Riverside City Council
September 17, 2024

Additionally, Section 5.9 – Noise indicates that with mitigation, the proposed Project would be consistent with local and state noise standards and would not substantially impact nearby sensitive receptors. Moreover, implementation of the proposed Project would provide local residents with employment
opportunities.

Connect SoCal Goal 7: Adapt to a
changing climate and support an
integrated regional development
pattern and transportation network.

Consistent: Redevelopment of the Project site is categorized as an infill development that will provide new uses to a site that has been abandoned. Thus, the Project will not result in a greenfield development.

Although the Project does not propose any changes to the transportation system, as discussed under Goals 2 and 3, the Project Site is in proximity to RTA routes and Metrolink trains that provide connectivity to adjacent jurisdictions.

Section 6.0 City of Riverside
Consistency with Regional Plans Arlington Mixed Use Development Draft EIR 6-6
Table 6.0-B, Proposed Project Consistency with the Connect SoCal 2020-2045 RTP/SCS Goals
Goal Analysis
The proposed Project will support the regional and
transportation network by payment of fair share fees pursuant to City MC 16.68 for payment of – Western Riverside County Transportation Uniform Mitigation Fee Program identified in Section 5.12 - Transportation.

Connect SoCal Goal 8: Leverage
new transportation technologies
and data-driven solutions that
result in more efficient travel
Not Applicable: This policy would be implemented by cities and the counties within the SCAG region as part of the overall planning of the transportation system. The proposed Project would not have an adverse impact on or otherwise affect efficient travel.

Connect SoCal Goal 9: Encourage
development of diverse housing
types in areas that are supported
by multiple transportation options.

Consistent: As discussed under Connect SoCal Goal 6, the Project will implement residential and commercial uses within one location. 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. Existing transportation systems are already in place that provide connectivity to adjacent jurisdictions.

Connect SoCal Goal 10: Promote
conservation of natural and
agricultural lands and restoration of
critical habitats.

Not Applicable: The Project site is not within agricultural lands nor is with within an area that requires restoration of critical habitats.

Source: Goals are identified in RTP/SCS, p. 9
The table above identifies that the proposed Project would be consistent with all applicable SCAG’s Connect SoCal policies. Consistency or inconsistency with SCAG regional policies does not result in physical changes to the environment and therefore, no significant effects on the environment.

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Other CEQA Topics
The State California Environmental Quality Act (CEQA) Guidelines set forth several general content requirements for Environmental Impact Reports (EIRs). Those applicable to this Project include cumulative impacts (Section 15130), unavoidable adverse impacts (Section 15126(b)), growth inducing impacts (Section 15126(d)), and significant irreversible impacts (Section 15126.2(c)). This section addresses each of those general requirements.

7.1 Cumulative Impact Analysis

7.1.1 Introduction
CEQA requires that an EIR examine the cumulative impacts associated with a project, in addition to project-specific impacts. The discussion of cumulative impacts must reflect the severity of the impacts and the likelihood of their occurrence; however, the discussion need not be as detailed as the discussion of environmental impacts attributable to the project alone (State CEQA Guidelines § 15130(b)).

As stated in the State CEQA Guidelines, an EIR “shall discuss cumulative impacts of a project when the project’s incremental effect is cumulatively considerable (§ 15130(a)). “Cumulatively considerable” means that “the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects as defined in Section 15130” (§ 15065(c)). Section 15355 of the State CEQA Guidelines states that “cumulative impacts” occur from “…the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.” A cumulative impact is not considered significant if the impact can be mitigated to below the level of significance through mitigation, including providing improvements and/or contributing funds through feepayment programs. The EIR must examine “reasonable options for mitigating or avoiding any significant cumulative effects of a proposed project” (State CEQA Guidelines §§ 15130(a)(3) and 15130(b)(5)).

State CEQA Guidelines Section 15130(b)(1) requires that a discussion of cumulative impacts be based on either a list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency; or a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact.

Section 15130(d) of the State CEQA Guidelines states that, “Previously approved land use documents such as general plans, specific plans, and local coastal plans may be used in cumulative impact analysis. A pertinent discussion of cumulative impacts contained in one or more previously certified EIRs may be incorporated by reference pursuant to the provisions for tiering and program EIRs. No further cumulative impact analysis is required when a project is consistent with a general, specific, master or comparable programmatic plan where the lead agency determines that the regional or area-wide cumulative impacts of the proposed project have been adequately addressed, as defined in Section 15152(f), in a certified EIR for that plan.” Additionally, if a cumulative impact was adequately addressed Section 7 City of Riverside
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in a prior EIR for a community plan, zoning action, or general plan, and the project is consistent with that plan or action, then an EIR for such a project should not further analyze that cumulative impact. (Section 15130(e) of the State CEQA Guidelines)
The “summary of projections method” is utilized as the cumulative impact analysis is based on information contained in the City of Riverside General Plan (GP) and Draft Environmental Impact Report, SCH No. 2004021108 (GP DEIR), certified by the City Council in 2007 Resolution No. 21535. This document is hereby incorporated by reference. A pertinent discussion of cumulative impacts contained in one or more previously certified EIRs may be incorporated by reference pursuant to the provisions for tiered and program EIRs. No further cumulative impact analysis is required when a project is consistent with a general, specific, master or comparable programmatic plan where the lead agency determines that the regional or area-wide cumulative impacts of the proposed project have been adequately addressed, as defined in section 15152(f), in a certified EIR for that plan.” Additionally, if a cumulative impact was adequately addressed in a prior EIR for a community plan, zoning action, or general plan, and the project is consistent with that plan or action, then an EIR for such a project should not further analyze that cumulative impact (State CEQA Guidelines § 15130(e)).

In those instances where the “list method” approach is used in the cumulative analysis, the analysis focuses on whether the impacts of the proposed Project are cumulatively considerable within the context of combined impacts caused by other past, present, or future projects. The cumulative impact scenario considers other projects proposed within the Project area that have the potential to contribute to cumulatively considerable impacts. The list of projects considered in this analysis includes development projects provided by the City of Riverside that were evaluated in the Project-specific Traffic Impact Analysis and are shown in Table 7.0-A, Cumulative Development Projects. The locations of these cumulative projects in relation to the Project site are shown in Figure 7.0-1, Cumulative Development Projects.

Table 7.0-A, Cumulative Development Projects
Identification Project Name Land Use Quantity of Units1 R1 PR-2021-001198 Manufacturing 25,250 TSF
General Office 40,000 TSF
R2 P20-0429 / P20-0430 / P20-0431 /
P20-0432 / P20-0433 Convenience Store 4,750 TSF
R3 P20-0044 Office / Warehouse 3,256 TSF
R4 P19-0874 Office / Warehouse 3,600 TSF
Source: URBAN, Table 4-3
Notes:

1. Units are in Thousand Square Feet (TSF)

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7.1.2 Cumulative Analysis Setting
The geographic scope (or cumulative impact area) used for each environmental issue is different depending upon the potential area of effect. For example, the geographic scope for air quality would be the South Coast Air Basin (Basin), while the geographic scope for cumulative aesthetics impacts would be the viewshed, and the geographic scope for traffic/circulation would be the roadways in the Project vicinity that could be affected by the cumulative projects.

7.1.3 Aesthetics
Utilizing the summary of projections method, the geographic scope for impacts related to aesthetics consists of the viewshed surrounding the Project site. The area immediately surrounding has a General Plan Land Use Designation of O - Office, C – Commercial, PF – Public Facility, MDR – Medium Density Residential, MHDR – Medium High Density Residential and HDR – High Density Residential. Thus, the surrounding urbanized area consists of a mix of commercial uses, single family residential units, public facilities and office buildings. The proposed Project does not exceed a building height of 41.25 feet of which only 36 feet will be habitable area. It should be noted that the existing structure already stands at 36 feet high. Thus implementation of the Project would not drastically alter the existing site views.

Considering the Project’s location and its surroundings, the Project would integrate all surrounding uses into one site as a mixed development. Therefore, the project would not implement a use that is not represented in the surrounding area.

For cumulative development to contribute to a significant cumulative impact on aesthetics, those cumulative development projects typically must be contiguous to the Project site and/or be located within the same viewshed, i.e., viewable from the same points as the Project. As the surrounding project area is already built and urbanized, there are no development projects contiguous to the Project site.

The nearest cumulative projects within the City represent projects and the associated visual character of these projects, including sources of potential light and glare during day and nighttime, will not contribute to a cumulatively considerable aesthetic impact to the Project area due to their distance from the Project site and each other. Further, although all of the cumulative development projects are anticipated to include lighting for security / and/or decorative purposes, all lighting associated with the cumulative development projects will be installed per the standards and policies of the City. These standards are intended to protect the views of the nighttime sky by requiring all lighting to be directed downward and away from adjacent properties and the sky.

Thus, there are no known or foreseeable development projects close enough to the Project site to contribute to a cumulatively considerable and significant impact on aesthetics. Therefore, cumulative impacts are not significant.

7.1.4 Air Quality
The cumulative impact for analysis for air quality employs the summary of projections approach because the dispersion of air pollutant emissions is influenced by an area larger than the list of cumulative projects. Utilizing the summary of projections method, due to the defining geographic and meteorological characteristics of the Basin, the cumulative area for air quality impacts is the Basin itself.

As previously stated in Section 5.2 – Air Quality of this Draft EIR (see Table 5.2-D), the portion of the City of Riverside Section 7
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Basin within which the Project is located is designated as a non-attainment area for ozone (O3) and particulate matter less than 2.5 microns in size (PM-2.5) under both State and federal standards and for particulate matter less than 10 microns in size (PM-10) under State standards.

The South Coast Air Quality Management District (SCAQMD) considers the thresholds for projectspecific impacts and cumulative impacts to be the same (see Section 5.2-24). Consequently, projects that exceed project-specific significance thresholds are considered by SCAQMD to be cumulatively considerable. Project emissions within the context of SCAQMD’s regional emissions thresholds provide an indicator of potential cumulative impacts within the Basin. Cumulative localized impacts for pollutants are also considered and reflect Project air pollutant emissions in the context of ambient conditions in the Project vicinity.

As discussed in Section 5.2 – Air Quality of this Draft EIR, the Project’s operational emissions do not exceed regional SCAQMD thresholds, and no mitigation was required.

Thus, the proposed Project’s cumulative contribution to air quality impacts is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.5 Cultural Resources
Utilizing the summary of projections method, the geographic scope for cumulative impacts to cultural resources is defined by the cultural setting and territory of the prehistoric and historic people who occupied the area of southern California in which the City is located. Western Riverside County was part of the territory of the Cahuilla and perhaps Luiseño people. Cumulative projects in the Project area and other development in western Riverside County could result in the progressive loss of as-yet unrecorded archaeological resources. This loss, without proper mitigation, would result in an adverse cumulative impact.

With respect to historic resources, the Project would demolish a potentially historic structure which is one of only two structures in the City designed by Charles Luckman that represent the Mid-Century Modern style of Architecture for a department store. According to the City’s Historic Resources Inventory list there are approximately 89 properties throughout the City that represent mid-century, and or modern architectural styles, excluding residential properties. Thus, removal of existing structures at the Project site would account for a reduction of approximately one percent of mid-century and or modern structures throughout the City. While the Project would be required to implement of mitigation measure MM CR-1 requiring preparation a Historic American Building Survey (HABS) to document the historic nature of the structure and will implement PDFs that incorporate architectural elements that acknowledge the history of sites Mid-Century Modern architecture, the loss of the structure will result in a significant impact to a historic resource as well as be inconsistent with General Plan policies HP-1.3 and HP-5.1.

With respect to archaeological resources, the Project would be required to comply with the City’s applicable General Plan resource protection requirements and conditions of approval. Cumulative projects within the City have the potential to impact cultural resources. However, to reduce impacts to archaeological resources, cumulative development projects within the Project vicinity will be required to comply with the resource protection requirements of the City’s General Plan, as applicable. Thus, cultural resource reports will be required for each individual cumulative development project to assess the potential for significant impacts to these resources and to identify mitigation measures if necessary.

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Additionally, all cumulative development projects, as well as the proposed Project, will be required to comply with state code and as discussed in Section 5.3 – Cultural Resources of this Draft EIR, with implementation of mitigation measures MM CR-2 through MM CR-5, the proposed Project would result in less than significant impacts to archaeological resources. Likewise, as discussed in the City’s General Plan EIR, cumulative development projects within the City will have a less than significant impact to archaeological resources.

Therefore, due to the loss of a historic resource which also results in an inconsistency with General Plan policies related to historic resources, cumulative impacts are significant and unavoidable and a statement of overriding consideration would be required to be adopted by the City prior to project approval.

7.1.6 Energy
Utilizing the summary of projections method, the geographic scope for cumulative impacts to energy is defined by the boundaries of Riverside Public Utilities (RPU) for electricity and Southern California Gas (SCG) for natural gas. The Project’s energy use includes electricity and natural gas usage as well as transportation-related energy (fuel). Energy impacts are cumulative in nature. RPU’s service area encompasses most of the City. SCG’s service area encompasses most of central and southern California.

Energy consumption by new buildings in California is regulated by the State Building Energy Efficiency Standards, embodied in Title 24 of the California Code of Regulations. The efficiency standards apply to new construction of both residential and non-residential buildings and regulate insulation, glazing, lighting, shading, and water- and space-heating systems. Building efficiency standards are enforced through the local building permit process. The City has adopted building standards consistent with Title

24. Fuel consumption from cars and trucks on the roadway network are also regulated at the State level.

Pavley, Low Carbon Fuel Standards (LCFS), and Advanced Clean Cars reduce emissions and increase fuel efficiency. Assembly Bill (AB) 1493 ("the Pavley Standard") requires reduction in GHG emissions from non-commercial passenger vehicles and light-duty trucks of model year 2009 and thereafter.

Executive Order S-01-07 went into effect in 2010 and required a reduction in the carbon intensity of transportation fuels used in California by at least 10 percent by 2020. It imposes fuel requirements on fuel that will be sold in California that will decrease GHG emissions by reducing the full fuel-cycle and the carbon intensity of the transportation fuel pool in California. The Advanced Clean Cars I and II program, first introduced in 2012, combines the control of smog, soot causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2017 through 2035.

Residents, employees of, and deliveries to the proposed Project site will utilize these vehicles as they become available. The cumulative development projects are also subject to these same regulations.

The proposed Project will comply with Title 24 standards for insulation, glazing, lighting, shading, and water and space-heating systems in all new construction. The Project will also comply with the California Green Building Standards Code (CALGreen), which implements sustainable construction practices that reduce negative impacts on the environment through planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental quality.

Through the use of modern energy-efficient construction materials and practices, in addition to City of Riverside Section 7
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compliance with Title 24 standards, the proposed Project will be consistent with the State’s energy conservation standards and, therefore would not conflict with an adopted energy conservation plan.

The analysis presented in Section 5.4 – Energy of this Draft EIR, is cumulative in nature. Thus, if an individual project does not result in wasteful or indifferent energy use, potential cumulative impacts of that project are not cumulatively considerable. As described in the analyses, the Project would not result in the unnecessary, inefficient, or wasteful use of energy resources nor would it conflict with or obstruct a state or local plan for increasing renewable energy or energy efficiency.

Thus, the proposed Project’s contribution to energy is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.7 Greenhouse Gas Emissions
GHGs are those gases that will contribute to global climate change; therefore, the cumulative impact area for GHG emissions is the earth’s atmosphere. Implementation of the proposed Project along with the cumulative development projects will contribute GHG emissions to the atmosphere.

It is important to note that the scope of the City’s jurisdictional authority is limited to certain types of emissions generated within the City’s physical boundaries. The City’s authority does not include the regulation of the majority of actions including, for example: transportation policy, fuel consumption, and energy generation, which the State has determined are necessary to meet all of its GHG reduction goals.

Further, some of the GHG emissions associated with the Project can be reduced only by measures to be implemented by other governmental agencies.

As discussed in Section 5.5 – Greenhouse Gas Emissions of this Draft EIR, the Project would contribute GHG emissions to the cumulative condition. Equipment and vehicles used during construction (e.g., onroad motor vehicles and heavy-duty construction equipment) and operations (i.e., vehicle trips, electricity consumption, and waste generation) would result in a net increase in GHG emissions over existing conditions and over the numeric threshold used by the City. Implementation of the Project would result in approximately 7,374.37 metric tons of carbon dioxide equivalents per year (MTCO2E/yr), which exceeds the 3,000 MTCO2E/yr draft threshold for non-industrial projects utilized by the City for the purpose of evaluating the GHG impacts associated with proposed general development projects. As such, the Project will generate a substantial amount of GHG emissions even after implementation of mitigation and Project design features. However, the Project will comply with existing regulations that reduce GHG emissions (i.e., Title 24, CALGreen code) and would not conflict with or obstruct implementation with Statewide, regional, and local plans adopted for the purpose of reducing and/or mitigating GHG emissions.

Thus, the proposed Project’s contribution to greenhouse gas emissions is cumulatively considerable.

Therefore, cumulative impacts are significant and unavoidable and a statement of overriding considerations would be required to be adopted by the City prior to Project approval.

