Attachment 5 - Consistency Analysis Checklist — Riverside City Council, June 24, 2025 (part 1 of 3)

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City of Riverside Case No. PR-2024-001656
(Tentative Tract Map No. 38921 - SEC La Sierra and Victoria Avenue)

Lead Agency

City of Riverside
3900 Main Street, 3rd Floor.

Riverside, CA 92522
[email protected]

Proposed Project Proponent

Warmington Residential
Southern California Division
3090 Pullman Street
Costa Mesa, CA 92626
[email protected]

CEQA Consultant

11801 Pierce Street, Ste. 200
Riverside, CA 92505
951-710-3010

February 14, 2025

Projects Consistent With Or Implementing a Community Plan or Zoning Exemption

COMMUNITY & ECONOMIC DEVELOPMENTDEPARTMENT PLANNING DIVISION

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TABLE OF CONTENTS

1 BACKGROUND INFORMATION ........................................................................................................ 1 2 INTRODUCTION ................................................................................................................................ 2 3 PROPOSED PROJECT DESCRIPTION ................................................................................................. 4

3.1 PROPOSED PROJECT SITE ENTITLEMENT HISTORY ......................................................................... 4

3.2 PROPOSED PROJECT ........................................................................................................................ 4

3.3 LAND USE REGULATIONS ................................................................................................................. 5

3.4 UTILITIES AND INFRASTRUCTURE IMPROVEMENTS ......................................................................... 7

3.5 CONSTRUCTION ACTIVITIES ............................................................................................................. 8

3.6 OPERATIONAL CHARACTERISTICS .................................................................................................. 8 4 EVALUATION OF ENVIRONMENTAL IMPACTS ................................................................................ 20

4.1 GENERAL PLAN PROJECT .............................................................................................................. 20

4.2 PROPOSED PROJECT’S CONSISTENCY WITH THE GENERAL PLAN AND ZONING DENSITY . 21

4.3 SCOPE OF EVALUATION ................................................................................................................ 22

4.3.1 Section 15183 ..................................................................................................................... 22

4.3.2 Section 15168 ..................................................................................................................... 23

4.4 EXPLANATION OF CHECKLIST EVALUATION CATEGORIES ....................................................... 24

4.4.1 Documents Incorporated by Reference...................................................................... 25

4.5 SUMMARY OF ENVIRONMENTAL ANALYSIS AND DETERMINATION ........................................ 25

4.6 DETERMINATION .............................................................................................................................. 26 5 ENVIRONMENTAL IMPACTS ........................................................................................................... 27

5.1 AESTHETICS ....................................................................................................................................... 27

5.1.1 Discussion ............................................................................................................................ 27

5.1.2 Cumulative Impacts Analysis .......................................................................................... 36

5.1.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 37

5.1.4 Conclusion .......................................................................................................................... 38

5.2 AGRICULTURE AND FORESTRY RESOURCES ................................................................................ 40

5.2.1 Discussion ............................................................................................................................ 41

5.2.2 Cumulative Impacts Analysis .......................................................................................... 47

5.2.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 48

5.2.4 Conclusion .......................................................................................................................... 48

5.3 AIR QUALITY ..................................................................................................................................... 50

5.3.1 Discussion ............................................................................................................................ 50

5.3.2 Cumulative Impacts Analysis .......................................................................................... 60

5.3.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 60

5.3.4 Conclusion .......................................................................................................................... 61 CEQA Sections 15168 and 15183 Analysis
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5.4 BIOLOGICAL RESOURCES .............................................................................................................. 63

5.4.1 Discussion ............................................................................................................................ 64

5.4.2 Cumulative Impacts Analysis .......................................................................................... 74

5.4.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 74

5.4.4 Conclusion .......................................................................................................................... 75

5.5 CULTURAL RESOURCES ................................................................................................................... 77

5.5.1 Discussion ............................................................................................................................ 77

5.5.2 Cumulative Impacts Analysis .......................................................................................... 81

5.5.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 82

5.5.4 Conclusion .......................................................................................................................... 86

5.6 ENERGY ............................................................................................................................................ 87

5.6.1 Discussion ............................................................................................................................ 87

5.6.2 Cumulative Impacts Analysis .......................................................................................... 89

5.6.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures... 90

5.6.4 Conclusion .......................................................................................................................... 93

5.7 GEOLOGY AND SOILS .................................................................................................................... 94

5.7.1 Discussion ............................................................................................................................ 95

5.7.2 Cumulative Impacts Analysis ........................................................................................ 102

5.7.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 102

5.7.4 Conclusion ........................................................................................................................ 104

5.8 GREENHOUSE GAS EMISSIONS ................................................................................................... 105

5.8.1 Discussion .......................................................................................................................... 105

5.8.2 Cumulative Impacts Analysis ........................................................................................ 110

5.8.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 110

5.8.4 Conclusion ........................................................................................................................ 113

5.9 HAZARDS AND HAZARDOUS MATERIALS .................................................................................. 114

5.9.1 Discussion .......................................................................................................................... 115

5.9.2 Cumulative Impacts Analysis ........................................................................................ 123

5.9.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 124

5.9.4 Conclusion ........................................................................................................................ 125

5.10 HYDROLOGY AND WATER QUALITY .......................................................................................... 127

5.10.1 Discussion .......................................................................................................................... 128

5.10.2 Cumulative Impacts Analysis ........................................................................................ 143

5.10.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 144

5.10.4 Conclusion ........................................................................................................................ 145

5.11 LAND USE AND PLANNING .......................................................................................................... 146

5.11.1 Discussion .......................................................................................................................... 146

5.11.2 Cumulative Impacts Analysis ........................................................................................ 153

5.11.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 153

5.11.4 Conclusion ........................................................................................................................ 155

5.12 MINERAL RESOURCES ................................................................................................................... 156

5.12.1 Discussion .......................................................................................................................... 156

5.12.2 Cumulative Impacts Analysis ........................................................................................ 158

5.12.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 158

5.12.4 Conclusion ........................................................................................................................ 158

5.13 NOISE .............................................................................................................................................. 160

5.13.1 Discussion .......................................................................................................................... 160 CEQA Sections 15168 and 15183 Analysis
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5.13.2 Cumulative ....................................................................................................................... 173

5.13.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 173

5.13.4 Conclusion ........................................................................................................................ 175

5.14 POPULATION AND HOUSING ...................................................................................................... 177

5.14.1 Discussion .......................................................................................................................... 177

5.14.2 Cumulative Impacts Analysis ........................................................................................ 180

5.14.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 180

5.14.4 Conclusion ........................................................................................................................ 181

5.15 PUBLIC SERVICES ........................................................................................................................... 182

5.15.1 Discussion .......................................................................................................................... 182

5.15.2 Cumulative Impacts Analysis ........................................................................................ 187

5.15.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 187

5.15.4 Conclusion ........................................................................................................................ 188

5.16 RECREATION .................................................................................................................................. 190

5.16.1 Discussion .......................................................................................................................... 190

5.16.2 Cumulative Impacts Analysis ........................................................................................ 192

5.16.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 192

5.16.4 Conclusion ........................................................................................................................ 193

5.17 TRANSPORTATION ......................................................................................................................... 194

5.17.1 Discussion .......................................................................................................................... 194

5.17.2 Cumulative Impacts Analysis ........................................................................................ 202

5.17.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 203

5.17.4 Conclusion ........................................................................................................................ 204

5.18 TRIBAL CULTURAL RESOURCES .................................................................................................... 205

5.18.1 Discussion .......................................................................................................................... 205

5.18.2 Cumulative ....................................................................................................................... 207

5.18.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 208

5.18.4 Conclusion ........................................................................................................................ 208

5.19 UTILITIES AND SERVICE SYSTEMS .................................................................................................. 209

5.19.1 Discussion .......................................................................................................................... 210

5.19.2 Cumulative Impacts Analysis ........................................................................................ 217

5.19.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 218

5.19.4 Conclusion ........................................................................................................................ 218

5.20 WILDFIRE ......................................................................................................................................... 220

5.20.1 Discussion .......................................................................................................................... 220

5.20.2 Cumulative Impacts Analysis ........................................................................................ 223

5.20.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures. 224 6 REFERENCES ................................................................................................................................. 225

TABLES
Table 3.3-1: Adjoining and Immediately Surrounding Properties ............................................................. 5 Table 5.1-1: Compliance with Victoria Avenue Policies .......................................................................... 30 Table 5.2-1: California LESA Model Scoring Thresholds ............................................................................ 42 Table 5.2-2: Total LESA Score Sheet – Proposed Project Site ................................................................... 43 Table 5.3-1: Summary of Peak Construction Emissions (No Mitigation) ................................................ 55 CEQA Sections 15168 and 15183 Analysis
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Table 5.3-2: Summary of Peak Operational Summer Emissions .............................................................. 55 Table 5.3-3: Summary of Peak Operational Winter Emissions ................................................................. 56 Table 5.3-4: Sensitive Receptor Locations .................................................................................................. 58 Table 5.4-1: MSHCP Consistency Analysis ................................................................................................... 73 Table 5.8-1: Proposed Project Greenhouse Gas Emissions .................................................................... 108 Table 5.8-2: Proposed Project Greenhouse Gas Emissions Summary.................................................. 109 Table 5.10-1: Proposed Infiltration Basin Characteristics ....................................................................... 134 Table 5.11-1: Authorization and Compliance Summary ....................................................................... 149 Table 5.11-2: Compliance With Applicable Development Standards .............................................. 151 Table 5.13-3: Closet Sensitive Receptors Locations ................................................................................ 164 Table 5.13-7: Vibration Levels of Typical Construction Equipment at 25 ft ....................................... 171 Table 5.14-1: Population, Housing, and Employment Projections ...................................................... 178 Table 5.15-1: Local Schools ........................................................................................................................ 185 Table 5.15-2: Proposed Project Student Generation ............................................................................. 185 Table 5.15-3: Local Parks ............................................................................................................................. 186 Table 5.19-1: Existing and Future Water Service Supply and Demand .............................................. 213

EXHIBITS
Exhibit 1: Regional Location Map .................................................................................................................. 9 Exhibit 2: Site Location - Aerial ...................................................................................................................... 10 Exhibit 3: Site Photos ........................................................................................................................................ 11 Exhibit 4: Proposed Project General Plan Land Use ................................................................................. 12 Exhibit 5: Proposed Project Site Zoning ....................................................................................................... 13 Exhibit 6: TTM 38921 ......................................................................................................................................... 14 Exhibit 7: Concept Site Plan .......................................................................................................................... 15 Exhibit 8: Conceptual Landscape Plan ...................................................................................................... 16 Exhibit 9: Architectural Elevations: Tudor Cottage Style .......................................................................... 17 Exhibit 10: Architectural Elevations: Craftsman Style ................................................................................ 18 Exhibit 11: Architectural Elevations: Spanish Style ..................................................................................... 19 Exhibit 12: Proposed Project Site Proximity to Agricultural Zones ........................................................... 49

APPENDICES

Appendix A Air Quality and GHG Technical Memorandum, KPC EHS Consultants, LLC, Revised June 6, 2024.

Appendix B-1 Land Evaluation and Site Assessment Model, EPC Environmental, December 26, 2024.

Appendix B-2 Biological Resources Assessment (BRA), prepared by VCS Environmental, April 1, 2024.

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Appendix C Cultural Resources Survey Update, CRM Tech, December 31, 2024

Appendix D Updated Preliminary Geotechnical Evaluation, Petra Geosciences, March 13, 2024.

Appendix E Phase I Environmental Site Assessment & Limited Soil Investigation, EFI Global December 19, 2019.

Appendix F Hydrology Report for TTM 3892, Adkan Engineers, February 26, 2024.

Appendix G Preliminary Water Quality Management Plan, Adkan Engineers, February 22, 2024.

Appendix H La Sierra & Victoria Residential Project – Noise Assessment, prepared by KPC EHS Consultants, LLC, February 4, 2025.

CEQA Sections 15168 and 15183 Analysis
City of Riverside Case No. PR-2024-001656 List of Acronyms Page viii
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Acronym Definition

AQMP Air Quality Management Plan
AUSD Alvord Unified School District
CEQA California Environmental Quality Act
CMP Congestion Management Plan
EIR Environmental Impact Report
EOP Emergency Operations Plan
FEMA Federal Emergency Management Agency
FPEIR GP 2025 Final Programmatic Environmental Impact Report GIS Geographic Information System
GHG Green House Gas
GP 2025 General Plan 2025
IS Initial Study
LHMP Local Hazard Mitigation Plan
MSHCP Multiple-Species Habitat Conservation Plan
NCCP Natural Communities Conservation Plan
OEM Office of Emergency Services
OPR Office of Planning & Research, State
PEIR Program Environmental Impact Report
PW Public Works, Riverside
RCALUC Riverside County Airport Land Use Commission
RCALUCP Riverside County Airport Land Use Compatibility Plan RCP Regional Comprehensive Plan
RCTC Riverside County Transportation Commission
RMC Riverside Municipal Code
RPD Riverside Police Department
RPU Riverside Public Utilities
RTIP Regional Transportation Improvement Plan
RTP Regional Transportation Plan
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCH State Clearinghouse
SKR-HCP Stephens’ Kangaroo Rat - Habitat Conservation Plan SWPPP Storm Water Pollution Prevention Plan
USGS United States Geologic Survey
WQMP Water Quality Management Plan

CEQA Sections 15168 and 15183 Analysis
City of Riverside Case No. PR-2024-001656 Section 1 Background Information

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1 BACKGROUND INFORMATION

1. Project Title: Warmington 49 SFR La Sierra/Victoria

2. Case No: PR-2024-001656 (Tentative Tract Map No. 38921)

3. Hearing Date: TBD

4. Lead Agency: City of Riverside
Community & Economic Development Department
Planning Division
3900 Main Street, 3rd Floor.

Riverside, CA 92522
Judy Egüez, Senior Planner
(951) 826-3969
[email protected]

5. Project Proponent: Matthew Esquivel
Warmington Residential
3090 Pullman Street
Costa Mesa, CA 92626

5. Project Location: The Proposed Project site is located south of the SR-91 Freeway at the southeast corner of La Sierra Avenue and Victoria Avenue in the City of Riverside (see Figure 1 - Regional Location Map and Figure 2 – Aerial Photo), identified as Assessor Parcel Map (APN) 136-2200-16. The site is located at latitude 33º 53’ 15” North and longitude -117º 27’ 42” West and in Township 3 South, Range 6 West, Sections 24 and 25.

6. Project Description: Tentative Tract Map (TM-38921) to subdivide the 9.91 - acre Proposed Project site into 49 lots for development of single-family residences and eight lettered lots for private streets, alleys, a bioretention basin and open space to facilitate construction of 46 market - rate residences and 3 affordable residences for very low-income households.

7. General Plan
Designation:

Low-Density Residential (LDR, 4.1 du/ac) La Sierra South Neighborhood

8. Zoning: R-1-1/2 – Single Family Residential Zone

9.Other public
agencies whose
approval is required
(e.g., permits,
financial approval, or
participation
agreement.):

• South Coast Air Quality Management District (SCAQMD) – Dust Control Plan
• Regional Water Quality Control Board (RWQCB), Santa Ana Region – National Pollutant Discharge
• Elimination System (NPDES) Construction General Permit • RWQCB, Santa Ana Regional Water Control Board – 401 Water Quality Certification – Waste Discharge Requirement (WDR) • Santa Ana Regional Water Quality Control Board – Water Quality Management Plan (WQMP); and
• Santa Ana Regional Water Quality Control Board – Storm Water Pollution Prevention Plan (SWPPP)

CEQA Sections 15168 and 15183 Analysis
City of Riverside Case No. PR-2024-001656 Section 2 Introduction

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2 INTRODUCTION
The City of Riverside (“City”) prepared a mitigated negative declaration (MND) for a proposed residential Proposed Project consisting of 49 single -family homes (“ Proposed Project”) on 9.91- acres located at the southeast corner of La Sierra Avenue and Victoria Avenue (“Proposed Project Site”), in the R-1-1/2 Acre – Single Family Residential Zone, in Ward

5. In compliance with Public Resources Code section 21091, the City circulated the draft MND for public comments from October 11, 2024, to October 31, 2024. The City issued a final MND responding to comments and the Planning Commission held a public meeting to consider the Proposed Project on November 7, 2024.

The staff report for the Planning Commission hearing recommended that the Planning Commission adopt the MND and approve the Proposed Project. As stated in the staff report, the Proposed Project Site was annexed into the City in 1985 and placed into the LDR - Low Density Residential Land Use designation and zoned R- 1- 1/ 2 Acre - Single Family Residential Zone (formerly R- 1- 130 Single Family Residential Zone). On February 24, 2015, the City Council approved Planning Case P14- 0176 (TM -36713) to subdivide the Proposed Project Site into 14 residential lots, but the developer of that project allowed its map to expire in 2019. On July 25, 2019, the Planning Commission approved the same subdivision design under Planning Case P19- 0380 and P19-0480 (TM -37764).

Since 2019, there have been several changes to state housing laws, including State Density Bonus Law and the Housing Accountability Act. State Density Bonus Law provides benefits, including a density bonus, incentives or concessions, waivers or deviations from development standards, and parking standards for projects that include affordable housing. The Proposed Project has more than five dwelling units and five percent of the units would be restricted to prices affordable to very low -income households and therefore is entitled to State Density Bonus Law benefits. These benefits are statutorily required unless a jurisdiction can make certain findings. (Gov. Code § 65915.)
The Housing Accountability Act protects housing development projects, which include purely residential projects with at least two units, from uncertainty during the application processing and approval process. Among other protections, a jurisdiction has strict timelines to determine whether a project is consistent with applicable plans, programs, policies, ordinances, standards, requirements, and other similar provisions. (Gov. Code, § 65589.5(j)(2)(A)(i).) In addition, a jurisdiction cannot deny a project that complies with applicable, objective standar ds or condition its approval on fewer units unless the project would have a “significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete” on the public health and safety and there is no feasible method to satisfactorily mitigate or avoid that adverse other than the disapproval of the housing development project or the approval of the project upon the condition that it be developed at a lower density. (Id. § 65589.5(j)(1).)

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Despite state housing laws and the staff’s recommendation, the Planning Commission voted to deny the Proposed Project. In light of this event, the Proposed Project applicant and City staff reviewed the environmental compliance for the Proposed Project. Given that the Proposed Project Site has been long planned and designated for housing in the City’s General Plan and the City has previously prepared environmental analysis for housing development on the Proposed Project Site, the applicant asked the City to consider the Proposed Project’s eligibility for a CEQA exemption pursuant to CEQA Guidelines section 15183 and tiering pursuant to CEQA Guidelines section 15168 . City staff considered the applicant’s request and prepared this checklist analysis, which concludes that the City is prohibited from undertaking additional CEQA analysis for the project because the project would have no peculiar impacts and no new or substantially more severe significant impacts than disclosed in the 2025 General Plan Programmatic Environmental Impact Report and its addendums (“GP PEIR”).

CEQA Sections 15168 and 15183 Analysis
City of Riverside Case No. PR-2024-001656 Section 3 Proposed Project Description

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3 PROPOSED PROJECT DESCRIPTION

3.1 Proposed Project Site Entitlement History
The 9.91-acre Proposed Project Site consists of a single parcel of an orange grove surrounded by single family residences to the north, southeast, and west (Exhibit 1: Regional Location Map, Exhibit 2: Site Location – Aerial and Exhibit 3: Site Photos). The property is subject to the Victoria Avenue Policy which establishes guidelines for landscaping, street improvements and standards for new development with the goal of preserving the historic and aesthetic integrity of Victoria Avenue, a City Historic Landmark.

The subject property was annexed into the City in 1985 and placed into the LDR – Low Density Residential Land Use designation and zoned R -1-1/2 Acre - Single Family Residential Zone (formerly R-1-130 Single Family Residential Zone), and it has remained unchanged since 1985.

On February 24, 2015, the City Council approved Planning Case P14- 0176 (TM -36713) to subdivide the site into 14 residential lots, with a new public cul-de-sac accessed from Victoria Avenue, and improvements to Millsweet Place. The Map included construction of a decomposed granite trail and planting of three rows of agricultural trees along the Victoria Avenue frontage. The map was not recorded timely and expired on February 24, 2019.

On July 25, 2019, the Planning Commission approved the same subdivision desig n under Planning Case P19-0380 and P19-0480 (TM-37764). While the map has not expired, it has not been submitted to be recorded.

On November 7, 2024, a motion to approve the Proposed Project will not have a significant effect on the environment based on t he findings set forth in the case record and adopt a Mitigated Negative Declaration (MND) and Mitigation Monitoring and Reporting Program (MMRP), pursuant to Sections 15074 and 21081.6 of the California Environmental Quality Act (CEQA) Guidelines; and to approve Planning Case PR -2024-001656 (Tentative Tract Map), based on the findings outlined in the staff report and summarized in the findings and subject to the recommended conditions failed with two Commissioners voting aye and four Commissioners voting no.

3.2 Proposed Project
The Proposed Project is unchanged from the one presented to the Planning Commission on November 7, 2024. The Proposed Project Proponent is requesting approval of a Tentative Tract Map (TTM-38921) to subdivide the 9.91- acre Proposed Project site, identified as Assessor Parcel Map (APN) 136-2200-16, into 49 lots for development of single-family residences and eight lettered lots for private streets, alleys, a bioretention basin and open space to facilitate construction of 46 market- rate residences and three affordable residences for very low - income households. Exhibit 6 through Exhibit 11, located at the end of this section, provide graphical representations of the concept Site Plan, Landscape Plan, Grading Plan and home design styles.

CEQA Sections 15168 and 15183 Analysis
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The Proposed Project proposes residential lots ranging in size from 3,690 square feet to 7,437 square feet. Lot G, located along Victoria Avenue, consists of a 0.67-acre open space lot that will preserve a portion of the existing orange grove. The Proposed Project includes the construction of a 10-foot-wide multi-purpose trail along Victoria Avenue. Lot H, located at the northeast portion of the Proposed Project Site along Millsweet Place, totals 0.59 acre and serves as common open space as well as an infiltration basin.

Vehicular access to the residential subdivision is from La Sierra Avenue. Pedestrian connections within the Proposed Project Site will be provided via an internal pedestrian network of sidewalks.

The Proposed Project Site will be secured with a 6 -foot-high decorative masonry wall along the south, east along Millsweet Place and west along La Sierra Avenue. A 4-foot-high tubular steel fence will be provided between the residences and the orange grove proposed to remain within Lot G.

