Addendum to MND - Pages 3-12 through 5-88 — Riverside City Council, December 20, 2022

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 4-15

4.0 Environmental Checklist

4.1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
Pursuant to Public Resources Code Section 21157.1 (b) and CEQA Guidelines 15177(b)(2), the purpose of this initial study is to analyze whether the current Project (Planning Case No. PR-2020-000519) may cause any additional significant effect on the environment, which was not previously disclosed in the Adopted MND (Case Nos. P14-0841, P14-0842, P14-0843, P14-0844, P14-0846, and P14-0847) that was adopted by the City of Riverside in January 2016. The environmental factors checked below would be potentially affected by the proposed Project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.

܆Aesthetics ܆Hazards & Hazardous Materials ܆Recreation ܆Agriculture & Forest Resources ܆Hydrology/Water Quality ܆Transportation ܆Air Quality ܆Land Use / Planning ܆Tribal Cultural Resources ܆Biological Resources ܆Mineral Resources ܆Utilities/Service Systems ܆Cultural Resources ܆ Noise ܆Wildfire
܆Energy ܆ Paleontological Resources ܆Mandatory Findings of ܆
܆
Geology/Soils
Greenhouse Gas Emissions
܆
܆
Population/Housing
Public Services
Significance

4.2 DETERMINATION
On the basis of this initial evaluation:

A PREVIOUS ENVIRONMENTAL IMPACT REPORT/NEGATIVE DECLARATION WAS NOT PREPARED:
܆I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
܆I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. ܆I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT (EIR) is required.

A PREVIOUS ENVIRONMENTAL IMPACT REPORT/NEGATIVE DECLARATION WAS PREPARED:
܆I find that although the proposed project could have a significant effect on the environment, NO NEW ENVIRONMENTAL DOCUMENTATION IS REQUIRED because (a) all potentially significant effects of the proposed project have been adequately analyzed in an earlier EIR or Negative Declaration pursuant to applicable legal standards, (b) all potentially significant effects of the proposed project have been avoided or mitigated pursuant to that earlier EIR or Negative Declaration, (c) the proposed project will not result in any new significant environmental effects not identified in the earlier EIR or Negative Declaration, (d) the proposed project will not substantially increase the severity of the environmental effects identified in the earlier EIR or Negative Declaration, (e) no considerably

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 4-16
different mitigation measures have been identified and (f) no mitigation measures found infeasible have become feasible.
܈I find that although all potentially significant effects have been adequately analyzed in an earlier EIR or Negative Declaration pursuant to applicable legal standards, some changes or additions are necessary but none of the conditions described in California Code of Regulations, Section 15162 exist.

An ADDENDUM to a previously-certified EIR or Negative Declaration has been prepared and will be considered by the approving body or bodies.
܆I find that at least one of the conditions described in California Code of Regulations, Section 15162 exist, but I further find that only minor additions or changes are necessary to make the previous EIR adequately apply to the project in the changed situation; therefore, a SUPPLEMENT TO THE ENVIRONMENTAL IMPACT REPORT is required that need only contain the information necessary to make the previous EIR adequate for the project as revised. ܆I find that at least one of the following conditions described in California Code of Regulations, Section 15162, exist and a SUBSEQUENT ENVIRONMENTAL IMPACT REPORT is required: (1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) Substantial changes have occurred with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any the following: (A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR or negative declaration; (C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives; or, (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR or negative declaration would substantially reduce one or more significant effects of the project on the environment, but the project proponents decline to adopt the mitigation measures or alternatives.

Signature Date

Printed Name

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-17

5.0 Environmental Analysis

5.1 ENVIRONMENTAL ISSUES ASSESSMENT
In accordance with the California Environmental Quality Act (CEQA) (Public Resources Code §§ 21000- 21178.1), this Initial Study (IS) has been prepared to analyze the proposed Project to determine any potential significant impacts upon the environment beyond those disclosed in MND (Case Nos. P14-0841, P14-0842, P14-0843, P14-0844, P14-0846, and P14-0847) that would result from construction and implementation of the Project. In accordance with California Code of Regulations § 15063, this Initial Study is a preliminary analysis prepared by the Lead Agency, the City of Riverside, in consultation with other jurisdictional agencies, to determine whether a Negative Declaration, Mitigated Negative Declaration (MND), Environmental Impact Report (EIR), or Addendum to an Adopted EIR or MND is required for the proposed Project.

5.1.1 Aesthetics

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
I. AESTHETICS. Except as provided in Public Resources Code Section 21099, would the project:

a. Have a substantial adverse effect upon a
scenic highway corridor within which it is
located?
܆ ܆ ܈ ܆
b. Substantially damage scenic resources,
including, but not limited to trees, rock
outcroppings and historic buildings within a
scenic highway?
܆ ܆ ܈ ܆
c. In non-urbanized areas, substantially degrade
the existing visual character or quality of
public views of the site and its surroundings?
(Public views are those that are experienced
from publicly accessible vantage points.) If the
project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality?
܆ ܆ ܈ ܆
d. Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
܆ ܆ ܈ ܆

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a) Would the Project have a substantial adverse effect on a scenic vista? (Source: General Plan 2025 Figure CCM-4 – Master Plan of Roadways, General Plan 2025 FPEIR Figure 5.1- 1 – Scenic and Special Boulevards and Parkways, Tabl e 5.1-A – Scenic and Special Boulevards, and Table

5.1-B – Scenic Parkways, Sycamore Canyon Business Park Specific Plan)

No Substantial Change from Previous Analysis:

The Adopted MND concluded that with compliance to and implementation of the Citywide Design Guidelines, impacts to scenic vistas would be less than significant. The proposed Project is consistent in terms of the bulk and scale of the previously entitled industrial building and other physical features. There are no components of the proposed Project that would result in an increased adverse effect on a scenic vista. Consistent with the Adopted MND, the proposed Project would comply with the Citywide Design Guidelines as well as the design guidelines of the Sycamore Canyon Business Park Specific Plan. Therefore, the Project’s potential to have a substantial adverse effect on a scenic vista remains less than significant.

Thus, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the proposed Project would not increase the severity of a significant impact as identified and analyzed in the Adopted MND. Direct, indirect, and cumulative impacts related to scenic vistas remain less than significant.

b) Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? (Source: General Plan 2025 Figure CCM-4 – Master Plan of Roadways, General Plan 2025 FPEIR Figure 5.1- 1 – Scenic and Special Boulevards, Parkways, Tab le 5.1-A – Scenic and Specia l Boulevards, Table 5.1-B – Scenic Parkways, the City’s Urban Forest Tree Policy Manual, Title 20 – Cultural Resources and, Title 19 – Article V – Chapter 19.100 – Residential Zones - RC Zone, Caltrans State Scenic Highway System Map)

No Substantial Change from Previous Analysis:

The California Department of Transportation does not identify any state scenic highways in the Project area. There are no components of the proposed Project that would result in an increased adverse effect to substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. The Adopted MND disclosed for informational purposes that the Project site is located along Alessandro Boulevard which is designated as a Scenic Boulevard within the Circulation and Community Mobility Element of the City’s General Plan 2025. Consistent with the Adopted MND, the proposed Project would comply with and implement the Citywide Design Guidelines as well as the design guidelines of the Sycamore Canyon Business Park Specific Plan, which would maintain the desired aesthetic along Alessandro Boulevard. The proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the proposed Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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Because there are no State scenic highways in the Project site’s viewshed, impacts would remain less than significant related to State scenic highways.

c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? (Source: General Plan 2025, General Plan 2025 FPEIR, Zoning Code, Citywide Design and Sign Guidelines, Sycamore Canyon Business Park Specific Plan)

No Substantial Change from Previous Analysis:

The Project site is located in an urbanized area at the Alessandro Boulevard/Interstate 215 interchange.

Although the visual character of the site would change from a vacant site to a developed site, there are no components of the proposed Project that would increase potential adverse effects to the existing visual character or quality of public views of the site and its surroundings. In addition, the proposed Project is consistent with all applicable zoning and other regulations governing scenic quality. Consistent with the findings of the Adopted MND, the proposed Project would not damage or substantially degrade the visual character or quality of the site and its surroundings, given that the Project would be compatible with the existing development to the north of the site and the existing zoning north and east of the site; thus, impacts due to the substantial degradation of the existing visual character or quality of public views of the site and its surroundings would remain as less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
No Substantial Change from Previous Analysis:

The Project site is located in an urbanized area at the Alessandro Boulevard/Interstate 215 interchange.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-20

5.1.2 Agriculture and Forest Resources

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
II. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland)
as shown on the maps prepared pursuant to
the Farmland Mapping and Monitoring
Program of the California Resources Agency,
to non-agricultural use?
܆ ܆ ܆ ܈
b. Conflict with existing zoning for agricultural
use, or a Williamson Act contract? ܆ ܆ ܆ ܈
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland
(as defined by Public Resources Code section
4526), or timberland zoned Timberland
Production (as defined by Government Code
section 51104(g))?
܆ ܆ ܆ ܈
d. Result in the loss of forest land or conversion
of forest land to non-forest use? ܆ ܆ ܆ ܈
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest land?
܆ ܆ ܆ ܈
a) Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? (Source: General Plan 2025 – Figure OS-2 – Agricultu ral Suitability & General Plan 2025 FPEIR – Appendix I – Designated Farmland Table, FPEIR Section 5.2-Agricultural Resources, Google Earth)

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No Substantial Change from Previous Analysis:

The Adopted MND states that according to Figure OS-2 – Agricultural Suitability of the General Plan 2025, the Project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. The California Department of Conservation does not designate lands within the Project site as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. As such, the Adopted MND concluded that no impact would occur. Since adoption of the Adopted MND, the Project site has not been designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) and there are no components of the proposed Project that would result in impacts to Farmland. Consistent with the Adopted MND, no impact would occur. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project conflict with existing zoning for agricultural use or Williamson Act contract? (Source: General Plan 2025 – Figure OS-3 - Williamson Act Preserves, General Plan 2025 FPEIR – Figure

5.2-4 – Proposed Zones Permitting Agricultural Uses, and Title 19)

No Substantial Change from Previous Analysis:

The Adopted MND states that according to Figure 5.2-2 – Williamson Act Preserves of the General Plan 2025 FPEIR, the Project site is not located within an area that is affected by a Williamson Act Preserve or under a Williamson Act Contract. The site is also not zoned for agricultural land. Therefore, the Project would not conflict with existing zoning for agricultural use, or a Williamson Act contract. Consistent with the Adopted MND, no impact would occur. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

c) Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
(Source: Figure LU-10 – Land Use Policy Map, General Plan 2025, City of Riverside Zoning Map, Sycamore Canyon Business Park Specific Plan, Google Earth)

No Substantial Change from Previous Analysis:

Consistent with the conditions that existed with the Adopted MND, the Project site does not contain any forest lands, timberland, or timberland zoned as Timberland Production, nor are any forest lands or timberlands located on or nearby the Project site. No impact would occur. Therefore, consistent with the findings of the Adopted MND, the Project would not conflict with zoning for forests or Timberland Production. Consistent with the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-22
d) Would the Project result in the loss of forest land or conversion of forest land to non-forest use? (Source: GIS Map – Forest Data, General Plan 2025-Figure OS-2-Agricultural Suitability, Google Earth)

No Substantial Change from Previous Analysis:

Consistent with the conditions that existed with the Adopted MND, the Project site does not contain any forest lands. No impact would occur. Therefore, consistent with the findings of the Adopted MND, the Project would not result in the loss of forest land or conversion of forest land to non-forest use. Consistent with the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
(Source: General Plan – Figure OS-2 – Agricultura l Suitability, Figure OS-3 – Williamson Act Preserves, General Plan 2025 FPEIR – Appendix I – Designated Farmland Table, Title 19 – Article V – Chapter 19.100 – Residential Zones – RC Zone and RA-5 Zone and GIS Map – Forest Data)

No Substantial Change from Previous Analysis:

Consistent with the conditions that existed with the Adopted MND, based on the analysis under Thresholds (a) through (d) above, no impacts would occur with respect to changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non- agricultural use and no mitigation measures are required. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.3 Air Quality

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a. Conflict with or obstruct implementation of the
applicable air quality plan? ܆ ܆ ܈ ܆
b. Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
܆ ܈ ܆ ܆

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-23

a) Would the proposed Project conflict with or obstruct implementation of the applicable air quality plan?
(Source: South Coast Air Quality Management Distr ict’s 2007 and 2016 Air Quality Management Plan (AQMP), Air Quality Impact Analysis prepared by Urban Crossroads, Inc. on October 26, 2021)

No Substantial Change from Previous Analysis:

The Project involves the construction and operation of one 115,526 s.f. warehouse building and associated improvements. To accomplish the Project, the vacant site and the location of an adjacent car wash facility would be developed, which would entail demolition of the car wash structure and its associated improvements. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND. The operational characteristics associated with the proposed warehouse use (e.g., traffic and traffic-related impacts) are less intensive than the commercial and industrial land uses evaluated for the Project site as part of the Adopted MND.

The Adopted MND concluded that because the Project was consistent with the Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) and the General Plan 2025 “Typical Growth Scenario,” it is also consistent with the Air Quality Management Plan (AQMP); therefore, impacts were determined to be less than significant. Although the Project entails a General Plan Amendment, the resulting land use proposed would result in fewer air pollutant emissions that were assumed for the existing land use designation. In 2021, Urban Crossroads conducted an Air Quality Impact Analysis for the proposed Project. As discussed below in Threshold (b), the proposed Project would result in emissions of criteria pollutants that are well below what was assumed for the Project site by the Adopted MND. The proposed Project also would be subject to all applicable regulatory requirements addressing air pollution, as well as the mitigation measures included in the Adopted MND to further reduce potential air pollutant emissions. In addition, the SCAQMD adopted an Indirect Source Rule (ISR) in 2021, which is intended to address air quality concerns associated

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
applicable federal or state ambient air quality
standard?
c. Expose sensitive receptors to substantial
pollutant concentrations? ܆ ܆ ܈ ܆
d. Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
܆ ܆ ܈ ܆

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-24
with warehouse development across the South Coast Air Basin. There are no components of the proposed Project that would result in a conflict with or that would obstruct implementation of the air quality attainment plans and impacts would therefore remain less than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the proposed Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
(Source: General Plan 2025 FPEIR Table 5.3-B SCAQMD CEQA Regional Significance Thresholds, South Coast Air Quality Management District’s 2007 and 20 16 AQMP, Air Quality Analysis prepared by Yorke Engineering, LLC on March 2015, Air Quality Analysis pr epared by Urban Crossroads, Inc. on October 26, 2021)

MM Air 1: To reduce diesel emissions associated with construction, construction contractors shall provide temporary electricity to eliminate the need for diesel powered generators, or provide evidence that electrical hook ups at construction sites are not cost effective or feasible.