7.1.8 Hazards and Hazardous Materials
Under the summary of projections method, the geographic scope for hazards relative to the release of hazardous materials into the environment are largely site‐specific. Each Cumulative Development Project within the City and surrounding areas are required to follow all federal, state, and local laws and Section 7 City of Riverside
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regulations regarding hazardous materials and other hazards. As explained in Section 5.6 – Hazards and Hazardous Materials implementation of the proposed Project would be required to comply with mitigation measures MM HAZ-1 and MM HAZ-2 in order to reduce impacts from existing residual petroleum and chlorinated solvents. Through implementation of regulatory requirements and mitigation measures MM HAZ-1 and MM HAZ-2 the Project would not cumulatively contribute to impacts resulting from the release of hazardous materials into the environment.

Utilizing the summary of projections method, the geographic scope for hazards relative to airports is the City, its sphere of Influence, and RCALUP. Cumulative impacts on airport land use plans and private airstrips are measured by the build-out of the General Plan. Airport authorities and other agencies regulate aircraft activity. A portion of the City is located within proximity to Riverside’s Municipal Airport.

The State Aeronautics Act of the California Public Utilities Code establishes statewide requirements for the airport land use compatibility planning and requires nearly every county to create an Airport Land Use Commission (ALUC) or other alternative. Airport operations and their accompanying noise and safety hazards require careful land use planning on adjacent lands to ensure the safety of residents and passengers alike, and to protect the City’s businesses and property owners to the greatest extent possible from the potential hazards that could be created by operations from Riverside Municipal Airport, especially by arriving and departing flights that fly over the portion of the City within close proximity to the Riverside Municipal Airport. Implementation of the proposed Project is inconsistent with Riverside County Airport Land Use Plan (RCALUP) that was created by ALUC. The Project is proposing a General Plan Amendment to the City’s General Plan and a Rezone in order to allow for mixed development uses on the Project site that will conflict increase site density and intensity and as such, will be inconsistent with Airport Land Use policies and General Plan policies related to airport compatibility. As a result, the Project will cumulatively contribute to impacts regarding safety hazards with regard to airport land use compatibility.

Thus, the proposed Project’s contribution to hazards and hazardous materials is cumulatively considerable. Therefore, cumulative impacts are significant and unavoidable and a statement of overriding considerations would be required prior to Project approval.

7.1.9 Land Use
Utilizing the summary of projections method, the geographic scope for land use and planning are the adjacent cities of Jurupa Valley and Moreno Valley, and the County of Riverside for the development projected under the buildout of their respective general plans. Cumulative land use impacts would result if growth resulting from the proposed Project would conflict with land use plans and/or policies, or state planning initiatives. Cumulatively, the Project will allow for higher density residential development amid other future development projects within the City and region that may impact existing land uses within the area. The proposed Project would amend the General Plan and re-zone the site so would modify regulations governing land use and development in the City. The proposed Project does not propose to modify or revise any of the existing specific plans within the City and as such will not conflict with those local plans. As discussed in Section 6.0 – Consistency with Regional Plans of this DEIR, the proposed Project is consistent with the 2020-2045 SCAG RTP/SCS. Because the proposed Project would be consistent with and/or supplement adopted plans and regulations governing land use and development in the region, it would not make a considerable contribution to cumulative impacts.

While the Project would represent a shift in land use policy for the site, the Project would not impact adjacent development and is representative of the surrounding land use pattern. Hence, the Project City of Riverside Section 7
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would not result in a substantial alteration to the planned land use of an area. Further, the Project is consistent with State planning initiatives, such as SB 2, SB 9, and SB 743. As the proposed Project is consistent with these planning initiatives, the proposed Project’s impacts to land use and planning would not be cumulatively considerable.

However, the Project will result in an inconsistency with the general plan policies related to airport land use because of the projects inconsistency with Riverside County Airport Land Use Plan policies so will result in significant and unavoidable impacts. Thus, the proposed Project’s contribution to land use and planning is cumulatively considerable. Therefore, cumulative impacts are significant and unavoidable and a statement of overriding considerations would be required prior to Project approval.

7.1.10 Noise
Utilizing the summary of projections method, the geographic scope for construction and operational noise and vibration impacts is the immediate vicinity of the Project site because noise and vibration by definition are a localized phenomenon, which drastically reduces in magnitude as the distance from the sources increases. Consequently, only those cumulative projects within the immediate vicinity of the Project will be likely to contribute to cumulative noise and vibration impacts resulting from construction or operation. Standard conditions of approval for future implementing projects will ensure no unnecessary temporary noise would impact nearby uses.

Any potentially significant cumulative impacts from construction-related Project noise will be reduced to less than significant as the Project and other cumulative projects would be required to comply with the regulations identified in Section 5.8 – Noise of this Draft EIR.

Cumulative noise impacts may occur when Project-related vehicular trips are combined with vehicular trips from the cumulative projects. This noise may be perceived by receptors along the nearby roadways near the Project site. Therefore, the geographic scope for cumulative traffic noise are the roadway segments that will be used by Project-related traffic. The cumulative traffic noise condition is the Future Buildout (2045) with Project traffic. As indicated in Section 5.8 – Noise, traffic noise increase from the Project results in less than 1 dBA CNEL and would not be perceptible to the average person so is considered less than significant.

The proposed Project’s contribution to noise would be less than significant with mitigation and is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.11 Population/Housing
Utilizing both the list and summary of projections method, the geographic scope for population and housing is the City of Riverside. Cumulative impacts related to population and housing resources are based upon projected development under the City General Plan. Implementation of the proposed Project and cumulative development projects may contribute to significant cumulative impacts to population and housing if they would induce substantial population growth or displace substantial numbers of existing housing units requiring the construction of replacement housing. Implementation of the Project will not displace any existing housing. As discussed in Section 5.10 – Population and Housing implementation of the Project would not result in a significant growth to the area, as the general plan for the City of Riverside had analyzed estimated projections that are greater than that proposed by Section 7 City of Riverside
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the Project. Additionally, the Cumulative Development Projects identified in Table 7.0-A do not propose residential uses.

Indirect population growth may indirectly induce population growth in the short term and long term because of new employment opportunities. However, it is anticipated that the extent to which the new jobs are created by cumulative development projects are filled by existing residents in nearby surrounding areas. Based on Section 6.0 – Consistency with Regional Plans, Southern California Association of Governments (SCAG) adopted the Connect SoCal 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) which anticipated the City’s population growth in 2045 to be 395, 800 persons and employment to increase to 188,700 in 2045. The Phase I General Plan Update (GPUI) acknowledged SCAG’s projections however, utilized a more conservative approach and projected a population of 431,685 by 2045; projecting a higher buildout population than SCAG’s SoCal RTP/SCS projections (GPUI, p. 3.9-17). Further, while the Project would incrementally increase the City’s buildout population, it would contribute less than one percent which is not considered significant. Thus, the proposed Project’s contribution to population/housing is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.12 Public Services
Public services include fire protection, police protection, libraries, and schools. Utilizing the summary of projections, the geographic scope for public services is the service area of each of the service providers as discussed in Section 5.10 – Public Services of this Draft EIR.

Riverside Fire Department (RFD) provides fire protection for the City. RFD’s major facilities include 14 fire stations throughout the City, administration and prevention offices, an Emergency Operations Center, and a training center. Riverside County Fire Department provides service to the unincorporated territory within the City’s Sphere of Influence. The Riverside Police Department (RPD) provides police protection services to the City from four stations. The City is served by two public school districts: Riverside Unified School District, which has 47 schools, and Alvord Unified School District, which has 23 schools. There is also one charter school serving the City: River Springs Charter. Riverside Public Libraries maintain eight existing libraries that serve the City. Four university and college libraries also serve the City.

As additional development occurs within the geographic context, there would be an overall increase in the demand for public services, which could cause physical deterioration of existing facilities. However, implementation of the Project would be consistent with the Public Safety Element of the City’s 2025 GP.

Increases in demand are routinely assessed by fire and law enforcement agencies as part of the budgeting processes so are anticipated to be adequate to accommodate future growth in the City.

These assessments are partially accomplished through collection of development impact fees. Similarly, school districts routinely assess increases in growth and would ensure that there would be sufficient school facilities to accommodate associated population growth through collection of development impact fees. Other cumulative projects in the region would also require collection of development impact fees to accommodate increases in demand for public services. These fees would be utilized to help fund construction of required new or expanded facilities, and the impacts of such development would be analyzed at a project-specific level.

Thus, the proposed Project’s contribution to public services is not cumulatively considerable. Therefore, cumulative impacts are not significant.

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7.1.13 Recreation
Utilizing the summary of projections method, the geographic scope for recreation is the City of Riverside. The Project consists of the addition of approximately 388 new dwelling units and as such, would increase population leading to an increased need for parks and recreational facilities. However, the proposed Project will include a pool and clubhouse for resident use as well as pedestrian promenade, dog park and other open spaces for public use. Nonetheless, Project would still be required to comply with MC Chapter 16.60 – Local Park Development Fees to help reduce impacts to parks and recreational facilities. Cumulative development may result in impacts to local city parks and regional parks. However, all new development will be required to comply with applicable fees and regulations to mitigate impacts of the new development. Cumulative projects would be required to meet Quimby requirements, comply with parkland dedication mitigation fees required by the City’s MC Chapter 16.60.

Thus, the proposed Project’s contribution to recreation is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.14 Transportation
Utilizing both the list and summary of projections method, the geographic scope for transportation is the City of Riverside. The City is connected regionally by California State Route 91 (SR-91) and SR-60, Interstate 215 (I-215) and I-15. Both SR-91 and SR-60 are major east-west interregional facilities that extend from the beach cities in Los Angeles County to the Inland Empire. Both I-215 and I-15 are northsouth interstate routes that provides access to Temecula and San Diego County. The roadway network within the City consists of freeways, boulevards, arterials, collectors, and local streets. The roadway network classifications were developed to guide long range transportation planning within the City to balance access and capacity.

The project-specific TIA identified that under Horizon Year (2045) Without Project traffic conditions, the following study area intersection is anticipated to operate at an unacceptable LOS during one or more peak hours:
 California Avenue & Arlington Avenue (#7) – LOS E AM peak hour only The project-specific TIA identified that the Project is not anticipated to result in any new deficiencies from those identified under Horizon Year (2045) Without Project traffic conditions. The intersection of California Avenue & Arlington Avenue (#7) is not anticipated to increase the delay by 2 seconds or more.

Additionally, the deficiency at this location is for the northbound movement. The proposed Project driveway on the north leg is anticipated to operate at an acceptable LOS C.

Traffic projections for Horizon Year (2045) with Project conditions were derived from the latest Riverside Transportation Analysis Model (RIVCOM). The Horizon Year (2045) conditions analysis was utilized to determine if improvements funded through regional transportation fee programs, such as the Development Impact Fee (DIF) program or Western Riverside Council of Governments (WRCOG) Transportation Uniform Mitigation Fee (TUMF), or other approved funding mechanisms can accommodate the long-range cumulative traffic at the target level of service (LOS) identified by the City of Riverside. Other improvements needed beyond the “funded” improvements (such as localized improvements to non-DIF facilities) are identified as such. (URBAN, p. 4).

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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 – Traffic and Transportation of this Draft EIR. While LOS is not a determining factor of consideration, the City does include GP policies related to LOS. As such, in the cumulative project condition, the Project remains inconsistent with GP policy.

The Project site is in TAZ 2022, which is located in a low VMT generating area. Due to the Project site being located in a low VMT generating area, the Project site was screened out from further VMT analysis for the residential portion. The retail portion of the Project was analyzed separately, however due to the square footage of the commercial area being less than 50,000 (SF) the Project site was considered a local-serving Project. Hence, is screened from further VMT analysis so is not considered to contribute cumulatively.

The precise timing of future development that would occur to reach General Plan buildout cannot be determined presently because of the complex nature of land development. It is anticipated that as development proceeds, each development will pay for and construct GP level road improvements on roads adjacent to the development sites and would pay “fair share” fees, development impact fees (DIF) or regional transportation fees for use by local jurisdictions to construct road improvements necessary to address the cumulative impact of area-wide development. However, the timing of road improvements needed to improve levels of service on a regional basis would be determined by City of Riverside based upon need and the availability of funding.

The priority and timing of these road improvements cannot be determined at this time, nor are they under the sole control of the project proponent and in case of other jurisdictions, the City, to implement.

Hence, it is possible that the required improvements will not be constructed in time to mitigate the Project’s cumulative impacts upon off-site intersections and roads to below the level of significance.

Thus, even after paying DIF and regional County Traffic Uniform Mitigation Fees (TUMF) to offset any regional traffic related deficiencies, while the Project’s cumulative traffic-related impacts would be reduced to less than significant, impacts would remain significant until such time as the improvements are completed. Further, the above mentioned intersection would continue to operate at an unacceptable LOS until improvements are completed, which would conflict with General Plan policies addressing the circulation system in the cumulative condition. Because of the uncertainty of when improvements would be implemented in relationship to project development and since cumulative conditions would be inconsistent with General Plan Circulation policies, impacts are cumulatively considerable.

Therefore, impacts are significant and unavoidable and a statement of overriding consideration would be required to be adopted by the City prior to project approval.

7.1.15 Tribal Cultural Resources
Utilizing the summary of projections method, the geographic scope for cumulative impacts to tribal cultural resources (TCR’s) is defined by the cultural setting and territory of the prehistoric and historic people who occupied the area of southern California in which the City is located. The Project area is situated within Western Riverside County as part of the territory of the Cahuilla and perhaps Luiseño people. Cumulative projects in the Project area and other development in western Riverside County may City of Riverside Section 7
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result in the progressive loss of as-yet unrecorded archaeological resources. This loss, without proper mitigation, would result in an adverse cumulative impact.

As identified in Section 5.13 – Tribal Cultural Resources of this Draft EIR, no known significant Native American historic or archaeological resources are located on the Project site or in the Study Area and the Project is not located on any known cemetery so is not expected to disturb any human remains. Site preparation and construction activities associated with the cumulative development projects may result in cumulative impacts to TCR’s if any of these resources are present and no documentation, consultation, or preservation were being implemented throughout the region. However, implementation of mitigation measures MM TCR-1 through MM TCR-4 will reduce potential impacts to Native American resources during ground disturbing activities. Further, in the unlikely event of the discovery of human remains on the Project site, all activities in the vicinity of the remains shall cease and the contractor shall notify the County Coroner immediately, pursuant to California Health & Safety Code Section 7050.5 (HSC 7050.5) and California Public Resource Code Section 5097.98 (PRC 5097.98).

Since all local jurisdictions, including the City, are subject to local, State, and federal laws, including CEQA, cumulative impacts to cultural resources are less than significant. Potentially significant impacts are also reduced by utilizing the site development permit process, the CEQA process for individual projects, and the notification and consultation requirements of AB52 and SB18.

Thus, the proposed Project’s contribution to TCR’s is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.1.16 Utilities and Service Systems
Utilizing the summary of projections method, the geographic scope for cumulative impacts to utilities and service systems are the service areas of each utility provider as discussed in Section 5.14 – Utilities and Service Systems of this Draft EIR. Potable and non-potable water services will be provided by Riverside Public Utilities (RPU). The City’s Public Works Department (PWD) provides for the collection, treatment, and disposal of all wastewater through its Riverside Regional Water Quality Control Plant (RWQCP). And the Agua Mansa Transfer Station (formerly known as the Robert A. Nelson Transfer Station), and Badlands, Lamb Canyon and El Sobrante landfills provide for the collection and disposal of solid waste.

The Project includes water conservation elements and will be required to comply with all regulations that require new construction to design, install, and maintain water efficient landscapes in order to reduce the amount of potable water used. The proposed Project, when combined with the cumulative development projects, will increase water demands from RPU. RPU’s 2020 Urban Water Management Plan (UWMP) incorporates regional projections to ensure that planning efforts for future growth are comprehensive. As determined in Section 5.14 – Utilities and Service Systems of this Draft EIR, the future estimated potable water demand from the Project combined with the current demand would still be less than the supply available. Additionally, future development facilitated within the City would be built using new building standards for water efficiency and would be designed to use less water than existing development. Future development would also occur incrementally over time, based on market conditions and other factors, such that existing water services are not overburdened by substantially increased demands at any single point in time. In addition, compliance with the existing regulatory framework would ensure adequate water supplies are available to serve future development associated with the Project under normal, dry, and multiple-dry years. Thus, because water supplies exceed Section 7 City of Riverside
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cumulative water demand, the proposed Project’s contribution to water supply is not cumulatively considerable.

As discussed in Section 5.14 – Utilities and Service Systems of this Draft EIR, RPW has adequate capacity of 46 mgd to serve the Project in addition to the existing commitments. It is anticipated that RWQCP treatment facilities would be able to meet increased demand for wastewater. To serve future population growth facilitated by the Project, sewer lines would have to be expanded within the City; this could occur with other cumulative projects as well. While development other projects within the geographic context may require extension, relocation, and expansion of new sewer lines within the City, construction activities associated with future development would be subject to compliance with local, state, and federal laws, ordinances, and regulations, as well as any Project-specific mitigation measures necessary to ensure construction-related impacts are not significant. Additionally, cumulative projects would undergo separate CEQA analyses and implement mitigation measures as necessary to reduce impacts on wastewater demand and ensure consistency with applicable wastewater management plans.

