Norco City Council
September 16, 2026

JACOB PULIDO |GIS TECHNICIAN

CORE TECHNICAL TOOLS
¡ ArcGIS Pro, ArcMap, ArcGIS
Online, ArcGIS Story Maps
¡ Python API, Tableau, ENVI, CAD,
Microsoft Office, Google Suite

CORE MUNICIPAL

STRENGTHS
¡ GIS Platforms: ArcGIS Pro,
ArcMap, ArcGIS Online, ArcGIS
Story Maps
¡ Technical Tools: Python API,
Tableau, ENVI, CAD, Microsoft
Office, Google Suite
¡ Geospatial Analysis: Spatial
analysis, geoprocessing, remote
sensing, metadata creation
¡ Data Management: Data
cleaning, map production,
topological corrections

OVERVIEW & PROFESSIONAL CREDENTIALS
As a GIS Technician, Jacob supports municipal clients with geospatial data maintenance, map production, QA/QC, and ArcGIS system support. His background includes municipal planning, consulting, and applied geospatial analysis for public-sector workflows.

Jacob's technical background includes ArcGIS Pro, ArcGIS Online, Python API, Tableau, ENVI, CAD, geocoding, spatial analysis, metadata creation, and GIS data validation.

VALUE TO THE CITY OF NORCO
Jacob will strengthen Norco's day-to-day GIS operations by supporting accurate data maintenance, map updates, QA/QC, and production support for infrastructure and departmental datasets.

His experience with ArcGIS Pro, ArcGIS Online, geocoding, spatial analysis, metadata, and topological corrections aligns with Norco's need for reliable map layer updates, asset data maintenance, and support for public works and planning workflows.

MUNICIPAL PROJECT EXPERIENCE
GIS Technician | January 2025 – Present
Infinity Technologies – Lake Forest, CA
¡ Supports GIS data maintenance, map production, and publishing for municipal clients, including public works, public safety, and infrastructure datasets.
¡ Assists with ArcGIS Enterprise and ArcGIS Online configuration, map service updates, and staging/production workflows.
¡ Performs QA/QC on spatial datasets, validates attributes and topology, and supports consistent metadata across environments.

Planning/GIS Technician | 2023 – 2025
MGT Consulting Group – CA
¡ Performed geocoding of student and assessor records and created maps and spatial visualizations for client presentations. ¡ Managed spatial datasets, validated data accuracy, and corrected topological issues.
¡ Participated in collaborative planning sessions with clients and advisory committees.

INFINITY TECHNOLOGIES | CITY OF NORCO B-1
APPENDIX B – REPRESENTATIVE EXPERIENCE
The following representative projects demonstrate Infinity Technologies' experience delivering municipal GIS services directly aligned with the City of Norco's requirements. Collectively, they highlight our expertise in enterprise GIS administration, GIS application development, ArcGIS Enterprise and ArcGIS Online administration, utility infrastructure management, systems integration, workflow automation, quality assurance, and long-term GIS program support.

Collectively these projects demonstrate Infinity's ability to provide both day-to-day GIS operations and long-term Enterprise GIS planning, modernization, and strategic advisory services.

B-1 City of Norco | Enterprise GIS and Utility Network Support (Current Services)
Project Summary
Infinity Technologies currently provides ongoing GIS support services for the City of Norco, including ArcGIS Enterprise administration, enterprise GIS data management, application support, and implementation of Esri Utility Network capabilities. As part of the City's GIS modernization program, Infinity is supporting Utility Network design, data migration, enterprise deployment, systems integration, testing, training, and operational readiness to enhance utility asset management and enterprise GIS operations.

Representative Services Provided
 ArcGIS Enterprise administration and enterprise GIS support  Utility Network design, configuration, and implementation  GIS and CAD data migration, transformation, and QA/QC  Network topology, tracing, and validation
 Enterprise deployment, systems integration, and ArcGIS Field Maps  Technical QA/QC including peer review, topology validation, attribute verification, application testing, and production readiness review.
 Staff training, dashboards, operational testing, and go-live support Project Relevance to the City of Norco
As the City's current GIS services provider, Infinity has developed extensive knowledge of Norco's GIS environment, enterprise geodatabase, utility infrastructure, and departmental workflows. This ongoing engagement demonstrates our ability to deliver advanced GIS solutions while maintaining continuity of service, minimizing implementation risk, and supporting the City's long-term GIS modernization objectives.

INFINITY TECHNOLOGIES | CITY OF NORCO B-2
B-2 City of Laguna Niguel | Property Information and Planning GIS Application
Project Summary
Infinity partnered with City staff to develop a centralized GIS application providing public access to parcel, zoning, planning, and property information through address- and parcel-based searches. The application serves as a single point of access for property information, improving customer service while reducing routine inquiries to the Planning Department.

Representative Services Provided
 ArcGIS web application design and deployment
 ArcGIS Online administration
 GIS data integration and management
 Public-facing web mapping applications
 Ongoing application support and enhancements
Project Relevance to the City of Norco
This project demonstrates experience developing and supporting GIS applications that improve access to information, streamline business processes, and provide centralized GIS resources for City staff and the public. These capabilities align closely with Norco's requirements for application development, ArcGIS Enterprise and ArcGIS Online administration, and ongoing application support.

Figure B-2 Property Information Web Application

INFINITY TECHNOLOGIES | CITY OF NORCO B-3
B-3 City of Thousand Oaks | Enterprise GIS Data Maintenance and Parcel Integration
Project Summary
Infinity implemented automated parcel maintenance workflows to improve the efficiency, accuracy, and consistency of enterprise GIS data management. Automated acquisition, validation, and synchronization processes reduced manual effort while maintaining authoritative parcel information across the City's GIS environment and integrated business systems.

Representative Services Provided
 Enterprise GIS data management
 Automated GIS update workflows
 Database integration and synchronization
 Data validation and QA/QC
 ArcGIS Enterprise administration
Project Relevance to the City of Norco
This project demonstrates experience maintaining enterprise geodatabases, integrating external data sources, implementing repeatable QA/QC procedures, and supporting authoritative GIS datasets. These services directly support Norco's requirements for GIS data maintenance, county data updates, master address management, enterprise database administration, and business system integration.

Figure B-3 Parcel Data Automation Workflow

INFINITY TECHNOLOGIES | CITY OF NORCO B-4
B-4 City of Napa | Water Utility Network Modernization
Project Summary
Infinity provided professional GIS services supporting the modernization of the City's water utility GIS environment through planning and implementation of Esri Utility Network capabilities. Services included utility data assessment, network modeling, connectivity validation, subnetwork configuration, and implementation planning to improve infrastructure management and operational decision-making.

Representative Services Provided
 Utility Network planning and implementation support
 Utility data assessment and migration planning
 Network connectivity and topology validation
 Utility asset modeling and QA/QC
 ArcGIS Pro and ArcGIS Enterprise support
 Infrastructure analysis and operational mapping
Project Relevance to the City of Norco
This project demonstrates Infinity's experience supporting municipal utility infrastructure modernization, Utility Network planning, connectivity analysis, and enterprise GIS implementation.

These capabilities complement the services currently provided to the City of Norco and further demonstrate our ability to support future utility GIS initiatives and enterprise modernization efforts.

Figure B-4 Utility Network Isolation Trace/Pressure Zone Example

INFINITY TECHNOLOGIES | CITY OF NORCO B-5
B-5 Representative GIS Modernization Services
Current Environment Strategic Recommendation
ArcGIS Enterprise Upgrade roadmap
Web AppBuilder Experience Builder migration
SQL Server Lifecycle planning
Enterprise GIS ArcGIS Online evaluation
Utility GIS Utility Network planning
CentralSquare Future ERP integration planning
GIS Data Governance improvements

INFINITY TECHNOLOGIES | CITY OF NORCO C-1
APPENDIX C – CLIENT REFERENCES
The following references represent municipal clients for whom Infinity Technologies has provided services comparable to those requested by the City of Norco, including Enterprise GIS administration, ArcGIS Server and ArcGIS Online support, GIS application development, utility infrastructure management, enterprise system integration, GIS data maintenance, field mobility solutions, and ongoing technical support.

AGENCY REFERENCE CONTACT RELEVANT SERVICES
City of
Lancaster
Joe Haggard
Assistant Director, Finance & IT
(661) 723-6060
[email protected]
ArcGIS Enterprise administration, GIS
application development, system
integrations, as-built and CAD-to-GIS
workflows, map production, GIS data
maintenance, training, and documentation.

City of
Napa
Scott Nielsen
IT Manager
(707) 257-9400
[email protected]
Utility GIS support, Enterprise GIS
administration, asset management
integration, operational mapping, field
mobility solutions, and GIS data
maintenance.

City of
Laguna
Niguel
Favian Bravo
Community Engagement Manager
(949) 362-4348
[email protected]
On-call GIS support, Enterprise GIS
administration, ArcGIS Online applications,
operational dashboards, field data
collection, emergency preparedness
mapping, and GIS data management.

Scope Alignment Summary
These references demonstrate Infinity's experience serving as a long-term municipal GIS partner providing Enterprise GIS administration, ArcGIS Online support, application development, enterprise integrations, Utility GIS, QA/QC, strategic planning, and continuous GIS modernization.

INFINITY TECHNOLOGIES | CITY OF NORCO D-1
APPENDIX D – CYBERSECURITY RESPONSE
Infinity Technologies provides managed IT and GIS services to cities, public agencies, and other public-sector organizations where protecting client systems and information is a fundamental operational requirement. Cybersecurity is integrated into our governance, service delivery, personnel practices, and technology environment to safeguard City information throughout the performance of the contract.

D.1 Cybersecurity Governance
Infinity maintains documented cybersecurity and risk governance policies that establish requirements for protecting information systems, client data, and personnel. These policies are reviewed periodically and updated to address evolving threats, regulatory requirements, and industry best practices.

A copy of Infinity's Cybersecurity and Information Security Policy is included at the end of this appendix.

D.2 Security Controls
Infinity employs layered administrative, technical, and physical safeguards to protect systems used to access and manage client information, including:
 Multi-factor authentication (MFA)
 Endpoint detection and response (EDR)
 Threat monitoring and malware protection
 Encryption of data in transit and at rest
 Secure remote access
 Role-based access control
 Least-privilege access management
 Activity logging and monitoring
 Routine security updates and patch management
These controls are designed to protect client systems while supporting secure project delivery.

D.3 Personnel Security
Access to client systems is granted only to authorized personnel based on business need and the principle of least privilege. User access is managed, monitored, and promptly revoked when no longer required.

Personnel receive ongoing security awareness training and are required to comply with Infinity's cybersecurity, confidentiality, and acceptable use policies.

INFINITY TECHNOLOGIES | CITY OF NORCO D-2
Personnel are screened in accordance with company hiring policies before being granted access to client systems.

D.4 Subconsultants
Infinity does not anticipate utilizing subcontractors to access or administer the City's GIS environment under this contract.

Should specialized subcontracting services become necessary, subcontractors will be subject to confidentiality obligations, cybersecurity requirements, and access controls equivalent to those applied to Infinity personnel.

All services will be performed within the United States unless otherwise authorized by the City.

D.5 Data Handling and Secure Data Transfer
City information will be accessed only through City-approved secure remote access methods. Data exchanged between Infinity and the City will utilize secure, encrypted transmission methods and will be handled in accordance with City requirements and Infinity's information security procedures.

City information will be retained only as necessary to perform authorized services, protected against unauthorized access, and returned or securely removed upon completion of the engagement in accordance with contractual and City requirements.

D.6 Remote Access
Infinity will utilize the City's secure remote access portal as the approved method for accessing City systems and will comply with all City authentication, access control, and remote access requirements. No alternative remote access methods will be implemented without the City's prior written authorization.

D.7 Cyber Liability Insurance
Infinity maintains Cyber Liability and Technology Errors & Omissions insurance appropriate for the professional services provided. Evidence of coverage will be furnished upon request or as required by the contract.

INFINITY TECHNOLOGIES | CYBERSECURITY AND INFORMATION SECURITY POLICY 1 Cybersecurity & Information Security Policy
Infinity Technologies

1. Purpose
This policy defines the security controls and operational practices used to protect systems, data, and client environments.

Infinity Technologies operates as an IT and GIS managed services and consulting provider. While it does not host or operate federal systems, it may access confidential, sensitive, or regulated client information during service delivery. Controls are designed to protect that information and the environments in which services are performed.

This policy focuses on preventive and protective controls. Incident response, business continuity, and recovery procedures are defined in the Cyber Resilience Plan.

2. Scope
This policy applies to:
• All employees and contractors
• Corporate systems and devices
• Cloud and SaaS platforms
• Managed client environments accessed by staff
• GIS systems and data platforms

3. Governance and Oversight
Security is managed through a defined governance structure.

Role Responsibility
Executive Sponsor Provides oversight and approves risk decisions Security Officer Manages security program and policy enforcement IT Leadership Implements controls and maintains systems Staff Comply with security requirements
Program Activities include:
• Annual risk assessment
• Maintained risk register
• Quarterly access reviews
• Annual policy review
• Periodic reporting to leadership

4. Access Control
Access to systems is controlled based on role and business need.

INFINITY TECHNOLOGIES | CYBERSECURITY AND INFORMATION SECURITY POLICY 2 Controls include:
• Role-based access control (RBAC)
• Unique user identification
• Least privilege enforcement
• Separation of administrative accounts where applicable • Access approval and periodic review
• Access removal within 24 hours of termination

5. Authentication and Identity Security
Authentication controls are enforced across all systems.

Requirements:
• Multi-factor authentication (MFA) for:
o Remote access
o Administrative systems
o Cloud platforms
• Strong password requirements
• Centralized identity management where feasible
• Monitoring of authentication activity

6. Endpoint and Administrative Security
Company-managed systems are secured to reduce risk of compromise.

Controls include:
• Endpoint Detection and Response (EDR)
• Full disk encryption on company devices
• Secure configuration baselines
• Controlled administrative access
• Logging of administrative actions

7. Network and Data Protection
Data is protected in transit and during access.

Controls include:
• Encrypted communications (TLS 1.2 or higher)
• Secure remote access via VPN or equivalent
• Use of secure file transfer methods
• Restriction on storing FCI on unauthorized systems

8. Logging and Monitoring
Security-relevant activity is logged and monitored

INFINITY TECHNOLOGIES | CYBERSECURITY AND INFORMATION SECURITY POLICY 3 Logging includes:
• Authentication and access events
• Administrative activity
• System changes and configuration updates
Logs are:
• Retained according to policy
• Reviewed based on system criticality
• Used for investigation and response

9. Vulnerability and Patch Management
Systems are maintained to reduce exposure to known vulnerabilities.

Control Area Requirement
Vulnerability scanning Performed regularly (at least monthly) Patch management Critical patches applied within defined timeframe Updates Automated where feasible
Remediation tracking Documented and monitored

10. Configuration Management
Systems are configured using defined standards.
• Baseline configurations are maintained
• Changes are documented and controlled
• Unauthorized configuration changes are not permitted

11. Managed Services (MSP) Controls
Additional controls apply due to the multi-client MSP environment.

Controls include:
• MFA enforced on all administrative platforms
• Restricted and logged access to RMM and PSA tools
• Segregation of client administrative credentials
• Monitoring of administrative activity
• Controlled use of automation and scripting
• Access to client systems limited to authorized activities

12. GIS and Data Security
GIS systems and data are managed based on sensitivity and use.

Controls include:
• Role-based access to GIS datasets

INFINITY TECHNOLOGIES | CYBERSECURITY AND INFORMATION SECURITY POLICY 4 • Protection of sensitive or restricted data
• Separation of public-facing and internal services where applicable • Regular validation of data integrity

13. Vendor and Third-Party Risk
Vendors are evaluated based on their impact on operations and security.

Vendor Type Review Approach
Critical SaaS / cloud Security review, certifications (e.g., SOC 2) Service providers Questionnaire and contractual controls All vendors Access limitations and MFA where applicable Vendor risks are reviewed periodically.

14. Incident Response (Reference)
Security incidents are handled according to defined procedures.

This includes:
• Identification and classification
• Containment and remediation
• Client notification where required
Detailed procedures are maintained in the Cyber Resilience Plan.

15. Contingency and Recovery (Reference)
Backup, recovery, and continuity processes are defined separately. • Data backups are maintained
• Recovery procedures are tested
• Service continuity is planned
See Cyber Resilience Plan.

16. Media Protection
Data storage and disposal are controlled.
• Sensitive data is not stored on unauthorized media
• Devices are securely decommissioned
• Media is sanitized using accepted methods

17. Personnel Security
• Access is based on role and need
• Access is removed promptly upon termination
• Staff are responsible for complying with security requirements

INFINITY TECHNOLOGIES | CYBERSECURITY AND INFORMATION SECURITY POLICY 5

18. Security Awareness and Training
• Staff receive periodic security training
• Topics include:
o phishing awareness
o credential protection
o acceptable use

19. Risk Management
• Risks are identified and documented
• Risk register is maintained
• Mitigation actions are tracked
• Risk posture is reviewed regularly

20. Compliance
This policy aligns with:
• NIST Cybersecurity Framework (CSF 2.0)
• NIST SP 800-53 control families
• FAR 52.204-21 safeguarding requirements
Controls are scaled based on contractual obligations and risk.

21. Enforcement and Review
• Violations may result in corrective action
• Policy is reviewed annually
• Updates are made based on changes in systems, risks, or requirements Policy Information
Policy Owner Security Officer
Approved By President
Effective Date March 25, 2026
Last Reviewed March 25, 2026
Review Frequency Annually
Version 1.0
This policy is provided in response to the City of Norco RFP. Certain operational and technical implementation details have been omitted for security purposes.

INFINITY TECHNOLOGIES | CITY OF NORCO E-1
APPENDIX E – CONFIDENTIALITY & NON-DISCLOSURE

AGREEMENT
This appendix contains the executed Confidentiality & Non-Disclosure Agreement required by the RFP. Infinity Technologies acknowledges its obligation to protect confidential, sensitive, and proprietary information and to comply with all applicable confidentiality, security, and data protection requirements throughout the performance of the contract.

CITY OF NORCO

CONFIDENTIALITY & NON-DISCLOSURE

AGREEMENT- EXTERNAL CONSULTANT
I acknowledge that the City of Norco (“City”) will make available to me from time to time certain information that is highly confidential to the City. I acknowledge that such information is a valuable, special and unique asset of the City and expressly covenant and agree that I shall not disclose all or any part of this confidential information to any person, firm, corporation, association, or partnership without the written permission of the City, which permission may be granted or denied in the City’s absolute and sole discretion.

For example, and not by way of limitation, this information may include the following kinds of information: (a) software; (b) remote application access and other computer information licensed to the City; (c) infrastructure and/or control system/operational data; (d) bidding information related to various contracts of the City; (e) human resources data; (f) proprietary information about various businesses that perform, or may perform, work on the City’s behalf; (g) the work product of the City’s employees and agents; (h) reports on any City system security or vulnerabilities and (i) any other confidential and/or sensitive information which is disclosed by the City in writing and marked as confidential and/or disclosed by the City in any other manner and identified as confidential at the time of disclosure.

I shall hold all of the City’s confidential information at all times in trust and strictest confidence for the City from and after the date of its creation or disclosure to me. I shall prevent the impermissible release of the City’s confidential information. I shall not retain nor incorporate any of the confidential information into any database or any medium other than as may be specifically required for the City’s exclusive benefit and as may be specifically directed by the City. I shall not duplicate or disclose or otherwise reveal such confidential information in any manner inconsistent with this agreement.

In addition, I shall not use City technology or data to perform an illegal act and I shall not share the password or account access provided exclusively to me. When leaving a City workstation (or a non-City workstation that is connected to City systems or contains City data) unattended, or out of sight, I shall save my work and log off or lock the workstation to prevent unauthorized access. I will make no attempt to circumvent access codes or information protection schemes or uncover security loopholes or attempt to break authentication procedures or encryption protocols. I will make no attempts to increase the level of access to which I have been authorized. I will not attempt to use or obtain access codes in an unauthorized manner or from another user. I shall not allow non-employees to access City computer systems.

In addition, I agree, at the completion of the work performed for the City, to return or destroy all copies of information that is identified by the City as confidential. Destruction will be certified in writing to the City.

I agree to abide by the statements made regarding the use of confidential information, including, without limitation, the applicable restrictions on the use of City computers. I agree to be bound by the representations and warranties set forth herein as well as any and all other policies and procedures of the City or as otherwise may be required by applicable law or regulation.

I acknowledge that my faithful compliance with this agreement is necessary to protect the City and that any action on my part that is inconsistent with this agreement or with any City policy and procedure will cause the City irreparable and continuing harm. Therefore, if anything I do is inconsistent with this agreement or any such policy and procedure, I consent to the City obtaining a court order to stop my inconsistent actions and otherwise to prevent any such prohibited actions, without the City having to post any bond or security for such order. The City may pursue other remedies available to it, all of which are nonexclusive and cumulative.

I hereby agree that monetary damages will not constitute an adequate remedy for the breach of this agreement, and therefore I consent to the enforcement of this agreement through the equitable remedies of specific performance and injunctive relief. In the event the City seeks to enforce this agreement, I agree that the City may seek such enforcement in the Superior Court of Riverside County, California, and I hereby consent to the jurisdiction of such court in any such action. I further agree that in the event of any legal action to construe or enforce the provisions of this agreement, or to obtain such other relief or recompense as may be available by law, the City shall be entitled to reimbursement costs and reasonable attorney’s fees.

Nothing in this agreement shall constitute an agreement for any reason other than the protection of confidential information. I am aware that I am entitled to obtain an independent legal opinion regarding the advisability of signing this agreement and I took said right into consideration prior to my execution of this agreement.

I have read and understand the “City of Norco’s Confidentiality and Non-Disclosure Agreement – External Consultant” and agree to comply with its provisions.

Full Name (please print):

Signature:________________________________ Date:____/_____/_____ Company Name:

Company Tax ID:

Company Address:

Phone Number: ( ) -
Fax Number: ( ) -
E-mail Address:

Mohammad Ahmed
06 15 26
Infinity Technologies
86-2691967
27051 Towne Centre Drive, Suite 120, Lake Forest, CA 92610 (916) 273-4662
[email protected]

INFINITY TECHNOLOGIES
www.inftechnologies.com

THANK YOU

FOR YOUR TIME AND CONSIDERATION

CA-17

GENERAL LIABILITY ENDORSEMENT

CITY OF NORCO
2870 Clark Avenue
Norco, CA 92860
(951) 270-5627
(951) 270-5677
A. POLICY INFORMATION Endorsement # ________________________

1. Insurance Company ____________________________________________ Policy Number _____________________

2. Policy Term (From) _______________ (To)________________ Endorsement Effective Date ______________________________________

3. Named Insured _______________________________________________

4. Address of Named Insured
_____________________________________________________________ _____________________________________________________________

5. Limit of Liability Any One Occurrence/Aggregate
$______________________________ /_____________________________

6. Deductible or Self-Insured Retention (Nil unless otherwise specified):
______________________________________________

7. Coverage is equivalent to:

Comprehensive General Liability Form GL0002 (Ed. 1/73)
______________________________________________
Commercial General Liability "Occurrence" Form CG0001
______________________________________________

8. Bodily Injury and Property Damage Coverage is:
____________________________________"occurrence"
Note: The City of Norco standard insurance requirements specify "occurrence" coverage. "Claims-made" coverage is not acceptable. If commercial general liability form or equivalent is used, the general aggregate must apply separately to this location/project or the general aggregate must be twice the occurrence limit.

CA-18

9. Description of Project:

ANNUAL ON-CALL PROFESSIONAL SERVICES

FOR GIS SUPPORT AND INTEGRATION
FISCAL YEARS 2026-27 TO 2028-29
The general items of work to be done hereunder consist of:

The Project includes furnishing all labor, materials, tools, equipment, services, and incidental and customary work necessary to fully and adequately supply GIS implementation and integration services on an as-needed basis necessary.

B. POLICY AMENDMENTS
This endorsement is issued in consideration of the policy premium. Notwithstanding any inconsistent statement in the policy to which this endorsement is attached or any other endorsement attached thereto, it is agreed as follows:

1. INSURED. As respects any work performed on the above described Projects, the City of Norco, its elected or appointed officers, officials, employees, consulting engineers, and volunteers are included as insured with regard to damages and defense of claims arising from: (a) activities performed by or on behalf of the Named Insured, (b) products and completed operations of the Named Insured, or (c) premises owned, leased, or used by the Named Insured.

2. CONTRIBUTION NOT REQUIRED. As respects: (a) work performed by the Named Insured on the above described Projects for or on behalf of the City of Norco; or (b) products sold by the Named Insured to the City of Norco for use on the Projects; or (c) premises leased by the Named Insured from the City of Norco, the insurance afforded by this policy shall be primary insurance as respects the City of Norco, its elected or appointed officers, officials, employees, consulting engineers, or volunteers; or stand in an unbroken chain of coverage excess of the Named Insured's schedule underlying primary coverage. In either event, any other insurance maintained by the City of Norco, its elected or appointed officers, officials, employees, consulting engineers, or volunteers shall be in excess of this insurance and shall not contribute with it.

3. SCOPE OF COVERAGE. This policy, if primary, affords coverage at least as broad as:
(1) Insurance Services Office Form Number GL 0002 (Ed. 1/73), Comprehensive General Liability Insurance and Insurance Services Office form number GL 0404 Broad Form Comprehensive General Liability endorsement; or
(2) Insurance Services Office Commercial General Liability Coverage,

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“Occurrence" Form CG 0001; or
(3) If excess, affords coverage which is at least as broad as the primary insurance forms referenced in the preceding Sections (1) and (2).

4. SEVERABILITY OF INTEREST. The insurance afforded by this policy applies separately to each insured who is seeking coverage or against whom a claim is made or a suit is brought, except with respects to the Company's limit of liability.

5. PROVISIONS REGARDING THE INSURED'S DUTIES AFTER ACCIDENT OR LOSS. Any failure to comply with reporting provisions of the policy shall not affect coverage provided to the City of Norco, its elected or appointed officer, officials, employees, consulting engineers or volunteers.

6. CANCELLATION NOTICE. The insurance afforded by this policy shall not be suspended, voided, canceled, reduced in coverage or in limits except after 30 days prior written notice by certified mail return receipt requested has been given to the City of Norco. Such notice shall be addressed as shown in the heading of this endorsement.

