10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Advocates for the Environment
A non-profit public-interest law firm
and environmental advocacy organization
October 28, 2025
Sean McPherson, Principal Planner
Rancho Cucamonga Planning Department
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Via U.S. Mail and email to [email protected]
Re: Comments on Draft Environmental Impact Report for El Camino Project, SCH No. 2023080369
Dear Mr. McPherson:
On June 12, 2025, Advocates for the Environment submitted a comment letter regarding the Draft Environmental Impact Report (DEIR) for the El Camino project (Project). The Project Site is located in the southern area of the City of Rancho Cucamonga (City), in southwestern San Bernardino County. The Project proposes to develop the 30.1-acre Project Site by constructing up to 1,054,541 square-feet of new manufacturing, light industrial, and office spaces across two construction phases. We have also reviewed the Final Environmental Impact Report (FEIR), prepared in October 2025, and submit additional comments regarding the sufficiency of the DEIR’s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA). The comments in this letter are intended to supplement, but not replace, the comments in our original comment letter.
The DEIR’s GHG Analysis Violates CEQA
The unmitigated project-related emissions for the first phase are 29,821.6 metric tons of carbon dioxide equivalent (MTCO2e) per year (DEIR, p. 4.8-28.) The yearly unmitigated emissions from the second phase are expected to be 43,898.9 MTCO2e without thermal recovery, or 41,126.0 MTCO2e with thermal recovery. The City adopted the South Coast Air Quality Management District’s (SCAQMD) numerical GHG threshold of 10,000 MTCO2e per year for industrial projects. (DEIR, p. 4.8-22.) This is an invalid threshold, as discussed below. But, based on this threshold, the City determined the project would have a significant and unavoidable impact even after mitigation measures. After mitigation efforts, the total emissions calculated still greatly exceeds the threshold. The two proposed GHG mitigation measures would only reduce the Project’s GHG emissions by about 150 MTCO2e per year, representing about 2% of the Project’s annual emissions. (DEIR, p. 4.8-31.) The City also references air quality mitigation measures for reducing vehicle emissions, but this still only would reduce less than 100 MTCO2e, representing a mere 0.4% of 11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 City of Rancho Cucamonga Page 2 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] mobile source emissions reductions. The City did not demonstrate that these mitigation measures represent the maximum feasible mitigation of the Project’s significant GHG impact. Under CEQA, the City is required to include all feasible mitigation measures, which were not incorporated here. The City offered Mitigation Measures GHG-1, which would reduce GHG emissions from appliance energy consumption; and GHG-2, which would reduce GHG emissions from building energy consumption. Additionally, Mitigation Measures AIR-3 through AIR-5 were cross-referenced from the Air Quality section of the DEIR because of their potential co-benefits of reducing carbon emissions. (DEIR, p. 4.8-31.) Yet, the City acknowledged that the impact of the air quality mitigation measures would have minimal effect on the overall GHG impact of the Project. The City determined that the Project’s GHG impact would be significant and unavoidable, without providing substantial evidence that the mitigation measures included in the DEIR represented the only feasible mitigation measures for reducing the significant GHG impact. There are other feasible mitigation measures that the City should have considered and adopted to reduce the significant GHG impact identified in the DEIR. The DEIR should have included more mitigation to reduce the Project’s GHG emissions to the extent required by CEQA. The City’s GHG analysis improperly relied upon SCAQMD’s recommendation SCAQMD adopted the 10,000 MTCO2e threshold (the Threshold) in 2009 based on the December 5, 2008 staff proposal. (the Staff Proposal).1 A single-sheet summary of SCAQMD’s Air Quality Significance Thresholds was posted in March 2023,2 and includes the purported GHG threshold of 10,000 MTCO2e/year for industrial facilities, without citation sources, despite citing references for the other standards (e.g., SCAQMD CEQA Handbook, AQMD Rules 1303 and 403.) So, it can be assumed that the Staff Proposal is therefore the only available authority supporting the Threshold. The City failed to independently analyze or support for why the SCAQMD GHG threshold of 10,000 MTCO2e/year is valid for this Project. It is inadequate for the Project because: • the SCAQMD lacks the authority to set CEQA thresholds for projects for which it is not the lead agency; • the rationale the SCAQMD used to establish the 10,000 MTCO2e threshold is not applicable to the Project; and • the City does not provide substantial evidence supporting the Threshold in the DEIR. 1 http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ghg-significance-thresholds - Board Letter and attachments 2 https://www.aqmd.gov/docs/default-source/ceqa/handbook/south-coast-aqmd-air-quality-significance-thresholds.pdf?sfvrsn=25 City of Rancho Cucamonga Page 3 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] The SCAQMD has no authority to set CEQA thresholds for other agencies The DEIR assumes, without explanation, that the