Attachment 8b - Final EIR — Riverside City Council, January 25, 2022

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-280

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-281

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-282

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-283

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-284

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-285

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-286

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-287

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-288

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-289

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-290

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-291

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-292

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-293

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-294

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-295

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-296

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-297

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-298

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-299

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-300

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-301

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-302

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-303

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-304

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-305

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-306

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-307

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-308

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-309

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-310

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-311

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-312

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-313

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-314

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-315

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-316

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-317

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-318

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-319

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-320

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-321

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-322

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-323

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-324

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-325

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-326

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-327

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-328

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-329

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-330

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-331

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-332

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-333

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-334

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-335

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-336

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-337

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-338

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-339

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-340

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-341

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-342

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-343

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-344

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-345

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-346

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-347

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-348

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-349

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-350

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-351

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-352

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-353

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-354

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-355

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-356

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-357

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-358

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-359

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-360

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-361

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-362

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-363

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-364

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-365

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-366

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-367

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-368

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-369

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-370

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-371

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-372

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-373

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-374

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-375

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-376

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-377

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-378
Letter 9 – SWAPE on behalf of Golden State Environmental Justice Alliance Commenter: Matt Hagemann and Paul E. Rosenfeld
Date: July 21, 2021
Response 9.1:

The commenter states that the commenter has reviewed the Project, provides a brief description of the Project, and summarizes the comment letter’s conclusions on issues the commenter has identified regarding the Project’s potential air quality, health risk, and greenhouse gas impacts.

These issues are identified and addressed in the subsequent responses below. The commenter’s claims that the DEIR fails to disclose impacts has been refuted in Responses 9.2 through 9.21; please refer to these responses for discussions on how the Project would not result in the types of impacts alleged by the commenter.

This comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 9.2:

The commenter summarizes their understanding of CalEEMod and claims that the em issions calculations using CalEEMod are not substantiated and are underestimated based on the subsequent comments. These comments are responded to as below in subsequent responses.

Response 9.3:

The comment claims that the proposed offices should be modeled as a land use separate from the proposed warehouses. However, the offices are not a separate land use; rather, they are an auxiliary use associated with the proposed warehouse operations and would be constructed within the proposed warehouse buildings. As outlined in Response 7.31 above, using this Square Feet (SF)/Employee factor to determine employment, the appropriate methodology is to divide the total number of building square feet for Light Industrial building by the SF/Employee factor of 1,030. Therefore, the total Light Industrial building square footage for the Project is 603,100 SF divided by 1,030, which is 585.5, which is rounded to the nearest whole number of 586. To use this method of determining employment it is not correct to use the square footage of office space within the larger warehouse building and then separately calculate the non- office designated areas within the warehouse as Light Industrial. This is in essence double counting and combining two different land use designation types within the same building. Therefore, it is inappropriate and inaccurate to use the SF/Employee factor for within the office portion of the warehouse when the methodology identified above indicates to use the total number of building square feet for the specified Land Use Designation, which for the warehouse buildings is Light Industrial.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-379
The trip generation rate used in the Traffic Operations Analysis accounts for trips associated with all ware house operations , including trucks and both office and warehouse employees.

Additionally, since the total square footage of all warehouse and office space was modeled in CalEEMod, the calculated construction and operational emissions, including mobile, ene rgy, area, water and wastewater, and solid waste sources, account for the proposed office space. As such, the analysis in the DEIR and underlying technical studies is correct and no changes are needed.

Response 9.4:

The comment claims that the carbon dioxide ( CO2), methane (CH4), and nitrous oxide (N2O) intensity factors were adjusted without substantiation. As these intensit y factors affect only the greenhouse gas ( GHG) emissions calculations and not the criteria pollutant calculations, a discussion of the adjustments to the intensity factors is included in the GHG Analysis (page 22- 23) and not the Air Quality Analysis. The commenter provides four reasons why the adjustments were not substantiated:

1. The commenter states that the DEIR and Air Quality ( AQ) and Health Risk Assessment (HRA) memo fail to provide a source that the utility provider had achieved 36 percent renewables as of 2017. Under the Power Source Disclosure Program, retail utility suppliers are required to annually disclose to their retail consumers the mix of sources used to provide electricity service during the previous calendar year. All Power Content Labels for utility s uppliers can be accessed through the California Energy Commission website at https://www.energy.ca.gov/programs -and-topics/programs/power-source- disclosure/power-content-label. The Riverside Public Utility 2017 Power Content Label indicates that they had achieved 36 percent renewables as of 2017. A source for this data has been added to the GHG Analysis on page 26 and to DEIR p. 5.7-33 as follows:
• Energy - State regulations and 2017 Scoping Plan measures that would reduce the project’s energy-related GHG em issions include RPS (see Section 3.2.2.5), Title 24 Energy Efficiency Standards (see Section 3.2.2.7a), and CALGreen (see Section

3.2.2.7b). The project would be served by Riverside Public Utilities, which has achieved 36 percent renewables as of 2017 (CEC 2018b)10. The project’s energy related GHG emissions would decrease as Riverside Public Utilities increases its renewables procurement beyond 2020 towards the 2030 goal of 60 percent.

Additionally, the project would be constructed in accordance with ener gy efficiency standards effective at the time building permits are issued. The current 2019 Energy Code is estimated to decrease energy consumption by 30 percent for non-residential buildings when compared to the 2016 Title 24 Energy Code.

10 California Energy Commission (CEC). 2018b. City of Riverside Public Utilities 2017 Power Content Label.

Version July 2018.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-380

2. The comment sta tes that the model includes an 18.4 percent reduction, but the commenter’s review of the modeling demonstrates that the CH 4, CO2, and N2O intensity factors were reduced by approximately 21 percent, 21 percent, and 17 percent, respectively, instead of using the default in the model of 18.4 percent. These percentages were calculated by the commenter using the values presented in Table 6 of the GHG Analysis. 17 percent is incorrect due to an error in the table (see footnote of Table 5.7 -6 below). The default intensity factors included in CalEEMod were based on public utilities inventory reports. The CalEEMod Version 2016.3.2 user’s guide indicates that the intensity factors for Riverside Public Utilities are based on a 2007 reporting year.

Therefore, the default intensity factor included in CalEEMod Version 2016.3.2 accounts for the amount of RPS that the Riverside Public Utilities had in 2007. As cited in the Union of Concerned Scientists (2012)11 source provided in the GHG Analysis, Riverside Public Utilities had achieved approximately 18.4 percent renewables. To calculate the intensity factors used in the DEIR analysis, the default values were first increased by 18.4 percent to calculate the intensity factors without any renewable resources and then decreased by 33 percent to calculate the intensity factors with the state mandated 33 percent renewables (note that increasing the default factors by 18.4 percent and then decreasing by 33 percent gets the same result as decreasing by 21 percent as calculated by the commenter). Those calculations are detailed in Table 5.7-6 below.

Further, since preparation of the GHG Analysis a new version of CalEEMod (CalEEMod Version 2020.4.0) has been release that includes updated energy intensity factors that are less than what was modeled. The CalEEMod Version 2016.3.2 user’s guide indicates that the updated intensity factors for Riverside Public Utilities are based on a 2021 reporting year. Those updated values are also summarized in Table 5.7- 6 below. As a result, the originally calculated GHG emissions summarized in the GHG Analysis and DEIR are conservative. To reflect the updated intensity factors, Project GHG emissions were recalculated using the current 2021 Riverside Public Utilities intensity factors, and the revised emissions are summarized in GHG Analysis Table 6 and Table 5.7-6 of DEIR Section 5.7 GHG Emissions (DEIR p. 5.7-25), which has also been included below , with changes reflected for reference. It was found that the revised energy related GHG emissions associated with the project would be less than previously calculated, and total GHG emissions would still be less than the 10,000 MT CO2E screening threshold.

11 Union of Concerned Scientists. 2012. Riverside Public Utilities. The Clean Energy Race: How Do California Public Utilities Measure Up. July.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-381
Table 5.7-6 – Riverside Public Utilities Intensity Factors Riverside Public Utilities Intensity Factors (lbs/MWh)
GHG
CalEEMod
Version 2016.3.2
Default values
(lbs/MWh)
Intensity Factors
with 0% RPS
Intensity Factors
with 33% RPS
CalEEMod
Version 2020.4.0
Intensity Factor
Carbon Dioxide
(CO2) 1,325.65 1,569.57 1,051.61 789.983
Methane (CH4) 0.029 0.034 0.023 0.033
Nitrous Oxide
(N2O) 0.006 0.007 0.005* 0.004
*The correct N2O intensity factor of 0.005 was used in CalEEMod, however, the incorrect value of

0.004 was reported in Table 6 of the GHG Analysis. Table 6 of the GHG Analysis has been updated to reflect the current 2021 intensity factors.

3. The comment states that even if the utility provided did achieve 36 percent renewable energy, this does not inherently result in a 36 percent reduction from the 2016 CalEEMod default values. As stated in Response 9.4(1), a source for the 36 percent renewables has been added to the GHG Analysis and RPS as well as DEIR p. 5.7-33. The comment also states that there is no justification explaining how this power mix correlates to 21 percent, 21 percent, and 17 percent reductions. As noted previously, due to an e rror in the table, the 17 percent calculation is incorrect . Using the previous N 2O intensity factor of 0.005 would have also resulted in a calculated reduction of 21% as with CO2 and CH4. Refer to Response 9.4(2) for an explanation of how the energy intens ity factors were calculated using the previous Riverside Public Utilities 18.4 percent attainment status and an RPS attainment requirement of 33 percent. It should also be noted that since preparation of the GHG Analysis, the state has increased the RPS goals beyond the year 2020 33 percent requirement. SB 100 (2018) further increased the standard set by SB 350 establishing the RPS goal of 44 percent by the end of 2024, 52 percent by the end of 2027, and 60 percent by 2030. Riverside Public Utilities is required to comply with these state RPS goals, and the project would be served by Riverside Public Utilities . Therefore, the project would benefit from a decrease in energy - related GHG emissions as Riverside Public Utilities complies with state RPS requirements. The analysis used the most recent 2021 Riverside Public Utility energy intensity factors (see Table 5.7-6 above). As Riverside Public Utilities further increases their RPS percentage in line with state goals, the energy intensity factors would decrease, and therefore, the project’s energy related GHG emissions would decrease. Thus, the GHG analysis is conservative.

4. The comment states that simply stating that the Project’s emissions would decrease as the utility provider increases its renewables procurement beyond 2020 towards the 2030 goal of 50 percent does not offer substantial evidence to justify the reductions included in the model. A utility provider’s renewables procurement directly relates to the energy intensity factors since increasing the amount of renewable energy and decreasing reliance on fossil fuels reduces the energy related GHG emissions. Refer to responses 9.4(1) and

9.4(2) for justification of the reductions included in the model. Further, as stated in response 9.4(3), the 2030 RPS goal has been increased to 60 percent.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-382
The comment concludes by stating that the unsubstantiated reductions in intensity factors may underestimate the Project’s GHG emissions. For the reasons stated above, the energy intensity factors used in the model are conservative and based on the updated 2021 energy intensity factors included in CalEEMod Version 2020.4.0, which are less than the modeled intensity factors.

Therefore, the GHG emissions calculated in the public review draft of the GHG Analysis are an overestimate of the Project’s actual emissions. GHG emissions were recalculated using the current 2021 Riverside Public Utilities intensity factors. It was found that the revised energy related GHG emissions associated with the Project would be less than previously calculated, and total GHG emissions would still be less than the 10,000 MT CO2E screening threshold.

It should be noted that even with this revision to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.5:

The commenter states that the DEIR underestimates the proposed parking lot land use size and that, accordingly, emissions models underestimate the Project’s construction- related and operational emissions.

The CalEEMod user’s guide states that “if actual lot acreage data is available, the user should override the default value.” If the CalEEMod default for the parking lot was used, the total lot acreage analyzed would be 8.18 acres, which would not correctly represent the total site area.

Using ArcGIS and the ArcMap mapping programs along with CAD drawings of the site plan, it was determined that approximately 21 acres would be paved and of this, approximately 5 acres would be striped parking spaces. This includes the trailhead parking lot. As shown in Attachment 1 of the DEIR Appendix C, Air Quality Analysis, these areas were modeled as 5 acres “Parking Lot” and 16 acres “Other Asphalt Surfaces”. As noted on Page 25 of the Air Quality Analysis, the trailhead parking lot was modeled as a paved and striped parking lot to account for emissions from striping paint and pavement sealant. The parking lot would be partially concrete and partially decomposed granite that would be properly stabilized to reduce dust. The analysis has been revised to include fugitive dust emissions that would occur from vehicles traveling on the decomposed granite. Thus, this is a worst -case analysis since it simultaneously accounts for architectural coatings that would result from pavement striping and dust that would result from decomposed granite. As shown in Table 9 on Page 26 of the Air Quality Analysis, these worst - case emissions would still be less than the applicable thresholds of significant.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-383
Response 9.6:

The commenter states the DEIR has unsubstantiated reductions to architectural coating emission factors and that the DEIR fails to mention SCAQMD Rule 1113 or specify the reactive organic gas/volatile organic compound (ROG/VOC) content limits that would be required.

The DEIR, Section 5.2.2.4 Air Quality, p. 5.2 -17 is revised as follows to include SCAQMD Rule 1113 compliance:

The project would also be required to comply with SCAQMD Rule 1113, which places VOC content limits on architectural coatings. The coatings used for the project would include building envelop coatings and non-flat coatings, which both have a VOC content limit of 50 grams per liter.

The Project would be required to comply with SCAQMD Rule 1113, which places VOC content limits on architectural coatings. The coatings used for the Project would include building envelop coatings and non-flat coatings, which both have a VOC content limit of 50 g rams per liter. The CalEEMod user’s guide states that if the user has more detailed site-specific information, the user should override the default values. Therefore, the VOC content limits used in the model were revised to 50 grams per liter. Out of an abundance of caution, criteria pollutant emissions were recalculated using the default VOC content value of 100 grams per liter. The revised emissions are summarized in Tables 6, 7, and 9 of the revised Air Quality Analysis and DEIR Tables 5.2-6,

5.2-7 (see Response 7.8), and 5.2-8 have been updated accordingly (see below). All construction and operational emissions would still be less than the applicable thresholds even without compliance, and air quality impacts would be less than significant.

Table 5.2-8 – Summary of Project Operational Emissions
Source
Emissions (pounds per day)
ROG NOx CO SO2 PM10 PM2.5
WINTER
Area Sources 14 <1 <1 <1 <1 <1
Energy Sources <1 <1 <1 <1 <1 <1
Mobile Sources – Passenger Cars 1 1 2 17 24 <1 10 3
Mobile Sources – Trucks 2 37 17 <1 10 3
Parcel C Parking Lot Dust -- -- -- -- 9 1
Total 17 38 39 34 41 <1 19 28 6 7
Significance Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
SUMMER
Area Sources 14 <1 <1 <1 <1 <1
Energy Sources <1 <1 <1 <1 <1 <1
Mobile Sources – Passenger Cars 1 1 2 19 27 <1 10 3
Mobile Sources – Trucks 2 36 16 <1 10 3
Parcel C Parking Lot Dust -- -- -- -- 9 1
Total 17 37 38 36 44 <1 19 28 6 7
Significance Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
Note: Emissions were rounded to the nearest whole number. Emissions reported as <1 indicate that emissions were calculated to be less than 0.5 pound per day.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-384

It should be noted that even with th ese revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.7:

The commenter states that the DEIR has unsubstantiated changes to individual construction phase lengths. The construction duration and phasing utilized represents a reasonable approximation of the expected construction activity as required by CEQA. The CalEEMod user’s guide states that if the user has more detailed site-specific equipment and phase information, the user should override the default values. The specific construction schedule was modified from the CalEEMod defaults based on information provided by the Project Applicant . Page 22 of DEIR Appendix C - Air Quality Analysis has been revised to note that the construction schedule and equipment list are based on a reasonable approximation and information provided by the Project Applicant. Rather than relying on the default construction schedule or proportionally altering the phases based on a different overall construction length, the analysis relies on actual project - specific scheduling and phasing. This information has been provided by an Applicant who has extensive experience with construction projects in the region. As such, the analysis in the DEIR and underlying technical studies is correct and no changes are needed.

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is not ed for the record , and revisions to the DEIR have been made as noted above.

