Riverside City Council
March 24, 2026

PART II - CODE OF ORDINANCES
Title 19 - ZONING

ARTICLE VI OVERLAY ZONES

Riverside, California, Code of Ordinances Created: 2024-01-12 10:14:44 [EST] (Supp. No. 23, Update 1)

ARTICLE VI OVERLAY ZONES
Chapter 19.170 INNOVATION DISTRICT OVERLAY ZONE (ID)

19.170.010 Purpose.

The Innovation District (ID) Overlay Zone is established to:

A. Implement the goals, policies, and principles of the General Plan.

B. Enable and encourage new development in the ID Overlay Zone area.

C. Support a mix of high-density residential, high-intensity employment/office, civic, entertainment, institutional and pedestrian-oriented retail uses.

D. Encourage investment in public facilities through quality redevelopment and improvements.

E. Ensure that new development and redevelopment are designed to minimize traffic, parking and impacts on surrounding residential neighborhoods, and create walkable environments.

If regulations or development standards are not included in this Chapter, refer to the standards in applicable Chapter of Title 19.
( Ord. 7573 § 1(Exh. A), 2021)

19.170.020 Application.

A. Application. The Innovation District (ID) Overlay Zone may be applied to the area bounded to the west by the State Route 91, to the north by State Route 60/Interstate 215, and to the south by Third Street. The ID Overlay Zone may be applied in combination with any existing Base Zone.

B. Relationship to ID Master Plan. The ID Overlay implements the intent and guidelines in the ID Master Plan document.

C. Permit requirements.

1. In addition to any other permits required by the Zoning Code, new building or structure construction, sign or exterior alterations, enlargement of an existing building, structure, or signs shall, pursuant to Chapters 19.710 require Design Review.

2. Minor Conditional Use Permit may be required pursuant to and 19.730.

D. Design Standards.

1. All projects must comply with the standards listed in this Chapter and in effect at the time the development is submitted to the City.

2. Design Review processing and approval does not preclude compliance with all regulations and permitting requirements applicable to the proposed development.

3. When required by this chapter, street dedication and improvements for building permits, the public street or right-of-way must be dedicated and improved consistent with all applicable City standards.

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

E. Existing and Entitled Industrial and Manufacturing Uses. The ID Overlay Zone authorizes existing and entitled industrial and manufacturing land uses to continue and expand as legal, conforming land uses until such time as they are converted to uses permitted in the applicable ID Overlay Zone Sub- District as set forth in Section

19.170.040 (Permitted Uses).
( Ord. 7573 § 1(Exh. A), 2021)

19.170.030 Sub-districts.

The ID Overlay Zone is divided into Sub-Districts as set forth in Table 19.240.030.

Table 19.170.030 - Innovation District Overlay Sub-District Descriptions Sub-District Sub-District Description
IE - Industrial
Emphasis
IE encourages a wide range of industrial, office, and commercial uses that may be integrated vertically and/or horizontally. While predominantly a mix of light industrial and office uses, other standalone uses, such as transportation services and energy- generation facilities, are encouraged. Clean & green industries, such as renewable energy, low-carbon, research and development, and public transportation infrastructure uses are encouraged in this Sub-District.

EE - Employment
Emphasis
EE promotes high-intensity vertical mix of office, clean & green industrial, educational, and hospitality uses to be an employment center of regional importance with a limited mix of residential uses to compliment the employment focus. Clean & green indust ries, including renewable energy, low-carbon, education and training, and research and development are encouraged.

HE - Housing
Emphasis
HE accommodates primarily residential housing development supported by ground -floor neighborhood-serving commercial uses and live work opportunities, with limited industrial functions.

ET - Eastside
Transition
ET accommodates mid to low-rise buildings with a diverse array of uses, including residential, neighborhood-serving commercial, and limited office uses, that integrate more seamlessly with the neighboring Eastside Neighborhood.

CS - Civic Space CS allows for greens, squares, and plazas with a variety of Civic Facilities.

