet of landscaping. The proposed project is not □ □ □ ~
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Public Storage Moreno Valley Page 25 City of Moreno Valley considered a project of statewide, regional, or areawide significance (e.g., large-scale projects such as airports, electrical generating facilities, petroleum and gas refineries, residential development of more than 500 dwelling units, or shopping centers or business establishments employing more than 1,000 persons or encompassing more than 500,000 square feet of floor space) as defined in the California Code of Regulations [(CCR) Title 14, Division 6, Chapter 3, Article 13, §15206(b)]. Because the proposed project would not be defined as a regionally significant project under CEQA, it does not meet the Southern California Association of Governments (SCAG) Intergovernmental Review criteria.

The City’s General Plan is consistent with the SCAG’s Regional Comprehensive Plan Guidelines and the South Coast Air Quality Monitoring District’s (SCAQMD) Air Quality Management Plan (AQMP). Pursuant to the methodology provided in the SCAQMD CEQA Air Quality Handbook, consistency with the South Coast Air Basin (Basin) 2022 AQMP is affirmed when a project (1) would not increase the frequency or severity of an air quality standards violation or cause a new violation, and (2) is consistent with the growth assumptions in the AQMP. Consistency review is presented as follows:

1. The project would result in short-term construction and long-term operational pollutant emissions that are less than the (CEQA) significance emissions thresholds established by SCAQMD, as demonstrated below; therefore, the project would not result in an increase in the frequency or severity of an air quality standards violation or cause a new air quality standards violation.

2. The CEQA Air Quality Handbook indicates that consistency with AQMP growth assumptions must be analyzed for new or amended General Plan elements, Specific Plans, and significant projects. Projects of statewide, regional, or areawide significance include large-scale projects such as airports, electrical generating facilities, petroleum and gas refineries, residential developments of more than 500 dwelling units, and shopping centers or business establishments employing more than 1,000 persons or encompassing more than 500,000 square feet of floor space), as defined in CCR Title 14, Division 6, Chapter 3, Article 13, Section 15206(b). As discussed in the Project Location and Description section, the project site is currently zoned as NC and has a land use designation of Commercial. Per the City Municipal Code Permitted Uses Table 9.02.020-1 in Section 9.02.020,11 self-storage facilities are not permitted uses in the NC zone. Therefore, the proposed project would require a zone change to change the zoning designation of the project site from NC to CC and a Conditional Use Permit (CUP) to allow development of the proposed project within the CC zone.

The projections in the AQMP for achieving air quality goals are based, in part, on assumptions in SCAG’s Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS) regarding population, housing, and growth trends, as well as assumptions and projections of local planning agencies to determine control strategies for regional compliance status. According to SCAG’s 2024–2050 RTP/SCS, the City’s households and employment are forecast to increase by approximately 21,900 households and 38,700 jobs, respectively, between 2019 and 2050.12 The City’s General Plan has a year 2040 buildout horizon; however, the General Plan does not specify or anticipate when complete buildout would occur because long-range demographic and economic trends are speculative. Further, it should be noted that the City is currently in the process of finalizing the adoption of its 2040 GP Update. Regardless of when the City’s 2040 General Plan is approved, this information from SCAG’s 2024-2050 RTP/SCS would remain the same. The designation within the General Plan of a site for a certain use does not necessarily mean that the site would be developed with that use during the planning period because most development depends on property owner initiative.

Based on information provided by the Applicant/Developer, the proposed project would include up to two employees per shift to operate the facility.13 Therefore, the proposed project has the potential to employ up to four employees, some of which may already reside in Moreno Valley.

According to SCAG, up to four employees would represent approximately 0.0001 percent of the City’s forecasted employment growth of 38,700 employees from 2019 to 2050. Therefore, the employment growth associated with the proposed project would be within the parameters of the expected overall growth in the City, and a zone change designation of the site from NC to CC for 11 City of Moreno Valley. 2024. Permitted Uses Table 9.02.020-1. Website: https://ecode360.com/attachment/MO4973/MO4973- 009a%20Permitted%20Uses%20Table%209.02.020-1.pdf (accessed January 2025). 12 Southern California Association of Governments (SCAG). 2024. 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy. Demographics and Growth Forecast, Technical Report, Table 13. Adopted April 4, 2024. 13 Assumes up to two shifts per day.
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Public Storage Moreno Valley Page 26 City of Moreno Valley development of the proposed 130,764-square-foot, three-story, self-storage building would not result in growth in the area or in Moreno Valley beyond that which was planned for by SCAG.

This is because the proposed project is intended to meet the storage needs of those who already live and/or work in the surrounding area.

Furthermore, the 2024–2050 RTP/SCS analyzed the region’s transportation system, future growth projections, and potential funding sources in order to develop a long-term framework for transportation improvements and maintenance.14 The RTP includes policies and regulations set forth to ensure that development of transportation infrastructure within the SCAG regional area is within planned and forecasted socioeconomic projections in order to achieve federal- and State-mandated regional emissions standards and greenhouse gas (GHG) reduction targets. As part of the Regional Transportation Plan (RTP), SCAG developed a Sustainable Communities Strategy (SCS), which was required by Senate Bill (SB) 375, the Sustainable Communities Act of 2008. The SCS is intended to combine land use and transportation planning with the overall goal of reducing air pollutant and GHG emissions generated from vehicle travel. The City currently has approximately 5,700 unemployed persons eligible to work.15 Therefore, development of the project site, as proposed, would provide employment opportunities within Moreno Valley and support the AQMP’s and SCAG’s goal of reducing air pollutant and GHG emissions generated from vehicle travel.

Based on the proposed self-storage building size (130,764 square feet), the project is expected to generate up to four employees. Therefore, the proposed project is not considered a project of Statewide, regional, or areawide significance (e.g., large-scale projects such as airports, electrical generating facilities, petroleum and gas refineries, residential developments of more than 500 dwelling units, and shopping centers or business establishments employing more than 1,000 persons or encompassing more than 500,000 square feet of floor space) as defined in CCR Title 14, Division 6, Chapter 3, Article 13, Section 15206(b). Because the proposed project would not be defined as a regionally significant project under CEQA, it does not meet SCAG’s Intergovernmental Review criteria.

Based on the analysis above, the proposed project would not represent substantial or unplanned employment or population growth forecast by SCAG or the AQMP. Therefore, the proposed project would not conflict with or obstruct implementation of the applicable air quality plan. Impacts would be less than significant, and mitigation is not required.
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 South Coast Air Basin is currently designated nonattainment for the federal and State standards for 8-hour ozone (O3) and particulate matter less than 10 microns in size (PM10). The Basin is also nonattainment for the State standard for 1-hour O3. The Basin’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of an ambient air quality standard. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, SCAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. Therefore, additional 14 Southern California Association of Governments (SCAG). 2024. 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy: A Plan for Navigating to a Brighter Future. April. Website: https://scag.ca.gov/sites/main/files/fileattachments/23-2987-connect-socal-2024-final-complete-040424.pdf?1714175547 (accessed January 2025). 15 State of California, Employment Development Department. 2023. Monthly Labor Force and Unemployment Rate for Cities and Census Designated Places. September. Website: https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2 Flabormarketinfo.edd.ca.gov%2Ffile%2Flfmonth%2Fsanbrsub.xls&wdOrigin=BROWSELINK (accessed January 2025). □ □ ~ □
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Public Storage Moreno Valley Page 27 City of Moreno Valley analysis to assess cumulative impacts is not necessary. The following analysis assesses the potential project-level air quality impacts associated with construction and operation of the proposed project.

Construction Emissions. During construction, short-term degradation of air quality may occur due to the release of particulate matter emissions (i.e., fugitive dust) generated by grading, building construction, paving, and other activities. Emissions from construction equipment are also anticipated and would include carbon monoxide (CO), nitrogen oxides (NOX), volatile organic compounds (VOCs), directly emitted particulate matter less than 2.5 microns in size (PM2.5) or PM10, and toxic air contaminants (TACs) such as diesel exhaust particulate matter. Project construction activities would include grading, site preparation, building construction, architectural coating, and paving activities. Construction-related effects on air quality from the proposed project would be greatest during the site preparation phase due to the disturbance of soils. If not properly controlled, these activities would temporarily generate particulate emissions. Sources of fugitive dust would include disturbed soils at the construction site.

Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and amount of operating equipment. Larger dust particles would settle near the source, whereas fine particles would be dispersed over greater distances from the construction site.

Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. SCAQMD has established Rule 403: Fugitive Dust, which would require the Applicant/Developer to implement measures that would reduce the amount of particulate matter generated during the construction period. The Rule 403 measures that were incorporated in this analysis include:
• Water active sites at least twice daily (locations where grading is to occur shall be thoroughly watered prior to earthmoving).
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 2 feet (0.6 meter) of freeboard (vertical space between the top of the load and the top of the trailer) in accordance with the requirements of California Vehicle Code Section 23114. • Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less.

In addition to dust-related PM10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, sulfur oxides (SOX), NOX, VOCs, and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

The California Emissions Estimator Model version 2022.1 (CalEEMod) computer program was used to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site. This analysis assumes that construction of the proposed project is anticipated to occur over a period of 12 months, beginning in the second quarter of 2027. This analysis also assumes that the proposed project would comply with SCAQMD Rule 403 measures. Site preparation, grading, and building activities would involve the use of standard earthmoving equipment such as large excavators, cranes, and other related equipment. In addition, the proposed project would result in approximately 4,210 cubic yards of soil exportation.16 All other construction details are not yet known; therefore, default assumptions (e.g., construction equipment, construction worker and truck trips, and fleet activities) from CalEEMod were used.

Construction emissions are summarized in Table A below. CalEEMod output sheets are included in Appendix A.17
16 The CalEEMod modeling evaluated the project emissions assuming construction would begin in November 2025 and end in November 2026 and require approximately 5,000 cubic yards of soil export. The project schedule and grading plans have since been modified to assume construction would end in the second quarter of 2027 and approximately 4,210 cubic yards of soil export would be required. The 12-month construction duration remained the same. These modifications to the project have been reviewed by LSA and it was determined that the modified construction schedule and soil export quantities would not result in more severe impacts than what is described within.
17 LSA Associates, Inc. 2025a. Air Quality, Energy, and Greenhouse Gas Technical Memorandum. March. 2462
Public Storage Moreno Valley Page 28 City of Moreno Valley Table A: Short-Term Regional Construction Emissions
Construction Phase Maximum Daily Regional Pollutant Emissions (lbs/day) VOCs NOX CO SOX Total PM10 Total PM2.5
Site Preparation 1.3 49.8 36.1 <0.1 9.7 5.1
Grading 0.7 22.0 16.4 <0.1 4.0 2.1
Building Construction 0.8 17.5 17.0 <0.1 1.6 0.8
Architectural Coating 12.4 1.1 1.8 <0.1 0.7 0.1
Paving 0.6 10.4 9.1 <0.1 0.1 0.5
Peak Daily Emissions 13.2 71.8 52.5 <0.1 13.7 7.2
SCAQMD Threshold 75.0 100.0 550.0 150.0 150.0 55.0
Significant? No No No No No No
Source: Compiled by LSA (January 2025).

Note: Maximum emissions occurred during the overlapping of site preparation and grading phases. VOCs maximum emissions occurred during the overlapping of building construction and architectural coating phases.

CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in diameter PM10 = particulate matter less than 10 microns in diameter SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOCs = volatile organic compounds
The results shown in Table A indicate the proposed project would not exceed the significance criteria for daily VOC, NOX, CO, SOX, PM10, or PM2.5 emissions. Therefore, construction of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable National Ambient Air Quality Standards (NAAQS) or California Ambient Air Quality Standards (CAAQS). Impacts would be less than significant, and mitigation is not required.

Operational Air Quality Impacts. Long-term air pollutant emissions associated with operation of the proposed project include emissions from area, energy, and mobile sources. Area-source emissions include architectural coatings, consumer products, and landscaping. Energy-source emissions result from activities in buildings that use natural gas. The proposed project would be all electric; therefore, the proposed project would not generate energy source emissions. Mobile-source emissions are from vehicle trips associated with operation of the project.

Mobile source emissions include reactive organic gas (ROG) and NOX emissions that contribute to the formation of O3. Additionally, PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways.

Long-term operational emissions associated with the proposed project were calculated using CalEEMod.

The proposed project would construct a 130,764-square-foot, three-story, self-storage building including 17,637 square feet of landscaping, 52 RV parking spaces, and 12 passenger vehicle spaces. Therefore, the proposed project analysis was conducted using the land use codes Unrefrigerated Warehouse-NoRail and Parking Lot. Trip generation rates used in CalEEMod for the project were based on the project’s trip generation analysis, which identifies that the project would generate approximately 216 average daily trips.18 In addition, consistent with the project design plans, this CalEEMod analysis incorporates selections to reflect drought tolerant landscape, low water irrigation, and no natural gas. When projectspecific data were not available, default assumptions from CalEEMod were used to estimate project emissions. Table B provides the proposed project’s estimated operational emissions. CalEEMod output sheets are included in Appendix A.19
Table B: Long-Term Regional Operational Emissions
Emission Type Pollutant Emissions (lbs/day)
VOCs NOX CO SOX Total PM10 Total PM2.5
Mobile Sources 0.8 0.7 5.6 <0.1 1.2 0.3
Area Sources 4.1 <0.1 5.7 <0.1 <0.1 <0.1
Energy Sources 0.0 0.0 0.0 0.0 0.0 0.0
Total Project Emissions 4.9 0.7 11.3 <0.1 1.2 0.3
SCAQMD Threshold 55.0 55.0 550.0 150.0 150.0 55.0
Exceeds Threshold? No No No No No No
Source: Compiled by LSA (January 2025).

Note: Some values may not appear to add correctly due to rounding. 18 LSA Associates, Inc. 2024. Trip Generation and Vehicle Miles Traveled Analysis for the Public Storage Moreno Valley Project (LSA Project No. 20241908). October 16.
19 LSA Associates, Inc. 2025a. Air Quality, Energy, and Greenhouse Gas Technical Memorandum. March. 2463
Public Storage Moreno Valley Page 29 City of Moreno Valley CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns diameter PM10 = particulate matter less than 10 microns in diameter SCAQMD = South Coast Air Quality Management District
SOX = sulfur oxides
VOCs = volatile organic compounds
The results shown in Table B indicate the proposed project would not exceed the significance criteria for daily VOC, NOX, CO, SOX, PM10, or PM2.5 emissions. Therefore, operation of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable NAAQS or CAAQS. Impacts would be less than significant, and mitigation is not required.

Long-Term Microscale (CO Hot Spot) Analysis. Vehicular trips associated with the proposed project could contribute to congestion at intersections and along roadway segments in the vicinity of the project site. Localized air quality impacts would occur when emissions from vehicular traffic increase as a result of the proposed project. The primary mobile-source pollutant of local concern is CO, a direct function of vehicle idling time and, thus, of traffic flow conditions. CO transport is extremely limited; under normal meteorological conditions, it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels, thereby affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients).

Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service (LOS) or with extremely high traffic volumes. In areas with high ambient background CO concentrations, modeling is recommended to determine a project’s effect on local CO levels.

An assessment of project-related impacts on localized ambient air quality requires that future ambient air quality levels be projected. Existing CO concentrations in the immediate project vicinity are not available.

Ambient CO levels monitored at the Lake Elsinore Monitoring station located at 506 West Flint Street (the closest station to the project site that monitors CO) showed a highest recorded 1-hour concentration of 1.3 parts per million (ppm) (the State standard is 20 ppm) and a highest 8-hour concentration of

0.8 ppm (the State standard is 9 ppm) from 2021 to 2023. The highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst-case analysis. Reduced speeds and vehicular congestion at intersections result in increased CO emissions.

The proposed project is expected to generate 216 average daily trips, with 14 trips occurring in the a.m. peak hour and 22 trips occurring in the p.m. peak hour. Because the proposed project would generate less than 400 daily trips, it is screened out from a Vehicle Miles Traveled (VMT) analysis and presumed to have less than significant transportation impact.20 Therefore, given the extremely low level of CO concentrations in the vicinity of the project site and the lack of traffic impacts at any intersections, projectrelated vehicles are not expected to result in CO concentrations exceeding the State or federal CO standards. No CO hot spots would occur, and the project would not result in any project-related impacts on CO concentrations. Impacts would be less than significant, and mitigation is not required. c) Expose sensitive receptors to substantial
pollutant concentrations?
Response:

Less Than Significant Impact with Mitigation. Sensitive receptors are defined as residential uses, schools, daycare centers, nursing homes, and medical centers. Individuals particularly vulnerable to diesel particulate matter are children, whose lung tissue is still developing, and the elderly, who may have serious health problems that can be aggravated by exposure to diesel particulate matter. The nearest sensitive receptors include the single-family residences along Pheasant Knoll Lane that are located within 50 feet to the east of the project site (measured from the project site boundary to the center of the nearest residence).

Localized Impact Analysis. The SCAQMD published its Final Localized Significance Threshold Methodology in July 2008, recommending that all air quality analyses include an assessment of air quality impacts to nearby sensitive receptors.21 This guidance was used to analyze potential localized air quality impacts associated with construction of the proposed project. Localized significance thresholds (LSTs) 20 LSA Associates, Inc. 2024. Trip Generation and Vehicle Miles Traveled Analysis for the Public Storage Moreno Valley Project (LSA Project No. 20241908). October 16.
21 South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology. July. □ I ~ □ □
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Public Storage Moreno Valley Page 30 City of Moreno Valley are developed based on the size or total area of the emission source, the ambient air quality in the Source Receptor Area (SRA), and the distance to the project site. Sensitive receptors include residences, schools, hospitals, and similar uses that are sensitive to adverse air quality.

LSTs are based on the ambient concentrations of that pollutant within the project’s SRA and the distance to the nearest sensitive receptor. For the proposed project, the appropriate SRA for the LST is the Moreno Valley area (SRA 24). The SCAQMD provides LST screening tables for 25-, 50-, 100-, 200-, and 500- meter source-receptor distances. The nearest sensitive receptors are the single-family residences along Pheasant Knoll Lane, which are located within 50 feet to the east of the project site (measured from the project site boundary to the center of the nearest residence). In cases where receptors may be closer than 82 feet (25 meters), any distances within the 82-foot (25-meter) buffer zone can be used. As such, the minimum distance of 25 meters was used for purposes of the LST assessment. Based on the anticipated construction equipment, it is assumed that the maximum daily disturbed acreage would be

3.5 acres for construction of the proposed project. The project site is 3.0 acres; therefore, the maximum daily disturbed acreage during operation of the proposed project would be 3.0 acres.22 Project construction and operation emissions were compared to the LST screening tables in SRA 24, based on a 25-meter source-receptor distance and a disturbed acreage of 3.5 acres for construction and an operational project site threshold of 3.0 acres. Table C shows the results of the LST analysis during project construction and operation.

Table C: Project Localized Construction and Operational Emissions Source Pollutant Emissions (lbs/day)
NOX CO PM10 PM2.5
Construction Emissions
On-Site Emissions 49.7 35.2 8.3 4.0
Localized Significance Threshold 220.0 1,230.0 10.0 6.0 Significant? No No No No
Operational Emissions
On-Site Emissions 0.7 6.0 <0.1 <0.1
Localized Significance Threshold 203.0 1,114.0 2.7 1.3
Significant? No No No No
Source: Compiled by LSA (January 2025).

Note: Source Receptor Area 24, based on a 3.5-acre construction disturbance daily area and a 3-acre disturbance area for operation, at a distance of 25 meters from the project site boundary to the nearest sensitive receptor.

CO = carbon monoxide
lbs/day = pounds per day
NOX = nitrogen oxides
PM2.5 = particulate matter less than 2.5 microns in diameter PM10 = particulate matter less than 10 microns in diameter By design, the localized impacts analysis only includes on-site sources; however, the CalEEMod outputs do not separate on-site and off-site emissions for mobile sources. For a worst-case scenario assessment, the emissions detailed in Table C assume that all area, stationary, and energy source emissions would occur on site, and 5 percent of the project-related new mobile sources (which is an estimate of the amount of project-related on-site vehicle travel) would occur on site. The 5 percent assumption is conservative because the localized impacts analysis only includes on-site sources and the majority of vehicle travel would occur off site, resulting in emissions that would also be released off site. Table C indicates the localized operational emissions would not exceed the LSTs at nearby residences. Therefore, the proposed operational activity would not result in a locally significant air quality impact.

As detailed in Table C, the emission levels indicate that the project would not exceed SCAQMD LSTs during project construction or operation. The project’s peak operational on-site NOX emissions are anticipated to be less than 1 pound per day. Due to the small size of the proposed project in relation to the overall Basin, the level of emissions is not sufficiently high to use a regional modeling program to correlate health effects on a Basin-wide level. On a regional scale, the quantity of emissions from the project is incrementally minor. Because the SCAQMD has not identified any other methods to quantify health impacts from small projects, and due to the size of the project, it is speculative to assign any specific health effects to small project-related emissions. However, based on this localized analysis, the proposed project would not expose sensitive receptors to substantial pollutant concentrations. Therefore, 22 South Coast Air Quality Management District (SCAQMD). n.d. Fact Sheet for Applying CalEEMod to Localized Significance Thresholds. Website: https://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/caleemodguidance.pdf (accessed January 2025). 2465
Public Storage Moreno Valley Page 31 City of Moreno Valley the project would not expose sensitive receptors to substantial levels of pollutant concentrations. Impacts would be less than significant, and mitigation is not required.

Health Risk Assessment. This section describes the potential impact on sensitive receptors from construction and operation of the proposed project based on the Health Risk Assessment (HRA)23 prepared for the proposed project, included in Appendix B. As identified above, the nearest sensitive receptors include the single-family residences along Pheasant Knoll Lane that are located within 50 feet to the east of the project site (measured from the project site boundary to the center of the nearest residence). In addition, the nearest worker receptor to the project site is located immediately south of the project site, within 10 feet. The nearest school receptor to the project site is located approximately 1,000 feet east of the project site, along Bay Avenue.

In accordance with SCAQMD guidance, health risk is considered significant under the following conditions:
• Cancer risk at a nearby receptor location (i.e., area where persons reside, work, or attend school—not including streets or sidewalks) is greater than 10 cases per one million persons over a period of 30 years for adults and 9 years for children (residential uses) and 25 years for workers.
• The cumulative increase in total chronic Hazard Index24 or total acute Hazard Index25 for any target organ system would exceed 1.0 at any receptor location.

