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28 RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF RIVERSIDE,
CALIFORNIA, CERTIFYING THE FINAL ENVIRONMENTAL IMPACT
REPORT FOR THE MISSION GROVE APARTMENTS PROJECT , MAKING
CERTAIN FINDINGS OF FACT RELATED THERETO, ADOPTING A
STATEMENT OF OVERRIDING CONSIDERATIONS, AND ADOPTING A
MITIGATION MONITORING AND REPORTING PROGRAM , ALL
PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT.
WHEREAS, an application submitted by MICHELLE RUBIN of REGIONAL PROPERTIES to develop 347 studio, one-, two-, and three -bedroom residential apartment units within five, 4-story buildings; General Plan Amendment (GPA) – to change the General Plan Land Use Designation from C - Commercial to MU -U - Mixed Use-Urban, to allow residential land use.; Zoning Code Amendment (RZ) – to change the zoning from CR-SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones to MU-U-SP – Mixed Use-Urban and Specific Plan (Mission Grove) Overlay Zones; Specific Plan Amendment (SPA) – to revise the Mission Grove Specific Plan; Tentative Parcel Map (TPM) 38598 – to subdivide the existing Parcel 1 of Parcel Map 26320 into two parcels for financing and conveyance purposes ; Design Review (DR) – for the proposed site design and building elevations ; Environmental Impact Report (EIR) – for the preparation of an Environmental Impact Report for the proposed Project; and, an Airport Land Use Commission (ALUC) – determination of consistency or inconsistency with applicable airport land use compatibility criteria of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IPA LUCP ) (collectively the “Project”) was presented for consideration; and
WHEREAS, in accordance with the requirements of the California Environmental Quality Act (“CEQA”) (Public Resources Code Section 21000 et seq.), the State of California CEQA Guidelines (“State CEQA Guidelines”) (California Code of Regulations Title 14, Cha pter 3, Sections 15000 et seq.) and the City of Riverside (“City”) CEQA Guidelines (collectively “CEQA Regulations”) an Environmental Impact Report (“EIR”) was prepared for the Project; and WHEREAS, on October 28, 2022, the City issued a Notice of Preparation of an Environmental Impact Report (“NOP” and “EIR” respectively); and
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28 WHEREAS, the NOP was filed with the State Clearinghouse on October 28th, 2022, which started a 30‐day comment period that ended on November 28th, 2022 (SCH#2022100610); and WHEREAS, any responses to the NOP were considered in the preparation of the Draft EIR and interested agencies and individuals were contacted to secure their input; and WHEREAS, the Draft EIR was completed and a Notice of Completion (“NOC”) and the Draft EIR was filed with the State Clearinghouse on or about May 10, 2024, in accordance with the provisions of section 15085 of the State CEQA Guidelines; and WHEREAS, the Notice of Availability for the DEIR was published in the Press Enterprise and distributed to a variety of government agencies, organizations and interested parties, including:
local jurisdictions, tribal governments, state and federal agencies, resource agencies, water districts and boards, transportation agencies, community groups and organizations, business organizations, chambers of commerce, universities and school districts, senior/aging organizations, interested parties and members of the public; and the DEIR was also posted on the City’s website and made available for review at City Hall at 3900 Main Street, Riverside, CA 92522, and at the Riverside Public Library, Orange Terrace Branch at 20010- B Orange Terrace Parkway, Riverside, CA 92508; and
WHEREAS, the NOC and the NOA provided a 45‐day public review period beginning May 10th, 2024, and ending June 24th, 2024; and
WHEREAS, the City received written and oral comments on the Draft EIR during this public comment period, as well as after the close of the public comment period; and WHEREAS, all comments on the Draft EIR concerning environmental issues that were received during the public review period were evaluated by the City as the Lead Agency in accordance with Section 15088 of the State CEQA Guidelines and responded to in accordance with the law; and
WHEREAS, the City Planning Commission held a duly noticed hearing on the Draft EIR on July 18, 2024; and
WHEREAS, the Final EIR dated December, 2024 for the Project consists of the May 2024 Draft EIR, comments and recommendations received on the Draft EIR, responses to comments on
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28 the Draft EIR, appendices to the DEIR, changes to the Draft EIR, and a Mitigation Monitoring and Reporting Program (collectively “FEIR”); and
WHEREAS, the FEIR includes comments received on the Draft EIR and written responses to those comments, the focus of which is on the disposition of significant environmental issues raised in the comments, as specified by CEQA Guidelines section 15088(b); and WHEREAS, the FEIR contains the elements required by the CEQA Regulations, including, but not limited to: (a) identification, description and discussion of all potentially significant environmental effects of the proposed Project; (b) a description of mitigation measures pr oposed to minimize potential significant environmental effects on the project identified in the FEIR; (c) a description of those potential environmental effects which cannot be avoided or can be mitigated but not to a level of insignifica nce; (d) a description of a range of reasonable alternatives to the proposed Project and evaluation of the comparative merits and potential significant environmental effects of the alternatives; (e) a discussion of cumulative impacts in accor dance with the requirements of section 15130 of the State CEQA Guidelines; (f) a discussion of growth inducing impacts; (g) a discussion of significant irreversible environmental changes; (h) a discussion of energy conservation; and (i) a list of all federal, state and local agencies, other organizations and private individuals consulted in preparing the FEIR and the firm preparing the FEIR; and WHEREAS, the City Council held a duly noticed hearing on the F EIR on December 3, 2024, at which time additional written and oral testimony was received; and WHEREAS, the City Council has been presented with and is familiar with the information in the administrative record, including the Staff Reports and the written and verbal testimony submitted thereon, and has reviewed and considered the information in the FEIR for completeness and compliance with the CEQA Regulations, has independently reviewed and analyzed the F EIR and has duly heard and considered the Staff Reports and all written and oral arguments presented at its meeting of December 3, 2024; and
WHEREAS, the City has made the written f indings set forth in Findings of Fact and Statement of Overriding Considerations (“Findings/SOC”) attached hereto as Exhibit “A” and incorporated herein by reference, for each potentially significant environmental impact identified
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28 in the FEIR pursuant to State CEQA Guidelines Section 15091 based upon all of the evidence in the administrative record, including, but not limited to the FEIR, written and oral testimony given at meetings and hearings, and submission of testimony from the public, organizations and regulatory agencies , and has determined that the Findings contain a complete and accurate reporting of the environmental impacts and mitigation measures associated with the Project, as well as complete and accurate reporting of t he unavoidable impacts and benefits of the Project ; and
WHEREAS, approval of the Project will result in significant effects which are identified in the FEIR that cannot be avoided or substantially lessened; and WHEREAS, the City has stated in writing the specific reasons to support its action to approve the Project, despite its significant environmental impacts, based on the F EIR and other information in the record, including in the Findings/SOC set forth in Exhibit “A” attached hereto; and
WHEREAS, the City Council certifies that (1) the FEIR for the Project has been completed in compliance with CEQA; (2) that the FEIR was presented to the City Council, and that the City Council reviewed and considered the information contained in the FEIR prior to making a decision on the Project; and (3) the F EIR reflects the City’s independent judgment and analysis, and has reviewed and considered all comments received during the public review process and at the public hearings; and
WHEREAS, the City Council found that the Project identified in the F EIR incorporated alterations or mitigation measures that avoid or substantially lessen potentially significant environmental effects associated with the Project to the fullest extent feasible; and WHEREAS, in accordance with the requirements of the CEQA Regulations, a Mitigation Monitoring and Reporting Program was prepared that identified (i) all feasible measures required to mitigate potentially significant impacts, and (ii) standards and requirements contained in Ordinances and State Laws with which the Project will be required to comply, which Mitigation Monitoring and Reporting Program is attached hereto as Exhibit “ B” and incorporated herein by reference; and
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28 WHEREAS, the City has not received any comments or additional information that constitutes substantial new information requiring recirculation under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and WHEREAS, all requirements of the CEQA Regulations have been satisfied by the City in the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated.
NOW, THEREFORE, IT IS RESOLVED by the City Council of the City of Riverside, California, and making the following findings, as follows:
Section 1: The above recitals are hereby found and determined to be true and correct and are hereby incorporated herein as if stated in full.
S ection 2 : The City Council hereby makes the following findings and conclusions:
(a) The FEIR for the Project has been completed and processed in compliance with the requirements of CEQA;
(b) The FEIR was presented to the City Council, and the City Council, as the decision making body for the City, reviewed and considered the information contained in the F EIR and the administrative record as a whole, which includes, but is not limited to, staff reports, testimony and information received, and scientific and factual data presented in evidence during the review process, prior to approving the Project; and
(c) The FEIR reflects the City’s independent judgment and analysis.
Section 3: The City Council hereby finds that any changes to the FEIR in response to comments received on the Draft EIR merely clarify, amplify or make insignificant modifications to an already adequate EIR pursuant to CEQA Guidelines Section 15088.5(b) and that no significant new information has been received that would require recirculation.
S ection 4 : The City Council finds that the Findings/SOC set forth in Exhibit “A,” attached hereto and incorporated by reference herein as if stated in full , are supported by substantial evidence in the administrative record and are hereby adopted by the City Council.
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28 Section 5: Potential environmental effects have been studied and, except as stated in Section 8 below, there is no substantial evidence in the record, as a whole, that supports any argument that the Project, as designed and mitigated, may cause a significant effect on the environment. No facts, reasonable assumptions predicated on facts, testimony supported by adequate factual foundation, or expert opinion supported by facts has been submitted that refute the conclusions reached by the F EIR, studies, data and reports. Nor does anything in the record alter the environmental determination, as presented, based upon investigation and independent assessment of those studies, data and reports. No new significant impacts have been raised by any commenting individual or entity, nor has any significant new information been added to the FEIR that would require recirculation under State CEQA Guidelines section 15088.5.
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ection 6: The F EIR dated December 3, 2024, for the Project reflects the independent judgment of the City based upon the findings and conclusions stated in the FEIR, staff reports, and in consideration of testimony and information received, and scientific and factual data presented in evidence during the review process.
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ection 7: The City Council Finds that the F EIR dated December 3, 2024, has fully examined the environmental impacts of the Project and, based on the information in the administrative record, including the analysis in the F EIR, has determined that the impacts on aesthetics, agricultural and forestry resources, air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions (generate greenhouse gas emissions, either directly or indirectly, and cumulative) , hazards and hazardous materials (except for a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard or excessive noise for people residing or working in the project area), hydrology and water quality, land use and planning (except for conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project [including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance ] adopted for the purpose of avoiding or mitigating an environmental effect [ALUC and ALUC Plan consistency]), mineral resources, noise , population and housing, publ ic services, recreation, transportation (except as significant project-generated VMT), tribal cultural
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28 resources, utilities and service systems, and wildfire either have no impact, are less than significant or are potentially significant but that with mitigation the impacts are reduced to less than significant based on the F indings/SOC set forth in Exhibit “ A” attached hereto and incorporated herein by reference, as well as the findings and analysis contained in the F EIR (collectively “Findings”).
The Findings are supported by substantial evidence contained therein as well as in the record, and as such, said Findings are hereby adopted by the City Council.
Section 8: The City Council finds that the F EIR dated December 3 , 2024 has fully examined the environmental concerns associated with the Project and, based on the information in the administrative record, including the analysis in the F EIR, has determined that the following significant impacts, identified in the FEIR, cannot be mitigated to a level of insignificant: hazards and hazardous materials (for a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard or excessive noise for people residing or working in the project area), land use and planning (conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project [including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance] adopted for the purpose of avoiding or mitigating an environmental effect [ALUC and ALUC Plan consistency]), and transportation (significant project-generated VMT).
As explained in attached Exhibit “A” Findings/ SOC, the City Council finds pursuant to Public Resources Code section 21081(a)(3) that specific economic, legal, social, technological or other considerations make infeasible additional mitigation measures or alternatives that would substantially lessen such impacts . The City Council further finds, pursuant to Public Resources Code section 21081(a)(1) and as explained in the Findings /SOC (Exhibit “A”) that changes or alterations h ave been incorporated into the P roject which mitigate or avoid those significant impacts identified in the FEIR to the fullest extent feasible.
Section 9: With the exception of the impacts identified in Section 8 above, the City Council finds that, the Project, including all mitigation measures, conditions, permits and approvals will not have any other significant adverse unmitigated impacts on the environment. Potential environmental effects have been studied and there is no substantial evidence in the record, as a
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28 whole, that supports any argument that the Project, as designed and mitigated, would cause a significant effect on the environment, except as to the impacts identified in Section 8. No facts, reasonable assumptions predicated on facts, testimony supported by adequate factual foundation, or expert opinion supported by facts has been submitted that refute the conclusions reached by the FEIR, studies, data and reports. Nor does anything in the record alter the environmental determination, as presented, based upon investigation and independent assessment of those studies, data and reports.
Section 10: The City Council finds that four (4) alternatives, including the No Project Alternative, were identified and analyzed in the F EIR and all were rejected as failing to meet all or most of the Project objectives, not sufficiently reducing environmental impacts as compared to the Project, and/or as infeasible, due to specific economic, legal, social technological and other considerations (all alternatives). These grounds are contained in the entirety of the administrative record, including the F EIR, the attached Exhibit “A” Findings /SOC, and the written and verbal testimony. Specifically:
(a) Alternative 1 – No Project/No Redevelopment (“No Project”) . The No Project alternative would not fulfill any of the Project’s objectives as the existing site would not provide high- quality housing in close proximity to many amenities and high quality transit corridors, assist the City of Riverside in meeting housing needs; use land resources more efficiently with infill redevelopment on an underutilized vacant site; or further the City’s Climate Action Plan by replacing aging building construction with green building practices and other sustainable development methods. Under this alternative, no improvements would be made to the P roject site and the site would continue to be vacant with temporary/seasonal retail tenants.
This alternative has no characteristics in common with the proposed Project nor any of the other alternatives as no proposed redevelopment would occur .
Aesthetics, air quality, cultural resources, energy, geology, GHGs, hazards, hydrology, land use, noise, population, public services, recreation, transportation, tribal cultural resources, and utilities impacts would be less than the Project;
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28 agriculture, biology, mineral resources, and wildfire impacts would be similar to the Project. The No Project alternative would not fulfill any of the Project’s objectives as the existing site would not provide high- quality housing in close proximity to many amenities and high quality transit corridors, assist the City of Riverside in meeting housing needs; use land resources more efficiently with infill redevelopment on an underutilized vacant site; or further the City’s Climate Action Plan by replacing a ging building construction with green building practices and other sustainable development methods. Under this alternative, no improvements would be made to the Project site and the site would continue to be vacant with temporary/seasonal retail tenants. This alternative has no characteristics in common with the proposed Project nor any of the other alternatives as no proposed redevelopment would occur. Because Alternative 1 meets no project objectives , and is thus infeasible, it is rejected.
(b) Alternative 2 – Reduced Density Apartment Development. This alternative would meet the project objectives, but to a much lesser extent. The impacts to agriculture, biology, cultural, geology, mineral resources, population and wildfire would be similar; impacts to aesthetics, air quality, energy, GHGs, hazards, hydrology, land use, noise, public services, recreation, transportation, tribal cultural resources, and utilities would be reduced. This alternative only partially meets project objectives 1, 2, 6, 7, and 8, and fails to meet the key objectives 3 and 4. Given the inability of this alternative to meet most or all of the project objectives , and failure to significantly reduce environmental impacts, this alternative is rejected. (c) Alternative 3 – Retail Development. analyzes alternative development of the site that remains in accord with the current land use and zoning designations and retains the existing retail building and associated surface parking, with only minor improvements to the inside of the building, the outside of the building, and/or associated surface parking lot and landscaping which would house a permanent retail tenant that would utilize the full square footage of the building for retail.
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28 Under this alternative, the land use designation and zoning would remain as is, and no SPA would be required. Impacts to aesthetics, cultural resources, energy, geology, hazards, hydrology, land use, noise, population, public services, recreation, transportation, tribal cultural resources, and utilities would be reduced.
Impacts to agriculture, biology, mineral s, and wildfire would be similar. Impacts to air quality and GHGs would be increased. This alternative would not meet any of the project objectives. On this basis, this alternative is rejected. (d) Alternative 4 – Proposed Project at Off-Site Location. This discussion analyzes the proposed 347 residential apartment project at an off -site location. While this alternative could still provide high- quality residential development it may not be located in close proximity to existing amenities and transit corridors (Project Objective 1). The City is not aware of any such available sites. The City is not aware of an available off-site location which could maximize the residential potential of the site or use of land resources (Project Objective 3) as efficiently as the proposed Project. Th City is not aware of any available site which could support the objective of creating a mixed -use environment that encourages walkability.
Without a specific location, it cannot be determined if the project objective of creating a mixed -use environment encouraging walkability (Project Objective 7) could be met. Because there is no site known which could meet most of the project objectives, this alternative remains speculative at best, and fails to meet most or all of the project objectives and is rejected on that basis.
Section 11: The FEIR dated December 3 , 2024, for the Project has been completed and processed in compliance with the requirements of the CEQA Regulations (both state and local), and based on the entirety of the administrative record is hereby certified.
Section 12
: The City Council has balanced the benefits of the adoption of the Project against its unavoidable environmental impacts and has determined that for the reasons set forth below, the economic, legal, social, technological and other benefits of the Project outweigh the unavoidable adverse environmental effects which have been identified in attached Exhibit “A ”
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28 Findings/SOC and the adverse environmental effects are therefore considered acceptable. Some of the benefits of implementing and approving the Project are summarized as follows:
(a) The Project would develop underutilized land that has been planned as part of the Mission Grove Specific Plan, a master -planned development for industrial and residential land uses, since 1985, that maximizes the use of the site, and that responds to the current housing shortage.
(b) The Project will increase the type and amount of housing available in the City of Riverside, consistent with the goals of the City's Housing Element. (c) The Project will provide high- quality residential development, consisting of 347 apartment units, close to existing amenities and transit corridors. (d) The Project will create a mixed-use environment encouraging walkability. (e) The Project will assist the City of Riverside with implementing its Climate Action Plan by replacing older building construction with newer and more green building practices and other sustainable development methods.
(f) The Project will maximize the residential potential of the site to assist the City of Riverside in meeting project housing demand as part of the City's housing needs and growth projections.
(g) The Project will utilize the land more efficiently by providing a well-planned, infill redevelopment on an underutilized vacant site (a former K -Mart retail store that closed in 2020).These findings are supported by substantial evidence and the data to support these overriding considerations are found throughout the FEIR, the supporting comments and responses section of the FEIR, and by information throughout the administrative record.
Section 1 3: Specific environmental, economic, social, legal, technical and other considerations and benefits derived from the development of the Project override and make infeasible any alternative to the Project or further mitigation measures beyond those incorporated into this Project.
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ection 1 4: The City Council further finds that the Project will provide numerous benefits to the City, as stated in Section 12 above, which outweigh its unavoidable environmental
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28 impacts and therefore adopts the Statement of Overriding Considerations set forth more fully Exhibit “A” attached hereto and incorporated herein by reference.
Section 1 5: The City Council finds that all significant environmental impacts from implementation of the Project have been identified in the FEIR and, with the implementation of the mitigation measures set forth in the Mitigation Monitoring and Reporting Program contained in Exhibit “B” attached hereto and incorporated herein by reference, will be mitigat ed to a less- than-significant level, with the exception of the impacts identified in Section 8 above. The City Council hereby adopts the Mitigation Monitoring and Reporting Program for the Project to implement the policies, goals and implementation measures identified in the FEIR as necessary to preclude the need for further mitigation measures. Said Mitigation Monitoring and Reporting Program, contained in the FEIR and attached hereto as Exhibit “B”, is hereby incorporated as part of the approval of the City Council for the adoption of the Project.
Section 16: The City Council hereby finds that the locations of documents and other materials which constitute the record of proceedings upon which its decision is based are the Community & Economic Development Department, Planning Division and the City Clerk’s Office located at 3900 Main Street, Riverside, California 92522, and the custodian of such records shall be the Community & Economic Development Director and the City Clerk, respectively.
ADOPTED by the City Council this _________ day of _______________, 2024.
________________________________
PATRICIA LOCK DAWSON
Mayor of the City of Riverside
Attest:
__________________________
DONESIA GAUSE
City Clerk of the City of Riverside
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28 I, Donesia Gause, City Clerk of the City of Riverside, California, hereby certify that the foregoing resolution was duly and regularly introduced at a meeting of the City Council on the ____ day of ____________, 2024, by the following vote, to wit:
Ayes:
Noes:
Abstain:
Absent:
IN WITNESS WHEREOF I have hereunto set my hand and affixed the official seal of the City of Riverside, California, this ___ day of _____________, 2024.
_________________________
DONESIA GAUSE
City Clerk of the City of Riverside
24-1851 ALB 11/07/24
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28 EXHIBIT A
CEQA FINDINGS OF FACT AND
STATEMENT OF OVERRIDING CONSIDERATIONS
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28 EXHIBIT B
MITIGATION MONITORING AND REPORTING PROGRAM
City of Riverside
Mission Grove Apartments Project
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EXHIBIT A
CEQA FINDINGS OF FACT AND MITIGATION MONITORING AND REPORTING
PROGRAM
This document includes the following sections:
I. Introduction to CEQA Findings of Fact
II. Location and Custodian of the Record
III. Findings for Less than Significant Impacts
IV. Findings for Impacts Identified as Significant but Mitigated to Less than Significant Level V. Findings for Impacts that are Significant and Unavoidable VI. Findings Regarding Cumulative Impacts
VII. Findings Regarding Significant Irreversible Environmental Changes VIII. Findings Regarding Growth Inducing Impacts
IX. Findings Regarding Alternatives
X. Findings Regarding No Need for Recirculation
XI. Statement of Overriding Considerations
XII. Mitigation Monitoring and Reporting Program
INTRODUCTION TO CEQA FINDINGS OF FACT
These Findings of Fact are made pursuant to the California Environmental Quality Act (Pub. Res.
Code §21000 et seq., “CEQA”) and the CEQA Guidelines (Cal. Code Regs. title 14, §15000 et seq.) by the City of Riverside, as the lead agency for the Exchange Pr oject (project). These Findings of Fact pertain to the Final Environmental Impact Report (“EIR”), State Clearinghouse #2020079023.
Project Location
1. The Project is located approximately 10 miles south of Downtown Riverside. The regional setting of the project is shown in Figure 3.0 -1 Regional Map. The Project site is within the southwestern quarter of Section 17, Township 3 South, Range 4 West, as show n on the Riverside East, California, United States Geological Survey (USGS) 7.5-minute quadrangle, Figure 3.0-2. The Project site is located in the eastern portion of the City of Riverside, east of Trautwein Road, west of Mission Grove Parkway, south of Alessandro Boulevard, and north of Mission Village Drive, Figure 3.0-3 Project Site Map.
The Project site address is 375 E. Alessandro Boulevard, Riverside CA 92508. The Project site is approximately 9.92 acres and includes the following Assessor’s Parcel Number APN 276-110-018.
Project Description Summary
Development of the Project would involve demolition and site clearing, grading and compaction, pouring of concrete and asphalt, and construction and operation of the proposed structures. The proposed P roject includes a total of 347 studio, one -, two -, and three- bedroom residential City of Riverside
Mission Grove Apartments Project
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apartments within five, 4- story buildings . The proposed Project is anticipated to house approximately 829 tenants. The Project would include indoor amenities including a leasing office, clubroom, fitness center, and outdoor amenities including a pool and spa, outdoor seating and dining areas, and a dog park.
Implementation of the Project will require the approval of the following development entitlements:
GENERAL PLAN AMENDMENT
The proposed Project includes a General Plan Amendment (GPA) to change the General Plan Land Use Designation from C – Commercial to MU-U – Mixed-Use – Urban, to allow residential land use.
CHANGE OF ZONING
The proposed Project includes a Zoning Code Amendment (RZ) to change the existing zoning of the Project site from the CR -SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones to MU-U-SP – Mixed-Use-Urban and Specific Plan (Mission Gove) Overlay Zones.
SPECIFIC PLAN AMENDMENT
The proposed Project includes a Specific Plan Amendment (SPA) to revise the Mission Grove Specific Plan. The proposed revisions to the Mission Grove Specific Plan include:
• Updating Table 2 – Amendment Descriptions to include the case number and description of the amendment.
• Updating Table 4 – Land Use (Updated to Reflect all Amendments) to include Mixed-Use – Urban for 9.92 acres, with density of 40 dwelling units per acre, and number of units of 396.80 and reducing the Non-Residential, Retail Business & Office to 59.84 acres. • Revising various text throughout the Specific Plan for consistency with the revisions above.
• Revise Section III Development Standards, to include Mixed-Use. • Revise Figure 12 – Specific Plan Proposed Zoning to include MU-U at the Project site. • Revise Section IV Appendix 2 – Development Standards Matrix to include the Land Use Designate of Mixed Use – Urban and to add standards for Open Space, Parking Reduction, and Fence and Walls.
TENTATIVE PARCEL MAP NO. 38598
The proposed Project includes Tentative Parcel Map (TPM) 38598 (Figure 3.0- 6 – Tentative Parcel Map) to subdivide the existing Parcel 1 of Parcel Map 26320 into two parcels for financing and conveyance purposes. Proposed Parcel 1 (Project site) would total 9.92 acres, similar shape and size as APN 276-110-018 with only minor realignment of parcel line in the southwest corner.
The remainder parcel, currently developed with the Mission Grove shopping center, will be approximately 9.35 acres and will be similar to the combined APNs 276- 110-012, -014, -015, - 016, and -017 in shape and size with only minor realignment of parcel line in the southeast corner.
City of Riverside
Mission Grove Apartments Project
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DESIGN REVIEW
The habitable gross square footage (SF) of the apartment community is 419,358 SF, the uninhabited square footage (e.g. garages, utility and storage closets) of the Project is 55,143 SF in total. The gross square footage of the Project is 474,501.
The Project includes 604 parking spaces in total. Of these, 513 parking spaces will be dedicated for the Proposed apartment project, and 91 will be shared between the Proposed apartment project and the existing adjacent retail site. The shared parking will be memorialized in a new covenant and restriction agreement between the residential developer entity and Mission Grove Plaza.
The Project offers a contemporary Spanish architectural style. The Project will be secured by utilizing the front façade of the residential buildings along with tubular steel fencing between the buildings. The Project includes a variety of exterior lighting fixtures that have been selected to complement and enhance the contemporary Spanish architecture and landscape features, as well as to provide functional light to vehicular and pedestrian pathways and wayfinding features.
Landscaping throughout the project site will consist of low water use trees, shrubs, and ground cover.
Procedural Compliance With CEQA
The City of Riverside (City) published a Draft Environmental Impact Report ( DEIR) on May 8th, 2024, and completed a Final EIR in compliance with CEQA requirements. As allowed for in CEQA Guidelines §15084(d)(2), the City retained consultants to assist with the preparation of the environmental documents. Acting as lead agency, the City has directed, reviewed, and edited as necessary all material prepared by the consultants, and such material reflects the City’s independent judgment. In general, the preparation of the EIR included the following key steps and public notification efforts.
• A 30‐day scoping process began with the City ’s issuance of the Notice of Preparation (NOP) of an EIR on October 28th, 2022. The NOP was filed with the State Clearinghouse on October 28th, 2022, which started a 30‐day comment period that ended on November 28th, 2022. The virtual EIR scoping meeting was held on November 2nd, 2022. • The City issued the DEIR by filing a Notice of Completion (NOC) with the State Clearinghouse on May 10, 2024. The Notice of Availability for the DEIR was published in the Press Enterprise and distributed to a variety of government agencies, organizations and interested parties, including: local jurisdictions, tribal governments, state and federal agencies, resou rce agencies, water districts and boards, transportation agencies, community groups and organizations, business organizations, chambers of commerce, universities and school districts, senior/aging organizations, interested parties and members of the public. The DEIR was also posted on the City’s website and made available for review at City Hall at 3900 Main Street, Riverside, CA 92522, and at the City of Riverside
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Riverside Public Library, Orange Terrace Branch at 20010- B Orange Terrace Parkway, Riverside, CA 92508.
• The DEIR was available for a 45‐day public review period beginning May 10th, 2024, and ending June 24th, 2024. The City held a public Planning Commission hearing on July 18, 2024.
• Following the close of the public review period, the City revised the DEIR in response to comments received during the public review period. It provided written responses addressing all significant environmental issues raised. Revisions made to the DEIR are shown in the Errata as strikethrough and underline text. • As part of its Final EIR, the City responded to all timely written comments on the DEIR, as well as comment letters received after the close of the comment review period and provided written responses to all public agencies that timely commented on the DEI R, consistent with the legal requirement that such agencies be provided written responses at least 10 days prior to any lead agency action to certify the EIR. A public City Council hearing was held on December 3, 2024, to consider certification of the Final EIR and approval of the proposed Project.
Incorporation Of Final EIR By Reference
The Final EIR is hereby incorporated by reference into these Findings of Fact. The Final EIR consists of three volumes:
1. Comments and Responses to Comments on the Draft Environmental Impact Report (Vol.
I),
2. Text Revisions to the DEIR (Vol. I),
3. Mitigation Monitoring and Reporting Program (Vol. I),
4. Draft Environmental Impact Report, May 2024 (Vol. II), and
5. Draft Environmental Impact Report Appendices, May 2024 (Vol. III).
Requirements For CEQA Findings
Pursuant to Public Resources Code §21081 and CEQA Guidelines §15091, no public agency shall approve or carry out a project for which an EIR has been certified, which identifies one or more significant effects on the environment that would occur if the project is approved or carried out, unless the public agency makes one or more of the following findings with respect to each significant impact.
1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.
2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency.
3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the EIR.
For purposes of the third of these possible findings, the CEQA Guidelines define “feasible” as “capable of being accomplished in a successful manner within a reasonable period of time, City of Riverside
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taking into account economic, environmental, legal, social, and technological factors.” (CEQA Guidelines §15364) Thus, a decision‐making body may reject a mitigation measure or project alternative as infeasible if the measure or alternative fails to meet this definition. Importantly, the courts understand the legal concept of infeasibility to encompass both (i) the ineffectiveness of a particular alternative or mitigation measure in promoting the agency’s underlying project purpose and objectives and (ii) the desirability of the measure or alternative from a policy standpoint, as reasonably determined by the decision-makers. (See City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Society v.
City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000‐ 1001; San Diego Citizenry Group v.
County of San Diego (2013) 2129 Cal.App.4th 1, 17‐18.) Environmental impacts that are less than significant do not require the imposition of mitigation measures. ( Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.)
The City of Riverside has made one or more of these specific written findings regarding each significant impact associated with the project. Those findings are presented below, along with a presentation of facts in support of the findings. The City certifies that these findings are based on full appraisal of all viewpoints, including all comments received up to the date of adoption of these findings, concerning the environmental issues identified and discussed. These findings are based on substantial evidence contained in the totality of the administrative record before the City, including, but not limited to, the Final EIR supporting evidence cited herein.
A full explanation of the environmental findings, conclusions, and mitigation measures referenced herein can be found in the Draft EIR and Final EIR; and these Findings hereby incorporate by reference the discussions and analyses in those documents. In mak ing these Findings, the City hereby ratifies, adopts, and incorporates those discussions and analyses, adopting them as the City’s own.
Location And Custodian Of The Record
The documents and other materials that constitute the record of proceedings on which the City of Riverside’s Findings of Fact are based are located at 3900 Main Street, Riverside, California. The custodian of these documents is Veronica Hernandez, Senior P lanner. This information is provided in compliance with Public Resources Code § 21081.6(a)(2) and CEQA Guidelines § 15091(e).
For purposes of CEQA and these Findings of Fact, the Record of Proceedings for the proposed Project consists of the following documents, among others:
• The Notice of Preparation and all other public notices issued by the City of Riverside and in conjunction with the proposed Project.
• The Draft and Final EIRs, including appendices and technical studies included or referenced in the Draft and Final EIRs.
• All comments submitted by agencies or members of the public during the public comment period on the DEIR.
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• All comments and correspondence submitted to the City of Riverside with respect to the proposed Project.
• The Mitigation Measure and Reporting Program (MMRP) for the proposed Project. • All Findings and resolutions adopted by the City of Riverside decision makers in connection with the proposed Project and all documents cited or referred to therein. • All reports, studies, memoranda, maps, staff reports, or other planning documents relating to the proposed Project prepared by Ruth Villalobos & Associates, Inc., consultant to the City of Riverside.
• All documents and information submitted to the City of Riverside by responsible trustee, or other public agencies, or by individuals or organizations, in connection with the proposed Project, up through the date that the City approved the proposed Project. • Any documentary or other evidence submitted to the City of Riverside at such information sessions, public meetings, and public hearings.
• Matters of common knowledge to the City of Riverside, including but not limited to applicable federal, state, and local laws and regulations. • Any documents expressly cited in these Findings of Fact, in addition to those cited above.
Any other materials, including deliberations, statements, findings, information and observations, required to be in the Record of Proceedings by Public Resources Code § 21167.6(e).
FINDINGS FOR LESS THAN SIGNIFICANT IMPACTS
The City Council hereby finds that the following impacts are less than significant without mitigation measures. The findings below are for impacts where implementation of the proposed Project would result in less than significant environmental impacts without mitigation.
These findings are based on the discussion of impacts in the detailed impact analyses in Section 5.1 through Section 5. 20 and Section 6 of the EIR, as well as relevant responses to comments in the Final EIR.
The potential impacts that are less than significant without mitigation are as follows:
AESTHETICS
Scenic Vistas
Threshold A: Would the Project have a substantial adverse effect on a scenic vista?
Finding: Less than significant. The proposed Project site is not a scenic vista itself. Of the scenic vistas identified in section 5.1.1 Setting of the DEIR. Only Box Springs Mountain is partially visible from the proposed Project site. As views of Box Springs Mountain from the Project site and surrounding area are currently partially or completely blocked, the proposed Project would not result in a substantial change to the view from the Project area of the Box Springs Mountain. (DEIR, p. 5.1-20)
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Explanation: As the view of Box Springs Mountain from the Project site is already partially or completely blocked from existing structures and mature trees in the Mission Grove Plaza, the proposed taller apartment buildings would only result in a minor incremental obstruction of this view from the Project area. The proposed Project, therefore, would not result in a substantial change in the view of this scenic vista or result in substantial adverse effects on a scenic vista.
Therefore, adverse effects on scenic vistas would be less than significant. (DEIR, p. 5.1-20) The proposed structures are compliant with the maximum building height allowed by the zone. Due to the Project’s distance from the Box Springs Mountains as well as the elevations of these mountains, it will not block views of these mountains from Alessandro Boulevard or the existing uses (commercial and residential) south of Alessandro Boulevard. The Project will not result in a substantial adverse effect on views of these mountains within the area. (DEIR, p. 5.1- 16)
Scenic Highway
Threshold B: Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway?
Finding: No impact
(DEIR, p. 5.1-20).
Explanation:
No officially designated State scenic highways or any eligible State scenic highways traverse the City or its Sphere of Influence. There are no rock outcroppings or historic building scenic resources located on the proposed Project site. The Project intends to protect in place and keep as part of the Project the existing Mexican fan palm trees located along Mission Grove Parkway.
A portion of Mission Grove Parkway North, north of Alessandro Boulevard, is designated as a Scenic and Special Boulevard in the City’s General Plan. However, the proposed project is located approximately 1,800 feet to the south of that designated special boulevard. Mission Grove Parkway South, which is located along the Project’s eastern boundary, is not designated as a Special or Scenic Boulevard. (DEIR, p. 5.1-20)
Public Views
Threshold C: In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?
Finding: Less than significant. The proposed Project is located in an urbanized area and is a redevelopment project. While the Project includes both a General Plan Amendment and a Specific Plan Amendment to change the land use designation and zoning the Project is not changing the site from a non -urbanized area to an urbanized area, as the existing land use designation and City of Riverside
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zoning are intended for commercial development. The project is consistent with all applicable zoning and other regulations governing scenic quality. (DEIR, p. 5.1-21)
Explanation: The Citywide Design and Sign Guidelines provide pictorial guidance on building treatments, façade articulation, site planning, sign guidelines and other matters in an effort to improve the overall visual quality of new development citywide. The Guidelines prevent large windowless blank walls through requiring building articulation and vegetation screening and establishing appropriate landscape areas along walls. The Guidelines also provide requirements for façade and signage treatments to prevent the use of highly reflective surfaces, large, blank, unarticulated wall surfaces, exposed, untreated precision block walls, chain link fencing, barbed wire, and materials requiring high maintenance such as stained wood, shingles, or metal siding.
The Design and Sign Guidelines also encourage the use of neutral paint colors, subtle lighting, and courtyard entrances where feasible. The Design and Sign Guidelines limit impacts to aesthetic resources by reducing interruptions of scenic vistas, maintaining and enhancing scenic resources and visual character, and reducing light and glare. The Design and Sign Guidelines will also serve to enhance Riverside’s visual character and avoid negative impacts by promoting and maintaining design continuity in the City’s neighborhoods. As the Guidelines encourage high- quality design, the proposed Project would comply with all City regulations governing scenic quality.
The proposed Project includes a contemporary Spanish architectural style that consists of stucco with score lines, concrete “S” roof tiles, and decorative stone veneer and decorative tiles to enhance project and building entries. The buildings include vary ing roof heights, articulation of building façades, and exterior building materials (stucco, decorative tile, decorative stone veneer, etc.) to provide building articulation to help break up the massing and provide detail and interest.
This contemporary Spanish architectural style also includes enhanced decorative iron details at roof vents, decorative tiles at project entries, foam trims, sills, corbels, and trellises at upper balconies. Landscaping throughout the Project site will consist of low water use trees, shrubs, and ground cover. The existing Mexican fan palms located along Mission Grove Parkway South will be protected in place and kept as part of the Project. Large trees are proposed on the periphery of the project site, along roadways, within parking lot planters, and throughout the residential common open space areas and around the apartment structures. Groundcover, shrubs and accent plants are proposed along walkways and throughout the residential common open space areas. The Project’s design and landscaping comply with the City’s Design Guidelines and Zoning Code and would not substantially degrade the existing visual character of the area. As outlined above in the analysis for Threshold A, the proposed Project would not result in a significant change in the viewshed from what currently exists in the Project area, and the proposed Project’s structures will not have a substantial adverse effect on an existing scenic vista.
Therefore, the impact on the applicable zoning and other regulations governing scenic quality would be less than significant. (DEIR, pp. 5.1-21 - 5.1-22)
Light and Glare
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Threshold D: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Finding: Less than significant. A Solar Glare Hazard Study was prepared for the Project and reviewed by the Riverside County Airport Land Use Commission staff. As outlined in the Riverside County Airport Land Use Commission, Staff Report, Agenda Item: 3.2, Case Number:
ZAP1548MA22, September 14, 2023 (RCALUC 2023), no glare from the solar panels would affect the March Air Reserve Base/Inland Port Airport Air Traffic Control Tower. T he Project’s solar panels would not result in solar glare impacts on MARB/IPA flight operations. (DEIR, p. 5.1-22 –
5.1-23) A dditionally, all lighting on the Project site is consistent with the Outdoor Lighting Ordinance of the Riverside Municipal Code. (DEIR, p. 5.1-5)
Explanation: The Project includes a variety of exterior lighting fixtures that have been selected to complement and enhance the contemporary Spanish architecture and the landscape features, as well as to provide functional light to vehicular and pedestrian pathways and wayfinding features.
Exterior light fixtures include pole lights along the Project’s main driveways and parking areas, downlights at carports, wall-mounted lights adjacent to garages, sconce lights at building entries, bollard lights along pedestrian pathways, overhead festival lighting and pendent lighting in outdoor amenity areas, and a sign light at the Project’s monument sign. The Project includes 40,00 square feet of solar panel area on the building’s rooftops and carports. (DEIR, p. 5.1-22) The proposed Project’s exterior lighting from the buildings or from the parking area will meet the City’s Zoning Code requirements for support structure height, intensity, flickering/flashing, placement, shielding, orientation, and style. The proposed project area is located in a CR commercial zone and, therefore, is designated as a Lighting Zone 3, as it does not fall into the categories of Lighting zones 0, 1, or 2. The City requires an exterior lighting plan as a condition of approval (City of Riverside Zoning Code, Chapter 19.566). A Photometric Plan was prepared as part of the Project plans and shows no light spillage from the Project outside of the property boundaries. Overall levels of light generated by the new buildings and passing cars would be comparable to typical light levels currently at the Project site and in the surrounding developed areas. (DEIR, p. 5.1-22)
A Solar Glare Hazard Study was prepared for the Project and reviewed by the Riverside County Airport Land Use Commission staff. As outlined in the Riverside County Airport Land Use Commission, Staff Report, Agenda Item: 3.2, Case Number: ZAP1548MA22, September 14, 2023 (RCALUC 2023), no glare from the solar panels would affect the March Air Reserve Base/Inland Port Airport Air Traffic Control Tower. Some potential for glare was identified within the Air Force traffic pattern and evaluation of the Air Force traffic patterns indicated that the panels would result in a low potential for temporary after-image (“green” level glare). The anticipated amount of green glare produced annually from the Project is below ALUC’s threshold of 20% of daylight minutes , and there would be no significant (red glare) glint or glare impacts. Therefore, the Project’s solar panels would not result in a solar glare impact on MARB/IPA flight operations. The Project will also comply with recommended conditions related to light and glare with minor modifications to City of Riverside
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continue to ensure safety but allow for flexibility in the final design of the Project’s solar panels.
Additionally, in May 2021, the FAA released a new policy that no longer requires glare and glint studies for green glare. Therefore, the proposed Project will not result in a substantial new source of light or glare and impacts with regard to daytime or nighttime views in the vicinity of the project site will be less than significant. (DEIR, p. 5.1-22 – 5.1-23)
AGRICULTURE AND FORESTRY RESOURCES
Farmland
Threshold A : Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (“Farmland”), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use?
Finding: No Impact. (DEIR, p. 5.2-2 – 5.2-3)
Explanation: A review of Figure OS-2 – Agricultural Suitability of the GP 2025 reveals that the project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and is not adjacent to or in proximity to any land classified as, Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Figure OS-2 was prepared pursuant to the California Department of Conservation, Farmland Mapping and Monitoring Program. Figure OS-2 shows the project site and adjacent areas as Urban and Built-Up Land. An area designated as Farmland of Local Importance is the closest Farmland Mapping and Monitoring Program designation to the project site, located approximately one mile northwest. The project will not convert any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (“Farmland”) or of Local Importance.
(DEIR, p. 5.2-2 - 5.2-3)
Agricultural Zoning or Williamson Act Contract
Threshold B: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
Finding: No impact. (DEIR, p. 5.2-3)
Explanation: A review of Figure OS-3 – Williamson Act Preserves of the GP 2025 and Figure 5.2- 2 – Williamson Act Preserves of the General Plan 2025 FPEIR reveals that the project site is not located within an area that is affected by a Williamson Act Preserve or under a Williamson Act Contract. Moreover, the project site is not zoned for agricultural use and is not next to land zoned for agricultural use. (DEIR, p. 5.2-3)
Forest Land or Timberland
Threshold C: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
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Finding: No impact. (DEIR, p. 5.2-3)
Explanation: Forest land, as defined in the Public Resources Code section 12220(g), is land that can support ten-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.
Timberland, as defined in the Public Resources Code section 4526, is land, other than land owned by the federal government, and land designated by the State Board of Forestry and Fire Protection as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees.
The Project site does not contain riparian vegetation. The Project site does not contain timberland, is not zoned for timberland production and is not next to land zoned for timberland. The City has no designated forest land or timberland as defined in Sections 12220[g] and 4526 of the California Public Resources Code. (DEIR, p. 5.2-3)
Forest Land Conversion
Threshold D: Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
Finding: No impact. (DEIR, p. 5.2-3)
Explanation: The City has no designated forest land. Presently, the project site has the zoning designations of Commercial-Retail (CR) per the City’s current zoning map. There are no active forest land resources or operations in proximity of the project site and the proposed Project would not result in the conversion of any forest land. (DEIR, p. 5.2-3)
Farmland Conversion
Threshold E Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use?
Finding: No impact. (DEIR, p. 5.2-3 - 5.2-4)
Explanation: The Project site is not designated as, or in close proximity to any land classified as Prime Farmland or Unique Farmland, and it does not support agricultural resources or operations.
The proposed Project will not result in the conversion of designated farmland to non- agricultural uses. In addition, there are no agricultural resources or operations, including farmlands immediately adjacent to the Project site. (DEIR, p. 5.2-4)
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AIR QUALITY
Conflict with Air Quality Plan
Threshold A: Would the Project conflict with or obstruct the implementation of the applicable air quality plan?
Finding: Less than significant. The Project would not result in or cause NAAQS or CAAQS violations. Although the Project would not be consistent with the current General Plan land use designation, the Project would seek a GPA for land use designation consistency, and construction and operational- source emissions would not exceed the applicable SCAQMD regional and localized thresholds. As such, the Project is therefore considered to be consistent with the AQMP. (DEIR, p. 5.3-25)
Explanation: The SCAQMD published the 1993 CEQA Air Quality Handbook to assist lead agencies, as well as consultants, project proponents, and other interested parties in evaluating potential air quality impacts of projects proposed in the Basin. The CEQA Air Quality Handbook provides standards, methodologies, and procedures for conducting air quality analyses in EIRs, including criteria for determining a Project’s consistency with an AQMP, which are found in Chapter 12 of the CEQA Air Quality Handbook. While the Handbook is currently under revision, Chapter 12 is not among the chapters, appendices, or tables that the SCAQMD has recommended to avoid using. The SCAQMD states that methodologies within the Handbook can still be used as long as documentation is provided regarding the source and applicability to a project. Thus, the Project’s consistency with the 2022 AQMP was determined using the project consistency criteria defined in Chapter 12, Section 12.2 and Section 12.3 of the SCAQMD’s CEQA Air Quality Handbook. These indicators are discussed below. Additionally, the SCAQMD air quality significance thresholds reflect the most recent thresholds, which were updated in March 2023. (DEIR, p. 5.3-20)
Consistency Criterion No. 1: The proposed project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.
Construction activities associated with the Project will result in emissions of VOCs, NO x, Sox, CO,
PM10, and PM 2.5. Construction-related emissions are expected from the following construction activities: demolition, site preparation, grading, building construction, architectural coating, and paving. (DEIR, p. 5.3-20)
The construction analysis includes estimating the construction equipment that would be used during each construction activity, the hours of use for that construction equipment, the quantities of earth and debris to be moved, and the on- road vehicle trips ( e.g., worker, soil -hauling, and vendor trips). The proposed earthwork for the Project includes 5,118 cubic yards (cy) of cut and 5,950 cy of fill. It was assumed that the cut would be reused as fill, leaving 832 cy of fill import City of Riverside
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required. CalEEMod defaults are assumed for the construction activities, off-road equipment, and on-road construction fleet mix and trip lengths. It is expected that construction would start in 2025 and take approximately 28 months, with an opening in 2027. (DEIR, p. 5.3-20)
The most recent version of CalEEMod (Version 2022.1.0) was used to develop the construction equipment inventory and calculate the construction emissions. The CalEEMod output is included in Attachment C of the Project’s Air Quality Analysis. (DEIR, p. 5.3-21)
Fugitive dust emissions are generally associated with land clearing and exposure of soils to the air and wind, as well as cut-and-fill grading operations. Dust generated during construction varies substantially on a project -by-project basis, depending on the level of activity, the specific operations, and weather conditions at the time of construction. The construction calculations prepared for this Project assumed that dust control measures (watering a minimum of two times daily consistent with SCAQMD Rule 403) would be employed to reduce emissions of fugitive dust during site grading. Furthermore, all construction would need to comply with SCAQMD Rule 403 regarding the emission of fugitive dust. (DEIR, p. 5.3-21)
Architectural coatings contain VOCs that are part of the O 3 precursors. Based on the Project, it is
estimated that application of the architectural coatings for the proposed peak construction day would result in a peak of 11 pounds per day (lbs/day) of VOCs. Therefore, VOC emissions from architectural-coating application would not exceed the SCAQMD VOC construction threshold of 75 lbs/day. (DEIR, p. 5.3-22)
Construction Localized Impacts Analysis shows the portion of the construction emissions that would be produced on the Project site compared to the Localized Significance Thresholds (LSTs).