For these reasons, the Project’s contribution, in combination with cumulative projects, to wastewater treatment is not cumulatively considerable.

The City has a comprehensive waste management program that ensures projects comply with wastereduction ordinances and programs. While there is a shortage of landfills statewide, recycling programs and regulations continue to evolve to help ensure adequate disposal capacity. Reasonably foreseeable future development would similarly comply with waste-reduction regulations. Development of the Project in conjunction with other cumulative projects within the geographic context for cumulative impacts would generate additional demand for solid waste services, depending on net increases in population, square footage, and intensification of uses. These projects would contribute to the overall regional demand for solid waste. Concurrent with the increased demand generated by past and present development, recycling programs are being improved and developed to reduce the amount of solid waste disposed of in landfills. Such programs help offset the demand associated with waste-generating development. Additionally, cumulative projects would comply with all waste-reduction requirements and be required to conduct separate CEQA analyses and implement mitigation measures as necessary to reduce impacts on solid waste disposal capacity. Further, Project would not generate solid waste in excess of state or local standards or impair the attainment of solid waste reduction goals. As identified in Section 5.14 – Utilities and Service Systems, the three landfills that serve the site have a combined remaining capacity of approximately 172 million cubic yards and the Project’s contribution to these facilities is minimal. As such, the Project’s adherence with local statues and regulations related to solid waste would not contribute to cumulatively considerable solid waste impacts.

Thus, the proposed Project’s contribution to utilities and service systems is not cumulatively considerable. Therefore, cumulative impacts are not significant.

7.2 Significant Unavoidable Adverse Impacts
This topic is intended to address any significant impacts that cannot be mitigated to below a level of significance (State CEQA Guidelines Section 15126.2). Specific impacts which cannot be avoided or eliminated if the Project is implemented have been discussed in detail throughout Section 5.0 - Potentially Significant Environmental Effects and Section 7.1 – Cumulative Impact Analysis. A summary of the areas in which impacts could not be reduced to a level below significance are summarized below.

Cultural Resources
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As outlined in Section 5.3 – Cultural Resources of this Draft EIR and Section 7.1.5 – Cultural Resources above, implementation of the Project will result in significant and unavoidable impacts to a potential historic resource because it involves demolition of a potential historic resource.

Greenhouse Gas Emissions
As outlined in Section 5.5 – Greenhouse Gas Emissions of this Draft EIR and Section 7.1.7 – Greenhouse Gas Emissions above, implementation of the Project will result in significant and unavoidable impacts to greenhouse gas emissions because its emissions exceed the numeric threshold used by the City.

Hazards and Hazardous Materials
As outlined in Section 5.6 – Hazards and Hazardous Materials of this Draft EIR and Section 7.1.8 – Hazards and Hazardous Materials above, implementation of the Project will result in an inconsistency with Riverside County Airport Land Use Commission policies so will result in significant and unavoidable impacts.

Land Use and Planning
As outlined in Section 5.7 – Land Use and Planning of this Draft EIR and Section 7.1.9 – Land Use and Planning above, implementation of the Project will result in an inconsistency with the general plan policies related to airport land use due the projects inconsistency with Riverside County Airport Land Use Compatibility Plan policies so will result in significant and unavoidable impacts.

Transportation
As outlined in Section 7.1.14 – Transportation above, the Project will result in cumulative transportation impacts. The priority and timing of these road improvements cannot be determined at this time, nor are they under the sole control of the project proponent and in case of other jurisdictions, the City, to implement. Hence, it is possible that the required improvements will not be constructed in time to mitigate the Project’s cumulative impacts upon off-site intersections and roads to below the level of significance. Further, an intersection will continue to operate at an unacceptable LOS in the buildout condition which is inconsistent with General Plan transportation policies. Therefore, the Project will result in significant and unavoidable impacts in the cumulative condition.

7.3 Growth Inducing Impacts
According to State CEQA Guidelines Section 15126.2 (e), a project may foster economic or population growth, or additional housing, either indirectly or directly, in a geographical area if it meets any one of the following criteria:

A project would remove obstacles to population growth;
Increases in the population may tax existing community service facilities, causing significant environmental effects; or
A project would encourage and facilitate other activities that could significantly affect the environment.

7.3.1 Removing Obstacles to Population Growth
As discussed in Section 3.0 – Project Description of this Draft EIR, the Project will foster population growth since it will allow for higher density residential uses. The Project is in an area that is surrounded by existing and proposed development for which regional infrastructure has either already been built or Section 7 City of Riverside
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has been approved through adopted master plans. As mentioned in Section 3.0 – Project Description the Project proposes off-site improvements within the roadway right-of-way to connect to electrical facilities located approximately 1.5 miles. Nonetheless 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 would remove an obstacle to growth.

7.3.2 Increases in Population that May Tax Existing Community Services As discussed in Section 5.10 - Population and Housing, the Project will provide an avenue to increase households within the City. However, as discussed in Section 5.11 – Public Services of this DEIR, while the Project will not have a significant impact upon public services such as police, fire, and schools.

Police and fire services are based upon response time. The Project will be required to contribute development impact fees which will be used to support these services. Hence, while the increase in population was not identified as part of the rate of growth projected under GP buildout projections, it will not impact existing service systems.

7.3.3 Encourage and Facilitate Activities that Significantly Affect the Environment
Implementation of the proposed Project will include population growth. However, given the development planned and projected under the City’s GP and the general plans of the surrounding jurisdictions, it is not anticipated that the Project’s potential to foster growth would lead to development not otherwise anticipated by the buildout of these general plans. The type and intensity of use proposed for the Project site will be consistent with the General Plan Amendment (GPA) and Rezone upon Project implementation.

However, as outlined in Section 5.6 – Hazards/Hazardous Materials and Section 7.1.8 above, implementation of the Project will result in an inconsistency with the RCALUP created by ALUC. The GPA and Rezone allowing for mixed uses on the Project site will increase site density and intensity which are not consistent with the Riverside County Airport Land Use policies and may contribute to safety hazards with regard to airport land use compatibility.

7.4 Irreversible Environmental Changes
The intent of this section of this Draft EIR is to discuss primary and secondary impacts of the proposed Project that result in significant irreversible changes in the environment. State CEQA Guidelines Section 15126.2(d) identifies, as examples, such things as use of nonrenewable natural resources, irreversible changes in land use, and irreversible damage to the environment resulting from environmental accidents associated with a project.

Development of the Project will require the commitment of the approximately 17 acres site. Projectrelated construction activities will entail the commitment of non-renewable and/or slowly renewable energy resources, human resources, and natural resources such as lumber and other forest products, sand and gravel, asphalt, steel, copper, lead, other metals, and water. An increased commitment of social services and public maintenance services (e.g., police, fire, and sewer and water services) would City of Riverside Section 7
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also be required. The energy and social service commitments would be long-term obligations. Given the financial and material investments that would be required of the Project applicant and the City, it is unlikely that the Project site would be returned to its original condition once it has been developed. See Sections 5.4 – Energy, 5.10 – Public Services, and 5.14 – Utilities and Service Systems of this Draft EIR for details.

The Project does include the development of the site which will be inconsistent with the airport land use regulations affecting Riverside Airport. Approval of the Project will result in an incompatibility that would be irreversible. Lastly, the Project includes the demolition of a structure that was found to be significant under CEQA related to historic resources. The loss of the structure would be considered irreversible.

7.5 Consistency with Regional Plans
Section 15125(d) of the State CEQA Guidelines also requires an EIR to “to discuss any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans.” The regional plans applicable to the proposed Project are: the City’s GP, the MSHCP, the SCAG RTP/SCS, Regional Water Quality Control Board (RWQCB), and the Air Quality Management Plan (AQMP). Table

7.0-B, Location in which DEIR Consistency with Regional Plans is Discussed, identifies the location in which each of these plans is discussed in this Draft EIR.

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Table 7.0-B, Location in which DEIR Consistency with Regional Plans is Discussed
Plan Discussion Location
Consistency
(Project / Cumulative)
AQMP Section 5.2 – Air Quality
(Related Regulations and Criteria Air Pollutants)
Yes / Yes
GP and GPUI
Sections 5.0 through 5.14
(Environmental impact analysis section for each
environmental issue under the heading “Related
Regulations”)
 5.1 – Aesthetics Yes / Yes
 5.2 – Air Quality Yes / Yes
 5.3 – Cultural Resources No / No
 5.4 – Energy Yes / Yes
 5.5 – Greenhouse Gas Emissions No / No
 5.6 – Hazards/Hazardous Materials No / No
 5.7 – Land Use and Planning No / No
 5.8 – Noise Yes / Yes
 5.9 - Population/Housing Yes / Yes
 5.10 – Public Services Yes / Yes
 5.11 – Recreation Yes / Yes
 5.12 – Transportation Yes / No
 5.13 – Tribal Cultural Resources Yes / Yes
 5.14 – Utility/Service Systems Yes / Yes
RWQCB
Section 5.14 – Utility and Service Systems
(National Pollutant Discharge Elimination System
Construction Permit)
Yes / Yes
SCAG
RTP/SCS Section 6.0 – Regional Consistency Yes
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8.0 Alternatives to the Proposed Project
An EIR must identify ways to mitigate or avoid the significant effects that a proposed project may have on the environment. The City, acting as the CEQA Lead Agency, is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. The range of alternatives addressed in an EIR is governed by a “rule of reason,” which requires the EIR to set forth only those alternatives necessary to permit a reasoned choice.

Of the alternatives considered, the EIR needs to examine in detail only those that the Lead Agency determines could feasibly attain most of the basic objectives of the proposed project but would avoid or substantially lessen any of the significant effects of the proposed project. Per State CEQA Guidelines Section 15364, “feasible” has been defined as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.”
The following discussion considers alternatives to implementation of the Project. The discussion examines the potential environmental impacts resulting from each alternative. Through comparisons of these alternatives to the Project, the relative advantage(s) of each can be weighed and analyzed. State CEQA Guidelines Section 15126.6 identifies the parameters within which consideration and discussion of alternatives to the proposed Project should occur. As stated in this section of the Guidelines, alternatives must focus on those that are potentially feasible and which attain most of the basic objectives of the Project.

The Initial Study prepared for this project determined the following topics to be less than significant and were therefore, not addressed in this Draft EIR: Agriculture and Forestry Resources, Biological Resources, Geology and Soils, Hydrology and Water Quality, Mineral Resources, and Wildfire Hazards.

Of the topics that were addressed in this Draft EIR, Section 5.0 of this Draft EIR determined the following environmental topics to be less than significant:
 Aesthetic Resources
 Air Quality
 Energy
 Noise
 Population and Housing
 Public Services
 Recreation
 Tribal Cultural Resources
 Utilities and Service Systems
For the purposes of the alternative analysis, since none of these topics were determined to be significant, they are not included in the detailed analysis of the alternatives below to compare to the proposed Project.

8.1. Project Objectives
Per State CEQA Guidelines Section 15124 (b), an EIR needs to include a statement of the objectives of a project which helps the City develop a reasonable range of alternatives. The Objectives need to outline City of Riverside Section 8.0
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the general purpose of the Project. The Project Objectives are identified by the Project applicant as follows:

1. Primarily, provide quality, multi-family housing on an existing underutilized site, to help the City meet the State’s allocated 2021-2029 Regional Housing Needs Assessment (RHNA) housing unit numbers, as well as the City’s overarching self-prescribed housing unit numbers.

2. Place housing near a transit corridor to reduce residential vehicle miles traveled and associated congestion and greenhouse gas emissions.

3. Place housing near existing commercial uses to encourage pedestrian connectivity and to reduce vehicular usage and associated impacts.

4. Provide compatible mixed-use development contributing to the character of the surrounding neighborhood.

5. Establish a mixed-use development that will provide a land use transition between the existing commercial Hardman Center and the residential developments surrounding the project site.

8.2. Summary of the Project’s Significant Unavoidable Impacts The analysis in Section 5.0 of this DEIR determined that even with implementation of mitigation measures, significant environmental impacts will result from the operation of the proposed Project. To satisfactorily provide the CEQA-mandated alternatives analysis, the alternatives considered must reduce any of the following Project-related significant unavoidable impacts:
 Cultural Resources: Project and Cumulative Impacts
 Greenhouse Gas Emissions: Cumulative Impacts
 Hazards and Hazardous Materials: Project and Cumulative Impacts  Land Use: Project and Cumulative Impacts
 Traffic/Transportation: Cumulative Impacts

8.3. Rationale for Alternative Selection
State CEQA Guidelines Section 15126.6(a) requires that an EIR “…describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.” According to this section of the State CEQA Guidelines, “…an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. ” An EIR is not required to consider alternatives which are infeasible. The City, as lead agency, is responsible for selecting a range of Project alternatives for examination, and there is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the “rule of reason” (CEQA Guidelines Section 15126.6 (a)). Among the factors that may be considered when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to an alternative site. (CEQA Guidelines Section 15126.6 (f)(1)).

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With respect to the selection of alternatives to be considered in an EIR, State CEQA Guidelines Section 15126.6(b) states “…the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the Project Objectives or would be more costly.” That is, each alternative must be capable of avoiding or substantially lessening any significant effects of the proposed Project. For this Project, those significant effects are related to Cultural Resources (historical resources), Hazards and Hazardous Materials (airport land use compatibility), Land Use and Planning (inconsistency with airport land use compatibility), and Traffic/Transportation (cumulative). .

The rationale for selecting the alternatives to be evaluated, and a discussion of the “no project” alternative are also required (State CEQA Guidelines§ 15126.6(e)). The “no project” alternative in this case, means no development would take place within the site limits and the existing building would remain with current zoning of General Commercial. The other alternatives evaluated in this DEIR were selected based on their ability to reduce or avoid impacts to Cultural Resources, Hazards and Hazardous Materials, Land Use and Planning, and Traffic/Transportation (Cumulative).

8.4. Alternatives Rejected From Further Consideration
Section 15126.6(c) of the CEQA Guidelines specifies that an EIR should identify alternatives that were considered by the lead agency but were rejected during the scoping process and identify the reasons for eliminating the alternatives from further consideration. Section 15126.6(c) further indicates that a lead agency may eliminate an alternative from detailed consideration in an EIR if it fails to meet the basic Project Objectives, is infeasible, or does not avoid significant environmental impacts.

1. No Change/Status Quo Scenario

2. Alternative Location

3. Other Uses Considered for Site – Storage Facility

8.4.1. No Change/Status Quo Scenario
Under the No Change/Status Quo Scenario, no development (including demolition) would take place within the Project site limits. No ground-disturbing activities would take place, nor would any form of structure be erected. Under this scenario, which was rejected as an Alternative, the site would remain in existing conditions and the site would not be developed as proposed or for any other use. The current site is the abandoned Sears building which is a source of nuisance to the neighborhood and is subject to transient attention which has resulted in on-going security issues. This No Change/Status Quo scenario would greatly underutilize the Project site and would not meet any of the Project Objectives. Section 15126.6(f)(1) of the State CEQA Guidelines states that among the factors that may be considered when addressing the feasibility of alternatives, are site suitability and economic viability. Although in the shortterm this scenario may be feasible to allow the site to remain unutilized and for the historic structure to remain on site, over the long-term, it is expected that the owners of the site would seek some productive use of this property and that the Project site would therefore be developed in some form. Additionally, the vacant aspect of the site will continue to represent a place where homeless individuals and other transient individuals trespass illegally and create issues with law enforcement and potential safety issues with the existing surrounding uses. Thus, since it can be reasonably anticipated that the site would develop in some form given its already entitled condition, this No Change/Status Quo scenario was rejected as an Alternative. Therefore, this scenario was not further considered.

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8.4.2. Alternative Location
Moving the Project to another site may potentially avoid significant impacts identified with the demolition of the existing Sears structures, which are considered historic and significant. It is required under CEQA that alternative site(s) be evaluated if any feasible sites exist where significant impacts can be lessened.

The environmental impacts of development on any other site in the City are expected to be similar to those of the proposed Project related to the proposed use. However, the demolition of a historic resource, as well as the airport land use incompatibility could be avoided by another site. An alternative site of similar size (approximately 17 acres), surrounded by existing utilities and access, was researched.

Although there are other 17-acre sites in the City, the other sites of this size are either not of the current zoning or General Plan designation to support the Project, and so would result in the same need to change the zone and general Plan designation as the Project does, or the other sites are located in incompatible areas such as surrounding by Industrial, rural residential, agricultural, or public facility sites.

The other site locations also offer incompatibility issues, as does the Project with the incompatible airport zones. Figure 8.0-1, Viable 17+Acre Parcels Zoning Map depicts the areas where similar locations with the corresponding zoning and general plan designations. Given that the Project proposes a General Plan Amendment and Rezone to allow for commercial-retail and high-density residential uses, there appear to be no compatible sites available. Therefore, this alternative was not further considered.