A construction HRA, which evaluates construction-period health risk to off-site receptors, was completed for the proposed project. Table D, below, identifies the results of the analysis at the maximally exposed individual (MEI), which is the residential receptor. Model snapshots of the sources are included in Appendix B.

Table D: Health Risks from Project Construction to Off-Site Receptors Location
Carcinogenic
Inhalation Health Risk in 1
Million
Chronic
Inhalation
Hazard Index
Acute
Inhalation
Hazard Index
Residential Receptor Risk 13.18 0.014 0.000
Worker Receptor Risk 0.79 0.048 0.000
School Receptor 0.01 <0.001 0.00
SCAQMD Significance Threshold 10 in 1 million 1.0 1.0
Significant? Yes No No
Source: Compiled by LSA (January 2025).

SCAQMD = South Coast Air Quality Management District
As shown in Table D, the maximum cancer risk for the residential MEI would be 13.18 in 1 million, which would exceed the SCAQMD cancer risk threshold of 10 in 1 million. The worker MEI would be 0.79 in 1 million and the school MEI would be lower at 0.01 in 1 million, which would not exceed the SCAQMD cancer risk threshold of 10 in 1 million. The total chronic hazard index would be 0.014 for the residential MEI, 0.048 for the worker MEI, and less than 0.001 for the school MEI, all of which are below the threshold of 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of 1.0. Therefore, implementation of Mitigation Measure AIR-1, which would require the use of cleaner construction equipment, would be necessary to reduce substantial pollutant concentrations during project construction.

Mitigation Measure AIR-1 During construction of the proposed project, the project contractor shall ensure all off-road diesel-powered construction equipment of 50 horsepower or more that are used for project construction meet, at a minimum, the California Air Resources Board Tier 2 emissions standards equipped with Level 3 Diesel Particulate Filters or the equivalent.
23 LSA Associates, Inc. 2025b. Health Risk Assessment for the Moreno Valley Public Storage. March. 24 Chronic Hazard Index is the ratio of the estimated long‐term level of exposure to a TAC for a potential maximum exposed individual to its chronic reference exposure level. The chronic Hazard Index calculations include multipathway consideration, when applicable.
25 Acute Hazard Index is the ratio of the estimated maximum 1‐hour concentration of a TAC for a potential maximum exposed individual to its acute reference exposure level.
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Public Storage Moreno Valley Page 32 City of Moreno Valley Table E identifies the results of the analysis with implementation of Mitigation Measure AIR-1.

Table E: Health Risks from Project Construction to Off-Site Receptors with Mitigation Location
Carcinogenic
Inhalation Health Risk in 1
Million
Chronic
Inhalation
Hazard Index
Acute
Inhalation
Hazard Index
Residential Receptor Risk 2.15 0.002 0.000
Worker Receptor Risk 0.13 0.008 0.000
School Receptor 0.0 <0.001 0.00
SCAQMD Significance Threshold 10 in 1 million 1.0 1.0
Significant? No No No
Source: Compiled by LSA (January 2025).

SCAQMD = South Coast Air Quality Management District
As shown in Table E, with implementation of Mitigation Measure AIR-1, the cancer risk at the residential MEI would be 2.15 in 1 million, which would not exceed the SCAQMD cancer risk of 10 in 1 million.

Therefore, with implementation of Mitigation Measure AIR-1, construction of the proposed project would not exceed SCAQMD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations. Impacts would be below thresholds and therefore less than significant with mitigation incorporated.

Once the proposed project is constructed, the proposed project would not be a source of substantial emissions. Therefore, implementation of the proposed project would not result in new sources of TACs.

Therefore, with implementation of Mitigation Measure AIR-1, the project would not expose sensitive receptors to substantial levels of TACs.

Naturally Occurring Asbestos. Furthermore, the project is in Riverside County, which is among the counties found to have serpentine and ultramafic rock in their soils.26 However, according to the California Geological Survey, no such rock has been identified in the vicinity of the project site. When demolition is proposed during construction, the demolition of existing buildings may expose asbestos used in building materials. However, the proposed project would not involve any demolition or renovation because no current development exists on the project site. Therefore, the potential risk for naturally occurring asbestos during project construction is small and would not be significant. Impacts would be less than significant, and mitigation is not required.

Overall, with implementation of Mitigation Measure AIR-1, the project would have a less than significant impact with mitigation incorporated related to exposing sensitive receptors to substantial pollutant concentrations.
d) Result in other emissions (such as those leading
to odors adversely affecting a substantial
number of people?
Response:

Less Than Significant Impact. Heavy-duty equipment on the project site during construction would emit odors, primarily from equipment exhaust. However, the construction activity would cease after individual construction is completed. No other sources of objectionable odors have been identified for the proposed project.

The proposed project would comply with SCAQMD Rule 402 regarding odors and sources that could cause nuisances. SCAQMD Rule 402 regarding 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 proposed uses are not anticipated to emit any objectionable odors. The proposed project would also include trash enclosures, which would reduce any potential for odors from project-related waste. Therefore, the proposed project would not result in other emissions (e.g., those leading to odors) adversely affecting a substantial number of people. Impacts would be less than significant, and mitigation is not required.

Sources:
26 California Department of Conservation (DOC). n.d. California Geological Survey. Asbestos. Website: https://www.conservation. ca.gov/cgs/minerals/mineral-hazards (accessed January 2025). □ □ ~ □
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Public Storage Moreno Valley Page 33 City of Moreno Valley

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 5.3-1 – 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 IV. BIOLOGICAL RESOURCES – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special
status species in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Wildlife or U.S. Fish and
Wildlife Service?
Response:

Less Than Significant with Mitigation Incorporated. A Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Analysis and Biology Report was prepared for the project site in January 2025 (included as Appendix C).27 A general biological resources survey was conducted on October 30, 2024. A habitat suitability assessment determined that the project site consists of ruderal/non-native annual grassland species as the property has been historically plowed or disked for weed abatement compliance. There is one tree, Goodding's willow (Salix gooddingii), located along the southern perimeter of the project site. The ruderal/non-native annual grassland is comprised of vinegar weed (Trichostema lanceolatum), flatspine bur ragweed (Ambrosia acanthicarpa), Bermuda grass (Cynodon dactylon), and slender wild oat (Avena barbata). Historical aerial imagery of the project site revealed that the project site has remained undeveloped since 1959.28 No special-status species were found or observed during the field reconnaissance.

The project site lies within the MSHCP Plan Area; however, the project site is not located within the MSHCP Criteria Area, Public/Quasi-Public Lands, or conservation areas, nor is the site located within the MSHCP Narrow Endemic Plant Species Survey Area, burrowing owl (Athene cunicularia hypugaea) survey area,
29 or any other species survey area. As the project site has been recently plowed or disked for weed abatement, the site does not contain suitable habitat for any threatened or endangered species.

Section 6.3.2 of the MSHCP prescribes survey needs for special-status species based on mapped surveys areas for: Criteria Area Plant Species, amphibians, and mammals; however, the project site does not fall within mapped survey areas for any of these special-status species. Species identified in MSHCP Table 9-3 are not considered adequately conserved under the MSHCP. Other species with limited coverage or with no take authorization under the MSHCP include chaparral sand-verbena (Abronia villosa var. aurita), salt marsh bird’s-beak (Chloropyron maritimum spp. maritimum), Robinson’s pepper-grass (Lepidium virginicum var. robinsonii), chaparral ragwort (Senecio aphanactis), San 27 LSA Associates, Inc. 2025c. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Analysis and Biology Report for the Moreno Valley Public Storage Project. Page 10. January. (Appendix C). 28 Nationwide Environmental Title Research, LLC (NETR). 2024. Historic Aerials by NETRonline (v.0.6.10). Website:
https://historicaerials.com (accessed December 2024).
29 Although the project site is not within a burrowing owl survey area, a burrowing owl habitat assessment was conducted in accordance with guidelines (California Department of Fish and Wildlife’s 2012 Staff Report on Burrowing Owl Mitigation and Burrowing Owl Survey Instructions for the Western Riverside Multiple Species Habitat Conservation Plan Area, Riverside County Environmental Programs Department, March 29, 2006). The assessment concluded there is no suitable habitat for the burrowing owl.
□ ~ □ □
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Public Storage Moreno Valley Page 34 City of Moreno Valley Bernardino aster (Symphyotrichum defoliatum), Cooper’s hawk (Accipiter cooperii), Crotch’s bumble bee (Bombus crotchii), southern California legless lizard (Anniella stebbinsi), California glossy snake (Arizona elegans occidentalis), San Bernardino ringneck snake (Diadophis punctatus modestus), coast patchnosed snake (Salvadora hexalepis virgultea), long-eared owl (Asio otus), California black rail (Laterallus jamaicensis coturniculus), western mastiff bat (Eumops perotis californicus), western yellow bat (Lasiurus xanthinus), pocketed free-tailed bat (Nyctinomops femorosaccus), southern grasshopper mouse (Onychomys torridus ramona), and American badger (Taxidea taxus).

No species identified in MSHCP Table 9-3 or the other species listed above have more than a low potential of being present on the project site due to the substantial disturbance of the site and a lack of suitable vegetation communities, soils, and hydrology. The project site does not include any suitable habitat for special-status species, and none were observed on the project site during the biological survey.30 Based on the analysis above, the project is consistent with the MSHCP.

Nesting Birds. During the bird breeding season (January 1 through August 31), large trees on or adjacent to the project site may be used by hawks, ravens, or other large birds for nesting. Trees, shrubs, and other vegetation may provide nest sites for smaller birds. The trees present on the site can provide habitat for nesting birds that are protected by the Migratory Bird Treaty Act of 1918 (MBTA) (16 United States Code [USC] 703–711) and California Fish and Game Code Sections 3503, 3053.5, and 3800.

These laws regulate the take, possession, or destruction of the nest or eggs of any migratory bird or bird of prey. To avoid potential effects to fully protected raptors, special-status bird species, and other nesting birds protected by the MBTA and California Fish and Game Code, and for compliance with the MSHCP, Mitigation Measure BIO-1 is identified below to address potential impacts to nesting birds. With adherence to Mitigation Measure BIO-1, impacts would be reduced to less than significant with mitigation incorporated.

Species Associated with Riparian/Riverine Areas and Vernal Pools. The definition of Riparian/ Riverine habitats is based on potential for the habitat to support Riparian/Riverine Covered Species. The MSHCP species associated with Riparian/Riverine areas and Vernal Pools, as listed in Section 6.1.2 of the MSHCP, were assessed for the probability of occurring in and adjacent to the project site. No drainage features, ponded areas, or riparian habitat subject to jurisdiction by the California Department of Fish and Wildlife (CDFW), the United States Army Corps of Engineers (USACE), and/or the Regional Water Quality Control Board (RWQCB) were found within the project site during site surveys. A review of the Sunnymead, Riverside East, Steele Peak, and Perris, California United States Geological Survey (USGS) quadrangle and historic aerial photographs (NETR) did not reveal any previously mapped drainage features within the project site.31 There are no vernal pools or other ponded areas suitable for sensitive fairy shrimp species on the project site. Soils in the project site are well drained from repeated plowing and have been previously mapped as Hanford coarse sandy loam, 0 to 2 percent slopes and Greenfield sandy loam, 0 to 2 percent slopes.32 No hydrophytic vegetation occurs in the project site. The project site does not contain any suitable riparian vegetation or habitat for special-status riparian birds.

No additional surveys or mitigation are required.

Stephens’ Kangaroo Rat. The project site is located within the Stephens’ Kangaroo Rat Habitat Conservation Plan (SKR HCP) area, and a fee payment will be required prior to issuance of a grading permit. The project will comply with the Habitat Conservation Plan (HCP) for the Stephens’ Kangaroo Rat in Western Riverside County and fulfill its compensatory mitigation requirements under this plan through the payment of a fee that would fund conservation activities within the HCP area. 33 Mitigation Measure BIO-1 A nesting bird pre-construction survey shall be conducted by a qualified biologist three days prior to ground-disturbing activities if working within the bird nesting season (January 1 through August 31). Should nesting birds be found, an exclusionary buffer shall be established by the qualified biologist. The buffer may be up to 500 feet in diameter depending on the species of nesting bird found. This buffer shall be 30 LSA Associates, Inc. 2025c. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Analysis and Biology Report for the Moreno Valley Public Storage Project. Page 10. January. (Appendix C). 31 Nationwide Environmental Title Research, LLC (NETR). 2024. Historic Aerials by NETRonline (v.0.6.10). Website: https://historic aerials.com (accessed December 2024).
32 United States Department of Agriculture Natural Resources Conservation Service (USDA NRCS). 2024. Web Soil Survey (Version 3.4.0). United States Department of Agriculture. Website: https://websoilsurvey.sc.egov.usda.gov/ (accessed December 2024).
33 Riverside County Habitat Conservation Agency (RCHCA). 1995. Stephens' Kangaroo Rat Mitigation Fee. Website: https://www. rchca.us/185/Stephens-Kangaroo-Rat-Mitigation-Fee (accessed December 2024). 2469
Public Storage Moreno Valley Page 35 City of Moreno Valley clearly marked in the field by construction personnel under guidance of the qualified biologist and construction or clearing shall not be conducted within this zone until the qualified biologist determines that the young have fledged, or the nest is no longer active. If there is a lapse in construction activities longer than seven days, an additional preconstruction survey shall be conducted. b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of
Fish and Wildlife or U.S. Fish and Wildlife
Service?
Response:

Less Than Significant Impact. Certain habitats/natural communities are considered to be of special concern based on: (1) federal, State, or local laws regulating their development; (2) limited distributions; and/or (3) whether they support the habitat requirements of special-status plants or animals. As discussed above, the project site was evaluated for biological resources pursuant to the MSHCP via an MSHCP Consistency Analysis (Appendix C), which included a literature review and one-day pedestrian survey conducted on October 30, 2024.34 The habitat suitability assessment provided in the Consistency Analysis indicates the project site is dominated by non-native forbs and grasses with a few native species of plants interspersed. Due to the disturbed nature of the site and the developed setting of the surrounding properties, the project site does not contain sensitive biological resources such as riparian/riverine or vernal pool habitats. No special-status plants or wildlife, Narrow Endemic Plant Species, or Criteria Area Wildlife Species were identified due to the lack of suitable habitat on and surrounding the project site.35 The nearest Critical Habitat unit is approximately 7.5 miles southeast of the project site as part of the MSHCP unit (Unit 6, Riverside Managed Area), specifically within Subunit 6A, San Jacinto River36 of USFWS designated Critical Habitat for the federally listed as threatened spreading navarretia (Navarretia fossalis).37 However, no portion of the project site is located in or adjacent to MSHCP Unit 6 or any other critical habitat. Additionally, a search of the California Natural Diversity Database (CNDDB) indicates the nearest sensitive habitat is Southern Sycamore Alder Riparian Woodland located approximately 4 miles west of the project site.38 Therefore, implementation of the proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans (i.e., MSHCP), policies, regulations, or by the CDFW or USFWS. Impacts are less than significant, and mitigation is not required.
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. The USACE regulates discharges of dredged or fill material into waters of the United States.

These waters include wetlands and non-wetland bodies of water that meet specific criteria. This connection may be direct through a tributary system linking a stream channel with traditional navigable waters (TNW) used in interstate or foreign commerce or may be indirect through a nexus identified in the USACE regulations. In the past, an indirect nexus could potentially be established if isolated waters provided habitat for migratory birds, even in the absence of a surface connection to a navigable water of the United States. In order to be considered a jurisdictional wetland under Section 404, an area must 34 LSA Associates, Inc. 2025c. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Analysis and Biology Report for the Moreno Valley Public Storage Project. Page 1 and Page 10. January. (Appendix C). 35 Ibid. Page 7 and 8.
36 Federal Register [FR], Vol. 75, Page 62192, October 7, 2010. Department of the Interior Fish and Wildlife Service. Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for Navarretia fossalis (Spreading Navarretia). 37 United States Fish and Wildlife Service (USFWS). 2024. Critical Habitat Portal. https://ecos.fws.gov/ecp/report/table/criticalhabitat.html (accessed December 2024). 38 California Department of Fish and Wildlife (CDFW). 2024. Natural Diversity Database. RareFind, Online Edition, Version 5.3.0. https://www.wildlife.ca.gov/Data/CNDDB/ (accessed December 2024). □ □ ~ □
□ □ □ ~
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Public Storage Moreno Valley Page 36 City of Moreno Valley possess three wetland characteristics: hydrophytic vegetation, hydric soils, and wetland hydrology. Each characteristic has a specific set of mandatory wetland criteria that must be satisfied in order for that particular wetland characteristic to be met.

The CDFW, under Section 1602 of the California Fish and Game Code, regulates alterations to lakes, rivers, and streams (defined by the presence of a channel bed and banks, and at least an intermittent flow of water) where fish or wildlife resources may be adversely affected. The RWQCB is responsible for the administration of Section 401 of the Clean Water Act. Typically, the areas subject to jurisdiction of the RWQCB coincide with those of the USACE (i.e., waters of the U.S. including any wetlands). The RWQCB can also assert authority over “waters of the State” under waste discharge requirements pursuant to the Porter-Cologne Water Quality Control Act. Please refer to Checklist Response IV(a). The project site is currently vacant and is currently surrounded by existing roadways, residential, and commercial uses. No federally protected wetlands, marshes, vernal pools, or coastal areas were identified within the project site. Therefore, no impact related to this issue would occur. No mitigation is required.
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. Habitat fragmentation occurs when a single, contiguous habitat area is divided into two or more areas, or where an action isolates two or more new areas from each other.

Isolation of habitat occurs when wildlife cannot move freely from one portion of the habitat to another or to/from one habitat type to another. Habitat fragmentation may occur when a portion of one or more habitats is converted into another habitat, as when scrub habitats are converted into annual grassland habitat because of frequent burning. Wildlife movement includes seasonal migration along corridors, as well as daily movements for foraging and reaching water sources. Migration corridors may include areas of unobstructed movement for deer, riparian corridors providing cover for migrating birds, routes between breeding waters and upland habitat for amphibians, and between roosting and feeding areas for birds.

The project site is not adjacent to any existing or proposed linkage or core areas as identified in the MSHCP. The project will not affect wildlife movement as the project site is surrounded by urban development and the project site does not serve as a wildlife movement corridor. A less than significant impact related to this issue would occur, and no mitigation is required. e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
Response:

Less Than Significant Impact. According to the City of Moreno Valley Municipal Code (as amended), Chapter 9.17, Landscape and Water Efficiency Requirements; Section 9.17.030, Landscape and Irrigation Standards; Part E, Trees, projects necessitating the removal of existing trees with four-inch or greater trunk diameters (calipers) shall be replaced at a 3 to 1 ratio, with minimum 24-inch box size trees of the same species, or a minimum 36-inch box for a one to one replacement, where approved.

Additionally, Part G defines Heritage Trees as any tree that defines the historical and cultural character of the City, including older palm and olive trees, and/or any tree designated as such by official action; trees with a 15-inch diameter measured 24 inches above ground level; or trees that have reached a height of 15 feet or greater.

The biological assessment for the project documented a single (1) Gooding’s willow located on the southern boundary of the project site. Additionally, the site contains three (3) Mexican fan palm (Washingtonia robusta) seedlings. Gooding’s willow is a common native tree to California while Mexican fan palm is an invasive species classified by the California Invasive Plant Council (Cal-IPC) California Invasive Plant Inventory as having a moderate rating. Cal-IPC describes those species with a moderate rating as having substantial and apparent, but generally not severe, ecological impacts on physical processes, plant and animal communities, and vegetation structure. Their reproductive biology and other attributes are conducive to moderate to high rates of dispersal, though establishment is generally dependent upon ecological disturbance.39
39 California Invasive Plant Council (Cal-IPC). 2024. California Invasive Plant Inventory. 2024. Website: www.cal-ipc.org (accessed □ □ ~ □
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Public Storage Moreno Valley Page 37 City of Moreno Valley While the trunk caliper and height of trees on site were not measured during the survey, the three palms are small and would not meet the minimum requirements for replacement under the City’s tree ordinance.

The Gooding’s willow is expected to meet the requirements for replacement due to having multiple trunks that would likely measure more than a 4-inch caliper combined.

Although the Gooding’s willow may be 15 feet or taller, it would not qualify as a Heritage Tree because it does not retain the integrity necessary to embody the historical and cultural character of the City. The project site is substantially surrounded by residential uses with contemporary landscaping. The on-site trees are located on an undeveloped property and, therefore, are outliers without the required context to convey the historical and cultural character of the City because the historic-era homestead with which they may have been associated in the past has been demolished. Therefore, all trees on the project site will be managed in accordance with Part E of Section 9.17.030 of the City Municipal Code, which requires all trees proposed for removal to be replaced at a 3 to 1 ratio, with minimum 24-inch box size trees of the same species, or a minimum 36-inch box for a 1 to 1 replacement, where approved. Compliance with these standards is required of all projects in the City as a matter of regulatory policy (i.e., City Municipal Code) and therefore does not constitute mitigation. Impacts are less than significant, and mitigation is not required.
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 with Mitigation Incorporated. The MSHCP is a comprehensive, multi-jurisdictional Habitat Conservation Plan focusing on conservation of species and their associated habitats in Western Riverside County. MSHCP participants include the County and fourteen cities, including the City, which is a signatory to the plan. The MSHCP allows Riverside County and its cities to better control local landuse decisions and maintain a strong economic climate in the region while addressing the requirements of the State and federal Endangered Species Acts. The plan covers 1.26 million acres and protects 146 native plant and animal species.

As described in Checklist Response IV(a) above, the project site does not contain the habitat types described for conservation in the MSHCP, and no special-status species were observed on the project site during the biological survey. Based on the analysis above, the project is consistent with the MSHCP.

The project site is mostly devoid of vegetation as the property has been historically plowed or disked for weed abatement. A habitat assessment for burrowing owl, a California Species of Special Concern (SSC) and candidate for listing as a threatened or endangered species under the California Endangered Species Act, was completed as part of the survey conducted on October 30, 2024 (Appendix C) and determined that the project site does not contain suitable habitat for burrowing owl. However, the site may be utilized by nesting birds that are protected by the MBTA and the California Fish and Game Code.

Impacts to nesting birds would be reduced with implementation of Mitigation Measure BIO-1, provided above.