C. INCIDENT AND CLAIM REPORTING PROCEDURE
Incidents and claims are to be reported to the insurer at:

ATTN:
_____________________________________________________________________ (Title) (Department)
_____________________________________________________________________ (Company)
_____________________________________________________________________ (Street Address)
_____________________________________________________________________ (City) (State) (Zip Code)
______________________________
(Telephone Number)

CA-20
D. SIGNATURE OF INSURER OR AUTHORIZED REPRESENTATIVE OF THE

INSURER
I, __________________________, warrant that I have authority to (Print/Type Name)
bind the below-listed insurance company and by my signature hereon do so bind this company.
____________________________________________

SIGNATURE OF AUTHORIZED REPRESENTATIVE
(Original Signature required on endorsement furnished to the City of Norco) ORGANIZATION: _____________________________________________________ TITLE: _____________________________________________________ ADDRESS: _____________________________________________________ _____________________________________________________
TELEPHONE: _____________________________________________________

CA-21

AUTOMOBILE LIABILITY ENDORSEMENT

CITY OF NORCO
2870 Clark Avenue
Norco, CA 92860
(951) 270-5627
(951) 270-5677
A. POLICY INFORMATION Endorsement #_____________________

1. Insurance Company _____________________________________________ Policy Number _____________________

2. Policy Term (From)________________(To) _______________ Endorsement Effective Date ___________

3. Named Insured________________________________________________

4. Address of Named Insured________________________________________

5. Limit of Liability Any One Occurrence/Aggregate
$______________________ /_____________________________________

6. Deductible or Self-Insured Retention
(Nil unless otherwise specified):
$____________________________________________________________ B. POLICY AMENDMENTS
This endorsement is issued in consideration of the policy premium. Notwithstanding any inconsistent statement in the policy to which this endorsement is attached or any other endorsement attached thereto, it is agreed as follows:

1. INSURED. The City of Norco, its elected or appointed officers, officials, consulting engineers, employees and volunteers are included as insured with regard to damages and defense of claims arising from: the ownership, operation, maintenance, use, loading or unloading of any auto owned, leased, hired or borrowed by the Named Insured, regardless of whether liability is attributable to the Named Insured or a combination of the Named Insured and the City of Norco, its elected or appointed officers, officials, employees, consulting engineers or volunteers.

2. CONTRIBUTION NOT REQUIRED. As respects work performed by the Named Insured for or on behalf of the City of Norco, the insurance afforded by this policy shall: (a) be primary insurance as respects the City of Norco, its elected or appointed officers, officials, employees, consulting engineers or volunteers; or (b)

CA-22
stand in an unbroken chain of coverage excess of the Named Insured's primary coverage. In either event, any other insurance maintained by the City of Norco, its elected or appointed officers, officials, employees or volunteers shall be in excess of this insurance and shall not contribute with it.

3. SCOPE OF COVERAGE. This policy, if primary, affords coverage to the Named Insured at least as broad as:
(1) Insurance Services Office form number CA 00001 (Ed. 1/78), Code 1 ("any auto") and endorsement CA 0025.
(2) If excess, affords coverage which is at least as broad as the primary insurance forms referenced in the preceding Section (1).

4. SEVERABILITY OF INTEREST. The insurance afforded by this policy applies separately to each insured who is seeking coverage, or against whom a claim is made or a suit is brought, except with respect to the Company's limit of liability.

5. PROVISIONS REGARDING THE INSURED'S DUTIES AFTER ACCIDENT OR LOSS. Any failure to comply with reporting provisions of the policy shall not affect coverage provided to the City of Norco, its elected or appointed officer, officials, employees, consulting engineers or volunteers.

6. CANCELLATION NOTICE. The insurance afforded by this policy shall not be suspended, voided, canceled, reduced in coverage or in limits except after 30 days prior written notice by certified mail return receipt requested has been given to the City of Norco. Such notice shall be addressed as shown in the heading of this endorsement.

C. INCIDENT AND CLAIM REPORTING PROCEDURE
Incidents and claims are to be reported to the insurer at:

ATTN:
_____________________________________________________________________ (Title) (Department)
_____________________________________________________________________ (Company)
_____________________________________________________________________ (Street Address)
_____________________________________________________________________ (City) (State) (Zip Code)
____________________________________________________
(Telephone Number)

CA-23
D. SIGNATURE OF INSURER OR AUTHORIZED REPRESENTATIVE OF THE

INSURER
I, __________________________, warrant that I have authority to (Print/Type Name)
bind the below-listed insurance company and by my signature hereon do so bind this company.
____________________________________________

SIGNATURE OF AUTHORIZED REPRESENTATIVE
(Original Signature required on endorsement furnished to the City of Norco) ORGANIZATION: _____________________________________________________ TITLE: _____________________________________________________ ADDRESS: _____________________________________________________ _____________________________________________________
TELEPHONE: _____________________________________

CA-24

WORKER'S COMPENSATION/EMPLOYER'S LIABILITY ENDORSEMENT

CITY OF NORCO
2870 Clark Avenue
Norco, CA 92860
(951) 270-5627
(951) 270-5677
A. POLICY INFORMATION Endorsement # ________________________

1. Insurance Company ____________________________________________ ("the Company")
Policy Number _________________________________________________

2. Effective Date of this Endorsement ________________________________

3. Named Insured_________________________________________________

4. Employer's Liability Limit (Coverage B)______________________________ _____________________________________________________________ B. POLICY AMENDMENTS
In consideration of the policy premium and notwithstanding any inconsistent statement in the policy to which this endorsement is attached or any other endorsement attached thereto, it is agreed as follows:
(1) Cancellation Notice. The insurance afforded by this policy shall not be suspended, voided, canceled, reduced in coverage or in limits except after 30 days prior written notice by certified mail return receipt requested has been given to the City of Norco. Such notice shall be addressed as shown in the heading of this endorsement.
(2) Waiver of Subrogation. The Insurance Company agrees to waive all rights of subrogation against the City of Norco, its elected or appointed officers, officials, agents and employees for losses paid under the terms of this policy which arise from work performed by the Named Insured for the City of Norco.

CA-25
C. SIGNATURE OF INSURER OR AUTHORIZED REPRESENTATIVE OF THE

INSURER
I, _______________________, warrant that I have authority to bind (Print/Type Name)
the below-listed insurance company and by my signature hereon do so bind this company.
_______________________________________________

SIGNATURE OF AUTHORIZED REPRESENTATIVE
(Original signature required on endorsement furnished to the City of Norco) ORGANIZATION: ____________________________________________________ TITLE: ____________________________________________________ ADDRESS: ____________________________________________________ TELEPHONE: ____________________________________________________

CA-26
W-9 FORM

CA-27

CA-28

CA-29

City Council

STAFF REPORT
Date: September 16, 2026 Agenda Item:

5.A.

To: Honorable Mayor and City Council Members
From: Colby Cataldi, Community Development Director
Prepared By: Colby Cataldi, Community Development Director Department: Community Development
SUBJECT:

JD Ranch Single-Family Residential Subdivision Project (TACRD Investments, L.P.):

Request for Approval of a Final Environmental Impact Report, General Plan Amendment 2022-02, Zone Change 2022-01, Tentative Tract Map 38330 and Conditions of Approval, and Option and Real Property Exchange Agreement RECOMMENDATION:

1. Adopt Resolution No. 2026-78, certifying the Final Environment Impact Report (State Clearinghouse No. 2023060617);

2. Adopt Resolution No. 2026-79, adopting General Plan Amendment 2022-02;

3. Introduce first reading of Ordinance No. 1146, adopting Zone Change 2022-01;

4. Adopt Resolution No. 2026-80, approving Tentative Tract Map 38330 and Conditions of Approval; and

5. Approve Option and Real Property Exchange Agreement between City of Norco and TACRD Investments, L.P.

SUMMARY:

The JD Ranch Residential Project is a proposed single-family residential subdivision by the Dallape Family (TACRD Investments, L.P.), long-time Norco residents. The proposed project would subdivide approximately 34.39-acres of the 37.84-acre project site into 64 single-family residential lots, reflecting a combination of lot sizes and zoning designations. To ensure that animal keeping remains an integral component of the development, the proposed lots would include a deed-restricted Primary Animal Keeping Area (PAKA), regardless of lot size. The proposed project includes new residential streets and equestrian-related improvements, including a public riding arena, publicly accessible trails throughout the residential development, and connections to future horse trails along Bluff Street and River Road.

BACKGROUND:

The JD Ranch Residential Project is a proposed single-family residential subdivision by the Dallape Family (TACRD Investments, L.P.). The two parcels being developed consist of approximately 37.84-acres located along River Road, between Bluff Street and Sundance Lane. The site includes privately owned property and approximately 8.24 acres of City-owned property proposed to be incorporated into the development through a land exchange. The property was formerly operated as a dairy beginning in the late 1960s and was operated by the Dallape Family for more than 50 years. The Dallape Family proposes to retain ownership of the original farmhouse and continue residing on JD Ranch. The proposed project would subdivide approximately 34.39 acres into 64 single-family residential lots, including the existing farmhouse. The proposed project also includes new residential streets and equestrian-related improvements, including a public riding arena, publicly accessible trails throughout the residential development, and connections to future horse trails along Bluff Street and River Road.

EXISTING CONDITIONS
The 37.84-acre project site is mostly vacant and consists of two parcels:

APN 121-110-001 (City of Norco): The parcel contains existing water well facilities, including related piping, utilities, and two above ground water storage reservoirs.

Portions of the site are used by the City to stockpile material for future use.

APN 121-110-003 (TACRD Investment, L.P.): The former Dallape Dairy property (2877 River Road) consists of a single-family home, former milking barn, retail outlet, barns/sheds, and related features. There is an existing 60-foot-wide Southern California Edison (SCE) easement with above-ground power poles along the northeast portion of the parcel.

The project site is situated in an urbanized area and is generally surrounded by developed land uses, including:
 Single-family homes to the south, west and east
 Stonebridge Christian Academy (north of Bluff Street)  Santa Ana River Corridor (north and northwest of Bluff Street)

PROPOSED PROJECT
Norco includes a variety of residential lot sizes and zoning designations. While many properties in the city are located in the A-1-20 (Agricultural Low Density) zone, which requires a minimum lot size of 21,780 square feet for all developments after 2014, established areas of Norco also include quarter-acre lots within the R-1 (Residential Single Family) zone, including neighborhoods near Highland Elementary School, Norco Intermediate School, and along River Drive.

The JD Ranch Single-Family Residential Subdivision Project includes 64 single-family residential lots, including the existing farmhouse. The proposal reflects a combination of lot sizes and zoning designations, while maintaining an animal-keeping component throughout the development, with each proposed lot including a deed-restricted Primary Animal Keeping Area (PAKA), as well as a dedicated, unobstructed 15-foot-wide vehicle access easement to the PAKA.

A-1-20 Lots (15 Lots): Lot sizes range from 21,801 to 44,261 square feet  Lots labeled 1 through 13, 53, and 64 on Tentative Tract Map No. 38330.

R-1 Lots (49 Lots): Lot sizes range from 10,976 to 19,554 square feet  Lots labeled 14 through 52, and 54 through 63 on Tentative Tract Map No. 38330.

Equestrian/Animal-Keeping Properties: Animal keeping is an integral component of the development. Each proposed lot will include a deed-restricted PAKA, regardless of lot size, to provide residents with designated space for the keeping of horses and other allowable animals. PAKA sizes are detailed on the Tentative Tract Map and are based on the allowable number of animal units for each lot, consistent with the Norco Municipal Code (NMC). For example, a lot with two allowable animal units includes a 1,152-square-foot PAKA, based on the NMC requirement of 576 square feet per animal unit. Each PAKA will also have a dedicated, flat, and unobstructed vehicular access area with a minimum width of 15 feet, recorded on each lot and shown on the Tentative Tract Map. Although the project is not subject to a specific plan, the City requires a PAKA be provided along with the requirements and mandatory access to establish a clear and enforceable framework comparable to the level that is typically provided through specific plan standards.

Equestrian Designation Compatibility: The proposed project is compatible with the City’s Equestrian Historic District and Equestrian Landmark and will remain within both designations. The project incorporates the characteristics that support Norco’s equestrian heritage, including residential lots with zoning that allows animal-keeping by right, deed-restricted PAKAs for the keeping of horses and other allowable animals, equestrian trails and trail fencing, equestrian amenities, and open space. These features are consistent with the purpose of the Equestrian Historic District to preserve Norco’s heritage and animal-keeping lifestyle and with the Equestrian Landmark’s focus on large lots, equestrian trails, and open space as defining elements of Norco’s equestrian community. As proposed, the project will continue to contribute to and preserve the equestrian character recognized by both designations.

Equestrian Amenities and Connectivity: The proposed project enhances connectivity to Norco’s surrounding equestrian trail network and provides additional public equestrian amenities. The project includes perimeter and interior equestrian trails, connections to two adjacent parks (Ted Brooks Park and Sundance Park), and connections to surrounding neighborhoods. The project will also include a public riding arena and round pen, which will provide additional capacity to complement the heavily utilized existing arena at Ted Brooks Park. Connections to future horse trails along Bluff Street and River Road will further enhance connectivity throughout the surrounding community.

Community Facilities District: A Community Facilities District (CFD) will provide a dedicated funding source for ongoing costs associated with the development, helping reduce the financial burden on the City and its existing taxpayers. The CFD will fund the ongoing operation, repair, and maintenance of development-related facilities and improvements, including horse trails, trail fencing, parkway and public landscaping, equestrian amenities, graffiti removal, lighting, sewer lift station, drainage improvements, and the detention basin, as well as costs to offset the project’s impacts on public safety services.

APPROVALS
Approval of the JD Ranch Single-Family Residential Subdivision Project requires:
 Option and Real Property Exchange Agreement
 Certification of the Final Environmental Impact Report  Adoption of General Plan Amendment 2022-02
 Adoption of Zone Change 2022-01 (4/5 vote required)
 Approval of Tentative Tract Map 38330 and Conditions of Approval Option and Real Property Exchange Agreement
The proposed project includes an Option and Real Property Exchange Agreement between the property owner and the City of Norco. Under the proposed exchange agreement, the property owner would transfer approximately 3.29 acres to the City, while the City would transfer approximately 8.24 acres of City-owned property to the property owner for incorporation into the residential development. The 3.29 acres transferred to the City would be designated as Open Space (OS) and would facilitate connections to future horse trails, as well as provide an opportunity for a new public riding arena. Based on the appraised fair market values of the properties involved, the City would receive $1 million for the 4.95-acre net difference between the land transferred by the City and the land received through the exchange, in addition to a $50,000 option payment.

Final Environmental Impact Report (Resolution No. 2026-78) In accordance with the California Environmental Quality Act (CEQA) and CEQA Guidelines, the City of Norco, acting as the Lead Agency, prepared an Environmental Impact Report for the Proposed Project. The Final Environmental Impact Report (FEIR) determined environmental impacts can be mitigated to a less than significant level. A Mitigation Monitoring and Reporting Program (MMRP) has been developed, providing mitigation measures to reduce identified environmental impacts to the less than

significant level. The MMRP includes enforceable mitigation measures and provides the City of Norco with a mechanism to verify and determine compliance with those measures. The FEIR addresses all environmental effects of the Proposed Project and fully complies with the requirements of CEQA and the CEQA Guidelines and reflects the City’s independent judgment and analysis.

The Western Riverside Council of Governments (WRCOG) Vehicle Miles Traveled (VMT) Tool and the Riverside County Transportation Model (RIVCOM) were updated after the VMT analysis for the proposed project was completed in 2024. In response, City staff requested that LLG Transportation and Planning Engineers conduct a second analysis using the revised models. The additional analysis, completed in June 2026, determined that the proposed project could meet the updated VMT thresholds.

Accordingly, the proposed project no longer requires a Statement of Overriding Considerations because the revised VMT analysis determined that the Project would not result in any significant and unavoidable environmental impacts.

An Errata to the FEIR has been completed to incorporate updated project details and the revised VMT analysis.

The FEIR is included as Attachment A to Resolution No. 2026-78. The Technical Memorandum – Revised Vehicle Miles Traveled Analysis is included in the FEIR.

The FEIR with revisions to the Public Review Draft, Response to Comments, Errata, and Mitigation Monitoring and Reporting Plan is available at www.norco.ca.us/publicnotice.

General Plan Amendment 2022-02 (Resolution No. 2026-79) General Plan Amendment (GPA) 2022-02 consists of amending the Land Use Designation on approximately 34.39-acres consisting of Assessor Parcel Numbers 121- 110-001 (City of Norco) and 121-110-003 (TACRD Investment, L.P.), including amending General Plan Policy 2.2.1a to allow a change in the General Plan land use designation of a portion of the existing Residential Agricultural (RA) property to a higher density residential use under specific circumstances resulting in a change of zoning to accommodate an increased density to meet General Plan policies. The change in land use designations is required to approve Zone Change 2022-01.

The current General Plan does not allow A-1 properties to be rezoned to higher-density residential uses:

General Plan Goal 2.0 Residential – Small Plot Agricultural/Animal-Keeping Goal: This goal promotes the health, safety, and well-being of the citizens of Norco by adopting standards for the proper balance, relationship, and distribution of residential land uses in accordance with the City's small plot agricultural/animalkeeping/equestrian lifestyle.

Policy 2.2.1a: Existing A-1 zones and similar agricultural-residential specific plan districts with similar densities shall not be rezoned for higher intensity residential uses.

GPA 2022-02 would create an exception to Policy 2.2.1a if a project also meets General Plan Policies 2.2.1d and 2.2.1e.

Policy 2.2.1d: Encourage residential open areas that support Norco’s small-plot agricultural and animal-keeping lifestyle.

Policy 2.2.1e: In residential areas where animal keeping is allowed, encourage lots that provide enough space and suitable conditions to safely and effectively keep animals.

With the approval of GPA 2022-02, General Plan Policy 2.2.1a would be amended as follows (additions are in bold and red):
“Policy 2.2.1a. Existing A-1 zones and similar agricultural-residential specific plan districts with similar densities shall not be rezoned for higher intensity residential uses, unless compliance with General Plan Policies 2.2.1d and 2.2.1e is achieved.” With the approval of GPA 2022-02, the following land use designations would also be amended:
 Approximately 8.24-acres from Public Land (PL) to Residential Low (RL) (Portion of APN 121-110-001)
 Approximately 15.08-acres from Residential Agricultural (RA) to Residential Low (RL) (Portion APN 121-110-003)
 Approximately 3.29-acres from Residential Agricultural (RA) to Parks (P) (Portion APN 121-110-003) leaving the remainder of said parcel APN 121-110-003 consisting of 7.78-acres with a land use designation of Residential Agricultural (RA)
“Existing and Proposed General Plan Land Use” is included as Attachment A to Resolution No. 2026-79.

Zone Change 2022-01 (Ordinance No. 1146)
Zone Change (ZC) 2022-01 consists of changing the Zoning Designation on approximately 34.39-acres consisting of Assessor Parcel Numbers 121-110-001 (City of Norco) and 121-110-003 (TACRD Investment, L.P.), including a portion of the existing Residential Agricultural (RA) property to a higher density residential use under specific circumstances resulting in a change of zoning to accommodate an increased density to meet General Plan policies.

With the approval of ZC 2022-01, the following zoning designations would be amended:
 Approximately 8.24-acres from Open Space (OS) to Residential Single-Family (R-1) (Portion of APN 121-110-001)
 Approximately 15.08-acres from Agriculture-Low-Density 20,000 square foot lot (21,780 square feet per Ordinance No. 977 (2014) (A-1-20)) to Residential Single-Family (R-1) (Portion APN 121-110-003)
 Approximately 3.29-acres from Agriculture-Low-Density 20,000 square foot lot (A-1-20) to Open Space (OS) (Portion APN 121-110-003) leaving the remainder

of said parcel APN 121-110-003 consisting of 7.78-acres with a zoning designation of Agriculture-Low-Density 20,000 square foot lot (21,780 square feet per Ordinance No. 977 (2014) (A-1-20))
“Existing and Proposed Zoning” is included as Attachment A to Ordinance No. 1146.

Tentative Tract Map 38330 (Resolution No. 2026-80)
Tentative Tract Map 38330 would be approved for a period of 24 months, subject to Conditions of Approval listed in Resolution No. 2026-80.

Tentative Tract Map 38330 is included as Attachment A to Resolution No. 2026-80.

FINDINGS
On December 10, 2025, the Planning Commission held a public hearing to consider the proposed project. The Commission ultimately did not recommend approval to the City Council due to concerns related to General Plan consistency, proposed lot sizes under the required 21,780 square feet, and potential traffic impacts.

Following the Planning Commission public hearing, City staff conducted a comprehensive review of the project and worked with the applicant to address concerns raised by community members and Planning Commission members during the public hearing. Based on the comments received, the proposed project has been amended to reflect the comments and concerns expressed. The proposed project includes revised lot numbers and sizes; compliance with the Norco Municipal Code development standards in accordance with Title 17; a reduction in the acreage proposed to be rezoned from A-1-20 to R-1; enlarged PAKA areas; and equestrian amenities throughout the project for use by both the neighborhood and the community. The project description and supporting materials have also been updated to reflect the coordinated efforts of City staff and the applicant and to provide a clearer depiction of the proposed lots and the intended single-family residential development pattern.

Overall, the revised project and updated documentation address the issues identified during the Planning Commission hearing and offer clarity through the updated VMT analysis and removal of the Statement of Overriding Considerations.

The Community Development Department recommends adoption of General Plan Amendment 2022-02 and Zone Change 2022-01 and approval of Tentative Tract Map 38330 based on the following findings:

I. FINDINGS FOR GENERAL PLAN AMENDMENT 2022-02:

A. The proposal is consistent with the General Plan in that the proposed land use designations and amendment to General Plan Policy 2.2.1a is consistent with protecting the small plot agricultural/animal-keeping/equestrian lifestyle through the recordation of a deed-restricted Primary Animal-Keeping Area (PAKA) on each residential lot, regardless of lot size. The proposed General Plan Amendment also proposes a land use designation for Parks (P), which is consistent with the characteristics of neighborhoods with both the Residential Agricultural (RA),

Residential Low (RL), and Parks (P) land use designations as defined in Section

3.4.2 of the General Plan, with zoning changes reflective of these uses in accordance with Ordinance No. 1146.

B. The proposal is reasonably compatible with the area immediately surrounding the project site in that the proposed land use designations are complementary to the designations of nearby single-family homes with animal-keeping provisions. The proposed amendment to General Plan Policy 2.2.1a will facilitate the creation of lots under 21,780 square feet (A-1-20 zoning designation per Ordinance No. 977), but in a manner that promotes the intent of the minimum 21,780 square-foot lot requirement, which is to protect City's small plot agricultural/animalkeeping/equestrian lifestyle.

C. The proposal is not detrimental to the public convenience or general welfare of the persons residing or working in the surrounding neighborhood in that the proposed land use designations will facilitate uses that are identical to the uses allowed in the land use designations of nearby residential-agricultural properties and are appropriate for the properties and neighborhood.

D. The proposal is not injurious to surrounding properties, nor does it adversely impact the use of adjoining parcels in that the proposed land use designations will facilitate uses that are identical to the uses allowed in the land use designations of nearby residential-agricultural properties and are appropriate for the properties and neighborhood.

Il. FINDINGS FOR ZONE CHANGE 2022-01:

A. The requested change of zone is necessary and desirable for the development of the community in harmony with the objective of the General Plan in that the proposed zone change supports General Plan Goal 2.2, “Residential – Small Plot Agricultural/Animal-Keeping Goal”, and General Plan Policy 2.2.1a:

General Plan Goal 2.0 Residential – Small Plot Agricultural/Animal-Keeping Goal:
“This goal promotes the health, safety, and well-being of the citizens of Norco by adopting standards for the proper balance, relationship, and distribution of residential land uses in accordance with the City's small plot agricultural/animalkeeping/equestrian lifestyle.” Policy 2.2.1a. Existing A-1 zones and similar agricultural-residential specific plan districts with similar densities shall not be rezoned for higher intensity residential uses, unless compliance with General Plan Policies 2.2.1d and 2.2.1e is achieved (Resolution No. 2026-79).

Furthermore, the proposed zone change will comply with General Plan Policies

2.21d and 2.21e, as it will facilitate open areas to encourage the small-plot agricultural/animal-keeping lifestyle, and to provide the necessary area and terrain to effectively maintain the health and safety of animals. The proposed zone change also proposes a zone change from Agriculture-Low-Density 20,000 square foot lot

(A-1-20) to Open Space (OS), which is consistent with the characteristics of surrounding neighborhoods and the community.

B. The requested change of zone will be compatible and complementary to existing conditions in the surrounding area in that the proposed zoning designations will facilitate uses that are identical to those allowed in the existing zoning designations of surrounding single-family residential, agricultural low density, and open space land uses.

C. The site is adequate in size to accommodate the uses permitted in the existing and proposed zones requested, and all applicable property development standards can be complied with in accordance with Title 18, Zoning, of the City of Norco Municipal Code.

D. The site properly relates to streets and highways designed and fully improved to carry the type and quantity of traffic that is expected to be generated in this area and that utilities exist or are planned, which will adequately serve the property as rezoned in that streets, street improvements, and water and sewer mains are needed and will be provided to serve the properties that are part of the proposed zone change.

III. FINDINGS FOR TENTATIVE TRACT MAP 38330:

A. Tentative Tract Map (TTM) 38330 is consistent with the Norco General Plan in accordance with Resolution No. 2026-79 designating the Proposed Project as Residential Agricultural (RA), Residential Low (RL), Parks (P), and Public Lands (PL). The Proposed Project is consistent with the rezone in accordance with Ordinance No. 1146, which rezoned approximately 34.39-acres as: A-1-20 (Agricultural-Low Density Residential – minimum 21,780), R-1-10 (Residential – Single Family – 10,000), and OS (Open Space). The proposed lots are designed and conditioned to meet all zoning requirements related to lot area and dimension standards, including animal-keeping areas.

B. None of the conditions for mandatory denial as set forth in Subsections (a) through (g) of Section 66474, Article 1, Chapter 4, Division 2, Title 7, of the California Government Code exist with respect to said subdivision.

C. The proposed subdivision, together with provisions for its design and improvements, is consistent with applicable General Plans of the City pursuant to Section 66473.5, Article 1, Chapter 4, Division 2, Title 7, of the California Government Code.

D. The City of Norco, acting as the Lead Agency, prepared an Environmental Impact Report for the Proposed Project TTM 38330. The Final Environmental Impact Report (FEIR) determined environmental impacts can be mitigated to a less than significant level. The City Council of the City of Norco certified the FEIR by Resolution No. 2026-78 in accordance with the California Environmental Quality Act (CEQA), as required by California Public Resources Code section 21081.6 and CEQA Guidelines section 15097 also adopting a Mitigation Monitoring and Reporting Program ensuring mitigation measures are met.

FISCAL IMPACT:

The proposed project would have a positive fiscal impact on the City through revenue generated from the proposed land exchange and residential development, as well as the establishment of a dedicated funding source for ongoing development-related costs.

Pursuant to the Option and Real Property Exchange Agreement, the City will receive $1 million for the 4.95-acre net difference between the land transferred by the City and the land received through the exchange, in addition to a $50,000 option payment. The proposed residential development will also generate additional property tax revenue for the City. A Community Facilities District (CFD) will provide a dedicated funding source for ongoing costs associated with the development, helping reduce the financial burden on the City and its existing taxpayers.