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8.4.3. Other Uses Considered for the Site
Other uses considered but rejected for consideration included a Self-Storage Facility. The existing Sears Department Store building is approximately 178,426 square feet in size which is significantly larger than typical self-storage facilities which are approximately 50,000 sf in size. A viable self-storage tenant would require multiple units that have access to the exterior of the building. This would require the addition of numerous exterior doors and cutting openings in the building. However, in doing so, the existing exterior walls of the building would not be of much use for seismic loads imposed on the structure by current code requirements, especially due to removal of the wall for creation of additional openings for storage access. For seismic requirements, the existing exterior walls would need to be reinforced with new walls inside of existing exterior walls and associated vertical elements from these walls would need to be transferred down to the lowest foundation level with new foundations.

To utilize the existing building, it would need to be modified to reinforce and significantly upgrade the ground level building slab in order to accommodate loading parameters required for this type of use which are 2.5 times higher than the currently allowable loading for the existing structure for a one-story storage structure. Upgrades would likely require the addition of an entirely new slab. Given that the exterior walls are supported by basement foundations and new supports would be supported on grade, this introduces potential differential settlement issues between the new building supports and existing building wall supports which would not be structurally acceptable. Support in the basement would be needed, foundations would need to be added, and existing foundations would need to be upgraded. If multiple levels of are desired for a storage facility, utilization of the existing structure would be impossible. (INNOVA, pp. 2-3).

In addition to the structural infeasibility, use of the existing Sears Department Store building as a SelfStorage Facility would not be a viable option due to the likely failure to attract a self-storage tenant.

There is already a sufficient number of Self-Storage Facilities in the market. The area around the Project site also has very little population growth or decline and the large majority (63.7 percent) of nearby housing units are owner-occupied as opposed to renters. Little fluctuation in population coupled with a low percentage of renters which tend to have a higher need for storage units decreases the viability of a Self-Storage Facility at this location. Finally, existing Self-Storage facilities in the City are “horizontal”, allowing users to drive to their garages and unload directly from a truck. “Vertical” or stacked storage facilities, as would be implemented in the existing Sears Department Store building, require users to unload, utilize a freight elevator, and wheel items down a corridor to their lockers, adding time and labor, and further decreasing viability. (AXIOM, p. 5).

Hence, utilizing the existing building as a self-storage facility was considered, but ultimately rejected by the Project proponent because of the structural issues required for this adaptive reuse, as well as the low viability of the use. Further, this other use would not meet the key Project Objective of meeting the City’s RHNA allocations. Therefore, this alternative was not further considered.

8.5. Alternatives under Consideration
This section of the Draft EIR presents the analysis of four alternatives in comparison to the potential environmental effects associated with the proposed Project. In accordance with State CEQA Guidelines Section 15126.6(d), the discussion of the environmental effects of the alternatives may be less detailed than the discussion of the impacts of the proposed Project.

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This section of the Draft EIR presents the analysis of four alternatives in comparison to the potential environmental effects associated with the proposed Project. In accordance with State CEQA Guidelines Section 15126.6(d), the discussion of the environmental effects of the alternatives may be less detailed than the discussion of the impacts of the proposed Project. The following Project Alternatives have been identified for their potential to reduce impacts related to the proposed Project:
 Alternative 1: No Project/No Demolition/Keep Existing Commercial Designation  Alternative 2: Adaptive Reuse to Residential
 Alternative 3: ALUC Consistent
 Alternative 4: Reduced Density
Each Alternative is described below and followed by:
 Alternative’s Impact Analysis: a discussion of environmental topics evaluated in this Draft EIR that were found to be potentially significant as a result of the proposed Project and the Alternative’s ability to reduce impacts over the proposed Project;  Relationship of Alternative to Project Objectives: the Alternative’s ability to achieve the proposed Project’s objectives; and
 Alternative Conclusion: the Alternative’s feasibility.

A comparison of Alternatives is presented in a matrix in Section 8.6, below.

8.5.1. Alternative 1: No Demolition/Keep Existing Commercial Designation
Alternative 1 involves keeping the existing 178,426 sf Sears building in its current condition with basement and ground level, along with maintaining the existing zoning designation of General Commercial. Under this Alternative the existing building will remain as is, and no demolition would occur. The use of the site under this Alternative assumes that another large commercial retailer could move into the building as is. However, under this Alternative, the current vacant status of the site would not occur, as it is expected that another company would want to use the whole retail building without having to demolish the main Sears Department Store building. This Alternative could instead, entail the demolition of the non-historic automotive service ancillary building.

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Alternative’s Impact Analysis
Cultural Resources
This Alternative would not require demolition of the existing structures. However, the existing structures do not meet current building codes. A large new retail use would still trigger the need for significant building upgrades and reconstruction in order to meet current building codes, which would result in significant changes to the existing structure. Even if the site were to be occupied by another retail use, because of the need to meet current building and seismic codes, the remodeling would be significant and would most likely result in structure changes that would detract from the historical significance of the existing structure. Like the proposed Project, this Alternative would result in impacts related to historical resources. Therefore, impacts related to cultural resources would be similar to that of the proposed Project.

Greenhouse Gas Emissions
This Alternative would not result in demolition of the existing building; however, it would include future commercial uses. It is expected this Alternative would result in greater GHG impacts than the Project since commercial uses typically generate more vehicle trips than residential uses on a per unit basis. As shown in Table 4-3 of the Project’s TIA (Appendix F), the existing commercial use could generate 1,326 more daily vehicle trips compared to the proposed Project. Therefore, Alternative 1 would result in greater impacts than the Project.

Hazards and Hazardous Materials
The existing structures are located entirely within Riverside County Airport Land Use Compatibility Plan (RCALUCP) Zone B1. As discussed in Section 8.5.4 below, B1 is the most restrictive land use compatibility zone allowing an average acre intensity of 25 people per acre and a single acre intensity of 50 people per acre. Utilizing RCALUCP’s Appendix C – Determining Concentrations of People; specifically Table C1: Occupancy Levels – California Building Code, this Alternative would result in 189 people per average acre1 which is not consistent with RCALUCP policy.

Issues related to hazardous materials, such as the presence of asbestos and potentially lead-based paint present in building materials of the existing Sears building would remain present under this Alternative. And any future removal of these materials would require legal removal and disposals.

Impacts related to Hazards and Hazardous Materials would be similar to that of the proposed Project.

Land Use and Planning
Because this Alternative would be inconsistent with RCALUCP policy, it would also result in an inconsistency with the City’s GP 2025 land use policies related to airports. Therefore, impacts related to Land Use and Planning would be like that of the proposed Project.

1. Based on use 27. Stores — Retail Sales Rooms Basements and Ground Floors, requires 30 square feet per occupant resulting in a potential of 2,974 people in the structure. To determine number of people per average acre, acreage of site located in Zone B1 as identified in ALUC-C, of 15.76 was utilized. (2,974 people / 15.76 acres = 189 people per average acre).

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Transportation
Under Alternative 1, the existing structures would simply be leased for commercial uses as they had been in the past. Under this Alternative, no demolition or new development would occur. As shown in Table 4-3 of the Project’s TIA (Appendix F), the existing commercial use would generate 1,326 more daily vehicle trips compared to the proposed Project. Therefore, Alternative 1 would result in greater impacts than the Project.

Relationship of Alternative 1 to Project Objectives
Alternative 1 assumes that the site would remain in its existing condition and redevelopment into a large retail commercial use which is consistent with the existing Commercial designation. An analysis of whether Alternative 1 meets each Project Objectives is provided in Table 8.0-A, Alternative 1: No Project/Development of Existing Land Use and Zoning Project Objectives Comparison below.

Table 8.0-A, Alternative 1: No Demolition/Keep Existing Commercial Designation Project Objective Alternative Meets Objective?
Primarily, provide quality, multi-family housing on
an existing underutilized site, to help the City’s
meet the State’s allocated 2021-2029 Regional
Housing Needs Assessment (RHNA) housing unit
numbers, as well as the City’s overarching selfprescribed housing unit numbers.

No. Alternative 1 will leave the existing structures in place.

Under this Alternative 1, the land use would remain
commercial-retail and the site would not provide quality multi-family housing nor would it meet the City’s goal to reach RHNA allocations.

Place housing near a transit corridor to reduce
residential vehicle miles traveled and associated
congestion and greenhouse gas emissions.

No. Alternative 1 would allow for retail use and would not place housing near a transit corridor.

Place housing near existing commercial uses to
encourage pedestrian connectivity and to reduce
vehicular usage and associated impacts.

No. Alternative 1 will not demolish the existing buildings and would not propose housing.

Provide compatible mixed-use development
contributing to the character of the surrounding
neighborhood.

No. Alternative 1 would keep the existing structures
commercial-retail designation and continue to use the site as a large box retailer. This Alternative would not meet this Objective because it would provide only commercial uses and not provide any residential component or amenities that would help contribute to the transitional character that a mixed-use development would provide.

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Table 8.0-A, Alternative 1: No Demolition/Keep Existing Commercial Designation Project Objective Alternative Meets Objective?
Establish a mixed-use development that will
provide a land use transition between the existing
commercial Hardman Center and the residential
developments surrounding the project site.

No. While Alternative 1 would keep the existing structures and commercial-retail designation for the continued use of the site as a large box retailer, it would not establish a mixed-use development because no other land uses would
be provided. The site under existing conditions does
transition from the Hardman Center to the surrounding
residential projects. However, maintaining the existing designation and structures, does not offer the residential component or amenities as a mixed-use development, that would provide better transitional characteristics, that would be provided by the proposed Project.

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Alternative 1 Conclusion
Alternative 1 has the potential to reduce cultural resource impacts as it relates to the Project.

Nonetheless, implementation of Alternative 1 would require a level of reconstruction to the existing building structure and thus would still reach the same conclusion. The site would reach the same conclusions for hazards/hazardous materials and land use planning as the proposed Project because the existing commercial designation is not consistent with RCALUCP policy, nor was the former big box retail use. Moreover, Alternative 1 would result in greater impacts as it relates to transportation and GHG as full commercial use of the site would result in a higher trip generation rate than that of the Project.

Additionally, while air quality and noise impacts were found to be less than significant for the proposed Project, because Alternative 1 results in greater traffic trips, it is anticipated that these topics would be greater than that of the Project due to increased emissions and roadway noise.

State CEQA Guidelines Section 15126.6(f)(1) states that among the factors that may be considered when addressing the feasibility of alternatives are site suitability and economic viability. Alternative 1 would satisfy none Project Objectives and would not meet the key Objective of providing additional housing to meet the City’s RHNA allocations. Additionally, the existing abandoned Sears building has been subject to extreme dismantlement and vagrancy and vandalism targeting electrical and mechanical systems within the structure.

Alternative 1 is not economically viable. The Sears building was designed for a single user. Large scale retailers requiring buildings the size of the abandoned Sears building are not choosing to locate near the Project site, instead opting for regional locations and developed shopping centers which attract larger volumes of customers. Demising the building into multiple smaller rental suites is also not possible as it would be difficult to create basic shells and floorplates for modern, creditworthy tenants. The building also has nearly 50% of its total floor area in the form of a subterranean basement which is not desirable space for the vast majority of retailers to whom this property would be marketed. (AXIOM, p. 4).

Further, according to Innova, many of the building’s systems have been removed/stolen and there are significant gaps between the structural integrity of the existing building and the current building codes thereby requiring significant modifications that in and of themselves could result in partial or full demolition of the building. Even if a new large retail use would still trigger the need for significant building upgrades and reconstruction, meeting today’s current building codes, which would result in significant changes to the existing structure. Even if the site were to be occupied by another retail use, because of the need to meet current building and seismic codes, the remodeling would be significant and would most likely result in structure changes that would detract from the historical significance of the existing structure. Additionally, a new retail user would also be subject to new approvals by the City for building permits and occupancy, both of which would trigger the need for compatibility study with the existing airport land use plan. A new retail use would also not meet the density requirements of the airport land use plan, and therefore Alternative 1 would still be considered incompatible with the airport.

Therefore, Alternative 1 is rejected and considered infeasible.

Thus, since Alternative 1 would most likely result in the same or similar impacts to the existing structure, its historical context and significance would also be impacted. Therefore, Alternative 1 is considered not feasible, and does not meet most of the Project Objectives.

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8.5.2. Alternative 2: Adaptive Reuse to Residential
Since the Proposed Project includes the full demolition of the Sears Building, which would result in a significant and unavoidable impact to a historical resource (See Cultural Resources Section), Alternative 2 proposes keeping the existing Sears building and adaptively reusing it for residential uses only. This Alternative would provide a range of 44 to 140 residential housing units. Under this Alternative, the demolition of the whole building would not occur, and some, but not all of the existing building could still be retained. Under this Alternative, the resulting land uses would need to fit into the existing building footprint primarily and any historically significant attributes of the building would need to be retained which involve the Mid-Century Modern style of architectural.

Characteristics of this type of architecture include: Simple geometric forms, post-and-beam construction, flat or low-pitched gabled roofs, flush mounted steel framed windows or large singlepaned wood-framed windows, exterior staircases, decks, patios, and balconies, and brick or stone often used as primary or accent material. Characteristics of the department store typology include: large surface parking lots surrounding the building, being disconnected from the street, windowless design, free-standing building, one to two stories in height, boxlike massing, and located outside of urban centers. The existing structures include all of the characteristics of department store typology and include such attributes as solid wall surfaces; rectangular shape with flat roof, clad in concrete, brick, tile, and stone; rectangular roof overhangs that wrap around the building; textured tile above the old signage; rock wall entrances; and trees integrated into the corners.

Rehabilitation and adaptive reuse of the building under this Alternative would follow the Secretary of the Interior’s Standards for Rehabilitation (Standards). If properly executed in conformance with the Standards, rehabilitation and adaptive reuse of the Sears department store and auto center building as part of a new development plan for the site would reduce project-related impacts to historical resources to a less-than-significant level and meet the preservation objectives of the City of Riverside to protect its important historic resources and encourage public accessibility of resources.

For Alternative 2, several residential densities and configurations were studied by Architects Orange and Innova for viability and historic and structural integrity as found in Appendix C of this Draft EIR. Four options with various numbers of residential units ranging from approximately 44 to 140 units were studied. All four options would require structural improvements to bring the building into compliance with current building codes and make it seismically safe.

Additionally, since the existing building currently consists of mostly solid walls, with little to no windows or openings besides the doors, transforming the existing building into residential units would require a certain amount of fresh air ventilation and windows/daylight. Creating ventilation, incorporating private open space through balconies/patios and installing windows would likely result in structural issues.

Transforming the existing building would require removing not only the roof, but the walls of the existing building. The analysis in Appendix C included considering removing the roof and leaving two walls intact however by doing so, this would then result in significant changes to the building that would not provide preservation of the historical aspect of the existing building (i.e. example of early-era big box retail).

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Alternative’s Impact Analysis
Cultural Resources
This Alternative would not require demolition of the existing structures. However, the existing structures do not meet current building codes and would need modification to transform the structure into residential units. To meet current building and seismic codes, remodeling of the structures would be significant and result in structural changes that would detract from the historical significance of the existing structures and would not be consistent with the Standards as there would be impacts to features and spaces that characterize a property. Efforts to preserve the existing structures the structures would be significantly altered to affect the historical context of the resources. Therefore, impacts related to cultural resources would be reduced from that of the proposed Project but will still be categorized as significant and unavoidable as was concluded by the proposed Project.

Greenhouse Gas Emissions
This Alternative would result in residential development and buildings which would still generate GHG emissions, like the Project. However, given that less than 40 percent of the dwelling units would be proposed under this Alternative, and that no commercial uses are proposed, impacts related to GHG will be substantially reduced and likely fall below the significance threshold. Therefore, this impact would less than the proposed Project.

Hazards and Hazardous Materials
This Alternative would be inconsistent with RCALUCP policy, as the existing structures are currently inconsistent with building height requirements outlined in the RCALUP policy. Adaptation of the existing structure into residential units would result in an inconsistency with RCALUCP policy since most of the site is located within RCALUCP Zone B1 which has density standards making residential development prohibitive.

Additionally, the asbestos and potential lead-based paint in the existing building materials would still be present and have to be legally disposed of in order to reuse the site and make it residential. Therefore, impacts related to Hazards and Hazardous Materials would be similar to that of the proposed Project.

Land Use and Planning
This Alternative would be inconsistent with RCALUCP policy. As such, this Alternative would conflict with the City’s GP 2025 policies related to airports. Therefore, impacts related to Land Use and Planning would be similar to that of the proposed Project.

Transportation
Under this Alternative, the site would still develop with residential uses. Development of the site with these uses would result in passenger vehicles trips to and from to the site and the City would require applicable roadway improvements for any project. Even if this Alternative was not built as contemplated, another project would still be conditioned to build any necessary roadway improvements and contribute fair share fees. As such, cumulative impacts to transportation/traffic would remain significant since the priority and timing of road improvements are not under the sole control of a project proponent. Thus, this Alternative would result in similar cumulative traffic impacts. Therefore, Project impacts to cumulative transportation/traffic would be similar to that of the proposed Project.

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Relationship of Alternative 2 to Project Objectives
The Adaptive Reuse Alternative envisions using the existing building for future residential uses, instead of demolishing the existing building. An analysis of whether Alternative 2 meets each Project objective is provided in Table 8.0-B, Alternative 2: Adaptive Reuse Project Objectives Comparison.