The project site is not within the MSHCP Criteria Area, Public/Quasi-Public Lands, or conservation area, nor is the site located within any species survey areas, including for plants.

As described above in Checklist Response IV(b), the project would not impact Riparian/Riverine areas.

The project site is located within the Stephens’ Kangaroo Rat Habitat Conservation Plan area, and a fee payment will be required prior to issuance of a grading permit. The project will comply with the Habitat Conservation Plan for the Stephens’ Kangaroo Rat40 in Western Riverside County and fulfill its compensatory mitigation requirements under this plan.

With implementation of Mitigation Measure BIO-1, the project as planned is consistent with the applicable MSHCP requirements, and impacts would be less than significant with mitigation incorporated.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
December 2024).
40 Riverside County Habitat Conservation Agency (RCHCA). 1995. Stephens' Kangaroo Rat Mitigation Fee. Website: https://www. rchca.us/185/Stephens-Kangaroo-Rat-Mitigation-Fee (accessed December 2024). □ ~ □ □
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Public Storage Moreno Valley Page 38 City of Moreno Valley • 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 5.9-1 – Planning Area Biological Geographic Sections - Figure 5.9-2 – Planning Area Vegetation Community
- Figure 5.9-3 – Project Site Location within the MSHCP Area - Figure 5.9-4 – 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. Stephens’ Kangaroo Rat Habitat Conservation Plan (SKR HCP), Governing Documents |

RCHCA, CA
V. CULTURAL RESOURCES – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
Response:

Less Than Significant Impact. A Cultural Resources Assessment41 was prepared to identify and determine whether any historical or archaeological resources may be present within the limits of the project site (included as Appendix D). The Cultural Resources Assessment included a pedestrian field survey, review of online historic maps and aerial photographs, and a records search.

An intensive pedestrian field survey of the project site was conducted on October 18, 2024. The field survey revealed that the project site is severely disturbed from earth-moving, geotechnical testing, and vegetation abatement activities. No archaeological resources were identified. Additionally, review of historic period maps, aerial photographs, and online research indicated there have never been buildings or structures, on the project site.

A records search was conducted at the South Coastal Information Center (SCIC) on January 7, 2025.

Results of the records search indicate that 20 previous cultural resources studies have been conducted within a 1-mile radius of the project site, none of which included any portion of the project site. Although no cultural resources have been documented within the project site, two historic period resources (33- 028200, a canal; and 33-28824, a minimal archaeological site) and a Native American Traditional Cultural Property (TCP) (33-029890, Pechanga Sycamore Hills TCP) are within 1 mile. The closest resource to the project site is the archaeological site (33-28824) approximately 0.81 mile to the northeast. There are no prehistoric archaeological resources documented within 1 mile.

No cultural resources were previously documented within or near the project site, no cultural resources were identified during the survey, and the project site has sustained severe disturbance. There are no existing structures on the project site and the project would not require demolition of any built resources.

The proposed project would not cause a substantial change in the significance of a historical resource pursuant to State CEQA Guidelines Section 15064.5. Impacts would be less than significant, and no mitigation is required.
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
Response:

Less Than Significant with Mitigation Incorporated. As described in Checklist Response V(a) above, the records search identified a minimal archaeological site and a Native American TCP within 1 mile of the 41 LSA Associates, Inc. 2025d. Cultural Resources Assessment, Public Storage Moreno Valley Project, City of Moreno Valley.

February.
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Public Storage Moreno Valley Page 39 City of Moreno Valley project site. No archaeological resources were identified during the field survey. The project site has sustained severe disturbance; therefore, the potential for discovery of subsurface resources is low.

However, construction would include excavation to depths of at least 5 feet below the proposed grade or 3 feet below bottom of foundations and floor slab, whichever is deeper. In the unlikely event that any previously unidentified archaeological resources are discovered during ground-disturbing activities, work in the area would be required to cease, and deposits would be treated in accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2 as specified in Standard Condition CUL-1. Additionally, due to the project’s proximity to a TCP, the project would implement Mitigation Measure CUL-1 and Mitigation Measure CUL-2, which require implementation of a Worker’s Environmental Awareness Program (WEAP) training and archeological monitoring during construction.

Through implementation of Standard Condition CUL-1 and Mitigation Measures CUL-1 and CUL-2, impacts to archaeological resources would be less than significant with mitigation incorporated.

Standard Condition CUL-1 In the event that archaeological resources are discovered during excavation, grading, or construction activities, work shall cease within 50 feet of the find until a qualified archaeologist has evaluated the find in accordance with federal, State, and local guidelines to determine whether the find constitutes a “unique archaeological resource,” as defined in Section 21083.2(g) of the California Public Resources Code (PRC). Personnel associated with construction of the proposed project shall not collect or move any archaeological materials and associated materials. Construction activity may continue unimpeded on other portions of the project site. The found deposits shall be treated in accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2. Prior to issuance of a grading permit, the Director of Development, their designee, and the Developer/Applicant shall ensure that this mitigation measure is documented on the grading plans.

Mitigation Measure CUL-1 Prior to the start of earth moving activities, the Project Applicant shall retain an archaeologist to conduct cultural resources sensitivity training for all construction personnel. Construction personnel shall be informed of the types of archaeological resources that may be encountered, and of the proper procedures to be enacted in the event of an inadvertent discovery of precontact or historic archaeological resources or human remains. The Project Applicant shall ensure that construction personnel are made available for and attend the training and retain documentation demonstrating attendance. This measure shall be implemented to the satisfaction of the City of Moreno Valley, Planning Division.

Mitigation Measure CUL-2 A qualified professional archaeologist (either an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archeology or an archaeologist supervised by such an archaeologist) shall monitor all construction-related ground-disturbing activities. Archaeological monitoring shall occur during these excavation activities until the Project Archaeologist, based on their observations, is satisfied that there is little likelihood of encountering intact archaeological deposits. The Project Archaeologist may also determine that it is appropriate to reduce monitoring to spot-checking on a part-time basis.
c) Disturb any human remains, including those
interred outside of formally dedicated
cemeteries?
Response:

Less Than Significant Impact. As discussed in Checklist Responses V(a) and V(b) above, the project site is severely disturbed from earth-moving, geotechnical testing, and vegetation abatement activities. No human remains have been previously identified or recorded on site. The project would require excavation, grading, and trenching activities and could result in the unanticipated discovery of unknown human remains, including those interred outside formal cemeteries.

In the unlikely event that human remains are encountered during construction activities, the proper authorities would be notified, and standard procedures for the respectful handling of human remains □ □ ~ □
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Public Storage Moreno Valley Page 40 City of Moreno Valley during the earthmoving activities would be implemented. This process is required as part of the City’s Standard Conditions of Approval for construction projects, and as specified by Standard Condition CUL-2. Implementation of Standard Condition CUL-2 would reduce the potential for impacts on unknown buried human remains to a less than significant level. Therefore, impacts associated with the inadvertent discovery of human remains would be less than significant.

Standard Condition CUL-2 If potential historic, archaeological, Native American cultural resources or paleontological resources are uncovered during excavation or construction activities at the project site, work in the affected area must cease immediately and a qualified person (meeting the Secretary of the Interior's standards (36CFR61)) shall be consulted by the applicant to evaluate the find, and as appropriate recommend alternative measures to avoid, minimize or mitigate negative effects on the historic, prehistoric, or paleontological resource. Determinations and recommendations by the consultant shall be immediately submitted to the Planning Division for consideration, and implemented as deemed appropriate by the Community Development Director, in consultation with the State Historic Preservation Officer (SHPO) and any and all affected Native American Tribes before any further work commences in the affected area. If human remains are discovered during grading and other construction excavation, no further disturbance shall occur 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 5 days 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, CEQA).

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 5.10-1 – Locations of Listed Historic Resource Inventory Structures - Figure 5.10-2 – Location of Prehistoric Sites
- Figure 5.10-3 – 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.) VI. ENERGY – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
Response:

Less Than Significant Impact. This section discusses energy use resulting from implementation of the proposed project and evaluates whether the proposed project would result in the wasteful, inefficient, or □ □ ~ □
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Public Storage Moreno Valley Page 41 City of Moreno Valley unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy and energy efficiency.

Construction. The anticipated construction schedule assumes that the proposed project would be built in approximately 12 months. Construction-specific phases were assessed for their energy consumption under each construction sub-phase: grading, site preparation, building construction, paving, and architectural coating activities.

Construction would require energy for the manufacture and transportation of construction materials, preparation of the site for grading and building activities, and construction of the building. All or most of this energy would be derived from nonrenewable resources. Petroleum fuels (e.g., diesel and gasoline) would be the primary sources of energy for these activities. However, construction activities are not anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the project. Energy (i.e., fuel) usage on the project site during construction would be temporary in nature and would be relatively small in comparison to the State’s available energy sources. Impacts would be less than significant, and mitigation is not required.

Operation. Energy use associated with the proposed project would consist of electricity and vehicle fuel use associated with project operations. The proposed project would not be powered by natural gas, and no natural gas demand is anticipated during construction or operation of the proposed project. Electricity uses were estimated for the project using default energy intensities by land use type in California Emissions Estimator Model (CalEEMod).

Table F shows the estimated potential increased electricity, gasoline, and diesel demand associated with the proposed project. The electricity rates are from the CalEEMod analysis, while the gasoline and diesel rates are based on the traffic analysis in conjunction with United States Department of Transportation’s (USDOT) fuel efficiency data and using the United States Environmental Protection Agency’s (USEPA) fuel economy estimates for 2020, and the California diesel fuel economy estimates for 2021.

Table F: Estimated Annual Energy Use of Proposed Project Electricity Use (kWh/yr)
Natural Gas Use
(kBTU/yr) Gasoline (gal/yr)
Diesel
(gal/yr)
Proposed Project 629,861 0 20,559 14,752
Source: Compiled by LSA (January 2025).
gal/yr = gallons per year
kBTU/yr = thousand British thermal units per year
kWh/yr = kilowatt-hours per year
As shown in Table F, the estimated increase in electricity demand associated with the operation of the proposed project would be 629,861 kilowatt-hours (kWh) per year. Total electricity consumption in Riverside County in 2022 was 17,780,573,271 kWh;42 therefore, operation of the proposed project would negligibly increase the annual electricity consumption in Riverside County by approximately less than

0.1 percent.

The project would also result in energy usage associated with motor vehicle gasoline to fuel projectrelated trips. As shown above in Table F, the proposed project would result in the consumption of 20,559 gallons of gasoline and 14,752 gallons of diesel per year. Based on fuel consumption obtained from EMFAC2021, approximately 744.5 million gallons of gasoline and approximately 301.2 million gallons of diesel are anticipated to be consumed from vehicle trips in Riverside County in 2026. Therefore, vehicle trips associated with the proposed project would increase the annual fuel use in Riverside County by approximately less than 0.1 percent for gasoline fuel usage and approximately less than 0.1 percent for diesel fuel usage. The proposed project would result in fuel usage that is a small fraction of current annual fuel usage in Riverside County, and fuel consumption associated with vehicle trips generated by project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Therefore, gasoline demand generated by vehicle trips associated with the proposed project would be a minimal fraction of gasoline and diesel fuel consumption in California.

Furthermore, the proposed project would be constructed using energy efficient modern building materials and construction practices, and the proposed project also would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (CCR Title 24, Sections 1601 42 California Energy Commission (CEC). 2022. Electricity Consumption by County. Website: http://www.ecdms.energy.ca.gov/ (accessed January 2025).
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Public Storage Moreno Valley Page 42 City of Moreno Valley through 1608). The expected energy consumption during construction and operation of the proposed project would be consistent with typical usage rates for public self-storage uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings.

As such, the proposed project would not result in a potential significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. Impacts would be less than significant, and mitigation is not required. b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
Response:

Less Than Significant Impact. The California Energy Commission (CEC) recently adopted the 2023 Integrated Energy Policy Report.43 The 2023 Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California. Many of these issues will require action if the State is to meet its climate, energy, air quality, and other environmental goals while maintaining energy reliability and controlling costs. The 2023 Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecasts, and the California Energy Demand Forecast.

As indicated above, energy usage on the project site during construction would be temporary in nature and would be relatively small in comparison to the State’s available energy sources. In addition, energy usage associated with operation of the proposed project would be relatively small in comparison to the region’s available energy sources, and energy impacts would be negligible at the regional level. Because California’s energy conservation planning actions are conducted at a regional level, and because the project’s total impact on regional energy supplies would be minor, the proposed project would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s 2023 Integrated Energy Policy Report. Therefore, the proposed project would not lead to new or substantially more severe energy impacts. Impacts would be less than significant, and mitigation is not required.

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 43 California Energy Commission (CEC). 2023. 2023 Integrated Energy Policy Report. California Energy Commission. Docket Number: 23-IEPR-01.
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Public Storage Moreno Valley Page 43 City of Moreno Valley VII. GEOLOGY AND SOILS – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
https://www.conservation.ca.gov/cgs/documents
/publications/special-publications/SP_042-
a11y.pdf
Response:

Less Than Significant Impact. The project site is located within the Peninsular Range Geomorphic Province, an area characterized by active northeast trending strike slip faults, including the San Jacinto Fault and the Elsinore Fault. Based on the City’s General Plan Safety Element, the project site is not located within the boundaries of an Earthquake Fault Zone as defined by the Alquist-Priolo Earthquake Fault Zoning Act of 1972.44 As described in the Geotechnical Engineering Exploration and Analysis prepared for the project, there are no known active or potentially active faults that traverse the project site and the risk of ground rupture due to a fault displacement beneath the site is low.45 The closest known fault is the San Jacinto Fault zone approximately 5.1 miles northeast of the project site. As the project site is not within an identified fault zone, implementation of the project would not exacerbate the risks associated with fault rupture. Therefore, impacts related to earthquake faults would be less than significant. No mitigation is required.
ii) Strong seismic ground shaking?
Response:

Less Than Significant Impact. Like all of southern California, the project site is located in a seismically active area and, therefore, will continue to be subject to ground shaking resulting from activity on local and regional faults. In addition, the project site lies in relatively close proximity to the San Jacinto fault, an active fault.46 Therefore, during the life of the project, there is a high likelihood that there will be similar levels of ground shaking from this fault zone. The project is required to be designed and constructed in accordance with the current California Building Code (CBC) requirements. Adherence to the CBC is anticipated to address the issues related to potential ground shaking. Implementation of the project would not exacerbate the risks associated with seismic ground shaking. With the implementation of CBC requirements, seismic-related impacts would be less than significant. No mitigation is required. iii) Seismic-related ground failure, including
liquefaction?
Response:

Less Than Significant Impact. Liquefaction involves a sudden loss in strength of a saturated, cohesionless soil (e.g., predominantly sand, low plasticity silts, or sand silt mixtures) caused by cyclic loading such as an earthquake. This results in temporary transformation of the soil to a fluid mass. There are three factors that must exist concurrently in order for liquefaction to occur. These factors include:
• A source of ground shaking, such as an earthquake, capable of generating soil mass distortions; • A relatively loose silty and/or sandy soil; and
• A relatively shallow groundwater table (within approximately 50 feet below ground surface) or completely saturated soil conditions that will allow positive pore pressure generation.

The project site is located within an area that has low to moderate liquefaction potential. However, the depth to groundwater in the vicinity of the project site is approximately 35 feet below grade. The results of a liquefaction analysis indicate that the ground settlement resulting from an earthquake would be 44 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Figure 6-3: Geologic Faults and Liquefaction. July. 45 Giles Engineering Associates, Inc. 2024. Geotechnical Engineering Exploration and Analysis. May. 46 Ibid.
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Public Storage Moreno Valley Page 44 City of Moreno Valley negligible.47 Therefore, implementation of the project would not exacerbate the risks associated with ground-related failure. Therefore, a less than significant impact related to this issue would occur. No mitigation is required.
iv) Landslides?
Response:

Less Than Significant Impact. The geologic and topographic characteristics of an area, often determine its potential for landslides. Steep slopes, the extent of erosion, and the rock composition of a hillside all contribute to the potential for slope failure and landslide events. Common triggering mechanisms of slope failure include undercutting of slopes by erosion or grading, saturation of marginally stable slopes by rainfall or irrigation, and seismic shaking of marginally stable slopes during earthquakes. As described in the City’s Safety Element of the General Plan, there is the potential for landslides in the Badlands area within the easternmost portion of the City’s Sphere of Influence because there are steep slopes, and the underlying geological material is poorly consolidated.48 The project site is generally flat with no evidence of landslides occurring on site and the project site, and it is not located near the Badlands area. There are no natural or artificial slopes on the project site that have the potential for landslides. As the proposed project is not expected to be exposed to a landslide hazard and would not exacerbate landslide risks, a less than significant impact related to this issue would occur. No mitigation is required. b) Result in substantial soil erosion or the loss of
topsoil?
Response:

Less Than Significant Impact. Soils are classified by the United States Department of Agriculture (USDA) Natural Resource Conservation Service into four hydrologic soils groups based on the soil’s runoff potential. “Hydrologic soil group” is a term that represents a group of soils having similar runoff potential under similar storm and cover conditions. Soil properties that influence runoff potential are those that influence the minimum rate of infiltration for bare soil after prolonged wetting. The two soil units mapped within the project site are: Greenfield sandy loam (GyA), 0 to 2 percent slopes, and Hanford coarse sandy loam (HcA), 0 to 2 percent slopes.49 GyA and HcA soils are in hydrologic soil Group A, which have a high infiltration rate and low runoff potential and consist of deep, well-drained, sands and gravels. The proposed project would require the excavation and movement of on-site soils, which could provide for runoff or erosion issues. However, the soil types of Group A have a high infiltration rate and are less susceptible to erosion compared to other soil groups.

Prior to the issuance of grading permits, the project applicant would be required to prepare and submit detailed grading plans. These plans must be prepared in conformance with applicable standards of the City’s Grading Ordinance. Development of the project site would involve more than 1 acre of ground disturbance; therefore, the proposed project is required to obtain a National Pollutant Discharge Elimination System (NPDES) permit. A Storm Water Pollution Prevention Plan (SWPPP) would also be required to address erosion and discharge impacts associated with the proposed on-site grading by implementing appropriate best management practices (BMPs). The project Applicant/Developer would be required to adhere to the SWPPP which would require the implementation of BMPs, including erosion control measures, to minimize construction impacts. Additionally, upon completion of all construction activities, all areas of temporary disturbance would be restored and revegetated. The proposed project would have a less than significant impact associated with soil erosion. No mitigation is required. 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 onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Response:

Less Than Significant Impact. As discussed under Checklist Responses VII(a.iii) and VII(a.iv), liquefaction and landslides are not significant hazards at the project site. Lateral spreading refers to ground or slope deformation due to the presence of weak or liquefiable soils in the subsurface combined with strong seismic shaking. Due to the absence of any slope or channel within or near the project site, 47 Ibid.
48 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 6-Safety-Section 6.5 – Geologic Hazards. Page 6-19.

July.
49 United States Department of Agriculture, Natural Resources Conservation Service (USDA NRCS). 2024. Web Soil Survey.

Website: https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm (accessed December 13, 2024). □ □ ~ □
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Public Storage Moreno Valley Page 45 City of Moreno Valley the potential for lateral spreading at the site is considered to be very low. 50 Subsidence is the sudden
sinking or gradual downward settling of the earth’s surface with little or no horizontal motion. Subsidence is caused by a variety of activities, which includes (but is not limited to) withdrawal of groundwater, pumping of oil and gas from underground, the collapse of underground mines, liquefaction, and hydrocompaction. The proposed project does not include the withdrawal of groundwater or other resources from underground sources. Settlement (“seismic compaction”) of loose to medium-dense clean dry sands can occur during seismic shaking.

The Geotechnical Engineering Exploration and Analysis51 prepared for the project includes projectspecific recommendations and construction specifications that meet or exceed seismic design requirements. The specific design recommendations described in the final report would be incorporated into all project-related construction documents. Adherence to the specific design recommendations described in the report would ensure that impacts related to on-site or off-site landslides, lateral spreading, subsidence, liquefaction, or collapse remain less than significant. No mitigation is 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 generally have a significant amount of clay particles, which can give up water (shrink) or take on water (swell). The change in volume exerts stress on buildings and other loads placed on these soils. The extent of shrink/swell is influenced by the amount and kind of clay in the soil. The occurrence of these soils is often associated with geologic units having marginal stability.

The distribution of expansive soils can be widely dispersed, and they can occur in hillside areas as well as low-lying alluvial basins. On-site soils were identified to have a very low expansion potential. However, there may be localized, discontinuous layers of clayey soils with higher expansion potential. The specific design recommendations described in the Geotechnical Engineering Exploration and Analysis would be incorporated into all project-related construction documents to meet or exceed seismic design requirements.
52 Adherence to the specific design recommendations described in the final geotechnical report would ensure that impacts related to expansive soils remain less than significant. Mitigation is not required.
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 proposed project is expected to connect to existing sewer infrastructure. The project would not use septic tanks or other alternative wastewater disposal systems. Therefore, the development of the proposed project would have no impact related to this issue. Mitigation is not required. f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
Response:

Less Than Significant with Mitigation Incorporated. California Administrative Code, Title 14, Section 4307 states that no person shall remove, injure, deface or destroy any object of paleontological, archaeological, or historical interest or value. Compliance with Section 4307 is required for all development and would apply to the project as a matter of regulatory policy. As described in the City’s General Plan Final Program Environmental Impact Report (EIR), 53 the City’s Planning Area contains
sedimentary rock-units (Mt. Eden Formation and San Timoteo Formation) that have the potential to contain significant nonrenewable paleontological resources. Figure 5.10-3 of the City’s Final Program EIR indicates that the project site is not underlain by these two sedimentary rock-units and that there is a low potential for sensitive paleontological resources to occur on the project site. Given the site’s history of disturbance, the potential for undiscovered paleontological resources is considered low. Construction of the project is not expected to impact, either directly or indirectly, any known unique paleontological 50 Giles Engineering Associates, Inc. 2024. Geotechnical Engineering Exploration and Analysis. May. 51 Giles Engineering Associates, Inc. 2024. Geotechnical Engineering Exploration and Analysis. May. 52 Ibid.
53 City of Moreno Valley. 2006. City of Moreno Valley General Plan Final Program EIR. Chapter 5.10 – Cultural Resources. July. □ □ ~ □
□ □ □ ~
□ ~ □ □
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Public Storage Moreno Valley Page 46 City of Moreno Valley resource or site of unique geologic features. However, ground-disturbing activities at the project site still have the potential to disturb previously unknown subsurface resources. Mitigation Measure GEO-1 would ensure the project paleontologist is engaged to evaluate the significance of any paleontological resources identified during ground-disturbing activities. With implementation of Mitigation Measure GEO-1 paleontological resources impacts would be less than significant with mitigation incorporated.

