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Draft Environmental Impact Report

Riverside City Council
September 17, 2024

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Draft Environmental Impact Report
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September 17, 2024
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 Creating targeted fees including a public goods charge on water use, fees on high global warming potential gases, and a fee to fund the administrative costs of the State of California's long-term commitment to AB 32 implementation.

The CARB approved the final “First Update to the Climate Change Scoping Plan” in May 2014. The first update describes California’s progress towards AB 32 goals stating that “California is on track to meet the near-term 2020 greenhouse gas limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB 32” (CARB 2014, p. ES2). Specifically, “if California realizes the expected benefits of existing policy goals (such as 12,000 megawatts [MW] of renewable distributed generation by 2020, net zero energy homes after 2020, existing building retrofits under AB 758, and others) it could reduce emissions by 2030 to levels squarely in line with those needed in the developed world and to stay on track to reduce emissions to 80 percent below 1990 levels by 2050” (CARB 2014, p. 34). The first update laid the groundwork for the greenhouse gas emission goals set forth in Executive Order S-3-05 and B-16-2012 (CARB 2017c, p. 5), which set an objective for California to reduce greenhouse gas emissions to 80 percent below 1990 levels by 2050. (CARB 2014, p. 1).

CARB adopted a second update to the Scoping Plan in 2017 to reflect the 2030 target codified by SB

32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s Executive Order B-30-15. Based on the emissions reductions directed by SB 32, the annual 2030 statewide target emissions level for California is 260 million metric tons of carbon dioxide equivalent (million MTCO2E). The companion bill to SB 32, AB 197, provides additional direction to CARB on the following areas related to the adoption of strategies to reduce GHG emissions. (CARB 2017c, pp. 2-3):
 Requires annual posting of GHG, criteria, and toxic air contaminant data throughout the State, organized by local and sub-county level for stationary sources and by at least a county level for mobile sources.
 Requires CARB, when adopting rules and regulations to achieve emissions reductions and to protect the State’s most affected and disadvantaged communities, to consider the social costs of GHG emissions and prioritize both of the following:
o Emissions reductions rules and regulations that result in direct GHG emissions reductions at large stationary sources of GHG emissions and direct emissions reductions from mobile sources.
o Emissions reductions rules and regulations that result in direct GHG emissions reductions from sources other than those listed above.
 Directs CARB, in the development of each scoping plan, to identify for each emissions reduction measure:
o The range of projected GHG emissions reductions that result from the measure. o The range of projected air pollution reductions that result from the measure. o The cost-effectiveness, including avoided social costs, of the measure.

CARB’s 2017 Scoping Plan builds upon the successful framework established by the Initial Scoping Plan and First Update, while identifying new, technologically feasible, and cost-effective strategies to ensure that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to foster economic growth, and delivers improvements to the environment and public health, including in disadvantaged communities. The 2017 Scoping Plan includes policies to require direct GHG reductions at some of the State’s largest stationary sources and mobile sources. These policies include City of Riverside Section 5.5
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the use of lower GHG fuels, efficiency regulations, and the Cap-and-Trade Program, which constrains and reduces emissions at covered sources. (CARB 2017c, pp. 5-6).

The CARB approved the most recent scoping plan update in December 2022 (CARB 2022a). CARB’s 2022 Scoping Plan lays out the sector-by-sector roadmap for California to achieve carbon neutrality by 2045 or earlier, outlining a technologically feasible, cost-effective, and equity-focused path to achieve the state’s climate target. The previous Scoping Plans have focused on specific GHG reduction targets for our industrial, energy, and transportation sectors—first to meet 1990 levels by 2020, then to meet the more aggressive target of 40 percent below 1990 levels by 2030. The 2022 Scoping Plan addresses recent legislation (AB 1279) and direction from the current Governor and extends and expands upon the earlier Scoping Plans with a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. The 2022 Scoping Plan also builds upon current and previous environmental justice efforts to integrate environmental justice directly into the plan, to ensure that all communities can reap the benefits of this transformational plan. Specifically, the 2022 Scoping Plan will:
 Identify a path to keep California on track to meet its SB 32 GHG reduction target of at least 40 percent below 1990 emissions by 2030.
 Identify technologically feasible, cost-effective path to achieve carbon neutrality by 2045 and a reduction in anthropogenic emissions by 85 percent below 1990 levels.  Focus on strategies for reducing California’s dependency on petroleum to provide consumers with clean energy options that address climate change, improve air quality, and support economic growth and clean sector jobs.
 Integrate equity and protecting California’s most impacted communities as driving principles throughout the document.
 Incorporate the contribution of natural and working lands (NWL) to the state’s GHG emissions, as well as their role in achieving carbon neutrality.
 Rely on the most up-to-date science, including the need to deploy all viable tools to address the existential threat that climate change presents, including carbon capture and sequestration, as well as direct air capture.
 Evaluate the substantial health and economic benefits of taking action.  Identify key implementation actions to ensure success.

The 2022 Scoping Plan outlines how carbon neutrality can be achieved by taking measures to reduce GHGs to meet the anthropogenic emissions target and by expanding actions to capture and store carbon through the state’s natural and working lands and using a variety of mechanical approaches. The actions and outcomes in the plan will achieve: significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon.

Senate Bill 375 and SCAG Regional Transportation Plan/Sustainable Community Plan SB 375 provides for a new planning process to coordinate land use planning, regional transportation plans, and funding priorities in order to help California meet the GHG reduction goals established in AB 32 (SB 375). SB 375 includes provisions for streamlined CEQA review for some infill projects such as transit-oriented development. SB 375 also requires Metropolitan Planning Organizations (MPOs) relevant to the Project area (including the Southern California Association of Governments (SCAG)) to incorporate a "sustainable communities strategy" (SCS) into their regional transportation plans (RTPs) that will achieve GHG emission reduction targets by reducing vehicle miles traveled (VMT) from light duty vehicles through development of more compact, complete, and efficient communities.

Section 5.5 City of Riverside
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On September 23, 2010, CARB adopted Regional Targets for the reduction of GHG applying to the years 2020 and 2035 (CARB 2010). For the area under SCAG's jurisdiction including the Project area, CARB adopted Regional Targets for reduction of GHG emissions by eight percent for 2020 and by 13 percent for 2035.

SCAG's SCS is included in the SCAG Connect SoCal (2020-2045 Regional Transportation Plan Sustainable Communities Strategy (RTP/SCS) (SCAG 2020). CARB updated the regional targets in 2018 to ensure consistency with the more stringent statewide reduction goals subsequently introduced by the California legislature and the Governor’s office. For the SCAG region, the updated targets are eight percent below 2005 per capita emissions levels by 2020 (this value is unchanged from the previous 2020 CARB target), and 19 percent below 2005 per capita emissions levels by 2035. (SCAG 2020, p. 138).

Connect SoCal SCS has been found to meet State targets for reducing GHG emissions from cars and light trucks. Connect SoCal achieves per capita GHG emission reductions relative to 2005 levels of 8 percent in 2020, and 19 percent in 2035, thereby meeting the GHG reduction targets established by the CARB for the SCAG region. (SCAG 2020, p. 138).

Senate Bill 605
On September 21, 2014, Governor Edmund Brown signed Senate Bill 605 (SB 605), which requires CARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants (SLCP) in the state no later than January 1, 2016. As defined in the statute, SLCP means "an agent that has a relatively short lifetime in the atmosphere, from a few days to a few decades, and a warming influence on the climate that is more potent than that of carbon dioxide." SB 605, however, does not prescribe specific compounds as SLCP or add to the list of GHGs regulated under AB 32. In developing the strategy, CARB must complete an inventory of sources and emissions of SLCP in the state based on available data, identify research needs to address any data gaps, identify existing and potential new control measures to reduce emissions, and prioritize the development of new measures for SLCP that offer co-benefits by improving water quality or reducing other air pollutants that impact community health and benefit disadvantaged communities (SB 605). In March 2017, CARB approved the ShortLived Climate Pollutants Reduction Strategy that lays out a range of options to reduce SLCP emissions in California, including regulations, incentives, and other market-supporting activities. The SLCP Strategy was also informed of the 2017 Scoping Plan (CARB 2017d).

Senate Bill 97 (CEQA Guidelines)
SB 97 required OPR to prepare amended CEQA Guidelines for submission to the California Natural Resources Agency (CNRA) regarding GHG analysis and feasible mitigation of the effects of GHG emissions as required by CEQA. These amendments became effective as of March 18, 2010 (CNRA SB 97). The State CEQA guidelines were also more recently amended as of December 2018; this amendment include several changes in State CEQA Guidelines Section 15064.4, which discusses determining the significance of impacts from GHG emissions, in order to reflect current case law on climate change analysis and help the public and policymakers understand a project’s potential contribution to climate change. (CNRA 2018, pp. 17-20).

The current State CEQA Guidelines adopted pursuant to the 2010 and 2018 amendments state in Section 15064.4(a) that lead agencies should "make a good faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate" GHG emissions. State CEQA Guidelines Section 15064.4(a) notes that an agency may identify emissions by either quantifying the emissions or by relying on "qualitative analysis or other performance based standards." City of Riverside Section 5.5
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State CEQA Guidelines Section 15064.4(b) provides that the lead agency should consider the following when assessing the significance of impacts from GHG emissions on the environment:
 The extent a project may increase or reduce GHG emissions as compared to the environmental setting.
 Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
 The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

In addition, Section 15064.7(c) of the State CEQA Guidelines specifies that "[w]hen adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence". Similarly, the 2010 revision to Appendix G, Environmental Checklist Form which is often used as a basis for lead agencies' selection of significance thresholds, does not prescribe specific thresholds (there were no revisions to the GHG emissions thresholds in the 2018 State CEQA Guideline amendments). Rather, Appendix G asks whether the project would conflict with a plan, policy, or regulation adopted to reduce GHG emissions or generate GHG emissions that would significantly affect the environment, indicating that the determination of what is a significant effect on the environment should be left to the lead agency.

Accordingly, the State CEQA Guidelines Section 15064 do not prescribe specific methodologies for performing an assessment of GHG impacts, do not establish specific thresholds of significance, and do not mandate specific mitigation measures. Rather, it emphasizes the lead agency's discretion to determine the appropriate thresholds of significance consistent with the manner in which other impact areas are handled in CEQA.

The State CEQA Guidelines Section 15126.4(c) indicate that lead agencies should consider all feasible means, supported by substantial evidence and subject to monitoring and reporting, of mitigating the significant effects of GHG emissions. As pertinent to a project, these potential mitigation measures set forth in Section 15126.4(c), may include (1) measures in an existing plan or mitigation program for the reduction of GHG emissions that are required as part of the lead agency's decision; (2) reductions in GHG emissions resulting from a project through implementation of project features or project design; (3) off-site measures, including offsets, to mitigate a project's emissions; (4) measures that sequester greenhouse gas; and (5) In the case of the adoption of a plan, such as a general plan, long range development plan, or plans for the reduction of greenhouse gas emissions, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions.

Energy-Related Sources
Renewable Portfolio Standards
Established in 2002 under SB 1078, accelerated in 2006 under SB 107 and again in 2011 under SBX1-2, California's Renewable Portfolio Standard (RPS) requires retail sellers of electric services to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020 (SB 1078, SB 1368). The 33 percent standard is consistent with the RPS goal established in the Scoping Plan (CARB 2008). As interim measures, the RPS requires 20 percent of retail sales to be sourced from renewable energy by 2013 and 25 percent by 2016. Initially, the RPS provisions applied to investor- Section 5.5 City of Riverside
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owned utilities, community choice aggregators, and electric service providers. SBX1-2 added, for the first time, publicly owned utilities to the entities subject to RPS.

Senate Bill 350 (SB 350), signed in 2015, increased the RPS from 33 percent in 2020 to 50 percent by 2030 and will double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation by 2030. (CARB 2017c, p. 2) Senate Bill 100 (SB 100) was subsequently signed in 2018 and directs the California Public Utilities Commission (CPUC), California Energy Commission (CEC), and CARB to plan for 100 percent of total retail sales of electricity in California to come from eligible renewable energy resources and zero-carbon resources by December 31, 2045. SB 100 also accelerates the RPS target to 50 percent by 2026 and to 60 percent by 2030. (SB-100)
Assembly Bill 1109
Assembly Bill 1109 (AB 1109), the Lighting Efficiency and Toxic Reduction Act, required the establishment of minimum energy efficiency standards for all general purpose lights. The standards are structured to reduce average statewide electrical energy consumption by not less than 50 percent from the 2007 levels for indoor residential lighting and not less than 25 percent from the 2007 levels for indoor commercial and outdoor lighting by 2018.

Senate Bill 350
Senate Bill 350 (SB 350), signed October 7, 2015, is the Clean Energy and Pollution Reduction Act of 2015. SB 350 is the implementation of some of the goals of EO B-30-15. The objectives of SB 350 are,

1. To increase from 33 percent to 50 percent, the procurement of our electricity from renewable sources.

2. To double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation.

Mobile Sources
Mobile Source Reductions (AB 1493)
Assembly Bill 1493 ("the Pavley Standard" or AB 1493) required CARB to adopt regulations by January 1, 2005, to reduce GHG emissions from non-commercial passenger vehicles and light-duty trucks of model year 2009 through 2016. The bill also required the California Climate Action Registry to develop and adopt protocols for the reporting and certification of GHG emissions reductions from mobile sources for use by CARB in granting emission reduction credits. The bill authorizes CARB to grant emission reduction credits for reductions of GHG emissions prior to the date of enforcement of regulations, using model year 2000 as the starting point for reduction.

In 2004, CARB applied to the EPA for a waiver under the federal Clean Air Act to authorize implementation of these regulations. The waiver request was formally denied by the USEPA in December 2007 after California filed suit to prompt federal action. In January 2008, the State Attorney General filed a new lawsuit against the EPA for denying California's request for a waiver to regulate and limit GHG emissions from these vehicles. In January 2009, President Barack Obama issued a directive to the EPA to reconsider California's request for a waiver. On June 30, 2009, the EPA granted the waiver to California for its GHG emission standards for motor vehicles. As part of this waiver, EPA specified the following provision: CARB may not hold a manufacturer liable or responsible for any noncompliance caused by emission debits generated by a manufacturer for the 2009 model year. CARB has adopted a new approach to passenger vehicles (cars and light trucks) by combining the control of smog-causing City of Riverside Section 5.5
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pollutants and GHG emissions into a single coordinated package of standards. The new approach also includes efforts to support and accelerate the numbers of plug-in hybrids and zero-emission vehicles in California. These standards will apply to all passenger and light duty trucks used by customers, employees of and deliveries to the proposed Project.

Low Carbon Fuel Standard
Executive Order S-01-07 was signed on January 18, 2007, the Low Carbon Fuel Standard (LCFS) and mandated a statewide goal be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020. In 2009, CARB adopted the LCFS and began implementation on January 1, 2011.

CARB approved some amendments to the LCFS in December 2011, which were implemented on January 1, 2013. In September 2015, the Board approved the re-adoption of the LCFS, which became effective on January 1, 2016, to address procedural deficiencies in the way the original regulation was adopted. In 2018, the Board approved amendments to the regulation, which included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with California's 2030 GHG emission reduction target enacted through SB 32, adding new crediting opportunities to promote zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector. (CARB 2023a).

Advanced Clean Cars
In January 2012, CARB approved the Advanced Clean Cars Program, a new emissions-control program for model year 2017 through 2025.

The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero-emission vehicles. By 2025, when the rules will be fully implemented, the new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smog-forming emissions.

The program also requires car manufacturers to offer for sale an increasing number of zero-emission vehicles (ZEVs) each year, including battery electric, fuel cell, and plug-in hybrid electric vehicles.

In December 2012, CARB adopted regulations allowing car manufacturers to comply with California's GHG emissions requirements for model years 2017-2025 through compliance with the EPA GHG requirements for those same model years (CARB 2012). In 2022, the Advanced Clean Cars II program was approved, which will rapidly scale down light-duty passenger car, pickup truck and SUV emissions starting with the 2026 model year through 2035. By 2035 all new passenger cars, trucks and SUVs sold in California will have zero emissions. (CARB 2022b)
Transportation Fuel: Phased-In Cap-and-Trade Compliance Obligation Pursuant to AB 32, CARB was allowed, but not required, to include among mechanisms intended to reduce GHG emissions a "system of market-based declining annual aggregate emission limits." As noted above, CARB developed a Scoping Plan that directed CARB staff to develop, among other programs, a cap-and-trade mechanism that would apply a declining aggregate cap on GHG emissions and provide a flexible compliance system using tradable instruments. On October 20, 2011, CARB adopted the final cap-and-trade regulation (CCR Title 17, Subchapter 10, Article 5). The program will impose a “cap” on the total GHG emissions from covered entities in the state and the quantity of emissions allowed under the cap will decrease each year, ultimately reaching the goal of returning statewide GHG emissions to 1990 levels by 2020. The quantity of allowed emissions actually increases between 2014 and 2015, but that is to account for the addition of the fuel importers and distributors and Section 5.5 City of Riverside
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additional electricity importers to the program as discussed below. The net effect is to reduce overall GHG emissions.

The Cap-and-Trade Program started on January 1, 2012 and will proceed in “compliance phases,” the first of which began on January 1, 2013. In the first phase, the program applies to electric utilities, importers of electricity, and specified industries, including refineries. Approximately 350 electric utilities and approximately 600 industrial facilities were included in the initial phase of the program. In 2015, importers and distributors of fossil fuels were added to the program in the second phase. Specifically, on January 1, 2015, cap-and-trade compliance obligations were phased in for suppliers of natural gas, reformulated gasoline blend stock for oxygenate blending (RBOB), distillate fuel oils, and liquefied petroleum gas that meet or exceed specified emissions thresholds. The threshold that triggers a capand-trade compliance obligation for a fuel supplier is 25,000 metric tonnes or more of CO2e annually from the GHG emissions that would result from full combustion or oxidation of quantities of fuels (including natural gas, RBOB, distillate fuel oil, liquefied petroleum gas, and blended fuels that contain these fuels) imported and/or delivered to California. Phasing in of cap-and-trade compliance obligations for transportation fuel providers further reduces GHG emissions attributable to mobile sources, beyond the GHG emissions reductions achieved by the Pavley Standard, LCFS, and Advanced Clean Cars Program discussed above. This analysis does not incorporate GHG emissions reductions based on capand-trade compliance obligations applicable to transportation fuel suppliers.

Building Standards
California Energy Code (California Code of Regulations, Title 24) The California Energy Code (CCR Title 24, Part 6) was established in 1978 to reduce California’s energy consumption. Energy use standards in the code, referred to as Building Energy Efficiency Standards, are updated on an approximately three-year cycle (CEC Standards).

These efficiency standards (commonly referred to as Title 24 standards) apply to newly constructed buildings and additions and alterations to existing buildings. (CEC 2022). They are designed to reduce wasteful, uneconomic, inefficient, or unnecessary consumption of energy, and enhance outdoor and indoor environmental quality. The current 2022 Building Energy Efficiency Standards, which went into effect January 1, 2023, focuses on four key areas in new construction of homes and business by encouraging 1) electric heat pump technology and use, 2) establishing electric-ready requirements when natural gas is installed, 3) expanding solar photovoltaic (PV) system and battery storage standards, and 4) strengthening ventilation standards to improve indoor air quality. Specifically, the 2022 updates require all new homes be electric-ready. That means buildings with gas stoves have electrical panels and wiring to support a switch to electric stoves. Further advancements and cost reductions will continue to expand electric options for heating, cooking, laundering, and electric vehicle (EV) charging to meet all Californians’ needs. (CEC 2022) The Project will be subject to the Title 24 Standards in effect at the time of building permits.

It is projected that the 2022 building efficiency standards will reduce 10 million metric tons of GHGs over 30 years. This reduction is equivalent to taking nearly 2.2 million cars off the road for a year. (CEC 2022) California’s Appliance Efficiency Regulations (CCR Title 20, Parts 1600–1608) contain energy performance, energy design, water performance, and water design standards for appliances (including refrigerators, ice makers, vending machines, freezers, water heaters, fans, boilers, washing machines, dryers, air conditioners, pool equipment, and plumbing fittings) that are sold or offered for sale in California. (CEC Title 20)
City of Riverside Section 5.5
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Green Building Standards
Part 11 of the California Green Building Standards Code in Title 24 of the CCR is also known as the CALGreen Code. The development of the CALGreen Code is intended to: (1) cause a reduction in greenhouse gas emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the Governor.

The CALGreen Code requires waste reduction measures including: providing readily accessible areas that serve the entire building and are identified for the depositing, storage and collection of nonhazardous materials for recycling, and a minimum 65 percent diversion of construction and demolition waste from landfills. Water reduction measures include: separate water meters for buildings in excess of 50,000 square feet; moisture-sensing irrigation systems for larger landscaped areas; and the reduction of generation of wastewater by either installing water-conserving fixtures or using nonpotable water systems. Pollution reduction measures include requiring low-pollutant emitting interior finish materials such as paints, carpet, vinyl flooring, and particleboard.

The 2022 CALGreen Code (CCR, Title 24, Part 11) became effective January 1, 2023. (CBSC 2022).

Specific sections of the CALGreen Code that are applicable to this Project include, but are not limited to:

Non-Residential
CALGreen Section 5.106.4: Bicycle parking. Comply with Sections 5.106.4.1 and 5.106.4.1.2 or meet local ordinance, whichever is stricter.

5.106.4.1 Short-term bicycle parking. If the project is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5 percent of visitor motorized vehicle parking capacity, with a minimum of one two-bike capacity rack.

5.106.4.1.2 Long-term bicycle parking. For buildings with over 10 tenant-occupants, provide secure bicycle parking for 5 percent of motorized vehicle parking capacity, with a minimum of one space. Acceptable parking facilities shall be convenient from the street and may include: 1.

Covered, lockable enclosures with permanently anchored racks for bicycles; 2. Lockable bicycle rooms with permanently anchored racks; and 3. Lockable, permanently anchored bicycle lockers. Note: Additional information on recommended bicycle accommodations may be obtained from Sacramento Area Bicycle Advocates.

CALGreen Section 5.106.5.3: Construction to provide electric vehicle infrastructure and facilitate electric vehicle charging shall comply with Section 5.106.5.3.1 and shall be provided in accordance with regulations in the California Building Code and the California Electrical Code.

5.106.5.3.1 Electric Vehicle (EV) Capable spaces shall be provided in accordance with Table

5.106.5.3.1(provided below) and the following requirements:

1. Raceways complying with the California Electrical Code and no less than 1-inch (25 mm) diameter shall be provide and shall originate at a service panel or subpanel(s) serving the area and shall terminate in close proximity to the proposed location of the EV Capable space and into a suitable listed cabinet, box, enclosure or equivalent. A common raceway may be used to serve multiple EV capable spaces.

2. A service panel or subpanel(s) shall be provided with panel space and electrical load capacity dedicated 208/240 volt, 40-ampere minimum branch circuit for each EV Section 5.5 City of Riverside
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capable space, with delivery of 30-ampere minimum to an installed Electrical Vehicle Supply Equipment (EVSE) at each Electric Vehicle Charging Station (EVCS)

3. The electrical system and any on-site distribution transformers shall have sufficient capacity to supply full rated amperage at each EV capable space.

4. The service panel or subpanel circuit directory shall identify the reserved overcurrent protective device space(s) as “EV CAPABLE.” The raceway termination location shall be permanently and visibly marked as “EV CAPABLE.”
CALGreen Code Table 5.106.5.3.1 shows the number of parking spaces required EV Capable Spaces and the number of EV Capable Spaces provided with EVSE. Table 5.5-B, CALGreen Code Electric Vehicle Charging Space Calculation, is reflected below.

Table 5.5-B, CALGreen Code Electric Vehicle Charging Space Calculation Total Number of Actual Parking Spaces Number of Required Capable Spaces Number of EVCS
0-9 0 0
10-25 4 0
26-50 8 2
51-75 13 3
76-10 17 4
101-150 25 6
151-200 35 9
201 and over 20 percent of total1 25 percent of EV capable spaces1 Source: CBSC 2022
Notes:

1. Calculation for spaces shall be rounded up to the nearest whole number.

CALGreen Section 5.106.5.4: EV charging: medium-duty and heavy-duty. Construction shall comply with Section 5.106.5.4.1 to facilitate future installation of EVSE. Construction for warehouses, grocery stores and retail stores with planned off-street loading spaces shall also comply with Section 5.106.5.4.1 for future installation of medium- and heavy-duty EVSE.
 5.106.5.4.1 EV charging readiness requirements for warehouses, grocery stores and retail stores with planned off-street loading spaces. In order to avoid future demolition when adding EV supply and distribution equipment, spare raceway(s) or busway(s) and adequate capacity for transformer(s), service panel(s) or subpanel(s) shall be installed at the time of construction in accordance with the California Electrical Code. Construction plans and specifications shall include, but are not limited to, the following:

1. The transformer, main service equipment and subpanels shall meet the minimum power requirement in Table 5.106.5.4.1 to accommodate the dedicated branch circuits for the future installation of EVSE.

2. The construction documents shall indicate one or more location(s) convenient to the planned off-street loading space(s) reserved for medium- and heavy-duty ZEV charging cabinets and charging dispensers, and a pathway reserved for routing of conduit from City of Riverside Section 5.5
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the termination of the raceway(s) or busway(s) to the charging cabinet(s) and dispenser(s), as shown in Table 5.106.5.4.1.

3. Raceway(s) or busway(s) originating at a main service panel or a subpanel(s) serving the area where the potential future medium- and heavy-duty EVSE will be located and shall terminate in close proximity to the potential future location of the charging equipment for medium- and heavy-duty vehicles.

4. The raceway(s) or busway(s) shall be of sufficient size to carry the minimum additional service load to the future location of the charging for medium- and heavy-duty ZEVs as shown in Table 5.106.5.4.1.

CALGreen Code Table 5.106.5.3.1 shows the raceway conduit and panel power requirements for medium- and heavy-duty EVSE. Table 5.5-C, CALGreen Code Requirements for Medium- and Heavy-Duty EVSE, is reflected below.

Table 5.5-C, CALGreen Code Requirements for Medium- and Heavy-Duty EVSE Building Type Building Size (SQ. FT) Number of Off-Street Loading Spaces
Additional Capacity
Required (KVA) for
Raceway & Busway and
Transformer & Panel
Grocery 10,000 to 90,000
1 or 2 200
3 or Greater 400
Greater than 90,000 1 or Greater 400
Retail 10,000 to 135,000
1 or 2 200
3 or Greater 400
Greater than 135,000 1 or Greater 400
Warehouse 20,000 to 256,000
1 or 2 200
3 or Greater 400
Greater than 256,000 1 or Greater 400
Source: CBSC 2022
CALGreen Section 5.504.5.3: Filters. In mechanically ventilated buildings, provide regularly occupied areas of the building with air filtration media for outside and return air that provides at least a Minimum Efficiency Reporting Value (MERV) of 13. MERV 13 filters shall be installed prior to occupancy, and recommendations for maintenance with filters of the same value shall be included in the operation and maintenance manual.

Residential
CALGreen Section 4.106.4: EV charging for new construction. New construction shall comply with Sections 4.106.4.1 or 4.106.4.2 to facilitate future installation and use of EV chargers. EVSE shall be installed in accordance with the California Electrical Code.

4.106.4.1 New one- and two-family dwellings and townhouses with attached private garages. For each dwelling unit, install a listed raceway to accommodate a dedicated 208/240-volt branch circuit.

The raceway shall not be less than trade size 1 (nominal 1-inch inside diameter). The raceway shall originate at the main service or subpanel and shall terminate into a listed cabinet, box, or other enclosure in close proximity to the proposed location of an EV charger. Raceways are required to be continuous at enclosed, inaccessible, or concealed areas and spaces. The service panel and/or Section 5.5 City of Riverside
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subpanel shall provide capacity to install a 40-ampere 208/240-volt minimum dedicated branch circuit and space(s) reserved to permit installation of a branch circuit overcurrent protective device.

4.106.4.2 New multifamily dwellings, hotels, and motels and new residential parking facilities. When parking is provided parking spaces for new multifamily dwellings, hotels and motels shall meet the requirements of Section 4.106.4.2.1 and 4.106.4.2.2. Calculations for spaces shall be rounded up to the nearest whole number. A parking space served by electric vehicle supply equipment or designed as a future EV charging space shall count as at least one standard automobile parking space only for purpose of complying with any applicable minimum parking space requirements established by a local jurisdiction. See Vehicle Code Section 22511.2 for further details.

4.106.4.2.1 Multifamily development projects with less than 20 dwelling units; and hotels and motels with less than 20 sleeping units or guest rooms. The number of dwelling units, sleeping units or guest rooms shall be based on all buildings on a project site subject to this section.

1. EV Capable. Ten (10) percent of the total number of parking spaces on a building site, provided for all types of parking facilities, shall be electric vehicle charging spaces (EV spaces) capable of supporting future Level 2 EVSE. Electrical load calculations shall demonstrate that the electrical panel service capacity and electrical system, including any on-site distribution transformer(s), have sufficient capacity to simultaneously charge all EVs at all required EV spaces at a minimum of 40 amperes. The service panel or subpanel circuit directory shall identify the overcurrent protective device space(s) reserved for future EV charging purposes as “EV CAPABLE” in accordance with the California Electrical Code.

2. EV Ready. Twenty-five (25) percent of the total number of parking spaces shall be equipped with low power Level 2 EV charging receptacles. For multifamily parking facilities, no more than one receptacle is required per dwelling unit when more than one parking space is provided for use by a single dwelling unit.

4.106.4.2.2 Multifamily development projects with 20 or more dwelling units, hotels, and motels with 20 or more sleeping units or guest rooms. The number of dwelling units, sleeping units or guest rooms shall be based on all buildings on a project site subject to this section.

1. EV Capable. Ten (10) percent of the total number of parking spaces on a building site, provided for all types of parking facilities, shall be electric vehicle charging spaces (EV spaces) capable of supporting future Level 2 EVSE. Electrical load calculations shall demonstrate that the electrical panel service capacity and electrical system, including any on-site distribution transformer(s), have sufficient capacity to simultaneously charge all EVs at all required EV spaces at a minimum of 40 amperes. The service panel or subpanel circuit directory shall identify the overcurrent protective device space(s) reserved for future EV charging purposes as “EV CAPABLE” in accordance with the California Electrical Code.

2. EV Ready. Twenty-five (25) percent of the total number of parking spaces shall be equipped with low power Level 2 EV charging receptacles. For multifamily parking facilities, no more than one receptacle is required per dwelling unit when more than one parking space is provided for use by a single dwelling unit.

3. EV Chargers. Five (5) percent of the total number of parking spaces shall be equipped with Level 2 EVSE. Where common use parking is provided, at least one EV charger City of Riverside Section 5.5
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shall be located in the common use parking area and shall be available for use by all residents or guests.

When low power Level 2 EV charging receptacles or Level 2 EVSE are installed beyond the minimum required, an automatic load management system (ALMS) may be used to reduce the maximum required electrical capacity to each space served by the ALMS.

The electrical system and any on-site distribution transformers shall have sufficient capacity to deliver at least 3.3 kW simultaneously to each EV charging station (EVCS) served by the ALMS. The branch circuit shall have a minimum capacity of 40 amperes and installed EVSE shall have a capacity of not less than 30 amperes. ALMS shall not be used to reduce the minimum required electrical capacity to the required EV capable spaces.

4.106.4.2.2.1 Electric vehicle charging stations (EVCS). Electric vehicle charging stations required by Section 4.106.4.2.2.1.2 Item 3, shall comply with Section 4.106.4.2.2.1.1.

4.106.4.2.2.1.1 Location. EVCS shall comply with at least one of the following options:

1. The charging space shall be located adjacent to an accessible parking space meeting the requirements of the California Building Code, Chapter 11A, to allow use of the EV charger from the accessible parking space.

2. The charging space shall be located on an accessible route, as defined in the California Building Code, Chapter 2, to the building.

Waste Diversion
California Integrated Waste Management Act of 1989
The California Integrated Waste Management Act of 1989 (Public Resources Code Sections 40000 et seq.) requires each jurisdiction's source reduction and recycling element to include an implementation schedule that shows (1) diversion of 25 percent of all solid waste by January 1, 1995, through source reduction, recycling, and composting activities; and (2) diversion of 50 percent of all solid waste on and after January 1, 2000, through source reduction, recycling, and composting facilities.2 Additionally,
jurisdictions are not prohibited from implementing source reduction, recycling, and composting activities designed to exceed these requirements.3
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75 percent of solid waste generated be source reduced, recycled, or composted by the year 2020, and annually thereafter.4 In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state's policy goal.5
Other Potentially Applicable State Regulations or Policies Executive Order S-13-08
On November 14, 2008, Governor Arnold Schwarzenegger signed Executive Order S-13-08 which called on state agencies to develop a strategy for identification of and preparation for expected climate change impacts in California. The resulting 2009 California Climate Adaptation Strategy (CAS) report was developed by the CNRA in coordination with the Climate Action Team (CAT). The report presents the 2 Cal. Pub. Res. Code § 41780(a).
3 Cal. Pub. Res. Code § 41780(b).
4 Cal. Pub. Res. Code § 41780.01(a).
5 Cal. Pub. Res. Code § 41780.02.

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best available science relevant to climate impacts in California and proposes a set of recommendations for California decision-makers to assess vulnerability and promote resiliency in order to reduce California's vulnerability to climate change. Guidance regarding adaptation strategies is general in nature and emphasizes incorporation of strategies into existing planning policies and processes.

In addition to requiring the CAT to create a Climate Adaptation Strategy, Executive Order S-13-08 ordered the creation of a comprehensive Sea Level Rise Assessment Report. The report, published in June 2012, indicates that the sea level along most of California's coast is expected to rise about one meter over the next century and is likely to increase the risk of damage in the form of flooding, coastal erosion, and wetland loss due to storm surges and high waves. The sea level increase is slightly higher than projected for global sea levels (NRC, 2012; ONPI 2012).

Executive Order S-13-08 also called for the California Ocean Protection Council (OPC) to work with the other CAT State agencies to develop interim guidance for assessing the potential impacts of sea level rise due to climate change in California. In coordination with National Academy of Sciences (NAS) efforts, the OPC drafted interim guidance recommending that state agencies consider a range of sea level rise scenarios for the years 2050 and 2100 in order to assess project vulnerability, reduce expected risks, and increase resiliency to sea level rise. The draft resolution and interim guidance document is consistent with the Ocean Protection Act (Division 26.5, Public Resource Code Section 3561 5(a)(1)), which specifically directs the OPC to coordinate activities of state agencies to improve the effectiveness of state efforts to protect ocean resources. An update to the 2009 CAS report, the final "Safeguarding California Plan," was published in July 2014.6
Senate Bill X7-7 (Water Conservation Act of 2009)
The Water Conservation Act of 2009 sets an overall goal of reducing per-capita urban water use by 20 percent by December 31, 2020. The state was required to make incremental progress toward this goal by reducing per-capita water use by at least 10 percent by December 31, 2015. Reduction in water consumption directly reduces the energy necessary and the associated emissions to convene, treat, and distribute the water and it also reduces emissions from wastewater treatment.

The Department of Water Resources adopted a regulation on February 16, 2011 that sets forth criteria and methods for exclusion of industrial process water from the calculation of gross water use for purposes of urban water management planning. The regulation would apply to all urban retail water suppliers required to submit an Urban Water Management Plan, as set forth in the Water Code, Division 6, Part 2.6, Sections 10617 and 10620.

Model Water Efficient Landscape Ordinance
The Model Water Efficient Landscape Ordinance (Ordinance) was required by AB 1881, the Water Conservation Act. The bill required local agencies to adopt a local landscape ordinance at least as effective in conserving water as the Model Ordinance by January 1, 2010. Reductions in water use of 20 percent consistent with (SBX7-7) 2020 mandate are expected upon compliance with the Ordinance.

Governor Brown’s Drought Executive Order of April 1, 2015 (EO B-29-15) directed DWR to update the Ordinance through expedited regulation. The California Water Commission approved the revised Ordinance, which became effective December 15, 2015. New development projects that include landscape areas of 500 square feet or more are subject to the Ordinance. The update requires: more efficient irrigation systems; incentives for graywater usage; improvements in on-site stormwater capture; 6 State of California, http://resources.ca.gov/docs/climate/Final_Safeguarding_CA_Plan_July_31_2014.pdf.

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limiting the portion of landscapes that can be planted with high water use plants; and reporting requirements for local agencies.

The City of Riverside has codified landscaping and irrigation requirements under Water Efficient Landscaping and Irrigation in Title 19, Chapter 19.570 of the City Municipal Code.

CARB Refrigerant Management Program
CARB adopted a regulation in 2009 to reduce refrigerant GHG emissions from stationary sources through refrigerant leak detection and monitoring, leak repair, system retirement and retrofitting, reporting and recordkeeping, and proper refrigerant cylinder use, sale, and disposal. The regulation is set forth in sections 95380 to 95398 of Title 17, California Code of Regulations. The rules implementing the regulation establish a limit on statewide GHG emissions from stationary facilities with refrigeration systems with more than 50 pounds of a high GWP refrigerant. The refrigerant management program is designed to (1) reduce emissions of high-GWP GHG refrigerants from leaky stationary, non-residential refrigeration equipment; (2) reduce emissions from the installation and servicing of refrigeration and airconditioning appliances using high-GWP refrigerants; and (3) verify GHG emission reductions.

Regional Regulations
South Coast Air Quality Management District
SCAQMD is principally responsible for comprehensive air pollution control for Los Angeles, Orange, and the urbanized portions of Riverside and San Bernardino Counties, including the Project site. SCAQMD works directly with SCAG, County transportation commissions and local governments, and cooperates actively with all federal and state government agencies to regulate air quality.

In April 2008, SCAQMD convened a Working Group to develop GHG significance thresholds. On December 5, 2008, SCAQMD Governing Board adopted its staff proposal for an interim CEQA GHG significance threshold for projects where SCAQMD is the lead agency. As to all other projects where SCAQMD is not the lead agency, the Board has, to date, only adopted an interim threshold of 10,000 MTCO2E per year for industrial stationary source projects (SCAQMD 2008).

For all other projects, SCAQMD staff proposed a multiple tier analysis to determine the appropriate threshold to be used. The draft proposal suggests the following tiers: Tier 1 is any applicable CEQA exemptions; Tier 2 is consistency with a GHG reduction plan; Tier 3 is a screening value or bright line; Tier 4 is a performance based standard; and Tier 5 is GHG mitigation offsets (SCAQMD 2008).

According to the presentation given at the September 28, 2010 Working Group meeting, SCAQMD staff proposed a Tier 3 draft thresholds for residential, commercial, and mixed-use projects at 3,500, 1,400, and 3,000 MTCO2E/yr, respectively. Alternatively, a lead agency has the option to use 3,000 MTCO2E/yr as a threshold for all non-industrial projects. Although both options are recommended by SCAQMD, a lead agency is advised to use only one option and to use it consistently.. For the Tier 4 draft threshold, SCAQMD staff presented a percent emission reduction target option but did not provide any specific recommendation for a percent emission reduction target; instead, it referenced the San Joaquin Valley Air Pollution Control District (SJVAPCD) approach. The percent reduction target is based on consistency with AB 32 as it was based on the same numeric reductions calculated in the Scoping Plan to reach 1990 levels by 2020. The second Tier 4 option is to utilize an efficiency target for 2020 and 2035 of 4.8 and 3.0 metric tons per service population per year for project level thresholds (SCAQMD 2010).

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The Working Group has not convened since the fall of 2010. As of October 2023, the proposal has not been considered or approved for use by SCAQMD’s Board. In the meantime, no GHG significance thresholds are approved for use in the Basin.

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside 2025 General Plan contains objectives and policies that are considered applicable to the proposed Project, as identified below (GP 2025, pp. A-35, A-36, A-38; OS-54 – OS-55; PF-28):

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

Policy AQ-1.5 Encourage infill development projects within urbanized areas, which include job centers and transportation nodes.

Policy AQ-1.7 Support appropriate planned residential developments and infill housing, which reduce vehicle trips.

Objective AQ-5 Increase energy efficiency and conservation in an effort to reduce air pollution.

Policy AQ-5.1 Utilize source reduction, recycling, and other appropriate measures to reduce the amount of solid waste disposed of in landfills.

Policy AQ-5.3 Continue and expand use of renewable energy resources such as wind, solar, water, landfill gas, and geothermal sources.

Policy AQ-5.6 Support the use of automated equipment for conditioned facilities to control heating and air conditioning.

Policy AQ-5.7 Require residential building construction to meet or exceed energy use guidelines in Title 24 of the California Administrative Code.

Objective AQ-8 Make sustainability and global warming education a priority for the City’s effort to protect public health and achieve state and federal clean air standards.

Policy AQ-8.17 Develop measures to encourage that a minimum of 40% of the waste from all construction sites throughout Riverside be recycled by the end of 2008.

Open Space & Conservation Element
Policy OS-8.2 Require incorporation of energy conservation features in the design of all new construction and substantial rehabilitation projects pursuant to Title 24 and encourage the installation of conservation devices in existing developments.

Policy OS-8.3 Encourage private energy conservation programs that minimize high energy demand and that use alternative energy sources.

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Policy OS-8.4 Incorporate solar considerations into development regulations that allow existing and proposed buildings to use solar facilities.

Policy OS-8.5 Develop landscaping guidelines that support the use of vegetation for shading and wind reduction and otherwise help reduce energy consumption in new development for compatibility with renewable energy sources (i.e., solar pools).

Policy OS-8.6 Require all new development to incorporate energy efficient lighting, heating, and cooling systems pursuant to the Uniform Building Code and Title 24.

Policy OS-8.7 Encourage mixed use development as a means of reducing the need for auto travel.

Policy OS-8.10 Support the use of public transportation, bicycling and other alternative transportation modes in order to reduce the consumption of non-renewable energy supplies.

Policy OS-8.12 Require bicycle parking in new non-residential development.

Public Facilities and Infrastructure Element
Objective PF-6 Provide affordable, reliable, and, to the extent practical, environmentally sensitive energy resources to residents and businesses.

Policy PF-6.3 Promote and encourage energy conservation.

Policy PF-6.4 Encourage energy-efficient development through its site plan and building design standard guidelines.

Policy PF-6.5 Promote green building design.

City of Riverside 2025 General Plan EIR
The are no applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to Greenhouse Gas Emissions.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to the proposed Project.

City of Riverside Municipal Code
The following sections of the City’s Municipal Code are applicable and pertain to GHG emissions:

Chapter 16.26 – Electrification of New Buildings. The City requires building electrification in certain newly constructed buildings. New building permits filed after January 6, 2023 for buildings three stories or less require electrification and buildings four or more stories are subject to this requirement in January 2026.

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Chapter 19.570 – Water Efficient Landscaping and Irrigation. The City has codified landscaping and irrigation requirements to increase water use efficiency and promote the use of recycled water.

City of Riverside Restorative Growthprint
The Riverside Restorative Growthprint, adopted January 2016, consists of the City’s Economic Prosperity Action Plan and Climate Action Plan (CAP), which work in conjunction to spur entrepreneurship and smart growth while advancing the City’s GHG emission reduction goals through the year 2035 (RRG). The CAP prioritizes the implementation of policies that enable the City to fulfill the requirements of State initiatives, Assembly Bill 32 and Senate Bill 375. The CAP includes a baseline GHG inventory for local government operations and for the community as a whole and establishes emission reduction targets consistent with State law. Through stakeholder engagement and cost-benefit analysis, the CAP resulted in strategies, measures, and actions for reducing emissions that align with the City’s planning priorities and its vision of a future economy based on clean, green businesses and business practices.

Envision Riverside 2025, City of Riverside Strategic Plan The City’s 2025 Strategic Plan, known as Envision Riverside, identifies a clear vision for the future of Riverside’s Economy, Community and Environment. It is comprised of the City Council’s strategic policies and operational workplan to advance the City’s potential. One of the six priorities of Envision Riverside is Environmental Stewardship, with one of the major themes being Sustainability and Resiliency. Environmental Stewardship goals include: rapidly decreasing Riversides’ carbon footprint by acting urgently to reach a zero carbon electric grid with the goal of reaching 100% zero cardon electricity production by 2040 with continuing to ensure safe, reliable, and affordable energy for all residents; and implementing the requisite measures to achieve citywide carbon neutrality no later than 2040.

5.5.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding greenhouse gas emissions in response to the Initial Study/Notice of Preparation (IS/NOP).

5.5.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the thresholds of significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines. However, in the case for GHG emissions to be analyzed for the purpose of CEQA, the City of Riverside does use the 3,000 MTCO2E/yr threshold to determine significance, and hence will be used as the threshold for this Project.

As identified in the Initial Study (Appendix A) prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and
 Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.

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5.5.5 Project Design Features
The proposed Project will be designed and constructed to meet all applicable standards under CALGreen, Title 24, and Municipal Code 16.26 (Electrification of New Buildings), as described in Section

5.5.2, above. In particular, the Project will include the following design features:
• Rooftop and carport solar (PV) panels, consistent with the 2022 CALGreen code; • Residential appliances installed by the developer will be Energy Star-rated; and • Waste reduction program.

Where possible, these features have been quantified in the Project’s GHG emissions estimates, as described in Section 5.5.7, below.

5.5.6 Methodology
The Technical Memorandum – Air Quality/Greenhouse Gas Analysis for Arlington Mixed Use Development Project (WEBB-A), was prepared for the proposed Project by Albert A. Webb Associates dated October 27, 2023 (included as Appendix B). The methodology used within the analysis is consistent with draft guidance prepared by the South Coast Air Quality Management District (SCAQMD) for quantification of emissions and evaluation of potential impacts related to GHG emissions. As recommended by SCAQMD staff, the California Emissions Estimator Model (CalEEModTM) version 2022.1 program was used to quantify project-related emissions from short-term construction and longterm operation.

Amendments to CEQA Guidelines Section 15064.4 were adopted to assist lead agencies in determining the significance of the impacts of GHG emissions. Consistent with existing CEQA practice, Section 15064.4 gives lead agencies the discretion to determine whether to assess those emissions quantitatively or qualitatively. The amendments do not establish a threshold of significance; rather, lead agencies are granted discretion to establish significance thresholds for their respective jurisdictions, including looking to thresholds developed by other public agencies or suggested by other experts, such as the California Air Pollution Control Officers Association (CAPCOA), so long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7(c)). The CNRA has also clarified that the CEQA Guidelines amendments focus on the effects of GHG emissions as cumulative impacts, and therefore GHG emissions should be analyzed in the context of CEQA’s requirements for cumulative impact analyses (see CEQA Guidelines Section 15064(h)(3)). A project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements to avoid or substantially lessen the cumulative problem within the geographic area of the project.

The City has not formally adopted a numerical significance threshold for assessing impacts related to GHG emissions. Nor have the SCAQMD, CARB, or any other State or regional agency adopted a numerical significance threshold for assessing GHG emissions that is applicable to the Project. However, the City of Riverside utilizes the SCAQMD significance threshold of 3,000 MTCO2E/yr for non-industrial projects.

The analysis calculates the amount of GHG emissions that would be attributable to the project using recommended air quality model, as described above. The primary purpose of quantifying the project’s GHG emissions is to satisfy CEQA Guidelines Section 15064.4(a), which calls for a good-faith effort to describe and calculate emissions. The estimated emissions inventory is also used to determine if there Section 5.5 City of Riverside
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would be a reduction in the project’s incremental contribution of GHG emissions as a result of compliance with regulations and requirements adopted to implement plans for the reduction or mitigation of GHG emissions.

5.5.7 Environmental Impacts
Threshold: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Short-Term Analysis
Construction-Related Emissions
The CalEEMod model calculates GHG emissions from fuel usage by construction equipment and construction-related activities, like construction worker trips, for the Project. CalEEMod also calculates the indirect GHG emissions related to electricity consumption. The CalEEMod output results for construction-related GHG emissions present the GHG emissions estimates for the Project for CO2, methane (CH4), nitrous oxide (N2O), refrigerants (R), and CO2e.7 Table 5.5-D, Project Construction Equipment GHG Emissions, summarizes the GHG emissions estimates for the Project in metric tons/year (MT/yr).

Table 5.5-D, Project Construction Equipment GHG Emissions Phase Metric Tons per year (MT/yr)
Total CO2 Total CH4 Total N2O Total R Total CO2E
2024 436 0.02 0.03 0.48 446
2025 1,281.10 0.05 0.06 1.41 1,303.20
2026 388 0.01 0.02 0.46 394
Total 2,105.10 0.08 0.11 2.35 2,143.20
Amortized1 71.44
Source: WEBB-A, Table 6
Note:

1. Construction emissions were amortized over a 30-year period, as recommended by SCAQMD.

Evaluation of Table 5.5-D indicates that an estimated 2,143.20 MTCO2E will occur from Project construction equipment over the course of the estimated construction period. Since the 2008 SCAQMD guidance document8 recommends that construction emissions be amortized for a project lifetime of 30 years to ensure that GHG reduction measures address construction GHG emissions as part of the operational reduction strategies, the total GHG emissions from Project construction were amortized and are included in Table 5.5-F, Total Unmitigated Project-Related Annual GHG Emissions, below.

Long-Term Analysis
Area Source Emissions
CalEEMod estimates the GHG emissions associated with area sources which include landscape equipment emissions, architectural coating, consumer products, and hearths. Landscape equipment servicing the Project site create CO2 resulting from fuel combustion based on the Project’s land uses.

Consumer products consist of consumer use of solvents and personal care products and architectural 7 CO2e is the sum of CO2 emissions estimated plus the sum of CH4, N2O, and refrigerant emissions estimated multiplied by their respective global warming potential (GWP). 8 https://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significancethresholds/ghgattachmente.pdf?sfvrsn=2 City of Riverside Section 5.5
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coatings consist of an average building square footage to be repainted each year. Hearth emissions apply to dwelling units; however, no fireplaces are proposed within the residential uses. Table 5.5-F summarizes the Project’s area source emissions.

Energy-Related Emissions
CalEEMod estimates the GHG emissions associated with building electricity and natural gas usage (nonhearth) for each land use type. Electricity and natural gas used in buildings is typically generated at an off-site power plant which indirectly generates GHG emissions. The default energy usage values used in CalEEMod are based on the CEC sponsored California Commercial End Use Survey and Residential Appliance Saturation Survey studies and reflect 2019 Title 24 improvements. As previously stated in Section 5.5.2, building electrification is required for the Project pursuant to the City’s municipal code (Chapter 16.26). Accordingly, CalEEMod mitigation measure E-15, which requires all electric development is incorporated as part of Project design as listed above in Section 5.5.5. However, CalEEMod only quantifies reductions from the residential land use for this measure. Therefore, the natural gas emissions are overstated in the analysis herein.

Additionally, as stated in Section 5.5.5, the Project design also includes energy star-rated appliances in the residential buildings. Therefore, the CalEEMod mitigation measure E-2 was incorporated as part of Project design for installation of energy star-rated, refrigerators, dishwashers, washing machines, and ceiling fans.

Finally, the Project will incorporate solar panels on rooftops and/or carports consistent with the 2022 California Green Building Code, as stated in Section 5.5.5. The energy production from the Project’s solar panels was not quantified, therefore providing a more conservative estimate in the analysis presented herein of the energy-related emissions. Table 5.5-E, Energy-Related GHG Emissions, summarizes the energy-related GHG emissions estimates reported by CalEEMod for the Project.

Table 5.5-E, Energy-Related GHG Emissions
Source Metric Tons per year (MT/yr)
CO2 CH4 N2O Total CO2E
Electricity 764.00 0.05 0.00 768.00
Natural Gas 19.70 0.00 0.00 19.70
Total 783.70 0.05 0.00 787.70
Source: WEBB-A, Table 7
Note: Emissions reported are the sum of each Phase.

Mobile Source Emissions
CalEEMod estimates the annual GHG emissions from Project-related vehicle usage based on trip generation data contained in defaults or in a project-specific traffic analysis. CalEEMod also estimates the GHG emissions from refrigerant leakage from vehicle air conditioning (A/C) systems. A Projectspecific Traffic Impact Analysis (TIA) (included in Appendix F of the Draft EIR) was utilized for weekday trip rates and the most recent Institute of Traffic Engineers (ITE) Trip Generation Manual, 11th Edition, was used for weekend trip rates. CalEEMod defaults were utilized for pass-by and diverted trip types.

The TIA’s internal capture trip reduction of approximately 22 percent was not applied to residential and supermarket trips to be conservative. In addition, no reductions were taken for transit and pedestrian accessibility. Table 5.5-F shows the mobile source emissions of GHG from the Project.

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Solid Waste Emissions
CalEEMod also calculates the GHG emissions associated with the disposal of solid waste into landfills based on default data contained within the model for waste disposal rates, composition, and the characteristics of landfills throughout the state. A large percentage of this waste will be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting. The remainder of the waste not diverted will be disposed of at a landfill. The Project will include a waste reduction/recycling program; however, to provide a conservative analysis, no waste reduction was quantified. Table 5.5-F shows the solid waste GHG emissions from the Project.

Water-Related Energy Usage
Electricity is also indirectly used in water supply, treatment, and distribution, as well as wastewater treatment in Southern California and plays a large role in GHG production.

There are three processes necessary to supply potable water to urban users (i.e., residential, commercial, and industrial): (1) supply of the water from the source; (2) treatment of the water to potable standards; and (3) distribution of the water to individual users. After use, the wastewater is treated and either reused as reclaimed/recycled water or returned to the environment. CalEEMod calculates the GHG emissions from these processes based on default emissions factors and water/wastewater generation rates for a project’s location. CalEEMod defaults were utilized to model the Project’s water demand. Table 5.5-F shows the GHG emissions from water-related energy usage for the Project.

Total Project GHG Emissions
As shown on Table 5.5-F – Total Unmitigated Project-Related Annual GHG Emissions, using all the emissions quantified above, the total GHG emissions generated from the Project is approximately 7,347.37 MTCO2E/yr which includes construction-related emissions amortized over a typical project life of 30 years.