Table 8.0-B, Alternative 2: Adaptive Reuse to Residential Project Objectives Comparison Project Objective Alternative Meets Objective?
Primarily, provide quality, multi-family housing on an
existing underutilized site, to help the City’s meet the State’s allocated 2021-2029 Regional Housing Needs
Assessment (RHNA) housing unit numbers, as well as
the City’s overarching self-prescribed housing unit
numbers.

Yes but to a lesser degree. Alternative 2 would allow for multifamily housing, however but only provide a range of units from 44 to 140 units given the constrains the existing structure would place on the ability to reuse the existing structure.

Place housing near a transit corridor to reduce
residential vehicle miles traveled and associated
congestion and greenhouse gas emissions.

Yes. Alternative 2 would place housing near a transit
corridor and could allow for less congestion and
greenhouse gas emissions.

Place housing near existing commercial uses to
encourage pedestrian connectivity and to reduce
vehicular usage and associated impacts.

Yes. Alternative 2 would place housing near existing
commercial uses and still provide pedestrian connectivity.

Provide compatible mixed-use development
contributing to the character of the surrounding
neighborhood.

No. Alternative 2 not provide mixed use development.

Under this Alternative there would not be a commercial
component to which there could be mixed use
contributions to the surrounding neighborhood.

Establish a mixed-use development that will provide a
land use transition between the existing commercial
Hardman Center and the residential developments
surrounding the project site.

No. Alternative 2 does not include mixed use
development. Under this Alternative there would not be a land use transition of mixed use between the Hardman
Center and the surrounding residential areas.

Alternative 2 Conclusion
Alternative 2 Adaptive Reuse was studied and considered. However, as identified in Appendix C, adaptive reuse and the need to meet the current building code, presents issues that would compromise the integrity of the building or the safety of the occupants. Alternative 2 meets three out of the five Project Objectives. However, this Alternative does not provide any mixed uses so it only partially meets the Objectives related to bringing mixed uses to the City, and only partially meets the key Objective of helping the City meet its RHNA obligations. As outlined above in Section 8.4.3, the marketability of the site being adaptively reused is very difficult related to the existing building codes and the type of structure remaining. Additionally, this use would also still not be compatible with the airport land use plans, which would still require a statement of overriding considerations overrides as does the proposed Project.

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Given the significant reconstruction and reconfiguration of the existing building that would need to take place to accomplish adaptive reuse, and that any adaptive reuse would still be considered incompatible with the airport land use plan, Alternative 2 is rejected as infeasible.

8.5.3. Alternative 3: ALUC Consistent
Since the proposed Project is within a mile of the Riverside Municipal Airport and will include inconsistencies with the Riverside Country Airport Land Use Comparability Plan (RCALUCP), unavoidable and significant impacts will occur. Alternative 3 proposes an Alternative that utilizes the densities or intensities allowable per the current RCALUCP. As outlined in both Section 3.0 – Project Description and Section 5.6 – Hazards and Hazardous Materials of this Draft EIR, this Alternative is in Zones B1, C and D of the RCALUCP. As shown in Table 5.6-B of this Draft EIR, the RCALUCP has classified Zone B1 with a high noise impact and a high-risk level, Zone C has both a moderate noise impact and risk level, and Zone D has a moderate noise impact and a low risk level. Figure 3.0-7 of this Draft EIR shows the relationship of these zones to the Project site. The RCALUCP provides standards and criteria for both residential density and non-residential intensity. These standards and criteria are defined and discussed below.

Residential Density Standards
Density standards are used for residential uses. Density is determined by calculating the number of dwelling units per acre (du/ac). Zone B1 allows for a residential density standard of 0.05 du/ac on parcels greater than 20 acres in size and Zone C allows for a residential density standard of 0.2 du/ac on parcels greater than 5 acres in size. Zone D allows two options for residential density. Option – 1 allows for a residential density standard of 0.02 du/ac or less on parcels at least 5 acres in size while Option – 2 allows for a residential density standard above 5.0 du/ac on parcels that smaller than 0.2 acres (or 8,712 square feet). Table 8.0-C, Alternative 3: Allowable Residential Dwelling Units below, identifies the number of units that could be developed on the Project site within the respective Land Use Compatibility Zone to be consistent with the RCALUCP.

Table 8.0-C, Alternative 3: Allowable Residential Dwelling Units Land Use Compatibility
Zone
Available Acres for
Development1
Number of Dwelling Units Permitted
by Alternative 3
B1 15.76 02
C 1.07 03
D – Option 14 0.48 05
D – Option 24 0.48 06
Source: ALUC-C
Notes:

1. Acreages in each zone are based on those presented in ALUC Staff Report (ALUC-C).

2. Parcels are under 20 acres in size so no dwelling units may be developed.

3. Parcels are under 5 acres in size so no dwelling units may be developed.

4. Must choose one Option only.

5. Site parcels are under 5 acres in size so do not meet minimum acreage requirement. Therefore, no dwelling units may be developed.

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Table 8.0-C, Alternative 3: Allowable Residential Dwelling Units Land Use Compatibility
Zone
Available Acres for
Development1
Number of Dwelling Units Permitted
by Alternative 3

6. RCALUCP policy requires that parcels be less than 0.2 acres or 8,712 square feet in size and density must exceed 5 du/ac. This requirement precludes any City of Riverside multi-family residential zones with respect to meeting minimum lot size. The City’s R-1-8500 and R-1-7000 zones require a minimum lot size for 8500 and 7000, respectively. However, density in these zones would not meet RCALUCP requirement of at least 5 du/ac. (MC 19.100).

During the General Plan Housing Element update conducted in 2022 and 2023, the City created an opportunity sites inventory which considered placing residential development on suitable vacant and/or non-vacant sites throughout the City. The opportunity site inventory identified how zoning and development standards on each of these opportunity sites could facilitate housing for the City to meet its RHNA obligation. (GPUI, p. HE105.) The City considered various sites throughout the City and evaluated them against various suitability criteria and developmental constraints. One of the constraints used to eliminate a site from the opportunity site inventory was airport land use compatibility. Existence of Airport Compatibility Zones removed properties from consideration if the properties were in the most restrictive airport land use areas: A, B1, B2, C, C1, and C2 as set forth in the RCALUCP. Since the site is located in Zone B1 and C, the proposed Project, which otherwise would have been an ideal opportunity site for residential development, was removed from consideration due to its proximity to the Riverside Municipal Airport. As identified in Table 8.0-C above, there are no RCALUCP compatibility zones and City land use designations/zoning designations that align that would allow for development of residential units on this site. Thus, Alternative 3 would not have the ability to provide any residential dwelling units which would be consistent with these RCALUCP residential densities for Zones B1, C and D.

Non-Residential Intensity Standards
Intensity standards are used for non-residential uses. Intensity is determined by calculating the number of people generated by type of non-residential use per acre. Two measurements are required by ALUC to determine site intensity: Average Acre and Single Acre. Average acre intensity is the total number of people on a site divided by the total numbers of site acreage. (Total People / Total Project Site Acreage = Average people per acre). Single Acre intensity is the total number of people within a given one acre area based on type of non-residential use.

Based on the acreages provided in Table 8.0-C above, average acre intensity would be restricted to 25 people per acre in Compatibility Zone B1, 75 people per acre in Zone C, and 100 people per acre in Zone D. Single acre intensity would be restricted to 50 people per acre in Compatibility Zone B1, 150 people per acre in Zone C, and 300 people per acre in Zone D.

RCALUCP’s Table C1 – Occupancy Levels/California Building Code found within Appendix C - Determining Concentrations of People identifies the number of people generated based on use per square feet. A majority of the site is located within Zone B1 so non-residential uses would be restricted to uses and square footages that do not generate people beyond those numbers identified in Table 8.0- C above. An example of consistent non-residential structures that may be compatible with this site’s location would be warehouse or airport hangers (with no repair), similar in square footage to the existing Sears Department Store building. These uses require 500 square feet per occupant so are likely to generate intensity that is consistent with RCALUCP policy.

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Alternative 3 would include non-residential uses meeting the above requirements for consistency with RCALUCP Compatibility Zone B1.

Alternative's Density/Intensity
As shown on Table 8.0-C above, Alternative 3 would allow no residential dwelling units and develop non-residential uses such as a warehouse or airport hangers no larger than the current building square footage of approximately 178,000 sf. This Alternative would also include demolition of the existing Sears Buildings.

Alternative’s Impact Analysis
Cultural Resources
This Alternative would still involve demolition of the existing structures. Like the proposed Project, this Alternative would result impacts related to historical resources. Therefore, impacts related to cultural resources would be similar to that of the proposed Project.

Greenhouse Gas Emissions
This Alternative would not allow for the development of residential or commercial uses, as those would not be consistent with the RCALUCP. Therefore, the limited warehouse or airport hangers that could be developed on the site after demolition of the existing structure, would still generate some GHG emissions; however, it’s expected that the uses on Alternative 3 would generate far less GHG emissions due to a reduction in vehicle trips and Alternative 3 will likely fall below the significance threshold. It’s expected that impacts to GHG would be less than the Project.

Hazards and Hazardous Materials
This Alternative would develop the site consist with RCALUCP policy. As such, this Alternative may not result in a conflict with RCALUCP policy. However to be viable, it is assumed that this Alternative would comply with all other development standards related to non-residential intensity requirements such as building height, open space standards, and noise abatement. Conversely, implementing the types of uses associated with this Alternative may result in impacts related to the proposed uses and the adjacent sensitive receptors. Additionally, the asbestos and potential lead-based paint in the existing building materials would still be present and have to be legally disposed of in order to reuse the site and make it residential. Therefore, impacts related to Hazards and Hazardous Materials would be similar to that of the proposed Project.

Land Use and Planning
This Alternative would develop the site consistent with RCALUCP policy. However, to be viable, it is assumed that this Alternative would comply with all other development standards related to nonresidential intensity requirements and City development standards such as building height, open space requirements, setbacks, and noise abatement. As such, this Alternative would not conflict with City’s GP 2025 policies related to airports. Conversely, implementing the types of uses associated with this Alternative may result in impacts related to the proposed uses and the adjacent sensitive receptors and result in additional land use policy conflicts Therefore, impacts related to Land Use and Planning would be similar to that of the proposed Project.

Transportation
The City would condition roadway improvements as needed for any proposed project. Therefore, even if this Alternative was not built as contemplated, another proposed project would still be conditioned to City of Riverside Section 8.0
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build any necessary roadway improvements and contribute fair share fees as applicable. As such, cumulative impacts to transportation/traffic would remain significant since the priority and timing of road improvements are not under the sole control of a project proponent. While traffic volumes would be significantly lower under this Alternative, similar cumulative traffic impacts would still occur. Therefore, Project impacts to transportation/traffic would be similar to that of the proposed Project.

Relationship of Alternative 3 to Project Objectives
The ALUC Consistent Alternative would develop the site with no residential dwelling units and nonresidential uses such as a warehouse or airport hangers no larger than the current building square footage of approximately 178,000 sf. This Alternative would also include demolition of the existing Sears Buildings. An analysis of whether Alternative 3 meets each Project objective is provided in Table 8.0-D, Alternative 3: ALUC Consistent Project Objectives Comparison.

Table 8.0-D, Alternative 3: ALUC Consistent Project Objectives Comparison Project Objective Alternative Meets Objective?
Primarily, provide quality, multi-family housing on
an existing underutilized site, to help the City’s
meet the State’s allocated 2021-2029 Regional
Housing Needs Assessment (RHNA) housing unit
numbers, as well as the City’s overarching selfprescribed housing unit numbers.

No. Alternative 3 would not provide residential,
multifamily land uses, since none are considered
RCALUCP compatible.

Place housing near a transit corridor to reduce
residential vehicle miles traveled and associated
congestion and greenhouse gas emissions.

No. Alternative 3 would not include housing since non
would be allowed under the RCALUCP.

Place housing near existing commercial uses to
encourage pedestrian connectivity and to reduce
vehicular usage and associated impacts.

No. Alternative 3 not include housing since the
RCALUCP does not allow housing on this site.

Provide compatible mixed-use development
contributing to the character of the surrounding
neighborhood.

No. Alternative 3 would not allow for any residential
uses due to the proximity to airport so would not
provide any housing which would be a part of a mixed
use development.

Establish a mixed-use development that will
provide a land use transition between the existing
commercial Hardman Center and the residential
developments surrounding the project site.

No. Alternative 3 would not allow for any residential
uses due to the proximity to airport so would not
provide any housing which would be a part of a mixed
use development.

Alternative 3 Conclusion
Alternative 3 would result in similar impacts to cultural, hazards/hazardous materials and land use planning. Alternative 3 would likely result in fewer traffic trips and as such, result in less direct impacts related to air quality energy consumption, and noise impacts when compared to the proposed Project.

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However, Alternative 3 would also increase the sources of diesel exhaust in the Project area and therefore increase the health risks to nearby sensitive uses compared to the proposed Project.

However, all of these topics were found to be less than significant as part of the proposed Project.

Alternative 3 would result in less impacts to GHG than the Project and Alternative 3 would still result in similar impacts to cumulative traffic/transportation impacts. Alternative 3 would not satisfy any of the Project Objectives and does not meet the primary objective of the proposed Project, which is to provide additional housing to meet the City’s RHNA allocations. Given the nature of development that would occur on this site and its potential incompatibility with existing surrounding sensitive uses and potential for additional impacts, Alternative 3 is rejected as infeasible. Additionally, Alternative 3 would result in similar impacts to the existing structure so its historical context and significance would still be impacted.

Therefore, Alternative 3 is considered not feasible, and does not meet any of the Project Objectives.

8.5.4. Alternative 4: Reduced Density/Intensity
Although the Project does not include significant vehicle miles traveled impacts, nor does it result in significant air quality impacts, implementation of the Project will increase existing vehicle emissions which could increase existing impacts related to air quality due to the passenger vehicles generated by the Project. Additionally, the Project will result in significant impacts to greenhouse gases mostly because of the traffic generated by the proposed uses. Additionally, concerns were raised during the NOP comment period of additional traffic impacts in terms of level of service. However, it should be noted that in 2020, CEQA removed traffic impacts and level of service as areas of potential impacts that have to be evaluated. Rather, CEQA now addresses traffic impacts in the form of vehicle miles traveled (VMT). Based on all this, a reduced density alternative could alleviate some of these concerns. To reduce vehicle miles traveled as well as the greenhouse gas emissions, from the use of cars, Alternative 4 would propose to provide less residential units and less commercial square footage (25 percent reduction) in order to reduce vehicle trips as reflected in Table 8.0-E, Alternative 4 Density Reduction below. A 25 percent reduction was chosen as this is a typical reduction size to still allow for development that makes market sense so it would be realistic, but also allows for a reduction in the cars that would use the site that would also result in a valuable reduction of emissions.

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Table 8.0-E, Alternative 4 Density Reduction
Land Use Alternative 4
Reduced Density1 Proposed Project
Residential 291 Units 388 Units
Commercial 18,990 square feet 25,320 square feet
Notes:

1. 25 percent reduction from proposed Project
Alternative’s Impact Analysis
Cultural Resources
This Alternative would still require demolition of the existing structures. Like the proposed Project, this Alternative would result impacts related to historical resources. Therefore, impacts related to cultural resources would be similar to that of the proposed Project.

Greenhouse Gas Emissions
Alternative 4 would reduce the amount of the Project density by 25%. Even with this decrease in units and commercial square footage, it is expected that Alternative 4 would still generate total GHG emissions which exceed the 3,000 MTCO2E/yr threshold. The Project results in 7,374.37 total CO2, and a 25% reduction of that number could still exceed the 3,000 MTCO2E/yr threshold. Therefore, this Alternative would most likely have similar impacts as the Project; significant and unavoidable related to GHG.

Hazards and Hazardous Materials
As discussed in 8.5.3 above, the addition of any residential units beyond two units on this site, would result in inconsistency with RCALUCP policy. Thus, this Alternative would be inconsistent with RCALUCP policies. Therefore, impacts related to Hazards and Hazardous Materials would be similar to that of the proposed Project.

Land Use and Planning
As discussed in 8.5.3 above, the addition of any residential units beyond two units on this site, would result in inconsistency with RCALUCP policy. Since this Alternative would be inconsistent with RCALUCP policy, similar to the proposed Project, this Alternative would also conflict with the City’s GP 2025 land use policies related to airports. Therefore, impacts related to Land Use and Planning would be similar to that of the proposed Project.

Transportation
Under this Alternative, the site would still develop with residential and commercial uses. Development of the site with these uses would result in passenger vehicles trips to and from to the site but at a lower volume than the proposed Project. The City would require applicable roadway improvements for any project. Even if this Alternative was not built as contemplated, another project would still be conditioned to build any necessary roadway improvements and contribute fair share fees. As such, cumulative impacts to transportation/traffic would remain significant since the priority and timing of road City of Riverside Section 8.0
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improvements are not under the sole control of a project proponent. Thus, this Alternative would result in similar cumulative traffic impacts. Therefore, Project impacts to cumulative transportation/traffic would be similar to that of the proposed Project.