Mitigation Measure GEO-1 If paleontological resources (fossils) are discovered during project grading, work shall be halted within 100 feet of the find until a qualified paleontologist assesses the significance of the find. Work occurring outside of the 100-foot buffer zone may continue. The project paleontologist shall monitor remaining earthmoving activities at the project site and shall be equipped to record and salvage fossil resources that may be unearthed during grading activities. The paleontologist shall be empowered to temporarily halt or divert grading equipment to allow recording and removal of the unearthed resources. Any fossils found shall be evaluated in accordance with the State CEQA Guidelines and offered for curation at an accredited facility approved by the City of Moreno Valley. Once grading activities have ceased or the paleontologist determines that monitoring is no longer necessary, monitoring activities shall be discontinued. This measure shall be implemented to the satisfaction of the City Planning Division.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.5 – Geologic Hazards - Figure 6-3 – 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 5.6-1 – Geology
- Figure 5.6-2 – 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 4-1 – Right-Lateral Strike -Slip Fault
- Figure 4-1.1 – Moreno Valley Geologic Faults and Liquefaction 2016 - Figure 4-1.2 – Moreno Valley Area Ground Shaking Map
• Chapter 8 – Landslide
- Figure 8-1 – Moreno Valley Slope Analysis 2016

6. Emergency Operations Plan, City of Moreno Valley, March 2009, http://www.moval.org/city_hall/ departments/fire/pdfs/mv-eop-0309.pdf
• Threat Assessment 1 – Major Earthquakes
- Figure 9 – Types of Faults
- Figure 10 – Earthquake Faults
- Figure 11 – Comparison of Richter Magnitude and Modified Mercalli Intensity - Figure 12 – Magnitude 4.5 or Greater Earthquake Map
- Figure 13 – Geologic Faults and Liquefaction
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Public Storage Moreno Valley Page 47 City of Moreno Valley VIII. GREENHOUSE GAS EMISSIONS – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
Response:

Less Than Significant Impact. This section discusses the project’s impacts related to the release of greenhouse gas (GHG) emissions for the construction and operational phases of the project.

Construction and operational GHG emissions were estimated using the California Emissions Estimator Model (CalEEMod) (refer to Appendix A) using the same methodology for the criteria pollutants described in Section III, Air Quality.

State CEQA Guidelines Section 15064(b) provides that the “determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data,” and further states that an “ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting.”
Appendix G of the State CEQA Guidelines includes significance thresholds for GHG emissions. A project would normally have a significant effect on the environment if it would do either of the following:
• Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents, South Coast Air Quality Management District (SCAQMD) has convened a GHG CEQA Significance Threshold Working Group (Working Group). Based on the last Working Group meeting modified in September 2010 (Meeting No. 15),54 SCAQMD proposed to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not the lead agency:
• Tier 1—Exemptions: If a project is exempt from CEQA, project-level and cumulative GHG emissions are less than significant.
• Tier 2—Consistency with a Locally Adopted GHG Reduction Plan: If the project complies with a GHG emissions reduction plan or mitigation program that avoids or substantially reduces GHG emissions in the project’s geographic area (i.e., city or county), project-level and cumulative GHG emissions are less than significant.
• Tier 3—Numerical Screening Threshold: If GHG emissions are less than the numerical screening-level threshold, project-level and cumulative GHG emissions are less than significant.

For projects that are not exempt or where no qualifying GHG reduction plans are directly applicable, SCAQMD requires an assessment of GHG emissions. SCAQMD, under Option 1, is proposing a “bright-line” screening-level threshold of 3,000 metric tons of carbon dioxide equivalent (MT CO2e) per year (or MT CO2e/yr) for all land use types or, under Option 2, the following land use-specific thresholds: 1,400 MT CO2e for commercial projects; 3,500 MT CO2e for residential projects; or 3,000 MT CO2e for mixed-use projects. This bright-line threshold is based on a review of the Governor’s Office of Planning and Research (OPR) database of CEQA projects. Based on their review of 711 CEQA projects, 90 percent of CEQA projects would exceed the bright-line thresholds identified above. Therefore, projects that do not exceed the bright-line threshold would have a nominal and therefore less than cumulatively considerable impact on GHG emissions.
54 South Coast Air Quality Management District (SCAQMD). 2010. Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15. September 28. Website: https://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases- (ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf (accessed January 2025). □ □ ~ □
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Public Storage Moreno Valley Page 48 City of Moreno Valley • Tier 4—Performance Standards: If emissions exceed the numerical screening threshold, a more detailed review of the project’s GHG emissions is warranted. The SCAQMD has proposed an efficiency target for projects that exceed the bright-line threshold. The current recommended approach is per-capita efficiency targets. The SCAQMD is not recommending use of a percentage emissions reduction target. Instead, the SCAQMD proposes proposed a 2035 efficiency target of 3.0 MT CO2e/yr per service population for project-level analyses and 4.1 MT CO2e/yr per service population for plan-level projects (e.g., program-level projects such as General Plans).

For the purpose of this analysis, the proposed project will be compared to the threshold of 3,000 MT CO2e/yr for all land use types. The proposed project is also evaluated for compliance with the City’s Climate Action Plan (CAP), the 2022 Scoping Plan, and the 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS).

Construction Greenhouse Gas Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. Construction would emit GHGs through the operation of construction equipment and from worker and builder supply vendor vehicles for the duration of the approximately 12-month construction period. The combustion of fossil-based fuels creates GHGs such as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). Furthermore, the fueling of heavy equipment emits CH4. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change. As indicated above, SCAQMD does not have an adopted threshold of significance for construction-related GHG emissions. However, lead agencies are required to quantify and disclose GHG emissions that would occur during construction. The SCAQMD then requires the construction GHG emissions to be amortized over the life of the project (which is defined as 30 years), added to the operational emissions, and compared to the applicable interim GHG significance threshold tier. Based on the CalEEMod results, it is estimated that the project would generate 448.0 MT CO2e during construction of the project. When amortized over the 30-year life of the project, annual emissions would be 14.9 MT CO2e.

Operational Greenhouse Gas Emissions. Long-term operation of the proposed project would generate GHG emissions from area, mobile, waste, and water sources, as well as indirect emissions from sources associated with energy consumption. Mobile-source GHG emissions would include project-generated vehicle trips associated with trips to the proposed project. Area-source emissions would be associated with activities such as landscaping and maintenance on the project site and other sources. Waste-source emissions generated by the proposed project include energy generated by landfilling and other methods of disposal related to transporting and managing project-generated waste. In addition, water-source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment. GHG emissions were estimated using CalEEMod. Table G shows the estimated operational GHG emissions for the proposed project. Motor vehicle emissions are the largest source of GHG emissions for the project, at approximately 43 percent of the project total. Energy sources are the next largest category, at approximately 30 percent. Water and waste sources are about 18 percent and 8 percent of the total emissions, respectively. Area-source emissions also make up less than 1 percent of the total emissions.

Table G: Greenhouse Gas Emissions
Emission Type Operational Emissions (MT/yr)
Total CO2 CH4 N2O CO2e Percentage of Total
Mobile Source 212.8 <0.1 <0.1 216.7 43
Area Source 2.7 <0.1 <0.1 2.7 <1
Energy Source 152.0 <0.1 <0.1 152.6 30
Water Source 60.2 1.0 <0.1 92.3 18
Waste Source 11.1 1.1 0.0 38.7 8
Total Operational Emissions 503.0 100.0
Amortized Construction Emissions 14.9 —
Total Annual Emissions 517.9 —
SCAQMD Threshold 3,000
Exceedance? No
Source: Compiled by LSA (January 2025).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
GHG = greenhouse gas
MT/CO2e = metric tons of carbon dioxide equivalent
MT/yr = metric tons per year
N2O = nitrous oxide
SCAQMD = South Coast Air Quality Management District
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Public Storage Moreno Valley Page 49 City of Moreno Valley As discussed above, a project would have less than significant GHG emissions if it would result in operational GHG emissions of less than 3,000 MT CO2e/yr. Based on the analysis results, the proposed project would result in approximately 517.9 MT CO2e/yr, which would not exceed the SCAQMD threshold of 3,000 MT CO2e/yr. Therefore, operation of the proposed project does not have the potential to generate significant GHG emissions that would have a significant effect on the environment. Impacts would be less than significant, and no mitigation is required. b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing
the emission of greenhouse gases?
Response:

Less Than Significant Impact. The following discussion evaluates the proposed project according to the goals of the City’s Climate Action Plan (CAP), the 2022 Scoping Plan, and SCAG’s 2024–2050 RTP/SCS.

City of Moreno Valley CAP. The City of Moreno Valley is currently in the process of updating its latest CAP as part of adopting the 2040 General Plan Update.
55 The City’s CAP is designed to reinforce the
City’s commitment to reducing GHG emissions and demonstrate how the City will comply with State of California’s GHG emission reduction standards. The CAP has been prepared concurrently with the updated Moreno Valley General Plan, reflecting the City’s most current land use and transportation strategy, and GHG implications of various General Plan’s goals and policies. While there is no sunset year for the CAP, the CAP provides analysis of GHG emissions to the year 2040, which is the General Plan horizon year. The following reduction measures from the City’s CAP will be applicable to the proposed project: Implement trip reduction programs in new residential, commercial, and mixed-use developments. Expand efforts to install energy efficient lighting technologies in new and existing private parking lots.
• Facilitate energy efficiency improvements in nonresidential buildings through incentives and regulations that may include energy performance reports, time of sale upgrades, and/or innovative partnerships such as expansion of utility provider (e.g., MVU, SCE, SoCalGas) programs to reduce energy use.
• Encourage residents and businesses to use efficient lawn and garden maintenance equipment or to reduce the need for landscape maintenance through native planting. • Reduce emissions from heavy-duty construction equipment by limiting idling based on SCAQMD requirements and utilizing cleaner fuels, equipment, and vehicles. • Require new landscaping to be climate appropriate.

The proposed project would construct a 130,764-square-foot, three-story, self-storage facility and associated site improvements including 19,437 square feet of landscaping. The proposed project would be consistent with the CAP goal of increasing energy efficiency in new buildings by complying with the latest California Building Code (Title 24), including the latest California Green Building Standards Code (CALGreen Code) standards. In addition, the proposed project would comply with local and State laws regarding solar energy and would be designed to be all-electric, consistent with the CAP goals. The proposed project would also use drought tolerant landscaping that requires low water and maintenance.

Therefore, the project would also be consistent with the CAP goal of increased canopy and tree count.

Based on the Trip Generation and Vehicle Miles Traveled (VMT) Analysis56 (Appendix J), the proposed project would be screened out from a VMT analysis and presumed to have a less than significant transportation impact. Therefore, the proposed project would not be implementing a trip reduction program. As such, the proposed project would be generally consistent with applicable CAP measures. 55 The 2040 General Plan Update was effective immediately upon adoption in June 2021. However, an environmental group subsequently filed a lawsuit challenging its adoption. In May 2024, the Riverside County Superior Court ruled in the lawsuit, directing the City to set aside the 2040 General Plan Update, including related changes to the Zoning Ordinance, its Climate Action Plan (CAP), and certification of its EIR until errors identified in the EIR’s analysis of air quality, greenhouse gas, and energy use impacts, and in its CAP, are rectified (Sierra Club v. City of Moreno Valley, et al., Riverside County Superior Court No. CVRI2103300). The project’s preliminary application was submitted on April 29, 2024, when the 2040 General Plan was in effect. This IS/MND is prepared as a stand-alone project analysis, which does not tier from the 2040 General Plan EIR or any other EIR document. It contains its own separate analysis of the environmental implications of the project. The IS/MND’s incorporation by reference of the 2040 General Plan does not affect the IS/MND’s adequacy under CEQA, or any other law or regulation. In addition, if the prior 2006 General Plan and Final EIR is the effective General Plan when the project goes before the City Council, the IS/MND also includes analysis of the project’s consistency with that prior plan. 56 LSA Associates, Inc. 2024. Trip Generation and Vehicle Miles Traveled Analysis for the Public Storage Moreno Valley Project.

October.
□ □ ~ □
2484
Public Storage Moreno Valley Page 50 City of Moreno Valley 2022 Scoping Plan. Executive Order (EO) B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. Senate Bill (SB) 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reduction target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. The California Air Resources Board (CARB) released the 2017 Scoping Plan to reflect the 2030 target set by EO B-30-15 and codified by SB 32.57 SB 32 builds on Assembly Bill (AB) 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels. AB 197, the companion bill to SB 32, provides additional direction to CARB that is related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 that is intended to provide easier public access to air emission data collected by CARB was posted in December 2016. AB 1279 codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative GHG emissions thereafter. In addition, the 2022 Scoping Plan58 assesses progress toward the statutory 2030 target while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities. • Energy-efficient measures are intended to maximize energy-efficiency building and appliance standards, pursue additional efficiency efforts (including new technologies and new policy and implementation mechanisms), and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. The proposed project would not be powered by natural gas, and no natural gas demand is anticipated during construction or operation of the proposed project. The elimination of natural gas in new development would help projects implement their “fair share” of achieving long-term 2045 carbon neutrality consistent with State goals. As such, if a project does not utilize natural gas, a lead agency can conclude that it would be consistent with achieving the 2045 neutrality goal and will not have a cumulative considerable impact on climate change. In addition, the proposed project would comply with the latest Title 24 standards regarding energy conservation and green building standards. Therefore, the proposed project would comply with applicable energy measures.
• Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. As noted above, the project would be required to comply with the latest Title 24 standards, which include a variety of different measures, including reduction of wastewater and water use. The proposed project would also include new drought tolerant landscaping that requires low water and maintenance. In addition, the proposed project would be required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the proposed project would not conflict with any of the water conservation and efficiency measures.
• The goal of transportation and motor vehicle measures is to develop regional GHG emission reduction targets for passenger vehicles. Specific regional emission targets for transportation emissions would not directly apply to the proposed project. However, vehicles traveling to the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program (Pavley standards). The second phase of Pavley standards will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025. Therefore, the proposed project would not conflict with the identified transportation and motor vehicle measures.

The proposed project would comply with existing State regulations adopted to achieve the overall GHG emission reduction goals identified in the 2022 Scoping Plan, EO B-30-15, SB 32, AB 197, and AB 1279.

SCAG’s Regional Transportation Plan/Sustainable Communities Strategy. SCAG’s 2024–2050 RTP/SCS identifies land use strategies that focus on new housing and job growth in areas served by high-quality transit, and other opportunity areas would be consistent with a land use development pattern that supports and complements the proposed transportation network. The core vision in the 2024–2050 RTP/SCS is to better manage the existing transportation system through design management strategies, 57 California Air Resources Board (CARB). 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. December. Website:
https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf (accessed January 2025). 58 California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan. November. 2485
Public Storage Moreno Valley Page 51 City of Moreno Valley integrate land use decisions and technological advancements, create complete streets that are safe for all roadway users, preserve the transportation system, expand transit, and foster development in transitoriented communities. The 2024–2050 RTP/SCS contains transportation projects to help more efficiently distribute population, housing, and employment growth, as well as providing a forecast development pattern that is generally consistent with regional-level General Plan data. The forecasted development pattern, when integrated with the financially constrained transportation investments identified in the 2024–2050 RTP/SCS, would reach the regional target of reducing GHG emissions from automobiles and light-duty trucks by 19 percent by 2035 (compared to 2005 levels). The 2024–2050 RTP/SCS does not require that local General Plans, Specific Plans, or zoning be consistent with the 2024–2050 RTP/SCS, but it provides incentives for consistency for governments and developers. Implementing SCAG’s RTP/SCS will greatly reduce the regional GHG emissions from transportation, thereby helping to achieve statewide emissions reduction targets. The proposed project would construct a 130,764-square-foot public self-storage building and associated site improvements. As demonstrated in the Consistency with Applicable Air Quality Plans in Section III, Air Quality, the proposed project does not meet the criteria identified in State CEQA Guidelines Section 15205.b.2 (Projects of Statewide, Regional, or Areawide Significance) for projects of Statewide, regional, or areawide significance. The proposed project would require a zone change to change the zoning designation of the project site from NC to CC and a CUP to allow development of the proposed project within the CC zone. The proposed project has the potential to employ up to 4 employees, some of which may already reside in Moreno Valley. According to SCAG’s 2024–2050 RTP/SCS, Moreno Valley households and employment are forecast to increase by approximately 21,900 households and 38,700 jobs, respectively, between 2019 and 2050.59 According to SCAG, up to 4 employees would represent approximately 0.0001 percent of the city’s forecasted employment growth from 2019 to 2050. As such, the proposed project would not interfere with SCAG’s ability to achieve the region’s GHG reduction target of 19 percent below 2005 per capita emissions levels by 2035. Furthermore, the proposed project is not regionally significant per State CEQA Guidelines Section 15206 and, as such, it would not conflict with the SCAG RTP/SCS targets because those targets were established and are applicable on a regional level. Therefore, it is anticipated that implementation of the proposed project would not interfere with SCAG’s ability to implement the regional strategies outlined in the RTP/SCS.

The proposed project would be consistent with applicable plans and programs designed to reduce GHG emissions. Therefore, the proposed project would not conflict with plans, policies, or regulations adopted for the purpose of reducing GHG emissions. Impacts would be less than significant, and no mitigation is required.

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 April 24, 2019
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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. The transport, use, and storage of hazardous materials during the construction and operation of the site would be conducted pursuant to all applicable local, state and federal laws, and in cooperation with the Riverside County Fire Department, Riverside County Department of Environmental Health, Hazardous Materials Division (DEH), Environmental Protection 59 Southern California Association of Governments (SCAG). 2024. 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy. Demographics and Growth Forecast, Technical Report, Table 13. Adopted April 4, 2024. □ □ ~ □
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Public Storage Moreno Valley Page 52 City of Moreno Valley and Oversight Division, and California Occupational Safety and Health Administration. Additionally, the United States Department of Transportation Office of Hazardous Materials Safety prescribes strict regulations for the safe transportation of hazardous materials by truck and rail on State highways and rail lines, as described in Title 49 of the Code of Federal Regulations (CFR) and implemented by Title 13 of the California Code of Regulations (CCR).

During demolition and construction activities for the project, there is a possibility of generating small quantities of hazardous materials. The construction phase of the project would include the transport, storage, and short-term use of petroleum-based fuels, lubricants, pesticides, and other similar materials.

The amount of hazardous chemicals present during construction is limited and would be in compliance with existing government regulations, such as the Hazardous Materials Transportation Act, the Resource Conservation and Recovery Act, and the CCR, Title 22.

Any associated risk would be adequately reduced to a level that is less than significant through compliance with these standards and regulations; thus, the limited use and storage of hazardous materials during construction of the project would not pose a significant hazard to the public or the environment. Accordingly, the potential for the release of hazardous materials during project construction would be low and, even if a release were to occur, it would not result in a significant hazard to the public, surrounding land uses, or environment due to the small quantities of these materials associated with construction.

The project would not emit hazardous emissions or involve hazardous or acutely hazardous materials, substances, or waste. However, the project could involve the use of materials associated with routine property maintenance, such as janitorial supplies for cleaning purposes and/or herbicides and pesticides for landscaping. Pursuant to the Federal Hazard Communication Standard (29 CFR 1910.1200) and the Laboratory Standard (29 CFR 1910.1450), Safety Data Sheets (SDS) outlining procedures to address spills and leaks for individual chemicals would be used to conduct chemical safety training for all employees who work with chemicals in order to minimize the occurrence of accidental chemical releases and ensure that, when one does occur, it is handled in a safe manner. These uses would not involve the routine transport, use, or disposal of quantities of hazardous materials that could create a significant hazard to the public or environment. Additionally, as described in the leasing agreements required for customers of the storage facilities, storage of hazardous materials is not permitted. The hazardous materials used during operations would be stored off site and would be handled and disposed of in accordance with applicable regulations.

The regulations discussed above inherently safeguard life and property from the hazards of fire/explosion arising from the storage, handling, and use of hazardous substances, materials, and devices, as well as hazardous conditions due to the use or occupancy of buildings. Through compliance with all applicable federal, State, and local laws, impacts to the public or environment from the routine transportation, use, and disposal of hazardous materials would be less than significant. No mitigation is required. 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. Refer to Checklist Response IX(a). As described in the Phase I Environmental Assessment60 prepared for the project, the project site was in agricultural use from approximately 1938 to 1997. The project site has been a vacant lot since 1997. Given the prior agricultural use on site, there is a potential for residual amounts of pesticides and/or herbicides to exist on site. According to the Phase I Environmental Assessment, based on the length of time since agricultural activity occurred on site, the likelihood that residual chemicals would be found above cleanup levels is low. Therefore, it was determined that the potential past use of pesticides and/or fertilizers does not present a recognized environmental condition (REC) to the project site.

The project would involve construction activities, including excavation, grading, and site preparation. As discussed in Checklist Response IX(a), during construction activities, the Applicant/Developer would be required to comply with relevant applicable federal, and local laws and regulations that pertain to hazardous materials and waste during construction and operation of the project. Therefore, the project 60 Apex Companies, LLC. 2024. Phase I Environmental Site Assessment Conducted on CA24007 Alessandro Boulevard and Indian Street, Moreno Valley, California 92553. April.
□ □ ~ □
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Public Storage Moreno Valley Page 53 City of Moreno Valley 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. No mitigation is required.
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:

No Impact. The nearest existing or proposed schools are the Ramona Elementary School located at 24801 Bay Avenue approximately 0.28 mile northeast of the project site and Sunnymead Montessori School located at 24851 Bay Avenue approximately 0.36 mile northeast of the project site. Neither of these schools are within 0.25 mile of the project site. As discussed in Checklist Response IX(b), the project would not result in a significant hazard affecting the public during project construction or operation. Furthermore, operation of the project would not result in significant impacts associated with hazardous materials because all materials would be handled, stored, and disposed of in accordance with applicable standards and regulations. Therefore, because the project does not involve activities that would result in the emissions of hazardous materials or acutely hazardous substances, and because the closest school is greater than 0.25 mile away from the project site, no impact would occur, and no mitigation is required.
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
Response:

No Impact. According to the EnviroStor website,61 no hazardous material sites were identified on or adjacent to the project site. Six sites were identified within 1 mile of the project site, and all sites were school investigations. The closest site is the Ramona Elementary School approximately 0.28 mile northeast of the project site. The site type was a school investigation with a “no further action determination” as of August 19, 2003.

