WUCOLS IV provides evaluations of the irrigation water needs for over 3,500 taxa (t P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters 10c. FRH Trees
ed
comments
ok
ok
ok but sensitive to extreme heat
ok
ok-- NEVER replace with other sycamores
ok
DO NOT USE. This tree has naturalized and is
invading natural habitats in southern California.
For example, it has spread outward from
landscaping around the museum at Lake Perris.
More and more records are showing up in
CalFlora. Birds and mamals disperse the seeds.
https://w
ww.calflor
a.org/cgi-
bin/specie
s_query.c
gi?where-
calrecnum
USDA Plants database. Not listed as naturalized
in Calif. Biogenic emissions may be high.
ldland and become invasive.
These would be good replacements
These would be good replacements
updated and corrected for Riverside
taxonomic plant groups) used in California landscapes.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters
SHRUBS-
Replace species listed here.
Scientific name common name WULCOLS
1 Baccharis pilulars 'Centenial' Coyote bush L
2 Ligustrum lucidum (=L. j. Texanum) Texas privet, tree privet M 3 Elaeagnus pungens silverberry L
4 5
6 7
8 Suggestions for substitutions
Substitutions: Use shrubs that are native or that do not disperse seeds into the wildland and becom Ceanothus 'Ray Hartman' Ray Hartment ceanothus
Rhus ovata sugarbush
Prunus ilicifolia ssp. ilicifolia hollyleaf cherry
Simmondsia chinensis jojoba
Peritoma arborea bladderpod
see WULCOLS IV search below for trees/shrubs with low water uses for Riverside https://ucanr.edu/sites/WUCOLS/Plant_Search/?step=results&city_id=328&plant_name=&w See WULCOLS IV https://ucanr.edu/sites/WUCOLS/
Water Use Classification of Landscape Species has been updated.
WUCOLS IV provides evaluations of the irrigation water needs for over 3,500 taxa (taxonomi P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters Riverside
WULCOLS IV comments
L not native here and will invade wildland reserve
M invasive into riparian areas of reserve
L potentially invasive
me invasive.
L
L
L
VL
L
water_use=VL&water_use=LO&water_use=M&plant_type=S&plant_type=T c plant groups) used in California landscapes.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters July 23, 2021
Veronica Hernandez
Senior Planner
City of Riverside
3900 Main Street, 3rd Floor
Riverside, California 92522
[email protected]
Dear Veronica Hernandez:
Thank you for providing the California Air Resources Board (CARB) with the opportunity to comment on the Sycamore Hills Distribution Center (Project) Draft Environmental Impact Report (DEIR), State Clearinghouse No. 2020079023. The Project consists of the construction and operation of two transload short-term warehouse buildings totaling 603,100 square feet, primarily for the short-term storage and/or consolidation of manufactured goods prior to their distribution to retail locations or other warehouses. The Project is expected to generate approximately 847 daily vehicle trips, including 274 daily heavy-duty truck trips, along local roadways. The Project is proposed within the City of Riverside (City), California, which is the lead agency for California Environmental Quality Act (CEQA) purposes.
CARB submitted a comment letter, which is attached to this letter, on the Notice of Preparation (NOP) for the DEIR released in July 2020. CARB’s comments, dated August 27, 2020, highlighted the need for preparing a health risk assessment (HRA) for the Project and encouraged the City and applicant to implement all existing and emerging zero emission technologies to minimize exposure to diesel particulate matter (diesel PM) and nitrogen oxides (NOx) emissions for all neighboring communities, and to minimize the greenhouse gases that contribute to climate change. Due to the Project’s proximity to residences already disproportionately burdened by multiple sources of pollution, CARB’s comments expressed concerns with the potential cumulative health risks associated with the construction and operation of the Project.
