Attachment 2f -PC Report and Exhibits - 9-14-2023 — Riverside City Council, November 7, 2023

Cultural Resource Report for the Dauchy Avenue Project –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––

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Plate 4.2–1: Overview of the project from the northern boundary, showing Ferrari Drive (right) and the rolling hill topography of the property, facing southwest.

Plate 4.2–2: Overview of the drainage along the western project boundary, facing northwest.

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Plate 4.2–3: View of the 2002 to 2003 manufactured home and landscaping in the northwest corner of the project, facing southeast.

Plate 4.2–4: View of the modern well on the property, facing southwest.

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5.0 RECOMMENDATIONS The cultural resources study for the Dauchy Avenue Project was negative for the presence of archaeological sites within the project. A review of records housed at BFSA has indicated that two cultural resource sites have been recorded within 50 meters (164 feet) of the southern project boundary, but none within the project boundaries. According to BFSA records, the assessment conducted by Parr and Wilke (1989) is the only study that includes the project location. It must be noted, however, that additional resources and surveys could have been reported to the EIC at UCR that will be part of the records search, the results of which are still pending due to circumstances related to the COVID-19 pandemic. Therefore, as a result of known previous studies, the documented development of the current project, and results of the current survey, no cultural resources appear to exist within the project. However, the possibility for unidentified buried cultural deposits exists within the project. The cultural resources survey of the Dauchy Avenue Project did not identify any historic or prehistoric resources within the project. The archaeological study was completed in accordance with City of Riverside report guidelines and CEQA significance evaluation criteria. While the cultural resources survey was negative for cultural resources, the records search conducted by BFSA indicates that at least 89 bedrock milling feature sites and one historic single-family ranch property are located within a one-mile radius of the project. Two of the bedrock milling feature sites, RIV-2184 and RIV-2670, are located within 50 meters (164 feet) of the southern project boundary. Additionally, the project is bound by a seasonal drainage to the west, which generally indicates the likelihood of additional cultural resources. Based upon the presence of the 89 bedrock milling feature sites within one mile of the project and the seasonal drainage to the west, the potential exists that other unidentified cultural resources may exist within the project that may be exposed during grading. Therefore, it is recommended that all earth disturbance of the project be monitored by an archaeologist and a Native American representative. 5.1 Mitigation Monitoring and Reporting Program Monitoring during ground-disturbing activities, such as grading or trenching, by a qualified archaeologist and Native American representative is recommended to ensure that if buried features (i.e., human remains, hearths, or cultural deposits) are present, they will be handled in a timely and proper manner. As a Condition of Approval, a Mitigation Monitoring and Reporting Program (MMRP) shall be required to ensure that any cultural resources discovered during the construction grading are treated in accordance with city guidelines and CEQA requirements. A recommended scope of the monitoring program is provided below, which shall be further refined by the City through their Assembly Bill 52 consultation efforts with local Native American groups.

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Mitigation Monitoring and Reporting Program A MMRP to mitigate potential impacts to undiscovered, buried cultural resources within the Dauchy Avenue Project shall be implemented to the satisfaction of the lead agency. This program shall include, but not be limited to, the following actions: 1) Prior to issuance of a grading permit, the applicant shall provide written verification in the form of a letter from the project archaeologist to the lead agency stating that a certified archaeologist has been retained to implement the monitoring program. 2) The project applicant shall provide Native American monitoring during grading. The Native American monitor shall work in concert with the archaeological monitor to observe ground disturbances and search for cultural materials. 3) The certified archaeologist shall attend the pre-grading meeting with the contractors to explain and coordinate the requirements of the monitoring program. 4) During the original cutting of previously undisturbed deposits, the archaeological monitor(s) and tribal representative shall be on-site, as determined by the consulting archaeologist, to perform periodic inspections of the excavations. The frequency of inspections will depend upon the rate of excavation, the materials excavated, and the presence and abundance of artifacts and features. The consulting archaeologist shall have the authority to modify the monitoring program if the potential for cultural resources appears to be less than anticipated. 6) Isolates and clearly non-significant deposits will be minimally documented in the field so the monitored grading can proceed. 7) In the event that previously unidentified cultural resources are discovered, the archaeologist shall have the authority to divert or temporarily halt ground disturbance operation in the area of discovery to allow for the evaluation of potentially significant cultural resources. The archaeologist shall contact the lead agency at the time of discovery. The archaeologist, in consultation with the lead agency, shall determine the significance of the discovered resources. The lead agency must concur with the evaluation before construction activities will be allowed to resume in the affected area. For significant cultural resources, a Research Design and Data Recovery Program to mitigate impacts shall be prepared by the consulting archaeologist and approved by the lead agency before being carried out using professional archaeological methods. If any human bones are discovered, the Riverside County Coroner’s Office and the lead agency shall be contacted. In the event that the remains are determined to be of Native American origin, the Most Likely Descendant, as identified by the NAHC, shall be contacted in order to determine proper treatment and disposition of the remains. 8) Before construction activities are allowed to resume in the affected area, the artifacts shall be recovered and features recorded using professional archaeological methods. The project archaeologist shall determine the amount of material to be recovered for an Cultural Resource Report for the Dauchy Avenue Project –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––

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adequate artifact sample for analysis. 9) All cultural material collected during the grading monitoring program shall be processed and curated according to the current professional repository standards. The collections and associated records shall be transferred, including title, to an appropriate curation facility, to be accompanied by payment of the fees necessary for permanent curation. 10) A report documenting the field and analysis results and interpreting the artifact and research data within the research context shall be completed and submitted to the satisfaction of the lead agency prior to the issuance of any building permits. The report will include DPR Primary and Archaeological Site Forms.

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6.0 CERTIFICATION I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this archaeological report, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief. December 2, 2020 Brian F. Smith Date Principal Investigator

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7.0 REFERENCES Bailey, Janet F. 1961 The Growth of Riverside. Unpublished thesis, University of California at Riverside, Riverside Special Collections Department, Riverside, California. Bean, Lowell John 1978 Cahuilla. In California, edited by Robert F. Heizer, pp. 575–587. Handbook of North American Indians, Vol. 8. William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. Bean, Lowell John and Charles R. Smith 1978 Gabrielino. In Handbook of North American Indians, Vol 8. California, edited by Robert F. Heizer. Smithsonian Institution, Washington, D.C. Bean, Lowell John and Florence C. Shipek 1978 Luiseño. In California, edited by Robert F. Heizer, pp. 550–563. Handbook of North American Indians, Vol. 8. William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. Beattie, George W. and Helen P. Beattie 1939 Heritage of the Valley: San Bernardino’s First Century. Biobooks, Oakland, California. Brigandi, Phil 1998 Temecula: at the Crossroads of History. Heritage Media Corporation, Encinitas, California. Brown, J.B. 1985 Harvest of the Sun: An Illustrated History of Riverside County. Windsor Publications, Northridge, California. Byrd, Brian F. 1998 Harvesting the Littoral Landscape During the Late Holocene: New Perspectives from Northern San Diego County. Journal of California and Great Basin Anthropology 20(2):195–218. Caughey, John W. 1970 California, A Remarkable State’s Life History. Prentice-Hall Inc., Englewood Cliffs, New Jersey. Chapman, Charles E. 1921 A History of California: The Spanish Period. The Macmillan Company, New York.