3.3 Land Use Regulations
The Proposed Project Site has a land use designation of Low Density Residential (LDR) (see Exhibit 4: Proposed Project General Plan Land Use). This land use designation provides for the development of large lot single family homes at a maximum density of 4.1 dwelling units per acre. Lands in this designation are developed or will be developed with the full range of urban services available in the City.

The Proposed Project Site is zoned Residential ( R-1-1/2) (see Exhibit 5: Proposed Project Site Zoning). The purpose of this zone is to provide areas for large lot single-family residences.

Table 3.3-1: Adjoining and Immediately Surrounding Properties below describes the General Plan land use designations and zoning classifications of the properties adjacent to the Proposed Project Site.

Table 3.3-1: Adjoining and Immediately Surrounding Properties Location General Plan Designation Zoning Designation
Proposed Project Site Low Density Residential (LDR)
(max. 4.1 du/ac)
Residential (R-1-1/2 Acre)
21,780 sf minimum lot size
North Agricultural/Rural Residential (A/RR)
(max. 0.2 du/ac)
Residential Agricultural (RA-5)
5-acre minimum lot size
East Low Density Residential (LDR)
(max. 4.1 du/ac)
Residential (R-1-1/2 Acre)
21,780 sf minimum lot size
South Low Density Residential (LDR)
(max. 4.1 du/ac)
Residential (R-1-1/2 Acre)
21,780 sf minimum lot size
West (County1) Medium Density Residential (MDR)
(max. 6.2 du/ac)
Residential (R-1-20000)
20,000 sf minimum lot size
Source: City GP Land Use Map (2021),City Interactive Zoning Map (2021) ; SF = square feet du/ac = dwelling units per acre

1 Within the County’s Lake Mathews/Woodcrest Area Plan CEQA Sections 15168 and 15183 Analysis
City of Riverside Case No. PR-2024-001656 Section 3 Proposed Project Description

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The Proposed Project uses the State Density Bonus Law (SDBL), which is a state mandate that grants developers with qualifying projects certain benefits. Chapter 19.545 of the City’s Zoning Code incorporates State Density Bonus Law by reference.

The Proposed Project would provide three residential lots for very low-income households; therefore, the Proposed Project is a qualifying project under the SDBL and is eligible to receive a density bonus, one concession or incentive, unlimited waivers or deviations from development standards, and to use the parking standards under the SDBL.

Under the SDBL, the applicant is allowed to develop the site based on the greate st number of units allowed under the LDR – Low Density Residential designation of the General Plan, which is 4.1 du/ac or, 41 residences (9.91 acres x 4.1 du/ac). Additionally, the applicant is allowed a 20 percent density bonus because it restricts 5 percent (3 residences) of the Proposed Project’s base density to very low-income households. The Proposed Project would include an additional 8 residences, which is within the 20 percent bonus allowed , for a total of 49 residences.

Because 5 percent of residences permitted under the base density would be sold at prices affordable to very low-income households, the Proposed Project is eligible for one concession or incentive and unlimited waivers to achieve the permitted density. A waiver is a reduction or modification of any development standard that would physically preclude the construction of the Proposed Project at the density and with the amenities proposed . The applicant requests 7 waivers to reduce or modify development standards in order to achieve the proposed density:

1. Decrease in Minimum Lot Area
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum lot area of 21,780 square feet. In order to accommodate the density of 4.95 du/ac allowed by the SDBL, the lots needed to be reduced to a minimum of 3,690 square feet. The map proposes residential lots ranging in size from 3,690 square feet to 7,437 square feet.

2. Reduction in Lot Width
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum lot width of 120- feet. The Proposed Project proposes lot widths of a minimum of 41-feet-wide.

3. Reduction in Lot Depth
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum lot depth of 150- feet. The Proposed Project proposes lot depths of a minimum of 90-feet.

CEQA Sections 15168 and 15183 Analysis
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4. Increase in Lot Coverage
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s maximum lot coverage of 30 percent. The Proposed Project proposes a maximum lot coverage of 55 percent.

5. Reduction in Front Yard Setback
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum front yard setback of 30-feet. The Proposed Project proposes a front setback of 10-feet to the residence and a minimum 18 -feet to the face of the garage.

6. Reduction in Side Yard Setback
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum side yard setback of 20-feet. The Proposed Project proposes a minimum side yard setbacks of 4-feet.

7. Reduction in Rear Yard Setback
• The Proposed Project is requesting a waiver from the R-1-1/2-Acre zone’s minimum rear yard setback of 35-feet. The Proposed Project proposes a minimum rear yard setbacks of 15-feet.

3.4 Utilities and Infrastructure Improvements
Sewer and Water Improvements
The Proposed Project will connect to existing utility lines (water, sewer, etc.) in La Sierra Avenue and Millsweet Street. A sewer extension approximately 200 feet long will be required to serve the Proposed Project.

Storm Drain Improvements
The Proposed Project site currently drains to the northeast and the water quality management plan proposes a detention/infiltration basin in the northeast portion of the site along with a new onsite storm drainage system to collect surface runoff and channel it to the new basin. Street Improvements
Street Improvements
The Proposed Project will construct the following street improvements:

Victoria Avenue: The existing improvements will remain. The Proposed Project will construct a new 10-foot-wide trail per the Trails Master Plan and Trails Standards from the Victoria Avenue Policy for the trail segment adjacent to the Proposed Project Site.

La Sierra Avenue: The Proposed Project will construct a new 46 -foot-wide private street for access from La Sierra Avenue and a six-foot high block wall along the property line.

CEQA Sections 15168 and 15183 Analysis
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Millsweet Place: Improve 30-foot half-width right-of-way adjacent to the Proposed Project Site with curb, gutter, paved travel lanes, and a landscaped berm.

3.5 Construction Activities
Construction activities include site preparation (ground clearing and removal of all vegetation); grading of the entire Proposed Project site and installation of building footings, utility lines, and underground infrastructure, construction of new houses), paving, landscaping, installation of perimeter fencing, and installation of landscaping. Construction equipment and staging are to occur on-site, and construction vehicle access is planned via Victoria Avenue and Millsweet Street . The Proposed Project will be built in one phase, and grading will require 6,252 cubic yards (CY) of cut and 29,04 CY of fill so overall earthwork will require the import of 22,788 CY of fill. Construction of the Proposed Project is expected to begin in mid-2025 and be completed in mid-2026. This is the earliest construction could occur.

Due to increasingly stringent state standards on construction equipment, if construction occurs later, impacts would be the same or less than what is discussed in this checklist.

3.6 Operational Characteristics
The Proposed Project would operate as a residential community. Typical operational characteristics would include residents and visitors traveling to and from the site, leisure and maintenance activities occurring on individual residential lots, and general maintenance of common areas. Low levels of noise and a moderate level of artificial exterior lighting typical of a residential community are expected.

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Exhibit 1: Regional Location Map

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Exhibit 2: Site Location - Aerial

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Exhibit 3: Site Photos

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Exhibit 4: Proposed Project General Plan Land Use

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Exhibit 5: Proposed Project Site Zoning

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Exhibit 6: TTM 38921

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Exhibit 7: Concept Site Plan

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Exhibit 8: Conceptual Landscape Plan

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Exhibit 9: Architectural Elevations: Tudor Cottage Style

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Exhibit 10: Architectural Elevations: Craftsman Style

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Exhibit 11: Architectural Elevations: Spanish Style

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4 EVALUATION OF ENVIRONMENTAL IMPACTS
The environmental analysis examines whether the Proposed Project would require preparation of additional environmental analysis or whether the GP PEIR adequately covered the Proposed Project’s environmental impacts.

4.1 General Plan Project
The City’s General Plan serves as a long- term blueprint for the City’s growth guidelines. The GP PEIR analyzed the City’s proposed General Plan (referred to as “GP Project” in the GP PEIR and this document), which consisted of the following elements:
 Comprehensive update of the City of Riverside General Plan.  Comprehensive update of the City of Riverside Zoning Code (Title 19 of the Municipal Code of the City of Riverside) and the rezoning of properties to reflect new zone names and to respond to General Plan land use designation changes in focus areas City-wide.
 Comprehensive update of the City of Riverside Subdivision Code (Title 18 of the Riverside Municipal Code of the City of Riverside.
 Amendment to the Noise Code (Title 7 of the Municipal Code of the City of Riverside.  Adoption of the Magnolia Avenue Specific Plan.
 Adoption of Citywide Design and Sign Guidelines.

As required by CEQA, the City prepared a Programmatic EIR, State Clearinghouse Number 2004021108, that analyzed the environmental impacts of the General Plan project . In November 2007, the City Council adopted Resolution No. 21535 certifying the GP P EIR as meeting the requirements of CEQA and approved the General Plan project. The GP PEIR considered the impacts from construction associated with the General Plan project , which includes developing the Proposed Project Site.

Since certification of the original GP PEIR, the City has adopted several addendums to the document, including:
 GP 2025 PEIR Addendum #4 - Housing Element Update.
 GP 2025 PEIR Addendum #5 – Air Quality, Mobility, Historic, Open Space, Public Safety, Parks, and Public Facilities Elements.
 GP 2025 PEIR Addendum #6 - 2006-2014 Housing Element Rezoning Program.  GP 2025 PEIR Addendum #8 – 2014-2021 Housing Element.

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For the purposes of this Checklist, the above original GP PEIR and its subsequent addendums are collectively referred to as the “GP PEIR.”

4.2 Proposed Project ’s Consistency with the General Plan and Zoning Density
Regarding General Plan density, the GP PEIR was evaluated at three levels of development intensity. They range from the reasonably foreseeable “typical” densities that the City expects to be built in the next 20 years (“Typical Growth Scenario”) to the absolute maximum allowable densities throughout the Planning Area (Max Scenario) . The Planning Area encompasses the land within the city limits plus the land within the city’s Sphere of Influence.

The GP PEIR analyzed this range of potential development scenarios in order to account for the inherent uncertainty in forecasting development impacts on a general plan program level . The Max imum and Maximum w/PRD projections are included and evaluated for comparison but will not be fully realized due to proposed development projects having to comply with roadway dedications, development standards, avoidance of sensitive habitat, and physical site constraints such as topography and site configuration. As a result of these constraints, full realization of Maximum and Maximum w/PRD scenarios is unlikely. As a result of full implementation of General Plan land use policy at the Typical expected level; the City’s population has the potential to grow from approximately 274,000 persons in 2003 to approximately 346,867 in 2025 within the City’s current city limits. According to the California Department of Finance (DOF), the C ity’s population as of Ja nuary 1, 2024, was 316,390 persons. Based on 3.06 persons per household), the number of dwelling units is 109,390. As compared to 115,622 (X% less).

Based on this, the level of development as of January 1, 2024 is less than analyzed in the GP PEIR. Specif ically, the population is 30,497 less, and the number of dwelling units is This population increase would equate to approximately 115,622 households within the City limits, and approximately 127,692 households.

As described in Chapter 3, Proposed Project Description, the Proposed Project Site has a General Plan land use designation of Low Density Residential (LDR). Under the LDR land use designation, the 9.91-acre Proposed Project Site could be developed with 41 dwelling units.

The Proposed Project proposes 49 units and utilizes the State Density Bonus Law.

The Proposed Project also is consistent with the density permitted by the Zoning Code, which incorporates State Density Bonus Law by reference. Zoning Code section 19.545.050 provides that if a t least 5 percent of a project’s base density is affordable to very -low income households, that project is entitled to a 20 percent density bonus. As discussed in Chapter 4, Proposed Project Description, the Proposed Project includes enough units affordable to very- low-income households to qualify for a 20 percent density bonus, and with that bonus, its density is consistent with the density allowed by the Zoning Code.

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4.3 Scope of Evaluation
This Checklist analyzes the items required by Section 15183 and Section 15168, as detailed below.

4.3.1 Section 15183
California Environmental Quality Action (CEQA) section 21083.3 and CEQA Guidelines section 15183 (Section 15183) mandate that projects that are consistent with the development density established by existing zoning, community plan, or general plan policies for which an environmental impact report (EIR) was certified, shall not be subject to additional environmental review except as might be necessary to examine whether there are project - specific significant effects that are peculiar to the project or its site. The exemption applies only to the extent that all feasible mitigation measures for a significant effect specified in the EIR are or will be undertaken by the public agency having jurisdiction to implement suc h mitigation measures. (CEQA Guidelines, §15183(e)(1),(2).) In evaluating whether a project is exempt from further environmental review in accordance with Section 15183(b), the examination of environmental effects shall be limited to those effects that:
(1) Are peculiar to the project or parcel on which the project would be located; (2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan or community plan with which the project is consistent; (3) Are potentially significant off-site and cumulative impacts that were not discussed in the underlying EIR; or
(4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

Section 15183(c) specifies that if an impact is not peculiar to the parcel or to the proposed project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, as contemplated by Section 15183 (e), then an additional EIR need not be prepared for the project solely on the basis of that impact.

An impact is not peculiar if uniformly applied development standards or procedures have been previously adopted by the city or county with a finding that the development standards or procedures will substantially mitigate that environmental impact . (CEQA Guidelines §15183(f).) The finding shall be based on substantial evidence which does not need to be addressed in an EIR, and such uniformly adopted policies or procedures do not need to be included in the general plan or any community plan ( Id.) An additional EIR, or other environmental document, need not be prepared for a project solely on the basis of an impact that is not peculiar to the parcel or to the project, has been addressed as a significant CEQA Sections 15168 and 15183 Analysis
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effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards (CEQA Guidelines §15183(c)).

4.3.2 Section 15168
As discussed above, in 2007 the City certified the GP PEIR and adopted a General Plan and corresponding zoning amendments that, among other things, designated and zoned the Proposed Project Site for residential development. The Proposed Project implements that residential designation and zoning by proposing a housing project.

Public Resources Code sections 21083 and 21003 and CEQA Guidelines sectio n 15168 (Section 15168) encourage the preparation of programmatic EIRs for a series of actions that can be characterized as one large project and are related either geographically, as logical parts in the chain of contemplated actions, in connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or as individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental e ffects which can be mitigated in similar ways. (CEQA Guidelines § 15168(a).) Use of a program EIR can provide the following advantages:
provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR o n an individual action, ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis, avoid duplicative reconsideration of basic policy considerations, allow the lead agency to consider broad policy alternatives and program wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, and reduce paperwork. (CEQA Guidelines § 15168(b).)
Section 15168 also encourages lead agencies to tier from certified prog ram EIRs when carrying out individual activities within the program. A lead agency must examine l ater activities in the program in the light of the program EIR to determine whether an additional environmental document must be prepared, which typically is done using a modified initial study checklist . If the lead agency finds that pursuant to CEQA Guidelines s ection 15162 (Section 15162) that no subsequent EIR would be required for the later activity, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document is required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that an agency may consider in making that determination include, but are not limited to, consistency of the later activity with the type of allowable land use, overall planned density and building intensity.

Section 15162 states that w hen an EIR has been certified, “ no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:” CEQA Sections 15168 and 15183 Analysis
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• Substantial changes are proposed in the project that require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; • Substantial changes occur with respect to the circumstances under which the project is undertaken that will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the s everity of previously identified significant effects; or
• New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:
o The project will have one or more significant effects not discussed in the previous EIR;
o Significant effects previously examined will be substantially more severe than shown in the previous EIR;
o Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
o Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

4.4 Explanation of Checklist Evaluation Categories
As there is no specific checklist format for which to evaluate a project against the CEQA Guidelines 15183 or 15168 conditions. This document follows the CEQA Guidelines Appendix G analysis format, but modifies the analysis to focus on how the Proposed Project would be compliant with the conditions outlined in Section 15183 and Section 15168 as follows:

GP PEIR Impact Determination: This describes the impact determination made in the GP PEIR for each impact category evaluated.

Effect Peculiar to the Proposed Project or Site: This applies if the project could result in a peculiar impact, including a physical change that belongs exclusively or especially to the project or that is a distinctive characteristic of the project or the project site and that peculiar impact is not substantially mitigated by the imposition of uniformly applied development policies or standards.

New or Substantially More Severe Significant Effect: This applies if the project causes a new significant impact or a substantial increase in the severity of an impact identified as significant in the GP PEIR. A significant impact is a substantial adverse change in CEQA Sections 15168 and 15183 Analysis
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any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance that was not addressed in the previously certified EIR and cannot be mitigated through uniformly applied development standards.

New Significant Off-Site or Cumulative Impact: This applies if the project causes a new significant effect to areas outside the boundaries of the project than identified in the GP PEIR or its effects when added to other closely related past, present, and reasonably foreseeable probable future p rojects would create a new significant cumulative impact not disclosed in the GP PEIR and that could not be mitigated through uniformly applied development standards.

New Information/More Severe Impact. This applies when new information that could not have been known at the time the GP P EIR was certified becomes available and such changes or new information require major revisions to the GP P EIR due to new significant environmental effects or a substantial increase in the severity of previously identified significant effects that cannot be mitigated through uniformly applied development standards.

4.4.1 Documents Incorporated by Reference
The following reports and/or studies were relied upon for the Proposed Project analysis, and are hereby incorporated by reference:
• Riverside General Plan 2025. (Available at
https://www.riversideca.gov/cedd/planning/general-plan.pdf) • Final Program Environmental Impact Report for the City of Riverside General Plan and Supporting Documents, State Clearinghouse Number 2004021108, certified November 2007, Resolution No. 21535 , Volume I and Volume II. (Available at https://www.riversideca.gov/cedd/planning/general-plan.pdf) • Victoria Avenue Policy for Preservation, Design and Development, City of Riverside, November 2019.

These documents are available for review at the City of Riverside Planning Division, Community Development Department, 3900 Main Street, Riverside, CA 92522

4.5 Summary of Environmental Analysis and Determination The analysis in this document shows that the P roposed Project meets the requirements of CEQA Guidelines Sections 15183 and 15168 , and no further environmental analysis under CEQA is required.

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4.6 Determination
Based on this initial evaluation, the following finding is made:

 I find that the proposed Project WOULD NOT result in: 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR or a substantial increase in the severity of a significant impact; 3) a potentially significant offsite impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time the prior EIR. NO FURTHER ACTION is required, and a Notice of Exemption will be filed indicating that the project IS ELIGIBLE for an EXEMPTION under State CEQA Guidelines Section 15183 and a Notice of Determination will be filed indicating the project IS ELIGIBLE for tiering under State CEQA Guidelines Section 15168.
 I find that the proposed Project would result in: 1) a peculiar impact that was not identified as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as significant in the prior EIR or a substantial increase in the severity of a significant impact; 3) a potentially significant offsite impact or cumulative impact not discussed in the prior EIR; or 4) a more severe impact due to substantial new information that was not known at the time the prior EIR. I find that FURTHER ENVIRONMENTAL REVIEW is necessary to analyze those effects that are subject to CEQA, and therefore, this Project is NOT ELIGIBLE for an EXEMPTION under State CEQA Guidelines Section 15183 or for tiering under State CEQA Guidelines Section 15168.

Signature Date

Printed Name Title

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5 ENVIRONMENTAL IMPACTS

5.1 Aesthetics
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant Off-
Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
Except as provided in Public Resources Code section 21099, would the project:
a) Have a substantial adverse
effect on a scenic vista?
Less Than
Significant No No No No
b) Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within a state scenic
highway?
Less Than
Significant No No No No
c) In non-urbanized areas,
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
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?)
Less Than
Significant No No No No
d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
Less Than
Significant With
Mitigation
Incorporated
No No No No

5.1.1 Discussion
a) Would the Project have a substantial adverse effect on a scenic vista? GP PEIR Impact Determination - Less than Significant
The GP PEIR concluded that the GP project will have a less than significant impact on scenic vistas, scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a scenic highway, and the visual character of the Planning Area. General Plan policies protect scenic vistas by, among other things, limiting development hillside and arroyo areas. (Draft PEIR, at pp. 5.1 -8 to 5.1-22.) Additionally, the Citywide Design and Sign Guidelines limit impacts to aesthetic resources by reducing interruptions of scenic vistas, CEQA Sections 15168 and 15183 Analysis
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maintaining and enhancing scenic resources and visual character, and reducing light and glare in the Planning Area. (Draft PEIR, at pp. 5.1-8 to 5.1-22.) The GP PEIR determined that each component of the GP Project would have a less than significant impact on scenic resources. The GP PEIR notes that the City of Riverside is characterized by the unique natural landforms that circle the City and create natural division of land uses and describes a variety of pro minent natural features: Mount Rubidoux, Pachappa Hill, Sycamore Canyon, Hawarden Hills, distinctive arroyos and isolated hills. It also notes that six major areas within the City serve as open space: the Santa Ana River Corridor, Box Springs Mountain Regional Park, Sycamore Canyon Wilderness Park, Fairmount Park, Mt.

Rubidoux Park, and California Citrus State Historic Park. Vista points can be found throughout the City, both as viewed from urban areas toward the hills and from wilderness areas toward Riverside. The most notable scenic vistas in the City include views of the La Sierra/Norco Hills, Sycamore Canyon Wilderness Park, and Box Springs Mountain Regional Park , the peaks of Box Springs Mountain, Mt. Rubidoux, Arlington Mountain, and Alessandro Heights. Based on General Plan policies related to preserving natural resources and open spaces as well as the requirements in the Residential Conservation Zone, the GP PEIR concludes that the GP project would have a less than significant impact on scenic vistas.

Proposed Project Impact
The Proposed Project is situated in a largely residential area although there are more commercial-oriented uses further to the north along the SR-91 Freeway and La Sierra Avenue.

The lower La Sierra/Norco Hills and the taller San Gabriel Mountains are visible to the north at many times of the year, the Santa Ana Mountains are always visible to the west, and the low Temescal Mountains are visible to the south and southeast of the Proposed Project area. The existing site has substantial foliage, which significantly obstructs views from adjacent roadways across the Proposed Project Site. There are no scenic vistas across the Proposed Project Site that could be obstructed by the Proposed Project. The Proposed Project does not contain components, such as tall buildings and building massing, that would block public views of the mountains to the north or hills to the south; therefore, the Proposed Project is consistent with Policy OS-2.4.

Figure CCM -4, Master P lan of Roadways, in the City General Plan, designates La Sierra Avenue and Victoria Avenue as scenic “Parkways” which have enhanced landscaping requirements. Travelers along these roadways have views of surrounding hills and mountains to the south, west, and north. The Proposed Project would adhere to all General Plan and zoning policies and regulations related to ensuring that Victoria Avenue and La Sierra Avenue continue to serve as scenic parkways. The Proposed Project would continue the landscaping features for those roadways. However, the Riverside City General Plan does not designate any specific scenic resources or vistas in the vicinity of the Proposed Project Site. For these reasons, the Proposed Project will have less than significant direct, ind irect, and cumulative impacts on scenic vistas, and no mitigation is required.

