Cities Index.
Attachment 3l - Public Comment Letters

Riverside City Council
August 20, 2024

Document
Attachment 3l - Public Comment Letters
Meeting
August 20, 2024
Body
Riverside City Council
Pages
4
Original file
9.7 MB
Text extracted from the city's file for reading and search. Open the original on riversideca.legistar1.com. That file is the official record.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
Riverside Ca 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:21 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 6.2

Significant and Unavoidable Adverse Impacts - VMT: VMT mitigation measures and strategies aim to promote overall mobility with the goal of reducing VMT and GHG emissions. Implementation of the project design features and TDM measures outlined in Section 5.17 Transportation, may possibly reduce the proposed Project’s VMT by approximately up to 17.7 percent. These TDM measures may help offset some of the VMT impacts of the proposed Project by up to 17.7 percent but will not reduce the impact to a less than significant level. Therefore, the proposed Project would have significant and unavoidable impacts related to transportation.

• Significant and unavoidable impacts related to transportation. Lets create a project that will serve the community and provide enhancements.
• Given that the proposed TDM measures can only reduce VMT by up to 17.7 percent and will not bring the impact to a less than significant level, what additional or alternative strategies have you considered to further mitigate VMT and GHG emissions? • Can you provide a detailed explanation of the specific TDM measures outlined in Section

5.17 Transportation, and how each measure contributes to the overall reduction in VMT? • What are the potential long-term impacts on the community if the significant and unavoidable transportation impacts are not fully mitigated, and how do you plan to address these impacts?
• Have you explored any partnerships with local transit agencies, businesses, or community organizations to develop more comprehensive solutions for reducing VMT and enhancing overall mobility?
• Can you provide examples of similar projects where significant and unavoidable transportation impacts were successfully managed or mitigated, and what lessons from those projects will be applied to ensure the success of this development?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters

Norman Cole
166 Acacia Glen Dr
Riverside ca 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:20 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 5.17.5

Parking - Unbundle Residential Parking Costs from Property Cost. According to CAPCOA, increasing the cost of owning a vehicle will decrease or discourage vehicle ownership and therefore reduce VMT and GHG. CAPCOA transportation Measure T-16, Unbundle Residential Parking Costs from Property Cost, was used to estimate the amount of VMT reduction that can be achieved by charging for additional parking stalls. The Project proposes to provide 1 parking stall to every apartment unit within the rental unit fee (no additional charge) and charge $75 per month for any and each additional parking spaces, which may reduce Project VMT by up to 3.9%.

• This section appears to be in violation of AB 1317 signed into law in 2023 and effective in January 2025 with any new certificate of occupancy, requires that all parking be unbundled and charged for separately. With this project being in the middle of a shopping center, not providing enough parking for the number of units, and the tenants being able to opt out of paying for parking since the shopping center parking is free, creates numerous issues for the retail establishments and their customers. This is especially true since occupancy standards allow for up to 6 people in a one bedroom. None of this has been addressed in this report.
• How do you plan to comply with AB 1317, which requires all parking to be unbundled and charged for separately starting in January 2025, given that your current proposal includes one parking stall per apartment unit within the rental fee? • What specific measures will be implemented to prevent tenants from opting out of paying for parking and instead using the free parking available in the shopping center, potentially causing parking shortages for retail customers?
• Can you provide a detailed analysis of the potential impacts on retail establishments and their customers if tenants use the shopping center parking, including any mitigation strategies to address these issues?
• How do you plan to address the potential for high occupancy rates (up to 6 people in a one-bedroom unit) and the resulting increased demand for parking, which may exceed the provided parking capacity?
• Have you conducted any studies or assessments to evaluate the effectiveness of unbundling residential parking costs in reducing VMT and GHG emissions, and how do these findings support the proposed parking strategy for this project?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:18 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 5.17.5

Environmental Impacts - Threshold B: Would the Project conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)?The City’s guidelines provide guidance regarding VMT analysis based on land use types.10. Implement Subsidized or Discounted Transit Program (TRT-4).In conclusion, while the previously discussed TDM measures may help offset some of the VMT impacts of the proposed Project by up to 17.7 percent, these measures would not reduce the Project-generated VMT impact to a less than significant level.

• The VMT impact cannot be mitigated.
• Given that the proposed TDM measures are insufficient to reduce the Project-generated VMT impact to a less than significant level, what additional innovative strategies or technologies have you considered to further mitigate VMT impacts? • Can you provide a detailed analysis of how the 17.7 percent reduction in VMT was calculated, and what specific assumptions were made in this calculation? • Have you explored partnerships with local transit agencies or ride-sharing companies to develop more robust transit solutions that could potentially reduce VMT beyond the current projections?
• What specific measures will be implemented to monitor and evaluate the effectiveness of the proposed TDM strategies over time, and how will these findings be used to adjust and improve VMT reduction efforts?
• Given that the VMT impact cannot be fully mitigated, how do you plan to address potential community concerns about increased traffic congestion and related environmental impacts, particularly in the context of the project's consistency with local and regional transportation plans?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters 166 Acacia Glen Dr.