( Ord. 7573 § 1(Exh. A), 2021)

19.170.040 Permitted uses.

The following table establishes the permitted land uses and uses permitted subject to the approval of a minor conditional use permit (Chapter 19.730 - Minor Conditional Use Permit) in the ID Overlay Zone Sub- Districts. Table

19.240.040 also identifies those uses that are specifically prohibited. Uses not listed in table are prohibited unless the Community & Economic Development Department Director, or his/her designee, pursuant to Chapter 19.060 (Interpretation of Code), determines that the use is similar and no more detrimental than a listed permitted or conditional use. Any use which is prohibited by state and/or federal law is also strictly prohibited.

Table 19.170.040 - Permitted Uses
This table identifies permitted uses and uses requiring approval of other permits by zoning designation.

District IE EE HE ET CS
Civic Facilities
Community Center and Services X P P P P
Emergency Shelters MC MC MC X P

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

Outdoor Auditorium and Performances X MC MC X P
Public Parking Areas and Structured Garages P P MC MC P Transit Mobility Services and Stations P P P P P
Commercial Functions
Alcohol Sales - On-Premises P P P MC P
Assemblies of People - Entertainment (<500 people) X MC MC MC MC Assemblies of People - Non-Entertainment (<500
people)

X MC MC MC MC
Clean Energy Use P P P X X
Day Care (child and senior) MC P P P P
Education and Training Facilities X P P MC MC
Home Occupations X P P P X
Personal Services P P P P X
Retail Sales P P P P P
Restaurant (Full Service, Limit-Service, Small Shop,
excluding drive-thru)

P P P P P
Shopkeeper Units (predominately work within a living
space)

X P MC P
Vehicle Repair (indoor only) P MC X X X
Veterinarian/Small Animal Clinic P P P MC X
Hospitality Functions
Convention Services X P P X P
Hotel X P P X X
Industrial Functions
Clean Energy Use P P P X X
Heavy-Industries MC MC X X X
Light-Industries P P MC X X
Outdoor Storage P MC X X X
Research Laboratories (wet laboratories/OSHA
regulated)

P P MC MC X
Transportation Facilities P MC X X X
Warehousing and Distribution Facilities P X X X X
Office Functions
Administrative and Professional Facilities P P P MC X Medical Facilities P P MC MC X
Research Laboratories (non-OSHA regulated) P P MC X X Residential Types
Attached Multiple-Family Dwelling X P P P X
Detached Single and Multiple Family Dwelling X X X P X Live/Work Units (predominately living within a
workspace)

X MC P MC X
Single-Room Occupancy Unit (Co-Living) X P P MC X
C = Subject to the granting of a conditional use permit (CUP), Chapter 19.760 SP = Site Plan Review Permit, Chapter 19.770
MC = Subject to the granting of Minor Conditional Use Permit (MCUP), Chapter 19.730 sq. ft. = Square Feet
P = Permitted

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

( Ord. 7573 § 1(Exh. A), 2021)

19.170.050 Application Requirements and Processes.

All application requirements and processes identified in Article IX of this Title shall apply to this Chapter. ( Ord. 7573 § 1(Exh. A), 2021)

19.170.060 Building intensity and location standards.

Table 19.170.060 - Building Intensity and Location
This table coordinates specific Building Functions, Intensities, and Location within each Zoning Sub -District.

Sub-District
Function

IE EE HE ET
Civic Civic space edges
shall be completely
or predominately
bounded by
buildings mid-block
or at street corners.

Civic spaces may be
hybrids and directly
with public
streetscape
elements located
mid-block and/or at
corners.

Civic space edges
shall be completely
or partially
bounded by
buildings and/or
located mid-block
and street corners.

Civic space edges
may be partially
bounded by
buildings and shall
be directly
accessible to 3rd
Street walkways.

Commercial 1st floor of the
primary building on
corner lots may be
commercial.

Up to 60% of the
primary and
accessory buildings
may be commercial.

Up to 40% of the
primary and/or
accessory buildings
may be commercial.

On corner lots up to
20% of the primary
buildings 1st floor
shall be
commercial.

Hospitality Not allowed. Up to 60% of the
primary and/or
accessory buildings
may be hospitality
uses.

Up to 80% of the
primary buildings
may be hotel uses.

Not allowed.

Industrial Up to 60% of the
primary and
accessory buildings
shall be industrial.