Response 9.8:

The comment claims that unsubstantiated changes to the default vendor and worker trip numbers were made. As explained in Appendix C of the DEIR – Air Quality Analysis, CalEEMod applies the same worker/vendor trip rates to parking/asphalt surfaces as it does to office/industrial construction, resulting in an overestimate of actual trips. These default values included in CalEEMod are based on Sacramento Metropolitan Air Quality Management District field surveys of residential, commercial, and office development projects, and not on other uses such as asphalt surfaces and parking that require only asphalt and other associated sealants and not actual building materials. The CalEEMod user’s guide states that if the user has more detailed site- specific information, the user should override the default values. CalEEMod uses a rate of 0.42 worker trips and 0.1639 vendor trips per 1,000 square feet of industrial building space. However, for parking lots, CalEEMod incorrectly applies these same worker and vendor trip rates to the total square footage of parking area, even though no building construction is associated with the parking areas. The worker trips associated with paving are included in the paving phase. Thus, the trips were reduced to avoid an overestimation. However, out of an abundance of caution, emissions were recalculated using the CalEEMod default values. The revised emissions are City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-385
summarized in Tables 6 and 7 of the revised Air Quality Analysis and Table 7 of the revised GHG Analysis. Accordingly, DEIR Tables 5.2-6 and 5.2-7 have been revised (see Response 7.8) and DEIR Table 5.7-6 has been revised (see Response 9.4). All construction emissions would still be less than the applicable thresholds, and air quality and GHG impacts would be less than significant.

Also, out of an abundance of caution, the construction worker fuel consumption and construction vendor fuel consumption for Medium -Heavy-Duty-Trucks (MHDT) were also recalculated using the same CalEEMod default values, and these consumption estimates identified in DEIR Tables

5.5-4 and 5.5-5 are revised as outlined below. Although fuel consumption would be higher due to increased trips, fuel consumption for construction would still be less than significant, as the Project is not anticipated to result in wasteful, inefficient, or unnecessary consumption of energy resources during construction.

Table 5.5-4 – Construction Worker Fuel Consumption Estimates Construction
Activity
Worker
Trips/Day
Trip Length
(miles)
Vehicle
Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
2021
Site Preparation
(18 days) 18 14.7 4,763 30.64 155
Grading
(47 days) 47 14.7 13,818 30.64 451
Building Construction
(132 days) 132 14.7 490,921
1,237,975 30.64 16,020 40,399
2022
Building Construction
(111 days) 111 14.7 412,820
1,041,025 31.57 13,075 32,971
Paving
(18 days) 18 14.7 3,969
24,476 31.57 126 775
Architectural Coating
(111 days) 111 14.7 208,858
33,869 31.57 6,615 1,073
Construction Worker Fuel Consumption 36,442 75,824

Table 5.5-5 – Construction Vendor Fuel Consumption Estimates – MHDT Construction Activity
Vendor
Trips/Day
Trip Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
Vendor
2021
Building Construction
(132 days) 50 125 6.9 45,540
113,850 8.88 5,127 12,817
2022
Building Construction
(111 days) 50 125 6.9 38,295
95,738 9.2217 4,153 10,422
Total Fuel Consumption – Vendor (MHDT) 9,280 23,259
Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-386

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly , this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence r elated to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record , and revisions to the DEIR have been made as noted above.

Response 9.9:

The comment claims that unsubstantiated changes to the vehicle fleet mix were made in the modeling. Two separate models – Passenger Cars and Trucks – were run because the trucks would have greater trip lengths than the employees and CalEEMod does not have an option to input different trip lengths based on vehicle type. The project would generate 573 passenger car trips and 274 truck trips, of which 46 would be 2-axle trucks, 57 would be 3-axle trucks, and 171 would be 4- axle+ trucks. The previous Passenger Car emissions were calculated using 100 percent light duty automobiles. As suggested in the comment, emissions have been recalculated using a more diverse mix of employee vehicles including the following vehicle categories:
passenger cars (LDA), light -duty trucks (LDT1 and LDT2), medium -duty trucks (MDV), and motorcycles (MCY). The 573 passenger car trips were modeled by proportionally altering these values based on the CalEEMod default values. Note that CalEEMod also includes other non-truck vehicles such as buses and motor homes; however, these vehicle classifications would not be associated with the project. The revised emissions are summarized in Table 9 of the revised Air Quality Analysis and Table 7 of the revised GHG Analysis. Accordingly, correspondi ng DEIR Tables 5.2- 8 (see revised table under Response 9. 6) and 5.7 -7 (see revised table under Response 7.8) have been revised as well . For the truck mix, CalEEMod includes four truck categories: LHD1, LHD2, MHD, and HHD. The 2-axle trucks were modeled as LHD1, the 3-axle trucks were modeled as LHD2, and the 4- axle+ trucks were divided proportionally and modeled as MHD and HHD. As such, the truck emission modeling is correct and no changes to the truck modeling is needed. Justification for the modeled vehic le mix has been added to Section 6.2 of the revised Air Quality Analysis and Section 4.2.2 of the revised GHG Analysis.

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the ad equacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.10:

The comment states that the reduction in indoor water use is unsubstantiated. The comment also states that simply because CalGreen expects a 20 percent reduction in indoor water use does not guarantee that this reduction would be implemented locally on the Project site. This statement is incorrect. CalGreen mandatory measures, including the 20 percent reduction in indoor water use, are a requirement of the California Green Building Standards Codes and are required for all City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-387
new development in order to obtain building permits. As such, the analysis in the DEIR and underlying technical studies is correct. However, out of an abundance of caution, emissions were recalculated using the CalEEMod default water consumption rate. The revised emission calculations are provided in Table 7 of the revised GHG Analysis and corresponding DEIR Table

5.7-7 has been revised accordingly (see revised table under Response 7.8 and below). Revised Project GHG emissions would still be less than the 10,000 MT CO 2E screening threshold, and GHG emissions would be less than significant as concluded in the DEIR.

Table 5.7-7 – Summary of Project GHG Emissions (metric tons per year) Source MT CO2 MT CH4 MT N2O MT CO2E
Mobile – Passenger Cars 1,204
1,465 <1 0 1,204
1,466
Mobile – Trucks 4,316 <1 0 4,320
Energy Source 781 603 <1 <1 782 604
Area Sources <1 <1 0 <1
Water/Wastewater Sources 728 695 4 5 <1 846 842
Solid Waste Sources 86 115 5 7 1 0 214 285
Construction (Amortized over 30 years) 37 68 <1 0 38 68 Total 7,152
7,262 9 12 <1 7,405*
7,587*
SCAQMD Significance Threshold for Industrial Sources 10,000 MT CO2E = metric tons of carbon dioxide equivalent
MT CH4 = metric tons of methane
MT N2O = metric tons of nitrous oxide
*The GWPs included in CalEEMod are from the IPCC Fourth Assessment Report. For informational purposes, total emissions calculated by CalEEMod were adjusted to account for the updated IPCC Fifth Assessment Report GWPs.

Using the current GWPs, total annual project emissions would be 7,428 7,618 MT CO2, and would also be less than the screening threshold. Note that the IPCC updates the GWPs periodically, and the nex t anticipated update will occur in 2022.

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.11:

The comment claims that the incorrect fugitive dust reduction was modeled. The modeled reduction of 61 percent is based on the SCAQMD Fugitive Dust Mitigation Measure Table XI -A accessed at http://www.aqmd.gov/home/rules -compliance/ceqa/air-quality-analysis- handbook/mitigation-measures-and-control-efficiencies/fugitive-dust. This reduction is based on watering three times per day. As a conservative analysis, the modeling has been revised to reflect a 55 percent reduction in fugitive dust for watering two times per day. The revised emission calculations are summarized in Tables 6 and 7 of the revised Air Quality Analysis and corresponding DEIR Tables 5.2-6 and 5.2-7 (see Response 7.8). Additionally, text in Section 6.1 regarding the project’s compliance with SCAQMD Fugitive Dust Rule 403 has been revised as Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-388
follows: “This analysis assumes that standard dust and emission control during grading operations would be implemented to reduce potential nuisance impacts and to ensure compliance with SCAQMD Rule 403, which is estimated to result in a 55 percent reduction in fugitive dust from watering twice per day.” The revised construction emissions would still be less than the applicable thresholds, and air quality impacts would be less than significant.

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.12:

The comment claims that the reduction in solid waste is unsubstantiated and the design feature of providing storage areas for recyclables and green waste and recycling containers in public areas is not formally included as a mitigation measure. As stated in DEIR Section 4.2 .6 of the GHG Analysis, “According to a CalRecyle report to the Legislature, as of 2013 California has achieved a statewide 50 percent diversion of solid waste from landfills through “reduce/recycle/compost” programs (CalRecycle 2015). However, AB 341 mandates that 75 percent of the solid waste generated be reduced, recycled, or composted by 2020. Therefore, to account for the continuing actions of recycling requirements under state law (i.e., AB 341), a 25 percent solid waste diversion rate was included in the model.” As such, the analysis in the DEIR and underlying technical studies is correct. However, out of an abundance of caution, the GHG emissions were recalculated without the application of any reduction in solid waste. The revised emission calculations are provided in Table 7 of the revised GHG Analysis and in corresponding DEIR Table 5.7-7 (see revised table in Response 7.8). Revised project GHG emissions would still be less than the 10,000 MT CO 2E screening threshold, and GHG emissions would be less than significant, without mitigation, as concluded in the DEIR. GHG emissions were below thresholds of significance both with and without accounting for solid waste diversion in the modeling. As such, the design feature of providing recycling storage and containers does not need to be enforced as a mitigation measure as it is not necessary to reduce impacts to less than significant levels.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.13:

The comment presents the results of SWAPE’s own CalEEMod emission calculations based on the preceding comments. The commenter attempts to provide updated modeling and claims it is based on information in the DEIR, however, the commenter provides no substantial evidence to support this claim. SWAPE’s calculations represent an overestimation of the Project’s actual construction and operational emissions. While some of SWAPE’s suggestions were incorporated City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-389
into the revised emission calculations as detailed in the preceding responses, others do not accurately reflect the project -specific information r esulting in emissions that do not accurately reflect project-specific conditions. The following is a list of the parameters that SWAPE adjusted in their calculations as outlined in the first paragraph of the comment, and a discussion of why some were incorporated into the revised emission calculations, and why others are incorrect and were not incorporated into the revised emission calculations:
• Land use types and sizes – See Response 9.3. The comment claims that a separate office use should be modeled. How ever, the trip generation rate used in the Traffic Operations Analysis accounts for trips associated with all warehouse operations, including trucks and both office and warehouse employees. Additionally, since the total square footage of all warehouse and office space was modeled in CalEEMod, the calculated construction and operational emissions, including mobile, energy, area, water and wastewater, and solid waste sources, account for the proposed office space.

Additionally, see Response 9.5. The comment c laims that the DEIR underestimates the parking lot size. This is also incorrect since ArcGIS and ArcMap mapping programs along with CAD drawing files of the site plan were used to determine the amount of paving. Therefore, commenter‘s change in modeled land use is not justified and was not included in the revised modeling.
• Intensity factors – See Response 9.4. The comment states that the incorrect GHG intensity factors were modeled without substantiation. Response 9.4 provides an explanation of the reductions required by RPS and an explanation of how the intensity factor reductions were calculated. The emissions were recalculated using the most recent 2021 Riverside Public Utilities energy intensity factors (see Table 5.7 -6 in Response 9.4). The default intensity factors that SWAPE used in their calculations are outdated and do not reflect the current Riverside Public Utilities renewable energy procurement, and therefore result in an overestimation of the project’s energy-related GHG emissions.
• Architectural coating emission factors – See Response 9.6. SCAQMD Rule 1113 places VOC content limit on a variety of architectural coatings. The SWAPE CalEEMod calculations modeled a VOC content of 730 grams per liter. This is not correct. This VOC content is for a clear shellac, and this type of architectural coating would not be used for the Project. The ROG emissions calculated by SWAPE are hugely overestimated because it assumes that every exterior and interior surface of the building would be coated in clear shellac. As explained in Response 9.6, the coatings used for the Project would include building envelop coatings and non- flat coatings, which both have a VOC content limit of 50 grams per liter. The use of a VOC content of 730 grams per liter was not included in the revised modeling. However, out of an abundance of caution, criteria pollutant emissions were recalculated using the default VOC content value of 100 grams per liter.
• Vendor and worker trip numbers – See Response 9.8. CalEEMod applies the same worker/vendor trip rates to parking/asphalt surfaces as it does to office/industrial construction, resulting in an overestimate of actual trips. The default worker and vendor trip rates are discussed in Response 9.8. As explained, CalEEMod incorrectly applies these same worker and vendor trip rates to the total square footage of parking area, even though no building construction is associated with the parking areas.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-390
However, out of an abundance of caution, emissions were recalculated using the CalEEMod default values as recommended by SWAPE.
• Indoor water use rate – See Response 9.10. CalGreen mandatory measures, including the 20 percent reduction in indoor water use, are a requirement of the California Green Building Standards Codes and are required for all new development in order to obtain building permits. As such, the analysis in the DEIR and underlying technical studies is correct. However, out of an abundance of caution, emissions were recalculated using the CalEEMod default water consumption rate as recommended by SWAPE. • Construction phase lengths – See Response 9.7. The specific construction schedule was modified from the CalEEMod defaults based on information provided by the Project Applicant, and are based on a reasonable approximation of the project-specific schedule. The CalEEMod user’s guide states that if the user has more detailed site- specific equipment and phase information, the user should override the default values.

Therefore, the construction phasing and schedule modeled by SWAPE does not accurate reflect actual project conditions, and these changes were not incorporated into the revised modeling.
• Operational vehicle fleet mix percentages – See Response 9.9. As suggested by SWAPE, the employee trip emissions have been remodeled by proportionally altering the LDA, LDT1, LDT2, MDV, and MCY vehicle categories.
• PM10 and PM2.5 emissions reductions – See Response 9.11. The previously modeled dust reduction rate of 61 percent is based on SCAQMD Fugitive Dust Mitigation Measure Table XI-A, and corresponds to watering 3 times per day. To be consistent with DEIR mitigation measure BIO -3, this reduction was remodeled as 55 percent, corresponding to watering 2 times per day. This reduction is substantiated by SCAQMD.
• Operational solid waste – See Response 9.12. SWAPE modeled no reduction in operational solid waste. To account for continuing actions of recycling requirements under state law (AB 341), the modeled reduction of 25 percent was substantiated.

However, out of an abundance of caution, GHG emissions were recalculated without the application of any reduction in solid waste as recommended by SWAPE.

For these reasons presented in Responses 9.3 through 9.12 and summarized in the bullet point above, the SWAPE CalE EMod calculations presented in Comment 9.13 greatly overestimate project emissions, and do not accurately reflect actual project conditions. As presented in the revised Air Quality Analysis and GHG Analysis and outlined in the revised DEIR Tables below, the recalculated criteria pollutant and GHG emissions associated with construction and operation of the project, would still be less than all applicable thresholds. The analysis in the DEIR is correct, however, these revisions are done in an abundance of caution to illustrate that even withou t the justified reductions taken in the modeling, impacts would still be less than significant. Thus, as concluded in the DEIR and the underlying technical studies, air quality and GHG impacts would be less than significant.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-391
Table 5.7-6 – Riverside Public Utilities Intensity Factors Riverside Public Utilities Intensity Factors (lbs/MWh)
GHG
CalEEMod
Version 2016.3.2
Default values
(lbs/MWh)
Intensity Factors
with 0% RPS
Intensity Factors
with 33% RPS
CalEEMod
Version 2020.4.0
Intensity Factor
Carbon Dioxide
(CO2) 1,325.65 1,569.57 1,051.61 789.983
Methane (CH4) 0.029 0.034 0.023 0.033
Nitrous Oxide
(N2O) 0.006 0.007 0.005* 0.004
*The correct N2O intensity factor of 0.005 was used in CalEEMod; however, the incorrect value of 0.004 was reported in Table 6 of the GHG Analysis. Table 6 of the GHG Analysis has been updated to reflect the current 2021 intensity factors.

Using the current GWPs, total annual project emissions would be 7,428 7,618 MT CO2, and would also be less than the screening threshold. Note that the IPCC updates the GWPs per iodically, and the next anticipated update will occur in 2022.

Table 5.2-7 – Maximum Daily Construction Emissions Comparison to SCAQMD Significance Thresholds
Construction Emissions (pounds per day)
ROG NOx CO SOx PM10 PM2.5
Site Preparation 4 41 22 <1 910 6
Grading 4 5 46 57 32 33 <1 6 2 4
Building Construction/Architectural Coatings1 32 59 29 45 34 51 <1 6 11 2 4 Paving/Architectural Coatings1 32 58 46 13 34 21 <1 2 1 Maximum Daily Emissions2 32 59 46 57 34 51 <1 9 11 6
SCAQMD Regional Threshold 75 100 550 450 150 55
Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-392
Exceed Threshold? No No No No No No
1The architectural coatings phase of construction was modeled simultaneously with building construction and parking lot paving emissions.
2Emissions were rounded to the nearest whole number, Emissions reported as <1 indicate that emissions were calculated to be less than 0.5 pound per day.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.14:

The commenter summarizes the results of the operational health risk assessment and then goes on to discuss the need for a construction related HRA and states that the DEIR’s conclusion for a less than significant impact is flawed for three reasons. Specific responses to each of the three reasons presented in Responses 9.15 through 9.17 below.

Response 9.15:

The commenter states that the DEIR fails to quantitatively evaluate the Project’s construction- related toxic air contaminant (TAC) emissions or make a reasonable effort to connect these emissions to potential health risk impacts to nearby sensitive receptors.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-393
As part of the FEIR, a detailed construction HRA has been prepared utilizing the appropriate AERMOD modeling software (the same model used in the DEIR for operational HRA), which allows for calculation of annual average concentrations and allows for the geospatial placing of the source and receptor s. The construction HRA utilizes the durations identified in SWAPE’s comment letter along with the emissions estimates and number of days identified by SWAPE.