RELATIONSHIP TO STRATEGIC PLAN:

This item is consistent with Strategic Plan Direction No. 3, "Economic Development and Financial Stability."
REVIEWED AND APPROVED BY:

Certified as to Availability of Funds: Joshua Calhoun, Finance Director Approved by: Lisette Free, City Manager
Approved as to Form: Harper and Burns, LLP, City Attorney ATTACHMENT(S):

Resolution No. 2026-78 – Certification of the Final Environmental Impact Report Resolution No. 2026-79 – Adoption of General Plan Amendment 2022-02 Ordinance No. 1146 – Adoption of Zone Change 2022-01
Resolution No. 2026-80 – Approval of Tentative Tract Map 38330 and Conditions of Approval
Option and Real Property Exchange Agreement

RESOLUTION NO. 2026-78

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

NORCO, CALIFORNIA, CERTIFYING THE FINAL

ENVIRONMENTAL IMPACT REPORT FOR THE JD RANCH
SINGLE-FAMILY RESIDENTIAL SUBDIVISION PROJECT.
(STATE CLEARINGHOUSE NO. 2023060617).

WHEREAS, TACRD Investments, L.P., submitted a series of development applications to the City of Norco, California requesting approval of a General Plan Amendment, Zone Change, and Tentative Tract Map to allow the development of a 64- lot single-family detached housing project on approximately 37.84 acres, located within the western portion of the City, along River Road between Bluff Street and Sundance Lane; and,
WHEREAS, the City is the lead agency under the California Environmental Quality Act (CEQA), for the Proposed Project; and,
WHEREAS, in accordance with Section 15082 of the CEQA Guidelines, the City of Norco prepared a Notice of Preparation (NOP) of the intent to prepare an Environmental Impact Report (EIR) for the Proposed Project, published a Public Notice informing the community, and distributed the NOP to responsible and interested agencies and key interest groups for comment during a 30-day public review period from June 23, 2023, through July 23, 2023; and,
WHEREAS, the City conducted a Scoping Meeting on July 10, 2023, at Norco City Hall in which the public was invited by the City to participate and provide comments on the scope of the environmental analysis; and,
WHEREAS, in recognition of the comments received in response to the NOP and Scoping Meeting, the City prepared a Draft Environmental Impact Report (DEIR), dated June 2024; and,
WHEREAS, a Notice of Availability for the DEIR was filed with the State Clearinghouse, published in the Daily Bulletin, and posted at the Riverside County ClerkRecorder’s office notifying the public that the DEIR would be available for a 45-day public review period from June 6, 2024, to July 22, 2024; and, WHEREAS, during the public review period, the City received letters, electronic mail (email), and telephone messages providing comments on the DEIR; and, WHEREAS, the City of Norco issued a Notice of Public Hearing and held a Planning Commission Hearing on December 10, 2025, to consider the Proposed Project’s compliance with the General Plan, zoning, and environmental impacts; and,

Resolution No. 2026-78 – Certification of Final Environmental Impact Report (FEIR) (SCH No. 2023060617)

September 16, 2026
WHEREAS, in accordance with the requirements of CEQA, full and complete responses to those comments received during the public review period were prepared and are included in the Final EIR (FEIR) (Attachment A); and, WHEREAS, all the information comprising the FEIR is on file at Norco City Hall, 2870 Clark Avenue, Norco, CA 92860; and,
WHEREAS, the FEIR is comprised of (i) the DEIR; (ii) the Responses to Comments which includes a list of persons, organizations and public agencies commenting on the DEIR along with the letters and emails received from such commenters, public meeting testimony and corresponding responses to comments; (iii) the Errata providing the revisions to the DEIR reflecting changes made in response to comments and other information as detailed in the Response to Comments; (iv) all attachments and documents incorporated by reference into the DEIR; and (v) a Mitigation Monitoring and Reporting Program (MMRP); and,
WHEREAS, the FEIR has been completed in compliance with CEQA (California Public Resources Code, Sections 21000 et seq.) and the CEQA Guidelines (Title 14, California Code of Regulations, Sections 15000 et seq.) (CEQA Guidelines) and is a Project EIR as defined by CEQA Guidelines Section 15161, and as such addressed the potentially significant environmental impacts associated with the Proposed Project, as well as the impacts anticipated from subsequent implementing steps in the chain of contemplated actions designed to carry out the final planning and development of the Proposed Project; and,
WHEREAS, as required by California Public Resources Code section 21081.6 and CEQA Guidelines section 15097, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared identifying Mitigation Measures (MM(s)) and Project Design Features implementing the General Plan Noise Element policies, all of which have been identified as Mitigation Measures to reduce potentially significant impacts as a result of the Proposed Project; and,
WHEREAS, the principal purpose of the MMRP is to ensure that the mitigation measures identified to reduce impacts to a less than significant level in the FEIR are implemented and monitored for compliance during subsequent planning stages and, ultimately, during project implementation for the Proposed Project that is approved by the City; and,
WHEREAS, a copy of the MMRP is included as Section 4.0 of Attachment A and incorporated herein by reference; and,
WHEREAS, the City Council conducted a legally noticed Public Hearing on September 16, 2026, regarding the FEIR and the Proposed Project.

Resolution No. 2026-78 – Certification of Final Environmental Impact Report (FEIR) (SCH No. 2023060617)

September 16, 2026
NOW, THEREFORE, the City Council of the City of Norco does hereby make the following FINDINGS AND DETERMINATION:

1. The City Council certifies the Final Environmental Impact Report (“FEIR”) as complete and adequate in that it addresses all environmental effects of the Proposed Project, fully complies with CEQA and the CEQA Guidelines, and reflects the City’s independent judgment and analysis.

2. Pursuant to Public Resources Code section 21081 and CEQA Guidelines section 15091, the City Council finds that, with respect to each significant environmental effect identified in the FEIR, changes or alterations have been required in or incorporated into the Project that avoid or substantially lessen those effects to a less-than-significant level. Those changes and alterations consist of the mitigation measures identified in the FEIR and Mitigation Monitoring and Reporting Program (“MMRP”), which are hereby adopted and incorporated into the Project as enforceable requirements.

3. The City Council specifically finds that implementation of the mitigation measures identified in the FEIR and MMRP will reduce the potentially significant impacts relating to biological resources, cultural resources, geology and soils, hazards and hazardous materials, tribal cultural resources, and utilities and service systems to less-than-significant levels. The City Council adopts the analysis and conclusions of the FEIR and MMRP as the explanation and evidentiary basis for these findings.

4. The City Council further finds, based upon the Revised Vehicle Miles Traveled Analysis prepared by Linscott, Law & Greenspan Engineers and incorporated into the FEIR, that the Project will have a less-than-significant VMT impact and that no Statement of Overriding Considerations is required.

5. The City Council adopts the Mitigation Monitoring and Reporting Program contained in Section 4.0 of Attachment A and incorporates it into the Project approvals.

6. All information comprising the FEIR and the record upon which these findings are based is on file with the City at Norco City Hall, 2870 Clark Avenue, Norco, California 92860.

Resolution No. 2026-78 – Certification of Final Environmental Impact Report (FEIR) (SCH No. 2023060617)

September 16, 2026
PASSED AND APPROVED by the City Council of the City of Norco, California, at a regular meeting held on September 16, 2026.
___________________________
Robin Grundmeyer, Mayor
City of Norco, California
ATTEST:
__________________________
City Clerk
City of Norco, California

Resolution No. 2026-78 – Certification of Final Environmental Impact Report (FEIR) (SCH No. 2023060617)

September 16, 2026
I, Norma I. Alley, MMC, City Clerk of the City of Norco, California, do hereby certify that the foregoing Resolution was introduced and adopted by the City Council of the City of Norco, California, at a regular meeting thereof held on September 16, 2026, by the following vote of the City Council:

AYES:

NOES:

ABSENT:

ABSTAIN:

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City of Norco, California, on September 16, 2026. ________________________
City Clerk
City of Norco, California
Attachments:

Attachment A – Final Environmental Impact Report (FEIR)

FINAL

ENVIRONMENTAL IMPACT REPORT
SCH No. 2023060617
JD Ranch Residential Project
LEAD AGENCY:

City of Norco
Planning Department
2870 Clark Avenue
Norco, California 92860
Contact: Colby Cataldi, Community Development Director
951.270.5682
PREPARED BY:

VCS Environmental
30900 Rancho Viejo Road, Suite 100
San Juan Capistrano, California 92675
Contact: Julie Beeman, President
949.489.2700
JULY 2026

This document has been set up for double-sided printing in order to conserve natural resources.

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TABLE OF CONTENTS
Section 1.0: Introduction .................................................................................................................. 1-1

1.1 Introduction ........................................................................................................ 1-1

1.2 Format of the Final EIR ........................................................................................ 1-1

1.3 CEQA Requirements Regarding Comments and Responses .............................. 1-2 Section 2.0: Response to Comments ................................................................................................ 2-1 Section 3.0: Errata ............................................................................................................................ 3-1

3.1 Introduction ........................................................................................................ 3-1

3.2 Revisions to the Draft EIR .................................................................................... 3-1 Section 4.0: Mitigation Monitoring and Reporting Program ........................................................... 4-1 Attachments
Attachment A Project Description
Attachment B Revised Vehicle Miles Traveled Analysis

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SECTION 1.0 INTRODUCTION

1.1 INTRODUCTION
This Final Environmental Impact Report (Final EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.) and CEQA Guidelines (California Code of Regulations Section 15000 et seq.).

According to the CEQA Guidelines, Section 15132 (Contents of Final Environmental Impact Report), the Final EIR shall consist of:
a. The Draft Environmental Impact Report (Draft EIR) or a revision of the draft. b. Comments and recommendations received on the Draft EIR either verbatim or in summary. c. A list of persons, organizations, and public agencies comments on the Draft EIR. d. The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
e. Any other information added by the Lead Agency.

This document contains responses to comments received on the Draft EIR for the JD Ranch Residential Project (State Clearinghouse Number [SCH No.] 2023060617) during the public review period, which began June 6, 2024 and closed July 22, 2024. This document has been prepared in accordance with CEQA and the CEQA Guidelines and represents the independent judgment of the Lead Agency. This document and the circulated Draft EIR comprise the Final EIR, in accordance with CEQA Guidelines, Section 15132.

The Draft EIR for the proposed JD Ranch Residential Project (herein referenced as the project) was distributed to responsible and trustee agencies, interested groups, and organizations. The Draft EIR was made available for public review and comment for a period of 45 days. The public review period for the Draft EIR established by the CEQA Guidelines commenced on June 6, 2024 and ended July 22, 2024.

1.2 FORMAT OF THE FINAL EIR
The Final EIR is organized into the following sections:
 Section 1.0, Introduction: Provides CEQA compliance information.  Section 2.0, Response to Comments: This section includes a list of all correspondence submitted to the City of Norco on the Draft EIR, each identified by a letter for later reference, together with the authors and the dates the letters were issued. Following this list, all of the letters are presented, with numbered brackets to highlight specific comments that are responded to in the next section.
 Section 3.0, Errata: This section identifies revisions to the Draft EIR to incorporate clarifications developed in response to comments on the Draft EIR. Additions to the text are underlined and deletions have been stricken through. None of the changes presented in the Errata present new information that would result in significant changes that either changes the conclusions

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of the analysis presented in the Draft EIR or is regarded as significant new information that would result in recirculation of the Draft EIR pursuant to Section 15088.5(b) (Recirculation of an EIR Prior to Certification) of the CEQA Guidelines.
 Section 4.0, Mitigation Monitoring and Reporting Program: This section ensures that the mitigation measures identified in the Draft EIR for the proposed project are implemented.

1.3 CEQA REQUIREMENTS REGARDING COMMENTS AND

RESPONSES
CEQA Guidelines Section 15204(a) (Focus of Review) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated.

Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, in light of the factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and the geographic scope of the project. …CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.” CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” Section 15204(d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 15204(e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.” In accordance with CEQA, Public Resources Code Section 21092.5 (Proposed Response to Public Agency Comments Received by Lead Agency; Notice to Agency Commenting on Negative Declaration; Untimely Comments), copies of the written responses to public agencies will be forwarded to those agencies at least 10 days prior to certifying the environmental impact report.

The responses will be forwarded with copies of this Final EIR, as permitted by CEQA, and will conform to the legal standards established for response to comments on Draft EIRs.

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SECTION 2.0 RESPONSE TO COMMENTS
Section 15088 (Evaluation of and Response to Comments) of the CEQA Guidelines requires the Lead Agency (City of Norco) to evaluate comments on environmental issues received from public agencies and interested parties who reviewed the Draft EIR and prepare written responses.

This section provides all written responses received on the Draft EIR and the City’s responses to each comment.

Comment letters and specific comments are given letters and numbers for reference purposes. Where sections of the Draft EIR are excerpted in this document, the sections are shown indented. Changes to the Draft EIR text are shown in underlined text for additions and strikeout for deletions in Section 3.0, Errata, of this Final EIR.

The following is a list of agencies and persons that submitted comments on the Draft EIR during the public review period.

Reference
Number Date of Comment Commenting Agency/Person
Agencies and Organizations
1 6/17/2024 Agua Caliente Band of Cahuilla Indians
2 6/18/2024 Riverside County Airport Land Use Commission 3 6/27/2024 Riverside Transit Agency
4 7/2/2024 Department of Toxic Substances Control
5 7/5/2024 CAL FIRE – Riverside Unit, Riverside County Fire Department 6 7/11/2024 Riverside County Flood Control & Water Conservation District 7 7/17/2024 City of Eastvale
8 7/18/2024 Riverside County Department of Waste Resources 9 7/22/2024 Riverside County Fire Department – Office of the Fire Marshal, City of Norco Residents and Individuals
10 6/19/2024 Sue Paterson

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COMMENT LETTER NO. 1

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Response No. 1
Claritsa Duarte, Cultural Resources Analyst
Agua Caliente Band of Cahuilla Indians
June 17, 2024
Comment 1-1: A records check of the Tribal Historic Preservation Office’s cultural registry revealed that this project is not located within the Tribe’s Traditional Use Area. Therefore, we defer to the other tribes in the area. This letter shall conclude our consultation efforts.

Response: The City acknowledges the commenter’s statement that the project is not within the Agua Caliente Band of Cahuilla Indians’ (Tribe) Traditional Use Area, that the Tribe defers to other tribes in the area, and that the comment letter concludes the Tribe’s consultation efforts. This comment does not raise an issue with the analysis of the Draft EIR, and no further response is necessary.

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COMMENT LETTER NO. 2

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Response No. 2
Jackie Vega, Urban Regional Planner II
Riverside County Airport Land Use Commission
June 18, 2024
Comment 2-1: Please note that the proposed project is located outside the AIA, and review by ALUC is only required if the project proposes a legislative action.

Response: The commenter notes that the proposed project is located outside the Airport Influence Area (AIA), and review by ALUC is only required if the project proposes a legislative action. Since the project is located outside the AIA and does not propose a legislative action, no further response is necessary.

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COMMENT LETTER NO. 3

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Response No. 3
Mauricio Alvarez, MBA, Planning Analyst
Riverside Transit Agency
June 27, 2024
Comment 3-1: Recommend providing either a sidewalk or multi-trail pathway to connect to the existing sidewalk on River Road, near Sundance Lane.

Response: The commenter recommends that a sidewalk or multi-trail pathway connect to the existing sidewalk on River Road, near Sundance Lane. Section 3.0, Project Description, under “Circulation Plan” and “Equestrian Trail Improvements”, discusses that the project proposes a 12-foot multi-use trail on the easterly side of River Road along the project boundary as part of the improvements being made to River Road; please refer to Figure 3-11, Conceptual Site Plan, of the Draft EIR for details on the multitrail pathway.

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COMMENT LETTER NO. 4

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Response No. 4
Dave Kereazis, Associate Environmental Planner | HWMP-Permitting Division – CEQA Unit Department of Toxic Substances Control
July 2, 2024
Comment 4-1: The Department of Toxic Substances Control (DTSC) recommends the City of Norco utilizing an approved oversight on the Certified Local Agencies list or enter into DTSC’s Standard Voluntary Agreement (SVA) program so a proper evaluation of the project is completed.

Response: The City of Norco will utilize an approved oversight on the Certified Local Agencies list as well as the City’s demolition procedures; please refer to Section 4.9, Hazards and Hazardous Materials, under IMPACT HAZ-2, Mitigation Measures HAZ-2 and HAZ-3, which discuss utilizing acceptable local agency sampling standards as well as proper procedures for disposal of contaminants.

Comment 4-2: If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual.

Response: Section 4.9, Hazards and Hazardous Materials, under IMPACT HAZ-2, discusses that the Phase I Environmental Site Assessment (ESA) prepared on October 7, 2021, stated that “no potential lead-based paint was noted; however, based on the construction period it is possible such materials may be present.” Since the existing buildings on the project site were constructed during a period where asbestos containing building materials (ACMs) and lead based paints (LBPs) were commonly used, they could inadvertently be released into the air during demolition activities. To avoid the potential release of asbestos, an asbestos, lead paint and polychlorinated biphenyl caulk survey should be conducted for structures and sampling around the area of those buildings/structures proposed for demolition in compliance with California environmental regulations and policies and the DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual; Mitigation Measure HAZ-1 has been added. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

Comment 4-3: That all imported soil and fill material should be tested to ensure any contaminants of concern are within DTSC’s and U.S. Environmental Protection Agency Regional Screen Levels for the intended land use. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material meets screening levels outlined in DTSC's PEA Guidance Manual for the intended land use. The soil sampling should include analysis based on the source of the fill and knowledge of the prior land use.

Response: The project would import approximately 48,400 cubic yards of material. Mitigation Measure HAZ-4 has been added to ensure that imported soil and fill are free of any contaminants of concern

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and meet the DTSC’s and U.S. Environmental Protection Agency Regional Screen Levels for the intended land use. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

Comment 4-4: When agricultural crops and/or land uses are proposed or rezoned for residential use, a number of contaminants of concern can be present. The Lead Agency shall identify the amounts of Pesticides and Organochlorine Pesticides (OCPs) historically used on the property. If present, OCPs requiring further analysis are Dichlorodiphenyltrichloroethane, toxaphene, and dieldrin. Additionally, any level of arsenic present would require further analysis and sampling and must meet Human Health Risk Assessment Note Number 3 approved thresholds outlined in the PEA Guidance Manual. If they do not, remedial action must take place to mitigate them below those thresholds.

Response: Phase I and Phase II ESAs have been completed for the project by TA-Group DD. Section 4.9, Hazards and Hazardous Materials, under “Phase II Environmental Site Assessment”, discusses that the Phase I ESA identified the presence of Recognized Environmental Conditions (REC) at the property.

These included the potential presence of hydrocarbon/solvent spillage at a maintenance barn, and the potential for transite in irrigation water conveyance piping. Based on these issues, the Phase I ESA recommended soil gas, soil sampling, and hand excavation. For the Phase II ESA sampling results, TAGroup DD performed limited surficial sampling for organochlorine pesticides on the overall property, as well as hand auger sampling at hydrocarbon-stained soil located near a maintenance building.

Concrete piping was also exposed, examined, and sampled.

Section 4.9, Hazards and Hazardous Materials, under “Phase II Sampling Results” as well as under IMPACT HAZ-2, discusses that soil samples collected in the maintenance shed did not contain chlorinated or fuel-related volatile organic compounds (VOC). Only low levels of diesel range hydrocarbons were reported in one shallow sample.

Five (5) samples found at the subject site contained dichlorodiphenyldichloroethylene (DDE) exceeding California’s conservative screening guidance for future residential uses. The average of the 5 DDE values reported (6.5, 11, 11, 15, 38) was 16 mg/kg. Three locations did not report DDE.

The total lead found in all pesticide samples were substantially below the 50 mg/kg that typically triggers additional analysis for leachable components.

The total arsenic found in 5 of the 8 pesticide samples were below 6 mg/kg. The general screening value utilized in California is derived from the Kearny Study, which found that 12 mg/kg is an average background level in the State.

To identify the amounts of pesticides and organochlorine pesticides (OCPs) historically used on the property, the Phase II ESA requires that substantial additional sampling be conducted following demolition to provide a more reliable dataset to evaluate the extent, depth, and distribution of DDE.

Following additional sampling, recommendations can be made regarding remediation and/or other mitigation and/or sampling options; refer to Mitigation Measure HAZ-2.

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Comment 4-5: Additional chemicals of concern may be found in mixing/loading/storage areas, drainage ditches, farmhouses, or any other outbuildings and should be sampled and analyzed. If smudge pots had been routinely utilized, additional sampling for Polycyclic Aromatic Hydrocarbons and/or Total Petroleum Hydrocarbons may be required.

Response: Phase I and Phase II ESAs have been completed for the project. Please refer to Response to Comment 4-4 above.

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COMMENT LETTER NO. 5

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Response No. 5
Kevin Shin, Deputy Fire Marshal
CAL FIRE – Riverside Unit, Riverside County Fire Department July 5, 2024
Comment 5-1: The Fire Planning Division within the Riverside County Fire Department currently has no comments. However, this project may undergo further review to assess potential cumulative impacts on the Fire Department’s ability to maintain an acceptable level of service. Fire Planning may impose additional requirements to mitigate these impacts at a later time.

Response: Comment noted. No further response is necessary.

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COMMENT LETTER NO. 6

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Response No. 6
Elsa McKinney, Engineering Tech 1 | Development Review
Riverside County Flood Control & Water Conservation District July 11, 2024
Comment 6-1: The Riverside County Flood Control & Water Conservation District would like to add Amy McNeill, Elsa McKinney and William (Michael) Cornelius to the City’s distribution list for Flood Control in order to ensure a timely response if someone is out of the office.

Response: The City of Norco’s distribution list has been updated to include the following: Amy McNeill ([email protected]), Elsa McKinney ([email protected]), and William (Michael) Cornelius ([email protected]).

Comment 6-2: The Riverside County Flood Control and Water Conservation District (District) does not usually review land divisions/land use cases or provide State Division of Real Estate letters/flood hazard reports for projects that are located within incorporated cities.

This project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed.

Response: Comment noted. No further response is necessary.

Comment 6-3: The District’s previous comments dated July 17, 2023, are still valid.

Response: Comment noted. The District’s previous comments dated July 17, 2023, were received and included in Section 2.0, Introduction, in Table 2-1, Summary of NOP Comments, of the Draft EIR. No further response is necessary.

Comment 6-4: This project may need to obtain an applicable National Pollutant Discharge Elimination System (NPDES) permit coverage from the State Water Resources Control Board or the California Regional Water Quality Control Board. Clearance for grading, recordation, or other final approval should not be given until the City has determined that the project has been granted a permit or is shown to be exempt.

Response: Section 4.10, Hydrology and Water Quality, under subheading IMPACT HWQ-1, discusses that the proposed project would be regulated under NPDES Municipal Stormwater Permits issued by the Santa Ana Regional Water Quality Control Board. The proposed project would be required to comply with City of Norco Municipal Code Chapter 15.70 Stormwater/Urban Runoff Management and Discharge Controls requirements, which ensures the “future health, safety and personal welfare of City residents” by reducing stormwater pollutants, eliminating illegal stormwater connections and discharges, and regulating discharged non-stormwater into the drainage system.

During construction, there would be the potential that degraded surface water runoff generated from the construction site could be conveyed into local drainage facilities. Depending on the constituents in the surface water, the water quality of the project area surface water bodies could be reduced, which could conflict with beneficial uses established for the project area surface water bodies. The proposed project would disturb more than one acre of area and would therefore be required to obtain a NPDES State General Construction Permit from the State Water Resources Control Board. In accordance with

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the State General Construction Permit, the project Applicant would be required to file a Notice of Intent (NOI) to the Storm Water Report Tracking System and obtain a waste discharger identification number from the State Water Resources Control Board. Additionally, the General Construction Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP).

The SWPPP would identify BMPs to minimize degraded surface water runoff impacts. Such measures would include a site map that shows the construction site perimeter, existing and proposed buildings, parking areas, roadways, storm drain collection and discharge points before and after construction.

Additionally, structural BMPs such as placement of sandbags or wattles near drainage inlets, use of rumble racks or wheel washers or other measures would be implemented to avoid sediment transport.

The SWPPP would be reviewed and approved by the City of Norco for water quality construction activities onsite. With compliance with the NPDES General Construction Permit requirements, potential short-term construction related impacts to water quality would be less than significant.

Comment 6-5: If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the City should require the applicant to provide all studies, calculations, plans, and other information required to meet FEMA requirements, and should further require that the applicant obtain a Conditional Letter of Map Revision (CLOMR) prior to grading, recordation, or other final approval of the project and a Letter of Map Revision (LOMR) prior to occupancy.

Response: According to FEMA Map No.06065CO687G (refer to Figure 4.10-3, National Flood Hazard Map, of the Draft EIR), effective December 3, 2009, the project site is in Zone X, an area subject to minimal flooding. West of Bluff Street, a small strip of area is subject to a 0.2% Annual Flood Hazard and the Santa Ana River is designated as a Special Flood Hazard Area. The project boundary does not involve a FEMA mapped floodplain.

Comment 6-6: The project proponent shall bear the responsibility for complying with all applicable mitigation measures defined in the California Environmental Quality Act (CEQA) document (i.e., Negative Declaration, Mitigated Negative Declaration, Environmental Impact Report) and/or Mitigation Monitoring and Reporting Program, if a CEQA document was prepared for the project. The project proponent shall also bear the responsibility for complying with all other federal, state, and local environmental rules and regulations that may apply.

Response: The project will comply with all applicable mitigation measures in the Environmental Impact Report as well as in the Mitigation Monitoring and Reporting Program prepared for the project. In addition, the project will comply with all other federal, state, and local environmental rules and regulations that may apply.

Comment 6-7: If a natural watercourse or mapped floodplain is impacted by this project, the City should require the applicant to obtain a Section 1602 Agreement from the California Department of Fish and Wildlife and a Clean Water Act Section 404 Permit from the U.S. Army Corps of Engineers, or written correspondence from these agencies indicating the project is exempt from these requirements. A Clean Water Act Section 401 Water Quality Certification may be required from the local California Regional Water Quality Control Board prior to issuance of the Corps 404 permit.

Response: Section 4.4, Biological Resources, Subsection 4.4.2, Environmental Setting, under subheading JURISDICTIONAL WATERS, discusses that there are no streambed or drainage features

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containing waters of the United States or waters of the State within the Project Footprint. According to FEMA Map No.06065CO687G (refer to Figure 4.10-3, National Flood Hazard Map, of the Draft EIR), effective December 3, 2009, the project site is in Zone X, an area subject to minimal flooding. West of Bluff Street a small strip of area is subject to a 0.2% Annual Flood Hazard and the Santa Ana River is designated as a Special Flood Hazard Area. The project boundary does not involve a FEMA mapped floodplain. Therefore, the project does not impact a natural watercourse or mapped floodplain. No further response is necessary.