Threshold is applicable to the Project. But SCAQMD’s enabling statute (Health & Safety Code §§ 40400-40540) does not provide legal authority to the agency to issue CEQA regulations or thresholds for other agencies. The CEQA Guidelines § 15064.7(b) encourages each agency to develop thresholds of significance for itself to use but provides no authority for the SCAQMD to develop CEQA thresholds for other agencies to use. The Board Letter for the December 5, 2008 SCAQMD Board meeting,3 drafted by SCAQMD staff but not adopted by the Board, proposes a 10,000 MTCO2e threshold which is applicable only to industrial projects where the SCAQMD is the lead agency under CEQA. (Board Letter, p. 5.) Thus, the creation of this threshold was intended for projects where the SCAQMD is the lead agency. The SCAQMD does not have the authority to prescribe significance thresholds for which it is not the lead agency. Lead agencies may choose their own significance thresholds, but they must be supported by substantial evidence, which means “facts, reasonable assumptions predicated on facts, and expert opinion supported by facts.” (14 CCR § 15064.7(b).) The burden is on the City to provide substantial evidence for the chosen threshold for the Project, not merely adopting a recommendation. The City cannot rely on the SCAQMD’s evidence supporting the threshold because the evidence that the SCAQMD used is not only insufficient to provide substantial evidence but also does not apply to this Project. Furthermore, it makes no sense for different thresholds to apply in the various air districts; global warming is a global phenomenon, and a ton of GHGs emitted in Los Angeles has the same impact as a ton emitted in the City of Rancho Cucamonga. Other districts have adopted much lower thresholds, such as the 1,100 MTCO2e threshold recommended by the Sacramento Metro Air Quality Management District,4 or the County of San Bernardino’s 3,000 MTCO2e per year screening level.5 The DEIR did not explain why the Threshold is more appropriate for the Project than these lower thresholds adopted by other air districts. The SCAQMD’s rationale for the threshold is not valid for this Project The SCAQMD’s rationale for adopting its 10,000 MTCO2e numerical threshold does not apply to this Project. The SCAQMD’s recommendation is based on the rationale that it would reduce 3 http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/ghgboardsynopsis.pdf 4 See Greenhouse Gas Thresholds for Sacramento County, SMAQMD https://www.airquality.org/LandUseTransportation/Documents/SMAQMDGHGThresholds2020-03-04v2.pdf 5 See County of San Bernadino Greenhouse Gas Emissions Development Review Process Screening Tables, available at: https://www.sbcounty.gov/uploads/LUS/GreenhouseGas/GHG_2021/GHG%20Revised%20Screening%20Tables%20-%20Adopted%209-20-2021.pdf City of Rancho Cucamonga Page 4 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] 90% of emissions from projects for which the SCAQMD is the lead agency. To arrive at the threshold, SCAQMD reviewed the natural-gas consumption for projects it permitted in 2006 and 2007, assuming the vast majority of emissions came from burning natural gas. These tend to be heavy industrial projects such as manufacturers of cement and steel. The SCAQMD is not a lead agency for land use projects generally, which include “shopping malls, housing tracts, commercial or industrial parks, sports stadiums, etc.”6 The kinds of projects for which the SCAQMD is the lead agency are different from commercial or warehousing projects, which are typically much smaller. The vast majority of GHG emissions from warehouse projects come from mobile emissions, not the burning of natural gas, as is the case for this Project. While reducing emissions to below 10,000 MTCO2e might achieve 90% emissions reductions for large industrial projects for which the SCAQMD is the lead agency, the mix of land-use projects in general, and warehouse projects in particular is very different from the mix of projects the SCAQMD analyzed. There is no support that a 10,000 MTCO2e threshold would capture 90% of GHG emissions for projects of this size, scope, and use. The City failed to support its chosen threshold with substantial evidence CEQA requires the City to support its choice of threshold with substantial evidence. The City has information available to determine an applicable significance threshold and support it with substantial evidence given the current regulatory setting and project features. Instead of doing so, the City improperly relied on an inapplicable threshold that does not conform to California’s most recent climate goals. CEQA requires that significance determinations are based on current regulations, as well as scientific and factual data. (CEQA Guidelines §§ 15064.4(b).) Thresholds that are not aligned with California’s current reduction goals are outdated under CEQA. The chosen threshold of 10,000 MTCO2e adopted by the SCAQMD does not address Senate Bill 32 (SB 32). The implementation of SB 32 is carried out by the California Air Resources Board’s 2017 Climate Change Scoping Plan (2017 Scoping Plan), which reflects SB 32’s GHG emissions reduction goal of 40% below 1990 levels by 2030. To assess statewide implementation of this goal, the 2017 Scoping Plan created a per-capita target of 6 MTCO2e by 2030 (2017 Scoping Plan, p. 99.) 6 https://www.aqmd.gov/home/rules-compliance/ceqa/frequently-asked-questions#:~:text=The%20South%20Coast%20AQMD%20typically,previously%20undergone%20a%20CEQA%20analysis.