Riverside, CA 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:12 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 5.9.6 March Air Reserve Base/United States Air Force Input -On July 31, 2023, the Air Force provided comments supporting ALUC’s recommendation of inconsistency due to concerns with the project’s inconsistent density. • MARB does not support this project. • Given that the proposed density of 35 du/ac significantly exceeds both the ALUC maximum of 6 du/ac for Zone C2 and the area's historical maximum of 16 du/ac, what specific justifications can you provide for proposing such a dramatic increase in density? • Have you conducted any studies or analyses to assess the potential impacts of this substantial density increase on local infrastructure, traffic patterns, and community services? • How do you plan to address potential safety concerns related to the project's non-compliance with ALUC density requirements, particularly given its proximity to March Air Reserve Base? • Can you provide examples of similar successful projects that have received approval for such significant deviations from ALUC requirements, and explain how those precedents might apply to this case? • What specific mitigation measures or design features are you proposing to offset the potential negative impacts of exceeding the ALUC density requirements by such a large margin? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:11 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 5.9.6 Riverside County ALUC Consistency with MARB/IPA Analysis and Findings - The Project’s proposed residential density of 35.0 du/ac exceeds the maximum allowable residential density for Zone C2 of 6.0 du/ac. • Nothing supports a project this far removed from the ALUC requirements. 35 units compared to 6 units is not even close. Why was this even proposed? The area has never exceeded 16 du/ac. • Given that the proposed density of 35 du/ac significantly exceeds both the ALUC maximum of 6 du/ac for Zone C2 and the area's historical maximum of 16 du/ac, what specific justifications can you provide for proposing such a dramatic increase in density? • Have you conducted any studies or analyses to assess the potential impacts of this substantial density increase on local infrastructure, traffic patterns, and community services? • How do you plan to address potential safety concerns related to the project's non-compliance with ALUC density requirements, particularly given its proximity to March Air Reserve Base? • Can you provide examples of similar successful projects that have received approval for such significant deviations from ALUC requirements, and explain how those precedents might apply to this case? • What specific mitigation measures or design features are you proposing to offset the potential negative impacts of exceeding the ALUC density requirements by such a large margin? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters 166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:10 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.3.2 The proposed Project includes a Zoning Code Amendment (RZ) to change the existing zoning of the project site from CR-SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones to MU-U-SP – Mixed Use-Urban and Specific Plan (Mission Grove) Overlay Zones. • All these zoning requirements have been in place for a reason, so the community thrives and attracts new residents with a carefully designed structure and purpose that promotes safety, security and a quality of life. All these necessary changes shows no support for improving the community. • Can you provide specific evidence or studies that demonstrate how the proposed Zoning Code Amendment from Commercial Retail to Mixed Use-Urban will enhance the safety, security, and quality of life for current and future residents of the community? • What measures will be taken to ensure that the proposed zoning changes do not negatively impact the existing community structure and purpose that have been carefully designed to promote thriving neighborhoods? • How does the proposed project plan to address potential concerns from residents regarding the integration of high-density residential units into an area currently zoned for commercial retail, particularly in terms of maintaining community cohesion and character? • Can you provide detailed plans or examples of similar projects where a transition from Commercial Retail to Mixed Use-Urban zoning has successfully improved the community, and what lessons from those projects will be applied here? • What specific benefits does the proposed Zoning Code Amendment offer to the existing community, and how do these benefits outweigh the potential negative impacts identified in the EIR, particularly in terms of traffic, parking, and overall community integration? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:09 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.3.1 The proposed Project includes a General Plan Amendment (GPA) to change the existing General Plan Land Use Designation of the project site from C - Commercial to MU-U - Mixed Use-Urban, to allow residential land use. • This is not an urban area and the proposed project is not Mixed Use. • Can you provide specific examples or case studies where similar suburban areas have successfully transitioned to Mixed Use-Urban designations, and how those transitions impacted the local community and environment? • What specific elements of the proposed project will ensure that it meets the criteria for Mixed Use-Urban zoning, particularly in terms of integrating residential and commercial uses in a way that benefits the community? • How does the proposed project plan to address potential increases in traffic and parking demands, given that the area is not currently designed to support high- density residential use? • Can you provide detailed plans or designs that demonstrate how the proposed project will integrate residential and commercial elements to create a true mixed-use environment, rather than just a high-density residential project? • What specific benefits does the proposed General Plan Amendment and zoning change offer to the existing community, and how do these benefits outweigh the potential negative impacts identified in the EIR? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters 166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:08 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.2.2 The site is bordered on the north, west, and east (across Mission Grove Parkway) by the Mission Grove Plaza Shopping Center, which has a General Plan Land Use Designation of C - Commercial and is zoned CR-SP - Commercial Retail and Specific Plan (Mission Grove) Overlay Zones, and is developed with retail uses. Multi-family residences are located further north (across Alessandro Boulevard), which have a General Plan Land Use Designation of HDR – High-Density Residential, and are zoned R-3-3000-SP – Multi-Family Residential and Specific Plan (Mission Grove) Overlay Zones. The project site is bordered on the south by a single-family residential neighborhood (across Mission Village Drive), which has a General Plan Land Use Designation of Medium High Density Residential (MHDR) and is zoned R-1-7000-SP – Single-Family Residential and Specific Plan (Mission Grove) Overlay Zones. • No market studies, supply and demand analysis or other data has been provided to support a High Density residential property being dropped into a retail shopping center in a suburban neighborhood with nothing nearby even close to the density levels being proposed is going to improve the area. Not to mention the impacts of traffic and parking. • Can you provide detailed market studies and supply/demand analyses that specifically justify the need for high-density residential development within this existing retail-focused area? • How do you plan to mitigate the potential impacts on traffic and parking, given that the proposed high-density residential project will be situated in a primarily retail and lower-density residential area? • What specific measures will be implemented to ensure a smooth transition between the proposed high-density development and the surrounding lower-density residential and commercial areas? • Have you conducted any community impact assessments to determine how the introduction of a high-density residential property might affect the character and functionality of the existing suburban neighborhood? • Given the significant difference in density between the proposed project and the surrounding areas, what specific benefits do you anticipate this development will bring to the existing community that outweigh potential negative impacts? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:07 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.2.3 The site is bordered on the north, west, and east (across Mission Grove Parkway) by the Mission Grove Plaza Shopping Center, which has a General Plan Land Use Designation of C - Commercial and is zoned CR-SP - Commercial Retail and Specific Plan (Mission Grove) Overlay Zones, and is developed with retail uses. Multi-family residences are located further north (across Alessandro Boulevard), which have a General Plan Land Use Designation of HDR – High-Density Residential, and are zoned R-3-3000-SP – Multi-Family Residential and Specific Plan (Mission Grove) Overlay Zones. The project site is bordered on the south by a single-family residential neighborhood (across Mission Village Drive), which has a General Plan Land Use Designation of Medium High Density Residential (MHDR) and is zoned R-1-7000-SP – Single-Family Residential and Specific Plan (Mission Grove) Overlay Zones. • No market studies, supply and demand analysis or other data has been provided to support a High Density residential property being dropped into a retail shopping center in a suburban neighborhood with nothing nearby even close to the density levels being proposed is going to improve the area. Not to mention the impacts of traffic and parking. • Can you provide detailed market studies and supply/demand analyses that specifically justify the need for high-density residential development within this existing retail-focused area? • How does the proposed high-density residential project align with the current suburban character of the neighborhood, and what measures will be taken to ensure a smooth transition between the different density levels? • Have you conducted a comprehensive traffic impact study that accounts for the increased population density and its effects on the existing retail-oriented traffic patterns in the area? • What specific plans do you have to address potential parking issues, given that the project will be situated within a retail shopping center that likely has its own parking demands? • How do you plan to integrate the high-density residential development with the existing retail environment to create a cohesive mixed-use area, rather than simply "dropping" a residential complex into a retail space? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:06 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 1.6 This type of EIR should focus primarily on the changes in the environment that would result from the development project. • The report should be unbiased and not show that it is promoting the project in any way. This EIR is a marketing report for the project emphasizing support for the project continually. • Can you provide specific examples of how the EIR maintains objectivity in its analysis, particularly in sections where potential negative impacts are discussed? • What measures were taken during the EIR preparation process to ensure an unbiased assessment of environmental impacts, rather than promoting the project? • How does the EIR balance the presentation of potential benefits and drawbacks of the project, and can you point to specific sections that demonstrate this balance? • Were any independent third-party reviewers involved in the EIR process to ensure objectivity, and if so, can you share their findings or recommendations? • Given the concern that the EIR appears to be promoting the project, what steps are you willing to take to address this perception and ensure a more neutral presentation of environmental impacts? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Drive
Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:06 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.2 The current land use of the project site is a vacant retail site. The General Plan designation for the project site is C - Commercial and it is currently zoned as CR-SP - Commercial Retail and Specific Plan (Mission Grove) Overlay Zones. The site is designated as Retail Business & Office within the Mission Grove Specific Plan. ● No supporting market data that indicates the Land Use, Zoning, General Plan and Specific Plan should be abandoned. ● Can you provide detailed market data and analysis that supports the need for changing the current land use, zoning, General Plan, and Specific Plan designations from Commercial to Mixed Use-Urban? ● What specific factors or trends in the local real estate market indicate that the current commercial designation is no longer viable or appropriate for the project site? ● How does the proposed change in land use and zoning align with the broader goals and objectives of the Mission Grove Specific Plan and the City of Riverside's General Plan? ● Have you conducted any feasibility studies or economic impact assessments to compare the potential benefits and drawbacks of maintaining the site as a commercial retail space versus redeveloping it for mixed-use or residential purposes? ● What community engagement or consultation processes have been undertaken to gather input from local residents and stakeholders regarding the proposed changes, and how have their concerns and suggestions been addressed in the project planning? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters 166 Acacia Glen Dr.