MM Air 2: To reduce construction related particulate matter air quality impacts of City projects the following measures shall be required:

1. The generation of dust shall be controlled as required by the AQMD;

2. Grading activities shall cease during period of high winds (greater than 25 mph);

3. Trucks hauling soil, dirt or other emissive materials shall have their loads covered with a tarp or other protective cover as determined by the City Engineer; and

4. The contractor shall prepare and maintain a traffic control plan, prepared, stamped and signed by either a licensed Traffic Engineer or a Civil Engineer. The preparation of the plan shall be in accordance with Chapter 5 of the latest edition of the Caltrans Traffic Manual and the State Standard Specifications. The plan shall be submitted for approval, by the engineer, at the preconstruction meeting. Work shall not commence without an approval traffic control plan.

No Substantial Change from Previous Analysis:

The Adopted MND concluded that air pollutant emissions (short-term and long-term) would not exceed the SCAQMD daily significance thresholds. The SCAQMD is the entity charged with bringing the South Coast Air Basin into State and federal attainment status and the SCAQMD’s significance thresholds standardize the review of projects across the Air Basin. To ensure short term emissions are further reduced, the General Plan 2025 Program EIR’s mitigation measures were applied to the Project, MM Air 1 and MM Air 2.

Impact Analysis for Construction Emissions
During construction of the proposed Project, the construction activities and equipment fleet is expected to be similar to the fleet assumed in the Adopted MND, although likely less polluting due to the

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-25
replacement of older equipment with newer, less polluting equipment in most standard fleets over time.

As shown on Table 5-1, Overall Construction Emissions Summary (Without Mitigation) emissions resulting from the Project construction would not exceed criteria pollutant thresholds established by the SCAQMD for emissions of any criteria pollutant. (Urban Crossroads, 2021a, p. 41) Although mitigation is not needed to reduce estimated daily construction regional emissions, the proposed Project would implement MM Air 1 and MM Air -2 consistent with the Adopted MND.

Overall Construction Emissions Summary (Without Mitigation)

(Urban Crossroads, Inc., 2021a, Table 3-5)

Impact Analysis for Operational Emissions
As shown in Table 5-2, Summary of Peak Operational Emissions , the proposed Project’s daily regional emissions from ongoing operations would not exceed any of the SCAQMD’s thresholds of significance.

Therefore, with respect to operational emissions, as shown in Table 5-3, Operational Emissions Comparison, the proposed Project is calculated to generate fewer emissions per day for pollutants as compared to emissions generated by the project that was approved under the Adopted MND. (Urban Crossroads, Inc., 2021a, pp. 44-45)

Consistent with the Adopted MND, the proposed Project would be required to comply with all applicable SCAQMD Rules, as well as the applicable mitigation measures (MM Air 1 and MM Air 2). Consistent with the Adopted MND, the Project would not result in an exceedance of any regional construction or operational-source emission thresholds. (Urban Crossroads, Inc., 2021a, p. 3)

Consistent with the findings of the Adopted MND, the proposed Project would not result in a cumulatively- considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or State ambient air quality standard, and impacts would be less than significant.

The proposed Project also would be subject to all applicable regulatory requirements addressing air pollution reduction. Therefore, the Project would not result in any new impacts not already analyzed in

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the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND.

Summary of Peak Operational Emissions

(Urban Crossroads, Inc., 2021a, Table 3-8)

Operational Emissions Comparison

(Urban Crossroads, Inc., 2021a, Table 3-10)

c) Would the proposed Project expose sensitive receptors to substantial pollutant concentrations? (Source: General Plan 2025 FPEIR Table 5.3-B SCAQMD CEQA Regional Significance Thresholds, South Coast Air Quality Management District’s 2007 and 2016 Air Quality Management Plan, Air Quality Analysis prepared by Yorke Engineering, LLC on March 2 015, Air Quality Analysis prepared by Urban Crossroads,

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Inc. on October 26, 2021, Mobile Source Health Risk Assessment prepared by Urban Crossroads, Inc. on October 22, 2021)

No Substantial Change from Previous Analysis:

The Adopted MND did not identify any potential impacts due to the exposure of sensitive receptors to substantial pollutant concentrations. Although not required for comparative analysis to the Adopted MND, a Mobile Source Health Risk Assessment was prepared for the current Project.

Impact Analysis for Construction Localized Emissions
Localized Significance Thresholds (LSTs) represent the maximum emissions from a project that would not cause or contribute to an exceedance of the most stringent applicable federal or State ambient air quality standard at the nearest residence or sensitive receptor. SCAQMD recommends that the newest sensitive receptor be considered when determining the Project’s potential to cause an individual or cumulatively significant impact.

Table 5-4, Localized Construction-Source Emissions -Without Mitigation, identifies the localized impacts at the nearest receptor to the Project site. As shown, localized construction emissions would not exceed the applicable SCAQMD LSTs for emissions of any criteria pollutant. (Urban Crossroads, Inc., 2021a, p. 53)

Impact Analysis for Operational Localized Emissions
As shown in Table 5-5, Localized Significance Summary of Operations - Without Mitigation , operational emissions for the proposed Project would not exceed the LST thresholds for the nearest sensitive receptor.

Therefore, the proposed Project would have a less than significant localized impact during operational activity. (Urban Crossroads, Inc., 2021a, pp. 44, 52, 58)

Impact Analysis for Diesel Particulate Emissions
Similar to the project described in the Adopted MND, diesel-fueled trucks would travel to/from the Project site during operation of the Project. Diesel trucks produce diesel particulate matter (DPM), which is known to be associated with health hazards, including cancer. To evaluate the Project’s potential to expose sensitive receptors within 0.25 mile of the Project site and the Project’s primary travel routes to substantial amounts of DPM during long-term operation, a Mobile Source Health Risk Assessment (HRA) was prepared for the proposed Project. On-site truck idling was calculated by Urban Crossroads to occur as trucks enter and travel through the Project site. Although the Project’s diesel-fueled truck and equipment operators are required by State law to comply with CARB’s idling limit of 5 minutes, staff at SCAQMD recommends that the on-site idling emissions be calculated assuming 15 minutes of truck idling, which would take into account on-site idling which occurs while the trucks are waiting to pull up to the truck bays, idling at the bays, idling at check-in and check-out, etc. As such, the Project’s HRA ( Technical Appendix L), analyzed truck idling at 15 minutes, consistent with SCAQMD’s recommendation. (Urban Crossroads, Inc., 2021a, pp. 14-15)

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Localized Construction-Source Emissions -Without Mitigation

(Urban Crossroads, Inc., 2021a, Table 3-12)

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Localized Significance Summary of Operations - Without Mitigation

(Urban Crossroads, Inc., 2021a, Table 3-14)

Operational-Related DPM Impacts
Residential Exposure Scenario: The residential land use with the greatest potential exposure to Project DPM source emissions is located approximately 61 feet east of the Project site at an existing residence. At the MEIR, the maximum incremental cancer risk attributable to Project DPM source emissions is estimated at 0.50 in one million, which is less than the SCAQMD’s significance threshold of 10 in one million. At this same location, non-cancer risks were estimated to be <0.01, which would not exceed the applicable significance threshold of 1.0. Because all other modeled residential receptors are exposed to lesser concentrations and are located at a greater distance from the Project site and primary truck route than the MEIR analyzed herein, and TACs generally dissipate with distance from the source, all other residential receptors in the vicinity of the Project site would be exposed to less emissions and therefore less risk than the MEIR identified herein. As such, the Project would not cause a significant human health or cancer risk to nearby residences. (Urban Crossroads, Inc., 2021a, p. 21)

Worker Exposure Scenario: The worker receptor land use with the greatest potential exposure to Project DPM source emissions is the adjacent potential worker receptor located 10 feet north of the Project site.

At the maximally exposed individual worker (MEIW) receptor, the maximum incremental cancer risk impact is 0.28 in one million which is less than the SCAQMD’s threshold of 10 in one million. Maximum non-cancer risks at this same location were estimated to be <0.01, which would not exceed the applicable significance threshold of 1.0. Because all other modeled worker receptors are located at a greater distance than the MEIW analyze herein, and DPM dissipates with distance from the source, all other worker receptors in the vicinity of the Project would be exposed to less emissions and therefore less risk than the MEIW identified herein. As such, the Project would not cause a significant human health or cancer risk to adjacent workers. (Urban Crossroads, Inc., 2021a, pp. 21-22)

School Child Exposure Scenario: There are no schools located within a ¼ mile of the Project site. As such, there would be no significant impacts that would occur to any schools in the vicinity of the Project. (Urban Crossroads, Inc., 2021a, p. 22)

In summary, the land use with the greatest potential exposure to Project construction and operational DPM source emissions is located approximately 67 feet east of the Project site at an existing residence. At the MEIR, the maximum incremental cancer risk attributable to Project construction and operational DPM source emissions is estimated at 6.94 in one million, which is less than the threshold of 10 in one million.

At this same location, non-cancer risks were estimated to be ≤ 0.01, which would not exceed the applicable threshold of 1.0. As such, the Project would not cause a significant human health or cancer risk

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-30
to adjacent land uses as a result of Project construction and operational activity. All other receptors during construction activity would experience less risk than what is identified for this location. Consistent with the adopted MND, there are no potential impacts due to the exposure of sensitive receptors to substantial pollutant concentrations. The proposed Project also would be subject to all applicable regulatory requirements addressing air pollution reduction. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND. (Urban Crossroads, Inc., 2021a, p. 22)

d) Would the proposed Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
(Source: Air Quality Analysis prepared by Yorke En gineering, LLC on March 2015, Air Quality Analysis prepared by Urban Crossroads, Inc. on October 26 , 2021, General Plan 2025 FPEIR Table 5.3-B SCAQMD Regional Significance Thresholds)

No Substantial Change from Previous Analysis:

The Adopted MND concluded that the Project’s potential to result in other emissions (such as those leading to odors) adversely affecting a substantial number of people would be less than significant. The MND concluded that such odors would occur only during daylight hours, be short-term in duration, and would be isolated to the immediate vicinity of the construction site and therefore, would not expose a substantial number of people to objectionable odors on a permanent basis.

Consistent with the project evaluated in the Adopted MND, the proposed Project does not contain land uses typically associated with emitting objectionable odors. Potential odor sources associated with the proposed Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities and the temporary storage of typical solid waste (refuse) associated with the proposed Project’s (long-term operational) uses. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short- term, and intermittent in nature and would cease upon completion of the respective phase of construction and is thus considered less than significant. It is expected that Project-generated refuse would be stored in covered containers and removed at regular intervals in compliance with the solid waste regulations. The proposed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, odors associated with the proposed Project’s construction and operation activities would remain less than significant and no mitigation is required.

Therefore, the Project would not result in any new impacts not already analyzed in Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-31

5.1.4 Biological Resources

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
IV. BIOLOGICAL RESOURCES. Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special status species in local or
regional plans, policies, or regulations, or by
the California Department of Fish and Game or
U.S. Fish and Wildlife Service?
܆ ܆ ܈ ܆
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations or by the California
Department of Fish and Game or US Fish and
Wildlife Service?
܆ ܆ ܈ ܆
c. Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means?
܆ ܆ ܈ ܆
d. Interfere substantially with the movement of
any native resident or migratory fish or
wildlife
species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?
܆ ܆ ܈ ܆
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
܆ ܆ ܆ ܈
a. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
܆ ܆ ܆ ܈

a) Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-32
local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

(Source: General Plan 2025 – Figure OS-6 – Stephen’s Kangaroo Rat (SKR) Core Reserve and Other Habitat Conservation Plans (HCP), Figure OS-7 – MSHCP Cores and Linkages, Figure OS-8 – MSHCP Cell Areas, General Plan 2025 FPEIR Figure 5.4-2 – MSHCP Area Plans, Figure 5.4-4 - MSHCP Criteria Cells and Subunit Areas, Figure 5.4-6 – MSHCP Narrow Endemic Plant Sp ecies Survey Area, Figure 5.4-7 – MSHCP Criteria Area Species Survey Area, Figure 5.4-8 – MSHCP Burrowing Owl Survey Area, Habitat Assessment prepared by ICF on August 2014, Determination of Biological Eq uivalent or Superior Preservation Analysis dated October 8, 2018, Email from Amir Morales on February 11, 2019, Helix Environmental Planning, Inc.)

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project described in the Adopted MND in terms of physical disturbance area. Specifically, the proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND. Through compliance with the Western Riverside Multiple Species Habitat Conservation Plan (MSHCP), the Adopted MND concluded that impacts to any species as a candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Game (CDFW) or U.S. Fish and Wildlife Services (USFWS) would be less than significant.

As discussed below in Threshold (b), Project construction requires permanent impact to 0.01 acre (336 linear feet) of one ephemeral USACE/RWQCB jurisdictional feature (Drainage A) and permanent impacts to 0.055 acre of ephemeral CDFW jurisdictional streambed/MSHCP Riverine Areas. Thus, the Project would unavoidably and adversely impact Riverine Wetland. To compensate for the loss of Riverine Wetland, pursuant to the Riverside Mitigation Bank Agreement for Sale of Credit, dated May 14, 2020, the Project Sponsor purchased rehabilitation credits to offset impacts to 0.055 acre of MSHCP Riparian Areas.

Consistent with the Adopted MND, through compliance with MSHCP Section 6.1.2 and other applicable requirements, impacts to any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS, impacts would remain less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service? (Source: General Plan 2025 – Figure OS-6 – Stephen’s Kangaroo Rat (SKR) Core Reserve and Other Habitat Conservation Plans (HCP), Figure OS-7 – MSHCP Cores and Linkages, Figure OS-8 – MSHCP Cell Areas, General Plan 2025 FPEIR Figure 5.4-2 – MSHCP Area Plans, Figure 5.4-4 - MSHCP Criteria Cells and Subunit Areas, Figure 5.4-6 – MSHCP Narrow Endemic Plant Sp ecies Survey Area, Figure 5.4-7 – MSHCP Criteria

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-33
Area Species Survey Area, Figure 5.4-8 – MSHC P Burrowing Owl Survey Area, MSHCP Section 6.1.2 - Protection of Species Associated with Riparian/Riverine Areas and Ver nal Pools, Habitat Assessment prepared by ICF on August 2014, Determination of Biologically Equivalent or Superior Preservation Analysis, prepared on October 8, 2019, Email from Amir Morales on February 11, 2019, Helix Environmental Planning, Inc to Sean Kelleher, City of Ri verside, Riverpark Mitigation Bank Agreement for Sale of Credits, dated May 14, 2020))

No Substantial Change from Previous Analysis:

The Adopted MND concluded that through compliance with MSHCP Section 6.1.2 and other applicable requirements, impacts to any riparian habitat or other sensitive natural community identified in local or reginal plans, policies, or regulations by the Department of Fish and Game or U.S. Fish and Wildlife Service would be less than significant.

As part of the Project’s Substantial Conformance process, in 2018, a Determination of Biologically Equivalent or Superior Preservation (DBESP) Analysis was prepared by Helix Environmental Planning, Inc.

