Riverside City Council
September 19, 2023

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

TECHNICAL MEMORANDUM

To: Judy Egüez, Senior Planner
City of Riverside Community & Economic Development, Planning Division From: Jessie Fan and Heidi Rous, Kimley-Horn and Associates, Inc.

Date: August 17, 2023
Subject: 1575 University Avenue Project – CEQA Consistency

1.0 INTRODUCTION
This technical memorandum assesses assess the potential environmental effects of the proposed 1575 University Avenue Project (Project), as described in Section 3.0, Project Description, below, under Section 15168(c) of the California Environmental Quality Act (CEQA) Guidelines.

CEQA Guidelines Section 15168(c) sets forth criteria to utilize a program EIR for “later activities” within the scope of a program environmental impact report (EIR). The City of Riverside (City) certified the City of Riverside Housing and Public Safety Element Updates and Environmental Justice Policies Project Final Environmental Impact Report ( Certified PEIR or PEIR ) on October 5, 2021. The Certified PEIR (State Clearinghouse No. 2021040089) evaluated the (1) adoption and implementation of the update to the Housing Element for the 2021-2029 period (Housing Element Update); (2) adoption and implementation of the Public Safety Element Update; (3) develop ment of the associated Environmental Justice Policies; and (4) update to the Zoning Code and Specific Plans to address the requirements of the 6 th Regional
Housing Needs Assessment (RHNA) cycle. The Certified PEIR evaluates an increase of 31,564 new dwelling units and 3,181,903 square feet of non -residential development, herein referred to as the development associated with the Housing Element Update.

Based on the Certified PEIR ’s analysis and pursuant to CEQA Guidelines Section 15168(c), this memorandum includes a written checklist to evaluate environmental impacts specific to the proposed Project and determine whether the Project-specific environmental effects would be within t he scope of the Certified PEIR. For each impact area addressed under CEQA, this document describes and relies on the analysis in the Certified PEIR and confirms that the effects of the proposed Project were examined as part of the Certified PEIR. This document relies on and incorporates the applicable and feasible mitigation measures from the Certified PEIR.1

1 The mitigation measures incorporated herein were taken from the Housing Element Final EIR Mitigation Monitoring and Reporting Program (MMRP), dated September 2021, https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/2021/Housing_Element/Attachment %2013%20-%20Final%20Environmental%20Impact%20Report_09-21.pdf. Accessed June 5, 2023.

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

2.0 STATUTORY AUTHORITY & REQUIREMENTS
CEQA Guidelines Section 15168(c) permits the lead agency to approve a subsequent activity or project if it is found to be “within the scope” of a certified Program EIR, provided that no subsequent EIR would be required pursuant to CEQA Guidelines Section 15162. Whether a later activity is within the scope of the Program EIR is a factual question that the lead agen cy determines based on substantial evidence in the record. Pursuant to CEQA Guidelines Section 15168(c)(2), factors that the lead agency may consider in making that determination include, but are not limited to, consistency of the later activity with the t ype of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts and covered infrastructure as described in the Certified PEIR.

CEQA Guidelines Section 15168(a) defines a program EIR as:
[A]n EIR which may be prepared on a series of actions that can be characterized as one large project and are related either:
(1) Geographically,
(2) As logical parts in the chain of contemplated actions, (3) In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or
(4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

CEQA Guidelines Section 15168(c) sets forth criteria to use a program EIR for “later activities.” Specifically, CEQA Guidelines Section 15168(c) states the following:
(c) Use with Later Activities. Later activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared. (1) If a later activity would have effects that were not examined in the program EIR, a new Initial Study would need to be prepared leading to either an EIR or a Negative Declaration.

That later analysis may tier from the program EIR a provided in Section 15152. (2) If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the sco pe of the project covered by the program EIR, and no new environmental document would be required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the reco rd. Factors that an agency may consider in making that determination include, but are not limited to, consistency of the

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for enviro nmental impacts, and covered infrastructure, as described in the program EIR.
(3) An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into later activities in the program.
(4) Where the later activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR.
(5) A program EIR will be most helpful in dealing with later activities if it provides a description of planned activities that would implement the program and deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed project description and analysis of the program, many later activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required.

CEQA Guidelines Section 15162 requires the preparation of a Subsequent EIR when an EIR has been certified or a negative declaration has been adopted for a project and one or more of the following circumstances exist:

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 occur with respect to the circumstance s 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 of 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;

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

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 measure or alternative; or d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

3.0 PROJECT DESCRIPTION
The Project would be located on a 4.29 -acre site (Assessor Parcel Number [APN] 250 -170-036) (Project Site) bounded by Seventh Street to the north, University Avenue to the south, Cranford Avenue to the east, and Chicago Avenue to the west (see Figure 1: Local Vicinity Map). The Project would demolish the existing 24,848- square-foot commercial building and surface parking lot and would construct a new mixed-use development with 257 dwelling units and 4,918 square feet of restaurant uses (see Figure 2:

Conceptual Site Plan). The Project would also provide a total of 499 vehicle parking spaces: 488 of which would be within a parking garage, and 11 would be provided on -grade. The Project would have a maximum height of 50 feet and contain approximately 284,561 square feet of gross building area see Figures 3 through 8 for Project elevations) . Project construction activities (e.g., demolition, site preparation, grading, paving, building construction, and architectural coating) is anticipated to begin in January 2024 and end in January 2026. The Project would be operational in January 2026.

Figure 1: Local Vicinity Map
1575 University Avenue Project
Riverside, CA
Myford II
Untitled layer
Riverside, CA
Source: Google Earth Pro, 2023
Project Site
University AveUniversity Ave University AveUniversity Ave W Linden StW Linden St
Seventh StSeventh St
Seventh StSeventh St
Cranford AveCranford Ave
3rd St3rd St
Iowa AveIowa Ave
60 Chicago AveChicago Ave
Figure 2: Conceptual Site Plan
1575 University Avenue Project
Riverside, CA
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 15 30 FEET60 120
N
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P
1A-7
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P
1A-5
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P
1A-5
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P
1A-5
U1.1A-11
DW
W/D
CSD
SD
PF-14A
1C-1
U1.1 A-11
DW
W/D
CSD
SD
PF-14A
1C-1
U1.1A-11
DW
W/D
CSD
SD
PF-14A
1C-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1

BB DWBB W/D
CSD
P
PF-14B
ST A-1
U1.1

BB DWBB W/D
CSD
P
PF-14B
ST A-1
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
DW
P
2A-5
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
DW
P
2A-5
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1

BBDW BBW/D
CSD
P
PF-14B
ST A-1SD
PF-14A
DW
CSD
SD
SD
W/D
CSD
CSD
SD
PF-14A
3A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P
1A-5
DW
P
U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
PU1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
P U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
PU1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
P
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
P U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD
2A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-8
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-10
U1.1
A-11
DW
W/D
CSD
SD
PF-14A
1C-2
EL: 962.79
12"
CLR
18"
CLR
18"
CLR
12"
CLR
18"
CLR
EL: 962.79
ELEC.

ROOM
EL: 962.79
EL: 962.77
8'-0"
CLG
FDC
12"
CLR
EL: 962.79
962.77962.77
EL: 962.79
12"
CLR
12"
CLR
C14C15C16C19 C18 C17
C37C39C40C42 C31C36C38 C35 C34C41
C22 C21 C20C25 C24 C23
C32C33
EV 2 EV 2
C11C10C09C08C07
C12 C13
03 C06
C43
C26
C44
C27
C45
C28C29
006005
022021
004
020
18"
CLR

COMPACTOR
Ø 5'-0"
CLR
18"
CLR
18"
CLR
Ø 5'-0"
CLR
P1623
18"
42" CLR
Ø 5'-0"
CLR
12"
CLR
U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD L
DW
P
2A-4
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-9
U2.1
SD
U2.1
CSD
W/D
PF-14A
DW
P
1A-4
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1P
A-11
DW
W/D
CSD
SD
L
PF-14A
1C-1
U1.1P
A-11
DW
W/D
CSD
SD
L
PF-14A
1C-1
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A-11
DW
W/D
CSD
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L
PF-14A
1C-1
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ST A-1
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U2.1
CSD
W/D
DW
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PF-14A
1A-1
U2.1
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U2.1
CSD
W/D
DW
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PF-14A
1A-1
PF-14A
PF-14A
W/D
CSD
SD
SD
SD
CSD
U1.1
L
DW
3C-1
U1.1
W/D
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PF-14A
PF-14A
SD
CSD
L
DW
P
2A-5
U2.1
SD
U2.1
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W/D
DW
P
PF-14A
1A-1
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1P
A-11
DW
W/D
CSD
SD
L
PF-14A
1C-1
U1.1P
A-11
DW
W/D
CSD
SD
L
PF-14A
1C-1
U1.1

BBDW BBW/D
CSD
P
PF-14B
ST A-1
U1.1 P
A-11
DW
CW/D
CSD
SD
L
PF-14A
1C-2
U1.1P
A-11
DW
W/D
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SD
L
PF-14A
1C-1
PF-14A
W/D
L
L P
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SD
SD
SD
CSD
L
DW
PF-14A
3D-2
U2.1
DW
PF-14A
U2.1
DW
PF-14A
U2.1
DW
PF-14A
U2.1
DW
PF-14A
U1.1P
A-11
DW
C
W/D
CSD
L
PF-14A
U2.1
SD
U2.1
CSD
W/D
PF-14A
DW
P
1A-4
U2.1
SD
U2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1
BBDW
CSDPPF-14BST A-1
DW
PU1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
L
2A-1
DW
P
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
L
2A-1
DW
P
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
L
2A-1
DW
P U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD
L
2A-1
DW
P
U1.1
W/D
SD CSD
PF-14A
PF-14A
SD
CSD
L
2A-1
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PF-14A
L
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PF-14A
L
DW
SD CSD
PF-14A
U1.1 P
A-11
DW
C
W/D
CSD
SD
L
PF-14A
1C-3
UPDN
UP DN
12"
CLR
18"
CLR
EL: 973.00
EL: 973.00
EL: 973.00EL: 973.00
EL: 973.00
EL: 973.00
EL: 973.00
EL: 974.00
EL:973.50" EL:973.25" EL:973.25" EL:972.75"EL:973.50"EL:973.50" 18"
CLR
12"
CLR

KITCHEN
SHAFT
1821 S.F.
3,096 S.F.
12"
CLR
EL: 973.00
12"
CLR
POOL EQUIP.

PUMP
ROOM

FIRE PUMP
ROOM
RESTAURANT 02
RESTAURANT 01
ELEC.

ROOM
18"
CLR
18"
CLR

BUSINESS CENTER FITNESS LOUNGE
F.A.A.

FDC
12"
CLR
12"
CLR
12"
CLR
12"
CLR
970.29
972
972
12"
CLR
12"
CLR
970.54
972.68
1:12
973
970.14
972.74
972.98
972.80
972.74
EL: 972.00
EL: 973.00 EL: 972.00
EL: 973.00
EL: 972.00 EL: 972.00
EL: 972.00
EL: 972.00
EL: 973.00
12"
CLR
1:20,
no handrail
-
R-035
4-036
043044045048 047 046
066068 060062065067 064 063
055056057
EV
1 058 041042
069071 070072073074
051 050 049054 053 052
018017016013 014 015
028026 034033032029027 030 031
081 019
025023 024
010 011 012007 008 009
061
059
079
080
037038039040
EV 2EV 2
075 076
EV 2
084083
110111
082
112
077
EV 2
078
EL: 973.00
000000
-
C03 C04
USPS

SHARE/UBER
C002
C001
EL: 973.00
18"
CLR
Ø 5'-0"
CLR
18"
CLR
EL: 978.10
EL: 967.90
EL: 973.00
EV 1
C05
R 24'-0"
R 24'-0"
EL: 972.00
EL: 978.10
EL: 978.10 110'-2"@ 4.6 % SLOPE
110'-2"@ 4.6 % SLOPE
R 24'-0"R 24'-0"
8'-0"
CLG
8'-0"
CLG
EV 1
Benchmark Title
0"
971.95
970.25 970.25
970.75
972.84972.88
970.75
972.83
971.98
971.92
972.70 970.25
971.75
968.25
962.73
962.77
972.98
970.25
971.87
971.75
20:1
20:1
970.75
971.46
970.90
971.80
972.80
972.70
972.98
972.83
971.87
971.87

0.01 971.00
972.73
972.42

0.010.05
971.40970.90
970.98 0.005

0.01 0.028
972.98

0.01 972.98

50'-0" '
50'-0" '
30'-0"27'-4 1/2"
30'-0"27'-4 1/2"
301'-0"
630'-7"
5'-0" 24'-0"

FIRE LANE
28'-0" 219'-6" 24'-6"
15'-0"

SETBACK
5'-9"
6'-5"
5'
88'-6" 47'-0 1/2" 71'-6" 162'-10 1/2" 90'-9" 53'-1" 70'-6"

S E V E N T H S T R E E T
231'-0"

PARKING GARAGE
2 STORY

RETAIL/OFFICE
BLDG
1 STORY RETAIL BLDG
3 STORY RESIDENTIAL BLDG 3 STORY RESIDENTIAL BLDG
1 STORY

WHOLESALE

WAREHOUSE
1 STORY

WHOLESALE

WAREHOUSE
1 STORY

WHOLESALE

WAREHOUSE
6 STORY TYPE I

PARKING GARAGE
411 STALLS
152,613 S.F.
4 STORY
TYPE V

RESIDENTIAL BLDG
284,561 S.F
RESIDENTIAL FAR: 1.53
50'-0"
F.F
973.00
F.F
973
F.F
973.00
F.G
973.00
F.F
973.00
162'-11"175'-0"
PARKING 7 STALLS

ON GRADE

COMMERICAL
4,918 SF
COMM. FAR:

0.02 LOBBY /

LEASING

GARAGE ENTRY
EL. 965.02

LOADING

MOVE IN

PROPERTY LINE
15'

SET BACK LINE
15'

SET BACK LINE

PROPERTY LINE

PROPERTY LINE

LOUNGEGYM/BUSINESS
CENTER
10'-0" 24'-0" 12'-8 1/2"
RESTAUARNT 01
RESTAURANT 02

COURTYARD ENTRY
EL. 962.79

COURTYARD ENTRY
EL. 972.00
C.L. OF U N I V E R S I T Y A V E N U E

PRIMARY BLDG ENTRY
EL. 973.00
TRASH

LOADING

COURTYARD ENTRY
EL. 972.00
9'-6"9'-0"9'-0"
18'-0"24'-0"18'-0"
R 24'-0"
175'-0"
80% COMMERCIAL
C.L.

OF STREET

RIGHT OF WAY
R 28'-0"
R 48'-0"
12'-0"

STORM DRAIN

EASEMENT
15'-0"

SETBACK
1 STORY RETAIL BLDG 1 STORY RETAIL BLDG
ARCADE
ARCADE
ARCADE
6'-1 1/2"11'-7"
B.O. BALCONY
992.15
5'-0"

FIRE PUMP
PUMP
ROOM
AS01
SCALE : 1" = 30'-0"

SITE PLAN
GAS
METERS

PRIVATE
OPEN
SPACE,
TYP.

TRANSFORMER TRANSFORMERFIRE TURNAROUND

SPECIALITY PAVING,

REFER TO LANDSCAPE DWG

FOR DETAILS

PRIVATE

HOSE CONNECTION
TYP.

PRIVATE

HOSE CONNECTION
TYP.

PRIVATE

HOSE CONNECTION
TYP.

PRIVATE
HOSE

CONNECTION
TYP.

SIDEWALK

SIDEWALK SIDEWALK

SIDEWALK

SPECIALTY PAVEMENT,

SEE LANDSCAPE DWG

FOR DETAILS

EGRESS/EMERGENCY

ACCESS GATE
(E) CMU SITE WALLWALK PATH WALK PATH WALK PATH

PROPOSED WQMP

STORMDRAIN INFILTRATION
SYSTEM ;

SEE CIVIL
(E) CMU

SITE WALL

EXISTING VAULT TO

BE REMOVED
15 FT. SETBACK
12 FT. STORM

DRAIN EASEMENT

COMMERCIAL
TRASH
5’ LANDSCAPE

SETBACK

LANDSCAPE

SETBACK
5’ (E) UTILITY

EASEMENT
(E) UTILITY

EASEMENT
(E) CMU SITE WALL
(N) SITE WALL,

REFER TO LANDSCAPE DWG
PLANTING NOTE @ FIRE ACCESS WALK PATH:

PLANT MATERIAL PROPOSED ALONG THE WEST PROPERTY LINE SHALL BE LOW MAINTENANCE AND CLIMATE-APPROPRIATE. A DETAILED PLANTING

PLAN, AS PART OF THE CONSTRUCTION DOCUMENT PACKAGE, IDENTIFYING SUCH PLANTS SHALL BE SUBMITTED TO THE RIVERSIDE PLANNING AND FIRE DEPARTMENTS FOR THEIR REVIEW. UPON INSTALLATION, SUCH PLANT MATERIAL SHALL BE MAINTAINED BY THE OWNER, BASED ON DIRECTIONS PROVIDED BY THE LANDSCAPE ARCHITECT, TO PROVIDE ACCESS TO THE FIRE DEPARTMENT WITHOUT ANY IMPEDIMENT.

DRIVEWAYDRIVEWAYDRIVEWAY
BFPs/DCDA:

DOMESTIC WATER

COMMERCIAL WATER

FIRE WATER

IRRIGATION
GREASE

INTERCEPTOR

NEW ELECTRICAL

VAULT PER

RPU DESIGN
Source: DesignARC, 2023
LEVEL 2
983.21'
LEVEL 3
993.42'

LEVEL G
962.79'

ZONING HEIGHT LIMIT
1027.88'
LEVEL 1
973.00'
10'-2 1/2" 10'-2 1/2" 10'-2 1/2"
65'-1 1/8"
A205
SCALE : 1" = 10'-0"

NORTH ELEVATION
A205
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. 16/20 INTEGRAL COLOR CEMENT PLASTER;
DUNN EDWARDS - DROPLETS DEW381

2. 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
123B475 121415 1310
Figure 3: North Elevation
1575 University Avenue Project
Riverside, CA
Source: DesignARC, 2023
Figure 4: South Elevation
1575 University Avenue Project
Riverside, CA

TOP OF MECHANICAL

EQUIPMENT

BEHIND PARAPET

RESERVE AREA FOR MURAL
A201
SCALE : 1" = 10'-0"

SOUTH ELEVATION
13A4567A8 9101112 131415
A201
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. SBMF* / 16/20 INTEGRAL CEMENT PLASTER;
COLOR: MATCH DUNN EDWARDS - DROPLETS DEW381

2. SBMF* / 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; COLOR: MATCH DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
* SBMF - LA Habra Stucco Santa Barbara Mission Finish
18 3A
1'-4"

EXTERIOR CEMENT PLASTER
(09.24)
SCHEDULED WINDOW (08.51)
'L' METAL TRIM AND PAINTABLE

CAULKING

SEALANT AT BACK OF FRAME O/
FLASHING; RUN 8" UP JAMB MIN.;

TYPICAL
9"

SELF-ADHERED MEMBRANE
FLASHING (07.65)
WEATHER BARRIER (07.26)
WINDOW DETAILS @ UNIVERSITY AVE 1

SLOPED CEMENT PLASTER SILL AT INSET
WINDOW DETAILS @ UNIVERSITY AVE
19 7B20 12 2
Source: DesignARC, 2023
Figure 5: East Elevation – South
1575 University Avenue Project
Riverside, CA
LEVEL 2
983.21'
LEVEL 3
993.42'
LEVEL 4
1003.63'

ZONING HEIGHT LIMIT
1027.88'
LEVEL 1
973.00'

ELEVATOR
PENTHOUSE EL.
1026.86'
10'-2 1/2" 10'-2 1/2" 10'-2 1/2"
54'-10 1/2"

EXTENT OF BUILDING WITH SBMF STUCCO
A202
SCALE : 1" = 10'-0"

EAST ELEVATION - SOUTH

MATCH LINE
A203
A202
12 47A89 1011 1213 1415
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. SBMF* / 16/20 INTEGRAL CEMENT PLASTER;
COLOR: MATCH DUNN EDWARDS - DROPLETS DEW381

2. SBMF* / 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; COLOR: MATCH DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
* SBMF - LA Habra Stucco Santa Barbara Mission Finish
7B 201 18
Source: DesignARC, 2023
Figure 6: East Elevation – Garage
1575 University Avenue Project
Riverside, CA
LEVEL 1
973.00'
LEVEL 2
983.21'
LEVEL 3
993.42'
LEVEL 4
1003.63'
10'-2 1/2" 10'-2 1/2" 10'-2 1/2"
LEVEL 2
983.21'
LEVEL 3
993.42'

LEVEL G
962.79'
LEVEL 1
973.00'
LEVEL 4
1003.63'

ROOF LEVEL
1013.83'
10'-2 1/2" 10'-2 1/2" 10'-2 1/2" 10'-2 1/2" 10'-2 1/2"

ZONING HEIGHT LIMIT
1027.88'

ELEVATOR
PENTHOUSE EL.
1032'
65'-1 1/8"
A203
SCALE : 1" = 10'-0"

EAST ELEVATION - GARAGE

MATCH LINE
A204

MATCH LINE
A202
A203
2 2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. 16/20 INTEGRAL COLOR CEMENT PLASTER;
DUNN EDWARDS - DROPLETS DEW381

2. 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
10 17A17
Source: DesignARC, 2023
Figure 7: West Elevation – North
1575 University Avenue Project
Riverside, CA
A206
SCALE : 1" = 10'-0"

WEST ELEVATION - NORTH
LEVEL1
973.00'
LEVEL 2
983.21'
LEVEL 3
993.42'

LEVEL G
962.79'
10'-2 1/2" 10'-2 1/2"10'-2 1/2"

MATCH LINE
A207
A206
123B 47B10121415 13
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. 16/20 INTEGRAL COLOR CEMENT PLASTER;
DUNN EDWARDS - DROPLETS DEW381

2. 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
Source: DesignARC, 2023
Figure 8: West Elevation – Pool Courtyard
1575 University Avenue Project
Riverside, CA
2558 Overland Ave, CA 90064 T. 310.204.8950 www.designarc.net All design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc.
1575 U N I V E R S I T Y A V E N U E ,

R I V E R S I D E, C A L I F O R N I A
APN # 250-170-036
0 5 10 FEET20 40

KEYPLAN

1. 16/20 INTEGRAL COLOR CEMENT PLASTER;
DUNN EDWARDS - DROPLETS DEW381

2. 20/30 INTEGRAL COLOR CEMENT PLASTER W/ TOOLED LINES; DUNN EDWARDS - LIMESTONE DE6233

3. PLASTER FINIAL
A: DUNN EDWARDS-DEW381
B: DUNN EDWARDS-DE6233

4. PLASTER CORBEL; DUNN EDWARDS-DEW381

5. PLASTER EAVE; DUNN EDWARDS-DEC756

6. SLOPED CEMENT PLASTER SILL AT INSET WINDOW;
PAINTED DUNN EDWARDS-DEW381

7. FOAM PLASTER MOULDING;
A: PAINTED DUNN EDWARDS- DEW381
B: PAINTED DUNN EDWARDS- DE6233

8. PRE-CAST CONCRETE BASE; EMPIRE PRECAST- CREAM C011

9. FAUX ROOF BEAM, FORMED FOAM PLANT-ON W/ CEMENT PLASTER COATING; DUNN EDWARDS-DEC756

10. 2-PIECE CLAY TILE ROOF; REDLAND: TERRA COTTA
BLEND-2211

11. BRONZE ANODIZED ALUMINUM STOREFRONT; ARCADIA AB-7

12. PAINTED STEEL IRON RAILING; DUNN EDWARDS-DE6314

13. VINYL WINDOW W/ BRONZE CAP-STOCK DEEP SET IN THICKEN WALL;

MILGARD-BRONZE

14. CEMENTITIOUS PANEL, PAINTED TO MATCH RAILING;
DUNN EDWARDS-DE6314

15. SUNBRELLA CANVAS AWNING ON STEEL FRAME; SUNBRELLA - FERN

16. METAL DOOR W/ METAL FRAME; PAINTED DUNN EDWARDS-DEW381

17. PAINT ON CONCRETE; DUNN EDWARDS-DE6233

18. GLAZED CERAMIC TILES; DALTILE 6x6 COLOR MATCHTM - MATTE ARTICHOKE 12

19. AWNING SUPPORT IN STEEL; BLACK

20. WOOD PERGOLA, PAINTED; DUNN EDWARDS-DEC756
A207
SCALE : 1" = 10'-0"

WEST ELEVATION - POOL COURTYARD

MATCH LINE
A208

MATCH LINE
A206
A207
23A7A 10 121415 13 4111
Source: DesignARC, 2023

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

As part of the Housing Element Update, the City identified available sites for potential future housing development (Opportunity Sites) th at would not contain significant constraints to development. As summarized in Chapter 2, Project Description, of the Certified PEIR , the Certified PEIR evaluates an increase of 31,564 new dwelling units and 3,181,903 square feet of non -residential development, or up to 31,175 dwelling units and 1,433,460 square feet over existing conditions as determined in the Certified PEIR.