Localized construction emissions would not exceed LSTs and therefore would not result in a locally significant air quality impact. The Project’s regional and localized construction- source emissions would not exceed applicable regional significance and LST thresholds. (DEIR, p. 5.3- 23)
Long-term air pollutant emission impacts are those associated with mobile sources (e.g., vehicle trips), energy sources (e.g., electricity and natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment) related to the Project. (DEIR, p. 5.3- 23)
PM
10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways. Entrainment of PM 10 occurs when vehicle tires pulverize small rocks and pavement, and the vehicle brakes generate airborne dust.
The contribution of tire and brake wear is small compared to the other PM emission processes.
Gasoline-powered engines have small rates of particulate matter emissions compared with diesel- powered vehicles. Based on the project Vehicle Miles Traveled Analysis (LSA 2023) prepared for City of Riverside
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the Project, the proposed Project would generate a total of 1,464 vehicle trips on a peak day (weekday), which was accounted for in the CalEEMod analysis. (DEIR, p. 5.3-23)
Energy source emissions result from activities in buildings that use electricity and natural gas.
The quantity of emissions is the product of usage intensity (i.e., the amount of electricity or natural gas) and the emission factor of the fuel source. Major sources of energy demand include building mechanical systems, such as heating and air conditioning, lighting, and plug-in electronics, such as computers. Greater building or appliance efficiency reduces the amount of energy for a given activity, thus lowering the resultant emissions. The emission factor is determined by the fuel source, with cleaner energy sources, like renewable energy, producing fewer emissions than conventional sources. The Project would include the required solar panels with the capacity to generate approximately 1,275,500 kWh annually . Typically, area source emissions consist of direct sources of air emissions at the Project site, including architectural coatings and the use of landscape maintenance equipment. Area source emissions associated with the Project would include emissions from the use of landscaping equipment and the use of consumer products. The Project would not exceed the significance criteria for any pollutant emissions; therefore, operation of the Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in nonattainment under an applicable Federal or State AAQS . (DEIR, p. 5.3-23)
Consistency with Criterion 2: The project will not exceed the assumptions in the AQMP based on the years of project build-out phase.
The 2022 AQMP builds upon measures already in place from previous AQMPs. As with the previous 2016 AQMP, the 2022 AQMP demonstrates that the applicable ambient air quality standards can be achieved within the timeframes required under Federal law. (DEIR, p. 5.3-24)
Growth projections from local general plans adopted by cities in the district are provided to the SCAG, which develops regional growth forecasts, which are then used to develop future air quality forecasts for the AQMP. The future growth projections are ba sed on demographic growth forecasts for various socioeconomic categories, such as population, housing, and employment by industry. The demographic growth forecasts were developed by SCAG for their 2020 RTP/SCS and were also used in the 2022 AQMP. As the growth projections in the AQMP reflect the SCAG growth projections from local general plans in the region, development consistent with the growth projections in City of Riverside General Plan are consistent with the AQMP. (DEIR, pp. 5.3-24 –
5.3-25)
The City of Riverside General Plan designates the Project site as Commercial. The Commercial designation provides for retail, sales, service, and office uses that serve multiple neighborhoods within the City. The Project consists of multifamily residential dwelling units. The Project’s residential land use and development is not consistent with the land use designation stated in the General Plan. As such, the Project would include a General Plan Amendment (GPA) to change City of Riverside
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the land use designation from Commercial to Mixed-Use-Urban, which would allow the Project to be developed in an existing retail environment. This would help create a framework for integration of uses with features such as pedestrian connectivity, walkability, and shared elements, including parking. (DEIR, p. 5.3-25)
While the Project would require a GPA for not being consistent with the site’s original land use designation, because the Project construction and operational regional and localized emissions would not exceed the thresholds of significance, the Project would not cause an exceedance of an air quality violation. It should also be noted that the residential use proposed by the Project will generate less traffic and consequently fewer emissions than if the Project site were developed consistent with the commercial land use designation (retail, sales, service, and office uses), which would generate more trips and consequently more emissions than the Project. Rather, as noted, the Project would promote pedestrian connectivity and walkability, which would aid in reducing vehicle trip emissions in the area. Therefore, the Project will not exceed the assumptions in the AQMP based on the years of the Project build-out phase and is determined to be consistent with Criterion 2. (DEIR, p. 5.3-25)
The Project would not result in or cause NAAQS or CAAQS violations. Although the Project would not be consistent with the current General Plan land use designation, the Project would seek a GPA for land use designation consistency, and construction and ope rational-source emissions would not exceed the applicable SCAQMD regional and localized thresholds. As such, the Project is therefore considered to be consistent with the AQMP, and any potential impacts would be less than significant. (DEIR, p. 5.3-25)
Criteria Pollutants
Threshold B: Would the Project result in a cumulatively considerable net increase in any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
Finding: Less than significant. The Project would not exceed any of the applicable significance thresholds or significance criteria, the Project would not result in a cumulatively considerable net increase of any criterial pollutant for which the Project region is in nonattainment under an applicable Federal or State AAQS. (DEIR, p. 5.3-26)
Explanation: The Basin is designated as nonattainment for O 3 and PM2.5 for Federal standards and nonattainment for O3, PM10, and PM2.5 for State standards. The SCAQMD’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s City of Riverside
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contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.
As discussed under Threshold A, regarding construction emissions, the Project’s Air Quality Analysis determined that the Project’s daily regional construction emissions and localized emissions would not exceed the established thresholds of any criteria pollutant emissions thresholds established by SCAQMD. Additionally, regarding operational emissions, the Project’s Air Quality Analysis determined that the Project would not exceed the significance criteria for any pollutant emissions. (DEIR, pp. 5.3-25 – 5.3-26)
Pollutant Concentrations
Threshold C: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than significant. Construction emissions would not exceed SCAQMD thresholds established to protect public health and air quality. Therefore, the health risk associated with construction emissions would be less than significant for the surrounding sensitive uses. (DEIR, p. 5.3-27)
Explanation: SCAQMD published its Final Localized Significance Threshold Methodology in June 2003 and updated it in July 2008, recommending that all air quality analyses include an assessment of both construction and operational impacts on the air quality of nearby sensitive receptors. LSTs are based on the ambient concentrations of that pollutant within the project’s Source Receptor Area (SRA) and the distance to the nearest sensitive receptor. The Project site is in the Metropolitan Riverside County area, or SRA 23, and the nearest sensitive receptors to the Project site are single- family residential units that are at least 115 feet to the south of the Project site boundary, across Mission Village Drive.
The SCAQMD provides LST screening tables for 25, 50, 100, 200, and 500-meter source-receptor distances. As noted, the nearest sensitive receptors are located approximately 115 feet (35 meters) from the Project site boundary. The Project site is 9.92 acres; however, the construction activities would only take place on portions of the Project site on any one (1) day. The SCAQMD recommends assuming that four (4) acres would be disturbed in any 1 day; therefore, LSTs for the 4 acre/35- meter combination were derived by interpolation in the Project’s Air Quality Analysis. Table 5.3 -10 – SCAQMD Localized Significance Thresholds shows the emissions thresholds that would apply to the Project based on project size and distance to the nearby receptors during Project construction and operation. (DEIR, p. 5.3-26)
The Project would not exceed these applicable emissions thresholds based on P roject size and distance to the nearest sensitive receptors during construction and operation. Health Risk Assessments (HRAs) include an evaluation of diesel particulate matter (DPM) emissions associated with a stationary source (combustion source for manufacturing) or mobile sources City of Riverside
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(such as heavy truck traffic associated with warehousing). Mobile HRAs are typically conducted to evaluate long-term exposure (e.g. 9 or 30 years) to DPM emissions associated with a project’s long-term diesel truck travel (i.e. those traveling to and from warehouses) on nearby sensitive receptors (residences, schools, etc.). Heavy -duty off -road construction equipment (graders, excavators, dozers, scrapers, loaders, etc.) typically have diesel engines and emit DPM emissions. However, construction activity is typically short -term (1 -2 years or less), as is anticipated for the proposed Mission Grove Apartments project, and does not constitute long-term exposure, typically used to generate risk estimates. As outlined above, construction emissions would not exceed SCAQMD thresholds established to protect public health and air quality.
Therefore, the health risk associated with construction emissions would be less than significant for the surrounding sensitive uses. Therefore, the Project would not expose sensitive receptors to substantial pollutant concentrations; potential impacts would be less than significant. (DEIR p.
5.3-27)
Emissions Leading to Odors
Threshold D: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Finding: Less than significant. No sources of objectionable odors have been identified or are expected for the proposed Project. The Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, the proposed Project would not result in other emissions, such as those leading to odors, that would adversely affect a substantial number of people. Potential impacts would be less than significant. (DEIR, p. 5.3-28)
Explanation: Heavy-duty equipment in the project area during construction would emit odors, primarily from the equipment exhaust. However, construction-produced odors would cease after individual construction is completed. No other sources of objectionable odors have been identified for the proposed Project. SCAQMD addresses odor criteria within the CEQA Handbook. The SCAQMD has not established a rule or standard regarding odor emissions; rather, the district has a nuisance rule: “Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.” Land uses and industrial operations that are associated with odor complaints include agricultural uses, wastewater treatment plants, food -processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. The proposed Project would not fall under any of these categories.
City regulations require trash storage areas to be in an enclosed area to limit air circulation from them and through adherence to City regulations, odors from trash storage areas would be minimal. The proposed Project’s trash enclosures are planned with the following features:
• All trash/recycling enclosures will be located within vestibules in the residential buildings (there will not be any trash enclosures in exterior areas of the property); • There will be one set of trash and recycling chutes per building (5 sets of trash/recycling chutes total for the property); and
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• Each set of trash chutes will have ventilation to move the indoor air up to the roof.
With these measures, no sources of objectionable odors have been identified or are expected for the proposed Project. (DEIR, pp. 5.3-27 – 5.3-28)
BIOLOGICAL RESOURCES
Riparian Habitat
Threshold B: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Finding: No impact. (DEIR, p. 5.4-10)
Explanation: The Project site consists of an existing structure with associated paved surface parking within a developed commercial shopping center. The Project site does not support any discernible drainage courses, inundated areas, or wetland vegetation that would be considered riparian/riverine habitat under Section 6.1.2 of the MSHCP. The Project site does not contain any special-status or sensitive natural communities, nor does the Project site contain any federally designated Critical Habitat. (DEIR, p. 5.4-10)
Federally Protected Wetlands
Threshold C : Would the Project have a substantial adverse effect on Federally -protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: No impact. (DEIR, p. 5.4-11)
Explanation:
The Project site assessment indicated that there are no records of wetlands or potential jurisdictional drainage features existing within the Project site and no potentially jurisdictional drainage features, wetlands, or riparian areas were observed on sit e during the February 2023 survey. Existing conditions and results indicate the site is entirely developed, with no ephemeral drainage features or culverts observed and no riparian vegetation is present on the Project site.
Based on these findings, the Project would not have any adverse effect on Federally protected wetlands and would not result in direct or indirect impacts to any delineated jurisdictional waters, including wetlands. (DEIR, p. 5.4-10-11)
Interfere with Wildlife Migratory Corridors
Threshold D:
Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites?
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Finding: No impact. (DEIR, p. 5.4-11)
Explanation: Wildlife movement includes seasonal migration along corridors and daily movements for foraging. Migration corridors may include areas of unobstructed movement of deer, riparian corridors providing cover for migrating birds, routes between breeding waters and upland habitat for amphibians, and areas between roosting and feeding areas for birds.
The Project site does not contain any essential connectivity areas, natural landscape blocks, natural areas, or potential riparian connections. The Project site is developed and bordered by existing paved roads and development on all adjoining properties that restrict wildlife movement in the Project vicinity. The majority of wildlife movement within the Project site is anticipated to be limited to wildlife present on site or within the ornamental vegetation present within the Project site. The Project would not substantially limit wildlife movement. (DEIR, p. 5.4-11)
Conflict with Policies or Ordinances Protecting Biological Resources Threshold E:
Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Finding: No impact. (DEIR, p. 5.4-11)
Explanation:
The City’s General Plan Open Space and Conservation element in the General Plan 2025 (GP 2025) seeks to preserve existing natural resources and open space in the City. The Project will not conflict with Objective OS-1, Policies OS-1.1 and 1.5 as the site does not contain open space or natural habitat and would be consistent with Policy OS -1.6 as the proposed new development is effectively integrated with existing convenient street and pedestrian connections as well as visual connections. The Project will not conflict with Objective OS-5, Policy OS-5.2 as it will comply with all applicable requirements of the MSHCP, including payment of the MSHCP fee.
The City does not have a tree preservation ordinance, but it has an adopted Urban Forestry Policy Manual to establish guidelines for planting, pruning, preservation, and removal of all trees in City rights-of-ways (PW). The City Public Works Department is responsible for the maintenance of all street trees planted by the Project within City right-of-way in accordance with the Urban Forestry Policy Manual (PW, p. 14). The Project does not propose the removal of any existing trees within public rights-of-way. As discussed, the Project intends to protect in place the existing Mexican fan palm trees located along Mission Grove Parkway south and keep as part of the Project . (DEIR, p. 5.4-11-12)
Conflict with a Habitat Conservation Plan
Threshold F: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
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Finding: No impact. (DEIR, p. 5.4-12)
Explanation: The Project site is located within the MSHCP Plan Area. The site is not located in a Criteria Cell. The MSHCP requires that projects comply with its Sections 6.1.2 (Protection of Species within Riparian/Riverine Areas and Vernal Pools), 6.1.3 (Protection of Narrow Endemic Plant Species), 6.1.4 (Urban and Wildlands Interface), 6.3.2 (Additional Survey Needs and Procedures), Appendix C (Standard Best Management Practices), and Section 7.5.3 (Construction Guidelines). The Project’s consistency with each of these sections is discussed below.
Section 6.1.2 Protection of Species within Riparian/Riverine Areas and Vernal Pools – The Project site is developed and does not contain riparian/riverine areas, vernal pools, or suitable habitat for sensitive species associated with these habitats.
Section 6.1.3 Protection of Narrow Endemic Plant Species – The Project site is not within a Narrow Endemic Plant Species survey area and the Project site does not support suitable habitat for any MSHCP narrow endemic plant species.
Section 6.1.4 Guidelines Pertaining to the Urban Wildlands Interface – The Project site is not adjacent to conserved lands or lands in a Criteria Area described for conservation. Therefore, the Urban Wildlands Interface Guidelines do not apply to this project.
Section 6.3.2 Additional Survey Needs and Procedures – The Project site is not within an MSHCP mapped survey area for Criteria Area Plant Species, amphibians, small mammals, or burrowing owl (Athene cunicularia).
Appendix C Standard Best Management Practices – The Project site is not adjacent to conserved lands or lands in a Criteria Area described for conservation. Therefore, the Standard Best Management Practices do not apply to this project.
Section 7.5.3 Construction Guidelines – The Project site is not within the Criteria Area or PQP lands. Therefore, the Construction Guidelines do not apply to this project.
Stephens Kangaroo Rat Habitat Conservation Plan (SKRHCP)
The Project is within the SKR HCP fee area. However, the Project is within an existing urban development built environment with no suitable habitat for the species. Despite not having any suitable habitat for this species, the Project is required to pay the SKR mitigation fee as it is located in the fee area of this HCP.
The Project site is not located within any other Habitat Conservation Plans, Natural Community Conservation Plans, or other approved local, regional, or state habitat conservation plans. The Project site is located in a developed, highly urbanized area and would not impact any sensitive habitat or special-status species. (DEIR, p. 5.4-12)
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CULTURAL RESOURCES
Historical Resources
Threshold A: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5 of the CEQA Guidelines?
Finding: No impact. (DEIR, p. 5.5-13)
Explanation: As discussed above, no historic or archaeological resources have been documented within or adjacent to the Project site. The proposed Project site is completely developed with a 104,231- square-foot, vacant retail building and an associated surface parking lot. The vacant retail building is a former K-Mart retail store that was constructed in 1991 and was closed in 2020.
As the building has no historical significance and is only 32 years old, it does not meet any of the criteria to be considered a Landmark or a Resource or Structure of Merit. (DEIR, p. 5.5-13)
Disturb Human Remains
Threshold C: Would the Project disturb any human remains, including those interred outside of formal cemeteries?
Finding: Less than significant. No human remains were observed during the 2023 pedestrian survey and it is unlikely human remains would be discovered, implementation of the Project would not disturb any human remains, including those interred outside of formal cemeteries. (DEIR, p.
5.5-12 and 5.5-14)
Explanation: As indicated in the Archaeological Site Records included in the cultural resources report, no human remains were observed at any of the aforementioned seven archaeological sites within the Project’s APE during the 2023 field surveys. In the unlikely event of an accidental discovery of human remains in a location other than a formal cemetery, the process under Health and Safety Code Section 7050.5, CEQA Guidelines Section 15064.5(e), and Public Resources Code Section 5097.98 would be followed. (DEIR, p. 5.5-14) ENERGY
Wasteful, Unnecessary Consumption of Energy Resources
Threshold A : Would the Project result in potentially significant environmental impact due to wasteful, inefficient, unnecessary consumption of energy resources, during project construction or operation?
Finding: Less than significant. The Project would not result in potentially significant environmental impact due to wasteful, inefficient, unnecessary consumption of energy resources, during project construction or operation. (DEIR, p. 5.6-15)
Explanation: The Project would increase the demand for electricity, natural gas, and gasoline compared to the existing condition of the site. The discussion and analysis below is based on data City of Riverside
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included in the Project’s California Emissions Estimator Model (CalEEMod) output, which is included as Attachment C of the Project’s Energy Analysis memorandum. Under CEQA, a Project would result in a potentially significant environmental impact if the Project employed wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. Thus, the following analyzes the Project’s projected construction and operational energy use to evaluate the Project’s consumption of energy resources. (DEIR, p. 5.6-12)
Construction Energy Use
The anticipated construction schedule assumes that the Project would be built over approximately 28 months. The Project would require demolition, site preparation, grading, building construction, architectural coating, and paving during construction.
Construction of the Project would require energy for the manufacture and transportation of building materials and for preparation of the site for grading activities and building construction.
Petroleum fuels (e.g., diesel and gasoline) would be the primary sources of energy for these activities.
Construction activities are not anticipated to result in an inefficient use of energy because gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the Project. Additionally, the Project would consist of an infill redevelopment project that would not require construction methods that would result in energy use that would exceed that of standard construction practices.
Energy usage on the Project site during construction would be temporary in nature and would be relatively small in comparison to the State’s available energy sources. Therefore, construction energy impacts would be less than significant, and no mitigation would be required. (DEIR, p. 5.6- 13)
Operational Energy Use
Energy use includes both direct and indirect sources of emissions. Direct sources of emissions include on-site natural gas usage for heating of common areas/amenities, while indirect sources of emissions include electricity generated by off-site power plants. The Project would incorporate all-electric appliances within the residential units; the units would not include any natural gas connections or use propane or other fossil fuels. Use of natural gas connections would be limited to some Project common use areas/amenities.
The estimated potential increased natural gas demand associated with the Project is 4,473,806 kBTU per year, or 49,738 therms. (LSA 2023) In 2021, California’s total natural gas consumption was 1,192,270,564 therms, while Riverside County consumed 430.8 million therms. (430,843,598 therms; CECc 2023) Therefore, the natural gas demand associated with the Project would be approximately 0.01 percent of Riverside County’s total natural gas demand and would be a minimal increase in the County’s natural gas consumption.
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In addition, vehicles associated with trips to and from the Project site would be subject to fuel economy and efficiency standards, which are applicable throughout the State. These statistics do not include the increasing use of electric vehicles. As such, the fuel efficiency of vehicles associated with Project operations would increase throughout the life of the Project. Therefore, implementation of the Project would not result in a substantial increase in transportation- related energy uses.
As supported by the preceding analyses, Project operations would not result in the inefficient, wasteful, or unnecessary consumption of energy. Further, the energy demands of the Project can be accommodated within the context of available resources and energy delivery systems. The Project does not require upgrades to off -site RPU transmission facilities and does not cause or result in the need for additional energy producing facilities off-site. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State. Potential impacts would be less than significant. (DEIR, p. 5.6-13 - 5.6-15)
Conflict with State or Local Plan for Renewable Energy or Energy Efficiency Threshold B: Would the Project conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
Finding: Less than significant. The Project’s plans for renewable energy or energy efficiency are consistent with state and local plans. Project-applicable energy plans are also consistent with the objectives and policies of the GP 2025’s Open Space and Conservation and Public Facilities and Infrastructure Elements, and the City’s Restorative Growthprint Climate Action Plan (RRG-CAP) and Green Action Plan. (DEIR, p. 5.6-15 - 5.6-16)
Explanation:
Consistency with 2021 IEPR
As indicated above, energy usage on the Project site during construction would be temporary in nature. In addition, energy usage associated with operation of the Project would be relatively small in comparison to the State’s available energy sources and energy impacts would be negligible at the regional level. Because California’s energy conservation planning actions are conducted at a regional level and because the Project’s total impacts to regional energy supplies would be minor, the Project would not conflict with California’s energy conservation plans as described in the CEC’s 2021 IEPR. In addition, the Project would comply with applicable 2022 Title 24 and CALGreen standards, which would ensure the Project would not otherwise interfere with, nor obstruct implementation of the goals presented in the 2021 IEPR.
Consistency with 2018 IRP
Electricity would be provided to the Project by RPU. RPU’s 2018 IRP builds on existing State programs and policies. As such, the Project is consistent with, and would not otherwise interfere with, nor obstruct, implementation of the goals presented in the 2018 IRP.
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Additionally, the Project will comply with the applicable Title 24 standards which would ensure that the Project energy demands would not be inefficient, wasteful, or otherwise unnecessary. As such, development of the Project would support the goals presented in the 2018 IRP.
Consistency with RRG CAP
The Project would implement energy-saving features and operational programs, consistent with the reduction measures set forth in the RRG CAP. For example, RRG-CAP Section 4.3 – Energy Efficiency provides a number of energy efficiency related measures that would result in emission reductions within Riverside County. Among the measures is R1 -EE1: California Building Code Title 24. As previously discussed, the Project would be required to comply with all applicable Title 24 Building Code standards for multifamily residential buildings, such as providing EV charging stations and implementing solar panels. The Project’s inclusion of solar panels would additionally include the implementation of RRG -CAP measure R2- CE1 – Clean Energy, which states that installing solar photovoltaic panels on residential building rooftops is an effective way to produce renewable energy on site.
Therefore, the Project will not conflict with or obstruct a state or local plan for renewable energy or energy efficiency and potential impacts would be less than significant . (DEIR, p. 5.6-15 - 5.6- 16)
Energy Conservation
Threshold C: Would the Project achieve the goal of energy conservation by the following:
• Decreasing overall per capita energy consumption;
• Decreasing reliance on fossil fuels such as coal, natural gas and oil; and • Increasing reliance on renewable energy sources?
Finding: Less than significant. The Project would comply with the 2023 California Building Code and utilize all-electric appliances within the Project’s residential units and decrease reliance on fossil fuels while including photovoltaic energy sources. (DEIR, p. 5.6-16 - 5.6-17)
Explanation: The proposed Project is subject to California Building Code requirements. New buildings must achieve compliance with 2022 Building and Energy Efficiency Standards and the 2022 California Green Building Standards requirements.
Per Section 4.106.4.2 of the 2022 Title 24, Part 11 CALGreen standards, new multifamily dwellings such as the Project and new residential parking facilities must comply with 2022 CALGreen standards to facilitate future installation and use of EV chargers and electric vehicle supply equipment (EVSE). Additionally, the Project would comply with the 2023 California Building Code and utilize all-electric appliances within the Project’s residential units. The residential units would not use natural gas connections, propane, or other fossil fuels; rather, natural gas connections would only be used for common space areas/amenities. In addition, the Project would implement photovoltaic solar power. On this basis, the Project would decrease overall per capita City of Riverside
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energy consumption; decrease reliance on fossil fuels such as coal, natural gas, and oil; and increase reliance on renewable energy sources. Therefore, potential impacts would be less than significant. (DEIR, p. 5.6-16 -17)
GEOLOGY AND SOILS
Faulting and Surface Rupture, Seismic Shaking, Landslides Threshold A: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: i) rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Spec ial Publication 42; ii) strong seismic ground shaking; iii) seismic - related ground failure, including liquefaction?
Finding: Less than significant. The Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death. i) The potential hazards associated with fault rupture are considered less than significant; ii) Potential impacts associated with seismic ground shaking will be less than significant; iii) Potential impacts associated with seismic ground failure, including liquefaction, will be less than significant; iv) With compliance of applicable regulations as well as policies identified in the General Plan, impacts resulting in risk of loss, injury, or death due to landslides are considered less than significant. (DEIR, p. 5.7-10 –
5.10-11)
Explanation:
i) Fault Rupture: Unlike damage from ground shaking, which can occur at great distances from the fault, impacts from fault rupture are limited to the immediate area of the fault zone where the fault breaks along the surface. The Project site does not lie within or adjacent to an Alquist- Priolo Earthquake Fault Zone and no faults were identified on the site during site evaluations.
Additionally, per the City’s General Plan 2025 PEIR there are no faults lines or fault zones within the City of Riverside boundaries. The possibility of damage due to ground rupture is considered low since no active faults are known to cross the site. The closest known active faults are associated with the San Bernardino Valley section of the San Jacinto Fault, located approximately 12 miles northeast of the Project site, and the Glen Ivy section of the Elsinore Fault Zone, located approximately 12 miles southwest of the Project site. Thus, the potential for damage due to fault rupture is considered remote. Even so, the Project is required to comply with the building design standards of the California Building Code (CBC) for construction of new buildings related to seismicity.
ii) Strong Seismic Ground Shaking: The Project site is located within the seismically active region of Southern California and may be subject to ground-shaking events. While no known active faults traverse the City, several faults in the region have the potential to produce seismic impacts within the City. As mentioned above, the two significant faults that are closest to the Project site are the Jacinto and Lake Elsinore Faults.
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The Project will be designed to resist seismic impacts in accordance with the applicable Municipal Code Title 16- Buildlings and Construction standards. Such building code compliance is required for development of all structures in the City. Project plans will be reviewed during the plan check process to confirm seismic safety measures and the structural engineer’s seismic design considerations are incorporated. Moreover, there is nothing unique about the Project site that would require additional measures beyond compliance with the adopted building code and the structural engineer’s seismic design considerations.
iii) Seismic-Related Ground Failure, Including Liquefaction: The entire Project site is underlain by Cretaceous -aged Val Verde Tonalite, a type of plutonic rock. The site is underlain at shallow depths by granitic bedrock; therefore, the potential for liquefaction induced settlement or seismic “dry-sand” settlement to occur beneath the site is considered low. Further, per the City’s General Plan 2025 PEIR the Project site is not in an area mapped as a liquefaction zone.
iv) Landslides: Seismically induced landslides and other slope failures are common occurrences during or soon after earthquakes. The susceptibility of a geologic unit to landslides is dependent upon various factors, primarily: 1) the presence and orientation of weak structures, such as fractures, faults, and joints; 2) the height and steepness of the pertinent natural or cut slope; 3) the presence and quality of groundwater; and 4) the occurrence of strong seismic shaking.
Strong ground shaking can also worsen existing unstable slope conditions. Per the City’s General Plan 2025 PEIR, the Project site is located in an area with 0-10% slopes. The Project site has relatively flat topography as it was graded and developed as a commercial retail store with associated parking. Furthermore, as discussed in threshold A i) and ii) above, there are no active faults on the Project site and the possibility of damage due to ground rupture is considered low since no active faults are known to cross the site. The closest known active fault is the San Jacinto Fault approximately 12 miles northeast from the Project site.
As outlined in the geotechnical report prepared for the project, landslides are not mapped on or near the site and due to the relatively level topography at the site landslides are not present at the property or at a location that could impact the project site. (DEIR, p. 5.7-10 - 5.10-11)
Erosion or Loss of Topsoil
Threshold B: Would the Project result in substantial soil erosion or the loss of topsoil?
Finding: Less than significant. With implementation of an approved S torm Water Pollution Prevention Plan (SWPPP) as well as the Project’s design considerations, potential impacts from erosion during construction or operation will be less than significant. (DEIR, p. 5.7-11)
Explanation: In order to obtain coverage under the NPDES Construction General Permit, a Project-specific SWPPP must be prepared. The SWPPP would outline Best Management Practices, including erosion control measures during construction, for the proposed Project. The City of Riverside
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stormwater management measures identified in the SWPPP will be implemented to effectively control erosion and sedimentation for the duration of construction.
As outlined in the WQMP, the proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems which have been incorporated into the site design to fully address storm water runoff volumes. As outlined in the WQMP, the volume and time of concentration of storm water runoff for the post -development condition is not different from the pre-development condition. Therefore, the proposed Project will not result in an increase to the rate or amount of surface runoff from the site, and in turn would not result in substantial erosion or siltation off-site. (DEIR, p. 5.7-11)
Unstable Soil
Threshold C: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Finding: Less than significant. With the implementation of Project -specific geotechnical recommendations (as Project Design Considerations) and the adopted building code, potential impacts associated with seismically induced landslides, lateral spreading, subsidence, liquefaction or collapse will be less than significant. (DEIR, p. 5.7-11 - 5.10-12)
Explanation: As outlined in the geotechnical report, the Project sit e is not susceptible to liquefaction and has a low risk of landslides. The site is underlain at shallow depths by granitic bedrock; therefore, the potential for liquefaction induced settlement or seismic “dry -sand” settlement to occur beneath the site is considered low.
As outlined in the geotechnical study for the Project, hydrocompression is the tendency of unsaturated soil structure to collapse upon wetting resulting in the overall settlement of the affected soil and overlying foundations or improvements supported thereon. Potentially compressible soils underlying the site are typically removed and recompacted during remedial site grading. However, if compressible soil is left in- place, a potential for settlement due to hydrocompression of the soil exists. For the proposed Project, remedial grading would remove and reprocess the site soils, resulting in compacted fill overlying granitic bedrock. Therefore, hydrocompression is not a design consideration for this site, and potential impacts from subsidence and settlement would be less than significant. (DEIR, p. 5.7-11 - 5.10-12)
Expansive Soil
Threshold D: Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
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Finding: Less than significant. The Project’s geological investigation testing on -site soils determined that the soils have a “very low” expansion potential. (DEIR, p. 5.7-12)
Explanation: Expansive soils are clayey soils characterized by their ability to undergo significant volume changes (shrinking or swelling) due to variations in moisture content, the magnitude of which is related to both clay content and plasticity index. These volume changes can be damaging to structures. Nationally, the annual value of real estate damage caused by expansive soils is exceeded only by that caused by termites. The onsite soils encountered include sands and decomposed granitic rock. Clay develops as granitic rock weathers; therefore, some clay would be expected to be present within the soils at the site. Laboratory testing result indicates a sample of the near surface soil exhibits a “very low” expansion potential (expansion index [EI] of 20 or less) with test results showing an expansion index of 0. (DEIR, p. 5.7-12)
Use of Septic Tanks or Alternative Wastewater Disposal Systems Threshold E: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
Finding: No impact. (DEIR p. 5.7-12)
Explanation: The City disposes of wastewater for the Project site and surrounding area. The proposed Project will be served by sewer infrastructure and will not utilize or require septic tanks or alternative wastewater disposal systems. Therefore, the proposed Project will have no impact. (DEIR, p. 5.7-12)
GREENHOUSE GAS
GHG Emissions
Threshold A: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Finding: Less than significant. The Project will result in approximately 2,528 MTCO2e per year, which would not exceed the SCAQMD/City’s screening threshold of 3,000 MTCO2e per year.
Therefore, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (DEIR, p. 5.8-29, -30, -31)
Explanation: Construction activities associated with the Project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil -based fuels to operate. The combustion of fossil -based fuels creates GHGs such as CO
2, CH4, and N 2O. Furthermore, CH 4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.
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The SCAQMD does not provide a separate GHG significance threshold for construction emissions; rather, their guidance specifies that construction emissions should be amortized over 30 years (a typical project lifetime), added to the project operational emissions, and that total compared to the GHG significance threshold. The City has not adopted its own numeric threshold of significance for determining impacts with respect to GHG emissions. A screening threshold of 3,000 MTCO2e per year to determine if additional analysis is required is an acceptable approach for small projects. This approach is a widely accepted screening threshold used by the City and numerous cities in the Basin and is based on the SCAQMD staff’s proposed GHG screening threshold for stationary source emissions for non- industrial projects, as described in the SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (“SCAQMD Interim GHG Threshold”). The SCAQMD Interim GHG Threshold identifies a screening threshold to determine whether additional analysis is required.
Long-term GHG emissions are typically generated from mobile sources (e.g., cars, trucks and buses), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobile-source GHG emissions would include project-generated vehicle and truck trips to and from the Project.
Area-source emissions would be associated with activities such as landscaping and maintenance on the Project site. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project generated waste. The Project would include solar panels with the capac ity to generate approximately 1,275,500 kWh per year.
Operational GHG emissions were estimated using CalEEMod and the results are presented in Table 5.8 -5 – Long-Term Operational GHG Emissions. As previously described, SCAQMD guidance specifies that construction emissions should be amortized over 30 years, added to project operational emissions, and that total be compared to the GHG significance threshold. The Project will result in approximately 2,528 MTCO 2e per year, which would not exceed the SCAQMD/City’s screening threshold of 3,000 MTCO2e per year. Therefore, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (DEIR, p. 5.8-29, -30, -31)
Conflict with Plan, Policy, or Regulation for reducing GHG Emissions Threshold B: Would the Project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Finding: Less than Significant. While some measures are not directly applicable, the Project will not conflict with the provisions of the 2022 Scoping Plan, the City RRG CAP, or the RTP/SCS or conflict with their implementation and in fact supports several of the action categories. Thus, the Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions. (DEIR p. 5.8-32, -33, -34, -35, -36) City of Riverside
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Explanation: The 2022 Scoping Plan Update reflects recent legislation that extends and expands upon earlier scoping plans by setting a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. 2022 Scoping Plan Appendix D – Local Actions, outlines approaches that lead agencies may consider for evaluating alignment of proposed plans and residential and mixed-use development projects with the State’s climate goals. (CARB 2022b) While the approaches are recommendations and not requirements, Appendix D of the 2022 Scoping Plan notes that the State currently faces both a housing crisis and a climate crisis, which necessitates prioritizing recommendations for residential projects to address the housing crisis in a manner that simultaneously supports the State’s GHG and regional air quality goals. Pursuant to 15604.4 of the CEQA Guidelines, a lead agency may rely on qualitative analysis or performance- based standards to determine the significance of impacts from GHG emissions. As such, and per the CARB guidance provided in the above excerpt from 2022 Scoping Plan Appendix D, the Project’s consistency with Appendix D Section 3.2.1 – Project Attributes for Residential and Mixed- Use Projects to Qualitatively Determine Consistency with the Scoping Plan.
Additionally, the Project has been analyzed for consistency with the 2020- 2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) of the Southern California Association of Governments (SCAG). As part of the state’s mandate to reduce per- capita GHG emissions from automobiles and light trucks, the RTP/SCS presents strategies and tools that are consistent with local jurisdictions’ land use policies and incorporate best practices for achieving the state-mandated reductions in GHG emissions at the regional level through reduced per-capita vehicle miles traveled (VMT). The strategies are intended to be supportive of implementing the regional SCS. Several strategies are directly tied to supporting related GHG reductions while others support the broader goals of the RTP/SCS. The Project has been analyzed for consistency with applicable RTP/SCS strategies as they related to reducing GHG emissions. The Project will not conflict with the provisions of the 2022 Scoping Plan, the City RRG CAP, or the RTP/SCS or conflict with their implementation and in fact supports several of the action categories. Thus, the Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions. (DEIR, p. 5.8-33, -34, -35, -36, -37, -38, -39, -40, -41, - 42, -43, -44,-45, -46)
HAZARDS AND HAZARDOUS MATERIALS
Routine Transport, Use, or Disposal of Hazardous Materials Threshold A: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Finding: Less than significant. The Project will conform with the applicable Federal and State laws related to the transportation and storage of hazardous materials, and future use will be subject to Federal, State, and local regulations. The proposed land use, as residential, would not entail the manufacturing or disposal of hazardous materials. Compliance with all applicable local, City of Riverside
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State and federal laws would ensure a less than significant impact from routine transport, use, or disposal of hazardous materials. (DEIR p. 5.9-11)
Explanation: The transportation of hazardous materials can result in accidental spills, leaks, toxic releases, fire, or explosion. It is possible that licensed vendors could bring some hazardous materials to and from the site as a result of the proposed Project. However, appropriate documentation for all hazardous waste that is transported in connection with specific Project-site activities would be provided in compliance with existing hazardous materials regulations codified in Titles 8, 22, and 26 of the CCR, and their enabling legislation set forth in Chapter 6.95 of the CHSC. In addition, future users would be required to comply with all applicable Federal, State, and local laws and regulations pertaining to the transport, use, disposal, handling, and storage of hazardous waste, including but not limited to the USDOT Office of Hazardous Materials Safety Title 49 of the CFR, and implemented by Title 13 of the CCR which prescribes strict regulations for the safe transportation of hazardous materials. Compliance with the applicable Federal and State laws related to the transportation of hazardous materials would reduce the likelihood and severity of accidents during transit; therefore, impacts would be less that significant.
Hazardous materials are required to be stored in designated areas designed to prevent accidental release to the environment. The CFC requirements prescribe safe accommodations for materials that present a moderate explosion hazard, high fire or physical hazard, or health hazards.
Compliance with all applicable Federal and State laws related to the storage of hazardous materials would maximize containment and provide for prompt and effective clean- up if an accidental release occurs.
Project-specific Phase I and Phase II ESAs were prepared for the proposed Project. (Frey, 2021 and Frey, 2022) The site inspection included a visual review of the Site for past or present use, storage, handling, and disposal of potentially hazardous substances, and possible future releases of such substances. In addition to a site inspection, information for the proposed Project site and surrounding area was reviewed to assess potential on- site and off-site sources of chemicals of concern (COCs) in soil and groundwater beneath the proposed Project site.
As a result of the Phase I ESA findings, a Phase II ESA was conducted to evaluate whether a vapor intrusion risk exists for the planned residential buildings from four off -site properties classified as RECs and VECs in the Phase I ESA report.
Soil samples from 6 borings were examined to characterize the soil lithology and to look for evidence of the presence of chemicals of potential concern (COPCs). The soil samples were also screened in the field for undifferentiated volatile organic compounds (UVOCs) using a photo ionization detector (PID). Subsurface soil encountered during the advancement of soil borings consisted primarily of gravelly sand (decomposed granite) in all soil borings. Groundwater was not encountered during the advancement of the soil borings. A total of six soil vapor samples were collected and analyzed for total petroleum hydrocarbons as gasoline (TPHg) and VOCs during City of Riverside
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the Phase II ESA. Concentrations of bromodichloromethane and chloroform in one of the soil vapor samples collected (VP5) slightly exceeded one or more regulatory screening level. No other compounds were detected over any regulatory screening levels in any soil vapor samples.
Based on the results of this environmental site assessment, the Phase II ESA concludes that the off-site RECs listed in the Phase I report do not appear to have environmentally impacted the locations of the proposed buildings at the Project site. Based on the results of the Phase I and Phase II ESAs, no further action was recommended. (DEIR, p. 5.9-11, -12, -12, -13, 14)
Reasonably Foreseeable Accidents
Threshold B: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Finding: Les s than significant. Future use will be subject to Federal, State, and local regulations, potential impacts related to the creation of a significant hazard to the public or the environment through reasonably foreseeable upset and accidental conditions involving the release of hazardous materials into the environment would be unlikely, therefore the impact would be less than significant.
Explanation: Construction of the proposed Project has the potential to create a hazard to the public or environment through the transportation, use, and disposal of construction- related hazardous materials such as fuels, oils, solvents, and other materials. These materials are typical materials delivered to construction sites. However, due to the limited quantities of these materials to be used by the proposed Project, they are not considered hazardous to the public at large. In accordance with the City’s Hazardous Materials Policy, the transport, use, and storage of hazardous materials during the construction and operation of the site would be conducted pursuant to all applicable local, State, and federal laws, and in cooperation with the County’s Department of Environmental Health. Title 49 of the Code of Federal Regulations (CFR) implemented by Title 13 of the CCR describes strict regulations for the safe transportation of hazardous materials. Compliance with all applicable local, State, and federal laws r elated to the transportation, use, and storage of hazardous materials would reduce the likelihood and severity of accidents during transit, use, and storage.
With regard to the proposed Project operations, widely used hazardous materials common for residential uses include paints and other solvents, cleaners, and pesticides. As required by California Health and Safety Code Section 25507, a business shall establish and implement a Hazardous Materials Business Emergency Plan for emergency response to a release or threatened release of a hazardous material in accordance with the standards prescribed in the regulations adopted pursuant to Section 25503 if the business handles a hazardous material or a mixture containing a hazardous material that has a quantity, at any one time, above the thresholds described in Section 25507(a)(1) through (6). Furthermore, the proposed land use, as residential, would not entail the manufacturing or disposal of hazardous materials. (DEIR p. 5.9-11) City of Riverside
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Hazards Within One-Quarter Mile of Schools
Threshold C : Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one- quarter mile of an existing or proposed school?
Finding: No impact. (DEIR p. 5.9-13)
Explanation: The proposed Project operations are anticipated to use hazardous materials common for residential uses, including paints and other solvents, cleaners, and pesticides. The proposed land use, as residential, would not entail the emitting hazardous emissions or handle hazardous or acutely hazardous materials or substances.
The proposed Project site is not located within one-quarter mile of an existing or proposed school site. The schools nearest the Project site are: 1) Taft Elementary School, located at 959 Mission Grove Parkway North in the City of Riverside (approximately 1.03 miles northwest of the Project site); and 2) John F. Kennedy Elementary School, located at 19125 Schoolhouse Lane in the City of Riverside (approximately 1.15 miles southwest of the Project site). As both schools are located over one-quarter mile away from the Project site, the proposed Project would have no impact regarding emitting hazardous emissions or handling hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. (DEIR, p. 5.9-13)
Hazardous Materials Site
Threshold D: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment?
Finding: Less than significant. The Project site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. (DEIR, p. 5.9-14)
Explanation: The proposed Project site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Further, as discussed in Threshold B above, the Phase I ESA identified LUSTs in the vicinity of, but not within, the Project site; the Phase II ESA concluded that the off-site RECs listed in the Phase I report do not appear to have environmentally impacted the location of the proposed Project site. (DEIR, p. 5.9-14) City of Riverside
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Hazard to Emergency Routes
Threshold F: Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Finding: Less than significant. T he Project would not impair implementation of or physically interfere with an emergency response or evacuation plan. (DEIR, p. 5.9-24)
Explanation: The Project will be served by Mission Grove Parkway South and Mission Village Drive. No street closures are required during the Project’s construction. Per the GP 2025, Public Safety Element Technical Background Report (TBR), Figure CP -8: Evacuation Routes, Alessandro Boulevard is an arterial evacuation route and the SR-60 and I-215 are designated as freeway evacuation routes. Thus, the Project site is located adjacent to and has access to Alessandro Boulevard and SR-60 and I-215, designated evacuation routes.
Emergency response and evacuation procedures would be coordinated through the City in coordination with the police and RFD. The Project would not impair an adopted emergency response plan or evacuation plan and would comply with necessary procedures. The P roject’s surrounding roadways would continue to provide emergency access to the Project area and to surrounding properties during construction and operation of the Project. (DEIR, p. 5.9-24)
Hazard to Wildfires
Threshold G: Would the Project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
Finding: The Project would be constructed in compliance with the CFC and CBC, along with being compliant with the GP 2025 and RFD requirements. The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. (DEIR, p. 5.9-24 -25)
Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project site is bordered by Mission Grove Parkway South to the east and Mission Village Drive to the south. The Project site has the Mission Grove Shopping Center and parking to the north and west. Outside of the shopping center is existing residential development to the south, west and north, and commercial/retail to the east. The only open space area with vegetation that could fuel a wildland fire near the Project site is the Sycamore Canyon Wilderness Park, located approximately 3,500 feet to the northeast. If there were a wildland fire in the Sycamore Canyon Wilderness Park it would not be expected to spread to the Project site due to the distance between them and separation by existing development and Alessandro Boulevard. And for these same City of Riverside
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reasons, if a fire were to occur at the Project site it would not be expected to spread to the Sycamore Canyon Wilderness Park.
The Project will incorporate RMC standards related to fire suppression at the Project site such as smoke detectors meeting the current CBC and CFCs installed in all units and other enclosed common areas such as hallways, recreation rooms, and utility rooms. Additional fire suppression equipment such as alarm systems, fire extinguishers and sprinklers will also be incorporated as recommended by the RFD. Furthermore, Project structures would be required to comply with the CFC with regard to emergency fire access and use of building materials that would limit the spread of wildfire to the greatest extent possible.
The nearest fire stations are Orangecrest Station No. 11, located at 19595 Orange Terrace Parkway and Canyon Crest Station No. 9, located at 6674 Alessandro Boulevard, both of which are less than 2 miles from the Project site. Due to the Project’s close pr oximity to existing fires stations, adequate response times can be provided by RFD. Also, the Project plans include a Fire Access Plan which demonstrates adequate fire access will be provided. (DEIR, p. 5.9-24 -25)
HYDROLOGY AND WATER QUALITY
Water Quality Standards and Waste Discharge Requirements Threshold A : Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
Finding: Less than significant. With compliance with all applicable local, state, and federal laws regulating surface water quality, including implementation of the project specific SWPPP and WQMP, the proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality. (DEIR, p. 5.10-9)
Explanation: Expected pollutant sources from the project include interior drains, indoor/structural pesticide use, landscape/outdoor pesticide use, refuse areas, plazas, sidewalks, and parking lots.
The Preliminary Project Specific WQMP outlines the LID BMPs required to adequately meet water quality standards and reduce storm water runoff. Furthermore, one of the LID principles for the proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems. These LID BMPs have been incorporated into the site design to fully address all expected pollutant sources and storm water runoff volumes.
In addition, coverage under the State’s General Permit for Construction Activities requires a Project-specific Storm Water Pollution Prevention Plan (SWPPP). Storm water management measures identified in the SWPPP will be implemented to effectively control erosion and sedimentation and other construction-related pollutants for the duration of construction.
With compliance with all applicable local, state, and federal laws regulating surface water quality, including implementation of the project specific SWPPP and WQMP, the proposed Project would City of Riverside
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not violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality. (DEIR, p. 5.10-9)
Groundwater Supplies
Threshold B : Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Finding: Less than significant. Development of the project would not significantly alter the volume of stormwater runoff leaving the site or the point of discharge from the site and would not in turn alter groundwater management of downstream receiving water bodies. (DEIR, p. 5.10-9 - 10)
Explanation: The Project will be served by Western Municipal Water District for domestic water supply. The project’s potential to decrease groundwater supplies is analyzed in the Utilities and Services Systems section of this EIR, specifically under the following threshold, “Will the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?”. (Utilities Threshold 5.19.4.b)
Natural infiltration capacity is not currently present as the site has been previously developed, largely with impervious surfaces. Therefore, implementation of the proposed Project would not impede groundwater recharge because it does not currently provide for groundwater recharge of stormwater at the site. Also, per the WQMP, the existing drainage pattern at the site is in a southwesterly overland flow. The proposed drainage patterns will be preserved at the existing site. Pollutant and flow control BMPs will maintain the site’s existing hydrologic response. In addition, the proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems. Therefore, development of the project would not significantly alter the volume of stormwater runoff leaving the site or the point of discharge from the site and would not in turn alter groundwater management of downstream receiving water bodies. (DEIR, p. 5-9 -10)
Alteration to Existing Drainage Patterns
Threshold C: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surface, in a manner which would: i) result in substantial erosion or siltation on- or off- site; ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; and/or iv) impede or redirect flood flows?
Finding: Less than significant. The Project will not result in substantial erosion or siltation, increase flood risk, exceed the capacity of existing or planned stormwater drainage systems, provide City of Riverside
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substantial additional sources of polluted runoff, or impede flood flows, on- or off-site. (DEIR, p.