Table 5.5-F, Total Unmitigated Project-Related Annual GHG Emissions Source Metric Tons per year (MT/yr)
CO2 CH4 N2O R Total CO2E
Amortized Construction -- -- -- -- 71.44
Area 7.27 0.00 0.00 0.00 7.31
Energy 784.00 0.05 0.00 0.00 787.00
Mobile 5,511.00 0.26 0.27 9.01 5,609.00
Solid Waste 37.35 0.62 0.01 0.00 57.57
Water 41.40 4.14 0.00 0.00 144.40
Refrigerants 0.00 0.00 0.00 697.65 697.65
Total 6,381.02 5.07 0.28 706.66 7,374.37
Source: WEBB-A, Table 8
Note: Emissions reported as zero are rounded and not necessarily equal to zero.

As discussed in Section 5.5.6, the City has been using the SCAQMD’s 3,000 MTCO2E/yr draft threshold for non-industrial projects for the purpose of evaluating the GHG impacts associated with proposed general development projects. As shown in Table 5.5-F, the total GHG emissions from the Project exceed the SCAQMD threshold of 3,000 MTCO2E/yr.

As shown in Table 5.5-F, the Project’s mobile source GHG emissions make up approximately 76 percent of the estimated total Project-related GHG emissions. However, as discussed below, there are City of Riverside Section 5.5
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limited, if any, feasible mitigation measures that can be applied to the Project to substantially reduce the mobile source GHG emissions from the Project. Although the Project will comply with existing regulations such as Title 24 and the CALGreen code, reductions from compliance with these regulations has not been included in the emissions estimates in this analysis so that a conservative analysis of the Project’s GHG emissions can be presented. Specific design aspects not included in the emissions estimates, specifically those aimed at reducing mobile source emissions, would aide in the reduction of GHG emissions, but are beyond what is presented in this analysis.

Project design features such as the rooftop and/or carport solar would further reduce GHG emissions; although, the magnitude of GHG reductions would be relatively small because these features affect the building and on-site emissions reductions.

As discussed under the Mobile Source Emissions subheading, above, the internal trip reduction anticipated between the Project’s residential and retails uses (estimated to be approximately 22 percent in the TIA) was not estimated in the analysis to be conservative. The degree of GHG emissions reduction from the internal trips in addition to potential reductions from the Project’s existing transit and pedestrian accessibility along with the proposed on-site pedestrian improvements is not assured and the effect on GHG emissions would depend on the future residents and customers and employees of the retail uses.

It is also important to note that mobile source emissions are regulated at the state and federal level and the Project’s GHG emissions estimates reflect the Project’s opening year and as such do not account for future reductions that will occur through implementation of regulations such as the Advanced Clean Cars II program that requires 100 percent of new light-duty vehicle sales be zero emission (ZEV) by 2035.

There are mitigation measures that can be incorporated which focus on the mobile GHG emissions by reducing the amount of car trips that are used by the future Project residents. As outlined in Section

5.5.8, below, MM GHG-1 through MM GHG-3 attempt to reduce car trips from the Project by encouraging the use of alternative transportation and telecommuting. MM GHG-1 through MM GHG-3 do not have quantitative reductions associated with them available in CalEEMod and given that most of the Project-generated emissions are from mobile sources, the emissions are outside the control of the Project and City. Although mitigation measures MM GHG-1 through MM GHG-3 will serve to potentially reduce mobile source emissions, it is reasonable to assume that the amount of GHG reductions resulting from their implementation would not reduce Project emissions from the estimated 7,374 MTCO2E/yr to the 3,000 MTCO2E/yr threshold of significance. Thus. even with implementation of existing regulations, Project design features, and MM GHG-1 through MM GHG-3, the Project will generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Therefore impacts are significant and unavoidable even with mitigation incorporated.

Threshold: Would the Project conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emission of greenhouse gases? As explained in Section 5.5.6, above, pursuant to Section 15064.4 of the CEQA Guidelines, a lead agency may rely on qualitative analysis to determine the significance of impacts from GHG emissions. A project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements to avoid or substantially lessen the cumulative problem within the geographic area of the project. As such, the GHG plan consistency for the Project is based on the Project’s consistency with the SCAG’s Connect SoCal (2020-2045 RTP/SCS), the applicable 2025 General Plan goals and policies, the City’s CAP, and the 2022 Scoping Plan. The SCAG 2020-2045 RTP/SCS includes strategies for the Section 5.5 City of Riverside
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5.5-30
region to reach the regional target of reducing GHG from the transportation sector. The City’s CAP and General Plan contain strategies, goals, and policies that would help implement energy efficient, transportation, water efficient, and waste reduction measures and would subsequently reduce GHG emissions within the City. The 2022 Scoping Plan lays out a path to achieve targets for carbon neutrality and reduce GHG emissions by 85 percent below 1990 levels no later than 2045.

Consistency with SCAG Connect SoCal
Connect SoCal (2020-2045 RTP/SCS) includes performance goals that were adopted to help focus future investments on the best-performing projects, as well as different strategies to preserve, maintain, and optimize the performance of the existing transportation system. The Connect SoCal plan is forecast to help California reach its GHG reduction goals by reducing GHG emissions from passenger cars by eight percent below 2005 levels by 2020 and 19 percent by 2035 in accordance with the most recent CARB targets adopted in March 2018. Section 6.0 Consistency with Regional Plans of this Draft EIR includes Table 6.0-B¸ Table 6.0-B, Proposed Project Consistency with the Connect SoCal 2020- 2045 RTP/SCS Goals, which presents a side-by-side comparison of the Connect SoCal Goals and a discussion regarding the Project’s consistency, non-consistency, or non-applicability with each goal.

Table 6.0-B identifies that the proposed Project would be consistent with all applicable SCAG Connect SoCal policies.

City of Riverside General Plan
The General Plan identifies objectives and policies that encourage a reduction in the City’s overall GHG emissions. Table 5.5-G, Consistency with City of Riverside General Plan evaluates the Project’s consistency with applicable General Plan policies.

Table 5.5-G, Consistency with City of Riverside General Plan Relevant Objectives and Policies Project Consistency
Air Quality Element
Objective AQ-1: Adopt land use policies that site polluting facilities away from sensitive receptors and vice versa; improve job-housing balance; reduce vehicle miles traveled and length of work trips; and improve the flow of traffic.

Policy AQ-1.5 Encourage infill development
projects within urbanized areas, which include job
centers and transportation nodes.

Consistent: The Project is an infill and using an
existing developed site. The area surrounding
the Project site is developed and urbanized
with a variety of land uses, including
commercial, medium-high density residential,
high-density residential, office, and public
facilities.

Policy AQ-1.7: Support appropriate planned residential
developments and infill housing, which reduce vehicle
trips.

Consistent: The Project proposes infill
development of residential and commercialretail uses in an area already having other commercial uses to compliment the one’s
proposed by the Project. With the pedestrian
and bike lane connections proposed by the
Project, residents of the new development as
well as existing residents can reduce their
vehicle trips by walking or biking to support
services.

Objective AQ-5: Increase energy efficiency and conservation in an effort to reduce air pollution.

Policy AQ-5.1: Utilize source reduction, recycling, and other appropriate measures to reduce the amount of
solid waste disposed of in landfills.

Consistent: The Project will include a waste
reduction/recycling program
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Table 5.5-G, Consistency with City of Riverside General Plan Relevant Objectives and Policies Project Consistency
Policy AQ-5.3: Continue and expand use of renewable
energy resources such as wind, solar, water, landfill
gas, and geothermal sources.

Consistent: The Project will include rooftop
and carport solar (PV) panels.

Policy AQ-5.6: Support the use of automated
equipment for conditioned facilities to control heating and air conditioning.

Consistent: The Project will comply with the
latest Title 24 and CALGreen code that support
efficient heating and air conditioning systems.

Policy AQ-5.7: Require residential building
construction to meet or exceed energy use guidelines
in Title 24 of the California Administrative Code.

Consistent: The proposed Project will be
designed and constructed to meet all
applicable standards under Title 24.

Objective AQ-8: Make sustainability and global warming education a priority for the City’s effort to protect public health and achieve state and federal clean air standards.

Policy AQ-8.17: Develop measures to encourage that
a minimum of 40% of the waste from all construction
sites throughout Riverside be recycled by the end of
2008.

Consistent: The Project will comply with the
latest CALGreen code, which requires a
minimum of 65 percent of construction waste
be recycled.

Open Space & Conservation Element
Policy OS-8.2: Require incorporation of energy
conservation features in the design of all new
construction and substantial rehabilitation projects
pursuant to Title 24 and encourage the installation of
conservation devices in existing developments.

Consistent: The Project will be designed and
constructed to meet all the applicable
standards of Title 24.

Policy OS-8.3: Encourage private energy conservation
programs that minimize high energy demand and that
use alternative energy sources.

Consistent: The Project will include rooftop
and carport solar (PV) panels, consistent with
the current CALGreen code.

Policy OS-8.4: Incorporate solar considerations into
development regulations that allow existing and
proposed buildings to use solar facilities.

Consistent: The Project will include rooftop
and carport solar (PV) panels, consistent with
the current CALGreen code.

Policy OS-8.5: Develop landscaping guidelines that
support the use of vegetation for shading and wind
reduction and otherwise help reduce energy
consumption in new development for compatibility with
renewable energy sources (i.e., solar pools).

Consistent: The Project will be designed and
constructed to meet the City’s water efficient
landscaping and irrigation requirements in the
Municipal Code.

Policy OS-8.6: Require all new development to
incorporate energy efficient lighting, heating, and
cooling systems pursuant to the Uniform Building Code
and Title 24.

Consistent: The Project will be designed and
constructed to meet all the applicable
standards of the Uniform Building Code and
Title 24.

Policy OS-8.7: Encourage mixed use development as
a means of reducing the need for auto travel.

Consistent: The Project proposes
development of residential and commercialretail uses.

Policy OS-8.10: Support the use of public
transportation, bicycling and other alternative
transportation modes in order to reduce the
consumption of non-renewable energy supplies.

Consistent: The Project will provide several
pedestrian pathways to facilitate the movement
of pedestrians within the site. The Project site
will also provide pedestrian linkage to the
surrounding area by providing connection to
the existing sidewalks. The Project area is
currently being served by Riverside Transit
Agency, providing public transportation along
Arlington Avenue and Streeter Avenue.

Policy OS-8.12: Require bicycle parking in new nonresidential development.Consistent: The Project site will provide bicycle parking, meeting, or exceeding the
current CALGreen requirements.

Public Facilities and Infrastructure Element
Objective PF-6: Provide affordable, reliable, and, to the extent practical, environmentally sensitive energy resources to residents and businesses.

Policy PF-6.3: Promote and encourage energy
conservation.

Consistent: The Project’s design features
include residential appliances to be Energy
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Table 5.5-G, Consistency with City of Riverside General Plan Relevant Objectives and Policies Project Consistency
Star-rated. Additionally, Project will be
designed and constructed to meet all
applicable standards under CALGreen and Title

24. Policy PF-6.4: Encourage energy-efficient
development through its site plan and building design
standard guidelines.

Consistent: The proposed Project will be
designed and constructed to meet all
applicable standards under CALGreen.

Policy PF-6.5: Promote green building design. Consistent: The proposed Project will be designed and constructed to meet all
applicable standards under CALGreen.

Consistency with City of Riverside Climate Action Plan
The City’s CAP provides a roadmap for the City to achieve deep GHG emissions reductions through the year 2035.The CAP prioritizes the implementation of policies that enable the City to fulfill AB 32 and SB 375 requirements. CAP Table B.3-2, 2020 and 2035 Reductions from Local Measures, lists local GHG reduction measures. Table 5.5-H, Project Consistency with the City of Riverside Climate Action Plan, compares the proposed Project to applicable reduction measures from the CAP.

Table 5.5-H, Project Consistency with the City of Riverside Climate Action Plan Applicable Measures Project Consistency
Measure E-2: Shade Trees. Strategically plant trees at
new residential developments to reduce the urban heat
island effect.

Consistent. The Project landscaping includes trees
throughout the development in the common open
spaces.

Measure T‐1: Bicycle Infrastructure Improvements.

Expand on-street and off-street bicycle infrastructure, including bicycle lanes and bicycle trails.

Consistent. As part of the City’s Bikeway Network,
Class II bike lanes exist along Arlington Avenue which
connect to the Magnolia/Market Corridor. While
Streeter Avenue is GP designated Class II Bike Lane, it is not currently striped as such. However, bike lane
improvements are part of the City’s capital
improvement projects. As such, the City, rather than
individual development projects, are responsible for the timing of implementation of bike lane improvements.

Measure T‐2: Bicycle Parking.

Provide additional options for bicycle parking.

Consistent. The Project site will provide bicycle
parking, meeting, or exceeding the current CALGreen
requirements.

Measure T‐3: End of Trip Facilities
Encourage use of non-motorized transportation modes
by providing appropriate facilities and amenities for
commuters.

Consistent. End of trip commuter facilities can include showers, changing rooms, lockers, and bicycle
storage/parking which encourage employees to walk
and bike to work. As stated, the Project would provide
bicycle parking spaces, thereby encouraging
alternative travel modes.

Measure T‐6: Density.

Improve jobs-housing balance and reduce vehicle miles
traveled by increasing household and employment
densities.

Consistent. The proposed Project includes mixed use
construction of residential and commercial buildings
which would therefore increase household and
employment density in the Project area.

T-8 Pedestrian Only Areas. Encourage walking by
providing pedestrian-only community areas.

Consistent. The Project provides a pedestrian network
along streets and on-site internal pedestrian walkways.

Measure T‐19: Alternative Fuel & Vehicle Technology
and Infrastructure.

Promote the use of alternative fueled vehicles such as
those powered by electric, natural gas, biodiesel, and
Consistent. As stated, the Project sire would include
electric vehicle charging stations and parking spaces to promote use of alternative fuel vehicles. Consistent
with the current CALGreen code.

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fuel cells by Riverside residents and workers.

W-1: Water Conservation and Efficiency.

Reduce per capita water use by 20% by 2020.

Consistent. Project will be designed and constructed
to meet all applicable standards under the City’s
Municipal Code and CALGreen.

SW-1: Yard Waste Collection.

Provide green waste collection bins community-wide.

Consistent. The Project would comply with applicable
solid waste requirements from the City and State.

SW-2 Food Scrap and Paper Diversion.

Divert food and paper waste from landfills by
implementing commercial and residential collection
programs.

Consistent. The Project would be required to
participate in applicable waste diversion programs. The Project would also be subject to all applicable State
and City requirements for solid waste reduction.
2022 Scoping Plan
The Project would be required to comply with applicable current and future regulatory requirements promulgated through the 2022 Scoping Plan. For example, current transportation sector measures are implemented by the manufacturers, which includes the Advanced Clean Cars II and the Low Carbon Fuel Standard. The Project is also subject to building code requirements under the building energy efficiency standards (Title 24) and green building standards (CALGreen) that improve building energy efficiency and promote transportation electrification. New buildings are required to comply with the applicable building code requirements and standards in place at the time building permit documentation submittals are made. Additionally, the City’s Municipal Code requires building electrification to reduce carbon emissions.

The 2022 Scoping Plan identifies three priority areas for local jurisdictions: transportation electrification, VMT reduction, and building electrification. As stated above, the Project supports both transportation electrification and building electrification through compliance with existing City and State standards. The Project would also provide sidewalks, bike racks, and pedestrian walkways which promotes alternative modes of transportation (walking, biking, and transit) and reduces VMT.

For these reasons outlined above, the proposed Project does not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Therefore, impacts would be less than significant.

5.5.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). Mitigation measures were evaluated for their ability to eliminate or reduce the potential significant adverse GHG impacts. The analysis above does show that the Project will exceed the threshold (3,000 MTCO2E/yr) and that the majority of these emissions from the Project are from the mobile sources (cars) from future residents and customers.

Mitigation measures MM GHG-1 through MM GHG-3, below, shall be implemented to reduce the Project’s GHG emissions from mobile sources. There are no additional feasible mitigation measures that would reduce the Project’s cumulative impacts related to GHG emissions to a less than significant level.

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MM GHG-1 Commute Trip Reduction. Upon a residential dwelling unit being rented, the Project Applicant or its designee shall notify and offer to the prospective tenant, as soon as it may be done, disclosure materials describing available public transit, ridesharing and non-motorized commuting opportunities available in the vicinity of the Project. Such information shall be transmitted no later than the finalization of a rental contract. A draft of this disclosure shall be submitted to the City of Riverside Planning Division for review prior to the issuance of the certificate of occupancy.

MM GHG-2 Telecommute. The Project Applicant or its designee shall install broadband infrastructure or other communication technologies that encourage telecommuting and working from home. The Project Applicant or its designee shall submit documentation to the City Building and Safety Division prior to occupancy.

MM GHG-3 Unbundle Residential Parking Costs. The Project Applicant or its designee shall provide information to the residential property owner and/or property management firm about the benefits of providing unbundled, or separate, residential parking costs from property costs for rental units, which allows those who wish to purchase parking spaces to do so at an additional cost. Unbundled parking costs may decrease vehicle ownership and, therefore, result in a reduction in VMT and GHG emissions. The Project Applicant or its designee shall submit documentation to the City Planning Division prior to occupancy.

5.5.9 Summary of Project-Specific Environmental Effects After Mitigation Measures are Implemented
Although the Project does not conflict with an applicable plan, policy or regulation adopted to reduce GHG, the Project’s GHG emissions exceed the SCAQMD draft threshold of 3,000 MTCO2E/yr which is being utilized as the City’s threshold for this Project. Implementation of local, state, and federal regulations outlined in Section 5.5.2, Project design features outlined in Section 5.5.5, and mitigation measures listed above will reduce the Project’s GHG emissions from mobile sources. However, there are no additional feasible mitigation measures that would reduce the Project’s overall GHG emissions to a less than significant level. Therefore, the Project’s cumulative GHG impacts will be significant and unavoidable and a statement of overriding considerations will be required prior to Project approval.

City of Riverside Sections 5.6
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5.6 Hazards and Hazardous Materials
The focus of this section is to analyze potential impacts related to hazards and hazardous materials. The following discussion addresses the potential for adverse impacts that could result from the construction and operation as a result of the Project specifically, from accident conditions involving the release of hazardous materials into the environment and safety hazard or excessive noise for people within airport land use plan. Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics.

A Phase I Environmental Site Assessment (2021 Phase I ESA) was conducted by Weis Environmental dated November 11, 2021 (WEIS-A) as well as an Addendum to Phase I Environmental Site Assessment (Addendum) dated March 10, 2023 (WEIS-B), and Work Plan for Subsurface Assessment (Work Plan) dated October 3, 2022 (WEIS-C). A Comprehensive Subsurface Assessment Report (Assessment) was also conducted by Weis Environmental dated July 31November 3, 2023 (WEIS-D). The Project was required to be reviewed by the Riverside County Airport Land Use Commission (ALUC). As such, ALUC prepared a Consistency Determination letter dated January 18, 2023 (ALUC-B), a Staff Report for Case ZAP1107RI22 dated January 12, 2023 (ALUC-C) and ALUC Development Review-Commissioner Concerns letter dated January 18, 2023 (ALUC-D). These reports and letters are included in Appendix D of this Draft EIR.

5.6.1 Setting
The Project site is located at the northeast corner of Arlington Avenue and Streeter Avenue and is currently developed with a multi-story former Sears Department store structure that includes a basement level and occupies the central portion of the property. The site also includes a single-story former Sears Automotive Service Center that includes a basement level on the western portion of the property. The Sears Department store structure has occasionally been occupied by a Spirit Halloween Store in the southeastern portion of the building on the ground level. However, both structures are currently vacant. (WEIS-A, p. 4).

The former Sears Department store was located in the central portion of the now vacant building. The interior of the vacant department store building includes retail areas, warehouse and supply storage areas, sub-grade basement areas, public and freight hydraulic elevators, and restrooms. The basement area contains a disconnected boiler, trash compactor, and emergency generator.

The former Sears Automotive Service Center structure includes six bay doors opening to a concretepaved former service area with secondary containment structures, nine hydraulic hoists, and a subgrade oil/water separator. The site formerly contained a vehicle fueling island and distribution lines with three 10,000-gallon gasoline underground storage tanks (USTs) and seven 1,000 to 2,000-gallon oil and waste oil USTs. The balance of the remaining site property comprises asphalt-paved parking areas, driveways, and minor landscaping. (WEIS, p. 4).

The area surrounding the site consists primarily of commercial and residential properties and public roadways. Access to the Project site is provided by Arlington Avenue and Streeter Avenue along the southern and western sides of the property, respectively. Indicators of various utility systems are present throughout the Project site, primarily adjoining the building exteriors and along the Project site perimeter.

Utilities present at the Project site or in the surrounding area include potable water, sewage maintenance, electrical, natural gas, and solid waste disposal. (WEIS-A, pp. 4-5).

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Site Background
A prior Phase I ESA conducted for the Project site identified that the Sears Automotive Service Center contained ten UST’s. The three 10,000-gallon UST’s were removed in 1985. The seven 1,000 to 2,000- gallon oil and waste oil UST’s were removed in 1987. The fueling island and distribution lines were removed in 1994. A leak was discovered during UST removal. Soil investigation and groundwater monitoring took place between 1993 and 2003. The Santa Ana Regional Water Quality Control Board (SARWQCB) granted regulatory closure for the UST release via a “No Further Action” letter dated June 26, 2003. The letter indicated that corrective action should be reviewed in the future if land use changes.

Groundwater contaminants were determined to be present at concentrations exceeding regulatory riskbased groundwater screening levels (specifically total petroleum hydrocarbons [TPH] as gasoline, ethylbenzene, xylenes, and tetrachloroethene [PCE]). The former USTs were identified as a controlled recognized environmental condition (CREC). Due to the 60 years of automotive servicing that previously took place, the Automotive Center’s oil/water separator site was identified as a REC because of the unknown chemical usage, hazardous waste management disposal activities, lack of the soil/groundwater data, and the absence of continuous service records. PCE detected in groundwater was also identified as a recognized environmental condition (REC) and a documented release was identified with the Crown Cleaners facility approximately 600 feet south (up-gradient) of the site in the current Heritage Plaza Shopping Mall as the likely source. Lastly, asbestos abatement work was conducted on the site in 2002 which included the removal of sheetrock joint compound, acoustic ceiling tile adhesive, vinyl floor tile, and flooring adhesive. Additional asbestos containing materials reportedly remains on the site. As such, a prior Phase II ESA was conducted. On March 6, 2015, five direct push boring locations were advanced to a maximum depth of 45 feet below ground surface for soil and groundwater sampling. Sample locations were chosen to characterize potential impacts related to the former on-Site UST system, the automotive center oil/water separator, and solvent releases from the upgradient off-Site Crown Cleaners facility. TPH concentrations below the applicable Los Angeles RWQCB maximum screening levels and volatile organic compound (VOC) concentrations below the United States Environmental Protection Agency (USEPA) Region 9 Regional Screening Levels were detected in soil collected from the former UST and oil/water separator areas. PCE was detected in groundwater collected from each of the five locations at concentrations above the laboratory method detection limits but below the USEPA Region 9 Regional Screening Level. VOCs (specifically benzene, ethylbenzene, 1,2-dichloroethane, and total xylenes) were detected at concentrations greater than California Environmental Protection Agency (CalEPA) Maximum Contaminant Levels (MCLs) in groundwater collected from one location near the former fueling island and area. VOCs were also detected in groundwater collected near the automotive service center, but at concentrations below respective CalEPA MCLs. TPH (gasoline, diesel, and oil range fractions) was detected at concentrations above the San Francisco RWQCB Regional Environmental Screening Levels in the vicinity of the former USTs, oil/water separator, and southeast portion of the Project site. (WEIS-A, pp. 10-11).

Airport Land Use Compatibility Zones
The Project site is located within the Riverside County Airport Municipal Airport Land Use Compatibility Plan (RCALUCP) and is approximately one mile from the airport runway (GE); specifically the Riverside Municipal Airport (RMA). The Plan identifies prohibited and discouraged uses within each land use compatibility zone as well as density/intensity standards and open land requirements, as shown on Table 5.6-A, Basic Land Use Compatibility Criteria. Most of the Project site is located within Land Use Compatibility Zone B1 while smaller portions are located with Zones C and D as shown in Figure 3.0-6 in Section 3.0 – Project Description of this Draft EIR.

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Table 5.6-A, Land Use Compatibility Criteria
Zone Location
Density/Intensity Standards
Req’d
Open
Land
Additional Criteria
Residential
(du/ac)1
Other Uses
(people/acre)2
Prohibited Uses 3 Other Development
Conditions4
Avg5 Single 6
B1 Inner
Approach
Departure
Zone

0.05 (average
parcel size
≥20.0ac)
25 50 30%  Children’s schools,
day care centers,
libraries
 Hospitals, nursing
homes
 Places of worship
 Buildings with >2
aboveground
habitable floors
 Highly noisesensitive outdoor
nonresidential
uses7
 Aboveground bulk
storage of
hazardous
materials8
 Critical community
infrastructure
facilities9
 Hazards to flight 10
 Locate structures
maximum distance
from extended
runway centerline
 Minimum NLR of 25
dB in residences
(including mobile
homes) and office
buildings11
 Airspace review
required for objects
>35 feet tall12
 Avigation easement
dedication
C Extended
Approach/
Departure
Zone

0.2 (average
parcel size
≥5.0 ac)
75 150 20%  Children’s schools,
day care centers,
libraries
 Hospitals, nursing
homes
 Buildings with >2
aboveground
habitable floors
 Highly noisesensitive outdoor
nonresidential
uses7
 Hazards to flight10
 Minimum NLR of 20
dB in residences
(including mobile
homes) and office
buildings11
 Airspace review
required for objects
>70 feet tall13
 Deed notice required
D Primary
Traffic
Patterns
and
Runway
(1) ≤0.2
(average
parcel size
100 300 10%  Highly noisesensitive outdoor
nonresidential
uses7
 Airspace review
required for objects
>70 feet tall13
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Table 5.6-A, Land Use Compatibility Criteria
Zone Location
Density/Intensity Standards
Req’d
Open
Land
Additional Criteria
Residential
(du/ac)1
Other Uses
(people/acre)2
Prohibited Uses 3 Other Development
Conditions4
Avg5 Single 6
Buffer
Area
≥5.0 ac)
or14
(2) ≥5.0
(average
parcel size
≤0.2 ac)
 Hazards to flight10  Children’s schools,
hospitals, nursing
homes discouraged 15
 Deed notice required
Source: RCALUCP, Table 2A – Basic Compatibility Criteria Notes:

1. Residential development must not contain more than the indicated number of dwelling units (excluding secondary units) per gross acre. Clustering of units is encouraged. See Policy 4.2.5 for limitations. Gross acreage includes the property at issue plus a share of adjacent roads and any adjacent, permanently dedicated, open lands. Mixed-use development in which residential uses are proposed to be located in conjunction with nonresidential uses in the same or adjoining buildings on the same site shall be treated as nonresidential development. See Policy 3.1.3(d).

2. Usage intensity calculations shall include all people (e.g., employees, customers/visitors, etc.) who may be on the property at a single point in time, whether indoors or outside.

3. Open land requirements are intended to be applied with respect to an entire zone. This is typically accomplished as part of a community general plan or a specific plan but may also apply to large (10 acres or more) development projects. See Policy

4.2.4 for definition of open land.

4. The uses listed here are ones that are explicitly prohibited regardless of whether they meet the intensity criteria. In addition to these explicitly prohibited uses, other uses will normally not be permitted in the respective compatibility zones because they do not meet the usage intensity criteria.

5. As part of certain real estate transactions involving residential property within any compatibility zone (that is, anywhere within an airport influence area), information regarding airport proximity and the existence of aircraft overflights must be disclosed.

This requirement is set by state law. See Policy 4.4.2 for details. Easement dedication and deed notice requirements indicated for specific compatibility zones apply only to new development and to reuse if discretionary approval is required.

6. The total number of people permitted on a project site at any time, except rare special events, must not exceed the indicated usage intensity times the gross acreage of the site. Rare special events are ones (such as an air show at the airport) for which a facility is not designed and normally not used and for which extra safety precautions can be taken as appropriate.

7. Examples of highly noise-sensitive outdoor nonresidential uses that should be prohibited include amphitheaters and drive-in theaters. Caution should be exercised with respect to uses such as poultry farms and nature preserves.

8. Storage of aviation fuel and other aviation-related flammable materials on the airport is exempted from this criterion. Storage of up to 6,000 gallons of nonaviation flammable materials is also exempted. See Policy 4.2.3(c) for details.

9. Critical community facilities include power plants, electrical substations, and public communications facilities. See Policy

4.2.3(d) for details.

10. Hazards to flight include physical (e.g., tall objects), visual, and electronic forms of interference with the safety of aircraft operations. Land use development that may cause the attraction of birds to increase is also prohibited. See Policy 4.3.7.

11. NLR = Noise Level Reduction, the outside-to-inside sound level attenuation that the structure provides. See Policy 4.1.6.

12. Objects up to 35 feet in height are permitted. However, the Federal Aviation Administration may require marking and lighting of certain objects. See Policy 4.3.6 for details.

13. This height criterion is for general guidance. Shorter objects normally will not be airspace obstructions unless situated at a ground elevation well above that of the airport. Taller objects may be acceptable if determined not be obstructions. See Policies 4.3.3 and 4.3.4.

14. Two options are provided for residential densities in Compatibility Zone D. Option (1) has a density limit of 0.2 dwelling units per acre (i.e., an average parcel size of at least 5.0 gross acres). Option (2) requires that the density be greater than 5.0 dwelling units per acre (i.e., an average parcel size less than 0.2 gross acres). The choice between these two options is at the discretion of the local land use jurisdiction. See Table 2B for explanation of rationale. All other criteria for Zone D apply to both options.

15. Discouraged uses should generally not be permitted unless no feasible alternative is available.

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Consistency with RCALUCP’s airport influence area is determined based on each criterion of the applicable compatibility zone. The Plan also identifies specific noise and safety compatibility zone factors as shown in Table 5.6-B Compatibility Zone Factors.

Table 5.6-B, Compatibility Zone Factors
Zone Location Noise and Overflight Factors Safety and Airspace Protection Factors
B1 Inner
Approach/Departure
Zone
Noise Impact: High
 Mostly within 60-CNEL contour (55-
CNEL at outlying airports)
 Single-event noise sufficient to
disrupt wide range of land use
activities including indoors if
windows open
Risk level: High
 Encompasses areas overflown by
aircraft at low altitudes —typically only
200 to 400 feet above runway
 Some 10% to 20% of off-runway
general aviation accidents near
airports take place here
 Object heights restricted to as little as
50 feet
C Extended Approach
/Departure Zone
Noise Impact: Moderate
 Mostly within 55-CNEL contour
beyond runway ends
 Aircraft typically below 1,000 feet
altitude on arrival; individual events
occasionally loud enough to intrude
upon indoor activities
Risk level: Moderate
 Includes areas where aircraft:
o Turn from base to final approach
legs of standard traffic pattern and
descend from traffic pattern
altitude
o On departure, normally complete
transition from takeoff power and
flap settings to climb mode and
begin turns to en route heading
o On an instrument approach
procedure, have descended below
about 500 feet AGL
o Some 10% to 15% of off-runway
general aviation accidents near
airports occur in this zone
 Object heights restricted to as little as
50 feet
D Primary Traffic
Patterns
Noise Impact: Moderate
 Mostly within 55-CNEL contour if any
 Aircraft at or above traffic pattern
except for instrument approaches
 More concern with respect to
individual loud events than with
cumulative noise contours
 Residential density criteria for this
zone provide two options on basis
that noise concerns can be
minimized either by limiting number
of dwelling units in affected areas or
by allowing high-density
development which tends to have
comparatively high ambient noise
levels
Risk level: Low
 Aircraft on instrument approaches
below 1,000 feet
 About 20% to 30% of general aviation
accidents take place in this zone, but
large area encompassed means low
likelihood of accident occurrence in
any given location
 Risk concern primarily with uses for
which potential consequences are
severe (e.g., very-high-intensity
activities in a confined area)
 Object height limits generally at least
100 feet
Source: RCALUCP, Table 3A – Compatibility Zone Factors
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Airport Safety Concerns
The State of California, Department of Transportation – Division of Aeronautics, California Airport Land Use Planning Handbook (DOT) identifies that safety is a factor in the interaction between airports and nearby land uses in three distinct ways:
 Protecting people and property on the ground.
 Minimizing injury to aircraft occupants.
 Preventing creation of hazards to flight.

Each of these concerns needs to be addressed in airport land use compatibility plans. The nature of each is summarized in the following discussion.

Protecting People and Property on the Ground
Protecting people and property on the ground from potential consequences of accidents near an airport is a fundamental land use compatibility objective. To accomplish this, some form of restrictions on land use is essential. Land use characteristics are the most important factors to consider in safety compatibility criteria. The potential severity of an off-airport accident is highly dependent upon the nature of the land use at the accident site. For the purposes of evaluating the relative risks presented by different land uses, three characteristics are most important.  Intensity of Use – The most direct means of limiting the potential consequences of an offairport aircraft accident is to limit the intensity of use. Intensity of use is measured in terms of the number of people which the development can attract per acre. This measurement service is a common denominator among various types of nonresidential uses. Except for certain especially risk-sensitive uses, as noted below, the degree of safety compatibility is usually considered the same for any two land uses of similar usage intensities.  Residential versus Non-residential Functions – Residential land uses are typically measured in dwelling units per acre, rather than people per acre. This is principally a practical measure to simplify implementation. However, residential uses are also normally afforded a comparatively higher degree of protection than non-residential uses. That is, for a given location, higher occupancy levels are permitted for non-residential uses than residential uses.
 Sensitive Uses – Certain other types of land uses are also commonly regarded as requiring special protection from hazards such as potential aircraft accidents. These uses fall into two categories:

1. Low Effective Mobility Occupancies: Society normally seeks a high degree of protection for certain groups of people, especially children and the infirm. A common element among these groups is inability, either because of inexperience or physical limitations, to move out of harm’s way. Among the types of land uses regarded as particularly risk-sensitive are elementary and secondary schools, day care centers, hospitals, and nursing homes.

2. Hazardous Materials: Functions, such as above-ground storage of large quantities of flammable materials or other hazardous substances which could substantially contribute to the severity of an aircraft accident if they were to be involved in one.

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Minimizing Injury to Aircraft Occupants
In accidents involving an aircraft that is out of control as it descends, the character of the land uses below are not likely to have a significant effect on the survivability of the crash. However, some aircraft mishaps involve situations in which the aircraft is descending, often without power, but otherwise under control. If the aircraft has sufficient altitude, the pilot has some choice as to where to attempt an emergency landing. Under these circumstances, the pilot of a disabled aircraft will, if possible, direct the aircraft toward some form of open land when an off-airport emergency landing is inevitable. This propensity forms the premise behind the primary form of land use control intended to minimize the severity of injury to aircraft occupants in the event of an off-airport emergency landing. Specifically, some amount of useful open land should be preserved in the vicinity of airports.

Preventing Creations of Hazards to Flight
Unlike the preceding land use characteristics which can only affect the consequences of an aircraft accident (for better or worse), hazards to flight can be the cause of an accident. Hazards to flight fall into three basic categories:
 Obstructions to airspace required for flight to, from, and around an airport.  Wildlife hazards.
 Other forms of interference with safe flight, navigation, or communication.

5.6.2 Related Regulations
Federal Regulations
Federal Toxic Substances Control Act of 1976
The Federal Toxic Substances Control Act of 1976 tasked the U.S. Environmental Protection Agency (EPA) with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. The Federal Toxic Substances Control Act (TCA) addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls, asbestos, radon, and lead-based paint. (EPA-A).

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as “Superfund,” was enacted by Congress on December 11, 1980. This law provided broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA established requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party could be identified. CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the National Priorities List, which is a list of contaminated sites warranting further investigation by the EPA. CERCLA was amended by the Superfund Amendments and Reauthorization Act on October 17, 1986. (EPA-B).

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Superfund Amendments and Reauthorization Act
The Superfund Amendments and Reauthorization Act amended CERCLA on October 17, 1986. The Superfund Amendments and Reauthorization Act had several changes and additions, including the following:
 Stressed the importance of permanent remedies and innovative treatment technologies in cleaning up hazardous waste sites
 Required Superfund actions to consider the standards and requirements found in other state and federal environmental laws and regulations.
 Provided new enforcement authorities and settlement tools  Increased state involvement in every phase of the Superfund program  Increased the focus on human health problems posed by hazardous waste sites  Encouraged greater citizen participation in making decisions on how sites should be cleaned up  Increased the size of the trust fund to $8.5 billion.

The Superfund Amendments and Reauthorization Act also required the Environmental Protection Agency (EPA) to revise the Hazard Ranking System to ensure that it accurately assessed the relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites that may be placed on the National Priorities List. (EPA-C).

Occupational Safety and Health Act of 1970 and Occupational Safety and Health Administration The Occupational Safety and Health Act of 1970 was passed to prevent workers from being killed or seriously harmed at work. The Occupational Safety and Health Act of 1970 created the Occupational Safety and Health Administration (OSHA), which sets and enforces protective workplace safety and health standards. OSHA also provides information, training, and assistance to employers and workers.

Under the Occupational Safety and Health Act of 1970, employers have the responsibility to provide a safety workplace. Title 29 CFR §1910 contains OSHA regulations for hazard communication. OSHA implements and enforces regulations pertaining to general industry standards (29 CFR §1910) and construction operations (29 CFR §1926). Both of these regulations address the handling of toxic or hazardous material. (OSHA).

Federal Aviation Administration
Land use safety guidance from the Federal Aviation Administration (FAA) is limited to the immediate vicinity of the runway, the runway protection zones at each end of the runway, and the protection of navigable airspace. The FAA criteria apply only to property controlled by the airport proprietor. It has no authority over off-airport land uses.

The emphasis in FAA safety criteria is upon the runway surface and the areas immediately adjoining it.

Standards are established which specify ground surface gradients for areas adjacent to runways and acceptable location and height of aeronautical equipment placed nearby.

Runway protection zones (RPZs) are trapezoidal-shaped areas located at ground level beyond each end of a runway. The dimensions of RPZs vary depending upon the type of landing approach available at the airport (visual, non-precision, or precision) and characteristics of the critical aircraft operating at the airport (weight and approach speed). Ideally, each RPZ should be clear of all objects. The FAA’s Airport Design advisory circular strongly recommends that airports own this property outright or to obtain City of Riverside Sections 5.6
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easements sufficient to control the land. Even on portions of the RPZs not under airport control, the FAA recommends that churches, schools, hospitals, office buildings, shopping centers, and other places of public assembly, as well as fuel storage facilities be prohibited. Beyond the RPZs, the FAA has no specific safety-related land use guidance other than airspace protection.

Federal Aviation Regulations, Part 77
Part 77 of the Federal Aviation Regulations (FAR), Safe Efficient Use and Preservation of the Navigable Airspace, establishes standards for determining obstructions to navigable airspace and the effects of such obstructions on the safe and efficient use of that airspace. The regulations require that the FAA be notified of proposed construction or alteration of objects (whether permanent, temporary, or of natural growth) if those objects would be of a height which exceeds FAR Part 77 criteria. (FAR PART77).

The Part 77 regulations define a variety of imaginary surfaces at certain altitudes around airports. The Part 77 surfaces include the primary surface, approach surface, transitional surface, horizontal surface, and conical surface. Collectively, the Part 77 surfaces around an airport define a bowl-shaped area with ramps sloping up from each runway end. The Part 77 standards are not absolute height restrictions, but instead identify elevations at which structures may present a potential safety problem. Penetrations of the Part 77 surface generally are reviewed on a case-by-case basis. (FAR PART77).

The Federal Aviation Administration (FAA) has additional guidelines regarding protection of airport airspace, which are set forth in other FAA documents. In general, these criteria specify that no use of land or water anywhere within the boundaries encompassed by FAR Part 77 should be allowed if it could endanger or interfere with the landing, take off, or maneuvering of an aircraft at an airport (FAA). Specific characteristics to be avoided include creation of electrical interference with navigational signals or radio communication between the airport and aircraft, lighting which is difficult to distinguish from airport lighting, glare in the eyes of pilots using the airport, smoke, or other impairments to visibility in the airport vicinity, and uses which attract birds and create bird strike hazards. (FAR PART77).

State Regulations
California Environmental Protection Agency
The boards, departments, and offices that make up the California Environmental Protection Agency (CalEPA) include CARB, the Department of Pesticide Regulation, the Department of Resources Recycling and Recovery, the Department of Toxic Substances Control (DTSC), the Office of Environmental Health Hazard Assessment, and the State Water Resources Control Board. These boards, departments and offices were placed within the CalEPA “umbrella” to create a cabinet-level voice for the protection of human health and the environment (such as clean air, clean water, clean soil, safe pesticides, and waste recycling and reduction) to assure the coordinated deployment of state resources. (CALEPA-A).

California Government Code Section 65962
Pursuant to Government Code 65962.5, environmental regulatory database lists were reviewed to identify and locate properties with known hazardous substance contamination within the proposed project area (California Government Code, Section 65960 et seq.). Four state agencies are required to provide lists of facilities that have contributed, harbor, or are responsible for environmental contamination within their jurisdiction. The four state agencies that are required to provide these lists to the Secretary for Environmental Protection include the DTSC, the State Department for Health Services, the State Water Resources Control Board, and the California Integrated Waste Management Board. The Secretary for Environmental Protection then takes each of the four respective agency lists and forms one Section 5.6 City of Riverside
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list, referred to as the Hazardous Waste and Substances Site List – Site Cleanup (Cortese List), which is made available to every city and/or county in California (CALEPA-B).

California Occupational Safety and Health Administration CalOSHA is the primary agency responsible for worker safety in the handling and use of chemicals in the workplace. CalOSHA standards are generally more stringent than federal regulations. Cal OSHA, under California Code of Regulations (CCR) Title 8 §§337–340, requires employers to monitor worker exposure to listed hazardous substances and notify workers of exposure. The regulations specify requirements for employee training, availability of safety equipment, accident prevention programs, and hazardous substance exposure warnings. (DIR).

California Hazardous Waste Control Law
The California Hazardous Waste Control Law (Health and Safety Code, Division 20, Chapter 69.5) is administered by the CalEPA to regulate the management of hazardous wastes. While the Hazardous Waste Control Law is generally more stringent than the Resource Conservation and Recovery Act, until the EPA approves the California hazardous waste control program (which is charged with regulating the generation, treatment, storage, and disposal of hazardous waste), both the state and federal laws apply in California. The Hazardous Waste Control Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills. (HSC 6.95).

Department of Toxic Substance Control
The Department of Toxic Substance Control manages hazardous waste under CCR Title 22 Division 4.5, which establishes criteria for identifying, packaging, and labeling hazardous wastes; dictate the management of hazardous waste; establish permit requirements for hazardous waste treatment, storage, disposal, and transportation; and identify hazardous wastes that cannot be disposed of in landfills. These regulations also require hazardous waste generators to prepare a Hazardous Waste Contingency Plan that describe hazardous waste storage and secondary containment facilities, emergency response and evacuation procedures, and employee hazardous waste training program. (DTSC).

Aeronautics Act
The Aeronautics Act (Public Utilities Code §§ 21001 et seq.) provides for the right of flight over private property, unless conducted in a dangerous manner or at altitudes below those prescribed by federal authority. The Act gives the State Department of Transportation (Caltrans) and local governments the authority to protect the airspace defined by FAR Part 77 criteria. The act prohibits any person from constructing a structure or permitting any natural growth of a height that would constitute a hazard to air navigation unless a permit is obtained from Caltrans. No permit is required if it is determined that the structure or growth is not a hazard to aviation. Typically, this has been interpreted to mean that no penetration of FAR Part 77 imaginary surfaces is permitted without a finding by the FAA that the object would not constitute a hazard to air navigation.

The State Aeronautics Act also created the requirement for an Airport Land Use Commission (ALUC) in each county and established statewide requirements for the conduct of airport land use compatibility planning. State statutes require that once an ALUC has adopted or amended an airport land use compatibility plan, the county (where it has land use jurisdiction within the airport influence area), and City of Riverside Sections 5.6
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any affected cities must update their General Plans and any applicable specific plans to be consistent with the ALUC’s plan (Government Code § 65302.3). The California Airport Land Use Planning Handbook is published by the Caltrans Division of Aeronautics to support and amplify the State regulations. The most recent California Airport Land Use Planning Handbook was published in October 2011 and as required by CEQA (Public Resources Code § 21096), was used as a technical resource in the preparation of this DEIR.

Public Utilities Code
Public Utilities Code (PUC) Section 21670 establishes that every county in which there is located an airport which is served by a scheduled airline shall establish an airport land use commission. Section 21676 and establishes among other things that prior to the amendment of a general plan or specific plan, or the adoption or approval of a zoning ordinance or building regulation within the planning boundary established by the airport land use commission pursuant to Section 21675, the local agency shall first refer the proposed action to the commission. If the commission determines that the proposed action is inconsistent with the commission’s plan, the referring agency shall be notified. Section 21676.5 establishes that the local agency may propose to overrule the commission after the hearing by a twothirds vote of its governing body if it makes specific findings that the proposed action is consistent with the purposes of this article as stated in Section 21670.

Regional Regulations
Riverside County Department of Environmental Health – Hazardous Materials Branch The California Environmental Protection Agency designated the County’s Hazardous Materials Branch as the Certified Unified Program Agency (CUPA) for Riverside County. The role of the CUPA is to assure consolidation, consistency, and coordination of the hazardous materials programs within the County.

The CUPA also oversees the two Participating Agencies (Corona Fire and Riverside Fire) that implement hazardous materials programs within the County. The Riverside County Department of Environmental Health Hazardous Materials Branch is responsible for overseeing the six hazardous materials programs in the County. The Branch is responsible for inspecting facilities that handle hazardous materials, generate hazardous waste, treat hazardous waste, own/operate underground storage tanks, or own/operate aboveground petroleum storage tanks. In addition, the Branch maintains an emergency response team that responds to hazardous materials and other environmental health emergencies 24 hours a day, 7 days a week. (CUPA)
Riverside County Airport Land Use Compatibility Plan
The Riverside County Airport Land Use Commission (ALUC) is the lead agency responsible for airport land use compatibility planning in Riverside County. The fundamental purpose of ALUC is to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The basic function of the airport land use compatibility plan is to promote compatibility between airports and the land uses that surround them. Compatibility plans serve as a tool for use by airport land use commissions in fulfilling their duty to review proposed development plans for airports and surrounding land uses. Additionally, compatibility plans set compatibility criteria applicable to local agencies in their preparation or amendment of land use plans and ordinances and to landowners in their design of new development.

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Local Regulations
City of Riverside 2025 General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project, as identified below (GP 2025, pp. LU-36 – LU-39, LU-56):

Land Use/Urban Design Element
Objective LU-22 Avoid land use/transportation decisions that would adversely impact the longterm viability of the March Air Reserve Base/March Inland Port, Riverside Municipal and Flabob Airports.

Policy LU-22.2 Work cooperatively with the Riverside County Airport Land Use Commission in developing, defining, implementing, and protecting airport influence zones around the MARB/MIP, Riverside Municipal and Flabob Airports and in implementing the new Airport Land Use Compatibility Plan.

Policy LU-22.3 Work to limit the encroachment of uses that potentially pose a threat to continued airport operations, including intensification of residential and/or commercial facilities within identified airport safety zones and areas already impacted by current or projected airport noise.

Policy LU-22.5 Review all proposed projects within the airport influence areas of Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport as noted in the Public Safety Element (Figure PS-6A – Riverside Municipal and Flabob Airport Safety Zones and Influence Areas; and Figure PS-6B – March ARB/IPA Airport Safety Zones and Influence Areas) for consistency with all applicable airport land use compatibility plan policies adopted by the Riverside County Airport Land Use Commission (ALUC) and the City of Riverside, to the fullest extent the City finds feasible.

Policy LU-22.7 Prior to the adoption or amendment of the General Plan or any specific plan, zoning ordinance or building regulation affecting land within the airport influence areas of the airport land use compatibility plan for Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport, refer such proposed actions for determination and processing by the ALUC as provided by Public Utilities Code Section 21670.

Policy LU-22.8 The City may from time to time elect to voluntarily submit proposed actions or projects that are not otherwise required to be submitted to the ALUC under Airport Land Use law in the following circumstances:
a. Clarification: If there is a question as to the purpose, intent, or interpretation of an airport land use compatibility plan (ALUCP) or its provisions; or b. Advisory: If assistance is needed concerning a proposed action or project relating to Airport Land Use matters; or.
c. ALUC Request: The ALUC requests that certain types be voluntarily submitted for review. These actions are identified in the ALUCP as “major land use action.”
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Policy LU-22.9 All development proposals within an airport influence area and subject to ALUC review will also be submitted to the manager of the affected airport for comment.

Objective LU-32 Preserve existing residential areas within the Airport Neighborhood.

Policy LU-32.1 Encourage developers of single-family residences to include a higher level of sound attenuation in new homes than required by City standards.

City of Riverside 2025 General Plan EIR
The following are applicable mitigation measures from the Riverside 2025 General Plan that pertain to hazards and hazardous materials (GP 2025 FEIR, p. 5.7-37).

Mitigation Measure MM Haz 1: To reduce project-related adverse impacts to sites containing hazardous materials and/or sites where known hazardous materials contamination may have existed that may be inadvertently discovered during construction of projects soils testing shall be conducted by a qualified soils engineer and submitted to the City for the evaluation of hazardous chemical levels in the soil. The report submitted to the City should indicate if remediation of the soils is necessary to achieve less than significant levels of hazardous chemical in the soils. Proper investigation, and remedial actions, if necessary, including a workplan shallshould be conducted under the oversight of and approved by a government agency at the site prior to construction of the project.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Hazards and Hazardous Materials.

City of Riverside Municipal Code
The following sections of the City’s Municipal Code that are applicable to potential hazards and hazardous materials:

Chapter 19.149 – Airport Land Use Compatibility. The purpose of this chapter is to establish and implement the requirements of the Riverside County Airport Land Use Compatibility Plan (RCALUCP) for airports that affect land uses within the City of Riverside. Airports that affect land uses within the City of Riverside are the Riverside Municipal Airport, Flabob Airport, and the March Air Reserve Base/Inland Port Airport.

Chapter 19.149.020 – Airport Land Use Compatibility Plan (ALUCP). For property located within a compatibility zone and subject to airport land use compatibility plan policies and criteria, land use, density, and intensity limitations of the ALUCP may be more restrictive than what would otherwise be allowed per City zoning designation applicable to the property. In addition to complying with the Zoning requirements of this title, proposed uses and development on property within an airport compatibility zone must be determined to be consistent with, and comply with the compatibility criteria of the applicable compatibility zone and airport land use compatibility plan.

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Chapter 19.149.030 – Airport Land Use Commission (ALUC). This chapter identifies the purpose of the ALUC which is to conduct airport land use compatibility planning. ALUCs protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public's exposure to excessive noise and safety hazards within areas around public airports.

Chapter 19.150 – Base Zones Permitted Land Uses. This section establishes land use regulations for all base zones listed in this article consistent with the stated intent and purpose of each zone.

Chapter 19.150.020 – Permitted Land Uses. This chapter identifies through sub-section 19.150.020.B that Airport Land Use Compatibility includes additional Airport Land Use Compatibility Plan requirements for discretionary actions proposed on property located within an Airport Compatibility Zone. When located within an Airport Land Use Compatibility Zone, greater land use, restrictions for airport compatibility may apply per the applicable Airport Land Use Compatibility Plan. Specifically, the permitted land use table identifies multiple-family dwellings in the Mixed Use Village zone as a permitted use by the City, but it also identifies that the uses are also subject to the ALUCP criteria “where use may be strictly prohibited.”
Chapter 19.590.030 – Hazardous and Toxic Materials. (A.) The intent of this section is to protect local health, safety, and general welfare by ensuring that the design and operational characteristics of a property or use does not adversely impact neighboring property owners, neighboring property users or the general public through the accidental or intentional release or use of hazardous materials. (B.) The use, handling, storage, and transportation of hazardous and extremely hazardous materials shall comply with the provisions of the California Hazardous Materials Regulations (California Administrative Code, Title 22, Division (4). The U.S. EPA and the California Department of Health Services (DHS) identify hazardous materials and prescribe handling, use and disposal practices. The use, storage, manufacture, and disposal of hazardous materials shall be regulated and monitored according to the standards established by these agencies and any delegated government agencies. (C.) The use, handling, storage, and transportation of combustibles and explosives shall comply with the provisions of the Uniform Fire Code. No gasoline or other inflammables or explosives shall be stored unless the location, plans, and construction conform to the laws and regulations of the State of California and have the approval of the City of Riverside. (D.) Toxic gases or matter shall not be emitted that can cause any damage to health, to animals or vegetation, or other forms of property, or that can cause any excessive soiling beyond the lot lines of the use.

City of Riverside Emergency Operations Plan
The City of Riverside (City) Office of Emergency Management (OEM) is also known as the City of Riverside Fire Department’s Emergency Services Division and administers a comprehensive all-hazards community based emergency management program. Riverside OEM promotes a disaster resistant and resilient community through partnerships with all levels of government entities, businesses, nongovernmental organizations and the residents and visitors of the City of Riverside.

City of Riverside Local Hazard Mitigation Plan
The City is guided by the Local Hazard Mitigation Plan (LHMP). The City is in the process of updating this plan. The purpose of the plan is to evaluate and assess the identified hazards pose to the city, review, and assess past disaster occurrences and through the engagement of the whole community set goals to mitigate potential risks to reduce or eliminate long-term risk to people, property, and environment from natural, human caused and technological hazards. (LHMP, p. 4) City of Riverside Sections 5.6
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5.6.3 Comments Received in Response to the Notice of Preparation No comments were received regarding recreation in response to the Initial Study/Notice of Preparation (IS/NOP).

