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Exhibit H - Draft Subsequent EIR.pdf

Rialto City Council
January 13, 2026

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Exhibit H - Draft Subsequent EIR.pdf
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January 13, 2026
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Rialto City Council
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Greenhouse Gas Emissions. The Project would result in significant and unavoidable impacts associated with GHGs. Both Alternative 2 and the Project would result in direct emissions of GHGs from construction activities. The approximate quantity of daily GHG emissions generated by construction equipment under Alternative 2 would be the same or similar to the Project; however, it would occur over a reduced time period due to the smaller development size. Once construction is complete, the generation of these GHG emissions would cease. The SCAQMD recommends that construction emissions be amortized over a 30-year project lifetime. Therefore, projected GHGs from construction are quantified and amortized over 30 years. The amortized construction emissions are added to the annual average operational emissions.

Due to the reduction in development size, it is estimated that Alternative 2 would result in fewer total project trips with fewer mobile source emissions compared to the Project. As such, Alternative 2 would result in reduced GHG emissions compared to the Project, during operation; however, Alternative 2 GHG emissions would still exceed the threshold, and, as with the Project, impacts associated with GHG emissions would remain significant and unavoidable.

Hazards and Hazardous Materials. Impacts related to hazards and hazardous materials under Alternative 2 would be similar to the Project. The project site is not on the Cortese list of hazardous materials sites and is not located in a designated fire hazard zone. Operation of Alternative 2 would include operation of an industrial warehouse. Similar to the Project, Alternative 2 is not anticipated to be exposed to airport hazards, affect aircraft operations, or create an airport safety hazard for Project empl oyees. Neither the Project nor Alternative 2 would result in the accidental release of hazardous materials into the environment due to the proposed uses of the projects. Overall, impacts would be similar and less than significant.

Hydrology and Water Quality. Similar to the Project, Alternative 2 would be required to include a Water Quality Management Plan (WQMP) and Storm Water Pollution Prevention Plan (SWPPP) , which would include construction and operational BMPs . Similar to the Project, Alternative 2 would have a less than significant impact regarding hydrology and water quality.

Land Use and Planning. As with the Project, the Alternative 2 development scenario would not physically divide an established community through the introduction of either physical or community barriers and would not cause a significant environmental impact due to a conflict wit h any plan, policy, or regulation adopted to avoid or mitigate an environmental effect. Similar to the Project, Alternative 2 would require rezone of Planning Areas 123, 126, and 133 to accommodate for the proposed land uses of the pr oject site. A ny proposed warehouse uses associated with Alternative 2 would require a CDP. Additionally, neither scenario would introduce any roadways or infrastructure that would bisect or transect surrounding land uses. Therefore, both Alternative 2 and the Project woul d have a less than significant impact associated with land use and planning.

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Noise. During construction, noise levels would be similar or the same as those associated with the Project.

The types of equipment and the daily use of the equipment is anticipated to be the same. Construction noise impacts for Alternative 2 and the Project would both be less than significant.

Operational noise sources from vehicle trips or stationary sources (e.g., HVAC units and landscaping equipment) would be slightly reduced under Alternative 2 because of the reduction in proposed truck trips. Operational noise impacts would be less than significant.

Population and Housing. Both the Project and Alternative 2 would generate new permanent employment opportunities. The Project proposes the development of two warehouse buildings which would employ approximately 147 employees. Alternative 2 would involve the development of one warehouse building, which would have employment opportunities but employ fewer employees in comparison to the Project due to the reduced size of the development . Similar to the Project, future employees are anticipated to travel to and from the project site from within the City and surrounding area. Neither Alternative 2 nor the Project would require the construction of additional residential units that could induce substantial unplanned population growth not analyzed in the City’s General Plan. Therefo re, both Alternative 2 and the Project would have a less than significant impact associated with population and housing.

Public Services. Development of both Alternative 2 and the Project would incrementally increase the demand for police and fire protection services; however, neither scenario is expected to substantially increase service demand such that a new or physically altered facility would need to be constructed, which would cause significant environmental impacts, to maintain acceptable service ratios, response times or other performance objectives for police and fire protection. Neither the Project or Alternative 2 would increase demand for school services, recreational facilities, or other public facilities. Further, development impact fees are paid on a project -by-project basis to ensure a proportionate fair share is contributed toward facilities, equipment, and personnel that would be needed over time to accommodate the additional demand from the Project. Pu blic service impacts would be the same or similar to Project.

Impacts would be less than significant.