Refer to Response 9.17 for more details related to the construction HRA methodology. The primary difference in the emissions is they are now appropriately divided over an average 8-hour per day construction period versus the inappropriate 24-hour per day assumption from SWAPE.

Use of an 8 -hour per day construction period is based on substantial evidence established through the construction surveys that are the basis for the 8- hour per day operations for construction equipment in CalEEMod. Further, an 8-hour workday is a reasonable assumption of construction work based on a typical 40-hour work week and is a recognized typical workday by SCAQMD. Also, as a Project Condition of Approval, construction will be limited to 8 hours a day, 5 days a week. SCAQMD’s Fact Sheet for Applying CalEEMod to localized significance thresholds (LSTs) is based on the maximum area a given piece of equipment can pass over in an 8-hour workday, as noted in the DEIR analysis, and assumes that each piece of anticipated construction equipment will operate for 8 hours per day, which, in reality, already would overestimate construction emissions. For example, during grading operations, water trucks would not operate continuously for an 8- hour period but would instead be deployed as necessary – usually three to four times per day – to minimize fugitive dust. In fact, most pieces of equipment would likely operate for fewer hours per day than indicated in the DEIR. Based on the screening- level construction HRA calculations, the maximum estimated risk would be 1.99 in one million which is less than the applicable threshold of 10 in one mil lion. As such, no significant impact would occur and the DEIR finding of less than significant health risks is appropriate. Appendix N to the FEIR includes the risk calculation and AERMOD output files.

It should be noted that even with the inclusion of Appendix N, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and no revisions to the DEIR are required.

Response 9.16:

The commenter states that the OEHHA recommends that all short-term projects lasting at least two-months be evaluated for cancer risks to nearby sensitive receptors and that the Project meets the threshold warranting a quantified construction-related HRA. Please see Response 9.15. As discussed in Response 9.15, as part of the FEIR, a detailed construction HRA has been prepared utilizing the appropriate AERMOD modeling software (the same model used in the DEIR for operational HRA), which allows for calculation of annual average concentrations and allows for the geospatial placing of the source and receptors. As further discussed in Response 9.15, based on the screening-level construction HRA calculations, the maximum estimated risk would be 1.99 in one million which is less than the applicable threshold of 10 in one million. As such, no significant impact would occur and the DEIR finding of less than significant health risks is appropriate. Appendix N to the FEIR includes the risk calculation and AERMOD output files.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-394
It should be noted that even with the inclusion of Appendix N , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and no revisions to the DEIR are required.

Response 9.17:

The commenter states that the Project’s operational HRA fails to evaluate cumulative lifetime cancer risk to nearby, existing receptors as a result of combined Project construction and operation. The commenter then states that an updated analysis should quantify the entirety of the Project’s construction and operational health risks together. Please see Responses 9.15 and 9.16 above regarding the construction HRA analysis. Contrary to the commenter’s assertions, a cumulative stacking of the construction health risks on top of the operational health risk impacts is not appropriate since the concentrations vary by location and the operational risk assessment is based on a separate 30-year exposure scenario consistent with applicable guidance.

The HRA modeled three different time periods of exposure, for three distinct land use types, as summarized in Appendix N of the DEIR. The HRA includes a 30- year exposure scenario for residential occupancies, a 25- year exposure scenario for worker occupancies, and a 9 -year exposure scenario for a school -child occupancy. The use of the 30 -year and 25-year exposure durations for residential and worker occupancies is based on recommendations published by SCAQMD in their Risk Assessment Procedures for Rules 1401, 1401.1, & 212 (2017).12 Page 7 of the SCAQMD guidance clearly identifies the Exposure Duration (ED) for a residential land use as 30-years and a worker location as 25-years. The commenters request for evaluating a 70-year exposure duration is not necessary or supported by substantial evidence. As shown in the additional discussion under Response 7.12, a 70-year exposure duration is very unlikely to occur given average residency times, specifically in California.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR . This comment is noted for the record and no changes to the DEIR are required.

Response 9.18:

The commenter states that the screening- level analysis performed by SWAPE indicates a potentially significant health risk impact. However, the commenter’s screening- level HRA has several critical flaws. The commenter utilizes the AERS CREEN model, which is not the most appropriate model for determining concentrations from construction activity for risk calculation.

AERSCREEN is limited in that it only produces a 1 -hour ground level concentration – risk assessments should be based on an annual average concentration as outlined in the SCAQMD’s Mobile Source Toxic Analysis guidance13. The commenter attempts to adjust for this by applying

12 http://www.aqmd.gov/docs/default-source/permitting/rule-1401-risk-assessment/riskassessproc-v8-

1.pdf?sfvrsn=12
13 http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/mobile-source-toxics- analysis
City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-395
a 10% conversion factor that is based on model documentation from 1992, which may no longer be relevant. Further, SWAPE’s emission factor calculation is severely flawed: SWAPE takes the total daily emissions and divides them over a 24- hour period – effectively assuming that construction occurs 24 hours per day 7 days per week. The City of Riverside regulations prohibit construction from occurring 24 hours per day. This critical flaw, along with the aforementioned errors, results in a significant overestimation of the potential risk estimates from construction activity. It is also not appropriate or required to calculate the combined risk from construction and operations; since risk estimates are based on a source- receptor relationship, the point of maximum impact is not likely to be the same and stacking the risk estimates from short -term construction (which would cease upon the completion of each respective phase of construction) to on-going operational activity would not be appropriate and is not warranted.

Additionally, please see Response 9. 15 and 9.16 for a discussion of the detailed construction HRA prepared as part of the FEIR, which utilizes the appropriate AERMOD modeling software (the same model used in the DEIR for the operational HRA). As concluded in Response 9.15 and

9.16, based on the screening- level construction HRA calculations, the m aximum estimated risk would be 1.99 in one million which is less than the applicable threshold of 10 in one million. As such, no significant impact would occur and the DEIR finding of less than significant health risks is appropriate.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 9.19:

The comment claims that the quantitative GHG analysis is unsubstantiated for the reasons discussed in the previous comments. Refer to responses 9.2 through 9.18. As presented in the revised Air Quality Analysis and GHG Analysis, the recalculated criteria pollutant and GHG emissions associated with construction and operation of the project would be less than all applicable thresholds. Construction and operational criteria pollutant emissions would be less than the SCAQMD thresholds for ROG, NO X, CO, SO X, PM10, and PM 2.5, and GHG emissions would total 7,587 MT CO2E which would be less than the SCAQMD screening threshold of 10,000 MT CO2E. Thus, as concluded in the DEIR and the underlying technical studies, air quality and GHG impacts would be less than significant.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of t he DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.20:

The comment incorrectly claims that the GHG analysis is inadequate because the DEIR does not provide substantial evidence of consistency with the Riverside Restorative Growthprint Climate Action Plan ( RRG-CAP) emissions reduction target of 49 percent emission reduction from the Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-396
2007 baseline. The DEIR and underlying technical study correctly rely on SCAQMD’s recommendation, as documented in their September 2010 meeting minutes, to use 10,000 MT CO2E as an appropriate threshold to determine if additional analysis is warranted.

Based on the supporting analysis outlined in SCAQMD’s draft GHG guidance and meeting notes, this screening level would capture 90 percent of GHG emissions from new industrial projects in the region. This type of market capture analysis captures a substantial fraction of the emissions from future development to accommodate for future population and job growth and excludes small development projects that would contribute a relatively small fraction of the cumulative statewide GHG emissions. The City relies on use this threshold because it has been recommended by SCAQMD and SCAQMD is the expert agency and regional authority for air quality in the South Coast Air Basin. Further, the Interim Thresholds document provides substantial evidence that the thresholds are consistent with the policy goals and GHG reduction targets set by the State.

Specifically, the thresholds were set at levels that capture 90 percent of the GHG emissions from the above-described uses, consistent with the Executive Order S-3- 05 target of reducing GHGs to 80 percent below 1990 levels by 2050.

There is no requirement to analyze the Project in relation to the presented 49 percent emission reduction from the 2007 baseline identified by the commenter. The DEIR and underlying technical study correctly utilize the SCAQMD-recommended 10,000 MT CO2E per year numeric threshold.

This threshold is based on the concept of establishing a 90 percent GHG emission capture rate.

The market capture rate is based on guidance from the California Air Pollution Control Officers Association (CAPCOA) report CEQA & Climate Change, dated January 2008, which identifies several pot ential approaches for assessing a project’s GHG emissions (CAPCOA 2008) 14.

Following the market capture rate approach, a lead agency defines an acceptable capture rate and identifies the corresponding emissions level. Following rationale presented in the C APCOA Guidance, the aggregate emissions from all projects with individual annual emissions that are equal to or less than the identified market capture rate would not impede achievement of the state GHG emissions reduction targets codified by AB 32 (2006) and SB 32 (2016) and impacts under CEQA would therefore be less than cumulatively considerable. Further, as identified in Section

3.2.3.3 of the GHG Analysis, the RRG -CAP provides a roadmap for the City to achieve GHG emission reductions through 2035 in li ne with State GHG reduction goals. Since the SCAQMD screening thresholds are consistent with the policy goals and GHG reduction targets set by the State, the Project in turn would also be consistent with the reduction goals identified in the RRG- CAP. As such, the analysis in the DEIR and underlying technical studies is correct and no changes are needed.

14 California Air Pollution Control Officers Association (CAPCOA). 2008. CEQA & Climate Change, Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, January.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-397
Response 9.21:

The comment claims that the Project cannot be found to be consistent with the 2017 Scoping Plan because it is not evaluated against a performance based VMT per capita threshold.

For the purposes of the GHG analysis, there is no requirement to use the presented VMT per capita threshold identified by the commenter. The DEIR and underlying technical study correctly utilize the SCAQMD-recommended 10,000 MT CO2E per year numeric threshold for determining significance, as outlined in detail in Response 9.20 above.

Therefore, this comment does not affect the analysis completed or conclu sions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR . This comment is noted for the record and no changes to the DEIR are required.

Response 9.22:

The commenter states that as SWAPE’s analysis demonstrates potentially significant air quality, health risk, and GHG impacts, SWAPE has recommended feasible mitigation measures.

As summarized in the DEIR and underlying technical studies, the Project would not result in a significant air quality or greenhouse gas impact. As such, there is no nexus to require additional mitigation and no additional mitigation is required. The commenter’s claims that the DEIR fails to disclose impacts has been refuted in Responses 9.2 through 9.21; please refer to these responses for discussions on how the Project would not result in the types of impacts alleged by the commenter. However, the Project is already incorporating the following mitigation measures listed by the commenter:
• The Project will install conduit for vehicle charging stations. • The Project will provide a total of 39 electric vehicle (EV) parking stalls to encourage the use of low or zero-emission vehicles.
• The Project will provide a total of 13 clean air/van pool parking stalls to support and encourage ridesharing.
• Material handling equipment will be electric or propane powered. • The Project will provide short term and/or long- term bicycle parking accommodations in accordance with the California Green Buildings Standards Code Sections 5.710.6.2.1 to promote the use of bicycles.
• The Project will require building operators (by contract specifications) to turn off equipment, including heavy -duty equipment, motor vehicles, and portable equi pment when not in use for more than five minutes. Truck idling shall not exceed five minutes in time. All facilities will post signs requiring that trucks shall not be left idling for more than five minutes pursuant to Title 13 of the California Code of Regulations, Section 2485, which limits idle times to not more than five minutes.
• During grading, heavy -duty construction equipment (i.e., excavators, graders, scrapers, dozers, tractor/loader/backhoes, etc.) shall be California Air Resources Board (CARB)/US Environmental Protection Agency (US EPA) Tier 3 certified. All construction equipment is subject to the CARB In -USE Off-Road Diesel-Fueled Fleets Regulation. This regulation, which applies to all off-road diesel vehicles 25 horsepower or greater, limits unnecessary idling to 5 minutes, requires all construction fleets to be labeled and reported to CARB, Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-398
bans Tier 0 equipment and phases out Tier 1 and 2 equipment (thereby replacing fleets with cleaner equipment), and requires that fleets comply with Best Av ailable Control Technology requirements.

Although not required, the following mitigation measures listed by the commenter will be incorporated and added to the EIR and Mitigation Monitoring and Reporting Program (MMRP):

MM AIR-2: The Project applicant shall provide electrical hook ups to the power grid, rather than use of diesel -fueled generators, for electric construction tools, such as saws, drills and compressors and use of electric tools whenever feasible.

MM AIR-3: The Project applicant shall p rovide information on transit and ridesharing programs and services to construction employees.

MM AIR-5: The Project applicant shall post signs at every truck exit driveway providing directional information to the truck route.

MM AIR-6: The Project applicant shall provide tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 9.23:

The commenter states that SWAPE retains the right to revise or amend their report when additional information becomes available. This comment does not relate to the adequacy or content of the DEIR, does not provide new information or evidence related to the analysis in the DEIR, and does not affect the analysis completed or conclusions provided in the DEIR. This comment is noted for the record and revisions to the DEIR are not required.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-399
Comment Letter 10 – Riverside County Flood Control and Water Conservation District Comment letter 10 commences on the next page.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-400

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-401

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-402

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-403

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-404

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-405
Letter 10 – Riverside County Flood Control and Water Conservation District Commenter: Deborah de Chambeau
Date: July 22, 2021
Response 10.1: The commenter indicates that the project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed.

Response 10.2:

The commenter indicates that the District’s previous comments are still valid (in the attached letter dated August 20, 2020). The responses to the August comment letter are outlined below in Responses 10.6 through 10.9.

Response 10.3:

The commenter indicates that this project may require a National Pollutant Discharge Elimination System (NPDES) permit from the State Water Resources Control Board (SWRCB). Clearance for grading, recordation, or other final approval should not be given until the City has determined that the project has been granted a permit or is shown to be exempt. The Project does require and will obtain an NPDES permit from the SWRCB.

Response 10.4:

The commenter indicates that if this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the City should require the applicant to provide all studies, calculations, plans, and other information needed to meet FEMA requirements, and should further require that the applicant obtain a Conditional Letter of Map Revision (CLOMR) prior to grading recordation, or other final approval of the project and a letter of Map Revision (LOMR) prior to occupancy. The Project is not located within a FEMA mapped floodplain and a CLOMR or LOMR are not required.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-406
Response 10.5:

The commenter indicates that if a natural watercourse or mapped floodplain is impacted by this project, the City should require the applicant to obtain a Section 1602 Agreement from the California Department of Fish and Wildlife (CDFW) and a Clean Water Act (CWA) Section 404 Permit from the U.S. Army Corps of Engineers (USACE or Corps) , or written correspondence from these agencies indicating the project is exempt from these requirements. A CWA Section 401 Water Quality Certification may be required from the local California Regional Water Quality Control Board (RWQCB or Waterboards) prior to issuance of the Corps 404 permit. The Project will result in impacts to natural watercourses and will need to obtain a Section 404 permit from USACE, Section 401 Certification from the RWQCB, and a Streambed Alteration Agreement from CDFW, as outlined in the DEIR, Section 5.3 Biological Resources, page 5.3-35.

Response 10.6:

The commenter indicates that the project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed. This comment is the same as 10.1.

Response 10.7:

The project will have to obtain coverage under the NPDES general Construction permit prior to grading permit issuance by the City. This comment is the same as 10.3. The Project does require and will obtain an NPDES permit from the SWRCB.

Response 10.8:

The project site is not located within mapped floodplain and will not require a CLOMR or LOMR.

This comment is the same as 10.4. The Project is not located within a FEMA mapped floodplain and a CLOMR or LOMR are not required.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-407
Response 10.9:

The project requires a CDFW Section 1602 Lake or Streambed Alteration Agreement, USACE Section 404 permit, and CA Waterboards 401 Water Quality Certification. All said permits have been applied for and must be obtained prior to City issuing the grading permit . This comment is the same as 10.5. The Project will result in impacts to natural watercourses and will need to obtain a Section 404 permit from USACE, Section 401 Certification from the RWQCB, and a Streambed Alteration Agreement from CDFW, as outlined in the DEIR, Section 5.3 Biological Resources, page 5.3-35.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-408
Comment Letter 11 – Friends of Riverside’s Hills
Comment letter 11 commences on the next page.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-409

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-410

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-411

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-412

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-413

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-414

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-415

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-416

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-417

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-418

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-419

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-420

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-421

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-422

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-423

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-424

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-425

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-426
Letter 11 – Friends of Riverside’s Hills
Commenter: Leonard Nunney
Date: July 22, 2021
Response 11.1:

This comment provides the commenter’s opinion regarding the sensitivity of the site and generally summarizes the uses surrounding the Project site. The commenter states that the project site is in a very environmentally sensitive area at the southern edge of the Sycamore Canyon Wilderness Park (SWCP) a park of approximately 1500 acres, and this natural open space is a critical component in the conservation of biodiversity in Western Riverside County and is a core area within the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP). The commenter also opines that the project site is important to the enjoyment of natural open space by residents of the area and visitors. The commenter states he is a professor at the University of California Riverside and focuses his research concerns on the ability of small populations to avoid extinction. He then states the number of scientific papers he has peer reviewed. The commenter is also part of the Scientific Advisory Panel that was involved in the establishment of the MSHCP.