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The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section

5.1.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the proposed project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new or substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
b. Would the p roject substantially da mage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? GP PEIR Impact Determination Less than Significant
The GP PEIR concluded that the GP Project will have a less than significant impact on scenic vistas, scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a scenic highway, and the visual character of the Planning Area. General Plan policies protect scenic vistas by, among other things, limiting development in hillside and arroyo areas. (Draft PEIR, at pp. 5.1 -8 to 5.1-22.) Additionally, the Citywide 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 in the Planning Area. (Draft PEIR, at pp. 5.1-8 to 5.1-22.) Although there are no officially designated State scenic highways or any eligible State scenic highways traverse the City or its Sphere of Influence, the GP PEIR identified several streets as scenic parkways, as listed in GP PEIR Table 5.1-B, Scenic Parkways, and as shown on GP PEIR Figure 5.1-1, Scenic and Special Boulevards and Parkways . Victoria Avenue and La Sierra Avenue are identified as General Plan scenic parkways. It was determined that with the implementation of General Plan policies related to scenic resources and designation of certain parkways as scenic, scenic resources near parkways will be protected and enhanced throughout the City. Additionally, there are no scenic highways within the City that could potentially be impacted. Based on this analysis, impacts related to scenic resources were concluded to be less than significant.

Proposed Project
According to the Caltrans “Scenic Highways” program website, there are no designated State Eligible Scenic Highways or other designated scenic routes in the general surrounding area.
2 Similarly, according to the County General Plan, there are no designated County Eligible Scenic Highways in the surrounding area. Figure CCM-4, Master Plan of Roadways, in the City General Plan, designates La Sierra Avenue and Victoria Avenue as scenic “Parkways”

2 Caltrans State Scenic Highway Map:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed November 17, 2024.

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that have enhanced landscaping requirements. Travelers along these roadways have views of surrounding hills and mountains to the south, west, and north.

The Proposed Project site is located along two roadways considered by the City to have scenic qualities (La Sierra and Victoria), as designated by the City of Riverside’s General Plan 2025 in the Circulation & Community Mobility Element. The Proposed Project proposes enhanced landscaping along the frontage of these two roadways, especially for Victoria Avenue, and it is within the Victoria Avenue Policy area, with which it must comply.

Additionally, the Proposed Project site is on the western boundary of the area governed by the Victoria Avenue Policy for Preservation, Design and Development , which applies to Victoria Avenue from the intersection of La Sierra on the west, approximately 7.5 miles west to the intersection of Myrtle Avenue. Development policies within the guidance document and how the Proposed Project complies with these policies is provided in Table 5 .1-1:

Compliance with Victoria Avenue Policies.

Table 5.1-1: Compliance with Victoria Avenue Policies
Policy Proposed Project Compliance
B. Trails:

3. Any new segments of trail shall be designed
and constructed to meet adopted City trail
standards.

Consistent. The project complies with the policy
guidelines for the preservation, design, and
development of a proposed 10 -foot-wide trail
along Victoria Avenue and the protection of the
existing groves to a depth of 100 feet from the
edge of Victoria Avenue.

4. All roadway modifications shall promote the
use of trails and protect the safety of
pedestrians and cyclists.

Consistent. As shown, Tentative Map No. 38921,
the Proposed Project will construct a n ew 10 -
foot-wide trail per the Trails Master Plan and
Trails Standards from the Victoria Avenue Policy
for the trail segment adjacent to the Proposed
Project Site.

C. Tree Protection

1.Any existing, healthy trees and their roots,
trunks and canopies, lo cated along Victoria
Avenue, or within 100 feet of Victoria Avenue’s
edge of roadway, shall be protected from any
construction activity.

Consistent. Prior to the issuance of grading or
building permits, the construction drawings will
identify the area to be avoided during
construction.

D. Single- and Two-Story Structures

1.For properties that front- on, side -on or
reverse-on to Victoria Avenue:
a. Single story structures:

Not Applicable. As shown on the Site Plan on file
with the Planning Department, there are no lots
that access Victoria Avenue.

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Policy Proposed Project Compliance
i. Are preferred and encouraged over two-
story structures; and
ii. Shall meet the s etback requirement of
Title 19, Zoning of the Riverside Municipal
Code.
b. Two-story structures:
i. Shall meet the setback requirements of
Title 19, Zoning of the Riverside Municipal
Code; and
ii. Shall be set back a minimum of 50 feet
from the ultimate right- of-way of Victoria
Avenue.

DI. Building Design and Landscaping

1.Any building constructed within 200 feet of
Victoria Av enue and located on properties
with frontage along Victoria Avenue shall be
required to obtain a Certificate of
Appropriateness from the Historic Preservation
Officer or Qualified Designee.

Not Applicable. Based on the Update to the
Cultural Resource Surve y (Appendix C), the
Proposed Project site is not identified as a
Historic Landmark or located within a Historic
District, nor are there properties with residences
that have proposed frontage on Victoria
Avenue; therefore, a Certificate of
Appropriateness is not required.

2.Buildings shall incorporate high quality
architectural design and detail, including
“four-sided” architecture subject to approval
by the Historic Preservation Officer or Qualified
Designee.

Not Applicable. Same as above.

When visible from Victoria Avenue, design
approvals shall include the following:
a. Building elevations, including colors;
b. Landscaping;
c. Fencing and walls;
d. Tree removals or additions; and
e. Driveway location and design.

Consistent. Planning staff and the other City
Departments and Divisions have reviewed the
Proposed Project through the City’s internal
application review process. This review process
enables various City Departments and Divisions
(i.e., Planning, Building, Public Works/
Engineering, Police, and Fire Department ) to
thoroughly evaluate land use development
proposals for conformity with the provisions
established in the City’s Municipal and Zoning
Code. Additionally, the review process ensures
that the proposal is designed to be compatible
with existing land uses and structures on-site and
on neighboring properties.

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Policy Proposed Project Compliance
DII. Trees Required for New Development

1. Any new development shall be required to
plant three (3) rows of trees within the
Victoria Avenue right-of-way.

2. The trees shall be planted between the
roadway and private property(both sides
of the Avenue).

3. Tree selection shall maintain the historic -
agricultural character of property
frontages along Victoria Avenue reflective
of the citrus groves in Riverside’s Historic
Greenbelt area.

Consistent. As shown on t he Conceptual
Landscape Plan on file with the Planning
Department, the Proposed Project would
preserve the existing grove of orange trees
located 100-feet from Victoria Avenue’s edge,
consisting of approximately six rows of trees.

G. Maintenance

3. Right-of-way
b. Additional right-of-way shall be required for
new development along Victoria Avenue to
provide for an ultimate right-of-way width of a
minimum of 180 feet (90 feet on each side of
the centerline of median), as illustrated in
Figure 2 below and consistent with policy
recommendations of the 1972 Specific Plan for
Victoria Avenue.

Consistent. As shown on Tentative Tract Map No.
38921, on file with the Planning Department , a
right-of-way dedication of 45 feet from the
monument centerline of Victoria Avenue will be
offered.
c. Dedication shall be required where the
existing undeveloped right-of-way is less than
180 feet.

Consistent. Same as above.

H. Landscaping Corners and along Side Streets

1. For any new development at a corner
property, landscapin
g shall be required at
the corner, and along the side street,
consistent with landscaping along Victoria
Avenue.

2. Landscaping shall be subject to approval
by the Historic Preservation Officer or
Qualified Designee.

Consistent. As shown in the Conceptual
Landscape Plan on file with the Planning
Department, the corner of Victoria Avenue and
La Sierra Avenue is within the area where the
existing orange trees will be preserved.

I. Utility Vaults

1.Utility facilities on Victoria Avenue, or on an
intersecting street within 200
feet of Victoria
Avenue, shall be either constructed
underground or appropriately screened
subject to approval of the Planning Division.

Consistent. New utilities in the areas mentioned
will be placed underground, and any new
above-ground utilities would be appropriately
screened as required.

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The Proposed Project complies with these policy guidelines by providing a 10-foot-wide trail along Victoria Avenue and protecting the existing orange groves to a depth of 100-feet from the edge of Victoria Avenue. Therefore, consistent with the GP PEIR, the Proposed Project will have a less than significant impact on scenic resources within a scenic parkway and no impacts on scenic resources within a state scenic highway and no mitigation is required.

5.1.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the proposed project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
c) Would the project, in non-urbanized areas, 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 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?
GP PEIR Impact Determination - Less than Significant
The GP PEIR analyzed whether the General Plan Project would substantially degrade the existing visual character of the City (refer to GP EIR, pp 5.1 -21 through 5.1- 22) The GP PEIR found that with regard to specific future development projects in the City, the development will be required to implement the General Plan’s goals and policies set forth in the 2025 General Plan addressing scenic quality and will be subject to design review consistent with established Citywide Design and Sign Guidelines. As such, the impacts are considered to be less than significant. The GP PEIR also states that the Zoning Code amendments will require all site plans to come under review to prevent unlawful or nonconforming uses and structures , and provides standards for fences and walls, landscaping, screening of exterior mechanical equipment, treatment of trash enclosures, and similar features that affect the visual integrity of a development site.

The General Plan Project also included adoption of the Citywide Design and Sign Guidelines, which provide pictorial guidance on building treatments, façade articulation, site planning, sign guidelines and other matters. The GP PEIR found that t he Guidelines prevent ed large windowless blank walls through building articulation, required vegetation screening and established appropriate landscape areas along walls. The Guidelines also prov ided requirements for façade and signage treatments to prevent the use of highly reflective surfaces, large, blank, unarticulated wall surfaces, exposed, untreated precision block walls, CEQA Sections 15168 and 15183 Analysis
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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 d the use of neutral paint colors, subtle lighting, and courtyard entrances where feasible. The GP PEIR concluded that based on these features the Design and Sign Guidelines would limit impacts to aesthetic resources and visual character.

The GP PEIR concluded that the General Plan Project would not substantially degrade the City’s existing visual character and as such, the impacts were less than significant.

Proposed Project
According to CEQA Statue and Guidelines §21071, a city that has a population of at least 100,000 is considered to be an urbanized area. The City’s current population is approximately 313,676 people so the City is considered an urbanized a rea (DOF). As such, the Proposed Project design was evaluated to determine consistency with applicable regulations governing scenic quality through the City’s design review procedures process required by Municipal Code section 19.710.020.

As part of the G eneral Plan Project, t he City of Riverside adopted the Riverside Citywide Design Guidelines and Sign Guidelines in 2007. Chapter III, Section A of the document provides residential design guidelines for single-family residential design. Additionally, Victoria Avenue is designated as a Parkway Scenic Boulevard and Special Boulevard in the Circulation and Community Mobility Element of the General Plan. As shown in Exhibit 8 , the Proposed Project proposes 1.4 acres of the northern portion of the site to have a 10-foot-wide decomposed granite (DG) multi-use trail through a grove of citrus trees that will remain from the existing onsite orchard that is no longer commercially harvested consistent with the Victoria Avenue Policy requirements.

Planning staff and the other City Departments and Divisions have reviewed the Proposed Project through the City’s internal application review process. This review process enables various City Departments and Divisions (i.e., Planning, Building, Public Work s/ Engineering, Police, and Fire Department) to thoroughly evaluate land use development proposals for conformity with the provisions established in the City’s Municipal and Zoning Code.

Additionally, the review process ensures that the proposal is designed to be compatible with existing land uses and structures on-site and on neighboring properties. In this way, the quality and economic health of local residential, commercial, and industrial districts are appropriately maintained. Based upon the review of the Proposed Project , staff has determined that the proposed site improvements conform to the requirements of the General Plan and Zoning Code and are compatible with the surrounding area. Conditions of approval are applied to a project to address potential compatibility issues and enhance the project to achieve greater consistency with the intent of the General Plan and Zoning Code.

Also, although the Proposed Project seeks minor deviations/waivers from zoning development standards (such as lot area, lot width, and lot depth), the Zoning Code anticipates such deviations, consistent with State Density Bonus Law. In addition, the Proposed Project proposes a single-family subdivision that is similar in scale to and intensity to CEQA Sections 15168 and 15183 Analysis
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surrounding developments, inclu ding those across Victoria Avenue. The Proposed Project would also incorporate significant landscaping, including along Victoria Avenue, which would buffer the Proposed Project and ensure compliance with design standards. Thus, the Proposed Project would not jeopardize scenic quality. As such, the Proposed Project would not conflict with applicable zoning and other regulations governing scenic quality and would have a less than significant impact, consistent with the analysis in the GP PEIR.

MM Aes-1 states:

MM Aes-1: To further reduce impacts related to light pollution, the City shall require at the time of issuance of building permits all de velopment which introduces light sources, or modifications to existing light sources, to have shielding devices or other light pollution limiting characteristics such as hoods or lumen restrictions.

Proposed Project
Impacts from lighting may occur if exce ssive or inappropriately directed lighting impacts nearby residential uses and reduces the ability to see the night sky and stars. The Proposed Project would result in an incremental increase in new sources of light or glare, but it will be consistent with similar existing uses in the surrounding area. As required by GP PEIR MM Aes-1 CEQA Sections 15168 and 15183 Analysis
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above, all lighting would comply with applicable standards from the City’s Municipal Code (Chapter 19.556, Outdoor Lighting and Chapter 19.590, Performance Standards) and California Building Code (Title 24, California Code of Regulations) standards, which would ensure that light and glare impacts from the Proposed Project would be less than significant.

Additionally, exterior building materials are proposed that would not contribute to daytime glare impacts and also be similar to those types of materials already used by existing residences in the surrounding area. With the lighting limits outlined in the City Zoning Code and implementation of the City’s standard Conditions of Approval, the Proposed Project will have less than significant direct, indirect, or cumulative impacts related to light, glare, or day or nighttime views, and no mitigation is required.

5.1.2 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the proposed project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

5.1.2 Cumulative Impacts Analysis
The GP PEIR evaluated the potential impacts associated with the General Plan project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently consider s cumulative impacts associated with population growth and increased development.

With respect to aesthetics, the GP PEIR (Section 6) explained that although development would increase in the City, including increasing sources of light/glare and adding structures, the goals/policies within the General Plan, standards of the zoning code, and other applicable policies that control development would limit potential impacts to aesthetic resources, including views, parkways and scenic corridors, and increased light/glare.

As discussed above, the Proposed Project would adhere to all applicable standards intended to minimize impacts to aesthetic resources, including the Victoria Avenue Policy for Preservation, Design and Development, as well as the zoning code’s light pollution standards (as implemented by MM Aes 1). The Proposed Project will change the nature of the existing site, however, it will introduce a use that is consistent with the surrounding uses. The Proposed Project would not result in a cumulative aesthetic impact.

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5.1.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures
City of Riverside Municipal Code Title 19 – Zoning
• Chapter 19.100.040 Residential Development Standards R-1-1/2Acre. • Chapter 19.545.070.A waiver or reduction to development standards. • Title 17 of the Riverside Municipal Code governs grading and other earthwork during construction, including fills and embankments. In part, it regulates hillside and arroyo grading in a manner that “minimizes the effects of grading on natural landforms…[and ensures] that significant natural characteristics such as landform…[and] scenic qualities…can be substantially maintained” (Riverside Municipal Code §17.01.010).
• Through Ordinance No.7447, the City adopted outdoor lighting regulations to ensure that outdoor lighting is adequate for safety and security while preserving the naturally dark sky through mitigating artificial sky glow and preventing light and glare pollution. The ordinance, located in Chapter 19.556 of the Riversi de Municipal Code, includes various light zones in the City and development standards for each zone.
• Through Resolution Number 21544, the City of Riverside adopted the Citywide Design Guidelines and Sign Guidelines to manage developing of the physical image of the City’s residential neighborhoods and shopping centers to emphasize “a small-town character within an urban metropolis.” This document offers an overview of what the City considers good design, outlines design objectives in terms of architectural styles relative to context and historic character in the areas where development occurs. It also provides specific guidance on scale and mass, landscaping, fences, privacy protection, common open space, and parking.

Applicable General Plan Policies
The following policies are applicable to the Proposed Project and were considered in the analysis above.
• Policy OS-2.2: Limit the extent and intensity of uses and development in areas of unstable terrain, steep terrain, scenic vistas, arroyos and other critica l environmental areas.
• Policy OS-2.3: Control the grading of land, pursuant to the City’s Grading Code, to minimize the potential for erosion, landscaping, and other forms of land failure, as well as to limit the potential negative aesthetic impact of excessive modification of natural landforms.
• Policy LU- 11.2: Recognize Victoria Avenue, Magnolia Avenue/Market Street, University Avenue, Van Buren Boulevard, Riverwalk Parkway, La Sierra Avenue, CEQA Sections 15168 and 15183 Analysis
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Arlington Avenue, Canyon Crest Drive, and Overlook Parkway as the fundamental elements of the City's parkway landscape network, and components of Riverside Park.
• Policy LU-11.3: Seek opportunities to provide enhanced bicycle and pedestrian usage along parkways through the development process.
• Policy LU-27.4: Encourage trees on private property to add to the City’s urban forest.
• Policy CCM-2.8: Design street improvements considering the effect on aesthetic character and livability of residential neighborhoods, along with traffic engineering criteria.
• Policy CCM-2.14: Ensure that intersection improvements on Victoria Avenue are limited to areas where Level of Service is below the City standard of D. Allow only the minimum necessary improvements in recognition of Victoria Avenue’s historic character.
• Policy OS -1.6: Ensure that any new development that does occur is effectively integrated through convenient street and/or pedestrian connections, as well as through visual connections.
• Victoria Avenue Policy for Preservation, Design and Development , November 2019.

Appliable General Plan EIR Mitigation Measures
MM Aes 1: To further reduce impacts related to light pollution, the City shall require at the time of issuance of building permits all development which introduces light sources, or modifications to existing light sources, to have shielding devices or other light pollution limiting characteristics such as hoods or lumen restrictions.

5.1.4 Conclusion
With regards to the issue area of Aesthetics, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

3. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

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5. The Proposed Project would comply with the mitigation measure contained within the GP PEIR which is designed to reduce any potential Proposed Project-specific impact to less than significant, and no further mitigation measures are required.

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5.2 Agriculture and Forestry Resources
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/M
ore Severe
Impact?
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information complied by the California Depar tment of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and the forest carbon measurement methodology provided in the Forest Protocols adopted by the California Air Resources Board.

Would the project:
a) 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 non-agricultural use?
Significant and
Unavoidable No No No No
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?
Significant and
Unavoidable No No No No
c) Conflict with existing zoning for, or
cause rezoning of, forest land (as
defined in Public Resources Code
section 12220(g)) timberland (as
defined in Public Resources Code
section 4526), or timberland zoned
Timberland Production (as defined
by Government Code section
51104(g))?
Not Analyzed Less Than
Significant
Less Than
Significant
Less Than
Significant
Less Than
Significant
d) Result in the loss of forest land or
conversion of forest land to non-
forest use?
Not Analyzed No Impact No Impact No Impact No Impact
e) Involve other changes in the
existing environment which, due to
their location or nature, could result
in conversion of Farmland, to non-
agricultural use or conversion of
forest land to non-forest use?
Significant and
Unavoidable
Less Than
Significant
Less Than
Significant
Less Than
Significant
Less Than
Significant
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5.2.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Land Evaluation and Site Assessment Model for La Sierra and Victoria, EPC Environmental Inc., December 10, 2024 (Appendix B-1).
a) 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 non-agricultural use? GP PEIR Impact Determination – Significant and Unavoidable The GP PEIR analyzes this threshold on pages 5.2-18 through 5.2-20. The GP PEIR concluded that the General Plan Project would have a significant and unavoidable impact on the conversion of farmland to non-agricultural uses. The GP PEIR reached this conclusion because the General Plan and Zoning designations proposed as part of the General Plan Project affected farmland and did not provide for the preservation of Prime Farmland, Unique Farmland or Farmland of Statewide Importance . In addition, General Plan policies d id not require preservation of designated Farmland.

The General Plan EIR considered mitigation measures to compensate for the loss of farmland on a Citywide and cumulative basis . These measures consisted of implementing a program that would establish a fee for the purchase of agricultural replacement land or a program that would establish agricultural easements. The EIR found that this measure would not:
(1) avoid the loss of farmland,
(2) minimize the scope of the project,
(3) repair, rehabilitate, or restore the affected farmland, (4) or replace the affected farmland with substitute farmland.

Thus, such a program would not actually mitigate the significant imp act caused by the Project. (State CEQA Guidelines, § 15370.) The General Plan discourages premature conversion of agricultural lands, but does not require protection of designated Farmland. The GP PEIR specifically concluded that maintaining agricultural uses outside of the RC and RA-5 Zones is not economically viable. Also, environmental factors and regulations were found to cause the decline in the viability of agriculture in the area.

Proposed Project
The California Dept of Conservation, Important Farm lands Map identifies that the Proposed Project Site is classified as Prime Farmland. However, the City’s General Plan Land Use Designation of Low-Density Residential (LDR, 4.1 du/ac) La Sierra South Neighborhood and a Zoning classification of R -1-1/2 – Single Family Residential Zone. Both the General Plan and zoning code identified the Proposed Project Site as providing areas for single -family residences with a variety of lot sizes and housing choices . The Proposed Project site is not CEQA Sections 15168 and 15183 Analysis
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zoned RA-5, which is intended to preserve agricultural areas regulated by Proposition R and Measure C. Thus, the GP PEIR analyzed potential conversion of the Proposed Project Site to non-agricultural uses in conjunction with the General Plan project. The GP PEIR concluded that the General Plan project would have Citywide significant and unavoidable impacts on farmland associated with various pressures that causes the conversion of f armland, including regulations, lack of water supply, urbanization, among other things. Thus, the GP PEIR analyzed the conversion of agricultural lands, such as the Proposed Project Site, in conjunction with the General Plan implementation, and no further analysis is required .

In determining whether there are Proposed Project-specific impacts to agricultural resources that would be significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (LESA) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. The LESA Model is a point -based approach that uses measurable factors to quantify the relative value of agricultural land resources and assist in the determination of the significance of agricultural land conversions.