Riverside, Ca 92506
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:05 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.0 • General Plan Amendment (GPA) – to change the General Plan Land Use Designation from C - Commercial to MU-U - Mixed Use-Urban, to allow residential land use. • Zoning Code Amendment (RZ) – to change the zoning from CR-SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones to MU-U-SP – Mixed Use-Urban and Specific Plan (Mission Grove) Overlay Zones. • Specific Plan Amendment (SPA) – to revise the Mission Grove Specific Plan. • Tentative Parcel Map (TPM) 38598 – to subdivide the existing Parcel 1 of Parcel Map 26320 into two parcels for financing and conveyance purposes. • Design Review (DR) – for the proposed site design and building elevations. • Environmental Impact Report (EIR) – for the preparation of an Environmental Impact Report for the proposed Project. • Airport Land Use Commission (ALUC) – determination of consistency or inconsistency with applicable airport land use compatibility criteria of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IPA LUCP). ● These Actions are a drastic abandonment of the current requirements established years ago to protect the neighborhood and ensure community continuity. No data or research has been provided that shows viable reasons for discarding these effective requirements. The proposed project is for a high density apartment project , not a mixed use building. Mixed use requires 80% of the ground floor to be offered as Commerical, Retail or Office space.

This project does not match the zoning change. ● Can you provide detailed data or research that supports the need for changing the General Plan Land Use Designation from Commercial to Mixed Use- Urban, and how this change will benefit the community? ● How does the proposed high-density apartment project align with the requirements for mixed-use zoning, particularly the stipulation that 80% of the ground floor be dedicated to commercial, retail, or office space? ● What specific measures will be taken to ensure that the proposed project does not negatively impact the neighborhood's character and continuity, which were protected by the original zoning requirements? ● Have you conducted any studies or analyses to determine the potential impacts of the proposed zoning changes on local traffic, infrastructure, and public services, and if so, what were the findings? ● How does the proposed project address the compatibility criteria of the March Air Reserve Base/Inland Port Airport Land Use PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Compatibility Plan, and what steps will be taken to mitigate any identified inconsistencies? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:04 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 5.16.4 Project Design- Parks -The Zoning Code requires 150 square feet of common usable open space per unit for projects in the Mixed-Use – Urban Zone, for a total of 52,050 square feet of required open space. The applicant is proposing a Specific Plan Amendment to require 75 square feet of common usable open space per unit for the Mixed-Use – Urban designation, for a total of 26,025 square feet of required usable open space. The common open space provided totals 28,611 square feet or 0.66 acres. • Another concession, modify the Park size requirement in the Specific Plan to a much lower level from 52,050 SF down to 26,025 SF so the project qualifies. Where is all that support for high density residential housing when all the requirements must be changed. These requirements are there for a reason. • Can you provide a detailed justification for reducing the common usable open space requirement from 150 square feet per unit to 75 square feet per unit, and explain how this reduction aligns with the overall goals of promoting high-density residential housing while maintaining quality of life for residents? • What specific studies or data have you used to determine that 75 square feet of common usable open space per unit is sufficient for the well-being and recreational needs of the residents in this high-density development? • How do you plan to mitigate the potential negative impacts of reducing the open space requirement by nearly 50%, particularly in terms of resident health, community interaction, and overall livability of the development? • Can you provide examples of similar high-density residential projects where reduced open space requirements have been successfully implemented without compromising the quality of life for residents? • Given that these requirements are in place for specific reasons, what additional amenities or design features do you propose to compensate for the significant reduction in common usable open space, and how will these ensure that the project still meets the intent of the original requirements? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:03 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 5.14.6 Environmental Impacts before Mitigation - The General Plan 2025 was designed to accommodate anticipated growth by providing adequate services, access and infrastructure. (P. 491)Per the 6th Cycle Housing Element Technical Background Report, the City of Riverside had an estimated population of 328,155 in 2020. This represents a growth of 58,445 people from 2020 to 2040. • There is no evidence to support this statement. The City cannot and does not maintain the current infrastructure and provide adequate services. If the growth rate is estimated to be 3,000 per year from 2020 to 2040, then why the RHNA commitment for 20,000 housing units by 2029. • Can you provide detailed evidence and data to support the statement that the General Plan 2025 was designed to accommodate anticipated growth by providing adequate services, access, and infrastructure, particularly in light of current infrastructure and service challenges? • How do you reconcile the estimated annual growth rate of 3,000 people per year from 2020 to 2040 with the RHNA commitment for 20,000 housing units by 2029, and what specific strategies will be implemented to meet this housing target? • What measures are being taken to ensure that the existing infrastructure and services can be upgraded or expanded to support the projected population growth and the additional housing units required by the RHNA commitment? • Can you provide a comprehensive analysis of the current state of infrastructure and services in the City of Riverside, including any identified deficiencies, and how these will be addressed to support future growth? • How will the proposed project contribute to meeting the RHNA commitment, and what specific steps will be taken to ensure that the development aligns with the broader goals and requirements of the General Plan 2025 and the 6th Cycle Housing Element? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:02 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 5.14.6 Environmental Impacts before Mitigation - Threshold A: Would the Project 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) • Yes, the project could have as many as 6 people in a one bedroom, potentially doubling the projected occupancy of 839 to over 1600, the population implications have not considered this issue as it relates to the local community of Mission Grove with less than 8000 residents. It’s the unplanned population growth to the local community that has not been examined. • Can you provide a detailed analysis of the potential for unplanned population growth resulting from the project, including scenarios where occupancy rates exceed the projected numbers, such as having up to 6 people in a one-bedroom unit? • How do you plan to address the potential strain on local infrastructure, public services, and community resources if the actual population growth significantly exceeds the projections? • What measures will be implemented to monitor and manage the actual occupancy rates of the residential units to ensure they align with the projected numbers and do not lead to unplanned population growth? • Have you conducted any studies or assessments to evaluate the potential social and economic impacts of a substantial increase in population on the local community of Mission Grove, which currently has less than 8,000 residents? • Can you provide examples of similar projects where unplanned population growth was effectively managed, and what strategies from those projects will be applied to mitigate potential impacts in Mission Grove? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:01 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.3.5 Parking- The Project includes 604 parking spaces in total. Of these, 513 parking spaces will be dedicated for the Proposed apartment project, and 91 will be shared between the Proposed apartment project and the existing adjacent retail site. The shared parking will be memorialized in a new covenant and restriction agreement between the residential developer entity and Mission Grove Plaza. 58 spaces are Tandem. • Only 513 parking spaces within the project and 58 of those are tandem spaces. 91 shared spaces with the shopping center. There is no support for this many parking spaces.