The DEIR clearly identifies that the Project site is located “immediately adjacent to the Sycamore Canyon Wilderness Park which is designated as Public Quasi Public ( PQP) lands and Existing Core D of the MSHCP conservation area, as illustrated in Figure 5.3-6 – Riverside County MSHCP Conserved Lands. The Sycamore Canyon Wilderness Park is also designated as part of the Sycamore Canyon-March Air Force Base (AFB) Core Reserve of the SKRHCP.” (DEIR, p. 5.3- 28)
The Project site is private property and not a part of the Sycamore Canyon Wilderness Park, which is open to the public. As such, the Project site is not for public use. Nonetheless, the applicant is providing a trailhead parking lot that is not required but being provided as an amenity to park users, thereby adding to the area and making enjoyment of the natural open space of the park more accessible to the public .. In addition, 12.23 acres of the site will be designated as a conservation area, to preserve the existing natural drainage course and riparian vegetation also contributes to the overall open space in the area and adjacent to the Sycamore Canyon Wilderness Park.

This comment is introductory and does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR are not required.

Response 11.2:

The commenter claims that the DEIR failed to consider the significant impact on the many individuals using the adjoining natural SCWP, without specifying what those significant impacts would be or providing substantial evidence to support the claim. The commenter states the project does incorporate a feature to mitigate this effect: a 42-inch cable fence with an inner fire-resistant boundary of locally native trees, and that because this mitigation is req uired in perpet uity, it i s important that a mitigation measure be added that requires the cable fencing and vegetation be City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-427
maintained into the future, and that any trees or plants that die are replaced with similar locally native trees or plants.

Section 5.1 Aesthetics of the DEIR included a thorough and detailed evaluation of the potential aesthetic impacts of the Project, including impacts to views of SCWP users as follows (DEIR, pp.

5.1-19 – 5.1-20):

Public views are those that are experienced from publicly accessible vantage point. Public views of Building A on Parcel 1 will be from two publicly accessible vantage points:

Alessandro Boulevard to the south and from trails within the Sycamore Canyon Wilderness Park to the north. As shown in Figure 5.1-2 – Elevation Rendering View A, the public view of Building A from Alessandro Boulevard is softened by the 520-foot setback, landscaping, natural vegetation within the restrictive property/conservation area, and the natural and earth-toned color palette. The Project’s landscaping will also partially screen the north elevation of Building A. The view from Sycamore Canyon Wilderness Park south towards Building A on Parcel 1 is shown in Figure 5.1 -3 – Elevation Rendering View B.

Building A will be screened on this side by the Project’s landscaping, including the water quality basin, and the view is softened by the 40- foot set-back of the building from the property line.

Public views of Building B on Parcel 2 will be from two publicly accessible vantage points:

Barton Street to the west and from trails within the Sycamore Canyon Wilderness Park to the north. As shown in Figure 5.1-4 – Elevation Rendering View C, the trailhead parking lot and amenities serve as an additional setback between the northern property line with the park and Buildi ng B. Building B will be located between 6020- 182 feet from the northerly property line of Parcel 2, and 90 feet from the northerly property line of the trailhead parking lot. The trailhead parking lot will largely be decomposed granite, with landscaping and amenities that are complementary to the adjacent Wilderness Park. The Project’s enhanced landscaping will also partially screen Building B and its parking areas from Barton Street, as shown in Figure 5.1-5 – Elevation Rendering View D.

With the natural and earth-toned color palette, the articulation of the building facades, the screen walls for the loading dock areas, and the enhanced landscaping, the Project will not substantially degrade the existing visual character or quality of public views of the site and its surroundings . The restricted property/conservation area with existing mature vegetation and the required 20- foot landscape setback at the front of Building A will preserve the existing character of the site along the frontage of Building A and between Buildings A and B. A landscaped buffer will be located along the northern side of Building A and an 8-foot high concrete wall along the northern and eastern sides of Building A to screen the building from the Sycamore Canyon Wilderness Park. Building B will have a 20-foot landscape setback on the western side, along Barton Street. There will also be an 8-foot high tubular metal fence and enhanced landscaping along the western side of Building B to screen the building from Barton Street. An 8-foot high combination screening fence/wall, consisting of a 4-foot high tubular metal fence on top of a 4-foot high screen wall and landscaping with shrubs and trees , will be located along the northerly property line adjacent to the trailhead parking lot to screen Building B from the Sycamore Canyon Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-428
Wilderness Park. The trailhead parking lot will also provide a buffer and setback between Building B and the Sycamore Canyon Wilderness Park.

Further, the Building B will be set back between 90 and 190 feet from the Sycamore Canyon Wilderness Park property line. And the landscape buffer between the Sycamore Canyon Wilderness Park property line and the 8-foot screen wall for Building A ranges in depth between 40 to 95 feet.

Therefore, the DEIR did consider and evaluate the views from the SCWP to the Project, and with implementation of the extensive design considerations incorporated into the Project to ensure aesthetic impacts are minimized, potential impacts were f ound to be less than significant. The DEIR includes Figure 5.1-1, an Elevation Renderings Key Map that identifies views from four different locations open to the public, and corresponding renderings, which reflect the extensive design considerations (including set -backs, trailhead parking lot, landscaping, screening, elevations, color palette, etc.), to show what the Project will look like in the future from these public vantage points, as Figure 5.1- 2 Elevation Rendering View A, Figure 5.1- 3 Elevation Rendering View B, Figure 5.1-4 Elevation Rendering View C, and Figure, 5.1-5 Elevation Rendering View D.

Therefore, the DEIR contains substantial evidence to support the conclusion of less than significant without mitigation.

The City will require, as a standard Condition of Approval, that all landscaping, including fencing, be maintained, including replacement of any dead trees or plants, in perpetuity by the Property Owner. The proposed landscaping is native and will be sourced locally, to the greatest extent feasible.

Response 11.3:

The commenter states that while the DEIR Section 5.2 Air Quality states that vehicle/construction vehicle/equipment idling will be limited to five (5) minutes, the idling limitation should be made into an enforceable mitigation measure.

It is stated throughout DEIR Section 5.2 Air Quality as well as the Project’s Air Quality Analysis contained in DEIR Appendix C that limiting idling to five (5) minutes is a requirement (responder emphasis added) per applicable State regulations. Per DEIR p. 5.2-23, The Project will require building operators (by contract specifications) to turn off equipment, including heavy-duty equipment, motor vehicles, and portable equipment when not in use for more than five minutes. Truck idling shall not exceed five minutes in time. All facilities will post signs requiring that trucks shall not be left idling for more than five minutes pursuant to Title 13 of the California Code of Regulations, Section 2485, which limits idle times to not more than five minutes.

Thus, while idling limitations are not specifically included as a mitigation measure, limits on idling times would still made known to drivers by readily visible signage on both buildings in the dock City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-429
door areas and be enforced as a requirement via contract specifications. Idling limitations cannot be ignored in the future, as the limitation is codified in Section 2485 of the California Code of Regulations. As outlined in Response 9.22 above, the following mitigation measure has been added to help ensure compliance:

MM AIR-4: The Project applicant shall post both interior and exterior facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to the California Air Resources Board (CARB), the South Coast Air Quality Management District (AQMD), and the building manager. Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. No change to the DEIR is necessary.

Response 11.4:

The commenter states that mitigation measure MM BIO-1 does not provide adequate mitigation as it relates to on-site seed collection or retention of topsoil regarding the paniculate tarplant and Robinson’s pepper-grass. The commenter goes on to state that if seeds have not yet been collected, the seeds would need to be collected during the appropriate seeding season for these plants in the next, reasonably good rainfall year. Lastly, the commenter states the options of seed collection or using stored topsoil provide no guarantee of success.

As discussed on DEIR p. 5.3 -28, while the Project site contains suitable habitat for Robinson’s pepper-grass, this species has not been observed on site and is not known to occur on site. Per the Biological Resources and Western Riverside County Multiple Species Habitat Conservation Plan Consistency Report (DEIR Appendix D), page 9, biologists hav e visited the site numerous times to conduct various surveys as well as updates to those surveys between 2014 and 2019, over a 5-year period. Further, DEIR p. 5.3-28 additionally discusses that, “impacts from the Project on paniculate tarplant are not expected to be significant as it [potential Project impacts] is not expected to substantially reduce habitat for this species throughout its range.” Nonetheless, DEIR p. 5.3-28 states, “To further reduce impacts to this species [paniculate tarplant], MM BIO-1 will be implemented, which will require a qualified biologist collect seed for paniculate tarplant and Robinson’s pepper-grass throughout the proposed development footprint of the Project.” Thus, as Robinson’s pepper-grass has not been observed on site and is not known to occur on site, and as potential impacts to paniculate tarplant are not expected to substantially reduce habitat for the species throughout its range, implementation of MM BIO-1 does provide adequate mitigation in terms of putting forth additional efforts to ensure potential impacts to these species are further reduced. MM BIO-1 was drafted such that if the seed cannot be appropriately collected before grading, either because it is not during the blooming season or it is during a drought season, that the seed bank contained in the topsoil would be an alternative method for capturing appropriate seeds.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-430
Response 11.5:

The commenter states that mitigation measure MM NOI -1 fails to require the identification of nesting activity and that the appropriate mitigation strategy is to plan the construction outside of the time window of nesting activity (‘mid-March to the end of August’). While MM NOI-1 does not specifically require the identification of nesting activity, it is because this mitigation measure is specific to potential noise impacts to biological species and would be implemented in addition (responder emphasis added) to all mitigation measures specific to biological resources, including MM BIO-9, which covers nesting bird protections. Per MM BIO-9 on DEIR pp. 5.3-53 to 5.3-54:

Although nesting can occur in any month in southern California for some species, breeding in the study area, given the habitat, would primarily be expected from about 1 February through 31 August. Work from about 1 September through 31 January would avoid most negative affects to birds and nesting activity. If work must be done during the breeding season, surveys for nesting birds should occur no more than three (3) days prior to all vegetation clearing and ground disturbance. If active nests are found, they should be avoided until young have fledged. While there is no established protocol for nest avoidance, when consulted the CDFW generally recommends avoidance buffers of about 500 feet for raptors and threatened/endangered species and 100 – 300 feet for non-raptors. Adherence to these nesting bird recommendations will also avoid and/or mitigate i mpacts to special status bird species known from the project site which are not covered by the MSHCP.

As shown in the excerpt from MM BIO-9 above, implementation of this mitigation measure would account for the commenter’s concerns as the mitigation measur e does acknowledge that conducting work outside of the nesting season would avoid most potential impacts to birds and nesting. Further, the mitigation measure requires that nesting bird surveys occur prior to all vegetation and ground disturbance should work need to be conducted during the nesting season.

Therefore, the commenter’s statement that MM NOI-1 fails to require the identification of nesting activity is only valid in that the identification of nesting behavior is covered under MM BIO-9, which would be implemented in addition to the requirements of MM NOI-1.

In addition, t he noise mitigation measure MM NOI -1 was included in the Riparian Riverine Determination of Biologically Equivalent or Superior Preservation ( DBESP) report that was reviewed by the USFWS and CDFW, the federal and state agencies responsible for protecting endangered species, as well as reviewing for consistency with the MSHCP. USFWS and CDFW reviewed and approved this mitigation measure as part of the DBESP report.

Thus, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. No change to the DEIR is necessary.

Response 11.6:

The commenter states that regarding Thresholds B and C of DEIR Section 5.3 Biological Resources (thresholds listed on DEIR p. 5.3- 27), the mitigation measures do not address “the continuing potential impacts to the riparian habitat within and near to the Project site” outside of Project construction. However, the commenter fails to identify what these “continuing potential City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-431
impacts” are. Further, the commenter is incorrect in asserting continuing potential impacts in that the DEIR includes language indicating riparian/riverine resources would be enhanc ed and conserved in perpetuity. DEIR p. 5.3-35 states, “The DBESP determined that the riparian/riverine resources proposed to be enhanced and conserved in perpetuity would provide a biologically superior riparian habitat for riparian species.” Moreover, condition 6 of MM BIO-6 states:

Prior to issuance of occupancy permit, in order to reduce impacts to on-site Riparian/Riverine areas and suitable habitat for LBVI, on site mitigation shall include:

6. Revise the existing Restricted Property to include Parcel A (7.19 acres) and Parcel B (5.04 acres), with a combined area of 12.23 acres. The revised 12.23 Restricted Property shall be managed in perpetuity with an endowment funded by the developer and by a CDFW approved 3rd party (such as Rivers and Lands Conservancy “RLC”).

As seen in these excerpts from the DEIR, the riparian/riverine resources would be managed in perpetuity (responder emphasis added) , which would account for any f uture or “continued” potential impacts the commenter has failed to identify.

Response 11.7:

The commenter inaccurately states that most of the biological mitigation measures primarily address construction- related issues and “av oids impacts that can occur after construction.” Regarding the commenter’s statements concerning light intrusion both during construction and beyond, both mitigation measures MM AES-1 and MM AES-2 as referenced in DEIR Table 5.3-3 – Project Compliance with MSHCP Urban/Wildlands Interface Guidelines (DEIR p. 5.3-43) include language that indicates potential post -construction/operational lighting issues would be addressed and mitigated for. The description of MM AES-1 on DEIR p. 5.3-43 describes how the completed (responder emphasis added) warehouse buildings would have nighttime lighting that would be shielded downwards. There would be zero penetration of light beyond the property line and all lighting would have motion detectors and automatically shut off when there is no one at the site. The screening wall on the northerly property line of Parcel 2 will block any vehicle lights from Building B. Additionally , the description of MM AES-2 on DEIR p. 5.3 -43 states that the trailhead parking lot would have an entrance gate to control access from dusk to dawn, which would prevent vehicle lights from the trailhead parking lot from shining into the Sycamore Canyon Wilderness Park (SCWP). Therefore, contrary to the commenter’s comments, the DEIR does provide mitigation measures that address potential issues after construction of the Project has been completed.

The commenter further states that a condition should be added to MM BIO-11 that material used in revegetation should be collected from within SCWP or within the local ecoregion . As the commenter states (contained in comment 11.1 ), the SCWP is a very environmentally sensitive area, and is a core area within the MSHCP. Seed collection from within this environmentally sensitive area should only be done if it can be without detrimental effects to the existing habitat Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-432
and would not conflict with the Sycamore Canyon Wilderness Park Stephens’ Kangaroo Rat Management Plan and Updated Conceptual Development Plan (SCWP SKRMP).

As outlined in the DEIR the project, including design features and mitigation, was found in compliance with the MSHCP by both the City of Riverside and the USFWS and CDFW, including avoidance of plant species in the plant palette of landscaping and revegetation/restoration plans for proj ects located next to or near conservation areas . Therefore, the Project has been determined to meet the requirement of the MSHCP for being located adjacent to a conservation area. In addition , the applicant is coordinating with Dr. Arlee Mon talvo to further modify the proposed plant palette to make the requested removals and replacements in accordance with her recommendations, which is above and beyond the requirements for compliance with the MSHCP and what is required to accomplish less than significant impacts to biological resources.

Response 11.8:

The commenter states that while the DEIR states that Project buildings would have solar ready roofs that will structurally accommodate later installation of rooftop solar panels, the DEIR does not include an enforceable mitigation measure that ensures solar panels would be installed. As stated throughout DEIR Section 5.5 Energy, the Project will be required to comply with all applicable California Green Building Code Title 24 standards. Per Section 110.10 of the California Energy Code . It is a mandatory requirement (responder emphasis added) for nonresidential buildings such as the Project to comply with the Code’s solar zone requirements for nonresidential buildings. Accordingly, as the commenter has referenced, the DEIR states that , “building operators providing rooftop solar panels will submit plans for solar panels prior to occupancy ” (DEIR p. 5.5-16) in compliance with these requirements. Therefore, contrary to the commenter’s comment, it is not necessary to include a mitigation measure for the installation of solar panels as this is already a mandatory requirement for compliance with applicable Title 24 standards.

Response 11.9:

The commenter states that the commenter has a long- term concern regarding nighttime noise and vibration levels around the western and north -eastern loading bays of Building A and recommends mitigation.