The California LESA Model is made up of two components, known as “Land Evaluation” (LE) and “Site Assessment” (SA), that are scored and weighted separately to yield a total LE subscore and SA subscore. The Final LESA Score is the sum of the LE and SA subscores and has a maximum possible score of 100 points. Based on the Final LESA Score, numerical thresholds are used to determine the significance of a project’s impacts on agricultural resources. 3 For
a complete description of the LESA methodology, please refer to the Land and Site Assessment (Appendix B-1). Table 5.2-1: California LESA Model Scoring Thresholds identifies the scoring thresholds.

Table 5.2-1: California LESA Model Scoring Thresholds
Total LESA
Score
Scoring Decision
0 to 39 Not Considered Significant
40 to 59 Considered Significant only if LE and SA subscores are each greater than or equal to 20 points
60 – 79 Considered Significant unless either LE or SA subscores is less than 20 points 80 to 100 Considered Significant

3 https://www.conservation.ca.gov/dlrp/Documents/lesamodl.pdf 1997 pg. 31 CEQA Sections 15168 and 15183 Analysis
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Land Evaluation (LE)
The LE subscore consists of two factors, including the Land Capability Classification (LCC) rating and the Storie Index rating, which were devised t o measure the inherent soil -based qualities of land as they relate to agricultural production. The LCC Rating and Storie Index rating scores are based upon the soil map unit(s) identified on a property and the acreage of each soil mapping unit relative to the property’s total acreage. Data for the soil map unit(s), LCC, and Storie Index are obtained from soil survey data provided by the U.S.

Department of Agriculture (USDA) Natural Resources Conservation Service. 4 Site Assessment (SA)

The SA subscore consists of four (4) factors that measure social, economic, and geographic features that contribute to the overall value of agricultural land. The SA factors include Project Size, Water Resource Availability, Surrounding Agricultural Land, and Protected Re source Land.
5 Table 5.2-2: Total LESA Score Sheet – Proposed Project Site identifies the LESA Scoring Thresholds.

Table 5.2-2: Total LESA Score Sheet – Proposed Project Site Factor Category Factor Scores Factor Weight Weighted Factor Scores LE Factors
LCC 8.91 0.25 2.23
Storie Index 84.06 0.25 21.02
LE Subtotal 23.25
SA Factors
Proposed Project Size 0.00 0.15 0
Water Resource
Availability

80.0 0.15 12
Surrounding Agricultural
Land

0.00 0.15 0
Protected Resource
Land

0.00 0.05 0
SA Subtotal 12
Final LESA Score 35.25

As shown in Table 5.2-2, the Proposed Project Site received a LESA score of 35.25. As shown in Table 5.2-1, impacts to land that receives a LESA score between 0 and 39 are not considered significant under CEQA. Thus, the Proposed Project site is determined to have a relatively low value for agricultural production and Proposed Project impacts on agricultural r esources would not be considered significant.

4 United States Department of Agriculture. Web Soil Survey. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx Acc essed 12- 13-24
5 https://www.conservation.ca.gov/dlrp/Do cuments/lesamodl.pdf 1997 p 31 CEQA Sections 15168 and 15183 Analysis
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Therefore, the Proposed Project would result in no new or substantially more severe impacts and no peculiar impacts on conversion of important farmland to non-agricultural use.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs and, Riverside Municipal Code requirements. The Proposed Project’s implementation of those regulations, policies, and standards, including the Gen eral Plan designation and zoning, which permit the P roposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? GP PEIR Impact Determination – Significant and Unavoidable The GP PEIR analyzed Williamson Act contract conflicts and conflicts with agricultural zoning on pages 5.2-20 through 5.2-23. The GP PEIR found that although there are some Williamson Act Contracts in the City, the General Plan and Zoning Code revisions in the General Plan Project did not propose to cancel those contracts . Therefore, the GP PEIR concluded that impacts related to Williamson Act contract conflicts specifically, were less than significant.

The GP PEIR found that the adoption of the revised General Plan and Zoning Code would retain the majority of its currently designated and zoned areas that allow for agricultural uses.

But in about fourteen locations zoning designations would be changed from zones, which allow agriculture to zones. The total acreage involved in these zoning changes was 535.45 acres. Similarly, the General Plan Project would change approximately 612.23 acres, giving the land General Plan designations that do not permit agriculture. Because the General Plan Project altered both zoning and General Plan designations from designations that allow ed agricultural uses to those that do not, the GP PEIR concluded that impacts from conflicts with existing zoning for agricultural uses would be signific ant and unavoidable . No feasible mitigation was available.

Proposed Project
As shown in Exhibit 12, Proposed Project Site Proximity to Agricultural Zones, which is located at the end of this section, the Proposed Project Site has a zoning classification of R-1-½ Acre which is established to provide areas for large lot single -family residences where the keeping of livestock and other farm animals and agricultural uses are not permitted. The Residential Agricultural Zone (RA -5) is established to provide area s where general agricultural uses can occur independently or in conjunction with a single -family residence, which preserves the agricultural character of the area. The nearest RA -5 zoned parcels are located to the northeast across Victoria Avenue and are developed with single -family residences. The other RA -5 zones in the vicinity of the Proposed Project Site are to the east and north and are separated by single -family residences.

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Additionally, a review of GP PEIR Figure 5.2-2 – Williamson Act Preserves reveals that the Proposed Project Site is within a built environment and not located within an area that is affected by a Williamson Act Preserve or under a Williamson Act Contract. The closest Williamson Act Preserv e is located over a half mile southeast of the Proposed Project Site.

Development of the Proposed Project Site would allow the continued use of existing Farmland within the Arlington Greenbelt in a manner that will ensure the viability and sustainability of existing agriculture/crop production. The Proposed Project would not have a significant impact related to conflicts with agricultural zoning or Williamson contracts . Therefore, the Proposed Project would result in no new impacts from such conflicts.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies General Plan Implementing Programs , and Riverside Municipal Code requirements. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)) timberland (as defined in Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
GP PEIR – Not Addressed
The issue of forest and timberland was not a ddressed in the GP PEIR because it was not an environmental topic under the City’s CEQA thresholds per Appendix G of the 2007 CEQA Guidelines.

Proposed Project
Subsequent to the certification of the GP PEIR, impacts regarding forest and timberland were added to Appendix G of the CEQA Guidelines.

As the City of Riverside is a densely populated, urbanized city, there is no forest land , timberland, or timberland Production zones as defined by forest land (as defined in Public Resources Code section 12220(g)) timberland (as defined in Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)) within the City limits. The most current California Department of Forestry and Fire Protection’s (CalFire) Fire Resource and Assessment Program ( FRAP) map indicates the Proposed Project Site and surrounding area do not contain any designated forest resources.

The Proposed Project does not propose to change the existing zoning, which currently allows for residential development and does not propose or require preservation of forest land or timberland. The Proposed Project would not conflict with any such zoning. Therefore, no CEQA Sections 15168 and 15183 Analysis
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impact will occur from this Proposed Project on a direct, indirect, or cumulative basis on zoning for forest land and no mitigation is required.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, and Riverside Municipal Code requirements. The Prop osed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

d) Result in the loss of forest land or conversion of forest land to non-forest use? See analysis under Threshold c above. The Proposed Project has no impact on the loss or conversion of forest land.
e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
GP PEIR Impact – Significant and Unavoidable
The GP PEIR analyzed this impact on pages 5.2-23 through 5.2-27 of the draft PEIR. The GP PEIR concluded that although the proposed General Plan Project would allow for agricultural uses in the majority of its Planning Area, the indirect influence of existing and proposed development in the City and its Sphere of Influence was expected to contribute to direct and indirect conversion of agricultural resources. In addition, some areas designated as Farmland of Local Importance would have land use and zoning designation changes that would preclude agriculture as a future use. Therefore, the GP PEIR concluded that impacts related to the conversion of Farmland of Local Importance, land subject to Proposition R and Measure C, as well as any other land being used for agricultural uses as non-conforming uses would be significant. The GP PEIR also concluded that no mitigation was feasible to reduce this significant impact.

Proposed Project Impact
For this analysis, state Farmland and agricultural land considered under this threshold include Farmland of Local Importance, Land subject to Proposition R and Measure C, land under the Williamson Act Contract, as well as any other land being used for agricultural uses as non- conforming uses. The Proposed Project Site is located in an urbanized area of the City of Riverside in an existing residential area around the La Sierra Avenue/Victoria Avenue intersection. Additionally, the site and surrounding areas are identified as urban/built-out land and do not support agricultural resources or operations although there is a commercial nursery 500 feet northeast of the Proposed Project Site. The Proposed Project will result in the conversion of 9.91 acres of farmland to non-agricultural uses. However, this land is surrounded CEQA Sections 15168 and 15183 Analysis
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by “Urban and Built-Up Land” and no longer supports citrus production. The Proposed Project is a lso consistent with the land use designation and zoning for the site, which assumes conversion to residential uses. In addition, there are no agricultural operations or farmlands currently within proximity of the subject site. The City of Riverside has no forest land that can support 10 percent native tree cover. Therefore, less than significant impact will occur from this Proposed Project on a direct, indirect, or cumulative basis related to the conversion of farmland to non-agricultural use or the loss of forest land, and no mitigation is required.

The Proposed Project has been designed consistent with the City’s guidelines, which are consistent with the City’s General Plan Policies. Based on the analysis above, the Proposed Project is consistent with appl icable General Plan Policies and General Plan Implementing Programs. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

5.2.2 Cumulative Impacts Analysis
The GP PEIR evaluated the potential impacts associated with the General Plan Project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently considers cumulative impacts associated with population growth and increased development.

With respect to agricultural resources, the GP PEIR (Section 6) acknowledged that the General Plan’s cumulative impact would be significant. Even though the General Plan includes policies intended to retain, protect, and encourage agricultural uses, the GP PEIR noted that development pressures, limited water resources, a nd high costs associated with agriculture would result in direct and indirect adverse impacts. The General Plan, which increased buildout within the City, contributed to that loss. Therefore, the GP PEIR concluded that no feasible mitigation was available.

The Proposed Project is consistent with the site’s existing General Plan designation and zoning, neither of which protect agricultural resources. Even though the site is identified as prime farmland, its value falls below applicable standards/thresholds for determining significance under CEQA (LESA score). Thus, although the project will remove lands from agricultural use, that removal is contemplated by the General Plan and the value of the lands removed are not considered substantial. Therefore, the Pro posed Project would not result in a significant impact at a project-level and, to the extent it contributes to the loss of farmland citywide, it is within the scope of the impact identified in the GP PEIR.

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5.2.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures
There are no applicable codes, development standards or policies, or GP PEIR mitigation measures related to preserving Agricultural Resources that apply to the implementation of this Proposed Project.

5.2.4 Conclusion
With regards to the issue area of Agricultural Resources, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

3. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

5. No mitigation measures contained within the GP PEIR would be required because Proposed Project specific impacts would be less than significant.

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Exhibit 12: Proposed Project Site Proximity to Agricultural Zones

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5.3 Air Quality
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project a) Conflict with or obstruct
implementation of the
applicable air quality plan?
Significant and
Unavoidable/
Less Than
Significant
(Typical Density
Scenario)

Significant and
Unavoidable
No No No No
b) Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is non-attainment
under an applicable federal or
state ambient air quality
standard?
Significant and
Unavoidable
(Program Level)

Less Than
Significant with
Mitigation
Incorporated
(Project Level)
No No No No
c) Expose sensitive receptors to
substantial pollutant
concentrations?
Less Than
Significant No No No No
d) Result in other emissions (such
as those leading to odors)
adversely affecting a substantial
number of people?
Less Than
Significant No No No No

5.3.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Air Quality and Greenhouse Gas Technical Memorandum prepared by KPC EHS Consultants, LLC on 3-29-2024 (Appendix A).
a) Would the project conflict with or obstruct the implementation of the applicable air quality plan?
GP PEIR Impact – Less Than Significant/Significant and Unavoidable.

The GP PEIR analyze d this threshold on pages 5. 3-30 through 5. 3-33. The GP PEIR conservatively acknowledged the possibility that growth could exceed SCAG growth CEQA Sections 15168 and 15183 Analysis
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projections and therefore conflict with the AQMP. No feasible mitigation exists to reduce this impact to a less than significant level. Therefore, impacts would be significant and unavoidable.

The General Plan included three growth scenarios:
 Typical
 Maximum (Max)
 Maximum with Planned Residential Development (Max w/PRD)

Less Than Significant (Typical Growth Scenario): The GP PEIR analyzed the General Plan Project’s consistency with the South Coast Air Quality District (SCAQMD) 2003 Air Quality Management Plan (AQMP) , which was the applicable AQMP in 2007, as well as other applicable air plans, on pages 5.3-31 to 5.3-48 of the draft GP PEIR. Since the AQMP growth projections are based on Southern California Association of Governments (SCAG) population levels, the General Plan build -out at the expected Typical Growth Scenario levels was determined to be consistent with the AQMP. Therefore, implementation of the proposed General Plan would generally meet attainment forecasts, and attainment of the standards would be achieved. The proposed General Plan Project would be consistent with the AQMP policy guidance in the reduction of vehicle miles traveled. The General Plan proactively addressed regional air quality in a manner consistent with policies and measures outlined in the AQMP established by the South Coast Air Quality Management District (SCAQMD) to achieve Federal and State standards for healthful air quality in the South Coast Air Basin (Basin). Therefore, the GP PEIR concluded that the General Plan would not conflict with or obstruct the implementation of the AQMP but will facilitate AQMP implementation. In addition, the population projections under the Typical Growth Scenario were found to be consistent with SCAG projections. Therefore, because the proposed General Plan is consistent with the implementation of the 2003 AQMP, the impact was considered less than significant.

Significant and Unavoidable (Maximum and Maximum with PRD Growth Scenario): The GP PEIR found that although the Typical Growth Scenario is reasonably foreseeable, the General Plan Project would allow more development and therefore , to understand the potential impacts of full buildout , the GP P EIR also analyzed growth under the Max and Max w/PRD Growth Scenarios. Because growth under those scenarios would not be consistent with SCAG’s growth projections, such development would not be consistent with the 2003 AQMP, and under those scenarios th e GP PEIR concluded that the General Plan project’s impacts would be significant and unavoidable.

Proposed Project
The Project is located within the South Coast Air Basin (SCAB) and is under the jurisdiction of the SCAQMD. The Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) designate air basins where ambient air quality standards are exceeded as nonattainment areas. Conflicts and obstructions that hinder implementation of the AQMP CEQA Sections 15168 and 15183 Analysis
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can delay efforts to meet attainment deadlines for criteria pollutants and maintain existing compliance with applicable air quality standards.

The SCAQMD AQMP is typically updated every three to five years, with the most recent major update being the "2022 AQMP" which was adopted by the SCAQMD in December 2022. The newly adopted AQMD i s not considered new information because the 2022 AQMP merely builds upon the previous versions of the AQMP by updating growth projections, modeling for various air pollutants, and an examination of policies and regulations to determine compliance and emis sion reductions. The GP PEIR also acknowledged that if greater than typical levels of development did occur, the AQMP would be updated to reflect the levels of development (Statement of Findings, p. 46). Moreover, the AQMP (all versions) is intended to guide air quality planning and standards within the SCAB to assist with meeting federal and state air quality standards. Thus, a project’s consistency with the AQMP reflects the same conclusion regardless of AQMP version – the Proposed Project does not result in an inconsistency that would jeopardize or conflict with implementing the applicable AQMP.

The Proposed Project would be required to comply with the 2022 AQMP. Pursuant to the methodology provided in Chapter 12 of the 1993 SCAQMD CEQA Air Quality Handb ook, consistency with the South Coast Air Basin 2022 AQMP is affirmed if the project: (1) Is consistent with the growth assumptions in the AQMP; and (2) Does not increase the frequency or severity of an air quality standards violation or cause a new one.

Consistency Criterion 1 refers to the growth forecasts and associated assumptions included in the 2022 AQMP. The 2022 AQMP was designed to achieve attainment for all criteria air pollutants within the Basin while still accommodating growth in the region. P rojects that are consistent with the AQMP growth assumptions would not interfere with the attainment of air quality standards, because this growth is included in the projections used to formulate the AQMP.

The Proposed Project Site’s General Plan land use is designated as Low -Density Residential (LDR) with a maximum density allowed of 4.1 du/ac. Under the LDR designation, the maximum number of units allowed is 41 (9.91 acres x 4.1 = 40.63 rounded to 41). However, the Proposed Project proponent has applied for a density bonus under the state affordable housing law, which would increase the number of units to 49. Even with the requested density bonus, the Proposed Project ’s increase in residential population is within the growth assumptions of the General Plan, which analyzed both typical growth and maximum growth scenarios. The Proposed Project does not request a General Plan amendment or zoning amendment that would dramatically increase the permitted density/population for the site.

The Proposed Project is also consistent with applicable General Plan policies and standards related to ensuring air quality is maintained.

The projections in the AQMP for growth assumptions are based on the SCAG Regional Transportation Plan/Sustainable Communities Strategy (RTP/SC S). The RTP/SCS is updated CEQA Sections 15168 and 15183 Analysis
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every four years. According to the 2020-2045 RTP/SCS, the forecast for the City’s population growth is estimated at 19,000 residents and an additional 5,500 households. The Proposed Project would include the development of 49 single- family dwelling units. According to the State of California Department of Finance E -5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2023, the City has an estimated 3.06 persons per household 6.

The Proposed Project would therefore increase the current population by approximately 150 residents versus 125 that would result from the current General Plan designation. The increase of 150 residents (net +25) is well within the estimated 5,500 projected increase in residents and as such the Proposed Project would be consistent with the growth assumptions from the 2020- 2045 RTP/SCS used in the SCAQMD plans.

Consistency Criterion 2 refers to the California Ambient Air Quality Standards (CAAQS). In developing its CEQA significance thresholds, the SCAQMD considered the emission levels at which a project’s emissions would be cumulatively considerable (SCAQMD, 2003; page D-3).

As described below in Section 3. b, the Proposed Project would not generate construction or operational emissions above SCAQMD criteria air pollutant thresholds.

Based on the analysis of the two criteria above, it is also consistent with the AQMP. The Proposed Project will have a less than significant direct, indirect, and cumulative impact on the implementation of an air quality plan.

5.3.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR. . b) Would the p roject result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard?
GP PEIR Impact - Significant and Unavoidable
The GP PEIR analyzes this threshold on pages 5. 3-33 through 5.3-49. The GP PEIR concluded that implementation of the GP Project will result in a cumulatively considerable net increase of criteria pollutants for which the SCAB region is in non -attainment under an applicable federal or state ambient air quality standard, and result in a cumulatively considerable

6 California Department of Finance E-5 Spreadsheet, accessed:
https://dof.ca.gov/forecasting/Demographics/estimates/e -5-population-and-housing-estimates-for-citiescounties-and-the-state-2020-2023/

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increase in greenhouse gas emissions. Changes or alterations have been required of or incorporated into the project which substantially lessen the significant environmental effects identified in the GP PEIR. However, specific economic legal, social, technological, or other considerations make infeasible mitigation measures or project alternatives that would completely reduce this impact to a less than significant impact. The GP Project’s impact on air quality is considered significant and unavoidable.

Construction
The GP PEIR found that short-term impacts associated with construction from buildout of the General Plan Project will result in increased air emissions from grading, earthmoving, and construction activities that would exceed applicable SCAQMD thresholds . While individual development projects anticipated by the General Plan Pr oject will be required to employ construction approaches that minimize pollutant emissions ( see MM Air 1 through MM Air 5, e.g., watering for dust control, tuning of equipment, limiting truck idling times , identified in Section 5.3.2 of this document ), ove r the next 20 years substantial pollutant emissions associated with construction activity will be expected to occur.

Although, MM Air 1 requires that future development projects be analyzed for their short-term construction impacts, it is likely that some will not meet SCAQMD standards, therefore even at the General Plan level, the GP PEIR concluded that impacts related to short- term (construction) air emissions are significant under all development scenarios.

Operations
The development envisioned in the General Plan will generate additional emissions over time from both stationary sources and vehicular t rips. The operational (long -term) emissions at build-out of the City of Riverside’s General Plan are above the SCAQMD thresholds and will have a significant impact on air quality in the Planning Area. Additionally, the City of Riverside is in non-attainment for ozone, carbon monoxide, PM10, and PM-2.5. Thus, the evaluation of build-out generated emissions in relation to the thresholds of significance demonstrates that impacts on air quality from General Plan implementation are considered significant, even with the mitigation measures incorporated. The 10 mitigation measures identified in the GP PEIR related to air quality impacts are identified in the GP PEIR on pages 5.3 -51 through 5.3- 54 (mitigation measures that are applicable to the current Proposed Project are identified in Section 5.3.2 of this document).

Proposed Project
In accordance with the General Plan Mitigation Measure MM Air-7, the Proposed Project- specific impacts were analyzed utilizing the California Emissions Estimator Model (CalEEMod) version 2022.1.1.22, which is a statewide land use emissions computer model designed to provide a uniform platform for government agencies to quantify potential criteria pollutant emissions associated with both construction and operations emissions. CalEEMod is authorized by the SCAQMD to assess Proposed Project emissions and replaced URBEMIS. As addressed in the Proposed Project -specific air quality assessment in Appendix A of this document, the results of the emissions modeling indicate that the Proposed Pro ject would CEQA Sections 15168 and 15183 Analysis
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not have impacts that exceed the SCAQMD’s thresholds of significance for construction or operation as shown in Table 5.3-1: Summary of Peak Construction Emissions (No Mitigation), Table 5.3-2: Summary of Peak Operational Summer Emissions, and Table 5.3-3: Summary of Peak Operational Winter Emissions. Therefore, the Proposed Project’s emissions would not be cumulatively considerable, and impacts would be less than significant, which is less than the impacts disclosed by the GP PEIR.

Table 5.3-1: Summary of Peak Construction Emissions (No Mitigation)

Year/Season
Emissions (lbs/day)
ROG NOX CO SOX PM10 PM2.5
Construction 2024 (Summer) 3.74 36.0 34.4 0.10 9.49 5.47 Construction 2024 (Winter) 1.29 11.5 14.3 0.02 0.78 0.53 Construction 2025 (Summer) 30.0 10.7 14.5 0.02 0.71 0.47 Construction 2025 (Winter) 1.20 10.7 14.1 0.02 0.71 0.47 Maximum Daily Emissions 30.0 36.0 34.4 0.10 9.49 5.47
SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
Source: CalEEMod 2022.1.1.22 Datasheets. (Appendix A).