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COMMENT LETTER NO. 7

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Response No. 7
Gustavo Gonzalez, AICP, Community Development Director
City of Eastvale
July 17, 2024
Comment 7-1: This project has the potential to generate traffic impacts in Norco and Eastvale.

According to the Riverside County Transportation Department’s Traffic Impact Analysis (TIA) Guidelines, the minimum area to be studied shall include any intersection of “Collector” or higher classification street, with “Collector” or higher classification streets, at which the proposed project will add 50 or more peak hour trips, not exceeding a 5-mile radius from the project site. The Transportation Department may require deviation from these requirements based on area conditions.

Response: This comment is acknowledged. The referenced Traffic Impact Analysis prepared by Linscott, Law and Greenspan, Engineers (LLG) did not incorporate analysis for intersections in the City of Eastvale and was not included as an Appendix in the DEIR because CEQA no longer requires level of service (LOS) analysis; however, CEQA does require Vehicle Miles Travelled (VMT) analysis which is included as Appendix J. The Traffic Impact Analysis was completed as part of the planning effort and the conclusion was that the projected 64 peak hour trips was below the Riverside County threshold of 100 peak hour trips. This result could be used by the City of Norco for future reference.

Comment 7-2: The City of Eastvale will be awaiting to review the Draft EIR for the JD Ranch Residential Project.

Response: The Notice of Availability (NOA) was sent via U.S. Postal Service Certified Mailing to the City of Eastvale Planning Department (Tracking Number 9589 0710 5270 0888 0231 50) on June 5, 2024 and signed by a City Employee on June 10, 2024 at 3:28 PM. The NOA contained the 45-day public review period (June 6, 2024 to July 22, 2024) and that the Draft EIR was available for download and review at http://www.bit.ly/NOAJDRANCH during the review period. This link was only active during the 45-day public review period.

Comment 7-3: Eastvale staff would like to request a meeting to discuss these comments and potential solutions that address concerns for both cities.

Response: This comment is acknowledged. The City of Norco will reach out to the City of Eastvale to discuss this project.

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COMMENT LETTER NO. 8

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Response No. 8
Katherine Avila, Assistant Planner
Riverside County Department of Waste Resources
July 18, 2024
Comment 8-1: The waste hauler may utilize the El Sobrante, Lamb Canyon, and/or the Badlands Landfill for disposal. Updated descriptions of the local landfills, inclusive of 2023 yearend landfill information is provided.

Response: Comment noted. The Final EIR will be updated to reflect the 2023 year-end landfill information. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

Comment 8-2: Consider incorporating a measure to help reduce the Project’s anticipated solid waste impacts and enhance efforts to comply with the State’s mandate (AB 75) of 50% solid waste diversion from landfilling and demonstrate compliance with SB 1383 which establishes regulations to reduce organics waste disposal and went into effect on January 1, 2022.

Response: Comment noted. Section 4.19, Utilities and Service Systems, under IMPACT USS-4, has a discussion that the handling of all debris and waste generated during construction of the project would be subject to the 2022 CALGreen requirements and the California Integrated Waste Management Act of 1989 (AB 939) requirements for salvaging, recycling, and reuse of materials from construction activity on the project site. Furthermore, pursuant to the Norco Municipal Code Section 6.42.310 (Construction and Demolition Debris Recycling), the project would be required to submit a construction and demolition waste management report on a form approved by the City, which must meet the requirements of the City and CALGreen.

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COMMENT LETTER NO. 9

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Response No. 9
Frank Martinez, Fire Safety Specialist
Riverside County Fire Department – Office of the Fire Marshal, City of Norco July 22, 2024
Comment 9-1: Riverside County Fire Department has been abbreviated as RCFD. Please change to RVCFD where applicable.

Response: Comment noted. RCFD has been changed throughout Section 4.15, Public Services, the document to RVCFD. Please see Section 3.0, Errata, for all the changes throughout the Draft EIR.

Comment 9-2: Section 4.15.3 references the Uniform Fire Code. The California Fire Code is modeled from the International Fire Code and amended through the City of Norco Municipal Code. Please correct or clarify.

Response: Comment noted. The International Fire Code has been added and the Uniform Fire Code language updated to reflect that it is modeled from the International Fire Code and amended through the City of Norco Municipal Code. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

Comment 9-3: Sheet 4.13-8 under Policy 2.3.1c, references the required fire-flow. The fire-flow should also include the required minimum residual pressure of 20 PSI and a duration of not less than 1 hour. Please correct or clarify.

Response: Comment noted. Policy 2.3.1c appears as it does in the City’s current General Plan and cannot be changed; however, a note has been added referencing the RVCFD fire flow and residual water pressure requirements. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

Comment 9-4: Sheet 4.20-4 references County of Orange. Please correct to County of Riverside or clarify.

Response: Comment noted. Reference has been revised to County of Riverside. Please refer to Section

3.0, Errata, for the revisions to the Draft EIR.

Comment 9-5: Sheet 4.20-4 references OCFA Guidelines. Please correct to RVCFD Guidelines, Standards, and Technical Policies.

Response: Comment noted. Reference has been revised to RVCFD Guidelines, Standards, and Technical Policies. Please refer to Section 3.0, Errata, for the revisions to the Draft EIR.

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COMMENT LETTER NO. 10

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Response No. 10
Sue Paterson
Resident
June 19, 2024
Comment 10-1: I live directly behind the JD dairy and had a lovely friendship with ‘Farmer Jerry’ as we called him. But I have to question the Reason to rezone. If I want to sell my property for 2.4 million dollars but can’t find anyone to buy it because it’s way overpriced for the neighborhood, then I need to put my price down to something reasonable. It sounds like JD Ranch, having tried to sell this property for $12 million for the last 10 years, is now wanting the City of Norco (that’s me and all my neighbors) to change the zoning laws so they can Still get their out of reason price for the property. And I fully understand that City Council will want to do that for them for added tax benefits.

But looking at the plans, it adds Nothing to the neighborhood. No park, no arena. If even some of the 68 houses do get the One horse they are allotted on their property, they will be headed for Ted Brooks park arena...even 30 more horses coming there will make a traffic jam. I don’t understand why JD Ranch wasn’t required to provide Something with all that property, not just small houses on non-half acre lots! Response: This comment is acknowledged. The City of Norco decision makers will consider all comments on the proposed project. Section 4.16, Recreation, under subheading “IMPACT REC-1 and IMPACT REC-2”, discusses that the project proposes to construct critical missing links to the City’s trail system with a 12-foot trail on River Road and on Bluff Street. Both trails would connect to existing City trails. Additionally, within the project, a 12-foot trail is proposed that would connect to the proposed trails along River Road and Bluff Street, and there would be a 15-foot pedestrian access (Lot F), between Lots 10 and 11, to Sundance Park; refer to Figure 3-9, Tentative Tract Map, of the Draft EIR.

The overall intent of the project is to close critical gaps in the City’s equestrian/pedestrian trail system as well as create an equestrian community that is unified by tree lined equestrian trails that circulate through the community connecting residents to the City’s equestrian heritage. The project also incorporates a comprehensive equestrian trail network within the development that will connect to existing City equestrian trails (refer to Figure 3-10, Equestrian Trail Plan, of the Draft EIR), which will provide additional recreational opportunities and help distribute equestrian activity throughout the area.

In accordance with Norco’s Municipal Code Section 17.14.16 (Disposition of Fees), the project will contribute Quimby Act fees that will be allocated toward improvements of existing recreational facilities, which could include equestrian amenities. Through the combination of new trail infrastructure and required park fee contributions, the City would have increased funding to mitigate future arena maintenance.

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Comment 10-2: As to the land swap...that has me nervous also! The plan says the land directly behind me, under the electrical lines, will be swapped to the City. The chain link fence will stay. I’ve been told it will probably be a storage yard for the City. I can only imagine what my view will be soon.

Response: This comment is acknowledged. As discussed in Section 1.0, Executive Summary, under subheading 1.3, Project Summary, as part of the Memorandum of Understanding with the City of Norco, TACRD proposes to deed 6.78 acres of their property to the City of Norco as open space. In exchange, the City of Norco would deed 8.20 acres of the City of Norco owned parcel to TACRD Investment to be incorporated into the proposed project. This land exchange allows for the construction of critically missing links to the Norco Equestrian Trail System along Bluff Street and River Road. It also facilitates completion of the full width of the River Road frontage up to the Bluff Street intersection. The City of Norco decision makers will consider all comments on the proposed project.

Comment 10-3: I am not happy with what the City and JD Ranch have planned for my and my neighbor’s future.

Response: This comment is acknowledged. The comment does not raise new environmental information or directly challenge information provided in the Draft EIR. The City of Norco decision makers will consider all comments on the proposed project.

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SECTION 3.0 ERRATA

3.1 INTRODUCTION
This section contains revisions to the Draft EIR based upon the following:
 Additional or revised information required to prepare a response to a specific comment;  Applicable updated information that was not available at the time of the Draft EIR publication; and/or
 Typographical errors.

This section also includes additional mitigation measures to fully respond to the commenters’ concerns as well as provide additional clarification to mitigation requirements included in the Draft EIR. The provision of these additional mitigation measures does not alter any impact significance conclusions as disclosed in the Draft EIR.

3.2 REVISIONS TO THE DRAFT EIR
As a result of continued coordination between the City of Norco and TACRD, the Tentative Tract Map (TTM) has been amended to fully realize the goals and policies of the City’s General Plan. A key revision includes retaining Lots 1-13, which abut existing residential neighborhoods, as A-1-20 zoning (Agricultural - Low Density, 20,000 square foot minimum lot size), ensuring appropriate transitions and compatibility with adjacent land uses. Additional revisions include a reduction in residential units from 69 to 64, modified land exchange areas between JD Ranch and the City, adjusted lot configurations and acreages for infrastructure and open space, and revised lot letter designations. Table 3-1, Comparison of Original and Revised Tentative Tract Map, provides a detailed comparison of the original (May 2024) and revised (May 2026) TTM. These revisions are incorporated throughout the Revised Public Review Draft EIR; corresponding text and figure revisions not specifically included in this Errata shall be assumed to reflect the revised TTM. Technical studies prepared for the project have not been revised. The TTM revisions, which include a reduction from 69 to 64 residential lots, would not result in new or substantially more environmental impacts than those previously analyzed. Environmental impacts identified in the technical studies would remain unchanged or would be reduced due to the decreased project land use intensity.

Table 3-1
Comparison of Original and Revised Tentative Tract Map
Item Original TTM
dated 5/29/2024
Revised TTM
dated 7/10/2026
Residential Units 69 lots 64 Lots
Project Gross Acreage 37.84 acres 37.84 acres
City Public Yard “Not A Part” 3.49 acres 3.45 acres
JD Ranch Land Exchange to City 6.78 acres 3.29 acres
City Land Exchange to JD Ranch 8.20 acres 8.24 acres
New Single-Family Residential Lots 1 – 68

17.61 acres
Lots 1 – 63

21.23 acres
Existing Single-Family Residence Lot 69

1.02 acres
Lot 64

1.01 acres

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Item Original TTM
dated 5/29/2024
Revised TTM
dated 7/10/2026
Water Quality Infiltration Basin and Storm Detention Basin Lot A

0.90 acres
Lot G

1.01 acres
Open Space Deeded to City Lot B

6.78 acres
Lot J

3.29 acres
Sewer Lift Station Lot C

0.13 acres
Lot H

0.13 acres
Landscape Open Space along River Road Lot D

0.06 acres
Lot L

0.06 acres
Landscape Open Space along Bluff Street Lot E

0.66 acres
Lot K

0.67 acres
Trail into Sundance Park
Lot F
(between Lots 10 & 11)

0.04 acres
Lot I
(between Lots 8 & 9)

0.12 acres
Streets “A” through “F” 6.31 acres Lots “A” through “F”

6.03 acres
Bluff Street 0.16 acres 0.16 acres
River Road 0.68 acres 0.68 acres
Changes to the Draft EIR are noted below. A double-underline indicates additions to the text; strikethrough indicates deletions to the text. Changes have been analyzed and responded to in Section

2.0, Response to Comments, of the Final EIR. The changes to the Draft EIR do not affect the overall conclusions of the environmental document. Changes are listed by page and, where appropriate, by paragraph. All mitigation measure modifications have been reflected in Section 4.0, Mitigation Monitoring and Reporting Program, of the Final EIR.

SECTION 1.0 EXECUTIVE SUMMARY
The entire section under the subheading “MEMORANDUM OF UNDERSTANDING” of Section 1.3, Project Summary, beginning on page 1-2 of the Draft EIR is amended as follows:

As part of the Memorandum of Understanding with the City of Norco, TACRD proposes to deed

3.296.78 acres of their property to the City of Norco as open space. In exchange, the City of Norco would deed 8.240 acres of the City of Norco owned parcel to TACRD Investment to be incorporated into the proposed project; refer to Table 1-1, Parcel Configuration Acreage. Figure 3-1, Parcel Configuration, depicts the land swap between TARCD and the City of Norco. This land exchange allows for the construction of critically missing links to the Norco Equestrian Trail System along Bluff Street and River Road. It also facilitates completion of the full width of the River Road frontage up to the Bluff Street intersection.

Table 1-1
Parcel Configuration Acreage
APN Owner Total
Acreage Land Swap Acreage Difference Total Acreage Remaining After Land Swap APN 121-110-001 City of Norco 11.69 acres 8.240 acres to TARCD 3.459 acres 3.459 + 3.296.78 =

6.7410.27 acres
APN 121-110-003 TARCD Investment 26.15 acres 3.296.78 acres to City 22.8619.37 acres

22.8619.37 + 8.240 =

31.1027.57 acres

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With the Memorandum of Understanding in place, the total gross acreage shown on Tentative Tract Map (TTM) No. 38330 is 37.84 acres. The remaining 3.459 acres of APN 121-110-001 (City-owned reservoir site) is part of the Tentative Tract Map No. 38330 Entitlement; however, there would be no improvements to this area and is depicted on Figure 3-9, Tentative Tract Map, as “Not A Part”. The

3.296.78 acres deeded to the City would have very limited grading to be completed in the future for drainage mitigation. Therefore, the EIR will analyze impacts for development improvements to

31.1027.57 acres which will be referred to as the proposed project.

The entire section under the subheading “PROPOSED PROJECT” of Section 1.3, Project Summary, beginning on page 1-2 of the Draft EIR is amended as follows:

The proposed project proposes approval of a General Plan Amendment, a Zone Change, and a Tentative Tract Map No. 38330 (on 37.84 acres), to allow for the development of a 648-lotunit singlefamily detached housing project consisting of 50 lots aton a minimum of 10,000 square feetfoot lots in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of an existing approximate 1.01 acre single-family residence. The proposed project would also retain the existing single-family detached home “in place” (Lot 649) and the City’s Water Quality Infiltration Basin and Storm Detention Basin (Lot GA); refer to Figure 3-9, Tentative Tract Map. The remaining 3.459 acres of APN 121-110-001 shown on Figure 3-9 is depicted as “Not A Part” of the proposed project but is part of the Tentative Tract Map and would remain as a City of Norco public facility.

In addition, the proposed project would demolish the existing dairy facilities and remove three power poles along River Road, one pole within Lot 649 and two poles within APN 121-110-001. It has yet to be determined if five poles along Bluff Street would be undergrounded.

The mitigation measures under “Section 1.5, Environmental Issues/Mitigation Summary” have been revised in the table as follows:

EIR
Section Impact Statement Mitigation Measure Significance After Mitigation

4.5 Cultural Resources
Impact CR-1: Cause a substantial adverse
change in the significance of a historical
resource pursuant to Section 15064.5?
No mitigation measures are required. Less Than Significant Impact CR-2: Cause a substantial adverse
change in the significance of an
archaeological resource pursuant to Section
15064.5?
CR-1: Prior to the issuance of grading
permits, the project Applicant/Developer
shall retain a qualified Archaeologist to
monitor all ground disturbing activities
related to the development of the site,
including but not limited to, demolition,
pavement removal, potholing, auguring,
clearing, grubbing, tree removal, boring,
grading, excavation, drilling, and trenching
for both onsite and offsite improvements.

CR-2: Prior to the issuance of grading
permits, the Archaeologist, in consultation
with the Tribe(s) and the City of Norco, shall
develop a Cultural Resources Monitoring
Plan (CRMP) to address the details, timing,
and protocols of all cultural resources
activities that occur on the project site. At
Less Than Significant
With Mitigation
Incorporated

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Section Impact Statement Mitigation Measure Significance After Mitigation the project pre-grading meeting, the
Archaeologist, the Native American Tribal
Representative(s), the Applicant/Developer,
and the excavation and grading Contractor
shall discuss appropriate grading and
ground disturbing methods within
archaeologically and culturally sensitive
areas on the project site pursuant to the
CRMP.

CR-3: Pursuant to the Cultural Resources
Monitoring Plan, the Archaeologist shall
actively monitor project-related grading and
in the event that cultural resources are
discovered, shall have the authority to
temporarily divert, redirect, or halt grading
activity to allow recovery of cultural
resources.

CR-4: The Archaeological monitor will
complete daily monitoring logs that
describe daily ground-disturbing activities,
the type of construction activities
performed, locations of ground- disturbing
activities, soil types, cultural-related
materials, and any other facts, conditions,
materials, or discoveries. Monitor logs will
identify and describe any discovered
archaeological and/or tribal cultural
resources, including but not limited to,
Native American cultural and historical
artifacts, remains, places of significance,
etc., (collectively, tribal cultural resources,
or “TCRs”), as well as any discovered Native
American (ancestral) human remains and
burial goods. Non-Tribal, historic-era
cultural resources will also be documented.

Copies of monitoring logs will be provided to
the project applicant/developer/lead
agency upon written request.

CR-5: At the completion of onsite and offsite
ground-disturbing activities, a Phase IV
Monitoring Report shall be prepared by the
Archaeologist and submitted to the City
documenting all monitoring activities
conducted by the project Archaeologist and
Native American Tribal Representative(s).

All reports produced will be submitted to
the City of Norco, the South Coastal
Information Center, San Diego State
University, and the consulting Tribe(s).

CR-1: Prior to the issuance of grading
permits, the Applicant shall retain a
qualified Archaeologist and Native
American Tribal representative(s) to
monitor grading and other ground
disturbances related to site development.

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation The Archaeologist, in consultation with the
Tribe(s) and City, shall develop a Cultural
Resources Monitoring Plan (CRMP) to
address the details, timing, and protocols of
all cultural resources activities that occur on
the project site. At the project pre-grading
meeting, the Archaeologist, the Tribal
representative(s), the Applicant, and the
excavation and grading contractor shall
discuss appropriate grading and ground
disturbing methods within archaeologically
and culturally sensitive areas on the project
site pursuant to the CRMP. Should the
Archaeologist, after consultation with the
consulting Tribe(s), find the potential exists
for impacts to archaeological resources,
cultural resources and/or sacred sites, the
archaeologist and the Native American
tribal representative(s) shall actively
monitor project-related grading and in the
event that cultural resources are
discovered, shall have the authority to
temporarily divert, redirect, or halt grading
activity to allow recovery of archaeological
and/or cultural resources. All cultural
material will be temporarily curated on the
project site until final disposition is
determined. The Applicant shall relinquish
ownership of all cultural material, including
sacred items, burial goods, and all
archaeological artifacts and non-human
remains discovered to the consulting
Tribe(s) for final disposition. Leaving
artifacts in place (in situ) or reburial of them
on site are the preferred methods of
mitigation. Reburial shall not occur until all
cataloguing and basic recordation has been
completed.

CR-2: At the completion of grading,
excavation, and ground-disturbing activities
on the site, a Phase IV Monitoring Report
shall be submitted to the City documenting
all monitoring activities conducted by the
project archaeologist and Native Tribal
Monitor(s). All reports produced will be
submitted to the City of Norco, the Eastern
Information Center, University of California,
Riverside, and the consulting Tribe(s).

Impact CR-3: Disturb any human remains,
including those interred outside of
dedicated cemeteries?
CR-63: Section 7050.5 of the California
Health and Safety Code provides for the
disposition of accidentally discovered
human remains. Section 7050.5 states that,
if human remains are found, no further
excavation or disturbance of the site or any
nearby area reasonably suspected to overlie
Less Than Significant
With Mitigation
Incorporated

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation adjacent remains shall occur until the
county coroner has determined, within two
working days, the appropriate treatment
and disposition of the human remains. If the
coroner recognizes those remains to be
Native American or has reason to suspect
so, the coroner shall contact the Native
American Heritage Commission (NAHC)
within 24 hours.

Section 5097.98 of the PRC states that,
when the NAHC receives notification of a
discovery of Native American human
remains from the county coroner pursuant
to Section 7050.5 of the California Health
and Safety Code, the NAHC shall
immediately notify those persons it believes
to be most likely descended from the
deceased Native American. The Most Likely
Descendants (MLD) shall complete their
inspection within 48 hours of being granted
access to the site. The designated MLD
would then recommend, in consultation
with the property owner, the means for
treatment or disposition, with appropriate
dignity, of the human remains and any
associated grave goods.

4.9 Hazards and Hazardous Materials
Impact HAZ-1: Create a significant hazard to
the public or the environment through the
routine transport, use, or disposal of
hazardous materials?
No mitigation measures are required. Less Than Significant Impact HAZ-2: 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?
HAZ-1: Prior to demolition of the buildings,
the Applicant shall prepare an asbestos,
lead paint and polychlorinated biphenyl
caulk survey on the buildings and sampling
around the area of those buildings. In the
event asbestos containing building
materials, lead paint or polychlorinated
biphenyl caulk are identified, it shall be
removed and disposed of in accordance
with local, state, and federal regulations
under the guidance of a California
Occupational Safety and Health
Administration (Cal/OSHA) - Certified
Asbestos Consultant (CAC) and/or LeadRelated Construction Inspector/Assessor.

HAZ-21: Additional sampling shall be
conducted following demolition and prior to
construction to evaluate the extent, depth,
and distribution of dichlorodiphenyldichloroethylene (DDE). Following additional sampling, recommendations will
be made regarding remediation and/or
other mitigation and/or sampling options.

Less Than Significant
With Mitigation
Incorporated

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation HAZ-32: Undocumented fill is located on the
northern parcel. One of the following
options must be completed to mitigate this
REC prior to construction:
 The property owner can properly
dispose of the undocumented fill.
 The property owner can properly
evaluate the fill to document its
suitability for use at the site and provide
sampling rationale/standards with
sampling location and laboratory data
to Client for evaluation.
 Client can properly evaluate the fill
using EPA SW-846 or other acceptable
sampling guidance.

HAZ-4: Prior to import and placement on
the project site, all imported soil and fill
material shall be tested by a qualified
environmental professional to ensure any
contaminants of concern are within
Department of Toxic Substances Control's
(DTSC) and U.S. Environmental Protection
Agency Regional Screen Levels for the
intended land use. The environmental
professional shall collect and analyze
representative samples from the source
location of any soil or fill material proposed
for import, prior to its removal from the
source site. To minimize the possibility of
introducing contaminated soil and fill
material, there shall be documentation of
the origins of the soil or fill material and, if
applicable, sampling shall be conducted to
ensure that the imported soil and fill
material meets screening levels outlined in
DTSC’s Preliminary Endangerment
Assessment (PEA) Guidance Manual for the
intended land use. The soil sampling shall
include analysis based on the source of the
fill and knowledge of the prior land use. If
testing reveals contaminant concentrations
that exceed applicable DTSC and EPA
screening levels for the intended land use,
the soil or fill material shall be rejected and
shall not be imported to the project site.

The project Applicant shall then either: 1)
source alternative fill material and conduct
the required testing, or 2) implement
appropriate soil treatment measures at the
source location to reduce contaminant
concentrations below applicable screening
levels, as demonstrated through additional
testing. Documentation of all soil testing
results and any required treatment
measures shall be submitted to the City of

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation Norco for review and approval prior to
importing any soil or fill material to the
project site.

Impact HAZ-3: 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?
No mitigation measures are required. Less Than Significant Impact HAZ-4: 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?
No mitigation measures are required. No Impact
Impact HAZ-5: Impair implementation of or
physically interfere with an adopted
emergency response plan or emergency
evacuation plan?
No mitigation measures are required. Less Than Significant Impact HAZ-6: Expose people or structures,
either directly or indirectly, to a significant
risk of loss, injury or death involving
wildland fires?
No mitigation measures are required. Less Than Significant

4.13 Noise
Impact NOI-1: 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?
Implementation of the proposed project
would not result in significant temporary
construction noise impacts or long-term
operational noise impacts.

Project Design Feature NOI-1 has been
incorporated into the proposed project to
meet requirements of Policy 2.2.2a that
requires the submittal of a construction
noise reduction plan. It also addresses Policy

2.2.2b by requiring all construction
equipment to be equipped with mufflers
and engine shrouds and addresses Policy

2.2.2c that requires limitation of when
construction equipment and haul trucks
may operate. As such, with implementation
of Project Design Feature NOI-1, the
proposed project would be following the
construction noise standards provided in
General Plan Noise Element Policies 2.2.2a,

2.2.2b, and 2.2.2c.

PDF-NOI-1: Prior to the issuance of the
grading permit, the project applicant shall
submit a construction related noise
mitigation plan to the City for review and
approval. The plan shall depict the locations
of where construction equipment will
operate on the project site and how the
noise from the construction equipment will
be mitigated during construction of the
Less Than Significant

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation project, through use of the following
methods:

1. Construction activity, including
equipment start-up and use, and the
loading, unloading and handling of
materials, shall not commence before
6:30 AM, or continue beyond 7:00 PM,
on weekdays. No construction activity
for residential development projects
that consist of more than one unit is
permitted on Saturdays, Sundays, or
national holidays unless otherwise
permitted with conditions on
entitlements. The restrictions from
Saturdays, Sundays, and national
holidays shall not apply to singlebuilding permits for expansion and upgrade to existing buildings; however,
no such construction shall begin before
8:00 AM. Deviations from these hours
may be approved if the Conditions of
Approval allow and if approved by the
Community Development
Director;Restriction of use of
construction equipment and haul truck
operations between 7:00 PM and 7:00
AM, Monday through Friday and
between 7:00 PM and 8:00 AM on
Saturday and Sunday, unless specified
by permit for activities such as pouring
of concrete that may need to occur
outside of these hours;

2. Placement of temporary noise
attenuation fences around stationary
equipment (i.e., air compressors and
generators) that are used in close
proximity to sensitive receptors;

3. Placement of equipment storage and
staging areas as far away as practical
from sensitive receptors;

4. Limitation of construction equipment
idling time to less than 5 minutes per
occurrence; and,

5. Require the use of construction
equipment noise attenuation features
that include mufflers and engine
shrouds that are at least as effective as
the original manufacturer equipment.