5.10-10, -12)
Explanation: The project site is currently developed with a small percent of permeable surface due to the presence of a commercial retail building and associated parking lots. The site does not contain a stream or river. Upon construction of the project, including: residential buildings, amenities, landscaping, and drive aisles, the permeable area of the project site would increase; the total impervious area is currently 475,191 SF, and post-Project the impervious area would be 437,965 SF. (WQMP 2022, Appendix G)
As outlined in the WQMP, the existing drainage patterns have been identified as southwesterly overland flow. The proposed drainage patterns will be preserved at the existing site drainage discharge locations. Pollutant and flow control practices will maintain the site’s existing hydrologic response. The proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems which have been incorporated into the site design to fully address storm water runoff volumes. As outlined in the WQMP, the volume and time of concentration of storm water runoff for the post -development condition is not different from the pre -development condition for a 2 -year return frequency storm (a difference of 5% or less is considered insignificant). Per Table F.1 of the WQPM the pre-condition storm water runoff volume is 26,782 cubic feet, and the post-conditions is also 26,782 cubic feet, with no change (0% difference) from existing condition to implemented proposed project. Therefore, the proposed project will not result in an increase to the rate or amount of surface runoff from the site, and in turn would not result in flooding, additional sources of polluted runoff off, or substantial erosion or siltation off -site. As there would be no increase of the amount of runoff, the project would not exceed the capacity of existing or planned stormwater drainage systems. Storm water management measures identified in a SWPPP would be required to be implemented to effectively control erosion and sedimentation and other construction-related pollutants for the duration of construction.
Furthermore, the proposed project site is not located within a flood hazard area. The FEMA FIRM map of the Proposed Project area (FEMA Map Number 06065C0740G) shows it is located in Zone X, which is an area of minimal flood hazard. The storm water drainage system will be installed concurrently with the construction of this project and will be adequately sized to accommodate the drainage created by this Project. On -site storm water and non -stormwater runoff will be treated with onsite BMPs identified in the Preliminary Project Specific WQMP and then discharged to the existing drainage facilities that extend off -site, retaining the overall drainage pattern of the site. Therefore, the proposed Project will not impede or redirect flood flows. (DEIR, p. 5.10-11)
Inundation
Threshold D : Would the Project , in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
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Finding: No impact. (DEIR, p. 5.10-11)
Explanation: The FEMA FIRM map of the Proposed Project area (FEMA Map Number 06065C0740G) shows it is located in Zone X, which is an area of minimal flood hazard. As the proposed Project site is in a minimal flood hazard zone, it is unlikely to release pollutants due to project inundation. As outlined above, the WQMP includes BMPs which have been incorporated into the site design to fully address all expected pollutant sources and storm water runoff volumes.
Tsunamis are large tidal waves that occur in coastal areas and the Project site is not located in a coastal area and would not be susceptible to tsunamis. A seiche is a to -and-fro vibration of a waterbody that is similar to the slopping of water in a basin. Once initiated, oscillation within the waterbody can continue independently. Seiches are often triggered by earthquakes. The most likely areas that could be subject to a seiche are the areas surrounding lakes. The Project site is not within proximity to Lake Mathews (approximately 10 miles), Lake Evans (approximately 4.5 miles), or the Santa Ana River (approximately 4.5 miles). The project site is also not located within a flood zone area or a dam inundation area as seen on Figure 5.8-2 in the GP FPEIR. (DEIR, p.
5.10-11)
Water Quality Control Plan
Threshold E: Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Finding: Less than significant. The proposed P roject would not conflict with or obstruct the implementation of a water quality control plan or sustainable groundwater management plan. (DEIR, p. 5.10-11, -12)
Explanation: The Project site is located in the Santa Ana River watershed. The Water Quality Control Plan (Basin Plan) for the Santa Ana River Basin (Region 8), as amended, includes water quality goals and policies, descriptions of conditions and discussions of solutions. I t is also the basis for the Regional Board’s regulatory programs and establishes water quality standards for the ground and surface waters of the region. The term “water quality standards,” as used in the federal Clean Water Act, includes both the beneficial uses of specific waterbodies and the levels of quality which must be met and maintained to protect those uses. As outlined in the WQMP, the project’s downstream receiving water is Santa Ana River, Reach 3. As the WQMP includes BMPs designed to fully address all expected pollutant sources and storm water runoff volumes, the proposed project is not anticipated to conflict with or obstruct implementation of the Basin Plan.
As outlined in response to Threshold B above, the Preliminary Project Specific WQMP, outlined that natural infiltration capacity is limited at the site. Therefore, development of the site would not impede groundwater recharge because it does not currently provide for groundwater recharge of stormwater at the site.
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The Project will be served by Western Municipal Water District for domestic water supply. The project’s potential to decrease groundwater supplies is analyzed in the Utilities and Services Systems section of this EIR, specifically under the following threshold, “Will the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?”. (DEIR, p. 5.10-12, -13, -14)
LAND USE AND PLANNING
Divide a Community
Threshold A: Would the Project physically divide an established community?
Finding: No impact. (DEIR, p. 5.11-10)
Explanation: The Project site is currently developed with an existing 104,231 square foot vacant retail building (former K -Mart store) and associated parking lot. The structure would be demolished and replaced by the proposed Project. The proposed Mixed Use-Urban land use and zoning has been selected for this site to bring together medium - to high-density residential and retail development in a mixed- use environment. The Mixed Use -Urban zone would allow the proposed apartment Project to be introduced into the existing retail environment and would create a framework for integration of uses, with features such as pedestrian connectivity and shared elements including parking. Rather than dividing an existing community, the proposed Project would create community and infrastructure connections by creating a mixed- use environment encouraging walkability and an urban setting, and by providing a high- quality residential development in close proximity to many amenities and transit corridors. The project would accomplish these goals by creating paved walkways and marked crosswalks throughout the Project site for resident paths of travel. These resident paths of travel would connect to existing public paths of travel, such as the sidewalks along Mission Grove Parkway South and Missi on Village Drive, which would create walkable and bikeable connectivity between the Project’s residential uses and surrounding existing shopping center uses. The location of the proposed project would allow residents pedestrian access to amenities that would otherwise only be accessible by burdening traffic and public transportation. The centralized location of the project would allow residents and their guests to forgo having to drive to these resources and incentivizes their use. The proposed Project is located within 1,200 feet of a Stater Bros grocery store, a Galaxy Theatres movie theatre, a hobby store, a hair salon, a gym, animal hospital and pet grooming, bank and ATMs, UPS Store, Goodwill Bookstore & Donation Center, Circle K convenient store, Starbucks coffee shop, and a variety of restaurants. Pedestrian walkways allow foot traffic to the neighboring shopping center amenities; current use of the closed K -Mart and seasonal Halloween store does not accomplish these goals. Furthermore, rezoning and redevelopment of the proposed Project site would serve to increase the type and amount of housing available, consistent with the goals of the City’s Housing Element, and to assist the City in meeting project housing demand as part of the City’s growth projections. The development of the Project would not displace residents or any established community. (DEIR, p. 5.11-10) City of Riverside
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MINERAL RESOURCES
Loss of Mineral Resources
Threshold A: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Finding: No impact. (DEIR, p. 5.12-3 -4)
Explanation: State-classified Mineral Resource Zones (MRZ) are shown in Mineral Land Classification Map prepared by California Department of Conservation. Per the GP 2025 PEIR Figure OS -1 Mineral Resources, the Project site is located in an MRZ- 3 Zone. The MRZ- 3 designation is for areas that have been determined by the California Department of Conservation to contain “known or inferred mineral occurrences of undetermined mineral resource significance.” As the project site is developed for commercial uses, the Project site is not within or adjacent to areas of known mineral resources that would be of value to the region or the State as identified in Figure OS-1 Mineral Resources.
Approximately 0.4 miles southwest of the proposed Project site is an area that is designated “Rock Products” (RP) by the GP 2025 Figure OS -1 Mineral Resources. However, this entire area has been developed for commercial and residential land uses. Furthermore, implementation of the proposed project would not conflict with any Mineral Resources or Open Space Element GP policies.
The Phase I ESA did not identify any active or previous mining occurring on site. There are no current mining operations surrounding the Project site. Therefore, the site and surrounding areas are not designated for mineral resources or mining or allow for these types of uses/operations.
Thus, development of the Project site is not anticipated to result in the loss of a known mineral resource that would be of value to the region and the residents of the State. (DEIR, p. 5.12-3, -4)
Loss of Recovery Sites
Threshold B: Would the Project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Finding: No impact. (DEIR, p. 5.12-4)
Explanation: The GP 2025 PEIR determined that there are no specific areas with the City boundary or the Proposed Sphere of Influence Area which have locally -important mineral resource recovery sites and that the implementation of the GP 2025 would not significantly preclude the ability to extract State-designated resources. (DEIR, p. 5.12-4) City of Riverside
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NOISE
Generation of a Substantial Increase in Ambient Noise Levels Threshold A: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Finding: Less than significant. The Project would not result in a permanent increase in ambient noise or in excess of local regulations. (DEIR, p. 5.13-16 -21)
Explanation:
Short-Term Construction Noise Impacts
Two types of short -term noise impacts could occur during construction on the project site. The first type would be from construction crew commutes and the transport of construction equipment and materials to the project site, which would incrementally raise noise levels on roadways leading to the site. The pieces of construction equipment for construction activities would move on site, would remain for the duration of each construction phase, and would not add to the daily traffic volume in the project vicinity. Although there would be a relatively high si ngle-event noise exposure potential causing intermittent noise nuisance (passing trucks at 50 ft would generate up to a maximum of 84 dBA), the effect on longer-term ambient noise levels would be small because the number of daily construction- related vehicle trips is small compared to existing daily traffic volume on Mission Grove Parkway and Mission Village Drive. Roadways that would be used to access the project site are Mission Grove Parkway South and Mission Village Drive. Mission Grove Parkway South and Mission Village Drive have estimated existing daily traffic volumes of 10,353 and 1,962, respectively, near the project site. Based on the information above, construction‐related traffic would increase noise by up to 1.3 dBA. A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment. Therefore, short-term, construction -related impacts associated with worker commutes and transport of construction equipment and material to the Project site would be less than significant.
The second type of short -term noise impact is related to noise generated from construction activities. Construction is performed in discrete steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. The proposed Project anticipates demolition, site preparation, grading, building construction, paving, and architectural coating phases of construction. These various sequential phases change the character of the noise generated on a Project site. Therefore, the noise levels vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase.
Although the closest residence and commercial use may be subject to temporary substantial ambient noise level increases, short- term construction noise levels would not exceed the FTA construction noise criteria of 80 dBA Leq for residences and 85 dBA Leq for commercial uses. In addition, Section 7.35.010 of the City’s Municipal Code exempts construction noise during the City of Riverside
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daytime between the hours of 7:00 a.m. and 7:00 p.m. on weekdays and between the hours of 8:00 a.m. and 5:00 p.m. on Saturdays. Compliance with the City’s exempt hours of construction pursuant to Section 7.35.010 of the City’s Municipal Code and the mitigation measure related to construction activities in the Mission Grove Specific Plan ( outlined below as MM NOISE -1 and MM NOISE -2) requiring the use and proper maintenance of noise -reducing devices on construction equipment would minimize construction- related noise and ensure construction noise would not be generated during the more sensitive nighttime hours. Although s hort-term noise increases due to construction activities would be less than significant and no noise reduction mitigation measures are necessary based on the noise impact analysis conducted for the Project pursuant to CEQA guidelines , mitigation measures have been included in compliance with the Mission Grove Specific Plan due to the Project’s location within the plan’s boundaries.
MM NOISE -1: The use and proper maintenance of noise reducing devices on construction equipment will minimize construction-related noise.
MM NOISE-2: Construction activities will take place only during those days and hours specified in the City Noise Ordinance to reduce noise impacts during more sensitive time periods.
Long-Term Traffic Noise Impacts
The FHWA Highway Traffic Noise Prediction Model (FHWA RD -77-108) was used to evaluate traffic-related noise conditions along street segments in the project vicinity. This model requires various parameters, including traffic volumes, vehicle mix, vehicle speed, and roadway geometry, to compute typical equivalent noise levels during daytime, evening, and nighttime hours. The resulting noise levels are weighted and summed over 24 -hour periods to determine the CNEL values. The Existing (2022), Opening Year (2027), and Cumulative (2045) ADT volumes were obtained from traffic counts conducted on May 12 and 17, 2022, and calculated with the project trip generation and cumulative project information. The standard vehicle mix for Southern California roadways was used for roadways in the project vicinity. The traffic noise levels for the Existing (2022), Opening Year (2027), and Cumulative (2045) Without and With Project scenarios, were analyzed and compared. These noise levels represent the worst -case scenario, which assumes that no shielding is provided between the traffic and the location where the noise contours are drawn. The analysis shows that the proposed Project would result in a project-related traffic noise increase of up to 0.6 dBA in the project vicinity. This noise level increase is below 3 dBA and would not be perceptible to the human ear in an outdoor environment. Therefore, long- term traffic noise impacts would be less than significant.
Long-Term Stationary Source Noise Impacts
The proposed Project includes on- site rooftop heating, ventilation, and air conditioning (HVAC) units for the 347 residential units, leasing office, clubhouse, and fitness room. It is estimated that the proposed Project would have a total of 354 HVAC units on site, which could potentially operate 24 hours per day. The HVAC equipment would generate a sound power level (SPL) of 76 dBA, which would be equivalent to 44.4 dBA Leq at 50 ft. The rooftop HVAC units are located in City of Riverside
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mechanical wells based on the roof plan, which would provide a minimum noise reduction of 5 dBA. Noise levels generated by HVAC equipment at the property line of the closest off-site land use along with the total number of HVAC units, range of distances from the equipment to the property line, range of distance attenuation, and shielding from the roofline and parapet were calculated. Noise levels generated from on-site HVAC units would not exceed the City’s exterior daytime (7:00 a.m. to 10:00 p.m.) and nighttime (10:00 p.m. to 7:00 a.m.) 30- minute (L50) noise standards of 60 dBA and 50 dBA, respectively, for residential uses. Also, noise levels generated from on- site HVAC units would not exceed the City’s exterior 30-minute (L50) noise standard of 65 dBA for commercial uses. Therefore, no off-site noise impacts from on-site HVAC equipment would occur. No noise reduction measures are required. Long -term stationary noise impacts would be less than significant.
Land Use Compatibility Assessment: Exterior Noise Assessment As discussed above, exterior noise levels in the project area include traffic on Mission Grove Parkway and Mission Village Drive. The project is located within the C2 zone of influence for the MARB, however it is located outside of the noise contour and the contribution of aircraft noise in the project area would be minimal to negligible. The FHWA Highway Traffic Noise Prediction Model (FHWA -RD-77-108) was used to evaluate the proposed on -site uses based on the cumulative (2045) with project traffic noise levels on Mission Grove Parkway and Mission Village Drive. Table 5.13-9 shows the cumulative (2045) with project exterior noise levels at the façade of the proposed residential building and at the courtyard/pool area represented by Receptors R- 1 through R-14. The proposed residential building would shield the courtyard/pool area (Receptor R-14) from traffic on Mission Grove Parkway and Mission Village Drive and would provide a noise reduction of 17 dBA. As shown in Table 5.13-9, traffic noise levels at the façade of the proposed residential building and at the courtyard/pool use area would reach up to 69.2 dBA CNEL.
The proposed Project is an infill residential project and noise levels up to 65 dBA CNEL are the upper limit of what is considered a “normally acceptable” noise environment, and noise levels between 65 dBA CNEL and 75 dBA CNEL are considered a “conditionally acceptable” noise environment based on the City’s Noise/Land Use Compatibility Criteria shown in Table 5.13- 5.
Since exterior noise levels for on- site uses are below 75 dBA CNEL, the proposed P roject is considered “conditionally acceptable.” Conditional acceptance is based on a detailed analysis of noise reduction requirements and noise insulation features included in the design that allow for new construction or development to be undertaken. Therefore, the proposed on-site exterior residential uses are considered compatible with the City’s Noise/Land Use Compatibility Criteria. (DEIR, p. 5.13-11 -21)
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Groundborne Vibration
Threshold B: Would the Project result in the generation of excessive groundborne vibration or groundborne noise levels?
Finding: Less than significant. Vibration levels at the closest commercial and residential building would not result in building damage because the commercial and residential buildings would be constructed equivalent to non- engineered timber and masonry, and vibration levels would not exceed the FTA vibration damage threshold of 0.20 PPV (in/sec). (DEIR, 5.13-22 -24)
Explanation:
Short-Term Construction Vibration Impacts
This construction vibration impact analysis discusses the level of human annoyance using vibration levels in VdB and assesses the potential for building damage using vibration levels in PPV (in/sec). Vibration levels calculated in RMS velocity are best for characterizing human response to building vibration, whereas vibration levels in PPV are best for characterizing damage potential. The greatest vibration levels are anticipated to occur during the site preparation and grading phase. All other phases are expected to result in lower vibration levels. The distance to the nearest buildings for vibration impact analysis is measured between the nearest off -site buildings and the project boundary (assuming the construction equipment would be used at or near the project boundary) because vibration impacts normally occur within the buildings. The formula for vibration transmission is provided below:
LvdB (D) = LvdB (25 ft) - 30 Log (D/25)
PPVequip = PPVref x (25/D)
1.5 The closest commercial and residential buildings west and south of the Project site approximately 80 ft and 130 ft, respectively, from the active project construction area near the center of the Project site would experience vibration levels of up to 72 VdB and 66 VdB, respectively. These vibration levels would not result in community annoyance because they would not exceed the FTA community annoyance threshold of 84 VdB for uses that are not as sensitive to vibration and 78 VdB for daytime residences. Other building structures that surround the Project site would experience lower vibration levels because they are farther away. The closest commercial and residential buildings to the west and south of the Project site are immediately west of the project construction boundary and approximately 80 ft, respectively, from the project construction boundary and would experience vibration levels of up to 0.191 PPV (in/sec) and 0.014 PPV (in/sec), respectively. Vibration levels at the closest commercial and residential building would not result in building damage because the commercial and residential buildings would be constructed equivalent to non-engineered timber and masonry, and vibration levels would not exceed the FTA vibration damage threshold of 0.20 PPV (in/sec).
Long-Term Ground-Borne Noise and Vibration from Vehicular Traffic Once operational, the proposed Project would not generate vibration. In addition, vibration levels generated from project-related traffic on the adjacent roadways (i.e., Mission Grove Parkway and City of Riverside
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Mission Village Drive) would be unusual for on- road vehicles because the rubber tires and suspension systems of on-road vehicles provide vibration isolation. (DEIR, 5.13-22 -24)
Airstrip or Airport Land Use Plan
Threshold C: For a Project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Finding: Less than significant. The exterior noise level would not be more than 20 dBA above the interior standard of 40 dBA CNEL based on the MARB/ IPA LUCP Countywide Policy 4.1.6 and the proposed Project would not expose people residing or working in the project area to excessive noise levels. (DEIR, p. 5.13-24 -25)
Explanation: The closest airports to the Project site are the March Air Reserve Base/Inland Port Airport (MARB/IPA), Riverside Municipal Airport, and Flabob Airport, which are located 3.2 miles southeast, 6.7 miles northwest, and 6.8 miles northwest of the project site, respectively. Although the Project site is located in Zone C2 based on the March Air Reserve Base/ Inland Port Airport Land Use Compatibility Plan (MARB/ IPA LUCP), the Project site is outside the 60 dBA CNEL noise contour. Therefore, the Project site would not be exposed to aircraft noise exceeding the exterior noise standard of 65 dBA CNEL based on the MARB/ IPA LUCP Countywide Policy 4.1.5.
In addition, the exterior noise level would not be more than 20 dBA above the interior standard of 40 dBA CNEL based on the MARB/ IPA LUCP Countywide Policy 4.1.6 and standard building construction, which would provide an exterior-to-interior attenuation of 20 dBA. Also, the Project site is outside the 55 dBA CNEL noise contours of Riverside Municipal Airport and Flabob Airport.
Figures showing the airport noise contours and the location of the Project site are provided in Appendix B. There are no private airstrips located within the vicinity of the Project site.
The Project would not exceed any of the noise thresholds of significance and potential Project - related impacts would be less than significant. Although impacts would be less than significant and no noise reduction mitigation measures are necessary based on the noise impact analysis conducted for the Project pursuant to CEQA guidelines, mitigation measures have been included in compliance with the Mission Grove Specific Plan due to the Project’s location within the plan’s boundaries. The mitigation measures related to aircraft noise in the Mission Grove Specific Plan (outlined below as MM NOISE -3 and MM NOISE -4) require prospective purchasers of dwelling units be informed of high aircraft noise levels and appropriate avigation and noise easements for all residentially developed property. Therefore, no additional noise related mitigation measures are proposed.
MM NOISE-3: A program to inform prospective purchasers of dwelling units within the Specific Plan area of high aircraft noise levels shall be submitted by the developer of City review and approval prior to issuance of any residential building permits. This program shall include a letter to be provided to the purchaser prior to completion of the sale.
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MM NOISE-4: Appropriate avigation and noise easements for all residentially developed property shall be prepared for City and U.S. Air Force review and approval and recorded prior to approval of implementing land division proposals or issuance of any individual building permits if no land division is proposed. (DEIR, p. 5.13-2, -25)
POPULATION AND HOUSING
Induce Growth
Threshold A: Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Finding: Less than significant. Per the City’s General Plan EIR, the maximum population projection with build out of the General Plan would be 444,308 persons, which would result in the Project’s generated residents of 829 persons to be approximately 0.2 percent of the GP 2025 build out maximum population growth. The Project’s contribution of an approximately 1.4 percent incremental increase in the City’s anticipated population growth would be a less than significant increase and would not exceed both the estimated projection and the maximum projection of the City’s General Plan 2025 EIR growth projections. (DEIR, p. 5.14-4)
Explanation: According to the City’s 6th Cycle Housing Element Update the population is expected to grow to 386,600 by 2040. The proposed Project includes a General Plan Amendment from C – Commercial to MU- U – Mixed Use Urban to allow for the multi- family development with 347 units. The expected number of tenants is 829 persons, and therefore the estimated population growth from the Project is 829 persons. Per the 6th Cycle Housing Element Technical Background Report, the City of Riverside had an estimated population of 328,155 in 2020. This represents a growth of 58,445 people from 2020 to 2040. Therefore, the Project is anticipated to contribute approximately 1.4 percent of the anticipated population growth.
The General Plan 2025 was designed to accommodate anticipated growth by providing adequate services, access and infrastructure. The Project area is currently served by existing roads and other infrastructure and the Project would only require minor extensions or laterals from nearby roads and utilities to the site. Also, the Project would result in a very small incremental increase in population growth, approximately 1.4 percent. Thus, the Project is within the City’s anticipated growth projections. The Project’s estimated 829 persons to the total population would be a minuscule incremental increase of the anticipated growth. Moreover, per the City’s General Plan EIR, the maximum population projection with build out of the General Plan would be 444,308 persons, which would result in the Project’s generated residents of 829 person to be approximately 0.2 percent of the GP 2025 maximum population growth. The approximately 1.4 percent incremental increase is anticipated to be a less than significant increase and would not exceed both the estimated projection and the maximum projection of the City’s General Plan 2025 EIR growth projections. (DEIR, p. 5.14-4)
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Displacement of Existing People or Housing
Threshold B: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Finding: No impact. (DEIR, p. 5.14-5)
Explanation: The proposed Project would not displace existing people or housing, necessitating the construction or replacement housing elsewhere because the Project site is proposed on developed land that has no existing housing that will be removed or affected by the proposed Project. Therefore, there will be no impact on existing housing either directly, indirectly or cumulatively. (DEIR, p. 5.14-5)
PUBLIC SERVICES
Governmental Facilities
Threshold A: Would the project result in substantial adverse physical impacts associated with the provi sion of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
• Fire protection,
• Police protection,
• Schools,
• Parks,
• Other public facilities?
Finding: Less than significant . T he proposed P roject would not result in substantial adverse impacts to the existing community that would require expansions to the current government facilities to maintain services. (DEIR, pp. 5.15-7 -10)
Explanation:
Fire Protection
The Riverside City Fire Department provides fire protection for the Mission Grove area from two facilities that are closest to the project site:
• Station No. 11 at the corner of Orange Terrace Parkway and Silk Oak Drive, across from Franklin School at 19595 Orange Terrace Parkway. From Station No. 11 to the Mission Grove Shopping Center is a three-minute response time.
• Station No. 9 is located within a five-minute response time at 6674 Alessandro Boulevard.
These stations are staffed with four full -time firefighters each and have the capability to respond to industrial as well as residential fires. (Housing and Public Safety Element Updates EIR)
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The Riverside Municipal Code (RMC), Chapter 16.52, Development Fees for Fire Stations, provides the City with the ability to collect development fees for the construction and purchase of land for fire stations as well as for the acquisition of equipment and furnishings to equip fire stations. However, to date, the City has not adopted a resolution establishing those development fees, so no fees are currently being collected. RFD implemented service improvements through application of Riverside Measure Z funding and achieved an ISO Rating of ISO Class 1 —the highest awarded level—in December 2019. Measure Z also continues to provide funding for RFD staff positions, training, and vehicle replacement and maintenance. (Housing and Public Safety Element Updates EIR)
The proposed Project includes a total of 347 residential apartment units and is anticipated to house approximately 829 tenants. The proposed Project would increase demands of fire services.
However, as outlined in Section 5.14 Population and Housing, the Project is anticipated to contribute approximately 1.4 percent of the total anticipated population growth to buildout of GP 2025. Due to its small proportion of the GP 2025 buildout population, the proposed Project is unlikely to contribute toward a need for additional facilities, equipment, or staff. GP 2025 Public Safety Element, Policy PS-6.1, ensures that sufficient fire stations, personnel, and equipment are provided to meet the needs of the community as it grows in size and population. Additionally, the Project is an infill project, in which the project site is served by two existing nearby fire stations, and current response times to the proposed Project area (within 5 minutes for Station 9 and within 3 minutes for Station 11) are lower than the City’s average response time of 8 minutes. The proposed Project would not increase response times and would be consistent with GP 2025 Public Safety Element, Policy PS -6.2, meet/maintain a five- minute response time for the City’s urbanized areas. Furthermore, in accordance with Policy PS-6.7: Continue to involve the City Fire Department in the development review process, the proposed Project would be reviewed as part of the review of all proposed development projects. Finally, the proposed Project would be constructed in accordance with current building and fire/life/safety ordinances and codes, including all applicable RMC code requirements related to construction, access, water mains, fire flows, and hydrants. (DEIR, p. 5.15-5)
Compliance with the above-mentioned state and local regulations would ensure that there would be sufficient fire protection service and facilities to accommodate the additional population resulting from the proposed Project. To further document RFD’s review of the Project and that they did not identify the need for additional facilities or staffing as a result of the Project, RFD issued a letter to the Planning Department (Appendix N) indicating “The fire department can meet the needs of the development with current facilities and staffing.” As such, impacts related to fire protection services would be less than significant.
Police Protection
The GP 2025 Public Safety Element, Policy PS-7.5 provides for response time of within 7 minutes to Priority 1 calls (life-threatening) and within 12 minutes for Priority 2 calls (non-life-threatening).
The proposed Project would increase demands of police services; however, this increase would City of Riverside
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be relatively minor as the Project would be developed in a generally urbanized area already served by RPD and within an area currently consisting of both commercial and residential uses.
Additionally, RPD would evaluate its budget annually to provide adequate police services, including police staffing increases, to accommodate additional growth associated with development within the City, including the Project. Further, any incremental impacts on the level of police services would be offset from revenue generated for the City from the Project’s property taxes per the City’s General Plan EIR. RPD would continue to meet the recommended police response times, and there would be sufficient police protection service and facilities to accommodate additional population resulting from the proposed Project. (Housing and Public Safety Element Updates EIR)
As there would be sufficient police protection service and facilities to accommodate the additional population resulting from the proposed Project, impacts related to police protection services would be less than significant.
Schools
The proposed Project would increase the demand for RUSD school facilities. However, the proposed Project will comply with RMC Chapter 16.56, School Development Fee, which establishes coordination between the City and the applicable school district to develop a school development fee for mitigating the impact of residential development on local school districts. In addition, legislation allows school districts to collect impact fees from developers of new residential and commercial uses. Pursuant to Government Code Section 65996, school fees imposed through the Education Code are deemed to be full mitigation for new development projects; the City cannot impose additional mitigation measures. RUSD collects Level II fees for new residential construction based on the square footage of new developments. (Housing and Public Safety Element Updates EIR)
Fees paid by the developer would be used to offset the impact of the number of new students generated by the Project and would ensure that the development contributes to a fair -share amount to help maintain adequate school facilities and levels of service. Therefore, the provision of schools is the responsibility of the school district. Senate Bill 50 provides that the statutory fees found in the Government and Education Codes are the exclusive means of considering and mitigating for school impacts. Imposit ion of the statutory fees constitutes full and complete mitigation.
Compliance with the above-mentioned state and local regulations would ensure that there would be sufficient facilities and service to accommodate additional students resulting from the Project.
As such, impacts related to schools would be less than significant.
Parks
Refer to Recreation Threshold A.
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Other Public Facilities
The proposed Project would increase the demand for other public services. The City has nine existing libraries, and service expansion would be evaluated regularly. Library service needs and standards are determined by the following methods: volumes by population, community need/service gaps (including services provided/not provided by other area departments and agencies), customer requests, and innovation/success of pilot projects.
The Riverside library system provides books, multimedia, sound recordings, magazine subscriptions, internet access, and other resources. The Riverside library system also includes two (2) cyber libraries (cybraries) that provide a collection of virtual materials and educational resources. Additionally, the Riverside Public Library has established online library services, which allow residents to access library data remotely.
At the time of publication (2007), GP 2025 Section 5.13 – Public Services reported that within the City, approximately 50,000 residents were students at the University of California Riverside, Riverside Community College, California Baptist University, and La Sierra University. The most current available student population information from these campuses provides an estimate of approximately 70,000 students. Per GP 2025 Section 5.13, libraries are provided at these colleges and students attending the colleges primarily use the library facilities provided at the campuses.
Per GP 2025 Education Element, Policy ED -5.1, the City is required to help provide ample and convenient library facilities. While there are no development impact fees that would fund the Riverside Public Library system, the Project would not affect the City’s ability to provide adequate libraries as the small incremental increase in library use would not require the expansion of library infrastructure or staffing. As described, there are a number of existing library facilities within the City and the Riverside library system provides online and virtual library services, materials, and resources that residents can access remotely. Additionally, the college campuses within the City provide library facilities for resident students, which further aids in reducing the dependence on public library space and content. The proposed Projects includes a total of 347 residential apartment units and is anticipated to house approximately 829 tenants. The proposed Project would increase demands of libraries. However, as outlined in Section 5.14 Population and Housing, the Project is anticipated to contribute approximately 1.4 percent of the total anticipated population growth from 2020 to 2040, as outlined in the City’s 6 th Cycle Housing Element Update.
Due to its small proportion of the GP anticipated population growth, the proposed Project is unlikely to contribute toward a need for additional facilities, equipment, or staff. GP 2025 Education Element, Policy ED-5.1, ensures that sufficient libraries are provided to meet the needs of the community as it grows in size and population. (DEIR, p. 5.15-7 -10)
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RECREATION
Use of Existing Recreational Facilities
Threshold A: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Finding: Less than significant. The Project would be required to pay impact fees, including the Trail Development Fee, Local Park Development Fee, Aquatic Facility Fee, and Regional Parks and Reserve Parks Development Fee per the Riverside Municipal Code Chapters (RMC) 16.44,
16.60, and 16.76. As detailed in RMC Chapter 16.44 and 16.76, the trail and regional park fees would be used solely for the acquisition of new parkland or trails. Local park fees could be used by the City to purchase new parkland and for upgrading existing neighborhood and community park facilities. (DEIR, p. 5.16-4, -5)
Explanation: The proposed Project includes a multi -family development with 347 units. The expected number of tenants is 829 persons (assuming all residents of the Project were new to the City), and therefore the estimated population growth from the Project is 829 persons. The proposed Project will incrementally increase the use of existing neighborhood and regional parks and recreational facilities from its estimated population growth of 829 persons. As outlined in Section 5.14 Population and Housing, per the 6
th Cycle Housing Element Technical Background
Report, the City of Riverside had an estimated population of 328,155 in 2020. This represents a growth of 58,445 people from 2020 to 2040. Therefore, the Project is anticipated to contribute approximately 1.4 percent of the anticipated 2020- 2040 population growth. As the Project’s population growth is a small percentage of the total City growth from 2020- 2040, the Project’s incremental increase in use of existing recreational facilities would also be small.
The Project includes onsite recreational amenities, including a clubroom, fitness center, pool and spa, outdoor seating and dining areas, and a dog park for its residents. In addition to onsite facilities, the Mission Grove Plaza, in which the Project site is located, offers the following existing recreational amenities: LA Fitness, club pilates, and a movie theatre. The onsite amenities and those nearby within the surrounding Mission Grove Plaza would supplement existing nearby park facilities, located within 1.5 miles of the Project, which include Castleview Park, Taft Park, Orange Terrace Park, and Sycamore Canyon Wilderness Park. As the proposed Project’s population growth is only a small percentage of the City’s anticipated 2020-2040 population growth and the Project includes onsite recreational amenities and there are other amenities within the surrounding Mission Grove Plaza, the Project is not anticipated to result in an increased demand for existing park and recreation facilities, such that substantial physical deterioration of existing facilities may occur or be accelerated. In addition, as outlined in the 2020 Master Plan, the City’s existing resources include 59 parks totaling 2,591.56 acres of developed parkland and an additional 9 parks that are undeveloped totaling 349.05 acres, for a combined total of 2,940.61 acres of parkland. As outlined in Section 5.14 Population and Housing, per the 6 th Cycle Housing
Element Technical Background Report, the City of Riverside had an estimated population of City of Riverside
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328,155 in 2020. Therefore, there were approximately 8.96 acres of existing park per each 1,000 residents in Riverside in 2020 and the City’s existing parks exceeded the Master Plan recommendation of 5 acres per 1,000 residents.
The Project would be required to pay impact fees, including the Trail Development Fee, Local Park Development Fee, Aquatic Facility Fee, and Regional Parks and Reserve Parks Development Fee per the Riverside Municipal Code Chapters (RMC) 16.44, 16.60, and 16.76. As detailed in RMC Chapter 16.44 and 16.76, the trail and regional park fees would be used solely for the acquisition of new parkland or trails. Local park fees could be used by the City to purchase new parkland and for upgrading existing neighborhood and community park facilities. Payment of applicable park development impact fees would mitigate impacts to parks and recreational facilities from its associated population increase. With payment of Park Development Impact Fees (local, aquatic, regional/reserve and trail fees) per Title 16, Chapters 16.60, 16.44 and 16.76 of the Municipal Code, with the Project’s onsite recreational amenities, and the number and size of available parks within 1.5 miles of the Project (Castleview Park, Taft Park, Orange Terrace Park, and Sycamore Canyon Wilderness Park, which combined total 1,404.08 acres) . (DEIR, p. 5.16- 4, -5)
Construction or Expansion of Recreational Facilities
Threshold B: Would the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Finding: Less than significant. With payment of Park Development Impact Fees (local, aquatic, regional/reserve and trail fees) per Title 16, Chapters 16.60, 16.44 and 16.76 of the Municipal Code, with the Project’s onsite recreational amenities, and the number and size of available parks within a few miles of the Project, the Project would not require the construction or expansion of recreational facilities which might have an adverse effect on the environment. (DEIR, p. 5.16-5)
Explanation: Although the proposed Project would result in a small incremental increase in use of existing neighborhood and regional parks and recreational facilities, from its estimated population growth of 829 persons (assuming all residents of the Project were new to the City), the onsite recreational amenities and the nearby neighborhood, community and regional parks are anticipated to accommodate the Project’s residents without requiring the construction or expansion of recreational facilities. As stated previously, there were approximately 8.96 acres of existing park per each 1,000 residents in Riverside in 2020 and the City’s existing parks exceeded the Master Plan recommendation of 5 acres per 1,000 residents. Payment of applicable park development impact fees would mitigate any impacts to parks and recreational facilities from its associated population increase. With payment of Park Development Impact Fees (local, aquatic, regional/reserve and trail fees) per Title 16, Chapters 16.60, 16.44 and 16.76 of the Municipal Code, with the Project’s onsite recreational amenities, and the number and size of available parks City of Riverside
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within a few miles of the Project, the Project would not require the construction or expansion of recreational facilities which might have an adverse effect on the environment. (DEIR, p. 5.16-5)
TRANSPORTATION
Plans and Policies Addressing the Circulation System
Threshold A: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Finding: Less than significant. The Project will not conflict with any existing or proposed transit facilities. Therefore, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. (DEIR, p. 5.17-9-11)
Explanation:
Project Trip Generation
Trip generation represents the amount of traffic which is both attracted to and produced by a development. Determining traffic generation for a specific project is therefore based upon forecasting the amount of traffic that is expected to be both attracted to and produced by the specific land uses being proposed for a given development.
The trip generation for the proposed Project was developed using rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual (11th Edition) for Land Use 221– “Multifamily Housing (Mid ‐Rise) Not Close to Rail Transit. ” The proposed Project is a partial redevelopment of a retail shopping plaza located at an existing vacant store building, and it is estimated that a certain percentage of trips between the existing land uses and adjacent land uses will be made on site and through alternative modes of travel such as walking and biking.
These internal trips and localized trips would not utilize the major street system. The internal capture rates were obtained using the Riverside County Transportation Model (RIVCOM). The net project trip generation is anticipated to generate 1,464 net daily trips, with 128 net trips occurring during the a.m. peak hour, and 124 net trips occurring during the p.m. peak hour. It is assumed that this amount of estimated net project trips generated would be less than the number of net project trips generated for the previous retail store use (K -Mart retail store), which would have generated individual vehicle trips from consumers visiting the store and shopping center as well as vehicle trips for product shipments to and from the store. The Project would place residential uses in close, walkable/bikeable proximity to existing retail and commercial uses in the shopping center, which would lessen the need for individual resident vehicle trips to access these shopping center uses.
General Plan Circulation Element
While the TOA examined LOS within the Project vicinity, a deficiency in LOS is no longer considered as a significant transportation related impact pursuant to updated CEQA guidelines.
Instead, the assessment of LOS is intended to identify key access, circulation, and operational City of Riverside
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issues within the Project area, and to confirm consistency with the City’s General Plan.
Consistency with General Plan policies are addressed in Section 5.11 Land Use, Table 5.11- 1 Summary of Consistency with Applicable General Plan Policies, and the Project’s LOS analysis and accompanying tables can be found in Appendix I – Traffic Operational Analysis.
Queuing Analysis
An intersection and driveway queuing analysis was requested by City staff during the scoping agreement process to ensure that adequate queuing is provided at proposed Project driveways and adjacent intersections. In case queuing deficiencies are identified, the proposed Project would need to alleviate potential queuing issues. As such, the queuing analysis was performed at the following six intersections/driveways:
• Mission Grove Parkway/Alessandro Boulevard;
• Mission Grove Parkway/Mission Village Drive;
• Project Driveway 1/Plaza Driveway 2;
• Mission Grove Parkway/Plaza Driveway 2;
• Mission Grove Parkway/Project Driveway 2; and
• Project Driveway 3‐Bayou Lane/Mission Village Drive.
Queues for some of the movements are projected to exceed the existing available turn ‐pocket storage length under Opening Year and Cumulative with Project scenarios. The queues that exceed the available storage lengths are as follows:
• Mission Grove Parkway South/Alessandro Boulevard: Southbound left ‐turn (a.m. peak hour)
• Mission Grove Parkway South/Mission Village Drive: Westbound left ‐turn (both a.m. and p.m. peak hours)
• Mission Grove Parkway South/Plaza Driveway 2: Northbound left ‐turn (a.m. peak hour), and eastbound left‐turn (both a.m. and p.m. peak hours).
It should be noted that the proposed Project does not add any Project trips for the movements that exceed the storage lanes at the intersections of Mission Grove Parkway South/Alessandro Boulevard and Mission Grove Parkway South/Mission Village Drive. The proposed Project does add Project traffic at the movements that are forecast to exceed the storage lengths at the intersection of Mission Grove Parkway South/Plaza Driveway 2 (under Opening Year and Cumulative With Project scenarios), for the northbound left turn and eastbound left turn movements.
Therefore, improvements were identified at this intersection to alleviate the respective queuing deficiencies. Recommended improvements include retiming the signal timing and extending the northbound left turn pocket 15 feet by cutting into the median to accommodate the forecast queues. For the eastbound left‐ turn pocket, it should be noted that a 25 -foot taper along with a 90-foot storage length may be sufficient to accommodate the deficient queue, although the queue would extend into the taper. However, this queue is not expected to block the eastbound through‐ City of Riverside
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right turn traffic or any of the internal driveways on‐site. Improvements, including signing and striping, at this intersection would be fully implemented by the proposed Project.
As previously discussed, the Project additionally proposed to provide pedestrian improvements, including the creation of sidewalks to connect the proposed residential development to existing surrounding retail land uses. As shown in Figure 5.17 -1 – Site Access and in Figure 3.0 -6 – Conceptual Site Plan, the Project would provide paved sidewalks and marked crosswalks within the Project site, between the residential uses and commercial uses to serve as resident paths of travel. As also shown in Figures 3.0-6 and 5.17-1, these resident paths of travel would connect to existing public pedestrian paths of travel, such as those along Mission Grove Parkway and Mission Village Drive.
There is currently an existing bus stop located approximately 265 feet north of the intersection of Mission Grove Parkway/Mission Village Drive for the southbound directions of RTA local bus Routes 20 and 22. Based on coordination with RTA, the proposed Project will relocate the bus stop approximately 200 feet north of the existing location as part of its project design considerations. This relocation of the bus stop will enhance pedestrian connectivity and access to public transit to and from the proposed Project site and the existing commercial/retail. The Project will not conflict with any existing or proposed transit facilities. Therefore, the Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. (DEIR, p. 5.17-9 -11)
Hazards Due to Geometric Design Features
Threshold C: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Finding: Less than significant. The Project plans include a Fire Access Plan and the Project will provide adequate fire access to ensure the safety of the residents. (DEIR, p. 5.17-21 -22)
Explanation: The proposed Project would be served by existing, fully improved streets, Mission Grove Parkway South and Mission Village Drive. The proposed Project’s internal drive aisles would be designed to meet the Public Works and Fire Departments’ specifications. The Project plans include a Fire Access Plan and the Project will provide adequate fire access to ensure the safety of the residents. The fire access will leave room for the fire trucks to come in and out of the Project site and will allow them to reach all areas of the site in case of a fire. As RFD requires a minimum 20- foot-wide fire lane, the Project’s fire access will have a clear fire lane/fire access to allow room for the fire trucks to navigate through the Project. For these reasons, the proposed Project is not anticipated to result in inadequate emergency access. (DEIR, p. 5.17-21 -22)
Hazards Due to Geometric Design Features
Threshold D: Would the Project result in inadequate emergency access?
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Finding: Less than significant. The proposed Project is not anticipated to result in inadequate emergency access. (DEIR, p. 5.17-22)
Explanation: The proposed Project would be served by existing, fully improved streets, Mission Grove Parkway South and Mission Village Drive. The proposed Project’s internal drive aisles would be designed to meet the Public Works and Fire Departments’ specifications. The Project plans include a Fire Access Plan and the Project will provide adequate fire access to ensure the safety of the residents. The fire access will leave room for the fire trucks to come in and out of the Project site and will allow them to reach all areas of the site in case of a fire. As RFD requires a minimum 20- foot-wide fire lane, the Project’s fire access will have a clear fire lane/fire access to allow room for the fire trucks to navigate through the Project. For these reasons, the proposed Project is not anticipated to result in inadequate emergency access. (DEIR, p. 5.17-22)
UTILITIES AND SERVICE SYSTEMS
New or Expanded Water, Wastewater Treatment, Storm Water Drainage, Electric Power, Natural Gas or Telecommunication Facilities
Threshold A : Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Finding: Less than significant. As there are existing dry and wet utility facilities in the adjacent roadways and only extensions into the Project site are required, the Project will not require or result in the relocation or construction of new or expanded facilities offsite, or relocation of facilities. (DEIR, p. 5.19-14 -16)
Explanation:
Water
As outlined in 5.19.1 Setting, domestic water services will be provided to the Project by WMWD, as stipulated by their Will Serve Letter supplied to the Project A pplicant (Appendix L). The proposed Project site is located within the WMWD Improvement District No. 3. Major distribution facilities are currently available within this District to serve the needs of the Project and surrounding area. WMWD has 12-inch domestic watermains located in Mission Village Drive and Mission Grove Parkway to provide connections for service to the Project. Additionally, domestic and fire services once serving the previous K- Mart building still exist and may be used for the project if they are determined to be adequately sized for the demands of the Project. The Project will be required to relocate existing 8-inch onsite WMWD mainlines and appurtenances within the Project footprint to locations that will allow for access and maintenance. All onsite WMWD facilities shall be within easements dedicated to WMWD.
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WMWD’s 2014 Master Plan shows a proposed 36-inch waterline fronting this property on Mission Grove Parkway. The Project may be required to construct this master planned facility. Western provides recycled water, however, is currently not available within the limits of this Project.
The Project will construct water main extensions from the existing water lines in City street rights- of-way (Mission Village Drive and Mission Grove Parkway) to the Project and within the Project site to ensure they are located to allow for access and maintenance. Because the construction of water main extensions, relocation of 8-inch mainlines within the Project site, and construction of 36-inch waterline would be within already developed areas for retail, parking, and public roadways, do not contain sensitive natural resources and have a relatively small construction footprint with associated minimal construction impacts, construction of these facilities would not cause significant environment effects. No additional improvements or relocations are needed to serve the proposed Project.
Wastewater
A Sewer Capacity Evaluation (Sewer Study 2022, Appendix J) was conducted to assess the impact the Project could have on the City’s wastewater collection system. The Project will connect to an existing 8-inch diameter gravity sewer pipeline in Mission Village Drive, south of the Project site, which connects to an existing 10-16-inch diameter gravity sewer line in Trautwein Road.
The Sewer Capacity Evaluation included an existing hydraulic evaluation to verify that the existing system improvements were appropriately sized to convey existing peak wet weather flows (PWWFs) in addition to Project flows and to identify new locations of sewers that cannot convey the increased flows. The evaluation showed that the City’s existing collection system has sufficient capacity to convey proposed PWWFs downstream of the Project without exceeding the established flow depth criterion. Additionally, the hydraulic analysis showed that the City’s 2020 Update of the Integrated Master Plan for the Wastewater Collection and Treatment Facilities’ (Master Plan Updates) proposed existing collection system projects are adequately sized to handle the change in the land use type at the proposed point of connection. (Sewer Study 2022)
Further, the Sewer Capacity Evaluation’s future capacity evaluation including the Project did not identify new system deficiencies not already identified in the Master Plan Update. The hydraulic analysis showed that the proposed Master Plan Update’s proposed future projects are adequately sized for the change in land use type at the proposed point of connection. (Sewer Study 2022)
The Project’s Sewer Capacity Evaluation determined that the City’s collection system has sufficient capacity to convey existing PWWFs downstream of the Project without exceeding the established flow depth criteria. Thus, the Project would not result in the relocation or construction of new or expanded wastewater facilities that would cause significant environmental effects.
Stormwater
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The Preliminary Project Specific WQMP outlines the LID BMPs required to adequately meet water quality standards and reduce storm water runoff. The proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems. These LID BMPs have been incorporated into the site design to fully address all expected pollutant sources and storm water runoff volumes.
Furthermore, the storm water drainage system would be installed concurrently with the construction of the proposed Project and would be adequately sized to accommodate the drainage created by this Project. On-site storm water and non-stormwater runoff would be treated with onsite BMPs identified in the Preliminary Project Specific WQMP and then discharged to the existing drainage facilities that extend off -site, thus retaining the overall drainage pattern of the site. Therefore, the project would not result in storm water runoff from the site that requires the construction of additional stormwater facilities downstream and off-site.
Dry Utilities
As discussed in Section 5.19.1 Setting, RPU will provide electricity to the proposed Project.