Recreation. Both the Project and Alternative 2 would require the rezone of land zoned for recreational facilities. Both the Project and this alternative would be required to pay development impact fees to fund future and existing recreational facilities within the City. Upon approval of the proposed rezone, both the Project and this alternative would result in less than significant impacts associated with recreation.

Transportation. The Project would result in less than significant transportation impacts. The Project is located within a low VMT generating area and further VMT analysis is not required for the Project. As Alternative 2 would include development within the same project site, this alternative would also result in less than significant transport ation impacts similar to the Project. Additionally, Alternative 2 would result in reduced development and therefore fewer daily trips. As such, Alternative 2’s less than significant impacts would be reduced in comparison to the Project’s less than significant impacts.

Tribal Cultural Resources. Tribal cultural resources are primarily dependent upon the construction and operations footprint of each development. Like the Project, Alternative 2 assumes that the entire project site would be graded. Therefore, for environmental issues where site disturbance would be the same for the Project and Alternative 2, there would be no change in the significance of potential impacts for tribal Miro Way and Ayala Drive Project Section 6.0
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cultural resources. Therefore, as with the Project, this alternative would result in a less than significant with mitigation incorporated impact on tribal cultural resources.

Utilities and Service Systems. When compared to the Project, Alternative 2 would result in a decrease in demand on utilities, as the Alternative would result in a decrease of 228,715 sf of development as compared to the Project. Alternative 2 would be consistent with the 2016 RSPA and the uses anticipated within the 2016 RSPA and General Plan. Similar to the Project, Alternative 2 would result in less than significant impacts associated with utilities and service systems.

Alternative 2: Conclusion
Alternative 2 would have a building area of approximately 200,000 sf. This is a decrease in development when compared to the Project. Proposed uses of Alternative 2 would be consistent with the Specific Plan and impacts would be similar to that of the Project, as identified in Table 6-1.

Like the Project, this alternative assumes that the entire project site would be graded. Therefore, for environmental issues where project site disturbance would be the same for the Project and Alternative 2, there would be no change in the significance of potential impacts. This would be the case for the topics of biological resources, cultural resources, and tribal cultural resources. As with the Project, impacts would be mitigated to a less than significant level.

Neither Alternative 2 nor the proposed Project would result in significant aesthetic impacts. The building heights would be similar and although the building square footage associated with Alternative 2 would be less, the remaining project site area would be developed with parking lots and landscaping.

With respect to traffic, both the Project and Alternative 2 would result in less than significant impacts as the project site is located within a low VMT generating area. Transportation impacts would be less than significant and reduced as compared to the Project given the reduced amount of development.

Although this alternative would result in reduced air quality, GHG emissions, and noise, as well as an incremental reduction in the use of energy as compared to the Project, it may not provide the production potential and revenue for the City that the Project would provide , and GHG emissions would not be reduced to a level below the threshold. As such, Alternative 2 would not eliminate the Project’s significant and unavoidable impact with regard to GHG emissions. In addition, Alternative 2 would likely re sult in reduced economic activity for the City as compared to the Project, and therefore Alternative 2 would not contribute as much to the City’s goal of expanding its economic base and providing revenue -generating uses. Thus, while Alternative 2 would meet Project objectives, it would meet them to a lesser extent than the Project.

Alternative 3: Industrial Park
Under the Industrial Park Alternative, the project site would be developed as an over 400,000 sf Industrial Park. This alternative represents a reduction in development square footage as compared to the proposed Project Alternative 3 development would include the construction of three buildings in comparison to two buildings proposed under the proposed Project . This distribution of buildings in Alternative 3 would allow for a more expansive layout across the project site, potentially reducing the overall building massing and visual bulk when compared to the proposed Project's more concentrated Miro Way and Ayala Drive Project Section 6.0
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two-building design. Alternative 3 would include approximately 211 automobile parking spaces and landscaping along the boundaries of the warehouse development and within parking areas. Similar to the proposed Project, Alternative 3 would be rezoned to Business Center and would comply with the development standards of the 2016 RSPA once rezoned to the Business Center zone. Both the proposed Project and Alternative 3 would require a CDP to allow for the proposed warehouse use. Table 6-4:

Alternative 3 and Proposed Project Comparison , identifies a decrease of 16,862 sf compared to the Project.

The analysis for this alternative is based on the information provided in the Alternative Site Plan Analysis prepared by Kimley-Horn and Associates (June 2024) and is included as Appendix L.