Relationship of Alternative 4 to Project Objectives
The Reduced Density Alternative would develop the site as a smaller mixed-use site by reducing residential units and commercial square footage area by approximately 25 percent resulting in 291 residential units and approximately 18,990 sf of commercial space. Alternative 4 would still require the

1.5 miles of off-site impacts located within roadway right-of-way to connect to existing Riverside Public Utilities (RPU) facilities located on Mountain View Avenue. An analysis of whether Alternative 4 meets each Project objective is provided in Table 8.0-F, Alternative 4: Reduced Density Project Objectives Comparison.

Table 8.0-F, Alternative 4: Reduced Density/Intensity Project Objectives Comparison Project Objective Alternative Meets Objective?
Primarily, provide quality, multi-family housing on
an existing underutilized site, to help the City’s
meet the State’s allocated 2021-2029 Regional
Housing Needs Assessment (RHNA) housing unit
numbers, as well as the City’s overarching selfprescribed housing unit numbers.

Yes, but to a lesser degree. Alternative 4 would
provide quality, multifamily housing, but less units
would be provided.

Place housing near a transit corridor to reduce
residential vehicle miles traveled and associated
congestion and greenhouse gas emissions.

Yes, to a lesser degree. Alternative 4 would provide
housing near a transit corridor and result in less
vehicle miles traveled and less greenhouse gas
emissions.

Place housing near existing commercial uses to
encourage pedestrian connectivity and to reduce
vehicular usage and associated impacts.

Yes. Alternative 4 would place housing near existing
commercial uses and still encourage pedestrian
connectivity.

Provide compatible mixed-use development
contributing to the character of the surrounding
neighborhood.

Yes. Alternative 4 would provide mixed use
development and contribute to the character of the
neighborhood.

Establish a mixed-use development that will
provide a land use transition between the existing
commercial Hardman Center and the residential
developments surrounding the project site.

Yes. Alternative 4 would provide mixed use
development that would serve as a transition from the
Hardman Center to the surrounding residential
developments around the site.

Alternative 4 Conclusion
Alternative 4 (Reduced Project Size) would reduce development of the Project site by 25 percent in comparison to the proposed Project site. Nonetheless, Alternative 4 still results in significant unavoidable impacts related to GHG, historic resources and airport land use compatibility. However, City of Riverside Section 8.0
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Alternative 4 would propose the same land uses as the Project, require a rezone and general plan amendment as well as demolition of the existing Sears building. By reducing the density of the Project which reduces the vehicles and therefore air quality emissions, Alternative 4 would create lesser impacts to VMT and air emissions. However, the Project as proposed already had less than significant VMT and air quality impacts. However, GHG emissions would likely still exceed thresholds as does the Project and significant and avoidable impacts from GHG would exist for this Alternative.

Although Alternative 4 meets the Project Objectives, these objectives are met to a lesser degree than the proposed Project, especially the key objective to meet the City’s RHNA allocations. Furthermore, Alternative 4 reduces the Project site by 25 percent. The demand for residential sites within the City of this size, attendant land costs and the low Inland Empire market lease rates for product of this type, Alternative 4 would result in a return on investment too low to justify the cost and risk of investment. Due to all of these factors, a reasonable developer would not take the risk to develop the Reduced Project Size Alternative. For these reasons, Alternative 4 is rejected as infeasible.

City of Riverside Section 8.0
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8.6. Comparison of Alternatives
The matrix approach to comparing the alternatives is used for ease of directly comparing the proposed Project's significant effects with those of the alternatives, per State CEQA Guidelines Section 15126.6(d). The potential environmental impacts of each alternative are ranked as greater, similar, or less than the proposed Project with respect to each topic discussed in the DEIR, as shown in Table 8.0-G, Comparison of Impacts from Project Alternatives
Table 8.0-G, Comparison of Impacts from Project Alternatives Environmental Issue
Alternative 1:

No Development/Keep
Existing Commercial
Designation
Alternative 2:

Adaptive Reuse to
Residential
Alternative 3:

ALUC Consistency
Alternative 4:

Reduced Density/Intensity
Cultural Resources
Project and Cumulative
Same – Alternative would not
require the demolition of the
existing structures.

However, modifications to
the structures would still be
required to bring them into
compliance with current
building and seismic codes to
a degree that would not result
in the preservation of a
historic resource. Therefore,
impacts related to cultural
resources would be similar to
that of the proposed Project.

Same – Alternative would still
require modifications to a
degree that would not result
in the preservation of a
historic resource. Therefore,
cultural resource impacts
would be the same as the
proposed Project.

Same – Alternative would still
require demolition of historic
resources. Therefore, cultural
resource impacts would be
similar to the proposed
Project.

Same – Alternative would still
require demolition of historic
resources. Therefore, cultural
resource impacts would be
similar to the proposed
Project.

Greenhouse Gas Emissions
Project and Cumulative
Greater – The fully
commercial use of the site
under Alternative 1 would
increase the GHG emissions
and further exceed
thresholds.

Less – the uses under this
Alternative would most likely
not result in GHG emissions
that would exceed standards.

Less – the uses under this
Alternative would most likely
not result in GHG emissions
that would exceed standards.

Same – although the
residential and commercial
uses would be reduced by
this Alternative, there would
still be uses to generate
mobile source and other
emissions that would most
likely exceed thresholds.

City of Riverside Section 8.0
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Table 8.0-G, Comparison of Impacts from Project Alternatives Environmental Issue
Alternative 1:

No Development/Keep
Existing Commercial
Designation
Alternative 2:

Adaptive Reuse to
Residential
Alternative 3:

ALUC Consistency
Alternative 4:

Reduced Density/Intensity
Hazards and Hazardous
Material
Project and Cumulative
Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP. Therefore,
hazards/hazardous material
impacts would be the same
as the proposed Project.

Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP. Therefore,
hazards/hazardous material
impacts would be the same
as the proposed Project.

Same – Alternative would
propose uses consistent with
RCALUCP development
standards. As such, this
Alternative would be
consistent with RCALUCP
policies. However, use may
not be compatible with
existing surrounding sensitive
receptors. Therefore, hazards
/hazardous material impacts
would be similar to the
proposed Project.

Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP. Therefore,
hazards/hazardous material
impacts would be the same
as the proposed Project.

Land Use
Project and Cumulative
Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP and as such,
inconsistency with General
Plan land use objectives and
policies as they relate to
airports. Therefore, land use
and planning impacts would
be the same as the proposed
Project.

Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP and as such,
inconsistency with General
Plan land use objectives and
policies as they relate to
airports. Therefore, land use
and planning impacts would
be the same as the proposed
Project.

Same – Alternative would
propose uses consistent with
RCALUCP development
standards. Because this
Alternative would be
consistent with the
RCALUCP, it would not result
in inconsistencies with
General Plan land use
objectives and policies as
they relate to airports.

However, use may not be
compatible with existing
surrounding sensitive
receptors. Therefore, land
use and planning impacts
Same – Alternative would still
result in an inconsistency
determination with the
RCALUCP and as such,
inconsistency with General
Plan land use objectives and
policies as they relate to
airports. Therefore, land use
and planning impacts would
be the same as the proposed
Project.

City of Riverside Section 8.0
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Table 8.0-G, Comparison of Impacts from Project Alternatives Environmental Issue
Alternative 1:

No Development/Keep
Existing Commercial
Designation
Alternative 2:

Adaptive Reuse to
Residential
Alternative 3:

ALUC Consistency
Alternative 4:

Reduced Density/Intensity
would be similar to the
proposed Project.

Transportation
Cumulative
Greater – Under the existing
land use, the existing site
would generate approximately
1,326 more trips then that of
the proposed Project. Thus,
this Alternative would result in
similar cumulative traffic
impacts but Project-specific
impacts would be greater
than of the proposed Project.

Same – There would be less
traffic originating to and from
the Project area because of
reduced density and intensity.

However, cumulative traffic
impacts would remain similar
to the proposed Project.

Same – There would be less
traffic originating to and from
the Project area because the
uses would be less intense.

But cumulative traffic impacts
would remain similar to the
proposed Project.

Same – There would be less
traffic originating to and from
the Project area because of
reduced density and intensity.

However, cumulative traffic
impacts would remain similar
to the proposed Project.

Environmentally Superior to
Proposed Project? No Yes, but to a lesser degree Yes, but to a lesser degree Yes, but impacts similar Meets Most of the Project
Objectives?
No
(0 of 5 Objectives Met)
Yes, but to a lesser degree
(3 of 5 Objectives Met)
No
(0 of 5 Objectives Met)
Yes, but to a lesser degree
(5 of 5 Objectives Met)
City of Riverside Section 8.0
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8.6.1. Environmentally Superior Alternative
The State CEQA Guidelines, Section 15126.6(e)(2), requires the identification of the environmentally superior alternative. Of the alternatives evaluated above, the No Project alternative is the environmentally superior alternative with respect to reducing impacts created by the proposed Project. However, the beneficial impacts of the proposed Project would not be realized. The State CEQA Guidelines also require the identification of another environmentally superior alternative if the No Project alternative is selected as the environmentally superior alternative. The following four Alternatives were reviewed for consideration of the environmentally superior alternative.

Alternative 1: No Development/Keep Existing Commercial Designation, results in greater impacts than the proposed Project and does not meet any of the Project Objectives. As such, this Alternative is rejected from consideration.

Alternative 2: Adaptive Reuse, results in similar impacts to the proposed Project but overall would result in less impacts than the proposed Project. The uses under this Alternative would most likely not result in GHG emissions that would exceed standards. However, when compared to the proposed Project, this Alternative does not have the ability to lessen impacts to the historic resources so will result in similar impacts to that of the proposed Project. Further, this Alternative meets only 3 of the 5 Project Objectives and to a lesser degree. As such, this Alternative is rejected from further consideration.

Alternative 3: ALUC Consistency, results similar impacts to the proposed Project but overall would result in less impacts than the proposed Project since the uses under this Alternative would most likely not result in GHG emissions that would exceed standards . However, this Alternative does not meet any of the Project Objectives so is rejected from further consideration.

Alternative 4: Reduced Density/Intensity, results similar impacts to the proposed Project and meets all of the Project Objectives but to a lesser degree than the proposed Project because Alternative 4 would reduce the size of the commercial buildings and amount of residential units by approximately 25 percent. As such, this Alternative would still provide more housing than the other Alternatives, which is a key objective. Hence, Alternative 4 is the environmentally superior alternative.

While the City of Riverside has examined a reasonable range of alternatives to the proposed Project site and Alternative 4 meets most of the Project Objectives and is environmentally superior to the proposed Project, the degree of which Alternative 4 reduces impacts to GHG emissions and Transportation is minimal when compared to the proposed Project. Since Alternative 4 is proposing to implement residential uses on the site impacts to GHG and Transportation would still exceed existing levels and thus still create an impact.

Alternative 4, when compared to the proposed Project, would meet all of the basic Project Objectives found in Section 3.0 – Project Description of this Draft EIR but to a lesser degree, because it fails to maximize the site location and surrounding features through site design and building placement since it offers a reduced density/intensity project; resulting in an increased the demand for development at other sites in the area. Further, while this Alternative would capitalize on the City’s Smart Growth principals, it would do so at a lesser degree than the proposed Project by offering smaller commercial structures and fewer dwelling units. Lastly, while this Alternative would provide housing opportunities allowing the City to help meet its RHNA allocations, it would do so at a lesser degree than the proposed Project.

City of Riverside Section 8.0
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Alternative 4 would result in essentially the same level of impacts as the proposed Project but would not meet all of the basic Project Objectives found in Section 3.0 - Project Description of this Draft EIR.

The proposed Project will result in significant and unavoidable impacts even after implementation of mitigation. Likewise, Alternative 4 (as well as Alternatives 1 through Alternative 3) will also result in similar significant unavoidable impacts. Therefore, none of the Alternatives will effectively lessen or avoid significant impacts that otherwise result from the proposed Project.

City of Riverside Sections 9.0
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9.0 References
As discussed in Section 2.0 – Introduction of this Draft EIR, Section 15150 of the State CEQA Guidelines permits and encourages an environmental document to incorporate, by reference, other documents that provide relevant data. The documents summarized below are incorporated by reference, and the pertinent material is summarized throughout this Draft EIR, where that information is relevant to the analysis of potential impacts of the Project. All documents incorporated by reference are available for review at, or can be obtained through, the City of Riverside Planning Department.

GP 2025 City of Riverside, General Plan 2025, Approved November 2007. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GP 2025 FEIR City of Riverside, General Plan Final Environmental Impact Report (SCH No. 2004021108), certified November 2007. (Available at
https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GPUI City of Riverside, Phase I General Plan Update, Approved October 5, 2021. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GPUI FEIR City of Riverside, Phase I General Plan Update Final Environmental Impact Report (SCH No. 2021040089), certified October 5, 2021. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GP 2025 City of Riverside, General Plan 2025, Approved November 2007. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
MC City of Riverside, Municipal Code, Updated July 26, 2023. (Available at http://www.riversideca.gov/municode/ accessed July 29, 2023.) Additional reference materials that were used in the preparation of this Draft EIR include the following:

Section 1.0 – Executive Summary
ALUC-A County of Riverside, Airport Land Use Commission, Landscaping Near Airports:

Special Considerations for Preventing or Reducing Wildlife Hazards to Aircraft, Table 2 - Acceptable Plants from Riverside County Landscaping Guide. (Available at https://rcaluc.org/sites/g/files/aldnop421/files/migrated/Portals-13-PDFGeneralResources-BROCHUREFINALEDALandscapeletter.pdf, accessed September 26, 2022.)
COR GP County of Riverside, General Plan – Appendix E-2: Socioeconomic Buildout Assumption Projections & Methodology, Revised April 11, 2017. (Available at https://planning.rctlma.org/General-Plan-Zoning/General-Plan, accessed December 6, 2022.)
DUDEK-A Dudek, Cultural Technical Resource Report, dated May 2023 (Appendix C) Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
9-2
PE Press Enterprise, Sears closing iconic Riverside location, 7 other Inland Stores, November 8, 2019 (Available at
https://www.pressenterprise.com/2019/11/08/sears-closing-11-area-storesriverside-loses-4-la-3-oc-1-and-san-bernardino-3/, accessed July 28, 2023.) RCALUCP County of Riverside - Airport Land Use Commission, Riverside County Airport Land Use Compatibility Plan, Adopted March 2005. (Available at https://rcaluc.org/current-compatibility-plans, accessed July 28, 2023.) RCDG City of Riverside, Riverside Citywide Design Guidelines, Amended January 15, 2019. (Available at
https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/Citywide_ Design_and_Sign_Guidelines_web%20version_Amended%2001-15-19_1.pdf, accessed September 26, 2022.)
RUHS Riverside University Health System, Farmer’s Market Locations. (Available at https://www.ruhealth.org/farmers-market, accessed September 28, 2022.) WEIS-A Weis Environmental, Phase I Environmental Site Assessment 5261 Arlington Avenue Riverside, California 92504. November 11, 2021. (Appendix D) Section 2.0 – Introduction
GP 2025 City of Riverside, General Plan 2025, Approved November 2007. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GP 2025 FEIR City of Riverside, General Plan Final Environmental Impact Report (SCH No. 2004021108), certified November 2007. (Available at
https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023)
GPUI City of Riverside, Phase I General Plan Update, Approved October 5, 2021. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
GPUI FEIR City of Riverside, Phase I General Plan Update Final Environmental Impact Report (SCH No. 2021040089), certified October 5, 2021. (Available at https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed June 28, 2023.)
MC City of Riverside, Municipal Code, Updated July 26, 2023. (Available at http://www.riversideca.gov/municode/ accessed July 29, 2023.) RCDG City of Riverside, Riverside Citywide Design Guidelines, Amended January 15, 2019. (Available at
https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/Citywide_ Design_and_Sign_Guidelines_web%20version_Amended%2001-15-19_1.pdf, accessed September 26, 2022.)
City of Riverside Sections 9.0
Arlington Mixed Use Draft EIR References
9-3
Section 3.0 – Project Description
ALUC-A County of Riverside, Airport Land Use Commission, Landscaping Near Airports:

Special Considerations for Preventing or Reducing Wildlife Hazards to Aircraft, Table 2 - Acceptable Plants from Riverside County Landscaping Guide. (Available at https://rcaluc.org/sites/g/files/aldnop421/files/migrated/Portals-13-PDFGeneralResources-BROCHUREFINALEDALandscapeletter.pdf, accessed September 26, 2022.)
COR GP County of Riverside, General Plan – Appendix E-2: Socioeconomic Buildout Assumption Projections & Methodology, Revised April 11, 2017. (Available at https://planning.rctlma.org/General-Plan-Zoning/General-Plan, accessed December 6, 2022.)
DUDEK-A Dudek, Cultural Technical Resource Report, dated May 2023 (Appendix C) PE Press Enterprise, Sears closing iconic Riverside location, 7 other Inland Stores, November 8, 2019 (Available at
https://www.pressenterprise.com/2019/11/08/sears-closing-11-area-storesriverside-loses-4-la-3-oc-1-and-san-bernardino-3/, accessed July 28, 2023.) RCALUCP County of Riverside - Airport Land Use Commission, Riverside County Airport Land Use Compatibility Plan, Adopted March 2005. (Available at https://rcaluc.org/current-compatibility-plans, accessed July 28, 2023.) RCDG City of Riverside, Riverside Citywide Design Guidelines, Amended January 15, 2019. (Available at
https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/Citywide_ Design_and_Sign_Guidelines_web%20version_Amended%2001-15-19_1.pdf, accessed September 26, 2022.)
RUHS Riverside University Health System, Farmer’s Market Locations. (Available at https://www.ruhealth.org/farmers-market, accessed September 28, 2022.) WEIS-A Weis Environmental, Phase I Environmental Site Assessment 5261 Arlington Avenue Riverside, California 92504. November 11, 2021. (Appendix D) Section 5.1 – Aesthetics
GE Google, Inc. Google Earth Pro version 7.3.4.8642. Build date 5/12/2020. Accessed February 6, 2023.