Review of the State Water Resources Control Board (SWRCB) GeoTracker database confirms that the project site is not on a Leaking Underground Storage Tank (LUST) Cleanup site.62 According to the GeoTracker database, there are four LUST sites within 0.5 mile of the project site; however, remediation activities have been completed on all four sites and classified as “case-closed”, which means that a closure letter or other formal closure decision document has been issued. As such, none of these LUST cases represent a REC affecting the project site. The project site is not located on a list of solid waste disposal sites identified by the SWRCB with waste constituents above hazardous waste levels outside the waste management unit63 or active cease and desist orders and cleanup and abatement orders.64 The Phase I Environmental Site Assessment65 corroborates that the project site is not listed on any federal, tribal, or State-equivalent databases for hazardous sites. All use, storage, transport and disposal of hazardous materials (including any small amounts of hazardous wastes) during construction and operational activities will be completed in accordance with existing local, State, and federal hazardous materials regulations. Because the project site is not listed on the Department of Toxic Substances Control (DTSC) Hazardous Waste and Substances Site List (Cortese List, compiled pursuant to Section 65962.5 of the Government Code),66 no impact related to this topic would occur. No mitigation is required.
61 California Department of Toxic Substances Control (DTSC). 2024. EnviroStor, Site/Facility Search. Website: https://www. envirostor.dtsc.ca.gov/public/map/?global_id=60000502 (accessed December 16, 2024). 62 State Water Resources Control Board (SWRCB). 2024. GeoTracker database. Website: https://geotracker.waterboards.ca. gov/map/ (accessed December 16, 2024).
63 California Environmental Protection Agency (CalEPA).2024-a. Sites Identified with Waste Constituents above Hazardous Waste Levels Outside the Waste Management Unit. Website: https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/SiteCleanupCorteseList-CurrentList.pdf (accessed December 16 24, 2024). 64 California Environmental Protection Agency (CalEPA). 2024-b. Cortese List Data Resources. Website: https://calepa.ca.gov/ sitecleanup/corteselist/section-65962-5a/ (accessed December 16, 2024). 65 Apex Companies, LLC. Phase I Environmental Site Assessment conducted on CA24007 Alessandro Boulevard and Indian Street, Moreno Valley, California 92553. April.
66 California Environmental Protection Agency (CalEPA). 2024.-b. Cortese List Data Resources. Website: https://calepa.ca.gov/ sitecleanup/corteselist/section-65962-5a/ (accessed December 16, 2024). □ □ □ ~
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Public Storage Moreno Valley Page 54 City of Moreno Valley 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 closest airport is the March Air Reserve Base/Inland Port Airport (MARB/IPA) located approximately 2.35 miles southwest of the project site. The project site is not located within an air crash hazard zone.67 Airport Land Use Compatibility Plans (ALUCPs) provide guidance to ensure that land development around an airport is compatible with airport operations, protecting public safety by limiting incompatible land uses near flight paths, thereby safeguarding the airport's functionality and the surrounding community from noise and safety hazards associated with aircraft operations.

According to the MARB/IPA ALUCP, the project site is in Compatibility Zone E. Properties within Compatibility Zone E are subject to low noise levels associated with aircraft operations. Occasional overflights may be intrusive to some outdoor activities in Compatibility Zone E. The only prohibited uses in this zone are hazards to flight, which include physical (e.g., tall objects), visual, and electronic forms of interference with the safety of aircraft operations and development that may cause attraction of birds to increase. Development conditions in this zone include disclosure of airport proximity and existence of overflights for residential properties.68 The proposed self-storage facility would not include any physical, visual, or electronic forms of interference, nor would it include residential uses. The project would be consistent with the applicable development regulations and design standards of the ALUCP and would not result in a safety hazard or excessive noise levels for people residing or working in the area.

Therefore, impacts would be less than significant, and no mitigation is required. f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
Response:

Less Than Significant Impact. The project site is currently vacant and unoccupied. Construction activities that could temporarily restrict vehicular traffic would incorporate appropriate measures to facilitate the passage of persons and vehicles through/around any temporary road closures in accordance with the California Fire Code. During construction, standard traffic control devices such as warning signs, warning lights, and flaggers will be utilized as applicable to minimize obstructions and ensure the safe passage of emergency vehicles as necessary for the purposes of coordinating efforts during local, State, and/or federal emergency events, including response to hazardous materials incidents. Implementation of these traffic control measures will include guidance and navigational tools on the streets adjacent to the project site in order to maintain traffic flow and safety during construction.

Vehicular access to the project site would be provided via Indian Street and the existing shared access driveway south of the proposed self-storage building. The access driveway would lead to two access gates, one on the east side of the proposed self-storage building facilitating access to the northern portion of the project site, and the other also on the east side of the proposed self-storage building facilitating access to the eastern portion of the project site. Fire department emergency vehicle apparatus access road locations and design shall be in accordance with the California Fire Code, Riverside County Ordinance No. 787, and Moreno Valley/Riverside County Fire Department Standards to ensure proper roadway turning radii, and fire lane widths, etc. Additionally, the project site layout includes provisions for emergency vehicle access, which also would be reviewed for adequacy by the Moreno Valley/Riverside County Fire Department. Therefore, impacts would be less than significant, and mitigation is not required.
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
Response:
67 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 6-Safety-Section 6.10 – Air Crash Hazards. Figure 6-

5. July.
68 Riverside County Airport Land Use Commission (ALUC). 2014. March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan. Map MA-1: Compatibility Map. Website: https://rcaluc.org/sites/g/files/aldnop421/files/2023-06/March.pdf (accessed January 7, 2025).
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Public Storage Moreno Valley Page 55 City of Moreno Valley No Impact. Fire hazard severity zone maps published by the California Department of Forestry and Fire Protection (CAL FIRE) do not identify the project site as being within or adjacent to a moderate, high, or very high fire hazard severity zone.69 The nearest fire hazard severity zones to the project site are approximately 2.7 miles northeast and southeast of the project site. Therefore, the proposed project would not expose people or property to new increased wildland fire risks. Therefore, there would be no impact relating to exposure of people or structures to wildland fires from project implementation. No mitigation is required.

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 6-5 – 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 5.5-1 – Hazardous Materials Sites
- Figure 5.5-2 – Floodplains and High Fire Hazard Areas - Figure 5.5-3 – 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, http://www.rcaluc.org/Portals/13/17%20-%20Vol.%201%20 March%20Air%20Reserve%20Base%20Final.pdf?ver=2016-08-15-145812-700

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 5-2 – 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 2009, http://www.moval.org/city_hall/ departments/fire/pdfs/mv-eop-0309.pdf
• Hazard Mitigation and Hazard Analysis
• Threat Assessment 2 – Hazardous Materials
• Threat Assessment 3 – Wildfire
• Threat Assessment 6 – Transportation Emergencies
- Figure 17 – Air Crash Hazards
69 California Department of Forestry and Fire Protection (CAL FIRE). 2007, 2024. Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/ (accessed December 18, 2024). 2490
Public Storage Moreno Valley Page 56 City of Moreno Valley X. HYDROLOGY AND WATER QUALITY – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?
Response:

Less Than Significant Impact. The proposed project includes development of a 130,764-square-foot, three-story, self-storage building and associated parking. During construction activities, excavated soil would be exposed, and there would be an increased potential for soil erosion and transport of sediment downstream compared to existing conditions. During a storm event, soil erosion could occur at an accelerated rate. In addition, construction-related pollutants such as chemicals, liquid and petroleum products (e.g., paints, solvents, and fuels), and concrete-related waste could be spilled, leaked, or transported via stormwater runoff into nearby drainages and into downstream receiving waters. Runoff water quality is regulated by the National Pollutant Discharge Elimination System (NPDES) Program (established through the federal Clean Water Act [CWA]). The NPDES program objective is to control and reduce pollutant discharges to surface water bodies. Compliance with NPDES permits is mandated by State and federal statutes and regulations. Locally, the NPDES Program is administered by the Santa Ana RWQCB.

Construction of the project would disturb greater than 1 acre of soil; therefore, construction activities would be subject to the State Water Resource Control Board’s (SWRCB) NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit), Order No. 2022-0057-DWQ, NPDES No. CAS000002. The Construction General Permit regulates stormwater discharges from construction sites that result in disturbance of at least 1 acre of soil, and/or are smaller sites that are part of a larger common plan of development. The Construction General Permit requires the project Applicant/Developer to prepare and implement a Stormwater Pollution Prevention Plan (SWPPP). As part of the SWPPP, the project shall identify best management practices (BMPs) to address water quality impacts associated with construction activities.

Construction BMPs would include, but not be limited to, erosion control and sediment control BMPs designed to minimize erosion and retain sediment on site and good housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters. The SWPPP would be developed, and construction BMPs selected and implemented, to target pollutants of concern during construction. The construction BMPs would be designed to retain sediment and other pollutants on site so they would not reach receiving waters or degrade beneficial uses. Therefore, the project would comply with the provisions of the Construction General Permit.

Additionally, the project would be required to comply with the provisions of City Municipal Code Section

8.21.160, Erosion Control, which requires preparation of an Erosion Control Plan for all earthmoving and grading activities. The Erosion Control Plan would describe the construction BMPs that would be implemented to control runoff, erosion, and sediment movement during construction.

According to the Geotechnical Engineering Exploration and Analysis (Appendix E)70 prepared for the project, groundwater was encountered during exploratory borings at depths of 36 feet below ground surface. Construction would include excavation to depths of at least 5 feet below the proposed grade or 3 feet below bottom of foundations and floor slab, whichever is deeper. Therefore, groundwater dewatering is not anticipated to be required during construction.

The project would develop a vacant site with a self-storage facility and would result in the increase of approximately 2.6 acres of impervious surface area. Project operations have the potential to introduce pollutants of concern in stormwater runoff and, therefore, would be subject to the requirements of the California Regional Water Quality Control Board, Santa Ana Region, NPDES Permit and Waste Discharge Requirements for the Riverside County Flood Control and Water Conservation District, the County of Riverside, and the Incorporated Cities of Riverside County within the Santa Ana Region, Order Number R8-2010-0033, NPDES Permit No. CAS618033, also known as the Riverside County Municipal 70 Giles Engineering Associates Inc. 2024. Geotechnical Engineering Exploration and Analysis. May. □ □ ~ □
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Public Storage Moreno Valley Page 57 City of Moreno Valley Separate Storm Sewer System (MS4) permit. The Riverside County MS4 Permit regulates the discharge of pollutants into waters of the United States (waters of the U.S.).

In compliance with the Riverside County MS4 Permit, DRC Engineering Inc. prepared a Project Specific Preliminary Water Quality Management Plan (PWQMP) (Appendix G), 71 which provides details regarding
the proposed project’s stormwater management program, including proposed BMPs to reduce or eliminate pollutants of concerns in stormwater runoff. As detailed in the PWQMP, the project would include an underground infiltration chamber, which would capture, treat, and infiltrate 100 percent of the calculated design capture volume. The infiltration chamber would include an outflow that would direct any stormwater overflow to Indian Street where it would enter the existing City storm drain system. In compliance with the Riverside County MS4 Permit, the project shall submit a Final Water Quality Management Plan (WQMP) to the City for review and approval, which would specify the project specific Site Design, Source Control, Low Impact Development (LID), and Treatment Control BMPs that would be implemented to capture, treat, and reduce pollutants of concern in stormwater runoff. Additionally, the project would be required to comply with the provisions of City Municipal Code Section 8.10, Stormwater/Urban Runoff Management and Discharge Controls, which requires new development projects to control stormwater runoff through implementation of BMPs such as permeable areas, landscaping, or on-site rain capture systems. Further, Section 8.10 prohibits illicit connections to the storm drain system at commercial or industrial facilities and subjects such facilities to a regular program of inspection. The project would implement BMPs to capture, treat, and reduce pollutants of concern in stormwater runoff and therefore comply with City Municipal Code Section 8.10.

Overall, because the project would be required to comply with existing regulations including the Construction General Permit, the Riverside County MS4 Permit, and City Municipal Code requirements, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. 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. The City is served by two water purveyors: Eastern Municipal Water District (EMWD) and the Box Springs Mutual Water Company.72 However, EMWD supplies water to the majority of the City, including the project site. EMWD has a diverse portfolio of water supplies, including imported water from the Metropolitan Water District of Southern California (MWD), local groundwater, desalinated groundwater, and recycled water.73 The City’s main source of water supply is imported water from the MWD. According to its 2020 Urban Water Management Plan, most of EMWD’s water is imported water from the MWD, which is expected to meet the demands of all member agencies through 2045.74 The MWD determined that its water resources will continue to provide a reliable supply to its member agencies from 2020 to 2045 during normal, single-dry, and multiple-dry years.75 As discussed in Checklist Response XIX(a), because the project would develop a self-storage facility, the project would not result in a substantial increase in demand for water. Therefore, the project would not contribute to a substantial depletion of groundwater supplies.

Development of the project would increase the impervious surface area on the project site. Impervious surfaces reduce groundwater infiltration and thereby interfere with groundwater recharge. However, the proposed project includes an underground infiltration chamber that would capture and treat runoff from impervious surface areas and allow it to infiltrate back into the soil, which would allow for continued groundwater recharge. Therefore, the project would not preclude or obstruct on-site infiltration of stormwater into the local groundwater aquifer or interfere with groundwater recharge. Impacts would be less than significant.
71 DRC Engineering Inc. 2025. Project Specific Water Quality Management Plan. October. 72 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Section 5.13 Public Services and Utilities. July. 73 Eastern Municipal Water District (EMWD). 2021a. 2020 Urban Water Management Plan. Page 3-3. Website:
https://www.emwd.org/what-we-do/water-supply/urban-water-management-plan (accessed December 30, 2024). 74 Ibid. Section 6 Water Supply Characterization. 6.2.1 Purchased or Imported Water. 75 Eastern Municipal Water District (EMWD). 2021a. 2020 Urban Water Management Plan. Page 7-2. □ □ ~ □
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Public Storage Moreno Valley Page 58 City of Moreno Valley 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. During construction activities, more than 1 acre of soil would be disturbed.

Soil would be exposed and drainage patterns temporarily altered during grading and other construction activities, and there would be an increased potential for soil erosion and siltation compared to existing conditions. Additionally, during a storm event, soil erosion and siltation could occur at an accelerated rate. The Construction General Permit requires the preparation of a SWPPP to identify construction BMPs to be implemented as part of the proposed project to reduce impacts on water quality during construction, including those impacts associated with soil erosion and siltation. With compliance with the requirements in the Construction General Permit and implementation of construction BMPs, construction impacts related to changes in existing drainage patterns and on- or off-site erosion or siltation would be less than significant.

Development of the proposed project (building and pavement) would alter the amount of existing impervious surface area and the amount of generated runoff. Currently, runoff generally drains to the southwest into an existing v-gutter to the north of the existing shared access drive aisle at the south of the site. Stormwater crosses the drive aisle and flows through an existing parkway drain directly to the south of the existing driveway and into the curb and gutter on Indian Street. Under post-development conditions, the stormwater drainage pattern would be much the same as in the existing condition.

Stormwater runoff would surface drain to the parking lot area and flow into the proposed drain inlets located around the project site. Storm drain lines would then flow into an infiltration basin. The storm drain design would include a drain inlet at the south of the existing v-gutter that is crossing the shared access drive aisle that would also function as the outlet point for any overflow within the infiltration basin. At this outlet, stormwater would flow south and enter the existing parkway drain south of the shared drive aisle and enter Indian Street.
76 However, operation of the proposed project would result in an increase in impervious surfaces on the project site by approximately 2.6 acres, which could result in a net increase in stormwater runoff that could lead to downstream erosion in receiving waters. However, as discussed above, the infiltration chamber included in the project’s design would be used for stormwater control and treatment in compliance with the requirements of the Riverside County MS4 Permit. Additionally, the project would implement an Erosion Control Plan that would describe the construction BMPs to be implemented to control runoff, erosion, and sediment movement during construction in compliance with City Municipal Code. With incorporation of LID techniques and hydromodification requirements as required by the Riverside County MS4 Permit and implementation of an Erosion Control Plan as required by the City Municipal Code, operational impacts related to on- or offsite erosion or siltation would be less than significant.

For the reasons listed above, impacts related to on- or off-site erosion or siltation would be less than significant, and no mitigation is required.
76 DRC Engineering Inc. 2024a. Preliminary Hydrology Study. July. □ □ I ~ □
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Public Storage Moreno Valley Page 59 City of Moreno Valley 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. Refer to Checklist Response X(c.i). Development of the proposed project would result in an increase in impervious surfaces on the project site by approximately 2.6 acres, which could have the potential to increase the volume and rate of stormwater runoff discharged from the project site. However, as previously discussed, an infiltration chamber included in the project’s design would be used for stormwater control and treatment in compliance with the requirements of the Riverside County MS4 Permit. The proposed drainage facilities and BMPs needed to accommodate stormwater runoff would be appropriately sized so that on-site flooding would not occur. Therefore, with implementation of LID techniques as required by the Riverside County MS4 Permit, the proposed project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding onor off site. Impacts would be less than significant. 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. Refer to Checklist Response X(c.i). The Preliminary Hydrology Study (Appendix H) prepared for the project determined that implementation of the BMPs outlined in the PWQMP would decrease the ultimate amount of runoff to the existing storm drain system compared to existing conditions.77 As detailed above, the project would implement a SWPPP to ensure the project does not generate substantial polluted runoff during construction. Additionally, the project Applicant/ Developer would be required to prepare a Final WQMP that shall demonstrate the BMPs for source control, pollution prevention, site design, LID implementation, and structural treatment control that are designed and implemented to address 303(d) listed pollutants. The BMPs shall retain the project site’s minimum design capture volume in accordance with the Riverside County MS4 Permit. Therefore, impacts would be less than significant.
iv) Impede or redirect flood flows?
Response:

No Impact. The project site is not located within a Federal Emergency Management Agency (FEMA) designated 100-year floodplain. According to the FEMA Flood Insurance Rate Map (FIRM) No. 06065C0761G, the project site is located within Zone X.78 Zone X is designated as an area determined to be outside the 500-year floodplain. As the project would not place improvements and structures directly within a 100-year floodplain, the project would not impede or redirect flood flows. Therefore, there would be no impact related to impeding or redirecting of flood flows, and no mitigation would be required. d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
Response:

Less Than Significant Impact. Refer to Checklist Response X(c.iv). The project site is not located within a 100-year floodplain.79 According to the Governor’s Office of Emergency Services (Cal OES), the project site is not within a tsunami hazard area.80 According to the City’s General Plan, the project site would not expose people or structures to a risk of loss, injury, or death involving the failure of a levee or dam.81 Additionally, the project site is located 5.4 miles north of Lake Perris. At this distance, the project site is not considered susceptible to seiche-related hazards originating at Lake Perris. Since the project is not in a flood hazard, tsunami, or seiche zone, risk from release of pollutants from project inundation would be less than significant. Mitigation is not required.
77 DRC Engineering Inc. 2024a. Preliminary Hydrology Study. July. 78 Federal Emergency Management Agency (FEMA). 2008. National Flood Hazard Layer FIRMette. Website: https://msc.fema. gov/portal/search?AddressQuery=24500%20Alessandro%20Blvd%2C%20Moreno%20Valley%2C%20CA%2092553 (accessed January 6, 2025).
79 Ibid.
80 Governor’s Office of Emergency Services (Cal OES). 2024. My Hazards. Website: https://myhazards.caloes.ca.gov/ (accessed January 6, 2025).
81 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 6-Safety. July. □ □ ~ □
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Public Storage Moreno Valley Page 60 City of Moreno Valley e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
Response:

Less Than Significant Impact. Refer to Checklist Responses X(a), X(b), and X(c.i). The Water Quality Control Plan for the Santa Ana River Basin (Basin Plan) designates beneficial uses for water bodies in the Santa Ana Region and establishes water quality objectives and implementation plans to protect those beneficial uses.82 Implementation actions outlined in the Basin Plan include compliance with NPDES permit requirements. Because the project would comply with NPDES permit requirements including compliance with the Construction General Permit and the Riverside County MS4 Permit, and associated BMPs, the project would be consistent with the Basin Plan.

As previously discussed, the Geotechnical Engineering Exploration and Analysis prepared for the project indicates that groundwater exists at depths of 36 feet below ground surface at the project site.

Construction would require excavation to a depth of approximately 5 feet below ground surface.

Therefore, groundwater dewatering is not anticipated. Furthermore, the project design includes the construction of an infiltration chamber, which would capture, treat, and infiltrate stormwater from the project site and allow for continued groundwater recharge. Compliance with the Construction General Permit, the Riverside County MS4 Permit, and City Municipal Code would ensure the project would not conflict with a water quality control plan or a sustainable groundwater management plan, and impacts would remain less than significant. Mitigation is not required.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.7 – Water Quality - Figure 6-4 – Flood Hazards
• Chapter 7 – Conservation Element – Section 7.5 – Water Resources - Figure 7-1 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 5.5-2 – Floodplains and High Fire Hazard Areas • Section 5.7 – Hydrology and Water Quality
- Figure 5.7-1 – Storm Water Flows and Major Drainage Facilities - Figure 5.7-2 – 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 XI. LAND USE AND PLANNING – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Physically divide an established community?
Response:

No Impact. The project proposes the development of a self-storage facility on land with a General Plan designation of Commercial and a zoning designation of Neighborhood Commercial (NC) District. The proposed use is not allowed under the existing zoning designation of the site; therefore, the project includes a zone change to Community Commercial (CC) District. Surrounding land uses include selfstorage uses to the north, residential uses to the east, commercial uses (gasoline station and auto parts store) to the south, and Indian Street and commercial/retail uses to the west. An existing self-storage facility is located immediately north of the project site, and commercial uses are located to the south and 82 Regional Water Quality Control Board (RWQCB), Santa Ana Region. 1995. Water Quality Control Plan, Santa Ana Region.