Project construction requires permanent impact to 0.01 acre (336 linear feet) of one ephemeral USACE/RWQCB jurisdictional feature (Drainage A) and permanent impacts to 0.055 acre of ephemeral CDFW jurisdictional streambed/MSHCP Riverine Areas. Thus, the Project would unavoidably and adversely impact Riverine Wetland. To compensate for the loss of Riverine Wetland, pursuant to the Riverside Mitigation Bank Agreement for Sale of Credit, dated May 14, 2020, the Project Sponsor purchased rehabilitation credits to offset impacts to 0.055 acre of MSHCP Riparian Areas.

c) Would the Project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
(Source: City of Riverside GIS/CADME USGS Quad Map Layer, and Wetlands Delineation, Determination of Biological Equivalent or Superior Preservation An alysis dated October 8, 2018, Department of Fish and Wildlife Notification of Lake or St reambed Alteration No. 1600-2018-0067-R6 dated July 24, 2018, Email from Amir Morales on February 11, 2019, Helix Environmental Planning, Inc., Department of the Army Nationwide Permit (NWP) Verification dated August 15, 2019)

No Substantial Change from Previous Analysis:

As concluded by the Adopted MND, the project originally encroached into a drainage course and/or wetland under the jurisdiction of the United States Army Corps of Engineers (USACOE). State and federal laws and regulations were implemented to protect resources from development through the USACOE

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-34
Section 404 permitting process, the California Wetlands Conservation Policy (CWCO), and with applicable MSHCP policies. With required compliance with the applicable local, State and federal laws and regulations, the MSHCP, and the “no net wetland loss” policy, impacts were concluded to be less than significant.

Pursuant to the Department of Fish and Wildlife Service Notification of Lake or Streambed Alteration No. 1600-2018-0067-R6, dated July 24, 2018, a 0.28-acre wetland and an approximate 30-foot buffer surrounding the wetland, located within the remaining 0.60-acre area at the western property boundary will be permanently avoided. In addition, the Project would comply with the Nationwide Permit (NWP) issued for the proposed Project.

Because the Project Applicant complied with the Lake or Streambed Alteration Agreement and obtained an NWP and the Project’s design avoids the wetland, consistent with the Adopted MND, the Project’s potential to have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means, would remain less than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species with established native resident or migratory corridors, or impeded the use of native wildlife nursery sites?
(Source: MSHCP, General Plan 2025 –Figure OS-7 – MSHCP Cores and Linkage and Habitat Assessment prepared by ICF on August 2014, Email from Amir Morales on February 11, 2019)

No Substantial Change from Previous Analysis:

As concluded by the Adopted MND, the proposed Project would have no impact on the movement of migratory fish or wildlife species or on established wildlife corridors or wildlife nursery sites. Step I and Step II burrowing owl (BUOW) surveys were conducted by ESA PCR between July 15 and August 30, 2016 pursuant to the County’s protocol. Suitable habitat was observed on the Project site; however, no BUOW or BUOW sign were observed during the Step II surveys. A 30-day pre-construction survey is required prior to ground disturbance. Consistent with the Adopted MND, impacts would remain less than significant.

Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
(Source: MSHCP, Title 16 Section 16.72.040 – Establishing the Western Riverside County MSHCP Mitigation Fee, Title 16 Section 16.40.040 – Establishing a Threatened and Endangered Species Fees, City of Riverside Urban Forest Tree Policy Manual, and Habitat Assessment prepared by ICF on August 2014)

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-35
No Substantial Change from Previous Analysis:

As evaluated in the Adopted MND, the proposed Project is subject to all applicable federal, State, and local policies and regulations related to the protection of biological resources and tree preservation. In addition, the project is required to comply with Riverside Municipal Code Section 16.72.040 establishing the MSHCP mitigation fee and Section 16.40.040 establishing the Threatened and Endangered Species Fees. In addition, as with any project in the City of Riverside that proposes planting a tree within a City right-of-way, the Project would be in compliance with the City’s Urban Forest Tree Policy Manual.

Consistent with the conclusion reached in the Adopted MND, the Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance due to mandatory compliance with the above policies and regulations. Consistent with the Adopted MND, impacts would remain less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

f) Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
(Source: MSHCP, General Plan 2025 – Figure OS-6 – Stephen’s Kangaroo Rat (SKR) Core Reserve and Other Habitat Conservation Plans (HCP), Stephens’ Ka ngaroo Rat Habitat Con servation Plan, Lake Mathews Multiple Species Habitat Conservation Plan and Natur al Community Conservation Plan, and El Sobrante Landfill Habitat Conservation Plan)

No Substantial Change from Previous Analysis:

As evaluated in the Adopted MND, the Project site is located within the Western Riverside MSHCP and would therefore be required to comply with the requirements of the Western Riverside MSHCP.

Consistent with the findings of the Adopted MND, the Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan because of mandatory compliance to the Western Riverside MSHCP. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-36

5.1.5 Cultural Resources

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
V. CULTURAL RESOURCES. Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource pursuant
to § 15064.5?
܆ ܈ ܆ ܆
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to § 15064.5?
܆ ܈ ܆ ܆
c. Disturb any human remains, including those
interred outside of formal cemeteries? ܆ ܆ ܈ ܆

a) Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
(Source: GP 2025 FPEIR Table 5. 5-A Historical Districts and Neighborhood Conservation Areas and Appendix D, Title 20 of the Riverside Municipal Cod e, Cultural Resources Survey prepared by Power Engineers on May 2015, Cultural Resource Survey prepared by Brian F. Smith and Associates on February 16, 2021)

MM CR 1: At least 30 days prior to beginning Project construction, the Project Applicant shall contact the Tribe(s) of grading, excavation, and the monitoring program and, if a Cultural Resources Treatment and Monitoring Agreement has not been developed, to develop a Cultural Resources Treatment and Monitoring Agreement between the Applicant and the Tribes. The Agreement shall address the treatment of known cultural resources, the designation, responsibilities, and participation of professional Native American Tribal monitors during grading, excavation and ground disturbing activities; Project grading and development scheduling; terms of compensation for the monitors; and treatment and final disposition of any cultural resources, sacred sites, and human remains discovered on the site.

MM CR 2: If inadvertent discoveries of subsurface archaeological/cultural resources are discovered during grading, the developer, the Project archaeologist, and the Tribe(s) shall assess the significance of such resources and shall meet and confer regarding the mitigation for such resources. Pursuant to Calif. Pub. Res. Code 21083.2(b) avoidance is the preferred method for archaeological resources. If the developer, the Project archaeologist, and the Tribe(s) cannot agree on the significance or the mitigation for such resources, these issues will be presented to the Community Development Director for decision.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-37
and practices of the Tribe(s). Notwithstanding any other rights available under the lay, the decision of the Community Development Direct shall be appealable to the Planning Commission and/or City Council.

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project evaluated in the Adopted MND in terms of the physical disturbance area. Specifically, the proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND. The adopted MND concluded that no historic resources were identified on the Project site. For the proposed Project, a Cultural Resources Assessment was conducted by Brian F. Smith and Associates (BFSA) in 2021. BFSA conducted a records search and a cultural resources field survey on the Project site and no historic resources were identified within the boundaries of the Project site. In addition, the Project site is not located within any of the City of Riverside’s “Existing & Potential Historic Districts and Neighborhood Conservation Areas.” In addition, a Sacred Lands File (SLF) search of the Native American Heritage Commission (NAHC) did not indicate the presence of any Native American sacred sites or locations of religious or ceremonial importance. As such, no impacts to historic resources would occur and the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

As required by the Adopted MND, the Project applicant is required to comply with MM CR-1 and MM CR- 2 in the event that a resource is discovered during ground-disturbing construction activities. Consistent with the Adopted MND, impacts would remain less than significant with mitigation incorporated.

b) Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
(Source: GP 2025 FPEIR Figure 5.5-1 - Archaeological Sensitivity and Figur e 5.5-2 - Prehistoric Cultural Resources Sensitivity, Appendix D – Cultural Resources Study, Cultural Resources Survey prepared by Power Engineers on May 2015, Cultural Resources Survey prepared by Brian F. Smith and Associates on February 16, 2021)

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-38
Calif. Pub. Res. Code 21083.2(b) avoidance is the preferred method for archaeological resources. If the developer, the Project archaeologist, and the Tribe(s) cannot agree on the significance or the mitigation for such resources, these issues will be presented to the Community Development Director for decision.

The Community Development Director shall make the determination based on the provisions of CEQA with respect to the archaeological resources and shall take into account the religious beliefs, customs, and practices of the Tribe(s). Notwithstanding any other rights available under the lay, the decision of the Community Development Direct shall be appealable to the Planning Commission and/or City Council.

No Substantial Change from Previous Analysis:

The Adopted MND concluded that no cultural resources were identified on the Project site. However, in order to address potential discoveries of Tribal Cultural Resources (TCRs), the Adopted MND included mitigation to protect any possible resources that may be uncovered by the Project’s grading activities and that would need to be to be properly identified and treated. With implementation of Mitigation Measure (MM) MM CR-1 and MM CR-2, impacts were determined to be less than significant.

As discussed above in Threshold (a), for the proposed Project, a Cultural Resources Assessment was conducted by BFSA in 2021. BFSA conducted a records search and a cultural resources field survey on the Project site which did not identify any cultural resources within the Project site. Based on the presence of cultural resources offsite within 0.50-mile of the Project site, BFSA determined, similar to the conclusions in the adopted MND, that the potential exists that unidentified cultural resources may exist within the Project site that may be uncovered during the Project’s grading activities. As such, no impacts to known archaeological resources would occur and the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

c) Would the Project disturb any human remains, including those interred outside of formal cemeteries?
(Source: GP 2025 FPEIR Figure 5.5-1 - Archaeological Sensitivity and Figur e 5.5-2 - Prehistoric Cultural Resources Sensitivity)

No Substantial Change from Previous Analysis:

The adopted MND concluded that where construction is proposed in undeveloped areas, disturbance on vacant lands could have the potential to disturb or destroy buried Native American human remains as well as other human remains, including those interred outside of formal cemeteries. Consistent with State laws protecting these remains, sites containing human remains must be identified and treated in a sensitive manner. In the event that Native American human remains are inadvertently discovered during project-related construction activities, there would be unavoidable significant adverse impacts to Native American resources, but implementation of the Cultural Resources Mitigation Measures will, however,

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-39
reduce impacts to human remains, including those interred outside of formal cemeteries to a less than significant level.

Consistent with the findings of the Adopted MND, in the event that human remains are discovered during Project-related grading or other ground disturbing activities, compliance with the applicable provisions of California Health and Safety Code §7050.5 as well as Public Resources Code §5097 et. seq. are required.

These regulations specify requirements that must be followed in the event that human remains are discovered and the process to undertake should the coroner identify the remains as Native American. The proposed Project has no greater potential to uncover human remains than was assumed in the Adopted MND. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.6 Energy

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
VI. ENERGY. Would the project:
a. Result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
܆ ܆ ܈ ܆
b. Conflict with or obstruct a State or Local plan for
renewable energy or energy efficiency? ܆ ܆ ܈ ܆

a) Would the Project result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
(Source: California Building Standards Code Title 24; California Air Resources Board – the Advanced Clean Truck Regulation; and Executive Order N-79-20)

No Substantial Change from Previous Analysis:

The CEQA Energy thresholds listed in this Addendum were not required by CEQA at the time the MND was adopted. Nonetheless, information about the approved project’s energy use was available in the MND’s discussion of utilities and was used in calculations for air quality emissions. The use of energy to construct and operate buildings was a commonly understood con cept when the MND w as prepared and with a reasonable exercise of diligence, information about the approved project’s use of energy was available in the public record; no concerns about energy consumption were raised. For information disclosure in this MND Addendum, an analysis of the proposed Project’s projected energy use is provided below.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-40
The Project involves the construction and operation of one 115,526 s.f. warehouse building and associated improvements. To accomplish the Project, the vacant site and the location of an adjacent car wash facility would be developed, which would entail demolition of the car wash structure and its associated improvements. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND; therefore the Project’s potential to result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during construction of the Project, would be similar to that analyzed in the Adopted MND.

The operational characteristics associated with the proposed warehouse use (e.g., traffic and traffic- related impacts (the proposed Project is estimated to generate a total of 1,414 fewer two-way trips per day as compared to the existing use (Urban Crossroads, Inc., 2021a, p. 4) and are less intensive than the commercial and industrial land uses evaluated for the Project site as part of the Adopted MND; therefore, the Project’s potential to result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project operation of the Project would be less than that analyzed in the Adopted MND.

For new development such as the proposed Project, compliance with California Building Standards Code Title 24 energy efficiency requirements (CALGreen) is considered demonstrable evidence of efficient use of energy, and the Project would be subject to the current version of the Title 24 energy efficiency requirements, which are more stringent than the energy efficiency requirements in place at the time the Adopted MND was adopted. The Project Applicant would be required to meet all CALGreen standards.

In addition, the Project does not include uses or operations that would inherently result in excessive and wasteful energy consumption. Because the Project would be subject to the CALGreen requirements, and because the Project Applicant does not propose operational characteristics that are substantially different from other similarly situated industrial warehouse developments, the Project would not result in the inefficient, wasteful, or unnecessary consumption of energy. Regarding energy required for passenger vehicle and truck travel, in June 2020, CARB adopted a new Rule requiring truck manufacturers to transition from diesel trucks and vans to electric zero-emission trucks beginning in 2024. By 2045, every new truck sold in California will be required to be zero-emission. Subsequently in September 2020, Governor Newsom directed by Executive Order that the CARB develop regulations to mandate that 100 percent of in-state sales of new passenger cars and trucks are zero-emission by 2035. As such, the use of gasoline and diesel fuel will decrease over time. Furthermore, the Project would not cause or result in the need for additional energy facilities or energy delivery systems.

In conclusion, impacts due to energy consumption would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-41
b) Would the Project conflict with a State or Local plan for renewable energy or energy conservation?
(Source: California Building Standards Code Title 24; California Air Resources Board – the Advanced Clean Truck Regulation; and Executive Order N-79-20)

No Substantial Change from Previous Analysis:

The Project involves the construction and operation of one 115,526 s.f. warehouse building and associated improvements. To accomplish the Project, the vacant site and the location of an adjacent car wash facility would be developed, which would entail demolition of the car wash structure and its associated improvements. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND; therefore, the Project’s potential to result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction, would be similar to that analyzed in the Adopted MND.

The operational characteristics associated with the proposed warehouse use (e.g., traffic and traffic- related impacts) are less intensive than the commercial and industrial land uses evaluated for the Project site as part of the Adopted MND; therefore, the Project’s potential to result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project operation of the Project would be less than that analyzed in the Adopted MND.