5.6.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the Thresholds of Significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A) and as outlined in Section 4.0 of this DEIR, implementation of the proposed Project will have a less than significant impact in the following areas and these topics are not addressed in this DEIR:
 Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials;
 Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school;  Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment;
 Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; and
 Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Create a significant hazard to the public or the environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials into the environment; and
 For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard or excessive noise for people residing or working in the project area.

5.6.5 Project Design Features
The Project includes design features that comply with ALUC’s policies to shield outdoor lighting so that it faces downward and include water quality features utilizing Modular Wetlands which are designed to capture and treat water in underground facilities before conveyance into the existing storm drain facilities in Streeter Avenue as discussed in Section 4.0 – Environmental Effects Found Not Significant of this Draft EIR. Because Modular Wetlands allow for treatment in underground chambers, there will be no basins that could allow for standing water. Further, all landscape and vegetation is in accordance with ALUC’s Landscaping Near Airports and Airports, Wildlife and Stormwater Management brochures so as not attract wildlife. Last, buildings will be constructed of anti-reflective materials to avoid glare.

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5.6.6 Methodology
The purpose of the 2021 Phase I ESA was to identify recognized environmental conditions (RECs), historical recognized environmental conditions (HRECs), and/or controlled recognized environmental conditions (CRECs) indicative of releases or threatened releases of hazardous substances on, at, in, or to a subject site. The Addendum to the Phase I ESA was conducted to include the off-site utility footprint (WEIS-B, p. 1).

The Phase I ESA for the proposed Project was prepared in accordance with the American Society of Testing and Materials (ASTM) for ESA’s, which include the Phase I ESA process, ASTM Standard E1527- 2013 protocols and CFR Part 312, Title 40. The 2021 Phase I ESA involved: a site reconnaissance, regulatory record review, interviews, and reporting. A REC is defined as the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment (WEIS-A, p. 1). A HREC is defined as a past release of any hazardous substances or petroleum products that has meeting unrestricted use criteria established by a regulatory authority, without subjecting the property in question to any required controls been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property in question to any required controls (WEIS-A, p.32). A CREC is defined as past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority, with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (WEIS-A, p. 32).

The Work Plan for Subsurface Assessment includes 47 soil borings ranging from 1 to 20 feet below ground surface. Analysis of the materials in these borings was used to develop soil management and vapor mitigation measures for future residential use on the Project site. (WEIS-C, p. 3).

5.6.7 Environmental Impacts
Threshold: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials into the environment?
Construction
During construction, the demolition of the existing vacant site and construction of new residential and commercial uses on the site could involve the use of hazardous materials that could create a hazard to the public or environment if not properly managed and controlled. Construction and demolition of the Project site would involve the use of fuels, lubricants, and various other liquids for operation of construction equipment. These materials will be used onsite during construction by equipment. In addition, workers will commute to the Project via private vehicles and will operate construction vehicles and equipment on public streets. Hence, the potential exists for direct impacts to human health and the environment from accidental spills of small amounts of hazardous materials during Project construction through the transport, use, and disposal of construction-related hazardous materials such as fuels, lubricants, and solvents. However, several federal and state agencies prescribe strict regulations for the use and handling of hazardous materials. For instance, hazardous material transport, storage and response to upsets or accidents are primarily subject to federal regulation by the United States DOT Office of Hazardous Materials Safety in accordance with Title 49 Part 171-180 of the CFR. Title 49 Part 171-180 regulates the safe transportation of hazardous materials and appropriate documentation for all City of Riverside Sections 5.6
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hazardous waste that is transported is required. OSHA protects workers from being killed or seriously harmed at work, specifically 29 CFR §§1910 and 1926 address the handling of toxic materials. Cal OSHA, under 8 CCR §§337-340, specify requirements for employee training, availability of safety equipment, accident prevention programs, and hazardous substance exposure warnings which lends to protecting the surrounding public and environment for accidental releases. Management of Hazardous Waste, under CCR Title 22 Division 4.5, establishes permits for the storage and disposal of hazardous material that cannot be disposed of in landfills. The California Hazardous Waste Control Law, under Chapter 6.95 of the Health and Safety Code, describes strict regulations for the safe transportation and storage of hazardous materials.

Lastly, demolition of the existing structure could release asbestos and lead-based paint into the environment which would have been used in the original building materials of the Sears structure.

According to Weis Environmental, an asbestos survey for the property was completed in 2020 which did identify some asbestos containing materials. Such materials do not represent a threat to the public’s health or the environment in their current state. These materials which tested positive for asbestos will be removed prior to full scale demolition in accordance with California Code of Regulations, Title 8, Subchapter 4 Construction Safety Orders, Article 4, Dusts, Fumes, Mists, Vapors and Gases, Section 1529 Asbestos, South Coast Air Quality Management District Rule 1403 and United States National Emissions Standards for Hazardous Air Pollutants [NESHAPS] (Code of Federal Regulations Title 40, Part 61).

A lead survey is not required prior to demolition, however the demolition contractor will by default work under conventional lead safe work practices required under California Code of Regulations, Title 8, Section 1532.1. The demolition contractor will profile all demolition derived waste and dispose of it as legally required.

Compliance with all applicable laws and regulations will reduce potential impacts associated with hazardous materials used during construction and impacts are considered less than significant related to construction.

Operation
Non-residential tenants of the proposed buildings are unknown at this time so there is a potential that hazardous materials such as petroleum products, pesticides, fertilizer, and other household hazardous products may be stored and transported from the proposed facility during operation. However, these hazardous materials would not be manufactured at the Project site and would only be stored short-term before transport. And transportation of such materials would be required to comply with Titles 8, 22, and 26 of the CCR, and their enabling legislation set forth in Chapter 6.95 of the CHSC in addition to all applicable Federal, State, and local laws and regulations pertaining to the transport, use, disposal, handling, and storage of hazardous waste, including but not limited to the United States Department of Transportation (DOT) Office of Hazardous Materials Safety Title 49 of the CFR, and implemented by Title 13 of the CCR.

Should there be a need for short-term storage of hazardous materials, these materials are required to be stored in designated areas designed to prevent accidental release to the environment. The California Fire Code (CFC) requirements prescribe safe accommodations for materials that present a moderate explosion hazard, high fire or physical hazard, or health hazards. Compliance with all applicable federal and state laws related to the storage of hazardous materials would maximize containment and provide for prompt and effective clean-up if an accidental release occurs.

Section 5.6 City of Riverside
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Regulatory Records Review
As part of the regulatory records review process a database report from Environmental Risk Information Services (ERIS) was obtained. ERIS searches a myriad of Federal, State, and local government environmental databases during the preparation of their deliverables (WEIS-A, p. 12).

Federal Listings
The Federal standard ASTM database search identified the Project site to be listed in Resource Conservation and Recovery Act (RCRA) database as a Non-Generator (NON GEN). The records identify the Project site as an implementor not a generator. The RCRA NON GEN database identifies persons or sites that do not presently generate hazardous waste. No spills or violations are noted. (WEIS-A, p. 13) Four adjoining sites were listed on the RCRA small quantity generator (SQG), and RCRA NON GEN databases and include: Chevron Station, Jones Dry Cleaners, USA#1 Photo and Smart & Final.

However, no spills, monitoring enforcement or violations associated where associated with any of these sites. Therefore, these properties were not considered to be a significant environmental concern to the Project site. (WEIS-A, pp. 13-14)
There are 20 properties in the surrounding area identified on various federal databases including RCRA treatments/storage/disposal (TSD), RCRA SQG, and RCRA NON GEN databases (WEIS-A, p. 14).

However, these properties are not considered to be significant environmental concerns for the Project site due to factors such as distance to the Project site, orientation of the listed properties to the Project site, interpreted direction of groundwater flow, and/or regulatory case status.

State, Tribal, and Local Listings
The State, Tribal and local standard ASTM database search found the Project site to be listed on the Leaking Underground Fuel Tank (LUST), Historical Hazardous Substance Storage Information Database (HHSS), Delisted California Environmental Reporting System Tank (DELISTED CTNK), Historical Hazardous Substance Storage Container Information (HIST TANK) and Riverside County Local Oversight Program (LOP RIVERSIDE) databases. As indicated above, historical tank listings identify ten USTs were installed on the site in 1964. The fuel tanks were removed in 1985, the oil tanks were removed in 1987, and the fueling island and associated distribution lines were removed in 1994. Listings identify that in June 1985, leakage from on-site gasoline USTs was detected during tank removal and closure activities.

In 1988, the leakage case was referred to the SARWQCB. Six groundwater monitoring wells were installed in 1985 but abandoned in 1992 when four new wells were installed. Five more wells were eventually installed and quarterly groundwater monitoring began in 1993. Remedial activities reportedly included removal of free product and impacted soil. A “No Further Action” letter indicating regulatory closure for the release was issued on June 26, 2003. The letter indicates that corrective action should be reviewed in the future if land use changes are proposed. (WEIS-A, p. 15). Thus, subsequent review from the SARWQCB is required and is detailed below.

Three adjoining sites were listed on the Recycling Center (RECYCLING), Geotracker Cleanup Sites (CLEANUP SITES), Collection, and Community Service Programs Voluntary Cleanup Program (VCP), EnviroStor, Delisted Storage Tanks (DELISTED TNK), LUST, HHSS, UST, California Environmental Reporting System Tanks (CERS TANK), HIST TANK, Statewide Environmental Evaluation and Planning System Underground Storage Tank List (UST SWEEPS), LOP RIVERSIDE and Riverside County Underground Storage Tanks List (UST RIVERSIDE) databases and include: Alexys Recycling, Crown Cleaners, and Chevron Station/R&T Oil, Inc. With the exception of Crown Cleaners, these sites are not considered a significant environmental concern to the Project site. Crown Cleaners had a previously City of Riverside Sections 5.6
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detected leak in 2003 and remediation via excavation of PCE-impacted soil took pace in July 2003. PCE was not detected above 1.5 parts per million (ppm) in excavation confirmation samples so a case closure was provided via a “No Further Action” letter provided by SARWQCB in October 2003. In 2015, a subsurface evaluation identified PCR-impacted environmental media. However, only low groundwater PCE concentrations were reported. PCE that was previously identified in the subsurface at the Project site is potentially due to the release of dry cleaning solvents from Crown Cleaners. (WEIS-A, pp. 15-16).

There are three properties within the surrounding area identified on the CONTAINER RECY, LUST, AND UST SWEEPS databases. However, none of these properties are considered to have a negative contamination effect on the Project site, due to the nature of the site, and due to the distance from the Project site. (WEIS, p. 16).

Non-ASTM Listings
The Project site is also listed on a number of non-ASTM regulatory databases including the Facility Registry Service/Facility Index (FINDS/FRS), Hazardous Waste Manifest Data HAZNET, HIST MANIFEST, and Delisted Environmental Reporting System Hazardous Waste Sites (DELISTED HAZ) databases.

Findings include storage, manifesting, and disposal of hazardous waste materials including alkaline solutions, aqueous solutions with organic residue, asbestos containing waste, paint sludge, hydrocarbon solvents, halogenated solvents, liquids with halogenated compounds, waste oil, latex, unspecified organic material and liquids, and other unspecified solvents and inorganic waste. Reviewed listings are consistent with ASTM database findings and previously identified historical information and there are no spills or violations indicative of potential releases noted. The Project site is also listed on the Historical California Hazardous Material Incident Report System (HIST CHMIRS) database which identifies a propane release to mechanical failure of a tank on a Winnebago R/V. This listing is not considered an environmental concern to the Site. (WEIS-A, p. 16)
Eight adjoining sites were listed on the: HAZNET, CDL, FED DRYCLEANERS, DRYCLEANERS, EMISSIONS, CERS HAZ, HWG RIVERSIDE, and MED WST RIVERSIDE non-ASTM databases and include William Byrne DDS/Riverside West Dental Group, an illegal drug lab at 6975 Capistrano Street, Crown Cleaners/Jones Dry Cleaners, Wing Stop, Smart & Final, Del Taco, and R&T Oil, Inc. With the exception of the Crown Cleaners/Jones Dry Cleaners site, none of these sites are considered to be significant environmental concern to the Project site. As previously mentioned above, PCE that was previously identified in the subsurface at the Project site is potentially due to the release of drycleaning solvents that occurred related to the Crown Cleaners/Jones Dry Cleaners site. (WEIS, p. 16).

There are an additional ten properties within the surrounding area identified on the FED DRYCLEANERS, MRDS, DRYCLEANERS, CERS HAZ, EMISSIONS, CDL, HWG RIVERSIDE, and MED WST RIVERSIDE databases. However, none of these properties are considered to have a negative contamination effect on the Project Site due to factors such as distance to the Project site, orientation of the listed properties to the Project site, interpreted direction of groundwater flow, and/or regulatory case status.

Historical Resource Review
Historical research was conducted in order to identify previous uses of the Project site and surrounding area from present to when the site was first developed or 1940 (whichever is earlier). Historical aerial photographs show the Project site was previously used for agricultural purposes. From 1901 to 1947, several small structures are depicted on the southern portion of the site and roads appear along the southern and western portion of the site. small structures are also depicted on the adjoining properties.

In 1953, an increased number of small structures appear on the western and southern portions of the Section 5.6 City of Riverside
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site and significant residential development is reflected on adjoining properties. Two large structures are visible on the southern adjoining property. In 1967, the existing Sears structures and fuel islands are reflected and adjoining properties appear developed consistent with current development. (WEIS, p.21).

During historical agricultural activities throughout the State of California, various pesticides and more specifically organochlorine pesticides (OCPs) were commonly applied during the normal course of agricultural operations. Such compounds have since been banned from production and use in the United States. Based on regulatory and historical research no accidental spill or release of pesticide products is believed to have occurred on the Project site and the potential presence of residual agricultural chemicals in Site soils is not considered to be a REC in connection with the Project site.

However, as outlined below in Work Plan, and pursuant to SARWQCB direction, future soil sampling will be screened for potential presence of residual agricultural chemicals. (WEIS, p.21). For the Project site soil latest samples see the findings of the Comprehensive Subsurface Assessment below.

Project Site Reconnaissance
A Project site reconnaissance was conducted on September 22, 2021 which consisted of observing the exterior grounds on foot, the accessible portions of the interior of the Sears Department store building, and publicly accessible areas surrounding the Project site. Keys and/or property management with access to the Sears Automotive Service Center building and limited portions of the retail building basement level were not available during the site visit. (WEIS-A, p.23).

Within the Sears Department store, interior floor drains are present in the bathrooms and former maintenance areas. Reportedly, two sumps are present in the basement but were not accessible during site reconnaissance. A chiller and disconnected boiler are present in the retail building basement level.

Two public and two freight hydraulic elevators were observed in the Sears Department Store building.

With the exception of the central freight elevator, maintenance rooms were inaccessible during site reconnaissance. No staining was observed in the accessible elevator maintenance room. A loading dock and solid waste receptacle are present at the northern portion of the retail building. A trash compactor is present in the retail building basement. Minor staining was observed of the concrete floor in the trash compactor area. Exterior stormwater drains are also present throughout the parking area. Within the Sears Automotive Service Center, there is reportedly one elevator and nine hydraulic hoists present. (WEIS-A, pp.23-25).

Hence, the 2021 Phase I ESA concluded there is no evidence of current or controlled RECs’s in connection with the Project site. But the former presence of underground storage tanks at the Project site and the previous release of petroleum hydrocarbons, is considered to be a HREC. The SARWQCB previously issued a “No Further Action” letter for the site based on existing commercial land use. But any change to land use would require additional assessment by SARWQCB. An Addendum to the 2021 Phase I ESA (Addendum) was conducted to include assessment of the offsite alignment for utilities. The Addendum provided the same conclusion. (WEIS-B, pp. 1-2).

Work Plan
As the Project proposes a change in land use from commercial-retail to residential, an assessment from the SARWQCB was conducted in accordance with the recommendations of the 2021 Phase I ESA, Addendum, and City of Riverside General Plan DEIR Mitigation Measure MM Haz 1. In May of 2022, the Project site was entered into the SARWQCB Site Cleanup Program through an Oversight Costs Reimbursement Agreement. A project scoping teleconference between the Property Owner and City of Riverside Sections 5.6
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SARWQCB was conducted on May 31, 2022 and a draft sampling and analysis plan was provided to the SARWQCB as a follow up to this scoping teleconference.

Following review of the submittal, SARWQCB directed a Work Plan for the proposed land uses be completed. The purpose of the Work Plan is to document current environmental conditions in the soil and soil gas for future residential redevelopment. The data collected during the assessment was compared to various residential screening criteria pertaining to the protection of human health and the environment; more specifically as it relates to potential vapor intrusion. More specifically, the data was used to develop soil management and vapor mitigation measures (if necessary) during anticipated future redevelopment activities for residential land uses. SARWQCB requested a total of 47 sample borings be placed around the site to measure soil gas and conditions of the soil. Borings were placed at depths ranging from 1 to 20 feet below ground surface. (WEIS-C, p. 3, 7, 9).

The Comprehensive Subsurface Assessment implemented the SARWQCB directed Work Plan which resulted in the following findings (WEIS-D, pp. 3-4):
 With the exception of some staining and odors indicative of petroleum hydrocarbons in a limited area of the Site (former UST area), no suspect soil conditions were noted during the assessment work. The residual petroleum impacts were noted at depths of 15 to 30 feet in just a few of the 49 borings drilled at the Site. Soil at these depths will not be encountered during future grading activities. At one of the sampling locations (near a former fueling dispenser), stained and odorous soil was observed/noted at depths of 5 and 10 feet. Soil in this limited area may be encountered during future grading activities and can be segregated and removed from the Site under conventional soil management protocols.  No indications of chemicals releases were noted in any other areas of the Site (outside of the former UST system area).
 Low concentrations of gasoline and diesel range hydrocarbons were detected in six of the groundwater samples collected proximate to the former UST and fueling island system area. No benzene or methyl tert-butyl ether (primary VOCs of concern at UST release locations as referenced in the State of California Low-Threat Underground Storage Tank Case Closure Policy [PolicyLTCP]) were detected in the groundwater samples.
 There are no indications that free product is present at the Site, and free product was not observed during subsurface investigation activities.  PCE was detected in three of the groundwater samples at concentrations below the maximum contaminant level (drinking water standard). These locations are situated topographically downgradient (northwest) of the known chlorinated solvent release location (Crown Cleaners – 5190 Arlington Avenue). The release location is situated at distances ranging from approximately 650 to 950 feet from various locations along the southern Site boundary. Other groundwater samples further downgradient from the drycleaners in the southwest portion of the Site and more proximate to the former UST system contain the chlorinated VOC solvent trichloroethene (TCE) which is a breakdown product of PCE. Other chlorinated VOCs detected in groundwater at the Site that are consistent with the solvent release at 5190 Arlington Avenue include Freon-11 and Freon-113. In the absence of PCE in each of the on-site soil samples, lack of obtained and analyzed for VOCs at the Site and no substantial TCE detected in vadose zone soil, and lack of historical chlorinated solvent use at the Site (i.e., no Section 5.6 City of Riverside
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source identified), it is inferred that the presence of chlorinated solvents in groundwater at the Site resulted from the off-Site release at the drycleaners facility to the south and southeast of the Site. The cleaners drycleaning property is currently under the environmental oversight of the California Department of Toxic Substances Control (Site Code 401875 – Crown Cleaners/Heritage Plaza). Recent assessment was completed at this property in early 2023 and at this time, remedial actions pertaining to vapor intrusion considerations are being evaluated.  Several VOCs were detected in soil gas samples obtained from throughout the Site.

As anticipated, the highest concentrations of petroleum related VOCs were detected in and around the former UST system area. Benzene, ethylbenzene and naphthalene are the primary VOCs of concern at UST release locations as referenced in the State of California Low-Threat Closure PolicyLTCP. Naphthalene was not detected in any of the soil gas samples. All dDetected concentrations of benzene, and ethylbenzene, and naphthalene are the primary VOCs of concern at UST release locations as referenced in the LTCP. Detected concentrations of benzene, ethylbenzene, and naphthalene are below both residential and commercial health risk based screening levels as published in the LTCP except for location SG21 where the presence of a bio attention zone could not be demonstrated Policy (assuming that a bio attenuation zone is present). The presence of a bio attenuation zone was confirmed by way of analysis of soil gas samples for the presence of oxygen (all greater than the four percent target percentage noted in the Policy) and analysis of shallow (one to five feet) soil for the presence of petroleum hydrocarbons.  PCE is prevalent in soil gas throughout the Site. The highest PCE concentrations are along its southern boundary and typically in the deeper, 15-foot samples, further supporting the conclusion that Site impacts are associated with historical chlorinated solvent releases at 5190 Arlington Avenue. A few TCE detections were also noted in soil gas. Other prevalent chlorinated VOCs detected in soil gas at the Site that are consistent with the solvent release at 5190 Arlington Avenue include Freon-11, and Freon-113, and chloroform. Similar to groundwater impacts, it is inferred that the presence of chlorinated solvents in soil gas throughout the Site resulted from the off-Site release at the drycleaners facility to the south and southeast of the Site.

No further assessment of the existing Sear’s site is required in order to prepare the site for future development. In accordance with SARWQCB, future soil management related documents (i.e.

SCAQMD Rule 1166 Mitigation Plan) and vapor intrusion mitigation system plans and specifications can be uploaded to the GeoTracker Database, so that they are made available to the SARWQCB and the public. (WEIS-D, pp. 15-18).

Conclusion
Impacts from construction operations are considered less than significant from accidental releases of hazardous materials used during construction due to existing regulations in place to project workers, the public and the environment as discussed above. The Project is also not expected to result in groundwater impacts and based on the site investigations, no groundwater active remediation is warranted.

Existing residual petroleum impacts and chlorinated solvent impacts may be attributed to the former UST system at the Project site and off-site drycleaners facility at 5190 Arlington Avenue (WEIS-D, pp. 4- City of Riverside Sections 5.6
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5). However, with implementation of mitigation measures MM HAZ-1 and MM HAZ-2 which require soil decontamination and vapor barriers, impacts from existing residual petroleum and chlorinated solvents would be less than significant. Thus, through regulatory requirements and implementation of mitigation measures MM HAZ-1 and MM HAZ-2, the proposed Project will not create a significant hazard to the public or the environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials into the environment either through construction or operations.

Therefore, impacts are less than significant with incorporation of mitigation.

Threshold: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The Project site is located approximately one mile westerly of the Riverside Municipal Airport.(RMA) and approximately 5,151 feet southeast of runway 9-27. Pursuant to the RCALUCP, the Project site is located within Land Use Compatibility Zones B1, C and D, with majority of the Project site within B1.

Table 5.6-A, above, identifies basic land use compatibility criteria such as prohibited uses, residential density standards, non-residential intensity standards, and other development conditions within the Compatibility zones. Since the Project site is located within RMA’s Land Use Compatibility Zones B1, C and D, the Project is required to undergo review by the Riverside County Airport Land Use Commission (ALUC) for a consistency determination. On January 12, 2023, ALUC determined the proposed Project to be inconsistent with the RCALUP and is discussed in detail below. (ALUC-B, p. 1). ALUC also issues a letter to Riverside City Council expressing their concerns about the proposed Project (ALUC-D).

Site Density/Intensity
Table 5.6-C, Residential Density Consistency below, identifies the Project’s proposed residential density measured by dwelling units per acre (du/ac) across the three Compatibility Zones and the Project’s consistency with ALUC policy for each of those zones.

Table 5.6-C, Residential Density Consistency
Zone
Proposed
Dwelling Units
Proposed Project
Density
(du/ac)
Maximum Allowed
Density
(du/ac) Consistent
B1 382 28.0 0.05 No
C 1 2.0 0.2 No
D 5 10
Below 0.2
or
Above 4.0
Yes
Total Dwelling
Units 388
Source: ALUC-C, pp. 2-3
As reflected in Table 5.6-C above, the Project is consistent with ALUC residential density standards for Zone D. However, the Project is inconsistent with residential density standards for Zones B1 and C. (ALUC-C, pp. 2-3).

The proposed clubhouse/fitness/leasing office and grocery uses are sited in Zone B1 while proposed retail uses lie within Zone C. Table 5.6-D, Non-Residential Intensity Consistency, identifies the Section 5.6 City of Riverside
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Project’s proposed non-residential intensity (people per acre) across these two Compatibility Zones and the Project’s consistency with ALUC policy for each of those zones.

Table 5.6-D, Non-Residential Intensity Consistency
Proposed NonResidential Use
Project’s
Average
Acre
Intensity
Allowable
Maximum
Average Acre
Intensity Consistent
Project’s
Single
Acre
Intensity
Allowable
Maximum
Single Acre
Intensity Consistent
Clubhouse/Fitness/
Leasing Area
(ALUC Zone B1)
49 25 No 769 50 No
Grocery
(ALUC Zone B1) 81 25 No 203 50 No
Retail
(ALUC Zone C) 134 75 No 83 150 Yes
Source: ALUC-C, pp. 3-4
As reflected in Table 5.6-D above, the Project’s proposed retail uses are consistent with ALUC nonresidential intensity standards for development in Zone C. However, the Project’s proposed clubhouse/fitness/leasing area and grocery uses are not consistent with ALUC non-residential intensity standards for Zone B1. A second method for determining total occupancy involves multiplying the number of parking spaces provided or required (whichever is greater) by average vehicle occupancy (assumed to be 1.5 persons per standard vehicle). Based on a total of 815 vehicle parking spaces provided, the total occupancy would be estimated at 1,223 persons, resulting in an average intensity of 70 persons per acre. Utilizing this second method for determining total site occupancy still results in an inconsistency with the non-residential intensity criteria since the maximum average acre intensity criterion for Zone B1 is 25 people per acre and Zone C is 75 people per acre. (ALUC-C, pp. 3-4).

Thus, the Project is not consistent with residential density or non-residential site intensity requirements.

Airport Noise
As shown in Table 5.6-A, the RCALCUP has classified Zone B1 with a high noise impact, Compatibility Zone C has a moderate noise impact, and a moderated risk level and Zone D has a moderated noise impact and a low risk level. As previously indicated, most of the Project site lies within Compatibility Zone B1. As shown in Table 5.6-B above, Compatibility Zone B1 is the Inner Approach/Departure Zone of the RMA. Zone B1 is considered to be a "High Noise Impact” area since it lies mostly within the 60 Community Noise Equivalent Level (CNEL) contour and because single-event noise within this area is typically sufficient enough to disrupt a wide range of land use activities including indoor land uses if windows are open. (ALUC-C, pp. 5-6).

The Project proposes a number of outdoor recreational areas that may expose users to a moderate level of interference from aircraft noise. Aircraft noise may also impact indoor residential activities in the event windows are open (or if they are on an outdoor balcony/patio). Although standard construction is normally considered to provide for a 15 decibel reduction from exterior noise levels, implementation of mitigation measure MM HAZ-3 would incorporate noise attenuation measures into the design of the residences as may be necessary to ensure interior noise levels from aircraft operations are at or below 45 CNEL. (ALUC-C, p. 6).

City of Riverside Sections 5.6
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RMA policy 2.1 identifies that while the limit of 60 dB CNEL is set by Countywide Policy 4.1.4 as the maximum noise exposure considered normally acceptable for new residential land uses, for RMC, the criterion is instead 65 dB CNEL. This higher threshold recognizes that ambient noise conditions in the area are relatively high because of other major noise sources, particularly railroads and freeways. (RCALUCP, p. 3-30). However, the actual noise levels from airplanes is in the 55 dBA CNEL to 62 dBA CNEL range, which does not exceed the RMA or the City’s standards for exterior noise (dBA, p. 13).

Thus, the Project’s outdoor uses would not be impacted by Airport Noise since noise levels from airplanes are under RMA and City standards.

Safety
Compatibility Zone B1 is also associated with a “High Risk Level” because it encompasses areas overflown by aircraft at low altitudes (typically only 200 to 400 feet above runway). Approximately 10 to 20 percent of off-runway general aviation accidents near airports take place here so object heights are restricted to as little as 50 feet. The intent and purpose of Compatibility Zone B1 is to restrict residential density in order to limit the potential risk of an off-field aircraft landing. The Project proposes some three-story residential buildings within Compatibility Zone B1. The elevation of Runway 9-27 at its easterly terminus is 815.8 feet above mean sea level (AMSL). At a distance of approximately 5,151 feet from the runway to the site, Federal Aviation Administration (FAA) review would be required for any structures with top of roof exceeding 867 feet AMSL. The Project site elevation is 791 feet AMSL. With a maximum building height of 41.5 feet, the resulting top point elevation is 832.5 feet AMSL. Thus, structures do not exceed height requirements so FAA review is not required. However, buildings with more than two aboveground habitable floors are identified as a “prohibited use” in Compatibility Zone B1. Since the Project’s proposes three-story residential buildings, the Project is inconsistent with this ALUC criterion. (ALUC-C, pp. 5-6).

The Project proposes a variety of rooftop and carport solar panels with a fixed tilt of 10 degrees with no rotation, and an orientation of 90 degrees throughout the site. Based on the FAA’s Interim Policy for Review of Solar Energy System Projects on Federally Obligated Airports, no glare potential or low potential for temporary afterimage, referred to as “green” level, are acceptable levels of glare on final approach (within 2 miles from end of runway) for solar facilities located on airport property and is the recommended standard for properties near airports. Potential for temporary after-image referred to as “yellow level” and potential for permanent eye damage referred to as “red level” are not acceptable levels of glare on final approach. No glare is permitted at air traffic control towers. A solar glare study completed by Forge Solar was based on a 2-mile straight in approach in accordance with FAA Policy to runways 9-27, runways 16-34, as well as analyzing glare impacts to the air traffic control tower. All times are in standard time. The analysis concluded that some potential “green level” glare would occur within the 2 mile approach to runways 9-27 representing less than 9 percent of total daylight time and no glare would occur at the air traffic control tower. The solar panels do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and any electrical facilities that do carry concentrated current would be buried beneath the ground and away from any signal transmission.

Further, there are no radar transmission or receiving facilities within the site. Hence, the Project is consistent with glint/glare reflectivity standards and will provide no electrical or communication interference.

Because the Project site’s infiltration rates are so low, the Project has been authorized to utilize Modular Wetlands as a form of stormwater treatment. Hence, storm water will be conveyed via underground pipes to Modular Wetlands located throughout the Project site. where storm water will be captured and treated in underground chambers before being conveyed to the existing storm drain facilities in Streeter Section 5.6 City of Riverside
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Avenue; rather than through the use of above ground water quality basins. The use of an underground system would not contain surface water or attract wildlife. Hence, the Project’s water quality treatment would not constitute a hazard to flight. (ALUC-C, p. 6).

The Project is also required to provide qualifying open space areas based on percentages identified in Table 5.6-A, above. Qualifying open space means areas that have a minimum shape of 75 feet in width by 300 feet in length with no objects greater than four feet in height of up to four inches in diameter in order to provide a safe area for aircraft to land in the event of an emergency. The Project is required to provide a minimum of 4.99 acres of qualifying open space. However, the Project provides just over 2 acres which does not meet minimum quantity or the qualifying open space requirements. Thus, the project is inconsistent with ALUC open area requirements. (ALUC-C, p. 6).

City Land Use and Zoning Policies
The Project proposes an amendment to the General Plan Land Use designation from (C)Commercial to (MU-V) Mixed Use Village, and a rezone (CG) Commercial General to (MU-V) Mixed Use-Village. The City’s General Plan MU-V land use designation and MU-V zoning designation allows for a maximum 30 residential dwelling units per acre with retail, and office uses in the same building allowing for horizontal integration as appropriate with two (2) to three (3) stories in height. The Project’s proposed two-story town homes located in Compatibility Zone D with resulting density of 13 du/ac, are consistent with the Zone D residential density and height criteria. However, the MU-V land use and zoning designations allowing for 30 dwelling units per acre and up to three-story structures, is inconsistent with the maximum residential density and height criteria for Compatibility Zones B1and Zone C, as discussed above. Further, the General Plan Amendment and Rezone would be inconsistent with City Municipal Code 19.149 or 19.150; specifically sub-sections 19.149.020, 19.149.030, and 19.150.020.B and inconsistent with General Plan policies related to airports specifically LU-22.2, LU-22.3, and LU-22.5.

Thus, these two actions would result in inconsistency with RCALUCP plan and General Plan. (ALUC-C, pp. 7-8; GP 2025, pp. LU-36 – LU-39, LU-56).

Conclusion
ALUC Commissioners issued a letter finding the Project to be inconsistent with ALUC policy and a separate letter expressing their concerns over the Project. Pursuant to the PUC Sections 21676 and 21676.5, the City may overrule the ALUC’s inconsistency determination if, after a public hearing, the City makes findings that the Project is consistent with the purposes set forth in PUC sections 21670 and 21670(a)(2) which provides that the purpose of the State Aeronautics Act is to protect public health, safety and welfare by ensuring the orderly expansion of airports and the adopting of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The existing Sears Department Store and Automotive Service Center, as well as the existing residential, commercial and office uses surrounding the Project site are considered to be incompatible with ALUC policy so the area is already devoted to incompatible uses. As identified in Section 3.0 – Project Description, the Project includes a proposal to override ALUC’s inconsistency determination in accordance with PUC Sections 21670. In the event the City pursues and overrule to ALUC’s determination, ALUC has provided conditions of approval for which the Project shall be required to adhere.

Hence, the Project would be inconsistent with ALUC and City land use policy. However, the existing Sears Department Store and Automotive Service Center, as well as the existing residential, commercial, and office uses surrounding the Project site are also considered to be incompatible with ALUC policy.

So while the proposed Project resulted in an inconsistency determination from ALUC, it is consistent City of Riverside Sections 5.6
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and compatible with the existing surrounding land uses. Regardless, even with implementation of mitigation measure MM HAZ-3, the Project would result in a safety hazard or excessive noise for people residing or working in the project area so the City may override the ALUC determination pursuant to PUC Section 21670. Therefore, impacts would be significant and unavoidable.

5.6.8 Recommended Mitigation Measures
An Environmental Impact Report is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines § 15126.4). Mitigation measures were evaluated for their ability to eliminate or reduce the potential significant adverse impacts related to Hazards and Hazardous Materials.

Mitigation measures MM HAZ-1 and MM HAZ-2 are required to reduce impacts related to exposure to the public or the environment involving the release of hazardous materials to less than significant due to existing residual petroleum and chlorinated solvent impacts. Mitigation measure MM HAZ-3 shall be implemented to eliminate or reduce potentially significant impacts related to airport noise hazards.

MM HAZ-1 Decontamination of Soil. During grading activities, petroleum impacted soil at the former UST system area and around one boring location B21/SG21 per the Subsurface Assessment Report prepared by Weis Environmental dated November 3, 2023, the soil shall be removed, handled and mitigated in accordance with South Coast Air Quality Management District (SCAQMD) Rule 1166 (VOC Emissions from Decontamination of Soil) Mitigation Plan. Petroleum impacted soil shall be segregated from non-impacted soil using the convention soil management soil practices. However, petroleum impacted soil at greater depths in the former UST and fueling islands areas shall remain in place.

MM HAZ-2 Vapor Barriers. In order to mitigate the past contamination on the site related to the Sears Auto Service Center, the City building department shall ensure that final construction drawings on the Project reflect requirements from the Santa Ana Regional Water Quality Control Board (SARWQCB). Requirements from the SARWQCB could include conventional vapor barriers with passive sub-slab venting incorporated into foundation design of the proposed structures on the Project site.

MM HAZ-3 Airport Noise. Prior to issuance of a building permit for any residential building or unit, an acoustical analysis shall be conducted by a noise specialist meeting the requirements set forth in Riverside Municipal Code 16.08-175 B 5 to confirm that the noise insulation proposed in the final design is sufficient to achieve interior noise levels at or below 45 CNEL and exterior noise levels at or below 65 CNEL. Interior noise attenuation measures identified in said acoustical analysis shall be incorporated into the design of the residences, to the extent such measures are necessary, to ensure that interior noise levels are at or below 45 CNEL. Measures may include, but not be limited to, upgraded building façade elements (windows, doors, and /or exterior wall assemblies) with Sound Transmission Class (STC) rating of 35 or higher. If the interior limit can be achieved only with the windows closed, then the building design shall include mechanical ventilation that meets California Building Code requirements. Exterior noise attenuation measures, which shall be unit/structure specific, may include site design and building layout and/or noise barriers sufficient to achieve exterior noise levels at or below 65 CNEL.

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5.6.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
Implementation of local, state, and federal regulations, project design features, General Plan DEIR mitigation measures and project-specific mitigation measures listed above, will reduce exposure to the public or the environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials. Therefore, Project impacts will be less than significant with incorporation of mitigation.

Implementation of local, state, and federal regulations, project design features, and project-specific mitigation measures listed above, will reduce exposure to airport hazards. However, due to the Project’s proximity to the Riverside Municipal Airport and its location within the RCALUCP, the Project would still result in a safety hazard or excessive noise for people residing or working in the Project area. Therefore, Project impacts will be significant and unavoidable and a statement of overriding considerations will be required prior to Project approval.

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5.7 Land Use and Planning
The focus of this section is to analyze potential impacts related to land use and planning. The following discussion addresses the potential for adverse impacts that could result from the construction and operation as a result of the Project. Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics.

5.7.1 Setting
The Project site entails an approximately 17.43 gross acre within the City of Riverside. Future development of all land within the City is guided by the City’s 2025 General Plan (2025 GP) which was adopted in 2007 and Phase I of the Updated General Plan adopted in 2021 (GPUI). The GP outlines is a broad framework for planning the future of the City expressing the City’s vision of its long-term physical form and development and serves as a basis for decision making. The GP was developed in accordance with California state law and is comprised of the following elements: Land Use and Urban Design, Housing, Circulation and Community Mobility, Arts and Culture, Education, Open Space and Conservation, Air Quality, Public Facilities and Infrastructure, Parks and Recreation, Historic Preservation, Public Safety, and Noise.

Existing and Surrounding Land Uses
The City of Riverside (City) is located in the northwestern portion of Riverside County. The City is bounded on the north by the Cities of Jurupa Valley, Colton, and Grand Terrace and the unincorporated community of Highgrove, to the east by the City of Moreno Valley, to the south by the unincorporated community of Woodcrest, and to the west by the Cities of Corona and Norco.

The existing Project site includes two existing vacant commercial buildings located on the 17.43 gross acre parcel associated with the former Sears Department Store and Automotive Service Center constructed in 1964. These structures are eligible for listing in the National Register for Historic Places, California Register for Historic Resources, and the City of Riverside Historical Landmarks. The former department store was located in the central building, now a vacant structure. The interior of the vacant department store building includes retail areas, warehouse and supply storage areas, sub-grade basement areas, public and freight hydraulic elevators, and restrooms. The basement area contains a disconnected boiler, trash compactor, and emergency generator. A smaller automotive service center structure is located on the western portion of the property. This building includes six bay doors opening to a concrete-paved former service area with secondary containment structures, nine hydraulic hoists, and a sub-grade oil/water separator. (WEIS-A, p. 4).

The Project site is located within the Riverside County Airport Land Use Compatibility Plan (RCALUCP); specifically, the Riverside Municipal Airport (RMA) and located approximately one mile from the airport runway. The Project site is located within Land Use Compatibility Zones B1, C, and D (refer to Figure

3.0-7 in Section 3.0 – Project Description of this Draft EIR) which restricts maximum residential density and non-residential intensity. As such, the Project has been reviewed by the Riverside County Airport Land Use Commission (ALUC) to determine compatibility with the RCALUCP. The ALUC determined via a public hearing January 12, 2023, that the Project is inconsistent with the RCALUCP. A detailed discussion is provided in Section 5.6 – Hazards and Hazardous Materials of this Draft EIR.

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Existing General Plan Land Use and Zoning Designations
The Project site has a General Plan Land Use Designation of (C) – Commercial and a zoning designation of (CG) - Commercial General as reflected in Figure 3.0-5 and Figure 3.0-6 of Section 3.0 – Project Description of this Draft EIR.

Proposed Land Use Applications
The proposed Project includes the following entitlement applications for consideration by the City of Riverside:
 General Plan Amendment (GPA): Proposes to amend the general plan land use designation from (C) - Commercial to (MU-V) - Mixed Use-Village as per Figure 3.0-8 in Section 3.0 – Project Description of this Draft EIR.
 Re-Zone (RZ): Proposes to rezone the site from (CG) - Commercial General to (MU-V) Mixed Use-Village as per Figure 3.0-9 in Section 3.0 – Project Description of this Draft EIR.  Site Plan Review (PPE): Proposes to develop the 17.43-gross acre (17.37 net acre site after dedication of 0.05 acres along Arlington Avenue for roadway right-of-way) with a 576,203 square foot (sf) mixed-use apartment and commercial development. Proposal includes development of 27 residential apartment buildings consisting of 2- and 3-story structures that would provide for a total of 388 residential dwelling units, one clubhouse building, and two commercial buildings providing for 546,474 sf of residential use and 4,409 sf associated clubhouse/leasing building, and 25,320 sf of commercial-retail use as per Figure 3.0-10 in Section 3.0 – Project Description of this Draft EIR.
 Tentative Parcel Map No. 38638 (TPM): Proposes to subdivide the 17.37-net acre site into 2 parcels for financing, conveyance, and phasing purposes. Parcel 1 will consist of 14.44 net acres for residential development and Parcel 2 will consist of 2.93-net acres for commercialretail development as per Figure 3.0-11 in Section 3.0 – Project Description of this Draft EIR in Section 3.0 – Project Description of this Draft EIR.
 Certificate of Appropriateness (COA): Proposal to demolish the existing, vacant, Sears structures. The Sears structures were built in 1964 and have been deemed eligible for listing in the California Register of Historic Resources under Criterion 3, National Register for Historic Places, and the City of Riverside Historical Landmarks.

5.7.2 Related Regulations
Federal Regulations
No federal regulations would be applicable to land use and planning with respect to the proposed Project.

State Regulations
Article XI, Section 7 of the California State Constitution is the primary authority for cities and counties to regulate land use. California State Planning and Land Use Law (Government Code § 65000 et seq.) sets forth minimum standards to be observed in local land use regulatory practices, reserving in cities and counties the maximum degree of control in such matters (CGC).

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Regional Regulations
Riverside Municipal Airport Land Use Compatibility Plan The Riverside County Airport Land Use Commission (ALUC) is the lead agency responsible for airport land use compatibility planning in Riverside County. The fundamental purpose of ALUC is to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The basic function of the airport land use compatibility plans is to promote compatibility between airports and the land uses that surround them. Compatibility plans serve as a tool for use by airport land use commissions in fulfilling their duty to review proposed development plans for airports and surrounding land uses. Additionally, compatibility plans set compatibility criteria applicable to local agencies in their preparation or amendment of land use plans and ordinances and to landowners in their design of new development. In March 2005, ALUC adopted the Riverside County Airport Land Use Compatibility Plan (LUCP); hereinafter referred to as the RCALUCP. The compatibility zones and associated criteria set forth in the LUCP provide noise and safety compatibility protection. 2012-2035 Regional Transportation Plan/Sustainable Communities Strategy The SCAG regional council adopted the 2016 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) in April 2016. The 2016 RTP/SCS seeks to improve mobility, promote sustainability, facilitate economic development, and preserve the quality of life for the residents in the region. The longrange vision plan balances future mobility and housing needs with goals for the environment, the regional economy, social equity, environmental justice, and public health. The goals included in the 2016 RTP/SCS are meant to provide guidance for considering projects within the context of regional goals and policies.

The RTP provides an opportunity to identify transportation strategies today that address mobility needs for the future. The SCS is a new element of the RTP that demonstrates the integration of land use, transportation strategies, and transportation investments within the Plan. This requirement was put in place by the passage of Senate Bill (SB) 375, with the goal of ensuring that the SCAG region can meet its regional greenhouse gas reduction targets set by the California Air Resources Board (CARB). The SCS exceeds the targets issued by CARB (which are 8 percent reductions by 2020 and 13 percent reductions by 2035), resulting in a 9 percent reduction by 2020 and 16 percent by 2035.

Local Regulations
City of Riverside General Plan
The City of Riverside General plan contains policies that are considered applicable to the proposed Project, as identified below (GP 2025 pp. LU-26 – LU-37):

Land Use/Urban Design Element
Objective LU-8 Emphasize smart growth principles through all steps of the land development process
Policy LU-8.2 Avoid density increases or intrusion of nonresidential uses that are incompatible with existing neighborhoods.

Policy LU-8.3 Allow for mixed-use development at varying intensities at selected areas as a means of revitalizing underutilized urban parcels.

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Objective LU-9 Provide for continuing growth within the General Plan Area, with land uses and intensities appropriately designated to meet the needs of anticipated growth and to achieve the community's objectives.

Policy LU-9.3 Designate areas for urban land uses where adequate urban levels of public facilities and services exist or are planned, in accordance with the public facilities and service provisions policies of this General Plan.

Policy LU-9.4 Promote future patterns of urban development and land use that reduce infrastructure construction costs and make better use of existing and planned public facilities when considering amendments to the Land Use Policy Map (Figure LU-10).

Policy LU-9.7 Protect residentially designated areas from encroachment by incompatible uses and from the effects of incompatible uses in adjacent areas. Uses adjacent to planned residential areas should be compatible with the planned residential uses and should employ appropriate site design, landscaping and building design to buffer the non-residential uses.

Objective LU-10 Provide for appropriate timing of development in accordance with the future land uses designated in this Land Use Element
Policy LU-10-1 Discourage the premature development of non-urbanized areas and encourage growth, through such programs as the Residential Infill Incentive Program, first in undeveloped and under-developed areas within, adjacent to or in close proximity to existing urbanized neighborhoods.

Objective LU-22 Avoid land use/transportation decisions that would adversely impact the longterm viability of the March Air Reserve Base/March Inland Port, Riverside Municipal and Flabob Airports.

Policy LU-22.2 Work cooperatively with the Riverside County Airport Land Use Commission in developing, defining, implementing, and protecting airport influence zones around the MARB/MIP, Riverside Municipal and Flabob Airports and in implementing the new Airport Land Use Compatibility Plan.

Policy LU-22.3 Work to limit the encroachment of uses that potentially pose a threat to continued airport operations, including intensification of residential and/or commercial facilities within identified airport safety zones and areas already impacted by current or projected airport noise.

Policy LU-22.5 Review all proposed projects within the airport influence areas of Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport as noted in the Public Safety Element (Figure PS-6A – Riverside Municipal and Flabob Airport Safety Zones and Influence Areas; and Figure PS-6B – March ARB/IPA Airport Safety Zones and Influence Areas) for consistency with all applicable airport land use compatibility plan policies adopted by the Riverside County Airport Land Use Commission (ALUC) and the City of Riverside, to the fullest extent the City finds feasible.

City of Riverside Sections 5.7
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Policy LU-22.7 Prior to the adoption or amendment of the General Plan or any specific plan, zoning ordinance or building regulation affecting land within the airport influence areas of the airport land use compatibility plan for Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport, refer such proposed actions for determination and processing by the ALUC as provided by Public Utilities Code Section 21670.

Policy LU-22.8 The City may from time to time elect to voluntarily submit proposed actions or projects that are not otherwise required to be submitted to the ALUC under Airport Land Use law in the following circumstances:
a. Clarification: If there is a question as to the purpose, intent, or interpretation of an airport land use compatibility plan (ALUCP) or its provisions; or b. Advisory: If assistance is needed concerning a proposed action or project relating to Airport Land Use matters; or.
c. ALUC Request: The ALUC requests that certain types be voluntarily submitted for review. These actions are identified in the ALUCP as “major land use action.”
Policy LU-22.9 All development proposals within an airport influence area and subject to ALUC review will also be submitted to the manager of the affected airport for comment.

Objective LU-28 Preserve and enhance the quality and character of Riverside by ensuring compliance with all relevant codes and regulations.

Policy LU-28.2 Encourage the rehabilitation or replacement of dilapidated housing units and buildings, discouraging further deterioration. Where necessary, seek to remove unsafe structures.

Objective LU-32 Preserve existing residential areas within the Airport Neighborhood.

Policy LU-32.1 Encourage developers of single-family residences to include a higher level of sound attenuation in new homes than required by City standards.

Objective LU-35 Maintain Arlington's sense of community through careful and coordinated planning that builds upon the neighborhood's key assets and reinforces its historic development patterns.

Policy LU-35.1 Focus commercial development at major intersections, discouraging “strip” commercial development
City of Riverside 2025 General Plan EIR
The are no applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to Land Use and Planning.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

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City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Land Use and Planning.

City of Riverside Municipal Code
Title 17 – Grading. This title sets forth rules and regulations intended to further implement the goals and objectives of the General Plan, to control evacuation, grading, and earthwork construction, including fills and embankments. It also establishes the administrative procedures for grading plan approval, issuance of permits, inspections, and establishes penalties for unauthorized grading activity. The purpose of this title is to protect life, limb, property, the public welfare, and the physical environment by regulating grading on private property. It is further the purpose of this title to regulate hillside and arroyo grading in a manner which minimizes the adverse effects of grading on natural landforms, soil erosion, dust control, water runoff and construction equipment emissions.

Title 18 – Subdivision. Establishes the comprehensive subdivision regulations of the City in conformance with current State planning, zoning, subdivision, and related development laws. The purpose of this Subdivision Code is to regulate and control the design and improvement of subdivisions within the City.

Title 19 – Zoning. The purpose of the Zoning Code is to encourage, classify, designate, regulate, restrict and segregate the highest and best location and use of buildings, structures and land for agriculture, residence, commerce, trade, industry, water conservation or other purposes in appropriate places; to regulate and limit the height, number of stories and size of buildings and other structures hereafter erected or altered; to regulate and determine the size of yards and other open spaces; and, to regulate and limit the density of population and for such purpose to divide the City into zones of such number, shape and area as may be deemed best suited to carry out these regulations and provide for their enforcement. These regulations encourage the most appropriate use of land; conserve and stabilize the value of property; provide adequate open spaces for light and air and prevent and fight fires; prevent undue concentration of population; lessen congestion on streets; facilitate adequate provisions for community utilities and facilities such as transportation, water, sewerage, schools, parks and other public facilities; and promote the public health, safety and general welfare, all as part of the General Plan of the City.

Chapter 19.120 – Mixed Use Zones. Mixed-use zones are established to provide development opportunities for integrated, complementary residential and commercial development on the same parcel or a contiguous group of parcels. Singular, stand-alone uses are permitted when they foster an overall mixture of uses in the zone. A wide range of uses is permitted, and it is the intent of these zones to foster a mixture of product types. Development solely as commercial or residential districts is strongly discouraged. Design and development standards for all three zones are directed toward encouraging pedestrian activity and ensuring that mixed commercial and residential uses are designed to be compatible both within the development and with other surrounding areas.

Chapter 19.120.050 Mixed Use Development Standards. This chapter identifies the development standards applicable to all development in the mixed-use zones.

Chapter 19.149 – Airport Land Use Compatibility. The purpose of this chapter is to establish and implement the requirements of the Riverside County Airport Land Use Compatibility Plan (RCALUCP) for airports that affect land uses within the City of Riverside. Airports that affect land uses within the City of City of Riverside Sections 5.7
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Riverside are the Riverside Municipal Airport, Flabob Airport, and the March Air Reserve Base/Inland Port Airport.

Chapter 19.149.020 – Airport Land Use Compatibility Plan (ALUCP). For property located within a compatibility zone and subject to airport land use compatibility plan policies and criteria, land use, density, and intensity limitations of the ALUCP may be more restrictive than what would otherwise be allowed per City zoning designation applicable to the property. In addition to complying with the Zoning requirements of this title, proposed uses and development on property within an airport compatibility zone must be determined to be consistent with, and comply with the compatibility criteria of the applicable compatibility zone and airport land use compatibility plan.

Chapter 19.149.030 – Airport Land Use Commission (ALUC). This chapter identifies the purpose of the ALUC which is to conduct airport land use compatibility planning. ALUCs protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public's exposure to excessive noise and safety hazards within areas around public airports.

Chapter 19.150 – Base Zones Permitted Land Uses. This section establishes land use regulations for all base zones listed in this article consistent with the stated intent and purpose of each zone.

Chapter 19.150.020 – Permitted Land Uses. This chapter identifies through sub-section 19.150.020.B that Airport Land Use Compatibility includes additional Airport Land Use Compatibility Plan requirements for discretionary actions proposed on property located within an Airport Compatibility Zone. When located within an Airport Land Use Compatibility Zone, greater land use restrictions for airport compatibility may apply per the applicable Airport Land Use Compatibility Plan. Specifically, the permitted land use table identifies multiple-family dwellings in the Mixed Use Village zone as a permitted use by the City, but it also identifies that the uses are also subject to the ALUCP criteria where use may be strictly prohibited.

Chapter 19.640 – General Permit Provisions. This chapter establishes the overall structure for the application, review, and action on discretionary permits and legislative actions. Further, it identifies and describes the permits regulated by the Zoning Code. It also identifies those minor activities, uses, and structures that are exempt from permit requirements. It further requires compliance with all applicable laws and regulations.

City of Riverside Citywide Design Guidelines and Sign Guidelines The City of Riverside adopted Citywide Design Guidelines and Sign Guidelines in November 2007 which were later amended and approved in January 2019. The purpose of these guidelines are to reinforce the physical image of Riverside which the City’s prosperity, well-being, and the value and contribution of agriculture, cultural diversity, industry and manufacturing, education, and architectural heritage of the city. The image of the City’s residential neighborhoods and neighborhood shopping centers emphasizes a small-town character within an urban metropolis. The physical image of Riverside provides an aesthetic that attracts the City’s work force, employers, residents, and visitors. The guidelines work to reinforce this physical image of Riverside and are intended to promote quality, well-designed development throughout Riverside that enhances existing neighborhoods, creates identity, and improves the overall quality of life within the City by promoting a desired level of future development within the City. (RCDG).

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5.7.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding land use and planning in response to the Initial Study/Notice of Preparation (IS/NOP).