Impact NOI-2: Generation of excessive
ground borne vibration or ground borne
noise levels?
No mitigation measures are required. Less Than Significant Impact NOI-3: For a project located within
the vicinity of a private airstrip of an airport
land use plan or, where such a plan has not
No mitigation measures are required. Less Than Significant

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EIR
Section Impact Statement Mitigation Measure Significance After Mitigation 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?

4.17 Transportation
Impact TRA-1: Conflict with a program plan,
ordinance or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
No mitigation measures are required. Less Than Significant Impact TRA-2: Conflict or be inconsistent
with CEQA Guidelines Section 15064.3,
subdivision (b)?
No mitigation measures are required.No
feasible mitigation measures would be
available to reduce the impact; therefore,
the impact would be significant and
unavoidable.

Less Than Significant
and Unavoidable
Impact
Impact TRA-3: Substantially increase
hazards due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g.,
farm equipment)?
TRANS-1: A Traffic Management Plan shall
be prepared for temporary construction
within the road right-of-way to ensure
pedestrian, equestrian and vehicular safety
and shall be approved prior to issuance of
an encroachment permit.

Less Than Significant
With Mitigation
Incorporated
Impact TRA-4: Result in inadequate
emergency access?
No mitigation measures are required. Less Than Significant

4.18 Tribal Cultural Resources
Impact TCR-1: Cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code
Section 21074 as either a site, feature,
place, cultural landscape that is
geographically defined in terms of the size
and scope of the landscape, sacred place, or
object with cultural value to a California
Native American tribe, and that is listed or
eligible for listing in the California Register
of Historical Resources, or in a local register
of historical resources as defined in Public
Resources Code Section 5020.1(k)?
Mitigation Measures CR-1 and CR-2 are
required.

TCR-1: Prior to the issuance of grading
permits, the project Applicant/Developer
shall retain a representative from each of
the Native American Tribes that requested
to monitor all ground disturbing activities
related to the development of the site
under AB 52, including but not limited to,
demolition, pavement removal, potholing,
auguring, clearing, grubbing, tree removal,
boring, grading, excavation, drilling, and
trenching for both onsite and offsite
improvements. Prior to the issuance of
grading permits, the project
applicant/developer shall enter into
Monitoring Agreements with the following
tribes:

1. Cahuilla Band of Indians

2. Gabrieleño Band of Mission Indians –
Kizh Nation

3. Gabrieleño/Tongva San Gabriel Band of
Mission Indians

4. Gabrielino Tongva Indians of California
Tribal Council

5. Gabrielino-Tongva Tribe

6. Morongo Band of Mission Indians

7. Pechanga Band of Luiseno Indians

8. Rincon Band of Luiseno Indians
All tribes are invited to monitor the entire
duration of grading; however, the Applicant
will only be required to pay up to two
Less Than Significant
With Mitigation
Incorporated

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Section Impact Statement Mitigation Measure Significance After Mitigation monitors per day pursuant to a rotating
monitoring payment schedule.

These Agreements shall be submitted to the
City of Norco prior to the earlier of the
commencement of any ground-disturbing
activity, or the issuance of any permit
necessary to commence a grounddisturbing activity.

TCR-2: Pursuant to the Cultural Resources
Monitoring Plan (CRMP), the Native
American Tribal Representatives shall
actively monitor project-related grading and
in the event that a tribal cultural resource(s)
(TCRs) is discovered, shall have the
authority to temporarily divert, redirect, or
halt grading activity to allow recovery of
archaeological and/or cultural resources. All
TCRs will be temporarily curated on the
project site until final disposition is
determined. The Applicant/Developer shall
relinquish ownership of all TCRs, including
sacred items, burial goods, and all
archaeological artifacts and non-human
remains discovered to the consulting Tribes
for final disposition. Leaving artifacts in
place (in situ) or reburial of them onsite are
the preferred methods of mitigation.

Reburial shall not occur until all cataloguing
and basic recordation has been completed
and notice to proceed by the Archaeologist
and Native American Tribal Representatives
is given. If the eight Tribes cannot come to
an agreement on the final disposition of the
TCRs, the Native American Heritage
Commission will be asked to mediate the
dispute.

TCR-3: Onsite Tribal monitoring shall
conclude upon either of the following
occurrences (1) written confirmation to the
Archaeologist and Native American Tribal
Representative(s) from a designated point
of contact for the project Applicant/
Developer/Lead Agency that all grounddisturbing activities and phases in native soil at the project site or in connection with the
project are complete; or (2) a determination
and written notification by the
Archaeologist and Native American
Representative(s) to the Project Applicant/
Developer/Lead Agency that no future,
planned construction activity and/or
development/construction phase at the
project site possesses the potential to
further impact any tribal resources.

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Section Impact Statement Mitigation Measure Significance After Mitigation TCR-4: Unanticipated Discovery of Tribal
Cultural Resource Objects (NonFunerary/Non-Ceremonial): Upon discovery of any cultural resources/TCRs, all
construction activities in the immediate
vicinity of the discovery shall cease (i.e., not
less than a radius of 50 feet) and shall not
resume until the discovered resource has
been fully assessed by onsite Archaeologist
and Native American Tribal
Representative(s). The Native American
Tribal Representative(s) shall retain all
discovered TCRs in the form and/or manner
the Tribe(s) deem appropriate, by the
Tribe(s) sole discretion, and for any purpose
the Tribe(s) deems appropriate, including
for educational, cultural and/or historic
purposes.

Impact TCR-2: 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 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 Resource Code Section 5024.1, the
lead agency shall consider the significance
of the resource to a California Native
American tribe.

Mitigation Measures TCR-1 throughand
TCR-42 are required as well as TCR-5.

TCR-5: Unanticipated Discovery of Human
Remains and Associated Funerary or
Ceremonial Objects: Native American
human remains are defined in Public
Resources Code (PRC) 5097.98 (d)(1) as an
inhumation or cremation, and in any state of
decomposition or skeletal completeness.

Funerary objects, called associated grave
goods in PRC Section 5097.98, are also to be
treated according to this statute. If Native
American human remains and/or grave
goods are discovered or recognized on the
project site, then PRC 5097.9 as well as
Health and Safety Code Section 7050.5 shall
be followed. Human remains and
grave/burial goods shall be treated alike per
California Public Resources Code section
5097.98(d)(1) and (2). Section 5097.98 of
the PRC states that, when the Native
American Heritage Commission (NAHC)
receives notification of a discovery of Native
American human remains from the county
coroner pursuant to Section 7050.5 of the
California Health and Safety Code, the NAHC
shall immediately notify those persons it
believes to be most likely descended from
the deceased Native American. The Most
Likely Descendants (MLD) shall complete
their inspection within 48 hours of being
granted access to the site. The designated
MLD would then recommend, in
consultation with the property owner, the
means for treatment or disposition, with
appropriate dignity, of the human remains
and any associated grave goods. Any
Less Than Significant
With Mitigation
Incorporated

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Section Impact Statement Mitigation Measure Significance After Mitigation discovery of human remains/burial goods
shall be kept confidential to prevent further
disturbance.

The first paragraph under the subheading “ALTERNATIVE 2 – EXISTING ZONING WITH NO LAND USE EXCHANGE” of Section 1.6, Summary of Project Alternatives, on page 1-22 of the Draft EIR is amended as follows:

Under Alternative 2, the site would be developed on 26.15 acres versus 31.1027.57 acres with the proposed project under its current Zoning designations. Under the current zoning, an estimated total of 4232 (net) dwelling units could be developed resulting in an increase ofwhich would create an estimated population of 139107 residents. There would be no exchange of parcels with the City of Norco and TACRD as shown on Figure 3-1, Parcel Configuration. Grading would occur on 26.15 acres.

The existing parcel, owned by the City of Norco, would continue to be used by the City as a spoils/staging yard, whereas if the land use exchange occurs, the site would be cleaned up at no cost to the Citydesignated as public lands/open space. There would be approximately 26 fewer units constructed to help meet the RHNA requirements.no opportunity for the City to meet regional housing needs, Without the project, no ability to build critical missing equestrian trail connections on Bluff Street and River Road would not be constructed and, no roadway improvements on River Road and landscaping on River Road and Bluff Street would not be constructedinstalled. Alternative 2 met two of the four project objectives and would not result in a significant unavoidable adverse impact.

The first, third and fifth paragraphs under the subheading “ENVIRONMENTALLY SUPERIOR/PREFERRED ALTERNATIVE” of Section 1.6, Summary of Project Alternatives, on page 1-22 of the Draft EIR is amended as follows:

CEQA requires that EIRs identify the Environmentally Superior Alternative and discuss the facts that support that selection. The Environmentally Superior Alternative is typically the Alternative that results in the least amount of significant unavoidable adverse impacts. For the proposed project, oneno significant unavoidable adverse impacts waswere identified. for transportation associated with vehicle miles travelled (VMT). The proposed project would also result in impacts to biological resources, cultural resources, geology/soils, hazards/hazardous materials, transportation, tribal cultural resources and utilities/service systems which were determined to be less than significant with mitigation. The remaining environmental topics were determined to either have less than significant impacts or no impacts with implementation of standard regulations and requirements.

Alternative 2 Existing Zoning With No Land Use Exchange was determined to result in no significant unavoidable impacts. While Alternative 2 would still result in increased VMT, impacts were determined to be less than significant because there would be a reduction from 648 units to 2632 (net) dwelling units which would be under the VMT screening threshold. Alternative 2 would also result in impacts to biological resources, cultural resources, geology/soils, hazards/hazardous materials, transportation, tribal cultural resources and utilities/service systems, which would also be less than significant with mitigation. The remaining environmental topics would also either have less than significant impacts or no impacts with implementation of standard regulations and requirements.

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Because both the proposed project and Alternative 2 would not result in a significant unavoidable adverse impact, and therefore,Alternative 2 would not be considered environmentally superior to the proposed project; however, Alternative 2 would only meet two of the four project objectives. Two critical objectives that would not be achieved include construction of critical equestrian trail linkages and the completion of River Road improvements and landscaping along the River Road and Bluff Street frontages. Because Alternative 2 would only partially meet the project objectives, it is not considered the Preferred Alternative.

Table 1-2
Project Alternative Impact Comparison
Issues Proposed Project Alternative 1
No Project
Alternative 2
Existing Zoning
with
No Land Use
Exchange
Aesthetics Less Than Significant Greater Greater
Agriculture/Forestry Resources No Impact Similar Similar Air Quality Less Than Significant Impact Less Less
Biology Less Than Significant With Mitigation Incorporated Greater Similar Cultural Resources Less Than Significant With Mitigation Incorporated Less Similar Energy Less Than Significant Less Less
Geology/Soils Less Than Significant With Mitigation Incorporated Less Similar Greenhouse Gas Emissions Less Than Significant Less Less Hazards/Hazardous Materials Less Than Significant With Mitigation Incorporated Less Greater Hydrology/Water Quality Less Than Significant Less Similar Land Use and Planning Less Than Significant Greater Greater Mineral Resources Less Than Significant Similar Similar Noise Less Than Significant Less Less
Population/Housing Less Than Significant Greater Greater Public Services Less Than Significant Less Less
Recreation Less Than Significant Greater Greater
Transportation Significant and Unavoidable ImpactLess Than Significant With Mitigation Incorporated Less LessGreater Tribal Cultural Resources Less Than Significant With Mitigation Incorporated Less Similar Utilities/Service Systems Less Than Significant With Mitigation Incorporated Less Less Wildfire Less Than Significant Greater Similar
SECTION 2.0 INTRODUCTION
Section 2.7, Technical Studies Prepared for the Proposed Project, on page 2-5 on of the Draft EIR is amended as follows:

The following technical studies were prepared for the project:
 Air Quality, Energy, and Greenhouse Gas Emissions Impact Analysis (April 4, 2024)  Biological Technical Report (March 2024)
 Phase I Cultural Resources Assessment (February 2024)  Historical Resource Analysis Report (February 2024)

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 Preliminary Geotechnical Evaluation (January 21, 2022)  Paleontological Records Search (June 16, 2021)
 Phase I Environmental Site Assessment (October 7, 2021)  Phase II Environmental Site Assessment (April 1, 2022)  Preliminary Hydrology and Hydraulic Study Report (February 2024)  Preliminary Project Specific Water Quality Management Plan (February 16, 2024)  Noise Impact Analysis (April 4, 2024)
 Vehicle Miles Traveled Analysis (March 21, 2024)
 Revised Vehicle Miles Traveled (VMT) Analysis (June 24, 2026) SECTION 3.0 PROJECT DESCRIPTION
Section 3.0, Project Description, has been substantially revised to reflect the amendments to the Tentative Tract Map (TTM) described above. Due to the comprehensive nature of these revisions, which affect multiple subsections, tables, and figures throughout the Project Description, the entire revised Section 3.0 is provided as Attachment A at the end of this Errata rather than presenting changes on a page-by-page basis.

Key revisions to Section 3.0 include, but are not limited to:
 Updated project statistics reflecting the reduction from 69 to 64 residential units.  Revised lot designations (e.g., Lot A to Lot G, Lot B to Lot J, etc.) and corresponding acreages.  Modified land exchange areas between JD Ranch and the City of Norco.  Retention of Lots 1-13 as A-1-20 zoning (Agricultural - Low Density, 20,000 square foot minimum).
 Updated descriptions of infrastructure locations, open space areas, and public improvements.  Revised circulation and access discussions reflecting current project layout.

Several figures within Section 3.0 have been updated to reflect the revised TTM, including but not limited to site plans, grading plans, conceptual landscape plans, and utility plans. Readers should refer to Attachment A for the complete revised Project Description, which supersedes Section 3.0 in the Public Review Draft EIR in its entirety.

As noted above, these revisions do not substantively affect the technical analyses or environmental impact conclusions presented in the Draft EIR, and technical studies remain valid and applicable to the revised project.

SECTION 4.1 AESTHETICS
The first paragraph under Section 4.1.2, Environmental Setting, on page 4.1-1 of the Draft EIR is amended as follows:

The project site is situated within an urbanized environment. The western side of the project site contains vacant land and the City of Norco Water Quality Infiltration Basin and Storm Detention Basin (Lot GA) and a Sewer Lift Station (Lot HD), including several wells and associated piping and utilities.

The remainder of the project site contains a former milking barn, a retail outlet, barns/sheds, and

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dairy-related features. Additionally, there is an existing residence with an attached shed/garage (Lot 649).

The second paragraph under the subheading “City of Norco Zoning Code” of Section 4.1.3, Regulatory Setting, on page 4.1-2 of the Draft EIR is amended as follows:

The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on 37.8434.38 acres), to allow for the development of a 648-lotunit singlefamily detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of an existing approximate 1.01 acre single-family residence.

SECTION 4.2 AGRICULTURE AND FORESTRY RESOURCES
The first paragraph under Section 4.2.1, Introduction, on page 4.2-1 of the Draft EIR is amended as follows:

This section evaluates the potential impacts to agriculture and forestry resources and analyzes the potential impacts associated with the development of the project which proposes to remove the existing dairy facilities to allow for the development of 648 single-family residential homes. The analysis is based, in part, on the California Department of Conservation Farmland Mapping and Monitoring Program and the City of Norco General Plan.

SECTION 4.5 CULTURAL RESOURCES
The first paragraph under the subheading “IMPACT CR-1” of Section 4.5.5, Environmental Impact Analysis, on page 4.5-17 of the Draft EIR is amended as follows:

Implementation of the proposed project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5. The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on

37.8434.38 acres), to allow for the development of a 648-lotunit single-family detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A1-20 Zoning regulations, and the retention of the existing single-family residence on an approximately

1.01-acre lot. The project is comprised of two (2) parcels, identified by Assessor’s Parcel Numbers (APNs) 121-110-003 and 121-110-001. APN 121-110-003 consists of 26.157 acres and is owned by TACRD Investment. APN 121-110-001 is owned by the City of Norco and consists of 11.6912.75 acres.

The 2877-4400 River Road property located on Riverside County Assessor’s Parcel No. 121-110-001 and 121-110-003, were analyzed for historical and architectural significance under the eligibility criteria of the Local Register and the CRHR. Generally, a resource shall be considered by the Lead Agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Public Resources Code Section 5024.1) including the following:

The third paragraph under the subheading “IMPACT CR-2” of Section 4.5.5, Environmental Impact Analysis, on page 4.5-19 of the Draft EIR is amended as follows:

With implementation of Mitigation Measures CR-1 throughand CR-52, potential impacts to unknown archaeological resources would be less than significant.

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The mitigation measures under the subheading “IMPACT CR-2” of Section 4.5.5, Environmental Impact Analysis, on page 4.9-19 of the Draft EIR is amended as follows:

CR-1: Prior to the issuance of grading permits, the project Applicant/Developer shall retain a qualified Archaeologist to monitor all ground disturbing activities related to the development of the site, including but not limited to, demolition, pavement removal, potholing, auguring, clearing, grubbing, tree removal, boring, grading, excavation, drilling, and trenching for both onsite and offsite improvements.

CR-2: Prior to the issuance of grading permits, the Archaeologist, in consultation with the Tribe(s) and the City of Norco, shall develop a Cultural Resources Monitoring Plan (CRMP) to address the details, timing, and protocols of all cultural resources activities that occur on the project site. At the project pre-grading meeting, the Archaeologist, the Native American Tribal Representative(s), the Applicant/Developer, and the excavation and grading Contractor shall discuss appropriate grading and ground disturbing methods within archaeologically and culturally sensitive areas on the project site pursuant to the CRMP.

CR-3: Pursuant to the Cultural Resources Monitoring Plan, the Archaeologist shall actively monitor project-related grading and in the event that cultural resources are discovered, shall have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of cultural resources.

CR-4: The Archaeological monitor will complete daily monitoring logs that describe daily grounddisturbing activities, the type of construction activities performed, locations of grounddisturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries. Monitor logs will identify and describe any discovered archaeological and/or tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCRs”), as well as any discovered Native American (ancestral) human remains and burial goods. Non-Tribal, historic-era cultural resources will also be documented. Copies of monitoring logs will be provided to the project applicant/developer/lead agency upon written request.

CR-5: At the completion of onsite and offsite ground-disturbing activities, a Phase IV Monitoring Report shall be prepared by the Archaeologist and submitted to the City documenting all monitoring activities conducted by the project Archaeologist and Native American Tribal Representative(s). All reports produced will be submitted to the City of Norco, the South Coastal Information Center, San Diego State University, and the consulting Tribe(s).

CR-1: Prior to the issuance of grading permits, the Applicant shall retain a qualified Archaeologist and Native American Tribal representative(s) to monitor grading and other ground disturbances related to site development. The Archaeologist, in consultation with the Tribe(s) and City, shall develop a Cultural Resources Monitoring Plan (CRMP) to address the details, timing, and protocols of all cultural resources activities that occur on the project site. At the project pre-grading meeting, the Archaeologist, the Tribal representative(s), the Applicant, and the excavation and grading contractor shall discuss appropriate grading and ground disturbing methods within archaeologically and culturally sensitive areas on the project site pursuant to the CRMP. Should the Archaeologist, after consultation with the consulting Tribe(s), find the potential exists for impacts to

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archaeological resources, cultural resources and/or sacred sites, the archaeologist and the Native American tribal representative(s) shall actively monitor project-related grading and in the event that cultural resources are discovered, shall have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of archaeological and/or cultural resources. All cultural material will be temporarily curated on the project site until final disposition is determined. The Applicant shall relinquish ownership of all cultural material, including sacred items, burial goods, and all archaeological artifacts and non-human remains discovered to the consulting Tribe(s) for final disposition. Leaving artifacts in place (in situ) or reburial of them on site are the preferred methods of mitigation. Reburial shall not occur until all cataloguing and basic recordation has been completed.

CR-2: At the completion of grading, excavation, and ground-disturbing activities on the site, a Phase IV Monitoring Report shall be submitted to the City documenting all monitoring activities conducted by the project archaeologist and Native Tribal Monitor(s). All reports produced will be submitted to the City of Norco, the Eastern Information Center, University of California, Riverside, and the consulting Tribe(s).

The first paragraph under the subheading “IMPACT CR-3” of Section 4.5.5, Environmental Impact Analysis, on page 4.5-21 of the Draft EIR is amended as follows:

Implementation of the project would not disturb any human remains, including those interred outside of dedicated cemeteries. No human remains or cemeteries are known to exist within or near the project site. However, there would always be the potential that subsurface construction activities associated with the proposed project could encounter and potentially damage or destroy previously undiscovered human remains. Accordingly, this is a potentially significant impact. In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5; Health and Safety Code Section 7050.5; Public Resources Code Section 5097.94 and Section 5097.98 must be followed. With the implementation of Mitigation Measure CR-63, potential impacts to human remains would be less than significant.

The mitigation measures under the subheading “IMPACT CR-3” of Section 4.5.5, Environmental Impact Analysis, on page 4.9-21 of the Draft EIR is amended as follows:

CR-63: Section 7050.5 of the California Health and Safety Code provides for the disposition of accidentally discovered human remains. Section 7050.5 states that, if human remains are found, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the county coroner has determined, within two working days, the appropriate treatment and disposition of the human remains.

If the coroner recognizes those remains to be Native American or has reason to suspect so, the coroner shall contact the Native American Heritage Commission (NAHC) within 24 hours.

Section 5097.98 of the PRC states that, when the NAHC receives notification of a discovery of Native American human remains from the county coroner pursuant to Section 7050.5 of the California Health and Safety Code, the NAHC shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The Most Likely Descendants (MLD) shall complete their inspection within 48 hours of being granted access to the site. The designated MLD would then recommend, in consultation with the

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property owner, the means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods.

SECTION 4.6 ENERGY
The first paragraph under the subheading “IMPACT E-1” of Section 4.6.5, Environmental Impact Analysis, on page 4.6-6 of the Draft EIR is amended as follows:

The proposed project would impact energy resources during operation and construction. Energy resources that would be potentially impacted include electricity, natural gas, and petroleum-based fuel supplies and distribution systems. This analysis includes a discussion of the potential energy impacts of the proposed project, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy. The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on 37.8434.38 acres), to allow for the development of a 648-lotunit single-family detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of the existing single-family residence on an approximately 1.01 acre lot. The proposed General Plan Amendment would increase the population on the project site above the level identified in the existing General Plan which would increase long-term energy consumption for electricity and natural gas above what is currently estimated for in the existing General Plan.

SECTION 4.8 GREENHOUSE GAS EMISSIONS
The first paragraph under the subheading “IMPACT GHG-1” of Section 4.8.5, Environmental Impact Analysis, on page 4.8-10 of the Draft EIR is amended as follows:

The proposed project would not generate significant gas emissions, either directly or indirectly, that may have a significant impact on the environment. The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on 37.8434.38 acres), to allow for the development of a 648-lotunit single-family detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of the existing single-family residence on an approximately 1.01 acre lot. The proposed General Plan Amendment would increase the population on the project site above what is currently projected for the project, which would increase greenhouse gas emissions above what was evaluated in the General Plan.

SECTION 4.9 HAZARDS AND HAZARDOUS MATERIALS
The sixth paragraph under the subheading “IMPACT HAZ-2” of Section 4.9.5, Environmental Impact Analysis, on page 4.9-12 of the Draft EIR is amended as follows:

Buildings on the subject property are wood framed with galvanized steel roofs and exterior walls. No potential asbestos containing materials were identified in the buildings. However, the Dallape Dairy site and the City owned property have large wells which conveyed water underground. There is a potential for Transite (asbestos containing materials containing concrete) pipes on both sides of the overall property. No potential lead-based paint was noted; however, based on the construction period, it is possible such materials may be present. To avoid the potential release of contaminated demolition material, Mitigation Measure HAZ-1 would require an asbestos, lead paint and polychlorinated

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biphenyl caulk survey for structures proposed for demolition. If asbestos containing building materials, lead paint and polychlorinated biphenyl caulk are present, hazardous material abatement during demolition of existing structures would be performed in accordance with all pertinent regulations and under the guidance of a California Occupational Safety and Health Administration (Cal/OSHA) - Certified Asbestos Consultant (CAC) and/or Lead-Related Construction Inspector/Assessor. With implementation of Mitigation Measure HAZ-1, potential impacts would be less than significant.

The 13th paragraph under the subheading “IMPACT HAZ-2” of Section 4.9.5, Environmental Impact Analysis, on page 4.9-13 of the Draft EIR is amended as follows:

The pesticide DDE, which is pervasive in southern California due to legal application prior to its ban in the 1970’s, was found in 5 of the 8 shallow samples at concentrations above the referenced screening criteria. Because DDE was not found in all samples, DDE does not appear to be completely pervasive in the sample area. The Phase II Site Assessment requires that substantial additional sampling be conducted following demolition to provide a more reliable dataset to evaluate the extent, depth, and distribution of DDE. Following additional sampling, recommendations can be made regarding remediation and/or other mitigation and/or sampling options; refer to Mitigation Measures HAZ-2 and HAZ-3.

In addition, the project would import approximately 48,400 cubic yards of material. Mitigation Measure HAZ-4 ensures that imported soil and fill are free of any contaminants of concern and meet the Department of Toxic Substances and U.S. Environmental Protection Agency Regional Screen Levels for the intended land use.

The mitigation measures under the subheading “IMPACT HAZ-2” of Section 4.9.5, Environmental Impact Analysis, on page 4.9-13 of the Draft EIR is amended as follows:

HAZ-1: Prior to demolition of the buildings, the Applicant shall prepare an asbestos, lead paint and polychlorinated biphenyl caulk survey on the buildings and sampling around the area of those buildings. In the event asbestos containing building materials, lead paint or polychlorinated biphenyl caulk are identified, it shall be removed and disposed of in accordance with local, state, and federal regulations under the guidance of a California Occupational Safety and Health Administration (Cal/OSHA) - Certified Asbestos Consultant (CAC) and/or Lead-Related Construction Inspector/Assessor.

HAZ-21: Additional sampling shall be conducted following demolition and prior to construction to evaluate the extent, depth, and distribution of dichlorodiphenyldichloroethylene (DDE).

Following additional sampling, recommendations will be made regarding remediation and/or other mitigation and/or sampling options.

HAZ-32: Undocumented fill is located on the northern parcel. One of the following options must be completed to mitigate this REC prior to construction:
 The property owner can properly dispose of the undocumented fill.  The property owner can properly evaluate the fill to document its suitability for use at the site and provide sampling rationale/standards with sampling location and laboratory data to Client for evaluation.

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 Client can properly evaluate the fill using EPA SW-846 or other acceptable sampling guidance.