As stated on page 1 -5 of Chapter 1:, Introduction and Scope of Environmental Impact Report, of the Certified PEIR, “while [this Certified PEIR] does not preclude future environmental review required under CEQA for subsequent development projects (i.e., Opportunity Sites), the analysis in [this Certified PEIR] and provision of program -level mitigation measures would streamline further CEQA review for specific projects to support facilitation of future development of individual Opportunity Sites. Projects that are within the scope of the analysis of [this Certified PEIR], whereby all Project -specific impacts could be adequately minimized or avoided through application of program-level mitigation, may be able to proceed without subsequent CEQA documentation.” Further, a s stated on page 5 -4 of Chapter 5, Other CEQA Considerations, of the Certified PEIR, “ the City will use [the Certified PEI R] as the basis for streamlining CEQA reviews of future residential and mixed-use development on Opportunity Sites consistent with the Housing and Public Safety Element Updates.”
The Project would be located on an Opportunity Site in the northeastern quad rant of the City. As stated above, the Project would develop a mixed-use building that includes residential and commercial uses that would be consistent with the types of uses analyzed within the Certified PEIR . Therefore, based on the analysis provided in Section 5, Comparative Analysis of Project Impacts, below, the Project would meet the applicability and requirements of CEQA Guidelines Section 15168(c)(2).

4.0 PREVIOUS ENVIRONMENTAL DOCUMENTS INCORPORATED BY

REFERENCE
Consistent with CEQA Guidelines Se ction 15150, the following documents were used in preparation of this document and are incorporated herein by reference:
• City’s Housing and Public Safety Element Updates and Environmental Justice Policies Draft Environmental Impact Report, State Clearinghouse No. 2021040089, July 2021 • City’s Housing and Public Safety Element Updates and Environmental Justice Policies Final Environmental Impact Report, State Clearinghouse No. 2021040089, September 2021 • Kimley-Horn and Associates, 1575 University Av enue Project – Responses to Planning Comment Summary Matrix, December 13, 2022 (see Attachment A of this Memorandum) • Kimley-Horn and Associates, Updated CalEEMod Modeling Results, July 2023 (see Attachment B of this Memorandum).

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

5.0 COMPARATIVE ANALYSIS OF PROJECT IMPACTS
This section provides an impact assessment of the Project. A Modified CEQA Guidelines Appendix G Environmental Checklist Form was used to compare the anticipated environmental effects of the Project with those disclosed in the Certified PEIR to evaluate whether the Project’s environmental effects would be within the scope of effects identified in the Certified PEIR in accordance with CEQA Guidelines Section 15168 and to review whether any of the conditions set forth in PRC Section 21166 or CEQA Guidelines Section 15162 requiring preparation of a Supplemental or Subsequent EIR have been triggered. Note, that to the extent that a Project impact does not trigger the need for a supplemental or subsequent EIR pursuant to CEQA Guidelines Section 15162, it is found to be within the scope of the impact analyzed in the Certified PEIR pursuant to CEQA Guidelines Section 15168(c)(4). The environmental effects for each of the following impact areas were evaluated:
• Aesthetics
• Agriculture and Forestry Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
The Environmental Checklist Form and evaluation below provides the following information for each of the environmental impact categories listed above:
• Impact Determination in the Certified PEIR — This section lists the impact determination made in

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

the Certified PEIR for each impact category evaluated in the PEIR.2 • Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? — Pursuant to CEQA Guidelines Section 15162(a)(1) , this section indicates whether the Project would result in new significant impacts that have not already been consider ed and mitigated by the prior environmental review or a substantial increase in the severity of a previously identified impact. This question also addresses whether the impact is within the scope of the impact analyzed in the Certified PEIR pursuant to CEQA Guidelines Section 15168(c)(4). To the extent that the Project does not have an impact that triggers the need for a subsequent or supplemental EIR due to the involvement of a new significant impact or more severe significant impact, the impact is considered within the scope of the Certified PEIR.
• Mitigation Measures Addressing Impacts — This section indicates whether the prior environmental document provides mitigation measures to address effects in the related impact category. In some cases, the mitigati on measures have already been implemented. If “None” is indicated, a significant impact was not identified and mitigation was not required. Mitigation measures from the Certified PEIR MMRP that are being imposed on the Project are included after the analysis. For those mitigation measures in the topic area that are not applicable to the Project, either because the Project is not anticipated to have a significant impact or because the mitigation measure is not relevant to the Project, the mitigation measure will be indicated as “N/A” or “not applicable.”
• Conclusion — For each environmental topic, a discussion of the conclusion relating to the analysis is provided.

5.1 Aesthetics
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
AESTHETICS: Except as provided in Public Resources Code Section 21099, would the P roject:
a) Have a substantial adverse effect on a scenic vista? Less Than Significant No N/A b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway?
Less Than Significant No N/A

2 It should be noted that the Certified PEIR addresses impacts from the Housing Element Update, Public Safety Element Update, and Environmental Justice Policies. As the Public Safety Element Update and Environmental Justice Policies are policy documents and would not result in physical environmental impacts, only the impacts from the Housing Element Update from the Certified PEIR are addressed in this document.

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

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 ?
Less Than Significant No N/A
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views
in the area?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding aesthetic were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that development associated with the Housing Element Update would increase residential densities and non-residential intensities in specific areas and would be concentrated in existing transit corridors or urban areas, would not be concentrated in open space areas, and would not block scenic views of surrounding mountains or the Santa Ana River.

Development would require design review and must demonstrate conformance with relevant General Plan 2025 policies and Riverside Municipal Code (RMC) standards. Therefore, implementation of the Housing Element Update would not have a substantial adverse effect on a scenic vista, and the impact would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that there are no State Scenic Highways within the City. Although scenic parkways exist within the City, the Certified PEIR determined that implementation of the Housing Element Update would not result in any effects on scenic highways or scenic resources. As the development associated with the Housing Element Update would not be on sites with rock outcroppings or scenic historic resources, impacts would be less than significant.

Regarding Threshold (c), compliance with General Plan 2025 policies, RMC, Specific Plan standards, and the Riverside Citywide Design Guidelines and Sign Guidelines, development under the Housing Element Update would not result in substantial degradation of visual character and quality, and impacts would be less than significant.

Regarding Threshold (d), the Certified PEIR concluded that while implementation of the Housing Element Update development would introduce new lighting and glare sources, compliance with Riverside County Ordinance No. 655 requirements, existing Riverside General Plan 2025 Final Program Environmental Impact Report (GP FPEIR) Mitigation Measure AES -1, and RMC Sections 19.556 and 19.590.070, impacts would be less than significant.

kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Senate Bill (SB) 743 (PRC Section 21099(d)) sets forth new guidelines for evaluating project transportation impacts under CEQA, as follows: ” Aesthetics and parking impacts of a residential, mixed- use residential, or employment center project on an infill site within a transit priority area (TPA) shall not be considered significant impacts on the environment.” PRC Section 21099 defines a “transit priority area” as an area within 0.5 mile of a major transit stop that is “existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement P rogram adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations.” PRC Section 21064.3 defines “major transit stop” as “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” PRC Section 21099 defines an “employment center project” as “a project l ocated on property zoned for commercial uses with a floor area ratio of no less than 0.75 and that is located within a transit priority area.” PRC Section 21099 defines an “infill site” as a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right -of-way from, parcels that are developed with qualified urban uses.

The Project Site is located in a Southern Californi a Association of Governments (SCAG) -designated High Quality Transit Area, which is defined as being within one half-mile of a well-serviced transit stop or transit corridor with 15 -minute or less service frequency during peak commute hours. Therefore, PRC Section 21099 applies to the Project, and the Project ’s aesthetic impacts shall not be considered significant impacts on the environment. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
Mitigation Measure from the Riverside GP FEIR
GP FEIR MM AES-1: Conduct literature review, habitat assessment, and surveys.

To further reduce impacts related to light pollution, the City shall require at the time of issuance of building permits all development which introduces light sources, or modifications to existing light sources, to have shielding devices or other light pollution limiting characteristics such as hoods or lumen restrictions.

No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

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Conclusion
Based on the above, the Project’s potential environmental impacts to aesthetics would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.2 Agricultural and Forestry Resources
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
AGRICULTURAL AND FORESTRY RESOURCES: 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?
No Impact No N/A
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
No Impact No N/A
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 4526), or timberland zoned
Timberland Production (as defined by Government
Code Section 51104(g))?
No Impact No N/A
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
No Impact No N/A
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 use?
No Impact No N/A

Impact Determination in the Certified PEIR
Impacts regarding agricultural and forestry resources were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR. The Certified PEIR determined that development associated with the Housing Element Update would not occur in areas designated as Important Farmland, Farmland of

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Statewide Importance, Unique Farmland, or Other Land ; therefore, no conversion of these lands would occur. None of the opportunity sites are within Williamson Act preserves or contracted land. None of the Opportunity Sites are zoned for forest land, timberland, or timberlan d zoned Timberland Production areas. Development associated with the Housing Element Update would not result in the conversion of Farmland to non-agricultural use or conversion of forest land to non -forest use. Implementation of the Housing Element Update would have no impact on agricultural and forestry resources.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? The Project Site is located on an O pportunity Site as designated in the Housing Element Update and Certified PEIR. It is not designated as Important Farmland, Farmland of Statewide Importance, Unique Farmland, or Other Land, within a Williamson Act preserve or contracted land, or zoned for forest land, timberland, or timberland zoned Timberland Production ar eas. The Project Site is developed with a commercial building and does not include any agricultural or forest land. Therefore, the Project would have no impact on agricultural and forestry resources. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to agricultural and forestry resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.3 Air Quality
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
AIR QUALITY: Would the Project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
Significant and Unavoidable No Yes
b) 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?
Significant and Unavoidable No Yes

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c) Expose sensitive receptors to substantial pollutant
concentrations?
Significant and Unavoidable No Yes
d) Result in other emissions (such as those leading to
odors adversely affecting a substantial number of
people?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding air quality under Thresholds (a) through (c) were discussed in Section 3.1, Air Quality , of the Certified PEIR. Threshold (d) was discussed in Section 3.15, Effects Not Found to be Significan t, of the Certified PEIR.

Regarding Threshold (a), as detailed in the Certified PEIR, while the construction emission impacts associated with each development under the Housing Element Update would be short-term in nature, the concurrent construction of a multitude of individual development projects could generate combined criteria pollutant emissions on a daily basis that could exceed the South Coast Air Quality Management District’s (SCAQMD) project -level thresholds. Additionally, the long -term operational emissions from buildout of the Housing Element Update would exceed SCAQMD’s daily emissions threshold for reactive organic gases (ROG), nitrous oxides (NO
X), and carbon monoxide (CO). To red uce impacts, the Housing Element Update would implement Mitigation Measures MM -AQ-1 and MM- AQ-2 to reduce criteria air pollution emissions form further construction-related and operational activities due to new development associated with the Housing Eleme nt Update. Additionally, the Housing Element Update’s emissions would increase concentrations of criteria pollutants or their precursors in a manner that could obstruct the SCAQMD’s efforts to achieve attainment of ambient air quality standards for any air quality criteria pollutant for which it is currently in nonattainment or jeopardize the current attainment status of the South Coast Air Basin for other criteria pollutants. The Housing Element Update would not be consistent with the 2016 Air Quality Management Plan (AQMP) under Criterion No. 1. Regarding Criterion No. 2, the growth associated with the Housing Element Update were not considered in SCAG’s growth assumptions in the 2016 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) upon which the regional emissions inventory for the South Coast Air Basin in the 2016 AQMP was based. It should be noted that future updates to the AQMP will incorporate the updater growth projections resulting from the Housing Element Update and would be incorporated by SCAG and SCAQMD into their regional planning projections and would become consistent with the AQMP. Therefore, the Housing Element Update would not be consistent with the 2016 AQMP, and impacts are potentially significant. While implementation of MM-AQ-1 and MM-AQ-2 would reduce criteria air pollutant emissions, they would not be able to reduce the emissions associated with buildout of the Housing Element Update to below SCAQMD’s significance thresholds. As determined in the Certified PEIR, the Housing Element Update’s impacts on air quality would be significant and unavoidable.

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Regarding Thresholds (b) and (c), as evaluated in the Certified PEIR, anticipated construction activities associated with concurrent construction of a multitude of individual development projects could generate combined criteria pollutant emissions on a da ily basis that could exceed SCAQMD’s project -level thresholds. As noted in the Certified PEIR, the City would need to require all future developments subject to CEQA requiring approval on a case-by-case basis to ascertain whether an individual development would generate potentially significant air quality impacts during construction, and, where necessary, would require implementation of additional mitigation measures to minimize air emissions and reduce potentially significant impacts. Implementation of the Housing Element Update would result in increases of certain criteria air pollutant emissions during operation as compared to existing conditions and would exceed the SCAQMD regional significance thresholds for ROG, NO X, and CO. Reductions from
implementation of Mitigation Measure MM -AQ-2 are uncertain and have not been quantified in the Certified PEIR. Further, development projects that would propose uses subject to SCAQMD permitting for air toxics (e.g., industrial facilities, dry cleaners, and gasoline -dispensing facilities) would ensure that health risks are minimized. Mitigation Measure MM -AQ-3 would ensure mobile sources of toxic air contaminants (TACs) not covered under SCAQMD permits are considered during subsequent project-level environmental review by the City. Implementation of the development associated with the Housing Element Update could generate TACs from both permitted and non-permitted (e.g., trucks) sources that would contribute to elevated levels in the South Coast Air Basin. Even with implementation of mitigation measures, construction and operational impacts are considered significant and unavoidable.

Regarding Threshold (d), the Certified PEIR concluded that implementation of the Housing Element Update would result in less than significant impacts related to odor.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), as discussed under 5.14, Population and Housing, of this Memorandum , based on the City’s average household size of 3.28, the Project’s 257 dwelling units would result in 843 new residents, which would represent approximately 1. 2 percent of the estimated population growth (approximately 70,500 new residents) forecasted by SCAG’s 2020-2045 RTP/SCS between 2016 and 2045.

This increase in population would be well within the existing population projections for the City .

Therefore, because the Project would result in a minimal increase in population, it would be consistent with the projections set forth in SCAG’s 2020-2045 RTP/SCS and which were used in the 2022 AQMP. Thus, the Project would not conflict with or obstruct implementation of the 20 22 AQMP. As shown in Table 1 and Table 2 below, the Project’s construction and operational emissions would not exceed the SCAQMD thresholds.

Table 1: Project Construction Emissions
Construction Year Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
2024 2.68 46.5 50.3 0.11 13.7 7.16
2025 42.9 15.7 34.8 0.04 4.3 1.41

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Table 1: Project Construction Emissions
Construction Year Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
2026 42.9 1.31 3.7 <0.01 0.72 0.22
SCAQMD Threshold 75 100 550 150 150 55
SCAQMD Threshold
Exceeded? No No No No No No

1. SCAQMD Rule 403 Fugitive Dust applied. The Rule 403 reduction/credits include the following: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; water all haul roads thrice daily; and limit speeds on unpaved roads to 15 miles per hour. Reductions percentages from the SCAQMD CEQA Handbook (Tables XI-A through XI-E) were applied. Pursuant to Certified PEIR Mitigation Measure MM-AQ-1, construction equipment was assumed to be Tier 3 and was applied to the modeling.

No additional mitigation was applied to construction equipment.

Source: CalEEMod version 2022.1.1.14.

Table 2: Project Operational Emissions
Source Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
Area 9.15 0.20 21.40 <0.01 0.01 0.01
Energy 0.06 0.99 0.48 <0.01 0.08 0.08
Mobile 3.59 3.44 29.70 0.07 6.43 1.67
Total 12.80 4.43 51.60 0.08 6.53 1.77
SCAQMD Threshold 55 55 550 150 150 55
SCAQMD Threshold
Exceeded? No No No No No No

1. Worst-case seasonal maximum daily emissions are reported.

Source: CalEEMod version 2022.1.1.14.

Therefore, the Project would be consistent with the 20 22 AQMP, and impacts would be less than significant. Therefore, the Project would not create any new significant impacts or substantially more severe significant impacts than disclosed in the Certified PEIR.

Regarding Threshold (b), pursuant to Certified PEIR Mitigation Measures MM-AQ-1 and MM-AQ-2 and as shown in Table 1 and Table 2 above, the Project’s construction and operational emissions were estimated and were determined to not exceed the applicable SCAQMD daily thresholds.3 The conclusions of the

3 Consistent with the CalEEMod User’s Guide, the air quality modeling uses Project-specific information from the Applicant’s construction team when available; if not the CalEEMod defaults were used.

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Certified PEIR indicated significant and unavoidable construction air quality impacts assuming the developments associated with the Housing Element Update were to occur concurrently. As analyzed in Attachment A of this Memorandum , Project construction emis sions would not exceed the SCAQMD’s significance thresholds for criteria pollutants. Based on SCAQMD guidance, individual construction projects that exceed SCAQMD’s recommended daily thresholds for project -specific impacts would also cause a cumulatively considerable increase in emissions for those pollutants for which the South Coast Air Basin is in non-attainment. As the Project’s construction emissions would not exceed SCAQMD thresholds, the Project’s contribution to cumulative air quality impacts due to regional and localized emissions would also not be cumulatively considerable. The Project would not be required to implement the mitigation measures proposed in the Certified PEIR MMRP, and impacts would be less than significant without such mitigation. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Regarding Threshold (c), Project -related localized construction emissions would not exceed applicable SCAQMD localized significance thresholds, and the Project would not be expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard. Although the Project would not exceed localized significance t hresholds, the Certified PEIR identified that other construction projects in the City analyzed under the Housing Element Update may result in significant and unavoidable localized impacts. While Project construction may contribute to the significant and unavoidable impacts identified in the Certified PEIR due to unknown and uncontrollable overlapping construction, the Project’s construction impacts would be within the scope of impacts analyzed in the Certified PEIR and would not result in new or more severe impacts.

Regarding operational impacts, the analysis prepared for CO attainment in the South Coast Air Basin by SCAQMD can be used to assist in evaluating the potential for project-related CO exceedances in the South Coast Air Basin. CO attainment was thoroughly analyzed as part of SCAQMD’s 2003 AQMP and the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan). 4 As discussed in the 1992 CO Plan, peak
CO concentrations in the South Coast Air Basin are due to unusual meteorologi cal and topographical conditions, and not due to the impact of particular intersections. Considering the region’s unique meteorological conditions and the increasingly stringent CO emissions standards, CO modeling was performed as part of the 1992 CO Plan and subsequent plan updates and AQMPs.

In the 1992 CO Plan, a CO hot spot analysis was conducted for four busy intersections in Los Angeles at the peak morning and afternoon time periods. The intersections evaluated included: Long Beach Boulevard and Imperial Highway (Lynwood); Wilshire Boulevard and Veteran Avenue (Westwood); Sunset Boulevard and Highland Avenue (Hollywood); and La Cienega Boulevard and Century Boulevard (Inglewood). These analyses did not predict a violation of CO standards. The busiest intersection evaluated was that at Wilshire Boulevard and Veteran Avenue, which had a daily traffic volume of approximately 100,000 vehicles per day. The 2003 AQMP estimated that the 1 -hour concentration for this intersection

4 SCAQMD, Federal Attainment Plan for Carbon Monoxide, 1992.

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was 4.6 parts per million ( ppm), which indicates that the most stringent 1 -hour CO standard (20.0 ppm) would likely not be exceeded until the daily traffic at the intersection exceeded more than 400,000 vehicles per day. 5 The AQMP CO hotspots modeling also took into account worst -case meteorological conditions and background CO concentrations. The Los Angeles County Metropolitan Transportation Authority (Metro) evaluated the level of service (LOS) in the vicinity of the Wilshire Boulevard/Veteran Avenue intersection and found it to be L evel E at peak morning traffic and Level F at peak afternoon traffic.6,7 As an initial screening step, if a project intersection does not exceed 400,000 vehicles per day, then the project does not need to prepare a detailed CO hot spot analysis. If a project would potentially result in a CO hotspot based on the initial screening, detailed modeling may be performed using California LINE Source Dispersion Model, version 4 (CALINE4), which is a model used to assess air quality impacts near transportation facilities (i.e., roadways, intersections, street canyons, and parking facilities).

Consistent with the CO methodology above, if a project intersection does not exceed 400,000 vehicles per day, then there is no need to prepare a detailed CO hot spot analysis for the Project . As stated in the Certified PEIR, the roadway segment within the City that would experience the highest level of average daily trips would be Van Buren Boulevard, north of Jurupa Avenue, which would experience 81,400 average daily trips. The highest recorded CO hourly concentration at the Riverside -Rubidoux monitoring station was 2.4 ppm in 2017, which is substantially lower than the California Ambient Air Quality Standards (CAAQS) 1-hour threshold of 20 ppm. T he Project would generate 889 net daily trips, or approximately

1.1 percent of the average trips on Van Buren Boulevard , and total traffic volumes along Van Buren Boulevard during Project operation would be well below the volumes that would cause or contribute to a CO hotspot. There is no reason unique to the South Coast Air Basin meteorology to conclude that the CO concentrations near to Van Buren Boulevard would exceed the 1 -hour CO standard if modeled in detail, based on the studies undertaken for the 2003 AQMP. In addition, CO background concentrations within the vicinity of the modeled intersection have substantially decreased since preparation of the 2003 AQMP primarily due to ongoing fleet turnover of older on -road light duty vehicles and use of cleaner fuels. In 2003, the 1- hour background CO concentration was 5 ppm and has decreased to 2 ppm in 2018.

Therefore, the Project does not trigger the need for a detailed CO hotspots model and would not cause any new or exacerbate any existing CO hotspots. Impacts would be less than significant.

With respect to TACs, the Project’s construction activities would be limited in duration and considered a short-term source of TAC emissions. SCAQMD’s CEQA Air Quality Handbook does not recommend analysis of TACs from short -term c onstruction activities associated with land use development projects. The rationale for not requiring a health risk assessment for construction activities is the limited duration of exposure. According to SCAQMD methodology, health effects from carcinogeni c air toxics are usually

5 Based on the ratio of the CO standard (20.0 ppm) and the modeled value (4.6 ppm). 6 Metro measured traffic volumes and calculated the LOS for the intersection Wilshire Boulevard/ Sepulveda Avenue, which is a block west along Wilshire Boulevard, still east of Interstate 405. 7 Metro, Congestion Management Program for Los Angeles County. Exhibit 2-6 and Appendix A, 2004.