5.7.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the thresholds of significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A) prepared for this Project, and as outlined in Section 4.0 of this DEIR, implementation of the proposed Project will have a less than significant impact in the following area and this topic is not addressed in this DEIR:
 Physically divide an established community.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following area and this topic is addressed in this DEIR:
 Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

5.7.5 Project Design Features
Design features refer to ways in which the proposed Project will avoid or minimize potential impacts through the design of the Project. The proposed Project has been designed with sensitivity to the adjacent land uses and the existing residential neighborhoods by siting commercial uses along the frontage of Arlington Avenue and three story residential buildings along the Streeter Avenue frontage.

Residential uses closest to adjacent single family residential neighborhoods to the north and east have been designed to be two story townhomes. Public open space areas for dining/gathering have been located where they can be easily accessed by the public.

5.7.6 Methodology
The following discussion analyzes the proposed Project’s consistency with applicable GP goals policies for the purposes of avoiding or mitigating an environmental effect.

5.7.7 Environmental Impacts
Threshold: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Section 15125(d) of the State CEQA Guidelines requires EIRs to “…discuss any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans.” The objective of such a discussion is to find ways to modify a proposed project, if warranted, to reduce any identified inconsistencies with relevant plans and policies. Pursuant to Section 15125(d), this Draft EIR includes an evaluation of the consistency of the proposed Project with pertinent goals and policies of relevant adopted local and regional plans.

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The existing General Plan Land Use designations and Zoning designations for APN 226-180-015-1 are not consistent with the proposed use. Hence, a General Plan Amendment and Rezoning are required for consistency.

The Project includes a proposal to amend the existing General Plan Land Use designation of the project site currently designated General Plan Land Use Designation of C – Commercial and a zoning designation of CG – Commercial General as shown on Figure 3.0-5, Existing General Plan Land Use Designation and Figure 3.0-6, Existing Zoning Designation in Section 3.0 - Project Description of this Draft EIR, respectively. The Project proposes a General Plan Amendment (GPA) to amend the General Plan Land Use designation from (C) – Commercial to (MU-V) – Mixed Use-Village as shown on Figure

3.0-7, in Section 3.0 – Project Description of this Draft EIR. Once the GP Amendment is approved, the planned uses for the site would be fully consistent with the site’s General Plan (MU-V) land use designation.

The Project also includes a proposal to rezone (RZ) the Project site from (CG) – Commercial General to (MU-V) Mixed Use-Village as shown on Figure 3.0-9 in Section 3.0 – Project Description of this Draft EIR. Development of the Project site is regulated by the development regulations and design standards contained within the City’s Zoning Ordinance. The City of Riverside’s Zoning Ordinance is contained as Chapter 19 of the City of Riverside Municipal Code. The proposed Project would be subject to the City of Riverside Municipal Code Chapter 19.120 – Mixed Use Zones and Chapter 19.640 – General Permit Provisions.

The primary purpose of the Mixed Use Zone is to provide development opportunities for integrated, complementary residential and commercial development on the same parcel or a contiguous group of parcels. Singular, stand-alone uses are permitted when they foster an overall mixture of uses in the zone. A wide range of uses is permitted, and it is the intent of these zones to foster a mixture of product types. Development solely as commercial or residential districts is strongly discouraged. Design and development standards for all three zones are directed toward encouraging pedestrian activity and ensuring that mixed commercial and residential uses are designed to be compatible both within the development and with other surrounding areas. The primary purpose of the General Permit Provisions is to establish the overall structure for the application, review, and action on discretionary permits and legislative actions. Further, it identifies and describes the permits regulated by the Zoning Code. It also identifies those minor activities, uses, and structures that are exempt from permit requirements. It further requires compliance with all applicable laws and regulations.

The proposed General Plan Amendment and Rezone will bring the Project site’s land use and zoning designations consistent with the proposed uses. City MC Chapter 19.100.040 identifies that total gross acreage be utilized to determine residential density. With respect to the MU-V zone, maximum allowable density is 30 dwelling units per acre (du/ac). As identified in MC Chapter 19.120.050, development standards are applicable to all development within the mixed-use zone. As such, all parcels proposed as MU-V as part of this Project are coupled to the same development standards meaning the entire gross acreage of 17.43 gross acres is utilized to calculate residential density. In accordance with City MC, the Project would result in an overall site density of 22.3 du/ac. However, in order to provide the most conservative density calculation, the net acreage of proposed residential parcel alone, was utilized to calculate maximum site density for this Project. As a result, the Project would result in a maximum residential density of 26.9 dwelling units per acre (du/ac). 1 This density is consistent with the MU-V
designation as it is still less than the maximum density of 30 du/ac. As such, the proposed Project

1. 388 Dwelling Units ÷14.44 Residential Acres = 26.9 du/ac Section 5.7 City of Riverside
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would be fully consistent with the Riverside General Plan objectives and policies identified in Section

5.7.2 except for the following; Objective LU-22, Policy LU-22.2, Policy LU -22.3, Policy LU-22.5 and Policy LU-22.7 due to the Project’s proximity to the Riverside Municipal Airport. The Project site is located within Zones B1, C, and D of the RMA LUCP. As discussed in Section 5.6 – Hazards and Hazardous Materials of this Draft EIR, the Project was determined by the Riverside County ALUC to be inconsistent with this plan. Since the Project is located within the RMA LUCP airport zones and the Project is inconsistent with the land use and density designations outlined in each of the applicable zones of the RMA LUCP, the Project would be inconsistent with the five identified Riverside General Plan objectives and policies. However, as also identified in Section 5.6.7 – Environmental Impacts, pursuant to the Public Utilities Code (PUC) Sections 21676 and 21676.5, the City may overrule the ALUC’s inconsistency determination if, after a public hearing, the City makes findings that the Project is consistent with the purposes set forth in PUC sections 21670 and 21670(a)(2) which provides that the purpose of the State Aeronautics Act is to protect public health, safety and welfare by ensuring the orderly expansion of airports and the adopting of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The existing Sears Department Store and Automotive Service Center, as well as the existing residential, commercial and office uses surrounding the Project site are considered to be incompatible with ALUC policy so the area is already devoted to incompatible uses. The Project does include a proposal to override ALUC’s inconsistency determination in accordance with PUC Section 21670. In the event the City pursues and overrule to ALUC’s determination, ALUC has provided conditions of approval for which the Project shall be required to adhere.

The Southern California Association of Governments (SCAG) regional council adopted Connect SoCal 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) a detailed discussion of the Project’s consistency with applicable SCAG’s Connect SoCal policies can be found in Table 6.0-B in Section 6.0 – Consistency with Regional Plans.

Thus, because the proposed Project was found inconsistent with the RMA LUCP by the Riverside County Airport Land Use Commission, it will conflict with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the Project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect unless the City overrides the inconsistency determination in accordance with PUC Section 21670. Therefore, impacts are significant and unavoidable.

5.7.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). Mitigation measures MM HAZ-3 and MM NOI-1 outlined in Section 5.6 – Hazards and Hazardous Materials and Section 5.8 – Noise, respectively, shall be implemented to reduce impacts related to reduce potentially significant impacts related to airport noise hazards. However there are no mitigation measures that can lessen impacts to land use and planning as a result of the inconsistency determination with the RCALUCP. Summary of Project-Specific Environmental Effects After Mitigation Measures are Implemented.

Implementation of local, state, and federal regulations, and project design considerations listed above, provide consistency with General Plan land use and zoning, GP policies and the MC. However, the proposed Project is inconsistent with the RCALUCP as discussed in Section 5.6 – Hazards and City of Riverside Sections 5.7
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Hazardous Materials of this Draft EIR. Therefore, impacts will be significant and unavoidable and a statement of overriding considerations will be required prior to Project approval.

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5.8 Noise
The focus of this section is to analyze potential impacts related to noise. The following discussion addresses the potential for adverse impacts that could result from the construction and operation as a result of the Project. Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics of this Draft EIR.

The analysis in this section is based on the Exterior Noise Analysis Report Arlington Mixed-Use, prepared by dBF Associates, dated October 28, 2023 (dBF). This report is herein referred to as the Noise Analysis and is contained in its entirety in Appendix E of this Draft EIR.

5.8.1 Setting
The area surrounding the Project site is currently dominated by residential, commercial, and office uses.

The Project site is located within the boundaries of the Riverside Municipal Airport Land Use Compatibility Plan (RMA LUCP). Noise sources in the Project area consist of vehicular traffic along Arlington Avenue, Streeter Avenue, and aircraft operations associated with RMA.

Characteristics of Sound
This section presents a discussion of noise fundamentals applicable to the Project, together with an assessment of existing ambient noise levels and noise sources in the Project vicinity. Sound is a pressure wave created by a moving or vibrating source that travels through an elastic medium such as air. Noise is most often defined as unwanted sound. The City of Riverside is subject to typical urban noises, such as noise generated by traffic, heavy machinery, and day-to-day outdoor activities (GP 2025 FEIR, p. 5.11-2).

Although exposure to high noise levels has been demonstrated to cause hearing loss, the principal human response to environmental noise is annoyance. The response of individuals to similar noise events is diverse and influenced by the type of noise, perceived importance of the noise and its appropriateness in the setting, time of day and type of activity during which the noise occurs, and sensitivity of the individual. (dBF, p. 3).

Noise Fundamentals
Although sound can be easily measured, the perceptibility is subjective and the physical response to sound complicates the analysis of its impact on people. People judge the relative magnitude of sound sensation in subjective terms such as “noisiness” or “loudness.” Sound pressure magnitude is measured and quantified using a logarithmic ratio of pressures, the scale of which gives the level of sound in decibels (dB). The human hearing system is not equally sensitive to sound at all frequencies. Therefore, to approximate this to human frequency-dependent response, the A-weighting filter system is used to adjust measured sound levels and is expressed as dBA. Noise levels using A-weighted measurements are written dB(A) or dBA. Table 5.8-A, Typical Noise Levels of Common Sounds below, shows the relationship of various noise levels to common noise events. (GP 2025 FEIR, p. 5.11-2).

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Table 5.8-A, Typical Noise Levels of Common Sounds
Common Outdoor Activities Noise Level
(dBA) Common Indoor Activities
110 rock band
jet fly-over at 1,000 feet 105
100
gas lawnmower at 3 feet 95
90 85 food blender at 3 feet
diesel truck, 50 mph at 50 feet 80 garbage disposal at 3 feet noisy urban area during daytime 75
gas lawnmower at 100 feet 70 vacuum cleaner at 10 feet
commercial area 65 normal speech at 3 feet
heavy traffic at 300 feet 60
55 large business office
quiet urban area during daytime 50 dishwasher in next room 45 quiet urban area during nighttime 40 theater, large conference room (background) quiet suburban area during nighttime 35
30 library
quiet rural area during nighttime 25 bedroom at night, concert hall (background) 20 15 broadcast/recording studio
10 5
lowest threshold of human hearing 0 lowest threshold of human hearing Source: CT-A, Table 2-5; GP 2025 EIR, Table 5.11-A
From the noise source to the receiver, noise changes both in level and frequency spectrum. The most obvious is the decrease in noise as the distance from the source increases. The manner in which noise reduces with distance depends on whether the source is a point or line source as well as ground absorption, atmospheric effects, and refraction, and shielding by natural and manmade features. Sound from small, localized sources radiates uniformly outward as it travels away from the source in a spherical pattern. The noise drop-off rate associated with this geometric spreading is 6 dBA per each doubling of the distance (dBA/DD). (CT-A, pp. 2-27-2.28).

Transportation noise sources such as roadways are typically analyzed as line sources, since at any given moment the receiver may be impacted by noise from multiple vehicles at various locations along the roadway. Because of the geometry of a line source, the noise drop-off rate associated with the geometric spreading of a line source is 3 dBA/DD. (CT-A, pp. 2-27-2.28; FTA, p. 69).

Decibels are measured on a logarithmic scale, which quantifies sound intensity in a manner similar to the Richter scale used for earthquake magnitudes. Thus, a doubling of the energy of a noise source, such as a doubled traffic volume, would increase the noise levels by 3 dBA; halving of the energy would result in a 3 dBA decrease. (CT-A, pp. 2-15, 6-5).

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It is widely accepted that the average healthy ear can barely perceive changes of 3 dBA; that a change of 5 dBA is readily perceptible, and that an increase (decrease) of 10 dBA sounds twice (half) as loud. (CT-B, pp. 3-2, 3-8, 7-1).

Noise Descriptors
Because community noise (environmental, residential, or domestic sources) fluctuates over time, a single measure called the Equivalent Sound Level (Leq) is often used to describe the time-varying character of community noise. (CT-A, p. 2-48).

The Leq is the energy-averaged A-weighted sound level during a measured time interval and is equal to the level of a continuous steady sound containing the same total acoustical energy over the averaging time period as the actual time-varying sound. Additionally, it is often desirable to know the acoustic range of the noise source being measured. This is accomplished through the Lmax and Lmin indicators, which represent the root-mean-square maximum and minimum noise levels obtained during the measurement interval. The Lmin value obtained for a particular monitoring location is often called the “acoustic floor” for that location. (dBF, p. 5).

To describe the time-varying character of environmental noise, the statistical noise descriptors L10, L50, and L90 are commonly used. They are the noise levels equaled or exceeded during 10, 50, and 90 percent of a stated time, respectively. Sound levels associated with L10 typically describe transient or short-term events, whereas levels associated with L90 describe the steady-state (or most prevalent) noise conditions. (dBF, p. 5).

Noise standards for land use compatibility are stated in terms of the Community Noise Equivalent Level (CNEL) and the Day-Night Average Noise Level (Ldn). CNEL is a 24-hour weighted average measure of community noise. CNEL is obtained by adding five decibels to sound levels in the evening (7:00 PM to 10:00 PM), and by adding ten decibels to sound levels at night (10:00 PM to 7:00 AM). This weighting accounts for the increased human sensitivity to noise during the evening and nighttime hours. Ldn is a similar 24-hour average measure that weighs only the nighttime hours. (dBF, p. 5).

The Day-Night Average Sound Level (Ldn or DNL) is also an adjusted average A-weighted sound level for a 24-hour day, similar to CNEL. It is calculated by adding a 10-dB adjustment to sound levels during nighttime hours (10:00 p.m. to 7:00 a.m.); there is no adjustment applied to evening hours. DNL is considered to be equivalent to CNEL. This descriptor is used by the City of Riverside to evaluate landuse compatibility with regard to noise. (dBF, p. 5).

Vibration
Groundborne vibration propagates from the source through the ground to adjacent buildings by surface waves. Vibration may be comprised of a single pulse, a series of pulses, or a continuous oscillatory motion. The ground motion caused by vibration is measured in vibration decibels (VdB). The background vibration velocity level in residential areas is usually around 50 VdB. The vibration velocity level threshold of perception for humans is approximately 65 VdB. A vibration velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels for many people.

The general human response to different levels of groundborne vibration velocity levels is described in Table 5.8-B, Human Response Levels to Groundborne Vibration below. (GP 2025 EIR, p. 5.11-4).

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Table 5.8-B, Human Response Levels to Groundborne Vibration Vibration Velocity Human Behavior
65 VdB Approximate threshold of perception for many people 75 VdB
Approximate dividing line between barely perceptible and distinctly perceptible. Many people find that transportation-related vibration at this level is unacceptable.
85 VdB Vibration acceptable only if there are an infrequent number of events per day
Source: GP 2025 EIR, Table 5.11-B
Most perceptible indoor vibration is caused by sources within buildings such as the operation of mechanical equipment, movement of people, or the slamming of doors. Typical outdoor sources of perceptible groundborne vibration are construction equipment, steel-wheeled trains, and traffic on rough roads. If roadways are smooth, the groundborne vibration from traffic is rarely perceptible. The range of interest is from approximately 50 VdB, which is the typical background vibration velocity level, and 100 VdB, which is general threshold where minor damage can occur in fragile buildings. Table 5.8-C, Typical Levels of Groundborne Vibration below, depicts the typical vibration levels and its sources. (GP 2025 EIR, p. 5.11-4).

Table 5.8-C, Typical Levels of Groundborne Vibration
Human/Structural Response Velocity
Level (VdB)
Typical Sources
(50 ft from source)
Threshold, minor cosmetic damage
fragile buildings 100 Blasting from construction projects Bulldozers and other heavy tracked
construction equipment
Difficulty with tasks such as reading a
VDT screen 90
Commuter train, upper range
Residential annoyance, infrequent
events (ex: commuter rail) 80 Rapid transit, upper range Residential annoyance, infrequent
events (ex: rapid transit)
Commuter rail, typical
Bus or truck over bump
70 Rapid transit, typical
Approx. threshold for human
perception Bus or truck, typical
60 Typical background vibration
50 Source: GP 2025 EIR, Table 5.11-C
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The frequency of a vibrating object describes how rapidly it is oscillating, measured in Hz. Most environmental vibrations consist of a composite, or “spectrum” of many frequencies, and are classified as broadband or random vibrations. The normal frequency range of most groundborne vibration that can be felt generally starts from a low frequency of less than 1 Hz to a high of about 200 Hz. Vibration data is expressed in terms of the peak particle velocity (PPV) in inches per second (in/sec). The PPV is the velocity of the soil particles resulting from a disturbance. Table 5.8-D, Vibration Damage Potential, below shows FTAs building damage threshold.

Table 5.8-D, Vibration Damage Potential
Building Category PPV (in/sec)
Reinforced-concrete, steel, or timber (no plaster 0.50
Engineered concrete and masonry (no plaster) 0.30
Non-engineered timber and masonry buildings 0.20
Buildings extremely susceptible to vibration damage 0.12 Source: FTA, Table 7-5
Existing Site and Surrounding Conditions
As the Project site lies within an existing urban setting, an American National Standards Institute (ANSI Section SI4 1979, Type 2) RION Model NL-31 sound level meter was used to document existing ambient noise levels. To do so, three (3) daytime noise measurements were taken on September 28, 2022, that were approximately 10 minutes in length. As shown on Figure 5.8-1, Ambient Noise Measurement Locations below, noise measurements were taken along the Project site’s northeast, west, and southeast property lines. The closest sensitive receptors to the Project site are the residential properties along the eastern and northern boundary, adjacent to the Project site, as well as the residential properties west of the Project site along Streeter Avenue. (dBF, pp. 7. 11).

Table 5.8-E, Existing (Ambient) Noise Levels below, provides a summary of the short-term ambient noise data. Ambient noise levels ranged between 51.5 and 69.0 dBA Leq at the three locations monitored. The primary existing noise source was from vehicles traveling along adjacent roadways and the secondary noise source was from aircraft operations associated with the Riverside Municipal Airport. (dBF, p. 9).

Table 5.8-E, Existing Noise Levels (dBA)
Site
Location1 Time dBA Leq Lmin Lmax L(10) L(50) L(90)
ML1 12:20 p.m. – 12:30 p.m. 68.5 52.2 79.6 72.4 65.8 57.9 ML2 12:35 p.m. – 12:45 p.m. 69.0 45.4 78.8 72.6 67.3 55.8 ML3 12:55 p.m. – 1:15 p.m. 51.5 41.2 72.9 53.1 67.3 44.2 Source: dBF, Table 2
Notes:

1. Location per Figure 5.9-A

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Vehicle Traffic
The Project site is adjacent to Arlington Avenue, an east-west roadway, to the south and Streeter Avenue, a north-south roadway to the west of the Project site. Arlington Avenue carries an existing (2022) average daily traffic (ADT) volume of approximately 57,600 vehicles at California Avenue. Streeter Avenue carries an existing (2022) ADT volume of 37,450 vehicles at El Molino. The nearby posted speed limit is 40 miles per hour. (dBF, p. 9).

Airport
The Project site is located southeast approximately 0.63 miles from the Riverside Municipal Airport and is within the Riverside Municipal Airport Comprehensive Land Use Compatibility Plan (RMCLUP). The Project Site is located within the Riverside Municipal Airport Compatibility Zones B1, C, and D as reflected in Figure 3.0-7 in Section 3.0 – Project Description of this Draft EIR. Most of the Project site lies within Zone B1 with smaller portions of the Project site located within Zones C and D. The RMCLUP identifies that the Project site is located within 55-60 CNEL noise contour. (RMA LUCP, Exhibit RI-7).

5.8.2 Related Regulations
To limit the population’s exposure to physically and/or psychologically damaging noise levels, the federal government, the State, various County governments, and most municipalities in California have established standards and ordinances to control noise.

Federal Regulations
Noise Control Act of 1972
The United States Environmental Protection Agency’s (EPA’s) Office of Noise Abatement and Control was established to coordinate federal noise control activities (EPA 2018). The Noise Control Act of 1972 establishes a national policy to promote an environment for all Americans free from noise that jeopardizes their health and welfare. The Act also serves to (1) establish a means for effective coordination of Federal research and activities in noise control; (2) authorize the establishment of Federal noise emission standards for products distributed in commerce; and (3) provide information to the public respecting the noise emission and noise reduction characteristics of such products. (EPA 2017).

In 1981, EPA administrators determined that subjective issues such as noise would be better addressed at lower levels of government. Consequently, in 1982 responsibilities for regulating noise control policies were transferred to State and local governments. However, noise control guidelines and regulations contained in EPA rulings in prior years remain in place by designated Federal agencies, allowing more individualized control for specific issues by designated Federal, State, and local government agencies. (EPA 2018).

Federal Transit Administration and Federal Railroad Administration Standards Although the Federal Transit Administration (FTA) standards are intended for federally-funded mass transit projects, the impact assessment procedures and criteria included in the FTA Transit Noise and Vibration Impact Assessment Manual, September 2018, are routinely used for projects proposed by local jurisdictions. The FTA and Federal Railroad Administration (FRA) have published guidelines for assessing the impacts of ground-borne vibration associated with rail projects, which have been applied by other jurisdictions to non-rail projects. The FTA measure of the threshold of architectural damage for conventional sensitive structures is 0.2 inch per second peak particle velocity (PPV).

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Occupational Safety and Health Administration (OSHA)
The federal government regulates occupational noise exposure common in the workplace through the Occupational Safety and Health Administration (OSHA). Noise regulations apply to the operation of construction equipment and may apply to industrial land uses. Noise exposure of this type is dependent on work conditions and is addressed through a facility’s Health and Safety Plan, as required under OSHA, and will not be addressed further in this analysis. (OSHA).

State Regulations
State of California General Plan Guidelines 2003
Through not adopted by law, the State of California General Plan Guidelines 2003 and updated in 2017, published by the California Governor’s Office of Planning and Research Guidelines (OPR Guidelines), provide guidance for the compatibility of projects within areas of specific noise exposure. The OPR Guidelines identify the suitability of several types of construction relative to a range of outdoor noise levels and provide each local community some flexibility in setting local noise standards that allow for the variability in community preferences. The OPR Guidelines include a Noise and Land Use Compatibility Matrix that identifies acceptable and unacceptable community noise exposure limits for various land use categories. The City of Riverside has utilized the State’s noise/land use compatibility matrix as a model to create their own. (OPR 2017, pp. 131-140, 374).

Figure 5.8-2, Land Use/Noise Compatibility Guidelines depicts the land use compatibility chart for community noise prepared by the State of California, Department of Health, as adopted by the City of Riverside. It identifies normally acceptable, conditionally acceptable, and clearly unacceptable noise levels for siting various new land uses. A conditionally acceptable designation implies new construction or development should be undertaken only after a detailed analysis of the noise reduction requirements for each land use is made and the needed noise insulation features are incorporated in the design. By comparison, a normally acceptable designation indicates that standard construction can occur with no special noise reduction requirements.

California Code of Regulations, Part 2, Title 24, Appendix Chapter 35, Section 3501 establishes the State Noise Insulation Standards, which limit the interior noise level exposure within new hotels, motels, dormitories, long-term care facilities, apartment houses and dwellings. This State standard indicates that interior noise levels attributable to exterior noise sources shall not exceed 45 dB (CNEL or Ldn) in any habitable room.

Business and Professions Code Section 11010 and Civil Code Sections 1102.6, 1103.4, and 1353 address buyer notification requirements for lands around airports and are available on-line at http://www.leginfo.ca.gov/calaw.html. Any person who intends to offer subdivided lands, common interest developments and residential properties for sale or lease within an airport influence area is required to disclose that fact to the person buying the property.

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Green Building Standards Code
The California Green Building Standards Code (“Green Code”) limits noise within non-residential buildings. Relevant portions include the following:
 5.507.4.2 Performance method. For buildings located as defined in Section 5.507.4.1 or

5.507.4.1.1 (exposed to a noise level of 65 dB Leq-1-hr during any hour of operation), wall and roof-ceiling assemblies exposed to the noise source making up the building or addition envelope or altered envelope shall be constructed to provide an interior noise environment attributable to exterior sources that does not exceed an hourly equivalent noise level (Leq-1Hr) of 50 dBA in occupied areas during any hour of operation.

Regional Regulations
Riverside Municipal Airport Land Use Compatibility Plan The Riverside County Airport Land Use Commission (ALUC) is the lead agency responsible for airport land use compatibility planning in Riverside County. The fundamental purpose of ALUC is to protect public health, safety, and welfare by ensuring the orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The basic function of the airport land use compatibility plans is to promote compatibility between airports and the land uses that surround them. Land Use Compatibility Plans (LUCP) serve as a tool for use by airport land use commissions in fulfilling their duty to review proposed development plans for airports and surrounding land uses. Additionally, compatibility plans set compatibility criteria applicable to local agencies in their preparation or amendment of land use plans and ordinances and to landowners in their design of new development. In March 2005, ALUC adopted the Riverside County Airport Land Use Compatibility Plan (RCALUCP). The compatibility zones and associated criteria set forth in the RMA LUCP provide noise and safety compatibility protection. The Project site is located within Land Use Compatibility Zones B1, C, and D which restrict maximum residential density and non-residential intensity. As such, the Project has been reviewed by ALUC to determine compatibility with the RCALUCP. The ALUC determined via a public hearing January 12, 2023, that the Project is inconsistent with the RCALUCP.

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside General plan contains policies and implementation tools that are considered applicable to the proposed Project, as identified below (GP 2025, pp. 5.11-17 – 5.11-20):

Noise Element
In compliance with California Government Code Section 65302, the GP 2025 Noise Element identifies noise and land use compatibility criteria that identifies “Normally Acceptable,” “Conditionally Acceptable,” “Normally Unacceptable,” and “Conditionally Unacceptable” noise exposure ranges for various land uses as shown on Figure 5.8-2, Land Use/Noise Compatibility Guidelines (Figure N-10 of the GP 2025).

These standards are primarily used for planning purposes such as determining a project’s compatibility with a proposed site with regard to existing and future acoustical impacts upon a project site sourced from the surrounding environment. In other words, the noise impacts from existing surrounding land uses to a proposed project.

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The “Normally Acceptable” range is defined as: specific land use is satisfactory, based on the assumption that any building is of normal conventional construction, without any special noise insulation requirements.

The “Conditionally Acceptable” range is defined as: new construction or development should be undertaken only after a detailed analysis of noise reduction requirements is made and needed noise insulation features included in design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning, will normally suffice.

The “Normally Unacceptable” range is defined as: new construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of noise reduction requirements must be made and include needed noise insulation features in design.

The “Conditionally Unacceptable” range is defined as: new construction or development should generally not be undertaken, unless it can be demonstrated that noise reduction requirements can be employed to reduce noise impacts to an acceptable level. If new construction or development does proceed, a detailed analysis of noise reduction requirements must be made and include needed noise insulation features in the design.

Noise Element Policies
Policy N-1.1 Continue to enforce noise abatement and control measures particularly within residential neighborhoods.

Policy N-1.2 Require the inclusion of noise-reducing design features in development consistent with standards in Figure N-10 – Noise/Land Use Compatibility Criteria (see Figure 5.8-2 of this Draft EIR above), Title 24 California Code of Regulations and Title 7 of the Municipal Code.

Policy N-1.3 Enforce the City of Riverside Noise Control Code to ensure that stationary noise and noise emanating from construction activities, private developments/residences and special events are minimized.

Policy N-1.4 Incorporate noise considerations into the site plan review process, particularly with regard to parking and loading areas, ingress/egress points and refuse collection areas.

Policy N-2.1 Ensure that new development can be made compatible with the noise environment by using noise/land use compatibility standards in Figure N-10 – Noise/Land Use Compatibility Criteria (see Figure 5.8-2 of this Draft EIR above) and the airport noise contour maps (found in the Riverside County Airport Land Use Compatibility Plans) as guides to future planning and development decisions.

Policy N-2.2 Avoid placing noise-sensitive land uses (e.g., residential uses, hospitals, assisted living facilities, group homes, schools, day care centers, etc.) within the high noise impact areas (over 60 dB CNEL) for Riverside Municipal Airport and Flabob Airport in accordance with the Riverside County airport Land Use Compatibility Plan.

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Policy N-2.5 Utilize the Airport Protection Overlay Zone, as appropriate, to advise landowners of special noise considerations associated with their development.

Policy N-3.2 Work with the Riverside County Airport Land Use Commission and the March Joint Powers Authority to develop noise/land use guidelines and City land use plans that are consistent with ALUC policies.

Policy N-4.1 Ensure that noise impacts generated by vehicular sources are minimized through the use of noise reduction features (e.g., earthen berms, landscaped walls, lowered streets, improved technology).:

Noise Element Implementation Tools
Tool N-1: Review development proposals to ensure that the noise standards and compatibility set forth in the Noise Element are met to the maximum extent practicable. Require acoustical analyses for all proposed development within the 60 dB CNEL contour as shown in the Noise Element and for all proposed residential projects within the vicinity of existing and proposed commercial and industrial areas. Require mitigation, where necessary, to reduce noise levels to meet standards and construction methods.

Tool N-2: Implement CEQA during the development review process for new projects.

Assess future development projects’ potential for noise and ground-borne vibration impacts related to noise land use compatibility, construction-related noise, on-site stationary noise sources, and vehicular-related noise.

Tool N-3: Continue to enforce City noise regulations to protect residents from excessive noise levels associated with nuisance and stationary noise sources (Title 7 of the City of Riverside Municipal Code). Periodically evaluate regulations for adequacy and revise, as needed, to address community needs and changes in legislation and technology.

Tool N-4: Ensure proposed development meets Title 24 Noise Insulation Standards for construction.

Circulation and Community Mobility Element Policies
Policy CCM-2.9 Design all street improvement projects in a comprehensive fashion to include consideration of street trees, pedestrian walkways, bicycle lanes, equestrian pathways, signing, lighting, noise, and air quality wherever any of these factors are applicable.

Policy LU-22.3 Work to limit the encroachment of uses that potentially pose a threat to continued airport operations, including intensification of residential and/or commercial facilities within identified airport safety zones and areas already impacted by current or projected airport noise.

Policy LU-22.4 Adopt and utilize an Airport Protection Overlay Zone and the Riverside County airport Land Use Compatibility Plan as it affects lands within the City of Riverside.

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Policy LU-22.5 Review all proposed projects within the airport influence areas of Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport as noted on Figure PS-6 – Airport Safety Zones and Influence Areas (in the General Plan) for consistency with all applicable airport land use compatibility plan policies adopted by the Riverside County Airport Land Use Commission (ALUC) and the City of Riverside, to the fullest extent the City finds feasible.

City of Riverside 2025 General Plan EIR
The following mitigation measures from the Riverside 2025 General Plan EIR are applicable pertain to Noise.

MM NOISE 1: To minimize impacts resulting from or to proposed projects such that noise levels exceed General Plan Noise Element standards, projects shall be reviewed against the noise compatibility matrix in the Noise Element of the General Plan (Table 5.11-D, herein) and Figures

5.11-6, 5.11-7, 5.11-8, 5.11-9, and 5.11-10 of this EIR to determine suitability of the use in relation to adjacent land uses and noise sources such as roadways, freeways, and airports. To the extent required by the compatibility matrix or one of the figures, a noise study shall be required to evaluate noise levels against standards and to recommend suitable mitigation consistent with Title 24 regulations and the City’s Noise Code. Mitigation may include but not be limited to: walls, berms, interior noise insulation, double paned windows, or other noise mitigation measures as appropriate, in the design of new residential or other noise sensitive land uses. (GP 2025 FEIR, p. 5.11-42)
The preparation of the Noise Analysis satisfied mitigation measure MM NOISE 1.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Noise.

City of Riverside Municipal Code
The following sections of the City’s Municipal Code are applicable and pertain to Noise:

Chapter 16.08.175 Exterior Noise Insulation Standards. This section establishes uniform minimum noise insulation performance standards to protect persons within new hotels, motels, apartment houses, and all other dwellings including detached single-family dwellings from the effects of excessive exterior noise, including but not limited to, hearing loss or impairment and persistent interference with speech and sleep. This section also requires submittal of an acoustical analysis with the building permit application.
 Interior Levels. Interior day-night average sound levels (Ldn) with windows closed, attributable to exterior sources shall not exceed an Ldn of 45 decibels (dBA) in any habitable room.  Airport noise source. Residential structures to be located within an Ldn contour of 60 dBA or higher require an acoustical analysis showing that the structure has been designed to limit intruding noise to the allowable interior noise levels prescribed in this subsection. The Ldn contour shall be determined in accordance with Ldn noise levels anticipated by the Riverside general plan or by more current Ldn contour maps developed for governmental agencies and deemed acceptable by the Planning Director.

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 Vehicular and industrial noise sources. Residential buildings or structures to be located within Ldn contours of 60 dBA or higher from the select system of County roads and City streets (as specified in Section 186.4 of the State Streets and Highways Code), freeways, State highways, railroads, rapid transit lines and industrial noise sources shall require an acoustical analysis showing that the proposed building has been designed to limit intruding noise to the allowable interior noise levels prescribed in this subsection. The Ldn contour shall be determined in accordance with Ldn noise levels anticipated by the Riverside General Plan or by more current Ldn contour maps developed for governmental agencies and deemed acceptable by the Planning Director. Exception: Railroads, where there are no nighttime (10:00 p.m. to 7:00 a.m.) railway operations and where daytime (7:00 a.m. to 10:00 p.m.) railway operations do not exceed four per day.
 Compliance. Evidence of compliance with this chapter of the municipal code shall consist of submittal of an acoustical analysis report, prepared under the supervision of a person experienced in the field of acoustical engineering, with the application for building permit. The report shall show topographical relationship of noise sources and dwelling site, identification of noise sources and their characteristics, predicted noise spectra at the exterior of the proposed dwelling structure considering present and future land usage, basis for the prediction (measured or obtained from published data), noise attenuation measures to be applied, and an analysis of the noise insulation effectiveness of the proposed construction showing that the prescribed interior noise level requirements are met. If interior allowable noise levels are met by requiring that windows be inoperable or closed, the design for the structure must also specify the means that will be employed to provide ventilation, and cooling if necessary, to provide a habitable interior environment.

Chapter 7.25.010 Exterior Sound Level Limits. This section specifies standards for exterior sound level limits. Per RMC 7.25.010 it is unlawful to for any person to cause or allow the creation of any noise that exceeds the levels set forth in Table 5.8-F, Exterior Noise Standards. This table summarizes the exterior noise standards by land use. If the measured ambient noise level exceeds that permissible within any of the first four noise limit categories, the allowable noise exposure standard shall be increased in five decibel increments in each category as appropriate to encompass the ambient noise level. In the event the ambient noise level exceeds the fifth noise limit category, the maximum allowable noise level under said category shall be increased to reflect the maximum ambient noise level.

Table 5.8-F, Exterior Noise Standards
Land Use Time Period Noise Level
Residential
Nighttime1 45 dBA
Daytimme1 55 dBA
Office/Commercial Anytime 65 dBA
Industrial Anytime 70 dBA
Community Support Anytime 60 dBA
Public Recreation Facility Anytime 65 dBA
Non-Urban Anytime 70 dBA
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Source: MC, Table 7.25.010 B
Notes:

1. Nighttime hours 10 p.m. to 7 a.m.; Daytime hours 7 a.m. to 10p.m Based on the ambient noise measurements collected as part of the Noise Analysis, noise levels at the southern and western property lines of the Project site (shown on Figure 5.9-A as ML1 and ML2, respectively) currently exceed the exterior noise standards reported in Table 5.8-F, above. As indicated in Table 5.8-E, Existing Noise Levels (dBa Leq), the existing ambient noise levels at ML1 and ML2 are

68.5 and 69.0 Leq, respectively. Chapter 7.30.015 Interior Noise Level Limits. This section specifies standards for operational noise sources. Table 5.8-H, Interior Noise Standards below summarizes the interior noise standards by land use at when measured inside the dwelling unit, school, or hospital.

Table 5.8-G, Interior Noise Standards
Land Use Time Period Noise Level
Residential
Nighttime1 35 dBA
Daytimme1 45 dBA
School Daytime1 while school is in session 45 dBA
Hospitals Anytime 45 dBA
Source: MC, Table 7.30.015
Notes:

1. Nighttime hours 10 p.m. to 7 a.m.; Daytime hours 7 a.m. to 10p.m Chapter 7.35.020 – Exemptions. This chapter, specifically subsection (G) Construction identifies those uses exempt from noise ordinance. Noise sources associated with construction, repair, remodeling, or grading of any real property; provided a permit has been obtained from the City as required; and provided said activities do not take place between the hours of 7:00 p.m. and 7:00 a.m. on weekdays, between the hours of 5:00 p.m. and 8:00 a.m. on Saturdays, or at any time on Sunday or a federal holiday.

5.8.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding noise in response to the Initial Study/Notice of Preparation (IS/NOP).

5.8.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the thresholds of significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

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As identified in the Initial Study (Appendix A), prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies;
 Generation of excessive groundborne vibration or groundborne noise levels; and  For a project located within the vicinity of a private airstrip of an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.

5.8.5 Project Design Features
The Project includes design features that includes a 6-foot cinder block wall (also referred to as Concrete masonry unit wall [CMU wall]) screen walls along the perimeter of the adjacent resident uses to screen and block noise and vibration, provide a buffer between the existing residential development to the east and the north of the Project site to mitigate noise impacts to adjacent uses. Specifically, the residential portion of the Project site will be surrounded by a 6 foot high tubular steel fence, 6 foot high block wall, or combination block wall/steel fence as reflected in Figure 3.0-27 in Section 3.0 – Project Description of this Draft EIR.

5.8.6 Methodology
The Noise Analysis reviewed the proposed Project’s construction noise and operational noise (offsite traffic noise and onsite operational noise). The purpose of the Noise Analysis is to provide an assessment of the noise impacts resulting from development of the proposed Project and to identify mitigation measures that may be necessary to reduce those impacts in the context of the California Environmental Quality Act (CEQA). There are two types of noise impacts applicable to any project; noise impacts to a project and noise impacts from a project. Noise from the proposed Project is generated during the construction and operational phases. Noise impacts to the Project may be from non-Project sources, such as airport operations, railroads, and traffic as well as from Project-generated noise.

Construction Noise
The magnitude of the noise impact during construction is a function of the type of construction activity, equipment, duration of the construction activity, distance between the construction noise source and receptor, and intervening structures. Noise levels associated with construction activities of the Project were estimated based on information from the Project developer for construction equipment requirements and schedule. It was assumed that construction of the Project will take 23 months to complete and that construction would be built in two phases with the first phase being commercial parcel and the second phase being the residential parcel. Construction is anticipated to commence July 2024. A grading plan and construction phasing plan has not been finalized at the time of this analysis; therefore, only a general estimate of construction noise levels can be provided.

The proposed Project would include the demolition of the existing vacant former Sears buildings (Sears Department Store building, Sears Auto Center building, and all appurtenances). Demolition would include removal of both structures, parking lot, existing onsite utility lines, and existing vegetation including trees. A protective fence with windscreen material would be installed around the Project site City of Riverside Sections 5.8
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during demolition to obscure views. Project construction would utilize crushed materials from the site as engineered fill material. Based on the Table 5.2, Estimated Construction Schedule in Section 5.2 – Air Quality of this Draft EIR, demolitions will take place over approximately 20 days. No blasting is anticipated as part of the Project. However, heavy machinery such as, but not limited, to crushing/processing equipment, concrete/industrial saws, excavators, rubber tired dozers, and other small- to medium-sized construction equipment may be utilized.

The Project would implement conventional construction techniques and equipment. The sound levels of standard equipment would range from 65 dBA to 95 dBA at 50 feet from the source (i.e., the piece of equipment). Worst case construction noise levels are associated with grading activities. Grading would require the use of heavy equipment such as bulldozers, backhoes, water tucks, and rollers. No blasting would be required. Noise sources associated with grading of the proposed Project, and associated noise levels, are shown in Table 5.8-H, Grading Noise Source Levels, below. (dBF, p 16).

Table 5.8-H, Grading Noise Source Levels
Noise Source Noise Level Number
Bulldozer 80 dBA at 10 meters 1
Backhoe 69 dBA at 10 meters 1
Water Truck 81 dBA at 10 meters 1
Roller 73 dBA at 10 meters 1
Source: dBF, Table 3
The Datakustik Cadna/A industrial noise prediction model was used to estimate worst-case noise from construction activity. It was assumed that up to four pieces of equipment at any given time would operate continuously within the grading boundary. No correction was made for downtime associated with equipment maintenance, breaks, or similar situations. And no noise reduction related to ground effects, atmospheric absorption, or intervening topography was taken into account in the model. (DBF, p 16).

Operational Noise
Sources of Project-related operational noise are mechanical equipment and Project-generated traffic.

The following basic parameters were used in the modeling assumptions. The Project applicant proposes development of approximately 576,203 sf of residential and commercial-retail uses. The residential component of the proposed Project includes development of 27 residential buildings. The commercial component of the proposed Project includes development of 25,320 sf of commercial-retail use by way of two commercial-retail buildings totaling 5,000 sf in the southeastern portion of the site along Arlington Avenue. The Project also includes a 5,000 sf multi-tenant retail speculative pad with an adjoining outdoor dining/flex space and a 20,320 sf grocery store.

As described in the Noise Analysis, the Federal Highway Administration (FHWA) Traffic Noise Model (TNM) version 2.5 was used to estimate traffic noise levels. The modeling calculations take into account the peak-hour traffic volumes, average estimated vehicle speed, and the estimated vehicle mix (percentage of cars, medium trucks, heavy trucks, buses, and motorcycles). The peak-hour traffic noise Section 5.8 City of Riverside
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was considered equivalent to the interior day-night average sound levels (Ldn) / Community Noise Equivalent Level (CNEL). (dBF, p. 12).

The model assumed pavement propagation conditions which corresponds to a drop-off rate of approximately 3 dBA per doubling distance. Noise attenuation effects such as changes in elevation, topography, and intervening structures were not included in the model to represent a worst-case representation of the roadway nose. (dBF, p. 12).

The Project would result in an operational-related noise impact if Project-generated noise levels conflict with the noise standards set forth in RMC Chapters 7.25.010 and 7.35.010, which are shown in Table

5.8-F, Exterior Noise Standards and Table 5.8-G, Interior Noise Standards.

Mechanical Equipment
One rooftop HVAC unit is proposed to be positioned over each of the residential units while three units are proposed on top the clubhouse/fitness/ leasing building. Each HVAC unit was assumed to be a 3-ton HVAC that would produce a sound power level of approximately 77 dBA. Rooftop HVAC units were treated as stationary point sources and assumed to be constantly operational. It is anticipated that there would be four 12.5-ton HVAC units on the commercial (grocery) structure, and two 10-ton units on the other retail building proposed by the Project. The units on the commercial spaces are expected to produce a sound power level of 88-90 dBA. These units would be at least 50 feet from the nearest residential property line and would be shielded with solid parapets at least as tall as the units. Further, they would not be in operation during nighttime hours of 10:00 om to 7:00 am. The Datakustik Cadna/A industrial noise prediction model was used to estimate operational noise levels from noise sources on the Project site. (dBF, p. 15).

Project Generated Traffic Noise
As described in the Noise Assessment, the Federal Highway Administration (FHWA) Traffic Noise Model (TNM) version 2.5 was used to estimate traffic noise levels. The modeling calculations consider the peak-hour traffic volumes, average estimated vehicle speed, and the estimated vehicle mix (percentage of cars, medium trucks, heavy trucks, buses, and motorcycles). (dBF, pp. 12). Project generated traffic would result in a noise related impact if traffic noise levels would result in an increase of 3 dBA at nearby roadways.

Vibration
The potential ground-borne vibration levels resulting from construction activities occurring from the proposed Project were estimated by data published by the Federal Transit Administration (FTA). Thus, the groundborne vibration levels generated by these sources have also been quantitatively estimated and compared to the applicable thresholds of significance listed below.

There are no City or state vibration standards applicable to the proposed Project. As such, available guidelines from the FTA are utilized to assess impacts due to ground-borne vibration. The FTA has adopted vibration standards that are used to evaluate potential building damage impacts related to construction activities. As shown in Table 5.8-D above, the threshold at which there is a risk to “architectural” damage to residential structures (non-engineered timber and masonry buildings) is a PPV of 0.2. The FTA has also adopted standards associated with human annoyance for groundborne vibration. As shown on Table 5.8-B above the FTA has identified that 75 VdB is the threshold for annoyance from groundborne vibration at sensitive receptors. As such, impacts would be significant if City of Riverside Sections 5.8
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construction activities result in groundborne vibration of 0.2 PPV or higher at residential structures or 75 VdB.

Noise Impacts to the Project
According to the City of Riverside 2025 General Plan Final Environmental Impact Report (the GP 2025 FEIR), the City relies on the noise compatibility matrix in the GP 2025 Noise Element identified in Figure

5.8-2, above to determine if a future development project will be subject to significant noise impacts, whether self-created or from the existing environment. Therefore, a significant noise impact to the proposed Project may occur if noise at the Project site produced by surrounding sources, including Project-generated traffic, will exceed:
 75 Ldn / CNEL at the residential portion of the Project Site. This noise level was selected because it is the highest “Conditionally Acceptable” noise level for Infill Single Family Residential land uses.1
 75 Ldn / CNEL at the commercial portion of the Project Site. This noise level was selected because it is the highest “Conditionally Acceptable” noise level for Office Buildings, Business, Commercial, Professional land uses.

5.8.7 Environmental Impacts
Threshold: Would the Project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Impacts for this threshold are Project-related noise impacts are evaluated from the perspective of noise impacts to the Project and noise impacts from the Project.

Temporary Noise Levels
Construction
Construction noise is considered temporary because once construction is completed this noise source ceases. On-site construction and demolition of the structures at the Project site will result in the generation of new temporary noise from the transport of workers, the movement of construction materials to and from the Project site, demolition of the existing structures, excavation, grading, and building activities. The closest sensitive receptors to the Project site, i.e., existing residences, are located to the north and east of the Project site. As indicated in Section 5.1 – Aesthetic Resources of this Draft EIR, habitable structures located within the existing residential neighborhoods east of the Project site are generally setback 37 to 79 feet from the Project site’s property line. Habitable structures located within the existing residential neighborhoods north of the Project site are generally setback 24 to 43 feet from the Project site’s property line. One exception is a structure at the northeastern most corner of the Project site’s property line which is only 8 feet from the property line which is actually noncompliant with its R-1-7000 zoning, which requires a 25 foot minimum setback. The Project would implement conventional construction techniques and equipment. Standard equipment such as scrapers, graders, backhoes, loaders, tractors, cranes, and miscellaneous trucks would be used for construction.

Sound levels of typical construction equipment range from 65 dBA to 95 dBA at 50 feet from the source.

Worst-case construction noise levels are associated with grading activities. As stated in Section 5.8.6 above, no noise reduction measures were utilized in the noise modeling in order to produce a

1. The City’s Land Use/Noise Compatibility Guidelines does not have a land use category for mixed use projects; therefore, the Infill Single Family Residential land use was used for the residential component of the Project.

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worst-case construction noise outcome. Construction equipment constantly moves around the site so the average noise level at a point on the property line is lower than the levels identified in Table 5.8-H, above. As such, construction equipment will be farther than 10 meters from any residence most of the time so the noise level would be lower. Without the inclusion of any noise abatement during construction, grading activities would produce noise levels ranging up to 73 dBA Leq at the property lines of the residences. RMC 7.35.020(G) indicates that construction between 7:00 a.m. and 7:00 p.m. on weekdays or between 8:00 a.m. and 5:00 p.m. on Saturday is exempt from noise limits. Construction activities and the delivery of construction materials and equipment would occur within these hours (dBF, p. 16). As such, temporary noise impacts as a result of Project site construction would be less than significant.

Off-site construction activities within the right-of-way (ROW) are exempt from the City’s General Noise Regulations outlined in RMC hapter 7.35. RMC 7.35.020 (E) states construction within City ROW is exempt from the provisions of RMC Chapter 7.35 when, in the opinion of the Public Works Director or designee, such work will create traffic congestion and/or hazardous or unsafe conditions. As such, temporary noise impacts as a result of Project-related construction within the City’s ROW would be less than significant.

Construction Conclusion
Through PDF’s and compliance with RMC Section 7.35, Project-related construction noise levels would not exceed the City’s acceptable noise levels so temporary noise related impacts would be less than significant.

Permanent Noise Levels
Operation (Noise From the Project)
The mechanical equipment on the residential buildings (i.e., the HVAC units) would generate noise levels up to approximately 35 dBA Leq at the Project’s property lines. The mechanical equipment on the commercial buildings would produce noise levels up to approximately 50 dBA at the Project’s northern and eastern property lines. Since the noise levels would be lower than the allowable levels of 55 dBA during the daytime hours and 45 dBA during nighttime hours (because the mechanical equipment on the commercial structures would not be operating) set forth in RMC 7.25.010, impacts would be less than significant. (dBF, p. 15).

Project Traffic
As discussed in Section 5.8.1 – Setting above, Project-generated trips, which includes both residential and commercial uses from the proposed Project, would need to result in a doubling of the traffic volumes on a road segment in order to result in an audible increase in ambient noise levels. The Project would add peak-hour volume of up to 1,700 vehicles to the existing 29,250 vehicles on Arlington Avenue and add peak-hour volume of up to 1,500 vehicles to the existing volume of 18,650 vehicles on Streeter Avenue. These increases in traffic would result in increases of less than 1 dBA CNEL. As the increases in traffic noise would be less than 3 dBA, it would be not perceptible to the average person. (dBF, p. 16).

As such, roadway noise levels during operations would be less than significant.

Operation
The existing and future noise environment may have impacts on the proposed residential land uses. As such, an analysis to determine impacts to these uses was conducted. The existing and future noise environment would continue to be a result of vehicular traffic on Arlington Avenue and Streeter Avenue City of Riverside Sections 5.8
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as well as the aircraft activity associated with Riverside Municipal Airport, which may result in potentially significant exterior noise impacts to the Project site.

Arlington Avenue at California Avenue is projected to carry a future (Horizon Year 2045 with Project) average daily trip (ADT) volume of 75,900 vehicles and it was assumed the existing speed limit of 40 mph and traffic mix of 2 percent medium trucks, 0.5 percent heavy trucks, 0.5 percent buses, and 1 percent motorcycles, would remain constant in the future. Streeter Avenue at El Molino Avenue is projected to carry a future ADT volume of 50,050 vehicles and assumed the existing speed limit of 40 mph and traffic mix of 3 percent medium trucks would also remain constant in the future. Since no noise projections for the Riverside Municipal Airport were available, it was assumed that the current noise levels of 55-62 dBA CNEL would not increase in the future. (dBF, pp. 12-13).

Based on these assumptions, the Project’s exterior composite (roadway plus airport) noise levels at the proposed residential buildings are projected to range from below 60 dBA Ldn / CNEL at the northeast façades to approximately 70 dBA Ldn / CNEL at the west façades as shown on Figure 5.8-3, Future Exterior Composite Noise Levels. (dBF, pp. 12-13). Because exterior noise levels in the residential portion of the Project site would exceed 60 dBA, based on standard construction providing 15 dBA noise reduction, the interior noise levels in Project’s proposed habitable rooms may exceed the RMC Section 16.08.175 and CBC Section 1206.4 maximum residential noise limit of 45 dBA Ldn / CNEL in habitable rooms. However, through compliance with RMC Section 16.08.175 B 5, which requires preparation of an acoustical analysis report with the application for building permit and implementation of mitigation measure MM NOI-1 which would require noise attenuation measures to ensure interior noise levels do not exceed these requirements, impacts would be less than significant with mitigation incorporated.

The residential component of the proposed Project includes the following outdoor use areas: pool, pedestrian, promenade, and dog park. Future exterior composite noise levels in these areas would be 65 dBA Ldn / CNEL or less at all of these areas, which would be considered Normally Acceptable for Infill Single Family Residential land uses. (dbf, p. 13). Because the future composite noise level is considered Normally Acceptable, impacts would be less than significant and no mitigation is required.

Future exterior composite noise levels at the proposed commercial buildings would range from approximately 61 dBA Ldn / CNEL at the north façades, which is considered Normally Acceptable for Office Buildings, Business, Commercial, Professional land uses to approximately 72 dBA Ldn / CNEL at the south retail façade, which is considered Conditionally Acceptable for Office Buildings, Business, Commercial, Professional land uses. According to Figure 5.8-3, The “Conditionally Acceptable” range is defined as: new construction or development should be undertaken only after a detailed analysis of noise reduction requirements is made and needed noise insulation features included in design.

Conventional construction, but with closed windows and fresh air supply systems or air conditioning, will normally suffice. The Project will implement mitigation measure MM NOI-2, which requires preparation of a detailed acoustic analysis report and incorporation of noise attenuation measures. Thus, impacts would be less than significant with mitigation incorporated.

The Project’s commercial component includes an outdoor dining / flex space area on the west side of the retail pad. Future exterior composite noise level at this space would be approximately 68 dBA Ldn / CNEL and would be considered “Conditionally Acceptable.” (dbf, p. 13.) With implementation of mitigation measure MM NOI-2, impacts to the outdoor dining / flex space would be less than significant with mitigation incorporated.

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Operation Conclusion
Through compliance with RMC Section 16.08.175 and implementation of mitigation measure MM NOI-1, Project-related operational noise levels would not exceed the City’s acceptable noise levels so operational noise related impacts would be less than significant with mitigation incorporated.

Conclusion
Thus, with through compliance with the RMC and implementation of mitigation measures MM NOI-1 and MM NOI-2, the Project would not result in substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Therefore, impacts would be less than significant with incorporation of mitigation.