City of Rancho Cucamonga Page 5 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Here, even after implementation of the mitigation measure, the Project’s emissions would be approximately 6.63 MTCO2e per service population,7 exceeding the target necessary to achieve SB 32’s goal as reflected in the CARB 2017 Scoping Plan. Only two of California’s air districts (Bay Area and Sacramento) have created thresholds which address SB 32’s reduction goal of GHG emissions 40% below 1990 levels by 2030. 8 All the other thresholds adopted by air quality management districts, including the 10,000 MTCO2e threshold recommended for industrial projects by the SCAQMD, are not consistent with current environmental policy in California. Consequently, the SCAQMD guidelines are not aligned with California’s current regulatory scheme and therefore the 10,000 MTCO2e numerical threshold is an outdated threshold not supported by substantial evidence. Further, the Threshold is invalid because it is not aligned with the most recent goals of the California Air Resources Board (CARB). CARB developed the 2022 Scoping Plan, which emphasizes that “any delays in action or insufficient action are a threat to public health and the environment.” (2022 Scoping Plan, p. 22.) It also specifies that all of the actions in the 2022 Scoping Plan are necessary to achieve climate goals. (2022 Scoping Plan, p. 11.) Accordingly, if the Project inhibits any of the specified actions in the 2022 Scoping Plan from being carried out without delay, then it will be inconsistent with the 2022 Scoping Plan. A numeric threshold, particularly one as large as 10,000 MTCO2e, does not require that any certain measures are achieved. Therefore, staying under the threshold would not mean that the Project would necessarily adhere to the measures in the 2022 Scoping Plan in a timely manner. Consistency with Identified Applicable Plans The City chose to analyze, as one of its adopted significance thresholds, whether the Project would “[c]onflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.” (DEIR, p. 4.8-21.) The DEIR included a discussion of the California Air Resources Board (CARB) 2022 Scoping Plan, Title 24 BEES and CalGreen Code, CARB’s Sustainable Freight Action Plan, Connect SoCal 2024, and the Rancho Cucamonga Climate Action Plan (CAP), to support its determination that the Project would not conflict with an applicable plan, policy, or regulation for GHG emissions reductions. This significance analysis violates CEQA by erroneously overlooking the Project’s conflict with the 2022 Scoping Plan, and particulary in relation to the cogeneration system. 7 9,949 𝑀𝑇𝐶𝑂2𝑒 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟 ÷1,500 𝑒𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠=6.63 𝑀𝑇𝐶𝑂2𝑒 𝑝𝑒𝑟 𝑐𝑎𝑝𝑖𝑡𝑎. Employee estimate obtained from CEQAnet Project page, available at https://ceqanet.lci.ca.gov/2023100540/3. Last accessed July 15, 2025. 8 See California Air Resources Board 2022 Climate Change Scoping Plan, Appendix D, p. 26, footnote 67. [noting that the only air quality districts that are in alignment with SB 32 are the recommendations from the Bay Area Air Quality Management District and Sacramento Metropolitan Air Quality Management District]. Available at: https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf. Last accessed July 14, 2025.
City of Rancho Cucamonga Page 6 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Cogeneration system conflicts with the 2022 Scoping Plan. The Project would involve expanding an existing beverage distribution facility, which the City incorrectly claims would not conflict with the 2022 Scoping Plan. The 2022 Scoping Plan establishes a sector-by-sector roadmap for California to achieve carbon neutrality by 2045 or earlier through an aggressive approach to decarbonize every sector of the economy.9 (2022 CARB Scoping Plan executive summary, p. 1) The plan recognizes that buildings, including commercial ones, must transition away from reliance on fossil fuels and should predominantly rely on advancing energy efficiency while replacing gas with non-combustion alternatives so commercial buildings do not require ongoing maintenance for gas delivery. (2022 CARB Scoping Plan, p. 212.) However, this Project includes a cogeneration system that “would reduce the quantity of natural gas required by the boilers for water-heating and beverage-production purposes.” (DEIR, p. 2-1, 3-47.) Though framed as an efficiency measure that reduces natural gas consumption in the boilers, the system itself operates through the combustion of natural gas. (DEIR, p. 4.3-38.) In effect, the system substitutes one source of fossil fuel combustion for another, introducing new long-term combustion infrastructure while claiming a reduction in GHG emissions. This justification conflicts with the 2022 Scoping Plans’ objectives to transition facilities away from fossil fuels altogether. While the 2022 Scoping Plan recognizes that some industrial processes may currently face cost or feasibility barriers to full electrification, it nonetheless establishes a clear long-term objective to decarbonize industrial facilities by “displacing fossil fuel use with a mix of electrification, solar thermal heat, biomethane, low- or zero-carbon hydrogen, and other low-carbon fuels to provide energy for heat and reduce combustion emissions.” (2022 CARB Scoping Plan, p. 207.) Understanding that “there is a continuing demand for fossil gas due to lack of non-combustion technologically feasible or cost-effective alternatives for certain industrial sectors.” (2022 CARB Scoping Plan, p. 207.) The Project is not consistent with this goal, based on the analysis provided in the DEIR. Its reliance on fossil fuels through the use of cogeneration systems that include natural gas combustion alongside boilers creates a direct conflict. (DEIR, p. 4.6-31.) Although the 2022 Scoping Plan understands there may be a continuing demand for fossil fuels in certain sectors, it does not treat the use of natural gas combustion as a preferred or encouraged energy source, nor does it treat the Project sectors as one that requires fossil fuels. The 2022 Scoping Plan emphasizes that “electrification and solar thermal heat are best-suited to industrial processes that have relatively low heat requirements, such as food processors, paper mills, and industries that use low-pressure steam in their processes,” and identifies approaches such as replacing fossil gas boilers with electric boilers and using industrial electric heat pumps (2022 CARB 9 2022 Scoping Plan Executive Summary p. 1 located at: https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp-es.pdf City of Rancho Cucamonga Page 7 CEQA Comments on the El Camino Project October 28, 2025 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Scoping Plan, p. 208). A beverage manufacturing facility falls within this category of industrial processes for which electrification is feasible. In contrast, the Scoping Plan limits continued onsite combustion to “industrial processes that require higher-temperature heat,” such as steel forging, glass manufacturing, and cement production industries with technological barriers to electrification (2022 CARB Scoping Plan, p. 208.) The DEIR’s implication that cogeneration is appropriate because of general “cost barriers” misconstrues this distinction. (DEIR Admin Draft, p. 2-137.) Those barriers do not justify new fossil fuel combustion at facilities that are otherwise well-suited for electrification. By proposing a new natural gas combusting cogeneration system at a beverage facility, the Project would perpetuate fossil fuel dependence in a sector the Scoping Plan identifies as capable of transitioning to clean energy, thereby conflicting with the Plan’s decarbonization framework and long-term goals. Consequently, because the Project is inconsistent with applicable plans for the reduction of GHGs, it is significant under the second threshold. The City’s determination that the Project would have a less-than-significant impact as to the second GHG threshold is not supported by substantial evidence. Conclusion The Project would have a significant GHG impact under the chosen threshold of consistency with applicable plans because the Project is not consistent with the applicable plans, policies, and regulations for the reduction of GHGs. Please put Advocates for the Environment on the list of interested parties to receive updates about the progress of this potential project approval. We make this request under Public Resources Code, section 21092.2. Sincerely, Dean Wallraff, Attorney at Law Executive Director, Advocates for the Environment MIG, Inc. November 2025
Memorandum
To: Sean McPherson, Principal Planner, City of Rancho Cucamonga CC: Kent Norton, MIG
From: Kasey Kitowski, MIG and Chris Dugan, ESA
Re: Response to Advocates for the Environment’s October 2025 Comments on Draft Environmental Impact Report for El Camino Project, SCH No. 2023080369 Date: November 4, 2025
MIG, Inc. has prepared this memorandum to respond to the comments submitted by Advocates for the Environment on October 28, 2025, regarding the Environmental Impact Report (EIR) for the El Camino Project (Project).
Response to CEQA Comments
Comment 1: The DEIR’s GHG Analysis Violates CEQA
The commenter provides an accurate summary of the EIR and unsubstantiated claims that the EIR’s conclusion of significant and unavoidable GHG impacts was incorrect. In addition, the commenter generally claims that EIR did not incorporate all feasible mitigation measures and that there are other feasible mitigation measure the City should considered to reduce the Project’s GHG emissions; however, the commenter does not provide any specific mitigation suggestion or recommendation for the City to consider. In contrast, as described in the DEIR, the Project includes design features and the DEIR incorporates mitigation to address GHG emissions from nearly all of the Project’s GHG emissions sources, including construction GHG emissions, building envelope and systems GHG emissions, appliance GHG emissions, passenger vehicle and truck trip emissions, and commercial and industrial yard equipment GHG emissions. The FEIR also evaluated and explained its conclusions on the feasibility of additional measures recommended by Advocates for the Environment in its first comment letter, as well as measures recommended by the Soil/Water/Air Protection Enterprise (SWAPE), and the South Coast Air Quality Management District (SCAQMD). The EIR incorporated all feasible mitigation measures.
Comment 2: The City’s GHG analysis improperly relied upon SCAQMD’s recommendation
11-05-2025 - Regular City Council Meeting - Response to Correspondence Received - Item G1 MIG, Inc. November 2025
The commenter incorrectly claims that the City failed to support why the SCAQMD 10,000 MT CO2e/year threshold was appropriate for the Project. Refer to the “Discussion of Potential GHG Emissions Thresholds of Significance” under Section 4.8.3 of the DEIR for a detailed analysis and justification on the use of this threshold to evaluate the Project’s GHG emissions impacts.
Comment 3: The SCAQMD has no authority to set CEQA thresholds for other agencies The commenter incorrectly implies that the SCAQMD set the CEQA threshold or issued some other CEQA regulation for the proposed Project. As discussed in Section 4.8.3 of the EIR, the City reviewed potential GHG thresholds and selected the 10,000 MT CO2e/year threshold as the most appropriate for the proposed Project. It is permissible under CEQA for a lead agency to choose a threshold formulated by a local air district. In fact, Appendix G of the 2025 CEQA Guidelines states (page 363, “Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations”).
The commenter also suggests additional thresholds for consideration that were not discussed in the DEIR. The City has reviewed these thresholds and determined they are not appropriate for the Project. The SCAQMD’s 10,000 MTCO2e threshold would instead be used for the Project because it is a stationary source project. The commenter referenced the Sacramento Metro Air Quality Management District (SMAQMD) as having a lower threshold of 1,100 MTCO2e. However, in the document referenced by the commenter, the SMAQMD recommends this 1,100 MTCO2e as a construction and land use operational threshold, but has a 10,000 MTCO2e stationary sources operational threshold (page 1).
Additionally, as mentioned by the commenter, the San Bernardino County threshold of 3,000 MTCO2e per year is a screening threshold. It was developed based specifically on the San Bernardino County GHG Emissions Reduction Plan, so that small projects that do not exceed the screening threshold could be considered consistent with the plan (County of San Bernardino page 1). This threshold is not applicable to the proposed Project. The GHG reduction plan applicable to the Project, the Rancho Cucamonga CAP , is not eligible to streamline the analysis for the proposed Project, as explained in Section 4.8.3. After reviewing the information provided by the commenter, the City affirms that the 10,000 MTCO2e threshold used in the DEIR is the appropriate threshold that is supported by substantial evidence.