Table 6-4: Alternative 3 and Proposed Project Comparison Development Standard Alternative 3
Proposed Project
Building 1 Building 2 Total
Building Area 411,853 53,640 375,075 428,715
Alternative 3: Impact Comparison to the Proposed Project Aesthetics. Similar to the Project, Alternative 3 would comply with development requirements of the 2016 RSPA. Both the Project and Alternative 3 would comply with applicable light and glare regulations, such as compliance with General Plan Policy 2-15.3, which requires the use of building materials that do not produce glare. Alternative 3 would include the construction of three buildings, which would allow for a more expansive layout across the project site, potentially reducing the overall building massing and visual bulk when compared to the proposed Project's more concentrated two -building design. Neither Alternative 3 nor the Project would result in significant visual impacts. Further, similar to the Project, Alternative 3 would include surface parking and landscaping. Both Alternative 2 and the Project would have a less than significant impact on aesthetics.

Air Quality. The proposed Project would result in less than significant air quality impacts with mitigation incorporated. Although Alternative 3 would result in a decrease in development size, it is anticipated that Alternative 3 would require a greater amount of hauling trips, resulting in greater construction -related emissions for NOx, CO, and SO2 (Appendix L). However, on-site construction emissions would be the same as the Project emissions because on-site activities are assumed to be the same. Due to the reduced square footage under Alternative 3, trip generation during operation would be reduced, resulting in lower mobile source emissions. Alternative 3 would include three buildings, which would result in an increase in potential emergency generator and truck emissions and overall greater emissions for ROG and CO. Similar to the Project, Alternative 3 would include mitigation and mitigated emissions would not exceed SCAQMD daily thresholds. Although Alternative 3 would include mitigation, Alternative 3 would result in more significant air quality impacts than the Project.

Biological Resources. Biological resources are primarily dependent upon the construction and operations footprint of each development. Like the Project, Alternative 3 assumes that the entire project site would be graded. Therefore, for environmental issues where project site disturbance would be the same for the Project and Alternative 3, there would be no change in the significance of potential impacts to biological Miro Way and Ayala Drive Project Section 6.0
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resources. Thus, as with the Project, Alternative 3 would result in a less than significant with mitigation incorporated impact on biological resources.

Cultural Resources. Cultural resources are primarily dependent upon the construction and operations footprint of each development. Like the Project, Alternative 3 assumes that the entire project site would be graded. Therefore, for environmental issues where project site disturbance would be the same for the Project and Alternative 3, there would be no change in the significance of potential impacts for cultural resources. Thus, as with the Project, this alternative would result in a less than significant with mitigation incorporated impact on cultural resources.

Energy. Under Alternative 3, the building square footage would be reduced and the associated energy demand would also be reduced. Electricity consumption for water conveyance would be the same as the Project and gasoline consumption from construction worker trips would be less than the Project due to the reduction in building square footage (Appendix L). Operational activities associated with Alternative 3 would have reduced electricity and natural gas demand compared to the proposed Project. As such, Alternative 3 would also result in less significant energy impacts but such impacts would be reduced as compared to the Project.

Greenhouse Gas Emissions. The proposed Project would result in significant and unavoidable impacts associated with GHGs. Under Alternative 3, the approximate quantity of daily GHG emissions generated by construction equipment would be similar to the Project. This Alternative would result in reduced operational emissions compared to the Project due to the reduced building square footage . However, Alternative 3 would still result in significant and unavoidable GHG impacts ( Appendix L ). As such, Alternative 3 would have a significant and unavoidable impact associated with GHG, but it would be reduced compared to the Project.

Hazards and Hazardous Materials. Impacts related to hazards and hazardous materials would be similar to the Project. The project site is not on the Cortese list of hazardous materials sites and is not located in a designated fire hazard zone. Operation of Alternative 3 would include opera tion of three industrial warehouses. Similar to the Project, Alternative 3 is not anticipated to be exposed to airport hazards, affect aircraft operations, or create an airport safety hazard for Project employees. Neither t he Project nor Alternative 3 would result in the accidental release of hazardous materials into the environment due to the proposed uses. Similar to the Project, Alternative 3 would be less than significant.

Hydrology and Water Quality. Similar to the Project, Alternative 3 would be required to provide a Water Quality Management Plan (WQMP) and Storm Water Pollution Prevention Plan (SWPPP), which would include construction and operational BMPs. Accordingly, Alternative 3 would have a less than significant impact regarding hydrology and water quality, similar to the Project.