Table 5.3-2: Summary of Peak Operational Summer Emissions Source Emissions (lbs/day)
VOC/ROG NOX CO SOX PM10 PM2.5
Mobile Source 1.85 1.56 14.4 0.03 3.06 0.79
Area Source 2.46 0.03 2.78 <0.005 <0.005 <0.005
Energy Source 0.03 0.44 0.19 <0.005 0.04 0.04
Total Maximum Daily Emissions 4.33 2.03 17.3 0.04 3.10 0.83 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
Source: CalEEMod 2022.1.1.22 Datasheets. (Appendix A).

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Table 5.3-3: Summary of Peak Operational Winter Emissions Source Emissions (lbs/day)
VOC/ROG NOX CO SOX PM10 PM2.5
Mobile Source 1.73 1.56 12.2 0.03 3.06 0.79
Area Source 2.21 - - - - -
Energy Source 0.03 0.44 0.19 <0.005 0.04 0.04
Total Maximum Daily Emissions 3.96 2.12 12.4 0.04 3.10 0.83 SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
Source: CalEEMod 2022.1.1.22 Datasheets. (Appendix A).

The Proposed Project has been designed consistent City’s General Plan Policies and mitigation measures identified in the GP PEIR. The GP PEIR identified that with mitigation, impacts to air quality during General Plan implementation would be significant and unavoidable. Based on the analysis above, the Proposed Project would not exceed threshold established by the SCAQMD and would be consistent with applicable General Plan Policies, General Plan Implementing Programs, and Uniformly Applied Development Standards as identified in Section 5.3. 3 of this document. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
c) Would the project expose sensitive receptors to substantial pollutant concentrations? GP PEIR Impact - Significant and Unavoidable
The GP PEIR analyzes this threshold on pages 5. 3-48 through 5.3-49. The GP PEIR concluded that even with regular assessment of air quality in relation to sensitive receptors from new development projects and transportation improvements and adherence to policies such as AQ-2.5, impacts related to exposing sensitive recept ors to substantial pollutant concentrations are significant and unavoidable.

Sensitive receptors include existing and future residential uses, school playgrounds, childcare facilities, athletic facilities, hospitals, and convalescent homes within the Planning Area. Short- term impacts associated with construction from General Plan buildout will result in increased air emissions from grading, earthmoving, and construction activities. The common air emission sources from construction that can be mitigated effectively are mostly PM-10 (air borne dust).

Mitigation measure MM Air 2 addresses ways future sources of PM -10 can be lessened.

Construction activity will also generate CO, NOX, and PM-10 and PM-2.5 (primarily from diesel engines). Mitigation measures MM Air -3 and MM Air -4 address reducing diesel emissions from construction. Architectural coatings, exterior paints, and asphalt may release reactive organic gases (ROG). Because the General Plan only sets forth broad parameters for new CEQA Sections 15168 and 15183 Analysis
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development and does n ot identify specific development projects, construction- related emissions of individual future developments cannot be quantified at this time. The GP PEIR considered that there could be relatively robust economic conditions over the next 20 years, and that construction activity will be constant throughout the Planning Area. Although MM Air-1 requires that future development projects be analyzed for their short -term impacts, it was not known if all impacts can be reduced to less than significant levels, and therefore at the General Plan level, the GP PEIR concluded that impacts related to short- term (construction) emissions were significant.

Long-term implementation of the General Plan will allow for substantial population and employment growth and development within the Planning Area. As a result, there will be a significant increase in the number of sensitive receptors within the Planning Area, which could be exposed to substantial pollutant concentrations. Review of individual projects will be necessary to ensure that projects involving activities (construction and operation) that generate significant levels of air pollutants are carefully designed and regulated to ensure that pollutant levels are reduced below significance thresholds and not concentrated near sensitive receptors. General Plan Policies like AQ -1.3 address how to lessen impacts to sensitive receptors. Policy AQ -1.12 supports mixed use land use patterns and encourages community centers that promote community self -sufficiency and discourage aut omobile dependency. Policy AQ -1.13 encourages employment centers that are non- polluting or extremely low-polluting and does not draw large numbers of vehicles near residential uses.

Policy AQ -3.6 supports “green” building codes that require air conditionin g/filtration installation, upgrades, or improvements for all buildings, but particularly for those associated with sensitive receptors. Vehicular emissions can also be concentrated near sensitive receptors, primarily at congested intersections. These conditions can result in localized CO “Hot Spots.” The General Plan Circulation and Community Mobility Element is intended to improve intersections and relieve congestion which affects traffic movement. Even with regular assessment of air quality in relation to sensitive receptors from new development projects and transportation improvements and adherence to policies such as AQ -2.5, impacts related to exposing sensitive receptors to substantial pollutant concentrations are expected to be significant and unavoidable.

Proposed Project
Sensitive receptors are those segments of the population that are most susceptible to poor air quality such as children, the elderly, the sick, and athletes who perform outdoors. Land uses associated with sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. For purposes of CEQA, the SCAQMD considers a sensitive receptor to be a location where a sensitive individual could remain for 24 hours. The closest sensitive receptors to the Proposed Project Site are shown in Table 5.3-4: Sensitive Receptor Locations and consist of various residences located from 60 to 175 feet from the Proposed Project Site (at their closest point so this would be considered the “worst case” condition).

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Table 5.3-4: Sensitive Receptor Locations
Closest Receptor (Direction)
Distance from
Proposed Project
Site Boundary (feet)
Distance from Proposed
Project Construction Center
(feet)
Residence (southeast) 75 425
Residence across Millsweet Place (northeast) 60 370
Residence across Victoria Avenue (north) 175 500
Residences across La Sierra Avenue (southwest) 115 450

Localized Significance Thresholds (LSTs)
The SCAQMD has established Localized Significance Thresholds (LST), which are used to determine whether a project may generate significant adverse localized air quality impacts for both construction and on-site operations. For a CEQA analysis, the SCAQMD considers a sensitive receptor to be a receptor such as a residential, hospital, or convalescent facility where it is possible that an individual could remain for 24 hours If the calculated emissions for the proposed construction or operational activities are below the LST emission thresholds then the proposed construction or operation activity is not significant for air quality.

Construction. The Proposed Project’s maximum daily construction emissions are compared against the SCAQMD-recommended LSTs in Table 5.3-4. The LSTs are for SRA 23 (Metropolitan Riverside County) in which the Proposed Project is located. Construction emissions were estimated against the SCAQMD’s thresholds for a 5 -acre Proposed Project size. A receptor distance of 25 meters (82 feet) was used to evaluate impacts at sensitive residential receptor locations for construction activities. This is considered to be a conservative approach as 1) the project would involve grading/site disturbance of approximately 8.8 acres, which is more than 5 acres, and 2) the nearest sensitive receptor property (i.e., residence) is approximately 60 feet northeast of the Proposed Project site. The results in Appendix A indicate that there would be a less than s ignificant impact to the LSTs as identified on Table 5.3- 4 because emissions do not exceed SCAQMD Thresholds, and the receptors are greater than 82 feet from the Proposed Project site.

Operations. The Proposed Project proposes 49 dwelling units and reside ntial uses are not considered uses with a potential to result in operational air quality impacts. Once constructed, vehicle trips will be the largest source of operational air emissions from the Proposed Project . However, as residential uses, the vast majo rity of vehicle trips will be passenger vehicles, not diesel-powered vehicles. Also, the Proposed Project will only result in the generation of a minimal amount of trips (less than 50 trips during the AM and PM peak hours). That low level of trips will not generate emissions that could cause exceedances of LSTs during the operational phase of the Proposed Project.

5.3.3 of this document. The Proposed Project’s implementation of those regulations, policies, CEQA Sections 15168 and 15183 Analysis
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and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
d) Would the p roject result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
GP PEIR Impact - Less than Significant
The GP PEIR analyzes this threshold on pages 5. 3-50. The GP PEIR concluded that implementation of the proposed General Plan will not result in development that will cause objectionable odors affecting a substantial number of people and the impacts thereof will be less than significant.

The GP PEIR found that potential operational airborne odors could occur as a result of certain land uses and how they are sited relative to other land uses. The analysis fo und that Policy AQ-2.11 promotes the use of the “Good Neighbor Guidelines for Siting New and/or Modified Warehouse/Distribution Facilities” in determining which land uses are compatible with each other. Additionally, the analysis concluded there would be n o significant impact because future industrial and commercial uses established pursuant to the General Plan that could generate objectionable odors within the Planning Area will be subject to SCAQMD Rule 402 governing odor emissions. Under that rule, any objectionable odor may be reported to the SCAQMD, which resolves complaints through investigation and would issue a Notice to Comply/Notice of Violation when necessary. Therefore, implementation of the proposed General Plan Project will not result in develo pment that will cause objectionable odors affecting a substantial number of people and the impacts thereof will be less than significant.

Proposed Project
The Proposed Project would be required to comply with all applicable General Plan policies relative to odors. As with the General Plan, objectional odors are subject to SCAQMD Rule 402 that governs complaints through investigation. The Proposed Project does not contain any land uses associated with emitting objectionable odors. Potential temporary odor sources associated with the Proposed Project may result from construction (e.g., equipment exhaust, application of asphalt and architectural coatings). The construction odor emissions would be temporary, short -term, and intermittent in nature and would cease upon completion of construction and are thus considered less than significant. Potential long term odor sources may arise from solid waste. The Proposed Project design includes solid waste enclosures, and Proposed Project-generated refuse would be removed at regular intervals in compliance with the City’s waste hauler contracts. The Proposed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances.

Therefore, odors associated with the Proposed Project construction and operations would be less than significant and no mitigation is required
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5.3.2 Cumulative Impacts Analysis
The GP PEIR evaluated th e potential impacts associated with the General Plan Project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently considers cumulative impacts associated with population growth and increased development.

With respect to air quality, the GP PEIR concluded that the General Plan Project would result in cumulative impacts related to air quality emissions, resulting from the assumed buildout and population increases associated with the General Plan. The Proposed Project is consistent with the assumptions in the General Plan, as reflected in the GP PEIR. Also, at the project-level, the Proposed Project would not result in any individual exceeda nces or inconsistencies with air emissions plans or policies that may jeopardize their implementation.

The project would, therefore, not result in cumulatively considerable significant impacts with respect to air quality.

5.3.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures
Applicable General Plan Policies
The following policies are applicable to the Proposed Project and were considered in the analysis above.
• Policy AQ -1.3: Separate, buffer and protect sensitive receptors from significant sources of pollution to the greatest extent possible.
• Policy AQ -3.4: Require projects to mitigate, to the extent feasible, anticipated emissions, which exceed AQMP Guidelines.
• Policy AQ-3.6: Support “green” building codes that require air conditioning/filtration installation, upgrades, or improvements for all buildings, but particularly for those associated with sensitive receptors.
• Policy AQ-4.1: Identify and monitor sources, enforce existing regulations and promote stronger controls to reduce particulate matter (e.g., require clean fuels for street sweepers and trash trucks, exceed the AQMD requirements for fleet rules).

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• Policy AQ-4.3: Support the reduction of all particulates potential sources. • Policy AQ-4.4: Support programs that reduce emissions from building materials and methods that generate excessive pollutants through incentives and/or regulations. • Policy AQ-4.5: Require the suspension of all grading operations when wind speeds (as instantaneous gusts) exceed 25 miles per hours).
• Policy AQ-5.7: Require residential building construction to meet or exceed energy use guidelines in Title 24 of the California Administrative Code.

Applicable General Plan Mitigation Measures
• MM Air -1: Implement measures to reduce construction- related criteria air pollutant emissions
• MM Air -2: Implement measures to reduce criteria air pollutant emissions during operation.
• MM Air -3: To reduce both mobile and stationary source emissions, to the extent feasible, the City will use Best Available Control Technologies and Best Available Retrofit Control Technology, as defined by SCAQMD.
• MM Air -4: To reduce diesel emissions associated with construction, construction contractors shall provide temporary electric ity to the site to eliminate the need for diesel-powered electric generators.
• MM Air-5: To reduce construction related particulate matter air quality impacts of City projects various measures shall be required such as compliance with SCAQMD rules, covering loads of soil and maintaining a traffic control plan. • MM Air-6: The City will implement the Good Neighbor Guidelines prepared by Western Riverside Council of Governments in coordination with the South Coast Air Quality Management District.
• MM Air-7: As part of the CEQA process, the City shall require proposed development projects with potential operational air quality impacts to identify and mitigate those impacts. To ensure proper characterization and mitigation of those impacts, regional impacts shall be analyzed using the latest available URBEMIS model, or other analytical method determined in conjunction with the SCAQMD.

5.3.4 Conclusion
With regards to the issue area of Air Quality, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

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3. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

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5.4 Biological Resources
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
Would the project:
a) 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. Fish and
Wildlife Service?
Less Than
Significant with
Mitigation
Incorporated
No No No No
b) 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?
Less Than
Significant with
Mitigation
Incorporated
No No No No
c) Have a substantial adverse
effect on state or federally
protected wetlands (including,
but not limited to, marsh, vernal
pool, coastal, etc.) through
direct removal, filling,
hydrological interruption, or other
means?
Less Than
Significant with
Mitigation
Incorporated
No No No No
d) 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?
Less Than
Significant with
Mitigation
Incorporated
No No No No
e) Conflict with any local policies
or ordinances protecting
biological resources, such as a
tree preservation policy or
ordinance?
Less Than
Significant No No No No
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f) Conflict with the provisions of
an adopted Habitat
Conservation Plan, Natural
Community Conservation Plan, or
other approved local, regional,
or state habitat conservation
plan?
Less Than
Significant No No No No

5.4.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Biological Resources Assessment (BRA), prepared by VCS Environmental, April 1, 2024 (Appendix B-2).

The GP PEIR assessed the six topics, a through f abov e. The overall analysis assumed that since the City of Riverside is signatory to the Western Riverside Multiple Species Habitat Conservation Plan (MHSCP), that all individual projects would be required to comply with the MSHCP, which is designed to reduce impacts on species and habitat. The GP PEIR also broadly assumed for all topic areas that Mitigation Measure Bio- 1 which requires project -specific surveys, would also be implemented. As such, all project topics were identified to be less than significant.

MM Bio -1: Potential direct and indirect impacts to Federal Species of Concern, California Species of Special Concern, California Species Animals or plants on lists one through four of the California Native Plant Society (CNPS) Inventory and not covered under the MS HCP are considered potentially significant without mitigation. To reduce potential significant impacts to these sensitive species, habitat assessment shall be prepared by a qualified biologist for projects located on undeveloped sites. The report shall be submitted to the City Planning Division prior to issuance of grading permits.
• If the findings of the habitat assessment show no sensitive species or suitable habitat occur on site, and then no additional surveys or mitigation measures are required. • If the potential for sensitive species exist or suitable habitat exists on site, focused surveys or mitigation, if identified in the habitat assessment, shall be completed. Focused surveys conducted in the appropriate season for each species, as identified i n the habitat assessment report, shall be conducted to determine presence/absence status. • If no sensitive species are identified through focused surveys, then no additional surveys o mitigation measures are required.
• If sensitive species are found on site and are not avoided by project design, then additional mitigation measures as recommended by a qualified biologist and approved by the City of Riverside shall be implemented.

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a) Would the p roject 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. Fish and Wildlife Service?
GP PEIR Impact - Less Than Significant with Mitigation Incorporated The GP PEIR analyze d this threshold on pages 5. 4-53 through 5.4-54. The GP PEIR concluded that through compliance with the MSHCP which covers 146 species, and MM Bio 1 which addresses impacts to s pecies that are not covered under the MSHCP, impacts from adoption and implementation of the City of Riverside General Plan are considered less than significant.

The GP PEIR identified that the General Plan itself could lead to potential species impacts from future development, both direct and indirect. As such, the GP PEIR identified potential impacts at a programmatic level. It acknowledged that proposed planning actions could result in the permanent loss of habitat by allowing future development to occur . In addition, proposed planning actions have the potential to produce indirect impacts that could adversely modify the composition and value of wildlife habitat adjacent to development areas. The impacts from future projects will need to be analyzed on a case-by-case basis as such projects are submitted to the City.

As identified above, the implementation of the MSHCP at the project-specific level would minimize direct and indirect impacts from future projects proposed in accordance with the General Plan.

Payment of the mitigation fee and compliance with all applicable requirements of the MSHCP provides full mitigation under CEQA, NEPA, FESA, and CESA for impacts to MSHCP covered species and habitats. The MSHCP also addresses indirect impacts through core s and linkages, criteria cells and plan fees. Furthermore, for MSHCP covered species the Environmental Impact Report/Environmental Impact Statement (EIR/EIS) (State Clearinghouse No. 2001101108, CEQ Number 020463, ERP Number SFW-K99032-CA) prepared for the MSHCP was a project-specific EIR/EIS and found that with a combination of impact reduction features incorporated into the MSHCP, including reserve configuration, adaptive management and monitoring, and species survey and avoidance/minimization policies, d evelopment consistent with the MSHCP would have less than significant impacts to covered species. The GP PEIR concluded that through compliance with the MSHCP which covers specific species, and MM Bio 1 which addresses impacts to species that are not covered under the MSHCP, impacts from adoption and implementation of the City of Riverside General Plan are considered less than significant.

Proposed Project
In accordance with MM Bio-1, the potential Proposed Project-specific impacts were evaluated and are provided in Appendix B-2. The analysis included the findings of projects previously approved for the site in 2014, but which never materialized, and the current site conditions to determine if changes had occurred that would be specific to the currently Proposed Project.

Findings from 2014 Project
The Environmental Checklist in the City of Riverside Planning Commission Memorandum for P19-0380 and P19-0480 (July 25, 2019) described the previous onsite biological resources as follows:

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“Original Project: Less than Significant Impact / No Impact. The Original Project site is within the boundary of the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP); however, it is not within a Criteria Cell; is not classified as Public/ Quasi -Public (P/ QP) land; and it not within an identified Linkage. The Original Project site is within the MSHCP survey area for burrowing owls. As part of the 2014 Initial Study, a project -specific habitat assessment and focused burrowing owl study was prepared. The f indings of these studies concluded that the Original Project was in compliance with the MSHCP and no candidate species, sensitive species, species of concern, or special status species or suitable habitat for such species were present on the Original Proje ct site. Additionally, the Original Project site did not support riparian habitat or any other sensitive natural community. For these reasons, the 2014 Initial Study concluded that implementation of the Original Project would result in no impact with regar d to candidate, sensitive or special status species; riparian habitat; the movement of native or migratory species; or conflict with the provisions of the MSHCP. The 2014 Initial Study concluded that due to the Original Project site being located within an urban built-up area and having a long history of severe site disturbance, implementation of the Original Project would not have a substantial effect on federally protected wetlands; therefore, impacts would be less than significant. The 2014 Initial Study also concluded that impacts with regard to local policies protecting trees would be less than significant because the planting and maintenance of street trees proposed as part of the Original Project will be in compliance with the City’s Urban Forest Tree Policy Manual.

Findings from 2019 Project
“No Substantial Change from Previous Analysis. As with the Original Project, the Revised Project must be consistent with and comply with the provisions of the MSHCP and the City’s Urban Forest Tree Policy Manual. Gonzales Environmental Consultant, LLC, conducted a burrowing owl survey in March 20192 (the 2019 survey) to determine if site conditions had changed since the 2014 surveys conducted for the Original Project. The results of the 2019 survey confirm the find ings of the 2014 surveys; specifically, there is no suitable burrowing owl habitat; no owl burrows or burrowing owls present on the site or in adjacent areas. Additionally, there are no stockpiles of material or areas that burrowing owls would be found. Thus, the2019 survey concurred with the findings of the 2014 surveys.

Because the 2019 survey confirmed the results of the earlier surveys and the Revised Project will comply with the MSHCP and City’s Urban Forest Tree Policy Manual, the Revised Project will result in the same impacts as the Original Project.”
Proposed Project (2024) Findings
A Biological Resources Assessment was prepared by VCS Environmental dated April 1, 2024 (Appendix B-2) and confirms that there are no changes to the results of the biolo gical resources survey previously completed in 2014 by Victor M. Horchar and the burrowing owl survey conducted in 2019 by Gonzales Environmental Consulting, LLC. The site does not support riparian habitat or any other sensitive natural community, and no candidate or sensitive species or suitable habitat for such species was present on the Proposed Project site. The Proposed Project is in compliance with the MSHCP and the City’s Urban Forest Tree Policy Manual.

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Although all of the studies determined that t here is no habitat or no signs of burrowing owls on the property, a 30 -day preconstruction is required pursuant to the MSHCP. However, because the Proposed Project site is located within the MSHCP burrowing owl survey area and because the burrowing owl was listed as a candidate species on October 25, 2024, and is granted full protection of a threatened species under CESA, implementation of GP PEIR MM Bio -1 to conduct pre- construction surveys would reduce impacts to less than significant. If the species is identified on site, the Proposed Project would be required to obtain an Individual Take Permit (ITP) prior to site grading, consistent with California Fish and Game Code Sections 3503. 3503.1, and 3513 and comply with CDFW permitting requirements. Therefore, the Proposed Project-specific impact for this criterion is less than significant as there are no significant Proposed Project-specific impacts.

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 Wildlife or U.S. Fish and Wildlife Service? GP PEIR Impact - Less Than Significant with Mitigation Incorporated The GP PEIR included an analysis of the General Plan’s potential impacts to riparian habitats in the City, which include: Arundo/Riparian Forest, Cismontane Alkali Marsh, Marsh, Riparian Forest, Riparian Scrub, Southern Cottonwood/Willow Riparian, Southern Willow Scrub, and land immediately adjacent to open water. Along the Santa Ana River, immediately adjacent to bodies of water, and within arroyos, which traverse the Planning Area, riparian areas may be found. As stated above, adoption and implementation of the General Plan 2025 Program would not result in significant direct impacts to existing biological resources including riparian and other sensitive natural community; however, the adoption of the General Plan could lead to potential impacts from future development. These potential impacts could be both direct and indirect. This section identifies potential impacts that could result from future development at a programmatic level. Based on this analysis, impacts related to riparian habitat or other sensit ive natural communities are considered less than significant.

Under the MSHCP, any proposed project will require a habitat assessment for riparian habitat, therefore determining the presence/absence, quantity, and quality of such habitat and the measures necessary to mitigate potential direct and indirect impacts of the given proposal. Section

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pools within the plan area. Compliance with the MSHCP Section 6.1.2 and other applicable requirements will decrease impacts to a less than significant level.

Proposed Project
General and focused biological surveys were conducted on the Proposed Project Site in 2014, 2019 and 2024. During the field visits, no riparian features were observed within the Proposed Project site.