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described in terms of individual cancer risk. Specifically, “Individual Cancer Risk” is the likelihood that a person continuously exposed to concentrations of toxic air contaminants (TACs) over a lifetime will contract cancer based on the use of standard risk assessment methodology, and OEHHA guidance evaluates residential exposure over a 30-year duration.

Because the construction schedule for the Project estimates that construction would be limited to approximately two years, construction of the Project would not result in a substantial, long-term (i.e., 30- year) source of TAC emissions. Long -term emissions of TACs during operations and corresponding individual cancer risk are anticipated to be minimal after construction as the Project does not include any substantial operational sources of TAC emissions (e.g., it is not a warehouse distribution facility). Because there is such a short -term exposure period (approximately two years out of a 3 0-year lifetime), further evaluation of construction TAC emissions is not warranted. As such, Project-related TAC emission impacts during construction would be less than significant and consequently would not result in a potential health risk impact.

From an operational standpoint, the Project would not include any land uses or activities that would involve the use, storage, or processing of carcinogenic TACs. The City follows the guidance of the SCAQMD, which recommends that HRAs be conducted for substantial sources of diesel particulate matter (DPM), such as truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 t rucks with operating transport refrigeration units. Based on this guidance, a HRA is not required as the residential mixed use Project would not generate substantial amounts of DPM during operation.

As such, the proposed Project would not result in new sig nificant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Regarding Threshold (d), odors generated during Project construction would be localized and temporary in nature and would not be sufficient to affect a substantial number of people or result in a nuisance as defined by SCAQMD Rule 402. The Project’s residential and commercial uses are not land uses associated with odor complaints. Therefore, the Project would not create any new significant impacts related to odors nor result in a substantial increase in a previously identified significant impact. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR and the associated MMRP to address air quality impacts were implemented as part of the Project. Certified PEIR MM-AQ-3 related to uses subject to SCAQMD permitting for a ir toxics (e.g., industrial facilities, dry cleaners, and gasoline -dispensing facilities) is not applicable to the Project. No additional mitigation measures are required.

MM-AQ-1: Implement measures to reduce construction-related criteria air pollutant emissions.

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Prior to approval by the City for non -ministerial projects proposed on Opportunity Sites, applicants shall prepare and submit a technical assessment evaluating potential project construction-related air quality impacts to the Planning Division for review and approval. The evaluation shall be prepared in conformance with SCAQMD methodology for assessing air quality impacts. If construction -related criteria air pollutants are determined to have the potential to exceed the SCAQMD -adopted thresholds o f significance, the City shall require that applicants for new development projects incorporate mitigation measures and/or project design features to reduce air pollutant emissions during construction activities. These identified measures shall be incorpor ated into all appropriate construction documents (e.g., construction management plans or construction drawings) submitted to the City and shall be verified by the City’s Building and Safety Division. While specific mitigation measures and/or project design features to reduce construction -related emissions would be determined during project-level analysis, potential mitigation could include, but is not limited to:
• Requiring fugitive-dust control measures that exceed SCAQMD’s Rule 403, such as:
o Use of nontoxic soil stabilizers to reduce wind erosion o Applying water every 3 hours to active soil-disturbing activities o Tarping and/or maintaining a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials
• Using construction equipment rated by EPA as having Tier 3 (model year 2006 or newer) or Tier 4 (model year 2008 or newer) emission limits, applicable for engines between 50 and 750 horsepower
• Ensuring that construction equipment is properly serviced and maintained to the manufacturer’s standards
• Limiting nonessential idling of construction equipment to no more than 5 consecutive minutes • Limiting onsite vehicle travel speeds on unpaved roads to 15 miles per hour • Installing wheel washers for all exiting trucks or washing all trucks and equipment leaving the project area
• Using Super-Compliant VOC paints for coating of architectural surfaces whenever possible MM-AQ-2: Implement measures to reduce criteria air pollutant emissions during operation.

Prior to approval by the City fo r non-ministerial development projects proposed on Opportunity Sites, applicants shall prepare and submit a technical assessment evaluating potential project operation phase-related air quality impacts to the Planning Division for review and approval. The evaluation shall be prepared in conformance with SCAQMD methodology in assessing air quality impacts. If operations -related air pollutants are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the Planning Division shall require incorporation of mitigation measures and/or project design features to reduce air pollutant emissions during operational activities, to be included as part of the conditions of approval. Possible mitigation measures and/or project design features to reduce long -term emissions could include, but are not limited to, the following:

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• Providing truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/u nloading in accordance with CARB Rule 2845 (13 California Code of Regulations Chapter 10 § 2485) • Providing changing/shower facilities as specified in Section A5.106.4.3 of the California Green Building Standards Code (CALGreen) (Nonresidential Voluntary Measures) • Providing bicycle parking facilities per Section A4.106.9 (Residential Voluntary Measures) of CALGreen
• Providing preferential parking spaces for low -emitting, fuel -efficient, and carpool/van vehicles per Section A5.106.5.1 of CALGreen (Nonresidential Voluntary Measures) • Encouraging facilities to support electric charging stations per Section A5.106.5.3 (Nonresidential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of CALGreen
• Providing appliances shall be Energy Star –certified appliances or appliances of equivalent energy efficiency (e.g., dishwashers, refrigerators, clothes washers, and dryers). Installation of Energy Star–certified or equivalent appliances shall be verified by Building & Safety during plan check
• Equipping landscaped common areas with electrical outlets to enable use of electric landscaping equipment to the extent feasible
Conclusion
Based on the above, the Project’s potential environmental impacts to air quality would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.4 Biological Resources
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
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 Wildlife or U.S. Fish and Wildlife S ervice?
Less Than Significant with
Mitigation Incorporated
No Yes
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
Less Than Significant with
Mitigation Incorporated
No Yes

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identified in local or regional plans, policies,
regulations, or by the California Department of Fish
and Wildlife or U.S. 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?
Less Than Significant with
Mitigation Incorporated
No Yes
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?
Less Than Significant with
Mitigation Incorporated
No Yes
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
Less Than Significant No N/A
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state
habitat conservation plan?
Less Than Significant with
Mitigation Incorporated
No Yes

Impact Determination in the Certified PEIR
Impacts regarding biological resources under Thresholds (a) through (d), and (f) were discussed in Section

3.2, Biological Resources, of the Certified PEIR. Threshold (e) was discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that development associated with the Housing Element Update co uld result in direct and indirect impacts on special -status plant and animal species, although impacts are expected to be minor given the placement of the Opportunity Sites within urban, developed areas. Implementation of Mitigation Measure MM -BIO-1 would avoid or minimize any potential impacts on special -status plant and/or animal species. With implementation of Mitigation Measure MM-BIO-1, impacts from the development associated with the Housing Element Update would be reduced to less than significant.

Regarding Threshold (b), the Certified PEIR determined that the Opportunity Sites were selected to avoid greenbelts, arroyos and canyons, and other areas of high biological sensitivity. Future development under the Housing Element Update could result in the removal and/or disturbance of sensitive natural

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communities. Implementation of Mitigation Measure MM -BIO-1 would avoid or minimize any potential impacts on sensitive natural communities. With implementation of Mitigation Measure MM -BIO-1, impacts from the development associated with the Housing Element Update would be reduced to less than significant.

Regarding Threshold (c), although future development associated with the Housing Element Update could result in the removal and/or disturbance of Western Riv erside County Multiple Species Habitat Conservation Plan (WRC MSHCP) -designated Riparian/Riverine habitats, wetlands, and/or potentially jurisdictional aquatic resources, implementation of Mitigation Measure MM -BIO-1 would avoid or minimize any potential impacts on WRC MSHCP-designated Riparian/Riverine habitats, wetlands, and/or potentially jurisdictional aquatic resources. With implementation of Mitigation Measure MM -BIO-1, impacts from the development associated with the Housing Element Update would be reduced to less than significant.

Regarding Threshold (d), trees, shr ubs, and structures throughout the City, including within the Opportunity Sites, could provide suitable habitat for nesting birds, including raptors, protected by the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) sections. Const ruction of future development has the potential to impact active native resident and/or migratory bird nests if, and to the extent that, those trees and shrubs are trimmed or removed, or the structures are demolished, during the avian nesting season and they contain nests. Construction could also occur adjacent to active nests causing nest failures or abandonment. Implementation of Mitigation Measure MM -BIO-1 would avoid or minimize any potential impacts on nesting birds and WRC MSHCP specific planning species are a result of any future development under the Housing Element Update. With implementation of Mitigation Measure MM-BIO-1, impacts from the development associated with the Housing Element Update would be reduced to less than significant.

Regarding Th reshold (e), construction and/or operational activities resulting from development associated with the Housing Element Update could require pruning or tree removal during vegetation clearing and grading and other construction activities. Operational activities designed to keep housing and public safety areas landscaped, clear, and accessible would require vegetation management, which could involve tree-trimming and/or tree removal. The trimming or removal of street trees would be subject to local tree polic ies and ordinances, regardless of whether the work was being performed as a part of construction or operational activities. Future projects under the Housing Element Update would be required to comply with the Urban Forestry Policy Manual, RMC, WRC MSHCP m itigation fees, and the Upper Santa Ana River Habitat Conservation Plan. With compliance with these policies and ordinances, impacts would be less than significant.

Regarding Threshold (f), as described in the Certified PEIR, development associated with the Housing Element Update would be required to implement Mitigation Measure MM -BIO-1 to demonstrate compliance with the WRC MSHCP and to reduce impacts to less than significant.

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Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? As described in Attachment A of this Memorandum, pursuant to Certified PEIR Mitigation Measure MM- BIO-1, a literature review, habitat assessment, and survey were conducted for the Project Site. As determined in the Biological Assessment Report, there are no natural communities on the Project Site. Of the eight special-status plant species considered to potentially occur within the Project Site, none were detected during the site survey. Of the 29 special -status wildlife species considered to potentially occur within the Project Site, none were observed during the site survey. There is no native habitat on -site to support special-status species. The removal of the ruderal vegetation would not threaten or endanger any regional wildlife populations, and the Project Site does not occur within or adjacent to designed critical habitat. Project construction would be subject to the federal MBTA and the CFGC Sections 3503, 3503.5, and 3501 to avoid disturbance of nesting birds.

The Project would be consistent with the WRC MSHCP. The Project Site is not within any wildlife migration corridors identified in the MSHCP Schematic Cores and Linkages Map. The Project Site d oes not contain MSHCP riparian/riverine areas, and none of these areas would be impacted. The Project Site is not located within a Narrow Endemic Plant Species Survey Area, Amphibian Survey Area, Burrowing Owl Survey Area, or Mammal Survey Area as defined in the MSHCP. Therefore, impacts to narrow endemic plant species or wildlife habitat would be covered through payment of appropriate MSHCP development fees, as applicable. Therefore, biological resources impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR and the associa ted MMRP to address biological resources impacts were implemented as part of the Project. No additional mitigation measures are required.

MM-BIO-1: Conduct literature review, habitat assessment, and surveys.

Preliminary Review: Prior to construction on Opportunity Sites that are vacant or where the potential presence of biological or aquatic resources exists, a consistency review shall be performed to ensure that the project is consistent with the requirements of the WRC MSHCP. For the project-specific WRC MSHCP consistency process, the applicant shall employ a qualified biologist approved by the City to review the future Opportunity Site project. The qualified biologist shall conduct a site -specific literature review, which shall consider, at a minimum, the future development project, site location, GIS information, WRC MSHCP survey areas and requirements, and known sensitive biological resources. The review shall assess the site for special-status plants and/or wildlife, aquatic resources, sensitive natural communities, wildlife corridors or nurseries, or other regulated biological resources covered by the WRC MSHCP and/or pursuant to CEQA, FESA, or CESA that could be affected by the project. In some cases, a literature review would be sufficient for the biologist to make a no impact

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and/or a less -than-significant impact determination for all six of the thresholds of significance (Section 3.2.4) of biological resources and/or the determination that the project is consistent with the WRC MSHCP. In this case, no further work shall be required, and if deemed necessary by the City, a summary report stating the basis for these findings, identifying each threshold of significance with a CEQA finding, shall be the only requirement.

Habitat Assessment Survey: If, during the preliminary review, it is determined that potential biological resources including any species covered under the MSHCP exist on the individual Opportunity Site that could be affected, then a habitat assessment survey shall be required unless a qualified biologist determines that a field review/habitat assessment is not needed. If needed, and/or the project is in a WRC MSHCP designated survey area, this survey shall consist of a site visit conducted by a qualified biologist, where the proposed individual development project and adjacent buffer (as appropriate for the target species relative to the potential project direct and indirect impacts) shall be assessed for WRC MSHCP covered species and habitats; candidate, sensitiv e, or special-status plants and/or wildlife; aquatic resources; sensitive natural communities; and wildlife corridors or nurseries while identifying and mapping all vegetation communities and land -cover types. If suitable habitat is present for candidate, sensitive, or special -status plants or animals and cannot be avoided, then focused protocol surveys may be required, as determined by the qualified biologist, with appropriate reporting. If aquatic resources are present and cannot be avoided, a jurisdictional delineation may be required. Mitigation shall include an analysis of all the biological resources identified in the thresholds of significance, with a determination made regarding significance for each threshold. Reporting shall include regulatory assessment, impact analyses, and identification and implementation of appropriate measures based on the presence of biological resources.

Reduce and Avoid Impacts: If, following the literature review and surveys for Opportunity Sites, it is determined that the site would not directly or indirectly affect any WRC MSHCP covered species or habitats; candidate, sensitive, or special -status plants and/or wildlife; aquatic resources; sensitive natural communities; or wildlife corridors or nurseries, then no further action or WRC MSHCP consistency analysis shall be required. If, however, it is determined that impacts on WRC MSHCP covered species or habitats; candidate, sensitive, or special -status plants and/or wildlife; aquatic resources; sensitive natural communities ; or wildlife corridors or nurseries would occur and therefore would be considered significant, then additional mitigation measures as recommended by the qualified biologist and approved by the Planning Division shall be implemented to avoid or reduce impacts to the maximum extent feasible.

Conclusion
Based on the above, the Project’s potential environmental impacts to biological resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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5.5 Cultural Resources
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
CULTURAL RESOURCES: Would the Project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to §
15064.5?
Less Than Significant with
Mitigation Incorporated
No Yes
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to CEQA Guidelines §15064.5?
Less Than Significant with
Mitigation Incorporated
No Yes
c) Disturb any human remains, including those interred outside of formal cemeteries?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding cultural resources under Thresholds (a) and (b) were discussed in Section 3.3, Cultural Resources, of the Certified PEIR (the City of Riverside Housing and Public Safety Element Updates and Environmental Justice Policies Project Final Environmental Impact Report). Threshold (c) was discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that the potential significance of much of the City’s remaining built environment and designed landscapes remains unknown. Therefore, a potential historical resource could be present on an Opportunity Site outside of a previously surveyed area. To mitigate the potential impact to previously unknown Cultural Resources, the Certified PEIR includes MM-CUL-1 as follows:

MM-CUL-1: Conduct a historical resource assessment. The individual applicants shall hire a Secretary of the Interior qualified historic preservation professional to conduct a historical resource assessment if a structure to be affected by a subsequent development project, at the time of application, is not in a previously surveyed area, is not a historical resource for the purposes of CEQA, and is at least 50 years old. The assessment shall formally evaluate the potential resource’s eligibility for listing to the CRHR, its potential eligibility as a Landmark or Structure of Merit, and its potential eligibility as a Contributor to a Historic District or Neighborhood Conservation Area. If the resource is found eligible for any of those designations, it shall be considered a resource that qualifies as a historical resource under CEQA and is therefore subject to the provisions of the Cultural Resources Ordinance. This includes obtaining the pertinent Certificates of Appropriateness and ensuring that the project plans adhere to the SOI

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Standards. For resources found ineligible for any of those designations, no additional mitigation would be necessary.

With implementation of Mitigation Measure MM -CUL-1, impacts on historical resources would be identified allowing for adequate CEQA review at the time of the project review. In 2012, the building in the Project Site was determined ineligible for listing in the California Register of Historical Resources (CRHR). Following this determination, the City of Riverside considered the building’s potential eligibility for local listing or designation through both the local government process and through local planning, and made the determination that the building was ineligible for local listing or designation. Additional details regarding prior inventory and evaluations conducted for the building can be found below and within Attachment C of this Memorandum.

Regarding Threshold (b), most of the Opportunity Sites associated with the Housing Element Update are in areas of unknown a rchaeological sensitivity, while a smaller number of these sites are in areas of low to high archaeological sensitivity. Implementation of Mitigation Measure MM -CUL-2 would reduce impacts to less than significant levels. If archaeological resources are discovered during an archaeological study (Mitigation Measure MM -CUL-2), or if archaeological resources are identified as inadvertent discoveries during ground-disturbing activities, then Mitigation Measures MM-CUL-3 through MMCUL-8 would reduce this impact t o less- than-significant levels. Not all projects would require Mitigation Measures MM- CUL-3 through MM -CUL-8, as these mitigation measures are only applicable if archaeological resources are discovered during an archaeological study (Mitigation Measure MM-CUL-2) or as unanticipated discoveries.

Regarding Threshold (c), State law, including Health and Safety Code Section 7050.5 and PRC Section 5097.98, provides guidance regarding how sites containing human remains must be treated. PRC Section 5097 specifies the procedures to be followed in the event of the unexpected discovery of human remains on nonfederal public lands. While development associated with the Housing Element Update has the potential to disturb human remains, including those outside dedicated c emeteries, if human remains should be discovered on vacant lands or other Opportunity Sites, however unlikely, their treatment would be subject to applicable codes and regulations, notably PRC Section 5097 and Health and Safety Code Section 7050.5, which would ensure that impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), as shown in Attachment C of this Memorandum, the Project Site is not located within a Historic District, potential Historic District, Historic Landmark, on a site with a Structure of Merit, or on the NRHP Site. Therefore, a historical resources assessment (Certified PEIR Mitigation Measure MM-CUL-1) was not required as part of the Project. However, a summary report outlining prior inventory and evaluation efforts conducted for the building within the Project Site was prepared and included in Attachment C of this Memorandum. As further detailed in Attachment C of this Memorandum, the building was recorded and evaluated for significance in 2012 as part of the planning efforts for the University Avenue Specific Plan. The study’s compilation of permit data and

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advertisements showed that the building changed owner/operators several times between the 1940s and 1960s, and again in the mid-1990s, and that the overall appearance of the building was heavily altered over time. The study concluded that the building no longer retained architectural integrity due to the successive alterations over the years, and as such, was not recommended eligible for any local registers or the CRHR. The building was subsequently provided the CRHR Status Code 6L, which notes the building was “determined ineligible for local listing or designation through local government review processes”. CRHR Status Code 6L also notes that a property, though determined ineligible for local listing or designation, may still warrant special consideration in local planning. However, upon review of the building’s status and consideration of the resource within the planning process, the City of Riverside determined the building to be ineligible for local listing or designation. The City then approved modifications to the building in 2015, which included additional substantial alterations to the exterior and façade of the building. Therefore, none of the original historic exterior remains on the existing building, and the property retains none of its original historic integrity. Consequently, the building is not a historical resource as defined by CEQA, and its removal would not result in a significant impact. The Project would result in no impacts on historical resources.

Regarding Threshold (b), as described in Attachment A of this Memorandum, pursuant to Certified PEIR Mitigation Measure MM- CUL-2, an archaeological study was prepared for the Project Site . This study identified two built environment resources consisting of concrete foundations that are ineligible for consideration as potential historical resources under any CRHR criteria 1, 2, 3, or 4. Therefore, the Project would not have a significant impact on these resources . The Project has low to moderate potential for encountering subsurface prehistoric archaeological resources. Because Project construction would include ground disturbance, mitigation measures would be required to reduce potential impacts to previously unknown archaeological resources and human remains to less than significant levels under CEQA. Full time monitoring is not required. However, if unanticipated archaeological resources are encountered, a qualified archaeologist shall be retained, and Certified PEIR Mitigation Measures MM - CUL-4 (Archaeological Treatment Plant), MM -CUL-5 (data recovery), and MM -CUL-8 (treatment and disposition) wou ld be implemented. Certified PEIR Mitigation Measure MM -CUL-9 (cultural sensitivity training) is also recommended prior to commencement of construction activities. With implementation of the aforementioned Mitigation Measures, impacts would be reduced to less than significant.

Regarding Threshold (c), the Project would be required to comply with PRC Section 5097 and Health and Safety Code Section 7050.5, which would ensure that impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR an d the associated MMRP to address cultural resources impacts were implemented as part of the Project. No additional mitigation measures are required.

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MM-CUL-2: Conduct an archaeological study.

For Opportunity Site development projects that require CEQA ana lysis (non -ministerial projects), prior to construction, and if it is determined that the development project will involve ground disturbance of some type, the applicant shall conduct an archaeological study. This study will be conducted during project-specific CEQA analyses at Opportunity Sites that have not been studied in such a manner in the previous 5 years. The archaeological study shall follow the guidelines set forth by the City of Riverside Community & Economic Development Department in the documen t titled Consultant Requirements for Cultural Resources Survey, Studies and Reports Information Sheet (City of Riverside Community & Economic Development Department 2011) or successor document.

The cultural resources archaeological recommendations shall be valid for 5 years after the date of the record search. After 5 years, the applicant shall retain an archaeologist who shall acquire an updated record search from the Eastern Information Center and review the cultural resources technical report recommendations.

For proposed development locations where only a record search and/or a site visit have already been conducted prior to this EIR, the project applicant shall retain an archaeologist to:
• Review record search results, site visit results, and any recommendations. • Obtain an updated record search from the Eastern Information Center if the record search is older than 5 years.
• Review available historic maps, historic aerials, and other archival materials. • Prepare a cultural resources memo with existing or updated record search results; a summary of background research of historic maps, aerials, etc.; and potential for historic and prehistoric archaeological resources to be present at the proposed development location.

Additionally, the memo shall identify potential impacts and provide recommendations.

The City shall review these findings and make a determination regarding the significance of project- level impacts prior to approval of any future development. Should the archaeological study result in the identification of archaeological resources on the proposed development site, or should unanticipated discoveries of previously unknown archaeological resources be made during ground - disturbing activities at an Opportunity Site, Mitigation Measures M M-CUL-3 through MM -CUL-6 would be applicable.

MM-CUL-4: Develop and implement an Archaeological Treatment Plan (ATP) for evaluation of newly discovered and/or unevaluated archaeological resources.

Mitigation Measure MM-CUL-4 shall apply as follows:
• The results of an archaeological study conducted under Mitigation Measure MM-CUL-2 are unable to determine the eligibility of newly identified archaeological sites for inclusion to the CRHR and it is determined by the consulting archaeologist that additional stud y through Phase II testing is required;
• It is not possible to avoid impacts through the establishment of ESAs; or

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• Unanticipated archaeological resources are discovered during construction on Opportunity Sites.

If it is necessary to properly evaluate such p roperties in such a manner, an ATP shall be developed that describes methods and procedures for conducting subsurface excavations to determine the vertical and horizontal extents of an archaeological site. The ATP shall define the parameters of archaeologi cal testing at the site and the extent of excavation and analysis of any materials recovered. The ATP shall also include guidelines for treatment and curation of any materials recovered during the testing process. Subsequent to implementation of the ATP, a technical report describing the methods and results of archaeological testing and formal evaluations of the archaeological sites and recommendations for further treatment shall be completed. The ATP shall be approved by the City and should involve consultation and review by Native American tribes consulting on the proposed development project. An ATP shall only be necessary for newly discovered archaeological sites that require additional information to make determinations of eligibility.

MM-CUL-5: Implement data recovery for CRHR-eligible sites that cannot be avoided.