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Cook, Sherburne Friend 1976 The Conflict Between the California Indian and White Civilization. University of California Press, Berkeley and Los Angeles, California. Engelhardt, Zephyrin 1921 San Luis Rey Mission, The King of the Missions. James M. Barry Company, San Francisco, California. Erlandson, Jon M. and Roger H. Colten (editors) 1991 An Archaeological Context for Archaeological Sites on the California Coast. In Hunter-Gatherers of Early Holocene Coastal California, edited by Jon M. Erlandson and Roger H. Colten. Perspectives in California Archaeology, Volume 1, Institute of Archaeology, University of California, Los Angeles. Fagan, Brian M. 1991 Ancient North America: The Archaeology of a Continent. Thames and Hudson, London. Gallegos, Dennis R. 1987 A Review and Synthesis of Environmental and Cultural Material for the Batiquitos Lagoon Region. In San Dieguito-La Jolla: Chronology and Controversy. Editor. San Diego County Archaeological Society Research Paper No. 1. 1992 Patterns and Implications of Coastal Settlement in San Diego County: 9000 to 1300 Years Ago. In Essays on the Prehistory of Maritime California, edited by Terry Jones. Center for Archaeological Research, Davis, California. Gallegos, Dennis R. and Carolyn E. Kyle 1988 Five Thousand Years of Maritime Subsistence at Ballast Point Prehistoric Site SDI-48 (W-164) San Diego, California. Unpublished report on file at the South Coastal Information Center at San Diego State University, San Diego, California. Garrison, Andrew J., Jennifer R.K. Stropes, and Brian F. Smith 2018 Cultural Resource Report for the 18806 Van Buren Boulevard Project, City of Riverside, Riverside County, California. Brian F. Smith and Associates, Inc. Unpublished report on file at the Eastern Information Center at the University of California at Riverside, Riverside, California. Guinn, J.M. 1907 A History of California and an Extended History of its Southern Coast Counties. Historic Record Company, Los Angeles, California. Gunther, Jane Davies 1984 Riverside County, California, Place Names. Rubidoux Printing Co., Riverside, California.

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Handley, Charles 1967 The Sun City Story. Sun City News 2 February:6, 15–19. Sun City, California. Harris, Marvin 1991 Cultural Anthropology. HarperCollins Publishers Inc., New York, New York. Koerper, Henry C., Paul E. Langenwalter II, and Adella B. Schroth 1986 The Agua Hedionda Project Archaeological Investigations at CA-SDI-5353 and CA-SDI-9649. Report on file at the South Coastal Information Center at San Diego State University, San Diego, California. Kowta, Makoto 1969 The Sayles Complex: A Late Millingstone Assemblage from Cajon Pass, and the Econological Implications of its Scraper Planes. University of California Prehistory (6), Salinas, California. Kroeber, A.L. 1976 Handbook of the Indians of California. Reprinted. Dover Editions, Dover Publications, Inc., New York. Originally published 1925, Bulletin No. 78, U.S. Government Printing Office, Washington, D.C. Laylander, Don (editor) 1985 Some Linguistic Approaches to Southern California’s Prehistory. San Diego State University Cultural Resource Management Casual Papers 2(1):14–58. Laylander, Don, Jerry Schaefer, Nick Doose, Jessica Hennessey, and Ian Scharlotta 2014 A Regional Synthesis of Prehistoric Archaeological Landscapes in the Jacumba/McCain Valley Region, San Diego and Imperial Counties, California. Prepared for the Bureau of Land Management and San Diego Gas & Electric by ASM Affiliates, Carlsbad, California. March Air Reserve Base 2010 The March Field Story. Electronic document, https://www.march.afrc.af.mil/About-Us/Fact-Sheets/Display/Article/167413/the-march-field-story/, accessed August 14, 2020. Martin, Paul S. 1967 Prehistoric Overkill. In Pleistocene Extinctions: The Search for a Cause, edited by Paul S. Martin and H.E. Wright. Yale University Press, New Haven. 1973 The Discovery of America. Science 179(4077):969–974. Masters, Patricia M. 1983 Detection and Assessment of Prehistoric Artifact Sites off the Coast of Southern California. In Quaternary Coastlines and Marine Archaeology, edited by Patricia M.

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Masters and N.C. Fleming, pp. 1–49, Academic Press, New York. Meighan, Clement W. 1954 A Late Complex in Southern California Prehistory. Southwestern Journal of Anthropology 10(2). Miller, Jaquelin Neva 1966 The Present and Past Molluscan Faunas and Environments of Four Southern California Coastal Lagoons. Master’s Thesis, University of California at San Diego. Moratto, Michael J. 1984 California Archaeology. Academic Press, New York. Moriarty, James R., III 1966 Culture Phase Divisions Suggested by Topological Change Coordinated with Stratigraphically Controlled Radiocarbon Dating in San Diego. Anthropological Journal of Canada 4(4):20–30. Morton, D.M. and B.F. Cox 2001 Geologic Map of the Riverside East 7.5' Quadrangle, Riverside County, California, Version 1.0: U.S. Geological Survey Open-File Report 01-452, scale 1:24,000. Moss, Madonna L. and Jon M. Erlandson 1995 Reflections on North American Pacific Coast Prehistory. Journal of World Prehistory 9(1):1–45. Parr, Robert E. and P.J. Wilke 1989 Cultural Resources Assessment of the Alessandro Heights Project Located in the City of Riverside, Riverside County, California. Archaeological Research Unit, U.C. Riverside. Unpublished report on file at the Eastern Information Center at the University of California at Riverside, Riverside, California. Patterson, Tom 1971 A Colony for California: Riverside’s First Hundred Years. Press-Enterprise, Riverside, California. Pourade, Richard F. 1961 Time of the Bells. In The History of San Diego (Volume 2). Union-Tribune Publishing Company, San Diego, California. 1963 The Silver Dons. In The History of San Diego (Volume 3). Union-Tribune Publishing Company, San Diego, California. Raven-Jennings, Shelly, Brian F. Smith, and Johnna L. Buysse 1996 The Results of a Cultural Resource Study at the 4S Ranch, Rancho Bernardo, County Cultural Resource Report for the Dauchy Avenue Project –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––

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of San Diego. Unpublished report on file at the South Coastal Information Center at San Diego State University, San Diego, California. Rogers, Malcolm J. 1939 Early Lithic Industries of the Lower Basin of the Colorado River and Adjacent Desert Areas. In San Diego Museum Papers (No. 3 – 1989 printing). San Diego Museum of Man, San Diego, California. Rolle, Andrew F. 1969 California: A History. 2nd ed. Thomas Y. Crowell Company, New York. Shumway, George, Carl L. Hubbs, and James R. Moriarty, III 1961 Scripps Estate Site, San Diego, California: A La Jollan Site Dated 5,460-7,370 Years Before the Present. Annals of the New York Academy of Sciences 93(3). Smith, Brian F. and James R. Moriarty, III 1985 An Archaeological Reconnaissance of San Diego Motor Racing Park, Otay Mesa, San Diego. Unpublished report on file at the City of San Diego, Environmental Analysis Division, San Diego, California. State Historic Preservation Office (SHPO) 1995 Instructions for Recording Historical Resources. Office of Historic Preservation, Sacramento. Stonehouse, Merlin 1965 John Wesley North and the Reform Frontier. University of Minnesota Press, Minneapolis, Minnesota. Strong, William Duncan 1929 Aboriginal Society in Southern California. Publications in American Archaeology and Ethnology No. 26, University of California, Berkeley. Sutton, Mark Q. 2009 People and Language: Defining the Takic Expansion into Southern California. Pacific Coast Archaeological Society Quarterly 41(2, 3):33–93. 2011a The Palomar Tradition and Its Place in the Prehistory of Southern California. Pacific Coast Archaeological Society Quarterly 44(4):1–74. 2011b A Prehistory of North America. Routledge, New York. Sutton, Mark Q. and Jill K. Gardener 2010 Reconceptualizing the Encinitas Tradition of Southern California. Pacific Coast Archaeological Society Quarterly 42(4):1–64.

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True, Delbert L. 1958 An Early Complex in San Diego County, California. American Antiquity 23(3). 1980 The Pauma Complex in Northern San Diego County. Journal of New World Archaeology 3(4):1–39 U.S. Census Bureau 2010 2010 Census of Population and Housing, Population and Housing Unit Counts, CPH-2-1, United States Summary. U.S. Government Printing Office, Washington, D.C., 2012. Electronic document, https://www.census.gov/prod/cen2010/cph-2-1.pdf, accessed August 14, 2020. Wallace, William J. 1955 A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11:214–230. Warren, Claude N. (editor) 1968 Cultural Tradition and Ecological Adaptation on the Southern Coast. In Archaic Prehistory in the Western United States, C.I. Williams ed. Eastern New Mexico University Contributions in Anthropology 1(3):1–14. Warren, Claude N. and D.L. True 1961 The San Dieguito Complex and its Place in California Prehistory. In Archaeological Survey Annual Report 1960-1961. University of California Press, Los Angeles, California. Warren, Claude N., D.L. True, and Ardith A. Eudey 1961 Early Gathering Complexes of Western San Diego County: Results and Interpretations of an Archaeological Survey. Archaeological Survey Annual Report 1960-1961. University of California, Los Angeles.