The results of the March 2024 survey confirm that the site conditions have not changed since the 2014 and 2019 surveys. The site does not support riparian habitat or any other sensitive natural community, and no candidate or sensitive species or suitable habitat for such species was present on the Proposed Project site. Therefore, there are no Proposed Project-specific impacts.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section 5. 4.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
c) Would the p roject have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) as defined by Section 404 of the Clean Water Act through direct removal, filling, hydrological interruption or other means? GP PEIR Impact - Less Than Significant with Mitigation Incorporated.

The GP PEIR analyzes this threshold on pages 5.4-54 through 5.4-55. The GP PEIR concluded that under the MSHCP, any proposed project will require a habitat assessment for riparian habitat, therefore determining the presence/absence, quantity, and quality of such habitat and the measures necessary to mitigate potential direct and indirect impacts of the given proposal. Section 6.1.2 of the MSHCP outlines the requirements and protection of riparian/riverine areas a nd vernal pools within the plan area. Compliance with the MSHCP Section 6.1.2 and other applicable requirements will decrease impacts to a less than significant level.

The GP PEIR acknowledged that potential development allowed under the General Plan which may impact protected wetlands includes future private development, roads, or public facilities projects located in and/or adjacent to the following identified habitats/resources: Arundo/Riparian Forest, Cismontane Alkali Marsh, Marsh, Riparian Forest, Rip arian Scrub, Southern Cottonwood/Willow Riparian, Southern Willow Scrub, and land immediately adjacent to open water. Along the Santa Ana River, immediately adjacent to bodies of water, and within arroyos, which traverse the Planning Area, riparian areas m ay be found. However, should certain proposed development be located within wetland areas, State and Federal laws and regulations would be implemented to protect resources from development through the ACOE Section 404 permitting process, the California CEQA Sections 15168 and 15183 Analysis
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Wetlands Conservation Policy (CWCO), and compliance with applicable MSHCP policies.

Accordingly, strict adherence to the identified State and Federal laws and regulations, MSHCP, and the “no net wetland loss” policy currently in place, would ensure that im plementation of the proposed General Plan would have a less than significant impact on jurisdictional waters and wetlands within the Planning Area.

Proposed Project
According to the biological resources report provided in Appendix B -2, the Proposed Project Site does not contain any state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) as defined by Section 404 of the Clean Water Act. Therefore, there would be no impact.

The Proposed Project complies with a pplicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section 5. 4.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Prop osed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
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?
GP PEIR Impact - Less than Significant with Mitigation Incorporated The GP PEIR analyzes this threshold on pages 5.4 -56 through 5.4-57. The GP PEIR concluded that through implementation of the General Plan policies, including those that preserve open space, in general, will reduce impacts less than significant.

The General Plan Policy OS-6.4 requires the City to continue efforts to establish a wildlife movement corridor between Sycamore Canyon Wilderness Park and the Box Springs Mountain Regional Park as identified in the MSHCP. New developments in this area will be conditioned to provide for the corridor with continued efforts to acquire additional wildlife corridors, and compliance with the MSHCP and Federal and State regulations, as stated above. Policies such as OS -6.1 address preserving wildlife migration areas in general while Policies O S-7.3 and LU-5.6 address wildlife movement through preservation and expansion of Santa Ana River open space and the crossing of Alessandro Arroyo, respectively. Therefore, through implementation of the General Plan policies discussed here as well as those policies, which preserve open space, in general will reduce impacts less than significant.

Proposed Project
The Proposed Project site is surrounded by development and does not directly connect to large blocks of habitat. It is not within any of the identified wildlife movement corridors in the General Plan.

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The site is constrained by existing development in all directions (including single family homes and active agricultural areas) so it does not facilitate local movement of wildlife within its boundaries.

Therefore, the implementation of the P roposed Project would not impact the regional wildlife movement.

Construction activities within the Proposed Project Site could disturb or destroy active migratory bird nests, including eggs and young. Disturbance to or destruction of migratory bird eggs, young, or adults violates the Migratory Bird Treaty Act and California Fish and Game Code. With compliance with the MBTA and CFG Code, the Proposed Project will have a less than significant impact on wildlife movement on a direct, indirect, or cumulative basis.

The Proposed Project is not located in a wildlife corridor as identified by the General Plan. Therefore, there would be no Proposed Project-specific impacts.

GP PEIR Impact - Less Than Significant
The GP PEIR analyzes this threshold on pages 5.4-57 through 5.4-58. The GP PEIR concluded that the General Plan policies are designed to ensure that future development within the City would not conflict with any local policies or ordinances protecting biological resources, and therefore, impacts were considered less than significant.

Implementation of the proposed General Plan would be subject to all applicable Federal, State, and local policies and regulations related to the protection of biological resources. In addition to the above threshold analyses, any new development proposed pursuant to General Plan land use designations within the City of Riverside or unincorporated areas within the Sphere of Influence will be required to comply with Ordinance 810.2 and Ordinance 633.10, both protecting biological resources. Ordinance 810.2 establishes the Western Riverside County MSHCP mitigation fee.

Any project within the City of Riverside’s boundaries, which proposes planting a street tree within a City right-of-way, must follow the Tree Policy Manual. The Manual documents gu idelines for the planting, pruning, preservation, and removal of all trees in City rights-of-way. The specifications in the Manual are based on national standards for tree care established by the International Society of Arboriculture, the National Arborists Association, and the American National Standards Institute. Any CEQA Sections 15168 and 15183 Analysis
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future project will be in compliance with the Tree Policy Manual when planting a tree within a City right-of-way, and therefore, impacts are considered less than significant. In addition, t he General Plan includes policies (as noted in this Section under Related General Plan Policies) to ensure that future development within the Planning Area would not conflict with any local policies or ordinances protecting biological resources. Finally, the GP PEIR noted that future projects must comply with MM Bio 1, as provided above. For these reasons, and impacts were considered less than significant.

Proposed Project
The Proposed Project is subject to the following:
• Victoria Avenue Policy for Preserv ation, Design and Development (November 2019) which requires that any existing, healthy trees and their roots, trunks, and canopies located along Victoria Avenue or within 100 feet of Victoria Avenue’s edge of roadway shall be protected from any construction activity. In fulfillment of this policy, the Proposed Project proposes to preserve 0.67 acres (54,110 square feet) of the northern portion of the site to be preserved as a landscaped parkway consistent with the Victoria Avenue Policy. This treatment along Victoria Avenue will have a 10-foot-wide decomposed granite (DG) multi-use trail through a grove of citrus trees that will remain from the existing onsite orchard, although it is no longer commercially harvested. The site will have extensive new landsca ping consistent with the Victoria Avenue Policy.
• Tree Policy Manual . Any project within the City of Riverside’s boundaries, which proposes planting a street tree within a City right -of-way, must follow the Tree Policy Manual. The Manual documents guidelines for the planting, pruning, preservation, and removal of all trees in City rights -of-way. The specifications in the Manual are based on national standards for tree care established by the International Society of Arboriculture, the National Arborists Association, and the American National Standards Institute. Any future project will be in compliance with the Tree Policy Manual when planting a tree within a City right-of-way • Stephens Kangaroo Rat (SKR) fee area . Ordinance 663.10 establishes the SKR HCP fee assessment area and mitigation fees. Any future applicant is required to pay the SKR mitigation fee and in doing so will not conflict with Ordinance 663.10.

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f) Would the p roject conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
GP PEIR Impact-Less than Significant
This threshold was analyzed in Section 5.9 – Land Use and Planning, pages 5.9 -42 to 5.9- 45.

Implementation of the proposed General Plan within the City and Sphere Area would be subject to the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP). General Plan Policy OS -5.2 states that the City will continue to participate in the MSHCP Program and LU 7.1 through 7.4, above, reinforce generally and specifically the MSHCP. There are no Project -specific impacts as a result of adoption of the General Plan; therefore, no impacts exist at a programmatic level. The City is a permittee of the MSHCP and must thereby comply with provisions set forth through the plan for projects proposed within the City. Any individual development projects constructed pursuant to the General Plan and public projects constructed to implement the General Plan will follow the measures of the MSHCP, and will comply with the plan. Therefore, impacts associated with potential inconsistencies with the MSHCP for the City and Sphere Area is considered less than significant.

Additionally, any future project will be required to comply with existing Federal, State, and local regulations. Impacts to certain species not covered by the MSHCP may require additional mitigation measures (MM Bio 1, as summarized below) to ensure potential impacts remain less than significant.

Through compliance with the MSHCP which covers 146 species, and MM Bio 1 which addresses impacts to species that are not covered under the MSHCP, impacts from adoption and implementation of the City of Riverside General Plan are considered less than significant.

Proposed Project
MSCHP Consistency Analysis

The project site is located within the MSHCP area. The MSHCP is a comprehensive, multi-jurisdictional Habitat Conservation Plan (HCP) focusing on the conservation of species and their associated habitats in Western Riverside County. The MSHCP’s overall goal is to provide for the conservation of covered species and their habitats, as well as maintain biological diversity and ecological processes while allowing for future economic growth within the urbanized areas. The project site is not located in any MSHCP Existing Cores, Linkages, non -contagious habitat blocks, MSHCP Cell area, MSHCP criteria cell. The project site is not classified as Public/ Quasi-Public (P/ QP) land or located within the Stephens’ Kangaroo Rat (Dipodomys stephensi) habitat Conservation Plan area for the endangered Stephen’s Kangaroo Rat. Furthermore, the project site is located outside of the mapped Stephen’s Kangaroo Rat suitable habitat area. A search of the MSHCP database and other appropriate databases identified no potential for a candidate, sensitive or special status species, or suitable habitat for such species onsite. Plant species that may not be listed as endangered, threatened, candidate, or proposed species under the Federal Endangered Species Act (FESA) or California Endangered Species Act (CESA), but are still considered r are, are generally assigned a rarity code by the California Native Plant Society (CNPS). CNPS has compiled an inventory of the geographic CEQA Sections 15168 and 15183 Analysis
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distribution and qualitative characterization of Rare, Threatened, or Endangered vascular plant species in California.

As discussed above and in the Biological Report, the project site does not have any sensitive plant or animal species covered by the MSHCP. Nevertheless, the Proposed Project will comply with all standards and policies of the MSHCP. Based on information obtained from the RCA MSHCP Information Map,7 and the Biological Report (Appendix B-2), the Proposed Project would not conflict with the provisions of the MSHCP as shown in Table 5.4-1: MSHCP Consistency Analysis, below.

Table 5.4-1: MSHCP Consistency Analysis
MSHCP Element/Requirements Proposed Project Site Status Criteria Cell/Cell Group The Proposed Project Site is not located within an MSHCP Criteria Area or Criteria Cell Group.

Area Plan Subunit The Proposed Project Site is not located within an MSHCP Area Plan Subunit.

Habitat Management Unit
The Proposed Project Site is located within the Gavilan Habitat Management Unit. The Proposed Project site is not located within or adjacent to MSHCP Conserved Lands. No requirements are imposed on the Proposed Project based on its presence in this habitat management unit.

MSHCP Conservation Areas The Proposed Project Site is not located within an MSHCP Conservation Area.

Public/Quasi Public (PQP)
Conservation Land
The Proposed Project Site is not located within Public/Quasi Public Conservation Land.

Narrow Endemic Plants (MSHCP
Section 6.1.3) Not in a narrow endemic plant survey area.

Amphibians, (MSHCP Section

6.3.2) Not in an amphibian survey area.

Burrowing Owl. MSHCP Section

6.3.2)
Burrowing Owl Survey is required. Proposed Project must comply.

Habitat assessments were conducted to determine the Project Site’s suitability to support burrowing owl. Biological reports confirmed there is no suitable burrowing owl habitat; no owl burrows or burrowing owls present on the site or in adjacent areas.

As such, no further surveys are required, per the MSHCP guidance for burrowing owl.

Mammal, (MSHCP Section 6.3.2) Not in a mammal survey area.

Riparian/Riverine Resources
(MSHCP Section 6.1.2)
There are no Riparian/Riverine resources on site, according to biological resources reports in 2014, 2019 and 2024.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any

7 https://wrcrca.maps.arcgis.com/apps/webappviewer/index.html?id=2b9d4520bd5f4d35add35fb58808c1b7. Accessed December 15, 2024.

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applicable GP PEIR mitigation measures as identified above and list ed in Section 5. 4.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

5.4.2 Cumulative Impacts Analysis
The GP PEIR evaluated the potential impacts associated with the General Plan Project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently considers cumulative impacts associated with population growth and increased development.

With respect to biological resources, the GP PEIR concluded that the General Plan Project would not result in cumulative impacts to biological resources. First, for those species covered by the MSHCP, the General Plan was determined to be consistent with the MSCHP, as implementing projects must comply with its requirements. Second, for those species that are not covered by the MSHCP, all future projects must implement MM Bio 1, which requires specific biological evaluation during the project consideration process and, as necessary.

As discussed above, and reflected in the Biological Report, the Proposed Project would not result in any project -level impacts to biological resources. Also, the Proposed Project must comply with applicable regulations, including those of the MSHCP. The Proposed Project would, therefore, not result in cumulatively considerable significant impacts with respect to biological resources.

5.4.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures The development standards that would apply to this specific Propos ed Project include but are not limited to the following:

Applicable General Plan Policies

Policy OS-1.1: Protect and preserve open space and natural habitat wherever possible.

Policy OS-1.5: Require the provision of open space linkages between development projects, consistent with the provisions of the Trails Master Plan, Open Space Plan and other environmental considerations including the MSHCP.

Policy OS-1.8: Encourage residential clustering as a means of preserving open space.

Policy OS-4.2: Establish buffers and/or open space between agricultural and urban uses so that the potential impacts from urban development will be mitigated.

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Policy OS-5.2: Continue to participate in the MSHCP Program and ensure all projects comply with applicable requirements.

Policy LU-7.4: Continue to participate in the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP).

Applicable General Plan Mitigation Measure
MM Bio 1: Potential direct and indirect impacts to Federal Species of Concern, California Species of Special Concern, California Species Animals or plants on lists one through four of the California Native Plant Society (CNPS) Inventory and not covered under the MSHCP are considered potentially significant without mitigation. To reduce potential significant impacts to these sensitive species, habitat assessment shall be prepared by a qualified biologist for projects located on undeveloped sites. The report shall be submitte d to the City Planning Division prior to issuance of grading permits.
• If the findings of the habitat assessment show no sensitive species or suitable habitat occur on site, then no additional surveys or mitigation measures are required. • If the potential for sensitive species exists or suitable habitat exists on site, focused surveys or mitigation, if identified in the habitat assessment, shall be completed. Focused surveys conducted in the appropriate season for each species, as identified in the habitat assessment report, shall be conducted to determine presence/absence status. • If no sensitive species are identified through focused surveys, then no additional surveys or mitigation measures are required.
• If sensitive species are found on site and are not avoided by project design, then additional mitigation measures as recommended by a qualified biologist and approved by the City of Riverside shall be implemented.

Applicable MSHCP Measure
• Pursuant to MSHCP Section 6.3.2, the Proposed Project must perform a 30-day burrowing owl preconstruction clearance survey in accordance with the Burrowing Owl Survey Instructions for the Western Riverside Multiple Species Habitat Conservation Plan Area prior to any ground disturbing activities and, if burrowing owls are observed, comply with the MSHCP, MBTA, and CDFW requirements.

5.4.4 Conclusion
With regards to the issue area of Biological Resources, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

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3. There are no potentially significant off -site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

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5.5 Cultural Resources
Impact

5.5.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Cultural Resources Survey Update (CRSU) prepared by CRM TECH in December 2024 (Appendix C)
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
GP PEIR Impact - Less than Significant
The GP PEIR analyzes this threshold on pages 5.5-23 through 5.5-25. The GP PEIR concluded that the with the continued use of the above Federal, State, and local regulations, and with compliance of the General Plan policies, impacts to historic resources will be less than significant.

While the General Plan Project did not propose any changes to any identified resources, future City development will occur in areas that may contain significant cultural resources. Although the City has programs and policies to protect and minimize adverse impacts to historical structures and features, the GP PEIR found that the potential remained for significant impacts to these resources to occur as a result of development. The GP PEIR notes that a Certificate of Appropriateness application is required for an action that may restore, reha bilitate, alter, develop, construct, demolish, remove or change the appearance of any cultural resource (unless the Building Official has determined that the historic resource creates an unsafe or dangerous condition that constitutes CEQA Sections 15168 and 15183 Analysis
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an imminent threat as defined in the California Building Code and the proposed action is necessary to mitigate the unsafe or dangerous condition), and the application is reviewed pursuant to adopted City procedures to determine if the proposed change would have a significant ad verse environmental effect as defined by CEQA. With the existing policy framework combined with the existing historic preservation program in the City promoting the Mills Act, historic design review, and surveys of historic resources, the GP PEIR concluded that potential impacts to cultural resources would be minimized.

Proposed Project
A standard Phase I Cultural Resources Survey for the Proposed Project was conducted on the same parcel by McKenna in 2014. As a result of that study, a site of historical age was recorded that coincided with the entire Proposed Project Site. The potential resource was designated 33 -023901 (CA-RIV11736H) in the California Historical Resources Inventory and consisted of an orange grove that had been cultivated on the property since 1902 along with associated irrigation features and a wind machine. The 2014 study concluded that Site 33 - 023901 did not meet any of the establishe d significance criteria and thus did not qualify as a “historical resource” under CEQA.

In 2019, McKenna updated the 2014 study and again concluded that no significant cultural resources were present on the Proposed Project Site. Although there has been no change to the property since that time, supplemental research and field investigation were conducted to re-verify the results of the previous research on this site. A new records search through the Eastern Information Center (EIC) at the University of Ca lifornia, Riverside. The results of the records search indicate the 2014 McKenna survey remains the only systematic cultural resources study of the Proposed Project Site.

Within a one -mile radius, the records search identified a total of 24 previously rec orded cultural resources, an increase of 10 from the 14 resources reported in the original 2014 McKenna survey.

None of these studies were on properties near the Proposed Project site and do not require further consideration during the assessment of the Proposed Project site.

Victoria Avenue from Arlington Avenue to Boundary Lane, which is approximately 0.5 mile east of the Project Site, is listed on the National Register of Historic Places (NRIS No. 00001267). The segment adjacent to the project boundary was built in the early 20th century (Appendix C) and has not been recorded as a potential “historical resource. As the Proposed Project or its related road improvements do not overlap with the portion of Victoria Avenue as listed on the National Register of Historic Places, there would be no impact to the historically significant resource. However, the City has identified policies for Victoria Avenue, from La Sierra to Arlington, to protect the visual integrity of Victoria Avenue. The Proposed Project is consistent with those policies (refer to Table 5.1 -1 in this document), therefore, there is a less than significant impact.

Therefore, the Proposed Project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any CEQA Sections 15168 and 15183 Analysis
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applicable GP PEIR mitigation measures as identified above and listed in Section 5. 5.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project woul d not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
GP PEIR Impact- Less than Significant with Mitigation Incorporated The GP PEIR analyzed this threshold on pages 5.5-25 through 5.5-26. The GP PEIR stated that based on what is known of the histories of local Native American groups and previously recorded archaeological sites, significant archeological resources are known to exist within the General Plan Project area. According to the GP PEIR, c onstruction projects within undeveloped portions of the City would promote a substantial increase in population, residential and non- residential structures, and associated infrastructure. Thus, implemen tation of the General Plan Project could cause disturbance on vacant lands that may cause the destruction of known significant archaeological resources, as defined in the CEQA Guidelines, Section 15064.5. The GP PEIR noted that t he significance of impacts to cultural resources resulting from specific future development projects will be evaluated on a project-by-project basis and General Plan policies as well as City standards and practices will be applied, individually or jointly, as necessary and appropria te. The GP PEIR concluded that with the implementation of the General Plan policies and implementation of mitigation measures MM Cultural 1 through 4, (GP PEIR pages 5.5 -28 through 5.5- 31) impacts to archaeological resources will be less than significant w ith mitigation. While already reduced to less than significant level, the GP PEIR found that MM Cultural 5 and 6 (GP PEIR pages 5.5-31 through 5.5- 33) will further reduce the less than significant impacts.

Cultural Resource mitigation measures that are rel evant to the Proposed Project are provided in Section 5.5.3 of this document.

Proposed Project
A Phase I Cultural Resources Assessment ( CRA) was prepared for the site. In 2014 and updated in 2019. In 2024 a Cultural Resources Survey Update was prepared f or the Proposed Project Site to determine if the conclusions of the original survey and its update were still valid. The CRA Update determined that the results of the previous studies were still valid (i.e., no significant historical resources on the site) but recommended monitoring of grading by an archaeologist.

The CRA Update in 2024 found Isolate 4101- 1 consisting of a granitic metate which was the only physical artifact found within the boundaries of the Proposed Project Site. It had been degraded/contaminated by concrete from construction activities during the 1900s and the original CRA concluded it was not a significant archaeological resource. Although no significant archeological resources are known to be present on the site, implementation of GP PEIR Mitigation CEQA Sections 15168 and 15183 Analysis
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Measures Cultural 1 through MM Cultural 4 implementing state law would reduce potential impacts in the event an unintended discovery is made, and any archeological resources would be protected.

A written request to the State of California N ative American Heritage Commission (NAHC) for an update to the Sacred Lands File search completed on the Proposed Project site during the 2014 study. The NAHC responded the Sacred Lands File identified no Native American tribal cultural resources in or near the Proposed Project area. The NAHC recommended that local Native American groups be consulted for further information and provided a referral list of potential contacts for that purpose (see Section 18, Tribal Cultural Resources).

The Proposed Project also does not involve restoration, rehabilitation, alteration, or demolition of a historical resource as defined under Section 15064.5 (a) of the CEQA Guidelines. If any structures or artifacts from past activities are unearthed during grading, the Proposed Project must comply with the CEQA Guidelines and Title 20 of the Riverside Municipal Code. With this regulatory compliance, the Proposed Project will have less than significant impact on a direct, indirect, or cumulative basis on historical resources as defined under Section 15064.5 (a) of the CEQA Guidelines. No mitigation is required.

c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
GP PEIR Impact-Less than Significant
The GP PEIR analyzed this threshold on pages 5.5-27 through 5.2-20. The GP PEIR concluded that the consistent with State laws prot ecting these remains, sites containing human remains must be identified and treated in a sensitive manner. The GP PEIR concluded that for non -Native American remains, Cultural Resources Mitigation Measures 1 through 6 would reduce impacts to a less than significant level. In the event that Native American human remains are inadvertently discovered during the City’s project -related construction activities, there would be unavoidable significant adverse impacts to Native American resources.