If archaeological studies identify a cultural resource as being potentially eligible for listing in the CRHR and ESAs cannot be established or project design cannot be altered, resulting in impacts on the site, then a Phase III data recovery program shall be developed, when mutually agreed upon by Native American representatives (for prehistoric or historic-period Native American sites) and the City. The data recovery program shall be outlined in a Data Recovery Treatment Plan that details the procedures and objectives for mitigation of impacts on the archaeological site. The Data Recovery Treatment Plan shall include a research design with testable hypotheses and data requirements necessary to address these hypotheses. Additionally, the Data Recovery Treatment Plan shall identify methods of excavation, analysis, and curation of any archaeological materials recovered. The Data Recovery Treatment Plan shall also identify the treatment of any human remains discovered during data recovery procedures. If the archaeological resource is Native American (prehistoric or historic- period in age), then the City, the applicant, and the archaeologist shall engage in consultation so that Native American representatives can be involved in the development of the data recovery plan.

Data recovery shall involve analysis of a representative sample of the materials recovered during excavation. For prehistoric archaeological sites, all excavations should be monitored by a representative from a geographically appropriate Native American group. At the conclusion of the data recovery program, a data recovery technical report shall be completed detailing the results of the excavations and analysis. Curation of recovered archaeological materials shall be conducted per the guidance in the Data Recovery Treatment Plan and with consultation between the City and appropriate Native American tribes. Other forms of mitigation could include additional research with archival sources, landscape studies, designation of open space, public outreach programs, and public education/public displays.

MM-CUL-8: Employ procedures for treatment and disposition of cultural resources.

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If cultural resources are inadvertently discovered during the course of grading for individual Opportunity Sites, the following procedures shall be carried out for treatment and disposition of the discoveries:

1. Consulting Tribe(s) Notified: Within 24 hours of discovery, and if the resources are Native American in origin, the consulting tribe(s) shall be notified via email and phone. The applicant shall provide the City evidence of notification to consulting tribes. Consulting tribe(s) shall be allowed access to the discovery in order to assist with the significance evaluation.

2. Temporary Curation and Storage: During the course of construction, all discovered resources shall be temporarily curated in a secure location on site or at the offices of the project archaeologist. The removal of any artifacts from a development site shall be thoroughly inventoried with tribal monitor oversight of the process.

3. Treatment and Final Disposition: The landowner(s) shall relinquish ownership of all cultural resources, including sacred items, burial goods, and all archaeologi cal artifacts and non -human remains, as part of the required mitigation for impacts on cultural resources. The applicant shall relinquish the artifacts through one or more of the following methods and provide the City of Riverside Community & Economic Development Department with evidence of same:
a. Accommodate the process for onsite reburial of the discovered items with the consulting Native American tribes or bands. This shall include measures and provisions to protect the future reburial area from any future impacts. Reburial shall not occur until all cataloguing and basic recordation have been completed.
b. Execute a curation agreement with an appropriate qualified repository within Riverside County that meets federal standards per 36 CFR Part 79 and therefore will ensure professional curation and availability to other archaeologists/researchers for further study. The collections and associated records shall be transferred, including title, to an appropriate curation facility within Riverside County, to be accompanied by payment of the fees necessary for permanent curation. c. If more than one Native American tribe or band is involved with the subsequent development project and cannot come to a consensus as to the disposition of cultural materials, curate the discovered items at the Western Science Center or Museum of Riverside by default. d. At the completion of grading, excavation, and ground-disturbing activities on the site, provide to the City a Phase IV Monitoring Report documenting monitoring activities conducted by the project archaeologist and Native American tribal monitors within 60 days of completion of grading. This report shall document the impacts on the known resources on the property; describe how each mitigation measure was fulfilled ; document the type of cultural resources recovered and the disposition of such resources; provide evidence of the required Cultural Sensitivity Training for the construction staff held during the required pre -grade meeting; and, in a confidential appendix, include the daily/weekly monitoring notes from the archaeologist. All reports produced shall be submitted to the City, the Eastern Information Center, and consulting tribes.

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MM-CUL-9: Conduct cultural sensitivity training.

Prior to the commencement of construction activities, the SOI Standards–certified archaeologist and Native American monitors shall attend the pre -grading meeting with the applicant/permit holder’s contractors to provide Cultural Sensitivity Training for all construction personnel. This shall include the procedures to be followed during ground disturbance in sensitive areas and protocols that apply in the event unanticipated resources are discovered. Only construction personnel who have received this training can conduct construction and disturbance activities in sensitive areas. A sign-in sheet for attendees of this training shall be included in the Phase IV Monitoring Report.

Conclusion
Based on the above, the Project’s potential environmental impacts to cultural resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.6 Energy
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
ENERGY: Would the Project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
Less Than Significant No No
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficie ncy?
Less Than Significant No No

Impact Determination in the Certified PEIR
Impacts regarding energy were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that the development associated with the Housing Element Update could result in increased consumption of en ergy resources. F uture developments associated with the Housing Element Update would be required to comply with applicable State, regional, and local plans, ordinances, and regulations related to energy efficiency. None of these future developments would be expected to require an unprecedented amount of energy consumption during construction. Because construction activities are considered to be relatively short term and would cease

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once construction of an individual development is complete, they would repre sent a relatively short demand on local and regional fuel supplies that would be easily accommodated. Overall, construction activities associated with future development in the City would not be any more inefficient, wasteful, or unnecessary than other sim ilar land use development projects of this nature. During operation, future development associated with the Housing Element Update would adhere to applicable federal, state, and local requirements for energy efficiency, including Title 24 standards, and would not result in a substantial increase in demand or transmission service or the need for new or expanded sources of energy supply, new or expanded energy delivery systems, or infrastructure. Residential and mixed -use development associated with the Housing Element Update would not result in a significant environmental impact due to a wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operation. Impacts would be less than significant.

Regarding Threshold (b), all future residential and mixed -use development associated with the Housing Element Update would be required to comply with the latest requirements of the California Building Code (CBC), which contains the mandatory California Green Building Standards (CALGreen) Code, along with the Building Energy-Efficiency Standards. As proposed, all future development projects would be required to obtain appropriate building permits and meet current applicable building standards, including, but not limited to, the CBC, California Electrical Code, and California Energy Code (Title 24). Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a) and Threshold (b) , the Project would be required to comply with the latest applicable requirements of the California Building Code (CBC), which contains the mandatory California Green Building Standards (CALGreen) Code, along with the Building Energy -Efficiency Standards. The Project would be required to obtain appropriate building permits and meet current applicable building standards, including, but not limited to, the CBC, California Electrical Code, and California Energy Code (Title 24). The Project would also be located on an Opport unity Site and would be located near public transit and essential services like neighborhood -serving shopping and amenities. The Project would develop a mixed -use building and increase density on an underutilized site within a developed, urban area. The Project’s location and mix of uses would reduce overall vehicle trips and VMT , and thus transportation energy. The Project will not result in the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

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Conclusion
Based on the above, the Project’s potential environmental impacts to energy would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.7 Geology and Soils
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
GEOLOGY AND SOILS: Would the Project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk or 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?
Less Than Significant No N/A
(ii) Strong seismic ground shaking? Less Than Significant No N/A (iii) Seismic-related ground failure, including
liquefaction?
Less Than Significant No N/A
(iv) Landslides? Less Than Significant No N/A
b) Result in substantial soil erosion or the loss of
topsoil?
Less Than Significant No N/A
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?
Less Than Significant No N/A
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? Less Than Significant No N/A
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water
Less Than Significant No N/A

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disposal systems where sewers are not available for
the disposal of waste water?
f) Directly or indirectly destroy a unique paleonto logical resource or site or unique geologic feature?
Less Than Significant with
Mitigation Incorporated
No Yes

Impact Determination in the Certified PEIR
Impacts regarding geology and soils under Thresholds (a) through (e) were discussed in Section 3.15, Effects Not Found to be Significant , of the Certified PEIR. Threshold ( f) was discussed in Section 3. 4, Paleontological Resources, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that all new residential and mixed -use development in the City would be required to comply with General Plan 2025 Policy PS-1.1, which requires that the developments abide by the most recently adopted City and State seismic and geotechnical requirements. As such, any future development associated with the Housing Element Update would require a geotechnical investigation and/or compliance with the CBC, to address the risk of fault rupture.

Development associated with the Housing Element Update would be required to prepare a geotechnical investigation prior to issuance of permits pursuant to RMC Section 16.08.185 for any property identified as being subject to the potential of liquefaction or within a seismic hazard zone disclosing the site-specific risk of fault rupture at a future development site. Regarding liquefaction, future development associated with the Housing Element Update would be required to comply with General Plan 2025 policies, such as Policy PS-1.6, which requires the City building official to explore and implement, where feasible, best practices and latest technologies to minimize damage to structures in areas determined to have a high liquefaction potential during seismic activities. Regarding landslides, General Plan 2025 includes policies that limit development on steep or unstable slopes, and none of the Opportunity Sites are in these areas, which have been specifically identified to avoid hillsides, arroyos, and canyons as well as areas within the RC – Residential Conservation Zone. Therefore, with compliance with General Plan 2025 policies, RMC standards, CBC standards, and the California Building Standards Code (CBSC) requirements, impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that projects associated with the Housing Element Update with construction activities that are one acre or larger would require a Stormwater Pollution Prevention Plan (SWPPP) in compliance with the Construction Ge neral Permit, local stormwater ordinances, and other related requirements. The SWPPP would require best management practices (BMPs) for earthmoving and clearing activities to minimize any mobilization of sediment, stabilize disturbed areas, and control sed iment. With implementation of a SWPPP with the inclusion of erosion control BMPs, impacts would be less than significant.

Regarding Threshold (c), the Certified PEIR determined that the risk of lateral spreading is highest near the Santa Ana River and alon g arroyos and watercourses, areas where the risk for liquefaction is higher

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than it is in the rest of the City. Any development associated with the Housing Element Update would be required to comply with CBSC requirements, which require submission of a preliminary soils report and a soils engineering analysis to identify unstable geologic units and/or soils. Future developments would also be subject to General Plan 2025 Policy PS -1.1, which would ensure that all new development in the City would abide by the most recently adopted State seismic and geotechnical requirements. Therefore, with compliance with General Plan 2025 policies, RMC standards, CBC standards, and the CBSC requirements, impacts would be less than significant.

Regarding Threshold (d), future development associated with the Housing Element Update would comply with CBSC requirements, which require the submission of a preliminary soils report and a soils engineering analysis. With compliance with the recommendations in the applicable soils repo rt, as well as standard regulations required by the CBSC, impacts would be less than significant.

Regarding Threshold (e), the Opportunity Sites identified in the Housing Element Update are located near existing wastewater infrastructure, and development would connect predominantly to existing water and wastewater disposal lines maintained by the City of Riverside Public Works Department and would not rely on septic tanks or alternative wastewater disposal systems. Impacts would be less than significant.

Regarding Threshold (f), the Certified PEIR determined that depending on the depth of disturbance and how far below ground surface the paleontological resources may be located, these ground disturbances have the potential to damage or destroy such resources. However, in identifying Opportunity Sites, attempts have been made to eliminate locations with high paleontological sensitivity. General Plan 2025 Policy HP -1.3 protects paleontological resources. The policy states that the City shall protect sites of archaeological and paleontological significance and ensure compliance with all applicable state and federal cultural resources protection and management laws in its planning and project review process.

However, despite compliance with General Plan Policy HP -1.3, impacts would remain potentially significant. Implementation of Mitigation Measures MM-PAL-1, MM-PAL-2, and MMPAL-3 would reduce impacts to less-than-significant levels by requiring the project applicant and/or private developer and the City to identif y whether future development sites are in areas of high or undetermined paleontological sensitivity and could have a substantial adverse effect on the significance of unique paleontological resources. If so, a Paleontological Mitigation Plan would be developed that would provide for salvage, curation, and reporting of any paleontological resources uncovered during ground disturbance. With implementation of Mitigation Measures MM -PAL-1, MM- PAL-2, and MM- PAL-3, impacts would be reduced to less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), a Geotechnical Engineering Exploration Report was prepared in February 21, 2022. As stated therein, the Project Site is not located within an Alquist-Priolo Earthquake Fault Zone, and no active faults cross the Project Site. The Project Site is also not located on soils that are considered susceptible to liquefaction. The Project would be required to comply with ap plicable General Plan 2025

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policies, RMC standards, CBC standards, and the CBSC requirements . Impacts would be less than significant.

Regarding Threshold (b), the Project would implement a SWPPP, which would include a Water Quality Management Plan (WQMP) and erosion control BMPs. Impacts would be less than significant.

Regarding Threshold (c), the Geotechnical Engineering Exploration Report determined that the settlement conditions for the Project Site are minor. The Project Site is also not located on soil s that are considered susceptible to liquefaction. Therefore, with compliance with General Plan 2025 policies, RMC standards, CBC standards, and the CBSC requirements, impacts would be less than significant.

Regarding Threshold (d), the Geotechnical Engine ering Exploration Report recommended bearing material would be future compacted fill with conventional foundations to support the building. The soils at the finished grade would have a very low expansion potential. With compliance with the recommendations in the Geotechnical Engineering Exploration Report, as well as standard regulations required by the CBSC, impacts would be less than significant.

Regarding Threshold (e), the Project would not utilize septic tanks or alternative wastewater disposal systems. There would be no impacts.

Regarding Threshold (f), as described in Attachment A of this M emorandum, pursuant to Certified PEIR Mitigation Measure MM- PAL-1, a paleontological resources investigation was prepared. While no paleontological resources were identified within the Project Site, geologic map review, literature review, and the paleontological resources record search revealed that the Project Site is underlain by potentially fossiliferous Older (Pleistocene) silt and clay alluvium, which has produced significant fossils elsewhere in western Riverside County. Because Project construction would include ground disturbance, mitigation measures would be required to reduce potential impacts to paleontological resources to less than significant levels und er CEQA. Certified PEIR Mitigation Measure MM -PAL-2 requires retention of a qualified paleontologist, paleontological monitoring of excavations exceeding 10 feet or when older Quaternary alluvial silts and clays are encountered, salvage and curation of sig nificant fossil discoveries, and final reporting. Certified PEIR Mitigation Measure MM -PAL-3 would also apply to the Project if paleontological resources and sensitive deposits remain or become exposed, then an avoidance and minimization plan would be prep ared. With implementation of the Certified PEIR Mitigation Measures MM-PAL-1, MM-PAL-2, and MM-PAL-3, impacts to paleontological resources would be reduced to less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR and the associated MMRP to address paleontological resources impacts were implemented as part of the Project. No additional mitigation measures are required.

MM-PAL-1: Conduct paleontological resources investigations.

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During the development review process and prior to construction on Opportunity Sites that are located on geologic units with Undetermined, High A, or High B paleontological sensitivity, the project applicant shall conduct paleo ntological resource investigations consistent with SVP guidelines. This process shall include:
• Conducting a paleontological records search through the Los Angeles County Natural History Museum to identify previously recorded paleontological localities and the presence of sensitive deposits in the City
• Reviewing Opportunity Site design and maximum depths and extents of Project ground disturbance components
• Reviewing publicly available geotechnical reports for information concerning subsurface deposits and deposit depths across the City
• Identifying the potential for sensitive paleontological deposits underlying the Opportunity Site that project implementation could affect
• Determining whether impacts on sensitive deposits, if present, would be significant.

If no sensitive deposits are identified or if they are sufficiently deeper than the Opportunity Site excavations and would not be encountered during construction, no further steps shall be required. If sensitive deposits are identified and could be affected by development of the Opportunity Sites, implement Mitigation Measure MM-PAL-2.

Opportunity Site projects that propose accessory dwelling units are not expected to have paleontological resource impacts and no additional assessment is necessary.

MM-PAL-2: Avoid paleontological resources or conduct monitoring.

The applicant shall redesign the Opportunity Site development to avoid sensitive paleontological resources and deposits that could potentially contain these resources. If avoidance and/or Opportunity Site redesign is infeasible, then paleontological monitoring shall be implemented and shall include the following implementation steps:
• The applicant shall retain a qualified paleontologist, who shall attend the preconstruct ion meeting(s) to consult with the grading and excavation contractors or subcontractors concerning excavation schedules, paleontological field techniques, and safety issues. A qualified paleontologist is defined as an individual who (1) has an MS or PhD in paleontology or geology and/or a publication record in peer-reviewed journals; (2) also has demonstrated familiarity with paleontological procedures and techniques; (3) is knowledgeable in the geology and paleontology of the county; (4) has proficiency in recognizing fossils in the field, determining their significance, and collecting vertebrate fossils in the field; and (5) has worked as a paleontological mitigation project supervisor in the county for at least 1 year. • A paleontological monitor or a quali fied paleontologist shall be on site on a full -time basis during excavation and ground -disturbing activities that occur in any undisturbed deposits below ground surface, to inspect exposures for contained fossils. The paleontological monitor shall work und er the direction of the Project’s qualified paleontologist. A

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paleontological monitor is defined as an individual selected by the qualified paleontologist who has experience in the collection and salvage of fossil materials. If fossils that have significance for the scientific record are discovered on a development site, the qualified paleontologist shall recover them and temporarily direct, divert, or halt grading to allow recovery of fossil remains.
• The qualified paleontologist shall be responsible for t he cleaning, repairing, sorting, and cataloguing of fossil remains collected during the monitoring and salvage portion of the mitigation program.
• Prepared fossils, along with copies of all pertinent field notes, photos, and maps, shall be deposited (as a d onation) at a scientific institution with permanent paleontological collections, such as the Los Angeles County Natural History Museum. • Within 30 days after the completion of excavation and ground -disturbing activities, the qualified paleontologist shall p repare and submit to the City of Riverside Community & Economic Development Department, Planning Division a paleontological resource recovery report that documents the results of the mitigation program. This report shall include discussions of the methods used, stratigraphic section(s) exposed, fossils collected, and significance of recovered fossils.

Opportunity Site projects that propose accessory dwelling units are not expected to have paleontological resource impacts and no additional assessment is necessary.

MM-PAL-3: Avoid/minimize impacts on paleontological resources during operations.

If significant paleontological resources and sensitive deposits with the potential to contain significant paleontological resources are identified within an Opportunity Site area during design/planning (Mitigation Measures MM- PAL-1 and MM- PAL-2), and deposits that are sensitive for significant paleontological resources remain exposed at or near the ground surface or become exposed during project operations, then an avoidance and minimization plan shall be prepared to avoid/minimize potential impacts during operations. This plan may include, but not be limited to:
• Securing sensitive deposits from accessibility through the development of exclusion zones • Preparing an operations and maintenance plan to minimize degradation and exposure of sensitive deposits
• Designing and developing interpretive exhibits to provide education and understanding of the importance of avoiding and protecting sensitive deposits and paleontological resources.

If significant impacts on a newly exposed or existing significant paleontological resource cannot be avoided, then Mitigation Measure MM-PAL-2 shall be implemented.

Conclusion
Based on the above, the Project’s potential environmental im pacts to geology and soils would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section

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21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.8 Greenhouse Gas Emissions
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
GREENHOUSE GAS EMISSIONS: Would the Project:
a) Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on
the environment?
Significant and Unavoidable No Yes
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
Significant and Unavoidable No Yes

Impact Determination in the Certified PEIR
Impacts regarding greenhouse gas (GHG) emissions were discussed in Section 3. 5, Greenhouse Gas Emissions, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that construction of new residential and nonresidential development associated with the Housing Element Update would occur intermittently throughout the City over the course of the build -out period (through horizon year 2029). Construction would result in direct GHG emissions generated by vehicle trips (i.e., trips by construction workers and haul trucks) and operation of construction equipment. While the details of future development within the City are currently unknown because development would be driven by market forces and private applicants, it is known that implementation of the Project ultimately would result in more development than previously assumed in the Ci ty’s General Plan 2025. Construction of a multitude of individual development projects throughout the buildout period could generate GHG emissions that could have a significant impact on the environment. Implementation of Mitigation Measure MM -GHG-1 would help reduce GHG emissions from construction-related activities to the extent feasible. However, construction time frames and equipment for site-specific development projects are not available at this time, and there is potential for implementation of the Project to result in significant construction-related GHG emissions.

Despite implementation of Mitigation Measure MM-GHG-1, construction impacts of the Housing Element Update would remain significant and unavoidable.

Regarding operation, the Certified PEIR calculated the operational (e.g., area, energy, mobile, waste, and water) emissions related to the development associated with the Housing Element Update would not exceed the efficiency threshold developed using the best available data from the City’s 201 6 Climate

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Action Plan (CAP) and SCAG population data, in the absence of an appropriate reduction target for 2030.

However, because the CAP does not contain sufficient strategies to meet the Statewide GHG goal established by SB 32 for 2030 and the Statewide goal for carbon neutrality in Executive Order B-55-18 for 2045, mitigation measures are required to ensure that emissions are reduced to the extent feasible. As most operational emissions result from mobile sources, development associated with the Housing Element Update would be required to implement transportation demand management (TDM) strategies to mitigate impacts related to increased vehicle miles traveled (VMT) through Mitigation Measure MM - TRA-1. Energy use emissions, the second largest source of G HG emissions during operation, would be reduced through implementation of Mitigation Measure MM -GHG-2 to ensure that new developments would not include any onsite fuel combustion, and new buildings would be installed with electrical lighting and heating to the extent feasible. Mitigation Measure MM-GHG-3 requires implementation of all feasible CALGreen Tier 1 and Tier 2 voluntary measures to further reduce emissions from operational energy use, water use, and solid waste. Because implementation to these mea sures is not guaranteed to reduce emissions to a level that aligns with Statewide GHG goals, operational impacts of the Housing Element Update would remain significant and unavoidable.

Regarding Threshold (b), the Certified PEIR qualitatively discussed the Housing Element Update’s consistency with relevant plans, including the City’s General Plan 2025, the 2016 CAP, the CARB 2017 Scoping Plan, and other plans, policies, and regulatory programs adopted, drafted, or recommended by CARB and other agencies. While the Housing Element Update would be consistent with the various plans mentioned above, even with implementation of Mitigation Measures MM -GHG-1 through MM -GHG-3, impacts would remain significant and unavoidable.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), as shown in Attachment B of this M emorandum, Project construction would result in approximately 767 metric tons of carbon dioxide equivalent (MTCO 2e) per year without accounting for emission reductions from implementation of Certified PEIR Mitigation Measure MM-GHG-

1. Project operation would result in approximately 2, 243 MTCO2e per year without accounting for emission reductions from implementation of Certified PEIR Mitigation Measures MM-TRA-1, MM-GHG-2, and MM-GHG-3. The Project’s 843 residents and 15 employees8, or service population (SP) of 858, would result in approximately 2. 6 MTCO2e per SP, which would not exceed the efficiency threshold of 2.7 MTCO2e per SP as determined in the Certified PEIR. Therefore, impacts would be less than significant, and no mitigation would be required.

Regarding Threshold (b), the Project would be required to demonstrate consistency with relevant plans, including the City’s General Plan 2025, the 2016 CAP, the CARB 2022 Scoping Plan, and SCAG’s 2020-2045 RTP/SCS objectives.

8 The number of employees is based on an employment generation factor (2.71 employees per 1,000 square feet) from the Los Angeles Unified School District’s Developer Fee Justification Study.

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General Plan 2025
The Project would be consistent with the following General Plan 2025 objectives:

Air Quality Element
• Policy AQ -1.5: The Project would b e infill development in an urbanized area consisting of job centers and transportation nodes.
• Policy AQ-1.6: The Project would also be a mixed-use development that allows the integration of retail and residential uses for the purpose of reducing costs of infrastructure construction and maximizing the use of land.
• Policy AQ-1.15: The Project would establish land use patterns that reduce the number and length of motor vehicle trips and promote alternative modes of travel. • Policy AQ -5.7: The Project would meet the energy use guidelines in Title 24 of the California Administrative Code.