The DEIR Did Not Model Mobile Air Pollutant Emissions Using CARB’s 2021 Emission Factor Model (EMFAC2021)
The City and applicant modeled the Project’s air pollutant emissions using mobile emission factors obtained from CARB’s 2014 Emission Factors model (EMFAC2014). Since the public release of EMFAC2014 in May 2015, CARB has made many updates to the EMFAC model.
These updates are reflected in EMFAC2017, released in May 2018, and EMFAC2021, released in January 2021. Some of the updates to the EMFAC model included updates to the heavy-duty truck activity and emission rates, and implementation of CARB’s latest regulations.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters EMFAC2014 underestimated diesel PM emission rates from diesel heavy-duty trucks due to limited in-use test data for engine model year 2010 and newer, thus the Project’s mobile source diesel PM emissions are likely underestimated in the DEIR. CARB urges the City and applicant to model and report the Project’s air pollution emissions from mobile sources using emission factors found in CARB’s latest EMFAC2021. Mobile emission factors can be easily obtained by running the EMFAC2021 Web Database: https://arb.ca.gov/emfac/emissions- inventory.
The DEIR Did Not Account for Air Pollutant Emissions from Heavy Duty Trucks During On Site Grading
The DEIR did not account for mobile source air pollutant emissions from grading operations during the Project’s construction phase. Based on CARB’s review of the California Emissions Estimator Model (CalEEMod) outputs found in Appendix B (Air Quality Studies) of the DEIR, the City and applicant assumed that no heavy-duty truck trips would be required to import or export soil during the on-site grading. Furthermore, the DEIR does not explicitly state the quantity of soil needed to grade the Project site that would support this assumption. If the Project site cannot be graded using existing on-site soil, the soil will need to be imported into the Project site. If that is the case, a large number of heavy-duty truck trips may be required to transport soil.
CARB urges t he City and applicant to remodel the Project’s construction air pollutant emissions using accurate heavy duty truck trip estimates. Residences and other sensitive receptors (e.g., daycare facilities, senior care facilities, and schools) located near construction haul routes could be exposed to diesel exhaust emissions that were not evaluated in the DEIR. The DEIR should clearly state the total number of heavy-duty truck trips expected during Project construction so the public can fully understand the potential environmental effects of the Project on their communities.
The Final Environmental Impact Report Should Restrict the Operation of Transport Refrigeration Units within the Project Area Chapter 3.2 (Project Characteristics) of the DEIR states that the proposed Project would not include the operation of on-site cold storage uses. Consequently, air pollutant emissions associated with cold storage operation were not included in the DEIR. Should the Project later include cold storage uses, residences near the Project-site could be exposed to significantly higher levels of toxic diesel PM and nitrogen oxides (NOx), and greenhouse gases than trucks and trailers without TRUs. To ensure TRUs will not operate within the Project site without first quantifying and mitigating their potential impacts, CARB urges the City to include one of the following design measures in the Final Environmental Impact Report (FEIR):
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters • A Project design measure requiring contractual language in tenant lease agreements that prohibits tenants from operating TRUs within the Project-site; or • A condition requiring a restrictive covenant over the parcel that prohibits the applicant’s use of TRUs on the property, unless the applicant seeks and receives an amendment to its conditional use permit allowing such use.