APPENDIX A Qualifications of Key Personnel
Brian F . Smith, MA Owner, Principal Investigator Brian F. Smith and Associates, Inc. 14010 Poway Road Suite A Phone: (858) 679-8218 Fax: (858) 679-9896 E-Mail: [email protected]

Education Master of Arts, History, University of San Diego, California 1982 Bachelor of Arts, History, and Anthropology, University of San Diego, California 1975 Professional Memberships Society for California Archaeology Experience Principal Investigator 1977–Present Brian F. Smith and Associates, Inc. Poway, California Brian F. Smith is the owner and principal historical and archaeological consultant for Brian F. Smith and Associates. Over the past 32 years, he has conducted over 2,500 cultural resource studies in California, Arizona, Nevada, Montana, and Texas. These studies include every possible aspect of archaeology from literature searches and large-scale surveys to intensive data recovery excavations. Reports prepared by Mr. Smith have been submitted to all facets of local, state, and federal review agencies, including the US Army Corps of Engineers, the Bureau of Land Management, the Bureau of Reclamation, the Department of Defense, and the Department of Homeland Security. In addition, Mr. Smith has conducted studies for utility companies (Sempra Energy) and state highway departments (CalTrans). Professional Accomplishments These selected major professional accomplishments represent research efforts that have added significantly to the body of knowledge concerning the prehistoric life ways of cultures once present in the Southern California area and historic settlement since the late 18th century. Mr. Smith has been principal investigator on the following select projects, except where noted. Downtown San Diego Mitigation and Monitoring Reporting Programs: Large numbers of downtown San Diego mitigation and monitoring projects, some of which included Broadway Block (2019), 915 Grape Street (2019), 1919 Pacific Highway (2018), Moxy Hotel (2018), Makers Quarter Block D (2017), Ballpark Village (2017), 460 16th Street (2017), Kettner and Ash (2017), Bayside Fire Station (2017), Pinnacle on the Park (2017), IDEA1 (2016), Blue Sky San Diego (2016), Pacific Gate (2016), Pendry Hotel (2015), Cisterra Sempra Office Tower (2014), 15th and Island (2014), Park and G (2014), Comm 22 (2014), 7th and F Street Parking (2013), Ariel Suites (2013), 13th and Marker (2012), Strata (2008), Hotel Indigo (2008), Lofts at 707 10th Avenue Project (2007), Breeza (2007), Bayside at the Embarcadero (2007), Aria (2007), Icon (2007), Vantage Pointe (2007), Aperture (2007), Sapphire Tower (2007), Lofts at 655 Sixth Avenue (2007), Metrowork (2007), The Legend (2006), The Mark (2006), Smart Corner (2006), Lofts at 677 7th Avenue (2005), Aloft on Cortez Hill (2005), Front and Beech Apartments (2003), Bella Via Condominiums (2003), Acqua Vista Residential Tower (2003), Northblock Lofts (2003), Westin Park Place Hotel (2001), Parkloft Brian F. Smith and Associates, Inc. 2 Apartment Complex (2001), Renaissance Park (2001), and Laurel Bay Apartments (2001). 1900 and 1912 Spindrift Drive: An extensive data recovery and mitigation monitoring program at the Spindrift Site, an important prehistoric archaeological habitation site stretching across the La Jolla area. The project resulted in the discovery of over 20,000 artifacts and nearly 100,000 grams of bulk faunal remains and marine shell, indicating a substantial occupation area (2013-2014). San Diego Airport Development Project: An extensive historic assessment of multiple buildings at the San Diego International Airport and included the preparation of Historic American Buildings Survey documentation to preserve significant elements of the airport prior to demolition (2017-2018). Citracado Parkway Extension: A still-ongoing project in the city of Escondido to mitigate impacts to an important archaeological occupation site. Various archaeological studies have been conducted by BFSA resulting in the identification of a significant cultural deposit within the project area. Westin Hotel and Timeshare (Grand Pacific Resorts): Data recovery and mitigation monitoring program in the city of Carlsbad consisted of the excavation of 176 one-square-meter archaeological data recovery units which produced thousands of prehistoric artifacts and ecofacts, and resulted in the preservation of a significant prehistoric habitation site. The artifacts recovered from the site presented important new data about the prehistory of the region and Native American occupation in the area (2017). The Everly Subdivision Project: Data recovery and mitigation monitoring program in the city of El Cajon resulted in the identification of a significant prehistoric occupation site from both the Late Prehistoric and Archaic Periods, as well as producing historic artifacts that correspond to the use of the property since 1886. The project produced an unprecedented quantity of artifacts in comparison to the area encompassed by the site, but lacked characteristics that typically reflect intense occupation, indicating that the site was used intensively for food processing (2014-2015). Ballpark Village: A mitigation and monitoring program within three city blocks in the East Village area of San Diego resulting in the discovery of a significant historic deposit. Nearly 5,000 historic artifacts and over 500,000 grams of bulk historic building fragments, food waste, and other materials representing an occupation period between 1880 and 1917 were recovered (2015-2017). Archaeology at the Padres Ballpark: Involved the analysis of historic resources within a seven-block area of the “East Village” area of San Diego, where occupation spanned a period from the 1870s to the 1940s. Over a period of two years, BFSA recovered over 200,000 artifacts and hundreds of pounds of metal, construction debris, unidentified broken glass, and wood. Collectively, the Ballpark Project and the other downtown mitigation and monitoring projects represent the largest historical archaeological program anywhere in the country in the past decade (2000-2007). 4S Ranch Archaeological and Historical Cultural Resources Study: Data recovery program consisted of the excavation of over 2,000 square meters of archaeological deposits that produced over one million artifacts, containing primarily prehistoric materials. The archaeological program at 4S Ranch is the largest archaeological study ever undertaken in the San Diego County area and has produced data that has exceeded expectations regarding the resolution of long-standing research questions and regional prehistoric settlement patterns. Charles H. Brown Site: Attracted international attention to the discovery of evidence of the antiquity of man in North America. Site located in Mission Valley, in the city of San Diego. Del Mar Man Site: Study of the now famous Early Man Site in Del Mar, California, for the San Diego Science Foundation and the San Diego Museum of Man, under the direction of Dr. Spencer Rogers and Dr. James R. Moriarty.