Website: https://www.waterboards.ca.gov/santaana/water_issues/programs/basin_plan/ (accessed January 6, 2025). □ □ ~ □
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Public Storage Moreno Valley Page 61 City of Moreno Valley west (refer to Figures 1 and 2). The project is proposed on vacant property along Indian Street, north of Alessandro Boulevard, and would not introduce features such as highways or transit lines that would divide an established community. Additionally, the proposed use is consistent with several uses in the surrounding area. No impact regarding dividing an established neighborhood would occur. No mitigation is required.
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 previously discussed, the project includes processing a zone change from Neighborhood Commercial (NC) District to Community Commercial (CC) District, so the proposed use would be compatible with City zoning regulations. The project’s proposed uses would currently not be permitted under the Neighborhood Commercial (NC) District zoning regulations. However, the proposed Community Commercial (CC) zone and self-storage use would be consistent with the Moreno Valley General Plan adopted in 2006. Further, it should be noted that the City is in the process of finalizing the adoption of its 2040 GP Update. To be consistent with the 2040 GP Update, the project site would be rezoned to Corridor Mixed Use (CMU). Although the project site’s General Plan land use designation would differ from its original designation from the 2006 General Plan as analyzed in this Initial Study, and the project site would be rezoned, a Conditional Use Permit (CUP) will still be processed by the City in order to ensure uses by the proposed project would be permitted under the zoning code and consistent with the latest iteration of the City’s General Plan.83 Pursuant to CEQA, it should be further noted that policy conflicts do not in and of themselves constitute a significant environmental impact. Policy conflicts are considered to be environmental impacts only when they would result in direct physical impacts or where those conflicts relate to avoiding or mitigating environmental impacts. As such, this Initial Study analyzes associated physical environmental impacts that could result from development of the project site with the proposed self-storage uses under each topical section. The Initial Study evaluates those impacts against the baseline condition (vacant undeveloped site) where applicable (e.g., noise, air quality) and against the previously anticipated Neighborhood Commercial (NC) District use per the City’s zoning code (e.g., population and housing, growth inducement). As indicated throughout this Initial Study, the proposed project would not result in any direct physical impacts that cannot be mitigated to a less than significant level. Therefore, this impact would be less than significant. No additional mitigation is required.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.1 – Land Use - Figure 2-1 – Neighboring Lands Uses
- Figure 2-2 – 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 83 The 2040 General Plan Update was effective immediately upon adoption in June 2021. However, a lawsuit challenging its adoption was subsequently filed. In May 2024, the Riverside County Superior Court ruled in the lawsuit, directing the City to set aside the 2040 General Plan Update, including related changes to the Zoning Ordinance, its Climate Action Plan (CAP), and certification of its EIR until errors identified in the EIR’s analysis of air quality, greenhouse gas, and energy use impacts, and in its CAP, are rectified (Sierra Club v. City of Moreno Valley, et al., Riverside County Superior Court No. CVRI2103300). The Project’s preliminary application was submitted April 29, 2024 when the 2040 General Plan was in effect. This IS/MND is prepared as a stand-alone project analysis, which does not tier from the 2040 General Plan EIR or any other EIR document. It contains its own separate analysis of the environmental implications of the project. The IS/MND’s incorporation by reference of the 2040 General Plan does not affect the IS/MND’s adequacy under CEQA, or any other law or regulation. In addition, if the prior 2006 General Plan and Final EIR is the effective General Plan when the project goes before the City Council, the IS/MND also includes analysis of the project’s consistency with that prior plan. □ □ ~ □
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Public Storage Moreno Valley Page 62 City of Moreno Valley XII. MINERAL RESOURCES – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 currently undeveloped. According to the City’s General Plan, 84 known
mineral resources within the City are common materials such as sand, gravel, and rock used to make concrete and road base. Furthermore, there are no active mines within the City. The City’s General Plan Final Program EIR states that there are no regionally or statewide significant mineral resources within the planning area, including the project site.
85 No impacts to known mineral resources would occur as a result of the proposed project, and no mitigation is required. b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan,
or other land use plan?
Response:

No Impact. As stated above, there are no known mineral resources within the City of Moreno Valley. The project site is currently undeveloped. No mineral extraction activities occur on the project site, and it is not located within an area known to contain locally important mineral resources. Therefore, the proposed project would not result in the loss of availability of a locally important mineral resource recovery site as delineated on a local general plan, specific plan, or other land use plan as a result of project implementation. No impact would occur, and no mitigation is required.

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 XIII. NOISE – Would the project result in:

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:

A detailed assessment of noise impacts for the proposed project based on the project development characteristics is included in the Noise and Vibration Impact Analysis (Appendix I).86 84 City of Moreno Valley. 2006. City of Moreno Valley General Plan. Chapter 7 – Conservation, 7.8 Mineral Resources. July. 85 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Chapter 5.14 – Mineral Resources. July. 86 LSA Associates Inc. 2025e. Noise and Vibration Impact Analysis: Proposed Public Storage Moreno Valley Project in the City of □ □ □ ~
□ □ □ ~
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Public Storage Moreno Valley Page 63 City of Moreno Valley Less Than Significant with Mitigation Incorporated.

Short-Term Noise. Two types of short-term noise would occur during project construction, including:
(1) equipment delivery and construction worker commutes; and (2) project construction operations.

The first type of short-term construction noise would result from the transport of construction equipment and materials to the project site and construction worker commutes. These transportation activities would incrementally raise noise levels on access roads leading to the site. It is expected that larger trucks used in equipment delivery would generate higher noise impacts than trucks associated with worker commutes. Although there would be a relatively high single-event noise-exposure potential causing intermittent noise nuisance, the effect on longer-term ambient noise levels would be small when compared to the existing average daily traffic (ADT) volume of approximately 7,400 on Indian Street.

During the overlap of the site preparation phase and grading phase, approximately 1,361 acoustically equivalent trips would occur during an average day from worker and delivery activities resulting in a traffic noise increase of approximately 0.7 A-weighted decibels (dBA). A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, short-term construction-related impacts associated with worker commutes and equipment transport to the project site would be less than significant.

The second type of short-term noise impact is related to noise generated during site preparation, grading, building construction, architectural coating, and paving on the project site. Construction is undertaken in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on the project site. Therefore, the noise levels would vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase. Table H lists the maximum noise levels recommended for noise impact assessments for typical construction equipment based on a distance of 50 feet between the construction equipment and a noise receptor. Typical operating cycles for these types of construction equipment may involve 1–2 minutes of full-power operation followed by 3–4 minutes at lower power settings.

Table I shows the construction phases, the expected duration of each phase, the equipment expected to be used during each phase, the composite noise levels of the equipment at 50 feet, the distance of the nearest sensitive receptor (single-family residence east of project site) from the average location of construction activities (a distance of 200 feet from the center of the project site to the façade of the home), and noise levels expected during each phase of construction.

It is expected that average noise levels during construction at the nearest sensitive receptor, the singlefamily residence to the east, would approach 75 dBA equivalent continuous sound level (Leq) during the site preparation phase, which would occur for a duration of approximately 15 days. Average noise levels during other construction phases would range from 62 dBA Leq to 74 dBA Leq. These predicted noise levels would only occur when all construction equipment is operating simultaneously; therefore, these noise levels are assumed to be conservative in nature.

Table H: Typical Construction Equipment Noise Levels
Equipment Description Acoustical Usage Factor (%)
Maximum Noise Level
(Lmax) at 50 feet
Compressor 100 81
Concrete Mixer 40 85
Concrete Pump 40 85
Crane 16 83
Dozer 40 80
Forklift 20 75
Front [End] Loader 40 79
Generator 100 78
Grader 8 85
Scraper 40 88
Welder 40 74
Moreno Valley, California. February.
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Public Storage Moreno Valley Page 64 City of Moreno Valley Source: Noise from Construction Equipment and Operations, Building Equipment, and Home Appliances (USEPA 1971); Roadway Construction Noise Model (FHWA 2006).
ft = foot/feet
Lmax = maximum instantaneous sound level
Table I: Construction Noise Levels by Phase
Phase Duration
(days) Equipment
Composite
Noise Level
at 50 ft
(dBA Leq)
Distance to
Sensitive
Receptor
(ft)1
Noise Level
at Receptor
(dBA Leq)
Site Preparation 15 1 grader, 1 scraper, 3
dozers, and 1 tractor
87 200 75
Grading 25 1 grader, 1 dozer, and
2 tractors, and 1
excavator
86 200 74
Building
Construction
200 1 crane, 2 forklifts, 1
generator set, 1 tractor,
and 3 welders
84 200 72
Paving 15 1 cement and mortar
mixer, 1 paver,1 paving
equipment, 2 rollers,
and 1 tractor
86 200 74
Architectural
Coating
100 1 air compressor 74 200 62
Source: Compiled by LSA (2024).
1 Distances are from the average location of construction activity for each phase, assumed to be the center of the project site. Residential uses to the east are 200 feet from the center of construction activity. Other buildings within the same development are further away and would be exposed to less noise. dBA Leq = average A-weighted hourly noise level
ft = foot/feet
Although the project construction-related short-term noise levels have the potential to be higher than the ambient noise in the vicinity of the project site, construction noise would cease to occur once the project construction is completed. Furthermore, the construction-related noise levels would be below the 80 dBA Leq criteria established by the Federal Transit Administration (FTA) for residential uses. The project would be constructed in compliance with the requirements of the City’s Noise Ordinance, which states that construction activities shall only occur between the hours of 7:00 a.m. and 8:00 p.m. In addition to compliance with appropriate construction times, the following Standard Condition NOI-1 would implement measures during construction to reduce noise impacts to the greatest extent feasible and reduce project construction impacts to less than significant.

Standard Condition NOI-1 Prior to issuance of grading and building permits, the project Applicant/Developer shall submit grading plans and building plans for review and approval by the Director the City of Moreno Valley Public Works Department, or designee. These plans shall include the following requirements for construction activities:
• Construction activities shall only occur between the hours of 7:00 a.m. and 8:00 p.m. No construction shall be permitted outside of these hours or on federal holidays.
• Construction contracts shall specify that all construction equipment, fixed or mobile, shall be equipped with properly operating and maintained noise mufflers consistent with manufacturers’ standards. • In order to maximize the distance between construction equipment staging areas and the sensitive noise receivers in the area, all equipment staging areas and material storage areas shall be placed as far from these receivers as possible.
• During construction, stationary construction equipment shall be placed so that emitted noise is directed away from sensitive receptors nearest the project site.

Long-Term Noise. Traffic Noise: As detailed in the Trip Generation and Vehicle Miles Traveled (VMT) Analysis (Appendix J) prepared for the project, the proposed project would generate 216 daily trips.

Based on the ADT counts provided by the City, the ADT along Alessandro Boulevard and Indian Street 2499
Public Storage Moreno Valley Page 65 City of Moreno Valley in the vicinity of the project site is approximately 22,100 and 7,400, respectively, based on projections for the year 2005. While the existing ADT is likely higher, using 22,100 and 7,400 ADT as the existing traffic volume would be a conservative approach. As described in the Noise and Vibration Impact Analysis, the project would result in an increase of less than 0.1 dBA Community Noise Equivalent Level (CNEL) along Alessandro Boulevard and Indian Street. A noise level increase of less than 3 dBA would not be perceptible to the human ear; therefore, the traffic noise increases along Alessandro Boulevard and Indian Street resulting from the proposed project would be less than significant.

Truck Loading and Unloading Activities: Section 11.80.030(C) of the City Municipal Code states that no person shall maintain, create, operate or cause to be operated on private property any source of sound in such a manner as to create any non-impulsive sound which exceeds the City’s exterior daytime and nighttime noise standard of 60 dBA Leq and 55 dBA Leq when measured at a distance of 200 feet or more from the real property line of the source of the sound. Noise levels generated by trucks would be similar to noise readings from truck loading and unloading activities, which generate a noise level of 75 dBA Leq at 20 feet based on measurements taken by LSA. During this process, noise levels are associated with the truck engine noise, air brakes, and backup alarms. These noise levels would occur for a period of approximately 5 minutes for each truck.

Heating, Ventilation, and Air Conditioning (HVAC)Equipment: The proposed project would include rooftop HVAC units atop the proposed building. The HVAC equipment could operate 24 hours per day and would generate sound power levels (Lw) of up to 87 dBA Lw or 72 dBA Leq at a distance of 5 feet. It is estimated that approximately nine HVAC units would be installed.

Operational noise level impacts would be 56.0 dBA Leq during the peak hour daytime and 52.4 dBA Leq during the off-peak hour nighttime at the nearest sensitive receptor (single-family residence east of project site). These noise levels are below the daytime and nighttime hourly noise level standards or 60 dBA Leq and 55 dBA Leq, respectively, for residential uses. Additionally, the proposed 6-foot-high wall along the eastern boundary of the project site would further reduce project-generated noise levels.

With implementation of Standard Condition NOI-1, short-term construction noise impacts would be reduced to less than significant. During operation, the project would not increase long-term ambient noise in excess of the City’s exterior daytime and nighttime noise standards of 60 dBA Leq and 55 dBA Leq when measured at a distance of 200 feet or more from the real property line of the source of the sound or the equivalent noise standard when measured at the nearest sensitive receptors. Therefore, long-term noise would be less than significant, and mitigation is not required. b) Generation of excessive groundborne vibration or
groundborne noise levels?
Response:

Less Than Significant with Mitigation Incorporated. This construction vibration impact analysis discusses the level of human annoyance using vibration levels in vibration velocity in decibels (VdB) and would assess the potential for building damage using peak particle velocity (PPV), which is measured in inches per second (in/sec). Vibration thresholds for significance are established by the City under Section

9.10.170 of the Municipal Code and by the FTA’s Transit Noise and Vibration Impact Assessment Manual.
87 Section 9.10.170 of the Municipal Code prohibits vibration that can be felt at or beyond the property line.

However, construction activity is exempt from Section 9.10.170 pursuant to Section 9.10.030, which states temporary construction, maintenance, or demolition activities between the hours of 7:00 a.m. and 7:00 p.m. are exempt from the provisions of Chapter 9.10 (Performance Standards) of the City Municipal Code.

FTA guidelines show that a vibration level of up to 94 VdB (0.2 PPV [in/sec]) is considered safe for nonengineered timber and masonry buildings, which are the types of buildings located on properties adjacent to the project site. Table J shows the PPV and VdB values at a distance of 25 feet from the construction vibration source. As shown in Table J, large bulldozers and other heavy‐tracked construction equipment (except for pile drivers and vibratory rollers) generate approximately 87 VdB of ground‐borne vibration when measured at a distance of 25 feet, based on the Transit Noise and Vibration Impact Assessment Manual.
87 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. Website: https://www. transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-manualfta-report-no-0123_0.pdf (accessed January 7, 2025). □ I ~ □ □
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Public Storage Moreno Valley Page 66 City of Moreno Valley Table J: Vibration Source Amplitudes for Construction Equipment Equipment Reference PPV/LV at 25 ft
PPV (in/sec) LV (VdB)1
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Caisson Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 RMS VdB re 1 µin/sec.
µin/sec = micro-inches per second
ft = foot/feet
FTA = Federal Transit Administration
in/sec = inches per second
LV = velocity in decibels
PPV = peak particle velocity
RMS = root-mean-square
VdB = vibration velocity in decibels
The closest structures, which are associated with the self-storage uses to the north, are approximately 5 ft from the project construction boundary. With the use of smaller equipment, such as a small bulldozer with a reference level of 0.003 PPV (in/sec), the structures at 5 ft could experience vibration levels of up to 0.034 PPV (in/sec) and would not exceed the 0.2 in/sec threshold.

In the case of using larger equipment, such as a large bulldozer, the structures at 5 ft could result in vibration levels that exceed the 0.2 in/sec threshold and experience vibration levels of up to 0.995 PPV (in/sec). This vibration level exceeds the 0.2 in/sec PPV threshold, which could result in a potentially significant impact. The distance from large construction equipment with a reference vibration level of

0.089 in/sec PPV at 25 ft for which the 0.2 in/sec threshold would no longer be exceeded is 15 ft. Vibration levels at all other buildings would be lower. With implementation of Mitigation Measure NOI-1, which includes implementing vibration reduction measures during construction, construction would not result in any vibration damage, and impacts would be less than significant with mitigation incorporated.

Mitigation Measure NOI-1 Construction Vibration Assessment. Due to the close proximity to surrounding structures, the City of Moreno Valley (City) Director of Community Development, their designee, and the Developer/Applicant shall verify prior to issuance of grading permits that the approved plans require that the construction contractor shall implement the following reduction measures during project construction activities to ensure that damage does not occur at surrounding structures:
• The first step in the Vibration Assessment should be a determination if any structures are within 15 feet of potential heavy construction activities. If is determined that no structures meet this criteria, no further effort is necessary.
• If heavy construction equipment is necessary, structures that are located within 15 feet of heavy construction activities and that have the potential to be affected by ground-borne vibration should be identified. This task shall be conducted by a qualified structural engineer as approved by the City’s Director of Community Development, or designee.
• Once the construction equipment list finalized, a comparison of the proposed equipment to be used and the assumed equipment vibration levels presented in Table 7-4 of the Federal Transit Administration’s (FTA) Noise and Vibration Impact Assessment Manual (FTA Report No. 0123) shall be completed. If it is determined that the proposed equipment would generate lower vibration levels than assumed, further vibration assessment would not be necessary.

However, if levels would potentially exceed the City’s standard of 0.2 inch per second peak particle velocity (PPV), the project Applicant/Developer shall develop a vibration monitoring and construction contingency plan for approval by the City Director of Community Development, or designee, to identify structures where monitoring would be conducted; set up a vibration monitoring schedule; define structure-specific vibration limits; and address the 2501
Public Storage Moreno Valley Page 67 City of Moreno Valley need to conduct photo, elevation, and crack surveys to document before and after construction conditions. Construction contingencies would be identified for when vibration levels approached the limits. • If a vibration monitoring and construction contingency plan is deemed necessary, monitoring of vibration during initial construction activities would be required. Monitoring results may indicate the need for more or less intensive measurements.
• When vibration levels approach limits, suspend construction and implement contingencies as identified in the approved vibration monitoring and construction contingency plan to either lower vibration levels or secure the affected structures.

The proposed project would not generate vibration during operation. According to the FTA’s Transit Noise and Vibration Impact Assessment Manual, vibration levels generated from project-related traffic on the adjacent roadways are unusual for on road vehicles because the rubber tires and suspension systems of on-road vehicles provide vibration isolation. Based on a reference vibration level of 0.076 in/sec PPV, structures more than 20 feet from the roadways that contain project trips would experience vibration levels below the most conservative standard of 0.12 in/sec PPV; therefore, vibration levels generated from project-related traffic on the adjacent roadways during operation would be less than significant, and no mitigation measures are required.
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:

No Impact. The proposed project is approximately 2.35 miles from the nearest airport (March Air Reserve Base/Inland Port Airport (MARB/IPA)). Based on the MARB/IPA Airport Land Use Compatibility Plan, the project site is located outside of the 60-dBA CNEL noise contour of the airport.88 In addition, there are no private airstrips or heliports within 2 miles of the project site. Further, the proposed project does not include any residential use. The project would not expose people residing or working in the vicinity of the project site to excessive noise levels from aircraft noise. Therefore, no impact would occur related to aircraft noise. Mitigation is not required.
88 Riverside County Airport Land Use Commission (ALUC). 2014. March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan. Map MA-1: Compatibility Map. Website: https://rcaluc.org/sites/g/files/aldnop421/files/2023-06/March.pdf (accessed January 7, 2025).
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Public Storage Moreno Valley Page 68 City of Moreno Valley Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 6 – Safety Element – Section 6.4 – Noise
- Figure 6-2 – Buildout Noise Contours

2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.4 – Noise
- Figure 5.4-1 – March Air Reserve Base Noise Impact Area - Figure 5.4-2 – Buildout Noise Contours – Alternative 1 - Figure 5.4-3 -- Buildout Noise Contours – Alternative 2 - Figure 5.4-4 -- 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%20 March%20Air%20Reserve%20Base%20Final.pdf?ver=2016-08-15-145812-700 XIV. POPULATION AND HOUSING – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 site is located along Indian Street, north of Alessandro Boulevard. The project site is zoned as Neighborhood Commercial (NC) and would be changed to Community Commercial (CC) as part of the proposed project. Both zoning designations indicate that the project site is planned for commercial use in the City. Therefore, the City has already planned for the development of the project site.

Construction. Construction of the proposed project would provide short-term construction jobs over an approximate 12-month period. Many of the construction jobs would be temporary and would be specific to the variety of construction activities. Generally, construction workers are only at a job site for the timeframe in which their specific skills are needed to complete that phase of construction. It is expected that local and regional construction workers would be available to serve the proposed project’s construction needs; therefore, project-related construction workers would not be expected to relocate their household’s place of residence as a consequence of working on the proposed project. The proposed project would not result in impacts associated with inducing substantial population growth or demand for housing through increased construction employment, and no mitigation would be required.

Operation. The proposed project includes up to two employees per shift to operate the facility. The proposed project would not cause or result in direct population growth because the proposed project would not provide or remove housing on the project site. The proposed project would interconnect to existing sewer, water, electric, and telecommunications utilities within the Indian Street right-of-way.

Therefore, the proposed project would not induce a substantial unplanned population growth to the area.

Impacts would be less than significant, and no mitigation is required. b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
Response:

No Impact. The project site is vacant and does not contain any existing people or housing that would be removed due to development of the proposed project. Therefore, the proposed project would not displace □ □ ~ □
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Public Storage Moreno Valley Page 69 City of Moreno Valley a substantial number of existing people or housing, requiring the construction of replacement housing elsewhere. No impact would occur, and no mitigation is required.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.1 – Land Use - Figure 2-1 – Neighboring Lands Uses
- Figure 2-2 – 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 XV. PUBLIC SERVICES – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 contracts with the Riverside County Fire Department (RCFD) to provide fire protection, fire prevention, and emergency services within the City.