If the City later chooses to allow TRUs to operate within the Project site, CARB urges the County to re-model the Project’s air quality impact analysis and HRA to account for potential health risks. The updated air quality impact analysis and HRA should include the following air pollutant emission reduction measures:
• Include contractual language in tenant lease agreements that requires all loading/unloading docks and trailer spaces to be equipped with electrical hookups for trucks with TRU or auxiliary power units. This requirement will substantially decrease the amount of time that a TRU powered by a fossil-fueled internal combustion engine can operate at the Project-site. Use of zero-emission all-electric plug-in TRUs, hydrogen fuel cell transport refrigeration, and cryogenic transport refrigeration are encouraged and can also be included in lease agreements.1 • Include contractual language in tenant lease agreements that requires all TRUs entering the project site to be plug-in capable
The Final Environmental Impact Report Should Include More Mitigation Measures to Further Reduce the Project’s Air Pollution Emissions
The DEIR concluded that the Project would not exceed the South Coast Air Quality Management District’s significance thresholds and potential impacts are expected to be less than significant. Therefore, the Project has no mitigation measures specific to air quality except for Mitigation Measure MM AIR-1, which is required to ensure that the actual use of the site is consistent with the use described in the Project Description and analyzed in the project specific air quality analyses. However, the community near the Project site is already exposed to toxic diesel PM emissions from freight operations at existing industrial buildings and vehicular traffic on East Alessandro Boulevard and Interstate 215 (I-215). Due to the Project’s proximity to residences and schools, CARB is concerned with the potential cumulative health impacts associated with the construction and operation of the Project. To further reduce the Project’s air pollutant emissions, CARB urges the City and applicant to implement the emissions reduction measures listed in CARB’s attached comment (Attachment A) on the NOP for the DEIR in the Final Environmental Impact Report. 1 CARB’s Technology Assessment for Transport Refrigerators provides information on the current and projected development of TRUs, including current and anticipated costs. The assessment is available at:
https://www.arb.ca.gov/msprog/tech/techreport/tru_07292015.pdf.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters Conclusion
CARB is concerned about the potential public health impacts should the City approve the Project. To fully understand the Project's environmental impacts, the HRA should be revised in the FEIR using mobile and idling PM10 emission factors obtained from the latest version of EMFAC (i.e., EMFAC2021). If heavy-duty trucks are required to import or export soil from the site during Project construction, the Project’s air quality analysis and HRA should be updated to reflect such activities. The FEIR should include a design measure restricting the operation of TRUs within the Project site. Should the City allow the proposed warehouse building to be used for cold storage, the City should update the Project's air quality analysis and HRA to account for the increase in air pollution and cancer risks resulting from trucks and trailers with TRUs visiting the Project site. Lastly, to reduce the Project’s impact on public health, CARB encourages the City to implement the measures listed in Attachment A of this comment letter.
Given the breadth and scope of projects subject to CEQA review throughout California that have air quality and greenhouse gas impacts, coupled with CARB’s limited staff resources to substantively respond to all issues associated with a project, CARB must prioritize its substantive comments here based on staff time, resources, and its assessment of impacts.
CARB’s deliberate decision to substantively comment on some issues does not constitute an admission or concession that it substantively agrees with the lead agency’s findings and conclusions on any issues on which CARB does not substantively submit comments.
CARB appreciates the o pportunity to comment on the DEIR for the Project and can provide assistance on zero‑emission technologies and emission reduction strategies, as needed. If you have questions, please contact Michaela Nucal, Air Pollution Specialist, via email at [email protected].
Sincerely,
Robert Krieger, Branch Chief, Risk Reduction Branch
Attachment
cc: See next page.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters cc: State Clearinghouse
[email protected]
Carlo De La Cruz, Senior Campaign Representative, Sierra Club [email protected]
Lijin Sun, Program Supervisor, CEQA Intergovernmental Review, South Coast Air Quality Management District
[email protected]
Morgan Capilla, NEPA Reviewer, U.S. Environmental Protection Agency,Air Division, Region 9
[email protected]
Marven Norman, Policy Specialist, Center for Community Action and Environmental Justice
[email protected]
Taylor Thomas, Research and Policy Analyst, East Yard Communities for Environmental Justice
[email protected]
Michaela Nucal, Air Pollution Specialist, Risk Reduction Branch
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters Attachment A
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters
A
ugust 27, 2020
Veronica Hernandez
Senior Planner
City of Riverside
3900 Main Street, 3rd Floor
Riverside, California 92522
Submitted via email: [email protected]
Dear Veronica Hernandez:
Thank you for providing the California Air Resources Board (CARB) with the opportunity to comment on the Notice of Preparation (NOP) for the Sycamore Hills Distribution Center Project (Project) Draft Environmental Impact Report (DEIR), State Clearinghouse No. 2020079023. The Project includes the development of two warehouse buildings totaling 603,100 square feet. The proposed warehouses will be used for short-term transloading operations, primarily for the short-term storage and/or consolidation of manufactured goods. The Project is located within the City of Riverside, California, which is the lead agency for California Environmental Quality Act (CEQA) purposes.