Land Use Element
• Objective LU-8: Emphasize smart growth principles through all steps of the land development process.
o The Project would construct a well-planned infill development in an area that is allowed for increased density (e.g., Opportunity Site) along an established transportation corridor.

The Project would also develop a mixed -use building in an area that is urban and developed with compatible uses.
• Objective LU-9: Provide for continuing growth within the General Plan Area, with land uses and intensities appropriately designated to meet the needs of anticipated growth and to achieve the community’s objectives.
o The Project would assist the City in meeting the Housing Element objectives to expand housing and services for the City’s population, facilitate and encourage new housing types, and provide opportunities for residents to have access to public transit and neighborhood-serving amenities. The Project would also focus development in already urbanized parts of the City to capitalize on existing and planned public facilities, rather than spreading growth to the urban fringes.
• Objective LU-10: Provide for appropriate timing of development in accordance with the future land uses designated in this Land Use Element.
o The Project would be developed on an Opportunity Site and would facilitate redevelopment of a site that is underutilized.
• Objective LU -28: Preserve and enhance the quality and character of Riverside b y ensuring compliance with all relevant codes and regulations.
o The Project would be developed on an Opportunity Site and would facilitate redevelopment of a site that is underutilized.
2016 Climate Action Plan

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The City adopted its CAP in January 2016. While the CAP is not a qualified reduction plan as defined by the CEQA Guidelines, it does propose measures and policies on community -wide and government levels that will support the City’s GHG reduction goals.
• SR-2: Mandatory energy efficiency standards for buildings. o The Project would meet the energy use guidelines in Title 24 of the California Administrative Code.
• T-6: Improve jobs-housing balance and reduce vehicle miles traveled by increasing household and employment densities.
o The Project would be a mixed -use development that would reduce VMT by allowing residents and employees to be co-located on the Project Site.

The Project would support, and not conflict with, the goals of the 2016 CAP.

SCAG 2020-2045 RTP/SCS
Under SB 375, each Metropolitan Planning Organization (MPO) is required to adopt and then update a Sustainable Community Strategy (SCS) to encourage compact development that reduces passenger vehicle miles traveled and trips so that its region will meet a target, set by CARB, for reducing GHG emissions. The purpose of SB 375 is to implement the State’s GHG emissions reduction goals by integrating land use planning with the goal of reducing car and light-duty truck travel.

Reflecting that purpose, the primar y goal of SCAG’s 2020 –2045 RTP/SCS is to provide a framework for achieving the CARB -assigned per capita reduction targets for GHG emissions from cars and light -duty trucks through land use planning and transportation options, while taking into account anticipated future growth within the region. To accomplish this target, the 2020–2045 RTP/SCS identifies various strategies for reducing per capita VMT. New GHG reduction targets are assigned by CARB, and thus, SCAG’s long - range planning document is updated, every four years.

In addition to demonstrating the region’s ability to attain and exceed the GHG emission-reduction targets set forth by CARB, the 2020 –2045 RTP/SCS outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. 2020 –2045 RTP/SCS can be grouped into the following three categories: (1) reduction of vehicle trips and VMT; (2) increased use of alternative fuel vehicles; and (3) improved energy efficiency. As previously discussed, the Project’s consistency with applicable growth forecasts is assessed because the development of the RTP/SCS involved compilation of local land use and growth tre nds to form the basis for projections and strategies of the RTP/SCS. The Project would also be in a very efficient VMT area and on an Opportunity Site near public transit and essential services like neighborhood-serving shopping and amenities, which would make the Project to be consistent with VMT reduction strategies and policies. The Project would be consistent with the CALGreen Code, which would encourage reduction of energy and water usage and waste, thereby reducing associated GHG emissions and helping minimize impacts on natural resources and infrastructure.

Therefore, as the Project would be consistent with the provisions and general policies of the 2020 -2045

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RTP/SCS, which incorporated policies to meet CARB’s targets, the Project would support, and not conflict with, the goals of the 2020-2045 RTP/SCS.

CARB 2022 Scoping Plan
Included in the 2022 Scoping Plan is a set of Local Actions (2022 Scoping Plan Appendix D) aimed at providing local jurisdictions with tools to reduce GHGs and assist the state i n meeting the ambitious targets set forth in the 2022 Scoping Plan. 2022 Scoping Plan Appendix D includes a section on evaluating plan-level and project -level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies s everal recommendations and strategies that should be considered for new development in order to determine consistency with the 2022 Scoping Plan. Notably, this section is focused on Residential and Mixed-Use Projects. CARB specifically states that Appendix D does not address other land uses (e.g., industrial). However, CARB plans to explore new approaches for other land use types in the future.

Appendix D notes that residential and mixed-use projects that meet the following three priority areas are “clearly” consistent with the State’s goals and projects that have these key project attributes should accommodate growth in a manner consistent with State GHG reduction and equity prioritization goals.

Appendix D also notes that lead agencies may determine, with adequate additional supporting evidence, that projects that incorporate some, but not all, of the key project attributes are consistent with the State’s climate goals.

1. Transportation Electrification: The Project would not affect local government fleets, and therefore, would not convert local government fleets to electric vehicles (EV). This goal is not applicable to the Project. However, the Project would provide parking spaces for EV and clean air vehicles.

2. VMT Reduction: The Project would be located on an Opportunity Site and would be located near public transit and essential services like neighborhood -serving shopping and amenities. The Project would also increase density on an underutilized site and would be located in a developed, urban area. Therefore, the Project would be consistent with this goal.

3. Building Decarbonization: The Project would be required to comply with the latest Title 24 and CALGreen Code requirements. The Project would also construct a modern building with updated equipment and appliances, which would be more energy -efficient than the existing building.

Therefore, the Project would be consistent with this goal.

The Project would support, and not conflict with, the goals of CARB’s 2022 Scoping Plan.

Based on the analysis above, the Project would be consistent with the relevant plans and policies listed above. Impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

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Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to GHG emissions would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Suppl emental or Subsequent EIR.

5.9 Hazards and Hazardous Materials
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
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?
Less Than Significant No N/A
b) Create a significant hazard to the public or the
environment through the reasonably foreseeable
upset and accident conditions involving the likely
release of hazardous materials into the
environment?
Less Than Significant with
Mitigation Incorporated
No Yes
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
Less Than Significant with
Mitigation Incorporated
No Yes
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code §65962.5 and, as a result, would it
create a significant hazard to the public or the
environment?
Less Than Significant with
Mitigation Incorporated
No Yes
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
Less Than Significant No N/A

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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?
Less Than Significant No N/A
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding hazards and hazardous materials under Thresholds (b), (c), and (d) were discussed in Section 3.6, Hazards and Hazardous Materials, of the Certified PEIR. Threshold s (a), (e), (f), and (g) were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that materials typically used in constru ction projects, such as fuel, paint products, lubricants, solvents, cleaning products, and fertilizers , would not represent the transport, use, and disposal of hazardous materials. The transport, use, and disposal of hazardous materials must comply with ap plicable federal and State regulations, such as the Resource Conservation and Recovery Act and Department of Transportation Hazardous Materials Regulations. For facilities that handle hazardous materials during operations, California Health and Safety Code Section 25507 requires businesses to establish and implement a Hazardous Materials Business Plan for emergency response to a release or threatened release of a hazardous material. This requirement applies to businesses that handle a hazardous material or a mixture above the thresholds described in California Health and Safety Code Section 25507. Therefore, impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that construction of a new residential or mixed - use devel opment would involve ground -disturbing activities such as, but not limited to, grading and excavation. Ground-disturbing activities have the potential to encounter and release contaminated soils or groundwater and could potentially expose people or the env ironment to these hazardous materials.

The potential to expose hazardous materials during ground disturbance would exacerbate the conditions on site by releasing hazardous materials to the environment (in the form of contaminated media), and therefore woul d result in impacts related to accidental conditions. Prior to the commencement of a construction project, Mitigation Measure MM -HAZ-1 would be implemented, which would require a project-level hazardous material site assessment for construction of the spec ific project, which would verify the presence or absence of hazardous materials on any Opportunity Site and require subsequent measures, if necessary, based on the conditions on the site. With implementation of Mitigation Measure MM-HAZ-1, impacts would be reduced to less than significant.

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Regarding Threshold (c), the Certified PEIR determined that there are several locations , including Opportunity Sites, where ground-disturbing construction could occur within or immediately adjacent to a hazardous material site that are within 0.25 mile of a school site. Therefore, soil- disturbance activities could encounter contaminated groundwater and/or contaminated soil within 0.25 mile of a school, and impacts are potentially significant. Implementation of the proposed policies and Mitigation Measure MM- HAZ-1 would reduce impacts to less than significant.

Regarding Threshold (d), construction could occur within or immediately adjacent to a site fitting the Cortese List site criteria as a result of buildout of the Housing Element Update, and impacts would be potentially significant. Implementation of the proposed policies and Mitigation Measure MM -HAZ-1 would reduce impacts to less than significant.

Regarding Threshold (e), the Housing Element Update would not propose future residential and/or mixed- use development on Opportunity Sites within a restricted Airport Influence Areas (AIA) for any of the airports within or adjacent to the City . The Opportunity Sites were identified based on compatible land use criter ia and established Land Use Compatibility Zones of the Riverside County Airport Land Use Compatibility Plan Policy Document. The Housing Element Update would not result in a change in air traffic patterns or result in a safety hazard for people residing or working in the City, and impacts would be less than significant.

Regarding Threshold (f), the developments associated with the Housing Element Update would be required to comply with the Riverside County Operational Area Multi -Jurisdictional Local Hazard Mitigation Plan, General Plan 2025 policies, and the updates to the City’s Public Safety Element. With continued use of the Standardized Emergency Management System (SEMS) and the Riverside County Operational Area Multi-Jurisdictional Local Hazard Mitigation Plan, as well as implementation of General Plan 2025 policies and Public Safety Element principles, impacts would be less than significant.

Regarding Threshold (g), the Certified PEIR determined that portions of the City are in areas classified as Very High Fire Hazard Severity Zones (VHFHSZ) . The Certified PEIR determined that development associated with the Housing Element Update would not include housing and mixed -use development within wildfire hazard areas. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), construction and operation of the Project would use fuel, paint products, lubricants, solvents, cleaning products, and fertilizers that woul d be transported, used, and disposed of .

These materials are typically used in construction projects and would not represent the transport, use, and disposal of hazardous materials. Project operation would transport, use, and dispose of potential hazardous materials in compliance with applicable State and federal regulations. Impacts would be less than significant.

Regarding Threshold (b), the Project Site is not an existing hazardous materials site and is not a Cortese List site. While the building was constructed prior to 1980 and would be demolished as part of the Project,

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an asbestos survey will be conducted in accordance with Cal/OSHA (CCR Title 8, Section 1529) and the National Emission Standards for Hazardous Air Pollutants for Asbestos Surveys (40 C FR 61, Subpart M).

CCR Title 8, Section 1532.1, “Lead,” and Cal/OSHA requirements will be followed when handling materials containing lead. With compliance with regulatory standards, impacts would be less than significant.

Regarding Threshold (c), the Proj ect Site is not within 0.25 mile of a school. Impacts would be less than significant.

Regarding Threshold (d), the Project Site is not on the Cortese List. The Project Site is also not listed on the California Department of Toxic Substances Control (DTSC) EnviroStor database and State Water Resources Control Board GeoTracker database. Impacts would be less than significant.

Regarding Threshold (e), the Project would not be located within two miles of a public airport or public use airport. There would be no impact.

Regarding Threshold (f), the Project would be required to comply with the Riverside County Operational Area Multi-Jurisdictional Local Hazard Mitigation Plan, General Plan 2025 policies, and the updates to the Public Safety Element. The Pr oject would be developed in an urban area with existing roadways that service emergency vehicles. Therefore, impacts would be less than significant.

Regarding Threshold (g), according to the California Department of Forestry and Fire Protection (CAL FIRE), the Project Site is not within a State Responsibility Area (SRA) or Local Responsibility Area (LRA) VHFHSZ.

There would be no impact.

As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Projec t’s potential environmental impacts to hazards and hazardous materials would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.10 Hydrology and Water Quality
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
HYDROLOGY AND WATER QUALITY: Would the Project:

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a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
Less Than Significant No N/A
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
Less Than Significant No N/A
c) Substantially alter the existing drainage patte rn 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?

(i) result in substantial erosion or siltation on - or off site;
Less Than Significant No N/A
(ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or off-site;
Less Than Significant No N/A
(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
Less Than Significant No N/A
(iv) impede or redirect flood flows? Less Than Significant No N/A d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less Than Significant No N/A
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
Less Than Significant No N/A
Impact Determination in the Certified PEIR
Impacts regarding hydrology and water quality were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that construction and development associated with the Housing Element Update would have the potential to temporarily increase sediment loads and affect surface water quality during ground disturbance and other construction activities. Individual

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development projects involving land disturbance of one ac re or more would be subject to NPDES requirements and be required to develop and implement a project-specific SWPPP in compliance with the Construction General Permit, local stormwater ordinances, and other related requirements. Also, individual development projects would generally require grading permits and erosion control plans to be submitted prior to construction. Construction BMPs would control or prevent the discharge of pollutants, including concrete, waste from pavement cutting, petroleum products, chemicals, wastewater, sediments, and non-stormwater discharges, to storm drains and water courses. In addition, construction materials and wastes would be stored, handled, and disposed of in compliance with applicable regulations to prevent contact with stormwater. Earthmoving and clearing activities would be performed during dry weather only to minimize any mobilization of sediment. Temporary erosion controls, as applicable, would be implemented to stabilize disturbed areas until permanent erosion controls can be established. Project- specific WQMPs would also be prepared that would outline the low -impact development (LID) BMPs required to meet water quality standards and reduce stormwater runoff. Impacts would be less than significant.

Regarding Threshold (b), implementation of development projects associated with the Housing Element Update may increase the impervious surface area and potentially decrease groundwater recharge.

However, some of the individual development could decrease the impervious surface area through the addition of pervious surfaces and landscaping compared to existing condit ions and potentially increase groundwater recharge. Stormwater infiltration measures would be implemented to allow runoff to infiltrate the soil media and percolate into the ground, which would allow groundwater recharge and increase recharge potential wit hin individual project areas. No Opportunity Sites are located in the immediate vicinity of the Western Municipal Water District recharge basin. Impacts would be less than significant.

Regarding Threshold (c.i), construction activities would temporarily alter existing drainage patterns and could result in temporary onsite erosion and siltation. New development would be subject to NPDES requirements, and projects with one acre or more of disturbance would prepare and implement a SWPPP.

Project-specific WQMPs would outline the LID BMPs required to adequately reduce stormwater runoff and erosion. Runoff from impervious areas would be directed to permeable surfaces, landscaping, or other LID areas. In addition, storm drain infrastructure would be designed and maintained in compliance with the City’s MS4 permit and applicable General Plan 2025 policies and ordinances. Impacts would be less than significant.

Regarding Threshold (c.ii), some of the future development associated with the Housing Element Update could increase the amount of impervious surface area compared with existing conditions, likely resulting in a net increase in the volume of runoff and floodwater leaving some of the individual Opportunity Sites.

Project-specific WQMPs, as applicable, would be prepared, outlining the LID BMPs required to reduce stormwater runoff. Future development must implement the BMPs identified in the project -specific SWPPP prior to the commencement of construction to reduce on- or offsite flooding. Onsite stormwater runoff and flooding would be minimized through site development using citywide landscape and irrigation

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and mixed-use design guidelines provided in the Riverside Citywide Design Guidelines and Sign Guidelines.

Impacts would be less than significant.

Regarding Threshold (c.iii), BMPs would be implemented to reduce adverse water quality impacts resulting from development. Development would also be required to comply with water quality measures pursuant to the City’s MS4 permit. The WQMP would outline the BMPs required to adequately reduce stormwater runoff; these would be approved prior to development approvals and issuance of grading permits. The City has developed a 5 -year Capital Improvement Program (CIP), which includ es a Storm Drain Program. The City would continue to fund and undertake storm drain improvement projects identified in the CIP. Impacts would be less than significant.

Regarding Threshold (c.iv), the City would review all development proposals to determine if an individual development project is proposed in a flood hazard area. Runoff from new development would be evaluated and attenuated on site if located within a Federal Emergency Management Agency (FEMA) 100- year flood zone. Stormwater infiltration meas ures such as infiltration beds, swales, basins, and other landscape features encouraged by the Citywide Water Efficient Landscaping and Irrigation Design Guidelines would be implemented on future development where feasible. These features would increase onsite infiltration and minimize the potential for overland floodflows. Impacts would be less than significant.

Regarding Threshold (d), the Certified PEIR determined that the City is not prone to inundation due to tsunamis or seiches. In the event of a floo d hazard, to reduce the risk of a pollutant release, individual projects associated with the Housing Element Update would comply with the requirements of local water quality programs and associated municipal stormwater-related NPDES permits (e.g., MS4 permit, project- specific WQMP) as well as GP 2025 policies and the Public Safety Element Update to manage flood risk and water quality. Compliance with these requirements would minimize risks related to a release of pollutants due to any potential inundation i n a flood hazard, tsunami, or seiche zone. Impacts would be less than significant.

Regarding Threshold (e), the Certified PEIR determined that implementation of the Housing Element Update would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. Commonly practiced BMPs would be implemented to control construction site runoff and reduce discharges of pollutants (i.e., stormwater and other nonpoint-source runoff) to storm drain systems. As part of compliance with permit requirements during ground-disturbing or construction activities, implementation of water quality control measures and BMPs would ensure that water quality standards would be achieved. The NPDES Construction General Permit als o requires stormwater discharges not to contain pollutants that cause or contribute to an exceedance of any applicable water quality objectives or water quality standards, including designated beneficial uses.

Impacts would be less than significant.

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Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), the Project would involve land disturbance of more than one acre and would be subject to NPDES requirements. A project -specific SWPPP would be deve loped and implemented in compliance with the Construction General Permit, local stormwater ordinances, and other related requirements. A Project-specific WQMP would also be prepared that would outline the LID BMPs required to meet water quality standards and reduce stormwater runoff. Impacts would be less than significant.

Regarding Threshold (b), the Project would not utilize groundwater supplies and would include landscaping features on-site to increase groundwater recharge. Impacts would be less than significant.

Regarding Threshold (c), the Project would implement a SWPPP and develop a WQMP to outline LID BMPs to reduce stormwater runoff and erosion. The Project is not located within a FEMA 100 -year floodplain and would be designed to minimize on -site stormwater runoff and flooding. Impacts would be less than significant.

Regarding Threshold (d), the Project is not located in a flood hazard area and would not be prone to flood, seiche, tsunami, or other inundation hazards. Therefore, the Project would n ot result in a release of pollutants due to inundation within a flood, tsunami, or seiche hazard zone. Impacts would be less than significant.

Regarding Threshold (e), the Project would comply with NPDES requirements and would implement water quality control measures and BMPs to ensure that water quality standards are achieved. Impacts would be less than significant . As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to hydrology and water quality would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that wou ld require the preparation of a Supplemental or Subsequent EIR.

5.11 Land Use and Planning
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
LAND USE AN DPLANNING: Would the Project:

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a) Physically divide an established community? Less Than Significant No N/A 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?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding land use and planning were discussed in Section 3. 7, Land Use and Planning , of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that implementation of the Housing Element Update would not divide, disrupt, or isolate an existing community or neighborhood. The physical division of an established community could occur if a major road (expressway or freeway, for example) were built through an existing community or neighborhood, or if a major development was built that was inconsistent with the land uses in the community such that it divided the community. The environmental effects caused by such a facility or land use could include obstruction or disruption of access to services, schools, or shopping areas. Development associated with the Housing Element U pdate would largely be in infill development, redevelopment, and/or adaptive reuse, and the development would be focused in already urbanized parts of the City near existing infrastructure. No major roadways that would traverse an existing community or neighborhood would be proposed. Impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR evaluated consistency with regional land use plans and local land use plans, including the City’s General Plan 2025 and SCAG’s 2020-2045 RTP/SCS. As discussed in the Certified PEIR, the Housing Element Update would be substantially consistent with objectives and policies that aim to provide housing of types, sizes, densities, and affordability levels required to satisfy the varying needs and desires of all segments of the community’s population. The Housing Element Update would be consistent with SCAG’s 2020 -2045 RPT/SCS goals and adopted growth forecasts. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), the Project would be developed in a developed, urban area. The Project would not develop a major road through the Project Site or a major development inconsistent with the land uses in the community. The Project would be consistent with the General Plan and zoning designation for the Project Site. Impacts would be less than significant.

Regarding Threshold (b), the Project would be located on an Opportunity Site and would be located near public transit and essential services like neighborhood -serving shopping and amenities. Therefore, the Project would be an infill development consistent with the growth projections of the Housing Element Update, SCAG’s 6
th RHNA Cycle, and SCAG’s 2020-2045 RTP/SCS. The Project would also be consistent with

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the General Plan 2025 objectives and policies that were intended to assist the City in achieving SCAG’s goals, such as Objective LU -8 related to smart growth principles fo r infill development and increased density in selected areas along established transportation corridors; Objective LU-9 related to continuing growth in areas designed to meet the needs of anticipated growth; and Policy LU -28.2 related to redeveloping an un derutilized site to prevent further deterioration . For more details, see Section 5.8, Greenhouse Gas Emissions, above. Therefore, impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substanti ally more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to land use and planning would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.12 Mineral Resources
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
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 and the
residents of the state?
No Impact No N/A
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 ?
No Impact No N/A

Impact Determination in the Certified PEIR
Impacts regarding mineral resources were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that mineral extraction does not play a major role in the City’s economy, and there are no known substantial mineral deposits. Development on Opportunity

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Sites within areas classified as mineral resource zones would not result in a loss of known mineral resources that would be of value to the region and residents of the State. There would be no impacts.

Regarding Threshold (b), the Housing Element Update would not result in the loss of availability of a locally important mineral resource recovery site delineated in the General Plan 2025, a Specific Plan, or any other land use plan. There would be no impact.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a) and (b), the Project Site would not be located in areas designated as a mineral resource zone. Development of the Project would not result in the loss of availability of a locally important mineral resource recovery site. There would be no impact. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to mineral resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.13 Noise
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
NOISE: Would the Project:
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 or noise ordinance, or applicable
standards of other agencies?
Significant and Unavoidable No Yes
b) Generation of excessive groundborne vibration or
groundborne noise levels?
Significant and Unavoidable No Yes
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
Less Than Significant No N/A

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public airport or public use airport, would the project expose people residing or working in the project area
to excessive noise levels?

Impact Determination in the Certified PEIR
Impacts regarding noise were discussed in Section 3.8, Noise, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that the construction vehicles would incrementally increase noise levels on access roads and on future development sites. This would include construction worker vehicles and haul trucks traveling to and from proposed development sites. Although there would be a relatively high single -event noise level, which could cause an intermittent noise nuisance (e.g., passing trucks at 50 feet would generate up to 77 dBA), the effect on longer -term ambient noise levels would be transitory and minimal. RMC Section 7.35.020 requires construction to be limited to 7:00 a.m. through 7:00 p.m. on weekdays and 8:00 a.m. through 5:00 p.m. on Saturdays, and all construction activities to be prohibited on Sundays and federal holidays. With implementation of construction BMPs detailed in the Certified PEIR , such as utilizing quietest available construction equipment or equipping mufflers or s ilencers on construction equipment, and compliance with the RMC, construction noise impacts would be less than significant.

The Certified PEIR determined that future operational traffic noise by the Opportunity Sites would exceed the relevant thresholds outlined by General Plan 2025. Mitigation Measure MM-NOI-1 would be required to reduce the impacts to the greatest extent practical. However, even with implementation of Mitigation Measure MM-NOI-1, impacts from operational traffic noise would remain significant and unavoidable.