The area is not conducive to people without auto transportation. The transit corridor is not reliable and not widely used. There is no support for this limited parking and the tenants can opt out of paying for parking and simply use the shopping center. This is has not been examined adequately. • Can you provide detailed data or studies that support the adequacy of 513 parking spaces for the proposed apartment project, including the 58 tandem spaces, given the area's reliance on auto transportation and the unreliability of the transit corridor? • How do you plan to enforce the covenant and restriction agreement to ensure that tenants do not opt out of paying for parking and instead use the shopping center's parking spaces, potentially causing parking shortages for retail customers? • What measures will be taken to address potential overflow parking issues, particularly during peak shopping hours, given that 91 parking spaces are shared between the residential project and the adjacent retail site? • Have you conducted any traffic and parking studies to assess the impact of the proposed parking arrangement on the surrounding area, and if so, what were the findings and recommendations? • Can you provide examples of similar mixed-use developments where a comparable parking strategy has been successfully implemented, and what lessons from those projects will be applied to ensure the success of this proposed parking plan? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 3:00 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.3.5 The proposed Project includes a total of 347 studio, one-, two-, and three-bedroom residential apartment units within five, 4-story buildings. The proposed Project is anticipated to house approximately 829 tenants. 56% -1 bdrm or less, 41%- 2 bdrm, 3%- 3 bdrm • This mix of unit sizes is not supported by market data. This is based on data long before Covid at it assumes people want to live in a shopping center and occupy a majority of 1 bedrooms. • Can you provide updated market data, including post-COVID trends, that supports the proposed mix of unit sizes (56% one- bedroom or less, 41% two-bedroom, and 3% three-bedroom) for the residential apartment units? • How did you determine the demand for one-bedroom units in a shopping center environment, and what evidence do you have that this demand remains strong in the current market? • Have you conducted any recent surveys or studies to understand the preferences of potential tenants regarding living in a mixed- use development within a shopping center, and if so, what were the findings? • What contingency plans do you have in place if the demand for one-bedroom units does not meet expectations, and how will you adapt the project to address potential vacancies? • Can you provide examples of similar mixed-use developments where a high percentage of one-bedroom units have been successful, and what lessons from those projects are being applied to ensure the success of this proposed project? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:59 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 3.2 Mission Grove Specific Plan - the project site is located within an area designated as Retail Business & Office and generally in the central portion of the Specific Plan. • No market data has been presented to support changing this area designation to Residential. • Can you provide comprehensive market data and analysis that justifies changing the area designation from Retail Business & Office to Residential, particularly considering the site's central location within the Specific Plan area? • How does the proposed residential development align with the original intent and goals of the Mission Grove Specific Plan, and what specific benefits will it bring to the area that the current Retail Business & Office designation does not? • Have you conducted any studies to assess the potential economic impact of removing retail and office space from this central location, and if so, what were the findings? • What measures do you propose to ensure that the loss of potential retail and office space in this area won't negatively impact local employment opportunities or the overall economic balance of the Mission Grove area? • Can you provide examples of similar successful conversions from Retail Business & Office to Residential in comparable specific plan areas, and what lessons from those projects can be applied to ensure the success of this proposed change? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed- use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters 166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:57 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 2.3 The City held a virtual EIR Public Scoping Meeting on November 2, 2022, from 6 PM to 7 PM. • No data has been provided on how this meeting was communicated and how many residents attended. • Can you provide detailed information on the methods used to communicate the virtual EIR Public Scoping Meeting to the community, including the platforms and channels used for notification? • How many residents attended the virtual EIR Public Scoping Meeting on November 2, 2022, and can you provide a summary of the key concerns or comments raised during the meeting? • What steps were taken to ensure that all potentially affected residents were informed about the meeting, and how did you address any barriers to participation, such as digital access or language differences? • Can you provide data on the overall community engagement efforts for this project, including the number of comments received, the demographic breakdown of participants, and any follow-up actions taken in response to community feedback? • How do you plan to improve future community engagement efforts to ensure broader and more effective participation, particularly for residents who may have been unaware of or unable to attend the initial virtual scoping meeting? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:56 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 1.6 This type of EIR should focus primarily on the changes in the environment that would result from the development project. • The report should be unbiased and not show that it is promoting the project in any way. This EIR is a marketing report for the project emphasizing support for the project continually. • Can you provide specific examples of how the EIR maintains objectivity in its analysis, particularly in sections where potential negative impacts are discussed? • What measures were taken during the EIR preparation process to ensure an unbiased assessment of environmental impacts, rather than promoting the project? • How does the EIR balance the presentation of potential benefits and drawbacks of the project, and can you point to specific sections that demonstrate this balance? • Were any independent third-party reviewers involved in the EIR process to ensure objectivity, and if so, can you share their findings or recommendations? • Given the concern that the EIR appears to be promoting the project, what steps are you willing to take to address this perception and ensure a more neutral presentation of environmental impacts? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:55 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 1.5 The city received only one comment letter in response to the NOP and no comments during the virtual scoping meeting. • Adequate notice was not provided by the City and/or developer. The communication might have met the laws minimum requirements but obviously that is not adequate. • Can you provide specific market data and analysis that demonstrates the demand for high- density residential units in this primarily retail area, and how this demand justifies the proposed zoning change? • How do you plan to ensure true integration of uses between the proposed apartment project and the existing retail environment, given that the project appears to be primarily residential? • Can you provide detailed plans or studies showing how the proposed project will enhance pedestrian connectivity and walkability in an area that was originally designed for car-dependent retail? • What specific shared elements, including parking, are planned between the residential and retail components, and how will these be implemented without negatively impacting the existing retail operations? • Given that the project will replace a portion of a commercial facility designed to support the neighborhood, how do you plan to mitigate the potential loss of retail services and ensure that the new development still meets the community's needs? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
166 Acacia Glen Dr.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters RIverside, CA 92506
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:54 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Section 1.3 The Mixed Use-Urban zone will allow the proposed apartment project to be introduced into the existing retail environment and will create a framework for integration of uses with features such as pedestrian connectivity, walkability, and shared elements including parking. • This is an unsupported statement that makes unsupported assumptions. This is a proposed apartment building that will replace a large portion of a commercial facility that was designed to support the neighborhood. There is no market data to support this project. • Can you provide specific market data and analysis that demonstrates the demand for high-density residential units in this primarily retail area, and how this demand justifies the proposed zoning change? • How do you plan to ensure true integration of uses between the proposed apartment project and the existing retail environment, given that the project appears to be primarily residential? • Can you provide detailed plans or studies showing how the proposed project will enhance pedestrian connectivity and walkability in an area that was originally designed for car-dependent retail? • What specific shared elements, including parking, are planned between the residential and retail components, and how will these be implemented without negatively impacting the existing retail operations? • Given that the project will replace a portion of a commercial facility designed to support the neighborhood, how do you plan to mitigate the potential loss of retail services and ensure that the new development still meets the community's needs? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Norman Cole
166 Acacia Glen Dr.

Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:48 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Alternative Uses - Section 7.0.3 The No Project alternative would not fulfill any of the Project’s objectives as the existing site would not provide high-quality housing in close proximity to many amenities and high-quality transit corridors, assist the City of Riverside in meeting housing needs, use land resources more efficiently with infill redevelopment on an underutilized vacant site; or further the City’s Climate Action Plan by replacing aging building construction with green building practices and other sustainable development methods. Under this alternative, no improvements would be made to the Project site, and the site would continue to be vacant with temporary/seasonal retail tenants. • This assumes the property will remain as-is and is only used for temporary retail with no desire for a permanent tenant. • Have you conducted any market studies or feasibility analyses to determine the potential for attracting permanent retail tenants to the existing site rather than assuming it will only be used for temporary/seasonal retail? • What specific green building practices and sustainable development methods are you proposing that would significantly contribute to the City's Climate Action Plan goals? • Can you provide a comparative analysis of how your proposed high-quality housing development would more effectively meet the city's housing needs than other potential uses for the site? • How does your project's proximity to high-quality transit corridors specifically translate into reduced environmental impacts compared to the No Project alternative? • Given that the site is described as "underutilized," have you explored any alternative development scenarios that could achieve similar objectives while preserving some existing structures or uses? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dr
RIverside, CA 92506Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:46 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented unbiased; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Alternative Uses - Section 7.0.2 State CEQA Guidelines Section 15126.6(a) requires that an EIR “…describe a range of reasonable alternatives to the project, or the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.” Each alternative must be capable of avoiding or substantially lessening any significant effects of the proposed project.

According to this section of the State CEQA Guidelines, “…an EIR need not consider every conceivable alternative to a project. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.” An EIR is not required to consider infeasible alternatives. The City, as lead agency, is responsible for selecting a range of Project alternatives to be discussed other than the “rule of reason” (CEQA Guidelines Section 15126.6(a)). • These alternative selections are not market-driven but simply as they relate to the project's significant effects. The city advocates for the project, so they will not be looking for objective and relevant alternatives unless they meet their needs. How did you determine the range of alternatives presented in the EIR, and can you provide evidence that these alternatives genuinely address the project's significant environmental effects? • Given that the City is described as an advocate for the project, what measures have been taken to ensure an objective evaluation of alternatives that may not align with the City's preferences? • Can you explain the process used to assess the feasibility of each alternative, particularly those that might substantially lessen environmental impacts but may not fully align with the City's goals? • How have you incorporated public input, especially from stakeholders who may have differing views from the City, into the selection and evaluation of project alternatives? • What criteria were used to determine that the presented alternatives would "foster informed decision-making and public participation," and how can you demonstrate that these criteria were applied objectively? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Norman Cole
Mission Grove Neighborhood Alliance
166 Acacia Glen Dt.

Riverside CA 92506
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Norman Cole <[email protected]>
Sent: Sunday, June 23, 2024 2:44 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Alternative Uses - Section 7.0 The following discussion considers alternatives to implementing the Project and examines the potential environmental impacts resulting from each alternative. By comparing these alternatives to the Project, the relative advantage(s) can be weighed and analyzed. • These alternatives are not based on any feasibility study, local market analysis, or other independent studies to support the statements or conclusions. Studies have shown that only a tiny percentage of old KMARTS are demolished and replaced with residential housing. • Can you provide specific feasibility studies or local market analyses supporting the viability of converting this KMART site into residential housing? • What percentage of similar KMART conversions to residential housing have been successful in comparable markets, and how does this inform your project's potential success? • Have you conducted any environmental impact assessments to compare the effects of demolition and new construction versus adaptive reuse of the existing KMART structure? • Given that studies show only a tiny percentage of old KMARTs are demolished for residential use, what unique factors make this site suitable for such a conversion? • How does your proposed residential development align with the local community's long-term urban planning goals and housing needs, and can you provide data to support this alignment? • Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter.

Sincerely,
Norman Cole
166 Acacia Glen Dr
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:29 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 5.1.5
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Threshold C: In non-urbanized areas, would the Project 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 a 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?
• This will be a huge build protruding into the commercial space creating an unsightly view and disrupting the continuity of the area. It will be an eyesore and no evidence has been provided that reflects anything different.
• Can you provide visual simulations or renderings of the proposed project from various publicly accessible vantage points to demonstrate how it will impact the existing visual character and quality of the site and its surroundings? • How does the proposed project comply with applicable zoning and other regulations governing scenic quality in the area, and what specific design elements have been incorporated to minimize visual disruption?
• What measures will be taken to ensure that the project does not create an unsightly view or disrupt the continuity of the commercial space, and how will these measures be enforced?
• Have you conducted any community consultations or surveys to gather feedback on the visual impact of the proposed project, and if so, what were the findings and how have they been addressed in the project design?
• Can you provide examples of similar projects where large builds have been successfully integrated into commercial spaces without degrading the visual character or quality, and what lessons from those projects will be applied to this development?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Riverside Ca 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:28 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 6.3
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Significant Irreversible Environmental Changes - This section addresses the use of non- renewable resources during initial and continued phases of the Project, the commitment of future generations to environmental changes or impacts because of the Project, and any irreversible damage from environmental accidents associated with the Project. Operation of the Project would irreversibly increase local demand for non-renewable energy resources, such as petroleum products and natural gas. Increasingly efficient building design, however, will offset this demand to some degree by reducing energy demands of the Project.
• The project will increase energy and utility demands. • Can you provide a detailed analysis of the projected increase in local demand for non- renewable energy resources, such as petroleum products and natural gas, due to the operation of the project?
• What specific measures will be implemented to ensure that increasingly efficient building designs will effectively offset the increased energy demands of the project? • How do you plan to mitigate the long-term environmental impacts and irreversible changes associated with the increased use of non-renewable resources? • Have you conducted any risk assessments to evaluate the potential for environmental accidents associated with the project, and what measures will be taken to prevent and respond to such incidents?
• Can you provide examples of similar projects where efficient building designs have successfully reduced energy demands, and what lessons from those projects will be applied to ensure the sustainability of this development?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
Riverside, Ca 92506
Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:27 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 6.3.2
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Commitment of Future Generations - Approval of the Project would result in environmental changes or impacts that commit future generations to new environmental circumstances.

Primarily, the approval of the Project would change the underlying GP 2025 land use designations and zoning of the Project site and the Mission Grove Specific Plan land use and zoning, as detailed in Section 5.11, Land Use and Planning. The change in the underlying regulations would allow for a change from C - Commercial to MU-U - Mixed Use-Urban for a multi-family development. This would result, in turn, in an increase in population as compared to commercial development as envisioned in the City’s GP 2025. • This project would have a lasting effect on the local area for generations. It would also set a precedent that all the regulations can be waived or overwritten if the local government wants a project that does not meet the current criteria and the people affected the most by the project will struggle to be heard.
• Can you provide a detailed analysis of how the proposed change from C - Commercial to MU-U - Mixed Use-Urban will impact the long-term land use and zoning consistency within the Mission Grove Specific Plan and the broader GP 2025 framework? • What specific measures will be taken to ensure that the voices and concerns of the local community, who are most affected by the project, are adequately heard and addressed throughout the planning and approval process?
• How do you plan to mitigate the potential negative impacts of increased population density on local infrastructure, public services, and community resources, given the shift from commercial to multi-family residential development? • Can you provide examples of similar projects where changes in land use designations and zoning have been successfully implemented without setting a negative precedent for future developments, and what lessons from those projects will be applied here? • What long-term monitoring and evaluation strategies will be put in place to assess the environmental and social impacts of the project on future generations, and how will these findings be used to inform future land use and zoning decisions?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters

Norman Cole
166 Acacia Glen Dr
Riverside ca 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:26 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 5.3.5
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Environmental Impacts - Threshold B: Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard? • The addition of 600-800 vehicles each day in the area would have a damaging effect on air quality. Leaving in the morning and returning in the evening with increased traffic on already crowded roads. The solution is to modify the traffic signals? • Can you provide detailed traffic impact studies that specifically address how the addition of 600-800 vehicles daily will affect air quality in the area, particularly during peak morning and evening hours?
• What specific mitigation measures, beyond modifying traffic signals, do you propose to reduce the cumulative air quality impacts from the increased vehicle traffic generated by the project?
• Have you conducted any air quality modeling to assess the potential increase in criteria pollutants, especially those for which the region is already in nonattainment? If so, can you share the results and methodology?
• How does your project plan to encourage alternative transportation methods to reduce reliance on personal vehicles and mitigate air quality impacts? • Can you provide a comprehensive analysis of how the project's cumulative air quality impacts, when combined with other planned developments in the area, align with regional air quality improvement goals and plans?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
Riverside Ca 92506
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: nd.cole <[email protected]>
Sent: Monday, June 24, 2024 11:25 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project.

Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 5.1.5
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Threshold C: In non-urbanized areas, would the Project 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 a 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?
• This will be a huge build protruding into the commercial space creating an unsightly view and disrupting the continuity of the area. It will be an eyesore and no evidence has been provided that reflects anything different.
• Can you provide visual simulations or renderings of the proposed project from various publicly accessible vantage points to demonstrate how it will impact the existing visual character and quality of the site and its surroundings? • How does the proposed project comply with applicable zoning and other regulations governing scenic quality in the area, and what specific design elements have been incorporated to minimize visual disruption?
• What measures will be taken to ensure that the project does not create an unsightly view or disrupt the continuity of the commercial space, and how will these measures be enforced?
• Have you conducted any community consultations or surveys to gather feedback on the visual impact of the proposed project, and if so, what were the findings and how have they been addressed in the project design?
• Can you provide examples of similar projects where large builds have been successfully integrated into commercial spaces without degrading the visual character or quality, and what lessons from those projects will be applied to this development?

Summary
The project is currently inconsistent with several City policies and development standards.

It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Norman Cole
166 Acacia Glen Dr
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Riverside Ca 92506
Mission Grove Neighborhood Alliance

Sent from my T-Mobile 4G LTE Device

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: PATTI WESTBROOK <[email protected]>
Sent: Sunday, June 23, 2024 10:17 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] KMART APARTMENT PROJECT

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

I am a Mission Grove homeowner and do not want these apartments at the center. We want more
restaurant choices and shopping.

Patti Westbrook
130 Cape Elizabeth Way....Riverside.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Patty Huddleston <[email protected]>
Sent: Monday, June 24, 2024 10:29 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project- related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Alternative Uses - Section 7.0.5 Alternative 3, the Retail Development Alternative, would consist of retaining the existing retail building and associated surface parking lot with only minor improvements to the inside and/or exterior of the building and/or associated surface parking lot and landscaping. The existing building would house a permanent retail tenant utilizing the full square footage of the building for retail. • Have you conducted a comprehensive market analysis to determine the viability of attracting a large-scale retail tenant for the entire building, and if so, what were the key findings? • How does the potential economic impact of retaining the site as retail compare to your proposed residential development regarding job creation, local tax revenue, and overall community benefit? • If selling the property to a retailer is considered, what criteria would you use to ensure the new owner's plans align with the city's long-term development goals and the needs of the surrounding community? • Have you explored any mixed-use alternatives that could incorporate retail and residential components, potentially PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters preserving some of the existing structure while addressing housing needs? • Given the trend of repurposing retail spaces for alternative uses, as mentioned in the search results, what innovative approaches have you considered for this site beyond traditional retail or residential development? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter. Sincerely, Patty Huddleston 639 Burwood Ct Mission Grove Neighborhood Alliance PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Patty Huddleston <[email protected]>
Sent: Monday, June 24, 2024 10:28 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City of Riverside, Planning Division Email:

[email protected] RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Dear Ms. Hernandez: Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project- related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project. The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base. I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for the residents in the area. More specifically, I would like to comment on the following sections related to the EIR: Alternative Uses - Section 7.0.6 This discussion analyzes the proposed 347 residential apartment project at an off-site location. This alternative does not include a specific off-site location; however, it is assumed for the purposes of this analysis that it would consist of redevelopment of a site similar in size and of a vacant or underutilized building or buildings within the City of Riverside. This development focuses on infill of abandoned or underutilized space. Alternative sites were not considered for this project, and thus, no specific off-site locations were considered by the applicant to be evaluated under this alternative. • Moving the Project to a similar location but mitigating some of the issues. • What specific criteria did you use to determine that no alternative sites within the City of Riverside were suitable for consideration, and can you provide documentation of this site selection process? • Have you conducted any preliminary assessments of potential off-site locations that could accommodate a similar project while potentially reducing environmental impacts or addressing community concerns? • How would PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters relocating the project to a different infill site within Riverside affect its ability to meet the city's housing goals and align with existing infrastructure and transit corridors? • Can you provide a comparative analysis of the potential environmental impacts, particularly regarding traffic and resource consumption, between the proposed site and a hypothetical alternative location with similar characteristics? • Given that the project focuses on infill development of abandoned or underutilized spaces, what specific challenges or opportunities do you foresee in adapting this 347-unit residential concept to other vacant or underutilized sites within Riverside? Summary The project is currently inconsistent with several City policies and development standards. It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of current residents. Thank you for your consideration of this letter. Sincerely, Patty Huddleston 639 Burwood Ct. Mission Grove Neighborhood Alliance PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Rainee Khabagnote <[email protected]>
Sent: Monday, June 24, 2024 7:49 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Dear Ms. Hernandez:

Thank you for the hearing our comments on the Draft Environmental Impact Report (EIR) on the Mission Grove Apartments project consisting of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel. The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. In keeping with this admonition, alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

As a Riverside resident, I have serious concerns about the viability of this project, its influence on the community, and the effect on the quality of life for us residents. My husband and I specifically moved to Mission Grove because we wanted a suburban community. I believe adding at least more than 347 families would hugely affect traffic and community experience. In addition as a physician, I am deeply concerned about the years of construction proposed adjacent to our neighborhood. My husband and I specifically picked this neighborhood because it was away from major roads and construction for air quality and health reasons. Lastly, I don’t believe the traffic caused by this project and then the minimum 347 more residents would be mitigated by adjusting traffic lights. We have already experienced major traffic from the short-term projects done on Alessandro. If this project were to be approved as is, my husband and I would strongly consider leaving this area because it in essence changes our community. More specifically, I would like to comment on the following sections related to the EIR:

Alternative Uses - Section 7.0.4

Under Alternative 2, the Reduced Density Apartment Redevelopment, the proposed PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters residential development would consist of 58 dwelling units in lieu of the proposed Project’s 347 dwelling units.
• The ALUC will allow higher density than 6 du/ac. The surrounding area shows densities as high as 16 du/ac. A 16du/ac with retail on the bottom floor would be more compatible with the area. Especially if the unit mix concentrated on 2 and 3 bedroom.
• Given that the surrounding area shows densities up to 16 dwelling units per acre, why have you chosen a significantly lower density of 58 units for Alternative 2, rather than exploring a middle ground that could better align with the neighborhood character?
• Have you conducted any studies to determine how a mixed-use development with retail on the ground floor and residential units above (at 16 du/ac) would impact local economic vitality and housing affordability compared to your current proposal?
• Can you provide a comparative analysis of the environmental impacts, particularly regarding traffic and infrastructure demands, between your proposed 347-unit development and a potential 16 du/ac mixed-use alternative? • How would focusing on two and 3-bedroom units in a higher-density scenario affect the project's ability to meet local housing needs, especially for families, compared to your current unit mix?
• Considering that the Airport Land Use Commission (ALUC) allows for higher density than six du/ac, what factors led to the decision to propose such a low-density alternative, and how does this align with broader city planning goals for efficient land use and housing provision.