Land Use and Planning. As with the Project, the Alternative 3 development scenario would not physically divide an established community through the introduction of either physical or community barriers and would not cause a significant environmental impact due to a conflict with any plan, policy, or regulation adopted to avoid or mitigate an environmental effect. Similar to the Project, Alternative 3 would require a rezone of Planning Areas 126 and 133 to the Business Center zone to accommodate the proposed land uses. Any proposed warehouse uses associated with Alternative 3 would require a CDP. Additionally, neither scenario would introduce any roadways or infrastructure that would bisect or transect Miro Way and Ayala Drive Project Section 6.0
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surrounding land uses. Therefore, both Alternative 3 and the Project would have a less than significant impact associated with land use and planning.

Noise. During construction, noise levels would be similar or the same as those associated with the Project.

The types of equipment and the daily use of the equipment is anticipated to be the same . Alternative 3 would still generate the same peak noise volumes and similar type and volume of construction noise as the Project (Appendix L). Construction noise impacts for Alternative 3 and the Project would both be less than significant. Operational noise sources from vehicle trips or stationary sources (e.g., H VAC units and landscaping equipment) would be similar to the Project under Alternative 3. Both the Project and Alternative 3 would result in less than significant noise impacts.

Population and Housing. Both the Project and Alternative 3 would generate new permanent employment opportunities. The Project would include the development of two warehouse buildings which would employ approximately 147 employees. Alternative 3 would involve the development of three warehouse buildings, which would have similar employment opportunities. Future employees are anticipated to travel to and from the project site from within the City and surrounding area. Neither Alternative 3 nor the Project would require the construction of additional residential units that could induce substantial unplanned population growth not analyzed in the General Plan. Therefore, both Alternative 3 and the Project would have a less than significant impact associated with population and housing.

Public Services. Development of both Alternative 3 and the Project would incrementally increase the demand for police and fire protection services; however, neither scenario is expected to substantially increase service demand such that a new or physically altered facility would need to be constructed, which would cause significant environmental impacts, reduce acceptable service ratios, response times or other performance objectives for police and fire protection. Alternative 3 would not result in an incre ase in demand for school services, recreational facilities, or other public services. Further, development impact fees are paid on a project -by-project basis to ensure a proportionate fair share is contributed toward facilities, equipment, and personnel that would be needed over time to accommodate the additional demand from the Project. Pu blic service impacts would be the same or similar to Project and less than significant.

Recreation. Both the Project and Alternative 3 would require the rezone of land zoned for recreational facilities. Both the Project and this alternative would be required to pay development impact fees to fund future and existing recreational facilities within the City. Upon approval of the proposed rezone, both the Project and this alternative would result in less than significant impacts associated with recreation.

Transportation. The Project would result in less than significant transportation impacts. The Project is located within a low VMT generating area and further VMT analysis is not required for the Project.

Alternative 3 would generate 1,180 PCE trips on a daily basis compared to the 1,228 PCE trips of the Project ( Appendix K ). Since this alternative would generate fewer trips, its less than significant transportation impacts would be reduced as compared to the Project’s less than significant impacts.

Tribal Cultural Resources. Tribal cultural resources are primarily dependent upon the construction and operations footprint of each development. Like the Project, Alternative 3 assumes that the entire project site would be graded. Therefore, for environmental issues where site disturbance would be the same for the Project and Alternative 3, there would be no change in the significance of potential impacts for tribal Miro Way and Ayala Drive Project Section 6.0
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cultural resources. Thus, as with the Project, this alternative would result in a less than significant with mitigation incorporated impact on tribal cultural resources.

Utilities and Service Systems. When compared to the Project, Alternative 3 would result in the same or similar demands on utilities. Alternative 3 would be consistent with the 2016 RSPA and the uses anticipated within the 2016 RSPA and General Plan. Similar to the Project, Alternative 3 would result in less than significant impacts associated with utilities and service systems.

Alternative 3: Conclusion
Alternative 3 would include the development of an industrial park and would have a building area of approximately 411,853 sf in three buildings for warehouse and office-related uses. Compared to the Project, impacts would be similar as a result of the similar development sizes, as identified in Table 6-1.

Like the proposed Project, this alternative assumes that the entire site would be graded. Therefore, for environmental issues where site disturbance would be the same for the proposed Project and Alternative 3, there would be no change in the significance of potential impacts. This would be the case for the topics of biological resources, cultural resources, and tribal cultural resources. As with the proposed Project, impacts would be mitigated to a less than significant level. However, as with the proposed Project, impacts related to GHG emissions would remain significant and unavoidable under Alternative 3.

Like the proposed Project, Alternative 3 would be required to comply with the development standards of the 2016 RSPA for development of sites within the Business Center zone. Although there would be a reduction in building square footage, the remainder of the project site would be developed with parking lots and site landscaping.