Freight facilities, such as warehouse and distribution facilities, can result in high daily volumes of heavy-duty diesel truck traffic and operation of on-site equipment (e.g., forklifts and yard tractors) that emit toxic diesel emissions, and contribute to regional air pollution and global climate change.
1 CARB has reviewed the NOP and is
concerned about the air pollution and health risk impacts that would result should the City approve the Project.
I. The Project Would Increase Exposure to Air Pollution in Disadvantaged Communities
The Project, if approved, will expose nearby disadvantaged communities to elevated levels of air pollution. Residences are located approximately 350 feet south of the Project’s southern boundary. In addition to residences, four schools (Taft Elementary School, John F. Kennedy Elementary School, Benjamin Franklin Elementary School, and Edgemont Elementary School) and a daycare center (Little Angels Daycare) are located within 2 miles of the Project. The community near the Project site is already exposed to toxic diesel particulate matter (diesel PM) emissions from freight operations
1. With regard to greenhouse gas emissions from this project, CARB has been clear that local governments and project proponents have a responsibility to properly mitigate these impacts. CARB’s guidance, set out in detail in the Scoping Plan issued in 2017, makes clear that in CARB’s expert view, local mitigation is critical to achieving climate goals and reducing greenhouse gases below levels of significance.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters at e
xisting industrial buildings, and vehicular traffic on East Alessandro Boulevard and Interstate 215 (I-215). Due to the Project’s proximity to residences, schools, and daycares already burdened by multiple sources of air pollution, CARB is concerned with the potential cumulative health impacts associated with the construction and operation of the Project.
The State of California has placed additional emphasis on protecting local communities from the harmful effects of air pollution through the passage of Assembly Bill 617 (AB 617) (Garcia, Chapter 136, Statutes of 2017). AB 617 is a significant piece of air quality legislation that highlights the need for further emission reductions in communities with high exposure burdens, like those in which the Project is located. Diesel PM emissions generated during the construction and operation of the Project would negatively impact the community, which is already impacted by air pollution from existing industrial facilities and vehicular traffic on East Alessandro Boulevard and I-215.
II. The DEIR Should Quantify and Discuss the Potential Cancer Risks at Residential and Other Sensitive Receptors in the Vicinity of the Proposed Industrial Building
The Project, as proposed in the NOP, will not include refrigerated storage. The operation of cold storage warehouses would include trucks with transportation refrigeration units (TRU)
2 that emit significantly higher levels of toxic diesel PM emissions, oxides of nitrogen (NOx), and greenhouse gases than trucks without TRUs.
To ensure TRUs will not operate within the Project site, CARB urges the City to include one of the following design measures in a revised DEIR:
• A Project design measure requiring contractual language in tenant lease agreements that prohibits tenants from operating TRUs within the Project site; or
•
A condition requiring a restrictive covenant over the parcel that prohibits the applicant’s use of TRUs on the property, unless the applicant seeks and receives an amendment to its conditional use permit allowing such use.
If the City chooses to allow TRUs within the Project site, CARB urges the City to model air pollutant emissions from on-site TRUs, as well as prepare a health risk assessment (HRA) that shows the potential health risks. The DEIR should also include the air pollutant reduction measures listed in Attachment A.