Brian F. Smith and Associates, Inc. 3 Old Town State Park Projects: Consulting Historical Archaeologist. Projects completed in the Old Town State Park involved development of individual lots for commercial enterprises. The projects completed in Old Town include Archaeological and Historical Site Assessment for the Great Wall Cafe (1992), Archaeological Study for the Old Town Commercial Project (1991), and Cultural Resources Site Survey at the Old San Diego Inn (1988). Site W-20, Del Mar, California: A two-year-long investigation of a major prehistoric site in the Del Mar area of the city of San Diego. This research effort documented the earliest practice of religious/ceremonial activities in San Diego County (circa 6,000 years ago), facilitated the projection of major non-material aspects of the La Jolla Complex, and revealed the pattern of civilization at this site over a continuous period of 5,000 years. The report for the investigation included over 600 pages, with nearly 500,000 words of text, illustrations, maps, and photographs documenting this major study. City of San Diego Reclaimed Water Distribution System: A cultural resource study of nearly 400 miles of pipeline in the city and county of San Diego. Master Environmental Assessment Project, City of Poway: Conducted for the City of Poway to produce a complete inventory of all recorded historic and prehistoric properties within the city. The information was used in conjunction with the City’s General Plan Update to produce a map matrix of the city showing areas of high, moderate, and low potential for the presence of cultural resources. The effort also included the development of the City’s Cultural Resource Guidelines, which were adopted as City policy. Draft of the City of Carlsbad Historical and Archaeological Guidelines: Contracted by the City of Carlsbad to produce the draft of the City’s historical and archaeological guidelines for use by the Planning Department of the City. The Mid-Bayfront Project for the City of Chula Vista: Involved a large expanse of undeveloped agricultural land situated between the railroad and San Diego Bay in the northwestern portion of the city. The study included the analysis of some potentially historic features and numerous prehistoric Cultural Resources Survey and Test of Sites Within the Proposed Development of the Audie Murphy Ranch, Riverside County, California: Project manager/director of the investigation of 1,113.4 acres and 43 sites, both prehistoric and historic—included project coordination; direction of field crews; evaluation of sites for significance based on County of Riverside and CEQA guidelines; assessment of cupule, pictograph, and rock shelter sites, co-authoring of cultural resources project report. February- September 2002. Cultural Resources Evaluation of Sites Within the Proposed Development of the Otay Ranch Village 13 Project, San Diego County, California: Project manager/director of the investigation of 1,947 acres and 76 sites, both prehistoric and historic—included project coordination and budgeting; direction of field crews; assessment of sites for significance based on County of San Diego and CEQA guidelines; co- authoring of cultural resources project report. May-November 2002. Cultural Resources Survey for the Remote Video Surveillance Project, El Centro Sector, Imperial County: Project manager/director for a survey of 29 individual sites near the U.S./Mexico Border for proposed video surveillance camera locations associated with the San Diego Border barrier Project—project coordination and budgeting; direction of field crews; site identification and recordation; assessment of potential impacts to cultural resources; meeting and coordinating with U.S. Army Corps of Engineers, U.S. Border Patrol, and other government agencies involved; co-authoring of cultural resources project report. January, February, and July 2002. Cultural Resources Survey and Test of Sites Within the Proposed Development of the Menifee West GPA, Riverside County, California: Project manager/director of the investigation of nine sites, both prehistoric and historic—included project coordination and budgeting; direction of field crews; assessment of sites Brian F. Smith and Associates, Inc. 4 for significance based on County of Riverside and CEQA guidelines; historic research; co-authoring of cultural resources project report. January-March 2002. Cultural Resources Survey and Test of Sites Within the Proposed French Valley Specific Plan/EIR, Riverside County, California: Project manager/director of the investigation of two prehistoric and three historic sites—included project coordination and budgeting; survey of project area; Native American consultation; direction of field crews; assessment of sites for significance based on CEQA guidelines; cultural resources project report in prep. July-August 2000. Cultural Resources Survey and Test of Sites Within the Proposed Development of the Menifee Ranch, Riverside County, California: Project manager/director of the investigation of one prehistoric and five historic sites—included project coordination and budgeting; direction of field crews; feature recordation; historic structure assessments; assessment of sites for significance based on CEQA guidelines; historic research; co-authoring of cultural resources project report. February-June 2000. Salvage Mitigation of a Portion of the San Diego Presidio Identified During Water Pipe Construction for the City of San Diego, California: Project archaeologist/director—included direction of field crews; development and completion of data recovery program; management of artifact collections cataloging and curation; data synthesis and authoring of cultural resources project report in prep. April 2000. Enhanced Cultural Resource Survey and Evaluation for the Tyrian 3 Project, La Jolla, California: Project manager/director of the investigation of a single-dwelling parcel—included project coordination; assessment of parcel for potentially buried cultural deposits; authoring of cultural resources project report. April 2000. Enhanced Cultural Resource Survey and Evaluation for the Lamont 5 Project, Pacific Beach, California: Project manager/director of the investigation of a single-dwelling parcel—included project coordination; assessment of parcel for potentially buried cultural deposits; authoring of cultural resources project report. April 2000. Enhanced Cultural Resource Survey and Evaluation for the Reiss Residence Project, La Jolla, California: Project manager/director of the investigation of a single-dwelling parcel—included project coordination; assessment of parcel for potentially buried cultural deposits; authoring of cultural resources project report. March-April 2000. Salvage Mitigation of a Portion of Site SDM-W-95 (CA-SDI-211) for the Poinsettia Shores Santalina Development Project and Caltrans, Carlsbad, California: Project archaeologist/ director—included direction of field crews; development and completion of data recovery program; management of artifact collections cataloging and curation; data synthesis and authoring of cultural resources project report in prep. December 1999-January 2000. Survey and Testing of Two Prehistoric Cultural Resources for the Airway Truck Parking Project, Otay Mesa, California: Project archaeologist/director—included direction of field crews; development and completion of testing recovery program; assessment of site for significance based on CEQA guidelines; authoring of cultural resources project report, in prep. December 1999-January 2000. Cultural Resources Phase I and II Investigations for the Tin Can Hill Segment of the Immigration and Naturalization Services Triple Fence Project Along the International Border, San Diego County, California: Project manager/director for a survey and testing of a prehistoric quarry site along the border—NRHP eligibility assessment; project coordination and budgeting; direction of field crews; feature recordation; meeting and coordinating with U.S. Army Corps of Engineers; co-authoring of cultural resources project report. December 1999-January 2000.

Brian F. Smith and Associates, Inc. 5 Mitigation of a Prehistoric Cultural Resource for the Westview High School Project for the City of San Diego, California: Project archaeologist/ director—included direction of field crews; development and completion of data recovery program including collection of material for specialized faunal and botanical analyses; assessment of sites for significance based on CEQA guidelines; management of artifact collections cataloging and curation; data synthesis; co-authoring of cultural resources project report, in prep. October 1999-January 2000. Mitigation of a Prehistoric Cultural Resource for the Otay Ranch SPA-One West Project for the City of Chula Vista, California: Project archaeologist/director—included direction of field crews; development of data recovery program; management of artifact collections cataloging and curation; assessment of site for significance based on CEQA guidelines; data synthesis; authoring of cultural resources project report, in prep. September 1999-January 2000. Monitoring of Grading for the Herschel Place Project, La Jolla, California: Project archaeologist/ monitor—included monitoring of grading activities associated with the development of a single- dwelling parcel. September 1999. Survey and Testing of a Historic Resource for the Osterkamp Development Project, Valley Center, California: Project archaeologist/ director—included direction of field crews; development and completion of data recovery program; budget development; assessment of site for significance based on CEQA guidelines; management of artifact collections cataloging and curation; data synthesis; authoring of cultural resources project report. July-August 1999. Survey and Testing of a Prehistoric Cultural Resource for the Proposed College Boulevard Alignment Project, Carlsbad, California: Project manager/director —included direction of field crews; development and completion of testing recovery program; assessment of site for significance based on CEQA guidelines; management of artifact collections cataloging and curation; data synthesis; authoring of cultural resources project report, in prep. July-August 1999. Survey and Evaluation of Cultural Resources for the Palomar Christian Conference Center Project, Palomar Mountain, California: Project archaeologist—included direction of field crews; assessment of sites for significance based on CEQA guidelines; management of artifact collections cataloging and curation; data synthesis; authoring of cultural resources project report. July-August 1999. Survey and Evaluation of Cultural Resources at the Village 2 High School Site, Otay Ranch, City of Chula Vista, California: Project manager/director —management of artifact collections cataloging and curation; assessment of site for significance based on CEQA guidelines; data synthesis; authoring of cultural resources project report. July 1999. Cultural Resources Phase I, II, and III Investigations for the Immigration and Naturalization Services Triple Fence Project Along the International Border, San Diego County, California: Project manager/director for the survey, testing, and mitigation of sites along border—supervision of multiple field crews, NRHP eligibility assessments, Native American consultation, contribution to Environmental Assessment document, lithic and marine shell analysis, authoring of cultural resources project report. August 1997- January 2000. Phase I, II, and II Investigations for the Scripps Poway Parkway East Project, Poway California: Project archaeologist/project director—included recordation and assessment of multicomponent prehistoric and historic sites; direction of Phase II and III investigations; direction of laboratory analyses including prehistoric and historic collections; curation of collections; data synthesis; coauthorship of final cultural resources report. February 1994; March-September 1994; September-December 1995.