Telecommunications will be provided by a local provider such as Spectrum or AT&T. The proposed Project does not require upgrades to off -site RPU transmission facilities and does not cause or result in the need for additional energy producing facilities off-site. The proposed Project includes 18 solar photovoltaic (PV) arrays on carport and building rooftops with the capacity to generate approximately 1,275,500 kWh per year, which would lessen the Project’s potential of resulting in a substantial increase in demand of energy supply sources. Telecommunication lines will have extensions from existing lines within the City’s street Right -of-Way (ROW) into the development. Therefore, the Project would not result in the need for new or expanded electric or telecommunications facilities.
As there are existing dry and wet utility facilities in the adjacent roadways and only extensions into the Project site are required, the Project will not require or result in the relocation or construction of new or expanded facilities offsite, or relocation of facilities. (DEIR, p. 5.19-14 -16)
Sufficient Water Supplies
Threshold B: Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Finding: Less than significant. The Project does not meet the threshold for requiring a Water Supply Assessment (WSA). Per the Metropolitan Water District of Southern California’s (Metropolitan’s) 2015 Urban Water Management Plan (UWMP) report, the Western Municipal Water District (Western) will have sufficient water supply available to serve the Project including any reasonably foreseeable future development during normal, dry, and multiple dry years.
Therefore, sufficient water supplies exist to serve the Project, and impacts are less than significant. (DEIR, p. 5.14-16 -19)
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Explanation: As discussed in Section 5.19.2.2, under SB 610 and SB 221, certain types of development projects are required to provide detailed WSAs to planning agencies. The threshold requiring the preparation of a WSA for residential developments is over 500 dwelling units. The Project includes a total of 347 residential apartment units, which is below the threshold of 500 dwelling units; therefore, the Project does not trigger the need for the preparation of a project - specific WSA.
Construction Demand
Water would be required for temporary construction activities on the Project site, including dust suppression, grading and grubbing, compaction, construction equipment wheel washing, and concrete mixing and casting. Water consumption by construction workers and cleaning of portable toilets on the Project site may also account for a small portion of overall construction water demand.
Construction water demand would be temporary and, therefore, would not result in long- term strain on water supplies. As discussed in Section 5.19.2.3, Regional Regulations, the City’s Water Conservation Ordinance allows the City Council to declare a Water Shortage Emergency, during which no construction water may be used for earthwork, including dust suppression and compaction activities. However, the City is currently in Stage 1 and not experiencing a water emergency.
Given the temporary and minimal nature of construction water demand in addition to the fact that the City would restrict water intensive construction activities through a Water Shortage Emergency declaration if it lacked adequate water supply, impacts related to construction water consumption would be less than significant.
Operational Demand – Indoor and Outdoor Use
The Project would introduce a new development consisting of multi -family residential uses. The Project would comply with all requirements of the California Green Building Code, as adopted by the City, pertaining to maximum flow rates for plumbing fixtures, such as toilets, showerheads, and faucets in the residential buildings.
WMWD has various water supply sources available (groundwater, imported water, and recycled water) to meet retail demands during normal, single- dry, and multiple- dry years. These supply sources may be impacted by climatic and hydrologic conditions, water quality, and legal restrictions, as well as potential for interruption of supply driven by catastrophic events. WMWD evaluated supply reliability during a single dry year, multiple dry years, and a multiple year drought that could potentially occur within the next five years (2021-2025). In all cases, WMWD’s supplies were sufficient to meet demand without any supply shortages (UWMP). WMWD anticipates adequate supplies for years 2025 to 2045 to meet retail demand under normal, single dry and multiple-dry year conditions.
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Commercial customers account for 5% of WMWD’s retail water supply use, while multi -family residential only uses 3% of the supply; these two uses account for a small percentage of the water supplied to the area. While the Mixed-Use – Urban land designation of the proposed Project would result in greater water usage than the current commercial land use designation, a slight increase in water usage would actually only result in a negligible change to water supplies. Therefore, there would be less than significant impacts to water supplies.
Although the Project is changing land use, it would result in a very small incremental increase in population growth, approximately one and a half percent, of what was anticipated under the GP 2025 typical growth scenario (refer to Section 5.14 Population and Housing). Thus, the Project is within the City’s anticipated 2025 growth projection. (DEIR, p. 5.14-16, -19)
Adequate Wastewater Treatment Capacity
Threshold C: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Finding: Less than significant. The Project would not require RPU to expand wastewater treatment facilities. Therefore, potential impacts would be less than significant. (DEIR, p. 5.19-19)
Explanation: The City provides sewer services to the proposed Project site. As discussed for Threshold A, a Sewer Capacity Evaluation (Sewer Study 2022, Appendix J) was conducted to assess the impact the Project will have on the City’s wastewater collection system. As described for Threshold A above, the Sewer Capacity Evaluation determined that the City’s collection system has sufficient capacity to convey existing PWWFs downstream of the Project without exceeding the established flow depth criteria.
As it has been determined that the City’s existing collection system has sufficient capacity to convey proposed PWWFs downstream of the Project without exceeding the established flow depth criterion, the Project would result in a determination that the Project’s wastewater treatment provider (the City) has adequate capacity to serve the Project’s projected demand in addition to the City’s existing commitments. (DEIR, p. 5.19-19)
Solid Waste Generation
Threshold D: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Finding: Less than significant. With compliance with the CALGreen standards, the Project will not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals . (DEIR, p. 5-19- 20)
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Explanation: The City of Riverside Public Works Department collects trash from 70 percent of the City’s households and the remainder is collected by private contractors. Athens, one of the City’s franchise haulers, would provide solid waste disposal services for the Project.
The Project would generate both construction and operational solid waste, which would be disposed of at nearby landfills. Per the City of Riverside’s General Plan, Public Facilities and Infrastructure Element, all solid waste collected is tipped at the Robert A. Nelson Transfer Station, which is owned by the County of Riverside. The waste is then transferred to either the Badlands Landfill in Moreno Valley, the El Sobrante Landfill located south of the City of Corona or the Lamb Canyon Landfill located between the City of Beaumont and the City of San Jacinto for disposal.
Implementation of the General Plan is anticipated to increase solid waste collection and disposal capacity between 884 tons per day and 2,573 tons per day at buildout. By 2025 the City will contribute 14% of the amount of solid waste. As shown on Table 5.16- M of the City’s GP 2025 PEIR, the generation of solid waste for Multi-Family Residents is anticipated to increase between 139.30 tons for typical and 208.90 for maximum. The Project falls under this category as it has more than 15 dwelling units/acre. With the remaining capacity of the current landfills, the proposed Project is not anticipated to exceed capacity of the landfills. In addition, Public Resource Code Section 41780 requires every city and county to divert from landfills at least 50% of waste generated within their jurisdiction, and the City has exceeded its required reduction in recent years. (GP 2025, GP 2025 PEIR)
Per the California Integrated Waste Management Act of 1989, the Project would have access to green waste collection, curbside recycling, newspaper drop- off, car tire amnesty, household hazardous waste and other service which will divert solid waste to the landfills. (GP 2025)
As outlined in 5.19.3, Project Design Considerations, the Project will adhere to CALGreen building code standards which include management of construction waste, reuse or recycling of excavated soil and land clearing debris, and recycling by occupants (per Section 5.7.3.3, summary of the CALGreen standards that are applicable to the Project) as further outlined below:
• Construction waste management - Recycle and/or salvage for reuse a minimum of 65 percent of the nonhazardous construction and demolition waste or meet a local construction and demolition waste management ordinance, whichever is more stringent. • Excavated soil and land clearing debris - 100 percent of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled. For a phased project, such material may be stockpiled on site until the st orage site is developed.
• Recycling by Occupants - Provide readily accessible areas that serve the entire building and are identified for the depositing, storage and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully enacted local recycling ordinance, if more restrictive.
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With compliance with the CALGreen standards, the Project will not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. (DEIR, p. 5-19-20)
WILDFIRE
Impair and Adopted Emergency Response Plan or Emergency Evacuation Plan Threshold A: Would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
Finding: Less than significant. The Project’s surrounding roadways would continue to provide emergency access to the Project area and to surrounding properties during construction and operation of the Project. (DEIR, p. 5-20-7)
Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project will be served by Mission Grove Parkway South and Mission Village Drive. No street closures are required during the Project’s construction. Per the GP 2025, Public Safety Element Technical Background Report (TBR), Figure CP-8: Evacuation Routes, Alessandro Boulevard is an arterial evacuation route and the SR -60 and I -215 are designated as freeway evacuation routes. Thus, the Project site is located adjacent to and has access to Alessandro Boulevard and SR-60 and I-215, designated evacuation routes.
Emergency response and evacuation procedures would be coordinated through the City in coordination with the police and RFD. The Project would not impair an adopted emergency response plan or evacuation plan and would comply with necessary procedures. While there would be an increase in the city population of 829 persons from the proposed Project, as outlined in Section 5.14 Population and Housing, the Project is anticipated to only contribute approximately
1.4 percent of the total anticipated population growth from 2020 to 2040 (per the City’s 6 th Cycle
Housing Element Update). Due to its small proportion of the GP anticipated population growth, the proposed Project would not result in significant enough increase in population to directly impair the use of Alessandro Boulevard as an evacuation rout e. The Project’s surrounding roadways would continue to provide emergency access to the Project area and to surrounding properties during construction and operation of the Project. (DEIR, p. 5.20-6, -7)
Environmental Factors that May Exacerbate Fire Risk
Threshold B: Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
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Finding: Less than significant. Overall , the project would be constructed in compliance with the CFC, CBC, GP 2025, and RFD requirements. (DEIR, p. 5.20-7, -8)
Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project site is bordered by Mission Grove Parkway South to the east and Mission Village Drive to the south. The Project site has the Mission Grove Shopping Center and parking to the north and west. Outside of the shopping center is existing residential development to the south, west and north, and commercial/retail to the east. The only open space area with vegetation that could fuel a wildland fire near the Project site is the Sycamore Canyon Wilderness Park, located approximately 3,500 feet to the northeast. If there were a wildland fire in the Sycamore Canyon Wilderness Park it would not be expected to spread to the Project site due to the distance between them and separation by existing development and Alessandro Boulevard. For these same reasons, if a fire were to occur at the Project site it would not be expected to spread to the Sycamore Canyon Wilderness Park.
The Project will incorporate RMC standards related to fire suppression at the Project site such as smoke detectors meeting the current CBC and CFCs installed in all units and other enclosed common areas such as hallways, recreation rooms, and utility rooms. Additional fire suppression equipment such as alarm systems, fire extinguishers and sprinklers will also be incorporated as recommended by the RFD. Furthermore, Project structures would be required to comply with the CFC with regard to emergency fire access and use of building materials that would limit the spread of wildfire to the greatest extent possible. This would reduce potential spread of a fire from the Project site to areas outside the Project site boundary, reducing the Project’s potential to exacerbate wildfire risks.
Overall, the Project would be constructed in compliance with the CFC and CBC, along with being compliant with the GP 2025 and RFD requirements. The Project would not expose Project occupants to pollutant concentrations from wildfire or the uncontrolled spread of a wildfire by exacerbating wildfire risks. (DEIR, p. 5.20-7, -8)
Infrastructure Installation or Maintenance that May Exacerbate Fire Risk Threshold C: Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Finding: Less than significant. Implementation of the Project would not require installation of new or increased level of infrastructure maintenance into wildland areas that could exacerbate fire risk or result in temporary or ongoing impacts to the environment. (DEIR, p. 5.20-8) City of Riverside
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Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project site is currently fully developed with a structure, surface parking lot, and landscaped areas. The Project site is surrounded by roadways and other residential and commercial/retail development. There are existing utilities adjacent to the Project site that will serve the Project.
There are no offsite staging areas, and no offsite improvements are required that would extend into an undeveloped wildland area.
The Project would not require the installation or maintenance of other associated infrastructure beyond already existing developed conditions in Mission Grove Parkway South and Mission Village Drive to the east and south, where the Project would connect to existing utilities.
Implementation of the Project would not require installation of new or increased level of infrastructure maintenance into wildland areas that could exacerbate fire risk or result in temporary or ongoing impacts to the environment. (DEIR, p. 5.20-8)
Exposure to Post-Fire Risks
Threshold D: Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes?
Finding: Less than significant. Impacts related to exposure of people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes would be less than significant. (DEIR, p. 5.20-8, -9)
Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project site is developed and relatively flat. There are no steep slopes on or around the Project site. The existing drainage patterns have been identified as southwesterly overland flow.
The proposed drainage patterns will be preserved at the existing site drainage discharge locations. The proposed Project includes four biotreatment basins located throughout the site; site runoff in the parking lot and roof runoff will be directed to these proposed Modular Wetlands Biofiltration systems which have been incorporated into the site design to fully address storm water runoff volumes. The proposed Project will not result in an increase in the rate or amount of surface runoff from the site, and in turn would not result in flooding or substantial erosion that could cause slope instability.
The Project would be constructed in compliance with the CFC and CBC, along with being compliant with the GP 2025 and RFD requirements. The Project would not expose people or City of Riverside
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structures within the Project to significant risks from wildfire or exacerbate wildfire risks from the Project to adjacent areas (DEIR 5.20-8, -9).
Exposure to Wildland Fire Risk
Threshold F: Would the Project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Finding: Less than significant. The Project would be constructed in compliance with the CFC, CBC, GP 2025 and RFD requirements. The Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. (DEIR, p.
5.20-9, -10)
Explanation: Per a review of Figure CP-5 – Very-High Fire Hazard Severity Zone Areas (GP 2025 Public Safety Element TBR), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
The Project site is bordered by Mission Grove Parkway South to the east and Mission Village Drive to the south. The Project site has the Mission Grove Shopping Center and parking to the north and west. Outside of the shopping center is existing residential development to the south, west and north, and commercial/retail to the east. The only open space area with vegetation that could fuel a wildland fire near the Project site is the Sycamore Canyon Wilderness Park, located approximately 3,500 feet to the northeast. If there were a wildland fire in the Sycamore Canyon Wilderness Park it would not be expected to spread to the Project site due to the distance between them and separation by existing development and Alessandro Boulevard. For these same reasons, if a fire were to occur at the Project site it would not be expected to spread to the Sycamore Canyon Wilderness Park.
The Project will incorporate RMC standards related to fire suppression at the Project site such as smoke detectors meeting the current CBC and CFCs installed in all units and other enclosed common areas such as hallways, recreation rooms, and utility rooms. Additional fire suppression equipment such as alarm systems, fire extinguishers and sprinklers will also be incorporated as recommended by the RFD. Furthermore, Project structures would be required to comply with the CFC with regard to emergency fire access and use of building materials that would limit the spread of wildfire to the greatest extent possible. This would reduce potential spread of a fire from the Project site to areas outside the Project site boundary, reducing the Project’s potential to exacerbate wildfire risks.
Overall, the Project would be constructed in compliance with the CFC and CBC, along with being compliant with the GP 2025 and RFD requirements. The Project would not expose Project occupants to pollutant concentrations from wildfire or the uncontrolled spread of a wildfire by exacerbating wildfire risks. (DEIR, p. 5.20-9, -10)
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FINDINGS FOR IMPACTS IDENTIFIED AS SIGNIFICANT BUT
MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City Council hereby finds that the following mitigation measures, which are identified in the EIR and these Findings, will reduce the following otherwise significant environmental impacts to a less than significant level, and have been required in or incorporated into the proposed Project.
The findings below are for impacts where implementation of the proposed Project would result in significant environmental impacts that would be reduced to less than significant following mitigation. These findings are based on the discussion of impacts in the detailed impact analyses in Section 5.1 through 5.15 and Section 6 of the EIR, as well as relevant responses to comments in the Final EIR.
Except where specifically otherwise noted below, the following statutory finding applies to all of the impacts described in this section (III):
Changes or alterations have been required in, or incorporated into, the proposed Project which mitigate the significant effects on the environment (to less than significant levels). (See Pub.
Resources Code § 21081(a)(1); State CEQA Guidelines § 15091(a)(1).)
The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:
BIOLOGICAL RESOURCES
Special Status Species
Threshold A: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U. S. Wildlife Service?
Finding: Less than significant with mitigation. The proposed project may impact identified candidate, sensitive, or special status species will be less than significant with the below listed mitigation measures. (DEIR, p. 5.4-9, -10)
Explanation:
Special-Status Plant Species
According to the CNDDB and CNPS, 15 special-status plant species have been recorded in the USGS Riverside East quadrangle. The Project site consists of an existing structure within a developed shopping center with associated paved parking. These existing site components have eliminated the ability of the Project site to provide suitable habitat for special-status plant species.
Based on habitat requirements for specific special -status plant species and the availability and quality of habitats needed by each species, the Project site does not provide suitable habitat for any of the special-status plant species known to occur in the area and are presumed to be absent from the Project site. Therefore, as the Project site does not provide suitable habitat for special - City of Riverside
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status plant species and these species are considered absent from the Project site, development of the Project would not result in the displacement of any special -status plant species known to occur in the USGS Riverside East quadrangle.
Special-Status Wildlife Species
According to the CNDDB, 29 special-status wildlife species have reported occurrences within the USGS Riverside East quadrangle. A review of the habitat requirements of each of the special - status wildlife species listed in the CNDDB query results indicates the Project site does not contain nor would be able to provide potentially suitable habitat for any of these wildlife species. Although loggerhead shrike was reported within 1 mile of the site, due to the level of development in the surrounding area of the site and the level of development on the site itself, the species is not expected to occur. Given the habitat quality, none of these species has more than a low potential of being present. Therefore, as the Project site does not contain nor would be able to provide suitable habitat for special-status wildlife species, and as these species are considered to have no more than a low potential of occurring within the Project site, development of the Project would not displace any special- status wildlife species known to occur in the USGS Riverside East Quadrangle.
Protected Nesting Birds
Most birds and their active nests are protected from “take” (meaning destruction, pursuit, possession, etc.) under the Migratory Bird Treaty Act and/or Sections 3503 through 3801 of the California Fish and Game Code. Activities that cause destruction of active nests, or that cause nest abandonment and subsequent death of eggs or young, may constitute violations of one or both of these laws. The light poles and large trees on or adjacent to the project site may be used by hawks, ravens, or other large birds for nesting. Trees, shrubs, and other vegetation may provide nest sites for smaller birds, and burrowing owls may nest in ground squirrel burrows, pipes, or similar features.
Therefore, to minimize or avoid potential impacts to migratory birds and raptors, the Project would implement mitigation measure MM BIO-1, which would require any landscape vegetation removal to occur outside of the nesting bird season, which is typically February 1 st to August 31 st, if
feasible. If vegetation removal must occur during nesting season, pre- construction nesting surveys would be conducted by a qualified biologist within three (3) days prior to vegetation removal activities to ensure no active nests are present. If active nests are present, a protective avoidance buffer will be established until the young have fledged or the qualified biologist has determined the nest to be inactive. The size of the buffer will be determined by a qualified biologist.
Vegetation removal would resume once nesting activity is complete.
The following mitigation measure will be implemented:
MM BIO-1: To avoid and/or minimize potential impacts to migratory birds and raptors, landscape vegetation removal will take place outside of the bird nesting season of February 1 st through
August 31 st. If vegetation removal must take place during nesting season, a pre- construction City of Riverside
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nesting survey shall be conducted by a qualified biologist (i.e., a biologist experienced with performing nesting bird presence/absence surveys and experienced with identifying signs of active nesting) within three (3) days prior to vegetation removal activities to ensure no active nests are present. If active nests are present, a protective avoidance buffer (a no work zone buffer around the tree containing the active nest as identified by the qualified biologist) will be established until the young have fledged or the nest is determined to be inactive by the qualified biologist. The design of the avoidance buffer shall be reviewed and approved by a qualified biologist in conjunction with the City. The size of the protective buffer will be determined by the qualified biologist depending on the nesting species. Vegetation removal may resume once nesting activity is complete. (DEIR, p. 5.4-9, -10)
CULTURAL RESOURCES
Archaeological Resources
Threshold B: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5 of the CEQA Guidelines?
Finding: Less than significant with mitigation. Due to the sensitivity of the proposed Project area’s surrounding area there is a likelihood of cultural resources being inadvertently discovered through soil disturbing activities. Because of this sensitivity mitigation measures MM CUL-1 through MM CUL-4 will be implemented. (DEIR, p. 5.5-13)
Explanation: Per the findings of the Project’s Cultural Resource Assessment (2023), no known archaeological resources occur within or adjacent to the Project site and the proposed project area is within an already graded and in a fully developed area. However, it is surrounded by 129 resources within 1 mile of the site (consisting of granitic milling features, lithic scatter, ancillary buildings, building foundations, privies, and various prehistoric resources unlisted in the record search), and the only previous survey of the project area was conducted almost 40 years ago.
The previous survey was not specific to the project area but of the surrounding 637 acres.
Considering the surrounding recorded resources that encircle the Project site there is a moderate to high likelihood to the unanticipated discovery of cultural resources during the construction process below previously disturbed depths. Therefore, based on the available information, the City may consider the project area to have moderate to high sensitivity for potential impacts to cultural resources.
Though the Project site is considered to be potentially sensitive for buried cultural resources, with the implementation of recommended mitigation measures (see below, Mitigation Measures MM CUL-1 through MM CUL-4), potential Project impacts to archaeological resources would be less than significant. In order to identify any unknown cultural resources, archaeological and paleontological monitoring will be performed for any ground- breaking activities (MM CUL- 2).
Additionally, if any cultural resources are inadvertently discovered, the detailed provisions for the treatment and disposition of the resources in MM CUL- 3 will be followed. These mitigation City of Riverside
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measures will ensure that any inadvertently discovered cultural resources are avoided and/or preserved. The following mitigation measures will be implemented:
MM CUL-1: Prior to grading permit issuance, if there are any changes to project site design and/or proposed grades, the Applicant and the City shall contact consulting tribes to provide an electronic copy of the revised plans for review. Additional consultation shall occur between the City, developer/applicant, and consulting tribes to discuss any proposed changes and review any new impacts and/or potential avoidance/preservation of the cultural resources on the project site. The City and the developer/applicant shall make all attempts to avoid and/or preserve in place as many cultural and paleontological resources as possible that are located on the project site if the site design and/or proposed grades should be revised. In the event of inadvertent discoveries of archaeological resources, work shall temporarily halt until agreements are executed with consulting tribe, to provide tribal monitoring for ground disturbing activities.
MM CUL-2: Archaeological and Paleontological Monitoring: At least 30 days prior to application for a grading permit and before any grading, excavation and/or ground disturbing activities take place, the developer/applicant shall retain a Secretary of Interior Standards qualified archaeological monitor to monitor all ground -disturbing activities in an effort to identify any unknown archaeological resources.
1. The project archaeologist, in consultation with consulting tribes, the Developer, and the City, shall develop an Archaeological Monitoring Plan to address the details, timing, and responsibility of all archaeological and cultural activities that will occur on the project site.
Details in the plan shall include:
a. Project grading and development scheduling;
b. The development of a rotating or simultaneous schedule in coordination with the developer/applicant and the project archaeologist for designated Native American Tribal Monitors from the consulting tribes during grading, excavation, and ground- disturbing activities on the site, including the scheduling, safety requirements, duties, scope of work, and Native American Tribal Monitors’ authority to stop and redirect grading activities in coordination with all project archaeologists;
c. The protocols and stipulations that the Applicant, tribes, and project archaeologist/paleontologist will follow in the event of inadvertent cultural resources discoveries, including any newly discovered cultural resource deposits, or nonrenewable paleontol ogical resources that shall be subject to a cultural resources evaluation;
d. Treatment and final disposition of any cultural and paleontological resources, sacred sites, and human remains if discovered on the project site; and e. The scheduling and timing of the Cultural Sensitivity Training noted in mitigation measure MM-CUL-4.
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MM CUL-3: Treatment and Disposition of Cultural Resources: In the event that Native American cultural resources are inadvertently discovered during the course of grading for this project, the following procedures will be carried out for treatment and disposition of the discoveries:
1. Consulting Tribes Notified: within 24 hours of discovery, the consulting tribe(s) shall be notified via email and phone. Consulting tribe(s) will be allowed access to the discovery, in order to assist with the significance evaluation.
2. Temporary Curation and Storage : During the course of construction, all discovered resources shall be temporarily curated in a secure location on site or at the offices of the project archaeologist. The removal of any artifacts from the project site will need to be thoroughly inventoried with tribal monitor oversight of the process; and
3. Treatment and Final Disposition: The landowner(s) shall relinquish ownership of all cultural resources, including sacred items, burial goods, and all archaeological artifacts and non- human remains as part of the required mitigation for impacts to cultural resources. The Applicant shall relinquish the artifacts through one or more of the following methods and provide the City of Riverside Community and Economic Development Department with evidence of same:
a. Accommodate the process for on- site reburial of the discovered items with the consulting Native American tribes or bands. This shall include measures and provisions to protect the future reburial area from any future impacts. Reburial shall not occur until all cataloguing and basic recordation have been completed; b. A curation agreement with an appropriate qualified repository within Riverside County that meets federal standards per 36 CFR Part 79 and therefore will be professionally curated and made available to other archaeologists/researchers for further study. The collections and associated records shall be transferred, including title, to an appropriate curation facility within Riverside County, to be accompanied by payment of the fees necessary for permanent curation; c. If more than one Native American tribe or band is involved with the project and cannot come to a consensus as to the disposition of cultural materials, they shall be curated at the Western Science Center or Riverside Metropolitan Museum by default; and
d. At the completion of grading, excavation, and ground-disturbing activities on the site, a Phase IV Monitoring Report shall be submitted to the City documenting monitoring activities conducted by the project archaeologist and Native Tribal Monitors within 60 days of completion of grading. This report shall document the impacts to the known resources on the property; describe how each mitigation measure was fulfilled; document the type of cultural resources recovered and the disposition of such resources; provide evidence of the required cultural sensitivity training for the construction staff held during the required pre-grade meeting; and, in a confidential appendix include the daily/weekly monitoring notes from the archaeologist. All reports produced will be submitted to the city of Riverside, Eastern Information Center, and interested tribes.
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MM CUL-4: Cultural Sensitivity Training: The Secretary of Interior Standards County certified archaeologist and Native American monitors shall attend the pre -grading meeting with the developer/permit holder’s contractors to provide Cultural Sensitivity Training for all construction personnel. This shall include the procedures to be followed during ground disturbance in sensitive areas and protocols that apply in the event that unanticipated resources are discovered. Only construction personnel who have received this training can conduct construction and disturbance activities in sensitive areas. A sign-in sheet for attendees of this training shall be included in the Phase IV Monitoring Report. (DEIR 5.5-13)
A Standard Condition of Approval will include the following – Consistent with State Law:
Discovery of Human Remains: In the event that human remains (or remains that may be human) are discovered at the Project site during grading or earthmoving, the construction contractors, Project Archaeologist, and/or designated Native American Monitor shall immediately stop all activities within 100 feet of the find. The Project proponent shall then inform the Riverside County Coroner and the City of Riverside Community & Economic Development Department immediately, and the coroner shall be permitted to examine the remains as required by California Health and Safety Code Section 7050.5(b) unless more current State law requirements are in effect at the time of the discovery. Section 7050.5 requires that excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If human remains are determined as those of Native American origin, the Applicant shall comply with the state relating to the disposition of Native American burials that fall within the jurisdiction of the NAHC (PRC Section 5097). The coroner shall contact the NAHC to determine the most likely descendant(s). The MLD shall complete his or her inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. The Disposition of the remains shall be overseen by the most likely descendant(s) to determine the most appropriate means of treating the human remains and any associated grave artifacts.
The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. The County Coroner will notify the Native American Heritage Commission in accordance with California Public Resources Code 5097.98. No photographs are to be taken except by the coroner, with written approval by the consulting Tribe(s).
According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). The disposition of the remains shall be determined in consultation between the Project proponent and the MLD. In the event that the Project proponent and the MLD are in disagreement regarding the disposition of the remains, State law will apply and the median and decision process will occur with the NAHC (see Public Resources Code Section 5097.98(e) and 5097.94(k)). (DEIR, p. 5.18-7, 8, -9)
GEOLOGY AND SOILS
Paleontological Resources or Unique Geologic Features
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Threshold F: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Finding: Less than significant with mitigation. Project related ground disturbance is not likely to impact significant paleontological resources. Mitigation is not recommended unless a fossil is encountered during grading and other construction activities. If an unanticipated on- site fossil is encountered during construction, implementation of mitigation measure MM GEO -1 is required. (DEIR, p. 5.7-12, -13)
Explanation: The Project site is not located in a paleontological sensitivity area (Riverside County GIS data). Due to extent of prior disturbances at the Project site and onsite undocumented fill, the Project site is not anticipated to have sensitive paleontological resources or unique geological features. that would be destroyed with project implementation. Project related ground disturbance is not likely to impact significant paleontological resources. Mitigation is not recommended unless a fossil is encountered during grading and other construction activities. If an unanticipated on-site fossil is encountered during construction, implementation of mitigation measure MM GEO-1 is required. (DEIR, p. 5.7-12) The following mitigation measures will be implemented:
MM GEO -1: If one or more fossils are discovered during construction, all ground disturbing activities within 50 feet of the area of the find shall be ceased and the applicant shall retain a paleontologist who meets the Society of Vertebrate Paleontology (SVP) qualifications standards for the Project Paleontologist to oversee the documentation of the extent and potential significance of the finds as well as recovery efforts. Ground -disturbing activities may resume in the area of the finds at the discretion of the Project Paleontologist. If the fossils are significant per the SVP’s 2010 criteria, then paleontological monitoring shall be conducted on an as -needed basis for further ground-disturbing activities in the Project area. (DEIR, p. 5.7-12, -13) City of Riverside
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TRIBAL CULTURAL RESOURCES
Tribal Resources
Threshold A: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe that is:
i. listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? or
ii. a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, would the lead agency consider the significance of the resource to a California Native American tribe?
Findings: Less than significant with mitigation. based on the findings of the Project -specific Cultural Resources Assessment (Appendix D) and on consultation with the Native American tribes who requested consultation no known tribally affiliated cultural resources are known to exist within the project area. However, if tribally affiliated resources are encountered MM CUL-1 through MM CUL-4 will be implemented. (DEIR, p. 5.18-7, 8, -9)
Explanation: No known significant tribal cultural resources are located on the Project site based on the findings of the Project -specific Cultural Resources Assessment (Appendix D) and on consultation with the Native American tribes who requested consultation. An archaeological field survey of the Project site was conducted on January 27, 2023. The survey was conducted on the unpaved portions of the project area in landscaping on the southern and eastern edges of the project area. The unpaved portions of the project make up less than ~90% of the proposed Project site. The Project site is already graded and in a fully developed area. During the field survey, LSA archaeologists did not identify any cultural resources within or adjacent to the Project site. No cultural resources have been previously recorded within the site’s boundary. Although no resources were previously documented within or adjacent to the project area, which is completely developed, it is surrounded by 129 resources (consisting of granitic milling features, lithic scatter, ancillary buildings, building foundations, privies, and various prehistoric resources unlisted in the record search) within 1 mile and the only previous survey of the project area was almost 40 years ago and was not specific to the project area but of the surrounding 637 acres. Considering the surrounding recorded resources that encircle the Project site there is a moderate to high likelihood to the unanticipated discovery of cultural resources during the construction process below previously disturbed depths. Therefore, based on the available information, the project area could have moderate to high sensitivity for potential impacts to cultural resources, and standard regulatory compliance measures regarding buried cultural resources are required in conformance with Section 15064.5(e) of the State CEQA Guidelines, Public Resources Code Section 5097.98, and State Health and Safety Code Section 7050.5.
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The City and the Soboba Band of Luiseno Indians and Aqua Caliente Band of Cahuilla Indians agreed that, in the event of the inadvertent discovery of previously unknown cultural resources of tribal or Native American importance during construction activities, appropriate mitigation measures would be implemented and followed. The Soboba Band of Luiseno Indians and Aqua Caliente Band of Cahuilla Indians accepted the City’s standard mitigation measures (MM CUL-1 through MM CUL-4 as previously discussed above in Cultural Resources), to ensure that potential impacts in the event of an inadvertent discovery of resources remain at less than a significant level.
FINDINGS FOR IMPACTS THAT ARE SIGNIFICANT AND
UNAVOIDABLE
The City Council hereby finds that the mitigation measures discussed below, which are identified in the EIR and will lessen the following significant environmental impacts but not to a less than significant level, have been required in or incorporated into the Project. The findings below are for impacts where implementation of the Project may result in significant, unavoidable environmental impacts. These findings are based on the discussion of impacts in the detailed impact analyses in Section 5.1 through Section 5.15 and Section 6 of the EIR, as well as relevant responses to comments in the Final EIR.
The following impacts from the Project and related approvals cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein.
HAZARDS AND HAZARDOUS MATERIALS
Airport Land Use Plan
Threshold E: Would the Project be located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
Finding: Significant and unavoidable. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measure or project alternatives identified in the EIR. (State CEQA Guidelines, section 15091(a)(3).)
The proposed residential Project would increase housing density within the compatibility C2 zone of the March Air Reserve Base/Inland Port Airport Land Us e Compatibility Plan ( MARB/IPA LUCP) which limits the residential density of housing within it. The Countywide Policy 3.3.1 regarding infill projects allows for the increase of housing density within the C2 zone but limits the increase to double the density of the existing limits, in this case would be as high as 12.0 dwelling units/acre (du/ac), however the proposed Project would bring the density to 35.0 du/ac which would be much greater than the allowed density.
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The Project would be consistent, however, with Compatibility Zone C2’s non-residential average intensity requirements of a maximum of 200 people per acre, height of structures, glare, electrical interference and there would be no safety issues related to these topics.
Due to the incompatibility and the project’s result in significant and unavoidable impact, a City Council proposed overrule of an ALUC action must provide a copy of the proposed decision and findings to both ALUC and the California Division of Aeronautics, a minimum of 45 days prior to decision to overrule ALUC. These agencies have 30 days in which to provide comments to the City Council. (DEIR, p. 5.9-14, -15, -16, -17, -18, -19, -20, -21, -22, -23, -24)
Explanation:
Riverside County ALUC Consistency with MARB/IPA Analysis and Findings The Project site is located within the March Air Reserve Base (MARB) airport influence area, within Compatibility Zone C2 of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IPA LUCP). The Riverside County Airport Land Use C ommission (ALUC) prepared a Staff Report (dated September 14, 2023) analyzing the Project’s consistency with applicable airport land use compatibility criteria as outlined in further detail below. On September 14, 2023, the Riverside County ALUC, by a 5- 0 vote, found the proposed Project inconsistent with the 2014 MARB/IPA LUCP, based on the findings of the Staff Report, that the project is inconsistent with the required residential density criteria. The Riverside County ALUC Staff Report concluded that the proposed Project would be inconsistent with the airport land use compatibility plan criteria and the City adopted General Plan and Zoning Ordinance based on the following points (Appendix M).
Residential Density
Pursuant to the MARB/IPA LUCP, the project site is located within Compatibility Zone C2, which restricts residential density to a maximum of 6.0 dwelling units per acre (du/ac). The proposed Project includes 347 multi-family units on 9.92 acres, which results in a density of 35.0 dwelling units per acre. The Zone C2, in which the Project is located, is identified as a Flight Corridor Zone, where the risk level is considered “moderate” in the ALUC Countywide Policies Table 3A – Compatibility Zone Factors. Per Table 3A – Compatibility Zone Factors, “some 10% to 15% of off- runway general aviation accidents near airports occur in this zone,” in reference to Compatibility Zone C2. Based on these safety factors, the intent and purpose of Compatibility Zone C2 is t o restrict residential density in order to limit the potential risk of an off -field aircraft landing. The Project’s proposed residential density of 35.0 du/ac exceeds the maximum allowable residential density for Zone C2 of 6.0 du/ac.
Countywide Policy 3.3.1 Infill
Countywide Policy 3.3.1 (Infill) allows for greater densities than would otherwise be permitted in Compatibility Zone C2, but caps densities at double the allowable density of the zone. As the City of Riverside
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maximum density of the zone is 6.0 du/ac, doubling the density increases the limit from 6.0 to
12.0 du/ac, which the proposed Project’s density of 35.0 du/ac would significantly exceed.
As designed for the March Air Reserve Base environs, Compatibility Zone C2 would allow an average of 200 people per acre and a single acre land use intensity of 500 persons.
Non-Residential Average Intensity
Pursuant to the MARB/IPA LUCP, the non-residential average intensity for Compatibility Zone C2 is limited to 200 people per acre. Per Appendix C, Table C -1 of the MARB/IPA LUCP and the Additional Compatibility Policies included in the MARB/IPA LUCP the following rates were used to calculate the occupancy for the proposed Project:
• Office area – 1 person per 200 square feet (SF);
• Exercise Room area – 1 person per 50 SF,
• Pool area – 1 person per 50 SF;
• Pool Deck area – 1 person per 15 SF; and
• Club area – 1 person per 15 SF.
As the Project includes construction of a 347-unit multi-family development including recreational amenities including 2,963 SF of leasing office area, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2.386 SF of fitness area, accommodating a total occupancy of 311 people, resulting in an average intensity of 31 people per acre, which is consistent with the Compatibility Zone C2 average intensity of 200 people per acre.
A second method for determining total occupancy involves multiplying the number of parking spaces provided or required (whichever is greater) by average vehicle occupancy (assumed to be 1.5 persons per vehicle).
ALUC misstated the number of spaces provided by the project and found that based on the number of parking spaces provided (misstated as 347 standard vehicles), the total occupancy would be estimated at 521 people for an average intensity of 53 people per acre, which is consistent with the Zone C2 intensity criterion of 200 people per acre. However, the P roject provides 604 parking spaces. As such, using ALUC’s methodology, the total occupancy would be estimated at 906 people, for an average intensity of 91 people per acre. This remains considerably lower than Zone C2 average intensity criterion of 200 people per acre. Thus, while the unit count may exceed ALUC’s residential density requirements, the actual number of people onsite would be much lower than what ALUC would allow in Zone C2 if this were a commercial development, and accordingly would not impose a safety impact due to the intensity of people onsite in the event of an emergency. (DEIR, p. 5.9-15)
Non-Residential Single-Acre Intensity
Pursuant to the MARB/IPA LUCP, Compatibility Zone C2 limits maximum single-acre intensity to 500 people. There are no risk -reduction design bonuses available as MARB/IPA is primarily utilized by large aircraft weighing more than 12,500 pounds. Based on the Project site plan and City of Riverside
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the occupancies previously calculated/noted, the maximum single-acre area would occur around the multi-family residential amenities which includes 2,963 SF of leasing office, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2,386 SF of fitness area, resulting in a single acre occupancy of 311 people, which would be consistent with the Compatibility Zone C2 single-acre intensity criterion of 500 people.
Flight Hazard Issues
Structure height, electrical interference, and reflectivity/glare are among the issues that solar panels in the airport influence area must address. The Project’s photovoltaic (PV) panel structures would be located on the building rooftops and carports within the Compatibility Zone C2.
Glint and Glare/Reflectivity
Based on the Federal Aviation Administration’s Interim Policy for Review of Solar Energy System Project on Federally Obligated Airports, no glare potential or low potential for temporary after - image (“green” level) are acceptable levels of glare on final approach (within 2 miles from end of runway) for solar facilities located on airport property. Potential for temporary after-image (“yellow” level) and potential for permanent eye damage (“red” level) are not acceptable levels of glare on final approach. No glare is permitted at air traffic control towers.
The proposed Project includes approximately 40,000 SF of solar panels on the building rooftops and carports. Two solar glare studies were prepared for the proposed Project utilizing web-based Forge Solar which analyzed 1) panels with a fixed tilt of 5 degrees with no rotation and orientation of 180 degrees with a height of 45 feet. The analysis concluded that some potential for glare was identified within the Air Force traffic pattern. Evaluation of the Air Force traffic patterns indicates that the panels would result in no glare or a low potential for temporary after-image (“green” level glare). The glare created by the Project would range between 39,047 minutes and 40,044 minutes of “green” level glare, which represents less than 20 percent of total day light time. The Riverside County ALUC has a policy that any proposed development with solar arrays should not have more than 60,000 minutes or roughly 20 percent of daylight minutes annually in predicted glare impact and the Project would not create glare that would exceed this Riverside County ALUC policy.
Electrical and Communication Interference
The proposed Project does not include the use of equipment that would interfere with aircraft communications. The solar panels themselves present little risk of interfering with radar transmission due to their low profiles. In addition, solar panels do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and any electrical facilities that do carry concentrated current will be buried beneath the ground and away from any signal transmission. There are no radar transmission or receiving facilities within the Project site.
March Air Reserve Base/United States Air Force Input
Given that the project site is located in Zone C2 westerly of the northerly runway at March Air Reserve Base, the Base staff was notified of the project, and sent plans and the solar glare hazard City of Riverside
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study for their review. On July 31, 2023, the Air Force provided comments supporting ALUC’s recommendation of inconsistency due to concerns with the project’s inconsistent density.
Prohibited and Discouraged Uses
The project does not propose any uses specifically prohibited or discouraged in Compatibility Zone C2 (highly noise-sensitive outdoor nonresidential uses), other than the inconsistent density.
Noise
The MARB/IPA LUCP depicts the site as being below the 60 CNEL range from aircraft noise.
Therefore, no special measures are required to mitigate aircraft-generated noise.
PAR 77 (Structure Height)
At a distance of approximately 17,464 feet from the Project site to the nearest point on the runway, Federal Aviation Administration (FAA) review would be required for any structures with top of roof exceeding 1,710 feet above mean sea level (amsl). The Project site’s finished floor elevation is 1,595 feet amsl and proposed building height is 57’2” feet, resulting in a top point elevation of 1,652’2” amsl. Therefore, review of the building for hei ght/elevation reasons by the FAA Obstruction Evaluation Service (FAAOES) is not required.
In summary, the Riverside County ALUC Staff Report for the P roject concluded that the project was inconsistent with the MARB/IPA ALUCP based on the following:
• It exceeds the Zone C2 residential density criteria maximum of 6.0 du/ac.
The Riverside County ALUC Staff Report for the project concluded that the Project was consistent with the following MARB/IPA ALUCP criteria:
• Non-residential average intensity (calculating with two different methods); • Non-residential single-acre intensity.
City of Riverside Consistency with MARB/IPA Analysis and Findings Residential Density
The Project site is located within Compatibility Zone C2, which restricts residential density to a maximum of 6.0 dwelling units per acre (du/ac). The proposed Project includes 347 multi -family units on 9.92 acres, which results in a density of 35.0 dwelling units per acre. The Project’s proposed residential density of 35.0 du/ac exceeds the maximum allowable residential density for Zone C2.
Non-Residential Average Intensity
The non-residential average intensity for Compatibility Zone C2 is limited to 200 people per acre.
The proposed Project includes construction of a 347- unit multi -family development including recreational amenities including 2,963 SF of leasing office area, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2.386 SF of fitness area, accommodating a total City of Riverside
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occupancy of 311 people, resulting in an average intensity of 31 people per acre, which does not exceed and is consistent with the Compatibility Zone C2 average intensity of 200 people per acre.
The Project would be consistent with non- residential intensity requirements using a second method based on the number of parking spaces provided by the Project. For determining total occupancy, the total number of parking spaces provided or required for the Project (whichever is greater) is multiplied by an average vehicle occupancy per vehicle, which is assumed to be 1.5 persons per vehicle. As outlined in the project description section (Section 3.0 – Project Description) the Project is providing a total of 604 parking spaces (not 347 as utilized in ALUC’s calculation). Based on the number of parking spaces provided, the total occupancy would be estimated at 906 people, for an average intensity of 91 people per acre, which does not exceed and is consistent with the Compatibility Zone C2 average intensity criterion of 200 people per acre. The Project’s average intensity of 91 people per acre is considerably lower than the C2 average intensity criterion of 200 people per acre. While the unit count may exceed ALUC’s residential density requirements, the actual amount of people onsite would be much lower than what ALUC would allow in Zone C2 if this were a commercial development, and accordingly would not impose a safety impact due to the intensity of people onsite in the event of an emergency.
Flight Hazard Issues
Structure height, electrical interference, and reflectivity/glare are potential flight hazard issues from solar panels being utilized in the airport influence area. The Project’s photovoltaic (PV) panel structures would be located on the building rooftops and carports within Compatibility Zone C2.
Height
The FAA FAR Part 77 Surface Map is a map used by the FAA and the ALUC to identify potential obstructions and hazards to aviation traffic. The ALUC uses the map as a height restriction boundary for the purposes of making consistency determinations with its ALUCP. The elevation of Runway 14- 32 at its northerly terminus is 1,535 feet amsl. The Project at a distance of approximately 17,464 feet from the nearest point on the runway, would require FAA review if the top roof exceeded 1.710 feet amsl. The Project site’s finished floor elevation is 1,595 feet amsl and the proposed maximum building height is 57’2” feet, resulting in a top point elevation of 1,652’2” feet amsl. Therefore, FAAOES review is not required. The Project is in compliance with and will have no impact related to FAA FAR Par 77 regulations.
The Project proposes to develop five, 4-story buildings with a maximum height of 57’2” feet. This is below the proposed Mixed Use – Urban (MU-U) maximum height of 60 feet and well below the current Commercial Retail (CR) maximum height of 75 feet. Development of the Project, as well as the proposed General Plan amendment (GPA) and change of zone (ZC) will result in reduced maximum height than what is allowed under the proposed GPA and ZC and what is currently allowed for the site. The Project would not impose a safety hazard due to height.
Electrical Interference
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There are no radar transmission or receiving facilities within the Project site. The Project’s solar panels are low profile and present little risk of interfering with radar transmission. In addition, the solar panels do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and any electrical facilities that do carry concentrated current will be buried beneath the ground and away from any signal transmission. The Project will not utilize equipment that would interfere with aircraft communications.
Glint and Glare/Reflectivity
Based on the Federal Aviation Administration’s Interim Policy for Review of Solar Energy System Project on Federally Obligated Airports, no glare potential or low potential for temporary after - image (“green” level) are acceptable levels of glare on final approach (within 2 miles from end of runway) for solar facilities located on airport property. Potential for temporary after-image (“yellow” level) and potential for permanent eye damage (“red” level) are not acceptable levels of glare on final approach. No glare is permitted at air traffic control towers.
The proposed Project includes approximately 40,000 SF of solar panels on the building rooftops and carports. Based on the results of the glint and glare analysis the following are the key results:
• No significant (red glare) glint and glare impacts on key receptors are predicted. • No impacts from glare were predicted on the final approach flight paths. • Minor (green) impacts from glare, “glare with low potential to cause temporary after - image,” were predicted; 44,049 minutes of “green” glare were predicted of annual daylight hours. Which would be approximately 16.7 percent of the total number of minutes of sunlight in a standard year. The proposed Project is in compliance with Riverside County ALUC policy that any proposed development with solar arrays should not have more than 20 percent of daylight minutes. The anticipated amount of green glare produced annually from the Project is below ALUC’s threshold of 20% of daylight minutes.
Therefore, the Project’s solar panels would not result in solar glare impacts on MARB/IPA flight operations.
The Project site is currently a part of the Mission Grove Plaza Shopping Center and will continue to share parking spaces with the commercial development upon Project implementation. As such, ample open space is provided adjacent to the Project in the event an aircraft requires an emergency landing.
The Project will comply with the recommended ALUC conditions of approval, including restrictions on outdoor lighting, prohibited uses, and notices and informational brochures for prospective purchasers and tenants. The Project will also comply with recommended conditions related to light and glare with minor modifications, to continue to ensure safety, but allow for flexibility in the final design of the Project’s solar panels. The City of Riverside recommended conditions of approval are outlined below.
Riverside County Recommended ALUC conditions:
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1. Any new outdoor lighting that is installed shall be hooded or shielded so as to prevent either spillage of lumens or reflection into the sky. Outdoor lighting shall be downward facing.
2. The following uses/activities are not included in the proposed project and shall be prohibited at this site:
a. Any use which would direct a steady light or flashing light of red, white, green, or amber colors associated with airport operations toward an aircraft engaged in an initial straight or circling climb following takeoff or toward an aircraft engaged in a straight or circling final approach toward a landing at an airport, other than a DoD or FAA-approved navigational signal light or visual approach slope indicator.
b. Any use which would cause sunlight to be reflected towards an aircraft engaged in an initial straight or circling climb following takeoff or towards an aircraft engaged in a straight or circling final approach towards a landing at an airport.
c. Any use which would generate smoke or water vapor or which would attract large concentrations of birds, or which may otherwise affect safe air navigation within the area. (Such uses include landscaping utilizing water features, aquaculture, production of cereal grains, sunflower, and row crops, composting operations, wastewater management facilities, artificial marshes, trash transfer stations that are open on one or more sides, recycling centers containing putrescible wastes, construction and demolition debris facilities, fly ash disposal, and incinerators.) d. Any use which would generate electrical interference that may be detrimental to the operation of aircraft and/or aircraft instrumentation. e. Highly noise-sensitive outdoor nonresidential uses. Examples of noise - sensitive outdoor nonresidential uses that are prohibited include, but are not limited to, major spectator-oriented sports stadiums, amphitheaters, concert halls and drive-in theaters.
f. Other Hazards to flight.