In addition to the health risk associated with operations, construction health risks should be included in the air quality section of the DEIR and the Project’s HRA. Construction of the Project would result in short-term diesel emissions from the use of both on-road and off-road diesel equipment. The Office of Environmental Health Hazard Assessment’s
2. TRUs are refrigeration systems powered by diesel internal combustion engines that protect perishable goods during transport in an insulated truck and trailer vans, rail cars, and domestic shipping containers.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters (
OEHHA) guidance recommends assessing cancer risks for construction projects lasting longer than two months. Since construction would very likely occur over a period lasting longer than two months, the HRA prepared for the Project should include health risks for existing residences near the Project site during construction.
The HRA prepared in support of the Project should be based on the latest OEHHA guidance (2015 Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments),
3 and the South Coast Air Quality Management District’s (SCAQMD) CEQA Air Quality Handbook.4 The HRA should evaluate and present the existing baseline (current conditions), future baseline (full build-out year, without the Project), and future year with the Project. The health risks modeled under both the existing and the future baselines should reflect all applicable federal, state, and local rules and regulations. By evaluating health risks using both baselines, the public and City planners will have a complete understanding of the potential health impacts that would result from the Project.
III. Conclusion
To reduce the exposure of toxic diesel PM emissions in disadvantaged communities already disproportionally impacted by air pollution, the final design of the Project should include all existing and emerging zero-emission technologies to minimize diesel PM and NO
x emissions, as well as the greenhouse gases that contribute to climate change.
CARB encourages the City and applicant to implement the measures listed in Attachment A of this comment letter to reduce the Project’s construction and operational air pollution emissions.
Gi
ven the breadth and scope of projects subject to CEQA review throughout California that have air quality and greenhouse gas impacts, coupled with CARB’s limited staff resources to substantively respond to all issues associated with a project, CARB must prioritize its substantive comments here based on staff time, resources, and its assessment of impacts. CARB’s deliberate decision to substantively comment on some issues does not constitute an admission or concession that it substantively agrees with the lead agency’s findings and conclusions on any issues on which CARB does not substantively submit comments.
3. Office of Environmental Health Hazard Assessment (OEHHA). Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. February 2015. Accessed at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf.
4. SCAQMD’s 1993 Handbook can be found at: http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters CA
RB appreciates the opportunity to comment on the NOP for the Project and can provide assistance on zero-emission technologies and emission reduction strategies, as needed. Please include CARB on your State Clearinghouse list of selected State agencies that will receive the DEIR as part of the comment period. If you have questions, please contact Michaela Nucal, Air Pollution Specialist, via email at [email protected].
Sincerely,
Richard Boyd, Chief
Risk Reduction Branch
Transportation and Toxics Division
Attachment
cc: See next page.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters cc:
State Clearinghouse
[email protected]
Carlo De La Cruz
Senior Campaign Representative
Sierra Club
[email protected]
Lijin Sun
Program Supervisor
CEQA Intergovernmental Review
South Coast Air Quality Management District
[email protected]
Morgan Capilla
NEPA Reviewer
U.S. Environmental Protection Agency
Air Division, Region 9
[email protected]
Taylor Thomas
Research and Policy Analyst
East Yard Communities for Environmental Justice
[email protected]
Andrea Vidaurre
Policy Analyst
Center for Community Action and Environmental Justice
[email protected]
Michaela Nucal
Air Pollution Specialist
Risk Analysis Section
Transportation and Toxics Division
[email protected]
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters AT
TACHMENT A
Recommended Air Pollution Emission Reduction Measures
for Warehouses and Distribution Centers
The California Air Resources Board (CARB) recommends developers and government planners use all existing and emerging zero to near-zero emission technologies during project construction and operation to minimize public exposure to air pollution. Below are some measures, currently recommended by CARB, specific to warehouse and distribution center projects. These recommendations are subject to change as new zero-emission technologies become available.
Recommended Construction Measures
1. Ensure the cleanest possible construction practices and equipment are used.
This includes eliminating the idling of diesel-powered equipment and providing the necessary infrastructure (e.g., electrical hookups) to support zero and near-zero equipment and tools.