The potential for operational stationary noise (e.g., from HVAC systems) may exceed both the daytime and/or nighttime sound level limits from the RMC. Even with implementation of Mitigation Measure MM- NOI-2, impacts from operational stationary noise would remain significant and unavoidable.

Regarding Threshold (b), the Certified PEIR determined that heavy construction equipmen t has the potential to produce groundborne vibration levels that are perceptible to people in the surrounding area and that would be intermittent sources for damage to buildings. As the location of construction is not known at this time, construction vibration levels cannot be calculated at specific vibration-sensitive land uses. Therefore, impacts from vibration would be potentially significant. Even with the implementation of Mitigation Measure MM-NOI-3, impacts could remain significant and unavoidable.

The Certified PEIR determined that truck pass-by vibration would not result in potential damage to nearby structures. Vibration would not be noticeable outside of 50 feet from the roadway. As the long -term operation of development projects associated with Housing Element Upda te, residential and mixed use projects, would not result in significant sources of vibration, impacts would be less than significant.

Retarding Threshold (c), the Certified PEIR determined that noise from aircraft on departure or approach to the Riverside Municipal Airport, Flabob Airport, and March Reserve Airforce Base would be audible at

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many of the Opportunity Sites identified throughout the City. However, n one of the Opportunity Sites identified would be within the 60 or 65 dBA CNEL contour from the surrounding airports. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), as described in Attachment A of this M emorandum, with implementation of Certified PEIR Mitigation Measures MM-NOI-1 and MM-NOI-2, the Project’s construction and operation- related noise impacts were estimated and were determined to not exceed the appropriate agency (e.g., Federal Transit Administration [FTA], Federal Highway Administration [FHWA], and RMC) thresholds.

Construction and operational noise impacts would be less than significant.

Regarding Threshold (b), as described in Attachment A of this Memorandum, groundborne vibration levels were estimated based on the specific construction equipment needed to construct the Project. Based on this equipment list and the distance to off-site vibration-sensitive land uses, the vibration velocities from Project construction would be below the FTA’s threshold for b uilding damage and the California Department of Transportation’s (Caltrans) threshold for human annoyance , without the need for mitigation measures. Further, once operational, the Project would not include vibration-generating uses or operations. Impacts would be less than significant.

Regarding Threshold (c), the Project would not be located within two miles of a public airport or public use airport. There would be no impact. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR and the associated MMRP to address cultural resources impacts were implemented as part of the Project. No additional mitigation measures are required.

MM-NOI-1: Prepare a focused noise study and implement findings to reduce traffic noise.

For Opportunity Site projects that would exceed the 60 or 65 dBA CNEL threshold (based on the noise contour maps included in GP 2025), the applicant shall prepare a detailed analysis and implement mitigation to comply with the applicable City standards outlined in GP 2025. This could include but would not be limited to actions such as:
• Installation of soundwalls to break the line of sight from noise sources such as traffic noise • Installation of noise-reducing insultation
• Installation of windows with sound transmission class (STC) ratings appropriate to reduce exterior-to-interior noise transmission
• Installation of HVAC systems
MM-NOI-2: For any development where stationary noise sources may exceed interior or exterior noise standards, prepare a focused noise study and implement findings to reduce HVAC noise.

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The applicant shall design HVAC systems for Opportunity Sites to comply with the applicable City Municipal Code standards. This could include but would not be limited to actions such as:
• Preparation of a focused noise study to analyze HVAC noise, which shall identify a location for HVAC systems at appropriate distances so as to not exceed a noise level of 55 dBA L eq (exterior) and 45 dBA L eq (interior) between the hours of 7:00 a.m. and 10:00 p.m. and 45 dBA Leq (exterior) and 35 dBA Leq (interior) between the hours of 10:00 p.m. and 7:00 a.m. at the closest noise-sensitive land use. Design features that could be used to comply with the relevant threshold could include but are not limited to:
o Locating HVAC systems far enough from residences so as to allow noise to attenuate to below the relevant standards
o Installing housings or structural parapets around HVAC systems o Installing noise-reducing insulation
o Installing windows with STC ratings appropriate to reduce exterior-to-interior noise transmission
Conclusion
Based on the above, the Project’s potential environmental impacts to noise would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.14 Population and Housing
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
POPULATION AND HOUSING: Would the Project:
a) Induce substantial unplanned 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)?
Significant and Unavoidable No N/A
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere ?
Less Than Significant No N/A

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Impact Determination in the Certified PEIR
Impacts regarding population and housing were discussed in Section 3.9, Population and Housing, of the Certified PEIR. Threshold ( b) is discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determi ned that the rezoning associated with the Housing Element Update would result in an increase in the number of new housing units between 2021 and 2029 of up to approximately 24,000 to fulfill the City’s RHNA obligation. Rezoning that would occur as part of the Housing Element Update would allow for development of up to 31,564 housing units, if all sites were developed to the maximum proposed zoning capacity. According to SCAG, the population of the City is projected to increase to 395,800 by 2045, which repr esents an increase of 20.61 percent from the 2020 population of 328,155. Based on Department of Finance population and housing estimates, the City’s current average household size is 3.28 persons. The increase in population that would potentially result by adding 31,564 new housing units would result in a population increase of 103,530 persons, which would be greater than the SCAG 2045 population projection of 67,645 new residents. Implementation of the Housing Element Update would result in additional hous ing beyond what is currently allowed under the existing General Plan 2025 and SCAG projections. This could result in an additional net increase of 47,175 in City population beyond what is currently anticipated at build -out under General Plan 2025 (increase of 56,355 persons). As the development associated with the Housing Element Update would result in projections beyond what was anticipated in the General Plan 2025 and no mitigation is available to reduce this impact to a less-than-significant level, impacts would be significant and unavoidable.

Regarding Threshold (b), the potential exists for an increase in the number of new dwelling units, up to approximately 31,564. Some redevelopment could result in the removal of existing housing (up to approximately 389 dwelling units), but this is anticipated to be minimal and would not displace a substantial number of people or existing housing units relative to the overall scale of the Housing Element Update. Any existing units removed through redevelopment would b e replaced with new units per the requirements of SB 166 (No Net Loss). Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), based on the City’s average household size of 3.28, the Project’s 257 dwelling units would result in 843 new residents, which would represent approximately 1. 2 percent of the estimated population growth (approximately 67,645 new residents) forecasted by SCAG’s 20 20-2045 RTP/SCS between 2020 and 2045. The Project’s residents would be part of the Housing Element Update and within SCAG’s projected population update. Impacts would be less than significant.

Regarding Threshold (b), the Project Site is currently developed with commercial uses. The Project would not displace people or housing. There would be no impact. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

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Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to population and housing would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.15 Public Services
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
PUBLIC SERVICES: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significa nt environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection? Less Than Significant No N/A
b) Police protection? Less Than Significant No N/A
c) Schools? Less Than Significant No N/A
d) Other facilities, including libraries? Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding public services were discussed in Section 3.10, Public Services, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that the demand for fire protection services would increase as a result of future development associated with the Housing Element Update. Future residential and mixed-use development would increase the use of existing fire protection services, which could cause physical deterioration of existing facilities. State, county, and City jurisdictions have policies related to providing adequate fire services to the area. All development would b e constructed in accordance with current building and fire/life/safety ordinances and codes, including all applicable County of Riverside and City jurisdiction code requirements related to construction, access, water mains, fire flows, and hydrants. Future development within Riverside County would be required to comply with Riverside Fire Department (RFD) and fire safety regulations. Compliance with the above-mentioned State and local regulations would ensure that there would be sufficient fire protection s ervice and facilities to

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accommodate additional population resulting from residential and mixed-use development and resulting population growth associated with the Housing Element Update. Impacts would be less than significant.

Regarding Threshold (b), the increase in dwelling units would increase population and could result in a permanent increase in demand for police protection services in areas served by the Riverside Police Department (RPD). The RPD would evaluate its budget annually to provide adequate police services, including police staffing increases, to accommodate additional growth associated with development facilitated by the Housing Element Update. The City would continue to meet the recommended police response times. Compliance with the above -mentioned State and local regulations would ensure that there would be sufficient police protection service and facilities to accommodate additional population resulting from development and resulting population growth associated with the Housing Element Update. Impacts would be less than significant.

Regarding Threshold (c), the increase in dwelling units from the Housing Element Update would increase population and could result in a permanent increase in demand for public school services in areas served by Riverside Unified School District (RUSD) and Alvord Unified School District (AUSD). Some of the new residents may attend private schools or charter schools, or they may be home schooled. Future residential development would co mply with RMC Chapter 16.56, School Development Fee, which establishes coordination between the City and the applicable school district to develop a school development fee for mitigating the impact of residential development on local school districts. In a ddition, legislation allows school districts to collect impact fees from developers of new residential and commercial uses. Pursuant to Government Code Section 65996, school fees imposed through the Education Code are deemed to be full mitigation for new d evelopment projects; the City cannot impose additional mitigation measures.

Compliance with the above -mentioned state and local regulation would ensure that there would be sufficient facilities and service to accommodate additional students resulting from development and resulting population growth associated with the Housing Element Update. Impacts would be less than significant.

Regarding Threshold (d), potential impacts would include placing greater demands on public service facilities, potentially resulting in the need to provide new or expanded facilities in order to maintain an acceptable level of service. Additionally, use of existing public services facilities would increase, which could cause physical deterioration of the facility. Library service needs and standards are determined by the following methods: volumes by population, community need/service gaps (including services provided/not provided by other area departments and agencies), customer requests, and innovation/success of pilot projects. Compliance with General Plan 2025 would ensure that the Housing Element Update would not affect the City’s ability to provide adequate libraries. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Thresholds (a) and (b), the Project would result in 843 new residents and would be required to comply with all applicable state and City regulations. Compliance with the above -mentioned state and

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local regulations would ensure that there would be sufficient fire protection and police protection service and facilities to accommodate additional population resulting from mixed -use development and associated population growth from the Project. Impacts on fire and police protection services would be less than significant.

Regarding Threshold (c), the Project’s 257 dwelling units and 843 new residents could result in an increase in students attending RUSD and AUSD schools. The Project would be required to comply with RMC Chapter

16.56, which requires payment of a school development fee to mitigate the impact of residential development on local school districts . Pursuant to Government Code Section 65996, no additional mitigation would be required for new development projects related to public school services. Compliance with the above-mentioned state and local regulation would ensure that there would be sufficient facilities and service to accommodate additional students resulting from development and associated population growth from the Project. Impacts would be less than significant.

Regarding Threshold (d), the Project would comply with General Plan 2025 Education Element Objective ED-5 and Policy ED-5.1 to ensure that the Project would not affect the City’s ability to provide adequate libraries. Impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to public services would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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5.16 Recreation
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
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??
Less Than Significant No N/A
b) Increase recreational facilities or require the
construction or expansion of recreational facilities
that might have an adverse physical effect on the
environment?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding recreation were discussed in Section 3.11, Recreation, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that the potential increase from the implementation of the Housing Element Update could result in increased use of park and recreational facilities in the City. The implementation of the Housing Element Update could result in an increased use of nearby existing neighborhood parks, regional parks, and community parks. Potential impacts would include greater demands on parkland and recreational facilities, potentially increasing the use of existing parks and other recreational facilities, which could cause physical deterioration of the facility. However, the impacts associated with park development and operation would be less than significant. New residential and mixed -use development within the City is required to adhere to minimum open space standards of the Zoning Code (Title 19 of the RMC), which could include pocket parks, tot lots, court facilities, barbeque facilities, jogging or walking trails, community gardens, acces sible green roof space, and traditional neighborhood parks. The development of these parks would offset the Project’s increased demand and thereby minimize physical deterioration of existing parks and open space facilities.

To provide more local recreational resources for City residents, developers will adhere to RMC 16.60, Local Park Development Fees, from build-out of the Opportunity Sites and are encouraged to incorporate living roofs and/or rooftop greenspace on mixed -use and high -density residential a nd, wherever possible, to design pocket parks into development plans to provide more local recreational resources. Chapter 6 of the Parks Master Plan outlines additional funding sources for the creation of new parks, including state funding through the Jun e 2018 Park Bond and through the California Department of Housing and Community Development’s Housing-Related Parks Program. The inclusion of public parks and green space would help offset the impacts on recreational resources in the City. New development of parks and

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Opportunity Sites would require subsequent project -specific CEQA analysis on a case -by-case basis.

Impacts would be less than significant.

Regarding Threshold (b), City parkland standards, RMC Chapter 16, and General Plan 2025 Policy PR -1.2 require a minimum of 3 acres of developed parkland per 1,000 residents and other requirements applicable to new residential development to accommodate demand for recreational facilities. The City requires that private developers proposing residential projects in the City include open space within their project as well as adhere to RMC 16.60 and pay park development impact fees. These dedications and fees are collected by the City as part of the development review process and are used for the purpose of supporting the City’s recreational budget for past and present facilities to serve the community. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a) and (b), the Project would include 37,063 square feet of residential common open space consisting of three main courtyards consisting of barbecue areas, dining and lounge areas, fire pits, a pet park, amenities, terraced decks, a business center, fitness room, and lounge. The Project’s provisions would comply with RMC Title 19. The Project would also be required to adhere to RMC 16.60 for local park development fees to offset impacts on recreational resources in the City. Impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to recreation would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.17 Transportation
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
TRANSPORTATION: Would the Project:

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a) Conflict with a program plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
Less Than Significant No N/A
b) Conflict or be inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)?
Significant and Unavoidable No N/A
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
Less Than Significant No N/A
d) Result in inadequate emergency access? Less Than Significant No N/A

Impact Determination in the Certified PEIR
Impacts regarding transportation were discussed in Section 3. 12, Transportation, of the Certified PEIR.

Thresholds (c) and (d) were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that as part of the standard development review process, the City would require all future development of identified Opportunity Sites to go through a review of pedestrian, bicycle, and transit facilit ies in the area surrounding the individual development project to ensure that future developments do not conflict with existing or planned facilities supporting those travel modes. All pedestrian, bicycle, and transit facilities proposed would be designed using the appropriate design standards. Impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that because the Housing Element Update would increase population and employment within the City, VMT would increase. How ever, as shown in the Certified PEIR, the VMT per service population would decrease within the City, showing that travel on a per-person basis would be more efficient with the addition of the developments associated with the Housing Element Update. The Housing Element Update would result in an increase in the Housing Element Update’s VMT from No Project baseline conditions, which is considered a significant impact for all VMT metrics presented. Mitigation Measure MM-TRA-1 would be required to reduce impacts; however, given the uncertainty in some components of the measure that influence VMT (such as the cost of fuel) combined with the City’s inability to influence other measures that would have the largest effect on VMT (such as implementation of a VMT tax o r an increase in the fuel tax), the effectiveness of these TDM measures cannot be guaranteed to reduce impacts. Impacts would be significant and unavoidable.

Regarding Threshold (c), the Certified PEIR determined that the Housing Element Update would not directly result in any activities that would substantially increase hazards because of a geometric design feature through implementation of policy changes and updates, rezoning, and Specific Plan amendments.

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Future roadways would be designed in compliance with City codes and standards (Chapter 19.102), which would be verified in design review and plan check on a project -by-project basis. The General Plan 2025 policies would help reduce potential hazards due to design features. Impacts would be less than significant.

Regarding Threshold (d), the Certified PEIR determined that the Housing Element Update would not directly result in any activities that would result in inadequate emergency access because Opportunity Sites are proposed near essential services and transportation routes. General Plan 2025 contains policies to encourage development of safe transportation systems and ensure that development does not conflict with emergency response or access during operations. The City continues to implement adopted ro ad standards and, as a result, new roadways would be designed to avoid unsafe design and provide adequate emergency access. The City has an Emergency Operations Plan and RFD provides response management through activation of SEMS. Impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), the Project would develop a mixed -use development in an urban area. The Project Site would be located in proximity to pedestrian, bicycle, and transit facilities. The Project would not conflict with existing or planned facilities supporting those travel nodes. Impacts would be less than significant.

Regarding Threshold (b), a Traffic Study was prepared for the Project in April 20 23. VMT analyses were conducted as part of the Housing Element Update. Based on the Certified PEIR, the Project Site would be in a very efficient area (VMT more than 15 percent below the City average). Therefore, it can be presumed that the Project would not have significant VMT impacts and would not need any VMT mitigation due to its location efficiency. Impacts would be less than significant.

Regarding Threshold (c), the Project would not substantially increase hazards by developing geometric design features or incompatible uses on the Project Site. The Project design would be verified in design review and plan check, and would be required to comply with General Plan 2025 policies to reduce potential hazards due to design features. Impacts would be less than significant.

Regarding Threshold (d), the Project would be located in an area with established roadway networks that provide adequate emergency access. The Project would not include improvements that would affect emergency access. Impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

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Conclusion
Based on the above, the Project’s potential environmental impacts to transportation would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.18 Tribal Cultural Resources
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
TRIBAL CULTURAL RESOURCES: Would the Project:
a) 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 defined 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:

(i) 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 ?
Less Than Significant with
Mitigation Incorporated
No Yes
(ii) 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 the criteria set
forth in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe?
Less Than Significant with
Mitigation Incorporated
No Yes

Impact Determination in the Certified PEIR
Impacts regarding tribal c ultural resources impacts were discussed in Section 3. 13, Tribal Cultural Resources, of the Certified PEIR.

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Regarding Thresholds (a) and (b), the Certified PEIR determined that because the Opportunity Sites under the proposed Housing Element Update are situated throughout the City in mostly urban and developed areas and in mostly unsurveyed areas, the potential for Opportunity Sites to encounter archaeological resources is unknown. Some prehistoric resources may be considered tribal cultural resources (TCRs) and can include sites, features, and objects that are listed in the CRHR, eligible to be listed in the CRHR, locally listed as defined in PRC Section 5020.1(k), or be determined by the lead agency to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. Future cultural resource studi es at Opportunity Site locations (see Mitigation Measure MM -CUL-2) could identify both archaeological resources and/or TCRs through survey and consultation with Native American tribes. Through continued consultation with tribes on a project-specific basis and implementation of Mitigation Measure MM-CUL- 2, it is possible that the City will be able to determine whether specific Opportunity Sites overlap with known locations of TCRs. Because ground -disturbing activities could result in disturbance or destructi on of TCRs, impacts would be potentially significant. For Opportunity Site projects that are not eligible for the ministerial approval process (and not projects per CEQA), and with continued consultation with Native American tribes, implementation of Mitigation Measures MM-CUL-2 through MM-CUL-9, MM-TCR-1, and MM-TCR-2 would reduce this impact to less-than-significant levels.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Thresholds (a) and (b), the Project would involve grading and excavation. While not anticipated, previously unknown resources could be covered. However, the Project would implement the applicable mitigation measures as set forth in the Certified PEIR to reduce potential impacts to archae ological resources and human remains, including TCRs, to less-than-significant levels. Thus, with implementation of Mitigation Measures MM- CUL-2, MM-CUL-4, MM-CUL-5, MM-CUL-8, and MM-CUL-9, impacts would be reduced to less than significant levels. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
The following mitigation measures set forth in the Certified PEIR and the ass ociated MMRP to address tribal cultural resources impacts were implemented as part of the Project. No additional mitigation measures are required.

MM-CUL-2
MM-CUL-4
MM-CUL-5
MM-CUL-8
MM-CUL-9

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See Section 5.5, Cultural Resources, above for more detail. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts.

Conclusion
Based on the above, the Project’s potential environmental impacts to TCRs would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.19 Utilities and Service Systems
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
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, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
Less Than Significant No N/A
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
Less Than Significant No N/A
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?
Less Than Significant No N/A
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?
Less Than Significant No N/A
e) Comply with federal, state, and local management
and reduction statutes and regulations relate d to
solid waste?
Less Than Significant No N/A

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Impact Determination in the Certified PEIR
Impacts regarding utilities and service systems were discussed in Section 3. 14, Utilities and Service Systems, of the Certified PEIR. Threshold ( e) was discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a) for water, the Certified PEIR determined that the implementation of the Housing Element Update would increase water demands by approximately 28 million gallons per day (30,848 acre- feet per year [afy]) over existing conditions. This increased demand would not be accommodated in accordance with the 2015 Riverside Public Utilities Urban Water Management Plan (RPU UWMP). Future development associated with the Housing Element Update would be built using new building standards for water efficiency and would be designed to use less water than existing development. Future development would also occur incrementally over time, based on market conditions and other factors, such that existing water services are not overburdened by substantially increased demands at any single point in time. In compliance with SB 221 and SB 610 requirements, future development satisfying certain criteria would require preparation of a water supply assessment in order to verify sufficient water supply is available to meet future development’s water demand. Future development would also be required to coordinate demands with the capacity of the water system and work with RPU and the Western Municipal Water District (WMWD) to coordinate water services. Future development would also be required to fund fair-share costs associated with the provision of water and to ensure that the provision of water is consistent with the growth planned for the City. Compliance with the abovementioned existing regulatory framework and implementation of existing General Plan 2025 Final Programmatic EIR Mitigation Measure UTL-1 would ensure adequate water facilities are available to serve future developm ent associated with the Project within the City. Therefore, impacts due to the extension, relocation, and expansion of new water facilities would be less than significant.

Regarding Threshold (a) for wastewater treatment, the Certified PEIR determined that the implementation of the Housing Element Update would generate an estimated 10 million gallons per day (mgd) within the City’s wastewater service area. The additional 10 mgd of wastewater would be adequately treated by the Riverside Water Quality Control Plant (RWQCP) which has a treatment capacity of 46 mgd. Future sewer line upgrades and developments within the City would assume their full fair - share costs (General Plan 2025 Policy PF -3.2) by implementing sewer service charges, which would be deposited with the City (RMC Chapter 14.04, Sewer Service Charge). While development of the Housing Element Update would require extension, relocation, and expansion of new sewer lines within the City, construction activities associated with future development would be subject to compliance with the local, State, and federal laws, ordinances, and regulations, as well as any project -specific mitigation measures necessary to ensure impacts would be less than significant.

Regarding Threshold (a) for stormwater drainage , future development would also be subject to compliance with General Plan 2025, which requires the City to continue to fund and undertake storm drain improvement projects as identified in the City of Riverside’s Capital Improvement Plan. General Plan

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2025 also requires continued cooperation between the City and regional programs to implement the NPDES, and requires the City to continually monitor and evaluate the effectiveness of its storm drain system and make adjustments as needed. Compliance with the ex isting regulatory framework would ensure adequate stormwater drainage facilities are available to serve development associated with the Housing Element Update, and impacts would be less than significant. Payment of applicable fees established by the City w ould also ensure that stormwater drainage facilities would serve the drainage needs of any future development allowed under the Housing Element Update. Impacts would be less than significant.

Regarding Threshold (a) for electric power, natural gas, and telecommunication facilities, existing services are available throughout the City, and no additional upgrades or new facilities would be required.

Construction activities associated with future development would be subject to compliance with the local, State, and federal laws, ordinances, and regulations, as well as any project -specific mitigation measures necessary to ensure impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that the increased water demand from the Housing Element Update of 30,858 afy would not be accommodated by the 2015 RPU UWMP under normal, dry, or multiple -dry years. However, future development would occur incrementally over time, based on market conditions and other factors, such that existing water services are not overburdened by substantially increased demands at any single point in time. In addition, compliance with the existing regulatory framework discussed under Threshold (a) and implementation of existing General Plan 2025 Final Programmatic EIR Mitigation Measure UTL-1 would ensure adequate water supplies are available to serve future development associated with the Housing Element Update under normal, dry, and multiple- dry years. Therefore, impacts would be less than significant.

Regarding Threshold (c), as discussed under Threshold (a), the increase in wastewater generation from the Housing Element Update would not exceed the treatment capacity of the wastewater treatment facilities that serve the City. Impacts would be less than significant.