RCDG City of Riverside, Citywide Design Guidelines and Sign Guidelines, Adopted November 2007 Resolution No. 21544 Amended January 2019 Resolution No. 23405. (Available at
https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/Citywide_ Design_and_Sign_Guidelines_web%20version_Amended%2001-15-19_1.pdf, accessed, February 6, 2023.)
UFPM City of Riverside Public Works, Urban Forestry Policy Manual, Revised August 2015. (Available at https://riversideca.gov/publicworks/trees/pdf/UrbanForestry-TOC.pdf, accessed February 6, 2023.)
Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
9-4
Section 5.2 – Air Quality
CARB 2005 California Air Resources Board, Air Quality and Land Use Handbook: A Community Perspective, April 2005. (Available at http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/california-air-resources-board-air-quality-and-land-usehandbook-a-community-health-perspective.pdf, accessed July 28, 2023.) CARB 2022a California Air Resources Board, Community Air Protection Program Recommendation Process. (Available at https://ww2.arb.ca.gov/capp-selection, accessed July 28, 2023.)
CARB 2022b California Air Resources Board, Community Nominations. (Available at https://ww2.arb.ca.gov/our-work/programs/community-air-protectionprogram/community-selection/community-nominations, accessed July 28, 2023.) CARB 2023 California Air Resources Board, Area Designations Maps / State and National, January 2023. (Available at https://www.arb.ca.gov/desig/adm/adm.htm, accessed January 3, 2023.)
CBSC California Building Standards Commission, 2022 California Green Building Standards Code (CALGreen), Part 11, Title 24, January 2023. (Available at https://www.dgs.ca.gov/BSC/CALGreen, accessed July 28, 2023.) CEC Standards California Energy Commission, Building Energy Efficiency Standards. (Available at https://www.energy.ca.gov/programs-and-topics/programs/building-energyefficiency-standards, accessed July 28, 2023.) CEC Title 20 California Energy Commission, Appliance Efficiency Regulations-Title 20, 2023. (Available at https://www.energy.ca.gov/rules-and-regulations/appliance-efficiencyregulations-title-20, accessed July 28, 2023.) CEC 2022 California Energy Commission. Energy Commission Adopts Updated Building Standards to Improve Efficiency, Reduce Emissions From Homes and Businesses, August 11, 2021 (Available at https://www.energy.ca.gov/news/2021-08/energycommission-adopts-updated-building-standards-improve-efficiency-reduce, accessed July 28, 2023)
EPA 2023 U.S. Environmental Protection Agency, Criteria Air Pollutants, 2023. (Available at https://www.epa.gov/criteria-air-pollutants, accessed July 24, 2023.) GP EIR City of Riverside, General Plan Final Environmental Impact Report (SCH No. 2004021108), certified November 2007. (Available at
https://riversideca.gov/cedd/planning/city-plans/general-plan-0, accessed July 28, 2023)
OEHHA 2023 Office of Environmental Health Hazard Assessment, SB 535 Disadvantaged Communities Map (2022 Update), May 2022. (Available at
https://oehha.ca.gov/calenviroscreen/sb535, accessed July 28, 2023.) Rule 220 South Coast Air Quality Management District, Rule 220 Exemption – Net Increase in Emissions, August 7, 1981. (Available at http://www.aqmd.gov/docs/defaultsource/rule-book/reg-ii/rule-220.pdf?sfvrsn=4, accessed July 24,2023.) Rule 402 South Coast Air Quality Management District, Rule 402 Nuisance, May 7, 1976. (Available at http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule402.pdf?sfvrsn=4, accessed July 24,2023.) City of Riverside Sections 9.0
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Rule 403 South Coast Air Quality Management District, Rule 403 Fugitive Dust, June 3, 2005. (Available at http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule403.pdf?sfvrsn=4, accessed July 24, 2023.) Rule 481 South Coast Air Quality Management District, Rule 481 Spray Coating Operations, January 11, 2002. (Available at http://www.aqmd.gov/docs/default-source/rulebook/rule-iv/rule-481.pdf?sfvrsn=4, accessed July 24, 2023.) Rule 1108 South Coast Air Quality Management District, Rule 1108 Cutback Asphalt, February 1, 1985. (Available at http://www.aqmd.gov/docs/default-source/rule-book/regxi/rule-1108-cutback-asphalt.pdf?sfvrsn=4, accessed July 24, 2023.) Rule 1113 South Coast Air Quality Management District, Rule 1113 Architectural Coatings, February 5, 2016. (Available at http://www.aqmd.gov/docs/default-source/rulebook/reg-xi/r1113.pdf?sfvrsn=17, accessed July 24, 2023.) Rule 1143 South Coast Air Quality Management District, Rule 1143 Consumer Paint Thinners & Multi-Purpose Solvents, December 3, 2010. (Available at http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule1143.pdf?sfvrsn=4, accessed July 24, 2023.) Rule 1186 South Coast Air Quality Management District, Rule 1186 PM-10 Emissions from Paved and Unpaved Roads, and Livestock Operations, July 11, 2008. (Available at http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule1186.pdf?sfvrsn=4, accessed July 24, 2023.) Rule 1303 South Coast Air Quality Management District, Rule 1303 Requirements, December 6, 2002. (Available at http://www.aqmd.gov/docs/default-source/rule-book/regxiii/rule-1303-requirements.pdf?sfvrsn=4, accessed July 24, 2023.) SCAG 2020 Southern California Association of Governments, Connect SoCal (2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy), September 2020. (Available at https://scag.ca.gov/read-plan-adopted-final-connect-socal-2020, accessed on July 24, 2023.)
SCAQMD 1993 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993. (Available at SCAQMD.)
SCAQMD 2000 South Coast Air Quality Management District, Multiple Air Toxics Exposure Study (MATES-II), March 2000. (Available at http://www.aqmd.gov/home/air-quality/airquality-studies/health-studies/mates-ii, accessed July 24, 2023.) SCAQMD 2003 South Coast Air Quality Management District, White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, August 2003. (Available at http://www.aqmd.gov/docs/default-source/Agendas/EnvironmentalJustice/cumulative-impacts-working-group/cumulative-impacts-white-paper.pdf, accessed July 28, 2023.)
SCAQMD 2005 South Coast Air Quality Management District, Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, May 6, 2005. (Available at http://www.aqmd.gov/docs/default-source/planning/air-quality-guidance/completeguidance-document.pdf, accessed January 11, 2023.) SCAQMD 2008 South Coast Air Quality Management District, Multiple Air Toxics Exposure Study (MATES-III), September 2008. (Available at http://www.aqmd.gov/home/airquality/air-quality-studies/health-studies/mates-iii, accessed January 11, 2023.) Section 9.0 City of Riverside
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SCAQMD 2014 South Coast Air Quality Management District, Multiple Air Toxics Exposure Study, May 2015. (Available at http://www.aqmd.gov/home/air-quality/air-qualitystudies/health-studies/mates-iv, accessed January 11, 2023.) SCAQMD 2015 South Coast Air Quality Management District, Application of the South Coast Air Quality Management District for Leave to File Brief of Amicus Curiae in Support of Neither Party and [Proposed] Brief of Amicus Curiae, April 13, 2015. (Available at https://www.courts.ca.gov/documents/9-s219783-ac-south-coast-air-quality-mgtdist-041315.pdf, accessed February 17, 2023.) SCAQMD 2021 South Coast Air Quality Management District, Multiple Air Toxics Exposure Study (MATES-V), August 2021. (Available at http://www.aqmd.gov/home/air-quality/airquality-studies/health-studies/mates-v, accessed July 28, 2023.) SCAQMD 2022 South Coast Air Quality Management District, 2022 Air Quality Management Plan, December 2, 2022. (Available at http://www.aqmd.gov/home/air-quality/clean-airplans/air-quality-mgt-plan, accessed July 28, 2023.) SCAQMD 2023 South Coast Air Quality Management District, Historical Data by Year, 2019, 2020, 2021. (Available at http://www.aqmd.gov/home/air-quality/historical-air-qualitydata/historical-data-by-year, accessed July 24, 2023.) SCAQMD Map South Coast Air Quality Management District, Map of Jurisdiction. (Available at http://www.aqmd.gov/docs/default-source/default-document-library/map-ofjurisdiction.pdf, accessed July 30, 2023.) WEBB-A Albert A. Webb Associates, Technical Memorandum – Air Quality/Greenhouse Gas Analysis for the Arlington Mixed Use Development Project, City of Riverside, California, October 27, 2023. (Appendix B)
WRCC Western Regional Climate Center, Riverside Fire Sta 3, California (047470) 1981- 2010 Monthly Climate Summary. (Available at https://wrcc.dri.edu/cgibin/cliMAIN.pl?ca7470, accessed February 17, 2023.) Section 5.3 – Cultural Resources
AO Architecture Design Relationships, Building Riverside Adaptive Reuse Study, July 13, 2023. (Appendix C)
Axiom AXIOM Retail Advisors, Feasibility of Re-Tenanting the Former Sears Building at 5261 Arlington Avenue, Riverside, CA with Retail of Self Storage Uses, January 17, 2024. (Appendix C)
CRHR Office of Historic Preservation, California Register of Historical Resources, 2023. (Available at https://ohp.parks.ca.gov/?page_id=21238, accessed February 24, 2023.)
DUDEK-A Dudek, Cultural Resources Technical Report 5261 Arlington Avenue, Riverside California. May 2023. (Appendix C)
DUDEK-B Dudek, Supplemental Cultural Memorandum. October 6, 2023. (Appendix C) DUDEK-C Dudek, Cultural Resources Technical Report Memorandum, April 25, 2024. (Appendix C)
City of Riverside Sections 9.0
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HSC 7050.5 California Health and Safety Code, Division 7, Part 1, Chapter 2, Section 7050.5, amended 1987. (Available at
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC& sectionNum=7050.5, accessed February 24, 2023.)
HSC 7051 California Health and Safety Code, Division 7, Part 1, Chapter 2, Section 7051, January 1, 2018. (Available at
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ALUC-D Riverside County Airport Land Use Commission, ALUC Development ReviewCommissioner Concerns, dated January 18, 2023. (Appendix D) CALEPA-A California Environmental Protection agency (CALEPA), History of California Environmental Protection Agency, 2023. (Available at
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https://www.envirostor.dtsc.ca.gov/public/search.asp?cmd=search&reporttype=CO RTESE&site_type=CSITES,OPEN,FUDS,CLOSE&status=ACT,BKLG,COM&reporttitle =HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIST, accessed on January 25, 2023.)
CUPA County of Riverside Department of Environmental Health, Hazardous Materials (HazMat), 2023. (Available at https://rivcoeh.org/hazardous-materials, accessed on January 27, 2023.)
DIR California Department of Industrial Relations, California Occupational Safety and Health Regulations (CAL/OSHA). (Available at California Occupational Safety and Health Regulations (CAL/OSHA), Subchapter 1. Regulations of the Director of Industrial Relations , accessed January 25, 2023.)
DOT State of California Department of Transportation – Division of Aeronautics, California Airport Land Use Planning Handbook, October 2011 (Available at https://dot.ca.gov/- /media/dotmedia/programs/aeronautics/documents/californiaairportlanduseplanninghandbooka11y.pdf, accessed May 10, 2021) DTSC Department of Toxic Substance Control, Official California Code of Regulations, Title 22 Division 4.5.(Available at https://dtsc.ca.gov/title22/, accessed on January 25, 2023.)
EPA-A United States Environmental Protection Agency (EPA). Federal Toxic Substances Control Act, updated on October 4, 2022. (Available at https://www.epa.gov/lawsregulations/summary-toxic-substances-control-act, accessed on January 25, 2023.) EPA-B United States Environmental Protection Agency (EPA). Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), updated on January 24, 2023. (Available at https://www.epa.gov/superfund/superfund-cerclaoverview, accessed on January 25, 2023.) Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
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EPA-C United States Environmental Protection Agency (EPA). Superfund Amendments and Reauthorization Act (SARA), updated on April 25, 2022. (Available at https://www.epa.gov/superfund/superfund-amendments-and-reauthorization-actsara, accessed on January 25, 2023.) FAR PART77 Federal Aviation Administration, Title 14 – Aeronautics and Space; Part 77 – Safe, Efficient Use, and Preservation of the Navigable Air Space, January 1, 2012. (Available at https://www.govinfo.gov/content/pkg/CFR-2012-title14-vol2/xml/CFR2012-title14-vol2-part77.xml, accessed January 25, 2023.) HSC 6.95 California Health and Safety Code, Chapter 6.95 Hazardous Materials Release Response Plans an Inventory. (Available at
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&divi sion=20.&title=&part=&chapter=6.95.&article=1, accessed on January 25, 2023.) LHMP City of Riverside, Local Hazard Mitigation Plan 2023. Approved February 24, 2023. (Available at https://riversideca.gov/fire/divisions/office-emergencymanagement/lhmp, accessed on June 29, 2023.) OSHA United States Department of Labor, Occupational Safety and Health Administration (OSHA), At-A-Glance OSHA. The Occupational Safety and Health Act of 1970 (OSH Act) OSHA 3439-B12R 2014. (Available at
https://www.osha.gov/Publications/3439at-a-glance.pdf, accessed on January 25, 2023.)
RCALUCP Riverside County Airport Land Use Commission, Riverside County Airport Land Use Compatibility Plan , October 14, 2004. (Available at https://rcaluc.org/currentcompatibility-plans, accessed January 25, 2023.) WEIS-A Weis Environmental, Phase I Environmental Site Assessment 5261 Arlington Avenue Riverside, California 92504. November 11, 2021. (Appendix D) WEIS-B Weis Environmental, Addendum to Phase I Environmental Site Assessment, dated March 10, 2023. (Appendix D)
WEIS-C Weis Environmental, Work Plan for Subsurface Assessment, dated March 10, 2023. (Appendix D)
WEIS-D Weis Environmental, Comprehensive Subsurface Assessment Report, dated July 31 November 3, 2023. (Appendix D)
Section 5.8 – Land Use and Planning
CGC California Government Code, Title 7, Section 65000-66499.58 (Available at http://leginfo.legislature.ca.gov/faces/codes_displayexpandedbranch.xhtml?tocCod e=GOV&division=&title=7.&part=&chapter=&article= , accessed February 22, 2019.) RCALUCP County of Riverside - Airport Land Use Commission, Riverside County Airport Land Use Compatibility Plan, Adopted March 2005. (Available at https://rcaluc.org/currentcompatibility-plans, accessed July 28, 2023.) City of Riverside Sections 9.0
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RCDG-B City of Riverside, Citywide Design Guidelines and Sign Guidelines, Adopted November 2007 Resolution No. 21544 Amended January 2019 Resolution No. 23405. (Available at
https://riversideca.gov/cedd/sites/riversideca.gov.cedd/files/pdf/planning/Citywide_ Design_and_Sign_Guidelines_web%20version_Amended%2001-15-19_1.pdf, accessed, February 6, 2023.)
WEIS-A Weis Environmental, Phase I Environmental Site Assessment 5261 Arlington Avenue Riverside, California 92504. November 11, 2021. (Appendix D) Section 5.9 – Noise
CT-A California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013. (Available at https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tens-sep2013- a11y.pdf, accessed March 22, 2023.)
CT-B California Department of Transportation, Traffic Noise Analysis Protocol for New Highway Construction, Reconstruction, and Retrofit Barrier Projects, April 2020. (Available at https://dot.ca.gov/-/media/dot-media/programs/environmentalanalysis/documents/env/traffic-noise-protocol-april-2020-a11y.pdf, accessed March 22, 2023.)
dBF dBF Associates, Inc., Exterior Noise Analysis Report Arlington Mixed-Use, October 28,2023. (Appendix E)
EPA 2017 United States Environmental Protection Agency, Summary of the Noise Control Act, December 8, 2017. (Available at https://www.epa.gov/laws-regulations/summarynoise-control-act, accessed March 21, 2023.) EPA 2018 United States Environmental Protection Agency, EPA History: Noise and the Noise Control Act, September 6, 2018. (Available at
http://www.dot.ca.gov/hq/env/noise/pub/TeNS_Sept_2013B.pdf, accessed March 21, 2023.)
FTA Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual. September 2018. (Available at https://www.transit.dot.gov/researchinnovation/transit-noise-and-vibration-impact-assessment-manual-report-0123, accessed July 10, 2023.)
OPR 2017 California Governor’s Office of Planning and Research, General Plan Guidelines, 2017. (Available at http://opr.ca.gov/docs/OPR_COMPLETE_7.31.17.pdf, accessed March 21, 2023.)
OSHA Occupational Safety and Health Administration, Occupational Noise Exposure. (Available at https://www.osha.gov/SLTC/noisehearingconservation/, accessed March 21, 2023.)
RCALUCP County of Riverside - Airport Land Use Commission, Riverside County Airport Land Use Compatibility Plan, Adopted March 2005. (Available at https://rcaluc.org/current-compatibility-plans, accessed July 28, 2023.) Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
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Section 5.10 – Population and Housing
COR GP County of Riverside, General Plan – Appendix E-2: Socioeconomic Buildout Assumption Projections & Methodology, Revised April 11, 2017. (Available at https://planning.rctlma.org/General-Plan-Zoning/General-Plan, accessed December 6, 2022.)
DOF State of California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2023, May 2022. (Available at https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-andhousing-estimates-for-cities-counties-and-the-state-2020-2022/, accessed June 19, 2023.)
EDD State of California, Employment Development Department, Monthly Labor Force Data for Cities and Census Designated Places (CDP) October 2022. (Available at https://www.labormarketinfo.edd.ca.gov/data/labor-force-and-unemployment-forcities-and-census-areas.html accessed December 2, 2022.) RHNA Southern California Association of Governments, 6th Cycle Final Regional Housing Needs Assessment Final Allocation Plan. (Available at https://scag.ca.gov/rhna, accessed December 2, 2022.)
RTP/SCS Southern California Association of Governments, The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the SCAG, September 3, 2021. (Available at https://scag.ca.gov/read-plan-adopted-final-plan, accessed December 1, 2022.)
SB 2 Legislative Counsel of California, California Senate Bill 2 Chapter 364, September 2017. (Available at
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB2, January 9, 2023.)
SCAG Southern California Association of Governments, The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the SCAG, Demographics and Growth Forecast-Technical Report, September 3, 2020. (Available at https://scag.ca.gov/sites/main/files/fileattachments/0903fconnectsocal_demographics-and-growthforecast.pdf?1606001579, accessed on December 1, 2022.) Section 5.11 – Public Services
DQ-A California Department of Education Data Quest, 2022-23 Enrollment by Grade; Riverside Unified Report (33-67215), (Available at
https://dq.cde.ca.gov/dataquest/dqcensus/EnrGrdLevels.aspx?cds=3367215&aggl evel=district&year=2022-23, accessed September 21, 2023.) DQ-B California Department of Education Data Quest, Enrollment Multi-Year Summary by Grade, Jefferson elementary Report (33-67215-6032668) (Available at https://dq.cde.ca.gov/dataquest/dqcensus/EnrGrdYears.aspx?cds=336721560326 68&agglevel=school&year=2022-23, accessed September 21, 2023.) City of Riverside Sections 9.0
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DQ-C California Department of Education Data Quest, Enrollment Multi-Year Summary by Grade, Sierra Middle Report (33-67215-6059141) (Available at https://dq.cde.ca.gov/dataquest/dqcensus/EnrGrdYears.aspx?cds=336721560591 41&agglevel=school&year=2022-23, accessed September 21, 2023.) DQ-D California Department of Education Data Quest, Enrollment Multi-Year Summary by Grade, Ramona High Report (33-67215-3336492) (Available at https://dq.cde.ca.gov/dataquest/dqcensus/EnrGrdYears.aspx?cds=336721533364 92&agglevel=school&year=2022-23, accessed September 21, 2023.) GE Google, Inc. Google Earth Pro version 7.3.6.9345. Build date December 29, 2023.