Because the Project would result in similar energy consumption during construction as that of the project analyzed in the Adopted MND and would result in less energy consumption than the project evaluated in the Adopted MND, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-42

5.1.7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Less than
Significant
Impact
No Impact
VII. GEOLOGY AND SOILS. Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the risk of
loss, injury, or death involving:
܆ ܆ ܆ ܈
i. Rupture of a known earthquake fault, as
delineated on the most recent Alquist-
Priolo Earthquake Fault Zoning Map issued
by the State Geologist for the area or based
on other substantial evidence of a known
fault? Refer to Division of Mines and
Geology Special Publication 42.
܆ ܆ ܆ ܈
ii. Strong seismic ground shaking? ܆ ܆ ܆ ܈
iii. Seismic-related ground failure, including
liquefaction? ܆ ܆ ܈ ܆
iv. Landslides? ܆ ܆ ܆ ܈
b. Result insubstantial soil erosion, or the loss of
topsoil? ܆ ܆ ܈ ܆
c. Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?
܆ ܆ ܈ ܆
d. Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to
life or property?
܆ ܆ ܈ ܆
e. Have soils capable of adequately supporting
the use of septic tanks or alternative waste
water disposal systems where sewers are not
available for the disposal of waste water?
܆ ܆ ܆ ܈
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
܆ ܆ ܈ ܆

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-43
a) Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

I). Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
(Source: General Plan 2025 Figure PS-1 – Regional Fault Zones, General Plan 2025 FPEIR Appendix E – Geotechnical Report, Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Investigation Update Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

The Adopted MND concluded that compliance with the California Building Code (CBC) regulations would ensure that no impacts would occur. As such, consistent with the Adopted MND, the proposed Project would result in no impacts due to a rupture of a known earthquake fault. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

II). Strong seismic ground shaking?
(Source: General Plan 2025 Figure PS-1 – Regional Fault Zones, Figure PS-2 – Liquefaction Zones, General Plan 2025 FPEIR Figure PS-3 – Soils with High Shrink-Swell Potential, and Appendix E – Geotechnical Report, Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Consistent with the conditions evaluated in the Adopted MND, the San Jacinto Fault Zone located in the northeastern portion of the City, or the Elsinore Fault Zone, located in the southern portion of the City’s Sphere of Influence, have the potential to cause moderate to large earthquakes that would cause intense ground shaking. Because the proposed Project complies with CBC regulations, no significantly adverse impact would occur.

The Adopted MND concluded that compliance with the CBC regulations would ensure that no impacts would occur. As such, consistent with the Adopted MND, the proposed Project would result in no impacts due to a rupture of a known earthquake fault or due to any strong seismic shaking. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-44
Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

II). Seismic-related ground failure, including liquefaction? (Source: General Plan 2025 FPEIR Figure 5.6-1 – Areas Underlain by Steep Slope, Appendix E – Geotechnical Report, Title 18 – Subdivision Code, Ti tle 17 – Grading Code, and Storm Water Pollution Prevention Plan SWPPP, Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Consistent with the conditions evaluated in the Adopted MND, the Project site is located in an area with low – moderate potential for liquefaction. Incorporation of the recommended design measures of the proposed Project’s geotechnical study/preliminary soils report for compliance with the CBC regulations would ensure that impacts related to seismic-related ground failure, including liquefaction, are reduced to less than significant.

The Adopted MND concluded that compliance with the CBC regulations would ensure that no impacts would occur. As such, with compliance with the CBC and the recommendations of the Project’s geotechnical investigation, impacts related to seismic-related ground failure, including liquefaction, would be reduced to less than significant. Thus, consistent with the Adopted MND, impacts would remain less than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

IV). Landslides?
(Source: General Plan 2025 FPEIR Figure 5.6-1 – Areas Underlain by Steep Slope, Appendix E – Geotechnical Report, Title 18 – Subdivision Code, Ti tle 17 – Grading Code, and Storm Water Pollution Prevention Plan SWPPP, Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-45
b) Would the Project result insubstantial soil erosion, or the loss of topsoil? (Source: General Plan 2025 FPEIR Figure 5.6-1 – Areas Underlain by Steep Slope, Figure 5.6-4 – Soils, Table

5.6-B – Soil Types, Title 18 – Su bdivision Code, Title 17 – Grading Cod e, SWPPP, Geotechnical Report prepared by Salem Engineering Group, Inc. on Ju ly 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Consistent with the conditions evaluated in the Adopted MND, erosion and loss of topsoil could occur as a result of the Project. State and federal requirements call for the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) establishing erosion and sediment controls for construction activities. The Project must also comply with the National Pollutant Discharge Elimination System (NPDES) regulations. In addition, with the erosion control standards for which all development activity must comply (Title 18 – Subdivision Code), the Grading Code (Title 17) also require the implementation of measures designed to minimize soil erosion. Compliance with State and Federal requirements as well as Titles 17 and 18 would ensure that impacts related to soil erosion or loss of topsoil would remain than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

c) Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
(Source: General Plan 2025 Figure PS-1 – Regional Fault Zones, Figure PS-2 – Liquefaction Zones, General Plan 2025 FPEIR Figure PS-3 – Soils with High Shrink-S well Potential, Figure 5.6-1 - Areas Underlain by Steep Slope, Figure 5.6-4 – Soils, Table 5.6-B – Soil Types, and Appendix E – Geotechnical Report, Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Consistent with the conditions evaluated in the Adopted MND, the general topography of the Project site is flat. Compliance with the City’s existing codes and the policies contained in the General Plan 2025 help to ensure that impacts related to geologic conditions remain less than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? (Source: General Plan 2025 FPEIR Figure 5.6-4 – Soils, Figure 5.6-4 – Soils, Table 5.6-B – Soil Types, Figure

5.6-5 – Soils with High Shrink-Swell Potential, Appendix E – Geotechnical Report, and California Building Code as adopted by the City of Riverside and set out in Title 16 of th e Riverside Municipal Code,

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-46
Geotechnical Report prepared by Salem Engineering Group, Inc. on July 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

Consistent with the conditions evaluated in the Adopted MND, the soil type onsite is known to be an expansive soil. Compliance with the recommendations of the soils report and applicable provisions of the City’s Subdivision Code- Title 18 and the CBC with regard to soil hazards related to the expansive soils, would ensure that impacts remain less than significant. Therefore, the proposed Project would not result in any new impacts not already analyzed in the adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Would the Project have soils capable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
(Source: General Plan 2025 FPEIR Figure 5.6-4 – Soi ls, Table 5.6-B – Soil Types, Geotechnical Report prepared by Salem Engineering Group, Inc. on Ju ly 31, 2014, Geotechnical Report prepared by Salem Engineering Group, Inc. on April 4, 2019)

No Substantial Change from Previous Analysis:

As anticipated by the Adopted MND, the Project Applicant proposes to connect to the City of Riverside’s sanitary sewer system. Consistent with the findings of the Adopted MND, because the Project Applicant does not propose septic tanks or alternative waste water disposal systems, nor do any such facilities occur on site under existing conditions, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

f) Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
(Source: General Plan 2025 Policy HP-1.3, Paleontological Assessment prepared by Brian F. Smith and Associates on February 16, 2021)

MM-3: A qualified paleontologist (the “Project Paleontologist”) shall be retained by the developer prior to the issuance of a grading permit. The Project Paleontologist shall be on-call to monitor ground- disturbing activities and excavations on the Project site in the event potential paleontological resources by project personnel are encountered during implementation of the Project. The Project Paleontologist will be allowed to temporarily divert or redirect grading or excavation activities in the vicinity in order to make an evaluation of the find. If the resource is significant, Mitigation Measure CR-4 shall apply.

MM-4: If a significant paleontological resource(s) is discovered on the Project site, in consultation with the Project proponent and the City, the qualified paleontologist shall develop a plan of mitigation which shall include salvage excavation and removal of the find, removal of sediment from around the

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-47
specimen (in the laboratory), research to identify and categorize the find, curation of the find in a qualified repository, and preparation of a report summarizing the find.

No Substantial Change from Previous Analysis:

The Adopted MND concluded that activities including construction-related and earth-disturbing actions, could damage or destroy fossils in rock units. A cultural resources survey prepared by Power Engineers in May 2015 determined that the project was consistent with General Plan Policy HP-1.3 including compliance with the Federal Native American Graves Protection and Repatriation Act, and as such, impacts were determined to be less than significant.

As concluded in the Adopted MND and the site-specific Paleontological Assessment conducted by Brian F. Smith and Associates ( Technical Appendix G ) in 2021, there is no evidence that paleontological resources exist on the subject property. Notwithstanding, the Adopted MND and the Paleontological Assessment acknowledged that ground-disturbing activities may have the potential to uncover previously undiscovered resources, including unique paleontological resources or unique geologic features.

Consistent with the project evaluated by the Adopted MND, the proposed Project would be consistent with the City’s General Plan Policy HP-1.3, which ensures protection of sites of archaeological and paleontological significance and ensures compliance with all applicable State and federal cultural resources protection and management laws.

As required by the Adopted MND, the Project applicant is required to comply with Adopted MND Mitigation Measures (MM) MM CR-3 and MM CR-4, in the event that a resource is discovered during ground-disturbing construction activities. Therefore, consistent with the Adopted MND, impacts remain less than significant with implementation of mitigation. Thus, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-48

5.1.8 Greenhouse Gas Emissions

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
VIII. GREENHOUSE GAS EMISSIONS. WOULD THE PROJECT:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
܆ ܆ ܈ ܆
b. Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse gases?
܆ ܆ ܈ ܆

a) Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
(Source: GHG Analysis prepared by Yorke Engineeri ng, LLC on March 2015, Greenhouse Gas Analysis prepared by Urban Crossroads, Inc. on October 26, 2021)

No Substantial Change from Previous Analysis:

The Project involves the construction and operation of one 115,526 s.f. warehouse building and associated improvements. To accomplish the Project, the vacant site and the location of an adjacent car wash facility would be developed, which would entail demolition of the car wash structure and its associated improvements. The Project Applicant would not construct the previously entitled commercial buildings, the vehicle fuel station or the vehicle wash facility, but would construct the previously entitled industrial building, at a slightly larger size than previously approved. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND. The operational characteristics associated with the proposed warehouse use (e.g., traffic and traffic-related impacts) are less intensive than the commercial and industrial land uses evaluated for the Project site as part of the Adopted MND.

The Adopted MND concluded that because the project evaluated in the MND is consistent with the City’s General Plan, the project would not interfere with the State’s goals of reducing greenhouse gas emissions to 1990 levels by the year 2020 as stated in AB 32 and an 80 percent reduction in GHG emissions below 1990 levels by 2050 as stated in Executive Order S-3-05. In addition, the Adopted MND concluded that emissions resulting from the project were expected to be far lower than the SCAQMD thresholds for significance and impacts were determined to be less than significant in regard to GHG emissions.

A Greenhouse Gas Analysis was prepared for the proposed Project in 2021 and is attached to this Addendum as Technical Appendix F. The analysis provides a comparison of the emissions disclosed in the

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-49
Adopted MND to the emissions anticipated in association with the proposed Project’s industrial uses. The annual GHG emissions associated with the operation of the proposed Project are summarized in Table 5- 6, Project GHG Emissions. As shown, construction and operation of the proposed Project would generate approximately 1,349.01 metric tons of carbon dioxide equivalent per year (MTCO2e/yr.). Thus, the proposed Project would not exceed the SCAQMD/City’s screening threshold of 3,000 MTCO2e/yr.; therefore, Project-related GHG emissions would not have a significant direct or indirect impact on GHG and climate change and no mitigation or further analysis is required. (Urban Crossroads, Inc., 2021a, pp. 47, 49)

Project GHG Emissions

(Urban Crosssroads, Inc., 2021b, Table 2-6)

The estimated GHG emissions for Project buildout conditions relative to the currently approved Project disclosed in the Adopted MND are summarized in Table 5-7, Adopted MND GHG Emissions. As shown in Table 5-8,
GHG Emissions Comparison, the proposed Project is anticipated to generate fewer GHG emissions as compared to emissions generated by the currently approved uses. (Urban Crosssroads, Inc., 2021b, pp. 47-48)

Adopted MND GHG Emissions

(Urban Crosssroads, Inc., 2021b, Table 5-7)

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-50
GHG Emissions Comparison

(Urban Crosssroads, Inc., 2021b, Table 5-8)

Because the proposed Project would generate fewer GHG emissions than the project evaluated by the Adopted MND, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. Consistent with the Adopted MND, impacts would remain less than significant. The proposed Project also would be subject to all applicable regulatory requirements addressing GHG emissions. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND.

b) Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
(Source: GHG Analysis prepared by Yorke Engineeri ng, LLC on March 2015, Greenhouse Gas Analysis prepared by Urban Crossroads, Inc. on October 26, 2021)

No Substantial Change from Previous Analysis:

The City of Riverside collaborated with the Western Riverside Council of Governments (WRCOG) on a Subregional Climate Action Plan (CAP). The City of Riverside Restorative Growthprint Climate Action Plan (RRG CAP) builds on the WRCOG Subregional CAP commitments and provides the City GHG reduction goals beyond 2020 to 2035. Through the WRCOG Subregional CAP process, the City has adopted a 2020 community-wide GHG emissions target of 2,224,908 MTCO2e, which represents a 15% reduction from the City’s 2010 GHG emissions baseline inventory, and a 2035 emissions target of 1,532,274 MTCO2e, 49% below the 2007 baseline. These reduction targets are consistent with the statewide AB 32 goal of reducing emissions to 1990 levels and fulfill the requirements of SB 375. (Urban Crosssroads, Inc., 2021b, p. 38)

Based on a review of the proposed Project, the proposed Project would not conflict with any of the GHG reduction strategies set forth in the RRG-CAP (Urban Crosssroads, Inc., 2021b, pp. 55-62). The proposed Project is consistent with CARB’s Final 2017 Scoping Plan Update, which reflects the 2030 target of a 40% reduction below 1990 levels set by Executive Order B-30-15 and codified by Senate Bill 32 (SB 32) (Urban Crosssroads, Inc., 2021b, pp. 49-55) There are no other applicable plans, policies, or regulations adopted for the purpose of reducing GHG emissions that apply to the Project area. Furthermore, and as discussed under Response (a) above, the proposed Project would generate only 1,347.81 MTCO2e/yr, resulting in a reduction of 615.09 MTCO2e/yr. as compared to the level of emissions that were disclosed for the Project analyzed in the Adopted MND. Because the proposed Project would be consistent with the applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases, consistent with the Adopted MND, impacts would remain less than significant and the proposed

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Project would result in fewer GHG emissions than the project disclosed in the Adopted MND. The proposed Project also would be subject to all applicable regulatory requirements addressing GHG emissions. Therefore, the Project would not result in any new impacts not already analyzed in Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND.