2. Implement, and plan accordingly for, the necessary infrastructure to support the zero and near-zero emission technology vehicles and equipment that will be operating on site. Necessary infrastructure may include the physical (e.g., needed footprint), energy, and fueling infrastructure for construction equipment, on-site vehicles and equipment, and medium-heavy and heavy-heavy duty trucks.
3. In construction contracts, include language that requires all off-road diesel-powered equipment used during construction to be equipped with Tier 4 or cleaner engines, except for specialized construction equipment in which Tier 4 engines are not available. In place of Tier 4 engines, off-road equipment can incorporate retrofits, such that, emission reductions achieved equal or exceed that of a Tier 4 engine.
4. In construction contracts, include language that requires all off-road equipment with a power rating below 19 kilowatts (e.g., plate compactors, pressure washers) used during project construction be battery powered.
5. In construction contracts, include language that requires all heavy-duty trucks entering the construction site, during the grading and building construction phases be model year 2014 or later. All heavy-duty haul trucks should also meet CARB’s lowest optional low-oxides of nitrogen (NO
x) standard starting in the year
2022.1
1. In 2013, CARB adopted optional low-NOx emission standards for on-road heavy-duty engines. CARB encourages engine manufacturers to introduce new technologies to reduce NOx emissions below the current mandatory on-road heavy-duty diesel engine emission standards for model year 2010 and later. CARB’s optional low-NOx emission standard is available at:
https://www.arb.ca.gov/msprog/onroad/optionnox/optionnox.htm.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters
6. I
n construction contracts, include language that requires all construction equipment and fleets to be in compliance with all current air quality regulations.
CARB is available to assist in implementing this recommendation.
Recommended Operation Measures
1. Include contractual language in tenant lease agreements that requires tenants to use the cleanest technologies available, and to provide the necessary infrastructure to support zero-emission vehicles and equipment that will be operating on site.
2. Include contractual language in tenant lease agreements that requires all loading/unloading docks and trailer spaces be equipped with electrical hookups for trucks with transport refrigeration units (TRU) or auxiliary power units. This requirement will substantially decrease the amount of time that a TRU powered by a fossil-fueled internal combustion engine can operate at the project site. Use of zero-emission all-electric plug-in TRUs, hydrogen fuel cell transport refrigeration, and cryogenic transport refrigeration are encouraged and can also be included in lease agreements.
2 3. Include contractual language in tenant lease agreements that requires all TRUs entering the project site be plug-in capable.
4. Include contractual language in tenant lease agreements that requires future tenants to exclusively use zero-emission light and medium-duty delivery trucks and vans.
5. Include contractual language in tenant lease agreements requiring all TRUs, trucks, and cars entering the Project site be zero-emission.
6. Include contractual language in tenant lease agreements that requires all service equipment (e.g., yard hostlers, yard equipment, forklifts, and pallet jacks) used within the project site to be zero-emission. This equipment is widely available.
7. Include contractual language in tenant lease agreements that requires all heavy-duty trucks entering or on the project site to be model year 2014 or later, expedite a transition to zero-emission vehicles, and be fully zero-emission beginning in 2030.
2. CARB’s Technology Assessment for Transport Refrigerators provides information on the current and projected development of TRUs, including current and anticipated costs. The assessment is available at:
https://www.arb.ca.gov/msprog/tech/techreport/tru_07292015.pdf.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters
8. I
nclude contractual language in tenant lease agreements that requires the tenant be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy-Duty (Tractor-Trailer) Greenhouse Gas Regulation,3 Periodic Smoke Inspection Program (PSIP),4 and the Statewide Truck and Bus Regulation.5
9. Include contractual language in tenant lease agreements restricting trucks and support equipment from idling longer than 5 minutes while on site.
10. Include contractual language in tenant lease agreements that limits on-site TRU diesel engine runtime to no longer than 15 minutes. If no cold storage operations are planned, include contractual language and permit conditions that prohibit cold storage operations unless a health risk assessment is conducted, and the health impacts fully mitigated.