APPENDIX B Archaeological Records Search Results (Deleted for Public Review; Bound Separately) Cultural Resource Report for the Dauchy Avenue Project –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––

APPENDIX C NAHC Sacred Lands File Search Results (Deleted for Public Review; Bound Separately)

13820-07 VMT
June 8, 2023

Signature Realty Capital Corp
c/o Mr. Keith Gardner
1901 Newport Boulevard, Ste 350
Costa Mesa, CA 92627

SUBJECT: D AUCHY STREET VEHICLE MILES TRAVELLED (VMT) ANALYSIS Dear Mr. Keith Gardner:

The following Vehicle Miles Travelled (VMT) Analysis has been prepared for the proposed Dauchy Street (Project), which located on the southwest corner of Ferrari Drive and Dauchy Avenue in the City of Riverside.

PROJECT OVERVIEW
The Project as addressed in this analysis consists of up to 53 single family residential dwelling units (See Attachment A).

BACKGROUND
Changes to California Environmental Quality Act (CEQA) Guidelines were adopted in December 2018, which requires all lead agencies to adopt VMT as a replacement for automobile delay -based level of service (LOS) as the new measure for identifying transportation impacts for land use projects. This statewide mandate went into effect July 1, 2020. To aid in this transition, the Governor’s Office o f Planning and Research (OPR) released a Technical Advisory on Evaluating Transportation Impacts in CEQA (December of 2018) (Technical Advisory) (1).

The City of Riverside City Council adopted analytical procedures, screening tools, and impact thresholds for VMT, which are documented in the City of Riverside Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment ( July 2020) ( City Guidelines ) (2). The VMT analysis presented in this report has been developed based on the adopted City Guidelines.

PROJECT SCREENING
The City Guidelines provide details on appropriate screening criteria that can be used to identify when a proposed land use project is anticipated to result in a less -than-significant impact without conducting a more detailed project lev el analysis. To aid in the project -level VMT screening process , the City of Riverside utilizes the Western Riverside Council of Governments (WRCOG) VMT Screening Tool (Screening Tool). The web- based Screening Tool allows a user to select an assessor’s parcel number Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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(APN) to determine if a project’s physical location meets one or more of the land use screening thresholds documented in the City Guidelines. Screening criteria is broken into three steps:

Step 1: Transit Priority Area (TPA) Screening
Step 2: Low VMT Area Screening
Step 3: Project Type Screening
A land use project need only to meet one of the above screening criteria to result in a less than significant impact.

STEP 1: TPA SCREENING
Consistent with guidance identified in the City Guidelines, projects located within a Transit Priority Area (TPA) (i.e., within ½ mile of an existing “major transit stop” 1 or an existing stop along a “high-quality transit corridor”2) may be presumed to have a less than significant impact absent substantial evidence to the contrary.

However, the presumption may not be appropriate if a project:
• Has a Floor Area Ratio (FAR) of less than 0.75;
• Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); • Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization); or • Replaces affordable residential units with a smaller number of moderate - or high -income residential units.

Based on the Screening Tool, the Project site is shown not to be located within a TPA (see Attachment B).

TPA screening criteria is not met.

STEP 2: LOW VMT AREA SCREENING
City Guidelines state that “Residential and office projects located within a low VMT-generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary. In addition, other employment -related and mixed- use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident or per worker that is

1 Pub. Resources Code, § 21064.3 (“‘Major transit stop’ means 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.”). 2 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”).

Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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similar to the existing land uses in the low VMT area- provided the VMT of the area fal ls below thresholds.”3 The City uses the WRCOG screening tool to determine low areas of VMT. The screening tool uses the sub- regional Riverside Transportation Analysis Model ( RIVTAM) to measure VMT performance within individual traffic analysis zones (TAZ ’s) within the region. The Project’s physical location based on parcel number is input into the Screening Tool to determine project generated VMT as compared to the City’s impact threshold. The parcel containing the proposed Project was selected and the screening tool was run for the VMT per service population (SP) measure of VMT based on the mixed-use nature of the Project. The Project resides within TAZ 3,547 and was found to generate 18.06 VMT per capita of whereas the City’s impact threshold of 15% below baseline City of Riverside VMT per employee is 11.25. The Project does not reside within a Low VMT Area (See Attachment B).

Low VMT Area screening criteria is not met.

STEP 3: PROJECT TYPE SCREENING
The City Guidelines identify that local serving retail less than 50,000 square feet or other local serving essential services (e.g., local parks, day care centers, public schools, medical/dental office buildings, etc.) are presumed to have a less than significant impact absent substantial evidence to the contrary. The Project is not intending to develop any local serving retail or essential services.

In addition, the City Guidelines indicate that projects generating fewer than 110 daily vehicle trips may be presumed to have a less than significant impact, subject to discretionary approval by the City. Trips generated by the Project’s proposed land uses have been estimated based on trip generation rates collected by the Institute of Transportation Engineers ( ITE) Trip Generation Manual, 10th Edition, 2017 (3). The proposed Project is anticipated to generate vehicle trip-ends per day above the 110 daily vehicle trip threshold.

The Project Type screening threshold is not met.

Based on a more detailed review of the applicable VMT screening methods, it was determined that the Project is not eligible for screening and VMT analysis should be performed.

VMT ANALYSIS

VMT MODELING
City Guidelines i dentifies RIVCOM as the appropriate tool for conducting VMT analysis for land development projects in the City of Riverside. WRCOG is the developer/owner of RIVCOM and recently launched the new modeling tool for use by its member agencies in August 2021. At the time this analysis

3 City Guidelines; Page 24
Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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was prepared , the RIVCOM tool was in its 4 th update (also referred to as version 3.0). It has been determined that this analysis would be prepared based on version 3.0 of RIVCOM.

VMT METRIC AND SIGNIFICANCE THRESHOLD
The City Guidelines state for residential land use projects in the City of Riverside shall use the VMT metric of VMT per capita as the appropriate measure in a VMT analysis. The City Guidelines have identified following recommended threshold:
• For residential projects: the baseline or cumulative project -generated VMT per capita exceeds 15% below the current jurisdictional baseline VMT per capita As the RIVCOM model is a new travel demand model, at the time of this report WRCOG has not yet published jurisdictional averages for its member agencies. To establish the City of Riverside’s baseline VMT per capita “no project” model runs will be performed and calculated utilizing RIVCOM to provide a consistent comparison. All TAZs located within the City of Riverside were selected and the total home - based (HB) VMT was calculated from the RIVCOM base year (2018) and cumulative year (2045) traffic models. To obtain baseline (2022) conditions a straight- line interpolation calculation of the base year and cumulative year model result s were performed. For ease of comparison, the total HB VMT for the City of Riverside was then divided by the City’s employme nt. Citywide VMT per capita for base year, cumulative year, and baseline 2022 traffic conditions are shown in Table 1.

TABLE 1: CITY OF RIVERSIDE VMT PER CAPITA
Base Year (2018) Cumulative Year (2045) Baseline (2022) City of Riverside VMT 5,276,844 6,497,620 5,457,699
Population 324,025 404,739 335,983
HB VMT per Capita 16.29 16.05 16.25
Based on the RIVCOM results the City of Riverside’s jurisdictional baseline average is 16.25 VMT per capita.

PROJECT LAND USE CONVERSION
In order to evaluate Project VMT, standard land use information must first be converted into a RIVCOM compatible input data. The RIVCOM model utilizes socio -economic data (SED) (e.g., population, households, employment, etc.) instead of land use information for the purposes of vehicle trip estimation. Project land use information such as building square footage must first be converted to SED for input into RIVCOM. Utilization of population factors were derived from the City of Riverside Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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Circulation Element Traffic Study and Traffic Study Appendix .4 Table 2 presents the estimated number of Project employees by land use type used to populate the RIVCOM model.

TABLE 2: EMPLOYMENT ESTIMATES
Land Use Dwelling Units Conversion Factor Estimated Population Residential 53 DU 3.18 Persons per Household 169 People The RIVCOM model was then run inclusive of the Project’s SED inputs.

PROJECT GENERATED VMT PER CAPITA CALCULATION
The City Guidelines identify that for residential land uses the measure of VMT should be VMT per capita.