Comment 4: The SCAQMD’s rationale for the threshold is not valid for this Project The commenter claims that the SCAMQD’s threshold does not apply to the proposed Project. The commenter notes that the SCAQMD arrived at the threshold by reviewing MIG, Inc. November 2025
natural gas consumption for permitted projects, and clarifies that the SCAQMD is not the lead agency for land uses including shopping malls, housing tracts, commercial or industrial parks, sports stadiums, etc. The proposed Project is not any of these land use types. The proposed Project is a beverage manufacturing facility that includes stationary sources that would combust natural gas. The commenter also claims that the SCAQMD’s recommendation is based on reducing 90% of emissions from projects. As a point of clarification, as discussed in the SCAQMD’s Draft Guidance Document-Interim CEQA Greenhouse Gas (GHG) Significance Threshold, the 90% emission capture rate refers to capturing 90% of total emissions from all new or modified stationary source projects, and not reducing 90% of emissions from projects. The EIR evaluated issues of threshold applicability in Section 4.8.3 and concluded that the 10,000 MTCO2e threshold was appropriate for the proposed Project. Finally, the SCAQMD submitted detailed a detailed comment letter, and did not comment with any issues on the applicability of the threshold they developed.
Comment 5: The City failed to support its chosen threshold with substantial evidence The commenter claims that the EIR uses a GHG threshold that does not align with current climate goals, and that a numeric threshold does not guarantee that all actions under the Scoping Plan would be achieved.
CEQA Guidelines Section 15064 establishes that the determination of the significance of a project’s GHG emissions requires careful judgement and a good-faith effort to describe or estimate the amount of GHG emissions resulting from a project. A lead agency may prepare a quantitative or a qualitative analysis of GHG emissions; however, the analysis should focus on a project’s reasonably foreseeable change in GHG emissions, for an appropriate timeframe, and with consideration of evolving scientific knowledge and state regulatory schemes. When determining the significance of a project’s GHG emissions impact, a lead agency should consider factors such as, but not limited to, the potential increase or decrease in GHG emissions compared to a project’s existing environmental setting, whether a project’s GHG emissions exceed threshold of significance determined to apply, and the extent to which a project complies with regulations or requirements in an adopted statewide, regional, or local plan for reducing or mitigating GHG emissions, provided such requirements were adopted in a public review process and reduce or mitigate a project’s incremental GHG emissions contribution to cumulative climate change effects. The City is not required to establish a threshold for GHG emissions impacts based on the actions in the Scoping Plan. However, an evaluation of consistency with the Scoping Plan is still provided in the EIR, under the Applicable GHG Plans, Policies, and Regulations discussion in Section 4.8.5. The analysis concluded that the Project would not conflict with MIG, Inc. November 2025
plans and policies such as the Title 24 Building Energy Efficiency Standards (BEES) and CalGreen Code, the Sustainable Freight Action Plan, and the 2022 Climate Change Scoping Plan
Comment 6: Consistency with Identified Applicable Plans The commenter accurately stated that the DEIR included a discussion of CARB’s 2022 Scoping Plan, Title 24 BEES and CalGreen Code, CARB’s Sustainable Freight Action Plan, Connect SoCal 2024, and the Rancho Cucamonga Climate Action Plan (CAP) to support its determination that the Project would not conflict with an applicable plan, policy, or regulation for GHG emissions reductions. The commenter then incorrectly claims that the proposed Project conflicts with the 2022 Scoping Plan. Refer to Section 4.8.5 of the EIR for a detailed evaluation of the Project’s consistency with the 2022 Scoping Plan.
Cogeneration System Conflicts with the 2022 Scoping Plan The commenter expresses disagreement with the EIR’s conclusion that the proposed Project would not conflict with the 2022 Scoping Plan. However, this disagreement does not constitute substantial evidence that the DEIR’s analysis is erroneous or deficient, nor does it constitute evidence that the Project would, in fact, have a substantial conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing GHG emissions.
The commenter provides a misleading introduction of the Scoping Plan by providing a quote from the Executive Summary that the Scoping Plan would achieve carbon neutrality by decarbonizing every sector of the economy without context. Earlier in the Executive Summary, the Scoping Plan announces its target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045 (page 1). The Scoping Plan would not achieve carbon neutrality in every sector; instead it would reduce but not eliminate carbon emissions while carbon sequestration from natural and working lands and carbon removal technology would address remaining emissions. As the commenter notes, the Scoping Plan recognizes some industrial processes may currently face cost or feasibility barriers to full electrification (page 207).
Furthermore, as analyzed in the EIR, there would be GHG benefits from the cogeneration system. The cogeneration system would substantially reduce building energy GHG emissions (from approximately 7,663 MTCO2e per year in Phase 1 to 4,504 MTCO2e per year in Phase 2). Additionally, the cogeneration’s CO2 recovery system would capture and purify CO2 generated by the combustion of natural gas in the cogeneration system, creating beverage-grade CO2 for Project use, which could recover approximately 9,362 metric tons and 11,364 metric tons of CO2 per year. The CO2 recovery system would also prevent the MIG, Inc. November 2025
need for between 702 and 852 annual heavy-heavy-duty truck trips that would otherwise need to deliver beverage-grade CO2 to the Project site, generating CO2 emissions from truck trips. The proposed Project also works towards carbon neutral electrification by including solar PV generation and a battery energy storage system, all-electric yard handing equipment, EV charging, and a portion of electric heavy-duty trucks. Thus, the Project would include strategies to electrify manufacturing processes well ahead of the timeline considered by the 2022 Scoping Pan.