3. The “Notice of Airport in Vicinity” that was provided in the ALUC Staff Report for the Project shall be provided to all prospective purchasers and occupants of the property and be recorded as a deed notice.
4. Any proposed stormwater basins or facilities shall be designed and maintained to provide for a maximum 48-hour detention period following the design storm, and remain totally dry between rainfalls. Vegetation in and around the basins that would provide food or cover for birds would be incompatible with airport operations and shall not be utilized in project landscaping. Trees shall be spaced so as to prevent large expanses of contiguous canopy, when mature. Landscaping in and around the basin(s) shall not include trees or shrubs that produce seeds, fruits, or berries.
Landscaping in the detention basin, if not rip-rap, should be in accordance with the guidance provided in ALUC “LANDSCAPING NEAR AIRPORTS” brochure, and the “AIRPORTS, WILDLIFE AND STORMWATER MANAGEMENT” brochure available at RCALUC.ORG City of Riverside
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which list acceptable plants from Riverside County Landscaping Guide or other alternative landscaping as may be recommended by a qualified wildlife hazard biologist. A notice sign, in a form similar to that attached hereto, shall be permanently affixed to the stormwater basin with the following language: “There is an airport nearby. This stormwater basin is designed to hold stormwater for only 48 hours and not attract birds. Proper maintenance is necessary to avoid bird strikes”. The sign will also include the name, telephone number or other contact information of the person or entity responsible to monitor the stormwater basin.
5. March Air Reserve Base must be notified of any land use having an electromagnetic radiation component to assess whether a potential conflict with Air Base radio communications could result. Sources of electromagnetic radiation include radio wave transmissi on in conjunction with remote equipment inclusive of irrigation controllers, access gates, etc.
6. The project has been evaluated to construct a multi -family development consisting of 347 multi-family residential units, pool area, leasing office, club area, and fitness center. Any increase in building area, change in use to any higher intensity use, change in building location, or modification of the tentative parcel map lot lines and areas will require an amended review to evaluate consistency with the ALUCP compatibility criteria, at the discretion of the ALUC Director.
7. All solar arrays installed on the project site shall consist of photovoltaic solar panels that are consistent with the specifications described in the glare study, which projects 44,049 minutes of solar glare annually based on the proposed Project. Any deviation that exceeds 20 percent of annual daylight minutes should be analyzed in an updated solar glare study which shall be submitted to ALUC. If the updated solar glare study results in a) more than 20 percent of annual solar glare minutes, b) any glare i mpacting the air traffic control tower, or c) creation of any “yellow” or “red” level glare in the flight paths, then the amended project shall require a new hearing by the Airport Land Use Commission.
8. In the event that any glint, glare, or flash affecting the safety of air navigation occurs as a result of project operation, upon notification to the airport operator of an event, the airport operator shall notify the project operator in writing. Within 30 days of written notice, the project operator shall be required to promptly take all measures necessary to eliminate such glint, glare, or flash. An “event” includes any situation that results in an accident, incident, “near - miss,” or specific safety complaint regarding an in-flight experience to the airport operator or to federal, state, or county authorities responsible for the safety of air navigation. The project operator shall work with the airport operator to prevent recurrence of the incidence. Suggested measures may include, but are not limited to, changing the orientation and/or tilt of the source, covering the source at the time of day when events of glare occur, or wholly removing the source to diminish or eliminate the source of the glint, glare, or flash. For each such event made known to the project operator, the necessary remediation shall only be considered to have been fulfilled when the airport operator states in writing that the situation has been remediated to the airport operator’s satisfaction.
9. In the event that any electrical interference affecting the safety of air navigation occurs as a result of project operation, upon notification to the airport operator of an event, the airport operator shall notify the project operator in writing. Within 30 days of written notice, the project City of Riverside
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operator shall be required to promptly take all measures necessary to eliminate such interference. An “event” includes any situation that results in an accident, incident, “near - miss,” report by airport personnel, or specific safety complaint to the airpor t operator or to federal, state, or county authorities responsible for the safety of air navigation. The project operator shall work with the airport operator to prevent recurrence of the event. For each such event made known to the project operator, the necessary remediation shall only be considered to have been fulfilled when the airport operator states in writing that the situation has been remediated to the airport operator’s satisfaction.
The Project would be consistent with Compatibility Zone C2’s non -residential density, height of structures, glare, electrical interference and there would be no safety issues related to these topics. However, the Project would be inconsistent with the allowable maximum residential density criteria for the Compatibility Zone C2. Due to the inconsistency of the maximum residential density, the Project would result in a significant and unavoidable impact. There are no feasible mitigation measures that would reduce impacts related to inconsistency with the residential density criteria.
The City Council of the City of Riverside, by a two-thirds vote (per RMC Title 19), has the authority to overrule the Riverside County ALUC decision based on specific findings that the proposed Project is consistent with the purposes of ALUC law to protect public health, safety and welfare ensuring (1) the orderly expansion of airports, and (2) the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are not already devoted to incompatible uses. The Project is consistent with the purpose and intent of ALUC law and the MARB/IPA LUCP based on the following:
1. The Project is consistent with the residential development surrounding MARB/IPA, specifically in Zone C2 and will not result in the encroachment of incompatible residential densities affecting current or future March ARB/IPA operations. The Project involves the redevelopment of an underutilized commercial parcel with a multi -family residential development. The Project’s proposed General Plan designation and zoning of Mixed Use - Urban, is consistent with surrounding development, and would assist in transitioning between commercial and single-family residential uses.
The Project site is bordered on the north, west, and east (across Mission Grove Parkway) by the Mission Grove Plaza Shopping Center, which has a General Plan Land Use Designation of C – Commercial and is zoned CR -SP – Commercial Retail and Specific Plan (M ission Grove) Overlay Zones and is developed with retail uses. Multi -family residences are located further north (across Alessandro Boulevard), which have a General Plan Land Use Designation of HDR – High-Density Residential, and area zoned R-3-3000- SP – Multi-Family Residential and Specific Plan (Mission Grove) Overlay Zones. The Project site is bordered on the south by a single- family residential neighborhood (across Mission Village Drive), which has a General Plan Land Use Designation of Medium High Density Residential (MHDR) and City of Riverside
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is zoned R-1-7000-SP – Single Family Residential and Specific Plan (Mission Grove) Overlay Zones.
Several multi-family residential uses are located in Zone C2, near the Project site. There is a condominium complex, Mission Villas, located at 200 E. Alessandro Boulevard, adjacent to the Project site, across from Alessandro Boulevard. The Mission Grove P ark apartments, located at 7450 Northrop Drive, are located closer to the end of Runway 14- 32 than the Project. Mission Grove Park consists of 432 units and has a density of approximately 16 dwelling units per acre (du/ac). Estancia, located at 7871 Missi on Grove Parkway South, consists of 208 units and has a density of approximately 17 du/ac. The Project is consistent with other multi - family residential developments in the C2 Zone. Additionally, the Project consist of infill development of a commercial site. The vast majority of Zone C2 in the City of Riverside has been built out, largely by single family residences. Few infill sites, such as the Project are available for development. As such, the Project would not encourage other developments to exceed Zone C2 density standards or encroach upon MARB/IPA operations.
Therefore, the Project will not affect the orderly expansion of the MARB/IPA.
2. The Project is consistent with the aircraft noise standards of the ALUCP and the requirements of Public Utilities Code (PUC) Section 21670. The MARB/IPA ALUCP provides the CNEL considered normally acceptable for new residential uses in the vicinity of MARB/IPA, which is 65 dBA. The Project site is approximately 3.3 miles from the end of Runway 14- 32. The MARB/IPA ALUCP depicts the site as being below the 60 CNEL range from aircraft noise.
Therefore, ALUC found no special measures were required to mitigate aircraft -generated noise. Because the Project is consistent with the noise standards in the March MARB/IPA ALUCP, the Project also complies with noise standards in the City of Riverside General Plan (General Plan Noise Element, Figure N-10). While multi-family or mixed uses are not defined in the City’s General Plan Noise Element, the “normally acceptable” noise level for an infill single family residential use is between 55 and 65 dBA CNEL. The General Plan Noise Element Figure N -9 shows the Project site as being just outside the 60 -65 dB CNEL noise contour projected for MARB/IPA operations. Accordingly, noise exposure from MARB/IPA would not exceed normally acceptable levels for the Project site.
The Project will comply with the Riverside Municipal Code requirements regarding construction noise and will not compound noise related to MARB/IPA operations. All construction would take place between 7:00 am and 7:00 pm on weekdays, 8:00 am and 5:00 pm on Saturdays, and would not take place at any time on Sundays or federal holidays. Consistent with MARB/IPA ALUCP, the Project will utilize standard construction techniques to ensure interior noise levels from aviation-related sources are no more than CNEL 40 dB. The Project will comply with ALUC noticing conditions and will provide a “Notice of Airport in Vicinity” to all prospective purchasers and occupants of the property.
The Project does not propose any uses specifically prohibited or discouraged in compatibility Zone C2 (highly noise- sensitive outdoor nonresidential uses), such as major spectator -oriented sports stadiums, amphitheaters, concert halls and drive- in theaters. The Project also does not City of Riverside
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propose noise sensitive uses such as children’s schools, day care centers, libraries, hospitals, or nursing homes.
Therefore, the Project minimizes the public’s exposure to excessive noise and safety hazards within areas around MARB/IPA.
A City Council proposed overrule of an ALUC action must provide a copy of the proposed decision and findings to both ALUC and the California Division of Aeronautics, a minimum of 45 days prior to decision to overrule ALUC. These agencies have 30 days in which to provide comments to City Council (DEIR 5.9-14, -24)
LAND USE AND PLANNING
Conflict with Land Use Plans or Policies
Threshold B: Would the Project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?
Finding: Significant and unavoidable. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measure or project alternatives identified in the EIR. (State CEQA Guidelines, section 15091(a)(3).)
The Project would be consistent with all applicable GP 2025 policies, with the exception of those that relate to consistency with the applicable airport land use compatibility plan, the MARB/IPA LUCP, in which the Project is partially inconsistent and parti ally consistent with, which are the following:
• Policy CCM-11.1: Protect flight paths from encroachment by inappropriate development using the Riverside County Airport Land Use Compatibility Plan and the 2014 March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan to determine the consistency of proposed development.
• Policy LU-22.3: Work to limit the encroachment of uses that potentially pose a threat to continued airport operations, including intensification of residential and/or commercial facilities within identified airport safety zones and areas already impacted by current or projected airport noise.
• Policy LU -22.5: Review all proposed projects within the airport influence areas of Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport as noted in the Public Safety Element (Figure PS -6A – Riverside Municipal and Flabob Airport Safety Zones and Influence Areas; and Figure PS -6B – March ARB/IPA Airport Safety Zones and Influence Areas) for consistency with all applicable airport land use compatibility plan policies adopted by the Riverside County Airport Land Use Commission (ALUC) and the City of Riverside, to the fullest extent the City finds feasible. • Policy LU-69.1: Do not permit further amendments to the Mission Grove Specific Plan City of Riverside
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that would increase the residential density of the neighborhood or otherwise conflict with ongoing safe operations at March Air Reserve Base/Inland Port as called out in the Riverside County Airport Land Use Compatibility Plan.
The Project’s proposed 35.0 dwelling units per acre would exceed the maximum permitted density of 6.0 dwelling units per acre within Zone C2. However, the Project does not exceed the non - residential average criteria (limited to 200 people per acre) or single-acre intensity criteria (limited to 500 people per acre). The Project is consistent with all other applicable policies. (DEIR, p. 5.11- 10 - 5.11-64)
Explanation:
General Plan 2025
Consistency with General Plan Policies
As outlined in Table 5.11- 1 above, the Project would be consistent with all applicable GP 2025 policies, with the exception of those that relate to consistency with the applicable airport land use compatibility plan, the MARB/IPA LUCP, in which the Project is partially inconsistent and partially consistent with, which are the following:
• Policy CCM -11.1: Protect flight paths from encroachment by inappropriate development using the Riverside County Airport Land Use Compatibility Plan and the 2014 March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan to determine the consistency of proposed development.
• Policy LU -22.3: Work to limit the encroachment of uses that potentially pose a threat to continued airport operations, including intensification of residential and/or commercial facilities within identified airport safety zones and areas already impacted by current or projected airport noise.
• Policy LU-22.5: Review all proposed projects within the airport influence areas of Riverside Municipal Airport, Flabob Airport or March Air Reserve Base/Inland Port Airport as noted in the Public Safety Element (Figure PS -6A – Riverside Municipal and Flabob Airport Safe ty Zones and Influence Areas; and Figure PS -6B – March ARB/IPA Airport Safety Zones and Influence Areas) for consistency with all applicable airport land use compatibility plan policies adopted by the Riverside County Airport Land Use Commission (ALUC) and the City of Riverside, to the fullest extent the City finds feasible. • Policy LU-69.1: Do not permit further amendments to the Mission Grove Specific Plan that would increase the residential density of the neighborhood or otherwise conflict with ongoing safe operations at March Air Reserve Base/Inland Port as called out in the Riverside County Airport Land Use Compatibility Plan.
The Project’s proposed 35.0 dwelling units per acre would exceed the maximum permitted density of 6.0 dwelling units per acre within Zone C2. However, the Project does not exceed the non- residential average criteria (limited to 200 people per acre) or single-acre intensity criteria (limited to 500 people per acre).
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Consistency with General Plan Land Use Designation
The current commercial land use designation would not allow the proposed Project’s multi-family residential development. The proposed Project includes a General Plan Amendment (GPA) to change the existing General Plan Land Use Designation of the project site from C - Commercial to MU-U - Mixed Use-Urban, to allow residential land use. The existing and proposed land use designations are shown in Figure 3.0- 4 General Plan Land Use Map. As outlined in Section 3.0 Project Description, the proposed Project would comply with the City’s Site Development Standards (Table 3.0-3 Building Development Standards). Upon approval of the Project, including the proposed GPA, the proposed development would comply with the new applicable land use designation.
Consistency with General Plan Housing Element
The proposed Project would comply with the applicable GP 2025 Housing Element objectives and policies by increasing the types and availability of housing in the City. The Project will comply with smart growth principles by providing multi-family residential housing in a mixed-use environment.
The Project would also provide appropriate site design, landscaping, and building design in order to comply with the GP 2025 Land Use and Urban Design Elements.
The Project would be consistent with all applicable GP 2025 objectives and policies, with the exception of policies CCM-11.1, Policy LU-22.3, Policy LU-22.5, and Policy LU-69.1, in which it would be partially consistent and partially inconsistent. The partial inconsistency is due to the Project exceeding the maximum permitted density of 6.0 dwelling units per acre within Combability Zone C2. Due to the partial inconsistency with applicable GP 2025 policies, the project would result in a significant and unavoidable impact. There are no feasible mitigation measures that would reduce impacts related to inconsistency with the residential density criteria.
Mission Grove Specific Plan
The current Mission Grove Specific Plan designation as Retail Business & Office would not allow the proposed Project’s multi- family residential development. The proposed Project includes a Specific Plan Amendment (SPA) to revise the Mission Grove Specific Plan. The proposed revisions to the Mission Grove Specific Plan include adding Mixed- Use – Urban for 9.92 acres, with density of 40 dwelling units per acre, and number of Mixed-Use – Urban units of 396.80, and reducing the Non-Residential, Retail Business & Office to 59.84 acres. The Project includes 604 parking spaces in total. Of these, 513 parking spaces will be dedicated for the Proposed apartment project, and 91 will be shared between the Proposed apartment project and the existing adjacent retail site. The shared parking will be memorialized in a new covenant and restriction agreement between the residential developer entity and Mission Grove Plaza. A 15% parking reduction request has been outlined for the Project site as noted in the Project’s Specific Plan Amendment, per City of Riverside Municipal Code 19.580.060.C.2.b. Upon approval of the Project, including the proposed SPA, the proposed development would comply with the new applicable zoning regulations.
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March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan The Project site is located within the March Air Reserve Base (MARB) airport influence area, within Compatibility Zone C2 of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IPA LUCP). The Riverside County Airport Land Use C ommission (ALUC) prepared a Staff Report (dated September 14, 2023) analyzing the Project’s consistency with applicable airport land use compatibility criteria as outlined in further detail below. The Project does not propose any uses specifically prohibited or discouraged in Compatibility Zone C2 (highly noise-sensitive outdoor nonresidential uses). On September 14, 2023, the Riverside County ALUC, by a 5-0 vote, found the proposed Project, Case Number ZAP1111RI23, inconsistent with the 2014 MARB/ IPA LUCP, based on the fact that the project is inconsistent with the required residential density criteria.
The Riverside County ALUC Staff Report concluded that the proposed Project would be inconsistent with the airport land use compatibility plan criteria and the City adopted General Plan and Zoning Ordinance based on the following points:
Residential Density
Pursuant to the MARB/IPA LUCP, the project site is located within Compatibility Zone C2, which restricts residential density to a maximum of 6.0 dwelling units per acre (du/ac). The proposed Project includes 347 multi-family units on 9.92 acres, which results in a density of 35.0 dwelling units per acre. The Zone C2, in which the Project is located, is identified as a Flight Corridor Zone, where the risk level is considered “moderate” in the ALUC Countywide Policies Table 3A – Compatibility Zone Factors. Per Table 3A – Compatibility Zone Factors, “some 10% to 15% of off- runway general aviation accidents near airports occur in this zone,” in reference to Compatibility Zone C2. Based on these safety factors, the intent and purpose of Compatibility Zone C2 is t o restrict residential density in order to limit the potential risk of an off -field aircraft landing. The Project’s proposed residential density of 35.0 du/ac exceeds the maximum allowable residential density for Zone C2 of 6.0 du/ac.
County Wide Policy 3.3.1 Infill
Countywide Policy 3.3.1 (Infill) allows for greater densities than would otherwise be permitted in Compatibility Zone C2, but caps densities at double the allowable density of the zone. As the maximum density of the zone is 6.0 du/ac, doubling the density increases the limit from 6.0 to
12.0 du/ac, which the proposed Project’s density of 35.0 du/ac would significantly exceed.
As designed for the March Air Reserve Base environs, Compatibility Zone C2 would allow an average of 200 people per acre and a single acre land use intensity of 500 persons.
Non-Residential Average Intensity
Pursuant to the MARB/IPA LUCP, the non-residential average intensity for Compatibility Zone C2 is limited to 200 people per acre. Per Appendix C, Table C -1 of the MARB/IPA LUCP and the City of Riverside
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Additional Compatibility Policies included in the MARB/IPA LUCP the following rates were used to calculate the occupancy for the proposed Project:
• Office area – 1 person per 200 square feet (SF);
• Exercise Room area – 1 person per 50 SF,
• Pool area – 1 person per 50 SF;
• Pool Deck area – 1 person per 15 SF; and
• Club area – 1 person per 15 SF.
As the Project includes construction of a 347-unit multi-family development including recreational amenities including 2,963 SF of leasing office area, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2.386 SF of fitness area, accommodating a total occupancy of 311 people, resulting in an average intensity of 31 people per acre, which is consistent with the Compatibility Zone C2 average intensity of 200 people per acre.
A second method for determining total occupancy involves multiplying the number of parking spaces provided or required (whichever is greater) by average vehicle occupancy (assumed to be 1.5 persons per vehicle). Based on the number of parking spaces provided (347 standard vehicles) the total occupancy would be estimated at 521 people for an average intensity of 53 people per acre, which is consistent with the Compatibility Zone C2 average intensity criterion of 200 people per acre. (DEIR, p. 5.11-56)
ALUC misstated the number of spaces provided by the project and found that based on the number of parking spaces provided (misstated as 347 standard vehicles), the total occupancy would be estimated at 521 people for an average intensity of 53 people per acre, which is consistent with the Zone C2 intensity criterion of 200 people per acre. However, the Project provides 604 parking spaces. As such, using ALUC’s methodology, the total occupancy would be estimated at 906 people, for an average intensity of 91 people per acre. This remains considerably lower than Zone C2 average intensity criterion of 200 people per acre. Thus, while the unit count may exceed ALUC’s residential density requirements, the actual number of people onsite would be much lower than what ALUC would allow in Zone C2 if this were a commercial development, and accordingly would not impose a safety impact due to the intensity of people onsite in the event of an emergency.
Non-Residential Single-Acre Intensity
Pursuant to the MARB/IPA LUCP, Compatibility Zone C2 limits maximum single-acre intensity to 500 people. There are no risk -reduction design bonuses available as MARB/IPA is primarily utilized by large aircraft weighing more than 12,500 pounds. Based on the Project site plan and the occupancies previously calculated/noted, the maximum single-acre area would occur around the multi-family residential amenities which includes 2,963 SF of leasing office, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2,386 SF of fitness area, resulting in a single acre occupancy of 311 people, which would be consistent with the Compatibility Zone C2 single-acre intensity criterion of 500 people.
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Flight Hazard Issues
Structure height, electrical interference, and reflectivity/glare are among the issues that solar panels in the airport influence area must address. The Project’s photovoltaic (PV) panel structures would be located on the building rooftops and carports within the Compatibility Zone C2.
Glint and Glare/Reflectivity
Based on the Federal Aviation Administration’s Interim Policy for Review of Solar Energy System Project on Federally Obligated Airports, no glare potential or low potential for temporary after - image (“green” level) are acceptable levels of glare on final approach (within 2 miles from end of runway) for solar facilities located on airport property. Potential for temporary after-image (“yellow” level) and potential for permanent eye damage (“red” level) are not acceptable levels of glare on final approach. No glare is permitted at air traffic control towers.
The proposed Project includes approximately 40,000 SF of solar panels on the building rooftops and carports. Two solar glare studies were prepared for the proposed Project utilizing web-based Forge Solar which analyzed 1) panels with a fixed tilt of 5 degrees with no rotation and orientation of 180 degrees with a height of 45 feet. The analysis concluded that some potential for glare was identified within the Air Force traffic pattern. Evaluation of the Air Force traffic patterns indicates that the panels would result in no glare or a low potential for temporary after-image (“green” level glare). The glare created by the Project would range between 39,047 minutes and 40,044 minutes of “green” level glare, which represents less than 20 percent of total day light time. The Riverside County ALUC has a policy that any proposed development with solar arrays should not have more than 60,000 minutes or roughly 20 percent of daylight minutes annually in predicted glare impact and the Project would not create glare that would exceed this Riverside County ALUC.
Electrical and Communication Interference
The proposed Project does not include the use of equipment that would interfere with aircraft communications. The solar panels themselves present little risk of interfering with radar transmission due to their low profiles. In addition, solar panels do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and any electrical facilities that do carry concentrated current will be buried beneath the ground and away from any signal transmission. There are no radar transmission or receiving facilities within the Project site.
March Air Reserve Base/United States Air Force Input
Given that the project site is located in Zone C2 westerly of the northerly runway at March Air Reserve Base, the Base staff was notified of the project, and sent plans and the solar glare hazard study for their review. On July 31, 2023, the Air Force provided comments supporting ALUC’s recommendation of inconsistency due to concerns with the project’s inconsistent density.
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Prohibited and Discouraged Uses
The project does not propose any uses specifically prohibited or discouraged in Compatibility Zone C2 (highly noise-sensitive outdoor nonresidential uses), other than the inconsistent density.
Noise
The MARB/IPA LUCP depicts the site as being below the 60 CNEL range from aircraft noise.
Therefore, no special measures are required to mitigate aircraft-generated noise.
PART 77 (Structure Height)
At a distance of approximately 17,464 feet from the Project site to the nearest point on the runway, Federal Aviation Administration (FAA) review would be required for any structures with top of roof exceeding 1,710 feet above mean sea level (amsl). The Project site’s finished floor elevation is 1,595 feet amsl and proposed building height is 57’2” feet, resulting in a top point elevation of 1,652’2” amsl. Therefore, review of the building for height/elevation reasons by the FAA Obstruction Evaluation Service (FAAOES) is not required.
In summary, the Riverside County ALUC Staff Report for the project concluded that the project was inconsistent with the MARB/IPA ALUCP based on the following:
• It exceeds the Zone C2 residential density criteria maximum of 6.0 du/ac.
The Riverside County ALUC Staff Report for the project concluded that the project was consistent with the following MARB/IPA ALUCP criteria:
• Non-residential average intensity (calculating with two different methods); • Non-residential single-acre intensity.
City of Riverside Consistency with MARB/IPA Analysis and Findings Residential Density
The Project site is located within Compatibility Zone C2, which restricts residential density to a maximum of 6.0 dwelling units per acre (du/ac). The proposed Project includes 347 multi -family units on 9.92 acres, which results in a density of 35.0 dwelling units per acre. The Project’s proposed residential density of 35.0 du/ac exceeds the maximum allowable residential density for Zone C2.
Non-Residential Average Intensity
The non-residential average intensity for Compatibility Zone C2 is limited to 200 people per acre.
The proposed Project includes construction of a 347- unit multi -family development including recreational amenities including 2,963 SF of leasing office area, 1,001 SF of pool area, 1,293 SF of pool deck area, 2,136 SF of club area, and 2.386 SF of fitness area, accommodating a total occupancy of 311 people, resulting in an average intensity of 31 people per acre, which does not exceed and is consistent with the Compatibility Zone C2 average intensity of 200 people per acre.
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The Project is also consistent with non-residential intensity requirements using a second method based on the number of parking spaces provided by the Project. For determining total occupancy, the total number of parking spaces provided or required for the Project (whichever is greater) is multiplied by an average vehicle occupancy per vehicle, which is assumed to be 1.5 persons per vehicle. As outlined in the project description section (Section 3.0 – Project Description) the Project is providing a total of 604 parking spaces (not 347 as utilized in ALUC’s calculation).
Based on the number of parking spaces provided, the total occupancy would be estimated at 906 people, for an average intensity of 91 people per acre, which does not exceed and is consistent with the Compatibility Zone C2 average intensity criterion of 200 people per acre. The Project’s average intensity of 91 people per acre is considerably lower than the C2 average intensity criterion of 200 people per acre. While the unit count may exceed ALUC’s residential density requirements, the actual amount of people onsite would be much lower than what ALUC would allow in Zone C2 if this were a commercial development, and accordingly would not impose a safety impact due to the intensity of people onsite in the event of an emergency.
Flight Hazard Issues
Structure height, electrical interference, and reflectivity/glare are potential flight hazard issues from solar panels being utilized in the airport influence area. The Project’s photovoltaic (PV) panel structures would be located on the building rooftops and carports within the Compatibility Zone C2.
Height
The FAA FAR Part 77 Surface Map is a map used by the FAA and the ALUC to identify potential obstructions and hazards to aviation traffic. The ALUC uses the map as a height restriction boundary for the purposes of making consistency determinations with its ALUCP. The elevation of Runway 14- 32 at its northerly terminus is 1,535 feet amsl. The Project at a distance of approximately 17,464 feet from the nearest point on the runway, would require FAA review if the top roof exceeded 1.710 feet amsl. The Project site’s finished floor elevation is 1,595 feet amsl and the proposed maximum building height is 57’2” feet, resulting in a top point elevation of 1,652’2” feet amsl. Therefore, FAAOES review is not required. The Project would be in compliance with and will have no impact related to FAA FAR Par 77 regulations.
The Project proposes to develop five, 4-story buildings with a maximum height of 57’2” feet. This is below the proposed Mixed Use – Urban (MU-U) maximum height of 60 feet and well below the current Commercial Retail (CR) maximum height of 75 feet. Development of the Project, as well as the proposed General Plan amendment (GPA) and change of zone (ZC) will result in reduced maximum height than what is allowed under the proposed GPA and ZC and what is currently allowed for the site. The Project would not impose a safety hazard due to height.
Electrical Interference
There are no radar transmission or receiving facilities within the Project site. The Project’s solar panels are low profile and present little risk of interfering with radar transmission. In addition, the City of Riverside
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solar panels do not emit electromagnetic waves over distances that could interfere with radar signal transmissions, and any electrical facilities that do carry concentrated current will be buried beneath the ground and away from any signal transmission. The Project will not utilize equipment that would interfere with aircraft communications.
Glint and Glare/Reflectivity
Based on the Federal Aviation Administration’s Interim Policy for Review of Solar Energy System Project on Federally Obligated Airports, no glare potential or low potential for temporary after - image (“green” level) are acceptable levels of glare on final approach (within 2 miles from end of runway) for solar facilities located on airport property. Potential for temporary after-image (“yellow” level) and potential for permanent eye damage (“red” level) are not acceptable levels of glare on final approach. No glare is permitted at air traffic control towers.
The proposed Project includes approximately 40,000 SF of solar panels on the building rooftops and carports. Based on the results of the glint and glare analysis the following are the key results:
• No significant (red glare) glint and glare impacts on key receptors are predicted. • No impacts from glare were predicted on the final approach flight paths. • Minor (green) impacts from glare, “glare with low potential to cause temporary after - image,” were predicted; 44,049 minutes of “green” glare were predicted of annual daylight hours. Which would be approximately 16.7 percent of the total number of minutes of sunlight in a standard year. The proposed Project is in compliance with Riverside ALUC policy that any proposed development with solar arrays should not have more than 20 percent of daylight minutes. The anticipated amount of green glare produced annually from the Project is below ALUC’s threshold of 20% of daylight minutes.
Therefore, the Project’s solar panels would not result in a solar glare impacts on MARB/IPA flight operations.
The Project site is currently a part of the Mission Grove Plaza Shopping Center and will continue to share parking spaces with the commercial development upon Project implementation. As such, ample open space is provided adjacent to the Project in the event an aircraft requires an emergency landing.
The Project will comply with the recommended ALUC conditions of approval, including restrictions on outdoor lighting, prohibited uses, and notices and informational brochures for prospective purchasers and tenants. The Project will also comply with recommended conditions related to light and glare with minor modifications, to continue to ensure safety, but allow for flexibility in the final design of the Project’s solar panels. The ALUC recommended conditions of approval are outlined below. (DEIR, p. 5.11-10 - 5.11-64)
Riverside County ALUC conditions:
1. Any new outdoor lighting that is installed shall be hooded or shielded so as to prevent either spillage of lumens or reflection into the sky. Outdoor lighting shall be downward facing.
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2. The following uses/activities are not included in the proposed project and shall be prohibited at this site:
a. Any use which would direct a steady light or flashing light of red, white, green, or amber colors associated with airport operations toward an aircraft engaged in an initial straight or circling climb following takeoff or toward an aircraft engaged in a straight or circling final approach toward a landing at an airport, other than a DoD or FAA -approved navigational signal light or visual approach slope indicator.
b. Any use which would cause sunlight to be reflected towards an aircraft engaged in an initial straight or circling climb following takeoff or towards an aircraft engaged in a straight or circling final approach towards a landing at an airport.
c. Any use which would generate smoke or water vapor or which would attract large concentrations of birds, or which may otherwise affect safe air navigation within the area. (Such uses include landscaping utilizing water features, aquaculture, production of c ereal grains, sunflower, and row crops, composting operations, wastewater management facilities, artificial marshes, trash transfer stations that are open on one or more sides, recycling centers containing putrescible wastes, construction and demolition debris facilities, fly ash disposal, and incinerators.) d. Any use which would generate electrical interference that may be detrimental to the operation of aircraft and/or aircraft instrumentation. e. Highly noise-sensitive outdoor nonresidential uses. Examples of noise - sensitive outdoor nonresidential uses that are prohibited include, but are not limited to, major spectator-oriented sports stadiums, amphitheaters, concert halls and drive-in theaters.
f. Other Hazards to flight.
3. The “Notice of Airport in Vicinity” that was provided in the ALUC Staff Report for the Project shall be provided to all prospective purchasers and occupants of the property and be recorded as a deed notice.
4. Any proposed stormwater basins or facilities shall be designed and maintained to provide for a maximum 48-hour detention period following the design storm, and remain totally dry between rainfalls. Vegetation in and around the basins that would provide food or cover for birds would be incompatible with airport operations and shall not be utilized in project landscaping. Trees shall be spaced so as to prevent large expanses of contiguous canopy, when mature. Landscaping in and around the basin(s) shall not include trees or shrubs that produce seeds, fruits, or berries.
Landscaping in the detention basin, if not rip-rap, should be in accordance with the guidance provided in ALUC “LANDSCAPING NEAR AIRPORTS” brochure, and the “AIRPORTS, WILDLIFE AND STORMWATER MANAGEMENT” brochure available at RCALUC.ORG City of Riverside
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which list acceptable plants from Riverside County Landscaping Guide or other alternative landscaping as may be recommended by a qualified wildlife hazard biologist.
A notice sign, in a form similar to that attached hereto, shall be permanently affixed to the stormwater basin with the following language: “There is an airport nearby. This stormwater basin is designed to hold stormwater for only 48 hours and not attract birds. Proper maintenance is necessary to avoid bird strikes”. The sign will also include the name, telephone number or other contact information of the person or entity responsible to monitor the stormwater basin.
5. March Air Reserve Base must be notified of any land use having an electromagnetic radiation component to assess whether a potential conflict with Air Base radio communications could result. Sources of electromagnetic radiation include radio wave transmissi on in conjunction with remote equipment inclusive of irrigation controllers, access gates, etc.
6. The project has been evaluated to construct a multi-family development consisting of 347 multi-family residential units, pool area, leasing office, club area, and fitness center. Any increase in building area, change in use to any higher intensity use, change in building location, or modification of the tentative parcel map lot lines and areas will require an amended review to evaluate consistency with the ALUCP compatibility criteria, at the discretion of the ALUC Director.
7. All solar arrays installed on the project site shall consist of photovoltaic solar panels that are consistent with the specifications described in the glare study, which projects 44,049 minutes of solar glare annually based on the proposed Project. Any deviation that exceeds 20 percent of the annual daylight minutes should be analyzed in an updated solar glare study which shall be submitted to ALUC. If the updated solar glare study results in a) more than 20 percent of annual solar glare minutes, b) any glare impacting the air traffic control tower, or c) creation of any “yellow” or “red” level glare in the flight paths, then the amended project shall require a new hearing by the Airport Land Use Commission.
8. In the event that any glint, glare, or flash affecting the safety of air navigation occurs as a result of project operation, upon notification to the airport operator of an event, the airport operator shall notify the project operator in writing. Within 30 days of written notice, the project operator shall be required to promptly take all measures necessary to eliminate such glint, glare, or flash. An “event” includes any situation that results in an accident, incident, “near -miss,” or specific safety complaint regarding an in-flight experience to the airport operator or to federal, state, or county authorities responsible for the safety of air navigatio n. The project operator shall work with the airport operator to prevent recurrence of the incidence. Suggested measures may include, but are not limited to, changing the orientation and/or tilt of the source, covering the source at the time of day when events of glare occur, or wholly removing the source to diminish or eliminate the source of the glint, glare, or flash. For each such event made known to the project operator, the necessary remediation shall only be considered to have been fulfilled when the airport operator states in writing that the situation has been remediated to the airport operator’s satisfaction.
9. In the event that any electrical interference affecting the safety of air navigation occurs as a result of project operation, upon notification to the airport operator of an event, the airport City of Riverside
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operator shall notify the project operator in writing. Within 30 days of written notice, the project operator shall be required to promptly take all measures necessary to eliminate such interference. An “event” includes any situation that results in an accident, incident, “near - miss,” report by airport personnel, or specific safety complaint to the airport operator or to federal, state, or county authorities responsible for the safety of air navigation. The project operator shall work with the airport operator to prevent recurrence of the event. For each such event made known to the project operator, the necessary remediation shall only be considered to have been fulfilled when the airport operator states in writing that the situation has been remediated to the airport operator’s satisfaction.
Riverside Municipal Code
Title 7 – Noise Control
The Project will meet the applicable requirements of the Noise Code. See Section 5.9 Noise for more information on compliance with Title 7.
Title 16 – Buildings and Construction
The purpose of Title 16 is to provide minimum standards to safeguard public health, safety and general welfare by regulating the design, construction, quality of materials, use and occupancy, location and maintenance of buildings, equipment, structures and grading within City; the electrical, plumbing, heating, comfort cooling and certain other equipment specifically regulated by the City. The Project has been reviewed by the City’s Departments and has been found consistent with Title 16.
As outlined in Sections 5.2, 5.5, and 5.7, the Project will meet or exceed all applicable standards under California’s Green Building Code Title 24 Standards. As outlined in Section 5.13, the Project is required to and will include automatic fire sprinkler systems. Construction plans are required to be submitted and permitted prior to construction. Fire Department access shall be maintained during all phases of construction. All required public and private fire hydrants will be in service and fire flow available prior to building permit issuance by the City. The Project will meet the applicable requirements of the Building Code.
Title 17 – Grading Code
Grading of the Project is regulated by Title 17, which sets forth rules and regulations to control erosion, grading, and earthwork construction, including fills and embankments. The purpose of the Grading Code is to regulate grading in a manner that minimizes the adverse effects on natural landforms, soil erosion, dust control water runoff, and construction equipment emissions. The Project will meet the applicable requirements of the Grading Code.
Title 19 – Zoning Code
The Zoning Code Amendment request would change the on- site zoning designation from CR – Commercial Retail – to MU-U – Mixed-use Urban. Mixed Use- Urban zoning has been selected for this site to bring together medium - to high- density residential and retail development in a City of Riverside
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mixed-use environment. The Mixed Use-Urban zone will allow the proposed apartment project to be introduced into the existing retail environment and will create a framework for integration of uses with features such as pedestrian connectivi ty, walkability, and shared elements including parking. The existing and proposed zoning are shown in Figure 3.0 -5 Zoning. The proposed Project is consistent with the development standards of the proposed zone.
Title 20 – Cultural Resources
See Section 5.4 Cultural Resources and Section 5.11 Tribal Cultural Resources for information on compliance with Title 20.
Consistency Conclusion
The Project will be consistent with the RMC, Titles 7, 16, 17, 19, and 20, the Mission Grove Specific Plan and General Plan 2025 land use designation and Housing Element. The Project would be consistent with all applicable GP 2025 objectives and policies except for be consistent with all applicable GP 2025 objectives and policies except for be consistent with all applicable GP 2025 objectives and policies except for Policies CCM-11.1, LU-22.3, LU-22.5, and LU-69.1 related to the MARB/IPA LUCP, in which the Project would be partially consistent and partially inconsistent. As the Project’s projected density would exceed the MARB/IPA LUCP Zone C2 residential density criteria of 6.0 dwelling units per acre and thus would also be partially inconsistent with Policies CCM -11.1, LU-22.3, LU-22.5, and LU- 69.1 related to the MARB/IPA LUCP. (DEIR, p. 5.11-10 - 5.11-64)
TRANSPORTATION
Project’s Effect on VMT
Threshold B: Would the Project conflict with or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)?
Finding: Significant and unavoidable. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measure or project alternatives identified in the EIR. (State CEQA Guidelines, section 15091(a)(3).) The proposed P roject’s VMT per capita is higher than jurisdictional threshold or 85% of baseline or cumulative jurisdictional VMT per capita. (DEIR 5.17- 13 - 5.17-21)
Explanation: The City’s guidelines provide guidance regarding VMT analysis based on land use types. The Project would consist of a multifamily development, which falls under the “residential land use project” category. Thus, pursuant to the City’s VMT analysis guidelines for “residential projects,” a significant VMT impact would occur according to the following criteria:
• The Project would result in a significant project -generated VMT impact if the baseline or cumulative project-generated VMT per capita exceeds 15% below the current jurisdictional baseline VMT per capita.
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• The Project’s effect on VMT would be considered significant if the baseline or cumulative link-level boundary VMT per capita (City) were to increase under the with project condition compared to the no project condition.
The most recent version of the regional travel demand model, the Riverside County Transportation Model version 3.0 (RIVCOM 3), was used to estimate the Project and jurisdictional VMT per capita. Both baseline (2018) and cumulative (2045) scenarios were analyzed to estimate project generated VMT and the project’s effect on VMT, as recommended in the City’s guidelines.
The baseline year of 2018 was used as it was the readily available information at the time the VMT analysis was initiated. The K- Mart retail store was still open and in operation at that time, closing its doors in October 2020.
Outputs from the above-mentioned model runs (with proposed land use changes) were used to develop project generated VMT and the project’s effect on VMT for both baseline and cumulative scenarios. No project model runs were also conducted for baseline and cumulative scenarios, and outputs from the no project model runs were used to estimate jurisdictional (City) specific thresholds. As shown in Table 5.17-1, Regional and Project VMT Per Capita, the Project VMT per capita is higher than jurisdictional threshold or 85% of baseline or cumulative jurisdictional VMT per capita. Therefore, the proposed Project would result in a significant impact for project generated VMT. (DEIR 5.17-13 - 5.17-21)
Table 5.17-1: Regional and Project VMT Per Capita
2018
Mission Grove Apts.
(Project)
City of Riverside Threshold
(85% of baseline)*
Difference
% Difference
VMT per capita 24.8 13.9 10.9 78.7%
2045
Mission Grove Apts.
(Project)
City of Riverside Threshold
(85% of baseline)*
Difference
% Difference
VMT per capita 22.9 13.6 9.3 68.1%
The link-level jurisdictional boundary VMT was compared for With and Without Project Conditions for both baseline and cumulative scenarios. As shown in Table 5.17-2, Proposed Project’s Effect on VMT – City of Riverside, the link-level boundary VMT is higher under With Project Conditions compared to Without Project Conditions in the cumulative scenario.
Therefore, pursuant to the criteria contained in the City’s VMT analysis guidelines, the proposed Project’s effect on VMT would be considered significant. (DEIR, p. 5.17-13 - 5.17-21)
Table 5.17-2: Proposed Project’s Effect on VMT – City of Riverside Roadway VMT within City of
Riverside
With Project
Without Project
Difference
2018 7,501,672 7,503,620 (1,948)
2045 8,766,524 8,762,685 3,839
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When a lead agency identifies a significant CEQA impact, the agency must identify feasible mitigation measures in order to avoid or substantially reduce that impact. The City’s TIA Guidelines state that to mitigate VMT impacts, the following may be considered for implementation:
• Modify the project’s built environment characteristics to reduce VMT generated by the project. (See 5.17.3 Project Design Considerations above) • Participate in a VMT fee program and/or a VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels.
At this time a VMT fee program and/or a VMT mitigation exchange/banking program do not exist within the City. Therefore, the P roject would not be subject to any VMT fees as part of a VMT fee program and/or a VMT mitigation exchange/bank. • Implement Transportation Demand Management (TDM) measures to reduce VMT generated by the Project.
The City’s TIA Guidelines identify a WRCOG study that lists appropriate TDM measures for the region. There are seven measures identified in the WRCOG guidance that are identified as likely to be effective in a rural or suburban setting, such as the WRCOG area. The measures include both modifications to the project’s built environment and TDM measures and are taken from Quantifying Greenhouse Gas Mitigation Measures. It should be noted that Quantifying Greenhouse Gas Mitigation Measures has been updated as of December 2021. Some of the measures identified in the 2010 California Air Pollution Control Officers Association (CAPCOA) guidance have been removed or reclassified in the updated 2021 CAPCOA guidance. In order to maintain consistency with the City’s TIA Guidelines, the mitigation strategies discussed below are taken from the WRCOG and 2010 CAPCOA documents. However, the calculation methodology from the 2021 CAPCOA guidance was used to determine the effectiveness of the mitigation measures that are determined to be feasible. The following strategies were considered for mitigation of proposed Project VMT impacts:
1. Increase Diversity of Land Uses (LUT- 3). This measure recognizes that VMT can be reduced by including different types of land uses within or near a development, since trips between land use types are shorter and may be accommodated by non-automotive modes of transportation. For example, when residential areas are proximate to employment uses, then a resident could make the commute trip via walking or bicycling. The need for external trips in a mixed-use development can be reduced by including services and facilities such as day care, banking/ATM, restaurants, vehicle refueling, and shopping. The Project proposes construction of 347 multifamily residential units, which by itself does not include a mix of land uses within the proposed Project site. However, the proposed Project is an infill development that would be located within an existing shopping center that currently includes restaurants, a day care center, movie theater, drug/grocery stores, banking/ATM, gas stations, and other commercial uses. The proposed Project would include the creation of paved sidewalks and marked crosswalks within the Project site that would serve as City of Riverside
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resident paths of travel. These resident paths of travel within the Project site would connect to existing public pedestrian paths of travel, such as existing sidewalks along Mission Grove Parkway South and Mission Village Drive (see Figure 5.17-1), which would provide walkable and bikeable access to surrounding shopping center uses. Therefore, the proposed Project location increases the potential for people to walk and bike to surrounding retail and commercial uses and thereby aids in promoting connectivit y to these nearby destinations. According to the WRCOG guidance, this TDM measure could provide a maximum reduction of 4 percent. However, this measure is not included in the 2021 CAPCOA guidance; as noted, these mitigation strategies are taken from the WRCOG and 2010 CAPCOA documents. However, the calculation methodology from the 2021 CAPCOA guidance was used to determine the effectiveness of the mitigation measures. As this LUT- 3 measure is not included in the 2021 CAPCOA guidance, the measure’s level of effectiveness was determined based on the level of effectiveness of a similar measure, T 31-A Locate Project in Area with High Destination Accessibility, which is included in the 2021 guidance. The T 31-A measure is noted as a “Supporting or Non- Quantified GHG Reduction Measure” in the 2021 CAPCOA guidance, meaning that it would be a complementary measure and could increase the effectiveness of other measures, but would not result in a quantifiable reduction in GHG or VMT by itself.
2. Provide Pedestrian Network Improvements (SDT- 1). Creating a connected pedestrian network with the development and connecting to nearby destinations could encourage walking for local trips. This leads to a reduction in VMT due to a mode shift from driving to walking for shorter trips (typically less than ¼ mile and no greater than ½ mile). This measure is also included in the 2021 CAPCOA guidance as Measure T- 18, Provide Pedestrian Network Improvement, and was used to estimate the VMT reduction due to Project related enhancements in pedestrian access and connectivity. The CAPCOA methodology requires existing sidewalks in the project study area in addition to the sidewalks being provided by the project. As the proposed Project is infill development, infrastructure already exists in the area and this strategy can be implemented. As previously discussed, the proposed Project would include the creation of paved sidewalks and marked crosswalks within the Project site that would serve as resident paths of travel.
These resident paths of travel within the Project site would connect to existing public pedestrian paths of travel, such as the existing sidewalks along Mission Grove Parkway and Mission Village Drive (see Figure 5.17-1), which would provide walkable access and connectivity to the existing retail and commercial shopping center. As discussed in the Project’s VMT Analysis (LSA April 2023), the Project would add approximately another
0.57 mile of sidewalk/pedestrian access to the existing pedestrian network in the area.
This may reduce the Project’s VMT by approximately 0.14%.
3. Provide Traffic Calming Measures (SDT-2). This measure would encourage walking and bicycling instead of using a vehicle through the implementation of traffic calming measures. Traffic calming would reduce motor vehicle speeds through features such as City of Riverside
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marked crosswalks, raised intersections, median islands, tight corner radii, roundabouts or mini -circles, count -down signal timers, curb extensions, speed tables, raised crosswalks, on -street parking, planter strips with street trees, chicanes/chokers, and similar improvements. This measure is also in the 2021 CAPCOA guidance as Measure T-35 – Provide Traffic Calming Measures, which requires projects to include pedestrian/bicycle safety and traffic calming measures above jurisdictional requirements.
Measure T-35 similarly notes that traffic calming features may include marked crosswalks, count-down signal timers, curb extensions, speed tables, raised crosswalks, raised intersections, median islands, tight corner radii, roundabouts or mini -circles, on -street parking, planter strips with street trees, chicanes/chokers, and others. Although the 2010 guidance notes a potential decrease in VMT of up to 1%, the 2021 guidance includes traffic calming as a supporting, non-quantified measure.