The Moreno Valley Fire Department is administered and operated by the California Department of Forestry and Fire Protection (CAL FIRE). The Kennedy Park Fire Station 65, located at 15111 Indian Street, is the closest station to the project site approximately 1.2 miles south. Fire Station 65 is a twobay facility that houses one paramedic engine company and a reserve fire engine.89 Fire hazard zones published by CAL FIRE do not identify the project site as being within either a moderate, high, or very high fire hazard severity zone.90 Although the proposed project would introduce new structures to a vacant site, the project site is located in an area that is already served by existing fire protection services. New development must comply with existing fire code pursuant to City Municipal Code and California Fire Code. The proposed project would not increase the City’s number of employed firefighters or indirectly increase the City’s population. Additionally, the proposed project would not increase the need for fire protection services, or adversely affect the City Fire Department’s ability to provide service to the project site. Therefore, a less than significant impact would occur, and no mitigation is required.
ii) Police protection?
Response:

Less Than Significant Impact. The City of Moreno Valley contracts with the Riverside County Sheriff’s department to provide police protection services within the City. The Moreno Valley Police Department (MVPD) headquarters is located at 22850 Calle de San Juan de Los Lagos, approximately 2 miles west of the project site. The MVPD has adopted a “Zone Policing” strategy that divides the City into four zones in which police officers are assigned. The intent of this strategy is to improve response times for calls and to connect MVPD with citizens and business owners within their assigned zones. According to the MVPD Zone Policing Map,
91 the project site is located within Zone 2. The Zone 2 team includes a Zone 89 City of Moreno Valley. n.d. City of Moreno Valley Fire Department. Fire Station Locations. Website: https://moval.gov/ departments/fire/dep-station-locations.html#tab-5 (accessed December 17, 2024). 90 California Department of Forestry and Fire Protection (CAL FIRE). 2007. 2024. Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/ (accessed December 18, 2024). 91 City of Moreno Valley. n.d. City of Moreno Valley Police Department. Zone Policing. Website: https://moval.gov/departments/ police/dept-zone-policing.html (accessed December 17, 2024). □ □ ~ □
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Public Storage Moreno Valley Page 70 City of Moreno Valley Commander, Zone Supervisor, and Zone Coordinator. Although the proposed project could incrementally increase the need for police services in the area, the project site is located in an area that is within the existing service area of MVPD. Therefore, the proposed project would not require new or physically altered police protection facilities, the construction of which could cause significant environmental effects.

Therefore, impacts would be less than significant, and no mitigation is required. iii) Schools?
Response:

No Impact. The project site is located within the Moreno Valley Unified School District (MVUSD) boundary. MVUSD educates nearly 32,000 students in grades TK-12 at 40 schools. MVUSD consists of 23 elementary schools, 6 middle schools, 4 comprehensive high schools, and 7 alternative schools.92 The project site is within the boundaries of Ramona Elementary School located approximately 0.28 mile northeast of the project site at 24801 Bay Avenue, Badger Springs Middle School located approximately

1.0 mile north of the project site at 24750 Delphinium Avenue, and Moreno Valley High School located approximately 1.6 miles northwest of the project site at 23300 Cottonwood Avenue.93 The proposed project does not include any residential uses that would increase population growth, generate an increased demand for school facilities, or require the construction of school facilities. The operation of the proposed project would not result in an increase in demand for schools and would not trigger the need for new or altered school facilities. Therefore, the project would have no impacts related to schools, and no mitigation would be required.
iv) Parks?
Response:

Less Than Significant Impact. The proposed project does not include any residential uses and, therefore, would not increase the City’s population or result in an increased demand for parks. The new employees anticipated by the project are expected to reside generally in the vicinity of the site. As there is no direct increase in population anticipated from the project, demand on existing park facilities is expected to be minimal. Therefore, no new park facilities would be required to serve the project. Impacts would be less than significant, and no mitigation is required.
v) Other public facilities?
Response:

Less Than Significant Impact. The proposed project would not cause an increase in population resulting in a significant impact on other public facilities such as libraries and public works/maintenance facilities.

There is one library within 1.0 mile of the project site. The Moreno Valley City Library is located approximately 1.0 mile east of the project site at 25480 Alessandro Boulevard. As described above, the proposed project would not contribute to a direct increase in population, increasing demand for public facilities such as libraries. As such, the proposed project would not result in an increase in demand for libraries and would not trigger the need for new or altered library facilities. No new facilities would be required to be constructed to accommodate the proposed project. Therefore, the project would have less than significant impacts related to public libraries, and no mitigation is required.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 2 – Community Development Element – Section 2.5 – Schools - Figure 2-3 – 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 4-2 – Future Parklands Acquisition Areas
- Figure 4-3 – Master Plan of Trails
92 Moreno Valley Unified School District (MVUSD). n.d.-a. About Our District. Website: https://www.mvusd.net/about/aboutus (accessed December 23, 2024).
93 Moreno Valley Unified School District (MVUSD). n.d.-b. MVUSD District Maps. School Locator Map. Website:
https://www.schoolsitelocator.com/apps/morenovalley/?data_id=dataSource_1-ssl_test_mapImageService_4376%3A16 (accessed December 17, 2024).
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Public Storage Moreno Valley Page 71 City of Moreno Valley • Chapter 6 – Safety Element – Section 6.1 – Police Protection and Crime Preventions • Chapter 6 – Safety Element – Section 6.2 – Fire and Emergency Services - Figure 6-1 – Fire Stations

2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.13 – Public Services
- Figure 5.13-1 – Location of Public Facilities

3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code XVI. RECREATION – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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. The proposed project does not include any residential uses and would not contribute to a direct increase in population. The new employees generated by the project are expected to reside in the general vicinity of the project site. Therefore, the project would not substantially increase demand on existing neighborhood or regional parks or other recreational facilities so as to increase or accelerate their physical deterioration. The proposed project would result in less than significant impacts, and no mitigation is required.
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:

No Impact. The proposed project does not include any recreational facilities or parkland. As stated above, the proposed project does not include residential uses and would not contribute to a direct increase in population. Therefore, the proposed project would not propose, or create a need for, new or physically altered recreational facilities. The project would result in no impact and no mitigation is required.

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 4-1 Open Space
- Figure 4-2 – Future Parklands Acquisition Areas
- Figure 4-3 – 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 5.13-1 – Location of Public Facilities

3. Title 9 – Planning and Zoning of the Moreno Valley Municipal Code □ □ ~ □
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Public Storage Moreno Valley Page 72 City of Moreno Valley XVII. TRANSPORTATION – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with program plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian
facilities?
Response:

Less Than Significant Impact. The project would develop a self-storage facility on a currently vacant project site. Vehicular access to the project site would be provided via Indian Street and the existing shared access driveway south of the proposed self-storage building. The access driveway would lead to two access gates, one on the east side of the proposed self-storage building facilitating access to the northern portion of the project site, and the other also on the east side of the proposed self-storage building facilitating access to the eastern portion of the project site.

The project would include a zone change to change the zoning designation of the project site from Neighborhood Commercial (NC) to Community Commercial (CC). The project would be consistent with the CC zoning designation and not conflict with a plan, ordinance, or policy addressing the circulation system. Vehicular access to the project site would be provided via Indian Street and the existing shared access driveway south of the proposed self-storage building. Currently, a Class 2 bicycle lane exists along Indian Street adjacent to the project site. The project would not impede or interfere with existing or planned bicycle facilities along Indian Street. The project would be required to include parking facilities for bicycles and accommodate bicycle routes along its roadway frontage.

Pedestrian facilities in proximity to the project site include the existing sidewalk along Indian Street. The project would provide a landscaped setback from the sidewalk along its roadway frontage and would not remove any pedestrian facilities, nor would it conflict with any adopted plans or policies for new pedestrian facilities.

The City is primarily served by the Riverside Transportation Agency (RTA), which provides public bus service to Riverside County.94 Although RTA does not operate any bus routes along the project frontage area on Indian Street, a bus stop for RTA route 11 is located on Indian Street just south of the intersection with Alessandro Boulevard 95
The project would not preclude or otherwise adversely affect existing or proposed transit, pedestrian, or bicycle projects or policies identified by the City. Therefore, impacts from conflict with a program, plan, ordinance, or policy addressing transit, pedestrian, or bicycle facilities, would be less than significant. 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 traveled (VMT). According to the City Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment,
96 projects generating less than 400 daily vehicle trips, exclusive of any existing daily vehicle trips generated by the site, are screened out from a VMT analysis and presumed to have a less than significant transportation impact.

As detailed in the Trip Generation and Vehicle Miles Traveled (VMT) Analysis97 (Appendix J) prepared for the project, the trip generation of the self-storage building was determined by referencing trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th 94 City of Moreno Valley. 2006. City of Moreno Valley General Plan Final Program EIR. Chapter 5.2 – Traffic/Circulation. July. 95 Riverside Transportation Agency. 2024. System Map. Website: https://www.riversidetransit.com/index.php/maps-schedules (accessed December 19, 2024).
96 City of Moreno Valley. 2020. Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment. Website: https://www.moval.org/departments/public-works/transportation/TIA-Guidelines.pdf (accessed December 16, 2024).
97 LSA Associates, Inc. 2024. Trip Generation and Vehicle Miles Traveled Analysis for the Public Storage Moreno Valley Project.

October.
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Public Storage Moreno Valley Page 73 City of Moreno Valley Edition (2021) for Land Use 151 (Mini-Warehouse).98 In addition, the trip generation potential for the RV spaces was assessed by applying average trip rates derived from trip generation surveys for similar existing RV and boat storage facilities in Chino and Ontario. The trip characteristics of these facilities are comparable to the proposed project, as customers store their vehicles and boats and retrieve them for recreational purposes when needed. Table K shows the anticipated trip generation for the project.99 Table K: Project Trip Generation
Land Use Size Unit Daily
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Trip Rates
Mini-Warehouse1tsf 1.45 0.05 0.04 0.09 0.07 0.08 0.15
RV Storage2 space 0.48 0.02 0.01 0.03 0.02 0.02 0.04
Project Trip Generation
Mini-Warehouse 132.006 tsf 191 7 5 12 9 11 20
RV Storage 53 spaces 25 1 1 2 1 1 2
Total 216 8 6 14 10 12 22
Source: Compiled by LSA (2024).
1 Trip rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition (2021). Land Use 151. 2 Trip rates are based on survey data for similar existing facilities in Chino and Ontario (2021). 50/50 inbound/outbound split is assumed for the peak hours.
tsf = thousand square feet
As shown in Table K, the proposed project would generate 216 daily trips, including 14 trips (8 inbound and 6 outbound) in the a.m. peak hour and 22 trips (10 inbound and 12 outbound) in the p.m. peak hour.

Because the proposed project would generate less than 400 daily trips, it is exempt from an VMT analysis and presumed to have a less than significant transportation impact pursuant to the City’s Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment.
100 Mitigation is not required.
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:

No Impact. As stated previously, vehicular access to the project site would be provided via Indian Street and the existing shared access driveway south of the proposed self-storage building. The access driveway would lead to two access gates, one on the east side of the proposed self-storage building facilitating access to the northern portion of the project site, and the other also on the east side of the proposed self-storage building facilitating access to the eastern portion of the project site. Vehicular traffic to and from the project site would use the existing network of regional and local roadways that currently serve the area surrounding the project site. Based on the temporary nature of the construction activities and trips, and the low trip generation for daily operations, project vehicles would not create operational deficiencies or related hazards to the public roadways when accessing the project site.

The City and the Developer/Applicant, at final plan check, would ensure that all improvements associated with the project are consistent with City standards and requirements. Adherence to applicable City requirements would ensure the proposed development would not include any sharp curves or dangerous intersections. Therefore, the proposed project would result in no impacts related to traffic safety due to a design feature (e.g., substandard roadway and/or roadway design), and no mitigation would be required.
98 Institute of Transportation Engineers (ITE). 2021, Trip Generation Manual, 11th Edition. 99 This analysis evaluated the project trip generation associated with 132,006 square feet of self-storage uses and 53 RV spaces.

The project’s site plan has since been modified to include 130,764 square feet of self-storage uses and 52 RV spaces. The modifications to the project site plan were reviewed by LSA, and it was determined that they would result in negligible impacts related to trip generation. Therefore, the Trip Generation and Vehicles Miles Traveled Analysis accurately presents traffic impacts for the project.
100 City of Moreno Valley. 2020. Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment. Website: https://www.moval.org/departments/public-works/transportation/TIA-Guidelines.pdf (accessed December 16, 2024).

I I
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Public Storage Moreno Valley Page 74 City of Moreno Valley d) Result in inadequate emergency access?

Response:

Less Than Significant Impact. Construction activities that may temporarily restrict vehicular traffic would be required to implement appropriate measures to facilitate the passage of persons and vehicles through/ around any required road closures. Typical City requirements include prior notification of any lane or road closures with sufficient signage before and during any closures, flag crews with radio communication when necessary to coordinate traffic flow, etc. The Applicant/Developer would be required to comply with these requirements, which would maintain emergency access and allow for evacuation if needed during construction activities. Compliance with these requirements would ensure that short-term impacts related to this issue are less than significant. Mitigation is not required.

Sources:

1. Moreno Valley General Plan, adopted July 11, 2006
• Chapter 5 Circulation Element
- Figure 9-1 – Circulation Plan
- Figure 9-2 – LOS Standards
- Figure 9-3 – Roadway Cross-Sections
- Figure 9-4 – Bikeway Plan

2. Final Environmental Impact Report City of Moreno Valley General Plan, certified July 11, 2006 • Section 5.2 – Traffic/Circulation
- Figure 5.2-1 – Circulation Plan
- Figure 5.2-2 – General Plan Roadway Cross-Sections
- Figure 5.2-3 – Year 2000 Number of Through Lanes
- Figure 5.2-4 – Year 2000 Daily Volume/Capacity (V/C) Ratios - Figure 5.2-5 – Year 2000 Average Daily Traffic Volumes - Figure 5.2-6 – Proposed Circulation Plan
- Figure 5.2-7 – 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
I D I D I ~ ID
2509
Public Storage Moreno Valley Page 75 City of Moreno Valley XVIII. TRIBAL CULTURAL RESOURCES – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code Section 5020.1(k), or
ii) A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resources
Code section 5024.1, the lead agency shall
consider the significance of the resource to a
California Native American tribe.

Response:

Less Than Significant Impact with Mitigation Incorporated. Effective July 1, 2015, Assembly Bill (AB) 52 requires meaningful consultation with California Native American Tribes on potential impacts to Tribal Cultural Resources, as defined in Public Resources Code (PRC) Section 21074 as 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 of Historical Resources or included in a local register of historical resource. Per PRC Section 21080.3.1, a tribe must submit a written request to the relevant lead agency if it wishes to be notified of proposed projects in its traditionally and culturally affiliated area. The lead agency must provide written formal notification to the tribes that have requested it within 14 days of determining that a project application is complete or of deciding to undertake a project.

The tribe must respond to the lead agency within 30 days of receipt of the notification if it wishes to engage in consultation on the project, and the lead agency must begin the consultation process within 30 days of receiving the request for consultation. Consultation concludes when either (1) the parties agree to mitigation measures to avoid a significant effect, if one exists, on a tribal cultural resource, or (2) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. AB 52 also addresses confidentiality during tribal consultation per PRC Section 21082.3(c).

In compliance with AB 52, letters were distributed to local Native American tribes that are traditionally and culturally affiliated with the geographic area of the proposed project and have previously requested to be notified of future projects proposed by the City. The letters, which were sent on March 27, 2025 via certified mail, provided each tribe with an opportunity to request consultation with the City regarding the proposed project. The purpose of this effort was to provide Native American tribes with the opportunity for meaningful participation and to identify known tribal cultural resources on or near the project limits.

In compliance with AB 52, tribes had 30 days from the date of receipt of notification to request consultation on the proposed project. Information provided through the AB 52 tribal consultation process typically informs the assessment as to whether tribal cultural resources are present within the project limits and the significance of any potential impacts to such resources. As a result of the City’s AB 52 notification process, representatives with the Agua Caliente, Pechanga, and Rincon tribes responded with the request to incorporate selected mitigation measures associated with Tribal Cultural Resources as part of this Draft IS/MND. These measures have been added as Regulatory Compliance Measure (RCM) CUL-1, identified in Section V, which sets forth procedures for handling inadvertent discoveries of human remains, including those determined to be Native American. Additional measures that also detail the inclusion of a Native American tribal monitor to be present during project construction activities and developing a Cultural Resources Monitoring Plan (CRMP) have been included as mitigation measures TCR-1 through TCR-9.
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Public Storage Moreno Valley Page 76 City of Moreno Valley However, as discussed above in Section V, Cultural Resources, of this Draft IS/MND, no known cultural resources have been documented within the project limits or in the direct vicinity of the project limits based on archival research and field surveys. In addition, low potential exists for the proposed project to impact tribal cultural resources due to significant prior disturbance from past grading and development activities on the project limits and in the surrounding area. Regulatory Compliance Measure (RCM) CUL1 and RCM CUL-2, identified in Section V, sets forth procedures for handling inadvertent discoveries of human remains, including those determined to be Native American. Therefore, with the incorporation of RCM CUL-1 and CUL-2 and MMs TCR-1 through TCR-9 impacts to tribal cultural resources would be less than significant.

Mitigation Measure 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 the project site. 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 Pechanga Tribe including the contractor, and the City, shall develop a CRMP as defined in TCR-3, below. 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.

Mitigation Measure TCR-2 Native American Monitoring. Prior to the issuance of a grading permit, the Developer shall secure agreements with the Pechanga Tribe 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.

Mitigation Measure TCR-3 Cultural Resource Monitoring Plan (CRMP). The Project Archaeologist, in consultation with the Pechanga Tribe, 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:
• Project description and location;
• Project grading and development scheduling;
• Roles and responsibilities of individuals on the Project; • The pre-grading meeting and Cultural Resources Worker Sensitivity Training details;
• The protocols and stipulations that the contractor, City, Pechanga Tribe, and Project archaeologist will follow in the event of 2511
Public Storage Moreno Valley Page 77 City of Moreno Valley inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits that shall be subject to a cultural resources evaluation;
• The type of recordation needed for inadvertent finds and the stipulations of recordation of sacred items;
• Contact information of relevant individuals for the Project.

Mitigation Measure 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:
• 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:
o 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.
o 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 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 CR 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 Consulting Native American Tribal Governments prior to certification of the environmental document.

Mitigation Measure TCR-5 Potential Discovery of Archaeological and Cultural Resources. 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." Mitigation Measure TCR-6 Inadvertent Finds. If potential historic or cultural resources are uncovered during excavation or construction activities at the project site 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 2512
Public Storage Moreno Valley Page 78 City of Moreno Valley implemented as deemed appropriate by the Community Development Director, 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(s), and shall be submitted to the City for their review and approval prior to implementation of the said plan. Pursuant to Calif. Pub. Res. Code § 21083.2(b) avoidance is the preferred method of preservation for archaeological resources and cultural resources.

Mitigation Measure 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 Pechanga Tribe.

Mitigation Measure 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).

Mitigation Measure 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 the Pechanga Tribe’s Cultural Resources Department.

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 5.10-1 – Locations of Listed Historic Resource Inventory Structures 2513
Public Storage Moreno Valley Page 79 City of Moreno Valley - Figure 5.10-2 – Location of Prehistoric Sites
- Figure 5.10-3 – 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.) XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 Impact. The proposed project would interconnect to existing sewer, water, electric, and telecommunication utilities within the Indian Street right-of-way. All proposed improvements and interconnection to existing utilities would be installed simultaneously with other construction activities.

Water. The City is served by two water purveyors: Eastern Municipal Water District (EMWD) and the Box Springs Mutual Water Company.101 However, EMWD supplies water to the majority of the City, including the project site. EMWD has a diverse portfolio of water supplies, including imported water from the Metropolitan Water District of Southern California (MWD), local groundwater, desalinated groundwater, and recycled water.102 The EMWD’s main source of water supply is imported water from the MWD. According to the 2020 Urban Water Management Plan, most of the EMWD’s water is imported water from the MWD, which is expected to meet the demands of all member agencies through 2045.103 The MWD determined that its water resources will continue to provide a reliable supply to its member agencies from 2020 to 2045 during normal, single-dry, and multiple-dry years.104 Therefore, development in the City is adequately served by existing EMWD infrastructure, and the proposed project would not require or result in the construction of new water facilities, or the expansion of existing facilities, which could cause a significant environmental impact, and the impact would be less than significant. No mitigation is required.

Wastewater. Wastewater services in the City are provided by the EMWD and the Edgemont Community Services District. EMWD provides service to most of the City, to approximately 268,000 customers and treats approximately 49 million gallons per day at its four active regional water reclamation facilities.

These reclamation plants include the San Jacinto Regional Water Reclamation Facility, the Moreno Valley Regional Water Reclamation Facility, the Perris Valley Regional Water Reclamation Facility, the Sun City Regional Water Reclamation Facility, and the Temecula Valley Regional Water Reclamation Facility. Generated wastewater from the project site would be treated at the Moreno Valley Regional Water Reclamation Facility (MVRWRF). Typical daily flows at the MVRWRF are 11.5 million gallons per day, with a current capacity of 16 million gallons per day, and an ultimate capacity of 18 million gallons per day.105 The proposed project’s incremental contribution to water and wastewater treatment demand 101 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Section 5.13 Public Services and Utilities. July. 102 Eastern Municipal Water District (EMWD). 2021a. 2020 Urban Water Management Plan. Page 3-3. Website: https://www. emwd.org/what-we-do/water-supply/urban-water-management-plan (accessed December 30, 2024). 103 Ibid. Section 6 Water Supply Characterization. 6.2.1 Purchased or Imported Water. 104 Ibid. Page 7-2.
105 Eastern Municipal Water District (EMWD). 2021b. Wastewater Service. Moreno Valley Regional Water Reclamation Facility. □ □ ~ □
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Public Storage Moreno Valley Page 80 City of Moreno Valley would not in and of itself exceed the existing or planned capacity of the MVRWRF or require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Impacts would be less than significant, and no mitigation is required.

Stormwater Drainage. Regional flood control planning and facilities are under the jurisdiction of the Riverside County Flood Control and Water Conservation District (RCFCWCD).106 The RCFCWCD has prepared three Master Drainage Plans for three portions of the City: Sunnymead area, West End, and Moreno.107 Most of the City drains into the San Jacinto River; however, the northwest portion of the City drains to the west into a tributary of the Santa Ana River.108 The Sunnymead Storm drain, the Kitching Storm drain, and the Perris Valley Storm drain are the three major storm drains that serve the City. The proposed project is located within the Sunnymead Master Drainage Plan area. Development of the proposed project (buildings and pavement) would alter the amount of existing impervious surface area and the amount of generated runoff.