Numerous archaeological studies within the City have revealed the presence of Native American human remains (it is not known where other human remains may be found throughout the General Plan Project area ). Although most have been associated with former residential village locations, isolated burials and cremations have also been found in many locations. If the City proposes to CEQA Sections 15168 and 15183 Analysis
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construct projects in currently undeveloped areas, disturbance on vacant lands could have the potential to disturb or destroy buried Native American human remains as well as other human remains, including those interred outside of formal cemeteries. Consistent with State laws protecting these remains, sites containing human remains must be identified and treated in a sensitive manner.

Nonetheless, the GP PEIR concluded that i n the event that Native American human remains are inadvertently discovered during the City’s project -related construction activities, there could potentially be adverse impacts to Native American resources, but level with adherence to standard Federal, State and City regulations, the impact to inadvertent discovery of human remains is considered less than significant.

Proposed Project
No known cemeteries are located on the Proposed Project Site. According to California Health and Safety Code regulations Sections 57051 and 7054, and California Public Resources Code Section 5097.98, in the unlikely event that suspected human remains are uncovered during construction, all activities in the vicinity of the remains shall cease and the contractor shall notify the proper authorities and standard procedures for the respectful handling of human remains will be adhered to. The Proposed Project would also be required to comply with regulatory requirement s for the treatment of Native American human remains contained in California Health and Safety Code Sections 7050.5 and 7052 as well as California Public Resource Code (PRC) Section 5097. These regulations prohibit the interference with any human remains or “cause severe irreparable damage to any Native American sanctified cemetery, place of worship, religious or ceremonial site or sacred shrine.” Through mandatory compliance with existing regulations, impacts concerning disturbing human remains, including those interred outside of dedicated cemeteries will be less than significant.

5.5.2 Cumulative Impacts Analysis
The GP PEIR disclosed that future development resulting from the General Plan Project could result in potentially significant impac ts to historic, archaeological, and paleontological resources. In addition, future development could result in disturbance of previously unknown human remains.

However, implementation of General Plan policies and GP PEIR mitigation measures would reduce the General Plan Project impacts to less than significant levels. The GP PEIR also found that although impacts to a particular historic resource are not usually cumulative in nature, cumulative impacts to paleontological and Native American resources, including human remains, could be cumulative if CEQA Sections 15168 and 15183 Analysis
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no documentation, consultation, or preservation were being implemented throughout the region.

Since all local jurisdictions, including Riverside, are subject to local, State and Federal laws, including CEQA, and consultation is required with local Native American tribes and the state Native American Heritage Commission under Senate Bill (SB) 18 , cumulative impacts to such resources should not occur. The GP PEIR concluded that by utilizing the site development permit process and the CEQA process for individual projects, consultation requirements of SB 18 for General Plan Amendments and Specific Plans, along with implementing the General Plan’s objectives and policies, and mitigation measures identified in the GP PEIR, potential cumulative impacts to cultural resources would be less than significant level.

The Proposed Project is within the development capacity analyzed in the GP PEIR and there is nothing peculiar about the Proposed Project or Proposed Project site as related to cultural resources.

In addition, as the GP PEIR noted, other projects in the region would be subject to the same state and federal laws that protect cultural resources and other City projects also would need to comply with City General Plan polic ies and the GP PEIR mitigation measures, all of which prevent projects from adding together to create a significant cumulative impact. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off- site or cumulative effects, or is there new information that would result in a more severe cumulative impact to cultural resources than identified within the GP PEIR.

5.5.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures The development standards that would apply to this specific Proposed Project include but are not limited to the following:

Applicable General Plan Policies

Policy HP-1.3: The City shall protect sites of archaeological and paleontological significance and ensure compliance with all applicable State and Federal cultural resources protection and management laws in its planning and project review process.

Policy HP-4.3: The City shall work with the appropriate tribe to identify and address, in a culturally appropriate manner, cultural resources and tribal sacred sites through the development review process.

Policy LU-4.6: Ensure protection of prehistoric resources through consultations with the Native American tribe(s) identified by the Native American Heritage Commission pursuant to Government Code § 65352.3 and as required by the California Environmental Quality Act.

Applicable General Plan Mitigation Measures
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MM Cultural 1: The City shall actively pursue a survey program to identify and document prehistoric and historical archaeological sites and sites containing Native American human remains. Although a comprehensive survey program may not be economically feasible by the City, the City shall require that all areas slated for development or other ground disturbing activities be surveyed for archaeological resources by qualified individuals who meet the Secretary of the Interior’s Standards and Guidelines regarding archaeological activities and methods prior to the City’s approval of project plans.

MM Cultural 2: Where feasible, project plans shall be developed to avoid known archaeological resources and sites containing human remains. Where avoidance of construction impacts is possible, the site shall be landscaped in a manner, which will ensure that indirect impacts from increased public availability to these sites are avoided. Where avoidance is selected, archaeological resource sites and sites containing Native American human remains shall be placed within permanent conservation easements or dedicated open space areas.

MM Cultural 3: If, after consultation with the appropriate Tribe, the project archaeologist, and the project engineer/architect, and in accordance with the law, avoidance and/or preservation in place of known prehistoric and historical archaeological resources and sites containing Native American human remains are not feasible management options, the following mitigation measures shall be initiated:
a. Prior to the issuance of a grading permit for a project, the City’s consultant shall develop a Phase II (i.e., test-level) Research Design detailing how the archaeological resources investigation will be executed and providing specific research questions that will be addressed through the Phase II Testing Program. In general terms, the Phase II Testing Program should be designed to define site boundaries further and to assess the structure, content, nature, and depth of subsurface cultural deposits and features. Emphasis should also be placed on assessing site integrity, cultural significance and the site’s potential to address regional archaeological research questions. These data should be used for two purposes: to discuss culturally sensitive recovery options with the appropriate Tribe(s) if the resource is of Native American origins, and to address the California Register of Historical Resources (CRHR) and National Register of Historic Places (NRHP) eligibility for the cultural resource and make recommendations as to the suitability of the resource for listing comment. Tribal comments must be received by the City Planning Division within 45 days. The City shall consider all comments, require revisions, if deemed necessary by the report writer and approve a final Research Design, which shall be implemented. For sites determined ineligible for listing on either the CRHR or NRHP, execution of the Phase II Testing Program would suffice as the necessary level of data recovery and mitigation of project impacts to this resource.

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b. A participant-observer from the appropriate Native American Band or Tribe shall be used during all archaeological excavations involving sites of Native American concern.
c. After approval of the Research Design by Cultural Heritage Board staff and prior to the issuance of a grading permit, the City’s consultant shall complete the Phase II Testing Program as specified in the Research Design. The results of this Program shall be presented in a technical report that follows the County of Ri verside’s Outline for Archaeological Testing. The Phase II Report shall be submitted to the appropriate Tribe and the City’s Cultural Heritage Board for review and comment. d. If the cultural resource is identified as being potentially eligible for either the CRHR or NRHP, a Phase III Data Recovery Program to mitigate project effects should be initiated. The Data Recovery Treatment Plan detailing the objectives of the Phase III Program should be developed, in consultation with the appropriate Tribe, and contain specific testable hypotheses pertinent to the Research Design and relative to the sites under study. The Phase III Data Recovery Treatment Plan should be submitted to the City’s Cultural Heritage Board and/or Cultural Heritage Board staff and the appropriate Tribe for review and comment. Tribal comments must be received by the City Planning Division within 45 days. The City shall consider all comments, require revisions, if necessary, by the report writer and approve a final Treatment Plan which shall be implemented.
e. After approval of the Treatment Plan, the Phase III Data Recovery Program for affected, eligible sites should be completed. Typically, a Phase III Data Recovery Program involves the excavation of a statistically representative sample of the site to preserve those resource values that qualify the site as being eligible for listing on the CRHR or NRHP. Again, a participant-observer from the appropriate Native American Band or Tribe shall be used during archaeological data -recovery excavat ions involving sites of Native American concern. At the conclusion of the Phase III Program, a Phase III Data Recovery Report should be prepared, following the County of Riverside’s Outline for Archaeological Mitigation or Data Recovery. The Phase III Data Recovery Report should be submitted to the appropriate Tribe and the City’s Cultural Heritage Board for review.
f. All archaeological materials recovered during implementation of the Phase II Testing or Phase III Data Recovery programs would be subject t o analysis and/or processing as outlined in the Treatment Plan. If materials are of the type which will be transferred to a curation facility, they should be cleaned, described in detail, and analyzed including laboratory and analytical analysis. Materials to be curated may include archaeological specimens and samples, field notes, feature and burial records, maps, plans, profile drawings, photo logs, photographic negatives, consultants’ reports of special studies, and copies of the final technical reports. All project-related collections CEQA Sections 15168 and 15183 Analysis
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subject to curation should be suitably packaged and transferred to a facility that meets the standards of 36 CFR 79 for long-term storage. Culturally sensitive treatment of certain artifacts may require treatment other than curation and as specified in the Treatment Plan, but it should be noted that provisions of the Native American Graves Protection Repatriation Act (NAGPRA) pertaining to Native American burials, sacred objects, and objects of cultural patrimony would come into effect when ownership of the collections transfer to a curation repository that receives Federal funding, unless otherwise agreed to with non-curation methods of treatment. g. The project proponent should bear the expense of identification, evaluation, and treatment of all cultural resources directly or indirectly affected by project -related construction activity. Such expenses may include, archaeological and Native American monitoring, pre -field planning, field work, post -field analysis, research, interim and summary report preparation, and final report production (including draft and final versions), and costs associated with the curation of project documentation and the associated artifact collections. On behalf of the City and the project proponent, the final technical reports detailing the results of the Phase II Testing or Phase III Data Recovery programs should be submitted to the appropriate Native American Tribe and to the Eastern Information Center (EIC) of the California Historical Resources I nformation System (CHRIS) for their information and where it would be available to other researchers.

MM Cultural 4: The following mitigation measures should be implemented to reduce project- related adverse impacts to archaeological resources and sites containing Native American human remains that may be inadvertently discovered during construction of projects proposed in the City’s General Plan Update:
a. In areas of archaeological sensitivity, including those that may contain buried Native American human remains, a registered professional archaeologist and a representative of the culturally affiliated Native American Tribe, with knowledge in cultural resources, should monitor all project -related ground disturbing activities that extend into natural sedim ents in areas determined to have high archaeological sensitivity.
b. If buried archaeological resources are uncovered during construction, all work must be halted in the vicinity of the discovery until a registered professional archaeologist can visit the site of discovery and assess the significance and origin of the archaeological resource. If the resource is determined to be of Native American origin, the Tribe shall be consulted. If the archaeological resource is determined to be a potentially signific ant cultural resource, the City, in consultation with the project archaeologist and the Tribe, shall determine the course of action, which may include data recovery, retention in situ, or other appropriate treatment and mitigation depending on the resources discovered.

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c. In the event of an accidental discovery of any human remains in a location other than a dedicated cemetery, the steps and procedures specified in Health and Safety Code 7050.5, State CEQA Guidelines 15064.5(e), and Public Resources Code 5097.98 must be implemented. Specifically, in
accordance with Public Resources Code (PRC)
Section 5097.98, the Riverside County Coroner must be notified within 24 hours of the discovery of potentially human remains. The Coroner will then determine within tw o working days of being notified if the remains are subject to his or her authority. If the Coroner recognizes the remains to be Native American, he or she shall contact the Native American Heritage Commission (NAHC) by phone within 24 hours, in accordance with PRC Section 5097.98. The NAHC will then designate a Most Likely Descendant (MLD) with respect to the human remains within 48 hours of notification.

The MLD then has the opportunity to recommend to the property owner or the person responsible for the excavation work means for treating or disposing, with appropriate dignity, the human remains and associated grave goods within 24 hours of notification. Whenever the NAHC is unable to identify a MLD, or the MLD fails to make a recommendation, or the landow ner or his or her authorized representative rejects the recommendation of the MLD and the mediation provided for in subdivision (k) of PRC Section 5097.94 fails to provide measures acceptable to the landowner, the landowner or his or her authorized representative shall re-inter the human remains and items associated with Native American burials with appropriate dignity on the property in a location not subject to further subsurface disturbance.

5.5.4 Conclusion
With regards to the issue area of Cultural Resources, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

3. There a re no potentially significant off -site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

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5.6 Energy
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
Would the project:
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
Less Than
Significant No No No No
b) Conflict with or obstruct a
state or local plan for renewable
energy or energy efficiency?
Less Than
Significant No No No No

5.6.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Air Quality and Greenhouse Gas Technical Memorandum prepared by KPC EHS Consultants, LLC on 3-29-2024 (Appendix A).
a. Would the p roject result in potentially significant environmental im pact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? GP PEIR Impact- Less Than Significant
Energy use was not specifically analyzed within the GP PEIR as a separate issue area under CEQA.

At the time, energy use was contained within Appendix F of the CEQA Guidelines and has since been moved to the issue areas within Appendix G of the CEQA Gu idelines. However, the issue of energy use in general was discussed in Section 5.3, Air Quality, of the GP PEIR and is discussed below.

The General Plan 2025 PEIR, for instance, identifies multiple General Plan policies that serve the purposes of energy conservation (Policies AQ-5.1, AQ-5.2, AQ-5.3, AQ-5.4, AQ-5.5, AQ-5.6, and AQ-

5.7). The GP PEIR analyzed the effect of these policies, as well as other mandates (such as the California Building Code) to ensure that energy use within the City would be efficie nt and not contribute to the unnecessary demand that would result in air quality or GHG emissions. The GP PEIR concluded that programs listed in the Local Programs section under Related Regulations and policies located in the Related General Plan Policies section will help increase energy efficiency CEQA Sections 15168 and 15183 Analysis
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throughout the Planning Area. Examples include the Residential Shade Tree Program and the Community Energy Efficient Program, which help increase energy efficiency and reduce fossil fuel consumption. In addition, General Plan policies, such as, OS -8.1 to OS8.11, encourage renewable energy and energy efficient development. Further, Implementation Plan Tools, such as, OS-30 to OS- 32, which promote energy efficient programs that conserve energy 15% above Title 24 requirements.

Also, policies included in the GP, such as AQ-1.7 promote planned residential development and infill housing, which reduces vehicle trips. The GP PEIR concluded that these policies, measures, and regulations would increase energy efficiency citywide.

Proposed Project
The Proposed Project would increase the demand for energy at the Proposed Project site during construction. Electric power w ould be required for lighting and electronic equipment (e.g., computers) located in trailers used by the construction crew. However, the electricity used for such activities would be temporary and would have a negligible contribution to the Proposed Project’s overall energy consumption. Natural gas consumption is not anticipated during construction of the Proposed Project. Fuels used for construction would generally consist of diesel and gasoline, which, given the small size of the Proposed Project site, ar e nominal and would have a negligible contribution to the Proposed Project ’s overall energy consumption. The Proposed Project is not unique with respect to its construction requirements, and its demand for energy during construction is consistent with othe r projects throughout the City. Also, the project would comply with all applicable regulations and requirements related to construction and energy efficiency.

During the operation of the new residences, the Proposed Project would consume electricity from appliance operation, indoor lighting, refrigeration, HVAC equipment, and outdoor lighting. Based on estimates generated by CalEEMod (Appendix A) , the proposed Proposed Project would consume approximately 457,623 kilowatt-hours (kWh) per year of electricity . The Proposed Project would be required to comply with the standards contained in the CalGreen Code (i.e., Part 11 of the Title 24 Building Code) that requires the buildings constructed at the site to meet energy efficiency standards that improve upon those from previous years.

Additionally, California's solar mandate is a building code that requires new construction homes to have a solar photovoltaic (PV) system as an electricity source. This code, which went into effect on January 1, 2020, applies to single- and multi-family homes that are up to three stories high. The solar panel system needs to be large enough to meet the building's annual electricity usage. 8 Although electricity would increase at the site under the implementation of the Proposed Project, the proposed facility would be designed to meet the current Title 24 Building Code standards, and benefit from other actions taken at the State level. The Proposed Project Compliance with the CBC Title 24 requires all projects to include design fe atures that offset electricity demand, including but not limited to the Proposed Project. For these reasons, the electricity consumed by the Proposed Project is not considered to be inefficient or wasteful.

8 2022 Building Energy Efficiency Standards, Section 150.1(c)14 of the 2022 Energy Code .

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Natural gas consumption may be required during the operation of the Proposed Project for various purposes, such as hot water and cooking. Based on estimates generated by CalEEMod, the Proposed Project would consume approximately 1,742,651 kilos or thousand British thermal units (kBtu) per year of natural gas. Although natural gas consumption would increase at the site under the implementation of the Proposed Project, the buildings would be more efficient because of the energy efficiency requirements outlined in the 2022 CBC, Title 24.. For these reasons, the natural gas that would be consumed by the Proposed Project is not considered to be inefficient or wasteful.

Although the Proposed Project would increase petroleum use in the region during construction and operation, the use would be a small fraction of the statewide use and would have its overall fuel consumption decrease over time. As such, petroleum consumption is associated with the Proposed Project but at levels standard for residential construction and operation and would not be considered inefficient or wasteful. Therefore, impacts would be less than significant, and no mitigation is required.

The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements listed in Section 5.6.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off -site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.

5.6.2 Cumulative Impacts Analysis
The GP PEIR evaluated the potential impacts associated with the General Plan Project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently considers cumulative impacts associated with population growth and increased development.

With respect to energy resources, the GP PEIR explained that the General Plan Project would, even though it would increase population/buildout and demand greater energy, increase overall efficiency through compliance with applicable General Plan policies and other regulations, such as the California Building Code (Title 2 4). The then -existing Title 24 energy efficiency standards have been improved upon greatly in subsequent versions. The current 2022 Title 24 standards are among the most energy efficient in the nation, and are magnitudes more efficient than the standards i n existence when the GP PEIR was certified. The Proposed Project would be consistent with all of the applicable energy efficiency standards and would not obstruct or be inconsistent with local or state standards or plans related to energy efficiency. The p roject would not result in a cumulatively considerable impact.

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5.6.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures The development standards that would apply to this specific Proposed Project include but are not limited to the following:
2022 Building Energy Efficiency Standards
Title 24, Part 6 of the Energy Code provides the Building Energy Efficiency Standards for Residential and Non- Residential Buildings. (CEC 2023) Per Table 100.0- A – Application of Standards, the following sections of building energy efficiency standards , current or as amended based on the date of construction and adoption of new regulations, would apply to single family buildings such as the Proposed Project:

Section 110.2 – Mandatory Requirements for Space-Conditioning Equipment Section 110.3 – Mandatory Requirements for Service Water-Heating Systems and Equipment Section 110.4 – Mandatory Requirements for Pool and Spa Systems and Equipment Section 110.5 – Natural Gas Central Furnaces, Cooking Equipment, Pool and Spa Heaters, and Fireplaces: Pilot Lights Prohibited
Section 110.6 – Mandatory Requirements for Fenestration Products and Exterior Doors Section 110.7 – Mandatory Requirements to Limit Air Leakage Section 110.8 – Mandatory Requirements for Insulation, Roofing Products, and Radian Barriers
Section 110.9 – Mandatory Requirements for Lighting Controls

Section 110.10 – Mandatory Requirements for Solar Readiness Section 110.11 – Mandatory Requirements for Electrical Power Distribution System Section 160.1 – Mandatory Requirements for Building Envelopes Section 160.2 – Mandatory Requirements for Ventilation and Indoor Air Quality Section 160.3 – Mandatory Requirements for Space Conditioning Systems in Multifamily Buildings
Section 160.4 – Mandatory Requirements for Water Heating Systems Section 160.5 – Mandatory Lighting Requirements for Indoor and Outdoor Spaces Section 160.6 – Mandatory Requirements for Electric Power Distribution Systems Section 160.7 – Mandatory Requirements for Covered Processes Section 160.8 – Mandatory Requirements for Solar Ready Buildings CEQA Sections 15168 and 15183 Analysis
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Section 160.9 – Mandatory Requirements for Electric Ready Buildings California Green Building Standards
The California Green Building Standards Code, which is Part 11 of the California Code of Regulations, is commonly referred to as the CALGreen Code. The State updates this code every three (3) years. The first edition of the CALGreen Code was released in 2008 and contained only voluntary standards. The 2019 CALGreen Code was updated in 2019, became effective on January 1, 2020, and applied to non- residential and residential developments. The 2022 CALGreen Code went into effect on January 1, 2023. The CALGreen Code contains requirements for construction site selection, stormwater control during construction, construction waste reduction, indoor water use reduction, material selection, natural resource conservation, site irrigation conservation, and more. The CALGreen Code provides for design options allowing the designer to determine how best to achieve compliance for a given site or building condition. The CALGreen Code also requires building commissioning, which is a process for the verification that all building systems, such as heating and cooling equipment and lighting systems, function at their maximum efficiency.

Chapter 4 of Title 24, Part 11 provides the Residential Mandatory Measures, including those regarding energy efficiency.

Applicable General Plan Policies

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

Policy AQ-5.2: Develop incentives and/or regulations regarding energy conservation requirements for private and public developments.

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

Policy AQ-5.4: Continue and expand the creation of locally based solar photovoltaic power stations in Riverside.

Policy AQ-5.5: Continue and expand Riverside Public Utilities’ rebate programs to promote energy efficiency.

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

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

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

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

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

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

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

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

Policy OS-8.9: Encourage construction and subdivision design that allows the use of solar energy systems.

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

Policy OS-8.11: Support public education programs for City residents and businesses to provide information on energy conservation and on alternatives to nonrenewable energy resources.

Policy OS-8.12: Require bicycle parking in new nonresidential development.

Policy PF-6.3: Promote and encourage energy conservation.

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

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Policy PF-6.5: Promote green building design.

Applicable General Plan Mitigation Measures
There are no applicable General Plan Mitigation Measures.

5.6.4 Conclusion
With regards to the issue area of Energy, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

3. There are no potentially significant off -site and/or cumulative impacts which were not discussed by the GPU EIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GPU EIR.

5. No mitigation measures contained within the GPU EIR would be required because Proposed Project specific impacts would be less than significant.