Vibration impacts are analyzed in Section 5.4 of DEIR Appendix K, Noise Analysis. As discussed, ground-borne vibration levels due to construction activities would be 0.031 peak particle velocity (PPV) at the self-storage facility and 0.002 PPV at the nearest residential use, and ground-borne vibration levels due to operation (i.e., trucks) would be 0.027 PPV at the self-storage facility and

0.002 PPV at the nearest residential use. These vibration levels would not exceed the significance threshold of 0.2 PPV. In regard to burrowing animals, the effects associated with truck vibration City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-433
on them would be speculative. Nonetheless, the on-site travel lane is located as close as 25 feet from the Project boundary. Where the travel lane is at its closest point to the property line on the western side, it is only for a length of approximately 150- 160 feet. Trucks generate a vibration level of 0.076 PPV at 25 feet; thus, vibration levels at the Project boundary would not exceed 0.2 PPV. The remainder of the travel lane in the western, northwestern, and north -eastern parts of Parcel 1/Building A, at its closest point to the property line with Sycamore Hills Wilderness Park, ranges from approximately 80-115 feet. As vibration attenuates with distance, potential vibrations from trucks within these other areas of the site closest to the park would be even further reduced.

The comment also suggests possible mitigation measures including reducing the sound of backup warnings during the nighttime hours or prohibiting nighttime u se for a few hours. The noise associated with nighttime activities, including backup warnings, was calculated at the adjacent uses. As summarized in Table 11 of the Noise Analysis, nighttime noise levels would not exceed 45 dB(A) Leq at the on-site conservation areas or the Sycamore Canyon Wilderness Park. Noise associated with on- site activities and backup warnings would be less than significant. Further, reducing the sound or eliminating backup warning signals would be a safety hazard, particularly during the nighttime hours.

Response 11.10: The commenter provides recommended deletions and additions to the landscape plans plant palette.

As outlined in the DEIR the project , including design features and mitigation, was found in compliance with the MSHCP by both the City of Riverside and the USFWS and CDFW, including avoidance of plant species in the plant palette of landscaping and revegetation/restoration plans for projects located next to or near conservation areas. Therefore, the Project has been determined to meet the requirement of the MSHCP for being located adjacent to a conservation area. In addition, the applicant is coordinating with Dr. Arlee Mon talvo to further modify the proposed plant palette to make the requested removals and replacements in accordance with her recommendations, which is above and beyond the requirements for compliance with the MSHCP and what is required to accomplish less than significant impacts to biological resources.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-434
Comment Letter 12 – California Air Resources Board
Comment letter 12 commences on the next page.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-435

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-436

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-437

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-438

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-439

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-440

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-441

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-442

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-443

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-444

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-445

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-446

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-447

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-448

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-449

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-450
Letter 12 – California Air Resources Board
Commenter: Robert Krieger
Date: July 23, 2021
Response 12.1:

The commenter provides a summary of the Project Description information. The commenter also indicates CARB submitted a comment letter on the Notice of Preparation for the Project (attached) that highlighted the need for preparing a health risk asse ssment (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 and nitrogen oxides emissions for all neighboring communities, and to minimize the greenhouse gases that contribute to climate change.

A Health Risk Assessment was prepared for the project and is contained in Appendix C to the DEIR and discusses the Project’s potential impacts regarding DPM emissions, cancer risk, non- carcinogenic risk, residential exposure, worker exposure, and school children exposure. Because construction and operational activity would not result in an exceedance of the SCAQMD’s DPM cancer risk exposure threshold of 10 in one million, or non-cancer risk threshold of 1.0, sensitive receptors would not be exposed to substantial DPM pollutant concentrations during Project construction or operation, and impacts would be less than significant with Mitigation Measure MM AIR-1. (DEIR, pp. 5.2-33 – 5.2-35.) As summarized in the DEIR and underlying technical studies, the Project would not result in a significant air quality or health risk impact from exposure to nitrogen oxides or diesel particulate matter emissions. As such, there is no obligation under CEQA to further reduce potential impacts via mitigation and no mitigation is required, as further detailed in Responses 9.2 through 9.21.

As outlined in Response 7.10 above, e nvironmental justice is not an environmental impact required to be evaluated or considered purs uant to CEQA, per CEQA Guidelines Article 9.

Contents of Environmental Impact Reports, Sections 15120 to 15132. Nonetheless, the air quality analysis contained in the DEIR demonstrates the Project would not result in environmental justice issues (disproportionate impacts to disadvantaged communities) as further outlined below.

The air quality analysis prepared for the Project provides an assessment of potential cumulative air quality impacts. The SCAQMD shares the responsibility with California Air Resources Board (CARB) for ensuring that all federal and state ambient air quality standards are achieved and maintained throughout the air basin. The SCAQMD has developed methodologies and thresholds of significance that are widely used throughout the air basin. SCAQMD staff has suggested in the cumulative significance methodologies contained in the CEQA Air Quality Handbook that the emissions-based thresholds be used to determine if a project’s contribution to regional cumulative emissions is cumulatively considerable. These thresholds were used in the Air Quality Analysis to assess the significance of the Project -specific and cumulative air quality impacts. Air quality impacts are basin-wide, and air quality is affected by all pollutant sources in the basin. Therefore, the ambient air quality measurements provided in the Air Quality Analysis provide a summary of basin-wide cumulative air quality impacts. As the individual Project thresholds are designed to help achieve attainment with cumulative basin- wide standards, they are also appropriate for City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-451
assessing the Project’s contribution to cumulative impacts. As shown in Tables 7 and 9 of the Air Quality Analysis (Appendix C to the DEIR) and corresponding Tables 5.2-7 and 5.2-8 of the DEIR (pp. 5.2-26, 5.2-32), construction and operational emissions would be less than the applicable project-level thresholds. Additionally, the project would be consistent with the growth projections used to develop the AQMP and would therefore not conflict with implementation of the AQMP or applicable portions of the State Implementation Plan (SIP). As such, air quality impacts would be less than significant.

On DEIR pp. 5.2-31 to 5.2-32, in response to Threshold C, which questions whether the Project would expose sensitive receptors to substantial pollutant concentrations, the DEIR describes the localized significance threshold (LST) anal ysis utilized in determining these potential impacts.

DEIR pp. 5.2-31 to 5.2-32 state that, “LSTs were developed in response to environmental justice and health concerns raised by the public regarding exposure of individuals to criteria pollutants in local communities.” These pages of the DEIR further state that, “the Project was analyzed for its potential to result in significant health risk impacts resulting from short-term construction and long- term operational emissions” and that it was determined, “the Project would not exceed the SCAQMD LSTs during construction and operational activities.” Thus, the DEIR does include analysis relevant to environmental justice issues as the LSTs utilized in determining potential impacts to sensitive receptors were developed in response to environmental justice concerns and the Project HRA assesses potential Project -related health risks to residents, workers, and school children.

Further, as stated on DEIR p. 5.2- 37 under Cumulative Environmental Effects, “SCAQMD considers the thresholds for project -specific impacts and cumulative impacts to be the same.

Therefore, projects that exceed project -specific significance thresholds are considered by SCAQMD to be cumulatively considerable.” DEIR p. 5.2-37 goes on to state, “in terms of localized air quality impacts, construction and operation of the Project would not have a cumulatively considerable impact due to criteria pollutant emission.” Therefore, as the Project was determined not to exceed any of the emissions signifi cance thresholds, including localized significance thresholds, and would accordingly not result in cumulatively significant air quality impacts, the Project would not result in significant impacts regarding the environmental justice issues stated by the commenter.

Response 12.2:

The commenter claims that the DEIR modeled the Project’s air pollutant emissions using mobile emission factors obtained from CARB’s 2014 Emission Factors model (EMFAC 2014) despite updates to the EMFAC model , including diesel particulate matter emission factors for diesel heavy-duty trucks. The commenter states that EMFAC 2014 underestimated diesel PM (DPM) emission rates from diesel heavy-duty trucks and thus the Project’s mobile source DPM emissions Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-452
are likely underestimated in the DEIR. The commenter goes on to recommend the use of EMFAC2021, which was released in January 2021.

The Mobile Source Health Risk Assessment (HRA, Appendix C) was prepared in July 2020 prior to the release of EMFAC 2021. The Mobile Source HRA “evaluates the potential mobile source health risk impacts to sensitive receptors (residents) and adjacent workers associated with the development of the Project, more specifically, health risk impacts (cancer and non- cancer risks) as a result of exposure to diesel Particulate matter (DPM) as a result of heavy-duty diesel trucks accessing the site.” (HRA, p. 1) The Mobile Source HRA did in fact utilize EMFAC 2017, per Section 3.1 On-site and Off-Site Truck Activity, page 8, Vehicle DPM emissions were estimated using emission factors for particulate matter less than 10 micrometer (um) in diameter (PM10) generated with the 2017 version of the Emissions FACtor model (EMFAC) developed by the CARB. EMFAC 2017 is a mathematical model that was developed to calculate emission rates from motor vehicles that operate on highways, freeways, and local roads in California and is commonly used by the CARB to project change in future emissions from on-road mobile sources (4). The most recent version of this model, EMFAC 2017, incorporates regional motor vehicle data, information and estimates regarding the distribution of vehicle miles traveled (VMT) by speed, and number of starts per day.

Therefore, the Mobile Source HRA prepared for the Project to evaluate health risk impacts from heavy-duty diesel trucks utilized the appropriate mobile emission factors using EMFAC 2017, as recommended by the commenter, and did not underestimate diesel emissions.

Further, the Air Quality Analysis (Appendix C) also utilized EMFAC 2017 emission factors for the operational Localized Significance Thresholds (LST) calculations, as outlined below.

Per DEIR Appendix C – Air Quality Analysis p. 29:

Once operational, on-site sources of emissions associated with the project would be passenger cars arriving at and departing from the facility, and trucks maneuvering on- site and idling at the proposed loading docks. The site plan identifies 49 loading docks on the east side of Building A, 39 loading docks on the west side of Building A, and 34 loading docks on the south side of Building B. The project would also include the operation of up to three non-diesel yard trucks used to move freight around the warehouse. For the operational LST analysis, on-site passenger car and truck travel and idling emissions were modeled in the AERMOD dispersion model using emission factors for CO, NO2, PM10, and PM 2.5 generated by EMFAC2017. Therefore, the DEIR and its underlying technical studies utilized EMFAC 2017 mobile emission factors for diesel heavy -duty trucks, as recommended by the commenter, and did not underestimate DPM emissions.

Further, the notice of preparation (NOP) for the Project was published on July 28, 2020 prior to CARB’s release of the EMFAC2021 model update. Moreover, at present, EMFAC2021 is not yet approved for use by the U .S. EPA. The EMFAC2017 model is the currently approved model for use and was correctly utilized in the Project’s Mobile Source HRA and operational LST analysis.

As such, the analysis in the DEIR and underlying technical studies are correct and no changes are needed.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-453
Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 12.3:

The commenter states that the DEIR did not account for air pollutant emissions from heavy-duty trucks during on-site grading.

As stated in Section 6.1 of the Air Quality Analysis, “Dur ing the grading phase, soil quantities would be balanced on- site between the two building areas with no net import or export.” The modeling assumes that this soil hauling between Parcel 1 and Parcel 2 would be done with the modeled grading equipment, which includes graders and scrapers capable of moving large quantities of soil. To be conservative and account for the usage of trucks to haul soil from one parcel to the other, 40,000 cubic yards of soil hauling has been added to the grading phase with a trip length of one mile. The revised emissions are summarized in Tables 6 and 7 of the revised Air Quality Analysis and Table 7 of the revised GHG Analysis. Accordingly, corresponding DEIR Tables 5.2-6, 5.2-7, and 5.7- 7 have been revised as well (see revised tables under Response

7.8). All construction emissions would still be less than the applicable thresholds, and air quality and GHG impacts would be less than significant.

It should be noted that even with these revisions to the DEIR , no change to the signifi cance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis co mpleted in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 12.4: The commenter correctly indicates the DEIR states that the proposed Project would not include the operation of on- site cold storage uses and that the air pollutant emissions associated with cold storage operation were not included in the DEIR. CARB urges the City to include one of the following design measures in the FEIR: 1) contractual language in tenant lease agreements that prohibits tenants from operating TRUs within the project site or a condition of approval requiring a restrictive covenant over the parcel that prohibits the applicants use of TRUs on the property.

Mitigation Measure MM AIR -1 is revised accordingly, as requested by CARB, to include a restrictive covenant that also restricts the use of TRUs:

MM AIR-1: The project applicant is required to record a covenant on the property (Parcels 1 and 2) that prohibit manufacturing, fulfillment center, and use of Transportation Refrigeration Units (TRUs). Proof of the record of covenant shall be submitted to the City of Riverside Planning Department prior to issuance of Building Permits.

As summarized in the DEIR and underlying technical studies, the proposed Project that was analyzed (as defined in the Project Description of the DEIR ) was High-Cube Transload Short - Term Warehouse, and not fulfillment center warehouse or refrigerated warehouse and correlating use of TRUs on trucks. Therefore, the EIR and supporting technical studies do not evaluate or Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-454
cover other uses of the site, and if other uses are proposed or would be allowed on the site, that would require new air quality, greenhouse gas, and HRA modeling and analyses, as well as subsequent CEQA review and approval by the City.

Therefore, this comment does not affect the analysis completed or conclusions provided i n the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 12.5:

The commenter states that 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. Due to the Project’s proximity to residences and schools, the commenter is concerned with the potential cumulative health impacts. 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 on the NOP for the DEIR.

As summarized in the DEIR and underlying technical studies, the Project would not result in a significant air quality or health risk impact, including cumulative impacts . As such, there is no obligation under CEQA to further reduce potential impacts via mitigation and no mitigation is required. As outlined in Response 12.4 above, Mitigation Measure MM AIR -1 is revised accordingly, as requested by CARB, to include a restrictive covenant that also restricts the use of TRUs.

As outlined in Response 9.22 above, the Project is already incorporating the following:
• The Project will install conduit for vehicle charging stations. • The Project will provide a total of 39 electric vehicle (EV) parking stalls to encou rage the use of low or zero-emission vehicles.
• The Project will provide a total of 13 clean air/van pool parking stalls to support and encourage ridesharing.
• Material handling equipment will be electric or propane powered. • The Project will provide short t erm and/or long-term bicycle parking accommodations in accordance with the California Green Buildings Standards Code Sections 5.710.6.2.1 to promote the use of bicycles.
• The Project will require building operators (by contract specifications) to turn off equipment, including heavy -duty equipment, motor vehicles, and portable equipment when not in use for more than five minutes. Truck idling shall not exceed five minutes in time. All facilities will post signs requiring that trucks shall not be left idling f or more than five minutes pursuant to Title 13 of the California Code of Regulations, Section 2485, which limits idle times to not more than five minutes.
• During grading, heavy -duty construction equipment (i.e., excavators, graders, scrapers, dozers, tractor/loader/backhoes, etc.) shall be California Air Resources Board (CARB)/US Environmental Protection Agency (US EPA) Tier 3 certified. All construction equipment is subject to the CARB In -USE Off-Road Diesel-Fueled Fleets Regulation. This regulation, which applies to all off-road diesel vehicles 25 horsepower or greater, limits unnecessary idling to 5 minutes, requires all construction fleets to be labeled and reported to CARB, City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-455
bans Tier 0 equipment and phases out Tier 1 and 2 equipment (thereby replacing f leets with cleaner equipment), and requires that fleets comply with Best Available Control Technology requirements.

Although not required, the following mitigation measures are incorporated, added to the EIR and Mitigation Monitoring and Reporting Program (MMRP):

MM AIR-3: The Project applicant shall provide information on transit and ridesharing programs and services to construction employees.

MM AIR-5: The Project applicant shall post signs at every truck exit driveway providing directional information to the truck route.

MM AIR-6: The Project applicant shall provide tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

MM AIR-7: The Project applicant shall 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.

MM AIR-8: The Project applicant shall include contractual language in tenant lease agreements restricting trucks and support equipment from idling longer than 5 minutes while on site.

MM AIR-9: The Project applicant shall include contractual language in tenant lease agreements that prohibit cold storage operations unless a health risk assessment is conducted and the health impacts are mitigated, if found significant.

MM AIR-10: Include rooftop solar panels to the extent feasible, with a capacity to supply 15% of the entire Project’s electrical demand.

The design features and/or additional mitigation measures above partially accomplish the commenters Attachment A Recommended Construction Measures 1 and 2. Although not required, Mitigation measures MM AIR -7 through MM AIR-9 accomplish the commenters Attachment A Recommended Operations Measures 6, 9, and 10. Mitigation measure MM AIR-10 partially accomplishes the commenters Attachment A Operations Measure 11. As the Project does not include use of TRUs, the commenters Attachment A R ecommended Operation Measures 2, 3 and part of 4 are not applicable. The commenters Attachment A Recommended Operation Measures 12 includes installing vegetative walls or other effective barriers that separate loading docks and people living or working nearby, is also not applicable as the loading docks are not close to people living or working nearby. The closest existing residences and commercial uses are approximately 225 feet of the Project site boundary or parcel line, across Alessandro Boulevard. The Building A set back from Alessandro Boulevard is 520 feet and greater Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-456
for Building B, thus loading docks for Building A and B are set back from nearest residences by at least 745 feet or greater.