4. Implement Car-Sharing Program (TRT-9). A car-sharing program would allow residents to have on-demand access to a shared fleet of vehicles on an as -needed basis. Costs are typically paid by the user via an annual membership or on a per -use basis. This method is applicable to the proposed Project because car -sharing programs could be more effective when implemented in high-density residential areas. The maximum reduction in VMT that could be achieved by a car - sharing program in the WRCOG region is 1.6 percent. This measure is included in the 2021 Guidance as Measure T-21-A – Implement Conventional Carshare Program. The 2021 CAPCOA description of this measure states that carsharing offers people convenient access to a vehicle for personal or commuting purposes, which helps encourage transportation alternatives and reduces vehicle ownership, thereby avoiding VMT and associated GHG emissions. However, according to the 2021 update, the maximum reduction in VMT is reduced to 0.15%. The Project doesn’t propose implementing a car -sharing program and as such, no VMT reduction has been estimated.
5. Increase Transit Service Frequency/Speed (TST -4). This measure is achieved through the addition of additional busses along an existing bus route, the addition of additional routes, or by adding rapid/express bus service that would provide service to activity areas with fewer local stops. This measure is included in the 2021 CAPCOA guidance as Measure T-26 – Increase Transit Service Frequency. The 2021 CAPCOA description of this measure states that increased transit frequency reduces waiting and overall travel times, which improves the user experience, increases the attractiveness of transit service, and thereby results in a mode shift from single occupancy vehicles to transit, which reduces VMT and associated GHG emissions.
Implementation of this measure would be by the local transit authority with funding from local developments. This measure is not as applicable to a single development, but would be achieved through multiple funding sources, including development fees. According to the 2021 CAPCOA guidance a maximum VMT reduction of 11.3% can be achieved.
However, the maximum achievable VMT reduction in the WRCOG area from this measure City of Riverside
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is 6.3%. As indicated in CAPCOA, this measure is not applicable to single development projects and as such no VMT reduction has been estimated for this measure.
6. Encourage Telecommuting and Alternative Work Schedules (TRT-6). This measure would encourage employers to allow employees to work from home or work a flexible schedule or compressed work week, thereby reducing the number of days that residents would commute to their workplace. This measure is commonly implemented by employers as part of a commute trip reduction program, so it is not applicable for the proposed residential Project. The maximum achievable reduction in VMT in the WRCOG region due to telecommuting and alternative work schedules is 4.5%. It should be noted that this measure is included in the 2021 CAPCOA guidance as Measure T -42 – Implement Telecommute and/or Alternative Work Schedule Program. The 2021 CAPCOA description of this measure states that while this measure would reduce commute- related VMT, research has shown that total VMT from telecommuters can exceed VMT from non - telecommuters (CAPCOA, 2021). The 2021 CAPCOA guidance recommends that the latest literature be reviewed before implementing a telecommute program for VMT reduction.
7. Provide Ride-Sharing Programs (TRT-3). A ride-sharing program would increase vehicle occupancy by matching commuters with others who live and work within close proximity to one another. This strategy is generally implemented by employers through a Transportation Management Association or on a regionwide basis through a regional ride- share matching program. The maximum achievable VMT reduction from ridesharing programs in the WRCOG region is 8.3%. This measure is also included in the 2021 CAPCOA guidance as Measure T- 8 – Provide Ridesharing Program, which would encourage carpooled vehicle trips in place of single- occupied vehicle trips, thereby reducing the number of trips, VMT, and GHG emissions. According to the latest guidance, the maximum VMT reduction from ride -sharing programs is 8%. The Project does not propose to implement ride sharing program; therefore, no VMT reduction has been estimated for this measure. In addition to these 7 TDMs from WRCOG, applicable measures from CAPCOA and measures recommended by the City were used to analyze and estimate VMT reductions that could be achieved through additional TDMs. In addition to these 7 TDMs from WRCOG, applicable measures from CAPCOA and measures recommended by the City were used to analyze and estimate VMT reductions that could be achieved through additional TDMs.
8. Provide EV Parking and EV Charging Infrastructure. The latest California Green Building Standards (CALGreen), California Building Code, requires the provision of electric vehicle infrastructure for new construction projects such as apartments, condos, hotels, and motels. While it is understood that the provision of electric charging stations might not reduce VMT, it would reduce GHG, which can be considered equivalent to a reduction in VMT. CALGreen code requires apartments to provide EV charging stations for 5% of the City of Riverside
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total project parking with an additional 35% that would be EV capable and EV ready. The Project proposes to include a total of 604 parking spaces and would therefore be required to provide a minimum of 26 electric charging stations and another 180 EV capable and EV ready spaces per CALGreen code. Additional electric charging stations, in addition to CALGreen requirements, can be considered as a GHG/VMT mitigation measure according to CAPCOA. In order to achieve maximum GHG reduction, and therefore VMT reduction, it was estimated that an additional 15 electric charging stations would achieve
11.9% reduction in GHG/VMT, the maximum allowable reduction for the measure.
Therefore, as a Project Design Consideration, the Project proposes to provide a total of a total of 41 electric charging stations (26 CALGreen requirement + 15 additional).
9. Unbundle Residential Parking Costs from Property Cost. According to CAPCOA, increasing the cost of owning a vehicle will decrease or discourage vehicle ownership and therefore reduce VMT and GHG. CAPCOA transportation Measure T -16, Unbundle Residential Parking Costs from Property Cost, was used to estimate the amount of VMT reduction that can be achieved by charging for additional parking stalls. The Project proposes to provide 1 parking stall to every apartment unit within the rental unit fee (no additional charge) and charge $75 per month for any and each additional parking spaces, which may reduce Project VMT by up to 3.9%.
10. Implement Subsidized or Discounted Transit Program (TRT-4). A bus pass program would generally be implemented as part of an employer commute trip reduction program.
However, implementation of a bus pass subsidy for a multi-family residential development could be implemented by the leasing office/property management. At the City’s request, a transit pass subsidy program to mitigate the proposed Project’s VMT impact was evaluated. Riverside Transit Routes 20 and 22 serve the proposed Project site with a stop at the corner of Mission Village Drive and Mission Grove Parkway South. Because the site is served by transit, a subsidized or discounted transit program could be effective in reducing project VMT. To encourage the use of public transit and reduce the VMT per capita of the project, the proposed Project would implement a subsidized transit pass program. The Project Applicant would establish an account and deposit the amount of $136,000 over a 10- year period, to be administered by the apartment property owner through the leasing office/property management to provide free or reduced cost transit passes to Project residents. The program would provide up to $60 for an RTA monthly bus pass or up to $100 for a Metrolink monthly pass to residents who request transit reimbursement from the leasing office/property management on a first-come, first-served basis until the available funds are depleted for that year. Residents who participate in the subsidized transit pass program would also be eligible to receive reimbursement for use of a ride sharing service (i.e., Uber or Lyft) for an emergency ride home.
The leasing office/property management shall provide an annual report of the transit pass program that includes the number of reimbursement requests, the amount disbursed to City of Riverside
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residents, and the remaining amount, if any, in the transit pass account at the end of each year. Any funds remaining in the account at the end of the year would roll over into the next year’s account and funds available for the program. If the City deems the program experiences low participation, (more than 25% of the funds each year are not utilized and remain in the account), the City shall have the discretion to implement another measure intended to reduce vehicle miles traveled by project residents. Such measures could include, but are not limited to, offsite or onsite pedestrian, bicycle, or public transit improvements, funding toward a bikeshare station on or near the site, implementation of further traffic calming measures, or other feasible and implementable TDMs. The measure is included in the 2021 CAPCOA guidance as T-9 and indicates that up to a 5.5% reduction in VMT can be achieved. The maximum VMT reduction for the proposed Project from implementing a transit pass subsidy program is approximately 2.55%.
11. Implement Commute Trip Reduction Marketing (2010 Guidance TRT -7, 2021 Guidance T-7). This measure would implement a marketing strategy intended to reduce commute trips through promotion of an employer’s commute trip reduction program (CTR). CTR marketing would educate employees (or residents) about their travel choices beyond driving, such as carpooling, transit, walking and bicycling. A CTR Marketing program is generally implemented by an employer and could result in a reduction in VMT of up to 4%.
There is no guidance for calculating the benefit when implemented by a residential project, therefore this measure would be considered a supportive measure to other resident-based programs, such as the subsidized/discounted transit program. The Project doesn’t propose implementation of a CTR marketing program and therefore no VMT mitigation was estimated for the proposed Project.
12. Implement a School Pool Program (2010 Guidance TRT- 10, 2021 Guidance T-41). This measure is not included in the WRCOG guidance but was included at the request of the City. A School Pool program would entail creating a ridesharing program for school children and is generally implemented on a District-wide basis. Implementation of a school pool by an individual development project would not be effective due to the limited number of potential school students utilizing the program. According to the 2021 CAPCOA guidance, school pool program would help match parents to transport students to private schools or to schools where students cannot walk or bike and do not meet the requirements for bussing. While implementation of a School Pool Program has the potential to reduce VMT for residential projects, the 2021 CAPCOA guidance indicates School Pool programs as a supporting measure and does not provide a method for calculating the reduction in VMT for School Pool programs. The Project doesn’t propose implementation of a school pool program and therefore no VMT mitigation was estimated for the proposed Project.
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Table 5.17- 3, Potential VMT Reduction Strategies, summarizes the VMT reduction strategies considered for the proposed Project, the maximum VMT reduction achievable for each strategy, and the feasibility of each for the proposed Project.
Additionally, as discussed in Section 5.17.3, the Project would include the following project design considerations that could result in additional reductions to Project-generated VMT:
Parcel Lockers. A parcel locker system that includes 75 package lockers would be implemented at the property as a Project Design Consideration. At least one (1) parking space near the parcel lockers will be designated for delivery vehicles during normal business hours. (see Section 5.17.3 above). The presence of locker system could potentially help reduce VMT by reducing the amount of driving by delivery trucks; delivery of parcels to a single known location would help reduce delivery truck trips within the development. Additionally, the presence of a secure locker system could minimize the types of deliveries where the recipient should be present to receive the mail/shipment. While this Project Design Consideration has the potential to reduce proposed Project VMT, no quantification methodology is available and therefore, no VMT reductions are calculated as a conservative approach.
Bike Racks. As discussed, the Project would include 32 short-term bicycle racks and 35 long-term bicycle racks at the Project site. CAPCOA includes mitigation measure T-10 - Provide End-of-Trip Bicycle Facilities, which quantifies the VMT reduction due to inclusion of bicycle facilities.
CAPCOA includes this measure for employment related land uses. While employment related uses will mainly reduce commuter VMT, the provision of bicycle facilities may have the potential to reduce VMT irrespective of destination land use. The provision of bike racks as part of the Project would provide residents the incentive to use bikes for local travel, such as to surrounding retail and commercial uses, rather than vehicles, thereby resulting in some reduction in the proposed Project’s VMT. As this measure is applicable only to employment related uses, no quantification of VMT reduction for this Project Design Consideration was considered as a conservative approach.
Table 5.17-3: Potential VMT Reduction Strategies
VMT Reduction Strategy aximum Achievable VMT
Reduction
Feasible for
the Project?
Land Use/Location Strategies (Maximum Reduction 65%)1
Increase Diversity of Land Uses 0%, Supportive Measure No Neighborhood Site Enhancements (Maximum Reduction 10%)2 Provide Pedestrian Network Improvements 0.14% Yes
Provide Traffic Calming Measures 0%, Supportive Measure No Implement Car-Sharing Program 1.6% No
Transit System (Maximum Reduction 15%)2
Increase Transit Service Frequency/Speed 6.3% No
Implement Subsidized or Discounted
Transit Program
2.6% Yes
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Commute Trip Reduction (Maximum Reduction 45%)1
Encourage Telecommuting and Alternative
Work Schedules
4.5% No
Provide Ride-Sharing Programs 8.3% No
Implement Commute Trip Reduction Marketing 0%, Supportive Measure No Implement a School Pool Program 0%, Supportive Measure No Parking or Road Pricing/ Management (Maximum Reduction 35%)1 Provide Electric Vehicle (EV) Parking and EV
Charging Infrastructure (41 electric charging
stations)
11.9%
Yes
Unbundle Residential Parking Costs from
Property Cost
3.9% Yes
Total VMT Reduction from All Subsectors
(Assumes Maximum Reduction where
Calculated Reduction is Greater)3
17.7%
Source: Handbook for Analyzing Greenhouse Gas Emission Reduction, Assessing Climate Vulnerabilities, and Advancing Health and Equity, California Air Pollution Control Officers Association (CAPCOA), December 2021. 1 Maximum Reduction per Sector for the Project/site level from CAPCOA 2021. 2 Maximum Reduction per Sector for the plan/community level from CAPCOA 2021. 3 Per CAPCOA, total VMT reduction for multiple strategies within same subsector is calculated using the equation:
1-(1-A)*(1-B)*(1-C)… where A, B, C are equal to individual mitigation strategy reduction percentages. This equation is applied to measures within a sector as well as the totals across all sectors. When applied to the Project, the calculation would be:
1-(1-0.0014)*(1-0.026)*(1-0.039) = 0.1765, or 17.7 percent
As shown in Table 5.17-1 – Regional and Project VMT Per Capita, the Project’s calculated VMT per capita for baseline year 2018 is 24.8. A 17.7 percent reduction to the Project’s baseline VMT per capita results in a reduced Project VMT of 20.4
1. As previously discussed, a project would
result in a significant project -generated VMT impact if the baseline or cumulative project - generated VMT per capita exceeds 15 percent below the current jurisdictional baseline VMT per capita. Table 5.17- 1 indicates that 85 percent of the jurisdictional baseline VMT per capita for future year 2045 is 13.6. Thus, even with the assumed maximum 17.7 percent VMT reduction as a result of implementing Project -applicable VMT reduction strategies, the Project’s baseline per capita VMT would still exceed 15 percent below the 2045 jurisdictional baseline VMT per capita, resulting in a significant project-generated VMT impact.
In conclusion, while the previously discussed TDM measures may help offset some of the VMT impacts of the proposed Project by up to 17.7 percent, these measures would not reduce the Project-generated VMT impact to a less than significant level. (DEIR, p. 5.17-14 - 5.17-21).
FINDINGS REGARDING CUMULATIVE IMPACTS
Consistent with CEQA’s requirements, the EIR includes an analysis of cumulative impacts, which include the impacts of the proposed Project plus all other pending or approved projects within the affected area for each resource. Where evaluation of potential cumulative impacts are located (e.g., noise, traffic, visual quality, biological, cultural resources, and public utilities) the analysis is City of Riverside
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based on a list of past, present, and probable future projects producing related or cumulative impacts. Currently planned and pending projects in Riverside and surrounding areas, including in the City of Moreno Valley and County of Riverside are included i n Table 4.0-1 and shown on Figure 4.0 -1 of the DEIR. Cumulative projects in the vicinity of this proposed Project include residential (single- family and multifamily), warehouse, commercial, hotel, office and industrial developments. (DEIR p. 4.0-1 – 4.0-3)
Regarding the Project’s potential to result in cumulative impacts, the City hereby finds as follows:
1. Aesthetics
Cumulative developments in the City and the surrounding area would modify the visual characteristic of the surrounding area through the development of vacant lots or through redevelopment. The planned and pending projects in the Project vicinity, listed in Table 4.0-1 include about 6 projects including residential, commercial, and distribution warehouse developments, as well as the County of Riverside’s Meridian Specific Plan – West Campus Upper Plateau Project, which includes warehouses for high-cube fulfillment and cold storage, business park office, warehouse, and mixed- use buildings, retail, and parks (active and public). The cumulative projects range in distance from the Project site, from the closest project approximately 800 feet north, across Alessandro Boulevard, to approximately 1 mile southwest of the Project site, approximately 1.2 miles southeast of the site, to the farthest project site, approximately 1.75 miles east, on Alessandro Boulevard (refer to Figure 4.0-1 – Cumulative Project Locations).
Only the closest cumulative project, which is a commercial vehicle wash facility, located approximately 800 feet north, across Alessandro Boulevard, would have the potential to result in cumulative aesthetic impact on a scenic vista or degrade the existing visual character of the Project site as they are close enough to be viewed at the same time by individuals in the Project area. As outlined above, the proposed Project would not result in a substantial adverse effect on a scenic vista, and therefore, it would not cumulatively contribute to an adverse effect on a scenic vista.
Each of the proposed developments would change the existing visual character of the area in which they are located. Each project located within the City would go through a design review of site design and building elevations and for consistency with the Citywide Design Guidelines and Sign Guidelines, and the Meridian Specific Plan – West Campus Upper Plateau Project would go through design review with the March Joint Powers Authority for site design and building elevations and consistency with development s tandards of the March Joint Powers Authority General Plan Land Use Element (March JPA GP).Design review is anticipated to ensure the projects would have architecture and design elements that are aesthetically coherent and compatible and complimentary with the existing surrounding built environment in terms of colors, materials and landscaping, and thus, would not result in adverse aesthetic impacts to the visual character in the City or adjacent unincorporated Riverside County. Furthermore, the lighting elements have no plans to increase lumens nor the elevation of the proposed structures to City of Riverside
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increase and impede visual elements. All projects within the MARB/IPA LUCP Zone C or higher that proposes solar panels would be required to provide a solar glare study, for review and approval by Riverside County ALUC staff. As each project would be requir ed to ensure it would not result in solar glare impacts, they would not be expected to result in cumulative glare impacts.
Thus, cumulatively the Project does not have a substantial adverse effect on a scenic vista or resource, substantially degrade the existing visual character of the area, or create a substantial new source of light or glare, when considered with other cumulative projects. Similar to the Project, visual quality impacts associated with other cumulative projects would be addressed on a case-by-case basis in order to determine their consistency with applicable plans and policies.
Potential cumulative aesthetics impacts are less than significant. (DEIR, p. 5.1-23, -24)
2. Agriculture and Forestry Resources
As discussed in Chapter 4 Environmental Setting of this DEIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, commercial, office, mixed-use and public facilities (parks). However, as there are no impacts to agriculture or forestry resources, and therefore there are also no cumulative environmental impacts from Project implementation to agriculture or forestry resources. (DEIR, p. 5.2-4)
3. Air Quality
As discussed in Chapter 4 Environmental Setting of this DEIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, commercial, office, mixed-use and public facilities (parks). The Project area is designated as a non‐attainment area for ozone and PM2.5, and PM10.
The SCAQMD recommends that project-specific air quality impacts be used to determine whether a project’s emissions are cumulatively considerable. As discussed in Section 5.3.5, the Project - specific evaluation of emissions demonstrates that Project construction -source air pollutant emissions and Project operational-source emissions would not result in exceedances of criteria pollutant regional thresholds established by SCAQMD for any criteria pollutant. Accordingly, the Project would also not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is nonattainment, and impacts would be less than significant, and no mitigation is required. Thus, cumulative impacts would be less than significant. (DEIR, p. 5.3-29)
4. Biological Resources
This cumulative impact analysis considers development of the Project in conjunction with other development projects in the geographic area based on a summary of projections approach resulting from full General Plan buildout in the City.
The Project would not contribute to or cause significant cumulative impacts to biological resources. The Project includes the development of apartments within an already developed commercial shopping center, located in a highly urbanized portion of the Cit y. The Project site does not contain any sensitive habitat, nor is the site suitable to support any sensitive or special- City of Riverside
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status wildlife and plant species. The Project site would utilize the developed infrastructure of the commercial shopping center and would not require construction or development within areas containing sensitive biological resources. Therefore, cumulative impacts to biological resources as a result of the Project would be less than significant (5.4-13).
5. Cultural Resources
The Project, in conjunction with other planned and pending projects in the Project vicinity, would cumulatively increase the potential to encounter sensitive cultural and archaeological resources.
There would be cumulatively considerable impacts to cultural resources if the project level impacts were significant for any of the cumulative projects. The planned and pending projects in the Project vicinity, listed in Table 4.0-1 include about 6 projects consisting of residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high- cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public).
In the event that cultural and/or archaeological resources are discovered, each individual project would be required to comply with the applicable regulatory requirements and mitigate any potential impacts to resources on the individual project site. Potential impacts of the Project would be reduced to a less than significant level due to implementation of mitigation measures MM CUL- 1 through MM CUL- 4 that would protect cultural and archaeological resources and state law, California Health and Safety Code Section 7050.5(b), that would protect human remains.
Compliance with CEQA requirements, including the implementation of recommendations provided in project-specific cultural resource studies, on all new development would ensure that, cumulative impacts to cultural resources would be less than significant with mitigation and would not be cumulatively considerable. (DEIR, p. 5.5-17)
6. Energy
As described, no mitigation measures have been proposed for the Project as the Project would not exceed energy thresholds of significance. Energy consumed by the Project is calculated to be comparable to, or less than, energy consumed by other residential, commercial, and recreational uses of similar scale and intensity that are constructed and operating in the State. Further, the energy demands of the Project can be accommodated within the context of available resources and energy delivery systems; thus, the Project would not cause or result in the need for additional energy producing or transmission facilities. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California and does not conflict with or obstruct applicable State or local plans for renewable energy or energy efficiency. Potential impacts to energy from the proposed Project would be less than significant and no mitigation is required.
As discussed in Chapter 4 Environmental Setting of this EIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, commercial, office, mixed-use and public facilities (parks). Each of the pr oposed developments City of Riverside
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would increase the consumption of energy and energy demand in the region. Energy consumption by the cumulative projects would be regulated by Energy Efficiency Standards embodied in Title 24 of the California Building Code, which apply to new construction of both residential and non - residential buildings, and indirect energy reduction measures from GHG reduction policies.
Therefore, the cumulative projects would not result in the wasteful use of energy.
The City of Riverside has a number of green power projects that would reduce overall energy consumption in the City. The City is funding various solar projects throughout the City that will reduce energy use from current users and from ongoing, cumulative projects in the City.
Additionally, RPU has a number of incentive programs for residences and businesses to reduce their electricity consumption which will result in cumulatively reducing GHG emissions from energy use.
Further, the cumulative projects in the area would consume a fraction of the energy supplies provided by RPU and have an insignificant demand on the State’s overall energy supply.
Therefore, RPU would have adequate supplies and the cumulative projects would not place a significant demand on the suppliers. Potential cumulative impacts would be less than significant. (DEIR, p. 5.6-17)
7. Geology and Soils
As discussed in Chapter 4 Environmental Setting of this DEIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, commercial, office, mixed-use and public facilities (parks). These planned and pending projects would increase structural development near the Project site, in turn exposing new residents and property to potential risks from seismic hazards or soil instability in the area. Like the Project, all new planned and pending development in the City and adjacent jurisdictions would be subject to current seismic and erosion control standards. Although new development would be exposed to existing geologic and seismic hazards, it would not increase the potential for such hazards to occur. Geologic hazards are site-specific, and individual developments would not create additive impacts that would affect geologic conditions on other sites. Therefore, development of individual projects would not exacerbate existing geologic conditions, and cumulative impacts would be less than significant.
Cumulative projects within the City have the potential to impact paleontological resources, the City’s General Plan and General Plan EIR incorporate policies and programs to protect and/or document these resources as part of the City’s development review p rocess and mitigation measures that require preparation of technical studies, and the presence of monitors if necessary.
Therefore, the General Plan EIR concluded that with adherence to and implementation of General Plan policies, mitigation measures, and standard Federal, State, and City regulations, cumulative impacts to historical resources, archaeological resources, and paleontological resources would be less than significant with mitigation. With implementation of mitigation measure MM GEO -1 City of Riverside
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the potential for the Project to contribute to a cumulative impact is reduced to less than significant levels with mitigation. (DEIR, p. 5.7-13)
8. Greenhouse Gasses
As discussed in Chapter 4 Environmental Setting of this DEIR, cumulative development in the City and surrounding cities and County would include residential development, warehouses, commercial, office, mixed use, and public facilities (parks). Each of the proposed developments would generate GHG emissions from vehicle trips, electrical and water use, and other sources.
The analysis of GHG emissions is cumulative in nature, as emissions affect the accumulation of GHGs in the earth’s atmosphere. Projects that fall below provided thres holds are considered to have a less than significant impact, both individually and cumulatively.
The City has a number of green power projects that would reduce overall GHG emissions in the City. The City is helping fund solar projects throughout the City that will reduce emissions from energy from current users and the cumulative projects in the City . The Riverside Public Utilities (RPU) has a number of incentive programs for residences and businesses to reduce their electricity consumption and cumulatively reduce GHG emissions from energy use.
As discussed, the Project would not exceed the SCAQMD/City’s screening threshold of 3,000 MTCO2e per year, nor would the Project conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions. Further, while some measures are not directly applicable, the Project will not conflict with any of the provisions of the 2022 Scoping Plan, the City RRG CAP, or RTP/SCS strategies, or conflict with their implementation; rather, the Project supports several of the action categories. Thus, the Project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions and potential impacts would be less than significant. Therefore, cumulative impacts would be less than significant. (DEIR, p. 5.8-41)
9. Hazards and Hazardous Materials
The geographic context for cumulative impacts relative to the use of hazardous materials is considered to be the City limits and the surrounding areas in which listed cumulative development projects are located. The planned and pending projects in the Project vicinity, listed in Table 4.0- 1 include about 6 projects consisting of residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high- cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public).
The Project, along with the cumulative development projects, may routinely transport, use, store, or dispose of hazardous materials and universal wastes. However, Riverside Municipal Code, Chapter 9.48 requires businesses to disclose storage and handling o f hazardous materials and hazardous waste, to establish and implement emergency response plans, and to cooperate in periodic reporting and inspections. Although the overall quantity of hazardous materials and waste City of Riverside
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generated in the City and the areas in which cumulative projects are located may increase as a result of implementation of the Project in combination with the cumulative development projects, all new development that will handle or use hazardous materials and all existing development that handles or uses hazardous materials are required to comply with the regulations, standards, and guidelines established by the USEPA, the State of California, County of Riverside, and the City of Riverside related to storage, use, and disposal of hazardous materials.
Because the Project would be in compliance with Federal, State, and local regulations, standards, and guidelines, the Project would have less than significant impacts related to hazardous materials and would not contribute to cumulatively considerable impacts. With respect to the cumulative development projects, each of these projects will also be required to evaluate their own project -specific potential impacts and will also be required to comply with all applicable Federal, State, and local regulations governing the use, handling, storage and transport of hazardous materials and other hazards. Since hazardous materials and risk of upset conditions are largely site-specific, this would occur for each individual project affected, in conjunction with development proposals on these properties, and develop project specific mitigation measures to reduce potential impacts to less than significant levels, and as such would not contribute to cumulatively considerable impacts either. In light of the existing regulatory framework governing the storage and use of hazardous materials and waste, the Project’s cumulative impact related to hazard and hazardous materials is less than significant, and the Project’s contribution is not considered cumulatively considerable. The refore, cumulative impacts with regard to hazardous materials are less than significant.
Airport Land Use Compatibility
Cumulative development projects that do not meet all criteria set forth in the applicable LUCP would be anticipated to contribute to a cumulative aviation hazard impact, and cumulative development projects within the Compatibility Zones that do not meet al l criteria set forth in the LUCP are subject to review by the Riverside County ALUC. ALUC may, as part of its review, impose height, use and lighting restrictions on development to reduce the potential impacts associated with aviation use the MARB/IPA from individual development projects to less than significant levels. Other cumulative projects (as listed in Table.4.0- 1) proposed within the MARB/IPA LUCP are anticipated to meet all criteria set forth in the LUCP and if not, these projects would be independently reviewed by ALUC and additional project design features or mitigation to ensure compliance with MARB/IPA LUCP policies would be imposed.
As previously discussed, the Project’s projected residential density of 35.0 dwelling units per acre would be inconsistent with the maximum allowable residential density of 6.0 dwelling units per acre for Compatibility Zone C2. Because the Project would not meet this single MARB/IPA LUCP density compatibility criterion, the Project would result in a significant and unavoidable impact with respect to airport land use compatibility. ALUC consistency is project -specific, and the other cumulative projects are anticipated to be consistent with ALUC Compatibility Zone criteria.
Therefore, although the proposed Project would be inconsistent with the residential density criteria City of Riverside
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for Compatibility Zone C2, as the other projects are not anticipated to have a significant impact, the proposed Project would not contribute to cumulatively considerable impacts. Therefore, cumulative impacts with regard to consistency with ALUC are less than significant.
Wildfire
The proposed Project site is not within a VHFHSZ. With compliance with applicable CBC and CFC standards and General Plan policies, implementation of the proposed Project, combined with other development in the City and County, would not result in increased exposure to wildfire risks. Furthermore, cumulative projects would not result in permanent road closures, nor impede an established emergency or evacuation access route, or interfere with emergency response requirements, such as fire protection response t ime standards established by GP 2025. The Project is surrounded by mostly urban development and served by existing infrastructure. It would not contribute incrementally with other projects in the City of Riverside and Riverside County to create an environment that could exacerbate wildfire risks. Cumulative wildfire impacts would be less than significant. (DEIR, p. 5.9-25, -27)
10. Hydrology and Water Quality
The cumulative impact area for hydrology and water quality impacts is the Santa Ana River watershed hydrologic unit. The City is located within the Santa Ana Region (Region 8) of the Regional Water Quality Control Board and Reach 3 of the Santa Ana River i s the ultimate receiving water body for runoff from the project site. As discussed in Chapter 4 Environmental Setting of this DEIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, commercial, office, mixed-use and public facilities (parks).
Cumulative impacts to water quality could be significant with the addition of substantial increases in development and temporary construction activities in the Santa Ana River watershed. These cumulative effects include increasing the amount of flow, sedimentation, and urban pollutants that are transmitted via storm flows to the Santa Ana River and its tributaries. The project, along with all of the cumulative development projects, are required to comply with current storm water requirements for construction-related activities and operation of the sites. Erosion and sediment control BMPs will be implemented during construction of the project in compliance with the NPDES General Permit for Construction Activities. After construction, the project would implement the permanent treatment systems identified in the WQMP. As noted in section 5.10.4 Project Design Considerations, the WQMP identifies site design, source control, and treatment control BMPs to be implemented as part of the proposed project. These include preserving existing vegetation and including landscaping and impervious surfaces to the greatest extent possible, maintaining the current drainage pattern of the site, and source and treatment control modular wetlands biofiltration systems. Therefore, the project construction and operation would not considerably contribute to a significant cumulative water quality impact.
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Because the project is not located within a groundwater recharge area, and will not result in the increase in the amount of impermeable surfaces within the watershed, there would be no cumulative impacts related to groundwater recharge.
The project site is not located within a flood hazard area or dam inundation zone; therefore, the project’s contribution to cumulative flood or dam inundation hazards is not cumulatively considerable. Therefore, cumulative impacts with regard to flood or dam inundation hazards are less than significant. (DEIR, p. 5.10-12, -13)
11. Land Use and Planning
The geographic context for cumulative impacts relative to the use of hazardous materials is considered to be the City limits and the surrounding areas in which listed cumulative development projects are located. The planned and pending projects in the Project vicinity, listed in Table 4.0- 1 include about 6 projects consisting of residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high- cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public).
Similar to the Project, land use regulations and policy consistency impacts associated with other cumulative projects would be addressed on a case- by-case basis in order to determine their consistency with applicable plans and policies. It is anticipated that most of the other cumulative projects, if not all of them, would be consistent with applicable GP 2025 policies. Therefore, although the proposed Project would be inconsistent with the Zone C2 residential density criteria and partially inconsistent with applicable GP 2025 Policies CCM-11.1, LU-22.3, LU-22.5, and LU-
69.1 related to the MARB/IPA LUCP, as the other cumulative projects are not anticipated to be inconsistent and have a significant impact, the proposed Project would not contribute to cumulatively considerable impacts. Therefore, cumulative impacts with regard to consistency with GP policies are less than significant. (DEIR, p. 5.11-64)
12. Mineral Resources
The GP 2025 determined that there are no areas within the City which have locally -important mineral resources recovery sites. The types of mineral deposits on the site are not known; however, there has been no historical use of the project site for mineral extraction purposes and the project does not involve the extraction of mineral resources. There would therefore be no significant cumulative environmental impacts from Project implementation. (DEIR, p. 5.12-4)
13. Noise
Cumulative development in the City and the surrounding area would modify existing land use patterns through the development of vacant lots or through redevelopment. The planned and pending projects in the Project vicinity, listed in Table 4.0-1 include about 6 projects consisting of residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high-cube fulfillment and cold storage, business park City of Riverside
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office, warehouse, and mixed-use buildings, retail, and park (active and public). The cumulative projects range in distance from the Project site from the closest project approximately 800 feet north, across Alessandro Boulevard, to approximately 1 mile southwest of the Project site, approximately 1.2 miles southeast of the site, to the farthest project site, approximately 1.75 miles east, on Alessandro Boulevard (refer to Figure 4.0-1 – Cumulative Project Locations).
Each of the proposed developments would generate temporary noise during construction.
Construction activities at the related projects and developments in the area would generate similar noise levels as the Project. Construction noise and vibration are localized and rapidly attenuate with distance from the source. Only the closest cumulative project, which is a commercial vehicle wash facility, located approximately 800 feet north, across Alessandro Boulevard, would have the potential to result in cumulative construction noise and vibration in the project area. The remaining cumulative projects are located far enough away that construction noise and vibration from the proposed Project and from the cumulative project sites would be attenuated with the distance between them such that they would not result in a cumulative effect. The commercial vehicle wash facility is currently under construction (at the time of preparation of this DEIR) and would be expected to be completed prior to the start of construction of the proposed Project. As the commercial vehicle wash facility and the proposed Project would not be under construction at the same time, they would not have a cumulative effect. Therefore, the Project would not contribute considerably to temporary cumulative construction noise and vibration impacts.
Because noise dissipates as it travels away from its sources, noise impacts associated with on- site activities and other stationary sources would be limited to the Project site and vicinity. Only the closest cumulative project, which is a commercial vehicle wash facility, located approximately 800 feet north, across Alessandro Boulevard, would have the potential to result in cumulative operational noise in the project area. Similar to construction, the remaining cumulative projects are located far enough away that operational noise from the proposed Project and from the cumulative project sites would be attenuated with the distance between them such that they would not result in a cumulative effect. As the commercial vehicle wash facility and the proposed Project would not be under construction at the same time, they would not have a cumulative effect. The commercial vehicle wash facility operational noise would be primarily generated from the washing and drying machinery in the car wash tunnel. The commercial vehicle wash facility was required to incorporate design features to reduce the operational noise impacts to adjacent residential uses such that the existing ambient noise levels, at the quietest measure time and level, are not exceeded. (PR -2021-001023 IS/MND 2022) As outlined in the Noise and Vibration Impact Analysis for the proposed Project, operational traffic noise levels for the existing condition, opening year, and cumulative with project scenarios were evaluated using worst -case scenario, which assumes that no shielding is provided between the traffic and the location where the noise contours are drawn, and determined to result in increase of up to 0.6 dBA in the project vicinity.
This noise level increase is below 3 dBA and would not be percepti ble to the human ear in an outdoor environment. The Noise and Vibration Impact Analysis also determined the Project would not generate vibration once operational. Therefore, on-site operation activities at the Project site, City of Riverside
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in combination with other planned and pending development, would not contribute considerable to long-term, cumulative noise or vibration impacts.
As discussed, the Project does not exceed any of the applicable noise significance criteria or significance thresholds; therefore, cumulative impacts would be less than significant however the below listed mitigation measures will still be included:
MM NOISE -1: The use and proper maintenance of noise reducing devices on construction equipment will minimize construction-related noise.
MM NOISE-2: Construction activities will take place only during those days and hours specified in the City Noise Ordinance to reduce noise impacts during more sensitive time periods.
MM NOISE-3: A program to inform prospective purchasers of dwelling units within the Specific Plan area of high aircraft noise levels shall be submitted by the developer of City review and approval prior to issuance of any residential building permits. This program s hall include a letter to be provided to the purchaser prior to completion of the sale.
MM NOISE-4: Appropriate avigation and noise easements for all residentially developed property shall be prepared for City and U.S. Air Force review and approval and recorded prior to approval of implementing land division proposals or issuance of any individual buil ding permits if no land division is proposed.
(DEIR, p. 5.13-25, -26)
14. Population and Housing
As there are no impacts related to displacing existing housing and people, there are also no cumulative impacts related to displacement of people. The General Plan 2025 was designed to accommodate anticipated growth under the typical development scenario by providing adequate services, access and infrastructure. The Project is an infill project as the area is currently served by existing roads and other infrastructure and the Project would only require minor extensions or laterals from nearby roads and util ities to the buildings. The Project would result in a very small incremental increase in population growth, approximately 1.4 percent, of anticipated growth in the City from 2020-2040. Thus, the Project is within the City’s anticipated 2025 growth projection and the Project would not result in any cumulative impacts beyond those that were already analyzed and disclosed in the GP 2025 PEIR. The project would result in less than significant cumulative impacts related to inducing substantial unplanned population growth. (DEIR, p. 5.14-5)
15. Public Services
The geographic context for an analysis of cumulative impacts with regards to public services is the local service area within the City for fire and police services, schools, and libraries. As discussed in Chapter 4 Environmental Setting of the DEIR, cumulative development in the City and surrounding cities and county would include residential development, warehouses, City of Riverside
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commercial, office, mixed -use and public facilities (parks). Past and present development has resulted in increased population, which in turn has resulted in an increase in demand for all public services. Growth in the City to date has been consistent with the growth projections in the City’s GP 2025. In addition, each of the public service providers conducts an annual budgeting process where future facility/staffing needs are identified. Because past and present development is consistent with growth identi fied in the GP 2025 and there are mechanisms in place to ensure provision of adequate service, there would be no significant cumulative environmental impact on public services from Project implementation. (DEIR, p. 5.15-10)
16. Recreation
The proposed Project would incrementally increase the population in the City, which would nominally increase the demand for and use of the existing park system. The proposed Project would be required to pay multiple park impact fees toward the purchase of new parkland, the development of trails, and the maintenance of existing facil ities. These measures would reduce impacts of the population increase caused by implementation of the proposed Project and associated use of parks in the City. Furthermore, future development would also be required to pay park impact fees to accommodate the associated population growth. Therefore, the project would result in less than significant cumulative impacts to recreation. (DEIR, p. 5.16-6)
17. Transportation
The Project will not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Additionally, the Project would not result in significant impacts regarding inadequate emergency access as the Project would be designed to meet Public Works and RFD specifications for providing adequate fire access. Therefore, cumulatively considerable potential impacts are less than significant, and no mitigation is required.
A project would result in a significant project-generated VMT impact if the baseline or cumulative project-generated VMT per capita exceeds 15 percent below the current jurisdictional baseline VMT per capita. Table 5.17- 1 indicates that 85 percent of the j urisdictional baseline VMT per capita for future year 2045 is 13.6. Thus, even with the assumed maximum 17.7 percent VMT reduction as a result of implementing Project -applicable VMT reduction strategies, the Project’s baseline per capita VMT would still exceed 15 percent below the 2045 jurisdictional baseline VMT per capita, resulting in a significant project-generated VMT impact.
The planned and pending projects near the Project site, listed in Table 4.0 -1 of this EIR, include residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high-cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public). These planned and pending projects would also increase VMT in the City. Cumulatively, the Project VMT impact is therefore considered significant and unavoidable. (DEIR, p. 5.17-23)
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18. Tribal Cultural Resources
The Project, in conjunction with other planned and pending projects in the Project vicinity, would cumulatively increase the potential to encounter sensitive tribal cultural resources. There would be cumulatively considerable impacts to tribal cultural resources if the project level impacts were significant for any of the cumulative projects. The planned and pending projects in the Project vicinity, listed in Table 4.0- 1 include about 6 projects consisting of residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high- cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public).
No tribal cultural resources were identified within the Project site. Potential impacts to tribal cultural resources are site- specific and would be reduced to a less -than-significant level due to implementation of mitigation measures MM CUL- 1 through MM CU L-4 that would protect tribal cultural resources. In the event that tribal cultural resources are discovered, each individual project would be required to comply with the applicable regulatory requirements and the consultation requirements of AB 52, and SB 18 if applicable, to determine and mitigate any potential impacts to tribal cultural resources. Therefore, cumulative impacts to tribal cultural resources would be less than significant with mitigation and would not be cumulatively considerable. (DEIR, p. 5.18-19)
19. Utilities and System Services
As discussed in Section 4, Environmental Setting, cumulative development in the City and surrounding cities and County would include residential development, warehouses, commercial, office, and public facilities. As discussed, the Project would not result in any significant impacts related to utilities and service systems, nor would the Project impair the attainment of solid waste reduction goals. Therefore, cumulative impacts would be less than significant related to utilities and service systems. (DEIR, p. 5.19-21)
20. Wildfire
The Project will have a less than significant impact directly or indirectly to an emergency response or evacuation plan and mitigation is not required. With the Project design (including Fire Access Plan), the two nearest Fire Stations being less than two miles from the Project site, the Project’s incremental impacts on fire protection services would be less than significant, and mitigation is not required. The Project’s potential to exacerbate wildfire risk from installation and maintenance of infrastructure would be less than significant and mitigation is not required.
The planned and pending projects near the Project site, listed in Table 4.0 -1 of this EIR, include residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high-cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public). These planned and pending projects would increase structural development near the Project site, in turn exposing new residents and property to potential risks from fires in the area.
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The Project site is not located in a VHFHSZ and the other cumulative projects are not either. With compliance with the CFC and CBC and implementation of design considerations potential impacts from the Project are reduced to less than significant levels. The other cumulative projects would also be required to comply with applicable codes, laws and standards and implement any project specific mitigation measures as appropriate identified through the CEQA review process for that project’s specific site conditions and design. All cumulative projects are required to be constructed in compliance with applicable CBC and CFC that ensure appropriate measures, including fire prevention and fuel modification features, are provided so that urban development does not expose project occupants to increased and uncontrolled fire hazards. Applicable CBC and CFC standards are designed to minimize the potential for uncontrolled fires. Furthermore, the cumulative projects would not result in permanent road closures, nor impede an established emergency or evacuation access route, or interfere with emergency response requirements, or fire protection response time standards. The Project is surrounded by mostly urban development and served by existing infrastructure. It would not contribute incrementally with other projects in the City or surrounding area to create an environment that would exacerbate wildfire risks.
Cumulative wildfire hazard impacts would be less than significant. (DEIR, p. 5.20-10)
SUMMARY OF THE SIGNIFICANT AND UNAVOIDABLE
PROJECT-LEVEL AND CUMULATIVE IMPACTS
Section 21067 of CEQA and Sections 15126(b) and 15126.2(b) of the State CEQA Guidelines require that an EIR describe any significant impacts, including those that can be mitigated but not reduced to a less than significant level. Furthermore, where there a re impacts that cannot be alleviated without imposing an alternative design, their implications and the reasons why the project is being proposed, notwithstanding their effect, should also be described.
• Hazards and Hazardous Materials: The Project’s projected residential density of 35.0 dwelling units per acre would be inconsistent with the maximum allowable residential density of 6.0 dwelling units per acre for Compatibility Zone C2. Because the Project would not meet this single MARB/IPA LUCP density compatibility criterion, the Project would result in a significant and unavoidable impact with respect to airport land use compatibility. ALUC consistency is project - specific, and the other cumulative projec ts are anticipated to be consistent with ALUC Compatibility Zone criteria. Therefore, although the proposed Project would be inconsistent with the residential density criteria for Compatibility Zone C2, as the other projects are not anticipated to have a s ignificant impact, the proposed Project would not contribute to cumulatively considerable impacts. Therefore, cumulative impacts with regard to consistency with ALUC are less than significant despite the immediate impacts being significant and unavoidable.
• Land Use and Planning: The Project will be consistent with the RMC, Titles 7, 16, 17, 19, and 20, the Mission Grove Specific Plan and General Plan 2025 land use designation and Housing Element. The Project would be consistent with all applicable GP 2025 objectives and policies except for be consistent with all applicable GP 2025 objectives and policies except for be City of Riverside
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consistent with all applicable GP 2025 objectives and policies except for Policies CCM-11.1, LU-
22.3, LU-22.5, and LU-69.1 related to the MARB/IPA LUCP, in which the Project would be partially consistent and partially inconsistent. As the Project’s project ed density would exceed the MARB/IPA LUCP Zone C2 residential density criteria of 6.0 dwelling units per acre and thus would also be partially inconsistent with Policies CCM -11.1, LU-22.3, LU-22.5, and LU-69.1 related to the MARB/IPA LUCP.
• Transportation: A project would result in a significant project-generated VMT impact if the baseline or cumulative project -generated VMT per capita exceeds 15 percent below the current jurisdictional baseline VMT per capita. Table 5.17-1 indicates that 85 percent of the jurisdictional baseline VMT per capita for future year 2045 is 13.6. Thus, even with the assumed max imum
17.7 percent VMT reduction as a result of implementing Project -applicable VMT reduction strategies, the Project’s baseline per capita VMT would still exceed 15 percent below the 2045 jurisdictional baseline VMT per capita, resulting in a significant project-generated VMT impact.
FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE
ENVIRONMENTAL CHANGES
Sections 15126(c) and 15126.2(d) of the CEQA Guidelines requires EIRs to contain a discussion of significant irreversible environmental changes which would be caused by the proposed Project should it be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
• The proposed Project would involve a large commitment of non‐renewable resources. • The primary and secondary impacts of the proposed Project would generally commit future generations to similar uses.
• The proposed Project involves uses in which irreversible damage could result from any potential environmental accidents; or
• The proposed consumption of resources is not justified.
This section addresses the use of non ‐renewable resources during initial and continued phases of the proposed Project, the commitment of future generations to environmental changes or impacts because of the proposed Project, and any irreversible damage from environmental accidents associated with the proposed Project:
Construction of the Project would involve an irreversible commitment of construction materials and non-renewable energy resources. The Project would involve the use of building materials and energy resources, some of which are non -renewable, to construct t he 347 apartment units. Consumption of these resources would occur with any development of the Project site and are not unique to the Project.
Operation of the Project would irreversibly increase local demand for non- renewable energy resources, such as petroleum products and natural gas. Increasingly efficient building design, however, will offset this demand to some degree by reducing energy demands of the Project.
The Project will be subject to the energy conservation requirements of the California Energy Code 2022 (Title 24, Part 6, of the California Code of Regulations, California’s Energy City of Riverside
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Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). The California Green Building Standards Code functions to:
• Reduce GHG emissions from buildings;
• Promote environmentally responsible, cost-effective, healthy places to live and work; • Reduce energy and water consumption; and
• Respond to the environmental directives of the administration.
In addition the 2022 CALGreen standards will require the Project recycle and/or salvage for reuse a minimum of 65 percent of the nonhazardous construction and demolition waste in accordance with either (CalGreen) Section 4.408.2, 4.408.3, or 4.408.4, or meet a more stringent local construction and demolition waste management ordinance (4.408.1).The California Energy Code provides energy conservation standards for all new and renovated commercial and residential buildings constructed in California, and the Green Building Standards Code requires solar access, natural ventilation, and stormwater capture. With adherence to these standards, the Project would not use unusual amounts of energy or construction materials, and impacts related to consumption of non -renewable and slowly renewable resources would be less than significant. Consumption of these resources would occur with any development of the Project site and would not be unique to the Project.
Future Generations: Approval of the Project would result in environmental changes or impacts that commit future generations to new environmental circumstances. Primarily, the approval of the Project would change the underlying GP 2025 land use designations and zoning of the Project site and the Mission Grove Specific Plan land use and zoning, as detailed in Section
5.11, Land Use and Planning (DEIR, p. 5.11-1). The change in the underlying regulations would allow for a change from C – Commercial to MU-U - Mixed Use-Urban for a multi-family development. This would result, in turn, in an increase in population as compared to commercial development as envisioned in the City’s GP 2025. However, as outlined in Section
5.14 Population and Housing (DEIR, p. 5.14-1), the GP 2025 was designed to accommodate anticipated growth by providing adequate services, access and infrastructure. The Project area is currently served by existing roads and other infrastructure and the Project would only require minor extensions or laterals from nearby roads and utilities to the site. Also, the Project would result in a very small incremental increase in population growth, 1.4% of the anticipated GP 2025 anticipated growth. The Project’s 1.4% percent incremental increase is anticipated to be a less than significant increase. The Project would also require an irreversible commitment of law enforcement, fire protection, water supply, wastewater treatment, and solid waste disposal services. However, as discussed in Section 5.15 Public Services (DEIR, p.