RIVCOM was utilized to calculate project generated VMT for the residential land uses and that value was then divided by the Project’s population estimate to derive project generated VMT per capita. Project- generated VMT per capita was then calculated for both the base year model (2018) and cumulative year model (2045). Then straight-line linear interpolation was used to determine the Project’s baseline (2022) VMT per capita. Table 3 presents HB VMT as calculated from RIVCOM for the Project’s residential land uses, the number of Project population, and Project VMT per capita.

TABLE 3: PROJECT GENERATED VMT PER CAPITA
Base Year (2018) Cumulative Year (2045) Baseline (2022) Project VMT 2,989 2,908 2,977
Project Population 169 169 169
HB VMT per Capita 17.68 17.21 17.61

PROJECT COMPARISON TO SIGNIFICANCE THRESHOLD
Table 4 illustrates the comparison between Project generated VMT per capita in the Baseline and Cumulative Conditions to the baseline City of Riverside jurisdictional average, as previously noted, of

16.25 VMT per capita , a 15% below the jurisdictional average is 13.81 VMT per capita. As shown, the Project would exceed the City’s threshold for either the Baseline or Cumulative Project conditions . The Project VMT impact is therefore considered potentially significant.

TABLE 4: PROJECT VMT PER CAPITA COMPARISON
Baseline Cumulative
City of Riverside 13.81 13.81
Project 17.61 17.21
Percent Change +27.52% +24.62%
Potentially Significant? Yes Yes

4 City Appendix, Page 185.

Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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PROJECT’S CUMULATIVE EFFECT ON VMT
The Technical Advisory notes that “… metrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency-based threshold that is aligned with long-term goals and relevant plans has no cumulative impact distinct from the project impact.” Accordingly, City Guidelines s tate “…cumulative no project shall reflect the adopted RTP/SCS; as such, if a project is consistent with the regional RTP/SCS, the cumulative impacts shall be considered less than significant subject to consideration of other substantial evidence.” 5 Since the Project proposed
land use of residential is consistent with the City of Riverside’s General Plan and the project level VMT per capita was found to be potentially significant. Resulting in the Project’s cumulative VMT impact is also to be considered potentially significant.

VMT REDUCTION STRATEGIES
Transportation Demand Management (TDM) strategies in the form of commute trip reduction program measures have been reviewed for the purpose of reducing Project related VMT impacts (i.e., commute trips) determined to be potentially significant. The level of effectiveness of each trip reduction measure has been determined based on the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA, 2021) (2021 Handbook).

City Guidelines state that “for any VMT mitigation measure, the project applicant will be required to provide substantial evidence while identifying a project-specific value. If that information is not available, the project should apply the low point of provided ranges for VMT reduction.” 6 In addition to specific tenancy considerations, locational context is also a major factor relevant to the potential application and effectiveness of TDM measures. The three locational contexts identified by the 2021 Handbook are suburban, urban, and rural.7 The locational context of the Project is characteristically suburban.

The proposed Project would require a minimum reduction of 27.52% to achieve a less than significant impact. The 2021 Handbook lists the following VMT reduction measures. These measures can be implemented individually or grouped together to create feasible VMT reductions. Based on consultation with the Project applicant the following TDM measures will be evaluated further.

MEASURE 1: T-18. PROVIDE PEDESTRIAN NETWORK IMPROVEMENT As noted in the 2021 Handbook, this measure will increase the sidewalk coverage to improve pedestrian access. Providing sidewalks and an enhanced pedestrian network encourages people to walk instead of drive. This mode shift results in a reduction in VMT and GHG emissions . The GHG reduction of this measure is based on the VMT reduction associated with expansion of sidewalk coverage expansion, which includes not only building of new sidewalks but also improving degraded or substandard sidewalk

5 City Guidelines; Page 28
6 City Guidelines; Page 32
7 2021 Handbook; Page 43
Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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(e.g., damaged from street tree roots).

TABLE 5: VMT CALCULATION VARIABLES

𝐴𝐴 = (𝐶𝐶
𝐵𝐵 − 1) × 𝐷𝐷

2.2% = � 0

1.44 − 1� × −0.05
The Project intends to develop external sidewalk connectivity along Ferrari Drive on the northern boundary of the Project, east along Dauchy Road, and south on Victor Hugo leading into the Project site. The total external sidewalks along Ferrari Drive, Dauchy Road, and Victor Hugo are calculated to be 2,697.94 feet. The Project’s internal private sidewalks have a combined total of 4,899.18 feet. The Project will develop a total of 7,597.12 feet or 1.44 miles. As calculated the Project’s inclusion of TDM measure 1 will reduce the Project’s VMT impact by 2.2%.

With the inclusion of feasible mitigation measure as calculated reduces the Project’s VMT impact to

17.22 VMT per capita in the baseline condition and 16.83 VMT per capita in the cumulative condition.

Thus, resulting in the Project still exceeding the City’s impact threshold by 24.69% in the baseline condition and 21.87% in the cumulative condition.

INTERIM VMT MITIGATION FEE
The City of Riverside is in the process of developing its VMT Mitigation Fee program. It is our understanding that fees (from an established list of projects) need to be collected to fund the Nexus Study to develop the VMT Mitigation F ee program. Once the VMT Nexus Study and fee program are developed, they will be presented to the City Council for final approval and implementation. This process could take approximately 12 months or more. It is our understanding that the city has already collected the necessary fees for the VMT nexus study and development of the fee program is underway.

The Project is currently seeking entitlement with the City. In an effort to ensure the 53 dwelling unit project meets CEQA requirements and will not be required to develop an EIR . The Project and the City ID Variable Value Unit Source
A
Percent reduction in GHG emissions from
household vehicle travel in plan/community 0-6.4 % calculated B Existing sidewalk length in study area 1.44 miles user input C Sidewalk length in study area with measure 0 miles user input D
Elasticity of household VMT with respect to the
ratio of sidewalks-to-streets -0.05 unitless
Frank et al.
2011
Output
User Inputs
Constants, Assumptions, and Available Defaults
Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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has made an Interim VMT Mitigation Fee agreement, which has accepted by both parties. Details of this acceptance letter can be found in Attachment C. Under the terms and conditions of the City’s acceptance letter, the Project will fully mitigate its VMT impact. Therefore, the Project’s VMT impact is considered less than significant.

CONCLUSION
• The Project was evaluated consistent with the City Guidelines ’ available screening criteria. The Project did not meet any available screening.
• A VMT analysis was performed with the new Riverside County model (RIVCOM). Findings of the VMT analysis resulted in potential VMT impacts.
• The Project’s design features were incorporated i nto the project generated VMT. However, the Project remains with potential VMT impacts.
• Based on an accepted agreement between the Project Applicant and City Staff, an Interim VMT Mitigation Fee has been established. With the inclusion of the Interim VMT Mitigation fee, the Project is found to have a less than significant impact on VMT.

If you have any questions, please contact me directly at [email protected].

Respectfully submitted,

URBAN CROSSROADS, INC.

Alexander So
Senior Associate

Mr. Keith Gardner
Signature Realty Capital Corp
June 8, 2023

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REFERENCES

1. Office of Planning and Research. Technical Advisory on Evaluating Transportation Impacts in CEQA.

State of California : s.n., December 2018.

2. City of Riverside Public Works Department. Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment. City of Riverside : s.n., July 2020.