It should be noted that even with these revisions to the DEIR, no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or e vidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 12.6:

The commenter indicates that to fully understand the Project’s environmental impacts, the HRA should be revised using the latest version of EMFAC, EMCAC 2021. If heavy -duty trucks are required to import or export soils from the site during Project construction, the Project’s air quality analysis and HRA should be updated to reflect such activities. The commenter states the FEIR should include a design measure restricting the operation of TRUs and if the City should allow the warehouse buildings to be used for cold storage, the City should update the Project’s air quality analysis and HRA to account for these. The commenter also encourages the City to implement the measures listed in Attachment A to their comment letter.

For all the reasons set forth above in Responses to Comments 12.1 thro ugh 12.5, no new information of substantial importance has been added to the EIR, and no new significant environmental impacts or substantial increases in existing significance impacts exist. Accordingly, recirculation of the DEIR is not required. (State CEQA Guidelines 15088.5) Response 12.7:

The commenter indicates that the Project will expose nearby disadvantaged communities to elevated levels of air pollution. The commenter states that there are residences located approximately 350 feet south of the Project’s southern boundary and there are four schools and a daycare center within 2 miles of the Project . The commenter is concerned with the potential cumulative health impacts associated with the Project and that diesel PM emissions generated by the Projec t would negatively the community that is already impacted by air pollution from existing industrial facilities and vehicular traffic on Alessandro Boulevard and I-215.

The EIR did identify the nearby sensitive receptors and analyze DPM using the appropriate methodology and thresholds. A Health Risk Assessment was prepared for the project and is contained in Appendix C to the DEIR and discusses the Project’s potential impacts regarding DPM emissions, cancer risk, non- carcinogenic risk, residential exposure, worker exposure, and school children exposure. Because construction and operational activity would not result in an exceedance of the SCAQMD’s DPM cancer risk exposure threshold of 10 in one million, or non- cancer risk threshold of 1.0, sensitive receptor s would not be exposed to substantial DPM pollutant concentrations during Project construction or operation, and impacts would be less than significant with Mitigation Measure MM AIR-1. (DEIR, pp. 5.2-33 – 5.2-35.) On DEIR pp. 5.2-31 to 5.2-32, in response to Threshold C, which questions whether the Project would expose sensitive receptors to substantial pollutant concentrations, the DEIR describes the City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-457
localized significance threshold (LST) analysis utilized in deter mining these potential impacts.

DEIR pp. 5.2-31 to 5.2-32 state that, “LSTs were developed in response to environmental justice and health concerns raised by the public regarding exposure of individuals to criteria pollutants in local communities.” These pages of the DEIR further state that, “the Project was analyzed for its potential to result in significant health risk impacts resulting from short-term construction and long- term operational emissions” and that it was determined, “the Project would not exc eed the SCAQMD LSTs during construction and operational activities.” Thus, the DEIR does include analysis relevant to environmental justice issues as the LSTs utilized in determining potential impacts to sensitive receptors were developed in response to environmental justice concerns and the Project HRA assesses potential Project -related health risks to residents, workers, and school children.

Further, as stated on DEIR p. 5.2- 37 under Cumulative Environmental Effects, “SCAQMD considers the thresholds for project-specific impacts and cumulative impacts to be the same.

Therefore, projects that exceed project -specific significance thresholds are considered by SCAQMD to be cumulatively considerable.” DEIR p. 5.2-37 goes on to state, “in terms of localized air quality impacts, construction and operation of the Project would not have a cumulatively considerable impact due to criteria pollutant emission.” Therefore, as the Project was determined not to exceed any of the emissions significance thresholds, including localized significance thresholds, and would accordingly not result in cumulatively significant air quality impacts, the Project would not result in significant impacts regarding the environmental justice issues stated by the commenter.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 12.8:

The commenter indicates that the Project, as proposed, will not include refrigerated storage and operation of cold storage warehouses would include trucks with transportation refrigeration units (TRUs) that emit significantly higher levels of toxic DPM, oxides of nitrogen, and greenhouse gases than trucks without TRUs. The commenter requests the City to include as a project design measure to ensure TRUs will not operate at the Project, that contractual language in tenant lease agreements prohibit tenants from operating TRUs or a condition requiring a restrictive covenant over the parcel that prohibits the use of TRUs.

As outlined in Response 12.4 above, Mitigation Measure MM AIR -1 is revised accordingly, as requested by CARB, to include a restrictive covenant that also restricts the use of TRUs. If the applicant were to request future use of TRUs at the site a new HRA would need to be prepared in accordance with the latest OEHHA, CARB, and SCAQMD guidance, and the City would need to conduct subsequent CEQA review.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the s ubsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-458
provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This com ment is noted for the record, and revisions to the DEIR have been made as noted above.

Response 12.9:

The commenter indicates they encourage the City and applicant to implement the measures listed in Attachment A of this comment letter to reduce the Projec t’s construction and operational air pollution emissions.

As outlined in more detail in Response 12.5 above, the design features and/or additional mitigation measures listed above partially accomplish the commenters Attachment A Recommended Construction Measures 1 and 2. Although not required, Mitigation measures MM AIR-7 through MM AIR-9 accomplish the commenters Attachment A Recommended Operations Measures 6, 9, and 10. Mitigation measure MM AIR -10 partially accomplishes the commenters Attachment A Operat ions Measure 11. As the Project does not include use of TRUs, the commenters Attachment A Recommended Operation Measures 2, 3 and part of 4 are not applicable. The commenters Attachment A Recommended Operation Measures 12 includes installing vegetative walls or other effective barriers that separate loading docks and people living or working nearby, is also not applicable as the loading docks are not close to people living or working nearby. The closest existing residences and commercial uses are approximately 225 feet of the Project site boundary or parcel line, across Alessandro Boulevard. The Building A set back from Alessandro Boulevard is 520 feet and greater for Building B, thus loading docks for Building A and B are set back from nearest residences by at least 745 feet or greater.

It should be noted that even with these revisions to the DEIR , no change to the significance conclusions presented in the DEIR will result. Accordingly, this comment and the subsequent DEIR revisions do not affect the analysis completed or conclusions provided in the DEIR, do not provide new information or evidence related to the analysis completed in the DEIR, and do not reflect on the adequacy or content of the DEIR. This comment is noted for the record, and revisions to the DEIR have been made as noted above.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-459
Comment Letters Received After Close of the DEIR Comment Review Period Comment Letter 13 – Golden State Environmental Justice Alliance Comment letter 13 commences on the next page.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-460

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-461

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-462

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-463
Letter 13 – Golden State Environmental Justice Alliance Commenter: Stephen Piepkorn
Date: August 17, 2021
Response 13.1:

The commenter provides their own summary of what CalEnviroScreen is, what agency updates and maintains it, what census tract the project is located in, and data on the census tract rankings for various pollution burdens, overall pollution, ozone, diesel particulate matter, etc.. The commenter also indicates that Interstate-215 freeway runs through the Project site census tract, as well as the census tract to the east of the Project site. The commenter additionally states that surrounding census tracts to the south and east of the Project site experience comparatively higher pollution than the rest of the State and that this information must be considered in the context of the Project.

Please see Responses 7.10 and 7.18. While the DEIR does not specifically cite CalEnviroScreen data in its analysis, the DEIR and its underlying technical studies do include a cumulative impact analysis as well as analysis relevant to environmental justice issues in reviewing potential Project impacts. As stated on p. iv of the CalEnviroScreen 3.0 January 2017 document (CalEnviroScreen

4.0 is still in its draft state as of October 2021),
During the initial consideration and adoption of CalEnviroScreen, concerns were raised about its potential for misuse. To ensure proper use and understanding we explained that the tool is not a substitute for a cumulative impacts analysis under the California Environmental Quality Act (CEQA ). Nor is the intent to restrict the authority of government agencies in permit and land-use decisions. Furthermore, CalEnviroScreen may not be the appropriate tool to guide all public policy decisions.

Therefore, the DEIR was not required to utilize CalEnviroScreen in its analysis and has fulfilled CEQA requirements by including a cumulative impact analysis for potential air quality impacts.

The SCAQMD has developed methodologies and thresholds of significance that are widely used throughout the air basin. SCAQMD staff has suggested in the cumulative significance methodologies contained in the CEQA Air Quality Handbook that the emissions-based thresholds be used to determine if a project’s contribution to regional cumulative emissions is cumulatively considerable. These thresholds were used in the Air Quality Analysis to assess the significance of the Project -specific and cumulative air quality impacts. Air quality impacts are basin-wide, and air quality is affected by all pollutant sources in the basin. Therefore, the ambient air quality measurements provided in the Air Quality Analysis provide a summary of basin-wide cumulative air quality impacts. As the individual Project thresholds are designed to he lp achieve attainment with cumulative basin- wide standards, they are also appropriate for assessing the Project’s contribution to cumulative impacts.

As discussed in Response 7.10, per DEIR p. 5.2 -37 under Cumulative Environmental Effects, “SCAQMD considers the thresholds for project-specific impacts and cumulative impacts to be the same. Therefore, projects that exceed project-specific significance thresholds are considered by Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-464
SCAQMD to be cumulatively considerable.” DEIR p. 5.2-37 goes on to state, “in terms of localized air quality impacts, construction and operation of the Project would not have a cumulatively considerable impact due to criteria pollutant emission.” Therefore, the Project was determined not to exceed any of the emissions significance thr esholds, including localized significance thresholds, and would accordingly not result in cumulatively significant air quality impacts.

Additionally, per Responses 7.10 and 7.18, DEIR pp. 5.2 -31 to 5.2- 32 state that, “LSTs were developed in response to env ironmental justice and health concerns raised by the public regarding exposure of individuals to criteria pollutants in local communities” and that it was determined, “the Project would not exceed the SCAQMD LSTs during construction and operational activit ies.” Response 7.10 further discusses that the Project’s Health Risk Assessment (HRA; DEIR Appendix C) discusses the Project’s potential impacts regarding diesel particulate matter (DPM) emissions, cancer risk, non -carcinogenic risk, residential exposure, worker exposure, and school children exposure. Further, the Project was determined not to exceed any of the emissions significance thresholds, including localized significance thresholds, and would accordingly not result in cumulatively significant air quality impacts.

Thus, the DEIR and its underlying technical studies have considered the Project in the context of potential impacts to local communities and within a cumulative context and it has been determined the Project would not result in significant air quality impacts in these regards.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Response 13.2:

The commenter states that it is the responsibility of the City’s elected and appointed officials to make environmentally responsible development decisions . The commenter further states that based on the CalEnviroScreen data, there is evidence of further air quality impacts that the citizenry of Riverside and its surrounding area will continue to encounter with further development of another warehouse/distribution center.

The DEIR, Section 5.2 Air Quality, under subheadings Physical Setting and Existing Air Quality, (p. 5.2 -2) acknowledges that the Project site is located in the South Coast Air Basin, which consists of Orange County, coastal and mountain portions of Los Angeles County, as well as Riverside and San Bernardino Counties, with topographical features such as mountains that form a natural barrier to the dispersion of air pollutants. The DEIR also acknowledges there is a gradual degradation of air quality from coastal areas to inland areas and that the basin is designated as in nonattainment for state air quality standards for eight-hour ozone and PM2.5, and for state PM10 standards. Thus, the DEIR acknowledges that the Project site is in an area of poor air quality and, as discussed in Response 13.1 above, was not required to utilize CalEnviroScreen data in its analysis.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-465
Further, as outlined in Response 7.10, the air quality analysis contained in the DEIR demonstrates the Project would not result in significant air quality impacts, either from a project specific or cumulative perspective, as further outlined below.

The air quality analysis prepared for the Project provides an assessment of potential cum ulative air quality impacts. The SCAQMD shares the responsibility with California Air Resources Board (CARB) for ensuring that all federal and state ambient air quality standards are achieved and maintained throughout the air basin. The SCAQMD has developed methodologies and thresholds of significance that are widely used throughout the air basin. SCAQMD staff has suggested in the cumulative significance methodologies contained in the CEQA Air Quality Handbook that the emissions-based thresholds be used to determine if a project’s contribution to regional cumulative emissions is cumulatively considerable. These thresholds were used in the Air Quality Analysis to assess the significance of the Project - specific and cumulative air quality impacts. Air quality impacts are basin-wide, and air quality is affected by all pollutant sources in the basin. Therefore, the ambient air quality measurements provided in the Air Quality Analysis provide a summary of basin-wide cumulative air quality impacts. As the individual Project thresholds are designed to help achieve attainment with cumulative basin- wide standards, they are also appropriate for assessing the Project’s contribution to cumulative impacts. As shown in Tables 7 and 9 of the Air Quality Analysis (Appendix C to the DEIR), construction and operational emissions would be less than the applicable project-level thresholds. Additionally, the project would be consistent with the growth projections used to develop the AQMP and would therefore not conflict with implementation of the AQMP or applicable portions of the SIP. CalEnviroScreen 4.0 is not a recommended method of evaluating potential air quality impacts. As such, air quality impacts would be less than significant.

On DEIR pp. 5.2-31 to 5.2-32, in response to Threshold C, which questions whether the Project would expose sensitive receptors to substantial pollutant concentrations, the DEIR describes the localized significance threshold (LST) analysis utilized in determining these potential impacts.

DEIR pp. 5.2-31 to 5.2-32 state that, “LSTs were developed in response to environmental justice and health concerns raised by the public regarding exposure of individuals to criteria pollutants in local communities.” These pages of the DEIR further state that, “the Project was analyzed for its potential to result in significant health risk impacts resulting from short-term construction and long- term operational emissions” and that it was determined, “the Project would not exceed the SCAQMD LSTs during construction and operational activities.” Additionally, the Project’s Health Risk Assessment (HRA; DEIR Appendix C) discusses the Project’s potential impacts regarding diesel particulate matter (DPM) emissions, cancer risk, non- carcinogenic risk, residential exposure, worker exposure, and school children exposure. Further, as described in Response

9.15, as part of the FEIR, a detailed construction HRA has been prepared utilizing the appropriate AERMOD modeling software (the same model used in the DEIR for operational HRA), which allows for calculation of annual average concentrations and allows for the geospatial placing of the source and receptors. Thus, contrary to the commenter’s statements, the DEIR does include analysis relevant to environmental justice issues as the LSTs utilized in determining potential impacts to sensitive receptors were developed in response to environmental justice concerns and Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-466
the Project HRA assesses potential Project-related health risks to residents, workers, and school children.

Further, as stat ed on DEIR p. 5.2- 37 under Cumulative Environmental Effects, “SCAQMD considers the thresholds for project -specific impacts and cumulative impacts to be the same.

Therefore, projects that exceed project -specific significance thresholds are considered by SCAQMD to be cumulatively considerable.” DEIR p. 5.2-37 goes on to state, “in terms of localized air quality impacts, construction and operation of the Project would not have a cumulatively considerable impact due to criteria pollutant emission.” Therefore, as the Project was determined not to exceed any of the emissions significance thresholds, including localized significance thresholds, and would accordingly not result in cumulatively significant air quality impacts, the Project would not result in signific ant impacts regarding the environmental justice issues stated by the commenter.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis compl eted in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-467
Comment Letter 14 – Lenora Mitchell

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-468
Letter 14 – Lenora Mitchell
Commenter: Lenora Mitchell
Date: August 19, 2021
Response 14.1:

The commenter indicates she is a resident of the City and opposes the project as it is too close to homes and too far away from the 215 Freeway, resulting in numerous truck trips along Alessandro Boulevard. The commentor states that the air quality in the area will be diminished with the increased smog, fumes and air particulates. The commentor states natural habitats will be destroyed and that the project will use huge amounts of water during construction dur ing a water shortage. The commenter states we need more open spaces for residents to enjoy.

As identified in the DEIR, Section 5.12 Transportation the DEIR acknowledges that the Project will generate additional truck trips on Alessandro Boulevard. As outli ned in Table 5.12- 8 – Trip Generation Summary (Actual Vehicles), page 5.12-39, the Project is anticipated to result in 847 daily trips. However, the DEIR concluded that the Project will not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities: potential impacts are less than significant and not mitigation is required. (DEIR p., 5.12-51)
As identified in the DEIR, Section 5.2 Air Quality, Subsection 5.2.2.4 Local Regulations, “The City adopted Good Neighbor Guidelines for Siting New and/or Modified Warehouse/Distribution Facilities (GNG) in October 2008 to focus on the relationship between land use, permitting and air quality. They also highlight strategies that can help minimize the impacts of diesel emissions associated with warehouse/distribution centers. Specifically, the Guidelines help to minimize the impacts of diesel particulate matter from on -road trucks associated with warehouses and distribution centers on existing communities and sensitive receptors. On November 10, 2020, the Riverside City Council adopted updates to the GNG, in addition to associated amendments to Title 19 – Zoning Code of the Riverside Municipal Code (RMC), the Hunter Business Park Specific Plan, and the Sycamore Canyon Business Park Specific Plan related to siting industrial uses in the City when located adjacent to sensitive receptors, including residential neighborhoods, schools, parks, playgrounds, day care centers, nursing homes, hospitals, and other public spaces. (DEIR, pp. 5.2-18 – 5.2-19) The Project was found to be consistent with both the 2008 and the 2020 GNGs. (DEIR, pp. 5.2-27 – 5.2-30)
As outlined in Responses 7.10 and 13.2, the air quality analysis contained in the DEIR demonstrates the Project would not result in significant air quality impacts, either from a project specific or cumulative perspective.