Threshold: Would the Project result in generation of excessive groundborne vibration or groundborne noise levels?
Construction
This construction vibration impact analysis discusses the level of human annoyance using vibration levels in vibration velocity decibels (VdB) and assesses the potential for building damage using vibration levels in peak particle velocity (PPV) (inches per second [in/sec]). Federal Transit Administration typical vibration levels associated with construction equipment are presented in Table 5.8-I, FTA Vibration Source Levels for Construction Equipment below.

Table 5.8-I, FTA Vibration Source Levels for Construction Equipment Equipment
Reference PPV/Lv at 25 feet
PPV (in/sec) Lv (VdB)
Pile Driver (impact), Typical 0.644 104
Pile Driver (sonic), Typical 0.170 93
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Caisson drilling 0.089 87
Loaded Truck 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Caltrans, Table 7-4
The greatest vibration levels are anticipated to occur during the grading phase of the Project. All other phases are expected to result in lower vibration levels. The distance to the nearest buildings for vibration impact analysis is measured between the nearest off-site buildings and the Project boundary (assuming the construction equipment would be used at or near the Project boundary) because vibration impacts normally occur within the buildings.

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To determine potential construction vibration damage annoyance the following formula was used PPVequip = PPVref x (25/D)1.1. Where PPVref is the reference equipment and D is the distance from the equipment to the receiver in feet. The Project’s grading activities would include one large bulldozer. The large bulldozer could be operated as close as 10 meters (32 feet) feet from the adjacent residential buildings located to the north and east of the Project site. At 32 feet, the large bulldozer would generate approximately 0.07 in/sec peak particle velocity (PPV). As reflected in Table 5.8-D above, the threshold at which there is a risk to “architectural” damage to residential structures (non-engineered timber and masonry buildings) is a PPV of 0.2 (in/sec). Because the large bulldozer would generate vibration below FTA’s threshold, then the potential for vibration building damage potential is low.

To determine potential construction vibration annoyance the following formula was used. LvdB (D) = LVdB (25 ft) - 30 Log (D/25). Where LvdB(25 ft) is the reference equipment and D is the distance from the equipment to the receiver in feet. The large bulldozer could be operated as close as 32 feet and would generate approximately 84 vdB. As shown on Table 5.8-B above, the FTA has identified that 75 VdB is the threshold for annoyance from groundborne vibration at sensitive receptors. Although the large bulldozer would exceed FTAs threshold for vibration annoyance of 75 VdB, these impacts would be temporary since Project construction is expected to occur for 23 months. As such, temporary vibration impacts associated with construction would be less than significant.

Operational
Once operational, the proposed Project would not generate vibration. In addition, vibration levels generated from Project-related traffic on the adjacent roadways (i.e., Arlington Avenue and Streeter Avenue) would be unusual for on-road vehicles because the rubber tires and suspension systems of on road vehicles provide vibration isolation.

Per Caltrans’ Transportation Noise and Vibration Manual, vehicular traffic on roadways rarely generates vibration amplitudes high enough to cause structural or cosmetic damage. (CT-B, Appendix A, p.14).

Caltrans collected vibration data for truck pass-bys, as a result it was concluded that vibration from trucks were higher than that of an automobile. However, vibration from these trucks drops off dramatically with distance. Vibration wavefronts emanating from several trucks closely together may either cancel or partially cancel (destructive interference) or reinforce or partially reinforce (constructive interference) each other, depending on their phases and frequencies. Since traffic vibrations can be considered random, total destructive or constructive interference probabilities are minimal. (CT-B, Appendix A, p.13).

Caltrans found that at 5 meters (m) from the centerline of the nearest lane vibrations never exceeded 2.0 mm/s (0.08 in/sec), even with worst combinations of heavy trucks. This amplitude coincides with the maximum recommended “safe amplitude” for historic buildings. Caltrans determined that for most people at 45 m from the center line vibration, amplitudes would dip below most human perception thresholds. According to Caltrans, sensitive receptors adjacent to local roadways within 15 m of the nearest travel lane’s center line will have the maximum worse-case vibration levels of 0.08 mm/s or (0.0032 in/sec or 70 VdB). (CT-B, Appendix A, p.14.)
As previously mentioned, FTA’s damage criteria is 0.2 PPV (in/sec) and the human annoyance level is 75 VdB. This worst-case vibration level from truck traffic would not exceed FTAs thresholds. Furthermore, it is expected that actual vibration levels within the Project area from truck traffic would be lower than this worst-case level when soil type and pavement conditions are considered so vibration from project- City of Riverside Sections 5.8
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related traffic on the adjacent roadways would not be significant. As such, vibration impacts associated with operations would be less than significant.

Conclusion
Thus, the Project would not result in generation of excessive groundborne vibration or groundborne noise levels during project construction or operation. Therefore, impacts would be less than significant.

Threshold: For a project located within the vicinity of a private airstrip of an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The proposed Project was required to be reviewed by the Airport Land Use Commission (ALUC) for its consistency with the RCALUCP. As discussed in detail in Section 5.6 – Hazards and Hazardous Materials, on January 12, 2023, ALUC determined via a public hearing, that the proposed Project is inconsistent with the RCALUCP. However, the Project was determined to be inconsistent with the residential density and non-residential site intensity requirements, not due to airport noise. Noise from airport operations would be considered a noise impact to the Project; thus, the appropriate threshold for this noise source is the Land Use/Noise Compatibility Criteria shown on Figure 5.8-2.

Based on the Noise Analysis, the Project site is located approximately one mile from the RMA runway and is exposed to RMA noise levels of 55 dBA CNEL to 62 dBA CNEL. (dBF, p 9).. As shown on Figure

5.8-2, Land Use/Noise Compatibility Guidelines, this CNEL level is considered Normally Acceptable for Infill Single Family Residential land uses and Normally Acceptable for Office Buildings, Business, Commercial, Professional land uses.

Most of the Project site is located within Land Use Compatibility Zone B1 (with smaller portions located within Zones C and D). The residential component of the Project proposes 382 units in Compatibility Zone B1, 1 unit in Zone C, and 5 units in Zone D. Zone B1 is identified as the Inner Approach/Departure Zone of the Riverside Municipal Airport. Zone B1 is considered a "High Noise Impact” area since it lies mostly within the 60 Community Noise Equivalent Level (CNEL) contour. Because of this, single-event noise may be sufficient enough to disrupt a wide range of land use activities, including indoor uses if windows are open. (ALUC-A, pp. 5-6). However, as presented above, the Project’s Noise Analysis indicated that the actual noise levels from RMA operations are in the 55 dBA CNEL to 62 dBA CNEL range, which is considered “Normally Acceptable” for Infill Single Family Residential Uses and as such does not exceed the City’s standards for exterior noise.

Since the RCALUCP considers Zone B1 as a “High Noise Impact” area, the Project proposes a number of outdoor recreational areas that could expose users to a moderate level of interference from aircraft noise including promenades, pool, and dog park. While the overall land use in this area is designated as a residential use, the proposed open space areas are recreational in nature. As shown on Figure 5.8-2, the “Normally Acceptable” range for the Playgrounds, Neighborhood Parks2 land use category is 50 dBA Ldn / CNEL to 70 dBA Ldn / CNEL.
2 The Playbrounds, Neighborhood Parks land use category was selected because it is the best fit for the proposed promenade, pool, and dog park.

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As outlined in the Project’s Noise Analysis, noise from airport operations combined with the ambient and future traffic noise, will combine to result in future exterior composite noise levels of 65 dBA Ldn / CNEL or less, for the exterior/outdoor areas of the Project’s residential component, which is considered “Normally Acceptable;” and approximately 68 dBA Ldn / CNEL at the proposed outdoor dining / flex space area, which is considered “Conditionally Acceptable.” (dBF, p. 13).

Since the airplane noise by itself will not exceed the City’s Land Use/Noise Compatibility Criteria or RMA’s outdoor noise limit of 65 dBA, the Project’s location within the RCALUCP Noise Contour of the B1 Zone, is not anticipated to expose residents and patrons to excessive aircraft noise alone. However, when combined with existing and future traffic noise, the exterior noise levels for residents will exceed the 65 dBA standard at the west residential façades (70 dBA), south retail façade (72 dBA), and the outdoor dining/flex space area on the west side of the retail pad (68 dBA). (dbf, p. 13.) However, as shown in Table 5.8-E, Existing Noise Levels (dBA), existing ambient noise levels already exceed noise levels from aircraft and the 65 dBA threshold for exterior noise identified by RMA policy 2.1.

For indoor noise levels which are 45 dBA CNEL, the expected airplane noise ranging from 55 to 62 dBA CNEL will cause an exceedance indoors, if not mitigated. Although standard construction is normally considered to provide for a 15-decibel reduction from exterior noise levels, which could by itself reduce the expected interior noise levels inside from airplane noise levels to be 40 to 47dBA CNEL. Compliance with RMC 16.08.175 B 5 and implementation of mitigation measure MM NOI-I, which requires an acoustical noise analysis to be conducted to identify of the required noise attenuation measures and incorporation of said measures into the design of the residential uses to ensure interior noise levels from aircraft operations and other noise sources are at or below 45 CNEL. Regarding the commercial component, the Project will implement mitigation measure MM NOI-2, which requires preparation of a detailed acoustic analysis report and incorporation of noise attenuation measures. Thus, impacts would be less than significant with mitigation incorporated.

Thus, through compliance with the municipal code and implementation of mitigation measure MM NOI-1 and MM NOI-2, the Project would not expose people residing or working in the project area to excessive noise from airport operations. Therefore, impacts would be less than significant with mitigation incorporated.

5.8.8 Recommended Mitigation Measures
An Environmental Impact Report is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines § 15126.4). Mitigation measures were evaluated for their ability to eliminate or reduce the potential significant adverse impacts related to Noise.

There are no mitigation measures required to reduce impacts related to an increase in temporary or permanent construction noise levels or impacts related to excessive groundborne vibration or groundborne noise levels since less than significant impacts are anticipated from implementation of the Project. Exterior noise levels were found to be less than significant. The following mitigation measures shall be implemented to eliminate or reduce potentially significant impacts related to traffic noise to the new residential units:

MM NOI-1 Residential Interior and Exterior Noise. Prior to issuance of a building permit for any residential building or unit, an acoustical analysis shall be conducted by a noise specialist meeting the requirements set forth in Riverside Municipal Code 16.08-175 B 5 City of Riverside Sections 5.8
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to confirm that the noise insulation proposed in the final design is sufficient to achieve interior noise levels at or below 45 CNEL and exterior noise levels at or below 65 CNEL.

Interior noise attenuation measures identified in said acoustical analysis shall be incorporated into the design of the residences, to the extent such measures are necessary, to ensure that interior noise levels are at or below 45 CNEL. Measures may include, but not be limited to, upgraded building façade elements (windows, doors, and /or exterior wall assemblies) with Sound Transmission Class (STC) rating of 35 or higher.

If the interior limit can be achieved only with the windows closed, then the building design shall include mechanical ventilation that meets California Building Code requirements. Exterior noise attenuation measures, which shall be unit/structure specific, may include site design and building layout and/or noise barriers sufficient to achieve exterior noise levels at or below 65 CNEL.

MM NOI-2 Commercial Exterior Noise. Prior to issuance of a building permit for any commercial structure, an acoustical analysis shall be conducted by a noise specialist meeting the requirements set forth in Riverside Municipal Code section 16.08-175 B 5 to confirm that the noise insulation proposed in the final design is sufficient to achieve exterior noise levels at or below 65 CNEL in any outdoor dining / flex space. Noise attenuation measures identified in said acoustical analysis shall be incorporated into the design of the commercial area, to the extent such measures are necessary, to ensure that exterior noise levels are at or below 65 CNEL. Exterior noise attenuation measures, which shall be specific to the ultimate location of the outdoor dining / flex space may include site design and building layout and/or noise barriers sufficient to achieve exterior noise levels at or below 65 CNEL.

5.8.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
Implementation of local, state, and federal regulations, project design features, and General Plan policies listed above, and project-specific mitigation measures MM NOI-1 and MM NOI-2 will reduce the Project’s habitable rooms interior noise levels at or below 45 dBA Ldn / CNEL, the residential exterior areas at or below 65 dBA Ldn / CNEL, and commercial outdoor dining / flex space at or below 65 DBA Ldn / CNEL. Implementation of these mitigation measures will not result in residual environmental impacts.

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5.9 Population and Housing
The focus of this section is to analyze potential impacts related to Population and Housing. The following discussion addresses the potential for adverse impacts that could result from the construction and operations as a result of the Project. Cumulative impacts related to this topic are discussed in Section

7.0 – Other CEQA Topics.

Changes in population, employment, and housing demand are social and economic effects, not environmental effects. According to Section 15382 of the CEQA Guidelines, “An economic or social change by itself shall not be considered a significant effect on the environment.” However, these effects should be considered in an EIR only to the extent that they create adverse impacts on the physical environment, such as increased traffic and associated air quality and noise impacts, and increased demands on public services and utilities. These effects are described in Section 5.2 – Air Quality, Section 5.8 – Noise, Section 5.10 – Public Services, and Section 5.13 – Utilities and Service Systems, of this DEIR.

5.9.1 Setting
The Project entails, an approximately 17.43 gross acre site located at the northeast corner of Arlington Avenue and Streeter The Project site currently houses an existing but vacant Sears Department Store building and associated Auto Center and respective surface parking lot. According to the latest Department of Finance (DOF) data, the City’s estimated population is currently 313,676 people (DOF).

Regional and Local Data Forecasts
Population, housing, and employment data for the City and surrounding area are available from the DOF and the Southern California Association of Governments (SCAG) Regional Growth Forecasts. SCAG is the regional planning agency with responsibility for reviewing the consistency of local plans, projects, and programs with regional plans. It is a federally-designated metropolitan planning organization (MPO) for six Southern California counties, including Riverside County. As such, SCAG is mandated to create regional plans that address among other things, growth management.

Population
Population forecasts for the City and surrounding area are provided by SCAG. The 2020-2045 SCAG Regional Transportation Plan/Sustainable Communities Strategy Growth Forecast, also known as Connect SoCal (RTP/SCS), was adopted September 3, 2020 by SCAG’s Regional Council. The RTP/SCS is a long-range visioning plan that balances future mobility and housing needs with economic, environmental, and public health goals so that the region can grow smartly and sustainably. SCAG updates the growth forecast every four years and is broken down into separate growth forecasts for individual counties and cities. Table 5.9-A, SCAG Growth Forecasts (Riverside County), shows SCAG’s population forecasts for Riverside County as a whole.

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Table 5.9-A, SCAG Growth Forecasts (Riverside County)
2018 2020 2035 2040 2045
Population 2,364,000 2,493,000 2,853,000 2,996,000 3,252,000 Households 716,000 785,000 930,000 988,000 1,086,000
Employment 743,000 823,000 961,000 1,009,000 1,103,000
Jobs-to-Housing Ratio1 1.04:1 1.05:1 1.03:1 1.02:1 1.02:1 Source: SCAG, Table 13
Notes:

1. Total number of jobs relative to the total number of households - calculated Table 5.9-B, SCAG Growth Forecasts (Riverside), depicts the SCAG population forecasts for the City of Riverside.

Table 5.9-B, SCAG Growth Forecast (Riverside)
2016 2045
Population 325,300 395,800
Households 94,500 115,100
Employment 145,400 188,700
Jobs-to-Housing Ratio1 1.54:1 1.70:1
Source: SCAG, Table 14
Notes:

1. Total number of jobs relative to the total number of households calculated.

2. 2020, 2035, and 2040 data not available
Employment
According to SCAG’s most recent 2017 data, the City has approximately 148,352 jobs (SCAG 2019, p. 24). The five largest employment sectors represent 64.4 percent of the total jobs in the City. These sectors include Education (27.9 percent), Retail (11.4 percent), Professional (9.4 percent), Public (8.7 percent), and Leisure (8.1 percent). Education/Health jobs include organizations such as elementary and secondary schools, junior colleges, universities, professional schools, technical and trade schools, medical offices, dental offices, outpatient care centers, medical and diagnostic laboratories, hospitals, nursing and residential care facilities, social assistance services, emergency relief services, vocational rehabilitation services, and child day care services. Retail jobs include organizations engaged in the sale of durable goods directly to consumers. Professional/Management jobs include activities that specialize in professional/scientific/technical services, management of companies and enterprises and administrative and support services. Establishment types may include law offices, accounting services, architectural/engineering firms, specialized design services, computer system design and related services, management consulting firms, scientific research and development services, advertising firms, office administrative services and facilities support services. Public Administration jobs include public City of Riverside Sections 5.9
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sector organizations, such as legislative bodies, public finance institutions, executive and legislative offices, courts, police protection, parole offices, fire protection, correctional institutions, administration of governmental programs, space research and technology and nation security. Leisure jobs include activities involved in the performing arts, spectator sports, museums, amusement/recreation, travel accommodations, and food and drink services (SCAG 2019, pp. 38-39).

Housing
In March 2021, SCAG adopted the Regional Housing Needs Assessment (RHNA) 6th Cycle for the planning period of October 2021 through October 2029. The RHNA identified new housing units needed by income category for the region, including the City of Riverside. The City has been allocated to provide 18,458 new housing units as shown in Table 5.9-C, City of Riverside RHNA 2021-2029 below (RHNA).

However, as part of the City Phase I General Plan Update (GPUI) which includes the 6th Cycle Housing Element for the planning period of 2021-2029, adopted in October 2021, the City added a selfprescribed buffer of new dwelling units to provide during this planning period to ensure the City meets the minimum recommended by State Department of Housing and Community Development to account for the “No Net Loss” requirements as mandated by Senate Bill 166 (SB 166). The City elected to provide an approximately 30 percent “No Net Loss” buffer and so will target providing 24,000 new homes. (GPUI, p. 3.9-12). The vacancy rate in the City has been steadily decreasing each year since 2010 and currently sits at 4.0 percent (DOF).

Table 5.9-C, City of Riverside RHNA 2021-2029
Household Income Category Target (units)
Very Low 4,861
Low 3,064
Moderate 3,139
Above Moderate 7,394
Subtotal 18,458
No Net Loss Buffer (30%) 5,500
Total1 24,000
Source: GPUI, p. 3.9-12
Notes:

1. No net loss units is approximate. Per GPUI, city will identify space for up to 24,000 new homes during the 2021-2029 RHNA cycle.

Jobs to Housing Ratio
The job-to-housing ratio is used as an indicator of a community’s jobs-rich or jobs-poor status. SCAG’s April 2001 report titled, The New Economy and Jobs/Housing Balance in Southern California, states that “a balance between jobs and housing in a metropolitan region can be defined as a provision of an adequate supply of housing to house workers employed in a defined area (i.e., community or subregion) (SCAG 2001, p.15). Alternatively, a jobs-to-housing balance can be defined as an adequate provision of Section 5.9 City of Riverside
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employment in a defined area that generates enough local workers to fill the housing supply.” Generally, a ratio of less than 1 to 1 indicates a jobs-poor area, and a ratio of more than 1 to 1 indicates a jobs-rich area. (SCAG 2001, p.15) The City of Riverside has a current unemployment rate of 3.5 percent (EDD).

As shown in Table 5.9-A, above, the RTP/SCS growth forecast indicates that in the year 2018 the jobsto-housing ratio for Riverside County was 1.04:1, which by definition is considered jobs-rich. Riverside County is projected to continue to have a jobs-rich area through the year 2045. The City’s growth forecast indicates that in the year 2016 the jobs-to-housing ratio was 1.54:1 and is anticipated to increase to 1.70:1 by the year 2045. So, the City’s forecast remains jobs-rich as shown in Table 5.9-B, above.

5.9.2 Related Regulations
Federal Regulations
No federal regulations are applicable to population and housing with respect to the proposed Project.

State Regulations
State law mandates local communities plan for enough housing to meet projected growth in California.

Article 10.6 of the California Government Code (Sections 655801–65590) requires each city and county to prepare a Housing Element as part of its General Plan. The Housing Element is one of seven statemandated elements that every general plan must contain. The State requires it to be updated every five years and determined to be legally adequate. The purpose of the Housing Element is to identify the community’s housing needs, state the community’s goals and objectives with regard to housing production, rehabilitation, and conservation to meet those needs, and define the policies and programs that the community will implement to achieve the stated goals and objectives. The Housing Element identifies and establishes policies with respect to meeting the needs of existing and future residents. It also establishes policies that will guide decision makers and sets forth an action plan to implement its housing goals.

The California Department of Housing and Community Development (HCD) determines a Regional Housing Needs Allocation (RHNA) by income category for each Council of Governments (COG) throughout the state. The Southern California Association of Governments (SCAG) is the COG for Riverside County. The RHNA is based on California Department of Finance population projections and regional population forecasts used in preparing regional transportation plans.

Once HCD has determined the RHNA, SCAG is required to allocate to each locality, including the County, a share of the RHNA sufficient to meet the projected housing demand for each income category. The County and other localities must update their General Plan Housing Element to accommodate the applicable RHNA share by income category. The City updated the Housing Element for the “sixth cycle” covering the 2021-2029 period adopted in September 2021.

Senate Bill 2 - Building Homes and Jobs Act
In 2017, Governor Brown signed a 15-bill housing package aimed at addressing the State’s housing shortage and high housing costs. The package included the Building Homes and Jobs Act (SB 2), which established a funding source to increase the supply of affordable homes in California by collecting a $75 recording fee on real estate documents. These funds were made available to all local governments in California to help prepare, adopt, and implement plans that streamline housing approvals and accelerate housing production. (SB2)
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Senate Bill 166 - No Net Loss Act
In 2017 Senate Bill 166 (SB 166) was signed into law as a requirement for local government to ensure that its housing element inventory can accommodate its share of the regional housing need throughout the planning period. It prohibits them from reducing, requiring, or permitting the reduction of the residential density to a lower residential density than what was used by the California Department of Housing and Community Development for certification of the housing element, unless the city or county makes written findings supported by substantial evidence that the reduction is consistent with the adopted general plan, including the housing element. In such cases, any remaining sites identified in the housing element update must be adequate to accommodate the jurisdiction’s share of the regional housing need. A local government may reduce the residential density for a parcel only if it identifies sufficient sites remaining within the housing element as replacement sites, so that there is no net loss of residential unit capacity (GPUI DEIR, pp.3-9).

Senate Bill 375 – California’s Sustainable Communities and Climate Protection Act Senate Bill 375 (SB 375) aligns land use and transportation planning to link development with transitaccessible places and reduce car dependency. SB 375 is the land use component of California’s wider strategy to reduce greenhouse gas emissions, codified by the 2006 Global Warming Solutions Act through Assembly Bill 32 (AB 32). AB 32 enabled the state to regulate emission sources and set the aggressive goal of reducing emissions to 1990 levels by 2020. SB 375 requires California Metropolitan Planning Organizations (MPOs) to create Sustainable Communities Strategies (SCS) as part of the federally mandated Regional Transportation Plan (RTP). SCSs lay out the locations and types of development needed to lower vehicle miles traveled and meet greenhouse gas emission reduction targets (GPUI DEIR, p. 3.9-9).

Senate Bill 330 – California Housing Crisis Act of 2019 In 2019 Senate Bill 330 (SB 330) was signed into law as a means to combat the state’s growing housing crisis. It applies to all urbanized areas or urban clusters. The legislation’s goal is to increase California’s housing stock by 3.5 million new units by 2025. To streamline residential development, a new preliminary application process is established which includes basic information regarding a project such as: (GPUI DEIR, pp. 3.9-9 – 3.9-10).
 Site characteristics
 Project Plans
 Certain environmental concerns
 Facts related to any potential density bonus
 Certain coastal zone-specific concerns
 Number of units to be demolished
 Location of recorded public easements
Assembly Bill 1397
California’s AB 1397 made a number of changes to housing element law by revising what could be included in a local government’s inventory of land suitable for residential development. AB 1397 changed the definition of land suitable for residential development to increase the number of multi-family sites. Identified sites must be “available” and “suitable” for residential development and have a “realistic and demonstrated potential” for redevelopment during the planning period. In addition, AB 1397 requires housing element inventory sites to be 0.5 acre to 10 acres, have sufficient infrastructure, or be included in a program to provide such infrastructure, to support and be accessible for housing development. The Section 5.9 City of Riverside
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local government must specify the realistic unit count for each site and whether it can accommodate housing at various income levels. (GPUI EIR, p. 3.9-10) Regional Regulations
Southern California Association of Governments
Southern California Association of Governments (SCAG) is the Metropolitan Planning Organization (MPO) for six counties: Riverside, Los Angeles, Orange, San Bernardino, Ventura, and Imperial. The region encompasses a population exceeding 19 million persons in an area of more than 38,000 square miles. As the designated MPO, the federal government mandates that SCAG researches and prepares plans for transportation, growth management, hazardous waste management, and air quality.

Additionally, SCAG provides informational resources to regionally significant plans, projects, and programs per CEQA to facilitate the consistency of these projects with SCAG’s adopted regional plans, to be determined by the lead agencies.

Connect SoCal
The SCAG regional council adopted the 2020 – 2045 RTP/SCS or Connect SoCal in September 2020.

Connect SoCal seeks to improve mobility and promote a more sustainable growth pattern. The longrange vision plan builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. The goals included in Connect SoCal are meant to provide guidance for considering projects within the context of regional goals and policies. (RTP/SCS)
Connect SoCal includes population, housing, and employment growth projections for 2045. These growth projections are used in SCAG’s transportation modeling and shape SCAG’s regional planning efforts, as outlined in Connect SoCal. Connect SoCal minimizes increases in regional traffic congestion by focusing growth, density, and land use intensity within existing urbanized area as the general land use growth pattern for the region while enhancing the existing transportation system and integrating land use into transportation planning. Connect SoCal recommends local governments accommodate future growth within existing urbanized areas to reduce VMT, congestion, and greenhouse gas emissions. (RTP/SCS)
SCAG Regional Housing Needs Assessment
State law requires that jurisdictions provide their fair share of regional housing needs by conducting a Regional Housing Needs Assessment (RHNA) and adopt a general plan for future growth (California Government Code Section 65300). The California Department of Housing and Community Development (HCD) is mandated to determine state-wide housing needs by income category for each Council of Governments (COG) throughout the state. The housing need is determined based on four broad household income categories: very low (households making less than 50 percent of median family income), low (50 to 80 percent of median family income), moderate (80 to 120 percent of median family income), and above moderate (more than 120 percent of median family income). The intent of the future needs allocation by income groups is to relieve the undue concentration of very low and low-income households in a single jurisdiction and to help allocate resources in a fair and equitable manner. SCAG is the COG for Riverside County. SCAG determined that Riverside’s projected RHNA share for the 6th Cycle Housing Element (2021 ‐ 2029) is 18,458 housing units.

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Local Regulations
City of Riverside General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project, as identified below (2025 GP, pp. AQ-26 – AQ-28, LU-26):

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

Policy AQ-1.5 Encourage infill development projects within urbanized areas that include job centers and transportation nodes.

Policy AQ-1.6 Provide mixed-use development that allows the integration of retail, office, institutional and residential uses for the purpose of reducing costs of infrastructure construction and maximizing the use of land.

Policy AQ-1.7 Support planned residential developments and infill housing, which reduce vehicle trips.

Policy AQ-1.23 Increase residential and commercial densities around rail and bus transit stations
Land Use Element
Objective LU-8 Emphasize smart growth principles through all steps of the land development process.

Policy LU-8.3 Allow for mixed-use development at varying intensities at selected areas as a means of revitalizing underutilized urban parcels.

City of Riverside 2025 General Plan EIR
There are no applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to Population and Housing.

City of Riverside Phase I General Plan Update
The City of Riverside Phase I General Plan Update contains objectives and policies that are considered applicable to the proposed Project, as identified below (GPUI, pp. HE20 - HE22, HE26; AP9, AP13, EJ3):

Environmental Justice Element
Policy LU-EJ-1.0 Housing Location: ensure new housing developments adhere to local, state, and federal requirements to avoid disproportionate impacts on environmental justice communities.

Housing Element
Policy HE-4 Thriving Neighborhoods. Facilitate and encourage a variety of new housing types, including both single-and multi-family and missing middle housing, and the necessary public amenities to support a sense of community that results in equitable and sustainable neighborhoods.

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Program HE-4-6 Conceptual Development Review. The City of Riverside already uses a conceptual development review process to encourage high-quality development and site design in residential and mixed-use districts through collaborative pre-application consultations between developers and City staff. The City will continue to program to facilitate the development of large lots.

Policy HE-5 Regulations. Reduce and remove government barriers, where feasible and legally permissible, to reduce costs of housing production and facilitate both ownership and rental opportunities for all residents
Program HE-5-1 Adequate Housing Opportunities Sites for RHNA. The City has developed an extensive inventory of potential development sites to accommodate the City’s share of the Regional Housing Needs Allocation (RHNA). While not all of these sites are currently zoned to allow for residential uses or for residential densities suitable for lower-income housing, the City has proactively initiated and effort to rezone these sites for higher-density residential and mixed-use development. The rezoning will be completed prior to the beginning of the 2021-2029 Housing Element cycle.

Program HE-5-2 Zoning Code Amendments. The City’s Zoning Code will implement many of the policies and programs in the Housing Element. Updates to the Zoning Code prepared concurrently with or planned to be implemented with this Housing Element include:
 Urban design regulations;
 Incentives for building the maximum number of homes allowed;  Inventory sites for lower-income development that contain existing residential units occupied by or deed-restricted for lower-income households will be subject to replacement requirements pursuant to AB 1297 as a condition of project approval, consistent with the requirements State density bonus laws;
 Allowance for the use of pre-approved construction plans;  Modifications to required findings for Requests for Reasonable Accommodations;
 Streamlined review and approval processes for residential development;  Objective Design Standards pursuant SB330; and
 Written procedures for streamlined approval of qualifying affordable housing projects pursuant SB 35.

Policy HE-EJ-7 Development Process. Facilitate a development process that promotes the design and rehabilitation of housing that is responsive to the needs and desires of the residents of environmental justice communities.

Program HE-EJ-7-3 Housing on Small and Infill Lots. The City has identified that housing on infill lots will increase housing opportunities in Riverside. A small lot and/or Infill Development Ordinance would then be prepared to facilitate streamlining of development on these lots. Revisions to the Zoning Code may include reduced minimum lot sizes, reduced setbacks, greater building heights, or less parking to eliminate the need for variances.

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City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Population and Housing.

City of Riverside Municipal Code
The following section of the City’s Municipal Code are applicable and pertain to population and housing:

Title 19 – Zoning. The purpose of the Zoning Code is to encourage, classify, designate, regulate, restrict and segregate the highest and best location and use of buildings, structures and land for agriculture, residence, commerce, trade, industry, water conservation or other purposes in appropriate places; to regulate and limit the height, number of stories and size of buildings and other structures hereafter erected or altered; to regulate and determine the size of yards and other open spaces; and, to regulate and limit the density of population and for such purpose to divide the City into zones of such number, shape and area as may be deemed best suited to carry out these regulations and provide for their enforcement.

5.9.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding Population and Housing in response to the Initial Study/Notice of Preparation (IS/NOP).

5.9.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the Thresholds of Significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A) prepared for this Project, and as outlined in Section 4.0 of this DEIR< implementation of the proposed Project will have a less than significant impact in the following area and this topic is not addressed in this DEIR:
 Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impact in the following area and this topics is addressed in this DEIR:
 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).

5.9.5 Project Design Features
Because the Project is proposing the implementation of new residential buildings which will introduce population growth at the Project site, no Project Design Features are incorporated that would lessen impacts related to population and housing.

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5.9.6 Methodology
In September 2021, the City adopted Phase I General Plan Update (GPUI) which consisted of the 6th Cycle Housing Element (2021-2029). The GPUI utilized data from SCAG which estimated a current 2020 population within the City of 328,155 people. SCAG projected population within the City to increase to approximately 395,800 people by 2045, representing 20.6 percent increase in people. (GPUI DEIR, p.

3.9-17).

However, the GPUI utilized the 2020 Department of Finance (DOF) population generation factor of 3.28 people per household (the City’s average household size). The population generation factor is an average of both single and multi-family uses. The GPUI projected that population would increase resulting in a total population of 431,685 persons by 2045; 35,885 more people than projected by SCAG.

Ultimately, the GPUI used a more conservative population projection over SCAG to determine population by buildout year 2045. With this more conservative projection, the GPUI determined that no mitigation was available to reduce the resulting impact to a less than significant level and that the impacts would be significant and unavoidable.

The analysis below has utilized 2023 Department of Finance (DOF) data to ascertain the City’s current population estimate which has been identified as 313,676 people. The DOF data also identifies current average household size is 3.05 persons per household. However, the subsequent analysis utilizes the more conservative 2020 DOF factor of 3.28 persons per household from the City’s Phase I General Plan Update to project the most conservative number of people the Project site would generate. .

Additionally, this Project is projected to provide a total of 511 employees. The Employment projections are based on Riverside County General Plan Appendix E-2: Revised Socioeconomic Build-Out Assumptions and Methodology generation factors of 500 SF per commercial-retail employee (COR GP, Appendix E, p. 3.).

5.9.7 Environmental Impacts
Threshold: 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)?
The proposed Project includes an amendment to the General Plan land use designation and rezone to allow for Mixed-Use Village (MU-V) to permit residential and commercial uses on the currently Commercial designated site. The Project proposes to development 27 residential buildings consisting of 2- and 3- story structures allowing for a total of 388 residential units and two commercial buildings totaling 25,320 sf located on the southeastern portion of the site.

Current data from DOF of approximately 26 percent from the current population estimate of 313,676 people DOF).

As identified in Section 5.9.6 – Methodology above, assuming a generation factor of 3.28 persons per dwelling unit, the Project would generate 1,273 persons2 . This results in an increase of 0.4 percent over
current City population and an increase of 0.3 percent of City’s 2045 buildout projections; neither of

1. Derived by dividing proposed commercial-retail square footage of 25,320 by a generation factor of 500 square foot/employee resulting in approximately 51 employees.

2. Based on household generation factor of 3.28 people per dwelling unit for the City of Riverside (GPUI EIR, p.

3.9-5).

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which represent substantial growth. Hence, impacts related to substantial unplanned growth would be less than significant.

RHNA for the 6th Cycle planning period has projected the City is obligated to provide for 18,458 units to meet their fair share allocation of RHNA requirements. The City self-prescribed a target 30 percent over SCAG’s target in order to include a “No Net Loss” buffer consistent with SB 166 resulting in the City goal to provide for 24,000 units as identified in Table 5.9-C, above. (GPUI, p. HE-TBR 101) Because the City is built-out and has self-prescribed a buffer increasing target housing beyond RHNA requirements, the City has adopted a number of policies to help meet these goals by reducing and removing governmental barriers; specifically policies HE-5-1 through HE-5-6. (GPUI, p. HE22-HE23). .

The Project will be able to develop the underutilized the Project site for mixed-use, By introducing mixed uses to the Project site, the proposed rezone and general plan amendment will allow for residential uses.

The ability to provide residential uses will provide the City an opportunity to help fulfill RHNA housing needs. The Project proposes to provide 388 dwelling units which will allow the City to move closer to the City’s fair share of RHNA allocation.

As demonstrated in Table 5.9-B, SCAG predicted that the City would have a Job-to-Housing Ratio of

1.70:1 in 2045 based on population projection of 395,800 persons. The Project would increase the existing population but would provide employment opportunities by adding approximately 51 new jobs.

SCAG predicted that the City would remain a job-rich area with the projected 2045 population growth and implementation of the Project would contribute to employment opportunities within the City, contributing to the City’s job to housing ratio. Implementation of the Project may introduce indirect population growth through the introduction of new job opportunities during both construction and operation of the Project site. Employment during construction activities would be short-term in nature.

As mentioned in Section 3.0 – Project Description during operation the proposed commercial retail portion of the Project site is estimated to employ approximately 51 employees. Additionally, the project will not create indirect population growth because the Project would not require the expansion of infrastructure and utilities to service the Project. Because existing infrastructure is already in place and the Project does not include any construction, the Project would not remove any obstacles to population growth. Moreover, the Project does not propose construction of any new major infrastructure facilities that create indirect growth and impacts.

The Project is consistent with applicable General Plan policies related to housing and infill development, as outlined above. Additionally, implementation of the Project would provide the City opportunities to help fulfill State RHNA housing requirements and would represent growth that is less than one percent of buildout projections. Thus, the Project would not induce substantial unplanned population growth.

Therefore, the impacts would be less than significant.

5.9.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). There are no mitigation measures required to reduce impacts to since less than significant impacts to population and housing are anticipated from implementation of the Project. Therefore, no mitigation measures are required.

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5.9.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
Less than significant impacts to population and housing are anticipated from implementation of the Project. There are no mitigation measures required to reduce impacts to Population and Housing.

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5.10 Public Services
The focus of this section is to analyze potential impacts related to Public Services, including fire protection, police protection, schools, and libraries. The following discussion addresses the potential for adverse impacts that could result from the construction and operations as a result of the Project.

Cumulative impacts related to this topic are discussed in Section 7.0 – Other CEQA Topics. Park services are addressed in Section 5.11 – Recreation of this Draft EIR.

5.10.1 Setting
The City of Riverside (City) is located in the northwestern portion of Riverside County. The City is bounded on the north by the Cities of Jurupa Valley, Colton, and Grand Terrace and the unincorporated community of Highgrove, to the east by the City of Moreno Valley, to the south by the unincorporated community of Woodcrest, and to the west by the Cities of Corona and Norco. The Project entails an approximately 17.43 gross acre site located at the northeast corner of Arlington Avenue and Streeter Avenue as discussed in Section 3.0 – Project Description of this Draft EIR. The Project site is located within the City’s Magnolia Center neighborhood. Discussion of Project parcel throughout this document is based upon net acreage of 17.37 acres.

Fire Protection Services
The Riverside Fire Department (RFD) provides fire protection for the City. RFD is an all-hazard emergency service agency that provides fire protection, emergency medical services, fire safety inspections, community education, and emergency preparedness planning and training for the City. RFD covers six divisions: Administration, Fire Prevention, Operations, Special Services, Urban Search and Rescue, and Training. RFD’s major facilities includes 14 fire stations located throughout the City, Administration/Prevention offices, an Emergency Operations Center, and a Fire Training Center to advance the training of personnel. (GPUI FEIR, p. 3.10-1). The two closest fire department are Station 5 – Airport, which is approximately 0.8 miles east of the Project site, and Station 3 – Magnolia Center (Midtown), which is approximately 1.7 miles west of the Project Site. (GE) Station 5 – Airport serves the Airport neighborhood and portions of the Ramona, Grand, and Magnolia Center neighborhoods. Station 5 is a multi-company station staffing Engine 5, Squad 5, and Breathing Support 5. On duty Station 5 personnel include one captain, one engineer, one firefighter and two firefighter/paramedics. Station 3 – Magnolia Center (Midtown) serves the Magnolia Center and Wood Streets neighborhoods and portions of the Victoria, Grand, Casa Blanca, Ramona, and Hawarden Hills neighborhoods. Station 3 is a multi-company station staffing Engine 3, Truck 3, and Rescue 3. On duty Station 3 personnel include; two captains, two engineers, two firefighter/paramedics and one firefighter. (RFD).

The City’s Fire Department Operations Division responds to over 41,000 service calls annually and has an average response rate of approximately 7 minutes and 59 seconds (RFD-SP, p. 12). RFD has established a performance goal for emergency response to arrive within 8 minutes of dispatch over 90 percent of the time, slower than the 5-minute response time that is generally preferred by fire officials for urban areas. It is a long-term goal of the City to prove a high level of service to the community. (GPUI FEIR, p. 3.10-3).

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Police Protection Services
The Riverside Police Department (RPD) provides police protection services to the City from four RPD stations. The locations and services provided at each station are shown below in Table 5.10-A, Riverside Police Stations.

Table 5.10-A, Riverside Police Stations
Station Address Services/Divisions Personnel Ward
Orange Station 4102 Orange
Street
Headquarters, Support Services Division
– Personnel Bureau, Community
Services, Records Bureau, and
Administrative Functions
70 1
Lincoln Station 8181 Lincoln
Avenue
Field Operations Division – Patrol/Traffic
Functions, and Technical Services Unit
(Bomb
Squad)
184 4
Magnolia
Station
10540 Magnolia
Avenue
Investigations and Special Operations
Divisions – Investigations, Forensics,
Property Room, Communications
(Dispatch), Neighborhood Policing
Centers, and Training Bureau
281 6
Aviation 7020 Central
Avenue
Air Support, METRO (SWAT) Team 25 3
Source: GPUI FEIR, p. 3.10-4, Table 3.10-2
The Field Operations Division provides first response to all emergencies, performs preliminary investigations, and provides basic patrol services for the City. The Field Operations Division is managed by a Captain who oversees patrol officers, sergeants, lieutenant Watch Commanders, an Executive Lieutenant, and civilian support staff. The Field Operations Division includes over 130 patrol officers, 24 Sergeants, six Lieutenant Watch Commanders, one Executive Lieutenant, one Traffic Lieutenant, and a civilian support staff position. (GPUI FEIR, p. 3.10-4).

The City has reconsidered RPD’s centralized form of organization, and RPD has implemented a decentralized Neighborhood Policing Center model in an effort to provide more equitable and responsive services across the City. Additionally, RPD does not use a formula for calculating the number of officers per capita. According to the RPD Policy Manual, adequate staffing ensures that proper supervision is available for all shifts. (GPUI FEIR, p. 3.10-4).

The precinct-based system of the police department automatically assigns officers to certain districts of the City which allows the officers to become more familiar with the areas of the community they are assigned to. This method is called community policing and it balances the reactive responses to calls for service with proactive problem-solving to prevent crime incidences. There are two essential criteria for police response. The first criteria are Priority One calls and these are considered urgent calls which include life-threatening incidences such as an in-progress robbery or a bodily injury. Police officers typically respond to Priority One calls within seven minutes from the time calls for service are received.

The second criteria is Priority Two calls. These calls are less urgent and include non-life-threatening City of Riverside Sections 5.10
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incidences such as past burglary, petty theft, shoplifting, etc. and these calls are typically responded to within twelve minutes. (GPUI FEIR, p. 3.10-4).

Public Schools
The Project site is within the boundaries of the Riverside Unified School District (RUSD). RUSD is the 14th largest school district in California and serves approximately 42,000 students across 47 schools in Riverside. The RUSD operates 30 elementary schools, one special-education preschool, seven middle schools (grades 7–8), five comprehensive high schools, two continuation high schools, and the Riverside Virtual School. Additionally, RUSD has approximately 7,000 adult education students enrolled in its District. (GPUI FEIR, pp. 3.10-43.10-5). Per RUSD’s School Locator, school-aged children are expected to attend the following schools; Jefferson Elementary School (4285 Jefferson Street) located 0.35 miles southwest, Sierra Middle School (4950 Central Avenue) located 0.44 miles northeast and Romona High School (7675 Magnolia Avenue) located 0.55 miles south. (RUSD-B; GE) Charter Schools
Charter schools are public schools that are created or organized by a group of teachers, parents, community leaders, or a community-based organization. Charter schools may provide instruction in any grades K–12 and are generally sponsored by a local public school board or county board of education.

Specific goals and operating procedures for the charter school are detailed in an agreement (or “charter”) between the sponsoring board and charter organizers. Public charter schools may not charge tuition and may not discriminate against any pupil on the basis of ethnicity, national origin, gender, or disability.

The State of California charters one school in the Riverside area: River Springs Charter. River Springs Charter has multiple schools which overall serves grades TK-12. (CDE).

Libraries
The Riverside Public Library (RPL) system provides library service to the City. Eight RPL libraries serve the City in addition to libraries and three universities (University of California Riverside, La Sierra University, California Baptist University) and Riverside City College. The closest libraries to the Project site are the Marcy Branch approximately one mile west of the Project site and the SSgt. Salvador J. Lara Casa Blanca Library approximately 1.5 miles southwest of the Project site. (GPUI FEIR, p. 3.10-7.) Collectively, RPL offers the following services at their library locations: books and E-media, including Ebooks; Wi-Fi and internet access; computer, laptop, and iPad access; printing; home delivery of books and audiovisual materials; Technology and literacy programs; reference and research services; public meeting rooms; veteran resource center; community outreach efforts; annual summer reading program; cultural programming; makerspace containing computers, 3-D printers, audio and video capture and editing tools; and traditional arts and crafts supplies; youth services; and toy-lending library. (GPUI FEIR, p. 3.10-7).

Library service needs and standards are determined by the following methods: volumes by population; community need/service gaps (including services provided/not provided by other area departments and agencies); customer requests; and innovation/success of pilot projects. The City does not collect assessed development impact fees on the library’s behalf. Library funding sources include the General Fund, trust funds, gift funds/donations, grants, and the Riverside Library Parcel Tax. (Measure I).

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5.10.2 Related Regulations
Federal Regulations
There are no federal regulations directly applicable to public services with respect to this Project.

State Regulations
California Fire Code
The California Fire Code (Title 24, Part 9) is based on the 2021International Fire Code and includes amendments from the State of California fully integrated into the code. The California Fire Code contains fire safety related building standards referenced in other parts of Title 24 of the California Code of Regulations (CCR), also known as the California Building Standards Code (BSC).

California Building Code
Current law states that every local agency enforcing building regulations, such as cities and counties, must adopt the provisions of the California Building Code (CBC) within 180 days of its publication. The publication date of the CBC is established by the California Building Standards Commission and the code is also known as Title 24 of the California Code of Regulations. The most recent building standard adopted by the legislature and used throughout the state is the 2022 version of the CBC, often with local, more restrictive amendments that are based upon local geographic, topographic, or climatic conditions. These codes provide minimum standards to protect property and the public welfare by regulating various aspects of the design and construction of buildings. (BSC).

Assembly Bill 2926 and Senate Bill 50 (California Government Code 65996) To assist in providing school facilities to serve students generated by new development projects, the state passed Assembly Bill (AB) 2926 in 1986. This bill allows school districts to collect impact fees from developers of new residential and commercial/industrial building space. Development impact fees are also referenced in the 1987 Leroy Greene Lease-Purchase Act, which requires school districts to contribute a matching share of costs for construction, modernization, and reconstruction projects. (AB 2926).

Senate Bill (SB) 50, which passed in 1998, provides a comprehensive school facility financing and reform program, and enables a statewide bond issue to be placed on the ballot. The provisions of SB 50 allow the state to offer funding to school districts to acquire school sites, construct new school facilities, and modernize existing school facilities. SB 50 also establishes a process for determining the amount of fees developers may be charged to mitigate the impact of development on school facilities resulting from increased enrollment. Under this legislation, a school district could charge fees above the statutory cap only under specified conditions, and then only up to the amount of funds that the district would be eligible to receive from the state. According to Section 65996 of the California Government Code, development fees authorized by SB 50 are deemed to be “full and complete school facilities mitigation.” (SB 50).

Regional Regulations
There are no regional regulations directly applicable to these public services with respect to this project.

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project, as identified below (GP 2025, pp. E-19, PS-29, PS-31, PS-32, PS-34, PS-35):

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Education Element
Objective ED-5: Ensure that the library system remains a premier information and independent learning resource for the Riverside residents and a complement to formal education.

Policy ED 5.1 Provide ample and convenient library facilities.

Public Safety Element
Policy PS-6.1 Ensure that sufficient fire stations, personnel and equipment are provided to meet the needs of the community as it grows in size and population.

Policy PS-6-3: Integrate fire safety considerations in the planning process.

Policy PS 6.7 Continue to involve the City Fire Department in the development review process.

Policy PS 7.1 Deploy human and financial resources to ensure adequate and equitable distribution of police services.

Policy PS-7.2 Support the transition of the Riverside Police Department from a centralized agency to one built around precincts as a means of providing more rapid, equitable and proactive community policing services.

Policy PS -8.2 Promote land use and design policies and regulations which encourage a mixture of compatible land uses to promote and increase the safety of public use areas and of pedestrian travel.

Policy PS-8.4 Coordinate efforts between the Police Department and Planning Division to develop guidelines for implementation of CPTED-related issues.

Policy PS-8.5 Continue to encourage residents and apartment managers to become involved in the Crime Free Multi-Housing Program as a way to reduce crime in apartment communities.

City of Riverside 2025 General Plan EIR
There are no applicable mitigation measures from the 2025 General Plan EIR that pertain to Public Safety.

City of Riverside Phase I General Plan Update
The City of Riverside Phase I General Plan Update contains objectives and policies that are considered applicable to the proposed Project, as identified below (GPUI, pp.15-16):

Public Safety Element
Policy PS-4 Emergency Services: Provide Responsive police, fire, and emergency services to all residences and businesses in Riverside.

Action Plan PS-4.2-3 (Emergency Preparedness) Through the Development Review Committee and plan check process, require new and redeveloped structures and facilities to adhere to Riverside Municipal Code Title 16, California Fire Code (as amended), the International Building and Fire Code and other applicable local, state, and national fire safety standards.

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City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Public Safety.

Riverside Municipal Code
Chapter 16.52 – Development Fees for Fire Stations. This Chapter provides for the collection of development fees to be utilized for the purchase of land for and the construction of fire stations and the acquisition of equipment and furnishings to equip fire stations. The fee is required to be paid prior to issuance of a building permit for new development (MC). However, to date, the City has not adopted a resolution establishing those development fees, so no fees are currently being collected. RFD implemented service improvements through application of Riverside Measure Z funding and achieved an Insurance Services Office (ISO) Rating of ISO Class 1, the highest awarded level in December 2019.

Measure Z also continues to provide funding for RFD staff positions, training, and vehicle replacement and maintenance.

Chapter 16.56 – School Development Fee. This chapter provides for the collection of a school development fee as established by a school district for school facilities. The fee shall be paid prior to the issuance of a building permit for a proposed residential development. The proposed Project is subject to payment of the established school development fee for RUSD.

Measure Z
Measure Z is a one-cent transaction and use tax (similar to a sales tax) approved by Riverside voters on November 8, 2016, to help pay for critical unfunded City programs and services. Measure Z was placed on the ballot at the recommendation of City staff to fund critical needs such as first responder staffing and vehicles, road, tree maintenance, and building repair and maintenance. Measure Z is projected to generate approximately $48,00,000 in annual revenues through 2036 unless extended by the voters. (MZ).

5.10.3 Comments Received in Response to the Notice of Preparation No comments were received regarding recreation in response to the Initial Study/Notice of Preparation (IS/NOP).

5.10.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the Thresholds of Significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A) prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: fire protection, police protection, schools, and libraries.

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5.10.5 Project Design Features
Design features refer to ways in which the proposed Project will avoid or minimize potential impacts through the design of the Project. The proposed Project has been designed with sensitivity to the adjacent land uses and the existing residential neighborhoods surrounding the site. The proposed Project will include exterior building lights and pedestrian lighting for safety and security purposes within parking lots, along pathways, and on buildings as identified in Figure 3.0-30 in Section 3 – Project Description of this Draft EIR. The residential portion of the Project will be gated. Existing streetlights are located along Streeter Avenue and Arlington Avenue within the right-of-way.

5.10.6 Methodology
The following discussion analyzes potential impacts to public services based on the specific service ratios, response times, or infrastructure requirements of each public service.

5.10.7 Environmental Impacts
Threshold: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for:

As discussed in Section 3.0 – Project Description of this Draft EIR, the Project proposes development of a 576,203 square foot (sf) mixed-use apartment community. The residential component of the project will consist of 546,474 sf of residential use that will include 27 residential apartment buildings consisting of 2- and 3-story structures. The residential portion of the site would provide for a total of 388 residential dwelling units and one clubhouse/fitness/leasing building. The commercial component of the Project will develop 25,320 sf of commercial-retail use (20,320 sf for grocery and 5,000 sf for retail) via two commercial buildings. As discussed in Section 5.9 – Population and Housing of this Draft EIR, the Project is expected to increase the City’s population by approximately 1,273 persons and generate approximately 51 employees. This increase in population and employment has the potential to increase demand for public services. A detailed discussion regarding impacts to recreational parks can be found in Section 5.11 – Recreation.

Fire Protection Services
Demand for fire protection services, in the form of new service calls, may increase as a result of Project implementation from both the residential and commercial uses. Based on the City’s Fire Department Incident Data1
, the last incident reported on the Project site was in November 2019, while the Project site was being utilized for commercial-retail purposes. The Project site has been vacant since 2020. It is anticipated that re-development of the Project site would result in an increase of service calls in comparison to its current state. State, county, and City jurisdictions have policies related to providing adequate fire services. All Project-related development would be constructed in accordance with current building and fire/life/safety ordinances and codes, including all applicable code requirements related to construction, access, water mains, fire flows, and hydrants. GP 2025 Public Safety Element, Policy PS1 City of Riverside Fire Department provided Project site Data via email December 19, 2023.

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6.1 ensures that sufficient fire stations, personnel, and equipment are provided to meet the needs of the community as it grows in size and population. (GPUI FEIR, p. 3.10-18).

The closest fire stations to the Project site are Station 5 – Airport and Station 3 – Magnolia Center (Midtown). These stations are expected to serve the Project site. While the increase dwelling units of the project would likely result in increased service calls to these stations, the Project proponent will be required to enter into a cost contribution agreement to pay for the incremental increase to fire services which will reduce any impacts resulting from the Project.

State, county, and City jurisdictions have policies related to providing adequate fire services to the area.

All Project-related development would be constructed in accordance with current building and fire/life/safety ordinances and codes, including all applicable code requirements related to construction, access, water mains, fire flows, and hydrants. Additionally, the Project does not propose to use substantially hazardous materials or engage in hazardous activities that will require new or expanded fire protection facilities to meet potential emergency demand. Hence, any incremental impacts to the provision of fire protection or emergency medical facilities and services will be offset from funds identified within the cost contribution agreement that Project will be required to enter into with the City for fire services.

As such, impacts to fire protection services would be less than significant.