HAZ-4: Prior to import and placement on the project site, all imported soil and fill material shall be tested by a qualified environmental professional to ensure any contaminants of concern are within Department of Toxic Substances Control’s (DTSC) and U.S. Environmental Protection Agency Regional Screen Levels for the intended land use. The environmental professional shall collect and analyze representative samples from the source location of any soil or fill material proposed for import, prior to its removal from the source site. To minimize the possibility of introducing contaminated soil and fill material, there shall be documentation of the origins of the soil or fill material and, if applicable, sampling shall be conducted to ensure that the imported soil and fill material meets screening levels outlined in DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual for the intended land use. The soil sampling shall include analysis based on the source of the fill and knowledge of the prior land use. If testing reveals contaminant concentrations that exceed applicable DTSC and EPA screening levels for the intended land use, the soil or fill material shall be rejected and shall not be imported to the project site. The project Applicant shall then either: 1) source alternative fill material and conduct the required testing, or 2) implement appropriate soil treatment measures at the source location to reduce contaminant concentrations below applicable screening levels, as demonstrated through additional testing. Documentation of all soil testing results and any required treatment measures shall be submitted to the City of Norco for review and approval prior to importing any soil or fill material to the project site.

SECTION 4.11 LAND USE AND PLANNING
The first paragraph under the subheading “IMPACT LU-1” of Section 4.11.5, Environmental Impact Analysis, on page 4.11-4 of the Draft EIR is amended as follows:

The project site is currently developed and situated within a suburban setting. The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on 37.8434.38 acres), to allow for the development of a 648-lotunit single-family detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of the existing single-family residence on an approximately 1.01 acre lot. The minimum lot width would be 85 feet and the minimum lot depth would be 100 feet. The anticipated house sizes would be a combination of one- and two-story dwelling units that would range from approximately 2,700 square feet to 3,500 square feet. The proposed project lot sizes would all accommodate the potential for animal keeping based on the requirements of the R-1 Zoning. The project site is surrounded by single-family land uses to the north, south, southwest and east and would be a compatible land use. Residential uses adjacent to the site would be buffered from the project by a block perimeter wall and landscaping. The proposed project would not divide or create a barrier to existing communities or result in the development of incompatible land uses; therefore, there are no impacts.

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The second paragraph under the subheading “CITY OF NORCO ZONING ORDINANCE” under “IMPACT LU-2” of Section 4.11.5, Environmental Impact Analysis, on page 4.11-4 of the Draft EIR is amended as follows:

The proposed Zone Change would convert 15.0819.37 acres of area currently zoned Agricultural Low Density (A-1-20), minimum 21,780 square foot lot to Residential Single Family (R-1), minimum 10,000 square foot lot size. Additionally, the project would change 8.240 acres of area currently zoned Open Space, which is currently used by the City as a spoils and staging yard to Residential Single Family (R1), minimum 10,000 square foot lot size and would change 3.296.78 acres of area currently zoned Agricultural Low Density, minimum 21,780 square foot lot to Open Space. There would be a net decrease of approximately fiveone acres of area zoned open space. The decrease in area zoned Open Space would not have a significant adverse impact on open space opportunities in the City when considering that the City of Norco’s Municipal Code Section 17.14.06 (Formula for Dedication of Land) states park dedication is 5.0 acres per 1,000 residents and the City currently maintains a parkland/open space to-resident ratio of approximately 65 acres per 1,000 residents.

Table 4.11-3
Proposed Zoning Designations
Existing Zoning Designation Proposed Zoning Designations

8.240 acres Open Space Residential Single Family (R-1), minimum 10,000 square foot lot size

15.0819.37 acres Agricultural Low Density (A-1-20),
minimum 21,780 square foot lot
Residential Single Family (R-1), minimum 10,000
square foot lot size

3.296.78 acres Agricultural Low Density (A-1-20),
minimum 21,780 square foot lot Open Space
SECTION 4.13 NOISE
The first paragraph under the subheading “LOCAL” “City of Norco Municipal Code” of Section 4.13.3, Regulatory Setting, on page 4.13-7 of the Draft EIR is amended as follows:

SECTION 15.30.020 HOURS OF CONSTRUCTION ACTIVITY
Construction activity, including equipment start-up and use, and the loading, unloading and handling of materials, shall not commence before 6:30 a.m., or continue beyond 7 p.m., on weekdays. No construction activity for residential development projects that consist of more than one unit is permitted on Saturdays, Sundays, or national holidays unless otherwise permitted with conditions on entitlements. The restrictions from Saturdays, Sundays, and national holidays shall not apply to singlebuilding permits for expansion and upgrade to existing buildings; however, no such construction shall begin before 8 a.m.

The first paragraph under the subheading “IMPACT NOI-1” of Section 4.13.5, Environmental Impact Analysis, on page 4.13-11 of the Draft EIR is amended as follows:

The proposed project would not generate 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. The proposed project requests approval of a General Plan Amendment, a Zone Change, and Tentative TractParcel Map No. 38330 (on 37.8434.38

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acres), to allow for the development of a 648-lotunit single-family detached housing project consisting of 50 lots aton a minimum 10,000 square feetfoot in accordance with the City’s R-1 Zoning regulations, 13 lots at a minimum 21,780 square feet in accordance with the City’s existing A-1-20 Zoning regulations, and the retention of the existing single-family residence on an approximately 1.01 acre lot. The proposed General Plan Amendment would increase population and associated traffic generated from the project site above the level identified in the existing General Plan which could increase operational noise levels and long-term traffic noise levels above levels currently estimated in the existing General Plan.

SHORT-TERM TEMPORARY CONSTRUCTION NOISE IMPACTS
The construction activities for the proposed project are anticipated to include demolition of the milking barn, retail outlet, barns/sheds, and dairy related features on the project site, site preparation and grading of up to 27.57 acres of the 37.84-acre project site that would include import of approximately 48,400 cubic yards of dirt to the project site building construction of 648 single-family homes, paving of the onsite roads, sidewalks and hardscapes, and application of architectural coatings. Construction activities would primarily create noise impacts from haul truck trips on the nearby roadways and from off-road equipment operating on the project site.

LONG-TERM OPERATIONAL NOISE IMPACTS
The proposed project would consist of the development of 648 single-family homes. Potential noise impacts associated with the operations of the proposed project would be from project-generated vehicular traffic on the nearby roadways. In addition, the proposed development would be adjacent to River Road and Bluff Street, which may create exterior and interior noise levels.

Project Design Feature NOI-1 under the subheading “IMPACT NOI-1” of Section 4.13.5, Environmental Impact Analysis, on page 4.13-18 of the Draft EIR is amended as follows:

PDF-NOI-1: Prior to the issuance of the grading permit, the project applicant shall submit a construction related noise mitigation plan to the City for review and approval. The plan shall depict the locations of where construction equipment will operate on the project site and how the noise from the construction equipment will be mitigated during construction of the project, through use of the following methods:

1. Construction activity, including equipment start-up and use, and the loading, unloading and handling of materials, shall not commence before 6:30 AM, or continue beyond 7:00 PM, on weekdays. No construction activity for residential development projects that consist of more than one unit is permitted on Saturdays, Sundays, or national holidays unless otherwise permitted with conditions on entitlements. The restrictions from Saturdays, Sundays, and national holidays shall not apply to single-building permits for expansion and upgrade to existing buildings; however, no such construction shall begin before 8:00 AM. Deviations from these hours may be approved if the Conditions of Approval allow and if approved by the Community Development Director;Restriction of use of construction equipment and haul truck operations between 7:00 PM and 7:00 AM, Monday through Friday and between 7:00 PM and 8:00 AM on Saturday and Sunday, unless specified by permit for activities such as pouring of concrete that may need to occur outside of these hours;

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2. Placement of temporary noise attenuation fences around stationary equipment (i.e., air compressors and generators) that are used in close proximity to sensitive receptors;

3. Placement of equipment storage and staging areas as far away as practical from sensitive receptors;

4. Limitation of construction equipment idling time to less than 5 minutes per occurrence; and,

5. Require the use of construction equipment noise attenuation features that include mufflers and engine shrouds that are at least as effective as the original manufacturer equipment.

SECTION 4.14 POPULATION AND HOUSING
The first paragraph under the subheading “IMPACT PH-1” of Section 4.14.5, Environmental Impact Analysis, on page 4.14-4 of the Draft EIR is amended as follows:

The proposed project would construct 638 single-family dwellings. Based on the City of Norco average household size of 3.34 persons per household, the project is estimated to have 210227 residents. This analysis assumes that the project would attract new residents who do not currently reside in Norco.

POPULATION
According to the Norco 2021-2029 Housing Element, the City of Norco’s population is expected to reach 32,100 residents by 2040, which is an increase of 7,063 residents, compared to the DOF 2023 estimate of 25,037 residents. The proposed project is expected to add 210227 new residents, approximately less than 1% of the 2040 population projection in the Housing Element.

HOUSING
According to the City of Norco 2021-2029 Housing Element, 454 housing units are needed to meet regional housing needs. The proposed project would provide 145% of these housing units. The project site is surrounded by single-family homes. As shown previously in Table 4.14-4, Household Characteristics, Family Households make up the majority of housing stock in the City. The proposed project would be targeted for Family Households and would increase the housing stock for Family Household opportunities in the City. Additionally, as previously indicated, the increased housing from implementation of the General Plan Amendment would be consistent with the goals of California Senate Bill 330, “The Housing Crisis Act of 2019,” which establishes a statewide housing emergency and the need for an estimated 180,000 additional homes annually to keep up with population growth within California. Because the proposed project would help the City meet its housing needs requirements, impacts would be less than significant.

JOBS-HOUSING RATIO
The jobs-housing ratio for the City is employment-rich (2.38 jobs per dwelling unit; refer to Table 4.14- 2). Although the proposed project would increase the jobs-housing ratio by adding 638 additional homes, the proposed jobs-housing ratio for the proposed project would be 2.365, which would provide more housing units in a city with a high number of jobs. Therefore, project implementation would have no impact on employment.

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The first paragraph under the subheading “IMPACT PH-2” of Section 4.14.5, Environmental Impact Analysis, on page 4.14-5 of the Draft EIR is amended as follows:

The proposed project would not displace any people or existing housing that would require replacement housing. The existing house on the project site (Lot 649) would be retained but is not a part of the proposed project and no changes/improvements would occur to the existing structure. The proposed project would not displace any people/existing housing nor require replacement housing.

The project would construct 638 new single-family homes. Therefore, no impact would occur.

SECTION 4.15 PUBLIC SERVICES
The first, second and third paragraphs under the subheading “FIRE PROTECTION” of Section 4.15.2, Environmental Setting, on pages 4.15-1 and 4.15-2 of the Draft EIR is amended as follows:

The Riverside County Fire Department (RVCFD) provides fire and emergency services to residents of unincorporated areas of Riverside County and to 20 partner cities, which includes the City of Norco.

RVCFD also responds to eight additional cities through mutual and automatic aid agreements. RVCFD provides full-service municipal and wildland fire protection, pre-hospital emergency medical response by paramedics and emergency medical technicians, technical rescue services, and response to hazardous materials discharges. RVCFD consists of four operational support divisions: Conservation Camps, Emergency Command Center, Hemet Ryan Air Attack Base, and Pre-Fire Management.

The California Department of Forestry and Fire Protection (CAL FIRE) identifies the project site as not located in a Very High Fire Severity Zone; refer to Figure 4.20-1, Regional Fire Hazard Severity Zones.

The nearest Very High Fire Severity Zone is located approximately 1.5 miles southwesterly of the project, as shown in Figure 4.20-1. As shown in Table 4.15-1, City of Norco Fire Station Locations, there are three fire stations in the City of Norco. The nearest fire station is Station 57, located approximately

0.75 miles northeast from the project site. In 2021, RVCFD responded to 4,291 calls for service in the City of Norco, of which 1,408 were responded from Station 14, 1,403 from Station 57, and 1,480 from Station 47.

Presently, RVCFD is evaluating target response times, generally for development projects, 4-minute response times are targeted. Responses to the project site would include 5 minutes from Station 57, 9 minutes from Station 14, and 12 minutes from Station 47. At this time, there are no plans to expand existing or construct new fire protection facilities.

A subheading “FEDERAL” has been added to Section 4.15.3, Regulatory Setting, on page 4.15-7 of the Draft EIR is amended as follows:

FEDERAL
International Fire Code
The 2024 International Fire Code® (IFC®) The 2024 IFC® contains regulations to safeguard life and property from fires and explosion hazards. Topics include general precautions, emergency planning and preparedness, fire department access and water supplies, automatic sprinkler systems, fire alarm systems, special hazards, and the storage and use of hazardous materials. As a model code, the IFC® is intended to be adopted in accordance with the laws and procedures of a governmental jurisdiction.

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The first paragraph under the subheading “STATE” “California Fire Code (Title 24, Part 9, California Code of Regulations) of Section 4.15.3, Regulatory Setting, on page 4.15-7 of the Draft EIR is amended as follows:

The California Fire Code is modeled from the International Fire Code and amended through the City of Norco Municipal Code incorporates the Uniform Fire Code (UFC) with necessary California amendments. This Code prescribes regulations consistent with nationally recognized good practices for the safeguarding, to a reasonable degree, of life and property from the hazards of fire explosion. It also addresses dangerous conditions arising from the storage, handling, and use of hazardous materials and devices; conditions hazardous to life or property in the use or occupancy of buildings or premises; and provisions to assist emergency response personnel.

Policy 2.3.1c under the subheading “SAFETY ELEMENT” of Section 4.15.3, Regulatory Setting, on page

4.15-8 of the Draft EIR is amended as follows:

Policy 2.3.1c: The minimum fire flow standard for low density residential construction should be 1,000 gallons of water per minute.
[Please note that the RVCFD requires a minimal residual pressure of 20 pounds per square inch (psi) with a duration of not less than one hour1] The first, second, third and fourth paragraphs under the subheading “IMPACT PS-1” of Section 4.15.5, Environmental Impact Analysis, on pages 4.15-10 and 4.15-11 of the Draft EIR is amended as follows:

The proposed project would construct 638 single-family dwellings which would accommodate approximately 210227 residents. The California Department of Forestry and Fire Protection (CAL FIRE) identifies the project site as not located in a Very High Fire Severity Zone; refer to Figure 4.20-1, Regional Fire Hazard Severity Zones. According to the City of Norco 2050 General Plan Existing Conditions Analysis Report: Safety Analysis (Figure 1 – Fire Hazard Severity Zones, WUI, and CPUC Fire Hazard Threat Mapping), the northwestern portion of the project site, near the Santa Ana River Corridor, is identified as a fire hazard threat zone by the California Public Utility Commission (CPUC).

The proposed project would increase the population on the project site by an additional 210227 persons over the planned population for the project site, based on the current zoning. The construction and operation of the proposed project could potentially increase the demand for fire protection and/or emergency services calls because of an increase in the number of people who would live on the project site.

Fire protection service would be provided from the Riverside County Fire Department (RVCFD). The project would be located in the existing service area of RVCFD and would not increase its coverage area. Fire Station 57 would be the closest fire station to the site with a response time of approximately 5 minutes, which would be a close target response time of 4 minutes. According to RVCFD (Adria Reinertson, Deputy Fire Marshal), current levels of staff and facilities are adequate to serve the proposed project.

The project would be required to comply with applicable RVCFDRiverside County Fire Department codes, ordinances, and regulations regarding fire prevention and suppression measures; fire hydrants and sprinkler systems; emergency access; and other similar requirements. Appropriate fire protection 1 Riverside County Fire Department – Office of the Fire Marshal, City of Norco, Correspondence with Frank Martinez, Fire Safety Specialist. July 22, 2024.

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measures would be incorporated into the design of proposed project buildings in accordance with the CBC and California Fire Code (2022 editions) and the National Fire Protection Association (NFPA) standards. As part of the development review process, the City of Norco would work with RVCFD to ensure that fire safety issues associated with the proposed project are considered, including adequate street and driveway widths to provide access to sites and buildings to provide adequate sufficient clearances for fire suppression and other emergency access needs. To reduce the project’s cumulative impact on fire protection services, the project would require payment of proportionate Development Impact Fees allocated to fire protection services. These fees would cover potential station construction or expansion to accommodate cumulative increases in RVCFD service population.

With compliance with RVCFDRiverside County Fire Department codes, ordinances, regulations and payment of Development Impact Fees, potential impacts to fire protection services would be less than significant.

The first paragraph under the subheading “IMPACT PS-2” of Section 4.15.5, Environmental Impact Analysis, on page 4.15-11 of the Draft EIR is amended as follows:

The proposed project would increase the population on the project site by an additional 210227 persons over the planned population for the project site, based on the current zoning. The proposed project would increase the demand for police protection services. Police protection services would be provided by the Riverside County Sherriff’s Department (RCSD). The project would be located in the existing service area of RCSD and would not increase its service area. Policy 2.5.2a of the General Plan Safety Element states that the City shall endeavor to provide a minimum response time of 5 minutes on all priority 1 calls (life-threatening situations and violent crime) and 12 minutes on all priority 2 calls (non-life-threatening situations).

Table 4.15-5 and the second paragraph under the subheading “IMPACT PS-3” of Section 4.15.5, Environmental Impact Analysis, on page 4.15-12 of the Draft EIR is amended as follows:

Table 4.15-5
CNUSD School Locations and Generation Factors for Single-Family Residences School Level Closest School Student
Generation
Estimated
Number
Students
Available
Capacity
Remaining
Capacity
With Project
Elementary Highland Elementary 0.3360 213 675 6542
Intermediate Norco Intermediate 0.1040 7 900 893
High School Norco High School 0.23030.6703 1546 2,600 2,58554 Total 4376 4,175 4,132099
Source: Corona-Norco Unified School District, Correspondence with Nicole Lavallee, Facilities Analyst. May 16, 2022.

Correspondence from Facilities Analyst, Nicole Lavallee, reports the current generation rates to predict future population growth for single families are 0.3360 for Elementary School, 0.1040 for Middle School, and 0.2303 for High School. Based on the CNUSD student generation rates, the project would generate 4376 new students, 841 additional students above what is currently estimated for the site based on existing zoning. The proposed project would incrementally increase the enrollment of students and the use of CNUSD facilities. As shown in Table 4.15-5, there would be available capacity at each school upon implementation of the proposed project.

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The first and second paragraphs under the subheading “IMPACT PS-4” of Section 4.15.5, Environmental Impact Analysis, on pages 4.15-12 and 4.15-13 of the Draft EIR is amended as follows:

The proposed project would increase the population on the project site by an additional 210227 persons over the planned population for the project site, based on the current zoning and would increase the demand for recreation uses. The City of Norco maintains 17 outdoor public parks that are less than five miles from the project site. Within less than one mile of the project site, there are four park sites; refer to Table 4.15-4, Norco Park and Recreational Facilities. Norco currently maintains a parkland/open space to-resident ratio of approximately 65 acres per 1,000 residents, well in excess of the 5.0 acres per 1,000 residents required by the City’s Quimby Act regulation. The population generated by the proposed project would not substantially reduce the City’s existing parkland/open space to-resident ratio and the availability of parkland for other residents in the City. In fact, the project would be required to contribute 1.051.14 acres of parkland or an in-lieu park fee equivalent.

Additionally, the proposed project would provide onsite equestrian trails and expand offsite equestrian trails near the project site which would enhance recreational opportunities in the City.

To reduce the proposed project’s cumulative impact on parklands, the creation of up to 1.051.14 acres2 of park and recreation improvements or equivalent in-lieu fee payment would be required.

These fees would cover future parkland and recreation facility construction or expansion to accommodate cumulative increases in Norco’s population. A combination of the project proposed onsite and offsite trail improvements and payment of park fees would reduce project-related and cumulative impacts to parks to less than significant.

The first paragraph under the subheading “IMPACT PS-5” of Section 4.15.5, Environmental Impact Analysis, on page 4.15-13 of the Draft EIR is amended as follows:

The proposed project would result in a total of 210227 residents, and based on the current zoning, would increase the demand for library facilities. The project’s increase in population would be a nominal increase in demand for library services compared to the existing population that is served by local libraries; however, the Riverside County Library System states that Riverside County Library cardholders have unlimited access to thousands of digital books 24 hours a day, 7 days a week. To reduce the project’s cumulative impact on library facilities, the project would provide payment of Development Impact Fees to help fund future acquisition or expansion of library facilities. With payment of Development Impact Fees, project and cumulative impacts on library facilities would be less than significant.

SECTION 4.16 RECREATION
The second paragraph under the subheading “IMPACT REC-1” of Section 4.16.5, Environmental Impact Analysis, on page 4.16-2 of the Draft EIR is amended as follows:

Norco currently maintains a parkland/open space to-resident ratio of approximately 65 acres per 1,000 residents. Implementation of the proposed project would increase the population and recreation demand. However, the additional population generated by the proposed project would not 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. Norco currently 2 Calculation is based on the City’s parkland ratio of 5 acres per 1,000 residents, proposed project would result in 210227 residents (5/1000 * 210227 = 1.05135).

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maintains a parkland/open space to-resident ratio of approximately 65 acres per 1,000 residents, well in excess of the 5.0 acres per 1,000 residents required by the City’s Quimby Act regulation. To reduce the proposed project’s cumulative impact on parklands, the creation of up to 1.051.14 acres3 of park
and recreation improvements or equivalent in-lieu fee payment would be required. These fees would cover future parklands and recreation facilities construction or expansion to accommodate cumulative increases in Norco’s population. With the combination of project proposed onsite and offsite trail improvements and payment of park fees, potential impacts and cumulative impacts on recreation facilities would be reduced to less than significant.

The second paragraph under the subheading “IMPACT REC-2” of Section 4.16.5, Environmental Impact Analysis, on page 4.16-3 of the Draft EIR is amended as follows:

The proposed project would not include or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. As shown previously in Figure 3-10, Equestrian Trail Plan, the project proposes to construct critical missing links to the City’s trail system with a 12-foot trail on River Road and on Bluff Street. Both trails would connect to existing City trails. Additionally, within the project a 12-foot trail is proposed that would connect to the proposed trails along River Road and Bluff Street, and there would be a 15-foot pedestrian access (Lot IF), between Lots 10 and 11, to Sundance Park; refer to Figure 3-9, Tentative Tract Map. The overall intent of the project is to close critical gaps in the City’s equestrian/pedestrian trail system as well as create an equestrian community that is unified by tree lined equestrian trails that circulate through the community connecting residents to the City’s equestrian heritage. The landscape treatment for the project is influenced by the native environs of the Santa Ana River and the City of Norco equestrian heritage. Impacts of the proposed recreational facilities onsite (equestrian/ pedestrian trails) have been analyzed throughout this DEIR. The proposed project would not increase the demand for recreation facilities where new facilities would be needed; therefore, potential impacts would be less than significant.

SECTION 4.17 TRANSPORTATION
The first paragraph under Section 4.17.1, Introduction, on page 4.17-1 of the Draft EIR is amended as follows:

This section evaluates the potential traffic impacts associated with implementation of the proposed project. It should be noted that at the time of public circulation of the DEIR, the proposed project consisted of sixty-eight (68) single-family dwelling units with one (1) existing single-family dwelling unit to remain. Since the DEIR circulation period ended, the proposed project has been reduced in size to consist of sixty-three (63) single-family dwelling units with one (1) existing single-family dwelling unit to remain. The original DEIR VMT analysis was based on the March 21, 2024 memorandum (Appendix J1) and has since been revised based on the June 18, 2026 memorandum (Appendix J2). Both memoranda are included in the environmental record and are listed as followsin this section is based on the following technical reports:
 Vehicle Miles Traveled Analysis, LLG Engineers, March 21, 2024 (Appendix J1). 3 Calculation is based on the City’s parkland ratio of 5 acres per 1,000 residents, proposed project would result in 210227 residents (5/1000 * 210227 = 1.05135).

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 Revised Vehicle Miles Traveled (VMT) Analysis for the Proposed JD Ranch Residential Project, LLG Engineers, June 18, 2026 (Appendix J2).

The first paragraph under the subheading “IMPACT TRA-1” of Section 4.17.5, Environmental Impact Analysis, on page 4.17-6 of the Draft EIR is amended as follows:

The project has been designed to provide equestrian trail circulation within the project and the construction of trail extensions to existing equestrian trails in the City. The project proposes a 12-foot equestrian trail on River Road and Bluff Street. Both equestrian trails would allow connection to an existing City equestrian trail located on River Road and Bluff Street. Additionally, within the proposed project, a 12-foot equestrian trail is proposed along the local streets within the proposed development.

Within the project, the proposed 12-foot equestrian trails would connect to the proposed equestrian trails along River Road and Bluff Street. Additionally, there would be a 15-foot pedestrian access (Lot IG), between Lots 10 and 11, to Sundance Park; refer to Figure 3-10, Equestrian Trail Plan. The overall intent of the project is to create an equestrian community that is unified by tree lined equestrian trails that circulate through the community connecting residents to the City’s equestrian heritage. Through connection to the existing trail network and design of the development, the project would be consistent with the following goals and policies from the City of Norco Trails Master Plan and would not conflict with implementation of the Trails Master Plan.

The entire section under the subheading “IMPACT TRA-1” of Section 4.17.5, Environmental Impact Analysis, beginning on page 4.17-7 of the Draft EIR is amended as follows:

PROJECT SCREENING CRITERIA
Project screening is used to determine if a project will be required to conduct a detailed VMT analysis.

The following section discusses the screening methods outlined in the City of Norco Resolution No. 2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020) for land use projects and outlines whether the project will screen-out, either in its entirety or partially, based on individual land uses.

The City of Norco Resolution No.2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020) states:

The City of Norco hereby adopts the VMT Project Screening Criteria consistent with Office Planning Research guidelines and screen out projects which fall into the following categories:
 Retail projects up to 50,000 SF in floor area.
 Projects generating less than 110 daily trips.
 Projects within a Transit Priority Area (TPA). A TPA is defined as locations within ½ mile of a major transit stop or within ½ mile of a high-quality transit corridor with 15-minute or less headways during peak commute hours.
 Affordable housing developments or affordable housing units within mixed-use developments.
 Transportation projects that promote non-auto travel, improve safety, or improve traffic operations at current bottlenecks, such as transit, bicycle and pedestrian facilities, intersection traffic control (e.g., traffic signals or roundabouts), or widening at intersections to provide new turn lanes.

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The proposed project will not screen-out of a VMT analysis as it does not satisfy any of the screening criteria listed above. Also, the proposed project does not screen-out as presented in the Western Riverside Council of Governments (WRCOG) VMT Screening Tool Website.As reflected in the revised analysis prepared by LLG Engineers (Appendix J2), the revised project does not screen out of a detailed VMT analysis; therefore, the detailed VMT analysis is provided below.

VMT SIGNIFICANCE THRESHOLD
A project that does not meet the screening criteria will require preparation of a detailed transportation analysis. The VMT significance criteria as stated in the City of Norco Resolution No.2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020) is shown in Table 4.17-1, City of Norco VMT Baselines and Thresholds of Significance. For the proposed project, the applicable VMT Threshold is Land Use Project (Residential).

Table 4.17-1
City of Norco VMT Baselines and Thresholds of Significance Project Type Thresholds
Land Use Plan 1) Project Impact: A significant impact would occur if the VMT rate for the plan would exceed the applicable baseline VMT rate per service population. Baseline VMT rate is defined as the City’s jurisdictional average VMT per appropriate development
category.
2) Cumulative Project Effect: A significant impact would occur if the project increases total regional VMT compared to cumulative no project conditions.