Regarding Threshold (d), development associated with the Housing Element Update would comply with all sustainability goals as dictated by State and local standards, such as the California Integrated Waste Management Act, AB 341, Riverside County Waste Management Department’s Design Guidelines and its Construction and Demolition Recycling Plan, and Riverside’s Countywide Integrated Waste Management Plan (CIWMP). Additionally, build -out of the Housing Element Update would be incremental as to not overwhelm solid waste collectors and landfills with a substantial increase in solid waste at one point in time. Development would also be required to comply with General Plan 2025 policies and Final Programmatic EIR Mitigation Measures to increase solid waste diversion efforts and ensure that operational impacts on solid waste disposal are less than significant. Impacts would be less than significant.

Regarding Threshold (e), the Certified PEIR determined that the City implemented numerous waste reduction and recycling programs, including AB 341 and AB 1862, to oversee the implementation of waste

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management and recycling/reuse programs. Additionally, the City has partnered with the haulers to send out non -compliance notifications to businesses and multi -family residences to encourage them to subscribe to the services. In addition, CALGreen required all developments to divert 50 percent of nonhazardous construction and demolition debris and 100 percent of excavated soil and debris from land clearing associated with all nonresidential projects beginning January 1, 2011. Development and redevelopment associated with the Housing Element Update would comply with City waste disposal requirements as well as CALGreen requirements. The impact would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a) for water, the Project would be located on an Opportunity Site and would be consistent with the General Plan land use designation and zo ning for the Project Site, so the Project’s estimated water supply demand would be accounted for as part of the Certified PEIR. While the Certified PEIR, which relied on the 2015 RPU UWMP, determined that the 28 mgd (30,848 afy) would not be accommodated at that time, the 2020 RPU UWMP, adopted July 1, 2021, utilized population projections for the City through 2045 from the SCAG 2020-2045 RTP/SCS and projected an actual water supply volume in 2020 of 86,324 afy . Therefore, because the 2020 UWMP would take i nto account the updated population projections and the increased supply from various improvement projects throughout the RPU service area, the Housing Element Update and the Project’s water use would be accommodated as part of the updated 2020 UWMP. Additionally, the Project would be required to fund fair -share costs associated with the provision of water and to ensure that the provision of water is consistent with the growth planned for the City. Compliance with the abovementioned existing regulatory framework would ensure adequate water facilities are available to serve the Project within the City. Impacts on the relocation or construction of new or expanded water facilities would be less than significant.

Regarding Threshold (a) for wastewater treatment, the Project would be consistent with the General Plan land use designation and zoning for the Project Site, so the Project’s estimated wastewater generation would be accounted for as part of the Certified PEIR. The Project’s estimated wastewater generatio n would be accommodated by the RWQCP. Impacts would be less than significant.

Regarding Threshold (a) for stormwater drainage, the City would continue to fund and undertake storm drain improvement projects identified in the City’s Capital Improvement Plan. The Project would be required to comply with existing regulatory framework and pay applicable fees to ensure that adequate stormwater drainage facilities are available to serve the Project. Impacts would be less than significant.

Regarding Threshold (a) for electric power, natural gas, and telecommunication facilities, the Project would be developed in areas with existing services and facilities. Impacts would be less than significant.

Regarding Threshold (b), see Threshold (a) for water. Impacts would be less than significant.

Regarding Threshold (c), see Threshold (a) for wastewater treatment. Impacts would be less than significant.

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Regarding Threshold (d) and (e), the Project would be required to comply with General Plan 2025 policies, Final Programmatic EIR Mitigation Measures to increase solid waste diversion efforts, comply with the City’s AB 341 and AB 1862 programs to implement waste management and recycling/reuse programs, and CALGreen requirements for diversion of nonhazardous construction and demolition debris. Impacts would be less than significant. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to utilities and service systems would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.20 Wildfire
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
WILDFIRE: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, wo uld the Project:
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
Less Than Significant No N/A
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?
Less Than Significant No N/A
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 fire risk or that may result in
temporary or ongoing impacts to the environment ?
Less Than Significant No N/A
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?
Less Than Significant No N/A

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Impact Determination in the Certified PEIR
Impacts regarding wildfire were discussed in Section 3.15, Effects Not Found to be Significant, of the Certified PEIR.

Regarding Threshold (a), the Certified PEIR determined that portions of the City are in areas classified as VHFHSZ. According to the General Plan 2025 Public Safety Element, the major urban/rural interface areas with a high -fire risk are Mount Rubidoux, the Santa Ana River Basin, Lake Hills, Mockingbird Canyon/Monroe Hills, Sycamore Canyon, Box Springs Mountain, and La Sierra/Norco Hills. The introduction of reside ntial and mixed -use development into these natural landscapes would increase potential risks related to fire for people and property. The RFD ensures multi -jurisdictional cooperation and communication for emergency planning and response management through activation of the SEMS.

Also, the City and County of Riverside prepared the Riverside County Operational Area Multi-Jurisdictional Local Hazard Mitigation Plan to identify Riverside County’s hazards (including those within the City), review and assess past disaster occurrences, estimate the probability of future occurrences, and set goals to mitigate potential risks and reduce or eliminate long -term risks for people and property from natural and human -made hazards. Future development within the City associa ted with the Housing Element Update would be required to comply with local regulations, including General Plan 2025 and the City’s development code. Impacts would be less than significant.

Regarding Threshold (b), the Certified PEIR determined that develop ment associated with the Housing Element Update would not include housing and mixed -use development within wildfire hazard areas.

Future development would be required to comply with local regulations, including General Plan 2025 and the RMC. Impacts would be less than significant.

Regarding Threshold (c), the Certified PEIR determined that future development associated with the Housing Element Update may require new public infrastructure and utilities, which would be installed to meet fire service requirements. All improvements would be subject to City development standards and verified as part of either a building permit or construction approval process. During the standard development review process, the City’s Development Review Committee, which includes the Fire Department and Building & Safety Division, evaluates developments in high fire-risk areas to ensure that improvements meet their requirements. With compliance with local regulations (e.g., RMC) and implementation of General Plan 2025 policies, impacts would be less than significant.

Regarding Threshold (d), all future development would be subject to City developmen t standards and verified as part of either a building permit or construction approval process. Impacts related to downstream flooding and drainage changes would be less than significant. Regarding landslides, grading and construction would be completed in compliance with 2019 CBSC regulations, County of Riverside ordinances, and the RMC, the potential for slope instability would be reduced. The Opportunity Sites would not be on the steepest slopes. Impacts related to flooding would be lessened through compliance with the Local Hazard Mitigation Plan and Public Safety Element policies that address flood hazards and

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conditions on individual development projects during development review. Compliance with CBSF regulations and applicable local codes and ordinance s would ensure that impacts would be less than significant.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Thresholds (a), (b), (c), and (d), according to CAL FIRE, the Project Site is not within a SRA or LRA VHFHSZ. There would be no impact. As such, the proposed Project would not result in new significant impacts or substantially more severe impacts than disclosed in the Certified PEIR.

Mitigation Measures Addressing Impact
No mitigation measures from the Certified PEIR would be applicable to the Project. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts to wildfire would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.21 Cumulative Impacts
Impact Determination in the Certified PEIR
The Certified PEIR determined the following cumulative impacts would be less than significant: aesthetics, agriculture and forestry resources, biological resources, cultural resources, energy, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, public services, recreation tribal cultural resources, utilities and service systems, and wildfire. The Certified PEIR determined that the following cumulative impacts would be sign ificant and unavoidable:
air quality, GHG emissions, noise and vibration, population and housing, and transportation. Mitigation measures identified in the Certified PEIR would reduce some of these impacts, but not to less than significant levels.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? As defined in CEQA Guidelines Section 15355, cumulative impacts refer to two or more individual effects, which, when considered together, are considerable or which compound or increase other environmental impacts.

As evaluated above, all of the Project’s potential project -specific environmental impacts would be less than significant. The Project’s contribution would not be cumulatively considerable with regard any of the cumulative impacts assessed in the PEIR as the Project’s impacts regarding these environmental topics

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would be less than significant or less than significant with incorporation of the mitigation measures included in the Certified PEIR.

Regarding aesthetics, agriculture and forestry resources, biological resources, cultural resources, energy, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, public services, recreation tribal cultural resources, utilities and service systems, and wildfire, the Certified PEIR found cumulative impacts to be less than signficant. As the Project’s impacts would also be less than significant, the Project would not make a cumulatively considerable contribution to these impacts.

Regarding air quality, the SCAQMD recommends utilizing project-specific air quality impacts to determine the project’s potential cumulative impacts to regional air quality. 9 The SCAQMD CEQA Air Quality
Handbook also states that “[f]ro m an air quality perspective, the impact of a project is determined by examining the types and levels of emissions generated by the project and its impact on factors that affect air quality. As such, projects should be evaluated in terms of air pollution t hresholds established by the District.”10 The City has determined to rely on thresholds established by the SCAQMD (refer to CEQA Guidelines Section 15064.7) to assess the Project’s cumulative impacts. While it may be possible to add emissions from the list of related projects with the Project, it would not provide meaningful data for evaluating cumulative impacts under CEQA because neither the City nor the SCAQMD have established numerical thresholds applicable to the summation of multiple project emissions for comparison purposes.

Additionally, regional emissions from a project have the potential to affect the South Coast Air Basin as a whole, and, unlike other environmental issues areas, such as aesthetics or noise, it is not possible to establish a geographical radius from a specific project site where potential cumulative impacts from regional emissions would be limited. Meteorological factors, such as wind, can disperse pollutants, often times tens of miles downwind from a project site. Therefore, consis tent with accepted and established SCAQMD cumulative impact evaluation methodologies, the potential for the Project to result in cumulative impacts from regional emissions is assessed based on the SCAQMD thresholds. As described above in Section 5.3, Air Q uality, the Project’s construction and operations emissions would not exceed the SCAQMD thresholds; therefore, the Project’s contribution to cumulative air quality impacts would also not be cumulatively considerable.

9 SCAQMD, Potential Control Strategies to Address Cumulative Impacts from Ai r Pollution White Paper, Appendix D, 1993, page D -3 (“As Lead Agency, the AQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR… Projects that exceed the Project -specific significance thresholds are considered by the SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project- specific thresholds are generally not considered to be cumulatively significant.”).
10 SCAQMD, Cumulative Impacts White Paper, Appendix D.

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According to the California Air Pollution Control officers Association (CAPCOA), “GHG impacts are exclusively cumulative impacts; there are no non-cumulative GHG emission impacts from a climate change perspective.”11 Therefore, as the Project’s GHG emissions impacts would be less than si gnificant, the Project’s contribution to cumulative GHG emissions impacts would also not be cumulatively considerable.

Cumulative noise and vibration impacts could occur if the Project’s construction overlapped with that of nearby cumulative projects so a s to affect the same off- site sensitive land use contemporaneously.

Groundborne vibration attenuates very rapidly and is generally imperceptible 50 feet from the source.

There are no sensitive land uses or related projects within 50 feet (the nearest potential related project, at 3770 Cranford Avenue, lies 370 feet to the east of the Project S ite). As such , there would be no cumulative vibration impacts experienced at the nearby sensitive land uses. Noise impacts from construction activities vary depending on the nature or phase of construction. Sensitive Receptor 1 (SR-1) is located between the Project and the nearest related project (3770 Cranford Avenue). The timing of construction for any of the related projects listed would be highly speculative. As shown on Table 8 of the Noise Assessment, maximum Project construction noise levels reaching SR-1 is estimated at 74.9 dBA Leq.

Assuming that maximum construction activity at the nearest potential related project would be similar to that of the Project, and that the maximum noise levels from the Project and the related project would occur simultaneously, combined cumulative construction noise reaching SR -1 would be approximately

77.9 dBA L eq.12 This combined noise level would not exceed the FTA threshold of 80 dBA L eq for construction noise at residential uses. Therefore, cumulative construction noise would be less than significant, and the Project’s contribution to cumulative construction noise would also not be cumulative considerable. Thus, it is unlikely that construction from any of the related projects (which are located at greater distances from the Project and other potential shared sensitive receptors) would overlap and combine with Project-generated noise to increase the impact to significant levels. Long-term operation of the Project, similar to the 14 related projects located 370 feet or more away, is not a source of substantive on-site noise, such as heavy manufacturing. As such, noise from the Project and the related projects is unlikely to combine to create cumulative impacts.

Regarding population and housing, the Project’s 257 dwelling units and resulting 843 new residents would be within the estimated population growth forecasted by SCAG in the 2020-2045 RPT/SCS between 2020 and 2045. The related projects would result in approximately 444 multi -family residential units , which could result in a potential impact on population and housing. Based on the City’s average household size of 3.28, these related projects woul d result in 1,456 new residents, not including any reductions of residents based on the removal of existing uses. These 1,456 new residents, in addition to the Project’s 843 residents, would result in a total of 2,299 residents, or approximately 3.4 percen t of the estimated

11 CAPCOA, CEQA & Climate change: Evaluating and Addressing Greenhous Gas Emissions from Projects Subject to the California Environmental Quality Act, 2008.
12 Combining two noise sources of an approximate equal noise level results in a total noise increase of 3 dB.

Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, page 2-14, September 2013

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population growth forecasted by SCAG’s 2020-2045 RTP/SCS between 2020 and 2045. Additionally, some of these related projects would be located on Opportunity Sites and are designated by the City in the Housing Element Update as sites that are intended to utilized for housing development . As such, these related projects would not result in unplanned growth. Therefore, the Project’s contribution to cumulative population and housing impacts would not be cumulatively considerable.

Overall, in each of the analyses provided above, impacts associated with the Project would be within the scope of impacts evaluated in the Certified PEIR. Accordingly, the Project would not result in any new significant cumulative impacts, nor would it substantially increase the severity of any significant cumulative impacts previously identified in the Certified PEIR.

Mitigation Measures Addressing Impact
As described above, the Project would implement the previously adopted mitigation measures set forth in the Certified PEIR, as applicable. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential cumulative environmental impacts would be within the scope of the Certified PEIR and would not result in any o f the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

5.22 Mandatory Findings of Significance
Thresholds
Impact Determination in the
Certified PEIR
Do Proposed Changes
Involve New Significant
Impacts or Substantially
More Severe Impacts?
Mitigation
Measures
Addressing
Impacts
MANDATORY FINDINGS OF SIGNIFICANCE: Does the Project:
a) 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, substantially 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?
Less Than Significance with
Mitigation Incorporated
No Yes
b) Have impacts that are individually limited, but
cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of
a project are considerable when view in connection
Significant and Unavoidable No Yes

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with the effects of past projects, the effects of other current projects, and the effects of probable future
projects)??
c) Have environmental effects which will cause
substantial adverse effects on human beings, either
directly or indirectly?
Less Than Significant No N/A

Impact Determination in the Certified PEIR
The environmental issues addressed in the Mandatory Findings of Significance were analyzed in a combination of the Initial Study (found in Appendix A of the Certified PEIR) and the Draft EIR of the Certified PEIR. As described above in Section 5.4, Biological Resources, development associated with the Housing Element Update would be required to implement Mitigation Measure MM -BIO-1 to reduce potential impacts to biological resources to less than significant levels. As summarized above, the Certified PEIR de termined that implementation of the Housing Element Update would result in significant and unavoidable impacts with respect to air quality, GHG emissions, noise and vibration, population and housing, and transportation. Mitigation measures identified in th e Certified PEIR would reduce some of these impacts, but not to less than significant levels. As such, the significant impacts of the Housing Element Update would have the potential to cause cumulatively considerable impacts and result in environmental effects which would cause substantial adverse effects on human beings.

Do Proposed Changes Involve New Significant Impacts or Substantially More Severe Impacts? Regarding Threshold (a), as described in Section 5.4, Biological Resources, pursuant to Certified PEIR Mitigation Measure MM-BIO-1, a literature review, habitat assessment, and survey were conducted for the Project Site. As determined above, the Project would have a less than significant impact on biological resources.

Regarding Threshold (b), see Section 5.21, Cumulative Impacts, above. As detailed therein, as analyzed in each section, impacts associated with the Project would be within the scope of impacts evaluated in the Certified PEIR. Accordingly, the Project would not result in any new significa nt cumulative impacts, nor would it substantially increase the severity of any significant cumulative impacts previously identified in the Certified PEIR.

Regarding Threshold (c), because the Project’s impacts would be less than significant in all resource areas analyzed above, the Project would not cause a substantial adverse effect on human beings, either directly or indirectly. Impacts would be less than significant.

The Project would not result in any new significant impacts or substantially increase the severity of impacts compared to the Certified PEIR analysis. As such, the Project’s impacts would be within the scope of impacts set forth in the Certified PEIR.

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Mitigation Measures Addressing Impact
As described above, the Project would implement the previously adopted mitigation measures set forth in the Certified PEIR, as applicable. No additional mitigation measures are required for the Project.

Conclusion
Based on the above, the Project’s potential environmental impacts would be within the scope o f the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

6.0 CONCLUSION
There is no basis to find the criteria in CEQA Guidelines Section 15162 have been met such that a major revision to the Certified PEIR is required. The analysis in Section 5, Comparative Analysis of Project Impacts, provided above shows the Project would not result in a change to the Housing Element Update analyzed in the Certified PEIR that would result in any new significant impacts or more severe significant impacts than those identified in the Certified PEIR as the Project is within the scope of and is consistent with the City’s Housing Element Update. Additionally, there have been no changes to the City’s Housing and Public Safety Element Updates since its adoption that resulted in or will foreseeably result in new significant impacts or more severe significant impacts. Bas ed on the number of projects that have been approved so far, the number of residential dwelling units, residential floor area, and non-residential floor area anticipated for the City have not met the previously-assessed buildout limitation in the Certified PEIR.

Moreover, there is no basis to find there has been a change to the development associated with the Housing Element Update analyzed in the Certified PEIR such that there will be new or more severe significant impacts. Additionally, there have been n o changes to the circumstances with respect to the circumstances under which be expected to result in new or more severe significant impacts. Finally, there is no new information of substantial importance that was not known or could not have been known when the Certified PEIR was certified and the Housing and Public Safety Element Updates were adopted.

As analyzed herein and demonstrated above, the Project is “within the scope” of the Certified PEIR pursuant to CEQA Guidelines Section 15168(c)(2), and no further environmental analysis is required.

Attachment A
Responses to Planning Comment Summary Matrix
December 13, 2022

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TECHNICAL MEMORANDUM

To: Haig Nazarian and Matthew Keenen, CGI Plus
From: Jessie Fan, Project Manager
Date: December 13, 2022
Subject: 1575 University Avenue Project – Responses to Planning Comment Summary Matrix

1.0 INTRODUCTION & PURPOSE
Kimley-Horn and Associates, Inc. has been retained to respond to the Environmental and Technical Studies Items on the Planning – Comment Summary Matrix dated March 2, 2022. Kimley -Horn understands that these Environmental and Technic al Studies Items are requested by the City of Riverside (City) as part of the City’s comments on the 1575 University Avenue Project (Project) Planning Case PR -2021-001268 Conceptual Development Review. The purpose of this Technical Memorandum is to summarize the findings of the requested technical studies and to note the Project’s consistency with the City’s Housing and Public Safety Element Updates and Environmental Justice Policies Project Final Environmental Impact Report (Housing Element Final EIR) and the associated Mitigation Monitoring and Reporting Program (MMRP).

The Project’s CEQA compliance review relied on the following documentation:
• City’s Housing and Public Safety Element Updates and Environmental Justice Policies Final Environmental Impact Report, State Clearinghouse No. 2021040089, September 2021 • Conceptual Site Plans, see Appendix A: Conceptual Site Plans • Kimley-Horn and Associates, Air Quality Summary, see Appendix B: CalEEMod Modeling Results
• Environmental Science Associates, Biological Assessment Report , see Appendix C:

Biological Assessment Report
• Environmental Science Associates, Cultural Resources Assessment Report , see Appendix D: Cultural Resources Assessment Report
• Environmental Science Associates, Paleontological Resources Assessment, see Appendix E: Paleontological Resources Study
• Kimley-Horn and Associates, Noise and Vibration Analysis, see Appendix F: Noise and Vibration Analysis

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2.0 PROJECT DESCRIPTION
The Project would be located on a 4.29 -acre site (Assessor Parcel Number [APN] 250 -170-036) (Project Site) bounded by Seventh Street to the north, University Avenue to the south, Cranford Avenue to the east, and Chicago Avenue to the west. The Project would demolish the existing 24,848-square-foot commercial building and surface parking lot and would construct a new mixed- use development with 257 dwelling units and 5,450 square feet of commercial uses. The Project would also provide a total of 499 vehicle parking spaces: 488 of which would be within a parking garage, and 11 would be provided on-grade. The Project would have a maximum height of 50 feet and would be approximately 225,000 square feet of gro ss building area. 1 Project construction activities (e.g., demolition, site preparation, grading, paving, building construction, and architectural coating) is anticipated to begin in January 2024 and end in January 2026. The Project would be operational in J anuary 2026. The Project Site plans are provided in Attachment A:

Conceptual Site Plans.

3.0 FINDINGS CONCERNING CEQA COMPLIANCE
Select technical studies have bene prepared to respond to the City’s comments on Planning Case PR-2021-001268 Conceptual Development Review.

Air Quality
In response to Item #56 in the Comment Summary Matrix, Kimley -Horn provided CalEEMod input/output files to quantify the Project’s construction and operation -related emissions (see Appendix B: CalEEMod Modeling Results ). As shown in Table 1: Project Construction Emissions , criteria pollutant emissions during Project construction would be below the respective South Coast Air Quality Management District (SCAQMD) thresholds. SCAQMD Rule 403 is included within the Housing Element Final EIR as Mitigation Measure AQ -1. Because SCAQMD Rule 403 is regulatory and required, the rule is applied as part of the calculations in Table 1. No further mitigation measures were required. Therefore, impacts during Project construction would be less than significant.

1 The analysis provided within this document is based on a preliminary set of plans for 225,000 square feet of gross building area. Since then, the Project has been refined to be 216,171 square feet of gross building area. Because the quantitative calculations provided in this document are for a larger project, the analysis is considered conservative.

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Table 1: Project Construction Emissions
Construction Year
Emissions (lb/day)a
ROG NOX CO SOX PM10 PM2.5
2024 5.04 49.32 39.50 0.09 27.33 15.27
2025 36.00 16.12 28.43 0.07 4.41 1.59
2026 33.74 1.23 3.33 <0.01 0.62 0.23
SCAQMD Threshold 75 100 550 150 150 55
Thresholds Exceeded? No No No No No No
a CalEEMod modeling results are provided in Appendix B. SCAQMD Rule 403 Fugitive Dust is applied.

No mitigation was applied.

As shown in Table 2: Project Operational Emissions, the Project’s operational emissions would not exceed the SCAQMD thresholds. No mitigation measures from the Housing Element Final EIR were required. Therefore, air quality impacts from regional operational emissions would be less than significant.

Table 2: Project Operational Emissions
Source
Emissions (lb/day)a
ROG NOX CO SOX PM10 PM2.5
Area 5.56 0.24 21.23 <0.01 0.12 0.12
Energy 0.11 0.94 0.40 <0.01 0.08 0.08
Mobile 4.15 5.54 40.37 0.10 10.52 2.86
Total 9.82 6.72 62.00 0.11 10.72 3.06
SCAQMD Threshold 55 55 550 150 150 55
Thresholds Exceeded? No No No No No No
a CalEEMod modeling results are provided in Appendix B. Worst-case seasonal emissions for emissions are represented here.

The Project would result in less than significant construction and operational air quality impacts.

No further mitigation measures would be required.