5.15-1), Section 5.19 Utilities (DEIR, p. 5.19-1), and Section 5.20 Wildfire (DEIR, p. 5.20-1), impacts to these services and systems would not be significant and any impacts would be mitigated by the applicant’s payment of impact fees for services provided (schools, fire, and transportation). (DEIR 6.0-7, -8)
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FINDINGS REGARDING GROWTH INDUCING IMPACTS
Section 15126.2(e) of the CEQA Guidelines requires a discussion of a proposed Project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create significant physical changes to the environment. However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. The proposed Project's growth inducing potential is therefore considered significant if pr oject-induced growth could result in significant physical effects in one or more environmental issue areas.
Population Growth: The Project would involve the development of multi-family residences, which will directly increase the City’s population. The expected number of tenants is 829 persons, and therefore the estimated population growth from the Project is 829 persons. Per the 6 th Cycle
Housing Element Technical Background Report, the City of Riverside had an estimated population of 328,155 in 2020. This represents a growth of 58,445 people from 2020 to 2040.
Therefore, the Project is anticipated to contribute approximately 1.4 percent of the anticipated population growth.
The General Plan 2025 was designed to accommodate anticipated growth under the typical development scenario by providing adequate services, access and infrastructure. The Project area is currently served by existing roads and other infrastructure and the Project would only require minor extensions or laterals from nearby roads and utilities to the site. Also, the Project would result in a very small incremental increase in population growth, approximately 1.4 percent, of what was anticipated. Thus, the Project is within the City’s anticipated 2025 growth projection.
The Project’s estimated 829 persons to the total population would be a minuscule incremental increase of the anticipated growth. Moreover, per the City’s General Plan EIR, the maximum population projection would be 444,308 persons, which would result in the Project’s generated residents of 829 person to be approximately 0.2 percent of the maximum population growth in 2025. The approximately 1.4 percent incremental increase is anticipated to be a less than significant increase and would not exceed both the estimated projection and the maximum projection of the City’s General Plan 2025 EIR growth projections.
In regard to indirect population growth, the Project area is currently served by existing roads and other infrastructure and the Project would only require minor extensions or laterals from nearby roads and utilities to the site. Therefore, the Project is not anticipated to indirectly induce population growth by the extension of infrastructure into undeveloped areas.
Economic Growth : The Project would generate temporary employment opportunities during construction. Because workers would be expected to come from the existing regional work force, construction of the Project would not be growth- inducing from a temporary employment standpoint.
The operations (on- site leasing office) and maintenance of the development (cleaning and landscape maintenance of the on-site amenities) would generate new employment opportunities.
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However, the proposed Project would not provide a substantial number of long- term jobs and workers would be expected to come from the existing regional work force.
The Project would not be expected to induce substantial economic expansion in the Project vicinity to the extent that direct physical environmental effects would result. Moreover, the environmental effects associated with any future development in or around Riverside would be addressed as part of the CEQA environmental review for each of those development projects. (DEIR 6.0-9, -10)
FINDINGS REGARDING ALTERNATIVES
Legal Requirements for Alternatives
Section 15126.6 of the CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:
(a) An EIR shall 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. 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 lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.
Subsection 15126.6(b) states the purpose of the alternatives analysis:
(b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), 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.
In subsection 15126.6(c), the CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to the project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record.
Among the factors that may be used to eliminate alternatives from detailed consideration in City of Riverside
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an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.
The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the proposed Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the proposed Project. “Feasible” means “capable of being accomplished in a reasonable period of time taking into account economic, environmental, legal, social and t echnological factors” (CEQA Guidelines §15364). The concept of feasibility also encompasses whether a particular alternative promotes the proposed Project’s underlying goals and objectives, and whether an alternative is impractical or undesirable from a policy standpoint. (See City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417; California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001 (CNPS).)
The issue of alternatives feasibility arises twice in the CEQA process, once when the EIR is prepared and again when CEQA findings are adopted. When assessing feasibility in an EIR, the EIR preparer evaluates whether an alternative is “potentially” feasible. Potentially feasible alternatives are suggestions by the EIR preparers that may or may not be adopted by lead agency decision makers. When CEQA findings are made, the lead agency decision making body independently evaluates whether the alternatives are actually feasible based on all the evidence in the record, including whether an alternative is impractical or undesirable from a policy standpoint. (See CNPS, supra, 177 Cal.App.4th at p. 999.)
If a significant impact can be avoided or substantially lessened (i.e., mitigated to a less than significant level) by adoption of mitigation measures, lead agency findings need not focus on the feasibility of alternatives to reduce that impact. (See Laurel Hills Homeowners Association v. City Council (1978) 83 Cal.App.3d 515, 521.) Nevertheless, Section 8 of the Draft EIR and these Findings of Fact do consider the effectiveness of the potentially feasible alternatives set forth in the EIR to substantially reduce all of the proposed Project’s significant impacts.
Project Objectives
As stated in Section 3.4 of this EIR (DEIR 3.0-23), the objectives for the Project, are as follows:
1. Provide a high- quality residential development in close proximity to many existing amenities and transit corridors.
2. Increase the type and amount of housing available, consistent with the goals of the City’s Housing Element.
3. Maximize the residential potential of the site to assist the City of Riverside in meeting project housing demand as part of the City’s housing needs and growth projections.
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4. Use land resources more efficiently by providing a well -planned, infill redevelopment on an underutilized vacant site.
5. Identify mixed-use development standards in the Specific Plan Amendment to create a framework for cohesive integration of uses.
6. In furtherance of the City’s Climate Action Plan, replace aging older building construction with newer and more green building practices and other sustainable development methods.
7. Create a mixed-use environment encouraging walkability.
8. Provide for enhanced residential architecture and aesthetically coherent design elements that are compatible and complimentary with the existing surrounding residential built environment in terms of colors and materials and landscaping.
Included in this analysis are four alternatives (DEIR, p. 1.0-4, -5), including the CEQA- required “No Project” alternative, that involve changes to the Project that may reduce Project -related environmental impacts as identified in this DEIR. Alternatives have been developed to provide a reasonable range of options to consider that would help decision makers and the public understand the general implications of revising or eliminating certain components of the proposed Project.
The following alternatives are evaluated in this DEIR:
• Alternative 1: No Project Alternative
• Alternative 2: Lower Density ALUC Consistent Multi-Family Residential Project • Alternative 3: Retail Project Alternative
• Alternative 4: Off-Site Multi-Family Residential Project
Detailed descriptions of the alternatives are outlined below.
ALTERNATIVES
Alternative 1 – No Project/No Redevelopment
The No Project/No Redevelopment Alternative assumes that the proposed 347 residential unit development would not be constructed. Alternative 1 considers no redevelopment/disturbance on the Project site. As such, the entire 9.92- acre site would remain a 104,231- square-foot vacant retail building (a former K -Mart retail store) and an associated surface parking lot. The re tail building was constructed in 1991 and the former K -Mart retail store closed in October of 2020.
Although there is no permanent tenant of the retail building, since vacated by K -Mart, it has had a temporary and seasonal tenant, the Spirit Halloween Costume Store. The No Project/ No Redevelopment Alternative would continue to be consistent with the existing General Plan land use designation of C Commercial, the existing zoning of CR-SP- Commercial Retail and Specific Plan (Mission Grove) Overlay Zones and with the Mission Grove Specific Plan and would not require a GPA, RZ, SPA, or TPM. The No Project alternative would not fulfill any of the Project’s objectives as the existing site would not provide high- quality housing in close proximity to many amenities and high quality transit corridors, assist the City of Riverside in meeting housing needs; City of Riverside
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use land resources more efficiently with infill redevelopment on an underutilized vacant site; or further the City’s Climate Action Plan by replacing aging building construction with green building practices and other sustainable development methods. Under this alternative, no improvements would be made to the Project site and the site would continue to be vacant with temporary/seasonal retail tenants. This alternative has no characteristics in common with the proposed Project nor any of the other alternatives as no proposed redevelopment would occur.
Impact Analysis for Alternative 1
Aesthetics
The Project site is currently developed and consists of a vacant retail building (formerly a K-Mart retail store) and associated surface parking lot. Since becoming vacant in 2020, the retail building hosts a Spirit Halloween Costume Store as a temporary and seasonal tenant.
The Project site is located within an existing shopping center consisting of various commercial and retail uses, such as grocery stores, fast food restaurants, and a gym/fitness center.
Additionally, the site’s surrounding uses consist of both single-family and multi-family residential uses.
Under Alternative 1, the vacant retail building would remain vacant aside from its temporary and seasonal tenant (Spirit Halloween) and no permanent aesthetic redevelopment changes or disturbances would occur to the building or its associated surface parki ng lot. The vacant retail building would only have the temporary and seasonal aesthetic change of a Spirit Halloween banner hung on the building’s frontage, which would be removed when the seasonal tenant vacates the space. Assuming the Project site retail building remains undeveloped, there would be no construction or redevelopment of structures that would alter site views, nor would there be any new sources of light and glare at the site associated with site construction or redevelopment.
Therefore, as Alternative 1 would not alter currently existing site views and would not introduce new or additional sources of light or glare, potential aesthetic impacts under Alternative 1 would be less than those associated with the proposed Project.
Agriculture and Forestry Resources
As discussed in DEIR Section 5.2, Agriculture and Forestry Resources (DEIR, p. 5.2-1), the Project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, nor is the Project site located adjacent to any of these farmland designation land uses. Additionally, the Project site is not currently zoned for agricultural use or adjacent to land zoned for agricultural use, nor is the site located within an area affected by a Williamson Act Preserve or under a Williamson Act Contract. As previously discussed, the Project site is currently developed and consists of a vacant retail building and associated surface parking lot and does not contain any farmland, forest land, or timberland, nor is the site located adjacent to any land containing these uses. As these uses are not located on or within the vicinity of the Project site, no impacts would occur to agricultural or forestry resources under development of the proposed City of Riverside
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Project or under Alternative 1. Therefore, potential impacts under the No Project/No Redevelopment Alternative would be similar to those of the proposed Project.
Air Quality
As analyzed in Section 5.3, Air Quality (DEIR, p. 5.3-1), the proposed Project would generate emissions through construction and operations, though emissions would not exceed regional localized significance thresholds (LSTs) for any criteria pollutant, nor would the proposed Project expose sensitive receptors t o substantial pollutant concentrations. Under Alternative 1, the currently existing vacant retail building would remain vacant, except for the building’s temporary and seasonal Spirit Halloween Costume Store tenant. Thus, under Alternative 1, there would be no construction at or redevelopment of the site and accordingly, no emissions from construction activities would be generated and operational emissions would be intermittent (i.e., seasonal and temporary when the Spirit Halloween tenant occupies the building). Therefore, potential air quality impacts under Alternative 1 would be less than those associated with the proposed Project.
Biological Resources
As analyzed in Section 5.4, Biological Resources (DEIR, p. 5.4-1), 15 special-status plant species have been recorded in the USGS Riverside East quadrangle, in which the Project site is located.
The Project site consists of an existing vacant retail building and associated surface parking lot, which are site conditions that have eliminated the Project site’s ability to provide suitable habitat for special- status plant species. Additionally, 29 special -status wildlife species have reported occurrences within the USGS Riverside East quadrangle. A review of the habitat requirements of each of the special -status wildlife species indicates that the Project site does not contain nor would be able to provide potentially suitable habitat for any of these wildlife species. The site contains trees that could provide potentially suitable habitat for nesting birds; these trees would be left in place under the development of the proposed Project and under Alternative 1. In addition, as the site is paved/developed, it does not contain, nor would it be able to provide, suitable conditions or habitat for features such as wetlands, vernal pools, or riparian or riverine resources.
As the site does not contain nor would it be able to support any sensitive biological resources, potential impacts to biological resources would be less than significant under both the proposed Project and the No Project/No Redevelopment Alternative. Therefore, potential impacts to biological resources under Alternative 1 would be similar to those associated with the proposed Project.
Cultural Resources
As discussed in DEIR Section 5.5, Cultural Resources (DEIR, p. 5.5-1), the City may consider the Project area to have a moderate to high sensitivity for potential impacts to cultural resources.
Additionally, while the proposed Project’s Cultural Resources Assessment did not report the presence or discovery of human remains, construction and/or ground-disturbing activities could have the potential to disturb or destroy previously undiscovered human remains, including those interred outside of formal cemeteries. Under the No Project/No Redevelopment Alternative, the previously developed Project site would remain vacant and undisturbed by construction or City of Riverside
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ground-disturbing activities. Therefore, potential impacts to cultural resources under Alternative 1 would be less than those associated with the proposed Project.
Energy
Under Alternative 1, No Project/Redevelopment, the existing retail building would remain vacant except for the times when it is occupied by its temporary and seasonal tenant, the Spirit Halloween Costume Store. There would be no construction or redevelopment of the site that would result in an increased use of electricity, natural gas, or petroleum associated with redevelopment construction and operation activities. As discussed in DEIR Section 5.6, Energy (DEIR, p. 5.6-1), the proposed Project would utilize electricity, natural gas, and petroleum during the construction and operation of the proposed Project residential development. Thus, potential impacts to energy resources under Alternative 1 would be less than those associated with the proposed Project.
Geology and Soils
Under Alternative 1, No Project/Development, the Project site would not be altered and there would be no ground disturbance on the site. As discussed, the Project site is previously developed and consists of a vacant retail building and associated surface parking lot. Under Alternative 1, the site would not undergo any construction or redevelopment disturbances, such as ground disturbance and grading, that could result in potential impacts to geological and soil resources.
Therefore, potential impacts to geology and soils under Alternative 1 would be less than those associated with the proposed Project.
Greenhouse Gas Emissions
As discussed in DEIR Section 5.8, Greenhouse Gas Emissions, construction of the proposed Project would generate greenhouse gas (GHG) emissions during the construction and operation of the Project, though emissions do not exceed any of the GHG significance thresholds. The No Project/Development alternative would not include on- site development and would thus not generate any construction or operational GHG emissions. Therefore, impacts associated with GHG emissions under Alternative 1 would be less than those of the proposed Project.
Hazards and Hazardous Materials
As discussed in DEIR Section 5.9, Hazards and Hazardous Materials (DEIR, p. 5.9-1), the proposed Project’s residential density would exceed and be inconsistent with the allowable maximum residential density criteria for MARB/IPA LUCP Compatibility Zone C2, resulting in a significant and unavoidable impact. While conditions of approval h ave been proposed, implementation of these conditions would not render the proposed Project consistent with the MARB/IPA LUCP Compatibility Zone C2 residential density criteria. Under Alternative 1, the site would not require any zoning, land use, or specific plan changes as the site would remain a vacant retail building within a commercial use area. The site would remain consistent with allowable uses and maximum residential densities under the No Project/Redevelopment Alternative. Therefore, potential impacts relating to hazards and hazardous materials under Alternative 1 would be less than those associated with the proposed Project.
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Hydrology and Water Quality
As discussed in DEIR Section 5.10, Hydrology and Water Quality (DEIR, p. 5.10-1), expected pollutant sources that could impact water quality resources from the proposed Project include interior drains, indoor/structural pesticide use, landscape/outdoor pesticide use, refuse areas, plazas, sidewalks, and parking lots. Under Alternative 1, the Project site would not undergo any construction or redevelopment activities that would generate pollutant sources associated with them. Rather, under Alternative 1, the Project site would remain under current site conditions, which consist of a vacant retail building and associated surface parking lot. While the proposed Project’s potential impacts to hydrology and water quality would be less than significant, because Alternative 1 would not include any on-site construction, redevelopment, or operational activities, potential impacts under Alternative 1 would be less than those associated with the proposed Project.
Land Use and Planning
As discussed in DEIR Section 5.11, Land Use and Planning (DEIR, p. 5.11-1), the proposed Project’s projected residential density of 35.0 dwelling units per acre would be inconsistent with the allowable 6.0 dwelling units per acre permitted by the MARB/IPA LUCP residential density criteria for Compatibility Zone C2, in which the Project site is located. Also, the proposed Project would be consistent with all applicable GP 2025 objectives and policies except for Policies CCM-
11.1, LU- 22.3, LU-22.5, and LU-69.1 related to the MARB/IPA LUCP, in which the Project would be partially consistent and partially inconsistent. Thus, the proposed Project would result in a significant and unavoidable impact to land use and planning due to inconsistency with the allowable maximum residential density of the MARB/IPA LUCP C2 Zone as well as being partially inconsistent with GP 2025 Policies CCM -11.1, LU -22.3, LU -22.5, and LU -69.1 related to the MARB/IPA LUCP. Under Alternative 1, the site would not require any zoning, land use, or specific plan changes as the site would remain a vacant retail building within a commercial use area. The site would remain consistent with allowable uses and densities of Compatibility Zone C2 of the MARB/IPA LUCP, under the No Project/Redevelopment Alternative. Therefore, potential impacts to land use and planning under Alternative 1 would be less than those associated with the proposed Project.
Mineral Resources
As discussed in DEIR Section 5.12, Mineral Resources (DEIR, p. 5.12-1), the Project site has been developed for commercial uses and is not located within or adjacent to areas of known mineral resources that would be of value to the region or State. Additionally, the City’s GP 2025 PEIR determined that there are no specific areas within the City boundary or proposed Sphere of Influence Area that have locally-important mineral resource recovery sites. As the Project site has already been developed with a retail building and associated surface parking lot, and as the site is not located within or adjacent to areas of known mineral resources, neither the development of the proposed Project nor implementation of Alternative 1 would result in impacts to mineral resources. Therefore, potential impacts to mineral resources under Alternative 1 would be similar to those associated with the proposed Project.
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Noise
Under the No Project/Redevelopment Alternative, the existing retail building would remain vacant except for when temporarily and seasonally occupied by the Spirit Halloween Costume Store tenant. There would be no redevelopment of the site or associated surface parking lot that would generate construction or operational noise as would occur under the proposed Project. While the proposed Project’s potential construction, vibration, and operational noise impacts would be less than significant, as Alternative 1 would not include any redevelopment construction noise or vibration and operational noise would be intermittent (i.e., seasonal and temporary), potential impacts under Alternative 1 would be less than those associated with the proposed Project.
Population and Housing
Under Alternative 1, no construction or redevelopment activities would occur on the Project site that would cause a substantial unplanned population growth, nor would Alternative 1 result in displacing substantial numbers of existing people or housing, nec essitating the construction of replacement housing elsewhere. As discussed, the Project site currently consists of a vacant retail building and associated surface parking lot; additionally, the site is currently zoned for commercial uses. While the propose d Project’s potential impacts to population and housing would be less than significant, because Alternative 1 would not include any redevelopment involving residential uses and associated population growth, potential impacts to population and housing under Alternative 1 would be less than those associated with the proposed Project.
Public Services
Under the No Project/Redevelopment Alternative, the Project site would remain under its current site conditions, which consist of a vacant retail building and associated surface lot, with no redevelopment of the site for alternative uses. The retail buildi ng would only be temporarily and seasonally occupied by the Spirit Halloween Costume Store tenant. These intermittent commercial uses would not result in an increased demand in public services, such as fire protection, police protection, parks, or libraries, such that new/additional facilities would need to be constructed. While potential impacts to public services under the proposed Project would be less than significant, because Alternative 1 would not result in any redevelopment of the Project site, potential impacts to public services under Alternative 1 would be less than those of the proposed Project.
Recreation
Under the No Project/Redevelopment Alternative, the Project site would remain under its current site conditions, which consist of a vacant retail building and associated surface lot, with no redevelopment of the site for alternative uses. The retail buildi ng would only be temporarily and seasonally occupied by the Spirit Halloween Costume Store tenant. These intermittent commercial uses would not increase population or associated use of existing neighborhood and regional parks or other recreational faciliti es such that substantial physical deterioration would occur, nor would the intermittent commercial uses require the construction or expansion of recreational facilities. While potential impacts regarding recreation under the proposed Project City of Riverside
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would be less than significant, because Alternative 1 would not result in any redevelopment of the Project site, potential impacts to recreation under Alternative 1 would be less than those of the proposed Project.
Transportation
As discussed in DEIR Section 5.17, Transportation (DEIR, p. 5.17-1), the proposed Project would result in significant and unavoidable impacts regarding vehicle miles traveled (VMT). While mitigation measures are proposed, implementation of the measures would not decrease the proposed Project’s impacts to VMT to a less than significant level. Under the No Project/Redevelopment Alternative, vehicular traffic and VMT levels associated with the Project site would remain relatively low in comparison to those generated by the proposed Project as the existing retail building would only be temporarily and seasonally occupied by the Spirit Halloween Costume Store tenant. Additionally, Alternative 1 would not include any construction related traffic associated with redevelopment of the site. Thus, potential impacts to transportation under Alternative 1 would be less than those of the proposed Project.
Tribal Cultural Resources
Construction of the proposed Project would involve ground-disturbing activities with the potential to unearth or adversely impact previously unidentified tribal cultural resources. The No Project Alternative would have no ground -disturbing activities and t here would be no potential for adversely impacting tribal cultural resources. The No Project/Development alternative would have less potential impact than the proposed Project.
Utilities
Construction and operation of the proposed Project would result in an increased demand for utility services, such as water supply, wastewater treatment, and solid waste services. While potential impacts to utilities and service systems would be less than significant under the proposed Project, because Alternative 1 would not include any site redevelopment that could increase the demand of utility services, potential impacts to utilities and utility services under Alternative 1 would be less than those of the proposed Project.
Wildfire
As discussed in DEIR Section 5.20, Wildfire (DEIR, p. 5.20-1), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
Additionally, under current site conditions and as would remain the case under Alternative 1, the site’s vacant retail building is only intermittently (i.e., seasonally and temporarily) occupied by the Spirit Halloween Costume Store tenant. Under Alternative 1, the site and its current uses would not have an increased risk of exposing people or structures to significant risks, such as downslope or downstream flooding or landslides, or to a significant risk of loss, injury, or death involving wildland fires due to being located in a VHFHSZ. As Alternative 1 was required to comply with the applicable California Building Standards Code (CBC) and California Fire Code (CFC) standards at the time it was constructed and the proposed Project would be required to comply with City of Riverside
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applicable CBC and CFC standards that ensure appropriate measures, including fire prevention and fuel modification features, are provided so that urban development does not expose project occupants to increased and uncontrolled fire hazards, the potential to expose people or structures to significant risks of loss, injury, or death involving wildland fires are low. Potential wildfire impacts under Alternative 1 would be similar to those associated with the proposed Project. (DEIR p. 7.0- 1, -9)
Relationship to Project Objectives
Alternative 1, the No Project/No Redevelopment Alternative, assumes that no redevelopment or disturbance of the 9.92- acre site would occur, leaving the 104,231- square-foot vacant retail building (formerly a K-Mart store) and associated parking lot in their current condition. While this alternative would reduce certain short-term environmental impacts related to construction, it would not fulfill any of the Project’s objectives.
Although the No Project/No Redevelopment Alternative would avoid potential construction-related impacts, it would not contribute to meeting the City of Riverside’s housing needs. Specifically, Alternative 1 would not provide high- quality residential development in proximity to existing amenities and transit corridors (Project Objective 1) , nor would it assist the City in meeting its housing demand (Project Objectives 2 & 3), as no housing units would be constructed. The site would remain an underutilized vacant property, which does not align with the objective of using land resources more efficiently through infill redevelopment (Project Objective s 4 & 5 ).
Furthermore, the alternative would not incorporate any green building practices or sustainable development methods (Project Objective 6), meaning it would not support the City’s RRG -CAP goals.
Additionally, Alternative 1 would continue to leave the site without any cohesive integration of uses, as no mixed -use development would be pursued (Project Objective 7). The vacant retail building would remain in place with only temporary and seasonal tenants, such as the Spirit Halloween store, and would not contribute to creating a mixed -use environment that promotes walkability or enhances the aesthetic quality of the area (Project Objectives 7 & 8). The existing structure, built in 1991, would not be updated or improved, meaning it would not provide any enhanced residential architecture or design elements compatible with the surrounding residential neighborhoods.
State CEQA Guidelines Section 15126.6(f)(1) states that factors such as site suitability and economic viability may be considered when assessing the feasibility of alternatives. In this case, Alternative 1 would not meet any of the key objectives, including providing housing to meet the City’s Regional Housing Needs Assessment ( RHNA) allocations (Project Objective 2 & 3) , improving the site’s land use efficiency, or contributing to sustainable development goals. Without redevelopment, the site would continue to remain vacant, failing to contribute to the City’s housing goals or economic growth.
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Therefore, Alternative 1 does not fulfill any of the Project’s objectives (Project Objectives 1-8) and is not considered a feasible alternative. It would perpetuate the underutilization of a prime urban site and fail to address the City’s need for housing and sustainable development. As a result, Alternative 1 is rejected as an infeasible option.
Finding
The City Council rejects Alternative 1 (No Project/No Redevelopment) as a project alternative on the basis that Alternative 1 is infeasible and does not fulfill the project objectives (Project Objectives 1-8). CEQA does not require a lead agency to select an alternative which does not meet most of the project objectives (State CEQA Guidelines section 15126.6).
Alternative 2 – Reduced Density Apartment Redevelopment This discussion analyzes alternative redevelopment of the site with a high- quality residential development with a reduced residential density, such that it meets the residential density criteria of the C2 Compatibility Zone of the March Air Reserve Base/ Inland Port Airport Land Use Compatibility Plan MARB/IPA LUCP). The residential density standard for the C2 zone is six or less dwelling units per acre (du/ac). As the Project site is 9.92 acres, in order to meet the C2 zone residential density criteria of 6.0 du/ac, only 58 dwelling units would be constructed. Under this alternative, a GPA would be required to change the land use designation to Mixed Use – Neighborhood (MU- N), with maximum of 10.0 dwelling units per acre, and associated zone change (MU-N) as well as a Specific Plan Amendment to the Mission Grove Specific Plan. A TPM may also be required under this alternative for leasing and financing purposes (DEIR, p. 1.0-4).
Impact Analysis for Alternative 2
Aesthetics
Under Alternative 2, the Reduced Density Apartment Redevelopment, the proposed residential development would consist of 58 dwelling units in lieu of the proposed Project’s 347 dwelling units. As discussed in DEIR Section 5.1, Aesthetics, the Project site is located in a highly urbanized area, consisting of commercial and retail uses as well as single- and multi -family residential uses. The Project site is not a scenic vista, nor are there any State scenic highways or City designated Scenic or Special Boulevards or Parkways in the vicinity of the Project site.
Assuming the Reduced Density Apartment Redevelopment would be constructed with the same design elements of the proposed Project, Alternative 2 would include a contemporary Spanish architectural style with features such as decorative tiles at Project entries, foam trims, sills, corbels, and trellises at upper balconies. These design elements would simply be implemented on a smaller scale due to the reduced density development of Alternative 2. Additionall y, the project design and landscaping of Alternative 2 would similarly be required to comply with the City’s Design Guidelines and Zoning Code. Moreover, as the higher density, larger proposed Project development would not result in substantial light or glare, it is anticipated that a smaller, reduced density development would result in even less potential light and glare impacts. While impacts to aesthetics would be less than significant under the proposed Project, because the City of Riverside
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Reduced Density Apartment Redevelopment would result in a smaller scale residential development, impacts under Alternative 2 would be less than those of the proposed Project.
Agriculture and Forestry
As discussed in DEIR Section 5.2, Agriculture and Forestry Resources (DEIR, p. 5.2-1), the Project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, nor is the Project site located adjacent to any of these farmland designation land uses. Additionally, the Project site is not currently zoned for agricultural use or adjacent to land zoned for agricultural use, nor is the site located within an area affected by a Williamson Act Preserve or under a Williamson Act Contract. As previously discussed, the Project site is currently developed and consists of a vacant retail building and associated surface parking lot and does not contain any farmland, forest land, or timberland, nor is the site located adjacent to any land containing these uses. As these uses are not located on or within the vicinity of the Project site, no impacts would occur to agricultural or forestry resources under development of the proposed Project or under Alternative 2. Therefore, potential impacts under the Reduced Density Apartment Redevelopment would be similar to those of the proposed Project.
Air Quality
Under Alternative 2, Reduced Density Apartment Redevelopment, development of the Project site would result in construction and operational emissions that could potentially impact air quality.
However, as Alternative 2 would consist of a multi -family residential development with only 58 dwelling units instead of the proposed Project’s 347 dwelling units, it is assumed that construction of the project under Alternative 2 would accordingly consist of a shorter construction period, which would therefore result in less construction- related emissions. Additionally, a smaller scale residential development as proposed under Alternative 2 would correspondingly house fewer residents than could be accommodated under the proposed Project, resulting in fewer vehicles, and therefore, fewer vehicle emissions. As such, potential impacts to air quality under Alternative 2 would be less than those associated with the proposed Project.
Biological Resources
As analyzed in Section 5.4, Biological Resources (DEIR, p. 5.4-1), 15 special-status plant species have been recorded in the USGS Riverside East quadrangle, in which the Project site is located.
The Project site consists of an existing vacant retail building and associated surface parking lot, which are site conditions that have eliminated the Project site’s ability to provide suitable habitat for special- status plant species. Additionally, 29 special -status wildlife species have reported occurrences within the USGS Riverside East quadrangle. A review of the habitat requirements of each of the special -status wildlife species indicates that the Project site does not contain nor would be able to provide potentially suitable habitat for any of these wildlife s pecies. While the site contains trees that could provide potentially suitable habitat for nesting birds, these trees would be left in place under the development of the proposed Project and, it is assumed, under the Reduced Density Apartment Redevelopment. In addition, as the site is paved/developed, it does not contain nor would it be able to provide suitable conditions or habitat for features such as City of Riverside
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wetlands, vernal pools, or riparian or riverine resources. As the site does not contain nor would it be able to support any sensitive biological resources, potential impacts to biological resources would be less than significant under either the proposed P roject or the Reduced Density Apartment Redevelopment Alternative. Therefore, potential impacts to biological resources under Alternative 2 would be similar to those associated with the proposed Project.
Cultural Resources
Similar to the proposed Project, development of the Reduced Density Apartment Redevelopment Alternative would require site preparation and grading. However, as Alternative 2 would consist of a smaller scale residential project, it is assumed the grading li mits and development footprint of Alternative 2 would be less than those of the proposed Project. Ground- disturbing activities with the potential to unearth or adversely impact previously undiscovered archaeological resources and/or human remains would still occur under Alternative 2, as construction activities would occur within the same development footprint as the proposed Project, resulting in the same area of ground disturbance. Therefore, potential impacts to cultural resources under Alternative 2 would be the same as those associated with the proposed Project.
Energy
Under the Reduced Density Apartment Redevelopment Alternative, electricity and natural gas would still be supplied by Riverside Public Utilities (RPU) and Southern California Gas Company (SoCalGas), respectively. It is anticipated that construction fuel consumption under Alternative 2 would be less than that of the proposed Project for construction equipment, vendor trips, and worker trips as Alternative 2 would be a comparatively smaller scale development than the proposed Project. Similar to the proposed Project, the project under Alternative 2 would comply with applicable Title 24 Building Standards for multi -family residential developments, including incorporating solar panels and providing electric vehicle (EV) charging stations. It is additionally anticipated that similar to the proposed Project, the project under Alternative 2 would utilize all electric appliances and only utilize natural gas for project amenities/common spaces. As the Reduced Density Apartment Redevelopment would be a smaller scale re sidential development, with only 58 dwelling units instead of the 347 dwelling units, it is anticipated that the project under Alternative 2 would consume less energy resources during both construction and operations as compared to the proposed Project. Th erefore, potential impacts to energy resources under Alternative 2 would be less than those associated with the proposed Project.
Geology and Soils
The existing geology and soils conditions of the site would remain the same for both the proposed Project and Alternative 2. As discussed, the Project site is previously developed and consists of a vacant retail building and associated surface parking lot. Ground-disturbing activities for construction would occur within the same development footprint as the proposed Project, resulting in the same area of ground disturbance and potential impacts on geology and soils resources.
Thus, potential impacts to geology and soils under Alternative 2 would be the same as those of the proposed Project.
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Greenhouse Gas Emissions
Under Alternative 2, Reduced Density Apartment Redevelopment, development of the Project site would result in construction and operational greenhouse gas (GHG) emissions. However, as Alternative 2 would consist of a multi -family residential development with only 58 dwelling units instead of the proposed Project’s 347 dwelling units, it is assumed that construction of the project under Alternative 2 would accordingly consist of a shorter construction period, which would therefore result in less construction- related emissions. Additionally, a smaller scale residential development as proposed under Alternative 2 would correspondingly house fewer residents than could be accommodated under the proposed Project, resulting in fewer vehicles, and therefore, fewer vehicle GHG emissions. As such, potential impacts regarding GHG emissions under Alternative 2 would be less than those associated with the proposed Project.
Hazards and Hazardous Materials
As discussed in DEIR Section 5.9, Hazards and Hazardous Materials (DEIR, p. 5.9-1), the proposed Project’s residential density would exceed and be inconsistent with the allowable maximum residential density criteria for MARB/IPA LUCP Compatibility Zone C2, resulting in a significant and unavoidable impact. Alternative 2 proposes a reduc ed density apartment redevelopment that would consist of 58 dwelling units in comparison to the 347 dwelling units associated with the proposed Project. The reduced number of dwelling units proposed under Alternative 2 would allow the proposed residential development to be consistent with the Compatibility Zone C2 allowable residential density. Therefore, as Alternative 2 would allow for a residential development that would be consistent with Compatibility Zone C2 residential density requirements, potential impacts regarding hazards and hazardous materials would be less than those associated with the proposed Project.
Hydrology and Water Quality
Similar to the proposed Project, expected pollutant sources that could impact water quality resources under Alternative 2 would include interior drains, indoor/structural pesticide use, landscape/outdoor pesticide use, refuse areas, plazas, sidewalks, and parking lots. While the proposed Project’s potential impacts to hydrology and water quality would be less than significant, because Alternative 2 would consist of a smaller scale, reduced density residential development, potential impacts under Alternative 2 would be less than those associated with the proposed Project.
Land Use and Planning
As discussed in DEIR Section 5.11, Land Use and Planning (DEIR, p. 5.11-1), the proposed Project’s projected residential density of 35.0 du/ac would be inconsistent with the allowable 6.0 du/ac permitted by the MARB/IPA LUCP density criteria for Compatibility Zone C2, in which the Project site is located. Thus, the proposed Project would result in a significant and unavoidable impact to land use and planning as a result of inconsistency with the maximum allowable residential density in the Compatibility Zone C2. Also, the proposed Project would be consistent City of Riverside
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with all applicable GP 2025 objectives and policies except for Policies CCM -11.1, LU-22.3, LU-
22.5, and LU -69.1 related to the MARB/IPA LUCP, in which the Project would be partially consistent and partially inconsistent. Alternative 2 proposes a Reduced Density Apartment Redevelopment Alternative that would consist of 58 dwelling units rather than the proposed Project’s total of 347 dwelling units, which would allow the development under Alternative 2 to be consistent with the maximum residential density criteria for Compatibility Zone C2 and it would be completely consistent with all applicable GP 2025 objectives and policies including Policies CCM-
11.1, LU-22.3, LU-22.5, and LU-69.1 related to the MARB/IPA LUCP. Therefore, potential impacts regarding land use and planning under Alternative 2 would be less than those associated with the proposed Project.
Mineral Resources
As discussed in DEIR Section 5.12, Mineral Resources (DEIR, p. 5.12-1), the Project site has been developed for commercial uses and is not located within or adjacent to areas of known mineral resources that would be of value to the region or State. Additionally, the City’s GP 2025 PEIR determined that there are no specific areas within the City’s boundary or proposed Sphere of Influence Area that have locally-important mineral resource recovery sites. As the Project site has already been developed with a retail building and associated surface parking lot, and as the site is not located within or adjacent to areas of known mineral resources, neither the development of the proposed Project nor implementation of Alternative 2 would result in impacts to mineral resources. Therefore, potential impacts to mineral resources under Alternative 2 would be similar to those associated with the proposed Project.
Noise
Similar to the proposed Project, development of the Reduced Density Apartment Redevelopment would result in construction related noise and vibration as well as operational noise. It is anticipated that because Alternative 2 would consist of a smaller scale, reduced density development, the construction period for Alternative 2 would be correspondingly shorter than that of the proposed Project, resulting in less construction generated noise and vibration. While the proposed Project’s potential construction, vibration, and operational noise impacts would be less than significant, because Alternative 2 would consist of a smaller, reduced density residential development, potential noise impacts under Alternative 2 would be less than those of the proposed Project.
Population and Housing
As discussed in DEIR Section 5.14, Population and Housing (DEIR, p. 5.14-1), development of the proposed Project would not cause substantial unplanned population growth, nor would the proposed Project result in displacing any existing people or housing, necessitating the construction of replacement housing elsewhere. Similar to t he proposed Project, the Reduced Density Apartment Redevelopment Alternative would consist of an infill redevelopment project that would provide multi-family residential uses. Both the proposed Project and Alternative 2 are growth accommodating (as compared to growth inducing), as the region, and the state as a whole, City of Riverside
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are short on housing. The proposed Project would result in less than significant impacts related to population and housing, and Alternative 2 would also. Although Alternative 2 is less growth accommodating, than the proposed Project (as it provides less units), both projects would not induce substantial population growth and therefore, potential impacts regarding population and housing under Alternative 2 would be the same as those of the proposed Project.
Public Services
As discussed in DEIR Section 5.15, Public Services (DEIR, p. 5.15-1), the proposed Project’s 347-unit multi-family residential development would not result in an increased demand in public services, such as fire protection, police protection, parks, or libraries, such that new/additional facilities would need to be constructed. In comparison to the proposed Project, Alternative 2 proposes a reduced density apartment redevelopment that would consist of only 58 dwelling units, which, accordingly, would result in a reduced number of residents who would utilize and be served by the Project site area’s public services. While potential impacts to public services under the proposed Project would be less than significant, because Alternative 2 would result in a reduced demand on public services as compared to the proposed Project, impacts to public services under Alternative 2 would be less than those of the proposed Project.
Recreation
As discussed in DEIR Section 5.16, Recreation (DEIR, p. 5.16-1), the proposed Project’s 347-unit multi-family residential development would not substantially increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration would occur. Additionally, the proposed Project would not require the construction or expansion of recreational facilities. In comparison to the proposed Project, Alternative 2 proposes a reduced density apartment redevelopment that would consist of only 58 dwelling units, which, accordingly, would result in a reduced number of residents who would utilize existing neighborhood and regional parks or other recreational facilities. While potential impacts relating to recreation under the proposed Project would be less than signific ant, because Alternative 2 would result in a reduced demand on recreational facilities as compared to the proposed Project, impacts regarding recreation under Alternative 2 would be less than those of the proposed Project.
Transportation
As discussed in DEIR Section 5.17, Transportation (DEIR, p. 5.17-1), the proposed Project would result in significant and unavoidable impacts regarding VMT. While mitigation measures are proposed, implementation of the measures would not decrease the proposed Project’s impacts to VMT to a less than significant level. The proposed Project would consist of a 347- unit multi- family residential development; in contrast, the Reduced Density Apartment Development Alternative would consist of 58 units. It is assumed that the reduced number of vehicles associated with the reduced number of residents who could be accommodated by Alternative 2 would accordingly result in fewer vehicle miles travelled. Therefore, potential impacts to transportation under Alternative 2 would be less than those of the proposed Project.
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Tribal Cultural Resources
Similar to the proposed Project, development of the Reduced Density Apartment Redevelopment Alternative would require site preparation and grading. Although Alternative 2 would consist of a smaller scale residential project, it is assumed the grading limits and development footprint of Alternative 2 would be the same as that of the proposed Project. Thus, while ground- disturbing activities with the potential to unearth or adversely impact previously undiscovered tribal cultural resources would still occur under Alternative 2, it is anticipated that these construction activities would occur within the same development footprint as that of the proposed Project, resulting in the same area of ground disturbance. Therefore, potential impacts to tribal cultural re sources under Alternative 2 would be the same as those associated with the proposed Project.
Utilities and Service Systems
As discussed in DEIR Section 5.19, Utilities and Service Systems (DEIR, p. 5.19-1), construction and operation of the proposed Project would result in an increased demand for utility services, such as water supply, wastewater treatment, and solid waste services. Although this would be a similar case for the construction and operation of Alternative 2, it is anticipated that the demand for utility services under Alternative 2 would be reduced as Alternative 2 consists of a reduced density apartment redevelopment that would be smaller in scale and number of residents than the proposed Project. While potential impacts to utilities and service systems would be less than significant under the proposed Project, because Alternative 2 would consist of a reduced density apartment project, potential impacts to utilities and utility services under Alternative 2 would be less than those of the proposed Project.
Wildfire
As discussed in DEIR Section 5.20, Wildfire (DEIR, p. 5.20-1), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ) nor would the proposed Project expose people or structures to significant risks, such as downslope or downstream flooding or landslides, or to a significant risk of loss, injury, or death involving wildland fires. Similar to the proposed Project, the Reduced Density Apartment Redevelopment Alternative would consist of an infill redevelopment project within a previously developed site that is not located within a VHFHSZ and that does not feature site conditions that would expose people or structures to the aforementioned significant risks. Therefore, potential impacts related to wildfire under Alternative 2 would be similar to those associated with the proposed Project. (DEIR p. 7.0-9, -15)
Relationship to Project Objectives
Alternative 2, the Reduced Density Apartment Redevelopment, proposes developing the Project site with 58 dwelling units, consistent with the residential density criteria for Compatibility Zone C2 of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan (MARB/IPA LUCP). While this alternative would reduce some environmental impacts compared to the proposed Project, it would only partially meet most of the Project’s objectives (meet Project Objectives 1, 2, 6, 7, and 8) and fails to meet two key objectives (Project Objectives 3 & 4).
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First, while Alternative 2 would provide a high- quality residential development, the significantly reduced density would not maximize the residential potential of the site (Project Objective 3). The proposed Project aims to construct 347 dwelling units, a scale that would meaningfully contribute to the City’s housing supply. In contrast, the 58 dwelling units under Alternative 2 would provide only a fraction of the housing needed to meet the City’s projected housing demand and goals outlined in the Housing Element. As such, Alternative 2 would not effectively assist the City of Riverside in meeting its housing needs or its RHNA allocations.
Additionally, although this alternative would still redevelop an underutilized vacant site, the reduced density would represent a less efficient use of the land resources. The Project’s objective of promoting well -planned infill redevelopment is best met by maximizing the site's potential (Project Objective 3), which Alternative 2 fails to do. Furthermore, the smaller-scale development under Alternative 2 would not create a mixed -use environment that encourages walkability (Project Objective 7) to the same degree as the proposed Project, which is designed to support a vibrant, pedestrian-friendly community through higher density and mixed-use integration.
State CEQA Guidelines Section 15126.6(f)(1) allows for consideration of factors like site suitability and economic viability in assessing the feasibility of alternatives. While Alternative 2 would meet the residential density requirements of Compatibility Zone C2, it would not provide the needed level of housing supply, use land resources as efficiently as possible, or create the mixed- use, walkable environment envisioned for the site. The reduced scale of development would also limit the architectural and aesthetic enhancements that could be achieved through a larger, more cohesive project design. Alternative 2 would only partially meet Project Objectives 1, 2, 6, 7, and
8. Alternative 2 would not meet Project Objectives 3 and 4.
Finding
The City Council finds that Alternative 2 would result in fewer impacts for certain environmental issues, such as air quality, noise, and vehicle miles traveled, compared to the proposed Project due to the reduced number of dwelling units. However, the City Council rejects Alternative 2 as a proposed Project alternative on the following grounds, each of which individually provides sufficient justification for rejection of this alt ernative: (1) failure to meet key Project objectives, particularly maximizing the residential potential of the site and providing a significant contribution to the City’s housing needs; and (2) infeasibility, as this alternative would underutilize a key i nfill site and not meet the City's long-term planning and housing goals.
Alternative 3 – Retail Development
This discussion analyzes alternative development of the site that remains in accord with the current land use and zoning designations and retains the existing development with the 104,231 square foot retail building and an associated surface parking lot. Under this alternative, the existing retail building and associated surface parking lot would be retained, with only minor improvements to the inside of the building, the outside of the building, and/or associated surface City of Riverside
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parking lot and landscaping which would house a permanent retail tenant that would utilize the full square footage of the building for retail. Under this alternative, the land use designation and zoning would remain as is, and no SPA would be required.
Impact Analysis for Alternative 3
Aesthetics
Alternative 3 (DEIR, p. 1.0-5), the Retail Development Alternative, would consist of the existing retail building and associated surface parking lot being retained, with only minor improvements to the inside of the building, the outside of the building, and/or associated surface parking lot and landscaping. The existing building would house a permanent retail tenant that would utilize the full square footage of the building for retail. The Project site currently exists within a previously developed shopping center with associated retail, commercial, and fast -food uses. As such, the existing retail building matches the existing aesthetic character of the Project area as the building was constructed for uses similar to that of the shopping center. Because Alternative 3 would only consist of minor improvements to the building interior, building exterior, and/or to the associated surface parking lot and landscaping, Alternative 3 is not anticipated to intr oduce any new/additional sources of light or glare that would result in significant impacts, nor would Alternative 3 result in structures that would further obstruct any views within the Project area.
Therefore, as Alternative 3 would not result in any redevelopment of the site other than minor improvements for a future retail tenant, potential impacts to aesthetics under Alternative 3 would be less than those of the proposed Project.
Agriculture and Forestry Resources
As discussed in DEIR Section 5.2, Agriculture and Forestry Resources (DEIR, p. 5.2-1), the Project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, nor is the Project site located adjacent to any of these farmland designation land uses. Additionally, the Project site is not currently zoned for agricultural use or adjacent to land zoned for agricultural use, nor is the site located within an area affected by a Williamson Act Preserve or under a Williamson Act Contract. As previously discussed, the Project site is currently developed and consists of a vacant retail building and associated surface parking lot and does not contain any farmland, forest land, or timberland, nor is the site located adjacent to any land containing these uses. As these uses are not located on or within the vicinity of the Project site, no impacts would occur to agricultural or forestry resources under development of the proposed Project or under Alternative 3. Therefore, potential impacts under the Retail Development Alternative would be similar to those of the proposed Project.
Air Quality
Under Alterative 3, there would be significantly fewer emissions that would impact air quality during site preparation as Alternative 3 would only consist of minor improvements to the existing retail building interior, building exterior, and/or to the associated surface parking lot and landscaping, rather than the demolition and building construction associated with the proposed Project. However, it is anticipated that operational emissions that would impact air quality would City of Riverside
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be greater under Alternative 3 than under the proposed Project as the commercial retail use of Alternative 3 would have a higher trip generation rate (e.g., repeated customer vehicle trips to and from the retail business, truck trips to deliver/restock ret ail merchandise/products) than the proposed Project’s residential uses. The higher trip generation rate for the commercial retail use under Alternative 3 would in turn result in a higher generation of vehicle emissions during operations. Therefore, potential air quality impacts would be greater under Alternative 3 than the proposed Project.
Biological Resources
As analyzed in DEIR Section 5.4, Biological Resources (DEIR, p. 5.4-1), 15 special-status plant species have been recorded in the USGS Riverside East quadrangle, in which the Project site is located. The Project site consists of an existing vacant retail building and associated surface parking lot, which are site conditions that have eliminated the Project site’s ability to provide suitable habitat for special -status plant species. Additionally, 29 special -status wildlife species have reported occurrences within the USGS Riverside East quadrangle. A review of the habitat requirements of each of the special-status wildlife species indicates that the Project site does not contain nor would be able to provide potentially suitable habitat for any of these wildli fe species.
While the site contains trees that could provide potentially suitable habitat for nesting birds, these trees would be left in place under the development of the proposed Project and, it is assumed, under the Retail Development Alternative. In addition, as the site is paved/developed, it does not contain nor would it be able to provide suitable conditions or habitat for features such as wetlands, vernal pools, or riparian or riverine resources. As the site does not contain nor would it be able to support any sensitive biological resources, potential impacts to biological resources would be less than significant under either the proposed Project or the Retail Development Alternative.
Therefore, potential impacts to biological resources under Alternative 3 would be similar to those associated with the proposed Project.
Cultural Resources
As discussed in DEIR Section 5.5, Cultural Resources (DEIR, p. 5.5-1), the City may consider the Project area to have a moderate to high sensitivity for potential impacts to cultural resources.