5.1.9 Hazards and Hazardous Materials

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
IX. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a. Create a significant hazard to the public or the
environment through the routine transport,
use, or disposal of hazardous materials?
܆ ܆ ܈ ܆
b. Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
܆ ܆ ܈ ܆
c. Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile
of an existing or proposed school?
܆ ܆ ܆ ܈
d. Be located on a site which is included on a list
of hazardous materials sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment?
܆ ܆ ܆ ܈
e. For a project located within an airport land
use plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project result
in a safety hazard or excessive noise for
people residing or working in the project
area?
܆ ܆ ܈ ܆
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation plan?
܆ ܆ ܈ ܆

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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
܆ ܆ ܆ ܈

a) Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? (Source: General Plan 2025 Public Safety Element, GP 2025 FPEIR, California Health and Safety Code, Title 49 of the Code of Federal Regulations, California Building Code, Riverside Fire Department EOP, 2002 and Riverside Operational Area – Multi-Jurisdictional LHMP, 2004 Part 1, OEM’s Strategic Plan, Phase I Environmental Site Assessment prep ared by HMC on December 14, 2020, Phase II Environmental Site Assessment prepared by HMC on January 7, 2021)

No Substantial Change from Previous Analysis:

Regarding existing site conditions, the Phase I ESA prepared for the Project site in 2020 by HMC disclosed that releases of gasoline at the adjacent ARCO station poses a potential vapor intrusion condition to the site. In 2021, HMC conducted a Limited Phase II Soil Vapor Investigation at the site targeting the area west of the ARCO facility. The Limited Phase II Soil Vapor Investigation disclosed the presence of elevated concentrations of VOCs in soil gas above vapor intrusion screening levels. With implementation of the Project’s design features, vapor intrusion levels would be at acceptable screening levels.

Regarding construction activity, the Project Applicant would not construct the previously entitled commercial buildings, the vehicle fuel station or the vehicle wash facility, but would construct the previously entitled industrial building, at a larger size than previously approved. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND. Therefore, the Project would not result in any increased impacts due to significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials during the construction phase as compared to what was evaluated and disclosed by the Adopted MND. With respect to the routine transport, use, or disposal of hazardous materials, the operational characteristics of the uses proposed by the Project Applicant is consistent with the industrial use proposed for the project evaluated in the Adopted MND. Consistent with the findings of the Adopted MND, through compliance with all applicable federal and State laws, the likelihood and severity of accidents would be reduced and impacts would remain less than significant.

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Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
(Source: General Plan 2025 Public Safety Element, GP 2025 FPEIR, California Health and Safety Code, Title 49 of the Code of Federal Regulations, California Building Code, Riverside Fire Department EOP, 2002 and Riverside Operational Area – Multi-Jurisdictional LHMP, 2004 Part 1, OEM’s Strategic Plan, Phase I Environmental Site Assessment prep ared by HMC on December 14, 2020, Phase II Environmental Site Assessment prepared by HMC on January 7, 2021)

No Substantial Change from Previous Analysis:

Consistent with the conclusion reached by the Adopted MND, because the Project Applicant is required to comply with all applicable federal and State laws, the Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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c) Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? (Source: General Plan 2025 Public Safety and Ed ucation Elements, GP 2025 FPEIR Table 5.7-D - CalARP RMP Facilities in the Project Area, Figure 5.13-2 – RUSD Boundaries, Table 5.13-D RUSD Schools, Figure

5.13-3 AUSD Boundaries, Table 5.13-E AUSD Schools, Figure 5.13-4 – Other School District Boundaries, California Health and Safety Code, Title 49 of the Code of Federal Regulations, California Building Code)

No Substantial Change from Previous Analysis:

As noted in the Adopted MND, there are no existing or proposed schools within one-quarter mile of the Project site. The nearest existing school is the Pacific View Charter School, located approximately 1.1 mile southeast of the Project site. Because the Project site is not located within one-quarter mile of a school and the Project is not associated with the storage, use, or handling of hazardous materials, substance, or waste, consistent with the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
(Source: General Plan 2025 Figure PS-5 – Haza rdous Waste Sites, GP 2025 FPEIR Tables 5.7-A – CERCLIS Facility Information, Figure 5.7-B – Regulated Facilities in TRI Information and 5.7-C – DTSC EnviroStor Database Listed Sites)

No Substantial Change from Previous Analysis:

Consistent with the conclusion reached by the Adopt ed MND, there are no known existing hazardous material conditions on the site and the Project site is not located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Consistent with the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? (Source: General Plan 2025 Figure PS-6 – Airport Safety Zones and Influence Areas, March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan, Airport Land Use Commission (ALUC) Development Review dated April 8, 2021; File No. ZAP1452MA21)

No Substantial Change from Previous Analysis:

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8, 2021 to ensure the Project is consistent with the compatibility zone as well as in compliance with the land use standards in the RCALUCP. Consistent with the findings of the Adopted MND, because the Project would be consistent with the ALUC, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area, and impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
(Source: GP 2025 FPEIR Chapter 7.5.7 – Hazards and Hazardous Materials)

No Substantial Change from Previous Analysis:

As concluded in the Adopted MND, the project will be served by existing, fully improved streets, as well as a network of on-site local streets and drive aisles. All streets have been designed to meet the Public Works and Fire Departments’ specifications. Consistent with the Adopted MND, any street closing needed during the Project’s construction would be of short duration so as not to interfere or impede with any emergency response or evacuation plan. Therefore, consistent with the Adopted MND, the Project would have a less than significant impact to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
(Source: General Plan 2025 Figure PS-7 – Fire Hazard Areas, GIS Map Layer VHFSZ 2010)

No Substantial Change from Previous Analysis:

Consistent with the finding of the Adopted MND, because the Project site is not located near any wildland fire hazard zones, the Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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5.1.10 Hydrology and Water Quality

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
X. HYDROLOGY AND WATER QUALITY. Would the project:
a. Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?
܆ ܆ ܈ ܆
b. Substantially decrease groundwater supplies
or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?
տ ܆ ܈ ܆
c. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would:
տ ܆ ܈ ܆
I. Result in substantial erosion or siltation on-
or off-site; տ տ ܈ ܆
II. Substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or offsite;
տ տ ܆ ܈
III. Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
տ տ ܈ ܆
IV. Impede or redirect flood flows? տ տ ܈ ܆
d. In flood hazard, tsunami, or seiche zones, risk
the release of pollutants due to project
inundation?
տ տ ܆ ܈
e. Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
տ տ ܆ ܈

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-57
a) Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? (Source: GP 2025 FPEIR Table 5.8-A – Beneficial Uses Receiving Water and Project Specific Hydrology Study and/or Water Quality Management Plan prepared by SDH & Associates, Preliminary Hydrology Calculations prepared by Thienes Engineering and dated January 19, 2021, Project Specific Water Quality Management Plan prepared by Thienes Engineering and dated March 2021)

No Substantial Change from Previous Analysis:

The California Porter-Cologne Water Quality Control Act (§ 13000 [“Water Quality”] et seq., of the California Water Code), and the Federal Water Pollution Control Act Amendment of 1972 (also referred to as the Clean Water Act [CWA]) require that comprehensive water quality control plans be developed for all waters within the State of California. The Project site is located within the jurisdiction of the Santa Ana Regional Water Quality Control Board (RWQCB). Consistent with the conditions that existed when the Adopted MND was adopted, the Project Applicant would be required to comply with the Santa Ana RWQCB’s Santa Ana River Basin Water Quality Control Plan.

A specific provision of the CWA applicable to the proposed Project is CWA Section 402, which authorizes the National Pollutant Discharge Elimination System (NPDES) permit program that covers point sources of pollution discharging to a water body. The NPDES program also requires operators of construction sites one acre or larger to prepare a Stormwater Pollution Prevention Plan (SWPPP) and obtain authorization to discharge stormwater under an NPDES construction stormwater permit. These requirements have not substantially changed since the Adopted MND was adopted.

Construction activities would occur on the same site and in a similar manner as assumed by the Adopted MND. As with the project evaluated by the Adopted MND, construction of the proposed Project would involve clearing, grading, paving, utility installation, building construction, and landscaping activities, which would result in the generation of potential water quality pollutants such as silt, debris, chemicals, paints, and other solvents with the potential to adversely affect water quality. As such, short-term water quality impacts have the potential to occur during construction of the Project in the absence of any protective or avoidance measures. However, pursuant to the requirements of the Santa Ana RWQCB, and consistent with the requirements that were in effect when the Adopted MND was adopted, the Project Applicant would be required to obtain a NPDES Municipal Stormwater Permit for construction activities.

The NPDES permit is required for all projects that include construction activities, such as clearing, grading, and/or excavation that disturb at least one acre of total land area. Compliance with the NPDES permit involves the preparation and implementation of a SWPPP for construction-related activities, and these requirements also would have applied to new development at the time the Adopted MND was adopted.

The SWPPP is required to specify the best management practices (BMPs) that the Project Applicant would be required to implement during construction activities to ensure that all potential pollutants of concern are prevented, minimized, and/or otherwise appropriately treated prior to being discharged from the subject property. As with the project evaluated in the Adopted MND, mandatory compliance with the SWPPP would ensure that the proposed Project does not violate any water quality standards or waste discharge requirements during construction activities. Therefore, with mandatory adherence to the

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required SWPPP, water quality impacts associated with construction activities would remain less than significant and no mitigation measures would be required.

For long-term operating conditions, the Project Applicant would be required to implement its site-specific Water Quality Management Plan (WQMP), pursuant to the requirements of the applicable NPDES permit.

The WQMP is a post-construction management program that ensures the on-going protection of the watershed basin by requiring structural and programmatic controls. The WQMP requires the implementation of structural control measures (e.g., detention basins) and operational source control measures (e.g., requirements for regular sweeping of parking areas, etc.). The structural and operational source control measures would minimize, prevent, and/or otherwise appropriately treat storm water runoff flows before they are discharged from the site. Mandatory compliance with the WQMP would ensure that the Project does not violate any water quality standards or waste discharge requirements during long-term operation.

Based on the foregoing analysis, and consistent with the conclusion reached by the Adopted MND, the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
(Source: General Plan 2025 Table PF-1 – RPU Projected Domestic Water Supply (AC-FT/YR), Table PF-2 – RPU Projected Water Demand, Table PF-3 – Wester n Municipal Water District Projected Domestic Water Supply (AC-FT/YR), RPU Map of Water Supply Basins, RPU Urban Water Management Plan, WMWD Urban Water Management Plan, Preliminary Hydrology Calculations prepared by Thienes Engineering and dated January 19, 2021, Project Specific Water Quality Management Plan prepared by Thienes Engineering and dated March 2021 )

No Substantial Change from Previous Analysis:

Consistent with the Adopted MND, the Project site is located within the Riverside South Water Supply Basin and is required to connect to the City’s sewer system and comply with all NPDES and WQMP requirements, which would ensure the Project would not substantially deplete groundwater supplies or interfere with groundwater rech arge such that the Project may impede sustainable groundwater management of the basin. As such and consistent with the conclusion reached by the Adopted MND, Project impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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c) Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner in which would:

I. Result in substantial erosion or siltation on- or off-site; (Source: Preliminary Grading Plan, Preliminary Hydr ology Calculations prepared by Thienes Engineering and dated January 19, 2021, Project Specific Water Quality Management Pla n prepared by Thienes Engineering and dated March 2021)

No Substantial Change from Previous Analysis:

The Adopted MND concluded that the Project would not alter the existing drainage pattern of the site, alter the course of stream or river, or increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site and with compliance with the NPDES requirements, a SWPP, and WQMP, impacts would be less than significant.

The Preliminary Hydrology Calculations and the WQMP prepared in 2021, conclude that the proposed condition drainage pattern mimics the pre-development conditions and runoff would continue to drain to the existing offsite public storm drain located east of the northbound ramp and west of the Project site.

The Project is designed to ensure that runoff from the site would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite. Based on the foregoing and consistent with the findings of the Adopted MND, the Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in substantial erosion of on or off-site. Consistent with the Adopted MND, impacts would remain less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

II. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
(Source: Preliminary Grading Plan, Preliminary Hydr ology Calculations prepared by Thienes Engineering and dated January 19, 2021, Project Specific Water Quality Management Pla n prepared by Thienes Engineering and dated March 2021)

The Project is designed to ensure that runoff from the site would not substantially increase the rate or

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amount of surface runoff in a manner which would result in flooding on- or offsite. Based on the foregoing and consistent with the findings of the Adopted MND, the Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off-site, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

III. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or

(Source: Preliminary grading plan, Preliminary Hydrolo gy Calculations prepared by Thienes Engineering, Inc. on February 19, 2021, Project Water Quality Management Plan prepared by Thienes Engineering, Inc. on March 12, 2021)

No Substantial Change from Previous Analysis:

Although minor modifications to the site’s existing topography would occur with implementation of the proposed Project, the Project would not result in substantial alterations to the site’s existing drainage pattern or the planned drainage pattern anticipated by the Adopted MND. An updated drainage study of the site (Technical Appendix H1) also concluded that development of the Project site would not change area drainage patterns or impact any surrounding properties. As mentioned under Response (a) above, the Project Applicant is required to implement a SWPPP and a WQMP, which would ensure that pollutants generated by the Project are treated through the incorporation of site design, and source control and treatment control measures. Because the Project’s drainage pattern would be similar to the project evaluated by the Adopted MND and the Project Applicant is required to implement a SWPPP and WQMP, the Project would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Consistent with the Adopted MND, impacts would remain less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

IV. Impede or redirect flows?

(Source: General Plan 2025 Figure PS-4 – Flood Hazard Areas, FEMA Flood Hazard Maps)

No Substantial Change from Previous Analysis:

As noted by the Adopted MND, the Project site is not located within a flood prone or hazard area and the existing drainage system was designed with capacity to serve the Project. Because the Project site is not located within a flood prone or hazard area and construction activities associated with the proposed Project would be similar to the construction anticipated for the Project site by the Adopted MND, the Project would not substantially alter the existing drain age pattern of the site or area, including through

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-61
the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) In flood hazard, tsunami, or seiche zones, would the proposed Project risk the release of pollutants due to project inundation?
(Source: GP 2025 FPEIR Chapter 7.5.8 – Hydrology and Water Quality)

No Substantial Change from Previous Analysis:

The Project site is located approximately 40 miles from the Pacific Ocean, and is therefore not subject to hazards associated with tsunamis. Additionally, there are no large bodies of water within the Project site’s vicinity that are capable of producing seiches that could affect the Project site. In addition, according to the Federal Emergency Management Agency, the Project site is not located within a flood prone or hazard area. Because the Project site is located approximately 40 miles from the Pacific Ocean and there are no large bodies of water within the Project site’s vicinity, the Project would not flood and would not risk release of pollutants due to Project site inundation as a result of flood, tsunami, or seiche hazards.

Consistent with the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Would the proposed Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
(Source: General Plan 2025 Table PF-1 – RPU Projected Domestic Water Supply (AC-FT/YR), Table PF-2 – RPU Projected Water Demand, Table PF-3 – Wester n Municipal Water District Projected Domestic Water Supply (AC-FT/YR), RPU Map of Water Supply Basins, RPU Urban Water Management Plan, WMWD Urban Water Management Plan)

No Substantial Change from Previous Analysis:

In 2014, the State of California enacted into law the Sustainable Groundwater Management Act (SGMA), which is intended to establish a framework for sustainable groundwater management. The SGMA requires governments and water agencies of high and medium priority basins to halt overdraft and bring groundwater basins into balanced levels of pumping and recharge. The Project Applicant would be subject to compliance with the City’s Urban Water Management Plan (UWMP) and the Integrated Regional Water Management Plan (IRWMP). The purpose of the UWMP and IRWMP is to provide safe, adequate, and dependable water supplies in order to meet the future needs of the metropolitan area in an economical manner; protect groundwater quality from further degradation and overdraft; and, provide a plan of reasonably implementable measures and facilities. The Project Applicant also would be subject to compliance with the City’s NPDES Permit. Refer also to the analysis of Responses (a) and (b), above.