Biological Resources
In response to Item #57 in the Comment Summary Matrix, Environmental Science Associates (ESA) conducted a literature review, habitat assessment, and survey for the Project Site (see Appendix C: Biological Assessment Report). As determined in the Biological Assessment Report, there are no natural communities on-site. The Project Site land cover types consist of developed and ruderal areas, the latter including non -native grasses and forbs. Of the eight special -status plant species considered to potentially occur within the Project Site, none were detected during the site survey.

Of the 29 special -status wildlife species considered to potentially occur within the Project Site, none were observed during the site survey. There is n o native habitat on -site to support the

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special-status species. The removal of the ruderal vegetation would not threaten or endanger any regional wildlife populations, and the Project Site does not occur within or adjacent to designed critical habitat. Pro ject construction would be subject to the federal Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code (CFGC) Sections 3503, 3503.5, and 3501 to avoid disturbance of nesting birds.

The Project would be consistent with the Western Riversi de County Multiple Species Habitat Conservation Plan (MSHCP). The Project Site is not within any wildlife migration corridors identified in the MSHCP Schematic Cores and Linkages Map. The Project Site does not contain MSHCP riparian/riverine areas, and none of these areas would be impacted. The Project Site is not located within a Narrow Endemic Plant Species Survey Area, Amphibian Survey Area, Burrowing Owl Survey Area, or Mammal Survey Area as defined in the MSHCP. Therefore, impacts to narrow endemic plant species or wildlife habitat would be covered through payment of appropriate MSHCP development fees, as applicable . Therefore, biological resources impacts would be less than significant.

Archaeological Resources
In response to Item #58 in the Comment S ummary Matrix, ESA provided an archaeological study pursuant to Housing Element Final EIR Mitigation Measure CUL -2 (see Appendix D: Cultural Resources Assessment Report). A record search was conducted on July 22, 2022 at the California Historic Resources I nformation System (CHRIS) Eastern Information Center (EIC) housed at the University of California, Riverside, and included a review of all recorded archaeological resources and previous studies within he Project Site and a 0.50 -mile radius of the Project Site. The records search results indicate that 27 cultural resources studies have been conducted within a 0.50 -mile radius of the Project Site. None of the assessments include the Project Site, and no archaeological resources have been previously recorded within a 0.50-mile radius of the Project Site.

A cultural resources survey of the Project Site identified two built environment resources consisting of concrete foundations that are ineligible for consideration as potential historical resources under any California Register of Historical Resources crit eria 1, 2, 3, or 4. Therefore, the Project would not have a significant impact on these resources.

The Project has low to moderate potential for encountering subsurface prehistoric archaeological resources. Because Project construction would include groun d disturbance, mitigation measures would be required to reduce potential impacts to previously unknown archaeological resources and human remains to less than significant levels under CEQA. Full time monitoring is not required.

However, if unanticipated ar chaeological resources are encountered, a qualified archaeologist shall be retained , and Housing Element Final EIR Mitigation Measures CUL -4 (Archaeological Treatment Plant) , CUL -5 (data recovery) , and CUL -8 (treatment and disposition) would be implemented. Mitigation Measure CUL-9 (cultural sensitivity training) is also recommended prior

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to commencement of construction activities. With implementation of the Housing Element Final EIR Mitigation Measures, impacts would be reduced to less than significant.

Paleontological Resources
As requested by the City and to demonstrate compliance with Housing Element Final EIR Mitigation Measure PAL -1, ESA conducted a paleontological resources investigation (see Appendix E :

Paleontological Resources Study). While no paleontological resources were identified within the Project Site, geologic map review, literature review, and the paleontological resources record search revealed that the Project Site is underlain by potentially fossiliferous Older (Pleistocene) silt and clay alluvium, which has produced significant fossils elsewhere in western Riverside County.

Because Project construction would include ground disturbance, mitigation measures would be required to reduce potent ial impacts to paleontological resources to less than significant levels under CEQA.

Housing Element Final EIR Mitigation Measure PAL -2 requires retention of a qualified paleontologist, paleontological monitoring of excavations exceeding 10 feet or when ol der Quaternary alluvial silts and clays are encountered, salvage and curation of significant fossil discoveries, and final reporting. Housing Element Final EIR Mitigation Measure PAL -3 would also apply to the Project if paleontological resources and sensitive deposits remain or become exposed, then an avoidance and minimization plan would be prepared. With implementation of the Housing Element Final EIR Mitigation Measures, impacts to paleontological resources would be reduced to less than significant.

Noise and Vibration
In response to Item #59 in the Comment Summary Matrix, Kimley -Horn prepared a Noise and Vibration analysis to quantify the Project’s construction and operation-related noise and vibration impacts (see Appendix F: Noise and Vibration Analys is). Five noise -sensitive receptors were identified in proximity to the Project Site:
• SR-1: University Gardens Apartment Building approximately 50 feet east of the Project Site • SR-2: Quality Inn Riverside and Courtyard Marriott approximately 98 feet south of the Project Site
• SR-3: John W. North High School approximately 730 feet north of the Project Site • SR-4: Apartment complexes approximately 358 feet east of the Project Site • SR-5: Rock Ridge Apartment Complex approximately 705 feet west of the Project Site Noise measurements were taken in proximity to the noise -sensitive receptors to represent the ambient noise levels at those receptors. While the City does not administer noise level standards for construction activities, the analysis utilizes the Federal Transit Administration’s (FTA) threshold of 80 dBA for residential uses to evaluate construction noise. Based on the analysis, Project construction noise would be below the FTA noise threshold for residential land uses, which are the most conservative amb ient noise thresholds in the Federal Highway Administration’s (FHWA)

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Roadway Construction Noise Model (RCNM). In compliance with Riverside Municipal Code (RMC) Section 7.35.020, Project construction would be prohibited 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. Construction noise impacts would be less than significant, and no mitigation measures are required.

During Project operation, pu rsuant to RMC Section 07.35.020, the Project’s hours of operation would be restricted to 7:00 A.M. and 10:00 P.M. Per the analysis, the Project’s stationary noise sources from mechanical equipment would be less than significant. The Project would also not generate enough traffic to result in a noticeable 3 -dBA increase in ambient noise levels, and impacts from mobile traffic noise would be less than significant. Project operation would have a less than significant impact on noise.

Increases in groundborne vibration levels would be primarily associated with short -term construction-related activities, depending on the specific construction equipment used.

Groundborne vibration generated by construction equipment spreads through the gr ound and diminishes in magnitude with increases in distance. Based on the equipment that Project construction would require, the vibration velocities from Project construction would be below the FTA’s threshold for building damage and the California Department of Transportation’s (Caltrans) threshold for human annoyance. Further, once operational, the Project would not include vibratoin0generating uses or operations. Therefore, the Project would result in a less than significant impact on vibration, and no mitigation measures are required.

4.0 CONCLUSION
As is evidenced by the discussions presented above, the Project would not result in less than significant impacts, with implementation of Housing Element Final EIR Mitigation Measures where necessary, in air quality, biological resources, archaeological resources, paleontological resources, and noise and vibration. Therefore, in response to Item #60 in the Comment Summary Matrix, the Project would not be inconsistent with the Housing Element Final EIR.

Appendix A
Conceptual Site Plans

NORTH
2558 Overland Ave, CA 90064 T. 310.204.8950www.designarc.netAll design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc. 1575 U n i v e r s i t y A v e n u e , R i v e r s i d e, C a l i f o r n i a SCALE : 1"=50'10' 50' 100'DEC 13 2022 P R O J E C T I N F OA 1 0 1 RESIDENTIAL UNIT TABULATIONUnit TypeNet Leasible AreaNo. of Units Unit Description%ST A-1 565 S.F. 27 15,255 S.F. STUDIOTOTAL STUDIO 27 10.51 % 1A-1 741 S.F. 77 56,980 S.F. 1BR 1BA1A-2 741 S.F. 2 1,480 S.F. 1BR 1BA1A-3 741 S.F. 2 1,480 S.F. 1BR 1BA1A-4 741 S.F. 3 2,220 S.F. 1BR 1BA1A-5 738 S.F. 4 2,948 S.F. 1BR 1BA1A-6 747 S.F. 3 2,241 S.F. 1BR 1BA1A-7 751 S.F. 1 751 S.F. 1BR 1BA1B-1 741 S.F. 2 1,480 S.F. 1BR 1BA1C-1 783 S.F. 40 31,280 S.F. 1BR 1BA1C-2 769 S.F. 8 6,152 S.F. 1BR 1BATOTAL 1BD 142 55.25 % 2A-1 1,084 S.F. 53 57,399 S.F. 2BR 2BA2A-2 1,084 S.F. 2 2,166 S.F. 1BR 1BA2A-3 1,084 S.F. 2 2,166 S.F. 1BR 1BA2A-4 1,084 S.F. 1 1,083 S.F. 1BR 1BA2A-5 1,087 S.F. 12 13,044 S.F. 1BR 1BA2B-1 1,277 S.F. 2 2,552 S.F. 2BR 2BA2C-1 1,243 S.F. 2 2,486 S.F. 2BR 2BATOTAL 2BD 74 28.79 % 3A-1 1,315 S.F. 4 5,256 S.F. 3BR 2BA3B-1 1,415 S.F. 2 2,828 S.F. 3BR 2BA3C-1 1,231 S.F. 4 4,924 S.F. 3BR 2BA3D-1 1,332 S.F. 3 3,993 S.F. 3BR 2BA3D-2 1,332 S.F. 1 1,331 S.F. 3BR 2BATOTAL 2BD 14 5.45 %TOTAL 257 216,171 S.F.AVERAGE UNIT AREA 841 S.F.

PARKING REQUIREDUNIT/FLOOR AREARATIONO. OF SPACESCODE REF.RESIDENTIAL UNIT RSMC 19.580.060 STUDIO 271.5/UNITS41 1BD 1421.5/UNITS214 2BD-3BD 882/UNITS176 TOTAL REQUIRED 43115% REDUCTION367RESTAURANT4918 S.F. 1/100 S.F. 50 TOTAL REQUIRED5015% REDUCTION43TOTAL REQUIRED FOR RESIDENTIAL & COMMERCIAL481TOTAL REQUIRED AFTER 15% REDUCTION414RSMC 19.580.060.C.2ACCESSIBLE PARKING REQUIREDASSIGNED 0.02 8 CBC 1109A.3UNASSIGNED N/A - CBC 1109A.4COMMERCIAL 2 CBC 11B-208.2TOTAL REQUIRED10 PARKING PROVIDED 5.5 LEVEL PARKING GARAGE 411ON GRADE PARKING 7 STATIONS*EXCLUDE 2 EV CHARGING TOTAL PROVIDED418 * NORTH
2558 Overland Ave, CA 90064 T. 310.204.8950www.designarc.netAll design ideas and plans indicated or represented by these drawings are owned by and are the property of DesignARC and were created and developed for use in connection with the specified project. None of such ideas, designs, or plans shall be used for any purpose whatsoever without the written permission of DesignARC. © DesignARC Inc. 1575 U n i v e r s i t y A v e n u e , R i v e r s i d e, C a l i f o r n i a SCALE : 1"=50'10' 50' 100'DEC 13 2022
971.95
970.25 970.25
970.75
972.84972.88
970.75
972.83
971.98
971.92 972.70 970.25 971.75968.25 962.73
962.77
972.98
970.25
971.87
971.75
20:1
20:1
970.75971.46
970.90
971.80
972.80
972.70
972.98
972.83
971.87
971.87

0.01 971.00
972.73
972.42 0.010.05971.40970.90
970.980.005

0.01 0.028
972.980.01
972.98

TRANS.PAD8'x10'FIRETURNOUT
TRANS.PAD8'x10'
50'-0"
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P1A-7
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P 1A-5
U2.1
U2.1
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W/D
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SD
DW
P1A-5
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U2.1
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SD
DW
P 1A-5
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1C-1
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1C-2
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PF-14A
1A-1
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1C-1
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DW
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1C-1
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1A-1
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BB DWBB W/D
CSD
P
PF-14B
ST A-1
U1.1

BB DWBB W/D
CSD
P
PF-14B
ST A-1
U1.1
W/D
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PF-14A
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CSD
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2A-5
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PF-14A
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CSD
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2A-5
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SDU2.1
CSD
W/D
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P
PF-14A
1A-1
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SDU2.1
CSD
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DW
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PF-14A
1A-1
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SDU2.1
CSD
W/D
DW
P
PF-14A
1A-1
U1.1

BBDWBBW/D
CSD
P
PF-14B
ST A-1SD
PF-14A
DW
CSD
SD
SD
W/D

CSD CSDSD
PF-14A
3A-1
U2.1
SDU2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
SDU2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
SDU2.1
CSD
W/D
DW
P
PF-14A
1A-1
U2.1
U2.1
CSD
W/D
PF-14A
SD
DW
P1A-5
DW
PU1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
P U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD2A-1
DW
PU1.1
W/D
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PF-14A
PF-14A
SD
CSD2A-1
DW
P U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD2A-1
DW
P U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
DW
P U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSD
2A-1
UPDN
12"CLR18"CLR
18"CLR
12"CLR
18"CLR 12"CLR18"CLR
EL: 962.79
ELEC.ROOM
EL: 962.79
EL: 962.79
8'-0"CLG
FDC
12"CLR12"CLR
U1.1
W/D
SDCSD
PF-14A
PF-14A
SD
CSDL
DW
P
2A-4
U2.1
SDU2.1
CSD
W/D
PF-14A
DW
P
1A-4
U2.1
SDU2.1
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W/D
PF-14A
DW
P
1A-4
U2.1
SDU2.1
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W/D
DW
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PF-14A
1A-1
U1.1PA-11
DW
W/D
CSD
SD
L PF-14A
1C-1
U1.1 PA-11
DW
W/D
CSD
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LPF-14A
1C-1
U1.1 PA-11
DW
W/D
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LPF-14A
1C-1
U1.1 PA-11
DW
W/D
CSD
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1C-1
U1.1

BB DWBB W/D
CSD
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PF-14B
ST A-1
U2.1
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W/D
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1A-1
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1A-1
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W/D
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DW
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1C-1
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BB DWBB W/D
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ST A-1
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CW/D
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W/D
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1A-1
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PF-14A
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2A-1
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PF-14A
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PF-14A
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PF-14A
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2A-1
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P U1.1
W/D
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PF-14A
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2A-1
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W/D
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PF-14A
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2A-1
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W/D
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PF-14A
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CSDL
2A-1
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P U1.1
W/D
SDCSD
PF-14A
PF-14A
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CSDL
2A-1
UPDN
18"CLR
12"CLR
UPDN
12"CLR18"CLR
EL: 973.00
EL: 973.00
EL: 973.00EL: 973.00
EL: 973.00
EL: 972.75
EL: 973.00
973.25
972.75
EL: 973.00
18"CLR12"CLR
EL: 974.00EL:970.33"
18"CLR12"CLR

KITCHENSHAFT
1821 S.F.
3,096 S.F.
24"12"CLR
12"CLR
24"
EL: 973.00
12"CLR
POOL EQUIP.PUMPROOM

FIRE PUMPROOM
RESTAURANT 02
RESTAURANT 01
ELEC.ROOM
18"CLR
18"CLR

BUSINESS CENTER FITNESSLOUNGE
F.A.A.

FDC
12"CLR12"CLR
12"CLR12"CLR
12"CLR
12"CLR
Ø 5'-0"CLR
Ø 5'-0"CLR
Ø 5'-0"CLR
18"CLR18"CLR
Ø 5'-0"CLR
Ø 5'-0"CLR Ø 5'-0"CLR
Ø 5'-0"CLRØ 5'-0"CLR
18"CLR12"CLR
-R-0354-036
043044045048047046
066068 060062065067 064063
055056057
EV 1
058 041042
069071070072073074
051050049054053052
018017016013014015
028026 034033032029027 030031
081 019
025023024
010011012007008009
061
059
079
080
037038039040
EV 2 EV 2
075076
EV 2
084083
110111
082
112
077
EV 2
078 EL: 973.00
000000
-
C03C04
USPS

SHARE/UBER
C002C001
EL: 973.00
18"CLR
Ø 5'-0"CLR
18"CLR
EL: 978.10
EL: 967.90
EL: 973.00
EV 1
C05
9'-6"9'-0"9'-0"8'-0" 9'-0"
18'-0" 24'-0" 18'-0"
R 24'-0"R 24'-0"
TRANS.PAD8'x10'TRANS.PAD8'x10'
24'-0" 10'-4"2'-0"
18'-0"1'-0" 24'-0" 18'-0" 18'-0" 24'-0" 18'-0"
EL: 972.00
EL: 978.10
EL: 978.10 110'-2"@ 4.6 % SLOPE
110'-2"@ 4.6 % SLOPE
R 24'-0" R 24'-0"9'-6"9'-0"9'-0"
8'-0"CLG
8'-0"CLG
EV 1
9'-9"9'-0"
10'-0"9'-0"
C14C15C16C19C18C17
C37C39C40C42 C31C36C38 C35C34C41
3'-8"MIN.4'-4"
C22C21C20C25C24C23
C32C33
EV 2EV 2
C11C10C09C08C07C12C13
03 01
02 C06
C43
C26
C44
C27
C45
C28C29C30
006005
022021
004
020
EL: 965.02
18"CLR
18"CLR
EL: 967.90'
12"CLR
18"CLR 12"CLR
18"CLRØ 5'-0"CLR
12"CLR
EL: 962.79
EL: 962.79
9'-6"9'-0"9'-0"8'-0" 9'-0"
18'-0" 24'-0" 18'-0"
R 24'-0"
R 24'-0"R 24'-0"

COMPACTOR
Ø 5'-0"CLR18"CLR
18"CLR
12"CLR
18"CLR
110'-2"@ 4.6 % SLOPE
18"CLR12"CLR
18"CLR12"CLR
Ø 5'-0"CLR
P1623
18"
42" CLR
Ø 5'-0"CLR
9'-6"9'-0"
1'-0"
S I T E P L A NA 1 0 2

Appendix B
CalEEMod Modeling Results

kimley-horn.com 660 South Figueroa St #2050, Los Angeles, CA 90017 213 261 4040

MEMORANDUM
To: Haig Nazarian and Matthew Keenen, CGI Plus
From: Jessie Fan and Ryan Callahan, Kimley-Horn and Associates, Inc.

Date: August 16, 2022
Subject: 1575 University Avenue Development Project– Air Quality Summary

Purpose

The purpose of this memorandum is to identify the air quality emissions associated with construction and operations of the proposed 1575 University Avenue Development Project (Project), located in the City of Riverside, California (City).

Methodology

Construction and operational emissions associated with the proposed Project were calculated using the California Air Resources Board (CARB) -approved California Emissions Estimator Model version 2020.4.0 (CalEEMod), which is designed to model emissions for land use development projects, based on typical construction requirements. Emissions were calculated using one development program, assumptions regarding construction equipment and scheduling, and associated vehicle trips and compared to the South Coast Air Quality Management District ( SCAQMD) regional thresholds of significance.

Air Quality Impacts
Construction Emissions

Construction associated with the Project would generate short -term emissions of criteria air pollutants. The criteria pollutants of primary concern within the Project area include ozone-precursor pollutants (i.e., reactive organic gases [ ROG] and nitrogen oxides [NOX]) and particulate matter (inhalable particles with diameters of 10 micrometers and smaller (PM10) and with diameters of 2.5 microns or less (PM2.5). Construction-generated emissions are short term and of temporary duration, lasting only as long as construction activities occur, but would be considered a significant air quality impact if the volume of pollutants generated exceeds the SCAQMD’s thresholds of significance.

Construction results in the temporary generation of emissions resulting from demolition, site preparation, site grading, road paving, motor vehicle exhaust associated with construction equipment and worker trips, and the movement of construction equipment, especially on unpaved surfaces.

Emissions of airborne particulate matter are largely dependent on the amount of ground disturbance

kimley-horn.com 660 South Figueroa St #2050, Los Angeles, CA 90017 213 261 4040

associated with site preparation activities as well as weather conditions and the appropr iate application of water.

The duration of construction activities for the Project is estimated to be approximately 24 months, beginning in January 2024. See Appendix A: Air Quality Data for more information regarding the construction assumptions used in this analysis. Predicted maximum daily construction -generated emissions for the Project are identified in Table 1: Project Construction Emissions.

Table 1: Project Construction Emissions
Construction Year Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
2024 5.04 49.32 39.50 0.09 27.33 15.27
2025 36.00 16.12 28.43 0.07 4.41 1.59
2026 33.74 1.23 3.33 <0.01 0.62 0.21
SCAQMD Threshold 75 100 550 150 150 55
SCAQMD Threshold Exceeded? No No No No No No

1. SCAQMD Rule 403 Fugitive Dust applied. The Rule 403 reduction/credits include the following: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; water all haul roads thrice daily; and limit speeds on unpaved roads to 15 miles per hour. Reductions percentages from the SCAQMD CEQA Handbook (Tables XI -A through XI-E) were applied. No mitigation was applied to construction equipment.

Source: CalEEMod version 2020.4.0. Refer to Appendix A for model outputs.

Table 1 shows that construction pollutant emissions would remain below their respective thresholds with implementation of SCAQMD Rule 403 (required for all projects) . The Project would also be required to comply with SCAQMD Rules 402 and 1113, which prohibit nuisances and limit VOC content in paints, respectively. Compliance with SCAQMD Rules 402 and 1113 would further reduce less-than- significant construction-related emissions. As shown above, all criteria pollutant emissions would be below their respective thresholds. Impacts would be less than significant.

kimley-horn.com 660 South Figueroa St #2050, Los Angeles, CA 90017 213 261 4040

Operational Emissions

Operational emissions are typically associated with mobile sources (i.e., motor vehicle use) and area sources (such as the use of landscape maintenance equipment, hearths, consumer products, and architectural coatings). Energy source emissions would be generated from electricity and natural gas (non-hearth) usage. Table 2: Operational Emissions summarizes the operational emissions attributable to the Project. As shown in Table 2, the Project’s emissions would not exceed SCAQMD thresholds. Therefore, regional operations emissions would result in a less than significant long-term regional air quality impact.

Table 2: Operational Emissions
Source Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
Area 5.56 0.24 21.23 <0.01 0.12 0.12
Energy 0.11 0.94 0.40 <0.01 0.08 0.08
Mobile 4.15 5.54 40.37 0.10 10.52 2.86
Total 9.82 6.72 62.00 0.11 10.72 3.06
SCAQMD Threshold 55 55 550 150 150 55
SCAQMD Threshold Exceeded? No No No No No No

1. Emissions were calculated using the California Emissions Estimator Model version 20 20.4.0 (CalEEMod), as recommended by the SCAQMD. Worst-case seasonal maximum daily emissions are reported.

Source: CalEEMod version 2020.4.0. Refer to Appendix A for model outputs.

Conclusion

Project implementation would result in less than significant construction and operational air quality impacts. No mitigation measures would be required.

Appendix A
Air Quality Data

1575 University Avenue
Riverside-Mojave Desert SCAQMD County, Summer
Project Characteristics -
Land Use - Likely change Commercial Land use type, lot acerage and square feet based on provided gross information.

Construction Phase - Baesed on construction schedule
Trips and VMT - 2000 Market Street, Riverside CA 92501
Demolition - Based on construction questionnaire
Grading - All Demolished hardscape reused onsite (45,000 sf of pavement material * 12 inches deep, converted to yards = 1667 cy) Woodstoves - Woodstoves and fireplaces would not be present in the mixed-use dwelling units Construction Off-road Equipment Mitigation -

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
General Office Building

5.45 1000sqft

0.13 5,450.00
0 Enclosed Parking Structure
415.00
Space

3.73 166,000.00
0 Apartments Mid Rise
257.00
Dwelling Unit

0.43 219,550.00
735

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10 Wind Speed (m/s)
Precipitation Freq (Days)

2.6 28

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
Southern California Edison
2026
Operational Year
CO2 Intensity
(lb/MWhr)
390.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/8/2022 5:41 PM