Additionally, while the proposed Project’s Cultural Resources Assessment did not report the presence or discovery of human remains, construction and/or ground-disturbing activities could have the potential to disturb or destroy previously undiscovered human remains, including those interred outside of formal cemeteries. Under Alternative 3, the existing previously developed Project si te would not undergo ground -disturbing construction activities. Rather, only minor improvements would be made to interior of the existing retail building, exterior of the building, and/or to the associated surface parking lot and landscaping in preparation of hosting a long-term retail tenant. Therefore, potential impacts to cultural resources under Alternative 3 would be less than those associated with the proposed Project.
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Energy
RPU would still supply electricity and SoCalGas would still supply natural gas under Alternative
3. Under Alternative 3, construction energy consumption is anticipated to be less than that of the proposed Project as only minor improvements would be made to interior of the existing retail building, exterior of the building, and/or to the associated sur face parking lot and landscaping in preparation of hosting a long-term retail tenant. Additionally, the operational energy consumption of the Retail Development Alternative is anticipated to be less than the proposed Project.
Alternative 3 is anticipated to be mainly a locally serving retail use as the site is located within an area surrounded by residential uses. As outlined in the City’s Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assess ment, local serving retail generally improves the convenience of shopping close to home and has the effect of reducing vehicle travel.
Additionally, it is assumed that the retail development proposed under Alternative 3 would not be a 24-hour retail business and the development would also be required to comply with all applicable energy conservation standards and therefore would have a lower operational energy demand than the proposed Project. Therefore, potential impacts to energy under Alternative 3 would be less than those of the proposed Project.
Geology and Soils
The existing geology and soils conditions of the site would remain the same for both the proposed Project and Alternative 3. As discussed, the Project site is previously developed and consists of a vacant retail building and associated surface parking lot. In contrast to the proposed Project, Alternative 3 would not require any ground- disturbing construction activities; rather, only minor improvements would be made to interior of the existing retail building, exterior of the building, and/or to the associated surface parking lot and landscaping in preparation of hosting a long-term retail tenant. Therefore, Alternative 3 results in fewer ground disturbances that could potentially impact geology and soils resources. Thus, potential impacts to geology and soils under Alternative 3 would be less than those of the proposed Project.
Greenhouse Gas Emissions
Under Alterative 3, there would be significantly fewer GHG emissions during site preparation as Alternative 3 would only consist of minor improvements to the existing retail building interior, building exterior, and/or to the associated surface parking lot and landscaping, rather than the demolition and building construction associated with the proposed Project. However, it is anticipated that operational GHG emissions would be greater under Alternative 3 than under the proposed Project as the commercial retail use of Alternative 3 would have a higher trip generation rate (e.g., repeated customer vehicle trips to and from the retail business, truck trips to deliver/restock retail merchandise/products) than the proposed Project’s residential uses. The higher trip generation rate for the commercial retail use under Alternative 3 would in turn result in a higher generation of vehicle GHG emissions during operations. Therefore, potential air quality impacts would be greater under Alternative 3 than the proposed Project.
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Hazards and Hazardous Materials
As discussed in DEIR Section 5.9, Hazards and Hazardous Materials (DEIR, p. 5.9-1), the proposed Project’s residential density would exceed and be inconsistent with the allowable maximum residential density criteria for MARB/IPA LUCP Compatibility Zone C2, resulting in a significant and unavoidable impact. Alternative 3, Retail Development would include retaining the existing development of the site that remains in accord with the current land use and zoning designations and the Mission Grove Specific Plan. The current retail use is consistent with the commercial density criteria (limits ) in the MARB/IPA LUCP Compatibility Zone C2. Under this alternative, the land use designation and zoning would remain as is and the Project site would be under a CR – SP CR-SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones.
Thus, under Alternative 3, there would not be a residential development in which the residential dwelling unit density could exceed and be inconsistent with the requirements of Compatibility Zone C2. As such, potential impacts regarding hazards and hazardous materials under Alternative 3 would be less than those of the proposed Project.
Hydrology and Water Quality
As discussed in DEIR Section 5.10, Hydrology and Water Quality, expected pollutant sources that could impact water quality resources from the proposed Project include interior drains, indoor/structural pesticide use, landscape/outdoor pesticide use, refuse areas, plazas, sidewalks, and parking lots. While the site preparation and operation of the retail development proposed under Alternative 3 may still include some of these sources (e.g., landscaping/outdoor pesticide use), it is anticipated that it would be to a lesser degree than the proposed Project. As discussed, under Alternative 3, the existing site and existing retail building would be retained, with only minor improvements anticipated for the interior of the retail building, exterior of the building, and/or to the associated surface parking lot and landscaping. It is assumed the existing landscaping established during the development of the retail building/shopping center would be retained under Alternative 3. As it is anticipated that development under Alternative 3 would overall have fewer uses and sources that would impact hydrology and water quality than the residential development proposed under the proposed Project, impacts under Alternative 3 would be less than those of the proposed Project.
Land Use and Planning
As discussed in DEIR Section 5.11, Land Use and Planning (DEIR, p. 5.11-1), the proposed Project’s residential density would exceed and be inconsistent with the allowable maximum residential density criteria for MARB/IPA LUCP Compatibility Zone C2, resulting in a significant and unavoidable impact. Alternative 3, Retail Developm ent, would include retaining the existing development of the site that remains in accord with the current land use and zoning designations and the Mission Grove Specific Plan. Under this alternative, the land use designation and zoning would remain as is and the Project site would be under a CR – SP CR-SP Commercial Retail and Specific Plan (Mission Grove) Overlay Zones. Alternative 3 is anticipated to be consistent with the commercial density criteria (limits) in the MARB/IPA LUCP Compatibility Zone C2 as well.
Alternative 3 would also be consistent with all applicable GP 2025 objectives and policies City of Riverside
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including Policies CCM -11.1, LU- 22.3, LU-22.5, and LU -69.1 related to the MARB/IPA LUCP.
Thus, potential impacts regarding land use and planning under Alternative 3 would be less than those of the proposed Project.
Mineral Resources
As discussed in DEIR Section 5.12, Mineral Resources (DEIR, p. 5.12-1), the Project site has been developed for commercial uses and is not located within or adjacent to areas of known mineral resources that would be of value to the region or State. Additionally, the City’s GP 2025 PEIR determined that there are no specific areas within the City’s boundary or proposed Sphere of Influence Area that have locally important mineral resource recovery sites. As the Project site has already been developed with a retail building and associated surface parking lot, and as the site is not located within or adjacent to areas of known mineral resources, neither the development of the proposed Project nor implementation of Alternative 3 would result in impacts to mineral resources. Therefore, potential impacts to mineral resources under Alternative 3 would be similar to those associated with the proposed Project.
Noise
Under Alternative 3, it is anticipated that noise and/or vibration generated during site preparation would be significantly less than construction noise and vibration generated during the development of the proposed Project. Under the Retail Development Al ternative, only minor changes to the existing retail building’s interior, exterior, and/or to the associated surface parking lot and/or landscaping would occur, rather than the building demolition and building construction that would occur under the propos ed Project. Additionally, the site is situated within an existing shopping center with various existing commercial, retail, and fast -food uses; therefore, it is anticipated that operational noise generated would be similar to the shopping center’s existing uses and would not result in a significant increase to existing noise levels in the Project area.
Therefore, potential noise impacts under Alternative 3 would be less than those associated with the proposed Project.
Population and Housing
The Retail Development Alternative would consist of retaining the existing retail building and associated surface parking lot within the existing shopping center and would include a permanent retail tenant using the existing building for retail uses. As Al ternative 3 would utilize existing commercial retail structures, it would not include development that would cause substantial unplanned population growth. Alternative 3 would not result in displacing any existing people or housing, necessitating the const ruction of replacement housing elsewhere. While potential impacts to population and housing would be less than significant under the proposed Project, because Alternative 3 would not consist of a residential development that would affect population and housing, potential impacts under Alternative 3 would be less than those of the proposed Project.
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Public Services
The Retail Development Alternative would consist of retaining the existing retail building and associated surface parking lot within the existing shopping center and would include a permanent retail tenant using the existing building for retail uses. As Al ternative 3 would operate within an area zoned for commercial retail uses, it is not anticipated that reinstating these uses via a permanent retail tenant at the existing retail building would result in an increased demand in public services, such as fire protection, police protection, parks, or libraries, such that new/additional facilities would need to be constructed. While potential impacts to public services under the proposed Project would be less than significant, because Alternative 3 would not intr oduce any new/additional uses to the Project site than the commercial retail uses the site was previously developed for, potential impacts to public services under Alternative 3 would be less than those of the proposed Project.
Recreation
Alternative 3 would consist of retaining the existing retail building and associated surface parking lot within the existing shopping center and would include a permanent retail tenant using the existing building for retail uses. As Alternative 3 includes a commercial retail use, it would not increase population or associated use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration would occur, nor would the commercial use require the construction or expansion of recreational facilities. While potential impacts regarding recreation under the proposed Project would be less than significant, because Alternative 3 would not introduce any new residential use and associated population growth, potential impacts to recreation under Alternative 3 would be less than those of the proposed Project.
Transportation
As discussed in DEIR Section 5.17, Transportation (DEIR, p. 5.17-1), the proposed Project would result in significant and unavoidable impacts regarding VMT. While mitigation measures are proposed, implementation of the measures would not decrease the proposed Project’s impacts to VMT to a less than significant level. Alternative 3 is anticipated to be mainly a locally serving retail use as the site is located within an area surrounded by residential uses. As outlined in the City’s Traffic Impact Analysis Gu idelines for Vehicle Miles Traveled and Level of Service Assessment, local serving retail generally improves the convenience of shopping close to home and has the effect of reducing vehicle travel. Therefore, it is anticipated that potential impacts to transportation under Alternative 3 would be less than those associated with the proposed Project.
Tribal Cultural Resources
Construction of the proposed Project would involve ground-disturbing activities with the potential to unearth or adversely impact previously unidentified tribal cultural resources. In contrast, Alternative 3 would include only minor improvements to the exi sting retail building’s interior, exterior, and/or associated surface parking lot and/or landscaping. Thus, under Alternative 3, there would be significantly reduced potential of adversely impacting unidentified tribal cultural City of Riverside
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resources. As such, potential impacts to tribal cultural resources under Alternative 3 would be less than those of the proposed Project.
Utilities and Service Systems
RPU would provide water service and the City’s Public Works Department would provide sewer service to the development under Alternative 3, as with the proposed Project. Therefore, the current and projected available water supplies would be the same under Alternative 3 as under the proposed Project. Based on the water demand projections in the City for the proposed Project, projected water supplies were determined to be enough for the projected water demand of the proposed Project. It is anticipated that the commercial retail uses under Alternative 3 would have less water demand and generate less wastewater than the proposed Project as the proposed Project would require water and sewer service for numerous residential tenants rather than for the single retail tenant for the existing building under Alternative 3. Therefore, potential impacts to utilities and service systems under Alternative 3 would be less than those associated with the proposed Project.
Wildfire
As discussed in DEIR Section 5.20, Wildfire (DEIR, p. 5.20-1), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ).
Additionally, under current site conditions, which would be retained under Alternative 3, the site and its proposed retail uses would not expose people or structures to significant risks, such as downslope or downstream flooding or landslides, or to a significant risk of loss, injury, or death involving wildland fires. Alternative 3 would utilize the existing, currently vacant retail building and associated surface parking lot to host a permanent retail tenant, which would be a use similar to the surrounding shopping center. Alternative 3 would operate within a previously developed site that is not located within a VHFHSZ and that does not feature site conditions that would expose people or structures to the aforementioned significant risks. Therefore, potential impacts related to wildfire under Alternative 3 would be simil ar to those associated with the proposed Project. (DEIR p. 7.0-15, -22)
Relationship to Project Objectives
Alternative 3, the Retail Development Alternative, proposes retaining the existing 104,231- square-foot retail building and associated surface parking lot with minor improvements for a new permanent retail tenant. While this alternative would be consistent with the current land use and zoning designations, it would not meet the majority of the proposed Project’s objectives.
This alternative does not support the objective of providing high- quality residential development (Project Objective 1) . Instead of delivering much- needed housing units, Alternative 3 would continue to dedicate the site to retail uses, failing to contribute to the City’s housing stock or assist in meeting the City’s RHNA allocations (Project Objectives 2 & 3). The Project's objective of increasing the type and amount of available housing would not be met, as no residential development is proposed under this alternative.
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Although Alternative 3 would continue the commercial use of the site, it does not support the goal of using land resources more efficiently by providing infill redevelopment on an underutilized vacant site (Project Objective 4) . The objective of transforming an underutilized vacant site through well-planned infill redevelopment would not be met. In contrast, the proposed Project would bring new housing units to the area, optimizing the use of the land for residential purposes and contributing to the City’s growth and housing goals.
This alternative would also fail to advance the City’s RRG-CAP, which aims to promote green building practices and sustainable development methods (Project Objective 6). The retention of the aging retail building with only minor improvements would not incorporate the modern green building practices that the proposed Project would employ, such as energy -efficient design and construction techniques, further diminishing the site’s potential to contribute to sustainability goals.
Furthermore, Alternative 3 would not create the mixed- use environment envisioned for the site, nor would it encourage walkability or provide enhanced residential architecture (Project Objectives 1 &7). The continued use of the site for retail would offer little to no improvement to the walkability of the area or promote a more cohesive integration of mixed- use development (Project Objective 8).
State CEQA Guidelines Section 15126.6(f)(1) states that factors such as site suitability and economic viability may be considered when assessing the feasibility of alternatives. While Alternative 3 would retain the existing retail structure and align with the current zoning, it would not meet the key Project objectives of providing high- quality housing, maximizing the site’s residential potential, or using land resources efficiently. Additionally, it would not contribute to the City’s long-term goals for housing, climate action, or sustainable development.
Thus, although Alternative 3 would have fewer construction impacts, it would not fulfill any of the Project’s objectives and is not considered feasible in achieving the overall goals of the proposed development.
Finding
The City Council finds that Alternative 3 would result in fewer environmental impacts related to construction activities, such as air quality, greenhouse gas emissions, and noise, but would generate greater operational impacts related to transportation and vehicle emissions due to higher trip generation. The City Council rejects Alternative 3 as a proposed Project alternative on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) inability to avoid environmental impacts; (2) failure to meet the Project's objectives (Project Objectives 1-8), including providing high-quality residential development and addressing the City’s housing needs; and (3) infeasibility, as this alternative would continue the underutilization of the site for retail purposes and not contribute to the City’s goals for housing and sustainable land use.
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Alternative 4 – Proposed Project at Off-Site Location
This discussion analyzes the proposed 347 residential apartment project at an off -site location.
This alternative does not include a specific off -site location; however, it is assumed for the purposes of this analysis that it would consist of redevelopment of a site similar in size and of a vacant or underutilized building or buildings within the City of Riverside. This development focuses on infill of abandoned or underutilized space. Alternative sites were not considered for this project and thus, there are no specific off -site locations that were considered by the applicant to be evaluated under this alternative. It is assumed for the purposes of this analysis that the off -site alternative location would also require a General Plan Amendment and a Zone Change from CR- Commercial to Mixed-Use Urban (MU-U), as with the proposed Project.
Impact Analysis for Alternative 4
Aesthetics
Under Alternative 4 (DEIR, p. 1.0-5), the proposed Project’s 347 dwelling units would be constructed at another project site of similar size within the City of Riverside limits. As discussed in DEIR Section 5.1, Aesthetics, the Project site is located in a highly urbanized area, consisting of commercial and retail uses as well as single- and multi-family residential uses. The Project site is not a scenic vista, nor are there any State scenic highways or City designated Scenic or Special Boulevards or Parkways in the vicinity of the Project site. The Proposed Project, at Off -Site Location would be constructed with the same design elements of the proposed Project, and the project design and landscaping of Alternative 4 would similarly be required to comply wit h the City’s Design Guidelines and Zoning Code. As with the proposed Project, Alternative 4 would not result in substantial light or glare. While impacts to aesthetics would be less than significant under the proposed Project, because Alternative 4 would result in similar scale and architectural style residential development, impacts under Alternative 4 would be similar to those of the proposed Project.
Agriculture and Forestry
As discussed in DEIR Section 5.2, Agriculture and Forestry Resources (DEIR, p. 5.2-1), the Project site is not designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, nor is the Project site located adjacent to any of these farmland designation land uses. Additionally, the Project site is not currently zoned for agricultural use or adjacent to land zoned for agricultural use, nor is the site located within an area affected by a Williamson Act Preserve or under a Williamson Act Contract. As previously discussed, the Project site is currently developed and consists of a vacant retail building and associated surface parking lot and does not contain any farmland, forest land, or timberland, nor is the site located adjacent to any land containing these uses. Similarly, the Alternative 4 location would not be anticipated to be designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, zoned for agricultural use or adjacent to land zoned for agricultural use, or located within an area affected by a Williamson Act Preserve or under a Williamson Act Contract, as the City of Riverside does not have large areas designated or zoned as such. As these uses are not located on or within the vicinity of the Project site, no impacts would occur to agricultural or forestry resources under City of Riverside
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development of the proposed Project or under Alternative 4. Therefore, potential impacts under the Reduced Density Apartment Redevelopment would be similar to those of the proposed Project.
Air Quality
Under Alternative 4, Proposed Project at Off-Site Location, development of the Project site would result in construction and operational emissions that could potentially impact air quality.
Alternative 4 would consist of a multi -family residential developm ent with the same number of dwelling units and would be expected to have the same or similar construction period. As such, potential impacts to air quality under Alternative 4 would be similar to those associated with the proposed Project.
Biological Resources
As analyzed in Section 5.4, Biological Resources (DEIR, p. 5.4-1), 15 special-status plant species have been recorded in the USGS Riverside East quadrangle, in which the Project site is located.
The Project site consists of an existing vacant retail building and associated surface parking lot, which are site conditions that have eliminated the Project site’s ability to provide suitable habitat for special- status plant species. Additionally, 29 special -status wildlife species have reported occurrences within the USGS Riverside East quadrangle. A review of the habitat requirements of each of the special -status wildlife species indicates that the Project site does not contain nor would be able to provide potentially suitable habitat for any of these wildlife species. Similarly, the Alternative 4 location would already have been developed and is not anticipated to be a site that contains or is able to support any sensitive biological resources. Therefore, potential impacts to biological resources under Alternative 4 would be similar to those associated with the proposed Project.
Cultural Resources
Development of the Proposed Project at Off -Site Location Alternative would require site preparation and grading of a similar size, grading limits, and development footprint to the proposed Project. Thus, ground- disturbing activities with the potential to unearth or adversely impact previously undiscovered archaeological resources and/or human remains would still occur under Alternative 4. Therefore, potential impacts to cultural resources under Alternative 4 would be similar to those associated with the proposed Project.
Energy
Under the Proposed Project at Off-Site Location, electricity and natural gas would still be supplied by Riverside Public Utilities (RPU) and Southern California Gas Company (SoCalGas), respectively. It is anticipated that construction fuel consumption under Alternative 4 would be similar to that of the proposed Project for construction equipment, vendor trips, and worker trips.
Similar to the proposed Project, the project under Alternative 4 would comply with applicable Title 24 Building Standards for multi -family residential developments, including incorporating solar panels and providing electric vehicle (EV) charging stations. It is additionally anticipated that City of Riverside
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similar to the proposed Project, the project under Alternative 4 would utilize all electric appliances and only utilize natural gas for project amenities/common spaces. As the Proposed Project at Off- Site Location would be a similar scale residential development, with the same number of dwelling units, it is anticipated that the project under Alternative 4 would consume similar energy resources during both construction and operations as the proposed Project. Therefore, potential impacts to energy resources under Alternative 4 would be similar to those associated with the proposed Project.
Geology and Soils
As geology and soils conditions are site specific, at the Proposed Project at Off-Site Location they could be similar to or differ from the proposed Project site. Alternative 4 would still include ground- disturbing and grading construction activities, wit h an anticipated similar overall construction period. As both the proposed Project and Alternative 4 would be required to comply with the CBC, RMC, and recommendations made by the geotechnical engineer, the potential impacts to geology and soils under Alternative 4 would be similar to those of the proposed Project.
Greenhouse Gas Emissions
Under Alternative 4, Proposed Project at Off -Site Location, development would result in construction and operational greenhouse gas (GHG) emissions. As Alternative 4 would consist of a multi -family residential development with the same number of dwelling units and the construction period is expected to be the same, Alternative 4 would result in similar vehicle GHG and construction emissions. As such, potential impacts regarding GHG emissions under Alternative 4 would be similar to those associated with the proposed Project.
Hazards and Hazardous Materials
Proposed Project at Off-Site Location is not anticipated to be in a compatibility zone of an airport where density criteria would apply. Therefore, as Alternative 4 would allow for a residential development that would not be inconsistent with an airport land use plan, potential impacts regarding hazards and hazardous materials would be less than those associated with the proposed Project.
Hydrology and Water Quality
Similar to the proposed Project, expected pollutant sources that could impact water quality resources under Alternative 4 would include interior drains, indoor/structural pesticide use, landscape/outdoor pesticide use, refuse areas, plazas, sidewalks, and parking lots. While the proposed Project’s potential impacts to hydrology and water quality would be the same, and they would be required to comply with the same regulations protecting water quality, potential impacts under Alternative 4 would be similar to those associated with the proposed Project.
Land Use and Planning
Proposed Project at Off-Site Location is not anticipated to be in a compatibility zone of an airport where density criteria would apply. Therefore, Alternative 4 would allow for a residential City of Riverside
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development that would not be inconsistent with an airport land use plan. Therefore, potential impacts regarding land use and planning under Alternative 4 would be less than those associated with the proposed Project.
Mineral Resources
Proposed Project at Off-Site Location is not anticipated to be located within or adjacent to areas of known mineral resources that would be of value to the region or State. Additionally, the City’s GP 2025 PEIR determined that there are no specific areas within the City’s boundary or proposed Sphere of Influence Area that have locally important mineral resource recovery sites. As the Project site has already been developed with a retail building and associated surface parking lot, and as the site is not located within or adjacent to areas of known mineral resources, neither the development of the proposed Project nor implementation of Alternative 4 would result in impacts to mineral resources. Therefore, potential impacts to mineral resources under Alternative 4 would be similar to those associated with the proposed Project.
Noise
Similar to the proposed Project, development of the Proposed Project at Off-Site Location would result in construction related noise and vibration as well as operational noise. It is anticipated that because Alternative 4 would consist of a similar scale and density development, the construction period for Alternative 4 would be correspondingly similar than that of the proposed Project, resulting in similar construction generated noise and vibration. The proposed Project’s potential construction, vibration, and operational noise impacts would be less than significant, and because Alternative 4 would consist of a similar residential development, potential noise impacts under Alternative 4 would be similar to those of the proposed Project.
Population and Housing
As discussed in DEIR Section 5.14, Population and Housing (DEIR, p. 5.14-1), development of the proposed Project would not cause substantial unplanned population growth, nor would the proposed Project result in displacing any existing people or housing, necessitating the construction of replacement housing elsewhere. Similar to t he proposed Project, the Proposed Project at Off-Site Location Alternative would consist of an infill redevelopment project that would provide multi-family residential uses. The proposed Project would result in less than significant impacts related to population and housing, and as Alternative 4 would provide the same number of dwelling units as the proposed Project, potential impacts regarding substantial unplanned population growth would be the same under Alternative 2. Therefore, potential impacts regarding population and housing under Alternative 2 would be similar to those of the proposed Project.
Public Services
As discussed in DEIR Section 5.15, Public Services (DEIR, p. 5.15-1), the proposed Project’s 347-unit multi-family residential development would not result in an increased demand in public services, such as fire protection, police protection, parks, or libraries, such that new/additional facilities would need to be constructed. Alternative 4 proposes the same density apartment City of Riverside
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redevelopment as the proposed Project. While potential impacts to public services under the proposed Project would be less than significant, Alternative 4 would also be less than significant on the demand for public services. Impacts to public services under Alternative 2 would be similar to those of the proposed Project.
Recreation
As discussed in DEIR Section 5.16, Recreation (DEIR, p. 5.16-1), the proposed Project’s 347-unit multi-family residential development would not substantially increase population that would increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration would occur. Additionally, the proposed Project would not require the construction or expansion of recreational facilities. In comparison to the proposed Project, Alternative 4 proposes the same density apartment redevelopment. While potential impacts relating to recreation under the proposed Project would be less than significant, Alternative 4 would also be less than significant. Impacts regarding recreation under Alternative 4 would be similar to those of the proposed Project.
Transportation
As discussed in DEIR Section 5.17, Transportation (DEIR, p. 5.17-1), the proposed Project would result in significant and unavoidable impacts regarding VMT. While mitigation measures are proposed, implementation of the measures would not decrease the proposed Project’s impacts to VMT to a less than significant level. The Proposed Project at Off -Site Location would consist of the same 347-unit multi-family residential development as the proposed Project. Alternative 4 would accordingly result in similar vehicle miles travelled, resulting in significant and unavoidable impacts regarding VMT. Therefore, potential impacts to transportation under Alternative 4 would be similar to those of the proposed Project.
Tribal Cultural Resources
Similar to the proposed Project, development of the Proposed Project at Off -Site Location Alternative would require site preparation and grading. Alternative 4 would consist of a similar scale residential project, grading limits and development footprint as the proposed Project. Thus, while ground- disturbing activities with the potential to unearth or adversely impact previously undiscovered tribal cultural resources would still occur under Alternative 4, resulting in a similar area of ground disturbance. Therefore, potential impacts to tribal cultural resources under Alternative 4 would be similar to those associated with the proposed Project.
Utilities and Service Systems
As discussed in DEIR Section 5.19, Utilities and Service Systems (DEIR, p. 5.19-1), construction and operation of the proposed Project would result in an increased demand for utility services, such as water supply, wastewater treatment, and solid waste services. This would be a similar case for the construction and operation of Alternative 4. As potential impacts to utilities and service systems would be less than significant under the proposed Project, they would also be for City of Riverside
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Alternative 4. Potential impacts to utilities and utility services under Alternative 4 would be similar to those of the proposed Project.
Wildfire
As discussed in DEIR Section 5.20, Wildfire (DEIR, p. 5.20-1), the proposed Project site is not located within an area or land classified as a Very High Fire Hazard Severity Zone (VHFHSZ) nor would the proposed Project expose people or structures to significant risks, such as downslope or downstream flooding or landslides, or to a significant risk of loss, injury, or death involving wildland fires. Similar to the proposed Project, the Proposed Project at Off -Site Location Alternative would be expected to consist of an infill redevelopment project within a previously developed site that is not located within a VHFHSZ and that does not feature site conditions that would expose people or structures to the aforementioned significant risks. Therefore, potential impacts related to wildfire under Alternative 2 would be similar to those associated with the proposed Project. (DEIR p. 7.0-22, -27)
Relationship to Project Objectives
Alternative 4, the Proposed Project at Off -Site Location, assumes that the proposed 347-unit residential apartment project would be constructed at a different site of similar size within the City of Riverside. This alternative does not specify an exact off -site location but assumes that the project would involve redeveloping a vacant or underutilized site of similar size.
While this alternative could still provide high- quality residential development in the City of Riverside, it may not necessarily be located in close proximity to existing amenities and transit corridors (Project Objective 1), as is the case with the propos ed Project site. The convenience and access to services, which are integral to the Project’s objective of providing a transit-oriented, walkable environment, may not be available at an off-site location. Without a specific site, it cannot be determined if this objective could be partially or fully met.
Similarly, while Alternative 4 would still provide 347 residential units and contribute to meeting the City’s housing needs, the off -site location may not maximize the residential potential of the site (Project Objective 3) as efficiently as the proposed P roject does. The current Project site represents an underutilized infill site, which is an optimal location for high- density residential development. An alternative site may not provide the same efficient use of land resources.
Without a specific site, it cannot be determined if this objective could be partially or fully met.
Additionally, Alternative 4 may not support the objective of creating a mixed-use environment that encourages walkability. The success of mixed-use environments relies heavily on the context and surrounding uses, and there is no guarantee that an off -site location would integrate well into a mixed-use framework. Without the specific location, it cannot be determined if the project objective of creating a mixed-use environment encouraging walkability (Project Objective 7) could be partially or fully met.
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State CEQA Guidelines Section 15126.6(f)(1) allows for consideration of factors such as site suitability and economic viability. In this case, the off-site alternative could theoretically meet many of the same objectives as the proposed Project, but without a specific location, there are uncertainties regarding site suitability, land use efficiency, and overall feasibility. Additionally, the off-site location may not provide the same strategic advantages in terms of transit access, walkability, and integration with existing land uses, limiting its ability to meet most or all the Project’s objectives. The City is not aware of another site that is comparable in size and is currently available for redevelopment, the developer does not own or control such another site, nor is it certain the developer can acquire such a site.
Finding
The City Council finds that Alternative 4, without a specific location it cannot be determined if there would be less environmental impacts than the proposed Project. The City is not aware of another site that is comparable in size and is currently available. The City Council rejects Alternative 4 as a proposed Project alternative on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) inability to avoid environmental impacts; (2) failure to partially or fully meet most of the Project's objectives; and (3) infeasibility, as no specific alternative site is currently available.
Alternatives Rejected from Further Consideration
Section 15126.6(c) of the State CEQA Guidelines specify 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. The following alternatives were considered and rejected by the City.
There are two other former K-Mart retail stores and one former Sears retail store within the City of Riverside that have closed and remain vacant. They are located at the following:
• Former K-Mart retail store at the northwest corner of Iowa Avenue and 3 rd/Blaine Street.
The site is within a shopping center that also has a Stater Brothers grocery store and other smaller retail stores. A mixed -use student housing is proposed for this site, which is in close proximity to University of California, Riverside (UCR). • Former K-Mart retail store at the southeast corner of Arlington Avenue and Van Buren Boulevard. This site is currently being redeveloped with commercial and retail uses and has a Stater Brothers grocery store as the anchor.
• Former Sears Department store at the northeast corner of Arlington Avenue and Streeter Avenue. A mixed use development is currently proposed with multi -family residential, an Aldi grocery store, and other commercial and retail spaces.
These alternative Project locations are not feasible as they are currently owned by others that are pursuing entitlements with the City or have already obtained entitlements from the City for these City of Riverside
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proposed redevelopment projects. Therefore, these alternative off -site potential redevelopment locations were eliminated from further consideration. (DEIR p. 7.0-27)
Environmentally Superior Alternative
CEQA requires the identification of the environmentally superior alternative among the options studied. The environmentally superior alternative must be an alternative to the proposed Project that reduces some of the environmental impacts of the proposed project, regardless of the financial costs associated with that alternative. Identification of the environmentally superior alternative is an informational procedure and the alternative identified as environmentally superior may not be the one that best meets the goals or needs of the proposed project.
Table 7.0 -1 - Comparison of Alternatives Matrix, indicates whether each alternative’s environmental impact is reduced, increased, or similar compared to that of the proposed Project for each of the issue areas studied. Based on the alternative’s analysis p rovided above, Alternative 1: No Project/Redevelopment Alternative, would be the environmentally superior alternative. The No Project/Redevelopment Alternative would either avoid or lessen the severity of all significant impacts of the proposed project, as nothing would be constructed. However, the No Project/ No Redevelopment Alternative would not fulfill the objectives of the proposed project.
When the “No Project/Development” alternative is determined to be environmentally superior, State CEQA Guidelines also requires identification of the environmentally superior alternative among the development options. Of the other alternatives evaluated in this EIR, Alternative 2:
Reduced Density Apartment Redevelopment and Alternative 3: Retail Development are determined to be the environmentally superior alternatives, however; they are not consistent with the proposed Project’s Objectives and Goals. Alternative 4: Proposed Project at Off-Site Location, assuming that it could be located on a site that was previously developed and is currently vacant and is also not located in a compatibility zone that restricts residential development, would also be an environmentally superior alternative. This alternative would be consistent with the proposed Project’s Objectives and Goals. However, it is unknown if such a property of similar size exists in the City and is currently available for purchase. (DEIR p. 7.0 -28) While the environmentally superior alternatives present fewer environmental impacts, the proposed Project remains the only feasible alternative to comply with applicable regulatory requirements and meet all of the project objectives, ensuring alignment with local, State, and federal laws, including the City ’s GP 2025, Riverside Municipal Code, and other relevant regional planning documents.
FINDINGS REGARDING NO NEED FOR RECIRCULATION
Section 3 of the EIR (DEIR, p. 3.0-1) includes the comments received on the DEIR and responses to those comments. The focus of the responses to comments is on the disposition of significant environmental issues as raised in the comments, as specified by CEQA Guidelines Section 15088(b), as wel l as to provide clarification regarding environmental issues raised. Volume II (DEIR) and Volume III (DEIR Appendices) of the Final EIR also incorporates information obtained after publication of the DEIR and revisions made for clarification and to provide additional City of Riverside
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detail. The comments received did not raise any concerns regarding the adequacy of the DEIR and simply presented minor revisions and clarifications that have been thoroughly addressed.
CEQA Guidelines 15088.5 provides that recirculation of an EIR is only required in limited circumstances where new or substantially increased significant impacts are identified; where a new feasible mitigation measure or alternative is needed to reduce or avoid significant impacts but is not adopted; or where the EIR circulated for review was so fundamentally inadequate that environmental review was precluded. However, Section 15088.5 confirms that “recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” It is for those reasons, that recirculation is the exception, not the rule. ( Laurel Heights Improvement Ass’n of S.F.v. Regents of Univ. of Cal. (1993) 6 Cal.4
th 1112, 1132.)
Here, the minor revisions shown in the Final EIR merely corrects spelling and minor errors through the Introduction, Project Description, Air Quality, Land Use and Planning, Noise, Public Services, Tribal Cultural Resources, and the Other CEQA Topics section within the DEIR. These corrections in the errata do not identify or demonstrate any new significant impacts or substantially increased environmental impacts. Similarly, no new mitigation measures for new significant impacts or alternatives are necessary because no new significant impacts exist. Thus, recirculation is not required under Guidelines 15088.5.
Therefore, the City Council finds that responses to comments made on the Draft EIR and revisions to the Final EIR merely clarify, amplify or make insignificant modifications to the analysis presented in the EIR document and do not trigger the need to recirculate per CEQA Guidelines Section 15088.5(b). Revisions made to the Draft EIR are shown throughout the Final EIR in strikethrough and underline text to denote deletions and additions, respectively.
STATEMENT OF OVERRIDING CONSIDERATIONS
For each significant impact of the project identified in the EIR, the lead agency must find, based on substantial evidence, that either a) the project has been changed to avoid or substantially reduce the magnitude of the impact; b) changes to the project are within another agency’s jurisdiction and such changes have or should be adopted; or c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (CEQA Guidelines Section 15091). If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision.
The City of Riverside adopts and makes this statement of overriding considerations concerning the project’s significant and unavoidable impacts to explain why the project’s benefits override and outweigh its unavoidable impacts. In the City’s judgment, the project and its benefits outweigh its potentially significant vehicle miles traveled and impacts. The following statement identifies the specific reasons why, in the City’s judgment, the benefits of the project outweigh its unavoidable significant effect. Any one of these reasons, standing along, is sufficient to justify approval of the City of Riverside
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project, and each and every one of the project’s benefits outweighs each and every one of the potentially significant and unavoidable impacts both individually and collectively. Thus, even if one or more overriding considerations was no longer supported by substantial evidence, the City would stand by its determination that each individual reason is sufficient.
The EIR has identified and discussed significant effects that may occur as a result of the project.
As set forth in these CEQA Findings, the City has made a reasonable and good faith effort to eliminate or substantially mitigate the impacts resulting from the project and has made specific findings on each of the projects significant impacts and on mitigation measures and alternatives.
However, the project will result in a significant and unavoidable project -level and cumulative impact as follows.
1. Vehicle Miles Traveled (VMT) Impact. A project would result in a significant project - generated VMT impact if the baseline or cumulative project -generated VMT per capita exceeds 15 percent below the current jurisdictional baseline VMT per capita. Table 5.17- 1 indicates that 85 percent of the jurisdictional baseline VMT per capita for future year 2045 is 13.6. Thus, even with t he assumed maximum 17.7 percent VMT reduction as a result of implementing Project-applicable VMT reduction strategies, the Project’s baseline per capita VMT would still exceed 15 percent below the 2045 jurisdictional baseline VMT per capita, resulting in a significant project -generated VMT impact. The Project VMT impact is therefore significant and unavoidable. (DEIR, p. 5.17-23)
2. Cumulative Vehicle Miles Traveled (VMT) Impact. The planned and pending projects near the Project site, listed in Ta ble 4.0-1 of this EIR, include residential, commercial, distribution warehouse, and Meridian Specific Plan – West Campus Upper Plateau Project with warehouses for high- cube fulfillment and cold storage, business park office, warehouse, and mixed-use buildings, retail, and park (active and public). These planned and pending projects would also increase VMT in the City. Cumulatively, the Project VMT impact is therefore significant and unavoidable. (DEIR, p. 5.17-23)
3. Hazards Impact/ Inconsistency with 2014 MARB/IPA LUCP . The Project would be consistent with MARB/IPA LUCP Compatibility Zone C2’s non- residential density, height of structures, glare, electrical interference and there would be no safety issues related to these topics. However, the Project would be inconsistent with the allowable maximum residential density criteria for the Compatibility Zone C2. Due to the inconsistency of the maximum residential density, the project would result in a significant and unavoidable impact. There are no feasible mitigation measures that would reduce impacts related to inconsistency with the residential density criteria. (DEIR, p. 5.9-22)
4. Land Use and Planning Impacts. The Project would be consistent with the RMC, Titles 7, 16, 17, 19, and 20, the Mission Grove Specific Plan and General Plan 2025 land use designation and Housing Element. The Project would be consistent with all applicable GP 2025 objectives and policies except for Policies CCM-11.1, LU-22.3, LU-22.5 and LU-69- 1 related to the MARB/IPA LUCP, in which the Project would be partially consistent and partially inconsistent . As the Project’s projected density would exceed the MARB/IPA LUCP Zone C2 residential density criteria of 6.0 dwelling units per acre and thus would City of Riverside
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also be partially inconsistent with Policies CCM -11.1, LU -22.3, LU -22.5, and LU -69.1 related to the MARB/IPA LUCP, the Project would result in a significant and unavoidable impact. (DEIR, p. 5.11-63 - 5.11-64)
In accordance with CEQA Guidelines Section 15093, and having reduced the adverse significant environmental effects of the project to the extent feasible, having considered the entire administrative record on the project, and having weighed the benefits of the project against its unavoidable adverse impacts after mitigation, the City hereby finds that the following legal, economic, social, environmental, and other benefits of the project outweigh its unavoidable adverse impacts and render them acceptable bas ed upon the following considerations. Each benefit identified below constitutes an overriding consideration warranting approval of the project, independent of the other benefits, despite each and every unavoidable impact, and each of these benefits are supported by the substantial evidence contained in the Draft and Final EIRs, the Project plans, the City’s conditions, and elsewhere in the administrative record.
1. All feasible mitigation measures have been imposed to lessen project impacts to less than significant levels; and furthermore, alternatives to the Project are infeasible because while they have similar or less environmental impacts, they do not provide the benefits of the Project, or are otherwise socially or economically infeasible when compared to the Project, as described in this Facts, Findings and Statement of Overriding Considerations.
2. The Project would develop underutilized land that has been planned as part of the Mission Grove Specific Plan, a master -planned development for industrial and residential land uses, since 1985 , that maximizes the use of the site, and that responds to the current housing shortage. The Project involves amending the Mission Grove Specific Plan to allow for mixed -use development. This amendment will establish clear standards for integrating residential and commercial uses in a way that enhances both the built environment and the surrounding community. The Specific Plan Amendment creates a cohesive framework that will guide future development, ensuring that housing, retail, and service uses complement each other, fostering a dynamic and livable urban environment. This approach enhances the synergy between different land uses, contributing to the City's long-term planning vision.
3. The Project will i ncrease the type and amount of housing available in the City of Riverside, consistent with the goals of the City's Housing Element. In the 2021-2029 Housing Element Cycle, the City of Riverside’s RHNA allocation is a minimum of 18,415 new housing units. The previously adopted Housing Element cycle covering the 2013 - 2021 period included a RHNA allocation of 10,025 units, of which only a small portion were built during the last seven years. The increase in the City’s RHNA housing number is reflective of the State’s current housing crisis, due in part to the difficulty of enabling the construction of new homes to keep up with the need for them. In order to ensure the City can safely meet its minimum, the City will need to identify space for approximately 24,000 City of Riverside
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new homes for the 2021 - 2029 Cycle. This Project has the opportunity to help fulfill the City’s RHNA requirement with its residential use, along with promoting growth and stability in the area by providing a total of 347 proposed units of multi-family housing. The Project directly addresses the City’s housing goals by increasing the quantity and variety of housing in a way that is compatible with the local urban fabric.
4. The Project will provide high -quality residential development, consisting of 347 apartment units, close to existing amenities and transit corridors. The Project will provide 347 residential units in a well -planned development located near key transit corridors, including major roads and bus routes, within the City of Riverside. Regional access to the Project site is provided via Interstate 215 from Alessandro Boulevard ramps located approximately 2 miles to the east. Further, public transportation is provided by Routes 20 and 22, which travel along Alessandro Boulevard and Mission Grove Parkway in the Project area. Placement of this Project near these various transit corridors reduces residential vehicle miles traveled through the surrounding neighborhoods, ther eby alleviating traffic congestion associated within the area and associated greenhouse gas emissions. This location allows future residents to have convenient access to shopping, schools, parks, and public transit options, reducing their dependence on private vehicles.
Proximity to amenities fosters a sense of community, encourages a pedestrian- friendly lifestyle, and reduces the environmental footprint associated with long commutes. By situating housing in close proximity to transit, the Project supports the City's goals for sustainable growth and better urban planning.
5. The Project will create a mixed- use environment encouraging walkability. The Project’s design emphasizes walkability by creating safe, pedestrian- friendly pathways that connect residents to local amenities and public transit. Residences within the development have multiple pedestrian connections with the commercial component of the site and to the signalized intersection for additional commercial amenities and conveniences to the east of the Project site. The inclusion of well-designed public spaces and walkways within the development encourages residents to walk or bike rather than rely on vehicles for short trips. This design feature not only promotes a healthier lifestyle but also helps reduce traffic congestion and associated emissions. By fostering a walkable environment, the Project contributes to the City’s goals of reducing VMT and enhancing overall quality of life. Additionally, residential developments typically generate less VMT rather than commercial uses, as residents make fewer frequent trips.
6. The Project will assist the City of Riverside with implementing its Climate Action Plan by replacing older building construction with newer and more green building practices and other sustainable development methods. The Project will replace the aging, vacant retail structure with modern, energy -efficient buildings that incorporate sustainable development practices. By adhering to green building standards, including energy-efficient materials, solar energy systems, and electric vehicle (EV) charging City of Riverside
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stations, the Project aligns with the City’s RRG -CAP goals. These measures will reduce the Project’s carbon footprint, minimize energy consumption, and contribute to the City’s broader efforts to combat climate change. By promoting sustainable development, the Project sets an example of responsible urban growth that protects environmental resources for future generations.
7. The Project will maximize the residential potential of t he site to assist the City of Riverside in meeting project housing demand as part of the City's housing needs and growth projections. The Project site, currently a 9.92-acre underutilized and vacant retail space, represents a prime opportunity for high- density residential development. By maximizing the site’s residential potential, the Project will significantly contribute to the City’s housing needs and growth projections. The 347-unit development optimizes the use of land, addressing the critical shortage of available housing within the City and supporting its long-term population and growth goals. The Project’s scale and design demonstrate a commitment to accommodating growth while maintaining a high standard of living for future residents.
8. The Project will utilize the land more efficiently by providing a well -planned, infill redevelopment on an underutilized vacant site ( a former K-Mart retail store that closed in 2020). The Project exemplifies efficient land use by transforming a former retail site, which has been vacant since 2020 with only temporary tenants, into a vibrant residential community. Notably, there has been a significant decline in the use of big box retail stores, driven by shifts in consumer behavior toward online shopping and a reduced demand for large retail spaces. This form of infill development uses existing infrastructure, services, and urban land more efficiently than expanding into undeveloped areas, preserving open space and reducing urban sprawl. The redevelopment will breathe new life into a neglected portion of the City, creating economic and social benefits while maintaining a smaller environmental footprint. The Project aligns with the City's broader goals of smart growth and sustainable urban development.
These findings are supported by substantial evidence and the data to support these overriding considerations are found throughout the FEIR, the supporting comments and responses section of the FEIR, and by information throughout the administrative record.
MITIGATION MONITORING AND REPORTING PROGRAM
The City of Riverside finds that a Mitigation Monitoring and Reporting Program (MMRP) for the Mission Grove Apartments Project has been prepared for the proposed Project and hereby adopts the MMRP concurrently with these Findings of Fact and Statement of Overriding Considerations (Public Resources Code, §21081.6(a)(1)).
CEQA requires that an agency adopt an MMRP that includes mitigation measures prior to approving a project. The MMRP for the proposed Project has been prepared in compliance with City of Riverside
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the requirements of Section 21081.6 of the California Public Resources Code and Sections 15091(d) and 15097 of the CEQA Guidelines.
The purpose of the MMRP is to ensure the implementation, in accordance with CEQA requirements, of the mitigation measures adopted by the City and under its control. The mitigation measures adopted in the Miss ion Grove Apartments Project EIR Findings are listed in Sections III, IV, and V of this document. The MMRP is bound separately as Section 4 of the Final EIR and hereby incorporated by reference.
MITIGATION MONITORING AND REPORTING PROGRAM
CEQA requires that a reporting or monitoring program be adopted for the conditions of project approval that are necessary to mitigate or avoid significant effects on the environment (Public Resources Code 21081.6). This mitigation monitoring and reporting program is designed to ensure compliance with adopted mitigation measures during project implementation. For each mitigation measure recommended in the Final Environmental Impact Report (Final EIR), specifications are made herein that identify the action required and the monitoring that must occur.
In addition, a responsible agency is identified for verifying compliance with individual conditions of approval contained in this Mitigation Monitoring and Reporting Program (MMRP).
City of Riverside Section 4.0 Arlington Mixed Use Development Project Final EIR Mitigation, Monitoring and Reporting Program FEIR 1
EXHIBIT “B”
Mitigation Monitoring and Reporting Program (MMRP)
4.1 Introduction
This Mitigation Monitoring and Reporting Program (MMRP) has been prepared for use in implementing the mitigation measures that are part of the Environmental Impact Report (EIR) that will be certified by the City of Riverside for the Arlington Mixed Use Project (Project).
The MMRP as reflected in Table 4.0-A, Arlington Mixed Use Development Mitigation Monitoring and Report Program below, has been prepared in compliance with State law and the Arlington Mixed Use Development EIR (State Clearinghouse No. 2023060428) prepared for the Project by the City of Riverside.
The California Environmental Quality Act (CEQA) requires adoption of a reporting or monitoring program for those measures placed on a project to mitigate or avoid adverse effects on the environment (Public Resources Code Section 21081.6). The law states that the reporting or monitoring program shall be designed to ensure compliance during project implementation.
The monitoring program contains the following elements:
1) The mitigation measures are recorded with the action and procedure necessary to ensure compliance. In some instances, one action may be used to verify implementation of several mitigation measures.
2) A procedure for compliance and verification has been outlined for each action necessary. This procedure designates who will take action, what action will be taken and when, and to whom and when compliance will be reported.
3) The program has been designated to be flexible. As monitoring progresses, changes to compliance procedures may be necessary based upon recommendations by those responsible for the program. As changes are made, new monitoring compliance procedures and records will be developed and incorporated into the program.
4.2 Mitigation Monitoring and Responsibilities
As the Lead Agency, the City of Riverside (City) is responsible for ensuring full compliance with the mitigation measures adopted for the proposed Project. The City will monitor and report on all mitigation activities. Mitigation measures will be implemented at different stages of development throughout the project area. If during the course of Project implementation, any of the mitigation measures identified herein cannot be successfully implemented, the City shall be immediately informed, and the City will then inform any affected responsible agencies. The City, in conjunction with any affected responsible agencies, will then determine if modification to the Project is required and/or whether alternative mitigation is appropriate.