Police Protection Services
Demand for police protection services, in the form of new service calls, may increase as a result of Project implementation from both the residential and commercial uses. While an incremental increase in law enforcement calls to the Project site may occur, such calls would be consistent to the types of calls RPD responds to at the existing area. GP 2025 policy PA-7.5 strives to provide minimum response times of seven minutes on all Priority 1 calls and twelve minutes on all Priority 2 calls. The Lincoln Police Station in nearest the Project site at just under 3 miles southwest of the Project so the City would continue to meet the recommended police response times (7 minutes for Priority 1 calls and 12 minutes for Priority 2 calls) Based on location of this station. RPD is required to evaluate its budget annually to provide adequate police services to accommodate additional growth in the City in accordance with GP 2025 policy PA-7.1. As such, the Project proponent would be required to contribute to polices services as assessed to reduce any impacts. Further, the Project would be required to comply with all State, County, and local regulations which ensure sufficient police protection service and facilities are available to accommodate existing and future population.

As such, impacts related to police services would be less than significant.

Schools
As discussed in Section 5.9 – Population and Housing, the Project’s residential component is expected to increase population within the City by approximately 1,273 persons, which will increase the numbers of school-aged children within RUSD. The combined student generation rate for multi-family units within RUSD as set forth in the School Fee Justification Study 2022, is 0.239 students per dwelling unit. Based on the 388 proposed dwelling units, the residential component of the Project is expected to generate approximately 93 students. Based on the neighborhood shopping center student generation rate of

0.2979 students per 1,000 sf, as set forth in the School Fee Justification Study 2022, and 25,320 sf of commercial uses, the commercial component of the Project is expected to generate approximately 8 students. Thus, the Project is anticipated to generate a total of approximately 101 students.

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As of the 2022-2023 school year data 52 percent of RUSD’s school aged children are elementary school students, 15 percent are middle schoolers and 33 percent are highschoolers. (DQ-A) Assuming that the projected students will follow similar age group patterns as the existing RUSD’s population it is anticipated that approximately 53 students will be elementary school students, 15 will be middle school students, and 33 will be high school students2
.

Table 5.10-B, Multi-Year RUSD Student Enrollment below, shows recent student enrollment trends for the schools anticipated to be affected by the proposed Project.

Table 5.10-B, Multi-Year RUSD Student Enrollment
Academic Year Jefferson Elementary School
Number of Students
Sierra Middle School
Number of Students
Ramona High School
Number of Students
2022-23 920 830 2,220
2021-22 901 792 2,078
2020-21 953 870 2,213
2019-20 974 840 2,030
2018-19 993 871 2,157
2017-18 1,002 825 2,154
2016-17 1,015 808 2,142
Source: DQ-B, DQ-C, DQ-D
As shown above the student population at Jefferson Elementary has declined since 2016. Sierra Middle school has also seen a similar decline between student enrollments over the year. Ramona High School is currently serving the highest student population of the last 7 years. However, it should be noted that high school enrollment does fluctuate based on student enrollment from middle school and elementary schools from the previous years as students advance to each grade. Thus, since with a current decline in student enrollment for both Jefferson Elementary School and Sierra Middle School, high school enrollment is also expected to decline in the upcoming years. As previously mentioned, it is anticipated that Project implementation will increase the number of elementary school students. As shown in the Table 5.10-B, Jefferson Elementary School has previously served a higher population. Nonetheless, the Project will comply with RMC Chapter 16.556 and pay the school development fee established by the RUSD prior to the issuance of building permits. As per AB 2926 and SB 50, the school development fee is charged to developers to mitigate the impact of development on school facilities which may result from increased enrollment and is deemed to provide full and complete school facilities mitigation for impacts to school facilities. (RUSD-A, pp. 10, 19).

As such, through compliance with City policy and payment of development impact fees, impacts related to schools would be less than significant.

Libraries
The City of Riverside Public Library consists of one Main Library and seven branch libraries. The library system has a collection of approximately 425,000 books and other library materials, 400 public access computers, and an annual circulation of 1.23 million. The Marcy Branch Public Library, covering 4,200 square feet, is located just under one mile from the site. The Arlanza Branch Public Library just under

2. 101 studnets x 0.52≈ 53 students; 101 students x 0.15 ≈15 students; and 101 students x 0.33 ≈33 students.

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three miles from the Project site and is a 10,000 square foot library with over 80 computers for public use and houses a starting collection of more than 11,750 items. Further, the City’s new main Library which was expanded in 2021 covering 42,000 square feet and providing more than 60,000 items is also anticipated to serve the site. As such, the proposed Project may result in an incremental increase in the use of libraries but is not expected to substantially increase the demand of these services such that construction of new or expanded facilities would be required. While there are no there are no development impact fees that would fund the RPL system, the Project would be required to comply with GP 2025 Education Element Objective ED-5 and Policy ED-5.1, which states that the City is required help to provide ample and convenient library facilities. Compliance with these policies would ensure that the Project would not affect the City’s ability to provide adequate libraries. Further, City Council may approve funds as necessary for library services.

As such, impacts related to library facilities and services would be less than significant.

Conclusion
Through implementation of PDF’s and compliance with all regulatory requirements, the Project will not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives. Therefore, impacts would be less than significant.

5.10.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). Since impacts to fire protection services, police protection services, schools, and libraries are less than significant, no mitigation measures are required.

5.10.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
There are no mitigation measures required to reduce impacts to public services.

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5.11 Recreation
The focus of this section is to analyze potential impacts related to recreation. The following discussion also addresses the potential for adverse impacts that could result from the construction of additional recreational facilities as a result of the Project. Cumulative impacts related to this topic are discussed in Section 7.0 – Other CEQA Topics.

5.11.1 Setting
The City provides numerous parks, open spaces, and offers diverse recreation activities and resources.

These parks, recreation facilities and activities allow residents of Riverside numerous ways to enhance their quality of life and allow for natural outdoor experiences. The City envisions a “necklace” of parks and open space that exists on and/or defines the edges of the City with connectivity occurring between these spaces and Riverside’s neighborhoods with landscaped parkways and trails accessible to pedestrians and cyclists alike. Together these parks and open spaces embody a broader concept of “Riverside Park,” a citywide park that provides places to find the peace and harmony of nature within or on the edges of the City's urban fabric. (GP 2025, p. PR-2).

The PMP defines parks as areas that are “intended as public green space where city dwellers can escape for the rush of urban life.” The City categorizes its parks into three categories: Developed Parks, Natural Parks, and Miscellaneous Facilities as described below. (GPUI FEIR, pp. 3.11-2, 3.11-3).

Developed Parks
Pocket Parks
These are small parks that the general public has access to. They are often designed and built in a single lot or smaller parcel. These parks may be created as a component of public space requirements of larger developments and can occur in all manner of settings.

Neighborhood Parks
These may provide green space, recreation centers, sports facilities, or playgrounds. They are often landscaped and serve a multitude of functions from passive recreation to a planned center for sports activities. They are typically less than 30 acres in total size and will often present themselves as a community or neighborhood focal point.

Community Parks
These are typically larger parks meant to serve a larger geographic area than the immediate neighborhood. These parks are formed with the intent to engage the community and visitors for longer periods of time and offer more diverse activities and amenities.

Regional Parks
These are areas preserved to protect or bring attention to natural features, historic significance, or recreational use or other reasons. These parks are administered by a local jurisdiction, usually a city or a county.

Joint-Use Facilities
These can also be referred to as shared-use or community-use sites. These sites are managed by jurisdictions or quasi-government entities and allow access for community use.

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Special-Use Facilities
These cover a broad range of specialized park and recreation facilities, often with a single major use.

Golf courses, historical sites, community center sites, theme parks, and water parks are other specialuse facilities that fall into this use type.

County and State Parks
These exist within the City of Riverside and the City’s Sphere of Influence. Although not directly owned or controlled by the City, these parks also provide recreation opportunities to the community.

Natural Parks
Regional Reserves
These are areas set aside for the protection of wildlife, habitat, and other ecological considerations.

There is usually minimal infrastructure within the park beyond trails and signs. These areas may be accessible for low-impact use. (GPUI FEIR, p. 3.11-2)
Miscellaneous Facilities
Private Use Parks
These are areas that have restricted access and are generally only available for use by the local community, such as a homeowners’ association or a private club.

Undeveloped City-Owned Property
This is land owned by the City. It can potentially be leased for use. It also may be projected as a potential park site in the future but is not included in calculations of acres or parkland per thousand people until improved as a Developed Park.

Existing Park Supply and Demand
The City has 68 parks and additional open space areas with approximately 2,940.61 acres of Cityowned parkland as reflected in Table 5.11-A, City-Owned Park/Recreational Facilities. The City has identified nine undeveloped City-owned park sites in underserved areas of the City that can be developed into parks contingent upon availability of funds. These sites include City Citrus State Park, Golden Star Park, Hole Lake, Mission Ranch Park, Mount Vernon Park, Savi Ranch Park, Seven Mile Trail, Tequesquite Open Space, and Victoria Cross Park (GPUI FEIR, p. 3.11-1). Note that there are four parks within the City that are not owned by the City totaling 131.74 acres: 1) AB Brown Sports Complex; 2) Riverwalk Parkway; 3) City Citrus State Park; and 4) Mount Vernon Park. Those parkland acres are not included below.

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Table 5.11-A, City-Owned Park/Recreational Facilities
Facilities Size (Acres)
Developed Parks
Pocket Park 3.50
Neighborhood Park 225.57
Community Park 370.18
Regional Park 279.45
Joint-Use Facilities Not Included
Special Used Facility 97.54
Natural Parks
Regional Reserve 1,615.33
Miscellaneous Facilities
Undeveloped City-Owned Property 349.05
Total City-Owned Property 2940.61
Total City Owned Acres excluding
Undeveloped City Owned Property 2,595.07
Source: GPUI FEIR, p.3.11-2
The existing parkland-to-resident ratio is 6.07 acres per 1,000 residents citywide. The projected parkland-to-resident ratio remains compliant with both the current standard of 3 acres per 1,000 residents and the suggested standard of 5 acres per 1,000 residents. New development is required to provide facilities to serve its own needs. Potential population growth may exacerbate the alreadyexisting neighborhood parkland deficiencies but, for the reasons explained above, would not lead to a further substantial physical deterioration of existing recreational facilities . Further, the City has signed joint-use agreements with the Alvord Unified School District to use aquatic facilities and with Riverside Unified School District and Ramona High School to use the stadium at the school campus. As stated in the City of Riverside’s Comprehensive Park, Recreation & Community Services Master (PMP), the City will continue to look for opportunities to implement joint-use agreements with the local school districts. (PMP)

5.11.2 Related Regulations
Federal Regulations
No federal regulations would be applicable to recreation with respect to recreation.

State Regulations
Quimby Act (California Government Code 66477)
The Quimby Act was established by the California legislature in 1965 to provide parks for the growing communities in California. The Act authorizes cities to adopt ordinances addressing parkland and/or fees for residential subdivisions for the purpose of providing and preserving open space and recreational facilities and improvements. The Act requires the provision of 3 acres of park area per 1,000 persons residing within a subdivision, unless the amount of existing neighborhood and community park area exceeds that limit, in which case the City may adopt a higher standard not to exceed 5 acres per 1,000 residents. The Act also specifies acceptable uses and expenditures of such funds. Because the City of Section 5.11 City of Riverside
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Riverside is a Charter City, it is not subject to the Quimby Act, but the City does base their analysis and imposition of appropriate Park Development Impact Fees on requirements of the Quimby Act. (GP 2025 FEIR, p. 5.14-13)
Proposition 40 Park Bond Act
Proposition 40 is intended to maintain a high quality of life for California’s growing population by providing a continuing investment in park and recreational facilities. Specifically, it is for the acquisition and development of neighborhood, community, regional parks and recreation land, as well as facilities in urban and rural areas. Eligible projects for Proposition 40 funding include the acquisition, development, improvement, rehabilitation, restoration, or enhancement of interpretive facilities, local parks, recreational land, or other related facilities. Funds are distributed based on the City’s population.

California Public Park Preservation Act
The California Public Park Preservation Act is the primary instrument for protecting and preserving parkland. Under the California Public Resources Code Sections 5400-5409, cities and counties may not acquire any real property that is in use as a public park for any non-park use unless compensation or land or both is provided to replace the parkland acquired. It provides that a public agency that acquires public parkland for non-park use must either pay compensation that is sufficient to acquire substantially equivalent substitute parkland or provide substitute parkland of comparable characteristics. This act ensures no net loss of parkland and facilities. However, the Project would not acquire parkland for nonpark use, and this act would not apply.

Regional Regulations
No regional regulations would be applicable to recreation with respect to recreation.

Local Regulations
City of Riverside General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project as identified below (GP 2025, pp. PR-15 – PR-18, OS-5, LU-27, LU-29 LU-30, PF-40):

Park and Recreation Element
Objective PR-1 Provide a diverse range of park and recreational facilities that are responsive to the needs of Riverside residents.

Policy PR-1.1 Implement the policies of the City of Riverside Comprehensive Park, Recreation & Community Services Master. Revise the neighborhood/community park ratio standard to two acres of community park and one acre of neighborhood park per one thousand residents.

Policy PR-1.3 Encourage private development of recreation facilities that complement and supplement the public recreational system.

Policy PR-1.6 Develop standards to design park facilities and landscaping that enhance and preserve natural site characteristics as appropriate, to minimize maintenance demands and to incorporate xeriscape (low-water demand) principles where feasible.

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Objective PR-2 Increase access to existing and future parks and expand pedestrian linkages between park and recreational facilities throughout Riverside.

Policy PR-2.1 Integrate public transportation routes when locating regional reserve parks, community parks and community centers.

Objective PR-3 Engage Riverside residents and the business community in planning for recreation and service needs.

Policy PR-3.1 Consider the needs of all age groups, abilities, disabilities and special interest groups in park and recreation planning and design.

Open Space/Conservation Element
Objective OS-1 Preserve and expand open space areas and linkages throughout the City and sphere of influence to protect the natural and visual character of the community and to provide for appropriate active and passive recreational uses.

Policy OS-1.6 Ensure that any new development that does occur is effectively integrated through convenient street and/or pedestrian connections, as well as through visual connections
Policy OS-1.8 Encourage residential clustering as a means of preserving open space.

Policy OS-1.11 Develop a program for City acquisition of identified open space land and encourage land donations or the dedication of land in lieu of park fees for the acquisition of usable land for public parks, open space, and trail linkages.

Land Use and Urban Design Element
Objective LU-9 Provide for continuing growth within the General Plan Area, with land uses and intensities appropriately designated to meet the needs of anticipated growth and to achieve the community's objectives.

Policy LU-9.2 Evaluate proposed amendments to the Land Use Policy Map (Figure LU-10) to consider the effect such amendments will have on the City's ability to achieve its objectives.

Policy LU-9.5 Encourage the design of new commercial developments as “integrated centers,” rather than as small individual strip development. Integrate pedestrian access, parking, access, building design and landscape themes across all parcels in the commercial center to unify the development.

Objective LU-11 Create a network of parkways to establish stronger linkages between Riverside's neighborhoods, major elements of its natural environment and neighborhood parks and schools.

Policy LU-11.1 Recognize parkways as distinctive elements of the City's circulation network.

Policy LU-11.2 Recognize Victoria Avenue, Magnolia Avenue/Market Street, University Avenue, Van Buren Boulevard, Riverwalk Parkway, La Sierra Avenue, Arlington Avenue, Section 5.11 City of Riverside
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Canyon Crest Drive, and Overlook Parkway as the fundamental elements of the City's parkway landscape network, and components of Riverside Park.

Policy LU-11.3 Seek opportunities to provide enhanced bicycle and pedestrian usage along parkways through the development process.

Objective LU-20 Recognize and enhance Arlington Avenue as a cross-city roadway that connects east to west.

Policy LU-20.1 Develop a landscaped parkway with distinctive signage that promotes the function of Arlington Avenue as a roadway that connects and links many neighborhoods and business centers.

Public Facilities and Infrastructure Element
Objective PF-10 Meet the varied recreational and service needs of Riverside’s diverse population.

Policy PF-10.1 Provide every neighborhood with easy access to recreation and service programs by decentralizing community centers and programs. Promote the development of shared facilities and satellite offices in each Riverside neighborhood.

Policy PF-10.2 Work cooperatively with the Riverside Transit Agency to improve transportation services to community centers for those who rely on public transportation, such as seniors, the disabled and teenagers.

Policy PF-10.4 Ensure that youth activities and programs are provided or are accessible by all neighborhoods, either in City facilities or through joint-use or cooperative agreements with other service providers.

City of Riverside 2025 General Plan EIR
The following are applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to Recreation (GP 2025 FEIR, p. 5.14-24).

Mitigation Measure MM Rec 1: All future development shall provide developed parks as part of their project approvals at the discretion of the City Parks, Recreation and Community Services Department, or pay applicable Park Development Impact Fees to the City of Riverside Parks, Recreation and Community Services Department prior to issuance of building permits.

City of Riverside Phase I General Plan Update
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project as identified below (GPUI p. HE20; HE-AP9):

Housing Element
Policy HE-4 Thriving Neighborhoods. Facilitate and encourage a variety of new housing types, including both single- and multi-family and missing middle housing, and the necessary public amenities to support a sense of community that results in equitable and sustainable neighborhoods.

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City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Recreation.

City of Riverside Municipal Code
The following section of the City’s Municipal Code are applicable and pertain to Recreation (MC):

Chapter 16-44 – Regional Parks and Reserve Parks Development Fee. The purpose of this chapter is to provide for the payment of a development fee to be utilized for the acquisition and development of regional parks and reserve parks, and if necessary, to be utilized for interfund borrowing for local parks.

Chapter 16.60 – Local Park Development Fees. The purpose of the Local Park Development Fee is to enable the acquisition and/or development and/or improvement of neighborhood and community parks to provide both passive and active recreational opportunities to the residents of the City of Riverside in order to improve the quality of life and for the public health, welfare, and benefit. New development within the City generates a need for added facilities and an increased demand upon existing facilities, and the imposition of a Local Park Development Fee upon such new development is necessary to provide funding for such new or improved facilities meeting established standards for such new development.

Section 9.08.110 – Park hours and closure. Hours of operation. All parks owned by the City of Riverside or to be hereafter owned by the City of Riverside, shall be closed from 10:00 p.m. to 5:00 a.m. for developed parks, and closed from a half hour after sunset to a half hour before sunrise for undeveloped parks, except for those uses noted in Section 9.08.110(C.) or 9.08.120.

1. "Developed park" means park acreage that has been improved with typical park amenities such as turf, trees, irrigation, children's play equipment, and picnic areas.

2. "Undeveloped park" means park acreage established for the protection and stewardship of wildlife, habitat, and other natural systems support functions with minimal infrastructure which may include trails, signage, staging areas, parking, restrooms, picnic tables, and other support facilities.

City of Riverside Comprehensive Park, Recreation and Community Services Master Plan On February 4, 2020, the City adopted the Comprehensive Park, Recreation & Community Services Master (PMP) which serves as a guide and implementation tool for the management and development of parks and recreation facilities within the city boundaries. The PMP builds on previous planning efforts and provides an up-to-date understanding of the current and future recreation facility and program needs and opportunities within the city. The purpose of the PMP is to: (PMP, p. 18)  Revise the City’s park standards to reflect the current ratio of 1.0 to 2.0 in favor of community parks;
 Establish new park designations and categories to eliminate redundancy and confusion;  Acquire key remaining open space areas, including La Sierra/Norco Hills, Alessandro and Prenda Arroyos and wildlife corridors
 Create seven (7) new park sites in underserved areas of the City;  Revitalize existing parks, including Fairmount Park;
 Consider Tequesquite Arroyo for a potential neighborhood park site and Arlington Heights for a potential community park site;
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 Partner with schools to increase the areas serviced by recreation programs;  Improve and create connections between park facilities and increase the safety of the bicycle, equestrian, and pedestrian trails system.

5.11.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding recreation in response to the Initial Study/Notice of Preparation (IS/NOP).

5.11.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the thresholds of significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; and  Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

The following Section 5.10 – Public Service threshold questions will be analyzed here in relation to Parks.
 Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks.

5.11.5 Project Design Features
The Project includes design features that integrate recreational areas into residential and commercial spaces that will provide public access to open space areas including promenade areas and a dog park.

Furthermore, the Project site offers additional amenities such as outdoor resort style pool and spa, fitness area, clubhouse, shade structures with barbeques and tables, multi-use turf areas, outdoor gaming, play spaces for the on-site residents.

5.11.6 Methodology
The level of significance is evaluated through the evaluation of the proposed Project against the City’s adopted standard of three acres of developed parkland per 1,000 residents and consistency with fee programs relevant to recreational resources. (PMP, p. 78; MC) City of Riverside Sections 5.11
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5.11.7 Environmental Impacts
Threshold: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
The nearest neighborhood park to the Project site is Don Jones Park located at 3995 Jefferson Street approximately 0.46 miles south of the Project site. The Project is located approximately 0.78 miles southeast of the Nichols Park (Joyce Jackson Community Center) community park located at 5505 Dewey Avenue. It should also be noted that the Project is located approximately 800 feet south of a developed Special Use Parks Facility, Streeter Park/Janet Goeske Senior Center at 5257 Sierra Street. (GE; PMP, p.38) The nearest regional park, which is Non-City owned or maintained is Rancho Jurupa Regional Park located approximately 2.40 miles northeast form the Project site as 4800 Crestmore Road (GE; GP 2025, pp. PR-5 – PR-7). Due to the proximity of the Project site to these recreational areas, nearby facilities may get some usage by the Project residents. However, these regional facilities are designed to serve the region and such use would be expected.

The parkland ratio established in the City’s 2025 General Plan is three acres per 1,000 residents.

Currently the City of Riverside, is behind in meeting the established parkland ratio1 . As identified in
Section 5.10 – Population and Housing, since the Project’s estimated population is 1,237 persons, the Project’s parkland demand would be approximately 3.7 acres. 2 Hence, implementation of the proposed Project would increase an existing deficit. However, it is not the responsibility of this Project to correct this deficit, and the Project would be required to pay into Local Park Development Fees per MC Chapter

16.60 – Local Park Development Fees for its fair share contribution. Further, as identified in Figure

5.11-1, Open Space Plan and Table 5.11-B, Project Qualified Open Space Provided below, the Project will be providing a number of open space and amenity features to serve the Project and neighboring community. Figure 5.11-1 and Table 5.11-B identify areas proposed for open space and the amount of open space that Project would provide that qualifies as parkland. The Project will include a pool and clubhouse. However, these amenities have restricted public access so are not counted as part of the open space provided.

Table 5.11-B, Project Qualified Open Space Provided
Qualified Open Space1 Square Feet Acres2
Area # 1 Promenade 3,952 0.1
Area # 3 Promenade 21,933 0.5
Area # 4 Dog Park 4,036 0.1
Area # 5 Open Space 1,604 0.0
Area # 6 Open Space 2,469 0.1
Total Provided 33,994 0.8
Notes:

1. Names listed correspond to Figure 5.11-2.

2. Numbers were calculated and rounded to the nearest tenth.

1. Per email from the City’s Park and Recreational Facilities.

2. 1,237 persons/1,000 x 3 = 3.7).

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As shown above, the Project will provide approximately 0.8 acres of parkland. The PMP found that there was a strong need for more dog parks identified by the community so it was recommended that the City should explore opportunities for the development of at least one additional dog park, preferably on existing parkland that is underutilized, and would not result in the displacement of a current recreational use. Alternatively, a new facility could be created in an underserved area and where the community has requested a dog park (PMP, p. 130, Exhibit 5.3-2). The Project site is located approximately 2.5 miles southwest of one of the eight locations where the community is requesting a dog park (GE). Thus, by implementing the Project the City is fulfilling a previously identified community need. Additionally, once fully operational the dog park would be required to adhere to MC Section

9.08.110 – Park hours and closure. While the dog park would be open to the public, it will be owned, managed, and maintained by the owners of the Arlington Mixed-Use Development project.

The project will include recreational areas that would supplement the existing recreational facilities in the area. Nonetheless, the Project would provide 2.9 fewer acres of parkland than required based on City requirements. However, in accordance with MC Chapter 16.60 – Local Park Development Fees, the Project would be required to pay Local Park Development Fees. Local park fees are collected by the City as part of the development review process and are used for the purpose of supporting the City’s recreational budget for past and present facilities to serve the community. Thus, through project design features, adherence to municipal code, compliance with conditions of approval, and payment of Local Park Development Fees, the Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Therefore, the impacts would be less than significant.

Threshold: Would the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
The proposed Project plans for approximately 0.8 acres of recreational areas including a public dog park, passive open spaces areas along with 0.5 acres of private amenities such as a clubhouse, workout facility and pool, which are all considered part of the Project’s design and are therefore analyzed throughout this DEIR. Since the Project is already analyzing the environmental effects of the Project as whole, the Project would not require any additional recreational facilities that are not already analyzed as part of this DEIR. Additionally, the Project would be required to pay into Local Park Development Fees per MC Chapter 16.60 – Local Park Development Fees. Thus, the proposed Project would not include recreational facilities or require the construction or expansion of recreational facilities which would substantially impact the environment. Therefore, the impacts would be less than significant.

Threshold: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for Parks?
As discussed above, the public and private park/recreational amenities proposed by the Project are all within the Project analysis included herein. Since the Project is already analyzing the environmental effects of the Project as whole, the Project would not require any additional recreational facilities that are not already analyzed as part of this DEIR. Thus, the proposed Project would not include recreational facilities or require the construction or expansion of recreational facilities which would substantially impact the environment. Therefore, the impacts would be less than significant.

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5.11.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). There are no mitigation measures required to reduce impacts to since less than significant impacts to recreation are anticipated from implementation of the Project. Therefore, no mitigation measures are required.

5.11.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
Less than significant impacts on recreation are anticipated from implementation of the Project.

Therefore, no mitigation measures are required.

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5.12 Traffic and Transportation
The focus of this section is to analyze potential impacts related to transportation. The following discussion addresses the potential adverse impacts that could result from the construction and operation as a result of the Project. Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics.

A Vehicle Miles Traveled Screening Assessment Memorandum (VMT Memo) dated June 6, 2023, was prepared by Albert A. Webb Associates (WEBB-C) and a Traffic Impact Analysis (TIA) dated October 18, 2023 was prepared by Urban Crossroads (URBAN). Both reports are included as Appendix F of this Draft EIR.

5.12.1 Setting
The Project site has frontage along Arlington Avenue and Streeter Avenue. The proposed Project consists of an existing vacant but fully developed site with buildings and parking, situated amongst an urbanized area surrounded by existing development. Existing surrounding land uses are described in Table 3.0-A found in Section 3.0 – Project Description of this Draft EIR Existing Site Access
There are six existing driveways to access the site: two on Arlington Avenue and four on Streeter Avenue. Current access to the Project site, however, is only available from the two driveways on Arlington Avenue, the southern Driveway on Streeter Avenue that aligns with Molino Avenue and the northernmost driveway on Streeter Avenue that aligns with Granada Avenue. The westernmost driveway on Arlington Avenue and southernmost driveway on Streeter are shared access driveways with the existing property located on the northeast corner of Streeter and Arlington Avenues. The easternmost driveway on Arlington Avenue is signalized and aligns with the driveway into the existing shopping center located south of the site.

Roadway System and Types
The existing street system in the general vicinity of the Project area consists of roadways designated as Arterial Streets, Collector Streets, and Local Streets as reflected on Figure 5.12-1, Master Plan of Roadways. The Project area includes the following roadway types:
 Arterial Streets. These streets carry through traffic and connect to the state highway system with restricted access to abutting properties. They are designed to have the highest traffic carrying capacity in the roadway system with the highest speeds and limited interference with traffic flow by driveways. The City has five arterial classifications that range from 88-feet of right of way (ROW) with four lanes of traffic to 145-feet of ROW with eight lanes of traffic. There are some arterial streets throughout the City that are also classified as a Parkway and or Scenic Boulevard. (GP 2025, p. CCM-10).
 Collector Streets. These streets are intended to serve as intermediate routes to handle traffic between Local Streets and streets of higher classification. The City has two types of collector street widths; 40-foot curb-to-curb width within a 66-foot ROW and 40-foot curb-to-curb width with an 80-foot ROW. (GP 2025, p. CCM-10).

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 Local Streets. These streets provide vehicular, pedestrian, and bicycle access to property directly abutting the public ROW, with movement of through traffic discouraged. Local streets are designated to have a 36 foot curb-to-curb width with 66-foot ROW and two travel lanes (one in each direction). (GP 2025, pp. CCM-9 - CCM-10).

Existing Project Roadways
 Arlington Avenue is classified as an Arterial roadway as well as a Special Boulevard and Parkway. Arlington Avenue ranges in width from a 110-foot roadway to a 120-foot roadway.

Arlington Avenue is an east-west divided roadway with a raised and landscaped median allowing for two lanes of travel in each direction. Arlington Avenue also provides striped bike lanes on both sides of roadway.

A dedicated left turn lane is provided in each direction of travel at the intersection of Arlington/Streeter Avenues and at the signalized intersection of the easternmost driveway where it aligns with the driveway to the existing Heritage Plaza Shopping Center.

Arlington Avenue provides an existing curb and gutter and road adjacent concrete sidewalk on both sides of the roadway. Signs provide a posted speed limit of 40 miles per hour (mph) and for no street parking. (GP 2025, p. CCM-16; GE).
 Streeter Avenue is classified as an 88-foot wide Arterial roadway. Streeter Avenue is a northsouth roadway with a combination of raised median, landscaped median, and striped median allowing for two lanes of travel in each direction.

A dedicated left turn lane with a raised median is provided in each direction of travel at the intersection of Streeter and Arlington Avenues. A striped center lane is available left-turning northbound traffic to access El Molino Avenue. This same intersection provides a dedicated left turn lane with raised median for south bound traffic to access existing Project site. A dedicated left turn lane with raised median for north and south bound traffic is located at the intersection of Streeter and Granada Avenues (the Projects northernmost existing driveway).

Streeter Avenue provides an existing curb and gutter and road adjacent concrete sidewalk on the east side of the roadway and an existing curb and gutter with concrete sidewalk with road adjacent landscape buffer on the western side of the roadway. Signs provide a posted speed limit of 40 mph and for no stopping for the entire block (GP 2025, p. CCM-16; GE).

Offsite Impact Area Roadways
The Project also includes approximately 1.5 miles of offsite impacts located within roadway right-of-way as reflected in Figure 3.0-4 found in Section 3.0 – Project Description of this Draft EIR. Offsite impacts would affect the following portions of listed roadways:
 Streeter Avenue from north of the Project site to Central Avenue  Central Avenue from Streeter Avenue to Hillside Avenue  Hillside Avenue to just before roadway transitions to Mountain View Avenue The following provides a brief description of the roadways that will be impacted as a result of electric improvements.
 Streeter Avenue (north of the Project site) is classified as an 88-foot wide Arterial roadway.

Streeter Avenue is a north-south roadway with a striped center median allowing for two lanes of travel in each direction.

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A dedicated left turn lane with raised median for northbound traffic is located at the intersection of Streeter Avenue and West Sierra Street. The intersection of Streeter Avenue and East Sierra Street is striped and signalized intersection with crosswalks, dedicated right turn lane for northbound traffic and dedicated left turn lane for southbound traffic. There is a striped center median for northbound travel allowing for left turning movements onto Rochester Street and Scott Avenue. The intersection of Streeter and Central Avenues provides crosswalks and striped dedicated left turn lanes for north and southbound traffic. (GE) Streeter Avenue provides an existing curb and gutter and road adjacent concrete sidewalk on the east side of the roadway until the intersection of Streeter Avenue and Rochester Street at which time it transitions to an existing curb and gutter with concrete sidewalk with road adjacent landscape buffer on the western side of the roadway. The west side provides an existing curb and gutter with concrete sidewalk and road adjacent landscape buffer. Signs provide a posted speed limit of 40 mph with exception of area near existing school where limits are 25 mph.

Signs are also posted for no stopping for the entire block (GE)  Central Avenue is classified as an 88-foot Arterial roadway. Central Avenue is an east-west roadway with a striped center median allowing for two lane travel in each direction. Central Avenue also provides striped bike lanes on both sides of roadway.

The intersection of Central/Streeter Avenues, Central Avenue/Phoenix Avenues, and Central/Hillside Avenues provide crosswalks and striped dedicated left turn lanes for north and southbound traffic.

The south side of the roadway provides an existing curb and gutter with road adjacent concrete sidewalk. A majority of the north side of the roadway provides an existing curb and gutter with road adjacent concrete sidewalk. A portion of the north side of the roadway provides an existing curb and gutter with concrete sidewalk and road adjacent landscape buffer.

Signs provide a posted speed limit of 40 mph and no 4 axle trucks. Street parking is allowed on both sides of the street with exception of a small segment near the intersection of Central/Street Avenues. (GE) (GP 2025, p. CCM-16) The area is already developed, therefore existing curbs and gutters are already in place.
 Hillside Avenue is classified as a local street. Hillside Avenue is a north-south roadway allowing for one lane travel in each direction and striped accordingly. The intersection of Hillside/Central Avenues is signalized with crosswalk and provides a striped left turn lane for southbound traffic.

All other intersections are stop sign controlled.

Both sides of the roadway provide an existing curb and gutter with concrete sidewalk and road adjacent landscape buffer. The posted speed limit is 25 mph. Street parking is allowed. (GE).

The Project site is just over one mile northwest of the access to State-Route 91, which provides local and regional access to the Project area and is under the jurisdiction of the California Department of Transportation (Caltrans).

Public Transit
Riverside Transit Agency
Riverside Transit Agency (RTA) is the Consolidated Transportation Service Agency for western Riverside County and is responsible for coordinating transit services throughout the approximately 2,500‐square mile service area. RTA provides both local and regional services throughout the region with 33 fixed routes, four CommuterLink Express routes, and Dial‐A‐Ride services using 334 vehicles. RTA local bus City of Riverside Sections 5.12
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Routes 1, 10, 12, 13, 14, 15, 16, 20, 21, 22, 27, 29, 49, 51, 59, and CommuterLink Express Route 200 and 204 operate within the City. (RTA)
The Project area is currently served by RTA’s Downtown Riverside – Merced & Magnolia Line Route 15 and the La Cadena and Interchange – Downtown- Riverside – Corona Hills Plaza Route 12. Route 15 includes stops that can be accessed by OmniTran and Metrolink and Route 12 includes stops that can be access by Corona Cruisers, which are other transit agencies. Access to the Metrolink stations is also available via Route 15 at both the Riverside-Downtown Station and the La Sierra Station.

Route 12 travels along Streeter Avenue while Route 15 travels along Arlington Avenue in the Project area. The nearest bus stops and shelters are located on Arlington Avenue and Streeter Avenue. A bus shelter for Route 15 currently exists along Arlington Avenue which is situated in front of the location of the proposed ALDI. RTA will replace the shelter once Arlington Avenue has been widened. A bus stop for Route 12 is provided on Streeter Avenue near the intersection of Arlington Avenue.

Metrolink
Rail service is provided by Metrolink operated by the Southern California Regional Rail Authority, which serves over thirty-five thousand passengers in fifty cities throughout Southern California. Lines traversing the City include the Inland Empire-Orange County Line, which runs between San Bernardino and San Juan Capistrano; the 91/Perris Valley Line, which runs from Riverside to downtown Los Angeles via Fullerton and other points in Orange County; and the Riverside Line, which also runs from Riverside to downtown Los Angeles via Ontario and downtown Pomona. The Riverside‐Downtown Metrolink Station is located in close proximity to the Project Site. RTA Route 15 Line has a stop at both the RiversideDownton Metrolink Station and La Sierra Metrolink Station at this station.

Bicycle and Pedestrian Facilities
The City provides a network of non-vehicular circulation as discussed below.

Bicycle Facilities
The City completed a four part planning process called the Riverside PACT Plan which consists of the following plans: Pedestrian Target Safeguarding Plan (PTS), Active Transportation Plan (AT Plan), Complete Streets Ordinance (CSO), and Trails Master Plan (TMP). The Riverside PACT Plan helps the City create robust, sustainable, and accessible transportation options.

Figure 5-3: Trails, On-Street Facilities, and Destinations of the City’s PACT Plan identifies the City’s future bicycle and pedestrian network and improvements. This master plan is based upon recommendations of the 2012 Bicycle Master Plan Addendum, current bicycle level of traffic stress, the demand of existing conditions, and public in-put. (PACT, pp. 1-5, 4-12) In 2020, Caltrans designated four classes of bicycle facilities, which are used in the AT Plan and are listed below:
 Class I – Share Used Paths. These are paved trails completely separated from the street. They allow two-way travel by people bicycling and walking.
 Class II – Bike Lanes. Striped preferential lanes on the roadway for one-way bicycle travel. Some bicycle lanes include a striped buffer on one or both sides to increase separation from the traffic lane or from parked cars where people may open doors into the bicycle lane (buffered bicycle lanes are referred to as Class II Buffered Bike Lane).

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 Class III – Bicycle Routes. Signed routes where people bicycling share a travel lane with people driving. Because they are shared facilities, bicycle routes are primarily used on select low-speed streets. Some Class III bicycle routes include shared lane markings or “sharrows” that recommend proper bicycle positioning in the center of the travel lane and alert drivers that bicyclists may be present.
 Class IV – Separated Bikeways. On-street bicycle facilities that are physically separated from motor vehicle traffic by a vertical element or barrier, such as a curb, bollards, or vehicle parking aisle. They can allow for one- or two-way travel on one or both sides of the roadway.

Based on the AT Plan Figure 4-20, Bikeway Recommendations, Arlington Avenue is designated as Class II Bike Lane and currently provides for striped bike lanes on both sides of the roadway; while Streeter Avenue and Central Avenue are designated as Class II Buffered Bike Lanes. Streeter Avenue is currently not striped as a bike lane. Central Avenue is striped for bike lanes.

Pedestrian Facilities
The implementation of enhanced pedestrian linkage with a comprehensive trails system links residential areas, schools, parks, and commercial centers so that residents can travel within the community without driving. Safe and attractive sidewalks and walkways improve the walkability of the City. Citywide, sidewalks are generally provided on both sides of the streets. Additionally, standard paved trails and non‐standard unpaved trails are frequently used by bicyclists and pedestrians in the City. Some trails are also available for equestrian riders. The existence of trails and sidewalks provides accessible facilities, provides safety features, and improves walkability in the City of Riverside. (GP 2025, p. CCM-29, CCM30). Pedestrian corridor improvements are identified in areas within the City that lack sidewalks and good pedestrian connections and that could benefit from more frequent maintenance. (PACT, p. 4-62 ).

Based on the AT Plan Figure 4-12, Pedestrian Recommendations, a linear recommendation is proposed within the Project vicinity, however not along the Project frontage.

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5.12.2 Related Regulations
Federal Regulations
No federal regulations are applicable to the Project with respect to transportation/traffic.

State Regulations
Complete Streets
In 2008, the state passed the California Complete Streets Act Assembly Bill 1358 (AB 1358), requiring circulation elements to include a “Complete Streets” approach that balances the needs of all users of the street. Complete Streets are streets designed and operated to enable safe access for all users, including pedestrians, bicyclists, motorists, and transit riders of all ages and abilities. The precise definition of a Complete Street can vary depending on the context and primary roadway users, but there are some common elements found in successful Complete Streets policies. These policies consider the needs of all users of the street in the planning, design, construction, operation, and maintenance of transportation networks. This framework allows policymakers to shift the goals, priorities, and vision of local transportation planning efforts by emphasizing a diversity of modes and users.

Senate Bill 375 - Sustainable Communities and Climate Protection Act The Sustainable Communities and Climate Protection Act, or Senate Bill 375 (SB 375), provides incentives for cities and developers to bring housing and jobs closer together and to improve public transit. The goal is to reduce the number and length of automobile commuting trips, helping to meet the statewide targets for reducing greenhouse gas emissions set by Assembly Bill 32. SB 375 requires each Metropolitan Planning Organization to add a broader vision for growth to its transportation plan through development of a Sustainable Communities Strategy (SCS). The SCS must lay out a plan to meet the region’s transportation, housing, economic, and environmental needs in a way that enables the area to lower greenhouse gas emissions. The SCS should integrate transportation, land use, and housing policies to plan for achievement of the emissions target for each region. The current sustainable community strategy for the City of Riverside is the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which is known as Connect SoCal. (SB375) In September 2020, the Southern California Association of Governments (SCAG) adopted Connect SoCal, which is a long-range visioning plan that balances future mobility and housing needs with economic, environmental, and public health goals. Connect SoCal was developed with input from local governments, county transportation commissioners, tribal governments, non-profit organizations, business, and local stakeholders within the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura. (SCAG).

Connect SoCal includes population, housing, and employment growth projections for 2045. These growth projections are used in SCAG’s transportation modeling and shape SCAG’s regional planning efforts, as outlined in Connect SoCal. Connect SoCal minimizes increases in regional traffic congestion by focusing growth, density, and land use intensity within existing urbanized area as the general land use growth pattern for the region while enhancing the existing transportation system and integrating land use into transportation planning. Connect SoCal recommends local governments accommodate future growth within existing urbanized areas to reduce VMT, congestion, and greenhouse gas emissions. (SCAG)
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Vehicle Miles Traveled
Senate Bill 743 (SB 743) was signed into law on September 27, 2013, and went into effect January 2014, seeking to balance the needs of congestion management, infill development, public health, greenhouse gas reductions, and other goals. The Governor’s Office of Planning and Research (OPR) was directed to develop new criteria for determining significance of transportation impacts and define alternative metrics to traffic Level of Service (LOS) under CEQA. Specifically, SB 743 mandates that lead agencies can no longer use automobile delay – commonly known as LOS – as a method for conducting transportation analysis under CEQA. In December 2018, OPR released the Technical Advisory on Evaluating Transportation Impacts in CEQA, which set forth guidelines for the use of a broader measure called Vehicle Miles Traveled (VMT). VMT measures the total amount of driving over a given distance and is intended to better align transportation analysis with the State's Greenhouse Gas reduction goals. These changes became mandatory on July 1, 2020, and lead agencies are now required to analyze transportation impacts under VMT, not LOS.

Congestion Management Program
The Congestion Management Program (CMP) was first established in 1990 under Proposition 111.

Proposition 111 established a process for each metropolitan county in California to designate a Congestion Management Agency (CMA) that would be responsible for development and implementation of the CMP within county boundaries. The intent of the CMP is to more directly link land use, transportation, and air quality, thereby prompting reasonable growth management programs that will effectively utilize new transportation funds, alleviate traffic congestion and related impacts, and improve air quality. Counties within California have developed CMPs with varying methods and strategies to meet the intent of the CMP legislation. The Riverside County Transportation Commission (RCTC) was designated as the CMA in 1990, and therefore, prepares the CMP updates in consultation with the Technical Advisory Committee (TAC), which consists of local agencies, the County of Riverside, transit agencies, and subregional agencies. (CMP)
Regional Regulations
County of Riverside Congestion Management Program
RCTC is designated as the CMA to oversee the CMP. Urbanized areas such as Riverside County are required by State law to adopt a CMP. The goals of the CMP are to reduce traffic congestion and to provide a mechanism for coordinating land use development and transportation improvement decisions.

Local agencies are required to establish minimum level of service (LOS) thresholds in their general plans and conduct traffic impact assessments on individual development projects. Deficiency plans must be prepared when a development project would cause LOS "F" on non-exempt CMP roadway segments.

Western Riverside County Transportation Uniform Mitigation Fee In 2002, the jurisdictions of western Riverside County (including the City), agreed to participate in the Western Riverside County Transportation Uniform Mitigation Fee (TUMF) program. TUMF is a multijurisdictional impact fee program administered by the Western Riverside Council of Governments (WRCOG) that funds transportation improvements on a regional and sub-regional basis associated with new growth. All new development in each of the participating jurisdictions is subject to TUMF, based on the proposed intensity and type of development. (GP 2025, p. CCM-6).

TUMF fees are collected by the City from project applicants and are passed on to WRCOG as the ultimate program administrator. TUMF funds are distributed on a formula basis to the regional, local, and transit components of the program. Of the TUMF funds received by WRCOG, 3.13 percent is allocated to RTA for making regional transit improvements, 45.7 percent is allocated to RCTC for programming City of Riverside Sections 5.12
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improvements to the arterials of regional significance on the Regional System of Highways and Arterials,

1.47 percent is allocated to the Western Riverside County Regional Conservation Authority (RCA) to purchase habitat for the Multiple Species Habitat Conservation Plan (MSHCP), and 45.7 percent is allocated to the five zones for programming improvements to the Regional System of Highways and Arterials (RSHA) as determined by the respective zone committees. (WRCOG, p. 6).

The City participated in the preparation of the Western Riverside County Transportation Uniform Fee Nexus Study (dated October 18, 2002) and adopted TUMF fees based on that study. The City also participated in the preparation of an updated nexus study titled Transportation Uniform Mitigation Fee Nexus Study:
2009 Update and Transportation Uniform Mitigation Fee Nexus Study: 2016 Update (2016 Nexus Study).

The City adopted the 2016 Nexus Study and its findings trough the approval of Ordinance 7393 §1. Fees owed to TUMF by the Project proponent will be based on the current fees when the certificate of occupancy is issued.

Measure A (Riverside County Half-Cent Sales Tax)
In November 1988, Riverside County voters approved Measure A, a one-half cent increase in sales tax over a 20-year period to be used for transportation purposes. Measure A included a “return to source” concept, which requires the additional sales tax revenue generated in a specific geographic area to be used to finance projects within that same area. In November 2002, Riverside County voters approved a 30-year extension of Measure “A” (2009-2039). Measure A funds go back to each of three geographic areas within Riverside County - Western Riverside County, Coachella Valley, and Palo Verde Valley - in proportion to the sales taxes they contribute. Each of the three geographic areas has its own transportation program.

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project as identified below (GP 2025, pp. CCM-15 - CCM-18; CCM-22; CCM-27 – CCM-28; CCM-35 – CCM-36).

Circulation Mobility Element
Objective CCM-2 Build and maintain a transportation system that combines a mix of transportation modes and transportation system management techniques, and that is designed to meet the needs of Riverside’s residents and businesses, while minimizing the transportation system’s impacts on air quality, the environment and adjacent development.

Policy CCM-2.2 Balance the need for free traffic flow with economic realities and environmental and aesthetic considerations, such that streets are designed to handle normal traffic flows with tolerances to allow for potential short-term delays at peak-flow hours.

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

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

Objective CCM-3 Design the Magnolia Avenue/Market Street Corridor as a transit- and pedestrian-oriented Mixed-Use boulevard.

Policy CCM-3.2 Consider the implementation of off-street shared parking with parking signage improvements, consolidation of driveways, installation of raised landscaped medians, bus turnouts, traffic signal enhancements, special pavement treatments at pedestrian crossings and intersections, curb extensions, signalized/enhanced crosswalks, wider sidewalks, and other appropriate measures which enhance traffic flow, transit efficiency and pedestrian movements.

Objective CCM-6 Cooperate in the implementation of regional and inter-jurisdictional transportation plans and improvements to the regional transportation system.

Policy CCM-6.1 Encourage the reduction of vehicle miles, reduce the total number of daily peak hour vehicular trips, increase the vehicle occupancy rate, and provide better utilization of the circulation system through the development and implementation of TDM programs contained in the SCAQMD and County of Riverside TDM Guidelines.

Objective CCM-9 Promote and support an efficient public multi-modal transportation network that connects activity centers in Riverside to each other and to the region.

Policy CCM-9.1 Encourage increased use of public transportation and multi-modal transportation as means of reducing roadway congestion, air pollution and nonpoint source water pollution, through such techniques as directing new growth along transportation corridors.

Policy CCM-9.6 Enhance and encourage the provision of attractive and appropriate transit amenities, including shaded bus stops, to facilitate use of public transportation, through the development process by incorporating the necessary design features as appropriate.

Objective CCM-10 Provide an extensive and regionally linked public bicycle, pedestrian, and equestrian trails system.

Policy CCM-10.3 Provide properly designed pedestrian facilities for the disabled and senior population to ensure their safety and enhanced mobility as users of streets, roads and highways emphasizing “complete streets” principles.

Policy CCM-10.6 Encourage pedestrian travel through the creation of sidewalks and street crossings.

Policy CCM-10.12 Encourage bicycling as a commute mode to school, work, etc.

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Objective CCM-12 Facilitate goods movement as a means of economic expansion, while protecting residents and visitors from the negative effects typically associated with truck operations and rail service.

Policy CCM 12.2 Ensure that new development projects provide adequate truck loading and unloading facilities.

Objective CCM-13 Ensure that adequate on- and off-street parking is provided throughout Riverside.

Policy CCM-13.1 Ensure that new development provides adequate parking.

City of Riverside 2025 General Plan EIR
There are no applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to traffic and circulation.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Traffic and Transportation.

City of Riverside Municipal Code
The following chapter of the City’s Municipal Code are applicable and pertain to traffic and transportation:

Chapter 16.64 – Traffic Signal and Railroad Signal Mitigation Fees and Transportation Impact Fees. The City Council hereby finds and determines that new private development in the City of Riverside increases the amount of traffic utilizing the City street system thereby requiring the installation of additional traffic signals, railroad signals including crossing gates and associated work, and street improvements at specified locations to increase or improve transportation capacity, in order to protect the public health, safety and welfare and that such private new development should pay its fair share of such improvements
This local development impact fee (DIF) is comprised of two fees: First, it is to provide for the imposition of fees on each new nonresidential unit, residential dwelling unit and mobile home space, which fees are to be placed in a specially-designed fund to be utilized for the purchase and installation of traffic signals and railroad signals including crossing gates and other protective devices and all costs associated with railroad crossing protection. Secondly, it is to provide for the imposition of fees on each new residential dwelling unit and mobile home space, which fees are to be placed in a specially-designated fund to be utilized for improvements to streets as designated by the City Council in order to increase or improve the carrying capacity of such streets to solve current and proposed traffic congestion.

Chapter 16.68 – Traffic Signal and Railroad Signal Mitigation Fees and Transportation Impact Fees. The purpose of this chapter is to establish TUMF to fund certain improvements to the Regional System as identified in the Riverside County 2016 Nexus Study. Fees are required to be paid at the time a certificate of occupancy is issued for a Development Project or upon final inspection, whichever comes first. The fees are calculated according to fee schedule set forth in this chapter and the Section 5.12 City of Riverside
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calculation methodology set forth in the Fee Calculation Handbook adopted July 14, 2003, as amended from time to time.

Neighborhood Traffic Management Program
As traffic volumes and congestion have increased on the major regional roadways, drivers looking to reduce their travel times begin to look at alternative routes using the local street system to avoid problem areas. This neighborhood intrusion by “cut-through” traffic has become a growing concern for some residential areas. The City has an active Neighborhood Traffic Management Program to minimize and/or prevent intrusion of regional cut-through traffic into residential neighborhoods through traffic management and traffic calming strategies, and to improve the livability of neighborhoods through controlling the impacts of outside traffic. The strategies include speed control methods, parking restrictions, speed humps, pedestrian safety improvements, and sight obstruction elimination. (GP 2025, p. CCM-22).

5.12.3 Comments Received in Response to the Notice of Preparation Two comment letters were received related to Traffic and Transportation in response to the Notice of Preparation (NOP). The comment letters were received from Beverly Phillips and the Inland Empire Biking Alliance and are included in Appendix A of this Draft EIR.

5.12.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the Thresholds of Significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A) prepared for this Project, and as outlined in Section 4.0 of this DEIR, implementation of the proposed Project will have a less than significant impacts in the following areas and these topics are not addressed in this DEIR:
 Substantially increase hazards due to a geometric design feature (e.g., share curves or dangerous intersections) or incompatible uses (e.g., farm equipment); and  Result in inadequate emergency access.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; and  Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

5.12.5 Project Design Features
The proposed Project site will leave in place four of the six existing full access driveways: two along Arlington Avenue and two along Streeter Avenue. Primary site access for the residential area will be from Streeter Avenue with secondary access from Arlington Avenue. Primary access for the commercial area will be from Arlington Avenue with secondary access from Streeter Avenue. The following lists the proposed improvements and is reflected in Figure 3.0-31 in Section 3.0 – Project Description of this Draft EIR:

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Driveway and Roadways
 Driveway #1 - Streeter Avenue and Granada Avenue Intersection o Install a stop control on the westbound approach (the Project driveway) and construct a westbound shared left-through-right turn lane.
 Driveway #2 - Streeter Avenue and El Molino Avenue Intersection o Install a stop control on the westbound approach (the Project driveway) and construct a westbound shared left-through-right turn lane and modify the existing median to provide 225-feet of storage for the southbound left turn lane.
 Driveway #3 - California Avenue and Arlington Avenue Intersection o Install a stop control on the southbound approach (the Project driveway), construct a southbound right turn lane and construct a westbound right turn lane.  Driveway #4 - Along Arlington Avenue
o Construct a shared left-through-right turn lane on the southbound approach (the Project driveway), construct a westbound right turn lane, improve the existing traffic signal infrastructure with Audible Push Buttons, install a new traffic signal pole on the north leg, widen Project driveway (north leg of intersection), relocate the existing traffic signal pole located on the north leg to accommodate new drive aisle width and sidewalk/curb-andgutter locations, and modify existing raised median to provide 150-foot eastbound left turn pocket.
 Streeter Avenue and Arlington Avenue Intersection
o Improve the existing traffic signal infrastructure with Audible Push Buttons, cut back medians on the north, east, and west legs to allow for a clear travel path for pedestrians at all approaches and purchase a new traffic signal controller for this intersection.  Streeter Avenue from southern Project boundary to northern Project boundary o Improve curb and gutter, sidewalk, and landscaping as necessary for site access and consistent with City standards.
 Arlington Avenue from western Project boundary to eastern Project boundary o Dedicate 5-feet of pavement from the existing curb-and gutter (60-feet from centerline to edge of ROW) on Arlington Avenue and improve curb and gutter, sidewalk, and landscaping as necessary for site access and consistent with City standards.  California Avenue, Streeter Avenue, and Arlington Avenue o Modify the traffic signal to implement a 130-second cycle.