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5.7 Geology and Soils
Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
Would the project:
a) Directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:

Less Than
Significant No No No No
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 Special Publication

42. Less Than
Significant
ii) Strong seismic ground
shaking?

Less Than
Significant
iii) Seismic-related ground
failure, including liquefaction?
Less Than
Significant
iv) Landslides? Less Than
Significant
b) Result in substantial soil erosion
or the loss of topsoil?
Less Than
Significant No No No No
c) 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?
Less Than
Significant No No No No
d) Be located on expansive soil,
as defined in Table 18-1-B of the
Uniform Building Code (1994),
creating substantial direct or
Less Than
Significant No No No No
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Impact

GP PEIR
Impact
Determination
Effect Peculiar
to Proposed
Project or
Site?
New or
Substantially
more Severe
Significant
Effect?
New
Significant
Off-Site or
Cumulative
Impact?
New
Information/
More Severe
Impact?
indirect risks to life or property?
e) Have soils incapable of
adequately supporting the use of
septic tanks or alternative waste
water disposal systems where
sewers are not available for the
disposal of waste water?
Less Than
Significant With
Mitigation
Incorporated
No No No No
f) Directly or indirectly destroy a
unique paleontological resource
or site or unique geologic
feature?
Less Than
Significant No No No No

5.7.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
 Phase I Environmental Site Assessment (ESA) and Limited Soil Investigation Report, TTM 37764. prepared by EFI Global, December 19, 2019 (Appendix D). 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 Special Publication 42; ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction? iv) Landslides?
GP PEIR Impact- Less than Significant
The GP PEIR analyzes this threshold on pages 5. 6-18 through 5. 6-19. The GP PEIR concluded that compliance of applicable regulations as well as policies identified in the General Plan, impacts were considered less than significant.

In the City of Riverside and the Sphere of Influence, there are no Alquist-Priolo zones. For this reason, no impact will occur with the proposed General Plan related to potential rupture of an Alquist-Priolo Earthquake Fault Zone.

New development would be required to comply with the building design standards of CBC Chapter 33 for the construction of new buildings and/or structures related to seismicity, and specific CEQA Sections 15168 and 15183 Analysis
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engineering design and construction measures would be implemented to anticipate and avoid potential impacts from seismic activity. Compliance with CBC regu lations and policies included in the General Plan would ensure that impacts related to seismic ground shaking and seismic-related ground failure, including liquefaction and landslides, are reduced to less than significant levels.

Compliance with the standards in the current CBC would require an assessment of hazards related to landslides and liquefaction and the incorporation of design measures into structures to mitigate this hazard if development were considered feasible. The Municipal Code requires prov isions regarding grading and development on or near hillsides. The City has included policies in its Public Safety Element to achieve the goal of minimizing the risk of injury, loss of life, and property damage caused by earthquake hazards or geologic dist urbances (Policies PS -1.1-1.5 & Policy PS -9.8). With compliance of applicable regulations as well as policies identified in the General Plan, the GP PEIR concluded that impacts would be less than significant.

Proposed Project
The Proposed Project would be required to comply with CBC regulations and any requirements of a site-specific geotechnical investigation for foundation design. Thus, the Proposed Project would not directly or indirectly cause potential substantial adverse effects, including t he risk of loss, injury, or death, involving strong seismic ground shaking. Therefore, impacts associated with strong seismic ground shaking will have less than significant impact on a direct, indirect, or cumulative basis. No mitigation is required.

The GP PEIR identified the site with as having a high potential for liquefaction. However, even in such areas, the GP PEIR concluded that compliance with applicable regulations (including the CBC) would ensure impacts remain less than significant. An Updated Geotechnical Evaluation prepared for the Proposed Project (Appendix D) has analyzed the boring data concerning the potential for liquefaction and dry sand settlement within the Proposed Project site. The analysis was performed following the guidelines contai ned in Special Publication 117A published by the California Geological Survey (1997, Revised 2008) and those in the 2022 California Building Code. Based on the updated analysis, seismically induced settlement within the site is calculated to be on the order of 1 to 1 ½ inches under the very unlikely scenario of high groundwater returning to a level of 5 feet below the ground surface. Based on these calculations, the differential settlement between various locations within the site is not expected to exceed 1 inch in 40 feet, which is considered well within tolerable limits for seismic differential settlement.

Earthwork will be performed under the Grading Code of the City of Riverside, in addition to the applicable provisions of the 2022 CBC. Grading must also be performed following the following site- specific recommendations prepared including the Grading Specifications presented in the Updated Geotechnical Evaluation. With mandatory compliance with the CBC seismic regulations and the recommendation from the Updated Geotechnical Evaluation potential impacts related to seismic ground shaking and seismic -related ground failure, including liquefaction, would be less than significant. Because the Proposed Project site and adjacent properties are relatively flat, there is no risk of landslides. No mitigation is required.

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The Proposed Project complies with applicable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section 5. 7.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
b) Would the project result in substantial soil erosion or the loss of topsoil? GP PEIR Impact – Less than Significant
The GP PEIR analyzes this threshold on pages 5.6-19 through 5.6-20. The GP PEIR concluded that future development projects implemented under the General Plan would have less than significant impact to soil erosion or topsoil by implementing the National Pollutant Discharge Elimination System (NPDES) program as well as following the Subdivision Code and Grading Code.

All individual construction project activities greater than one acre will be subject to the State’s General Permit for Construction Activities, which is administered by the California Regional Water Quality Control Board (RWQCB). Employment of Best Management Practices (BMPs) implemented through a Storm Water Pollution Prevention Plan (SWPPP) would be required to limit the extent of eroded materials from a construction site. Development that is one acre or more would be required to comply with the provisions of the NPDES regulations concerning the discharge of eroded materials and pollutants from construction sites and prepare and implement a SWPPP.

Further, the City of Riverside Subdivision Code (Title 18) sets forth erosion control standards to which all development activity must comply. The City's Grading Code (Title 17) also requires implementation of BMPs, and other measures designed to minimize soil erosion. Compliance with the policies contained in the General Plan, Subdivision Code, and Grading Code would further ensure that new development would not result in substantial soil erosion or loss of topsoil. Also, for operational activities, complying with the Water Quality Management Plan would minimize effects from erosion and ensure consistency with NPDES requirements. Future development projects implemented under the General Plan would have less than significant impact on soil erosion or the loss of topsoil.

Proposed Project
Erosion and loss of topsoil could occur as a result of the Proposed Project if applicable standards are not followed. State and Federal requirements call for the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) establishing erosion and sediment controls for construction activities. The Proposed Project must also comply with the National Pollutant Discharge Elimination System (NPDES) regulations. The Proposed Project also requires the preparation of a Water Quality Management Plan (WQMP) to add ress the potential for long -term impacts on water quality. In CEQA Sections 15168 and 15183 Analysis
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addition, with the erosion control standards for which all development projects must comply per the Subdivision Code (Title 18), and the Grading Code (Title 17) will ensure that both short- and long-term soil erosion or loss of topsoil will have a less than significant impact on a direct, indirect, or cumulative basis. No mitigation is required.

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?
GP PEIR Impact - Less than Significant
The GP PEIR analyzes this threshold on pages 5. 6-19 through 5.6-20. The GP PEIR concluded that compliance to the City’s existing codes and policies contained in the General Plan would ensure the maximum practical protection available for users of buildings and infrastructure. With these requirements, the implementation of the General Plan would have a less than significant impact.

As part of the construction permitting process and reflected in the Subdivision Code (Section

18.090.050), the City requires completed reports of soil conditions at specific construction sites to identify potentially unsuitable soil conditions including landslides, liquefaction and subsidence. The reports must be written by a registered soil professional, and measures to eliminate inappropriate soil conditions must be applied. T he design foundation support must conform to the analysis and implementation criteria described in CBC Chapter 15. Additionally, if any development is proposed on terrain where slopes are greater than 10%, provisions will have to meet to comply with Title 17, Grading, of the City’s Municipal Code. Compliance with the City’s existing codes and policies contained in the General Plan would ensure the maximum practical protection available for users of buildings and infrastructure. With these requirements, the proposed GP Project would have a less than significant impact.

Proposed Project
The Proposed Project site is located in an urbanized area and the general topography of the subject site is flat. As stated under Threshold (a) above, the Proposed Project site is not located in an area prone to landslides (GP PEIR, p. 5.6 -3). Grading would be performed in accordance with the site - specific recommendations contained in the Updated Geotechnical Evaluation (Appendix D). With mandatory compliance with the CBC seism ic regulations and the recommendation from the Updated Geotechnical Evaluation, potential impacts related to on - or off -site landslide, lateral CEQA Sections 15168 and 15183 Analysis
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spreading, subsidence, liquefaction, or collapse would be less than significant. A dditionally, based on the lack of shallow groundwater encountered and the hard to very hard nature of the older alluvial fan deposits and granitic bedrock further underlying the site, the potential for manifestation of liquefaction and for seismic (i.e., dynamic) settlement in the form of dry sand settlement, are expected to be very low and less than significant. No mitigation is required.

GP PEIR Impact – Less than Significant
The GP PEIR analyzes this threshold on pages 5.6-20. The GP PEIR concluded that development under the General Plan would be required to comply with applicable provisions of the Subdivision Code as well as the CBC with regard to soil hazards such as expansive soils. Policies included in the General Plan would also help reduce impacts related to expansive soils. Due to these regulatory requirements this impact was considered less than significant.

Soils containing high clay content often exhibit a relatively high potential to expand when saturated and to contract when dried out. Within the Planning Area, expansive soils are widely scattered and are found in hillside areas as well as low lying alluvial bas ing. Implementation of the proposed General Plan may result in the construction and occupation of structures within areas that have expansive soils. However, development under the General Plan would be required to comply with applicable provisions of the Subdivision Code (Title 18) as well as the CBC with regard to soil hazards such as expansive soils. Policies included in the General Plan would also help reduce impacts related to expansive soils. Due to these regulatory requirements this impact is considered less than significant.

Proposed Project
The geotechnical report in Appendix D indicated that soils within the site are anticipated to exhibit expansion potential that is within the Very Low range (Expansion Index from 0 to 20) based on soil sampling performed. As indicated in Section 1803.5.3 of 2022 California Building Code (2022 CBC), these soils are considered non-expansive and, as such, the design of slabs on-grade is considered to be exempt from the procedures outlined in Sections 1808.6.2 of the 2022 CBC and may be performed using any method deemed rational and appropriate by the Proposed Project structural engineer. As such, there is no impact. No mitigation is required.

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The Proposed Project complies with applicable standards and regulations, inc luding General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section 5. 7.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
e) 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? GP PEIR Impact-Less Than Significant With Mitigation Incorporated The GP PEIR analyzes this threshold on pages 5.6-20 through 5.6-21. The GP PEIR concluded that for any development proposing to use septic systems, MM Geo 1 that requires an investigation as to the site’s suitability to support a septic system will be implemented in order to reduce project impacts to a less than significant level.

Proposed Project
The Proposed Project will be connected to and served by City sewer infrastructure ; therefore, the Proposed Project will have no impact related to septic systems. No mitigation is required.

The Proposed Project complies with appli cable standards and regulations, including General Plan Policies, General Plan Implementing Programs, Riverside Municipal Code requirements, and any applicable GP PEIR mitigation measures as identified above and listed in Section 5. 7.3 of this document. The Proposed Project’s implementation of those regulations, policies, and standards, including the General Plan designation and zoning, which permit the Proposed Project, ensures that the project would not result in significant impacts. As such, the Proposed Project does not have peculiar effects, new substantially more severe significant effects, new off-site or cumulative effects, or is there new information that would result in a more severe impact than identified within the GP PEIR.
f) Would the p roject directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
GP PEIR Impact - Less than Significant
The GP PEIR analyzes this threshold in the Cultural Resources section, pages 5.5-26 – 5.5-27. The GP PEIR concluded that compliance with the General Plan policy and existing regulations would reduce impacts to paleontological resources to a less -than-significant level by ensuring paleontological resources would be subject to scientific recovery and evaluation, which would ensure that important scientific information that could be provided be provided by these resources.

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A number of locations in the Planning Area have a variety of known significant paleontological resources. Ground -disturbing activities in the fossil -bearing soils and rock formations have the potential to damage or destroy paleontological. General Plan Policy HP -1.3 is in place to protect paleontological resources. Policy HP-1.3 provides that “The City shall protect sites of archaeological and paleontological significance and ensure compliance with all applicable State and Federal cultural resources protection and management laws in its planning and project review process.” For example, the policy states that the City shall protect sites of archaeological and paleontological significance and ensure compliance with the Federal Native American Graves Protection and Repatriation Act in its planning and project review process. Compliance with the General Plan policy and existing regulations would reduce impacts to paleontological resources to a less-than-significant level by ensuring paleontological resources would be subject to scientific recovery and evaluation, which would ensure that important scientific information that could be provided be provided by these resources will be recovered.

Proposed Project Impacts
According to Figure 5.5 -2, Prehistoric Cultural Resources Sensitivity, of the GP PEIR, the Proposed Project site is within an area described as having a “Medium “sensitivity for paleontological resources. However, in such areas, the GP PEIR concluded that compliance with applicable General Plan policies and regulations would ensure no impacts to paleontological resources. The Proposed Project would be required to comply with all applicable General Plan policies and mitigation measures related to protection of prehistoric resources. Specifically, the Proposed Project would need to comply with Policy HP-1.3 provides that “The City shall protect sites of archaeological and paleontological significance and ensure compliance with all applicable State and Federal cultural resources protection and management laws in its planning and project review process.” Pursuant to this Policy, the City will require the Proposed Project to include the following not on all grading plan: “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 a nd the applicant shall retain a paleontologist who meets the Society of Vertebrate Paleontology (SVP) qualifications standards for the Proposed 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 Proposed Project Paleontologist. If the fossils are significant per SVPs 2010 criteria, then paleontological monitoring shall be conducted on a n as -needed basis for further ground - disturbing activities in the Proposed Project area.” This condition will ensure the Proposed Project complies with Policy HP-1.3.

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or is there new information that would result in a more severe impact than identified within the GP PEIR.

5.7.2 Cumulative Impacts Analysis
The GP PEIR evaluated the potential impacts associated with the General Plan Project, a citywide plan for buildout and design of the City. To that end, because it evaluates planned buildout (multiple projects at the programmatic level), the GP PEIR inherently considers cumulative impacts associated with population growth and increased development.

With respect to geologic resources, the GP PEIR concluded that geologic hazards are localized by nature and that impacts would result if state and local development codes were not followed.

However, because compliance with such codes is mandatory, meaning that development is required to incorporate appropriate design and construction measures to lessen geologic hazards, projects constructed within the city would have result in geologic or seismic safety hazards. All development is required to prepare a geotechnical report and implement recommendations to ensure seismic safety.

A Geotechnical Report was prepared for the project, which concluded that compliance with the CBC and implementation of specific construction design recommendations would ensure that no significant impact would result. Consistent with the GP PEIR’s recognition of geological risks as localized by nature, the construction of the project would not result in a cumulatively considerable impact. In addition, as noted in the cultural resources section of the GP PEIR, all projects in the City must comply with General Plan policies and GP PEIR mitigation measures that prevent significant impacts to paleontological resources and therefore cumulative projects with the project would not add together to create a significant cumulative impact on paleontological resources.

5.7.3 Uniformly Applied Development Standards and GP PEIR Mitigation Measures The development standards that would apply to this specific Proposed Project include but are not limited to the following:

California Building Code
The California Building Code (CBC), Title 24, Part 2, provides building codes and standards for the design and construction of structures in California. The purpose of the CBC is to establish minimum standards to safeguard the public health, safety, and general welfare through structural strength, means of egress facilities, and general stability by controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of building and structures. The CBC contains specific requirements for seismic safety, excavation, foundations, retaining walls, and site demolition. I t also regulates grading activities, including drainage and erosion control. Chapter 16 of the CBC contains definitions of seismic sources, and the procedure used to calculate seismic forces on structures.

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The CBC is updated every three years by order of t he legislature, with supplements published in intervening years. State Law mandates that local government enforce the CBC. In addition, a city and/or county may establish more restrictive building standards reasonably necessary because of local climatic, geological, or topographical conditions.

Riverside Municipal Code
Title 14- Public Utilities
The Riverside Municipal Code (RMC) contains a number of ordinances relevant to geology and soil. Title 14 addresses the City’s public utilities infrastructure. Section 14.08.030 requires anyone desiring to obtain a building permit for a new house or structure to connect to the public sewer system when the property on which such house or structure is situated is not more than 160 feet from the public sewer and the right-of-way admits such connection, or if the house or structure is located within an area where the use of a septic tank poses a potential contamination risk to the City's drinking water wells in the area, as specified by resolution of City Council.

Title 17-Grading Code
Title 17 of the RMC contains the City’s grading ordinance, which establishes procedures for grading plan approval, issuance of grading permits, and subsequent inspection and enforcement protocols.

With a few exceptions detailed in Section 17.12.010, the grading ordinance prohibits grading on any lot, parcel, or tract of land without issuance of a grading permit from the City’s Public Works Director. Materials required as part of a grading permit application include grading plans, interim erosion control plans, and a preliminary soils report prepared by a geotechnical engineer. Pursuant to Section 17.16.010(B), recommendations specified in the preliminary soils report must be incorporated into the design of the grading plan.

Additionally, the grading permit application incorporates the requirements of the NPDES Construction General Permit, such as preparation of a SWPPP, and requires documentation of water quality best management practices required under the Riverside County Drainage Area Management Plan.

Section 17.28.010 contains minimum grading standards and general requirements, including standards for cuts, fills, retaining walls, setbacks, drainage and terracing, and excavation blasting. Additionally, the grading ordinance establishes supplementary regulations for grading in hillsides and arroyos.

Applicable General Plan Policies

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Policy PS-1.1: Ensure that all new development in the City abides by the most recently adopted City and State seismic and geotechnical requirements.

Policy PS-9.8: Reduce the risk to the community from hazards related to geologic conditions, seismic activity, flooding and structural and wildland fires by requiring feasible mitigation of such impacts on discretionary development projects.

Applicable General Plan Mitigation Measures
The GP PEIR identified that projects that propose to install septic systems comply with MM Geo-1 which requires an investigation as to the suitability of the site to support septic systems.

MM Geo-1 does not apply to the Proposed Project because it will connect to the City sewer system. Therefore, the Proposed Project will adhere to and implement the above General Plan policies, as well as the existing regulations and Codes as identified above.. As no Proposed Projec t-specific impacts were identified, no additional mitigation measures are applicable.

5.7.4 Conclusion
With regards to the issue area of Geology and Soils, the following findings can be made:

1. No peculiar impacts to the Proposed Project or its site have been identified.

2. There are no impacts that were not analyzed as significant effects in the GP PEIR, with which the Proposed Project is consistent.

3. There are no potentially significant off -site and/or cumulative impacts which were not discussed by the GP PEIR.

4. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

5. No mitigation measures contained within the GP PEIR would be required because they are not applicable to the Proposed Project, and no additional mitigation is required because the Proposed Project-specific impacts would be less than significant.

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5.8 Greenhouse Gas Emissions
Impact

5.8.1 Discussion
The following study was performed to determine potential Proposed Project-specific impacts:
• Air Quality and Greenhouse Gas Technical Memorandum prepared by KPC EHS Consultants, LLC on 3-29-2024 (Appendix A).
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
b. Conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases?
GP PEIR Impacts-Significant and Unavoidable
Note: The 2025 EIR analyzed greenhouse gas (GHG) emissions under Section 5.3, Air Quality, of the GP PEIR. Updates to the CEQA Guidelines in 2010 created a separate category for GHG emissions.

To be consistent with the most recent version of Appendix G of the CEQA Guidelines. the discussion from the GP PEIR is now analyzed under Section 5.8, Greenhouse Gas Emissions.

The GP PEIR discussed GHG emissions on pages 5.3 -43 through and indicated that build -out of the General Plan at Typical densities is expected to increase vehicle trips by approximately 50 percent above existing conditions, while Maximum w/PRD-level development, which is theoretically possible but not reasonably foreseeable, would increase vehicle trips over 400 percent compared to existing conditions. Further, the GP PEIR indicated that CO2 emissions associated with vehicle miles traveled (VMT) are a good indicator of GHGs associated with a land development projects. Table 5.3 -P of CEQA Sections 15168 and 15183 Analysis
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the GP PEIR shows CO2 emissions of 4.2 tons per person annually, corresponding to annual VMT per person of 11,592.81.

In addition to emissions from VMT, GHG emissions may also be emitted from stationary sources, such as electricity generation. As noted in the Utilities section of the GP P EIR, implementation of the proposed General Plan would increase use of electricity in the Planning Area, particularly the demand for electricity to light, heat, and air condition the residential, commercial, and business development. New power production facilities proposed by the City i nclude photovoltaic stations and natural gas-powered plants. Existing sources of energy, which includes a mix of renewable, coal, nuclear, and natural gas, will also continue to be used. The GP PEIR noted that s ources and categories of sources will be subj ect to the emissions reductions strategy mandated by AB 32, however, no specific regulations, market mechanism, or other actions had been identified or adopted since AB 32 was adopted. Nevertheless, due to increased use in the Planning Area and for the pur poses of this analysis, GHG emissions from energy use and other stationary sources were considered cumulatively considerable under all development scenarios.

Given that the build-out of the General Plan would result in GHG emissions of 1.63 million metric tons in 2020 within a region that will produce 7.3 million metric tons and would generate approximately three times the annual level in 1990 and approximately double the tons of CO2 per person, the increase in GHG was considered significant. Therefore, GHG production is considered cumulatively considerable.

In accordance with CEQA, impacts that are less than significant individually, but cumulatively considerable, may be significant. Although there is no standard directly applicable to adoption and implementation of the General Plan, cumulative emissions resulting from buildout in 2025 will contribute criteria pollutants and global warming gases to the Basin. Therefore, The GP PEIR concluded that implementation of the General Plan will result in a cumulati vely significant net increase of criteria pollutants and global warming gases.

However, the GP PEIR identified Mitigation Measures MM Air-8 through MM Air-10 (refer to GP EIR pp

5.3-53 through 5.3-54) that are specific to greenhouse gas emission reduction, which if implemented, would reduce impacts of greenhouse gas emissions to less than significant. Mitigation Measures MM Air-8 through MM Air-10 are identified as follows:

MM Air 8: To reduce GHG emissions through reduced energy consumption and the procurement of lower-emission resources, Riverside Public Utilities (RPU) shall join the California Climate Action Registry (www.climateregistry.org) and comply with GHG regulations developed by the California Air Resources Board (CARB) and the California Energy Commission (CEC) pursuant to AB 32. RPU shall perform yearly GHG inventories according to the Power/Utility Protocol to identify and implement conservation measures and resource procurement practices that will reduce its GHG emissions.

MM Air 9: To reduce GHG emissions, the City’s Environmental Relations Manager, working in conjunction with RPU shall develop, enhance, and/or implement programs to reduce energy consumption. Some examples of programs may be, but are not limited to:

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Riverside City CouncilJune 24, 2025

Riverside City Council
June 24, 2025