The proposed project would result in an increase in impervious surface area on site. However, as discussed in Section X, Hydrology and Water Quality, the proposed project would comply with the Construction General Permit, which regulates stormwater discharges from construction sites which result in disturbance of at least 1 acre of soil, and the Riverside County MS4 Permit, which regulates urban stormwater runoff, surface runoff, and drainage that flow into the MS4 system. Additionally, the project would comply with City Municipal Code Section 8.21.160, Erosion Control Plan, and City Municipal Code Section 8.10, Stormwater/Urban Runoff Management and Discharge Controls. The project would be required to prepare a SWPPP, Final WQMP, and Erosion Control Plan in compliance with the Construction General Permit, Riverside County MS4, and City Municipal Code, would reduce any impacts to stormwater and drainage facilities to less than significant. No mitigation is required.

Electric Power. Southern California Edison (SCE) and Moreno Valley Electric Utility (MVU) provide electrical power to the City. The project site is within the service area of MVU.109 According to the MVU, the total amount of electricity sales in Fiscal Year 2019/2020 was 201,765,902 kilowatt-hours (kWh), or 201.765902 gigawatt-hours (GWh).110 According to the California Energy Commission (CEC), total electricity consumption for Riverside County in 2019 was 15,763 GWh.111 Short-term construction activities would be limited to providing power to the staging area and portable construction equipment and would not substantially increase demand for electricity. Given the limited nature of potential demand for electricity during construction and the availability of existing power lines near the project site, there would not be a need to construct new or alter existing electric transmission facilities. Impacts to local regional supplies of electricity would be less than significant, and no mitigation is required.

The project site is currently undeveloped. The proposed project would interconnect to existing electricity infrastructure. Operation of the proposed project would increase on-site electricity demand. California Emissions Estimator Model (CalEEMod) Version 2022.1 was used to calculate the approximate annual electricity demand of the proposed project. The proposed project would be required to adhere to all federal, State, and local requirements for energy efficiency, which would substantially reduce energy usage. As shown in Section VI, Energy, the estimated increase in electricity demand associated with the operation of the proposed project would be 629,861 kWh per year. Total electricity consumption in Riverside County in 2022 was 17,780,573,271 kWh;112 therefore, operation of the proposed project would negligibly increase the annual electricity consumption in Riverside County by approximately 0.00004 percent. Electricity service providers use projected demand forecasts in order to provide an adequate supply or plan for surplus in their service areas. Because the proposed project would only represent a small fraction of electricity demand in Riverside County, would meet Title 24 requirements, and sufficient Website: https://www.emwd.org/what-we-do/wastewater-service (accessed December 18, 2024). 106 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Section 5.13 Public Services and Utilities. July. 107 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Section 5.7 Hydrology/Water Quality. July. 108 Ibid.
109 City of Moreno Valley. 2021. Moreno Valley Public Works Department. MVU Service Area Map. Website: https://moval.gov/ mvu/index.html (accessed December 27, 2024).
110 City of Moreno Valley Public Works Department. 2020. Moreno Valley Electric Utility Annual Report 2019-2020. Website:
https://moval.gov/mvu/pubs/MVU-2020-AnnualReport/index.html (accessed December 27, 2024). 111 California Energy Commission (CEC). 2019. Electricity Consumption by County. Website: https://ecdms.energy.ca.gov/elec bycounty.aspx (accessed December 27, 2024).
112 California Energy Commission (CEC). 2022. Electricity Consumption by County. Website: http://www.ecdms.energy.ca.gov/ (accessed January 2025).
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Public Storage Moreno Valley Page 81 City of Moreno Valley electricity supplies would be available; energy demands for the proposed project would be less than significant. No mitigation would be required.

Natural Gas. Natural gas is provided to the City by the Southern California Gas Company (SoCal Gas).113 The proposed project would not use natural gas for construction or operation. Therefore, construction activities would not impact natural gas services, and the proposed project would not require new or physically altered gas transmission facilities. The project would not require or result in the relocation or construction of new or expanded gas facilities, the construction of which could cause significant environmental effects. There would be no impact, and no mitigation would be required.

Telecommunications Facilities. Cable, internet, and telephone services are provided to the City’s residents by major third-party purveyors. Cellular services provided by all major cellular networks are available in the City. Construction activities associated with the proposed project would not increase the demand for telecommunications facilities. Telecommunication infrastructure would be extended to the proposed project; however, no off-site telecommunication infrastructure would be required. Therefore, implementation of the proposed project would result in no impact related to the construction or relocation of existing telecommunications facilities, and no mitigation would be required. 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. As discussed in Response XIX(a), implementation of the proposed project would not substantially increase the demand for water supplies on the project site. Short-term demand for water may occur during construction activities on site. Water from existing potable water lines in the vicinity of the project site would be used. Overall, short-term construction activities would require minimal water and are not expected to have any adverse impacts on the existing water system or available water supplies. The proposed project would not require the construction of new or expanded water conveyance, treatment, or collection facilities with respect to construction activities.

Water demand associated with the operation of the proposed project would be similar to other developments in the area that are a similar use. The project-generated increase in water demand would be negligible and would fall within the City’s existing capacity and available supply. As such, the proposed project would not necessitate new or expanded water entitlements, and the City would be able to accommodate the increased demand for potable water.

The project would be served by EMWD through interconnection to existing water utilities. The proposed project would not require or result in the construction of new or expanded water entitlements, and the City would be able to accommodate the incrementally increased demand for potable water. Therefore, water demand from the proposed project would have sufficient water supplies available to serve the project from existing entitlements and resources and would not require new or expanded entitlements.

Therefore, impacts related to water supplies would be less than significant, and no mitigation would be required.
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 discussed in Response XIX(a), implementation of the proposed project would not result in a substantial increase in demand for wastewater services on the project site. Impacts related to wastewater are considered less than significant, and mitigation is not required. 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:
113 City of Moreno Valley. 2006. Moreno Valley General Plan Final Program EIR. Section 5.13 Public Services and Utilities. July. □ □ ~ □
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Public Storage Moreno Valley Page 82 City of Moreno Valley Less Than Significant Impact. The City provides trash, recycling, and special waste handling services to residents and businesses through a contract with Waste Management. Solid waste generated within the proposed project would be disposed of at the Riverside County Waste Management Department’s Badlands Sanitary Landfill located at 31125 Ironwood Avenue approximately 6 miles northeast of the project site. The Badlands Sanitary Landfill has a maximum daily permitted throughput of 5,000 tons per day, remaining capacity of 7,800,000 cubic yards, and an anticipated closure date of 2059. 114 The
proposed project would generate approximately 124 tons of solid waste per year, or 0.34 tons per day, which is 0.00007 percent of the current daily permitted throughput at the Badlands Sanitary Landfill.

Therefore, the Badlands Sanitary Landfill would have adequate capacity to serve the proposed project.

Additionally, the project proposes a self-storage use that would not generate volumes or types of waste not already considered under the City’s General Plan and zoning for the project site, and as addressed under existing policies and regulations. Impacts to solid waste disposal would be less than significant, and mitigation is not required.
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
Response:

No Impact. The proposed project would be required to comply with applicable statutes and regulations, including waste diversion programs mandated by City, State, or federal law. California Department of Resources Recycling and Recovery (CalRecycle) regulations require that construction contractors recycle/reuse at least 65 percent of construction materials, and use “Green Building Materials” for at least 10 percent of the project.115 City Municipal Code Section 8.80.040 (On-Site practices) establishes protocols that construction contractors must follow to ensure construction materials are properly diverted from the waste stream and quantified. Pursuant to Assembly Bill 341, all commercial accounts with the City’s solid waste provider must implement a recycling program if it would generate at least 4 cubic yards of solid waste per week. Compliance with regulations related to solid waste disposal and diversion is required for all projects within the City. Therefore, the project would not conflict with statutes and regulations related to solid waste. No impact related to this issue would occur, and no mitigation is required.

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 7-1 – 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 5.7-1 – Strom Water Flows and Major Drainage Facilities - Figure 5.7-2 – Groundwater Basins
• Section 5.13 – Public Services
- Figure 5.13-1 – 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
114 California Department of Resources Recycling and Recovery (CalRecycle). n.d.-a. Facility/Site Summary Details: Badlands Sanitary Landfill. Website: https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2245?siteID=2367 (accessed December 19, 2024).
115
California Department of Resources Recycling and Recovery (CalRecycle). n.d.-b. Construction and Landscaping. Overview of Requirements. SB 1383 & CALGreen. Website: https://calrecycle.ca.gov/organics/slcp/jurisdictions/calgreenmwelo/#:~:text= Construction%20Waste%20Diversion&text=The%20SB%201383%20regulations%20require,building%20projects%20in%20the %20state (accessed December 19, 2024).
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Public Storage Moreno Valley Page 83 City of Moreno Valley XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
Response:

Less Than Significant Impact. The project site is not located within any State Responsibility Area (SRA) for fire service and is not within or near a Very High Fire Hazard Severity Zone (VHFHSZ).116 In addition, as noted in Checklist Response IX(f), the proposed project would not impair an adopted emergency response plan or emergency evacuation plan.

During temporary construction activities, all construction equipment and parking would be staged within the project site. Although, it is possible there would be temporary lane closures along Indian Street during project construction, the proposed project would not permanently obstruct any transportation routes that could be used as evacuation routes during emergency events. Adequate emergency access would be provided to and from the project site. Additionally, emergency access would be subject to review by the Moreno Valley Fire Department and Police Department for compliance with fire and emergency access requirements. Therefore, potential impacts related to emergency response and evacuation plans during operation would be less than significant. No mitigation is required. 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 in Checklist Response XX(a), the project site is not within or near a VHFHSZ.117 Additionally, the project site is generally flat and is bound by existing developments in an urban area.

Therefore, the proposed project would not exacerbate wildfire risks or expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. No impact would occur, and no mitigation is required.
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. The proposed project is not located in or near a VHFHSZ within an SRA or LRA.118 The proposed project is surrounded by urban uses and would not require the installation or maintenance of associated infrastructure. No impact would occur, and no mitigation is required. 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. The proposed project is not located in or near a VHFHSZ within an SRA or LRA.119 The topography of the project site and surrounding area is relatively flat. Therefore, the proposed project would not expose people or structures to significant risks, including downslope or downstream flooding 116 California Department of Forestry and Fire Protection (CAL FIRE). 2024. Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/ (accessed December 18, 2024). 117 Ibid.
118 California Department of Forestry and Fire Protection (CAL FIRE). 2024. Fire Hazard Severity Zone Viewer. Website:
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/ (accessed December 18, 2024). 119 Ibid.
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2518
Public Storage Moreno Valley Page 84 City of Moreno Valley or landslides, as a result of runoff, post-fire slope instability, or drainage changes. No impact would occur, and no mitigation is required.

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 5.5-2 – 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 5-2 – Moreno Valley High Fire Area Map 2016
• Chapter 8 – Landslide
- Figure 8-1 – 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
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
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 project site was previously used for agriculture from 1938 to 1997 and has been historically plowed or disked for weed abatement compliance. Currently, the project site is vacant and contains ruderal vegetation.

Compliance with the NPDES and Riverside County MS4 Permit ensures the State’s mandatory standards for the maintenance of clean water and the federal minimums are met. Compliance with the provisions of the NPDES permit and implementation of the LID BMPs specified in the WQMP are regulatory requirements that apply to all development projects. These requirements were previously detailed in Section X, Hydrology and Water Quality. A Final WQMP and SWPPP will be approved as a routine action during the processing of the project by the City; therefore, the required measures and features detailed in the WQMP and SWPPP to safeguard water quality would be incorporated into the project. Additionally, the project would comply with City Municipal Code Section 8.21.160, Erosion Control Plan, and City Municipal Code Section 8.10, Stormwater/Urban Runoff Management and Discharge Controls, in order to control runoff and erosion and incorporate BMPs to capture, treat, and reduce pollutants of concern in stormwater runoff. Compliance with the requirements included in the NPDES permit, Riverside County MS4 Permit, and City Municipal Code would ensure impacts to water quality remain less than significant.
□ ~ □ □
2519
Public Storage Moreno Valley Page 85 City of Moreno Valley No riparian or sensitive natural community is located on site, and there is no designated critical habitat within or adjacent to the project site for any species (Appendix C). The project site does not include any federally protected wetlands or any drainage features, ponded areas, wetlands, or riparian habitat subject to jurisdiction by the CDFW, USACE, and/or RWQCB. The Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Consistency Analysis and Biology Report (Appendix C) included a literature search and pedestrian survey of the site and indicates the site does not contain suitable habitat for any threatened or endangered species. Additionally, no species identified in MSHCP Table 9-3 have more than a low potential of being present on the project site due to disturbance. The project site is located within the Stephens’ Kangaroo Rat Habitat Conservation Plan area, and a fee payment will be required prior to issuance of a grading permit. The project will comply with the Habitat Conservation Plan for the Stephens’ Kangaroo Rat in Western Riverside County (Riverside County Habitat Conservation Agency, February 1995) and fulfill its compensatory mitigation requirements under this plan through the payment of a fee.
120
.

Trees, shrubs, and other vegetation on the project site provide suitable nesting habitat for common bird species, so the project would be required to implement Mitigation Measure BIO-1 to ensure a qualified biologist conducts a pre-construction survey for nesting birds if construction activities occur during nesting bird season. During the biological survey of the project site, several ornamental trees were found on site. The ornamental trees will be managed in accordance with Part E and Part G of 9.17.030 (Landscape and Irrigation Design Standards) of the City Municipal Code. Prior to the issuance of grading permits, the project Applicant/Developer must submit detailed grading plans prepared in conformance with applicable standards of the City’s Landscape and Irrigation Design Standards. The City, at final plan check, would ensure that all improvements associated with the project are consistent with these City standards and requirements. Compliance with these standards is required of all projects in the City as a matter of regulatory policy (i.e., City Municipal Code) and therefore would not constitute mitigation in order to remove the trees. With implementation of Mitigation Measure BIO-1, impacts to native resident or migratory fish or wildlife species, established native resident or migratory wildlife corridors, and native wildlife nursery sites would be reduced to less than significant with mitigation incorporated.

The project-specific Cultural Resources Assessment (Appendix D) identified two historic period resources (33-028200, a canal; and 33-28824, a minimal archaeological site) and a Native American Traditional Cultural Property (TCP) (33-029890, Pechanga Sycamore Hills TCP) are within 1 mile of the project site. No cultural resources were previously documented within or near the project site, no cultural resources were identified during the survey, and the project site has sustained severe disturbance.

Additionally, no archeological resources were identified. However, construction of the project would include excavation to depths of at least 5 feet below the proposed grade or 3 feet below bottom of foundations and floor slab, whichever is deeper. In the unlikely event that any previously unidentified archaeological resources are discovered during ground-disturbing activities, work in the area would be required to cease, and deposits would be treated in accordance with federal, State, and local guidelines, including those set forth in PRC Section 21083.2 as specified in Standard Condition CUL-1.

Additionally, due to the project’s proximity to a TCP, the project would implement Mitigation Measure CUL-1 and Mitigation Measure CUL-2, which require implementation of a Worker’s Environmental Awareness Program (WEAP) training and archeological monitoring during construction. Further, in the unlikely event that any previously unidentified human remains are discovered during ground-disturbing activities, the project would implement the requirements as specified in Standard Condition CUL-2 to protect human remains. With implementation of mitigation, impacts related to historical and archaeological resources would be less than significant with mitigation incorporated.

As a result of the City’s AB 52 notification process, representatives with the Agua Caliente, Pechanga, and Rincon tribes responded with the request to incorporate selected mitigation measures associated with Tribal Cultural Resources as part of this Draft IS/MND. Regulatory Compliance Measure (RCM) CUL-1 and RCM CUL-2, identified in Section V, which sets forth procedures for handling inadvertent discoveries of human remains, including those determined to be Native American. Additional measures that also detail the inclusion of a Native American tribal monitor to be present during project construction activities and developing a Cultural Resources Monitoring Plan (CRMP) have been included as mitigation measures TCR-1 through TCR-9 based on the input provided by the Pechanga Tribe. Therefore, with the incorporation of RCM CUL-1 and CUL-2 and MMs TCR-1 through TCR-9, impacts to tribal cultural resources would be less than significant.

As discussed in Checklist Response III(c), the proposed project would exceed SCAQMD cancer risk thresholds during construction and would result in a potentially significant impact on sensitive receptors.

However, the proposed project would implement Mitigation Measure AIR-1, which requires the use of cleaner construction equipment to reduce substantial pollutant concentrations during construction. With 2520
Public Storage Moreno Valley Page 86 City of Moreno Valley implementation of Mitigation Measure AIR-1, the proposed project would have a less than significant impact related to substantial pollutant concentrations. Accordingly, impacts would be reduced to less than significant with mitigation incorporated.

The proposed project has either no impact, a less than significant impact, or a less than significant impact with implementation of mitigation with respect to all natural resources issues pursuant to CEQA. Due to the limited scope of physical impacts to the environment associated with the proposed project, implementation of the Standard Conditions and Mitigation Measures described above would ensure impacts to the quality of the environment would be reduced to less than significant with mitigation incorporated.
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. In evaluating the cumulative effects of the project, Section 21100(e) of the State CEQA Guidelines states that “previously approved land use documents including, but not limited to, general plans, specific plans, and local coastal plans, may be used in cumulative impact analysis.” The proposed project includes up to two employees per shift to operate the facility.121 The proposed project would be consistent with the current land use designation in the City’s General Plan and would not substantially alter the housing and employment forecast in the City.

As discussed in Checklist Response III(b), construction and operation of the project would not generate criteria pollutants in excess of South Coast Air Quality Management District (SCAQMD) emissions thresholds. Therefore, the project would not contribute significantly to cumulative impacts for any air quality pollutants for which the region is in nonattainment. As for cumulative impacts to regional air quality, the discussion in Checklist Response III(a) indicates the proposed project would neither conflict with the SCAQMD’s Air Quality Management Plan (AQMP) nor jeopardize the region’s attainment of air quality standards. The SCAQMD uses the project-level significance thresholds to determine whether a project’s emissions are cumulatively considerable. Because the project’s emissions do not exceed the SCAQMD’s regional significance thresholds, as detailed in Checklist Response III(b), the SCAQMD does not consider the project to contribute significantly to a cumulative air quality impact.

Because the proposed project would generate less than 400 daily trips, it is exempt from a vehicle miles traveled (VMT) analysis and presumed to have a less than significant transportation impact pursuant to the City’s Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment.
122
As detailed in Checklist Response XIII(a), the project-related traffic noise increase on adjacent roadways would be less than 0.1 A-weighted decibels (dBA). Noise level increases less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, traffic noise impacts from cumulative project-related traffic on off-site sensitive receptors would be less than significant. The closest structures to the project site, which are associated with the storage uses to the north are approximately 5 feet from the project construction boundary and would experience vibration levels of up to 0.995 PPV (in/sec). This vibration level would exceed the 0.2 in/sec PPV threshold, which would result in a potentially significant impact. With implementation of Mitigation Measure NOI-1, which includes implementing vibration reduction measures during construction, construction would not result in any vibration damage, and impacts would be less than significant with mitigation incorporated. 120 Riverside County Habitat Conservation Agency (RCHCA). 1995. Stephens' Kangaroo Rat Mitigation Fee. Website:
https://www.rchca.us/185/Stephens-Kangaroo-Rat-Mitigation-Fee (accessed December 2024). 121 Assumes up to two shifts per day.
122 City of Moreno Valley. 2020. Transportation Impact Analysis Preparation Guide for Vehicle Miles Traveled and Level of Service Assessment. Website: https://www.moval.org/departments/public-works/transportation/TIA-Guidelines.pdf (accessed December 16, 2024).
□ ~ □ □
2521
Public Storage Moreno Valley Page 87 City of Moreno Valley The project has no impact, a less than significant impact, or a less than significant impact with implementation of mitigation with respect to all environmental issues. Therefore, a less than significant cumulative impact with mitigation incorporated would occur. 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. All development associated with the project must comply with applicable provisions of the California Building Code (CBC) and the City’s building regulations. Accordingly, proper engineering design and construction in conformance with the CBC standards and project-specific geotechnical recommendations would ensure that the project does not subject people to significant geologic hazards.

The transport, use, and storage of hazardous materials during the construction and operation of the site would be conducted pursuant to all applicable local, State and federal laws, and in cooperation with the Riverside County Fire Department, the Riverside County Department of Environmental Health, Hazardous Materials Division, the Environmental Protection and Oversight Division, and the California Occupational Safety and Health Administration. Through compliance with all applicable federal, State, and local laws, impacts to the public or environment from hazardous materials would be less than significant.

The project is required to comply with SCAQMD Rule 402, 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.” SCAQMD published its Final Localized Significance Threshold Methodology in June 2003 and updated it in July 2008, recommending that all air quality analyses include an assessment of both construction and operational impacts on the air quality of nearby sensitive receptors. Localized significance thresholds (LSTs) represent the maximum emissions from a project site of up to 5 acres that are not expected to result in an exceedance of the National Ambient Air Quality Standards or California Ambient Air Quality Standards for CO, NO2, PM10 and PM2.5. LSTs are based on the ambient concentrations of that pollutant within the project Source Receptor Area (SRA) and the distance to the nearest sensitive receptor. For this project, the appropriate SRA is the Moreno Valley Area (SRA 24) according to the project air quality analysis included in Appendix A. As detailed in Tables C and D, construction and operation of the proposed project would not expose nearby sensitive receptors to substantial pollutant concentrations. However, as detailed in the HRA prepared for the project (Appendix B), the project would exceed the SCAQMD cancer risk threshold for the residential MEI. Therefore, the project would implement Mitigation Measure AIR-1, which requires the use of cleaner construction equipment to reduce substantial pollutant concentrations during construction. Implementation of Mitigation Measure AIR-1 would ensure impacts would be below thresholds. Accordingly, impacts would be reduced to less than significant with mitigation incorporated.

As detailed in Checklist Responses XIII(a) and XIII(b), construction and operation of the project would not generate a substantial temporary or permanent increase in ambient noise levels or generate vibration in the vicinity of the project in excess of standards established in the local general plan or noise ordinance with implementation of Mitigation Measure NOI-1.

Through compliance with existing regulations and policy, as well as Mitigation Measure NOI-1 and Mitigation Measure AIR-1, substantial direct or indirect effects on human beings would be reduced to less than significant with mitigation incorporated.
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2522
Public Storage Moreno Valley Page 88 City of Moreno Valley

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