Bikeways
 Streeter Avenue
o From Central Avenue to Arlington – stripe a Class II bike lane. o Streeter Avenue/Granada Avenue Intersection – stripe a northbound and southbound Class II bike lane on the east and west sides of Streeter Avenue. o Streeter Avenue/Sierra Street South – stripe a northbound and southbound Class II bike lane on the east and west sides of Streeter Avenue.
o Streeter Avenue/Sierra Street North – stripe a northbound and southbound Class II bike lane on the east and west sides of Streeter Avenue.

5.12.6 Methodology
The analysis herein is based in part on the Traffic Impact Analysis (TIA) and Vehicle Miles Traveled Screening Memorandum (VMT Memo). Both studies were prepared consistent with the requirements of Section 5.12 City of Riverside
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SB 743 and the City of Riverside’s Public Works Department Traffic Impact Analysis (TIA) Guidelines for Vehicle Miles Traveled (VMT) and Level of Service (LOS) Assessment (dated July 2020). (TIA).

CEQA Guidelines Section 15064.3 requires that the determination of significance for transportation impacts be based on VMT instead of a congestion metric such as LOS. The change in the focus of transportation analysis is the result of SB 743, as outlined in Section 5.12.2 - Related Regulations, above. Thus, the analysis below does not consider LOS within the impact determination.

Traffic Impact Analysis
A traffic scoping package was provided for review by City staff prior to preparation of the TIA and provided an outline of the Project study area, trip generation, trip distribution, and analysis methodology.

The TIA was prepared to evaluate the mix of land uses proposed by the Project to determine potential for traffic related impacts and improvements required by the Project. The following specifications were evaluated: 388 multifamily residential dwelling units, 21,000 square feet of grocery store and a standalone 5,000 square foot multi-tenant building. Trips generated by the Project’s proposed land uses have been estimated based on trip generation rates collected by the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition, 2021. The TIA evaluated how the proposed transportation network improvement and GP goals and policies would serve to improve transportation conditions under project buildout. (URBAN, p. 1).

Study Area
Table 5.12-A, Study Area Intersections identifies the location of the study area intersections analyzed by the TIA. All intersections are located within the jurisdiction of the City and none are CMP facilities.

The Project study area and corresponding intersection identification is reflected in Figure 5.12-2, Project Study Area.

Project Study Area
Intersection ID Location
1 Streeter Avenue and Central Avenue
2 Streeter Avenue and Sierra Street North
3 Streeter Avenue and Sierra Street South
4 Driveway #1Streeter Avenue and Granada Avenue
5 Driveway #2 Streeter Avenue and El Molino Avenue
6 Streeter Avenue and Arlington Avenue
7 Driveway #3 California Avenue and Arlington Avenue
8 Driveway #4 and Arlington Avenue
9 Madison Street/Palomar Way and Arlington Avenue
Source: URBAN, Table 1-1: Intersection Analysis Locations 2 Section 5.12 City of Riverside
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Trip Distribution
The Project trip distribution represents the directional orientation of traffic to and from the Project site.

Trip distribution is the process of identifying the probable destinations, directions or traffic routes that will be utilized by Project traffic. The potential interaction between the planned land uses and surrounding regional access routes are considered to identify the route where the Project traffic would distribute. The Project trip distribution was developed based on anticipated travel patterns to and from the Project site and are consistent with other similar projects that have been reviewed and approved by City of Riverside staff. The proposed Project trip distribution is reflected in Figure 5.12-3, Project (Retail) Trip Distribution and 5.12-4, Project (Residential) Trip Distribution. Each of these distribution patterns was reviewed and approved by the City of Riverside as part of the traffic study scoping process. (URBAN, p. 33).

Traffic Projections
Future year traffic forecasts have been accounted for, for the proposed Project’s anticipated opening year of 2028. The total ambient growth for 2028 conditions is 12.62 percent based upon background (ambient) growth at 2.0 percent per year, compounded over 6 years. The ambient growth factor is intended to approximate regional traffic growth. This ambient growth rate is added to existing traffic volumes to account for area-wide growth not reflected by cumulative development projects. Ambient growth has been added to daily and peak hour traffic volumes on surrounding roadways, in addition to traffic generated by the development of future projects that have been approved but not yet built and/or for which development applications have been filed and are under consideration by governing agencies.

The traffic generated by the proposed Project was manually added to the base volume to determine Opening Year Cumulative “With Project” forecast conditions. To provide the most conservative analysis, traffic generated by other known or probable related projects was added to the estimated area ambient traffic growth. These related projects are at least in part already accounted for in the assumed ambient growth rates; and some of these related projects may not be implemented and operational within the 2028 Opening Year time frame assumed for the Project.

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Vehicle Miles Traveled
The VMT Memo was prepared to analyze the Project’s potential effect on and ability to reduce VMT.

The City’s Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment (2020) include the following criteria to screen for projects that are presumed to have a less-thansignificant effect on VMT and were used in the analysis discussion below to determine CEQA impacts:

1. Transit Priority Area (TPA) Screening
Projects located with a TPA may be presumed to have a less than significant impact absent substantial evidence to the contrary. This presumption may NOT be appropriate if the project:
a) Has a Floor Area Ratio (FAR) of less than 0.75;
b) Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); c) Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the City), with input from the Metropolitan Planning Organization); or d) Replaces affordable residential units with a smaller number of moderate- or high-income residential units.

A TPA is defined as a half mile area around an existing major transit stop or an existing stop along a high quality transit corridor per the definitions below.  Pub. Resources Code, § 21064.3 - 'Major transit stop' means a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.  Pub. Resources Code, § 21155 - For purposes of this section, a 'high-quality transit corridor' means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.

2. Low VMT Area Screening
Residential and office projects located within a low VMT-generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary. In addition, other employment-related and mixed-use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident or per worker that is similar to the existing land uses in the low VMT area—provided the VMT of the area falls below thresholds.

For this screening in the WRCOG area, the Riverside County Transportation Model (RIVCOM) travel forecasting model was used to measure VMT performance for individual jurisdictions and for individual traffic analysis zones (TAZs). TAZs are geographic polygons similar to Census block groups used to represent areas of homogenous travel behavior. Daily VMT per capita was estimated for each TAZ. This presumption may not be appropriate if the project land uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips.

3. Project Type Screening
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improves the convenience of shopping close to home and has the effect of reducing vehicle travel.

4. Mixed-Use Projects
To identify if the proposed project requires a VMT analysis, the City of Riverside may evaluate each component of a mixed-use project independently and apply the significance threshold for each project type included (e.g. residential and retail).

5. Redevelopment Projects
Where a project replaces existing VMT generating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to less than significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds described above should apply.

5.12.7 Environmental Impacts
Threshold : Would the Project conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Public transit, bicycles, and pedestrian facilities
The City’s 2025 General Plan - Circulation and Community Mobility Element introduces and implements various strategies and approaches to accommodate, improve, enhance, and maintain multiple modes of travel (vehicular and non-vehicular) throughout the City. Mode choice is influenced by sidewalk connectivity and proximity of buildings, bike accommodations, transit stop density and service characteristics, and availability of interconnected low speed routes. Non-vehicular transportation includes pedestrians (sidewalks), bicycles (on-road lanes or off-road paths), bus transit, and train transit.

The City’s 2025 GP Objective CCM-2 promotes and supports modes of transportation that offer an alternative to single-occupancy automobile use and help reduce air pollution and road congestion.

Emphasizing non-vehicular transportation is a key element of SB 375 and SCAG’s Regional Transportation Plan/Sustainable Community Strategy (RTP/SCS). (GP 2025, p. CCM-15).

Although there are no current or proposed trails near the Project Site, there are existing sidewalks adjacent to the Project site, along both Arlington Avenue and Streeter Avenue. Pedestrian circulation within the Project site is reflected in Figure 3.0-32 in Section 3.0 – Project Description of this Draft EIR.

The Project will provide several pedestrian pathways to facilitate the movement of pedestrians within the site. These pathways will be lit to ensure security. The Project site will also provide pedestrian linkage to the surrounding area by providing connection to sidewalks along Streeter Avenue and Arlington Avenue.

The Project will remove the existing sidewalks to incorporate a landscape buffer between the roadway and sidewalks. The sidewalks will continue to connect to the existing sidewalks in the area and continue to provide pedestrian linkage beyond the boundaries of the Project site. As such the Project would facilitate and would not obstruct City goals and policies to provide efficient and safe pedestrian access and no impacts to pedestrian facilities would occur.

As part of the City’s Bikeway Network, Class II bike lanes exist along Arlington Avenue which connect to the Magnolia/Market Corridor. The PACT Plan designates Streeter Avenue as a Class II Buffered Bike Lane, however it is not currently striped as such. The Project will stripe Class II bike lane on the east and west sides of Streeter Avenue, as identified in Section 5.12.5 – Project Design Features, above.

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With respect to bicycle and pedestrian safety, the Project is required to comply with all design guidelines and regulations to ensure facilities meet City’s current standards. The City has prepared a 2022 Local Roadway Safety Plan (LRSP). The goal of the City and their safety partners through the LRSP, is to provide safe, sustainable, and efficient mobility choices for their residents and visitors. Through the development and implementation of the LRSP, the City continues its collaboration with safety partners to identify and discuss safety issues within the community and the LRSP identifies a framework to identify, analyze, and develop traffic safety enhancements on the City’s roadway network. (LRSP, pp.

ES-7, 1). The Project will incorporate all bike lane improvements outlined in Section 5.12.5 – Project Design Features above, in accordance with all City standards.

As mentioned in Section 5.12.1 – Setting the Project is currently served by the RTA. Bus Route 12 and Bus Route 15 that travel along Streeter Avenue and Arlington Avenue, respectively, in the Project area.

The nearest bus stops and shelters are located on Arlington Avenue and Streeter Avenue. The shelter along Arlington Avenue is situated in front of the location of the proposed ALDI. The bus shelter along Streeter Avenue is along the easterly side of Streeter near Streeter Avenue/ Arlington Avenue. The existing bus services would continue to serve the Project site and the future residents and retail patrons would have convenient access to transit. Furthermore, it should be noted that Route 15 provides connections to both the Riverside‐Downtown Metrolink Station and the La Sierra Metrolink Station which allows for connections to adjacent communities. The proposed Project would not alter or conflict with existing bus stops and schedules, and impacts related to RTA transit services would not occur.

Vehicular Circulation
The City’s 2025 GP Policy CCM-2.3 requires Arterial Streets to maintain an LOS D or better. This policy also provides that at key locations, such as City Arterials that are used by regional freeway bypass traffic and at heavily traveled freeway interchanges, an LOS E at peak hours is acceptable on a case-by-case basis. The Project TIA provided a conservative trip generation analysis by evaluating a worst-case scenario by utilizing a slightly higher commercial square footage than proposed by the Project. The TIA calculated existing trip generation counts as if the Project site were not vacant and still being utilized as its previous use Under the existing land use, a total of 4,698 vehicular trips with 119 AM peak hour trips and 400 PM peak hour trips would result. Since the site has been vacant since approximately 2020, no trip credits were taken into account as part of this calculation. The proposed Project is estimated to generate 3,372 two-way trip-ends per day on a typical weekday with 229 AM peak hour trips and 284 PM peak hour trips; 1,326 fewer trips than the previous use.(URBAN, p. 1) In 2013, the State of California passed Senate Bill (SB) 743, which mandates that lead agencies can no longer use automobile delay, commonly known as Level of Service (LOS), as a method for conducting transportation analysis under CEQA. The State later issued guidelines for the use of a broader measure called Vehicle Miles Traveled (VMT), which measures the total amount of driving over a given distance and is intended to better align transportation analysis with the State's Greenhouse Gas reduction goals.

These changes became mandatory on July 1, 2020, and lead agencies are now required to analyze transportation impacts under VMT, not LOS. Therefore, the LOS data and the relationship of the Project’s effect on LOS with General Plan goals concerning LOS are reported for informational purposes and utilized by the City in considering General Plan consistency, but are not used to gauge environmental impacts in this Draft EIR.

As reflected in Table 5.12-B, Level of Service (LOS) - Existing and Existing Plus Project (Opening Year 2028) below, with incorporation of improvements listed in Section 5.12.5 – Project Design Features, the proposed Project is not anticipated to result in new LOS deficiencies(URBAN, p. 50).

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Level of Service (LOS) – Existing and Existing Plus Project (Opening Year 2028)
ID/Intersection Existing Opening Year
Without Project
Opening Year
With Project

AM PM AM PM AM PM

1. Streeter Avenue and Central Avenue C C D C D C

2. Streeter Avenue and Sierra Street North A A A A A A

3. Streeter Avenue and Sierra Street South B B B B B B

4. Driveway #1Streeter Avenue and Granada
Avenue B B C B C C

5. Driveway #2 Streeter Avenue and El Molino
Avenue C B C C C C

6. Streeter Avenue and Arlington Avenue C C D D D D

7. Driveway #3 California Avenue and Arlington
Avenue C C D C D C

8. Driveway #4 and Arlington Avenue B B B B B B

9. Madison Street/Palomar Way and Arlington
Avenue B B B B C B
Source: URBAN, Table 3-1, Table 5-1
Further, the proposed Project will be required to install traffic signing and striping in accordance with California Manual on Uniform Traffic Control Devices in conjunction with detailed Project construction plans. Sight distance at each access point will be required to be reviewed with respect to standard CalTrans and City of Riverside sight distance standards at the time of preparation of final grading, landscape, and street improvement plans.

With incorporation of the Project’s proposed improvements (PDFs), implementation of the recommended optimizing signal phasing improvements, payment of City Developer Impact Fees (DIF), and payment of regional County Traffic Uniform Mitigation Fee (TUMF)to offset traffic related deficiencies, all intersections are expected to operate at a satisfactory LOS. As such, the Project complies with General Plan policies as they relate to LOS. No additional improvements are required.

Program Plans
Congestion Management Program (CMP) and the Long-Range Transportation Study (LRTS) The CMP is a component of the RCTC’s Long Range Transportation Study (LRTS), the first countywide long range transportation study that identifies and evaluates highway, major roadway, and transit projects throughout the Riverside County region. The LRTS identified four roadway improvement projects within the City of Riverside to reduce traffic congestion:
the Main Street and 60 Interchange project;
the Tyler Street and 91 Interchange project;
the Adams Street and 91 Interchange project; and
the Arlington Avenue from Magnolia Avenue to Alessandro Boulevard project. (LRTS, Appendix A)
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The proposed Project would not affect the ability of these improvement projects in the City to be constructed. The Project would ultimately benefit from these roadway improvement projects identified in the CMP. Hence, the Project would not conflict with the RCTC’s CMP.

Connect SoCal
As discussed in Section 6.0 – Consistency with Regional Plans, the Plan is consistent with the goals of Connect SoCal. Hence, the Project would not conflict with this program plan.

Thus, because the proposed Project’s vehicular and non-vehicular network will be designed and constructed in compliance will all applicable regulations, will implement PDFs and improvements consistent with City requirements, and is consistent will GP policies and all applicable program plans, the Project will not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Therefore, impacts would be less than significant.

Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
The VMT memo utilized the five screening criteria outlined in the City’s TIA Guidelines for VMT and LOS Assessment to determine the Projects impact.

1. Based on WRCOG tool, the Project is located within traffic analysis zone (TAZ) 2022 which is located within a designated TPA. While the Project is located in a TPA, provides no more parking than is required, does not replace affordable housing, and will be required to comply with the SCS, it also has a proposed floor to area ratio (FAR) of 0.6, which is less than 0.75. Thus, this criterion is not met.

2. Based on WRCOG tool, the Project is located the Project is located within TAZ 2022 which is located within a low VMT generating area. Therefore, this criterion is met.

3. The residential portion of the project would not be considered local-serving due to its size (over 16 townhomes). However, based on the square footage of the proposed commercial area and its potential to serve the local community, it is considered local serving. Thus, the Project meets the criterion through the proposed retail.

4. Per the City’s guidelines, the Project is analyzed separately for residential and retail portions for Criterion 2 and Criterion 3.

5. While the project is proposing to replace the existing Sears store, due to its land use and size, it is not expected to generate less VMT than the previous use so the criterion is not met.

In accordance with the City of Riverside Guidelines screening criteria, the proposed Project is presumed to have a less than significant transportation impact and is screened out from further VMT analysis based on the Project being within a low VMT-generating area. Further, the retail portion of the Project meets the criteria for screening from further VMT analysis because it is under 50,000 square feet so is considered a local-serving project. (WEBB-C, p. 3, 4).

Thus, because the Project is considered to be within a low VMT-generating area and considered a localserving project, it is consistent with CEQA Guidelines Section 15064.3, subdivision (b). Therefore, impacts would be less than significant.

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5.12.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). There are no mitigation measures required to reduce impacts to since less than significant impacts to transportation are anticipated from implementation of the Project. Therefore, no mitigation measures are required.

5.12.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
The Project does not result in any significant impact to transportation, and no mitigation is required.

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5.13 Tribal Cultural Resources
The focus of this section is to analyze potential impacts related to tribal cultural resources. The following discussion addresses the potential for adverse impacts that could result from the construction and operation as a result of the Project. Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics.

Cultural resources include places, objects, and settlements that reflect group or individual religious, archaeological, architectural, or paleontological activities. By statute, “tribal cultural resources,” are generally described as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe and are further defined in PRC Section 21074(a)(1)(A)–(B). Tribal cultural resources are generally described as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe and are further defined in PRC Section 21074(a)(1)(A)–(B).

The Project was analyzed for cultural resources in the Cultural Resources Technical Report for 5261 Arlington Avenue, Riverside, California, prepared by Dudek dated May 2023 (DUDEK-A). A Supplemental CHRIS Records Search Results was prepared by Dudek dated October 2023 (DUDEK-B) which includes the off-site utility line. The Project in its entirety (including one parcel and offsite improvement areas) is referred to as “Project site”, whereas reference to the one parcel (APN 226-180-015) referred to as “Project parcel”. (DUDEK-A, p.3). These reports are attached as Appendix C of this Draft EIR.

5.13.1 Setting
The Project is located in a fully developed area surrounded by residential and commercial businesses within the City of Riverside, California.

Ethnographic Setting
The history of the Native American communities prior to the mid-1700s largely relies on later missionperiod and early ethnographic accounts. The first records of the Native American inhabitants of the region come predominantly from European merchants, missionaries, military personnel, and explorers.

Based on ethnographic information, it is believed that at least 88 different languages were spoken from Baja California Sur to the southern Oregon state border at the time of Spanish contact. The distribution of recorded Native American languages has been dispersed as a geographic mosaic across California through six primary language families. The tribes of this area have traditionally spoken Takic languages that may be assigned to the larger Uto–Aztecan family. These groups include the Gabrielino, Cahuilla, and Serrano. Based on the amount of internal diversity within these language-speaking communities it is believed to reflect a time depth of approximately 2,000 years. Other researchers have contended that Takic may have diverged from Uto–Aztecan ca. 2600 BC–AD 1, which was later followed by the diversification within the Takic speaking tribes, occurring approximately 1500 BC–AD 1000 (DUDEK-A, pp. 43-44).

Gabrielino (Gabrieleño)/Tongva)
The archaeological record indicates that the Gabrielino arrived in the Los Angeles Basin around 500 B.C.

Surrounding native groups included the Chumash and Tataviam to the northwest, the Serrano and Cahuilla to the northeast, and the Juaneño and Luiseño to the southeast. While names by which Native Americans identified themselves have be lost and replaced by Spanish people from local Missions. The Section 5.13 City of Riverside
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name “Gabrielino” was first established by the Spanish from the San Gabriel Mission and included people from the established Gabrielino area as well as other social groups. (DUDEK-A, p. 44).

The Tongva established large, permanent villages along rivers and streams, and lived in sheltered areas along the coast. Tongva lands included the greater Los Angeles Basin and three Channel Islands, San Clemente, San Nicolas, and Santa Catalina and stretched from the foothills of the San Gabriel Mountains to the Pacific Ocean. The tribal population has been estimated to be at least 5,000, but recent Ethnohistoric work suggests a much larger population of about 10,000. Archaeological sites composed of villages with various sized structures have been identified through the Los Angeles Basin. The largest, and best documented, ethnographic Tongva village in the Gabrieleño territory was likely that of Yanga which was in the vicinity of downtown Los Angeles. (DUDEK-A, pp. 44-45).

The Tongva subsistence economy was centered on gathering and hunting. The surrounding environment was rich and varied, and the tribe exploited mountains, foothills, valleys, deserts, riparian, estuarine, and open and rocky coastal eco-niches. Like that of most native Californians, acorns were the staple food.

Acorns were supplemented by the roots, leaves, seeds, and fruits of a wide variety of flora (e.g., islay, cactus, yucca, sages, and agave). Fresh water and saltwater fish, shellfish, birds, reptiles, and insects, as well as large and small mammals, were also consumed. (DUDEK-A, p. 45).

Tools and implements used by the Tongva to gather and collect food resources included the bow and arrow, traps, nets, blinds, throwing sticks and slings, spears, harpoons, and hooks. Trade between the mainland and the Channel Islands Groups was conducted using plank canoes as well as tule balsa canoes. These canoes were also used for general fishing and travel. The collected food resources were processed food with hammerstones and anvils, mortars and pestles, manos and metates, strainers, leaching baskets and bowls, knives, bone saws, and wooden drying racks. Catalina Island steatite was used to make ollas and cooking vessels. (DUDEK-A, p. 45).

Cahuilla
The name “Cahuilla” is possibly derived from a native word meaning “master, boss”. It is believed that the Cahuilla migrated to southern California about 2,000 to 3,000 years ago, most likely from southern Sierra Nevada ranges of east–central California with other related socio-linguistic groups (i.e. the Takic speakers). The Cahuilla then settled in a territory that extended west to east from the present-day City of Riverside to the central portion of the Salton Sea in the Colorado Desert, and south to north from Lake Elsinore to the San Bernardino Mountains. While 60 percent of Cahuilla territory was located in the Lower Sonoran Desert environment, 75 percent of their diet from plant resources was acquired in the Upper Sonoran and Transition environmental zones. (DUDEK-A, p. 46).

The Cahuilla had three primary levels of socio-political organization. The highest level was the cultural nationality, encompassing everyone speaking a common language. Next were the two patrimoieties of the Wildcats (tuktum) and the Coyotes (‘istam). Every clan of the Cahuilla fell into one or the other of these moieties. The third basic level consisted of the numerous political–ritual–corporate units called sibs, or patrilineal clans. (DUDEK-A, p. 46).

Cahuilla villages were usually located in canyons or on alluvial fans near a source of accessible water, such as springs or where large wells could be dug. A wide variety of tools and implements were employed by the Cahuilla to gather and collect food resources. For the hunt, these included the bow and arrow, traps, nets, slings and blinds for hunting land mammals and birds, and nets for fish in Holoceneepoch Lake Cahuilla. Rabbits and hares were commonly taken with the throwing stick, but communal hunts for these animals utilized tremendously large nets and clubs for mass-capture. Foods were City of Riverside Sections 5.13
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processed with a variety of tools, including portable stone mortars, bedrock mortars and pestles, basket hopper mortars, manos and metates, bedrock grinding slicks, hammerstones and anvils, woven strainers and winnowers, leaching baskets and bowls, woven parching trays, knives, bone saws, and wooden drying racks. Food was consumed from a number of woven and carved wood vessels and pottery vessels. The ground meal and unprocessed hard seeds were stored in large finely woven baskets, and the unprocessed mesquite beans were stored in large granaries woven of willow branches and raised off the ground on platforms to keep it from vermin. Pottery vessels were made by the Cahuilla, and also traded from the Yuman-speaking groups across the Colorado River and to the south. (DUDEK-A, p. 46).

5.13.2 Related Regulations
Federal Regulations
National Historic Preservation Act
The National Historic Preservation Act of 1966 (NHPA) (54 U.S.C. 300101 et seq.) is legislation intended to preserve historical and archaeological sites in the United States of America. The act created the National Register of Historic Places, the list of National Historic Landmarks, and the State Historic Preservation Offices (SHPO). Among other things, the act requires federal agencies to evaluate the impact of all federally funded or permitted projects on historic properties (buildings, archaeological sites, etc.) through a process known as “Section 106 Review.” (NPS-A).

National Register of Historic Places
Developed in 1981 pursuant to Title 36 CFR Section 60, the NRHP provides an authoritative guide to be used by federal, state, and local governments, private groups, and citizens to identify the nation’s cultural resources and to indicate what properties should be considered for protection from destruction or impairment. It should be noted that the listing of a private property on the NRHP does not prohibit any actions which may otherwise be taken by the property owner with respect to the property. The listing of sites in California to the National Register is initiated through an application submitted to the State Office of Historical Preservation. Applications deemed suitable for potential consideration are handled by the State Historic Preservation Officer. All NRHP listings for sites in California are also automatically added to the California Register of Historical Resources by the State of California. The listing of a site on the NRHP does not generally result in any specific physical protection. Among other things, however, it does create an additional level of CEQA (and NEPA, the National Environmental Protection Act) review to be satisfied prior to the approval of any discretionary action occurring that might adversely affect the resource. (NPS-B).

American Indian Religious Freedom Act
This American Indian Religious Freedom Act became law in 1978 (Public Law 95-341, 42 USC 1996) in order to protect and preserve for American Indians their inherent right of freedom to believe, express and exercise their traditional religions. These religious rights extend to, but are not limited to, access to sites, use and possession of sacred objects and the freedom to worship through ceremonials and traditional rites. Under this regulation, federal agencies and departments are charged with evaluating their policies and procedures in consultation with native traditional religious leaders in order to eliminate interference with the free exercise of native religion. Agencies must determine and make appropriate changes necessary to protect and preserve Native American religious cultural rights and practices, and to accommodate access to and use of religious sites “to the extent that the use is practicable and not inconsistent with an agency’s essential functions.” The intent is to protect Native Americans’ First Amendment right to “free exercise” of religion. (AIRFA).

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Native American Graves Protection and Repatriation Act
Enacted in 1990 under Title 25 U.S. Section 3001, the Native American Graves Protection and Repatriation Act (NAGPRA) describes the rights of Native American lineal descendants, Indian Tribes, and Native Hawaiian organizations with respect to treatment, repatriation, and disposition of Native American cultural items for which they can show a relationship of lineal descent or cultural affiliation. The statute also requires federal agencies and museums receiving federal funds to inventory holdings of Native American human remains and funerary objects and provide written summaries of other cultural items. In an attempt to recognize the religious and cultural significance of such sites and to protect their sacred integrity, it also provides for greater protection of Native American burial sites and more careful control over the removal of Native American human remains, funerary objects, sacred objects, and items of cultural patrimony on federal and tribal lands. Federal curation regulations are also provided in 36 Code of Federal Regulations 79, which apply to collections that are excavated or removed under the authority of the Antiquities Act (16 United States Code [USC] 431-433), the Reservoir Salvage Act (16 USC 469-469c), Section 110 of the NHPA (16 USC 470h-2), or the Archaeological Resources Protection Act (16 USC 470aa-mm). Such collections generally include those that are the result of a prehistoric or historic resources survey, excavation or other study conducted in connection with a federal action, assistance, license, or permit. (NPS-C).

State Regulations
California Environmental Quality Act
The California Environmental Quality Act (CEQA) requires the lead agency to determine whether the proposed development project will have a significant effect on the environment. Sections 21083.2 and 21084.1 of the State CEQA Guidelines deal with the definitions of unique and non-unique archaeological resources and historical resources, respectively. Section 21083.2 directs the lead agency to determine whether the project may have a significant effect on unique archaeological resources. If the lead agency determines that the project may have a significant effect on unique archaeological resources, the environmental impact report shall address the issue of those resources. Section 21084.1 directs the lead agency to determine whether the project may have a significant effect on historical resources, irrespective of the fact that these historical resources may not be listed or determined to be eligible for listing in the California Register of Historical Resources (CRHR), a local register of historical resources, or they are not deemed significant pursuant to criteria set forth in California Public Resource Code (PRC) Section 5024.1(g). A cultural resource is considered “historically significant” under Pub. Res. Code § 5024.1, Title 14 CCR, Section 4852, if it meets any one of the following criteria for:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or,

4. Has yielded, or may be likely to yield, information important in prehistory or history.

A tribal cultural resource may be considered significant if it is included in a local or state register of historical resources or determined by the lead agency to be significant pursuant to criteria set forth in PRC Section 5024.1; is a geographically defined cultural landscape that meets one or more of these criteria; or is a historical resource described in PRC Section 21084.1, a unique archaeological resource City of Riverside Sections 5.13
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described in PRC Section 21083.2, or a non-unique archaeological resource if it conforms with the above criteria. (CRHR).

State Historic Preservation Office
The State Historic Preservation Office (SHPO) is a state governmental function created per the NHPA, which called for the creation of a state agency to implement provisions of the law, including the preparation of a comprehensive historic preservation plan and a statewide survey of historical resources (SHPO-A). SHPO administers the National Register of Historic Places, the California Register of Historical Resources, the California Historical Landmarks, and the California Points of Historical Interest programs. The responsibilities of the SHPO include identifying, evaluating, and registering historic properties; ensuring compliance with federal and state regulatory obligations; encouraging the adoption of economic incentives programs designed to benefit property owners; encouraging economic revitalization by promoting a historic preservation ethic through preservation education and public awareness and, most significantly, by demonstrating leadership and stewardship for historic preservation in California. SHPO maintains the California Historical Resources Information System (CHRIS), which includes the statewide Historical Resources Inventory database. (SHPO-B).

California Register of Historical Resources (Public Resource Code Section 5024.10 et seq.) State law protects cultural resources by requiring evaluations of the significance of historical resources in CEQA documents. A cultural resource is an important historical resource if it meets any of the criteria found in Section 15064.5(a) of the State CEQA Guidelines. These criteria are similar to those used in federal law. The CRHR is maintained by the state Office of Historic Preservation. Properties listed, or formally designated eligible for listing, on the NRHP are automatically listed on the CRHR, as are state historical landmarks and points of interest. The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys.

CRHR Criteria
For purposes of CEQA, a historical resource is any object, building, structure, site, area, place, record, or manuscript listed in or eligible for listing in the CRHR (California Public Resources Code [PRC] Section 21084.1). A resource is eligible for listing in the CRHR if it meets any of the following criteria:
• Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
• Is associated with the lives of persons important in our past. • Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values. • Has yielded, or may be likely to yield, information important in prehistory or history.

The California Code of Regulations (CCR) further provides that cultural resources of local significance are CRHR-eligible (Title 14 CCR, Section 4852).

Native American Heritage Commission
The Native American Heritage Commission (NAHC), created in statute in 1976, is a nine-member body, appointed by the Governor, to identify and catalog cultural resources (i.e., places of special religious or social significance to Native Americans, and known graves and cemeteries of Native Americans on private lands) in California. The NAHC is also charged with ensuring California Native American tribes’ accessibility to ancient Native American cultural resources on public lands (i.e. Sacred Lands File), Section 5.13 City of Riverside
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overseeing the treatment and disposition of inadvertently discovered Native American human remains and burial items, and administering the NAGPRA. (NAHC).

Human Remains
According to Section 15064.5 of the State CEQA Guidelines, all human remains are assigned special importance and specific procedures are to be used when Native American remains are discovered.

These procedures are discussed within Public Resources Code Section 5097.98 (PRC 5097.98). PRC 5097.98 addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are discovered during construction of a project; and establishes the NAHC to resolve disputes regarding the disposition of such remains.

California Health & Safety Code (Sections 7050.5, 7051, and 7054) Sections 7050.5, 7051, and 7054 of the California Health & Safety Code collectively address the illegality of interference with human burial remains (except as allowed under applicable sections of the Public Resources Code), as well as the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are discovered during construction of a project, treatment of the remains prior to, during and after evaluation, and reburial procedures. (HSC 7050.5, HSC 7051, and HSC 7054).

Senate Bill 18
Senate Bill 18 (SB 18), effective September 2004, requires local government to notify and consult with California Native American tribes when the local government is considering adoption or amendment of a general or specific plan. Prior to adoption of a specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county’s jurisdiction. Pursuant to Government Code Section 65352.3, prior to adoption or any amendment to a General Plan proposed on or after March 1, 2005, the city or county shall conduct consultations with California Native American tribes for the purpose of preserving or mitigation impacts to Cultural Places. The tribe(s) has 90 days from when the tribe is contacted by the city or county in which to request a consultation.

Assembly Bill 52
Assembly Bill 52 (AB 52), became effective on July 1, 2015, adding a new requirement to CEQA regarding tribal cultural resources. Public Resource Code (PRC) Section 21084.2 establishes that a project with an effect that may cause a substantial adverse change in the significance of a TCR is a project that may have a significant effect on the environment. To help determine whether a project may have such an effect, PRC Section 21080.3.1 requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project. This consultation must take place prior to the release of a negative declaration, mitigated negative declaration, or environmental impact report for a project. As a result of AB 52, the following must take place: 1) prescribed notification and response timelines; 2) consultation on alternatives, resource identification, significance determinations, impact evaluation, and mitigation measures; and 3) documentation of all consultation efforts to support CEQA findings.

Under AB 52, if a lead agency determines that a project may cause a substantial adverse change to a TCR, the lead agency must consider measures to mitigate that impact. PRC Section 21074 provides a definition of “tribal cultural resources.” In brief, in order to be considered a tribal cultural resource, or City of Riverside Sections 5.13
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TCR, a resource must be either 1) listed, or determined to be eligible for listing, on the national, state, or local register of historic resources, or 2) a resource that the lead agency chooses, in its discretion supported by substantial evidence, to treat as a TCR. In the latter instance, the lead agency must determine that the resource meets the criteria for listing in the state register of historic resources or City Designated Cultural Resource. In applying those criteria, a lead agency shall consider the value of the resource to the tribe. Elder testimony, oral, and written accounts are all considered to be examples of substantial evidence for determining the significance of a tribal cultural resource.

Regional Regulations
There are no applicable regional regulations.

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside 2025 General Plan contains objectives and policies that are considered applicable to the proposed Project as identified below (GP 2025, pp. HP-25 - HP-27, HP-28):

Historic Preservation Element
Objective HP-1 To use historic preservation principles as an equal component in the planning and development process.

Policy HP-1.1 The City shall promote the preservation of cultural resources to ensure that citizens of Riverside have the opportunity to understand and appreciate the City's unique heritage.

Policy HP-1.3 The City shall protect sites of archaeological and paleontological significance and ensure compliance with all applicable State and federal cultural resources protection and management laws in its planning and project review process.

Policy HP-2.1 The City shall actively pursue a comprehensive program to document and preserve historic buildings, structures, districts, sites (including archaeological sites), objects, landscapes, and natural resources.

Policy HP-2.3 The City shall provide information to citizens, and the building community about what to do upon the discovery of archaeological resources and burial sites, as well as, the treatment, preservation, and repatriation of such resources.

Objective HP-4 To fully integrate the consideration of cultural resources as a major aspect of the City's planning, permitting and development
Policy HP-4.3 The City shall work with the appropriate tribe to identify and address, in a culturally appropriate manner, cultural resources and tribal sacred sites through the development review process.

City of Riverside 2025 General Plan EIR
There are no applicable mitigation measures from the Riverside 2025 General Plan EIR that pertain to tribal cultural resources.

City of Riverside Phase I General Plan Update
There are no objectives or policies considered applicable to the proposed Project.

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City of Riverside Phase I General Plan Update EIR
The are no applicable mitigation measures from the GPUI EIR that pertain to Tribal Cultural Resources.

City of Riverside Municipal Code
The following sections of the City’s Municipal Code are applicable and pertain to tribal cultural resources:

Title 20 – Cultural Resources. The purpose of this title is to promote the public health, safety and general welfare by providing for the identification, protection, enhancement, perpetuation and use of improvements, buildings, structures, signs, objects, features, sites, places, areas, districts, neighborhoods, streets, works of art, natural features and significant permanent landscaping having special historical, archaeological, cultural, architectural, community, aesthetic or artistic value in the City for the following reasons:
 To safeguard the City's heritage as embodied and reflected in such resources;  To encourage public knowledge, understanding and appreciation of the City's past;  To foster civic and neighborhood pride and a sense of identity based on the recognition and use of cultural resources;
 To promote the enjoyment and use of cultural resources appropriate for the education and recreation of the people of the City;
 To preserve diverse and harmonious architectural styles and design preferences reflecting phases of the City's history and to encourage complementary contemporary design and construction;
 To enhance property values and to increase economic and financial benefits to the City and its inhabitants;
 To protect and enhance the City's attraction to tourists and visitors, thereby stimulating business and industry;
 To identify as early as possible and resolve conflicts between the preservation of cultural resources and alternative land uses;
 To integrate the preservation of cultural resources and the extraction of relevant data from such resources into public and private land management and development processes;  To conserve valuable material and energy resources by ongoing use and maintenance of the existing built environment.
 To implement the City's General Plan.
 To work in concert with the City's Zoning Code

5.13.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding utilities and service systems in response to the Initial Study/Notice of Preparation (IS/NOP).

5.13.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the Thresholds of Significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

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As identified in the Initial Study (Appendix A) prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this Draft EIR:
 Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
o Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resource Code section 5020.1(k); or o A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

5.13.5 Project Design Features
Because no tribal cultural resources were identified at the Project site, no Project Design Features are incorporated that would lessen impacts related to tribal cultural resources. Mitigation measures included below would lessen impacts to unknown tribal cultural resources which may occur below the surface at the Project site.

5.13.6 Methodology
A Cultural Resources Technical Report was prepared by Dudek date May 2023 (DUDEK-A) and attached as Appendix C. The analysis herein is based upon this report consisting of a records search; search of the Native American Heritage Commission’s (NAHC) Sacred Lands File (SLF); a pedestrian survey; and development of an appropriate ethnographic context for the Project site.(DUDEK, p, 3) Record Search and Literature Review
On September 3, 2020, the Eastern Information Center (EIC) completed a records search of the CHRIS database for the Project site and a one halve mile radius buffer. At the time of this, the 1.5 miles utility line had not been added to the study area so only approximately one-half of the utility line was captured in the record search results. A supplemental records search request was submitted but results have not been received to date. The search identified and collected the records for any previously recorded cultural resources and cultural resource studies and reviewed the following lists in an effort to identify resources meeting the respective criteria for the NRHP, the CRHR, the California Points of Historical Interest list, the California Historical Landmarks list, the Archaeological Determinations of Eligibility list, and the California State Historic Resources Inventory list. With respect to the built environment resources, the Built Environment Resources Database, California Inventory of Historical Resources (1976); Historical Maps; Local Inventories; and General Land Office and/or rancho plat maps were also reviewed. (DUDEK, p. 23)
The 1938 Kirkman-Harriman Historical Map was also reviewed. Based on this map, the Project site located is approximately 15 miles southwest of the San Bernardino Mountains, approximately 10 miles northeast of the Santa Ana Mountains, and approximately 5 miles south of the Jurupa Hills and mapped

0.2-mile south of the historical route of the Santa Ana River. The proposed utility line terminates Section 5.13 City of Riverside
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adjacent to the southern bank of the Santa Ana River’s historical route. In this portion of the map, the Santa Ana River and the Project site are encircled by two roadways. Approximately 1.5 miles to the north of the Project parcel and 1.3 miles north of the proposed utility line is an unnamed northeast southwest trending road. To the south, the northeast southwest trending “Spanish Town Road” intersects the Project site. Within the land between the roadways are two (2) unnamed Native American villages. The villages are north of the Santa Ana River and equidistant from the Project site, approximately 4.5 miles to the east and west. It should be noted that this map is highly generalized due to scale and age and may be somewhat inaccurate with regards to distance and location of mapped features and was prepared based on review of historic documents and notes more than 100 years following secularization of the missions (in 1833). Although the map contains no specific primary references, it does matches the details documented by the Portolá expedition (circa 1769–1770). The map is a valuable representation of post-colonization mission history; however, it is limited to a specific period of Native American history and substantiation of the specific location and uses of the represented individual features should be verified by archaeological records and/or other primary documentation. (DUDEK, p. 26)
Building Development and Archival Background Research
A number of previously conducted studies and building development and archival research was also conducted. Both the City of Riverside General Plan 2025 Program – Section 5.5 Cultural Resources and City of Riverside Historic Context Statement documents were reviewed. Building development and archival research were conducted to establish a thorough and accurate historic context for the evaluations and to confirm the building development history. This included a review of Riverside County Building Permits, historical newspaper search, historical topographic maps, and historical aerial photographs. Part of this research also included requests for information from the Riverside Metropolitan Museum, Riverside Archives, and Riverside Historical Society. However, no information has been received to date from these entities. (DUDEK, pp. 28-32).

Pedestrian Surveys
An intensive level survey for historic built environment resources was conducted on May 11, 2022. The survey entailed walking only the exterior of the buildings on the subject property, documenting the property with notes and photographs, specifically noting character-defining features, spatial relationships, observed alterations, and examining any historic landscape features on the property. All field practices met the Secretary of Interior’s standards and guidelines for a cultural resources inventory. (DUDEK, p. 33).

An archaeological pedestrian survey of the Project site was conducted on February 7, 2023. The survey focused on identifying exposed ground surface within landscaped areas and edges of pavement. All available ground surface was inspected for prehistoric artifacts (e.g., flaked stone tools, tool-making debris, groundstone tools, ceramics, fire-affected rock), soil discoloration that might indicate the presence of a cultural midden, soil depressions, features indicative of structures and/or buildings (e.g., standing exterior walls, post holes, foundations), and historical artifacts (e.g., metal, glass, ceramics, building materials). (DUDEK, p. 32).

Native American Communications
As part of the Phase I Cultural Resources Assessment, the Native American Heritage Commission (NAHC) was contacted on February 8, 2023, to request a Sacred Lands File (SLF) and a list of potentially interested Native American Tribes for the purposes of general Native American consultation under CEQA. (DUDEK, p. 27).

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Pursuant to both AB 52 and SB 18, the City notified the following Native American tribes1 of the proposed Project. The following tribes were notified related to AB 52:
 Gabrieleño Band of Mission Indians
 Soboba Bank of Luiseño Indians
 Cahuilla Band of Indians
 Pechanga Band of Luiseño Indians
 Rincon Band of Luiseño Indians
 San Manuel Band of Mission Indians
 Morongo Band of Mission Indians
 Agua Caliente Band of Cahuilla Indians
 San Gabriel Band of Mission Indians
The following tribes were notified related to SB 18:
 Agua Caliente Band of Cahuilla Indians
 Augustine Band of Cahuilla Indians
 Cabazon Band of Mission Indians
 Cahuilla Band of Indians
 Los Coyotes Band of Cahuilla and Cupeño Indians
 Morongo Band of Mission Indians
 Pala Band of Mission Indians
 Pechanga Band of Indians
 Quechan Tribe of the Fort Yuma Reservation
 Ramona Band of Cahuilla
 Rincon Band of Luiseno Indians
 Santa Rosa Band of Cahuilla Indians
 Soboba Band of Luiseno Indians
 Torres-Martinez Desert Cahuilla Indians
Tribal responses are provided in Table 5.13-A, Tribal Communications, below. The Rincon Band of Luiseño Indians was the only tribe to request consultation. 1 Table 5.13-A provides a complete list of the Native American tribes that responded to either AB 52 and/or SB 18 consultation efforts.

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Tribal Communications
Native American Group
(Individual Responding) Response
Yuhaaviatam of San Manuel Nation
[formerly known as the San Manuel
Band of Mission Indians]
(Ryan Nordness)
 On November 21, 2022, the tribe indicated that the
Project site is located outside of Serrano ancestral
territory. Thus, consultation was not requested.

Yuma Quechan Tribe
(H. Jill McCormick)
 On November 28, 2022, the tribe deferred to local
tribes. Thus, consultation was not requested.

Rincon Band of Luiseño Indians
(Cheryl Madrigal)
 On December 19, 2022, tribe indicated Project site
is within the Luiseño Traditional Use Area and
requested consultation
Agua Caliente Band of Cahuilla Indians
(Nicole Raslich)
 On October 28, 2022, the tribe indicated that the
Project site is located outside of the Tribe’s
Traditional Use Area and deferred to other tribes.

Thus, consultation was not requested.

Source: City of Riverside
The City held tribal consultation meetings with Rincon Band of Luiseño Indians) as requested to further determine the potential for any impact. Results are discussed in Section 5.13.7 – Environmental Impacts below.

5.13.7 Environmental Impacts
Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resource Code section 5020.1(k); As discussed in Section 5.3 – Cultural Resources, the buildings are eligible for listing in the HRHP, CRHR and local register of historical resources. However, the structures are not associates with Native American activities or traditional uses and instead listed for eligibility based on its architectural features and historic character as a Mid-Century Modern department store . No prehistoric sites or resources documented to be of specific Native American origin have been previously recorded within the records search area or the Project site (DUDEK, p. 23). Thus, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resource Code section 5020.1(k) as the structures are not associated with traditional Native American activities. Therefore, no impacts are anticipated.

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Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code section 5024.1; in applying the criteria set forth in subdivision (c) of Public Resource Code section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe?
As discussed above, there are no known Native American cultural resources within the Project site.

However, the potential for intact cultural deposits to exist within native soils (encountered from 2 feet below ground surface in some areas) to the depths of proposed ground disturbance (approximately 8 feet below ground surface) is considered moderate and the Project site is within a geographical region known for supporting Native American occupation. The Project site is within the vicinity of two unnamed Native American villages and transportation routes as mapped on the 1938 Kirkman Harriman map.

Additionally, the Project site is within the Santa Ana River watershed, an area that would provide sustainable resources for habitation. Archival research indicates that the Project site has been occupied since at least the early twentieth century. Initially used as agricultural land, the Project site transitioned to rural residential properties in the early to mid-twentieth century and again to a fully developed commercial property in the 1960s. (DUDEK, p 65).

While the “Spanish Town Road” as identified by the 1938 Kirkman Harriman map, intersects the Project site, no archaeological evidence of this feature was provided in the CHRIS records search results or review of other archaeological information. Additionally, the CHRIS results contained no archaeological evidence of the Native American villages within proximity to the Project site. This is likely because the nearest mapped villages are located outside the Project’s one half mile records search radius. (DUDEK, pp. 26).

Development of the Project site may have buried unknown cultural resources associated with Native American use and/or historic-period agricultural or residential properties. Native soils underlying the artificial fill consist of alluvial deposits from the terminal Pleistocene. These soils are considered contemporaneous with human use, and therefore retain the potential to preserve cultural material in context. (DUDEK-A, p. 65, DUDEK-B, p. 5)
Though the archaeological survey was negative for cultural resources associated with Native American use, the existing development within the Project site provided little to no observable ground surface for inspection; thus, the negative findings of the archaeological survey are an unreliable indicator of the archaeological sensitivity of the Project site. Previous and proposed ground disturbances were considered in light of the potential for yet unknown archaeological resources and human remains to be encountered leading to a determination that there is a potential for an inadvertent discovery of unknown archaeological resources and human remains to occur during Project implementation. Implementation of mitigation measures MM TCR-1 and MM TCR-4 would ensure the proper treatment of any cultural resources and human remains associated with Native Americans encountered during ground disturbing activities. (DUDEK, p 65)Additionally, the City as lead agency, is required to coordinate with Native American Tribes through AB 52 and SB 18 consultation processes for the proposed Project and proposed General Plan Amendment. As identified in Table 5.13-A above, the City of Riverside notified four local tribal governments on October 28,2023 of the proposed Project pursuant to AB52 and SB18.

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Of the tribes contacted for AB52 and SB18 consultation, only Rincon Band of Luiseño Indians requested consultation with the City. In a letter dated December 19, 2022, Cheryl Madrigal, Tribal Historic Preservation Officer, of the Rincon Band of Luiseño Indians Cultural Resource Department, that the Project area is within the Traditional Use Area of the Luiseno people. As such, the Rincon Band of Luiseño Indians is traditionally and culturally affiliated to the Project area. During consultation efforts, mitigation measures were proposed by the City and reviewed by Rincon Band of Luiseño Indians. After review of the proposed mitigation measures, Rincon Band of Luiseño Indians had no additional comments and concluded consultation efforts on May 22, 2023.

As a result of the City’s consultation efforts, implementation of mitigation measures MM TCR-1 and MM TCR-4 would reduce impacts to any potential tribal resources. Thus, with implementation of mitigation measures MM TCR-1 and MM TCR-4, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 that is a resource determined significant to a California Native American Tribe. Therefore, impacts are less than significant with mitigation incorporated.

5.13.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). Mitigation measures were evaluated for their ability to eliminate or reduce the potential significant adverse impact to tribal cultural resources. However, there is a potential that unknown resources on the Project site may have been obscured by pavement or other materials over the years. As such, the potential exists for unknown tribal cultural resources to be present and Project construction activities may impact unknown tribal cultural resources within the Project disturbance area. As a result of the Tribal Consultation with the Rincon Band of Luiseño Indians, the City’s standard mitigation measures related to the disposition of any uncovered artifacts that may be inadvertently discovered during ground disturbance will be incorporated as outlined below to reduce impacts related to tribal cultural resources to less than significant levels.

Mitigation measures MM TCR-1 and MM TCR-4 will be implemented to reduce impacts to unknown cultural resources to less than significant with mitigation incorporated.

MM TCR-1 Consultation. Prior to grading permit issuance, if there are any changes to project site design and/or proposed grades, the Applicant and the City shall contact consulting tribes to provide an electronic copy of the revised plans for review. Additional consultation shall occur between the City, developer/applicant, and consulting tribes to discuss any proposed changes and review any new impacts and/or potential avoidance/preservation of the cultural resources on the project site. The City and the developer/applicant shall make all attempts to avoid and/or preserve in place as many cultural and paleontological resources as possible that are located on the project site if the site design and/or proposed grades should be revised. In the event of inadvertent discoveries of archaeological resources, work shall temporarily halt until agreements are executed with consulting tribe, to provide tribal monitoring for ground disturbing.

MM TCR-2 On call Project Archaeologist. Prior to the issuance of a grading permit, the Property Owner/Developer shall provide a letter from a County certified Archaeologist and Paleontologist stating that the Property Owner/Developer has retained these individuals, and that the Archaeologist and Paleontologist shall be on call during all grading and other significant ground-disturbing activities in native sediments.

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MM TCR-3 Treatment and Disposition of Cultural Resources. In the event that Native American cultural resources are inadvertently discovered during the course of grading for this project, the following procedures will be carried out for treatment and disposition of the discoveries:

1. Consulting Tribes Notified: within 24 hours of discovery, the consulting tribe(s) shall be notified via email and phone. The developer shall provide the city evidence of notification to consulting tribes. Consulting tribe(s) will be allowed access to the discovery, in order to assist with the significance evaluation.

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

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

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MM TCR-4 Cultural Sensitivity Training. The Secretary of Interior Standards County certified archaeologist and Native American monitors shall attend the pre-grading meeting with the developer/permit holder’s contractors to provide Cultural Sensitivity Training for all construction personnel. This shall include the procedures to be followed during ground disturbance in sensitive areas and protocols that apply in the event that unanticipated resources are discovered. Only construction personnel who have received this training can conduct construction and disturbance activities in sensitive areas. A sign-in sheet for attendees of this training shall be included in the Phase IV Monitoring Report.

5.13.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
As a result of the City’s Tribal Consultation efforts, MM TCR-1 through MM TCR-4 will be incorporated in order to address the unlikely discovery of unknown tribal cultural artifacts during construction.

Mitigation measure MM TCR-1 through MM TCR-4 provides the process of how any artifacts will be handled. Implementation of these mitigation measures will not result in residual environmental impacts.

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5.14 Utility and Service Systems
The focus of this section is to analyze potential impacts related to utilities and service systems, such as water, wastewater treatment, storm water drainage, solid, waste, natural gas, electrical power, and telecommunication facilities. The following discussion addresses the potential impacts that could result from the construction of new or expanded facilities as a result of the proposed Project. The Initial Study attached as Appendix A to this Draft EIR, determined that the Project would result in a less than significant impact to stormwater drainage, electric power, natural gas, and telecommunication facilities.

Since no new, expanded, or relocated facilities are anticipated for these utilities, they will not be further analyzed in this Draft EIR so the analysis below will only focus on water, sewer, and solid waste.

Cumulative impacts are discussed in Section 7.0 – Other CEQA Topics.

A Water Service Availability Notice was provided by the Riverside Public Utilities Department dated May 10, 2023 (RPU-WS) and a Sewer Study Memorandum was prepared by Carollo Engineers, Inc. dated December 20, 2022 (CAROLLO). These letters are included in Appendix G of this Draft EIR

5.14.1 Setting
The Project site is currently developed but vacant, located in an urbanized area with generally flat topography. Existing utility systems and infrastructure are present within and adjacent to the Project site. The utility companies that would serve the Project site and the existing utilities located on or adjacent to the Project site are listed in Table 5.14-A, Utility Providers, below.

Table 5.14-A, Project Utility Providers
Utility Provider Existing Location
Potable Water
Riverside Public Utilities Department  12-inch line in Arlington  8-inch and 36-inch lines in Streeter
Avenue
Sewer Riverside Public Works  21-Inch line in Arlington Avenue  8-inch line in Streeter Avenue
Storm Drain
Riverside County Flood Control and
Water Conservation District, and
Riverside Public Works
 24-inch line in Arlington Avenue
 30-inch and 33-inch lines in Streeter
Avenue
Natural Gas
Southern California Gas Company  Lines in both Arlington and Streeter Avenues
 30-inch transmission line1 in
Arlington Avenue
Electric Riverside Public Utilities Department  Overhead power lines along Arlington and Street Avenues
Solid Waste Riverside Public Works (or through
contract with private local haulers)
Not Applicable
Television Varies  Overhead power lines along
Arlington and Street Avenues
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Table 5.14-A, Project Utility Providers
Utility Provider Existing Location
Telephone Varies  Overhead power lines along
Arlington and Street Avenues
Notes:

1. Transmission lines are generally large diameter pipelines that operate at pressures above 200 psi and transport gas from supply points to the gas distribution system.