• Have you conducted a comprehensive market analysis to determine the viability of attracting a large-scale retail tenant for the entire building, and if so, what were the key findings?
• Have you explored any mixed-use alternatives that could incorporate retail and residential components, potentially preserving some of the existing structure while addressing housing needs?

• Moving the Project to a similar location but mitigating some of the issues. • What specific criteria did you use to determine that no alternative sites within the City of Riverside were suitable for consideration, and can you provide documentation of this site selection process?
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters • How would relocating the project to a different infill site within Riverside affect its ability to meet the city's housing goals and align with existing infrastructure and transit corridors?

Summary
The project is currently inconsistent with several City policies and development standards.

It could be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs, or attracting a different large-scale tenant, or moving the project to another site. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well-being of us current residents. Thank you for considering all options that are best for our community.

Sincerely,

Rainee Khabagnote and Michael Choi
945 High Peak Drive, Riverside CA 92506
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Ira and Rajean Long <[email protected]>
Sent: Monday, June 24, 2024 8:19 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 5.9.6

Due to the inconsistency of the maximum residential density, the project would result in a significant and unavoidable impact. There are no feasible mitigation measures that would reduce impacts related to inconsistency with the residential density criteria.

• There is no evidence as to why the project is bei ng considered at all based on this issue. Other than it helps meet the Cities RHNA requirements. • Given that the project would result in a signific ant and unavoidable impact due to inconsistency with maximum residential density requirements, what specific justifications can you provide for pursuing this project beyond meeting the City's RHNA requirements?
• Have you explored any alternative designs or conf igurations that could bring the project closer to compliance with the residential density criteria while still meeting your development goals?
• Can you provide detailed analysis of how the bene fits of this project, including its contribution to RHNA requirements, outweigh the significant and unavoidable impacts identified in the EIR?
• What specific measures do you propose to mitigate or offset the negative impacts of exceeding the maximum residential density, even if they cannot fully resolve the inconsistency?
• Have you conducted any studies or community engag ement efforts to assess local support or opposition to this project, given its significant deviation from established density requirements?

Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well- being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Ira and Rajean Long
7048 City View CIrcle
Riverside, CA 92506
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Ira and Rajean Long <[email protected]>
Sent: Monday, June 24, 2024 8:18 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 5.17.5

Parking - Unbundle Residential Parking Costs from Property Cost. According to CAPCOA, increasing the cost of owning a vehicle will decrease or discourage vehicle ownership and therefore reduce VMT and GHG. CAPCOA transportation Measure T-16, Unbundle Residential Parking Costs from Property Cost, was used to estimate the amount of VMT reduction that can be achieved by charging for additional parking stalls.

The Project proposes to provide 1 parking stall to every apartment unit within the rental unit fee (no additional charge) and charge $75 per month for any and each additional parking spaces, which may reduce Project VMT by up to 3.9%.

• This section appears to be in violation of AB 131 7 signed into law in 2023 and effective in January 2025 with any new certificate of occupancy, requires that all parking be unbundled and charged for separately. With this project being in the middle of a shopping center, not providing enough parking for the number of units, and the tenants being able to opt out of paying for parking since the shopping center parking is free, creates numerous issues for the retail establishments and their customers. This is especially true since occupancy standards allow for up to 6 people in a one bedroom.

None of this has been addressed in this report.
• How do you plan to comply with AB 1317, which req uires all parking to be unbundled and charged for separately starting in January 2025, given that your current proposal includes one parking stall per apartment unit within the rental fee? • What specific measures will be implemented to pre vent tenants from opting out of paying for parking and instead using the free parking available in the shopping center, potentially causing parking shortages for retail customers? • Can you provide a detailed analysis of the potent ial impacts on retail establishments and their customers if tenants use the shopping center parking, including any mitigation strategies to address these issues? • How do you plan to address the potential for high occupancy rates (up to 6 people in a one-bedroom unit) and the resulting increased demand for parking, which may exceed the provided parking capacity?
• Have you conducted any studies or assessments to evaluate the effectiveness of unbundling residential parking costs in reducing VMT and GHG emissions, and how do these findings support the proposed parking strategy for this project?

Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well- being of current residents.

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters

Thank you for your consideration of this letter.

Sincerely,
Ira and Rajean Long
7048 City View CIrcle
Riverside, CA 92506
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Ira and Rajean Long <[email protected]>
Sent: Monday, June 24, 2024 8:18 AM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Section 5.17.5

Environmental Impacts - Threshold B: Would the Project conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)?The City’s guidelines provide guidance regarding VMT analysis based on land use types.10. Implement Subsidized or Discounted Transit Program (TRT-4).In conclusion, while the previously discussed TDM measures may help offset some of the VMT impacts of the proposed Project by up to

17.7 percent, these measures would not reduce the Project-generated VMT impact to a less than significant level.

• The VMT impact cannot be mitigated.
• Given that the proposed TDM measures are insuffic ient to reduce the Project- generated VMT impact to a less than significant level, what additional innovative strategies or technologies have you considered to further mitigate VMT impacts? • Can you provide a detailed analysis of how the 17 .7 percent reduction in VMT was calculated, and what specific assumptions were made in this calculation? • Have you explored partnerships with local transit agencies or ride-sharing companies to develop more robust transit solutions that could potentially reduce VMT beyond the current projections?
• What specific measures will be implemented to mon itor and evaluate the effectiveness of the proposed TDM strategies over time, and how will these findings be used to adjust and improve VMT reduction efforts?
• Given that the VMT impact cannot be fully mitigat ed, how do you plan to address potential community concerns about increased traffic congestion and related environmental impacts, particularly in the context of the project's consistency with local and regional transportation plans?

Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its consistency with existing planning guidelines and protecting the well- being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Ira and Rajean Long
7048 CityView Circle
Riverside, CA 92506
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Tony Haro <[email protected]>
Sent: Monday, June 24, 2024 1:33 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Alternative Uses - Section 7.0.6

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters This discussion analyzes the proposed 347 residential apartment project at an off-site location. This alternative does not include a specific off-site location; however, it is assumed for the purposes of this analysis that it would consist of redevelopment of a site similar in size and of a vacant or underutilized building or buildings within the City of Riverside. This development focuses on infill of abandoned or underutilized space.

Alternative sites were not considered for this project, and thus, no specific off-site locations were considered by the applicant to be evaluated under this alternative.