Consistent with the findings of the Adopted MND, because the Project Applicant would comply with the City’s UWMP, IRWMP, and NPDES Permit, the Project would not conflict with or obstruct implementation

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-62
of a water quality control plan or sustainable groundwater management plan, and no impact would occur.

5.1.11 Land Use and Planning

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XI. LAND USE AND PLANNING. Would the project:
a. Physically divide an established community? ܆ ܆ ܆ ܈
b. Cause a significant environmental impact due
to a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding
or mitigating an environmental effect?
܆ ܆ ܈ ܆

a) Would the physically divide an established community? (Source: General Plan 2025 Land Use and Urban Design Element, Project Site Plan)

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project described in the Adopted MND in terms of physical location. Consistent with the findings of the Adopted MND, the Project site is currently undeveloped and is located in an area planned for commercial and industrial uses. A gas station with car wash facility is located to the east. While scattered residential uses occur to the east of the Project site, area to the north is planned and zoned for industrial development, and roadways border the Project site to the south and to the west. Because the Project site is not located within an established community or within the vicinity of an established community, the Project has no potential to physically divide an established community, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
(Source: General Plan 2025, General Plan 2025 Figure LU-10 – Land Use Policy Map, Table LU-5 – Zoning/General Plan Consistency Matrix, Figure LU-7 – Redevelopment Areas, Sycamore Canyon Business Park Specific Plan, Title 19 – Zoning Code, Titl e 18 – Subdivision Code, Title 7 – Noise Code, Title 17 –

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Grading Code, Title 20 – Cultural Resources Code, Title 16 – Buildings and Construction and Citywide Design and Sign Guidelines)

No Substantial Change from Previous Analysis:

The Adopted MND anticipated development of one 73,200 s.f. industrial building, two 4,000 s.f. commercial buildings, a 7,000 s.f. commercial building, a 2,572 s.f. diesel canopy and relocation of an existing 880 s.f. automated car wash. The Project includes an amendment to the City of Riverside General Plan Land Use Map that would change the Project site’s land use designation from “Commercial” to “Business/Office Park.” Approval of the requested General Plan Amendment would eliminate any potential inconsistency between proposed land uses and the site’s existing land use designations. There are no environmental impacts that would result as a specific consequence of the proposed changes to the site’s General Plan land use designation, beyond what is already evaluated and disclosed by this MND Addendum.

The Project also includes a Zone Change Amendment to amend the City of Riverside Zoning Map to change the zoning classification of the Project site from CR-SP - Commercial Retail and Specific Plan (Sycamore Canyon Business Park) Overlay Zones to BMP-SP - Business and Manufacturing Park and Specific Plan (Sycamore Canyon Business Park) Overlay Zones. Approval of the requested Zone Change Amendment would eliminate any potential inconsistency between the proposed Project and the its underlying zoning classifications. The Project would not conflict with any development regulations and design standards in the Zoning Ordinance, and there are no components of the Project’s proposed Zone Change Amendment that would result in impacts not already evaluated and disclosed by this MND Addendum.

The Project also includes a Specific Plan Amendment to amend the Sycamore Canyon Business Park Specific Plan to change the land use subarea from industrial support to industrial to allow for warehouse development. Approval of the requested Specific Plan Amendment would eliminate any potential inconsistency between the proposed Project and its underlying permitted land use. The Project would not conflict with any development regulations and design standards in the Specific Plan, and there are no components of the Project’s proposed Specific Plan Amendment that would result in impacts not already evaluated and disclosed by this MND Addendum.

Lastly, the Project would be subject to all applicable development standards of the City of Riverside Municipal Code, as well as applicable policies of the General Plan and Sycamore Canyon Business Park Specific Plan. Consistent with the findings of the Adopted MND, the proposed Project, including the design and improvement of the subject property, would be consistent with the goals, objectives and policies of the applicable City of Riverside General Plan and Sycamore Canyon Business Park Specific Plan; would be safe from potential cause or introduction of serious public health problems; and, would not conflict with any public interests in the subject property or adjacent lands. The Project site also is suitable for the type and intensity of development proposed. Based on the foregoing and consistent with the conclusion reached in the Adopted MND, the Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and impacts would be less than significant. Therefore, the Project

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would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.12 Mineral Resources

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XII. MINERAL RESOURCES. Would the project:
a. Result in the loss of availability of a known
mineral resource that would be of value to the
region or the residents of the State?
܆ ܆ ܆ ܈
b. Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific plan
or other land use plan?
܆ ܆ ܆ ܈

a) Would the proposed Project result in the loss of availability of a known mineral resource that would be of value to the region or the residents of the State? (Source: General Plan 2025 Figure – OS-1 – Mineral Resources)

No Substantial Change from Previous Analysis:

As evaluated in the Adopted MND, according to the California Geological Survey mapping, the Project site is located in the MRZ-3 Mineral Resource Zone (MRZ), which is defined as “Areas containing mineral deposits the significance of which cannot be evaluated from available data.” No mineral extraction activities are currently taking place within the Project site and there are no specific areas within the City of Sphere Area which have locally-important mineral resource recovery sites. Consistent with the determination in the Adopted MND, the proposed Project would not result in the loss of availability of a known mineral resource that would be of value to the region or the residents of the State. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the proposed Project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? (Source: General Plan 2025 Figure – OS-1 – Mineral Resources)

No Substantial Change from Previous Analysis:

As evaluated in the Adopted MND, according to the California Geological Survey mapping, the Project site is located in the MRZ-3, which is defined as “Areas containing mineral deposits the significance of which

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cannot be evaluated from available data.” No mineral extraction activities are currently taking place within the Project site and there are no specific areas with the City of Sphere Area which have locally-important mineral resource recovery sites. Consistent with the determination in the Adopted MND, the proposed Project would not result in the loss of availability of a locally important resource recovery site delineated on a local general plan, specific plan, or other land use plan. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.13 Noise

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XIII. NOISE. Would the project cause:
a. Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan, noise ordinance, or applicable
standards of other agencies?
܆ ܆ ܈ ܆
b. Generation of excessive ground-borne
vibration or ground-borne noise levels? ܆ ܆ ܈ ܆
c. For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been adopted,
within two miles of a public airport or public
use airport, would the project expose
people residing or working in the project
area to excessive noise levels?
܆ ܆ ܈ ܆

a) Would the proposed Project cause generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan, noise ordinance, or applicable standards of other agencies? (Source: General Plan Figure N-1 – 2003 Roadway Noise, Figure N-2 – 2003 Freeway Noise, Figure N-3 – 2003 Railway Noise, Figure N-5 – 2025 Roadway Noise, Figure N-6 – 2025 Freeway Noise, Figure N-7 – 2025 Railroad Noise, Figure N-8 – Riverside and Fl abob Airport Noise Contours, Figure N-9 – March ARB Noise Contours, Figure N-10 – Noise/Land Use Noise Compatibility Criteria, FPEIR Table 5.11-I – Existing and Future Noise Contour Comparison, Table 5.11-E – Interior and Exterior Noise Standards, Appendix G – Noise Existing Conditions Report, Title 7 – Noise Co de, Project Specific Noise Study/Acoustical Analysis

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prepared by Acoustics Group, Inc., Noise Impact Analysis prepared by Urban Crossroads, Inc. on October 18, 2021)

No Substantial Change from Previous Analysis:

The Project involves the construction and operation of one 115,526 s.f. warehouse building and associated improvements. To accomplish the Project, the vacant site and the location of an adjacent car wash facility would be developed, which would entail demolition of the car wash structure and its associated improvements. The Project Applicant would not construct the previously entitled commercial buildings, the vehicle fuel station or the vehicle wash facility, but would construct the previously entitled industrial building, at a larger size than previously approved. The proposed Project would not develop or disturb any additional property that was not assumed to be developed by the Adopted MND and the proposed Project’s construction equipment and construction duration would be similar to the Project that was evaluated by the Adopted MND. The operational characteristics associated with the proposed warehouse use (e.g., traffic and traffic-related impacts) are less intensive than the commercial and industrial land uses evaluated for the Project site as part of the Adopted MND.

The Adopted MND concluded that per Implementation Tool N-1 of the General Plan 2025 Noise Element, the project was reviewed to ensure that noise standards and compatibility issues were addressed. The acoustical analysis for the project concluded that the project would meet the City’s noise standards as set forth in Title 7 of the Municipal Code and was compliant with the Noise/Land Use Noise Compatibility Criteria Matrix (Figure N-10) of the Noise Element. Impacts were determined to be less than significant.

Construction Noise Impact Analysis
In 2021, Urban Crossroads prepared a Noise Impact Analysis ( Technical Appendix I) for the proposed Project. To evaluate whether the proposed Project would generate potentially significant short-term noise levels at nearest receiver locations, a construction-related daytime noise level threshold of 80 dBA Leq is used as a reasonable threshold to assess the daytime construction noise level impacts. As disclosed in the Project’s Noise Impact Analysis, according the City of Riverside Municipal Code Section 7.35.020 (G), Project construction noise levels are considered exempt from municipal regulation if noise level activity, associated with construction, repair, remodeling, or grading of any real property; provided a permit has been obtained from the City as required; do not take place between the hours of 7:00 p.m. and 7:00 a.m. on weekdays, between the hours of 5:00 p.m. and 8:00 a.m. on Saturdays, or at any time on Sunday or a federal holiday.

The Project’s construction noise analysis shows that the nearest receiver locations would satisfy the reasonable daytime 80 dBA Leq significance threshold during Project construction activities as shown on Table 5-9, Typical Construction Noise Analysis . Therefore, the noise impacts due to Project construction noise is considered less than significant at all receiver locations. In addition, consistent with the project evaluated in the Adopted MND, per Implementation Tool N-1 of the General Plan 2025 Noise Element, the proposed Project was reviewed to ensure that noise standards and compatibility issues were addressed. The acoustical analysis concluded that the proposed Project would meet the City’s noise standards as set forth in Title 7 of the Municipal Code and was compliant with the Noise/Land Use Noise Compatibility Criteria Matrix (Figure N-10) of the Noise Element.

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Typical Construction Noise Analysis

1 Noise receiver locations are identified in Exhibit 9-A of Technical Appendix I. 2 Highest construction noise level calculations based on distance from the construction noise source activity to the nearest receiver locations as shown on Table 9-2 of Technical Appendix I. 3 Construction noise level thresholds as shown on Table 4-1 of Technical Appendix I. 4 Do the estimated Project construction noise levels exceed the construction noise level threshold? (Urban Crossroads, Inc., 2021c, Table 5-9)

Operational Noise Impact Analysis
To demonstrate compliance with local noise regulations, Urban Crossroads evaluated the Project-only operational noise levels against exterior noise level thresholds based on the City of Riverside exterior noise level standards at nearby noise-sensitive receiver locations. As shown on Table 5-10, Operational Exterior Noise Level Compliance shows that the operational noise levels associated with the proposed Project would satisfy the City of Riverside and the City of Moreno Valley daytime and nighttime exterior noise level standards at all nearby receiver locations. Therefore, the operational noise impacts are considered less than significant at the nearby noise sensitive receiver locations. In addition, the interior noise levels will satisfy the City of Riverside daytime and nighttime interior sound level limits for Receiver R2 located in the City of Riverside. The City of Moreno Valley does not maintain any interior noise level limits for receivers R1 and R3. Thus, the Project’s operational noise impacts are considered to be less than significant at the nearby noise sensitive receivers. (Urban Crossroads, Inc., 2021c, p. 32)

Operational Exterior Noise Level Compliance

1 See Exhibit 7-A of Technical Appendix I for the receiver locations. 2 Proposed Project operational noise levels as shown on Tables 8-3 and 8-4 of Technical Appendix I. 3 Exterior noise level standards, as shown on Table 4-1 of Technical Appendix I. 4 Do the estimated Project operational noise source activities exceed the noise level standards? "Daytime" = 7:00 a.m. - 10:00 p.m.; "Nighttime" = 10:00 p.m. - 7:00 a.m. (Urban Crossroads, Inc., 2021c, Table 8-5)

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In addition, as shown in Table 5-11, Daytime Project Operational Noise Level Increases and Table 5-12, Nighttime Operational Noise Location Increases, the proposed Project would not generate a daytime and nighttime operational noise level increase at the nearby receiver locations. Therefore, the Project-related operational noise level increase would satisfy the operational noise level significance criteria (see Table 4-1 of Technical Appendix I for the significance criteria summary). Therefore, the incremental Project- related operational noise level increase would be less than significant at all receiver locations. (Urban Crossroads, Inc., 2021c, p. 33)

Daytime Project Operational Noise Level Increases

1 See Exhibit 7-A of Technical Appendix I for the receiver locations. 2 Total Project daytime operational noise levels as shown on Table 8-3 of Technical Appendix I. 3 Reference noise level measurement locations as shown on Exhibit 5-A of Technical Appendix I. 4 Observed daytime ambient noise levels as shown on Table 5-1 of Technical Appendix I. 5 Represents the combined ambient conditions plus the Project activities. 6 The noise level increase expected with the addition of the proposed Project activities. 7 Significance increase criteria as shown on Table 4-1 of Technical Appendix I. (Urban Crossroads, Inc., 2021c, Table 8-6)

Nighttime Operational Noise Location Increases

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-69
7 Significance increase criteria as shown on Table 4-1 of Technical Appendix I. (Urban Crossroads, Inc., 2021c, Table 8-7)

b) Would the proposed Project cause generation of excessive ground-borne vibration or ground- borne noise levels?
(Source: General Plan Figure N-1 – 2003 Roadway Noise, Figure N-2 – 2003 Freeway Noise, Figure N-3 – 2003 Railway Noise, Figure N-5 – 2025 Roadway Noise, Figure N-6 – 2025 Freeway Noise, Figure N-7 – 2025 Railroad Noise, Figure N-8 – Riverside and Fl abob Airport Noise Contours, Figure N-9 – March ARB Noise Contours, FPEIR Table 5.11-G – Vibration Sour ce Levels For Construction Equipment, Appendix G – Noise Existing Conditions Report, Project Specific Noi se Study/Acoustical Analysis prepared by Acoustics Group, Inc., Noise Impact Analysis prepared by Urban Crossroads, Inc. on October 18, 2021)

No Substantial Change from Previous Analysis:

The Adopted MND concluded that the project evaluated by the Adopted MND was in compliance with the City’s noise standards and found impacts related to groundborne vibration and groundborne noise levels as a result of the project to be less than significant.