The DEIR contains a thorough and detailed analysis of the Project’s impacts to natural habitats.

The DEIR acknowledges that the Project will result in 0.80 acre of permanent impacts and 0.02 acre of temporary impacts to riparian/riverine areas, as well as grassland areas that are suitable habitat for Stephens’ kangaroo rat ; however, with implementation of mitigation measures MM BIO-2 through MM BIO -8, impacts would be reduced to less than significant. (DEIR, p. 5.3- 29) For example, as stated on DEIR p. 5.3 -53, MM BIO-6 includes the following, which would serve to reduce to impacts to on- site riparian/riverine areas and suitable habitat for least Bell’s vireo (LBVI):

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-469

1. Enhancement of a total of 1.58 acres of riparian habitat: 0.01 acre in Drainages A, 1.34 acres in B, and 0.23 acre in Area C.

2. Create (establish) 0.61 acre of in-kind riparian woodland in Area C.

3. Restoration of 0.02 acre of riparian habitat in Drainage B.

4. The non-jurisdictional, non- riparian/riverine upland areas of slopes associated with the access road will be restored/ replanted with native seed mix.

5. The roadway/access to Parcel 1/ Building A shall include culverts to provide a hydrological connection to the riparian habitat on the east side of the roadway and a corridor for small wildlife species.

As listed under MM BIO-6, the Project would include additions of land to the Restricted Property, which would serve as further compensation for impacts. Additionally, per DEIR p. 5.3- 53, MM BIO-8 includes payment of the Stephen’s Kangaroo Rat Habitat Conservation Plan (SKRHCP) fee to the City of Riverside prior to issuance of a grading permit.

As outlined in the DEIR, Section 5.14 Utilities and Service Systems (DEIR, pp. 5.14 -17 – 5.14- 20),

Therefore, there is adequate water supply for the Project’s water use during construction and operations, even in multiple dry years, or a drought.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-470
As outlined in Response 11.1, the applicant is providing a trailhead parking lot that is not required but being provided as an amenity to Sycamore Canyon Wilderness Park users, including residents.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-471
Comment Letter 15 – Greater Riverside Chambers of Commerce Comment letter 15 commences on the next page.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-472

City of Riverside Section 2.0
Sycamore Hills Distribution Center FEIR Responses to Comments

2.0-473
Letter 15 – Greater Riverside Chambers of Commerce
Commenter: Cindy Roth
Date: July 26, 2021
Response 15.1:

The commenter indicates that the Greater Riverside Chambers of Commerce supports this project and does not have any questions, comments, or concerns about the project or the CEQA analysis detailed in the FEIR. Also, the commenter requests further project support from the Chair (Richard Kirby) and members of the City of Riverside Planning Commission.

Therefore, this comment does not affect the analysis completed or conclusions provided in the DEIR, does not provide new information or evidence related to the analysis completed in the DEIR, and does not reflect on the adequacy or content of the DEIR. This comment is noted for the record and no changes to the DEIR are required.

Section 2 City of Riverside
Responses to Comments Sycamore Hills Distribution Center FEIR

2.0-474

2.4 References
The following references were used in the preparation of this section of the FEIR:

Appendix C Revised Air Quality Impact Analysis
Appendix D Revised Burrowing Owl Focused Survey Report
Appendix H Revised Greenhouse Gas Analysis
Appendix M Federal Aviation Administration (FAA) Determination Letters Appendix N Construction Health Risk Assessment
Appendix O Floor Plans for Buildings A and B
CalEviroScre
en 3.0
“CalEnviroScreen 3.0 – Updated to the California Communities Environmental Health Screening Tool,” Office of Environmental Health Hazard Assessment (OEHHA), January 2017. (Accessible at:
https://oehha.ca.gov/media/downloads/calenviroscreen/report/ces3report.pdf )
CAPCOA
Market
Capture Rate
California Air Pollution Control Officers Association (CAPCOA). 2008. CEQA & Climate Change, Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, January.

City of
Riverside
Public
Utilities 2017
Power
Content
California Energy Commission (CEC). 2018b. City of Riverside Public Utilities 2017 Power Content Label. Version July 2018.

ESRI
ArcMap 10.8
Environmental Systems Research Institute (ESRI) Aeronautical Reconnaissance Coverage Geographic Information System (ARCGIS) Desktop Version 10.8.

Integrated
Public Use
Microdata
Series 5.0
Steven Ruggles, J. Trent Alexander, Katie Genadek, Ronald Goeken, Matthew B. Schroeder, and Matthew Sobek. Integrated Public Us e Microdata Series:

Version 5.0 [Machine-readable database]. Minneapolis: University of Minnesota, 2010.

OEHHA

IPUMS-USA
Office of Environmental Health Hazard Assessment (OEHHA) Integrated Public Use Microdata Series (IPUMS -USA). (Accessible here:
http://oehha.ca.gov/air/hot_spots/SRP/Appendix%20L.pdf) City of Riverside Section 2.0
Crestview Apartments Project FEIR Responses to Comments

2.0-475
Riverside
Public
Utilities RPS
in 2007
Union of Concerned Scientists. 2012. Riverside Public Utilities. The Clean Energy Race: How Do California Public Utilities Measure Up. July.

SCAQMD
Mobile
Source Toxic
Analysis
Guidance
South Coast Air Quality Management District (SCAQMD). Mobile Source Toxic Analysis Guidance. 2002. (Accessible at: http://www.aqmd.gov/home/rules- compliance/ceqa/air-quality-analysis-handbook/mobile-source-toxics- analysis)
SCAQMD
Risk
Assessment
Procedures
for Rules
1401,
1401.1, &
212
South Coast Air Quality Management District (SCAQMD) . Risk Assessment Procedures for Rules 1401, 1401.1, & 212. 2017. (Accessible at:
http://www.aqmd.gov/docs/default-source/permitting/rule-1401-risk- assessment/riskassessproc-v8-1.pdf?sfvrsn=12)
USEPA
Exposure
Factors
Handbook
United States Environmental Protection Agency (USEPA). Exposure Factors Handbook (1997, Final Report). (Accessible at:
http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=12464#Download) USEPA Risk
Assessment
Guidance for
Superfund –
Vol 1: Human
Health Eval
Manual
United States Environmental Protection Agency (USEPA). Risk Assessment Guidance for Superfund – Volume 1 Human Health Evaluation Manual. (Available at:
http://www.epa.gov/oswer/riskassessment/ragsa/pdf/rags_a.pdf)

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-1

3.0 Revisions to the Draft EIR
This section presents other specific changes to the text of the Draft EIR that have been made to clarify information presented in the Draft EIR or to update information presented in the Draft EIR based on new regulatory or policy guidance since preparation of the Draft EIR. The changes in this section are in addition to the changes and revisions to the Draft EIR that have been made in response to the comments received on the Draft EIR, as presented in Section 2.0, Response to Comments. However, the revisions presented above in Section 2.0 are also shown below. These revisions are not considered significant new information that would trigger Draft EIR recirculation pursuant to State CEQA Guidelines Section 15088.5. For example, they do not disclose a new or substantially worsened significant environmental impact, a new feasible mitigation measure , or new alternative. Rather, the revisions correct or clarify information presented.

Where revisions to the main text are called for, the section and page are set forth, followed by the appropriate revision. Added text is indicated with underlined text. Text deleted from the Draft EIR is shown in strikethrough. Page numbers correspond to the page numbers of the Draft EIR.

Furthermore, any and all revisions related to mitigation measures have been incorporated into the final Mitigation Monitoring and Reporting Program (see Section 4).

3.1 Text Revisions to the Draft EIR

Section 3.2 Project Description, Table 3.0-4 – Building B p. 3.0-23 changes as follows:

Table 3.0-4: Building B
City’s Site Development Standard Proposed
Max Floor Area
Ratio

1.50 0.45
Building Height 45 feet 42-45 feet
Building
Minimum
Setbacks
Front Yard (West) 50 feet 90 feet
Side Yard (North & South) 0 feet 60 & 20182 feet
Rear Yard (East) 0 feet 57 feet

Minimum
Parking
Office: 1 space/250 sq. ft.
(10,000 sq. ft.)
40 spaces
235 spaces
45 trailer stalls
Warehouse: 1 space/1,000 sq. ft.
(193,100 sq. ft.)
194 spaces
Section 3.0 City of Riverside
Revisions to the Draft EIR Sycamore Hills Distribution Center Project FEIR

3.0-2
Total: 234 spaces
Minimum
Landscape
Setbacks
Front: (West) 20 feet 20 feet
Side: 0 feet 0 feet
Rear: 0 feet 0 feet

Section 3.4 Discretionary Actions and Approvals pp. 3.0-42-3.0-43 changes as follows:

March Joint Powers Authority
• Restrictive Covenant Amendment
Metropolitan Water District of Southern California
• Issuance of Public Road Easement
U.S. Army Corps of Engineers
• Section 404 Permit for Disposal of Dredge or Fill Material per the Clean Water Act • Concurrence with Restrictive Covenant Amendment

Section 5.1.5 Aesthetics, pp. 5.1-19 - 5.1-20 changes as follows:

Building B will be located between 2060-182 feet from the northern property line of Parcel 2, and 90 feet from the northerly property line of the trailhead parking lot.

Section 5.2.2.4 Air Quality, p. 5.2-17 changes as follows:

The GP 2025 contains objectives and policies to protect air quality within the City in the Air Quality Element. The following objectives and policies are applicable to the Project:

Objective AQ-1: Adopt land use policies that site polluting facilities away from sensitive receptors and vice versa; improve jobs-housing balance; reduce vehicle miles travelled and length of work trips; and improve the flow of traffic.

Policy AQ-1.1: Ensure that all land use decisions, including enforcement actions, are made in an equitable fashion to protect residents, regardless of age, culture, ethnicity, gender, race, socioeconomic status, or geographic location, from the health effects of air pollution.

Policy AQ -1.2: Consider potential environmental justice issues in reviewing impacts (including cumulative impacts for each project proposed).

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-3
Section 5.2.5 Air Quality, Tables 5.2-6 and 5.2-7, p. 5.2-26 changes as follows:

Table 5.2-6 – Total Annual Construction Emissions Comparison to General Conformity de Minimis Levels
Construction
Emissions (tons per year)
ROG NOx CO SO2 PM10 PM2.5
Year 2021 Emissions (tons/year) 0.35

0.49 3.29

4.59 2.78

3.97 0.01 0.51

0.88 0.25

0.36 Year 2022 Emissions (tons/year) 1.77

3.27 1.61

2.44 1.95

2.84 0.01 0.33

0.62 0.13

0.21 Total Emissions (tons) 2.12

3.76 4.91

7.02 4.73

6.78 0.01

0.02 0.83

1.49 0.38

0.57 Maximum Annual Emissions (tons/year) 1.77

3.27 3.29

4.59 2.78

3.94 0.01 0.51

0.88 0.25

0.36 De Minimus Levels 10 10 100 -- 100 70
Exceed Threshold? No No No -- No No

Table 5.2-7 – Maximum Daily Construction Emissions Comparison to SCAQMD Significance Thresholds
Construction Emissions (pounds per day)
ROG NOx CO SOx PM10 PM2.5
Site Preparation 4 41 22 <1 910 6
Grading 4 5 46 57 32 33 <1 6 2 4
Building Construction/Architectural Coatings1 32 59 29 45 34 51 <1 6 11 2 4 Paving/Architectural Coatings1 32 58 46 13 34 21 <1 2 1 Maximum Daily Emissions2 32 59 46 57 34 51 <1 9 11 6
SCAQMD Regional Threshold 75 100 550 450 150 55
Exceed Threshold? No No No No No No
1The architectural coatings phase of construction was modeled simultaneously with building construction and parking lot paving emissions.
2Emissions were rounded to the nearest whole number, Emissions reported as <1 indicate that emissions were calculated to be less than 0.5 pound per day.

Section 5.2.5 Air Quality, p. 5.2-30 changes as follows:

Section 5.2.5 Air Quality, Table 5.2-8, p. 5.2-31 changes as follows:

3.0-4
Significance Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
SUMMER
Area Sources 14 <1 <1 <1 <1 <1
Energy Sources <1 <1 <1 <1 <1 <1
Mobile Sources – Passenger Cars 1 1 2 19 27 <1 10 3
Mobile Sources – Trucks 2 36 16 <1 10 3
Parcel C Parking Lot Dust -- -- -- -- 9 1
Total 17 37 38 36 44 <1 19 28 6 7
Significance Threshold 55 55 550 150 150 55
Exceed Threshold? No No No No No No
Note: Emissions were rounded to the nearest whole number. Emissions reported as <1 indicate that emissions were calculated to be less than 0.5 pound per day.

Section 5.2.5 Air Quality, Table 5.2-9, p. 5.2-32 changes as follows:

Table 5.2-9 – Localized Construction Emissions
CO NOx PM10 PM2.5
Maximum Daily On-Site Emission 3331 3946 910 56
LST Threshold 6,860 488 75 31
Threshold Exceeded? No No No No

Section 5.2.5 Air Quality, p. 5.2-36 changes as follows:

MM AIR-2: The Project applicant shall provide electrical hook ups to the power grid, rather than use of diesel -fueled generators, for electric construction tools, such as saws, drill s and compressors and use of electric tools whenever feasible.

MM AIR-3: The Project applicant shall provide information on transit and ridesharing programs and services to construction employees.

MM AIR-5: The Project applicant shall post signs at every truck exit driveway providing directional information to the truck route.

MM AIR-6: The Project applicant shall provide tenants with information on incentiv e programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-5
MM AIR-7: The Project applicant shall 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.

MM AIR-8: The Project applicant shall include contractual language in tenant lease agreements restricting trucks and support equipment from idling longer than 5 minutes while on site.

MM AIR-10: Include rooftop solar panels to the extent feasible, with a capacity to supply 15% of the entire Project’s electrical demand.

Section 5.3.1 Biological Resources, p. 5.3-8 changes as follows:

Burrowing owl ( Athene cunicularia; BUOW) is protec ted under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code and is a CDFW SSC. BUOW focused surveys were conducted in 2018 with updated focused surveys conducted in 2020 on April 24, May 7, May 21, and June 5, 2020. No rain was present within five (5) days of each survey in accordance with the Burrowing Owl Survey Instructions for the Western Riverside MSHCP Area. Based on the results of the 2018 and 2020 BUOW focused surveys, BUOW are presumed absent on the Project site (ELMT p. 15). A lthough no individual BUOW or BUOW sign was observed during the surveys, potentially suitable BUOW burrows were recorded via CNDDB observations within a five (5) mile radius of the BSA as shown on Figure 5.3-5 – CNDDB BUOW Observations.

Section 5.3.1 Biological Resources, pp. 5.3-49 and 5.3-53 changes as follows:

MM BIO-1: Prior to issuance of a grading permit , a Qualified Biologist shall collect seed during the blooming period for paniculate tarplant and Robinson’s pepper grass throughout the proposed development footprint of the project, if they occur. The seeds shall be stored in accordance with the biologist’s recommendations until restoration efforts are commenced within the existing and additional Restricted Property/conservation area. If seed is not collected prior to grading permit issuance then topsoil, where identified by the Qualified biologist, shall be salvaged, and temporarily stored in accordance with the qualified biologist’s recommendations until restoration efforts are commenced. On site restoration efforts shall incorporate the collected seed or salvaged topsoil.

MM BIO -7: To reduce potential impacts to MSHCP c overed species and to comply with the MSHCP, payment of the MSHCP mitigation fee shall be provided to the City of Riverside prior to issuance of a grading building permit for the project.

Section 5.4.6 Cultural Resources, p. 5.4-36 changes as follows:

MM CUL-9: Sites CA-RIV-11769, CA-RIV-11770, CA-RIV-11772, CA-RIV-2486, CA-RIV-2487, CA-RIV-2488, and CA-RIV-2489 will be impacted during grading and construction activities and the soils surrounding them will be disturbed. Prior to any grading in the associated areas, the Project Applicant, the Consulting Tribes, and the City will formalize a written agreement to identify Section 3.0 City of Riverside
Revisions to the Draft EIR Sycamore Hills Distribution Center Project FEIR

3.0-6
the area that will be subject to “Controlled Grading” during construction of the Project. The Pechanga and Soboba Tribes, the Project Applicant, and the City will develop an exhibit t hat outlines the area subject to controlled grading, and that area will be highlighted on the rough grading plans, precise grading plans or other off-site improvement plans that may impact this site. “Controlled Grading” shall include, without limitation, the slow and deliberate excavation and removal of soils employing the smallest reasonable cuts in certain areas using light scrapers (for example Caterpillar 623 or 627), dozers (for example D6- D8), front end loaders, excavators, skip loaders, dump trucks , and motor graders. A controlled grading plan will be monitored by the Project Archeologist and Tribal Monitor(s) to ensure the systematic removal of the ground surface surrounding these features are monitored to allow for the identification of resources. Results of all controlled grading activities shall be included in the Phase IV monitoring report.