Finally, CARB, the agency authorized by the legislature to prepare the Scoping Plan (Scoping Plan page 23), provided a detailed comment letter for the proposed Project, and did not comment that there were any flaws in the analysis of the Project’s consistency with CARB’s 2022 Scoping Plan.
References
California Air Resources Board 2022.2022 Scoping Plan. November 2022. https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp_1.pdf South Coast Air Quality Management District (SCAQMD) 2008. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold. October 2008. https://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases- (ghg)-ceqa-significance-thresholds/ghgattachmente.pdf?sfvrsn=812cf961_2 Sacramento Metro Air Quality Management District (SMAQMD) 2020. Greenhouse Gas Thresholds for Sacramento County.
https://www.airquality.org/LandUseTransportation/Documents/SMAQMDGHGThres holds2020-03-04v2.pdf
County of San Bernardino 2015. Greenhouse Gas Emissions Development Review Process.
March 2015https://lus.sbcounty.gov/wp-
content/uploads/sites/48/GreenhouseGas/FinalGHGUpdate.pdf November 5th, 2025
Rancho Cucamonga City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
RE: Letter of Support for Reyes Coca-Cola Bottling’s Project Dear Mayor Michael and City Councilmembers,
As Executive Director of the Rancho Cucamonga Chamber of Commerce, I am pleased to express our enthusiastic support for the El Camino Project. This development represents an important investment in the future of our city and is fully aligned with our mission to support business growth and community prosperity.
Reyes Coca-Cola Bottling has long been a valued member of the Rancho Cucamonga business community. Beyond being a major employer, they have consistently demonstrated a deep commitment to community service and local partnerships. Their engagement with local nonprofits, schools, and civic groups highlights their role as not just a business partner, but as a true community partner.
The El Camino Project will generate new economic activity, provide meaningful employment opportunities, and strengthen Rancho Cucamonga’s position as a vibrant place to live and work. We believe this project will positively impact both local businesses and residents for years to come.
We strongly encourage your recommendation of approval of the El Camino Project and look forward to seeing its benefits realized throughout our community.
Heather Rawlings-Polk, Executive Director
Rancho Cucamonga Chamber of Commerce
EXECUTIVE BOARD
PRESIDENT
DAN DECKER
BRUSTER'S REAL ICE CREAM
IMMEDIATE PAST PRESIDENT
MARK GUIRGUIS
HOME MASTERS INTL.
PRESIDENT ELECT
RHONDA KELIIPIO
SPARROWLILY REALTY
TREASURER
JACK MANSOUR
INLAND EMPIRE HEALTH PLAN
SECRETARY
ANDY CARLSON
EDW ARD JONES
GENERAL COUNSEL
ROBERT HUFNAGEL
RESNICK & LOUIS, P.C.
AMY WENSLOW
PRODUCTS TO PROFITS
ARLETTE GARIBAY
ONTARIO CONVENTION CENTER-
GOCAL
DAN DISCHNER
AMPHASTAR PHARMACEUTICALS, INC.
ERNESTO RIVERA
REYES COCA-COLA BOTTLING
ERNIE BRAUNWALDER
ERNIE BR AUNWALDER-BRAUNWALDER
INSURANCE & FINANCIAL SERVICES
JASON BLANCHARD
LOMA LINDA UNIVERSITY HEALTH
JENNIFER G ARCIA
NEWLINE FINANCIAL AND
INSURANCE SOLUTIONS
MELBA REY
CHINO COMMERCIAL BANK
MOHAMED FELO
TEAMLOGIC IT
NICK PAEZ
IE MASTERMIND GROUP
RICHARD SARPONG
KAISER PERMANENTE
RIGO ESPINOZA
RAW KI TCHEN & CANTINA
THEODORE FIAWOO
MODERN WOODMEN FRATERNAL
FINANCIAL
BOARD OF DIRECTORS
Rancho
Chamber
Leadership
Rancho
Chamber
Leadership
2025 - 2026
RANCHO CHAMBER
OF COMMERCE
9500 CLEVELAND AVE.
SUITE 110
RANCHO CUCAMONGA, CA
909.987.1012
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 11/03/2025
City of Rancho Cucamonga
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Re: Lone Oak - El Camino Project
Dear Members of the Council,
On behalf of the Western States Regional Council of Carpenters, I am writing to express our strong support for the Lone Oak - El Camino Project which will be considered at the City Council meeting on November 5, 2025.
Our union has deep roots in Rancho Cucamonga and throughout San Bernardino County.
We are proud to represent hardworking members who live right here in the city, men and women who are raising families, and contributing to the community every day.
We believe the project reflects a shared commitment to responsible growth and community partnership by contributing to strengthening the city’s future. It will create good-paying local jobs and provide lasting benefits that families can rely on for years t o come. It is a project that our members—your neighbors will be directly involved in building.