Existing Potable Water Facilities
The City of Riverside established its own water utility, the Riverside Public Utilities Department (RPU), in 1913 (GP 2025 FEIR, p. 5.16-5). RPU’s primary source of supply is ground water. RPU has facilities to extract groundwater from five groundwater basins: Bunker Hill, Rialto-Colton, Riverside North, Riverside South, and Arlington Basins. The Riverside Basin is divided into Riverside North and Riverside South by the San Bernardino County/Riverside County boundary. The Riverside North and South sub-basins are hydro geologically connected but separated for administrative purposes. RPU’s service area is approximately 75 square miles, 70 of which are located within the City of Riverside. In addition to retail potable water service, RPUD delivers water to two wholesale customer agencies: Western Municipal Water District and City of Norco. Most of RPUD’s current retail customers are residential (mostly single family). All other customers consist of commercial/institutional, landscape, agricultural irrigation uses, as well as other land uses such as fire and temporary special needs. (UWMP, pp. 3-5, 4-4, 6-2).

RPU currently has 53 active wells (46 producing potable water). RPU has 20 inactive wells that are being used as monitoring wells and 13 other monitoring wells, for a total of 33 dedicated monitoring wells. Raw groundwater from many of RPU’s wells receives treatment prior to entering the potable distribution system. (UWMP, p. 6-2).

If additional water supply is needed RPU has an agreement with the Western Municipal Water District (WMWD) to access imported water when needed. This agreement can provide RPU with up to 21,700 acre feet per year (AFY) of imported water. RPU also has an exchange agreement with the City of Norco for the sale of up to 1,000 AFY and the exchange of water during emergencies. RPU also has the ability to purchase SWP water from WMWD through a connection at the Metropolitan Water District (MWD) Henry J Mills Water Treatment Plant where up to 19.4 million gallons per day (mgd) of imported water can be purchased from the Water Management District (WMD) through an existing agreement and can be conveyed through existing infrastructure. Existing potable water supply and demands are identified below in Table 5.14-B, Existing Potable Water Supply and Demand. (UWMP, pp.6-2).

Table 5.14-B, Existing Potable Water Supply and Demand
Type Supply (AFY) Demand (AFY)
Potable 74,262 69,347
Source: UWMP, Table 4-2 and Table 6-9
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The Project site lies within the service area of the RPU (GP 2025, p. PF-3). The former Sears Department Store and Auto Service Center buildings are connected to an existing 12-inch diameter potable water pipeline in Arlington Avenue and an existing 8-inch diameter pipeline in Streeter Avenue.

Existing Non-Potable (including Recycled) Water Facilities RPU produces and distributes disinfected, tertiary treated recycled water for non-portable uses. Nonpotable uses are supplied from the City of Riverside Regional Water Quality Control Plant. RPUD currently has 7 active wells producing non-potable water. By agreement, RPU delivers non-potable water to WMWD via the Riverside canal while meeting the demands of retail customers within its service area. The Project site lies within the service area of RPU for non-potable water (GP 2025, p. PF-3). The City currently operates a recycled water distribution system with a combined pipeline length of approximately 5.4 miles. The existing use of recycled water is 141 AFY. There is an existing 12-inch diameter non-potable water pipeline in Arlington Avenue adjacent to the Project site.

Existing Wastewater (Sewer) Facilities
The City’s Public Works Department (RPW) provides for the collection, treatment, and disposal of all wastewater through its Riverside Regional Water Quality Control Plant (RWQCP) and complies with state and federal requirements governing the treatment and discharge of wastewater. The City’s service area comprises approximately 81.5 square miles broken into five sewer basins: Arlanza, Northside, Phoenix, Spruce, and Tequesquite. The collection system conveys wastewater flows through these basins to the RWQCP through four major sewers: Acorn/Arlanza Trunk Sewer (A/A Trunk Sewer), Santa Ana Trunk Sewer (Riverside/Hillside), Jurupa Force Main, and Rubidoux Force Main. The Jurupa and Rubidoux force mains bring flows from the Jurupa and Rubidoux Community Service Districts (CSDs), respectively and exclusively. The Edgemont CSD and Highgrove Community, which have individual agreements with the City, both route their wastewater flows through the Santa Ana Trunk Sewer (Riverside/Hillside). (SSWIMPU, p. ES-10).

The existing wastewater collection system includes approximately 16,000 manholes; 20 lift stations; 19 wastewater pump stations that range in size from less than 100 gallons per minute (gpm) to over 2,000 gpm; 10.4 miles of force mains, more than 830 miles of gravity public sewer pipes ranging in size from 4- inches to 51-inches in diameter, and 412 miles of City-owned laterals. Almost 82 percent of the system consists of 8-inch diameter and smaller pipes and over 90 percent of the collection system is comprised of vitrified clay pipe. The firm capacity of the lift stations range in size from 80 gpm to the largest lift station Pierce Street Lift Station, with 11,100 gpm of firm pumping capacity. (SSMP, p. 1; WIMPU, p.

ES-14).

As identified in Table 5.14-C, Existing and Projected Wastewater Capacity below, the RWQCP currently treats approximately 28 million gallons per day (mgd) of average annual flow (AAF) and primary, secondary, and tertiary treatment of wastewater for a rated hydraulic capacity of approximately 46 mgd AAF. The RWQCP provides treatment from the Jurupa, Rubidoux, and Edgemont Community Services Districts in addition to treating wastewater generated in the community of Highgrove and serves a population of more than 300,000. A daily influent flow of approximately 39 mgd has been projected through the year 2037. (RIV-A; WIMPU p, ES-1).

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Table 5.14-C, Existing and Projected Wastewater Capacity Daily Influent Flow Capacity (mgd)
Existing1 28
Maximum Capacity1 46
Projected 2037 Daily Inflow2 39
Notes:

1. Source: WIMPU, pp. ES-1

2. Source: WIMPU, pp. ES-6
Existing Solid Waste
Solid waste, recycling, and green waste collection and disposal service in the City is provided by the City Public Works Department. Athens Services has a contract with the City to provide various trash collection and recycling services to businesses and multi-family properties within the City of Riverside.

As such, the proposed Project would be services by Athens Services. The City also sponsors a program known as “Clean Up Riverside” that provides collection events such as Incredible Bulky Item Drop-off, E-Waste Shredding and Bulb/Battery Collection, Household Hazardous Waste and throughout the year which is open to the residents. (SW-B,RIV-B).

The Agua Mansa Transfer Station (formerly known as the Robert A. Nelson Transfer Station), located at 1830 Agua Mansa Road, is owned by the County of Riverside and is operated under a 20-year franchise by Burrtec Waste Industries Inc. Non-hazardous waste is taken to the transfer station, to be sorted and then transported to the Badlands Landfill. Trash haulers may also dispose of collected waste at other County landfills in the area, such as the Lamb Canyon Landfill and El Sobrante landfill. (GP 2025 FEIR, p.

5.16-15).

The Badlands Landfill is a regional municipal solid waste landfill that is owned and operated by Riverside County located at 31125 Ironwood Avenue in the City of Moreno Valley – approximately 17 miles west of the Project site. The El Sobrante Landfill is a regional municipal solid waste landfill that is owned and operated by USA Waste Services of California, Inc. located at 10910 Dawson Canyon Road in the City of Corona – approximately 10 miles northeast of the Project site. The Lamb Canyon Sanitary Landfill is a regional municipal solid waste landfill that is owned and operated by Riverside County Department of Water Resources located at 16411 Lamb Canyon Road in the City of Beaumont – approximately 24 miles northwest of the Project site. Table 5.14-D, Existing Solid Waste below, identifies the capacity and intake of each solid waste facility serving the Project site.

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Table 5.14-D, Existing Solid Waste Capacity
Landfill Total Capacity (CY2)
Remaining
Capacity (CY)
Maximum Permitted
Daily Intake (TPD3)
Average Daily
In-Take (TPD)
Badlands1 82,300,000 7,800,000 5,000 2,883
El Sobrante 209,910,000 143,977,170 16,054 10,845
Lambs Canyon 39,618,513 19,242,950 5,000 2,101
Agua Mansa
Transfer
Station
NA NA 4,000 NA4
Source: CAL-A, CAL-B, CAL-C, DWR-A, DWR-B, DWR-C
Notes:

1. This landfill has a “ceased operation date” of January 1, 2059. (CAL-A)

2. CY=Cubic Yards

3. TPD=Tons per day

4. Average Daily In-Take amount not available. However, April 2023 inspection report indicates daily in-take is not being exceeded.

5.14.2 Related Regulations
Federal Regulations
Clean Water Act
The United States Environmental Protection Agency (USEPA) has delegated responsibility for compliance with the federal Clean Water Act to the State of California, which is discussed under “State Regulations.”
There are no other federal regulations that apply to the water supply, wastewater and solid waste services that are needed to serve the Project.

State Regulations
Urban Water Management Planning Act
The Urban Water Management Planning Act (1983), which was codified into Sections 10610 to 10656 of the California Water Code, requires urban water suppliers to develop water management plans to actively plan ahead for future water supplies to meet future anticipated water demands. Every five years, water suppliers are required to develop Urban Water Management Plans (UWMPs) for approval by the California Department of Water Resources (DWR). UWMPs can be used as the main source of information for WSAs and WSVs.

Clean Water Act
The Clean Water Act prohibits the discharge of pollutants to waters of the United States unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit.

Applicable NPDES permits are those managed on a statewide basis by the State Water Resources Control Board (i.e., General Permits), such as the General Industrial Activities Storm Water Permit and the General Construction Activity Storm Water Permit. Both of these permits require a Storm Water Pollution Prevention Plan (SWPPP); the industrial permit requires an industrial SWPPP used in perpetuity based on the SIC code, and the construction permit requires a SWPPP for construction phase only. In addition, the State Board issues statewide municipal permits for Municipal Separate Storm Sewer Systems (MS4) owned by municipalities. (MS4).

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The MS4 permit program regulates all stormwater discharges from municipal storm drains. The Santa Ana RWQCB regulates the Riverside County MS4 permit (Order No. R8-2010-0033), which requires the principal permittee Riverside County Flood Control and Water Conservation District (RCFC&WCD) and co-permittees (County of Riverside and cities, including the City of Riverside) to develop several items designed to reduce pollutants in urban runoff to the Maximum Extent Practicable (MEP). Specifically for qualifying new developments and redevelopments, this includes a Water Quality Management Plan (WQMP). All future development within the Project site would be required to prepare a project specific WQMP.

California State Water Resources Control Board
In the State of California, the State Water Resources Control Board and nine Regional Water Quality Control Boards (RWQCB) are responsible for implementing the Clean Water Act (CWA) and the State Porter Cologne Water Quality Control Act. The Porter-Cologne Water Quality Control Act Section 13000 directs each Regional Water Quality Control Board (RWQCB) to develop a Water Quality Control Plan (Basin Plan) for all areas within its region. The Basin Plan is the basis for each RWQCB’s regulatory programs. The City of Riverside is located within the purview of the Santa Ana RWQCB (Region 8) and must comply with applicable elements of the region’s Basin Plan, as well as the Porter-Cologne Water Quality Control Act.

Water Conservation Act
The Water Conservation Act of 2009, or Senate Bill 7X-7, set a requirement for water agencies to reduce their per capita water use by the year 2020. The overall goal is to reach a statewide reduction of per capita urban water use of 20 percent by December 31, 2020, with an intermediate 10 percent reduction by December 31, 2015. Demand reduction can be achieved through both conservation and the use of recycled water as a potable demand offset.

The City of Riverside has codified landscaping and irrigation requirements under Water Efficient Landscaping and Irrigation in Title 19, Chapter 19.570 of the City Municipal Code.

California Water Code
Sections 13550–13556 of the State Water Code provide that local, regional, or state agencies shall not use water from any source of quality for non-potable uses if suitable recycled water is available as provided in Section 13550 of the Water Code.

California Integrated Waste Management Act (Assembly Bill 939) Solid waste regulation in California is governed by the California Integrated Waste Management Act of 1989, which is commonly known as Assembly Bill (AB) 939. The Act, codified into the California Public Resources Code, emphasizes a reduction of waste disposed in California landfills. To achieve a reduction of waste in California landfills, AB 939 requires all city and county plans to include a waste diversion schedule with the goals to divert 25 percent of solid waste from landfills by 1995 and divert 50 percent of solid waste from landfills by the year 2000. To achieve these goals, AB 939 emphasizes that cities and counties reduce, recycle, and reuse solid waste. To attain these goals for reductions in disposal, AB 939 established a planning hierarchy utilizing new integrated solid waste management practices.

Assembly Bill 341
California Assembly Bill 341 (Chapter 476, Statutes of 2011) directed CalRecycle to develop and adopt regulations for mandatory commercial recycling. The final regulation was approved by the Office of Administrative Law on May 7, 2012. AB 341 was designed to help meet California’s recycling goal of 75 City of Riverside Sections 5.14
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percent by the year 2020. AB 341 requires all commercial businesses and public entities that generate four cubic yards or more of waste per week to have a recycling program in place. In addition, multifamily apartments with five or more units are also required to form a recycling program.

Assembly Bill 1826
AB 1826 (2014) is the statewide mandatory organic waste recycling law that requires businesses and multi-family properties to arrange for organic waste recycling services that generate 4 cubic yards of organic waste or more, effective January 2017.

Senate Bill 1383
SB 1383 (2016) requires CalRecycle to adopt regulations that achieve the specified targets for reducing organic waste in landfills. The bill authorizes local jurisdictions to charge and collect fees to recover the local jurisdiction’s costs incurred in complying with the regulations.

Regional Regulations
Countywide Integrated Waste Management Plan
The County of Riverside Countywide Integrated Waste Management Plan (CIWMP) was prepared in accordance with the California Integrated Waste Management Act of 1989, Chapter 1095 (AB 939). The CIWMP’s components include the Countywide Summary Plan, the Countywide Siting Element, the Source Reduction and Recycling Element (SRRE), the Household Hazardous Waste Element (HHWE) and Non-Disposal Facility Element (NDFE).

The Summary Plan summarizes the steps needed to cooperatively implement programs among the County’s jurisdictions to meet and maintain the 50 percent diversion mandates. The Siting Element demonstrates that there are at least 15 years of remaining solid waste disposal capacity to serve all the jurisdictions within the County. If there is not adequate capacity, a discussion of alternative disposal sites and additional diversion programs must be included in the Siting Element. The SRRE was developed separately by each Riverside County jurisdiction to analyze the local waste stream to determine where to focus diversion efforts, including programs and funding. The HHWE was developed by jurisdictions and provides a framework for recycling, treatment, and disposal practices for Household Hazardous Waste programs. The NDFE identifies and describes existing and proposed facilities, other than landfills and transformation facilities, requiring a solid waste permit to operate. Non-disposal facilities are also those facilities that will be used by a jurisdiction to meet its diversion goals. The Riverside County NDFE identifies and describes those non-disposal facilities that will be needed to implement the Riverside County SRRE. (CIWMP).

Local Regulations
City of Riverside 2025 General Plan
The City of Riverside General Plan contains objectives and policies that are considered applicable to the proposed Project, as identified below (GP 2025, pp. PF-12 – PF-13, PF-16, PF-19, OS-57 – OS-58):

Public Facilities and Infrastructure Element
Objective PF-1: Provide superior water service to customers.

Policy PF-1.1: Coordinate the demands of new development with the capacity of the water system.

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Policy PF-1.2 Support the efforts of the Riverside Public Utilities Department, Eastern Municipal Water District and Western Municipal Water District to work together for coordination of water services.

Policy PF-1.3: Continue to require that new development fund fair-share costs associated with the provision of water service.

Policy PF-1.4: Ensure the provision of water services consistent with the growth planned for the General Plan area, including the Sphere of Influence, working with other providers.

Policy PF-1.5: Implement water conservation programs aimed at reducing demands from new and existing development.

Policy PF-3.2: Continue to require that new development fund fair-share costs associated with the provision of wastewater service.

Open Space and Conservation Element
Objective OS-10: Preserve the quantity and quality of all water resources throughout Riverside.

Policy OS-10.1: Support the development and promotion of water conservation programs.

City of Riverside 2025 General Plan EIR
There are no applicable mitigation measures from the 2025 General Plan EIR that pertain to Utilities and Service Systems.

City of Riverside Phase I General Plan Update
There are no objectives or policies within the GPUI that are considered applicable to the proposed Project.

City of Riverside Phase General Plan Update EIR
There are no applicable mitigation measures from the GPUI EIR that pertain to Utilities and Service Systems.

City of Riverside Municipal Code
The following sections of the City’s Municipal Code are applicable and pertain to utility and service systems.

Chapter 6.06 – Business and Multifamily Solid Waste, Recycling and Organics Recycling. It is the intent and purpose of this chapter to promote recycling and organics recycling. It is further the purpose of this chapter to provide a mechanism to require the implementation of recycling programs and organics recycling programs for covered generators within the city to thereby enable the city to meet and maintain the 50 percent waste diversion requirements set forth in Section 41780(a)(2) of the California Public Resources Code.

Chapter 14.22 – Water Conservation. This chapter establishes a Water Conservation Program which uses five stages to address conditions and needs. The Water Conservation Stage shall be set by City Council action. All normal water efficiency programs and water conservation regulations shall remain in force during any stage unless the City Council directs otherwise.

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A. Stage One represents normal conditions; Stages Two, Three, Four, and Five represent potential and actual shortages. Stages Two, Three, Four, and Five may be triggered by a local or regional water supply shortage; production, treatment, transmission, or delivery infrastructure problems; limited or unavailable alternative water supplies; or other circumstances.

B. Stage one conservation measures are voluntary, and will be encouraged through public outreach, education, and awareness measures by the City.

C. Stages Two, Three, Four, and Five conservation measures are mandatory, and violations may be subject to criminal, civil, and administrative enforcement.

Urban Water Management Plan
The 2020 Urban Water Management Plan (UWMP) provides an overview of the RPUD’s long-term water supplies and demands and reports on the City’s progress towards meeting the water use efficiency targets. The plan includes demand management measures that the R{UD has agreed to implement to achieve water supply savings. In accordance with Water Code 10632 requirements, RPUD is responsible for conserving the available water supply, protecting the integrity of water supply facilities, and implementing a contingency plan in times of drought, supply reductions, failure of water distribution systems, or emergencies. As such, RPUD adopted Water Shortage Contingency Plan (WSCP) to regulate the delivery and consumption of water use during water shortages. The WSCP defines five shortage stages and outlines the actions that will be required of customers during each stage. (UWMP, pp. iii, 8-1-3).
2020 Update of the Integrated Master Plan for the Wastewater Collection and Treatment Facilities In January 2020, the 2008 Integrated Master Plan for the Wastewater Collection and Treatment Facilities (Master Plan Update) for the City of Riverside RPW was updated. The Master Plan Update was prepared to facilitate planning through a 20-year horizon for the City’s RWQCP and collection system.

The recommended plan is intended to enable the RWQCP to continue to reliably provide wastewater treatment for the City and surrounding communities as the wastewater flow and loading increase due to projected population growth. In addition, a Capital Improvements Program (CIP) and the resulting rate structure was developed. The Master Plan Update also brings key portions of the 2008 Master Plan and the 2014 rate and development study up to date and addresses collection system and facility needs for projected influent flow and loading through the year 2037. (WIMPU, p. ES1).

Sewer System Management Plan
On May 2, 2006, the State Water Resources Control Board adopted the California State Water Resources Control Board (CSWRCB) Order No. 2006-0003-DWQ -- Statewide General Waste Discharge Requirements for Sanitary Sewer Systems (WDRs). WDRs require owners and operators of collection systems to apply for coverage and abide by its provisions and prohibitions. Its purpose is to prevent sanitary sewer overflows (SSOs) and establish uniform procedures for monitoring and reporting. On October 13, 2006, the City applied for coverage under this order by submitting a Notice of Intent (NOI) to the State Water Board. On January 18, 2007, the City obtained an account on the State of California SSO Database California Integrated Water Quality System. This provided the City with a mechanism to report SSOs in accordance with the WDRs. The WDRs also require the development and implementation of a Sewer System Management Plan (SSMP). A SSMP must include provisions to provide proper and efficient management, operation, and maintenance of sanitary sewer systems, while taking into consideration risk management and cost benefit analysis. Additionally, a SSMP must contain a spill response plan that establishes standard procedures for immediate response to an SSO in a manner Section 5.14 City of Riverside
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designed to minimize water quality impacts and potential nuisance conditions. The City’s SSMP was adopted in July 2009 and revised in June 2022. The SSMP was developed by the City’s Public Works Department to comply with CSWRCB Order No. 2006-0003-DWQ. (SSMP, p. 1).

5.14.3 Comments Received in Response to the Initial Study/Notice of Preparation
No comments were received regarding utilities and service systems in response to the Initial Study/Notice of Preparation (IS/NOP).

5.14.4 Thresholds of Significance
The City of Riverside has not established local CEQA significance thresholds and instead, defers to the thresholds of significance identified in Appendix G (“Environmental Checklist”) to the State CEQA Guidelines.

As identified in the Initial Study (Appendix A), and as outlined in Section 4.0 of this DEIR, implementation of the proposed Project will have a less than significant impact in the following area and this topic is not addressed in this DEIR:
 Comply with federal, state, and local management and reduction statue and regulations related to solid waste.

As identified in the Initial Study prepared for this Project, implementation of the proposed Project will have potentially significant impacts in the following areas and these topics are addressed in this DEIR:
 Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects;  Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years;  Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments; and
 Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

5.14.5 Project Design Features
The Project will connect to the following water, sewer, and storm drain facilities as reflected in the Existing and Proposed Utility Plan shown in Figure 3.0-33 of this Draft EIR. Hence, the Project will incorporate the following project design features (PDFs):

Water
 10-inch water lateral will tie into existing 8-inch water pipeline located at the northwestern corner on of the Project boundary along Streeter Avenue and another 10-inch lateral will tie in at the southwest corner of Project boundary along Streeter Avenue;  10-inch meter and backflow will tie in to existing 12-inch water line located along Arlington Avenue at two connection points
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 Additionally, the Project will install two Double Check Detector Assembly (DCDA), that will connect to the existing 12-inch water pipeline along Arlington Avenue. All other fire hydrants will be connected to internal water lines constructed by the Project.

Sewer
 Sewer mains throughout project site;
 8-inch sewer lateral will connect to existing 21-inch sewer line in Arlington with two connection points; and
 8-inch sewer lateral will connect to existing 8-inch sewer pipe in Streeter Avenue.

Storm Drain
 18-inch storm drain lateral will connect to existing 33-inch storm drain line in Streeter Avenue.
 24-inch storm drain will tie into existing 33-inch storm drain line in Streeter Avenue.

The Project includes design features that will provide Water Conservation and reduction in Solid Waste as follows:
 The Project site will be landscaped with a plant palette consistent with Riverside Citywide Design Guidelines for Water Efficient Landscape and Irrigation Design Guidelines.  Design buildings to be water-efficient. Install water-efficient fixtures in accordance with Section

5.303 of the California Green Building Standards Code Part 11; and  The Project will utilize the crushed concrete from the demolition phase as engineering fill.

5.14.6 Methodology
In order to identify potential impacts, the proposed Project is compared to existing utility service levels.

The analysis herein is based upon the City’s UWMP and Water Supply Availability to determine capacity of existing facilities to meet both potable and non-potable water demands of the proposed Project.

The City’s 2020 Update of the Integrated Master Plan for the Wastewater Collection and Treatment Facilities (2020 Sewer Master Plan Update), Sewer System Management Plan, and Sewer Study Memorandum which includes a hydraulic evaluation are used to determine capacity of existing sewer facilities to meet the needs of the Project. The model evaluated in the Sewer Study Memorandum includes the use of 10-inch diameter or larger pipelines as well as some 8-inch diameter and smaller pipelines, where needed for connectivity. Implementation of the Project would result in a change of land use type and the change in rain derived inflow and infiltration during a wet weather flow event rate so these circumstances were also taken into account during the hydraulic modeling process. (CAROLLO, p.1).

Additionally, the Robert A. Nelson Transfer Station, and El Sobrante, Badlands, and Lambs Canyon landfills are reviewed for their capacity to meet the needs of the Projects’ solid waste needs during both construction and operation.

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5.14.7 Environmental Impacts
Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?
As previously indicated in Section 5.14 above, the Initial Study determined that Project would result in a less than significant impact storm drain, electric, natural gas, and telecommunication facilities so these utilities will not be further analyzed in accordance with State CEQA Guidelines Section 15128. As outlined in the Initial Study and in Section 4.0 of this EIR, the electrical utility 1.5-mile extension involving trenching in existing paved roadways will not result in significant impacts. This EIR document considers the physical improvements of this electrical offsite improvement throughout the analysis herein.

Water and Wastewater
The focus of the analysis below, pursuant to the Initial Study, is related to water and wastewater. The Project includes construction of an on-site network of water and sewer pipes that will connect to existing water and sewer lines in Arlington and Streeter Avenues. The installation of water and sewer line connections as proposed by the Project may result in physical environmental impacts. However, the Project’s construction phase is evaluated throughout this Draft EIR. In instances where significant impacts may have been identified for the Project’s construction phase, mitigation measures are recommended in each applicable subsection of this Draft EIR so the construction of water and sewer laterals would not result in any significant physical effects on the environment that are not already identified and disclosed as part of this Draft EIR. Thus, the proposed Project does not require or result in the relocation or construction of new water or wastewater treatment facilities.

Conclusion
Therefore, the implementation of the Project would not result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation. While the Project would require the expansion of electric facilities, construction of these facilities are less than significant. Therefore, impacts are less than significant for water and wastewater facilities needed to serve the Project.

Threshold: Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? RPU currently services the Project area, via existing water lines along Arlington Avenue and Streeter Avenue. The Project includes the water PDFs identified in Section 5.14.5 above which includes two laterals for connection to the existing water line on Streeter Avenue.

The City’s 2020 Urban Water Management Plan (UWMP) developed water demand projections considering variables such as climate, population growth, and customer behaviors. The UWMP used 2020 Census data, SCAG population growth projections, and updates to the City’s General Plan in order to calculate future water demands within RPU’s service area. The UWMP estimates water service reliability by calculating supply and demand for the following scenarios normal year supply, single dry year supply and multiple dry year supply. These estimates are based on assumptions that 100 percent of RPU’s groundwater and recycled water supplies would remain available during a single dry year and multiple dry years. The availability of imported water has been adjusted based on the reliability assessment by WMWD. Table 5.14-E, Water Service Supply and Demand1 below, shows estimated supply and demand calculated in the UWMP for future years. For all the scenarios (normal year, single City of Riverside Sections 5.14
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dry year, and multiple dry year) the available water supply is greater than the anticipated demands. (UWMP, pp. III, 7-5, 7-6).

Table 5.14-E, Existing and Future Water Service Supply and Demand1 Scenario 2025 2030 2035 2040 2045
Normal Year Supply 114,923 124,893 128,193 129,693 129,693 Demand 90,712 100,803 103,260 105,807 108,447
Single Dry Year Supply 114,923 124,893 128,193 129,693 129,693 Demand 90,712 100,803 103,260 105,807 108,447
Multiple Dry Years
First Year
Supply 114,923 124,893 128,193 129,693 129,693
Demand 90,712 100,803 103,260 105,807 108,447
Multiple Dry Years
Second Year
Supply 114,923 124,893 128,193 129,693 129,693
Demand 90,712 100,803 103,260 105,807 108,447
Multiple Dry Years
Third Year
Supply 114,923 124,893 128,193 129,693 129,693
Demand 90,712 100,803 103,260 105,807 108,447
Multiple Dry Years
Fourth Year
Supply 114,923 124,893 128,193 129,693 129,693
Demand 90,712 100,803 103,260 105,807 108,447
Multiple Dry Years
Fifth Year
Supply 114,923 124,893 128,193 129,693 129,693
Demand 90,712 100,803 103,260 105,807 108,447
Source: UWMP, Tables 7-2 thru 7-4
Notes:

1. All Values are provided in Acre Feet.

As identified in Table 5.14-E above, water supplies are estimated to accommodate demand projections through 2045 under normal and multiple dry-year conditions. As mentioned in Section 5.9 – Population and Housing of this Draft EIR, implementation of the Project would result in development of 388 housing units that will increase population; by approximately 1,273 residents lending to a permanent increase in demand for water supply.

Per SB X7-7 water agencies are required to calculate their baseline water use for a 10 to 15 year period.

As such RPU determined in their 2020UMWP that average base daily per-capita water use within the RPU service area was 266 gallons per capita per day. (UWMP, pp. 5-1 - 5-2). Utilizing this information, Table 5.14-F, Projected Water Demand projects the anticipated water demand of the proposed Project below.

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Table 5.14-F, Projected Water Demand
Projected
Population1
Water Generation
Rate (GCD)2
Project Demand
GCD3
Demand
AFY4,5
1,273 266 338,618 379.3
Source: UWMP, p. 5-2
Notes:

1. Population projection was calculated in Section 5.9 – Population and Housing

2. GPCPD = Gallons per Capital per Day

3. 1,273 persons X 266 GCD= 338,618 GCD

4. AFY = Acre Feet per Year

5. Conversion factor 892. (338,618 ÷ 892.7 = 379.3)

6. As reflected in Table 5.14-F above, implementation of the proposed Project would increase water demands by approximately 379.3 AFY over existing and future conditions in normal, dry, and multiple dry years. However, as identified in Tables 5.14-B and 5.14-E above, RPU’s supplies are larger than existing and projected demands. Thus, the increased demand resulting from the proposed Project would be accommodated.

Further, RPU issued a Water Service Availability letter dated May 10, 2023, which indicated that PRU is prepared to offer water service to the proposed Project site upon completion of financial arrangements and compliance with the RPU’s Rules and Regulations for the installation of water facilities.

Project landscaping will be required to comply with Riverside Citywide Design Guidelines for Water Efficient Landscape and Irrigation Design Guidelines.

Thus, through regulatory compliance and PDFs, the proposed Project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years. Therefore, the impacts would be less than significant.

Threshold: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? The wastewater collection provider for the Project is RPW. Wastewater treatment will be provided for the Project by the RWQCP. As indicated in Section 5.14.5 – Project Design Features above, the Project will implement sewer PDFs which includes 8-inch sewer lateral connections to the existing facilities in Arlington and Streeter Avenues.

The 2020 Sewer Master Plan Update (Master Plan Update) utilized the City’s 2025 General Plan land use designations to analyze capacity needs of the wastewater system. The Project proposes to change the existing General Plan land use designation from commercial uses to high density residential and commercial. Hence, additional loads associated with proposed land use were used in hydraulic evaluation. (CAROLLO, p. 1).

The Sewer Study Memorandum prepared for the proposed Project included both an existing and a future hydraulic evaluation to determine both existing and future capacity of wastewater treatment.

Table 5.14-G, Project Site Wastewater below, identifies anticipated wastewater flows that were City of Riverside Sections 5.14
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anticipated to be produced by the Project site, currently designated as commercial, as part of the Master Plan Update as well as flows projected to be produced proposed by the Project.

Table 5.14-G, Project Site Wastewater
Acres Flow Factor (gpd/ac) Average Daily Weather Flow (gpd) Flows Planned by
Master Plan Update 17.37 710 12,333
Proposed Residential 14.44 2,800 40,432
Proposed Commercial 2.99 710 2,123
Proposed Project
Increased Flows - - 30,180
Source: CAROLLO, p. 2
The proposed Project would result in an increase in the sewer flows anticipated for this site. Hence, a capacity analysis was conducted. The capacity analysis identifies areas in the sewer system where flow restrictions occur or where pipe capacity is insufficient to convey peak wet weather flows (PWWFs).

Sewers that lack sufficient capacity to convey peak wet weather flow conditions create bottlenecks in the collection system that can potentially cause sanitary sewer overflows. (CAROLLO, p. 4).

The capacity analysis was utilized to determine if the proposed Project would result in impacts on the existing and planned sewer system. It was also utilized to determine if the recommended sewer improvement projects and pipe sizing identified in the Master Plan Update, would be adequately sized to accommodate the proposed Project. (CAROLLO, p. 4).

For the existing sewer collection system, the PWWF conditions were routed through the hydraulic model along with the changes to the point of connections for average dry weather flow (ADWF) and rain derived inflow and infiltration (RDII) in order to verify if the existing system is appropriately sized to convey existing PWWFs plus the additional flows from the proposed land use change. The Master Plan Update identified one existing system improvement downstream of the proposed Project. The Easement Trunk Sewer Replacement (Project GM-7) is a gravity Main located along an easement 330 feet North of Mountain View Avenue to Santa Ana River Trail.
1 RPU Project GM-7 outlined in the Master Plan Update
consists of the replacement of approximately 770 feet of 24-inch diameter pipeline and replacing with a 27-inch diameter pipeline. This improvement has already been identified in the Master Plan Update as an existing need and is in queue for replacement. The proposed replacement of the pipeline will be adequately sized for the proposed change in land use. (CAROLLO, p. 4).

For the future sewer system, the Master Plan Update identified one future sewer system improvement downstream of the proposed Project. The New Parallel Trunk to Santa Ana Trunk Sewer (Project GM34) which will provide approximate 9,160 linear feet of 39-inch diameter pipe (WIMPU, Vol 3, p.7-11).

The timing of growth under future conditions is expected to occur within the planning horizon, which is the year 20372
. As flows continue to increase in the future, there will be some areas of the collection 1 The City of Riverside has approved the Easement Trunk Sewer Replacement Project. Construction is anticipated to commence late 2024.
2 The New Parallel Trunk to Santa Ana Trunk Sewer Project GM-34 is a distant future project for allocated for the years 2028-2037 as the Project would mitigate a future deficiency within the existing system.

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system that cannot convey the future PWWF without flows exceeding capacity. However, the future capacity evaluation which includes the proposed Project, did not identify new system deficiencies not already identified in the Master Plan Update or the existing hydraulic evaluation discussed above. Thus, the hydraulic analysis identified that future sewer system improvements identified in the Master Plan Update are adequately sized to accommodate the proposed Project in the future. (CAROLLO, p. 5).

Hence, the analysis concluded that both the existing system and future sewer improvement projects proposed by the Master Plan Update are adequate to meet the increased flows of the proposed Project.

Further, as identified in Table 5.14-C above, the RWQCP currently treats approximately 28 million mgd of AAF with a hydraulic capacity of approximately 46 mgd AAF. The RWQCP has a projected daily influent flow of approximately 39 mgd through the year 2037 so the RWQCP has capacity to treat the flows of the proposed Project.

Thus, implementation of the proposed Project would result in a determination that the wastewater treatment has adequate capacity to serve the projected demand in addition to their existing commitments because RPW has been shown to have adequate capacity to serve the Project’s projected demand in both existing and future conditions. Therefore, impacts would be less than significant.

Threshold: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
The Project site is developed and the Project is proposing demolition and reconstruction of the existing site so the following discussion will include an evaluation of the demolition, construction, and operational solid waste.

Site Demolition Solid Waste
The Project would entail the demolition of the existing structures, parking lot, trees/vegetation, and existing utility lines. Anything with salvage value that includes steel, metal rebar from footings, old mechanical equipment, etc. will be segregated and recycled. Some material like old plywood with builtup roofing material stuck to it or used carpet may end up in a landfill. However, by weight (tonnage), most of the building and demolition spoils will come from the concrete structure and the paved parking lot. It will be crushed and used as fill and road base on the property and thus diverted from a landfill.

Prior to full demolition, anything such as lead based paint or asbestos containing materials will be stripped and disposed of legally as outlined in Section 5.6 Hazards and Hazardous Materials, by and under the supervision of a qualified environmental remediation company. Anything hazardous is separately bagged and disposed of prior to the main building demolition process.

The Project proposes to crush the existing concrete and asphalt from demolition to a maximum size of six inches and utilize as engineered fill for the basement area. (ALTA, pp. 2-3). The Project site will then be graded. Anticipated earthwork is expected to balance with 28,000 cubic feet (cf) of cut and 28,000 cf of fill. Thus, no solid waste will result from the demolition of existing building and parking lot or during grading activities.

New Construction Solid Waste
Construction of the Project would result in the generation of construction-related solid waste. Table

5.14-H, Project Construction Waste below, identifies Project’s projected contribution to these landfills during construction.

City of Riverside Sections 5.14
Arlington Mixed Use Development Draft EIR Utility and Service Systems

5.14-17
Table 5.14-H, Project Construction Waste
Building Type
Building Size
(SF)
Generation
Rate (lbs/SF) Total (Tons)1
Residential 546,474 4.38 1197
Office
(Clubhouse/Fitness/Leasing building) 4,409 3.89 9
Commercial 25,320 3.89 49
Total 1,255
Disposal Facility
Yearly InTake
Capacity
(tons/year)2
Project’s
Yearly
Disposal Rate3
Proposed Project’s
Contribution to
Yearly In-Take
Capacity4
Badlands 1,825,000 654 0.04
El Sobrante 5,859,710 654 0.01
Lamb Canyon 1,825,000 654 0.03
Robert A Nelson Transfer Station & MRF 1,460,000 654 0.04 Source: USEPA, pp. 2-2 – 2-4
Notes:

1. (Building Size) X (Generation Rate) = (Total Pounds of Waste), (Total Pounds of Waste X 0.0005 = (Total Tons of Waste)
(546,474 SF) X (4.38) = 2,393,556 lbs/sf, 2,393,556 lbs/sf X 0.0005 = 1196.77806 tons (4,409 SF) X (3.89) = 17,151.01 lbs/sf, 17,151.01 lbs/sf X 0.0005 = 8.575505 tons (25,320 SF) X (3.89) = 98494.8 lbs/sf, 98494.8 lbs/sf X 0.0005 = 49.2474 tons

2. Daily disposal capacity multiplied by 365 days per year.

3. Total tons divided by years of construction (1.92 years, 23 months =1.92 years)

4. Yearly Intake / Disposal Capacity x 100
As mentioned in Section 5.14.1 - Setting above, solid waste produced by the Project would be collected and transported to the Agua Mansa Transfer Station to be sorted and then be transferred to the Badlands Landfill; or waste would be transported directly to the Badlands, El Sobrante, or Lamb Canyon Landfills. The Project will require short-term construction activities resulting in 1,255 tons of construction waste as identified in Table 5.14-H above. Under a worst-case scenario, assuming all of the Project’s construction solid waste is transferred to the transfer station and one landfill, the Project’s contribution to the disposal facilities would be less than 0.05 percent. Hence, the Project’s construction solid waste contribution to the transfer station or any of the three landfills during construction activities will be negligible.

Operational Solid Waste
The Project is proposing to change the land use designation of the Project site to Mixed-Use which would result in commercial and residential solid waste. Anticipated solid waste during operation is calculated below in Table 5.14-I, Project Operational Waste below. One commercial building is speculative as it has no known tenant. The other is proposed as a grocery store so its specific use has been designated in the calculations below.

Section 5.14 City of Riverside
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5.14-18
Table 5.14-I, Project Operational Waste
Proposed Land Use Total (Tons/Year)
Grocery 115
Retail 5
Multi-Family 345
Project’s Total Projected Operational Waste 465
Disposal Facility
Yearly In-Take Capacity
(tons/year)1
Proposed Project’s
Percent of Yearly
Intake2
Badlands 1,825,000 0.025
El Sobrante 5,859,710 0.008
Lamb Canyon 1,825,000 0.025
Agua Mansa Transfer Station 1,460,000 0.032
Source: WEBB-A (CalEEMod data for solid waste)
Notes:

1. Daily disposal capacity multiplied by 365 days per year.

2. Total tons / Disposal Capacity x 100
Based on the results from Table 5.14-I above, the Projects contribution to any of the three Landfills during operation will be negligible. The proposed Project’s yearly tonnage contribution is less than 0.1 percent of the yearly permitted intake rate for any of the three landfills. Further, these percentages reflect a worst-case scenario as they are based on all waste going to one landfill when in reality, these would likely be split between the three resulting in smaller total contributions.

Pursuant to AB 939, at least 50 percent of the Project’s solid waste is required to be diverted from landfills. Non-recyclable solid waste generated during long-term operation of the Project would be disposed of at the El Sobrante, Badlands Landfill, and/or the Lamb Canyon Landfills. All of these landfills receive well below their maximum permitted daily disposal volume; thus, waste generated by the Project’s operation is not anticipated to cause the landfill to exceed its maximum permitted daily disposal volume (CalRecycle). Because the Project would generate a relatively small amount of solid waste per day as compared to the permitted daily capacities at receiving landfills, impacts to regional landfill facilities during the Project’s long-term operational activities would be less than significant.

Federal, state, and local statutes and regulations regarding solid waste reductions are intended to decrease solid waste generation through mandatory reductions in solid waste quantities (e.g., through recycling and composting of green waste) and the safe and efficient transport of solid waste. The proposed Project would be required to develop a collection program for recyclables, such as paper, plastics, glass, and aluminum, in accordance with local and state programs. Additionally, the proposed Project would be required to comply with applicable practices enacted by the City under AB 341 and any other applicable local, state, and federal solid waste management regulations.

Thus, the proposed Project’s estimated solid waste generation during demolition, construction, and operation will not generate solid waste in excess of State or local standards, or in excess of City of Riverside Sections 5.14
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5.14-19
infrastructure capacity because estimated waste will constitute an extremely small proportion of the daily available disposal capacity of any of the landfills. Further, the proposed Project will be required to comply with all existing regulations. Therefore, impacts would be less than significant.

5.14.8 Recommended Mitigation Measures
An EIR is required to describe feasible mitigation measures which could minimize significant adverse impacts (State CEQA Guidelines, Section 15126.4). Mitigation measures were evaluated for their ability to reduce or eliminate impacts. Because all Project impacts related to utilities and service systems are less than significant, no mitigation measures are necessary.

5.14.9 Summary of Project-Specific Environmental Effects After Mitigation Measures Are Implemented
There are no mitigation measures required to reduce impacts to Utility and Service Systems.

City of Riverside Section 6.0
Arlington Mixed Use Development Draft EIR Consistency with Regional Plans 6-1

6.0 Consistency with Regional Plans
California Environmental Quality Act, Section 15125(d), requires an EIR to discuss any inconsistencies between the proposed Project and applicable general, specific, and regional plans. The purpose of this section is to discuss the proposed Project’s consistency with the regional and local growth forecasts, the Southern California Association of Governments (SCAG) Connect SoCal 2020-2045 Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS), and to provide an analysis of the Project’s impacts on the population, housing, and job projections for the region. SCAG is the designated metropolitan planning organization, and as such, is mandated by the federal government to research and draw up plans for transportation, growth management, hazardous waste management, and air quality. Additionally, a discussion of the Project’s impacts upon the growth forecasts and its compliance with SCAG’s regional policies is discussed below.

A discission of the proposed Project’s consistency with the applicable Air Quality Management Plan and Connect SoCal RTP/SCS is addressed in Section 5.2 - Air Quality and Section 5.6 - Greenhouse Gas Emissions, respectively.

6.1 Setting

6.1.1 SCAG Regional Growth Factors
Population forecasts for the City and surrounding area are provided by SCAG, in the 2020-2045 RTP/SCS Demographics and Demographics and Growth Forecast-Technical Report Appendix (SCAG 2020). The RTP growth forecast is updated every four years and it was recently updated in 2020. The SCAG RTP Growth Forecast is broken down into separate growth forecasts for individual cities and unincorporated county areas. Table 6.0-A, SCAG Growth Forecasts (Riverside) depicts the SCAG population forecasts for the City, which includes the proposed Project site.

Table 6.0-A, SCAG Growth Forecasts (Riverside)
2016 2045
Population 325,300 395,800
Households 94,500 115,100
Employment 145,400 188,700
Jobs-to-Housing Ratio1 1.54:1 1.70:1
Source: SCAG 2020, Table 14
Notes:

1. Total number of jobs relative to the total number of households – calculated

2. 2020, 2035, and 2040 data not available.

Jobs-to-housing ratio is used as an indicator of how jobs-rich or jobs-poor a community is. SCAG’s April 2001 report titled, The New Economy and Jobs/Housing Balance in Southern California, states that a balance between jobs and housing in a metropolitan region can be defined as a provision of an Section 6.0 City of Riverside
Consistency with Regional Plans Arlington Mixed Use Development Draft EIR 6-2
adequate supply of housing to house workers employed in a defined area (i.e., community or subregion) (SCAG 2001, p.15). Alternately, a jobs/housing balance can be defined as an adequate provision of employment in a defined area that generates enough local workers to fill the housing supply.” Generally, a ratio of less than 1 to 1 indicates a jobs-poor area, and a ratio of more than 1 to 1 indicates a jobs-rich area (SCAG 2001, p. 15). Currently, the City of Riverside has an unemployment rate of 3.5 percent. (EDD). As reflected in Table 6.0-A, above, the 2020-2045 SCAG growth forecast indicates that in the year 2016 the jobs to housing ratio for the City was 1.54:1, which is by definition indicates a jobs-rich area and anticipated to increase to 1.70:1 by the year 2045.

6.2 Related Regulations

6.2.1 Southern California Association of Governments (SCAG) The Southern California Association of Governments (SCAG) is the largest Metropolitan Planning Organization (MPO) in the nation. The region covers more than 38,000 square miles and includes six counties: Riverside, Los Angeles, Orange, San Bernardino, Ventura, and Imperial and 191 cities (SCAG 2022). As the designated MPO, SCAG is mandated by federal law to research and develop a Regional Transportation Plan (RTP), which incorporates a Sustainable Communities Strategy (SCS) per California state law (SCAG 2019, p. 1). The SCAG region is a major hub of global economic activity, representing the 16th largest economy in the world, and is considered the nation’s gateway for international trade, with two of the largest ports in the nation (SCAG 2019, p. 1). The region encompasses six counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura) and 191 cities in an area covering more than 38,000 square miles (SCAG 2022).

6.2.2 Connect SoCal 2020-2045 Regional Transportation
Plan/Sustainable Communities Strategy
The SCAG regional council adopted the Connect SoCal 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) September 3, 2020 (RTP/SCS, p. 12). The RTP/SCS is a long-range visioning plan that balances future mobility and housing needs with economic, environmental, and public health goals. The plan charts a path toward a more mobile, sustainable, and prosperous region by making key connections: between transportation networks, between planning strategies and between the people whose collaboration can make plans a reality (RTP/SCS, p. 8). This plan reaffirms zero and near-zero emission technologies as a priority, describes progress to date, and outlines a framework and key action steps to reach that goal (RTP/SCS, p. 78). It outlines more than $638 billion in transportation system investments over the next 25 year (RTP/SCS, p. 4). The Plan was prepared through a collaborative, continuous, and comprehensive process with input wide range of constituents and stakeholders within the Counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura, including public agencies, community organizations, elected officials, tribal governments, the business community, and the general public (RTP/SCS, p. 8). The goals included in RTP/SCS are meant to provide guidance for considering projects within the context of regional goals.

The RTP provides an opportunity to identify transportation strategies today that address mobility needs for the future. The SCS is an element of the RTP that which outlines growth strategies for land use and transportation and help reduce the state’s greenhouse gas emissions from cars and light duty trucks, a requirement put in place by the passage of Senate Bill (SB) 375 with the goal of ensuring that the SCAG region can meet its regional greenhouse gas reduction targets set by the California Air Resources Board City of Riverside Section 6.0
Arlington Mixed Use Development Draft EIR Consistency with Regional Plans 6-3
(CARB) (RTP/SCS, p. 9). CARBs targets for the SCAG region, which were updated in 2018, are 8 percent below 2005 per capita emissions level by 2020 (this target was unchanged), and 19 percent below 2005 per capita emissions level by 2035 (this was increased from 13 percent below 2005 per capita emissions levels by 2035) (RTP/SCS, p. 138). The regional targets were updated to ensure consistency with the more stringent statewide reduction goals subsequently introduced by the California legislature (RTP/SCS, p. 38). The SCS has been found to meet state targets for reducing GHG emissions from cars and light trucks. The RTP/SCS achieves per capita GHG emission reductions relative to 2005 levels of 8 percent in 2020, and 19 percent in 2035, thereby meeting the GHG reduction targets established by the CARB for the SCAG region (RTP/SCS, p. 48).

6.3 Consistency Analysis
In March 2021, SCAG adopted the Regional Housing Needs Assessment (RHNA) 6th Cycle for the planning period of October 2021 through October 2029. The RHNA identified new housing units needed by income category for the region, including the City of Riverside. The City has been allocated to provide 18,458 new housing units by the RHNA. However, as part of the City Phase I General Plan Update (GPUI) which includes the 6th Cycle Housing Element for the planning period of 2021-2029, adopted in October 2021, the City added a self-prescribed buffer of new dwelling units to provide during this planning period to ensure the City meets the minimum recommended by State Department of Housing and Community Development to account for the “No Net Loss” requirements as mandated by Senate Bill 166 (SB 166). The City elected to provide a an approximately 30 percent “No Net Loss” buffer and so will target providing 24,000 new homes. (GPUI, p. 3.9-12). The vacancy rate in the City has been steadily decreasing each year since 2010 and currently sits at 4.0 percent. (DOF).

In October 2021, the City adopted Phase I General Plan Update (GPUI) which consisted of the 6th Cycle Housing Element (2021-2029). The GPUI identified that according to SCAG, the population of the City is projected to increase to 395,800 by 2045, which represents an increase of 20.61 percent from the 2020 population of 328,155 (GPUI, p. 3.9-17). However, based on DOF population and housing estimates, the City’s average household size was 3.28 persons. The GPUI utilized the more conservative DOF generation rate of 3.28 persons which projected an increase of 103,530 persons resulting in a total population projection of 431,685 persons by 2045; 67,645 persons more than the SCAG projection. The GPUI utilized the more conservative population estimate of 431,685 persons in its analysis and determined that no mitigation was available to reduce the impact of unplanned population growth to a less than significant level so the impacts would be significant and unavoidable. The proposed Project includes a rezone and a general plan amendment to change the designation to Mixed-Use Village to allow for residential use. Implementation of the Project would allow for a total of 388 residential dwelling units resulting in a population increase of 1,273 persons1 . This increase represents growth that is less
than one percent of the more conservative population projections analyzed by the GPUI that projected 67,645 more persons than SCAG projections. . Additionally, the Project will provide the City more opportunities to help reach the RHNA allocation of 18.458 for the planning period for 2021-2029 and the City’s self-prescribed target of 24,000 units. (RHNA).

1. Based on household generation factor of 3.28 people per dwelling unit for the City of Riverside (GPUI FEIR, p.

3.9-5).

Section 6.0 City of Riverside
Consistency with Regional Plans Arlington Mixed Use Development Draft EIR 6-4
Table 6.0.-B, Proposed Project Consistency with the Connect SoCal 2020-2045 RTP/SCS Goals, presents a side by side comparison of the Connect SoCal 2020-2045 RTP/SCS Goals and a discussion regarding the Project’s consistency, non-consistency, or non-applicability with each goal.

Table 6.0-B, Proposed Project Consistency with the Connect SoCal 2020-2045 RTP/SCS Goals
Goal Analysis
Connect SoCal Goal1: Encourage
regional economic prosperity and
global competitiveness.

Consistent: The proposed Project would involve construction of new commercial uses that would satisfy the needs of
commercial occupiers in the area and would be competitive with similar commercial-retail areas in the Inland Empire marketplace
Connect SoCal Goal 2: Improve
mobility, accessibility, reliability,
and travel safety for people and
goods
Not Applicable: The Project does not propose changes to the existing transportation system. The Project Site is currently served by the RTA, both Route 12 and Route 15 sever the Project area. Route 12 travels along Streeter Avenue and Route 15 travels along Arlington Avenue. Route 15 connects to two Metrolink Stations within the City of Riverside; the Riverside‐Downtown Metrolink station and the La Sierra
Metrolink Station.

Connect SoCal Goal 3: Enhance
the preservation, security, and
resilience of the regional
transportation system.

Not Applicable: The Project does not propose changes to the existing transportation system. However, as discussed above under Connect SoCal Goal 2, the Project Site is in proximity RTA routes and Metrolink trains that provide connectivity to adjacent jurisdictions.

Connect SoCal Goal 4: Increase
person and goods movement and
travel choices within the
transportation system.

Consistent: The Project does not directly entail the movement of persons or goods. However, as discussed under Connect SoCal Goals 2 and 3, the Project Site is in proximity to RTA routes that connect Metrolink to provide connectivity to adjacent jurisdictions and agencies.

Connect SoCal Goal 5: Reduce
greenhouse gas emissions and
improve air quality.

Consistent: The reduction of energy use, improvement of air quality, and promotion of more environmentally sustainable development would be encouraged through the development of alternative transportation methods (pedestrian sidewalk), green design techniques for buildings, solar, and other energyreducing techniques. The Project is required to comply with the provisions of the California Building and Energy Efficiency Standards (Title 24 of the California Code of Regulations; CEC 2022) and the California Green Building Standards Code
(CALGreen; Part 11 of Title 24). Title 24 standards would reduce project-related energy usage (30 percent reduction for City of Riverside Section 6.0
Arlington Mixed Use Development Draft EIR Consistency with Regional Plans 6-5
Table 6.0-B, Proposed Project Consistency with the Connect SoCal 2020-2045 RTP/SCS Goals
Goal Analysis
nonresidential uses) when compared to the 2016 standards.

The Title 24 standards are updated every three years and become more stringent with each update; therefore, complying with the latest Title 24 standards would make the proposed Project more energy efficient than existing buildings built under the earlier versions of the Title 24 standards.

The Project will maximize the protection of the environment and improvement of air quality by coordinating with local transit services to ensure any required transit connections are included within the Project.

Furthermore, due to the location of the Project site and its’ proposed Mixed Use, the Project will allow residents to grocery shop, dine, and shop within walking distance.

Connect SoCal Goal 6: Support
healthy and equitable communities.

Consistent: The Project implements additional housing and commercial uses within one site. This Project aims to increase the variety of housing options within the neighboring
residential area, along with integrating commercial uses keeping with the character of the existing area and offering an outdoor dog park for community use. Implementation of the Project would direct support to healthy and equitable
communities.

As further detailed Section 5.2 – Air Quality, the proposed Project will be consistent with Federal and State Ambient Air Quality standards and with mitigation, the proposed Project would not substantially impact nearby sensitive receptors.

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