3. Institute of Transportation Engineers. Trip Generation Manual. 11th Edition. 2021.

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ATTACHMENT A:

PRELIMINARY SITE PLAN

13820-07 VMT

ATTACHMENT B:

WRCOG SCREENING TOOL

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ATTACHMENT C

APPLICANT OFFER LETTER & INTERIM VMT MITIGATION FEE ACCEPTANCE LETTER

90664063.4

Samuel C. Alhadeff
3 Better World Circle, Suite 100
Temecula, California 92590
[email protected]
Direct: 951.252.6152
February 27, 2023 File No. 52637.4

ARIZONA • CALIFORNIA • COLORADO • CONNECTICUT • DELAWARE • FLORIDA • GEORGIA • ILLINOIS • INDIANA • KANSAS • KENTUCKY • LOUISIANA MARYLAND • MASSACHUSETTS • MINNESOTA • MISSISSIPPI • MISSOURI • NEVADA • NEW JERSEY • NEW MEXICO • NEW YORK • NORTH CAROLINA OHIO • OREGON • PENNSYLVANIA • RHODE ISLAND • TENNESSEE • TEXAS • UTAH • VIRGINIA • WASHINGTON • WASHINGTON D.C. • WEST VIRGINIA

VIA E-MAIL

Mike Futrell, City Manager
City of Riverside
3900 Main Street
Riverside, CA 92522
E-Mail: [email protected]
Jennifer A. Lilley, AICP
Community and Economic Development Director
City of Riverside
3900 Main Street
Riverside, CA 92522
E-Mail: [email protected]
Re: Dauchy Street Project - TR 38074

Dear Mr. Futrell and Ms. Lilley:

Congratulations to each of you on coming aboard at the City of Riverside. I am sure you will enjoy working with the City as it is a great place to live, grow and prosper.

We represent the applicant for the above-referenced project, who needs your assistance to complete its tentative tract map process. For about three years now, this small developer has worked on trying to get his project through the City. At present, we have been through eight plan checks and cannot proceed any further because, quite frankly, the lack of a City VMT policy.

The City is working toward establishing a VMT policy but in the interim, projects have been held up. On November 30, 2022, I sent a letter that was hand-delivered to the City explaining our concern about this lack of policy, and proposing an interim alternate solution pending the City’s adoption of a formal VMT policy (Mitigation Bank) (please see letter and proposal attached to this letter as Exhibit 1). That interim solution is in the form of a condition of approval, which we believe provides the necessary protections to the City, the project and homeowners. Please understand that our client has always been willing to provide funds to the City for its work on a formal VMT policy.

Let me give you just a brief overview of the project. The project consists of only 53 lots with an average lot size is 7,581 sq. ft. with three lots in the RC zone that average 27,958 sq. ft. We do not need a General Plan Amendment or zoning change or any other “amendments” to process this project. The project is located in the Alessandro Heights area at the corner of Dauchy and Ferrari.

The City’s housing element provides some additional information that is helpful to you. That housing element at Section 3.12 Transportation outlines some suggested processes and procedures. Unfortunately to date, funds apparently have not been raised to do the VMT policy

Mike Futrell
Jennifer Lilley
February 27, 2023

Page 2 ends

90664063.4

LEWIS BRISBOIS BISGAARD & SMITH LLP
www.lewisbrisbois.com

although in the documentation the City identifies approximately $61,000,000 in transportation needs.

We are only aware of one city that has recently adopted a VMT policy, the City of Lancaster, but the County of Riverside is working on the same issue and has accepted interim solutions very similar to what we have proposed in this letter. We have also reviewed the City’s July 2020 Draft Traffic Impact Analysis Guidelines, a copy of which is attached to this letter as Exhibit 2. There have been some projects that have been let through without having to go through this VMT process, and we don’t understand how that occurred except there must have been some dates that they met and were allowed to proceed.

Our client has been through eight plan checks and has submitted all documentation that was required of it to proceed with the project, but the project is in limbo because the City lacks a final VMT policy. We don’t know why the City has not accepted our interim solution (Exhibit 1), but we have another suggestion. We propose that the City move forward and process the project with the interim solution set forth in Exhibit 1, with the additional requirement that our client fund up to $100,000 of the City’s costs to research and create a formal VMT policy. That $100,000 would be credited toward the VMT requirements ultimately imposed on the project by the City.

We also understand that the City may have completed a Nexus report apparently costing approximately $300,000 or is in the process of being completed. The $100,000 that we suggest may assist in the funding of that report.

Our client has suggested a couple of observations that are also interesting in that there are “VMT policies laid out” but it is the Mitigation policies that appear to be missing. In other words, we need a Mitigation Bank to which developers can contribute. That Mitigation Bank, we hope, will be created as a result of the report and our suggested assistance in the funding of that report but in the interim we need to work out a policy that can be a bridge to the formal Mitigation policy. This is the reason we have suggested a number of alternatives. It is critical for us now to move our project along.

I understand from our client that with the exception of “minor cleanup issues,” Engineering and Planning may be close to signing off the project.

We have now made a second proposal. Requiring anything more burdensome for this 53- unit project would be financially impossible. The City staff has been very professional in working with us but as they have stated, there is no policy. In these difficult economic times, the housing industry needs help. The cities need more housing. We are certain that if we could meet and work together, we could come up with a solution that may be a compromise and a bridge toward the ultimate policy.

I just want to stress again in these uncertain economic times, it is crucial that applicants and agencies work together to find reasonable compromises. Please give this letter your consideration and let us know if we can meet or conference with you or staff member you select in early March to discuss how to resolve this question and build a bridge for a compromise.

Mike Futrell
Jennifer Lilley
February 27, 2023

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90664063.4

LEWIS BRISBOIS BISGAARD & SMITH LLP
www.lewisbrisbois.com

Thank you so much for your anticipated courtesy and cooperation.

Sincerely,

Samuel C. Alhadeff of

LEWIS BRISBOIS BISGAARD & SMITH LLP

SCA:ch
Attachments as noted

Exhibit “1”

4869-0672-7489.1

Samuel C. Alhadeff
3 Better World Circle, Suite 100
Temecula, California 92590
[email protected]
Direct: 951.252.6152
November 30, 2022 File No. 52673.4

VIA ELECTRONIC MAIL

Alyssa Wiedeman, Associate Planner
City of Riverside Planning Division
3900 Main Street - 3rd Floor
Riverside, CA 92522
E-Mail: [email protected]
Judy Eguez
City of Riverside Planning Division
3900 Main Street - 3rd Floor
Riverside, CA 92522
E-Mail: [email protected]
Re: Dauchy Street Project - City of Riverside TR 38074

Dear Ms. Wiedeman and Ms. Eguez:

We represent the applicant for this project, and understand that there has been some challenge in trying to work through a VMT Condition of Approval since there is no formal mitigation as yet set up by the City. We worked through these issues in other cities and with the County of Riverside, and I am proposing the condition of approval language that is included with this letter which I believe meets all the requirements that are necessary to protect the City of Riverside, the project and any homeowners. I appreciate your consideration and would like to get this done as quickly as possible. I understand that our client has worked diligently with the City and really is at a point now that we need to complete this.

Please feel free to call me if you have any questions.

Very truly yours,

Samuel C. Alhadeff of

LEWIS BRISBOIS BISGAARD & SMITH LLP

SCA:ch
Attachment

cc: Alan Cohen
Keith Gardner

4868-7657-3760.1

Samuel C. Alhadeff
3 Better World Circle, Suite 100
Temecula, California 92590
[email protected]
Direct: 951.252.6152

City of Riverside
TR 38074

PROPOSED CONDITION OF APPROVAL

Alternate 1

The applicant shall p ay the applicable fee pursuant to the City’s VMT mitigation bank fee program, if available, for each dwelling unit prior to issuance of grading permit.

If a VMT mitigation bank fee program has not yet been adopted by the City when the grading permit is requested, t he applicant shall in the interim pay an estimated fair share contribution to mitigate VMT impacts of $2,500 per dwelling unit (“Interim VMT Mitigation Fee”) prior to issuance of the grading permit. This amount may be used by the City for establishing a formal VMT mitigation bank fee program or such other uses as required for developing a citywide nexus study for that program. The City shall apply the applicant's payment of the Interim VMT Mitigation Fees as a pro-rata credit towards the fees required by any future VMT mitigation bank fee program adopted by the City.

In the event that after the applicant has paid the Interim VMT Mitigation Fee s, the City subsequently adopts a VMT mitigation bank fee program prior to the recordation of the final map for the project , (i) the project shall be annexed into the VMT fee program, (ii) the applicable per unit fee from the VMT fee program shall supersede and be used instead of the Interim VMT Mitigation Fee, and the Interim VMT Mitigation Fees paid by the applicant shall be applied as a pro-rata credit towards the fees required by the VMT fee program, and (iii) the applicant hereby waives any objection to the fees required by the VMT fee program and agrees to pay its pro-rata fair share contribution based upon such program.