• Moving the Project to a similar location but mitigating some of the issues. • What specific criteria did you use to determine that no alternative sites within the City of Riverside were suitable for consideration, and can you provide documentation of this site selection process?
• Have you conducted any preliminary assessments of potential off-site locations that could accommodate a similar project while potentially reducing environmental impacts or addressing community concerns?
• How would relocating the project to a different infill site within Riverside affect its ability to meet the city's housing goals and align with existing infrastructure and transit corridors?
• Can you provide a comparative analysis of the potential environmental impacts, particularly regarding traffic and resource consumption, between the proposed site and a hypothetical alternative location with similar characteristics? • Given that the project focuses on infill development of abandoned or underutilized spaces, what specific challenges or opportunities do you foresee in adapting this 347- unit residential concept to other vacant or underutilized sites within Riverside?

Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its
consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,

Name, and address
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters From: Tony Haro <[email protected]>
Sent: Monday, June 24, 2024 1:35 PM
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610

Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Alternative Uses - Section 7.0.6

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters This discussion analyzes the proposed 347 residential apartment project at an off-site location. This alternative does not include a specific off-site location; however, it is assumed for the purposes of this analysis that it would consist of redevelopment of a site similar in size and of a vacant or underutilized building or buildings within the City of Riverside. This development focuses on infill of abandoned or underutilized space.

Alternative sites were not considered for this project, and thus, no specific off-site locations were considered by the applicant to be evaluated under this alternative.

• Moving the Project to a similar location but mitigating some of the issues. • What specific criteria did you use to determine that no alternative sites within the City of Riverside were suitable for consideration, and can you provide documentation of this site selection process?
• Have you conducted any preliminary assessments of potential off-site locations that could accommodate a similar project while potentially reducing environmental impacts or addressing community concerns?
• How would relocating the project to a different infill site within Riverside affect its ability to meet the city's housing goals and align with existing infrastructure and transit corridors?
• Can you provide a comparative analysis of the potential environmental impacts, particularly regarding traffic and resource consumption, between the proposed site and a hypothetical alternative location with similar characteristics? • Given that the project focuses on infill development of abandoned or underutilized spaces, what specific challenges or opportunities do you foresee in adapting this 347- unit residential concept to other vacant or underutilized sites within Riverside?

Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its
consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Antonio Haro
269 Cannon Rd. Riverside, Ca 92506
Mission Grove Neighborhood Alliance

PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

From: Jeanne ONeill
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Date: Wednesday, June 26, 2024 5:32:54 PM
Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610
Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The EIR must meet CEQA requirements that include an impartial analysis of the proposed project. The information and analysis must be presented in an unbiased manner; that is, the EIR and any project-related technical reports must not suggest in any way that the project should be approved or favored. In keeping with this admonition, project alternatives must not be formulated in such a way as to support the proposed project. Alternatives must meet the spirit and intent of CEQA in that they must be feasible and reduce or avoid the significant impacts resulting from the proposed project.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Alternative Uses - Section 7.0.6
This discussion analyzes the proposed 347 residential apartment project at an off-site location.

This alternative does not include a specific off-site location; however, it is assumed for the purposes of this analysis that it would consist of redevelopment of a site similar in size and of a vacant or underutilized building or buildings within the City of Riverside. This development focuses on infill of abandoned or underutilized space. Alternative sites were not considered for this project, and thus, no specific off-site locations were considered by the applicant to be PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters evaluated under this alternative.
• Moving the Project to a similar location but mitigating some of the issues. • What specific criteria did you use to determine that no alternative sites within the City of Riverside were suitable for consideration, and can you provide documentation of this site selection process?
• Have you conducted any preliminary assessments of potential off-site locations that could accommodate a similar project while potentially reducing environmental impacts or addressing community concerns?
• How would relocating the project to a different infill site within Riverside affect its ability to meet the city's housing goals and align with existing infrastructure and transit corridors? • Can you provide a comparative analysis of the potential environmental impacts, particularly regarding traffic and resource consumption, between the proposed site and a hypothetical alternative location with similar characteristics?
• Given that the project focuses on infill development of abandoned or underutilized spaces, what specific challenges or opportunities do you foresee in adapting this 347-unit residential concept to other vacant or underutilized sites within Riverside? Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone.

The City should make steady progress toward its residential housing goals while maximizing its
consistency with existing planning guidelines and protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,.

Jeanne O'Neill, 8167 Faircrest Road, Riverside, CA, 92508.

Mission Grove Neighborhood Alliance
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

From: Jeanne ONeill
To: Hernandez, Veronica
Subject: [EXTERNAL] Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610 Date: Wednesday, June 26, 2024 5:37:23 PM
Veronica Hernandez, Senior Planner City
of Riverside, Planning Division Email:

[email protected]
RE: Public comment on the record for the Mission Grove Apartments EIR, SCH # 2022100610
Dear Ms. Hernandez:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (EIR) on
the Mission Grove Apartments (Project). The project consists of demolishing the existing vacant Kmart located in the middle of the Mission Grove Shopping Center and developing a high-density 347-unit residential apartment project on a 9.92-acre parcel.

The proposed Project is inconsistent in multiple ways, including the City of Riverside land use policies, The General Plan, the Mission Grove Specific Plan, the current Zoning, and the VMT impact would be significant and unavoidable as it relates to transportation, the Airport Land Use Commission (ALUC) flight path inconsistency for dwelling density, and the City of Riverside policies regarding development around March Air Reserve Base.

I have serious concerns about the viability of this project, its influence on the community, and the
effect on the quality of life for the residents in the area.

More specifically, I would like to comment on the following sections related to the EIR:

Section 5.3.5
Environmental Impacts - Threshold B: Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard? • The addition of 600-800 vehicles each day in the area would have a damaging effect on air quality. Leaving in the morning and returning in the evening with increased traffic on already crowded roads. The solution is to modify the traffic signals? • Can you provide detailed traffic impact studies that specifically address how the addition of 600-800 vehicles daily will affect air quality in the area, particularly during peak morning and evening hours?
• What specific mitigation measures, beyond modifying traffic signals, do you propose to reduce the cumulative air quality impacts from the increased vehicle traffic generated by the project?
• Have you conducted any air quality modeling to assess the potential increase in criteria pollutants, especially those for which the region is already in nonattainment? If so, can you share the results and methodology?
• How does your project plan to encourage alternative transportation methods to reduce PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters reliance on personal vehicles and mitigate air quality impacts? • Can you provide a comprehensive analysis of how the project's cumulative air quality impacts, when combined with other planned developments in the area, align with regional air quality improvement goals and plans?
Summary
The project is currently inconsistent with several City policies and development standards. It could
be mitigated through a genuinely mixed-use project with ground-floor retail and a unit mix that meets the market needs. The City of Riverside should aim to maximize its consistency with ALL relevant policies in its General Plan, Specific Plan, ALUC consistency, and zoning development standards for this project and others rather than override those inconsistencies to give primacy to the RHNA residential needs alone. The City should make steady progress toward protecting the well-being of current residents.

Thank you for your consideration of this letter.

Sincerely,
Pam O'Neill
8167 Faircrest Road
Riverside, CA 92508
PR-2022-001359 (GPA, RZ, SPA, TPM, DR, EIR) Exhibit 14 - Public Comment Letters

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