Accessed September 21, 2023.

MZ Riverside City Manager’s Office, Implementation of Measure Z website. (Available at Implementation of Measure Z | City Manager's Office (riversideca.gov), accessed July 11, 2023.)
RCS City of Riverside, Crime Statistics. 2016. (Available at https://riversideca.gov/rpd/resources-forms/crimestatistics#:~:text=The%20information%20provided%20is%20divided%20into%20t wo%20sections.,this%20category%20are%20burglary%2C%20theft%20and%20a uto%20theft., accessed December 31, 2023.)
RFD Riverside Fire Department, Stations website. (Available at https://riversideca.gov/fire/about-contact/stations, accessed July 11, 2023.) RUSD-A Riverside United School District, School Fee Justification Study, May 19, 2022. (Available at https://cdnsm5-
ss12.sharpschool.com/Userfiles/DBFiles/server_580721/202206/21524101/2022_rus d_fee_justification_study_fjs_.pdf, accessed July 12, 2023.) RUSD-B Riverside Unified School District, Interactive Map; RUSD School Locator, September 21, 2023. (Available at
https://webapps.riversideunified.org/apps/SchoolLocator/, accessed September 21, 2023.)
SP City of Riverside Fire Department, Community – Driven, Employee-Supported Strategic Plan 2023-2028. updated September 2023. (Available at https://riversideca.gov/fire/community-driven-employee-supported-strategic-plan, accessed September 2023)
Section 5.12 – Recreation
GE Google, Inc. Google Earth Pro version 7.3.6.9345. Build date December 29, 2023.

Accessed July 29, 2023.

PMP City of Riverside, Comprehensive Park, Recreation & Community Services Master Plan, Adopted February 4, 2020. (Available at
https://riversideca.gov/park_rec/sites/riversideca.gov.park_rec/files/56402%20Riversi de%20Master%20Plan%20Final%2002-26-20.pdf, accessed on January 9, 2023.) Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
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Section 5.13 – Traffic and Transportation
CMP County of Riverside, 2011 Riverside County Congestion Management Program, December 14, 2011. (Available at
http://www.rctcdev.info/uploads/media_items/congestionmanagementprogram.origi nal.pdf, accessed June 30, 2023.)
LRSP City of Riverside, Local Roadway Safety Plan, dated May 31, 2023. (Available at https://riversideca.gov/publicworks/sites/riversideca.gov.publicworks/files/pdf/Rivers ide_LRSP_SIGNED_05.31.2023.pdf, accessed July 29, 2023.) LRTS Riverside County Transportation Commission, Riverside County Long Range Transportation Study. December 2019. (Available at https://www.rctc.org/wpcontent/uploads/2019/12/RCTC-Draft-LRTS-120119-GV22.pdf, accessed June 30, 2023)
Riv PACT City of Riverside, PACT Plan, (Available at https://riversideca.gov/pact/, accessed October 17, 2023.)
RTA Riverside Transit Authority, Maps and Schedules, May 14, 2023. (Available at https://www.riversidetransit.com/index.php/route-info, accessed June 30, 2023.) SB375 California Legislative information. Senate Bill No 375, Filed September 30, 2008. (Available at
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200720080SB375, accessed June 30, 2023.)
SCAG Southern California Association of Governments, Connect SoCal – The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy, adopted September 3, 2020. (Available at
https://www.connectsocal.org/Documents/Adopted/0903fConnectSoCal-Plan.pdf, accessed June 30, 2023.)
TIA City of Riverside, Draft Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment, adopted July 2020. (Available at the City of Riverside )
URBAN Urban Crossroads, Arlington Mixed Use (PR-2022-001252) Traffic Analysis, dated December 23, 2022. (Appendix F).

WEBB-C Albert A Webb Associates, Vehicle Miles Traveled Screening Assessment for the Proposed Arlington Mixed-Use Development (PR-2022-001252) Memorandum, dated June 6, 2023. (Appendix F)
WRCOG Western Riverside Council of Governments (WRCOG), Transportation Uniform Mitigation Fee, Administrative Plan, March 1, 2021. (Available at https://www.wrcog.us/DocumentCenter/View/9158/TUMF-AdminPlan-CreditManualMar1-2021, accessed June 30, 2023.) City of Riverside Sections 9.0
Arlington Mixed Use Draft EIR References
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Section 5.14 – Tribal Cultural Resources
AIRFA National Oceanic and Atmospheric Administration, American Indian Religious Freedom Act. (Available at
https://coast.noaa.gov/data/Documents/OceanLawSearch/Summary%20of%20Law %20-%20American%20Indian%20Religious%20Freedom%20Act.pdf, accessed February 24, 2023.)
CRHR Office of Historic Preservation, California Register of Historical Resources, 2023.(Available at https://ohp.parks.ca.gov/?page_id=21238, accessed February 24, 2023.)
DUDEK-A Dudek, Cultural Resources Technical Report 5261 Arlington Avenue, Riverside California. May 2023. (Appendix C)
HSC 7050.5 California Health and Safety Code, Division 7, Part 1, Chapter 2, Section 7050.5, amended 1987. (Available at
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&s ectionNum=7050.5, accessed February 24, 2023)
HSC 7051 California Health and Safety Code, Division 7, Part 1, Chapter 2, Section 7051, January 1, 2018. (Available at
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&s ectionNum=7051, accessed February 24, 2023)
HSC 7054 California Health and Safety Code, Division 7, Part 1, Chapter 2, Section 7054, January 1, 2018. (Available at
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&s ectionNum=7054, accessed February 24, 2023)
NAHC Native American Heritage Commission, Welcome, 2023. (Available at http://nahc.ca.gov/, accessed February 24, 2023)
NPS-A National Park Service, National Historic Preservation Act, Update August 16,2022. (Available at https://www.nps.gov/subjects/historicpreservationfund/nationalhistoric-preservation-act.htm, accessed February 24, 2023.) NPS-B National Park Service, National Register of Historic Place Publications of the Nation Register of Historic Place, Updated January 6, 2023. (Available at https://www.nps.gov/subjects/nationalregister/publications.htm, accessed February 24, 2023.)
NPS-C National Pakr Service, Native American Graves Protection and Repatriation Act: The Law, Updated January 31, 2023. (Available
https://www.nps.gov/subjects/nagpra/the-law.htm, accessed February 24, 2023.) PRC 21074 California Public Resources Code, Division 13, Chapter 2.5, Section 21074. (Available at
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC& sectionNum=21074, accessed February 24, 2023.)
PRC 21083 California Public Resources Code, Division 13, Chapter 2.6, Section 21083 (Available at
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=21 083.&nodeTreePath=31.4&lawCode=PRC, accessed July 28, 2023).

Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
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PRC 21084 California Public Resources Code, Division 13, Chapter 2.6, Section 21084.2. (Available at
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC& sectionNum=21084.2, accessed February 24, 2023)
PRC 5024.1 California Public Resources Code, Division 5, Chapter 1, Article 2, Section 5024.1. (Available at
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC& sectionNum=5024.1, accessed February 24, 2023.)
PRC 5097.98 California Public Resource Code, Division 5, Chapter 1.75, Section 5097.98, January 1, 2010. (Available at
http://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&s ectionNum=5097.98, accessed February 24, 2023).

Section 5.15 – Utilities and Service Systems
CAL-A
Cal Recycle, SWIS Facility/Site Activity Details Badlands Sanitary Landfill (33-AA0006) December 18, 2020. (Available at https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2245?siteID=2367, accessed May 30, 2023.)
CAL-B
Cal Recycle, SWIS Facility/Site Activity Details El Sobrante Landfill (33-AA-0217) April 1, 2018. (Available at
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2280?siteID=2402, accessed May 30, 2023.)
CAL-C
Cal Recycle, SWIS Facility/Site Activity Details Lamb Canyon Sanitary Landfill (33- AA-0007) January 8, 2015. (Available at
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2246?siteID=2368, accessed May 30, 2023.)
CAL-D California Department of Resources, Recycling and Recovery, Targeted Statewide Waste Characterization Study: Waste Disposal and Diversion Findings for Selected Industry Groups . June 2006 Available at
https://www2.calrecycle.ca.gov/Publications/Details/1184, accessed March 9, 2023) CAROLLO Carollo Engineers Inc. Arlington Mixed Use – City of Riverside: Sewer Study, December 20, 2022. (Appendix G)
CIWMP County of Riverside, Countywide Integrated Waste Management Plan, 2023.(Available at https://rcwaste.org/about-us/planning-services-overview/ciwmp, accessed July 10, 2023.)
DWR-A County of Riverside - Department of Waste Resources, SWIS Facility/Site Inspection Details Badlands Sanitary Landfill (33-AA-0006) – Tonnage Report, May 2023.(Available at
https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/355688, accessed July 10, 2023.)
DWR-B County of Riverside - Department of Waste Resources, SWIS Facility/Site Inspection Details El Sobrante Landfill (33-AA-0217) – Tonnage Report, May 2023.(Available at https://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/356094, accessed July 10, 2023.)
City of Riverside Sections 9.0
Arlington Mixed Use Draft EIR References
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DWR-C County of Riverside - Department of Waste Resources, SWIS Facility/Site Inspection Details Lamb Canyon Sanitary Landfill (33-AA-0007) – Tonnage Report, April 2023.(Available
athttps://www2.calrecycle.ca.gov/SolidWaste/SiteInspection/Details/355046, accessed July 10, 2023.)
MS4
State of California, Regional Water Quality Control Board, Santa Ana Region. Order No. R8-2010-0033, NPDES No. CAS 618033, National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements for the Riverside County Flood Control and Water Conservation District, the Count of Riverside, and the Incorporated Cities of Riverside County within the Santa Ana Region, Area-Wide Urban Runoff Management Program. Adopted January 29, 2010. (Available at http://waterboards.ca.gov/santaana/water_issues/programs/stormwater/index.shtml, accessed February 28, 2023.).

RIV-A City of Riverside, Public Works - Sewer, 2023. (Available at https://riversideca.gov/publicworks/sewer/, accessed February 28, 2023.) RIV-B City of Riverside, Public Works – Clean Up Riverside,2023.(Available at https://www.riversideca.gov/publicworks/trash-recycling/clean-riverside, accessed July 10, 2023.)
RPU-WS City of Riverside Public Utilities Department, Water Service Availability To Tentative Parcel Map 38638 5261 Arlington Avenue, Riverside CA92504 APN#226-180-015.

May 10, 2023. (Appendix G)
SSMP City of Riverside, Sewer System Management Plan, Originated July 2009 revised June 2022. (Available at
https://riversideca.gov/publicworks/sites/riversideca.gov.publicworks/files/City%20o f%20Riverside%20SSMP%20rev%202022%20%281%29.pdf, accessed July 10, 2023.)
USEPA United States Environmental Protection Agency, Characterization of Building Related Construction and Debris, dated 1988. (Available at
https://www.epa.gov/smm/characterization-building-related-construction-anddemolition-debris-united-states, accessed July 29, 2023.) UWMP Riverside Public Utilities, 2020 Urban Water Management Plan, July 1,2021. (Available at
https://riversideca.gov/utilities/sites/riversideca.gov.utilities/files/pdf/residents/RPU %20Final%202020%20UWMP%20%282%29.pdf, accessed January 24, 2023.) WIMPU City of Riverside Public Work Department, Update of the Integrated Master Plan for the Wastewater Collection and Treatment Facilities. January 2020. (Available at the City of Riverside
Section 6.0 – Consistency
DOF State of California Department of Finance, E-1 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022, May 2022. (Available at https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-andhousing-estimates-for-cities-counties-and-the-state-2020-2022/, accessed December 2, 2022.)
Section 9.0 City of Riverside
References Arlington Mixed Use Development Draft EIR
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EDD State of California, Employment Development Department, Monthly Labor Force Data for Cities and Census Designated Places (CDP) October 2022. (Available at https://www.labormarketinfo.edd.ca.gov/data/labor-force-and-unemployment-forcities-and-census-areas.html, accessed December 2, 2022.) RHNA Southern California Association of Governments, 6th Cycle Final Regional Housing Needs Assessment Final Allocation Plan. (Available at https://scag.ca.gov/rhna, accessed December 2, 2022.)
RTP/SCS Southern California Association of Governments, The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the SCAG, September 3, 2021. (Available at https://scag.ca.gov/read-plan-adopted-final-plan, accessed December 1, 2022.)
SCAG 2001 Southern California Association of Governments, The New Economy and Jobs/Housing Balance in Southern California, April 2001. (Available at https://scag.ca.gov/sites/main/files/fileattachments/neweconomyjobshousingbalance.pdf?1604179652 accessed December 2, 2022.)
SCAG 2019 Southern California Association of Governments, Profile of the City of Riverside, May 2019. (Available at https://scag.ca.gov/sites/main/files/fileattachments/riverside_localprofile.pdf?1606013511, accessed December 1, 2022.) SCAG 2020 Southern California Association of Governments, The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the SCAG, Demographics and Growth Forecast-Technical Report, September 3, 2020. (Available at https://scag.ca.gov/sites/main/files/fileattachments/0903fconnectsocal_demographics-and-growthforecast.pdf?1606001579, accessed on December 1, 2022.) SCAG 2022 Southern California Association of Governments, About SCAG. (Available at http://www.scag.ca.gov/about/Pages/Home.aspx, accessed January 18, 2023).

Section 7.0 – Other CEQA
URBAN Urban Crossroads, Arlington Mixed Use (PR-2022-001252) Traffic Analysis, December 23, 2022.

WEBB-B Albert A Webb Associates, Vehicle Miles Traveled Screening Assessment for the Proposed Arlington Mixed-use Development (PR-2022-001252) Memorandum, June 6, 2023. (Appendix F)