Exhibit “2”
DRAFT Traffic Impact Analysis Guidelines
for Vehicle Miles Traveled and Level of
Service Assessment

ALL SUBMITTALS AND INQUIRIES PERTAINING TO THIS DOCUMENT MA Y BE DIRECTED

TO THE CITY OF RIVERSIDE TRAFFIC ENGINEERING DIVISION
PWtraffic @riversideca.gov
951-826-5366
Kris Martinez
Public Works Director
3900 Main Street, Riverside, CA 92522 I Phone: (951) 826-53661 RiversideCA.gov July 2020
Cit) ••I :!rt., &_ l nno1·a110n
Public Works Department

2. For office projects: the baseline or cumulative link-level boundary VMT per employee (City) to increase under the plus project condition compared to the no project condition.

3. For retail & other land use projects: the baseline or cumulative link-level boundary VMT (City) to increase under the plus project condition compared to the no project con dition.

Please note that the cumulative no project shall reflect the adopted RTP /SCS; as such, if a project is consistent with the regional RTP /SCS, then the cumulative impa cts shall be conside red less than significant subject to conside ration of other substantial evidence.

Vt0I_0itigation Meas~_re_s ___ .

To mitigate VMT impacts, the following choices are available to the applicant:
l . Modify the project's built environmen t chara cteri stics to reduce VMT generated by the project

2. Implemen t transportation Demand Management (TDM) measures to redu ce VMT generated by the project.

3. Participate in a VMT fee program and/or VMT mitigation exchange/bank ing program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels
Key TDM measures that are appropriate to the region have been identified as part of a WRCOG study and can be accessed at the following location , h ttps://www. fehrand peers .com/wp -con tent /uploads/20 l 9 /03/ TDM-Strat egies Evalua tion. pd f
Measures appropriate for most of the WRCOG regi on are summarized in Attachment B of the TDM Strategies Evaluation Memorandum. Given the City of Riverside's position as the urban core of the County, it may be appropriate to use mitigati on outside of the rural/suburban context mitigat ions identified by WRCOG. Evaluation of VMT reducti ons should be evaluated using state -of-the-practice methodologies recognizing that many of the TDM strategies are dependent on building tenan t performan ce over time. As such, actual VMT reduct ion canno t be reliably predicted and monitoring may be necessary to gauge performance related to mitigation expectations.
28 3900 Main Street, Riverside , CA 92522 I Phone: (951) 826- 53661 RiversideCA.gov

3900 Main Street, Riverside, CA 92522 | Phone: (951) 826-5366 | Fax: (951) 826-2570 | RiversideCA.gov

PUBLIC WORKS

DEPARTMENT
Traffic Engineering

April 27, 2023

LEWIS BRISBOIS BISGAARD & SMITH LLP
c/o Mr. Samuel C. Alhadeff
3 Better World Circle, Suite 100
Temecula, California 92590

SUBJECT: Response to Dauchy Street Vehicle Miles Traveled Proposed Mitigation Option Letter dated February 28, 2022

Dear Mr. Samuel Alhadeff:

The City of Riverside has received the letter and attachments regarding the Dauchy Street Project (TR 38074) dated February 27, 2023.

The City has collaborated with the applicant and the applicant’s hired traffic engineering consulting firm (Urban Crossroads, Inc.) over several meetings, discussions, and email correspondence regarding the proposed fifty-three (53) single-family detached residential (SFDR) dwelling unit development and associated Vehicle Miles Traveled (VMT) transportation impacts.

We appreciate the proposal within your February 27
th letter that the “applicant shall in the
interim pay an estimated fair share contribution to mitigate VMT impacts of $2,500 per dwelling unit (‘Interim VMT Mitigation Fee’) prior to issuance of the grading permit.”

The City has compared this proposed offer with other local jurisdictions’ VMT mitigation impact fees and conducted a preliminary review of what fees may be in place upon establishment of the City’s VMT Mitigation Bank, Fees & Exchanges Program.

The City has deemed the Interim VMT Mitigation Impact Fee payment of $2,500 per dwelling unit likely to be accurate, and based on that estimated accuracy, and lack of current practical alternatives, the City can accept this proposal.

The offer of $2,500 per dwelling unit fee for the proposed 53 SFDR dwelling units results in a total amount of $132,500. The full amount of $132,500 would be conditioned as due prior to the issuance of site grading permits.

The advance payment will be retained until the City establishes and adopts a VMT Mitigation Impact Fee for residential developments. If the interim advanced payment is higher than the adopted VMT Mitigation Impact Fee for residential developments, then the City will

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reimburse the applicant for the difference in the payment. Conversely, the City will reserve the right to adjust the applicant’s VMT Mitigation Impact Fee prior to issuance of the site’s certificate of occupancy in response to any findings of an adopted VMT Mitigation Program.

The City’s VMT Mitigation Bank, Fees & Exchanges Program is scheduled to begin in May 2023 and is anticipated to be completed in 2024.

The City looks forward to collaborating with the applicant to establish a condition of approval that addresses the VMT transportation impacts and advances the proposed Dauchy Street Project (TR 38074).

Sincerely,

Nathan Mustafa,
Deputy Public Works Director

Attachment: Letter to City of Riverside Re: Dauchy Street Project – TR 38074 (dated 2/27/23)

Distribution:

Mike Futrell, City Manager
Kris Martinez, Assistant City Manager
Rafael Guzman, Assistant City Manager
Jennifer Lilley, Director of Community & Economic Development Gilbert Hernandez, Director of Public Works Department
Nathan Mustafa, Deputy Public Works Director
Maribeth Tinio, City Planner
Philip Nitollama, City Traffic Engineer
Chris Scully, Engineering / Land Development Manager
Anthony Beumon, Senior Deputy City Attorney
Brian Norton, Senior Planner
Vital Patel, Assistant Engineer
Alyssa Wiederman (Berlino), Associate Planner

CARLSON STRATEGIC LAND SOLUTIONS, INC.

Carlson Strategic Land Solutions | 27134A Paseo Espada, Suite 323, San Juan Capistrano, California 92675 Memorandum
Date: June 15, 2023
To: Al Cohen, Signature Realty Capital Corp
From: Brianna Bernard, Carlson Strategic Land Solutions Subject: Jurisdictional Delineation the Dauchy Project Site located in the City of Riverside

Carlson Strategic Land Solutions ( CSLS) prepared this Jurisdictional Delineation for Signature Realty Capital Corp for the Dauchy Road Project Site and adjacent right -of- way (Project Site) located in the City of Riverside. The Project site is comprised of 24.73-acres and adjacent right of way , consisting of Ferrari Drive, Dauchy Avenue, and proposed Victor Hugo Drive . The jurisdictional assessment for the Project Site and the surrounding 300 -feet, collectively known as the “Study Area,” incorporates the findings from a field survey and jurisdictional delineation conducted on January 20, 2021.

1.0 Project Location
The Study Area is located in the City of Riverside, west of Dauchy Avenue, and south of Ferrari Drive (Figures 1 and 2). Areas surrounding the Study Area include rural residences to the north and south, residential development and Dauchy Avenue to the east, and Prenda Arroyo to the west (Figure 2). The Study Area is located within the United States Geological Survey (USGS)

7.5-Minute Topographic Map Riverside East Quadrangle. The Assessor’s Parcel Numbers are 276-040-011, 276-040-012, 276-050-029, and Right-of-Ways.

Access to the Project Site is from Dauchy Avenue or Ferrari Drive.

2.0 Project Description and Existing Conditions
The Project proposes to construct 53 residential homes, open space, common space amenities, and associated infrastructure . The Project site is characterized as rolling hilltops at approximately 1,500 feet elevation primarily dominated by disturbed/non -native grassland, Riversidean sage scrub and a blue -line drainage located within and adjacent to the southwestern Project site boundary.

Riverside City CouncilNovember 7, 2023

Riverside City Council
November 7, 2023