Land Use Project (Residential) 1) Project Impact: A significant impact would occur if the VMT rate for the project would exceed the daily total VMT per service population;
OR

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Project Type Thresholds
2) Project Impact: A significant impact would occur if the VMT rate for the project would exceed daily residential home-based VMT per capita.
3) Cumulative Project Effect: A significant impact would occur if the project would exceed the total regional VMT compared to cumulative no project conditions, under either condition above.

Office, Commercial or Retail Land Use
Project
1) Project Impact: A significant impact would occur if the VMT rate for the project would exceed the applicable baseline VMT rate per service population;
OR
2) Project Impact: A significant impact would occur if the VMT rate for the project would exceed daily home-based work VMT per worker.
3) Cumulative Project Effect: A significant impact would occur if the project increases the VMT rate in the study area above the baseline conditions for that area.

Transportation Project A significant impact would occur if the project caused a net increase in total regional VMT compared to baseline conditions, opening year no project conditions, or cumulative no project conditions.

All Land Use and Transportation Projects A significant impact would occur if the project were inconsistent with the RIVTAM/RIVCOM.

Source: Linscott, Law & Greenspan, Engineers (LLG), Vehicle Miles Traveled (VMT) Analysis; March 21, 2024.(Appendix J1)

VMT ANALYSIS METHODOLOGY
According to City of Norco Resolution No.2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020), projects that do not screen-out based on the aforementioned criteria shall complete a full VMT analysis and forecasting using the Riverside County Traffic Analysis Model (RIVTAM/RIVCOM) to determine if it will have a significant VMT impact. Based on the above, a full VMT analysis utilizing RIVTAM has been used to determine the VMT for the project as well as for the City of Norco average and will provide the following:
 Daily Home-based VMT per Capita
 Total Regional VMT
VMT Analysis
Summarized below are the average VMT per Capita values utilizing RIVTAM for the City of Norco and for the proposed project. It should be noted that the project is located in Traffic Analysis Zone (TAZ) 3150 and the project development totals were converted into Socio-Economic Data (SED) and inputted into the RIVTAM.

Project Impact
As shown in Table 4.17-2, Project Threshold, the proposed project VMT per Capita is 22.50% higher than the City average VMT per Capita. Based on the criteria outlined in this report, the proposed

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project will exceed the City of Norco base year VMT per Capita of 13.05 and thus will have a significant project VMT impact.

As reflected in the Revised VMT Analysis Technical Memorandum prepared by LLG Engineers (June 18, 2026), the Western Riverside Council of Governments (WRCOG) VMT Tool was utilized to evaluate the project site. It should be noted that the current version of the WRCOG VMT Tool is based on the current RIVCOM Traffic Model, which was updated in conjunction with the update of the WRCOG VMT Tool, whereas the prior VMT analysis utilized the prior RIVTAM Traffic Model. The prior and current Traffic Models included different Traffic Analysis Zone (TAZ) numbering as well as different Southern California Association of Governments (SCAG) socioeconomic data for the region, such that VMT results differ between the prior and current versions of the Traffic Model. The prior version of the WRCOG VMT Tool showed that the proposed developed project site VMT per service population and VMT per resident would be greater than the jurisdictional average, whereas the current version of the WRCOG VMT Tool shows that the proposed developed project site VMT per service population and VMT per resident would be less than the jurisdictional average, as detailed below. As shown in Table

4.17-2, WRCOG VMT Screening Tool Results, the proposed developed project site VMT per service population and VMT per resident would both be below the City of Norco’s applicable thresholds.

Because the project land use is residential, which matches the existing residential land use in Traffic Analysis Zone (TAZ) 1559, the project VMT essentially matches the TAZ VMT per resident (capita) and TAZ VMT per service population. Therefore, the proposed project would be presumed to have a less than significant VMT impact.

Table 4.17-2
Project ThresholdWRCOG VMT Screening Tool Results
VMT MetricBase Year TAZ 15591350
(Project Site)
City Average
Jurisdiction Threshold
Compare to City
Threshold
(% Difference)
VMT Per Capita 15.99 13.05 22.50% Higher
Origin-Destination (OD) VMT per
Service Population 35.0 47.4 -26.12% (below threshold)
Production-Attraction (PA) VMT
per Resident 14.3 15.3 -6.8% (below threshold)
Source: Linscott, Law & Greenspan, Engineers (LLG), Revised Vehicle Miles Traveled (VMT) Analysis; June 18, 2026March 21, 2024.

Cumulative Impact
As shown in Table 4.17-23, WRCOG VMT Screening Tool ResultsCumulative Threshold, the revisedproposed project total dailyVMT per service population and VMT per resident would both be below the City of Norco’s applicable thresholds. Therefore, consistent with the Revised VMT Analysis Technical Memorandum prepared by LLG Engineers (June 18, 2026), the proposed project can be presumed to have a less than significant cumulative VMT impact.within the City is 0.10% higher than the “no Project” scenario total daily VMT under cumulative conditions. Based on the criteria outlined in this report, the proposed project total daily VMT will exceed under the “with Project” condition when compared to the “without Project” condition and thus the project will have a significant cumulative VMT impact.

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Table 4.17-3
Cumulative Threshold
Cumulative Year With Project Scenario Without Project Scenario Compare to Threshold Total VMT 1,164,288.81 1,163,127.15 0.10% Higher
Source: Linscott, Law & Greenspan, Engineers (LLG), Vehicle Miles Traveled (VMT) Analysis; March 21, 2024.

VMT MITIGATION ANALYSIS
If a significant VMT impact is identified, measures to reduce the project’s VMT impact should be identified to reduce the VMT levels to a level at or below the City’s thresholds. To mitigate VMT impacts, the project applicant must reduce VMT, which can be done by either reducing the number of automobile trips generated by the project or by reducing the distance that people drive. The following strategies are available to achieve this:

1. Modify the project’s build environment characteristics to reduce VMT generated by the project.

2. Implement Transportation Demand Management (TDM) measures to reduce VMT generated by the project.

Strategies that reduce single-occupant automobile trips or reduce travel distance are called TDM strategies. There are several resources for determining the reduction in VMT due to TDM measures such as the CAPCOA Quantifying Greenhouse Gas Mitigation Measures.

As referenced in the Office of Planning and Research (OPR) Technical Advisory, the California Air Pollution Control Officers Association’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, Designed for Local Government, Communities, and Project Developers Report, Chapters 3 - Transportation, December 2021, (CAPCOA Report) quantifies the reduction in vehicle miles traveled (VMT) associated with a particular mitigation measure. The CAPCOA VMT reduction strategies include built environment changes and TDM actions.

The acceptable TDM strategies and VMT calculations are outlined in more detail in the Vehicle Miles Traveled Analysis (Appendix J.)
The recommended mitigation measures for the project type of residential with the project locational Context of suburban, consist as the following:
 T-1 (Increase Residential Density): up to 30% maximum VMT reduction.  T-18 (Provide Pedestrian Network Improvement): up to 6.4% maximum VMT reduction.  T-42 (Implement Telecommute and/or Alternative Work Schedule Program) T-1: Increase Residential Density
The proposed project Traffic Analysis Zone (TAZ) area is 1,120 acres. The Project TAZ in the Traffic Model contains 252 dwelling units (DU) without the Project (baseline condition) and 320 DU with the Project. The CAPCOA T-1 formula was applied accordingly, as shown below:

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Based on the above, after considering that the project would support and contribute to a greater residential density in the TAZ where the project is located, the project’s VMT could reasonably be reduced by 5.9% (less than the CAPCOA’s maximum reduction 30%).

T-18: Provide Pedestrian Network Improvement
According to CAPCAO, this measure would increase the trail coverage to improve pedestrian access.

Providing trails and an enhanced pedestrian network encourages people to walk instead of drive. This mode shift results in a reduction in VMT and GHG emissions.

The CAPCOA T-18 formula was applied accordingly, as shown below:

The 1.28 value (miles) in the numerator represents the trail length in study area with measure and the

0.40 value (miles) in the denominator represents the existing trail length in study area. Based on the above, the project’s VMT could reasonably be reduced by 6.4% (equal to CAPCOA’s maximum VMT reduction of 6.4%).

T-42: Implement Telecommute and/or Alternative Work Schedule Program According to CAPCAO, this measure requires projects to permit employee telecommuting and/or alternative work schedules and monitor employee involvement to ensure forecasted participation matches observed participation.

Based on information provided by the project applicant, it is understood that the proposed project is designed to accommodate the teleworking needs of future residents through features, technology, finishes and filters that help contribute to improved working conditions, increased convenience, healthier indoor air quality, and energy efficiency. The proposed project would include:
 Dedicated home office spaces;
 High-speed internet connections and Wi-Fi network infrastructure;  Data connections power outlets and USB charging outlets;  Smart home technology (e.g., smart thermostats, locks and/or video doorbells);  Modern internet routers in each home;
 Electric appliances, advanced technology HVAC air filters, and low VOC interior finishes; and  Energy efficient features (e.g., low E glass, smart thermostats, Energy-Start appliances, LED lighting, and tankless water heaters).

Based on inclusion of the above, the project’s VMT could reasonably be reduced by 6.40%.

Total Combined VMT Reduction Calculation
Based on the combined implementation of the recommended VMT impact mitigation measures described above, the total VMT reduction will be:

Therefore, the above mitigations would offset the project’s VMT impacts by 17.56%, less than would be required to fully mitigate the impact.

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CONCLUSION
Consistent with the City of Norco Resolution No.2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020) and based on the VMT methodology, criteria, guidelines, thresholds, and results outlined in the Revised Vehicle Miles Traveled Analysis (Appendix J2), the proposed project would have a significant project VMT impactthe proposed project would have a less than significant VMT impact based on the current version of the WRCOG VMT Tool, which was updated in conjunction with the update of the RIVCOM Traffic Model.

Because both VMT thresholds are met under the revised project description, no mitigation measures are required, and a Statement of Overriding Considerations is no longer required for this potential impact.Options for mitigation were reviewed including smart home technology and home office space to encourage working from home and proximity to existing transit facilities which the nearest is located approximately 1.5 miles from the project site at Norco College. Such mitigation measures were determined infeasible because 1) the number of residents choosing to work from home would be speculative and unmeasurable, and 2) proximity to existing transit facilities and resident commuter choice would also be speculative and unmeasurable. Therefore, the project would result in a significant and unavoidable adverse impact to VMT, and a Statement of Overriding Considerations would be required.

Mitigation Measures: No mitigation measures are requiredfeasible mitigation measures would be available to reduce the impact; therefore, the impact would be significant and unavoidable.

Level of Impact After Mitigation: Significant and UnavoidableLess Than Significant Impact.

The following under Section 4.17.6, References, on page 4.17-15 of the Draft EIR is amended as follows:

Linscott, Law & Greenspan, Engineers (LLG), Revised Vehicle Miles Traveled (VMT) Analysis for the Proposed JD Ranch Residential Project. June 18, 2026.

SECTION 4.18 TRIBAL CULTURAL RESOURCES
The second paragraph under subheading “AB 52/SB 18 CONSULTATION” of Section 4.18.2, Environmental Setting, on page 4.18-3 of the Draft EIR is amended as follows:

A listing of 26 tribal individuals representing 21 tribes were consulted as part of the AB 52/SB 18 consultation. A total of 12 tribes provided responses to the consultation request., of which four indicated they did not want to consult and eEight tribes requested consultation:indicated that they wanted to consult. The tribes that requested to consult include the Cahuilla Band of Indians, Gabrieleno Band of Mission Indians – Kizh Nation, Gabrieleno/Tongva San Gabriel Band of Mission Indians, Gabrielino Tongva Indians of California Tribal Council, Gabrielino-Tongva Tribe, Morongo Band of Mission Indians, Pechanga Band of Luiseno Indians, and Rincon Band of Luiseño Indians.

Consultation is currently underway with these tribes. A total of nine tribes, after multiple contact attempts, have not responded to the consultation request.

The City of Norco closed AB 52/SB 18 consultation at the end of January 2025.

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The first paragraph under subheading “IMPACT TRC-1” of Section 4.18.2, Environmental Impact Analysis, on page 4.18-6 of the Draft EIR is amended as follows:

The archaeological site recorded on the project site, (P-33-001436/CA-RIV-1436), is not listed nor 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) (refer to Section 4.5, Cultural Resources, Impact CR-2, for a discussion on eligibility). Therefore, implementation of the proposed project would not cause an adverse change to known historical resources. The regional area is known to contain historical resources and therefore, the potential exists that unknown historical resources could be present and could be encountered during excavation activities. To avoid impacts to unknown tribal historical cultural resources, the project would be required to implement Mitigation Measures TCR-1 throughand TCR-42 which would require that a certified archaeologist and a Native American monitor(s) be onsite to observe grading activities, and salvage and catalogue tribal historical cultural resources, if encountered. With implementation of Mitigation Measures TCR-1 throughand TCR-42, potential impacts to tribal resources would be less than significant.

The mitigation measures under the subheading “IMPACT TCR-1” of Section 4.18.5, Environmental Impact Analysis, on page 4.18-6 of the Draft EIR is amended as follows:

Mitigation Measures: Mitigation Measures CR-1 and CR-2 are required.

TCR-1: Prior to the issuance of grading permits, the project Applicant/Developer shall retain a representative from each of the Native American Tribes that requested to monitor all ground disturbing activities related to the development of the site under AB 52, including but not limited to, demolition, pavement removal, potholing, auguring, clearing, grubbing, tree removal, boring, grading, excavation, drilling, and trenching for both onsite and offsite improvements. Prior to the issuance of grading permits, the project applicant/developer shall enter into Monitoring Agreements with the following tribes:

1. Cahuilla Band of Indians

2. Gabrieleño Band of Mission Indians – Kizh Nation

3. Gabrieleño/Tongva San Gabriel Band of Mission Indians

4. Gabrielino Tongva Indians of California Tribal Council

5. Gabrielino-Tongva Tribe

6. Morongo Band of Mission Indians

7. Pechanga Band of Luiseno Indians

8. Rincon Band of Luiseno Indians
All tribes are invited to monitor the entire duration of grading; however, the Applicant will only be required to pay up to two monitors per day pursuant to a rotating monitoring payment schedule.

These Agreements shall be submitted to the City of Norco prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

TCR-2: Pursuant to the Cultural Resources Monitoring Plan (CRMP), the Native American Tribal Representatives shall actively monitor project-related grading and in the event that a tribal cultural resource(s) (TCRs) is discovered, shall have the authority to temporarily divert,

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redirect, or halt grading activity to allow recovery of archaeological and/or cultural resources. All TCRs will be temporarily curated on the project site until final disposition is determined. The Applicant/Developer shall relinquish ownership of all TCRs, including sacred items, burial goods, and all archaeological artifacts and non-human remains discovered to the consulting Tribes for final disposition. Leaving artifacts in place (in situ) or reburial of them onsite are the preferred methods of mitigation. Reburial shall not occur until all cataloguing and basic recordation has been completed and notice to proceed by the Archaeologist and Native American Tribal Representatives is given. If the eight Tribes cannot come to an agreement on the final disposition of the TCRs, the Native American Heritage Commission will be asked to mediate the dispute.

TCR-3: Onsite Tribal monitoring shall conclude upon either of the following occurrences (1) written confirmation to the Archaeologist and Native American Tribal Representative(s) from a designated point of contact for the project Applicant/Developer/Lead Agency that all ground-disturbing activities and phases in native soil at the project site or in connection with the project are complete; or (2) a determination and written notification by the Archaeologist and Native American Representative(s) to the Project Applicant/Developer/Lead Agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to further impact any tribal resources.

TCR-4: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/NonCeremonial): Upon discovery of any cultural resources/TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than a radius of 50 feet) and shall not resume until the discovered resource has been fully assessed by onsite Archaeologist and Native American Tribal Representative(s). The Native American Tribal Representative(s) shall retain all discovered TCRs in the form and/or manner the Tribe(s) deem appropriate, by the Tribe(s) sole discretion, and for any purpose the Tribe(s) deems appropriate, including for educational, cultural and/or historic purposes.

The second and third paragraphs under subheading “IMPACT TRC-2” of Section 4.18.5, Environmental Impact Analysis, on page 4.18-7 of the Draft EIR is amended as follows:

The EIC records search identified one cultural resource (P-33-001436) recorded in the northwest portion of the project site, adjacent to Bluff Street. The NAHC Sacred Lands File Search was negative.

The grading activities associated with construction of the proposed project would encounter native soils and could have the potential to encounter unknown historical resources. Because tribal cultural resources are known to occur within the region, there is the potential that tribal cultural resources could be encountered during excavation activities. To avoid adverse impacts to tribal cultural resources that could be encountered during construction, it is recommended that a qualified archaeologist and Native American monitor be retained to monitor grading of the site. Should the archaeologist and Native American Monitor find the potential exists for impacts to tribal cultural resources, the archaeologist and Native American Monitor should have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of tribal cultural resources and report on the findings. With implementation of Mitigation Measures CR-1 (Monitoring) and CR-2 (Reporting), potential impacts to unknown tribal historical cultural resources would be less than significant.

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The City of Norco initiated tribal consultation for the purposes of AB 52 and SB 18 for the proposed project on July 26, 2023. A listing of 26 tribal individuals representing 21 tribes were consulted as part of the AB 52/SB 18 consultation. A total of 12 tribes provided responses to the consultation request, of which four indicated they did not want to consult and eight indicated that they wanted to consult.

The tribes that requested to consult include the Cahuilla Band of Indians, Gabrieleno Band of Mission Indians – Kizh Nation, Gabrieleno/Tongva San Gabriel Band of Mission Indians, Gabrielino Tongva Indians of California Tribal Council, Gabrielino-Tongva Tribe, Morongo Band of Mission Indians, Pechanga Band of Luiseno Indians, and Rincon Band of Luiseño Indians. Consultation is currently underway with these tribes. A total of nine tribes, after multiple contact attempts, have not responded to the consultation request. Consultation has been concluded with the implementation of Mitigation Measures TCR-1 through TCR-4, potential impacts to tribal historical cultural resources would be less than significant.

In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5; Health and Safety Code Section 7050.5; Public Resources Code Section 5097.94 and Section 5097.98 must be followed. Therefore, with compliance with Mitigation Measures TCR-51 and CR-2, potential impacts to historical resourcestribal human remains and associated funerary or ceremonial objects would be less than significant.

The mitigation measures under the subheading “IMPACT TCR-2” of Section 4.18.5, Environmental Impact Analysis, on page 4.18-7 of the Draft EIR is amended as follows:

Mitigation Measures: Mitigation Measures TCR-1 throughand TCR-42 are required as well as TCR-5.

TCR-5: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects: Native American human remains are defined in Public Resources Code (PRC) 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC Section 5097.98, are also to be treated according to this statute. If Native American human remains and/or grave goods are discovered or recognized on the project site, then PRC 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). Section 5097.98 of the PRC states that, when the Native American Heritage Commission (NAHC) receives notification of a discovery of Native American human remains from the county coroner pursuant to Section 7050.5 of the California Health and Safety Code, the NAHC shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The Most Likely Descendants (MLD) shall complete their inspection within 48 hours of being granted access to the site. The designated MLD would then recommend, in consultation with the property owner, the means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

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SECTION 4.19 UTILITIES AND SERVICE SYSTEMS
The first paragraph under subheading “STORMWATER MANAGEMENT” of Section 4.19.2, Environmental Setting, on page 4.19-4 of the Draft EIR is amended as follows:

The Pre-Developed Hydrology Condition on the project site is shown previously in Figure 4.10-1, PreDeveloped Condition Hydrology Map. In the existing condition, the site is open space and was a former dairy farm. Approximately 1.80 acres (.046) of 37.8434.48 acres site consists of impervious surfaces (e.g., buildings). The site is relatively flat. However, surface water drains from northeast to southwest to a sump. There is an existing 54-inch storm drain along River Road; refer to Figure 3-9, Tentative Tract Map.

The second paragraph under subheading “SOLID WASTE DISPOSAL” of Section 4.19.2, Environmental Setting, on page 4.19-4 of the Draft EIR is amended as follows:

The El Sobrante Landfill (10910 Dawson Canyon Road, Corona) is permitted to receive 16,054 tons of solid waste per day and has a maximum permitted capacity of 209,90,000 cubic yards with a remaining capacity of 47.250.1 million tons per the 202321 Annual Report.4 The Lamb Canyon Landfill (16411
Lamb Canyon Road, Beaumont) is permitted to receive 5,000 tons of solid waste per day and has a maximum permitted capacity of 21.1 million tons with a remaining capacity of 6.77.3 million tons.1 The Badlands Landfill (31125 Ironwood Avenue, Moreno Valley) is permitted to receive 5,000 tons of solid waste per day and has a maximum permitted capacity of 68.682.3 million tons with a remaining capacity of 49.83.5 million tons.1
Table 4.19-6, the third and fourth paragraphs under subheading “IMPACT USS-2” of Section 4.19.5, Environmental Impact Analysis, on page 4.19-17 of the Draft EIR is amended as follows:

Table 4.19-6
Estimated Water Demand
Land Use Population Demand Rate Water Demand in
Gallons Per Day1
Annual Water
Demand
Residential 210227 361 gallons per day per person 75,81088,445 8599 acre-feet Notes:
1 Domestic water use City of Norco Urban Water Management Plan Table 5 Baseline Per Capita Day.

As shown in Table 4.19-6, the project is estimated conservatively to have a water demand of 8599 acre-feet per year. The increase in demand would be an approximate 0.0110.013 increase compared to the 2025 estimated demand of 7,425 acre-feet and an approximate increase of 0.0100.012 in 2045.

The increase in water demand would be nominal.

The City Urban Water Management Plan shows that there would be between 6,840 acre-feet and 7,590 acre-feet of additional water supplies over projected demands during multiple dry years between 2025 and 2045. The proposed project would increase water demand by 8599 acre-feet per 4 Riverside County Department of Waste Resources, NOP and NOA Correspondence with Katherine Avila, Urban/Regional Planner I, dated July 19, 2023 and July 18, 2024. (Appendix A2)

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year. Based on available water supplies between 2025 and 2045, there would be adequate water supplies for the project.

Table 4.19-7 and the second paragraph under subheading “IMPACT USS-3” of Section 4.19.5, Environmental Impact Analysis, on pages 4.19-18 and 4.19-19 of the Draft EIR is amended as follows:

Table 4.19-7
Estimated Wastewater Demand
Land Use Households Demand Rate
Per Household Per Day Total Daily Demand
Residential 6468 2501 gpd 1716,000 gpd
Abbreviations: gpd – gallons per day
Notes:
1 State Water Resources Control Board, Water Quality Control Policy for Siting, Design, Operation, and Maintenance of Onsite Wastewater Treatment Systems; April 18, 2023.
<https://www.waterboards.ca.gov/water_issues/programs/owts/docs/adopted_owts_policy.pdf> Wastewater treatment for the project would be provided by the Western Riverside County Regional Wastewater Authority (WRCRWA), a tertiary wastewater treatment facility. The total treatment capacity of the plant is 14 million gallons per day (mgd). The City of Norco owns 2.5 mgd of conveyance capacity and 2.7 mgd of treatment capacity at the Western Riverside County Regional Wastewater Authority. Norco has an average daily flow of approximately 1.8 mgd. The wastewater flows generated by the proposed project would increase wastewater flows by 1716,000 gpd, a minimal increase of

0.5963% of the total available treatment capacity of 2.7 mgd; therefore, impacts would be less than significant.

The first paragraph under subheading “IMPACT USS-4” of Section 4.19.5, Environmental Impact Analysis, on page 4.19-19 of the Draft EIR is amended as follows:

Solid waste disposal for the proposed project would be provided at the El Sobrante Landfill, Lamb Canyon Sanitary Landfill and/or the Badlands Landfill. The El Sobrante Landfill is permitted to receive 16,054 tons of solid waste per day and has a maximum permitted capacity of 209,910,000 cubic yards with a remaining capacity of 47.250.1 million tons per the 202321 Annual Report.5 The Lamb Canyon
Landfill is permitted to receive 5,000 tons of solid waste per day and has a maximum permitted capacity of 21.1 million tons with a remaining capacity of 6.77.3 million tons.2 The Badlands Landfill is
permitted to receive 5,000 tons of solid waste per day and has a maximum permitted capacity of

68.682.3 million tons with a remaining capacity of 49.83.5 million tons.2 NOA Correspondence has been added to Section 4.19.6, References, on page 4.19-21 of the Draft EIR is amended as follows:

Riverside County Department of Waste Resources, NOA Correspondence with Katherine Avila, Urban/Regional Planner I, dated July 18, 2024. (Appendix A2) 5 Riverside County Department of Waste Resources, NOP and NOA Correspondence with Katherine Avila, Urban/Regional Planner I, dated July 19, 2023 and July 18, 2024. (Appendix A2)

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SECTION 4.20 WILDFIRE
The first paragraph under the subheading “2022 California Building and Fire Codes” of Section 4.20.3, Regulatory Setting, on page 4.20-4 of the Draft EIR is amended as follows:

In accordance with the 2022 California Building and Fire Codes as adopted by the County of RiversideOrange; specifically Building Code Chapter 7A; Fire Code, Chapter 49. Chapter 7A of the Building Code focuses primarily on hardening the structures against wildland fire impacts. In addition to state regulations and adopted model codes, the Project Site will be in compliance with the RVCFDOCFA Guidelines, Standards, and Technical Policies (Fire Alarm systems, Architectural review, Fire Master Plan, Fire Sprinkler systems, Underground installations, Fuel Modification & Vegetation Management, and any other applicable standards).

The fourth paragraph under subheading “IMPACT WF-1” of Section 4.20.5, Environmental Impact Analysis, on page 4.20-8 of the Draft EIR is amended as follows:

In the event evacuation is required, the Riverside County Sheriff’s Department would identify and direct traffic to designated emergency evacuation routes to ensure that residents can leave their neighborhoods safely, which would avoid any potential conflicts with emergency response plans.

Should they be needed, evacuation routes would be established based on the location and magnitude of an event. The City’s main evacuation routes are the 1-15 Freeway and Hamner Avenue (2.1 miles from project site). Secondary routes include Second Street and River Road (0.86 miles from project site)/Archibald Avenue (0.79 miles from the project site), California Avenue/North Drive (4.15 miles from project site), and Mountain Avenue and Hidden Valley Parkway (2.13 miles from project site)/McKinley Avenue (3.77 miles from project site). The proposed project is estimated to have 210227 residents. In the event evacuation is needed, a worst case of 210227 vehicle trips would occur assuming each resident would drive their own vehicle. The vehicle trips would be distributed between the two different access points (River Road and Bluff Street) from the project site, which would reduce congestion. The City of Norco’s Fire Department would review site plans for the proposed project to ensure adequate ingress/egress. In addition, the proposed project would comply with applicable regulations (e.g., CBC, CFC).