Additionally, this state -of-the-art facility features an excellent design concept that will complement and integrate beautifully with the city’s existing architectural theme.
We respectfully urge the City Council to approve the Lone Oak - El Camino Project and continue fostering a city where working families can live, work, and thrive.
Thank you for your leadership and for considering our voice in this important decision.
With respect and appreciation,
Jacob Lopez
Regional Manager
Western States Regional Council of Carpenters
CC: Rafael Legido
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 17495 HURLEY STREET EAST
lronworkers Local 433
International Associatio n of Bridge, Structural &
Ornamental Iron Workers A.F.l.-C.1.O.
Established 1929
CITY OF INDUSTRY , CALIFORNIA 91744 PHONE: (626) 964-2500 FAX: (626) 964-1919
[email protected]
KEITH HARKEY
Business Manager
Financial Secretary-Treasurer
City of Rancho Cucamonga
Honorable Mayor and City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
REF: Support for the Proposed El Camino Project
Dear Honorable Mayor and Members of the City Council,
On behalf of Ironworkers Local 433, I am writing to express our enthusiastic support for the proposed El Camino Project.
Ironworkers Local 433 is committed to protecting the rights of its members, promoting safe job sites, and securing fair wages and benefits. We offer a world-class apprenticeship program, ongoing training opportunities, and a unified voice that fights for fair compensation, strong labor standards, and safe working conditions.
Given this mission, we are proud to continue supporting the proposed project. The Applicant has made commitments that ensure the local skilled construction workforce, including our members in Rancho Cucamonga, will benefit from the project. That commitment represents the kind of responsible corporate stewardship that will protect the health and well-being of residents and ensure continued opportunities for growth and development in the city.
On behalf of our robust membership, we ask that you vote to approve this project and open the doors of economic opportunities for thousands of your residents.
Sincerely,
Keith Harkey
Business Manager
Ironworke rs local 433
November 4, 2025
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 California Arizona Hawaii Nevada
President David Osborne District Representatives Erik Schmidli Victor Lopez Field Representative Jonathan Paramo Executive Council Local Union 75 Jason Sangster Local Union 118 Troy Arntson Local Union 155 Jesus Castaneda Local Union 229 Beau Coleman Local Union 377 Charles Hernandez Local Union 378 Jason Gallia Local Union 416 Frankie Jimenez Local Union 433 Keith Harkey Local Union 625 Joe O’Donnell Local Union 855 Jonathan Paramo District Council of Iron Workers of the State of California and Vicinity 3281 E. Guasti Rd., Suite 625, Ontario, CA 91761 Telephone (510) 724-9277 November 4, 2025 City of Rancho Cucamonga Honorable Mayor and City Council 10500 Civic Center Drive Rancho Cucamonga, CA 91730 Subject: Letter of Support for Proposed El Camino Project Dear Honorable Mayor and Members of the City Council, I am writing on behalf of District Council of Ironworkers of California and Vicinity to express our strong support for the proposed El Camino project. This project represents an important opportunity to strengthen our local economy, create high-quality jobs, and continue the City’s commitment to responsible growth and development. A key aspect of this project is its commitment to ensure that local union construction workers will benefit from fair wages, strong safety standards, and excellent training through established apprenticeship programs. Union-built projects not only uphold the highest standards of craftsmanship and safety, but also reinvest in the community by supporting local families and the regional workforce. We also support the project because it’s design and operational plans demonstrate a thoughtful approach to environmental stewardship, traffic management, and compatibility with surrounding land uses. Therefore, I respectfully urge the City Council to approve this project and allow it to move forward. Rancho Cucamonga will benefit from the quality jobs, economic investment, and community stability this union-built facility will bring. Thank you for your consideration of this important project. Very truly yours, Davis S. Osborne President
13830 San Antonio Dr., Norwalk, CA 90650 • (562) 868-1251 960 Wigwam Pkwy., Suite 130, Henderson, NV 89014 • (702) 434-7416 www.ironworkers416.org
International Association of
Bridge, Structural, Ornamental, and Reinforcing Ironworkers Local Union 416
11/4/2025
City of Rancho Cucamonga
Honorable Mayor and City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Subject: Support Letter for the Proposed El Camino Project Dear Honorable Mayor L. Dennis Michael and Honorable Members of the City Council, Iron Workers Local 416 proudly supports the El Camino Project. We supported the project at the Planning Commission and continue to do so in the firm belief that it is a great project for Rancho Cucamonga.
The modernization of this manufacturing and distribution site means union careers with family- sustaining wages, healthcare, and pensions. These are benefits that ripple through local small businesses, schools, and neighborhoods. In addition, by utilizing contractors who employ apprentices from state- approved programs, the project will train the next generation of craftworkers in a true earn-while-you- learn model.
The El Camino Project is precisely the kind of private-sector investment cities strive to attract: it is transformative, it is accountable to labor standards, and it builds long-term capacity for regional prosperity.
We respectfully urge your approval.
Sincerely,
Frankie Jimenez
Business Manager/ Financial Secretary-Treasurer
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 Special Olympics Southern California
1600 Forbes Way, Suite 200, Long Beach, CA 90810
Tel 562.502.1100 | www.sosc.org
Created by Joseph P. Kennedy Jr. Foundation. Authorized and accredited by Special Olympics, Inc for the benefit of persons with intellectual disabilities.