Section 5.7.5 Greenhouse Gas Emissions, Table 5.7-6, p. 5.7-25 changes as follows:

Table 5.7-6 – Riverside Public Utilities Intensity Factors Riverside Public Utilities Intensity Factors (lbs/MWh)
GHG
CalEEMod
Version 2016.3.2
Default values
(lbs/MWh)
Intensity Factors
with 0% RPS
Intensity Factors
with 33% RPS
CalEEMod
Version 2020.4.0
Intensity Factor
Carbon Dioxide
(CO2) 1,325.65 1,569.57 1,051.61 789.983
Methane (CH4) 0.029 0.034 0.023 0.033
Nitrous Oxide
(N2O) 0.006 0.007 0.005* 0.004
*The correct N2O intensity factor of 0.005 was used in CalEEMod; however, the incorrect value of

0.004 was reported in Table 6 of the GHG Analysis. Table 6 of the GHG Analysis has been updated to reflect the current 2021 intensity factors.

Section 5.7.5 Greenhouse Gas Emissions, Table 5.7-7, p. 5.7-26 changes as follows:

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-7
As shown in Table 5.7-7, the Project would result in a net increase of 7,405 7,587 MT CO2E per year. As discussed previously, the SCAQMD’s 10,000 MT CO 2E screening level is appropriate for exempting industrial projects that are too small to have significant impacts from further analysis.

Conclusion
As discussed, the Project’s GHG analysis utilizes the SCAQMD’s Interim CEQA GHG Significance Thresholds for Stationary Sources, Rules, and Plans . The interim thresholds are a tiered approach; project impacts may be determined to be less than significant under each tier or require further analysis under subsequent tiers. Because the Project is subject to CEQA and is not subject to a regional GHG emissions reduction plan, the Project does not fall under Tiers 1 or

2. As shown in Table 5.7-7 – Summary of Project GHG Emissions, construction and operation of the Project would result in the annual equivalent emission of 7,405 7,587 MT CO2E in 2023.

Project GHG emissions would be less than the applicable SCAQMD screening level of 10,000 MT CO 2E for industrial uses. As Project emissions would be less than the 10,000 MT CO 2E screening level, GHG emissions impacts would be less than significant with Mitigation Measure MM AIR-1.

Section 5.7.6 Greenhouse Gas Emissions, p. 5.7-33 changes as follows:
• Energy – State regulations and 2017 Scoping Plan measures that would reduce the project’s energy-related GHG emissions include RPS (see Section 3.2.2.5), Title 24 Energy Efficiency Standards (see Section 3.2.2.7a), and CALGreen (see Section

3.2.2.7b). The project would be served by Riverside Public Utilities, which has achieved 36 percent renewables as of 2017 (CEC 2018b) . The project’s energy related GHG emissions would decrease as Riverside Public Utilities increases its renewables procurement beyond 2020 towards the 2030 goal of 50 60 percent. Additionally, the project would be constructed in accordance with energy effi ciency standards effective at the time building permits are issued. The current 2019 Energy Code is estimated to decrease energy consumption by 30 percent for non-residential buildings when compared to the 2016 Title 24 Energy Code.

3.0-8
MT N2O = metric tons of nitrous oxide
*The GWPs included in CalEEMod are from the IPCC Fourth Assessment Report. For informational purposes, total emissions calculated by CalEEMod were adjusted to account for the updated IPCC Fifth Assessment Report GWPs. Using the current GWPs, total annual project emissions would be 7,428 7,618 MT CO2, and would also be less than the screening threshold. Note that the IPCC updates the GWPs periodically, and the next anticipated update will occur in 2022.

Section 5.7.5 Greenhouse Gas Emissions, Table 5.7-8, p. 5.7-34 changes as follows:

Table 5.7-8 – Project Consistency with RRG-CAP GHG Reduction Measures Number Strategy/Goal Project Consistency
State and Regional Energy Measures
The following are state and regional measures that are expected to reduce GHG emissions associated with the energy sector.

SR-1 Renewable
Portfolio Standard
(RPS)
Utilities must secure
33 percent of their
power from
renewable sources
by 2020.

The Project would be served by Riverside Public Utilities, which has achieved 36 percent renewables as of 2017. The Project’s energy-related GHG emissions would decrease as Riverside Public Utilities increases its renewables procurement beyond 2020 towards the 2030 goal of 50 60 percent. The Project would not conflict or interfere with RPS.

Section 5.7.7 Greenhouse Gas Emissions, p. 5.7-41 changes as follows:

As shown in Table 5.7-7, the Project would result in a net increase of 7,405 7,587 MT CO2E per year, which would be less than the 10,000 MT CO 2E screening level. Additionally, the Project would be consistent with applicable RRG-CAP measures and is in line with the GHG reductions needed to achieve the 2050 GHG emission reduction targets identified by EO S-3-05. Therefore, the Project would not generate GHG emissions that would cause a significant impact on the environment and the impacts are less than significant with Mitigation Measure MM AIR-1.

Section 6.4.1 Population Growth, p. 6.0-6 changes as follows:

However, the anticipated number of employees for both buildings was calculated using the County of Riverside generation rate1 to be approximately 586. This number represents approximately 0.3

1.3 percent of the expected opportunities within the City by 2045. Thus, the Project will not induce substantial population growth and impacts would be less than significant.

Section 6.4.2 Economic Growth, p. 6.0-6 changes as follows:

Additionally, as described above in Section 6.4.1, the 586 employm ent opportunities represent approximately 0.3 1.3 percent of the expected opportunities within the City by 2045.

1 County of Riverside General Plan Square Feet/Employee Factor of 1,030 SF per employee for Light Industrial land use, Appendix E-2: Socioeconomic Build-Out Assumptions and Methodology, April 11, 2017, https://planning.rctlma.org/General-Plan-Zoning/General-Plan City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-9

3.2 Appendix Revisions to the Draft EIR and New Final EIR Appendix

3.2.1 Revised Draft EIR Appendices
Appendix B – Revised Consistency with General Plan and Specific Plan Policies, pp. 29-30 of Appendix B are changed as follows:

Air Quality Element
Objective
AQ-1:

Adopt land use policies that site polluting facilities away from sensitive receptors and vice versa; improve job-housing balance; reduce vehicle miles traveled and length of work trips; and improve the flow of traffic.

Policy AQ-

1.1 Ensure that all land use decisions,
including enforcement actions, are
made in an equitable fashion to
protect residents, regardless of age,
culture, ethnicity, gender, race,
socioeconomic status, or geographic
location, from the health effects of air
pollution.

Section 5.2 as well as Project’s
Air Quality Analysis discuss the
localized significance threshold
(LST) analysis utilized in
determining potential air quality
impacts to sensitive receivers.

The LSTs “were developed in
response to environmental justice
and health concerns raised by the
public regarding exposure of
individuals to criteria pollutants in
local communities” (DEIR pp. 5.2-
31 to 5.2-32). It was determined
“the Project would not exceed the
SCAQMD LSTs during
construction and operational
activities.”
Consistent
Policy AQ-

1.2 Consider potential environmental
justice issues in reviewing impacts
(including cumulative impacts for
each project proposed
As stated under Policy AQ-1.1
above, Section 5.2 as well as
Project’s Air Quality Analysis
discuss the localized significance
threshold (LST) analysis utilized
in determining potential air quality
impacts to sensitive receivers.

The LSTs “were developed in
response to environmental justice
and health concerns raised by the
public regarding exposure of
individuals to criteria pollutants in
local communities” (DEIR pp. 5.2-
31 to 5.2-32). The Project was
determined not to exceed any of
the emissions significance
thresholds, including localized
significance thresholds, and
would accordingly not result in
Consistent
Section 3.0 City of Riverside
Revisions to the Draft EIR Sycamore Hills Distribution Center Project FEIR

3.0-10
cumulatively significant air quality
impacts.

Appendix B – Revised Consistency with General Plan and Specific Plan Policies, pp. 9-10 of Appendix B are changed as follows:

Circulation and Community Mobility Element
Objective
CCM-2:

Build and maintain a transportation system that combines a mix of transportation modes and transportation system management techniques, and that is designed to meet the needs of Riverside’s residents and businesses, while minimizing the transportation system’s impacts on air quality, the environment and adjacent development.

Policy CCM-

2.3 Maintain LOS D or better on Arterial
Streets wherever possible. At key
locations, such as City Arterials that
are used by regional freeway
bypass traffic and at heavily traveled
freeway interchanges, allow LOS E
at peak hours as the acceptable
standard on a case-by-case basis.

The DEIR was prepared while
the State and City were
transitioning from LOS to VMT as
a CEQA impact. While the DEIR
includes LOS and VMT analysis,
the Office of Planning and
Research confirms that auto
delay, on its own, is no longer an
environmental impact under
CEQA. While the Project would
not be consistent with this policy,
the Project would not have a
significant impact related to LOS
because LOS is not considered
an environmental impact.

Inconsistent
Policy CCM-

2.4 Minimize the occurrence of streets
operating at LOS F by building out
the planned street network and by
integrating land use and
transportation in accordance with
the General Plan principles.

Although the General Plan target
LOS will be exceeded at the
Sycamore Canyon Boulevard
and Alessandro Boulevard
intersection, the intersection is
currently built out to its General
Plan ultimate cross-section and
until additional right-of-way
beyond those designated in the
General Plan is obtained, there
are no anticipated feasible
improvements.

Additionally, the DEIR was
prepared while the State and City
were transitioning from LOS to
VMT as a CEQA impact. While
the DEIR includes LOS and VMT
analysis, the Office of Planning
and Research confirms that auto
delay, on its own, is no longer an
environmental impact under
CEQA. While Project would not
Inconsistent
City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-11
be consistent with this policy, the
Project would not have a
significant impact related to LOS
because LOS is not considered
an environmental impact.

Appendix B – Table 3 – Project Consistency with the 2020-2045 Connect SoCal RTP/SCS is added, p. 54 of Appendix B is changed as follows:

Table 3- Project Consistency with the 2020-2045 Connect SoCal RTP/SCS 2020-2045 RTP/SCS Goal 4:

Increase person and goods
movement and travel choices within
the transportation system.

Consistent: The Air Quality and Greenhouse Gas analysis (DEIR Appendix C and H) conducted for the Project determined it would not result in emissions that would exceed thresholds or result in significant impacts. The Project will meet or exceed all applicable standards under California’s Green Building Code (CalGreen) and Title 24. The Project includes design
considerations to help reduce emissions both during
construction and operations including:

Energy Efficiency
• Design building shells and components, such as
windows, roof systems and electrical systems to
meet California Title 24 Standards for
nonresidential buildings.
• Use of Energy Star products such as appliances,
building products, heating and cooling equipment,
appliances, and other energy-efficient equipment.
• Install efficient lighting and lighting control
systems. Solar or light-emitting diodes (LEDs) will
be installed for outdoor lighting. Lighting will
incorporate motion sensors that turn them off
when not in use.
• Install skylights on the rooftops, 2.5% of roof area of the buildings and incorporate the use of natural light. • Achieve construction energy efficiencies and energy
conservation through bulk purchase, transport, and
Section 3.0 City of Riverside
Revisions to the Draft EIR Sycamore Hills Distribution Center Project FEIR

3.0-12
use of construction materials. Use of materials in bulk reduces the preparation and transport of construction
materials as well as transport and disposal of
construction waste.
• Use trees and landscaping on west and south exterior
building walls to reduce energy use.

Renewable Energy
• Design buildings to have “solar ready” roofs that
will structurally accommodate later installation of
rooftop solar panels. Building operators providing
rooftop solar panels will submit plans for solar
panels prior to occupancy.

Water Conservation and Efficiency
• Create water-efficient landscapes in compliance with
the City’s Water Efficient Landscape and Irrigation
Ordinance 19.570.
• Surface parking lots will be landscaped in accordance with City standards to reduce heat island effect.
• Install water-efficient irrigation systems and devices, such as soil moisture-based irrigation controls and
sensors for landscaping according to the City’s Water
Efficient Landscape and Irrigation Ordinance 19.570,
which complies with the California Department of
Water Resources Model Efficient Landscape
Ordinance.
• Design buildings to be water efficient. Install water- efficient fixtures and appliances.
• Restrict watering methods (e.g., prohibit systems that apply water to non-vegetated surfaces) and control
runoff.
• Provide education about water conservation and
available programs and incentives to the building
operators to distribute to employees.

Solid Waste Measures
• Sort, recycle, and divert from landfills Project-related construction and demolition waste in accordance with
mandatory regulatory requirements.
• Provide interior and exterior storage areas for
recyclables and green waste and adequate recycling
containers located in public areas.
• The property operator will provide readily available
information provided by the City for employee
education about reducing waste and available recycling
services.

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-13
VMT, Transportation and Motor Vehicles
• Limit idling time for commercial vehicles to no more
than five minutes.
• Implement sidewalks to facilitate and encourage
pedestrian and access, which would reduce vehicle
miles traveled (VMT).
• Provide a total of 39 electric vehicle (EV) parking stalls to encourage the use of low or zero-emission vehicles. • Provide a total13 clean air/van pool parking stalls
to support and encourage ridesharing.
• Provide short-term and long-term bicycle parking per
the Cal Green Code Sections 5.710.6.2.1 and

5.710.6.2.2, respectively.
• The Building Operator will support and encourage
ridesharing and transit for the construction crew.

On-Site Equipment and Loading Docks
• The Project will require building operators (by contract specifications) to turn off equipment, including heavy- duty equipment, motor vehicles, and portable
equipment, when not in use for more than 5 minutes.

Truck idling shall not exceed 5 minutes in time. All
facilities will post signs requiring that trucks shall not be left idling for more than 5 minutes pursuant to Title 13 of the California Code of Regulations, Section 2485, which limits idle times to not more than five minutes.

Construction
• Require Construction Equipment to Turn Off When Not
in Use.
• Use “green” building materials where feasible, such as those materials that are resource efficient and recycled and manufactured in an environmentally conscious
way.
• During grading heavy-duty construction equipment
shall be CARB/ US EPA Tier 3 certified. All
construction equipment is subject to the CARB In-Use
Off-Road Diesel-Fueled Fleets Regulation.

Section 3.0 City of Riverside
Revisions to the Draft EIR Sycamore Hills Distribution Center Project FEIR

3.0-14
2020-2045 RTP/SCS Goal 6: Support
healthy and equitable communities.

Consistent: The Project includes design considerations to promote walking and the use of bicycles:
• Implement sidewalks to facilitate and encourage
pedestrian and access.
• Promote the use of bicycles as an alternative means of transportation by providing short-term and long-term
bicycle parking per the California Green Building
Standards Code Sections 5.710.6.2.1 and 5.710.6.2.2,
respectively.

The Project also includes a trailhead parking area adjacent to the Sycamore Canyon Wilderness Park, which is a popular location for mountain biking and hiking.
2020-2045 RTP SCS Goal 7: Adapt to
a changing climate and support an
integrated regional development
pattern and transportation network.

Consistent: The Project proposes a logistics center within the SCBPSP on a site that has been designated for industrial uses since 1984. The SCBPSP is strategically located near State Route 60 and Interstate 215, which provide good access to the Ports of Long Beach and Los Angeles. The Project includes design considerations to promote the use of an integrated transportation network:
• Implement sidewalks to facilitate and encourage
pedestrian and access, which would reduce vehicle
miles traveled (VMT).
• Provide a total of 39 electric vehicle (EV) parking stalls to encourage the use of low or zero-emission vehicles. • Provide a total13 clean air/van pool parking stalls
to support and encourage ridesharing.
• Provide short-term and long-term bicycle parking per
the Cal Green Code Sections 5.710.6.2.1 and

5.710.6.2.2, respectively.

2020-2045 RTP/SCS Goal 9:

Encourage development of diverse
housing types in areas that are
supported by multiple transportation
options.

Not Applicable: Encouraging development of diverse housing types in areas that are supported by multiple transportation options is beyond the scope of the proposed Project and the authority of the Project proponents. The Project site is within the SCBPSP and has been planned for industrial uses since 1984.

The SCBPSP is strategically located in proximity to State Route 60 and Interstate 215.

City of Riverside Section 3.0
Sycamore Hills Distribution Center Project FEIR Revisions to the Draft EIR

3.0-15
2020-2045 RTP/SCS Goal 10:

Promote conservation of natural and
agricultural lands and restoration of
habitats.

Not Applicable. Promoting conservation of natural and
agricultural lands and restoration of habitats is beyond the scope of the proposed Project and the authority of the Project proponents. However, the Project does not include any
component that would impede the attainment of this goal.

Appendix C – Revised Air Quality Impact Analysis
Appendix D – Revised Burrowing Owl Focused Survey Report Appendix H – Revised Greenhouse Gas Analysis

3.2.2 New Final EIR Appendix
Appendix M – Federal Aviation Administration (FAA) Determination Letters Appendix N – Construction Health Risk Assessment
Appendix O – Floor Plans for Buildings A and B

Riverside City CouncilJanuary 25, 2022

Riverside City Council
January 25, 2022