With respect to traffic, both the Project and Alternative would result in less than significant impacts as the project site is located within a low VMT generating area. Transportation impacts would be less than significant.

Due to the similar development size between the Project and Alternative 3, both the Project and Alternative 3 would result in similar impacts , and Alternative 3 would not eliminate the Project’s significant and unavoidable impact with regard to GHG emissions . Alternative 3 would likely result in reduced economic activity for the City as compared to the Project and therefore Alternative 3 would not contribute as much to the City’s goal of expanding its economic base and providing revenue -generating uses. As such, while Alternative 3 would achieve the Project objectives, it would meet them to a lesser degree than the Project.

6.5 Environmentally Superior Alternative
State CEQA Guidelines require that an Environmentally Superior Alternative be identified; that is, an alternative that would result in the fewest or least significant environmental impacts. If the “No Project” Alternative is the environmentally superior al ternative, CEQA Guidelines Section 15126.6(e)(2) requires that another alternative that could feasibly attain most of the Project’s basic objectives be chosen as the environmentally superior alternative.

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Since the No Project Alternative is environmentally superior, the SEIR has identified Alternative 2 as the Environmentally Superior Alter native. Alternative 2 would reduce the impacts to air quality, energy, GHG emissions, noise, and transportation, although it would not reduce GHG emissions to a less than significant level and GHG impacts would remain significant and unavoidable. This Alternative would meet the requirements of the 2016 RSPA and therefore is in conformance with all applicable City regulations.

This Alternative meets the Project objectives, but to a lesser extent than the Project, and meets the goals of the General Plan.

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7.0 PREPARERS AND CONTRIBUTORS

7.1 EIR Preparers
City of Rialto (Lead Agency)
Daniel Casey ......................................................................................................................... Principal Planner Kimley-Horn and Associates, Inc.

Casey Schooner, AICP .......................................................................................................... Project Manager Madison Brown. .......................................................................................................... Environmental Analyst Trevor Briggs, P.E. ................................................................................................................. Traffic Manager Leslie Sorenson. ....................................................................................................................... Traffic Planner Ace Malisos ............................................................................. Air Quality, Greenhouse Gas, Noise Manager Danielle Millar ........................................................................... Air Quality, Greenhouse Gas, Noise Planner

7.2 Contributors
Rock Biological Resources .................................................................................. Biological Resources Report ASM Affiliates ........................................................................................................ Cultural Resources Memo

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State Water Resources Control Board (SWRCB). (2024a). Geotracker: Rialto Municipal Airport Property (T10000002088). https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T10000002088.

Accessed October 2024).

SWRCB. (2024b). GeoTracker.
https://geotracker.waterboards.ca.gov/map/?myaddress=California&from=header&cqid=5618207633& __cf_chl_tk=H2.kx_3keRryuY4ROpTlM3vJmEqY00iECxXM9p0NWbA-1679416346-0-gaNycGzNDRA.

Accessed October 2024.

United States Census Bureau. (2024). Quick Facts: Rialto city, California. https://www.census.gov/quickfacts/rialtocitycalifornia. Accessed October 2024.

United States Energy Information Administration. (2023a). Table F33: Total Energy Consumption, Price, and Expenditure Estimates, 2020. https://www.eia.gov/state/seds/sep_fuel/html/fuel_te.html.

Accessed October 2024.

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United States Energy Information Administration. (2023b). California State Profile and Energy Estimates, California Energy Consumption by End-Use Sector, 2020,
https://www.eia.gov/state/?sid=CA#tabs-2. Accessed October 2024.

United States Environmental Protection Agency (EPA). (2024a). Frequent Questions about General Conformity. https://www.epa.gov/general-conformity/frequent-questions-about-general- conformity. Accessed October 2024.

Unites States EPA. (2024b). EPA Map of Radon Zones. https://www.epa.gov/radon/epa-map-radon- zones. Accessed November 2024.

United States Geological Survey (USGS). (2018). Santa Ana Basin, National Water Quality Assessment Program.https://www.waterboards.ca.gov/waterrights/water_issues/programs/enforcement/c omplaints/docs/investigation/40_usgs_santa_ana_basin_national_water_quality_assessment_p rogram.pdf. Accessed October 2024.

USGS. (2013). Federal Standards and Procedures for the National Watershed Boundary Dataset (WBD).

Pages 14 and 19. Reston, Virginia: United States Geological Survey. https://pubs.usgs.gov/tm/11/a3/pdf/tm11-a3_4ed.pdf. Accessed October 2024.

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