In 2021 as part of the Noise Impact Analysis for the proposed Project, Urban Crossroads’ analysis shows that construction equipment vibration levels would satisfy the building damage thresholds at all receiver locations. In addition, the typical construction vibration levels at the nearest sensitive receiver locations are unlikely to be sustained during the entire construction period but would occur rather only during times that heavy construction equipment is operating adjacent to the Project site perimeter. (Urban Crossroads, Inc., 2021c, p. 43, Table 9-5)

Construction and operational activities associated with the proposed Project would not result in the generation of excessive groundborne vibration or groundborne noise levels beyond what was evaluated and disclosed by the Adopted MND. Furthermore, construction-related vibration is unlikely to be sustained during the entire construction period but would occur rather only during the times that heavy construction equipment is operating adjacent to the Project site perimeter. Table 5-13, Construction Equipment Vibration Levels, presents the expected typical construction equipment vibration levels at the nearest receiver locations. At distances ranging from 43 feet to 598 feet from typical Project construction activities (at the Project site boundary), construction vibration levels are estimated to range from 45.6 to

79.9 VdB and will remain below the FTA Transit Noise and Vibration Impact Assessment Manual maximum acceptable vibration criteria of 80 VdB for daytime residential uses at all receiver locations. Therefore, the Project-related vibration impacts are considered less than significant during typical construction activities at the Project site. Moreover, the vibration levels reported at the sensitive receiver locations are unlikely to be sustained during the entire construction period but will occur rather only during the times that heavy construction equipment is operating adjacent to the Project site perimeter. (Urban Crossroads, Inc., 2021c, p. 43) Accordingly, the Project would not result in generation of excessive groundborne vibration or groundborne noise levels, and impacts would be less than significant.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-70
Construction Equipment Vibration Levels

1 Noise receiver locations are shown on Exhibit 9-A of Technical Appendix I. 2 Based on the Vibration Source Levels of Construction Equipment included on Table 9-4 of Technical Appendix I. 3 FTA Transit Noise and Vibration Impact Assessment Manual maximum acceptable vibration criteria as shown on Table 4-1 of Technical Appendix I.
4 Does the vibration level exceed the maximum acceptable vibration threshold? (Urban Crossroads, Inc., 2021c, Table 9-5)

c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
(Source: General Plan 2025 Figure N-8 – Riverside and Flabob Airport Noise Contours, Figure N-9 – March ARB Noise Contour, Figure N-10 – Noise/Land Use Noise Compatibility Criteria, March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan, Airport Land Use Commission Riverside County, ALUC Review dated April 8, 2021 (File No. ZAP1452MA21)

No Substantial Change from Previous Analysis:

Consistent with the project evaluated within the Adopted MND, the Project site is located within Compatibility Zone B1 and Accidental Potential Zone 2 (APZ II) of the March Air Reserve Base/Inland Port Airport (MARB/IP Airport). The proposed Project was reviewed by the ALUC on April 8, 2021 to ensure that the Project is consistent with the compatibility zone as well as in compliance with the land use standards in the RCALUCP. Consistent with the findings of the Adopted MND, because the Project would be consistent with the ALUC, there are no components of the proposed Project that would affect existing aircraft or airport operations in the Project vicinity. As such, and consistent with the findings of the Adopted MND, the proposed Project would not expose people residing or working in the project area to excessive noise levels, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-71

5.1.14 Population and Housing

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XIV. POPULATION AND HOUSING. Would the project:
a. Induce substantial population growth in an
area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
܆ ܆ ܆ ܈
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?
܆ ܆ ܆ ܈

a) Would the Project induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
(Source: General Plan 2025 Table LU-3 – Land Use Designations, FPEIR Table 5. 12-A – SCAG Population and Households Forecast, Table 5.12-B – General Plan Population and Employment Projections– 2025, Table 5.12-C – 2025 General Plan and SCAG Comparisons, Table 5.12-D - General Plan Housing Projections 2025)

No Substantial Change from Previous Analysis:

As stated in the Adopted MND, the project is in an urbanized area and does not propose new homes or businesses that would directly induce substantial population growth, and does not involve the addition of new roads or infrastructure that would indirectly induce substantial population growth. In addition, and consistent with the information presented in the Adopted MND, the Project site is located in close proximity to developed areas of the City and water and sewer service are available to serve land uses within the Project area, inclusive of the Project site, and roadways exist in the vicinity of the Project area.

Therefore, the expansion or new construction of public facilities and utilities will be localized and not extend into distant undeveloped areas of the City. In addition, consistent with the or new construction of public facilities and utilities will be localized and not extend into distant undeveloped areas of the City. In addition, consistent with the Adopted MND and as evaluated in Threshold 5.15, Public Services, impacts on public services would be less than significant; thus, the public service provider’s ability to provide services will not be reduced. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-72
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
(Source: Google Earth)

No Substantial Change from Previous Finding:

Consistent with the conditions that existed when the Adopted MND was prepared, the Project site consists of vacant, undeveloped land that does not contain residential housing. Therefore, consistent with the findings of the Adopted MND, the Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. The Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as Previously identified and analyzed in the Adopted MND

5.1.15 Public Services

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XV. PUBLIC SERVICES.

Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times or other performance
objectives for fire protection services?
܆ ܆ ܆ ܈
Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times or other performance
objectives for police protection services?
܆ ܆ ܆ ܈
Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable
܆ ܆ ܆ ܈

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-73

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
service ratios, response times or other performance
objectives for schools?
Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times or other performance
objectives for parks?
܆ ܆ ܆ ܈
Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable
service ratios, response times or other performance
objectives for other public facilities?
܆ ܆ ܆ ܈

a) Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services?
(Source: FPEIR Table 5.13-B – Fire Station Locations, T able 5.13-C – Riverside Fire Department Statistics and Ordinance 5948 § 1)

No Substantial Change from Previous Analysis:

As stated in the adopted MND, adequate fire facilities and services are provided to serve this Project. Fire protection services to the proposed Project would be provided by the City of Riverside Fire Department (RFD), and the nearest RFD fire station (Station 13) occurs approximately 1.1 miles northwest of the Project site. Consistent with the Adopted MND, the proposed Project would be conditioned by the City to provide a minimum of fire saf ety and support fire suppression activities, including compliance with State and local fire codes, fire sprinklers, a fire hydrant system, paved access, and secondary access routes.

Consistent with the finding of the Adopted MND, no impact would occur. The Project would not trigger the need to provide new or physically altered fire stations or other fire protection facilities. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-74
would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services?

(Source: General Plan 2025 Figure PS-8 – Neighborhood Policing Centers)

No Substantial Change from Previous Analysis:

Police protection services to the Project site would be provided by the Riverside Police Department. As stated in the adopted MND, adequate police facilities and services are provided to serve this Project. In addition, with implementation of General Plan 2025 policies, compliance with existing codes and standards, and through Police Department practices, there will be no impact on the demand for additional police facilities or service. Consistent with the finding of the Adopted MND, no impact would occur. The Project would not trigger the need to provide new or physically altered police stations or other law enforcement facilities. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

c) Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for school services?
(Source: FPEIR Figure 5.13-2 – RUSD Boundaries, Tabl e 5.13-D – RUSD, Figure 5.13-3 – AUSD Boundaries, Table 5.13-E – AUSD, Table 5.13-G – Student Generation for RUSD and AUSD by Education Level, and Figure

5.13-4 – Other School District Boundaries)

No Substantial Change from Previous Analysis:

The Project is a non-residential use that would not involve the addition of any housing units that would increase numbers of school age children. Consistent with the Adopted MND, the proposed Project does not involve the construction of any residential dwelling units, and as such only would have an indirect potential to increase the demand for school services in the area. The Project applicant would be required to pay school impact fees to the local school district to offset the potential impacts of increased student enrollment. Pursuant to Senate Bill 50, payment of school impact fees constitutes complete mitigation for project-related impacts to school services. As such, the Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. Consistent with the finding of the Adopted MND, no impact would occur. Therefore, the Project would not result in

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-75
any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks?
(Source: General Plan 2025 Figure PR-1 – Parks, Open Spaces and Trails, Table PR-4 – Park and Recreation Facilities, Parks Master Plan 2003, GP 2025 FPEIR Tab le 5.14-A – Park and Recreation Facility Types, and Table 5.14-C – Park and Recreation Facilities Funded in the Riverside Renaissance Initiative)

No Substantial Change from Previous Analysis:

Consistent with the Adopted MND, the proposed Project is a non-residential use that would not involve the addition of any housing units that would increase the population. Therefore, there would be no impact on the demand for additional park facilities or services. Consistent with the Adopted MND, the proposed Project does not involve the construction of any park facilities or housing that would generate a demand for park facilities. Consistent with the finding of the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities?
(Source: General Plan 2025 Figure LU-8 – Communi ty Facilities, FPEIR Figure 5.13-5 - Library Facilities, Figure 5.13-6 - Community Centers, Table 5.3-F – Riversid e Community Centers, Table 5.13-H – Riverside Public Library Service Standards)

No Substantial Change from Previous Finding:

As stated in the Adopted MND, adequate public facilities and service such as libraries and community centers and are provided to serve this Project. Therefore, the Project would not result in the intensification of land use and there would be no impact on the demand for additional public facilities or services. Consistent with the finding of the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-76

5.1.16 Recreation

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XVI. RECREATION. Would the project:
a. Increase the use of existing neighborhood
and regional parks or other recreational
facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
܆ ܆ ܆ ܈
b. Does the project include recreational facilities
or require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?
܆ ܆ ܆ ܈

a) Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
(Source: General Plan 2025 Figure PR-1 – Parks, Open Spaces and Trails, Table PR-4 – Park and Recreation Facilities, Figure CCM-6 – Master plan of Trails and Bikeways, Parks Master Plan 2003, FPEIR Table 5.14-A – Park and Recreation Facility Types, and Table 5.14-C – Park and Recreation Facilities Funded in the Riverside Renaissance Initiative, Tab le 5.14-D – Inventory of Existing Community Centers, Riverside Municipal Code Chapter 16.60 - Local Park Development Fees, Bicycle Master Plan May 2007)

No Substantial Change from Previous Analysis:

Consistent with the Adopted MND, the Project applicant will pay applicable Park Development Impact Fees to the City of Riverside Parks, Recreation and Community Services Department. Also, consistent with the Adopted MND, the proposed Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Consistent with the finding of the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?? (Source: General Plan 2025 Figure PR-1 – Parks, Open Spaces and Trails, Table PR-4 – Park and Recreation Facilities, Figure CCM-6 – Master plan of Trails and Bikeways, Parks Master Plan 2003, FPEIR Table 5.14-A – Park and Recreation Facility Types, and Table 5.14-C – Park and Recreation Facilities Funded in the

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-77
Riverside Renaissance Initiative, Tab le 5.14-D – Inventory of Existing Community Centers, Riverside Municipal Code Chapter 16.60 - Local Park Development Fees, Bicycle Master Plan May 2007)

No Substantial Change from Previous Finding:

Consistent with the Adopted MND, the Project applicant will pay applicable Park Development Impact Fees to the City of Riverside Parks, Recreation and Community Services Department. Also, consistent with the adopted MND, the proposed Project would not include recreational facilities or require the construction or expansion of recreational facilities that may have an adverse physical effect on the environment. Consistent with the finding of the Adopted MND, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.17 Transportation

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XVII. TRANSPORTATION. Would the project:
a. Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?
܆ ܈ ܆ ܆
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b)? ܆ ܈ ܆ ܆
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible
uses (e.g. farm equipment)?
܆ ܆ ܈ ܆
d. Result in inadequate emergency access? ܆ ܆ ܆ ܈

a) Would the Project conflict with a program, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? (Source: General Plan 2025 Figure CCM-4 – Master Plan of Roadways, FPEIR Figure 5.15-4 – Volume to Capacity (V/C) Ratio and Level of Service (LOS) (Typical 2025), Table 5.15-D – Existing and Future Trip Generation Estimates, Table 5.15-H – Existing and Typical Density Scenario Intersection Levels of Service, Table 5.15-I – Conceptual General Plan Intersection Improvement Recommendations, Table 5.15-J – Current Status of Roadways Projected to Operate at LOS E or F in 2025, Table 5.15.-K – Freeway Analysis

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-78
Proposed General Plan, Appendix H – Circulation Element Traffic Study and Traffic Study Appendix, Trip Generation Assessment prepared by Urban Crossroads, Inc., on May 18, 2021)

No Substantial Change from Previous Analysis:

The Adopted MND determined that roadway capacity is adequate to accommodate the projected traffic volumes of the Project and the Project would operate at better than the required LOS D with implementation of the conditions of approval, and MM-1 Traffic, which would have required the Project to install a second eastbound left turn lane at the signalized intersection of Alessandro Boulevard and the Arco gas station. Based on an evaluation of the currently proposed Project, MM-1 Traffic shall be replaced with a comparable improvement, listed below as modified MM-1 Traffic. Impacts were determined to be less than significant and will remain less than significant with the modified mitigation measure.

MM-1 Traffic: Prior to the issuance of a Certificate of Occupancy, the applicant shall complete street improvement plans including signing and striping plans and traffic signal modification plans related to the widening of the northernly curb of Alessandro Boulevard between the I-215 Freeway Northbound On-Ramp and Project Driveways in order to accommodate a 3rd and 4th westbound lane as recommended in the Traffic Study (Dated July 28, 2022). The applicant shall obtain any necessary permits and approvals from both the City of Riverside and Caltrans District 8 associated with the widening and improvements on Alessandro Boulevard. The applicant is solely responsible for the procurement and installation of the street improvements to the satisfaction of the Director of Public Works.

The proposed Project is consistent with the project described in the Adopted MND in terms of general circulation design, including the proposed shared driveway along the Project site frontage with Alessandro Boulevard. Operationally, the Project evaluated in the Adopted MND anticipated construction of a gasoline service station, shopping center, and manufacturing warehouse uses. The proposed Project would consist of one warehouse building in place of the commercial retail and manufacturing use evaluated in the 2018 Substantial Conformance modification.

In 2021, a Trip Generation Assessment was prepared for the proposed Project, which is included as Technical Appendix J to this MND Addendum. Table 5-14, Trip Generation Comparison, indicates that the Project’s proposed use is anticipated to generate a total of 1,414 fewer two-way trips per day with 35 fewer AM peak hour trips and 57 fewer PM peak hour trips as compared to the currently approved project.

In addition, the Project would contribute fewer than 50 peak hour trips to any off-site intersections.