11. Include rooftop solar panels for each proposed warehouse to the extent feasible, with a capacity that matches the maximum allowed for distributed solar connections to the grid.
12. Including language in tenant lease agreements, requiring the installing of vegetative walls
6 or other effective barriers that separate loading docks and people living or working nearby.
3. In December 2008, CARB adopted a regulation to reduce greenhouse gas emissions by improving the fuel efficiency of heavy-duty tractors that pull 53-foot or longer box-type trailers. The regulation applies primarily to owners of 53-foot or longer box-type trailers, including both dry-van and refrigerated-van trailers, and owners of the heavy-duty tractors that pull them on California highways. CARB’s Heavy-Duty (Tractor-Trailer) Greenhouse Gas Regulation is available at:
https://www.arb.ca.gov/cc/hdghg/hdghg.htm.
4. The PSIP program requires that diesel and bus fleet owners conduct annual smoke opacity inspections of their vehicles and repair those with excessive smoke emissions to ensure compliance. CARB’s PSIP program is available at:
https://www.arb.ca.gov/enf/hdvip/hdvip.htm.
5. The regulation requires that newer heavier trucks and buses must meet particulate matter filter requirements beginning January 1, 2012. Lighter and older heavier trucks must be replaced starting January 1, 2015. By January 1, 2023, nearly all trucks and buses will need to have 2010 model year engines or equivalent. CARB’s Statewide Truck and Bus Regulation is available at:
https://www.arb.ca.gov/msprog/onrdiesel/onrdiesel.htm.
6. Effectiveness of Sound Wall-Vegetation Combination Barriers as Near-Roadway Pollutant Mitigation Strategies (2017) is available at: https://ww2.arb.ca.gov/sites/default/files/classic//research/apr/past/13-306.pdf.
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters
3985 University Avenue, Riverside, CA 92501 • Phone: (951) 683-7100 • Fax: (951) 683-2670 www.riverside-chamber.com
GREATER RIVERSIDE
CHAMBERS OF COMMERCE
__________________________________________________
The Chamber…building a stronger local economy
July 26, 2021
Chair Richard Kirby
Planning Commission
City of Riverside
3900 Main Street,
Riverside, CA 92501
Subject: Sycamore Hills Distribution Center Project - SUPPORT
Dear Chair Kirby and Members of the Planning Commission,
On behalf of the Greater Riverside Chambers of Commerce, representing over 1,200 local employers and 110,000 jobs in the Inland Southern California region, we respectfully SUPPORT KB Development’s proposed development of the Sycamore Hills Distribution Center on East Alessandro Boulevard.
The Chamber’s EastHills Business Council met with KB Development and voted in unanimous support of the project due to the investment and connectivity this development will bring to the EastHills area. The project will bring two 400,000 and 200,000 square foot centers to the currently vacant zoned commercial land. The buildings and landscaping will complement the surrounding area with natural aesthetics and colors.
In preservation of the surrounding trails and wild landscape, the development proposed to build out a parking lot adjacent to the Sycamore Canyon trails to allow residents to safely park without impeding on the land and to encourage healthy outdoor activities. The proposed project will also be built out 500 feet away from the conservation areas.
The Sycamore Hills Distribution Center will also bring needed jobs to the region. With the after-effects of COVID-19, the introduction of new employment opportunities in the area will boost the region towards economic growth and trajectory.
For these reasons, the Chamber requests your support of the proposed development of the Sycamore Hills Distribution Center on East Alessandro Boulevard.
Thank you for your consideration. Should you have any questions, please do not hesitate to contact me at 951- 683-7100.
Respectfully,
Cindy Roth
President/CEO
CR/jd
P20-0025, P19-0626, P19-0627, P20-0258, P20-0282, P20-0024, Exhibit 11 - Public Comment Letters