SECTION 5.0 CUMULATIVE IMPACT ANALYSIS
The fifth paragraph under subheading “STORMWATER MANAGEMENT” of Section 4.19.2, Environmental Setting, on page 4.19-4 of the Draft EIR is amended as follows:

The proposed project proposes approval of a General Plan Amendment, a Zone Change, and a Tentative Tract Map, to allow for the development of a 638-unit single-family detached housing project on a minimum of 10,000 square foot lots in accordance with the City’s R-1 Zoning regulations with offsite equestrian/pedestrian trails and River Road and Bluff Street improvements. The proposed project would also retain the existing single-family detached home “in place” (Lot 649) and the City’s Water Quality Infiltration Basin and Storm Detention Basin (Lot GA); refer to Figure 3-9, Tentative Tract Map.

The first paragraph under Section 5.2.14, Population and Housing, on page 5-10 of the Draft EIR is amended as follows:

The proposed project would allow 638 single-family dwelling units to be developed on the project site.

The City of Norco’s estimated household is 3.34 persons per dwelling unit; therefore, the project would

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have approximately 210227 residents. The estimated population increase would be a negligible increase and would be in the range of estimated future growth projections and would not be considered substantial unplanned housing growth. As such, the proposed project would not contribute considerably to cumulative adverse unplanned housing growth impacts. The proposed project would increase the population on the project site by approximately 103120 persons over the estimated population anticipated in the existing General Plan.

The first paragraph under Section 5.2.16, Recreation, on page 5-11 of the Draft EIR is amended as follows:

The proposed project would increase population on the project site and would increase the demand for recreation facilities. The proposed project has been designed to provide onsite recreation trail amenities for residents and expand existing offsite recreation trails which would expand trail recreation opportunities and reduce the pressure on existing recreation facilities in the City. The project proposes a 12-foot equestrian trail on the north side of River Road and on the east side of Bluff Street. Both equestrian trails would allow connection to an existing City equestrian trail. Additionally, within the project, a 12-foot equestrian trail is proposed along the local streets that would connect to the proposed equestrian trails along River Road and Bluff Street. Additionally, there would be a 15- foot pedestrian access (Lot IF), between Lots 10 and 11, to Sundance Park. The overall intent of the project is to create an equestrian community that is unified by tree lined equestrian trails that circulate through the community connecting residents to the City’s equestrian heritage.

The second and third paragraphs under Section 5.2.17, Transportation, on page 5-12 of the Draft EIR is amended as follows:

Pursuant to the City of Norco Resolution No. 2020-62 – Vehicle Miles Travelled Impact (dated September 2, 2020), the proposed project was revised to remove five single-family units and was evaluated using the Western Riverside Council of Governments (WRCOG) VMT Tool. The California Office of Planning and Research states that a project’s cumulative Vehicle Miles Traveled (VMT) impacts are based on a determination of whether the “incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” City of Norco Resolution No. 2020-62 – Vehicle Miles Traveled Impact (dated September 2, 2020) requires project-by-project analysis.The California Office of Planning and Research PR states that a project’s cumulative Vehicle Miles Traveled (VMT) impacts are based on a determination of whether the “incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” City of Norco Resolution No.2020-62 – Vehicle Miles Travelled Impact (dated September 2, 2020) requires project-by-project analysis.

As confirmed by the Revised VMT Analysis Technical Memorandum prepared by LLG Engineers (June 18, 2026), the current version of the WRCOG VMT Tool, which was updated in conjunction with the update of the RIVCOM Traffic Model, demonstrates that the project VMT per service population (35.0 VMT/SP) and VMT per resident (14.3 VMT/Resident) would both be below the City’s applicable thresholds of 47.4 VMT/SP and 15.3 VMT/Resident, respectively. Therefore, consistent with the Revised VMT Analysis Technical Memorandum prepared by LLG Engineers (June 18, 2026), the proposed project can be presumed to have a less than significant cumulative VMT impact, and no mitigation measures are required. Related cumulative development projects shown in Table 5-1 would be evaluated for potential VMT impacts on a project-by-project basis.Pursuant to the City VMT Policy,

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if a significant VMT impact is identified, measures to reduce the project’s VMT impact should be identified. The proposed project would implement several Transportation Demand Management (TDM) measures, which when combined, reduce VMT by 17.50%. Because the proposed project’s VMT would not be completely offset by Mitigation Measure TRANS-1, the project would have a significant unavoidable adverse impact to VMT. Related cumulative development projects shown in Table 5-1 would be evaluated for potential VMT impacts, and would have to comply with applicable regulations, and mitigation measures on a project-by-project basis to ensure significant cumulative impacts to VMT do not occur.

SECTION 6.0 ALTERNATIVES ANALYSIS
Table 6-1 under Section 6.5, Proposed Project Alternatives, on page 6-3 of the Draft EIR is amended as follows:

Table 6-1
Project Alternatives
Topic Proposed
Project
Alternative 1:

No Project
Alternative 2:

Existing Zoning with No
Land Use Exchange
Unit Count 68 0 4232
Zoning 10,000 sq.ft./ac N/A 21,780 sq.ft./ac
Includes City Land Swap Yes No No
Meets Project Objectives Yes No Meets Objective 1
and 2 only
The first paragraph under Section 6.7, Alternative 2: Existing Zoning With No Land Use Exchange, on page 6-8 of the Draft EIR is amended as follows:

Under Alternative 2, the project would be developed under its current General Plan and Zoning designations. Under the current zoning, an estimated total of 4232 (net) dwelling units could be developed resulting in an increase ofwith an estimated resident population of 139107 residentspeople. There would be no land use exchange betweenof parcels with the City of Norco and TACRD as shown on Figure 3-1, Parcel Configuration. Grading would occur on 26.15 acres versus 27.57 acres with the proposed project. The existing parcel owned by the City of Norco, would continue to be used by the City as a spoils/staging yard, whereas if the land use exchange occurs, the site would be cleaned up at no cost to the City. There would be approximately 21 fewer units constructed to help meet the RHNA requirements.no opportunity for the City to increase compliance with regional housing needs, Without the project, no ability to build critical missing equestrian trail connections on Bluff Street and River Road would not be constructed and no roadway improvements on River Road and landscaping on River Road and Bluff Street would not be constructedinstalled.

The first paragraph under Section 6.7.1, Aesthetics, on page 6-8 of the Draft EIR is amended as follows:

Neither Alternative 2 nor the proposed project would have a substantial adverse effect on any scenic vistas and would not have an adverse impact on aesthetic resources along a State Scenic Highway.

Compared to the proposed project, Alternative 2 would have 4232 (net) dwelling units and would be a less dense residential project. Aesthetic impacts during construction would be similar between the proposed project and Alternative 2 (no land use exchange), since grading impacts would beare similar,

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however, grading will occur closer to the homes to the northeast under Alternative 2. Under Alternative 2, the equestrian trail on Bluff Street and part of River Road would not be constructed nor would landscape treatment along Bluff Street and a portion of River Road be constructedinstalled.

Light and glare would be expected to be similar to the proposed project. However, impacts would be expected to be greater than the proposed project due to the elimination of the trails and roadway landscaping improvements.

The first paragraph under Section 6.7.14, Population and Housing, on page 6-11 of the Draft EIR is amended as follows:

Under Alternative 2, the number of housing units and estimated population for the site would be consistent with the existing General Plan. Alternative 2 would provide approximately 2136 fewer new homes in the City. Compared to the proposed project, Alternative 2 would generate lower population and housing units. However, the City is required by the State to meet regional housing needs and Alternative 2 would not contribute as much to that objective. Therefore, Alternative 2 has greater impacts to population and housing.

The first paragraph under Section 6.7.17, Transportation, on page 6-12 of the Draft EIR is amended as follows:

Both the proposed project and Alternative 2 can meet City thresholds to comply with numeric standards for vehicle miles traveled. However, Alternative 2 would limit accessibility to the project for emergency access because there would be no access to Bluff Street and roadway improvements to build out the River Road connection to the Bluff Street Intersection which would not be completed.

For these reasons, Alternative 2 would have similarless VMT impacts asthan the proposed project but greater transportation impacts.

Table 6-2 under Section 6.8, Summary of Alternative Impacts, on page 6-14 of the Draft EIR is amended as follows:

Table 6-2
Project Alternative Impact Comparison
Issues Proposed Project Alternative 1
No Project
Alternative 2
Existing Zoning
with
No Land Use
Exchange
Aesthetics Less Than Significant Greater Greater
Agriculture/Forestry Resources No Impact Similar Similar Air Quality Less Than Significant Impact Less Less
Biology Less Than Significant With Mitigation Incorporated Greater Similar Cultural Resources Less Than Significant With Mitigation Incorporated Less Similar Energy Less Than Significant Less Less
Geology/Soils Less Than Significant With Mitigation Incorporated Less Similar Greenhouse Gas Emissions Less Than Significant Less Less Hazards/Hazardous Materials Less Than Significant With Mitigation Incorporated Less Greater Hydrology/Water Quality Less Than Significant Less Similar Land Use and Planning Less Than Significant Greater Greater Mineral Resources Less Than Significant Similar Similar

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Issues Proposed Project Alternative 1
No Project
Alternative 2
Existing Zoning
with
No Land Use
Exchange
Noise Less Than Significant Less Less
Population/Housing Less Than Significant Greater Greater Public Services Less Than Significant Less Less
Recreation Less Than Significant Greater Greater
Transportation Significant and Unavoidable ImpactLess Than Significant Impact With Mitigation Incorporated Less LessGreater Tribal Cultural Resources Less Than Significant With Mitigation Incorporated Less Similar Utilities/Service Systems Less Than Significant With Mitigation Incorporated Less Less Wildfire Less Than Significant Greater Similar
The first, third and fifth paragraphs under Section 6.9, Environmentally Superior/Preferred Alternative, on page 6-15 of the Draft EIR is amended as follows:

CEQA Guidelines Section 15126.6 requires that EIRs identify the Environmentally Superior Alternative and discuss the facts that support that selection. The Environmentally Superior Alternative is typically the Alternative that results in the least amount of significant unavoidable adverse impacts. For the proposed project, oneno significant unavoidable adverse impact waswere identified for transportation associated with vehicle miles travelled (VMT). The proposed project would also result in impacts to biological resources, cultural resources, geology/soils, hazards/hazardous materials, transportation, tribal cultural resources and utilities/service systems which were determined to be less than significant with mitigation. The remaining environmental topics were determined to either have less than significant impacts or no impacts with implementation of standard regulations and requirements.

Alternative 2 Existing Zoning With No Land Use Exchange was determined to result in no significant unavoidable impacts. While Alternative 2 would still result in increased VMT compared to the existing condition, impacts were determined to be less than significant because there would be a reduction from 68 units to 4232 (net) dwelling units which would be under the VMT screening threshold.

Alternative 2 would also result in impacts to biological resources, cultural resources, geology/soils, hazards/hazardous materials, tribal cultural resources and utilities/service systems, which would also be less than significant with mitigation. The remaining environmental topics would also either have less than significant impacts or no impacts with implementation of standard regulations and requirements.

Because both the proposed project and Alternative 2 would not result in a significant unavoidable adverse impact, and therefore,Alternative 2 would not be considered environmentally superior to the proposed project on that basis; however, Alternative 2 would only meet two of the four project objectives. Two critical objectives that would not be achieved include construction of critical equestrian trail linkages and the completion of River Road improvements and landscaping along the River Road and Bluff Street frontages. Because Alternative 2 would only partially meet the project objectives, it is not considered the Preferred Alternative.

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SECTION 7.0 OTHER CEQA CONSIDERATIONS
The first paragraph on page 7-3 of Section 7.2, Growth-Inducing Impacts, of the Draft EIR is amended as follows:

In 2023, the City of Norco had a population of 25,037 persons and an estimated population of 32,100 in 2040. The proposed project would construct 6368 single-family dwellings. Based on the City of Norco average household size of 3.34 persons per household, the project is estimated to have 210227 residents. However, under the current zoning, a total of 4232 (net) single-family dwelling units could be developed with an estimated resident population of 139107 persons.

Section 7.4, Unavoidable Adverse Impacts, of the Draft EIR is amended as follows:

An EIR must identify any significant environmental effects that would result from the project. (Public Resources Code, §21100, Subdivision (b)(2)(B).) There are no significant and unavoidable environmentalVMT effects associated withof the project as summarized below.

VEHICLE MILES TRAVELED IMPACT
Project Impact
As shown in Table 7-1, Project Threshold for VMTWRCOG VMT Screening Tool Results, the proposed project’s Origin-Destination (OD) VMT per Service Population and Production-Attraction (PA) VMT per Resident are both below the City of Norco’s applicable thresholds. Based on the criteria outlined in the Revised VMT Analysis Technical Memorandum (Appendix J2), the proposed project would be presumed to have a less than significant project VMT impact.VMT per Capita is 22.50% higher than the City average VMT per Capita. Based on the criteria outlined in this report, the proposed project will exceed the City of Norco base year VMT per Capita of 13.05 and thus will have a significant project VMT impact.

Table 7-1
Project Threshold for VMTWRCOG VMT Screening Tool Results Base YearVMT Metric TAZ 3150TAZ 1559
(Project Site)
City AverageJurisdiction
Threshold
Compare to City Threshold
(% Difference)
VMT Per
CapitaProductionAttraction (PA) VMT per
Resident

14.315.99 15.313.05 22.506.8% Higher
(below threshold)
Origin-Destination (OD)
VMT per Service
Population

35.0 47.4 -26.12% (below threshold)
Source: Linscott, Law & Greenspan, Engineers (LLG), Revised Vehicle Miles Traveled (VMT) Analysis; March 21, 2024June 18, 2026 (Appendix J2).

Cumulative Impact
As shown in Table 7-12, Cumulative Threshold for VMTWRCOG VMT Screening Tool Results, the proposed project’s VMT per service population and VMT per resident would both be below the City of Norco's applicable thresholds. Therefore, consistent with the Revised VMT Analysis Technical

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Memorandum prepared by LLG Engineers (June 18, 2026) (Appendix J2), the proposed project can be presumed to have a less than significant cumulative VMT impact.total daily VMT within the City is

0.10% higher than the “No Project” scenario total daily VMT under cumulative conditions. Based on the criteria outlined in the Vehicle Miles Traveled (VMT) Analysis (Appendix J), the proposed project total daily VMT will exceed under the “With Project” condition when compared to the “Without Project” condition and thus the project will have a significant cumulative VMT impact.

Table 7-2
Cumulative Threshold for VMT
Cumulative Year With Project Scenario Without project Scenario Compare to Threshold Total VMT 1,164,288.81 1,163,127.15 0.10% Higher
Source: Linscott, Law & Greenspan, Engineers (LLG), Vehicle Miles Traveled (VMT) Analysis; March 21, 2024.

SECTION 8.0 INVENTORY OF ENVIRONMENTAL IMPACTS
The following inventory of mitigation measures of the Draft EIR are amended as follows:

CULTURAL RESOURCES
CR-1: Prior to the issuance of grading permits, the project Applicant/Developer shall retain a qualified Archaeologist to monitor all ground disturbing activities related to the development of the site, including but not limited to, demolition, pavement removal, potholing, auguring, clearing, grubbing, tree removal, boring, grading, excavation, drilling, and trenching for both onsite and offsite improvements.

CR-2: Prior to the issuance of grading permits, the Archaeologist, in consultation with the Tribe(s) and the City of Norco, shall develop a Cultural Resources Monitoring Plan (CRMP) to address the details, timing, and protocols of all cultural resources activities that occur on the project site. At the project pre-grading meeting, the Archaeologist, the Native American Tribal Representative(s), the Applicant/Developer, and the excavation and grading Contractor shall discuss appropriate grading and ground disturbing methods within archaeologically and culturally sensitive areas on the project site pursuant to the CRMP.

CR-3: Pursuant to the Cultural Resources Monitoring Plan, the Archaeologist shall actively monitor project-related grading and in the event that cultural resources are discovered, shall have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of cultural resources.

CR-4: The Archaeological monitor will complete daily monitoring logs that describe daily grounddisturbing activities, the type of construction activities performed, locations of grounddisturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries. Monitor logs will identify and describe any discovered archaeological and/or tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or “TCRs”), as well as any discovered Native American (ancestral) human remains and burial goods. Non-Tribal, historic-era cultural resources will also be

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documented. Copies of monitoring logs will be provided to the project applicant/developer/lead agency upon written request.

CR-5: At the completion of onsite and offsite ground-disturbing activities, a Phase IV Monitoring Report shall be prepared by the Archaeologist and submitted to the City documenting all monitoring activities conducted by the project Archaeologist and Native American Tribal Representative(s). All reports produced will be submitted to the City of Norco, the South Coastal Information Center, San Diego State University, and the consulting Tribe(s).

CR-63: Section 7050.5 of the California Health and Safety Code provides for the disposition of accidentally discovered human remains. Section 7050.5 states that, if human remains are found, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the county coroner has determined, within two working days, the appropriate treatment and disposition of the human remains.

If the coroner recognizes those remains to be Native American or has reason to suspect so, the coroner shall contact the Native American Heritage Commission (NAHC) within 24 hours.

Section 5097.98 of the PRC states that, when the NAHC receives notification of a discovery of Native American human remains from the county coroner pursuant to Section 7050.5 of the California Health and Safety Code, the NAHC shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The Most Likely Descendants (MLD) shall complete their inspection within 48 hours of being granted access to the site. The designated MLD would then recommend, in consultation with the property owner, the means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods.

CR-1: Prior to the issuance of grading permits, the Applicant shall retain a qualified Archaeologist and Native American Tribal representative(s) to monitor grading and other ground disturbances related to site development. The Archaeologist, in consultation with the Tribe(s) and City, shall develop a Cultural Resources Monitoring Plan (CRMP) to address the details, timing, and protocols of all cultural resources activities that occur on the project site. At the project pre-grading meeting, the Archaeologist, the Tribal representative(s), the Applicant, and the excavation and grading contractor shall discuss appropriate grading and ground disturbing methods within archaeologically and culturally sensitive areas on the project site pursuant to the CRMP. Should the Archaeologist, after consultation with the consulting Tribe(s), find the potential exists for impacts to archaeological resources, cultural resources and/or sacred sites, the archaeologist and the Native American tribal representative(s) shall actively monitor project-related grading and in the event that cultural resources are discovered, shall have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of archaeological and/or cultural resources. All cultural material will be temporarily curated on the project site until final disposition is determined. The Applicant shall relinquish ownership of all cultural material, including sacred items, burial goods, and all archaeological artifacts and non-human remains discovered to the consulting Tribe(s) for final disposition. Leaving artifacts in place (in situ) or reburial of them on site are the preferred methods of mitigation. Reburial shall not occur until all cataloguing and basic recordation has been completed.

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CR-2: At the completion of grading, excavation, and ground-disturbing activities on the site, a Phase IV Monitoring Report shall be submitted to the City documenting all monitoring activities conducted by the project archaeologist and Native Tribal Monitor(s). All reports produced will be submitted to the City of Norco, the Eastern Information Center, University of California, Riverside, and the consulting Tribe(s).

HAZARDS AND HAZARDOUS MATERIALS
HAZ-1: Prior to demolition of the buildings, the Applicant shall prepare an asbestos, lead paint and polychlorinated biphenyl caulk survey on the buildings and sampling around the area of those buildings. In the event asbestos containing building materials, lead paint or polychlorinated biphenyl caulk are identified, it shall be removed and disposed of in accordance with local, state, and federal regulations under the guidance of a California Occupational Safety and Health Administration (Cal/OSHA) - Certified Asbestos Consultant (CAC) and/or Lead-Related Construction Inspector/Assessor.

HAZ-21: Additional sampling shall be conducted following demolition and prior to construction to evaluate the extent, depth, and distribution of dichlorodiphenyldichloroethylene (DDE).

Following additional sampling, recommendations will be made regarding remediation and/or other mitigation and/or sampling options.

HAZ-32: Undocumented fill is located on the northern parcel. One of the following options must be completed to mitigate this REC prior to construction:
 The property owner can properly dispose of the undocumented fill.  The property owner can properly evaluate the fill to document its suitability for use at the site and provide sampling rationale/standards with sampling location and laboratory data to Client for evaluation.
 Client can properly evaluate the fill using EPA SW-846 or other acceptable sampling guidance.

HAZ-4: Prior to import and placement on the project site, all imported soil and fill material shall be tested by a qualified environmental professional to ensure any contaminants of concern are within Department of Toxic Substances Control's (DTSC) and U.S. Environmental Protection Agency Regional Screen Levels for the intended land use. The environmental professional shall collect and analyze representative samples from the source location of any soil or fill material proposed for import, prior to its removal from the source site. To minimize the possibility of introducing contaminated soil and fill material, there shall be documentation of the origins of the soil or fill material and, if applicable, sampling shall be conducted to ensure that the imported soil and fill material meets screening levels outlined in DTSC’s Preliminary Endangerment Assessment (PEA) Guidance Manual for the intended land use. The soil sampling shall include analysis based on the source of the fill and knowledge of the prior land use. If testing reveals contaminant concentrations that exceed applicable DTSC and EPA screening levels for the intended land use, the soil or fill material shall be rejected and shall not be imported to the project site. The project Applicant shall then either: 1) source alternative fill material and conduct the required testing, or 2) implement appropriate soil treatment measures at the source location to reduce

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contaminant concentrations below applicable screening levels, as demonstrated through additional testing. Documentation of all soil testing results and any required treatment measures shall be submitted to the City of Norco for review and approval prior to importing any soil or fill material to the project site.

NOISE
PDF-NOI-1: Prior to the issuance of the grading permit, the project applicant shall submit a construction related noise mitigation plan to the City for review and approval. The plan shall depict the locations of where construction equipment will operate on the project site and how the noise from the construction equipment will be mitigated during construction of the project, through use of the following methods:

1. Construction activity, including equipment start-up and use, and the loading, unloading and handling of materials, shall not commence before 6:30 AM, or continue beyond 7:00 PM, on weekdays. No construction activity for residential development projects that consist of more than one unit is permitted on Saturdays, Sundays, or national holidays unless otherwise permitted with conditions on entitlements. The restrictions from Saturdays, Sundays, and national holidays shall not apply to single-building permits for expansion and upgrade to existing buildings; however, no such construction shall begin before 8:00 AM. Deviations from these hours may be approved if the Conditions of Approval allow and if approved by the Community Development Director;Restriction of use of construction equipment and haul truck operations between 7:00 PM and 7:00 AM, Monday through Friday and between 7:00 PM and 8:00 AM on Saturday and Sunday, unless specified by permit for activities such as pouring of concrete that may need to occur outside of these hours;

2. Placement of temporary noise attenuation fences around stationary equipment (i.e., air compressors and generators) that are used in close proximity to sensitive receptors;

3. Placement of equipment storage and staging areas as far away as practical from sensitive receptors;

4. Limitation of construction equipment idling time to less than 5 minutes per occurrence; and,

5. Require the use of construction equipment noise attenuation features that include mufflers and engine shrouds that are at least as effective as the original manufacturer equipment.

TRIBAL CULTURAL RESOURCES
TCR-1: Prior to the issuance of grading permits, the project Applicant/Developer shall retain a representative from each of the Native American Tribes that requested to monitor all ground disturbing activities related to the development of the site under AB 52, including but not limited to, demolition, pavement removal, potholing, auguring, clearing, grubbing, tree removal, boring, grading, excavation, drilling, and trenching for both onsite and offsite

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improvements. Prior to the issuance of grading permits, the project applicant/developer shall enter into Monitoring Agreements with the following tribes:

1. Cahuilla Band of Indians

2. Gabrieleño Band of Mission Indians – Kizh Nation

3. Gabrieleño/Tongva San Gabriel Band of Mission Indians

4. Gabrielino Tongva Indians of California Tribal Council

5. Gabrielino-Tongva Tribe

6. Morongo Band of Mission Indians

7. Pechanga Band of Luiseno Indians

8. Rincon Band of Luiseno Indians
All tribes are invited to monitor the entire duration of grading; however, the Applicant will only be required to pay up to two monitors per day pursuant to a rotating monitoring payment schedule.

These Agreements shall be submitted to the City of Norco prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

TCR-2: Pursuant to the Cultural Resources Monitoring Plan (CRMP), the Native American Tribal Representatives shall actively monitor project-related grading and in the event that a tribal cultural resource(s) (TCRs) is discovered, shall have the authority to temporarily divert, redirect, or halt grading activity to allow recovery of archaeological and/or cultural resources. All TCRs will be temporarily curated on the project site until final disposition is determined. The Applicant/Developer shall relinquish ownership of all TCRs, including sacred items, burial goods, and all archaeological artifacts and non-human remains discovered to the consulting Tribes for final disposition. Leaving artifacts in place (in situ) or reburial of them onsite are the preferred methods of mitigation. Reburial shall not occur until all cataloguing and basic recordation has been completed and notice to proceed by the Archaeologist and Native American Tribal Representatives is given. If the eight Tribes cannot come to an agreement on the final disposition of the TCRs, the Native American Heritage Commission will be asked to mediate the dispute.

TCR-3: Onsite Tribal monitoring shall conclude upon either of the following occurrences (1) written confirmation to the Archaeologist and Native American Tribal Representative(s) from a designated point of contact for the project Applicant/Developer/Lead Agency that all ground-disturbing activities and phases in native soil at the project site or in connection with the project are complete; or (2) a determination and written notification by the Archaeologist and Native American Representative(s) to the Project Applicant/Developer/ Lead Agency that no future, planned construction activity and/or development/ construction phase at the project site possesses the potential to further impact any tribal resources.

TCR-4: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/NonCeremonial): Upon discovery of any cultural resources/TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than a radius of 50 feet) and shall not resume until the discovered resource has been fully assessed by onsite Archaeologist and Native American Tribal Representative(s). The Native American Tribal

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Representative(s) shall retain all discovered TCRs in the form and/or manner the Tribe(s) deem appropriate, by the Tribe(s) sole discretion, and for any purpose the Tribe(s) deems appropriate, including for educational, cultural and/or historic purposes.

TCR-5: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects: Native American human remains are defined in Public Resources Code (PRC) 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC Section 5097.98, are also to be treated according to this statute. If Native American human remains and/or grave goods are discovered or recognized on the project site, then PRC 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). Section 5097.98 of the PRC states that, when the Native American Heritage Commission (NAHC) receives notification of a discovery of Native American human remains from the county coroner pursuant to Section 7050.5 of the California Health and Safety Code, the NAHC shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The Most Likely Descendants (MLD) shall complete their inspection within 48 hours of being granted access to the site. The designated MLD would then recommend, in consultation with the property owner, the means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.

SECTION 9.0 ORGANIZATIONS AND PERSONS CONSULTED
The first paragraph on page 9-1 of Section 9.1, Lead Agency, of the Draft EIR is amended as follows:

Colby CataldiAlma Robles, Community Development Director Sam NelsonChad Blais, Director of Public Works