Therefore, the proposed Project would result in reduced impacts to study area transportation facilities as compared to the project evaluated by the Adopted MND. Because the Project Applicant proposes the same circulation design as the Adopted MND and would generate less traffic trips than the project evaluated in the Adopted MND, the proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

Consistent with the findings of the Adopted MND, impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-79
Trip Generation Comparison

(Urban Crossroads, Inc., 2021d, Table 5)

b) Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
(Source: General Plan 2025 Figure CCM-4 – Master Plan of Roadways, FPEIR Figure 5.15-4 – Volume to Capacity (V/C) Ratio and Level of Service (LOS) (Typical 2025), Table 5.15-D – Existing and Future Trip Generation Estimates, Table 5.15-H – Existing and Typical Density Scenario Intersection Levels of Service, Table 5.15-I – Conceptual General Plan Intersection Improvement Recommendations, Table 5.15-J – Current Status of Roadways Projected to Operate at LOS E or F in 2025, Table 5.15.-K – Freeway Analysis Proposed General Plan, Appendix H – Circulation Element Traffic Study and Traffic Study Appendix, Vehicle Miles Traveled Analysis prepared by Urban Crossroads, Inc. and dated March 15, 2021)

No Substantial Change from Previous Analysis:

CEQA Guidelines § 15064.3(b) includes specific considerations for evaluating a project’s transportation impacts using a Vehicle Miles Travelled (VMT) measure, instead of evaluating impacts based on Level of Service (LOS) criteria, as required by California Senate Bill (SB) 743. LOS has been used as the basis for determining the significance of traffic impacts as standard practice in CEQA documents for decades, including at the time the Adopted MND was adopted in December 2015. In 2013, SB 743 was passed, which is intended to balance the need for LOS for traffic planning with the need to build infill housing and mixed-use commercial developments within walking distance of mass transit facilities, downtowns, and town centers, and to provide greater flexibility to local governments to balance these sometimes- competing needs. In January 2019, the Natural Resources Agency finalized updates to the CEQA Guidelines including the incorporation of the SB 743 modifications. The Guidelines’ changes were approved by the Office of Administrative Law and are now in effect. As such, as of July 1, 2020, LOS can no longer be the basis for determining an environmental effect under CEQA, and the analysis of impacts to transportation is now based on VMTs.

As indicated in Table 5-14, the proposed Project would result in 1,414 fewer daily trips as compared to the project evaluated in the Adopted MND and would therefore not exceed the City’s VMT threshold. (Urban Crossroads, Inc., 2021d, pp. 3-5). Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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c) Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? (Source: Project Site Plans)

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project described in the Adopted MND in terms of general circulation design and providing a shared driveway along the Project site’s frontage with Alessandro Boulevard. Consistent with the project evaluated in the Adopted MND, the Project would not result in or require major improvements to circulation facilities within the City and the geometrics of the Project’s proposed access driveway is consistent with applicable City requirements. Additionally, the Project occurs in an area that is p lanned for long-term develo pment with industrial use s, and the manufacturing warehouse uses proposed as part of the Project would not represent an incompatible use. Because the Project would be consistent with the project evaluated in the Adopted MND in terms of circulation design and compatible use, the Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment), and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project result in inadequate emergency access? (Source: City of Riverside Municipal Code, and Fire Code)

No Substantial Change from Previous Analysis:

The proposed Project would not involve substantial changes to the area’s circulation system, and the Project would be served by a shared driveway along the Project site’s frontage with Alessandro Boulevard.

The Project’s design is required to be reviewed by the RFD as part of the building permit issuance process.

The Project accommodates a fire lane surrounding the proposed building, which would provide for adequate emergency access on the site. Because the Project’s circulation design would provide adequate fire lane access and would comply with the RFD, the Project would not result in inadequate emergency access, and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Addendum to Mitigated Negative Declaration Planning Case No. PR-2020-000519 TT&B Planning, Inc. Page 5-81

5.1.18 Tribal Cultural Resources

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XVIII. TRIBAL CULTURAL RESOURCES. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defines in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California
Register of Historical resources or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k), or;
܆ ܈ ܆ ܆
b. A resource determined by the lead agency, in
its discretion and supported by substantial
evidence, to be significant pursuant to
criteria set forth in subdivision (c) of Public
Resources Code section 5024.1. In applying
for the criteria set forth in (c) of Public
Resources Code Section 5024.1, the lead
agency shall consider the significance of the
resource to a California Native American
tribe.
܆ ܈ ܆ ܆

a) Would the proposed Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defines in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical resources or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? (Source: AB-52 Native Americans: California Environmental Quality Act – California Legislative Information)

No Substantial Change from Previous Analysis:

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Adopted MND has been prepared for the Project pursuant to § 15164 of the CEQA Guidelines, and the Project would not require a notice of preparation or notice of negative declaration or mitigated negative declaration. Therefore, the provisions of AB 52 are not applicable to the Project. Refer also to the discussion and analysis of potential impacts to cultural resources provided herein in Subsection 5.1.5, which concludes that with implementation of applicable mitigation measures (i.e., MM CR 1 and MM CR 2) from the Adopted MND, Project impacts to cultural resources, including tribal cultural resources, would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the proposed Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defines in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code section 5024.1? (In applying for the criteria set forth in (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.)
(Source: AB-52 Native Americans: California Environmental Quality Act – California Legislative Information)

No Substantial Change from Previous Analysis:

The above-listed threshold was added to Appendix G to the CEQA Guidelines pursuant to AB 52. AB 52 was signed into law in 2014 while the Adopted MND was adopted in January 2016. AB 52 requires tribal consultation for certain development projects and applies only to projects that have a notice of preparation or notice of negative declaration or mitigated negative declaration filed on or after July 1, 2015. As demonstrated by the analysis herein, the proposed Project is fully within the scope of analysis of the Adopted MND, and the Project would not trigger any of the conditions described in § 15162 of the CEQA Guidelines calling for the preparation of a subsequent EIR or MND. As such, an Addendum to the Adopted MND has been prepared for the Project pursuant to § 15164 of the CEQA Guidelines, and the Project would not require a notice of preparation or notice of negative declaration or mitigated negative declaration. Therefore, the provisions of AB 52 are not applicable to the Project. Refer also to Response (a)(ii) above.

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Project would not require a notice of preparation or notice of negative declaration or mitigated negative declaration. Therefore, the provisions of AB 52 are not applicable to the Project. Refer also to the discussion and analysis of potential impacts to cultural resources provided herein in Section 5.1.5 from the Adopted MND, Project impacts to cultural resources, including tribal cultural resources, would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.19 Utilities and Service Systems

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XIX. UTILITIES AND SERVICE SYSTEMS. Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment, or storm water
drainage systems, whereby the construction
or relocation would cause significant
environmental effects?
܆ ܆ ܈ ܆
b. Have sufficient water supplies available to
serve the project and reasonably foreseeable
future development during normal, dry, and
multiple dry years?
܆ ܆ ܆ ܈
c. Result in a determination by the wastewater
treatment provider which serves or may
serve the project that it has adequate
capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
܆ ܆ ܆ ܈
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity of
local infrastructure, or otherwise impair the
attainment of solid waste reduction goals?
܆ ܆ ܆ ܈
a. Comply with federal, State, and local
management and reduction statutes and
regulations related to solid waste?
܆ ܆ ܆ ܈

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a) Would the proposed Project require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage systems, whereby the construction or relocation would cause significant environmental effects? (Source: General Plan 2025 Table PF-1 – RPU PROJECTED DOMESTIC WATER Supply (AC-FT/YR), Table PF- 2 – RPU Projected Water Demand, Table PF-3 – Wester n Municipal Water District Projected Domestic Water Supply (AC-FT/YR), RPU, FPEIR Table 5.1 6-G – General Plan Projected Water Demand for RPU Including Water Reliability for 2025, Table 5.16-I - Current and Projected Water Use WMWD, Table 5.16- J - General Plan Projected Water Demand for WMWD Including Water Reliabili ty 2025, Table 5.16-K - Estimated Future Wastewater Generation for the City of Riverside’s Sewer Service Area & Table 5.16-L - Estimated Future Wastewater Generation for the Planning Area Served by WMWD, Figure 5.16-4 – Water Facilities and Figure 5.16-6 – Sewer Infrastructure an d Wastewater Integrated Master Plan and Certified EIR.)

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project described in the Adopted MND in terms of utility provision and demand. Specifically, there would be no major changes in the Project’s proposed utility connections. Impacts associated with the Project’s proposed utility connections have been evaluated throughout this Addendum to the Adopted MND, and were evaluated as part of the Adopted MND. There are no components of the Project’s proposed utility connections that would result in impacts to the environment that have not already been addressed and, where necessary, mitigated to the maximum feasible extent. Because the Project would be consistent with the project evaluated in the Adopted MND in terms of utility provision and demand, the Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects, and impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

b) Would the proposed Project have sufficient water supplies available to serve the project and reasonably foreseeable development during normal, dry, and multiple dry years? (Source: FPEIR Figure 5.16-3 – Water Service Areas, Figure 5.16-4 – Water Facilities, Table 5.16- E – RPU Projected Domestic Water Supply (AC-FT/YR, Table 5.16-F – Projected Water Demand, Table 5.16-G – General Plan Projected Water Demand for RPU including Water Reliability for 2025, Table 5.16-H – Current and Projected Domestic Water Supply (acre-ft/year) WMWD Table 5.16-I Current and Projected Water Use WMWD, Table 5.16-J – General Plan Projected Water Demand for WMWD Including Water Reliability 2025, RPU Master Plan, EMWD Master Plan, WMWD Master Plan, Highgrove Water District Master Plan)

No Substantial Change from Previous Analysis:

Consistent with the finding of the Adopted MND, water service is available to serve the proposed Project subject to the payment of applicable connection charges and/or fees; provision and construction of standard connections, extensions, and installations of facility infrastructure in accordance with Department of Public Utilities standards, specifications, and policies; the rules and regulations of the

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California Public Utilities Commission and California Health Services; and implementation of the City-wide program for the completion of incremental expansions to facilities for planned water supply, treatment, and storage. Accordingly, there would be sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as Previously identified and analyzed in the Adopted MND.

c) Would the proposed Project result in a determination by the wastewater treatment provider that serves or may service the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? (Source: FPEIR Figure 5.16-5 - Sewer Service Areas, Fig ure 5.16-6 -Sewer Infrastructure, Table 5.16-K - Estimated Future Wastewater Genera tion for the City of Riverside’s Sewer Service Area, Table 5.16-L - Estimated Future Wastewater Generation for th e Planning Area Served by WMWD, Wastewater Integrated Master Plan and Certified EIR)

No Substantial Change from Previous Analysis:

The proposed Project is consistent with the project described in the Adopted MND in terms of wastewater conveyance and treatment. Consistent with the findin g of the Adopted MND, sanitary sewer service is available to serve the proposed Project subject to the payment of applicable connection charges and/or fees; provision and construction of standard connections, extensions, and installations of facility infrastructure in accordance with Department of Public Utilities standards, specifications, and policies; and the rules and regulations of the California Public Utilities Commission and California Health Services.

Accordingly, and consistent with the finding of the Adopted MND, the proposed Project would not result in a determination by the waste water treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

d) Would the Project generate solid waste in excess of State or Local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
(Source: FPEIR Table 5.16-A – Existing Landfills and Table 5.16-M – Estimated Future Solid Waste Generation from the Planning Area, CalRecycle – El Sobrante Landfill, Badlands Landfill, and Lamb Canyon Landfill)

No Substantial Change from Previous Analysis:

The Project would be served by either the El Sobrante Landfill, Badlands Landfill, and/or Lamb Canyon Landfill. As determined in the Adopted MND, adequate landfill capacity would exist to serve the Project because these landfills have an excess of approximately 65,932,830, 18,651,201 tons, and 19,692,703 tons

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of solid waste, respectively. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

e) Does the Project comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
(Source: California Integrated Waste Management Board 2002 Landfill Facility Compliance Study)

No Substantial Change from Previous Analysis:

Consistent with the project evaluated in the Adopted MND, the Project Applicant would be required to comply with the City of Riverside’s waste reduction programs pursuant to the State’s Integrated Waste Management Act (IWMA). Project-generated solid waste would be conveyed to either the El Sobrante Landfill, Badlands Landfill, and/or Lamb Canyon Landfill. These landfills are required to comply with federal, State, and local statutes and regulations related to solid waste. Mandatory compliance with federal, State, and local statues also would reduce the amount of solid waste generated by the proposed Project and diverted to landfills, which in turn will aid in the extension of the life of the El Sobrante Landfill, Badlands Landfill, and/or Lamb Canyon Landfill. There are no components of the proposed Project with the potential to conflict with federal, State, or local management or reduction statutes and regulations related to solid waste. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

5.1.20 Wildfire
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Less than
Significant
Impact
No Impact
XX. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an adopted emergency
response plan or emergency evacuation
plan?
܆ ܆ ܆ ܈
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose project occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?
܆ ܆ ܆ ܈
c. Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power
lines or other utilities) that may exacerbate
܆ ܆ ܆ ܈

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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Less than
Significant
Impact
No Impact
fire risk or that may result in temporary or
ongoing impacts to the environment?
d. Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
܆ ܆ ܆ ܈

a) Would the proposed Project substantially impair an adopted emergency response plan or an emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors, would the proposed Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Would the proposed Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
d) Would the proposed Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
(Source: General Plan 2025 Figure PS-7 – Fire Hazard Areas, GIS Map Layer VHFSZ 2010)

No Substantial Change from Previous Analysis:

Although not originally analyzed in the Adopted MND, the Project site is not located near any wildland fire hazard zones, and the Project site is not located within or near a state responsibility area. The building proposed as part of the Project would be required to contain appropriate fire suppression measures, such as fire sprinklers, consistent with the City of Riverside’s building code requirements. There are no components of the Project that would result in increased risk due to fire hazards, either on or off site, and the Project is not required to maintain fire-related inf rastructure that could exacerb ate fire risk or that may result in temporary or ongoing impacts to the environment. The Project site is not identified as part of any emergency response plans or emergency evacuation plans, and the Project would accommodate appropriate fire department access around the propos ed building. Accordin gly, there would be no impacts associated with wildland fire hazards. Therefore, the Project would not result in any new impacts, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

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5.1.21 Mandatory Findings of Significance

Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No Impact
XX. MANDATORY FINDINGS OF SIGNIFICANCE
a. Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the habitat
of a fish or wildlife species, cause a fish or
wildlife population to drop below self-
sustaining levels, threaten to eliminate a
plant or animal community, reduce the
number or restrict the range of a rare or
endangered plant or animal, or eliminate
important examples of the major periods of
California history or prehistory?
܆ ܈ ܆ ܆
b. Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects)?
܆ ܈ ܆ ܆
c. Does the project have environmental effects
which will cause substantial adverse effects
on human beings, either directly or
indirectly?
܆ ܈ ܆ ܆

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? (Source: General Plan 2025 – Figure OS-6 – Stephen’s Kangaroo Rat (SKR) Core Reserve and Other Habitat Conservation Plans (HCP), Figure OS-7 – MSHCP Cores and Linkages, Figure OS-8 – MSHCP Cell Areas, General Plan 2025 FPEIR Figure 5.4-2 – MSHCP Area Plans, Figure 5.4-4 - MSHCP Criteria Cells and Subunit Areas, Figure 5.4-6 – MSHCP Narrow Endemic Plant Species Survey Area, Figure 5.4-7 – MSHCP Criteria Area Species Survey Area, Figure

5.4-8 – MSHCP Burrowing Owl Survey Area, MSHCP Section 6.1.2 - Protection of Species Associated with Riparian/Riverine Areas and Vernal Pools, and Habitat Assessment, FPEIR Table 5.5-A Historical Districts and Neighborhood Conservation Areas, Figure 5.5-1 - Archaeological Sensitivity, Figure 5.5-2 - Prehistoric Cultural

Riverside City CouncilDecember 20, 2022

Riverside City Council
December 20, 2022