November 5, 2025
Rancho Cucamonga City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
RE: Acknowledgment of Reyes Coca-Cola Bottling’s Community Partnership Dear Mayor Michael and City Councilmembers,
On behalf of Special Olympics Southern California (SOSC), I am pleased to share our appreciation for Reyes Coca-Cola Bottling and their longstanding partnership with our organization. As an organization dedicated to promoting inclusion, health, and athletic opportunities for individuals with intellectual disabilities, we have seen firsthand the positive impact Reyes Coca-Cola has had across Southern California communities, including here in Rancho Cucamonga.
Reyes Coca-Cola Bottling has been a valued supporter of SOSC for many years, contributing to our flagship events such as the Fall and Summer Games, and playing an important role in fostering community engagement through our annual Polar Plunge fundraiser in the Inland Empire. Their ongoing support has helped us raise critical funds, increase awareness, and empower athletes to reach their full potential while promoting inclusion throughout the region.
As Reyes Coca-Cola Bottling looks to expand its local facility in Rancho Cucamonga, we recognize the potential for this growth to further strengthen their community engagement. An expanded presence could enhance their ability to provide even greater support to organizations like ours—through increased product donations, volunteer participation, and logistical support that directly benefits athletes and programs across the Inland Empire.
We are deeply grateful for Reyes Coca-Cola Bottling’s continued commitment to community service, volunteerism, and partnership. Their dedication to making a positive difference in the lives of others reflects the very best of corporate citizenship.
Sincerely,
Kelly Pond
President & CEO
Special Olympics Southern California
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 2151 East Convention Center Way, Suite 210
Ontario, California, 91764
Phone: (909) 944 – 2201
www.ieep.com
Executive Board
Richard Egger, Chairman
Best, Best, & Krieger
John Chapman, First Vice-Chair
San Antonio Regional Hospital
Bansree Parikh, Second Vice-Chair
JP Morgan Chase
Lupe Valdez, Immediate Past-Chair
Union Pacific Railroad
Aaron Rios, Treasurer
Walmart
Ron Vera, Legal Counsel
Vera & Barbosa Law
Fran Inman, At-Large Member
Majestic Realty
Peter Villegas, At-Large Member
Actum, LLC
Paul Granillo, Secretary
Inland Empire Economic Partnership
Board of Directors
Dr. Ron Carter
Loma Linda University Health
Patty Senecal, WSPA
Carrie Schindler, SBCTA
Derek Armstrong, County of San
Bernardino EDA
Dr. Kurt Wilson, WRCOG
Dr. S. Jack Hu
University of California, Riverside
Jarrod McNaughton
Inland Empire Health Plan (IEHP)
Sandra Cuellar, Charter Spectrum
Manfred Keil, Ph.D.
Chief Economist, IEEP
Atif Elkadi, Ontario Airport Authority
Mayor Acquanetta Warren
City of Fontana
Dr. Tomas Morales
President, California State University,
San Bernardino
Lena Kent, BNSF Railway
Trini Jimenez, Watson Land Company
Col. Paul Cook (Ret.)
Supervisor 1st District,
County of San
Bernardino
Hon. Karen Spiegel
Supervisor, 2nd District, County of
Riverside
Suzanne Holland, County of Riverside
EDA
Lisa Anderson
LMA Consulting Group
Kristine Scott, SoCalGas
David Ambroz, Amazon
Pat Morin, California Steel Industries
Omar Cobian, SWRCC
Frank Pine, Southern California News
Group
Michael Burrows, San Bernardino
Airport
Lowell King, Goodwill Southern
California
Mark Cloud, Southern California Edison
Michael D’Elia, PNC Bank
Alyson Piguee, Inland Empire Utilities
Agency
Kevin Haboian, HNTB
Jessica Grimes, Kaiser Permanente
November 5th, 2025
Rancho Cucamonga City Council
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
RE: Letter of Support for the Reyes Coca-Cola Bottling Project Dear Mayor Michael and City Councilmembers,
On behalf of the Inland Empire Economic Partnership (IEEP), I am writing to express our strong support for Reyes Coca-Cola Bottling’s Rancho Cucamonga Project. As the region’s largest economic development organization, our mission is to improve the quality of life and business climate in the Inland Empire by bringing together private- and public-sector leaders to advance responsible growth.
Reyes Coca-Cola Bottling’s project represents exactly the type of investment our region needs. By creating new employment opportunities, generating economic activity, and fostering collaboration between business and community stakeholders, this development strengthens Rancho Cucamonga’s role as a hub of innovation and prosperity within the Inland Empire.
Reyes Coca-Cola Bottling has been a longstanding and trusted partner in our region. Beyond being a major employer, they consistently demonstrate a commitment to the community through philanthropy, local partnerships, and civic engagement. Their leadership in the El Camino Project ensures that it will deliver benefits far beyond the economic, contributing to long-term community vitality.
We respectfully urge your recommendation of approval for Reyes Coca-Cola Bottling’s Rancho Cucamonga project. IEEP looks forward to supporting its successful realization and to continuing our work to build a more prosperous and sustainable Inland Empire.
Sincerely,
Paul C. Granillo
President and CEO
Inland Empire Economic Partnership
11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1 11-05-2025 - Regular City Council Meeting - Correspondence Received - Item G1