Primary and
accessory buildings
may be industrial.

Up to 60% of the
primary buildings
may be light
industrial and/or
clean and green
industry.

Only 1st floors of
accessory buildings
may be light
industrial and/or
clean and green
industries.

Only 1st floors of
accessory buildings
may be light
industrial and/or
clean and green
industries.

Not allowed.

Office Up to 40% of the
primary and
accessory buildings
may be office.

Up to 100% of the
primary buildings
may be office.

Up to 40% of the
area of the primary
and accessory
buildings may be
Floors 1 - 2 of the
primary buildings
may be office.

Up to 100% of

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

office.

Only floors 1-2 in
the accessory
buildings may be
office
accessory buildings
may be office.

Residential Not allowed. Up to 40% of the
primary and/or
accessory buildings
shall be residential.

Units are allowed to
average >400
square feet.

Up to 100% of the
primary buildings
may be residential.

Units are allowed to
average >600
square feet
Up to 100% of the
primary and
accessory buildings
may be residential,
except corner lots.

Units are allowed to
average >800
square feet

( Ord. 7573 § 1(Exh. A), 2021)

19.170.070 Sub-district development standards.

The following diagram illustrates key terms used to define development areas on a lot for this Chapter:

Figure 19.170.070

Table 19.170.070 IE - Industrial Emphasis (IE) Sub-District Development Standards

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

IE Development Standards Minimum Maximum #
Lot and Density
Lot Width (ft.) 25 - ①
Floor Area Ratio (FAR) Sites under 5 acres 1.0 2.0
Sites over 5 acres 0.40 N/A
Residential Density (Lots - Dwelling Units per Acre) N/A N/A Building Form and Location
Building Height - Primary Building (Floors) 2 floors N/A 5 floors/75-feet ② Building Height - Accessory Building (Floors) 3 floors Build-to Lines and Setbacks (ft.)
Front (Principal Building) 5 10 ③
Front (Principal Building)1
Kansas, Massachusetts,
and Chicago Avenues
5 102 ③
All Other Frontages Same as I –
General
Industrial Zone
N/A
Front (Front Layer and Principal Building) Side Street 5 10 ④ Side Street (Rear Layer and Accessory Building) 5 10 ⑤ Interior Side 5 10 ⑥
Rear 10 10 ⑦
Architectural Feature Projection Front (Principal
Building) Encroachment (%)
- 40% 5 feet ⑧
Storage and Loading Area (Principal Building - Front
Lot Layer)
5 - ⑨
Outdoor Storage and Loading Area (Accessory Building
- Real Lot Layer)
10 - ⑩
Rear Lot Layer Setback from Primary Frontage Line 25 - ⇑ Parking
Off-Street Parking 2 1 spaces per
51000 sq ft or
per Zoning
Code,
whichever is
less
5 spaces per 1000
sq ft

"#"in the table corresponds with the numbers on the graphic 1 Common ground floor open space may encroach into the setback area Formatted Table
Formatted Table
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Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

2 Eighty percent or more of the building façade shall comply.

Table 19.170.070 EE - Employment Emphasis Sub-District Development Standards

EE Development Standards Minimum Maximum #
Lot and Density
Lot Width (ft.) 25 300 ①
Floor Area Ratio (FAR) 2.0 6.0
Residential Density (Lots - Dwelling Units per Acre) 30 100 Building Form and Location
Building Height - Primary Building (Floors) 2 floors 12 floors/140- feet
②
Building Step-back 4th floor/+55
feet
6th floor/+75 feet
Building Height - Accessory Building (Floors) - 6 floors Build-to Lines and Setbacks (ft.)
Front (Principal Building) 0 10 ③
Front (Principal Building) Street Side (Primary Street) 0 10 ④ Street Side (Secondary) Minimum 5 10 ⑤
Interior Side 0 10 ⑤
Rear Minimum 5 10 ⑦
Front (Principal Building) Encroachment (%) 60% 80% ⑧ Storage and Loading Area (Principal Building - Front
Lot Layer)
5 - ⑨
Outdoor Storage and Loading Area (Accessory Building
- Real Lot Layer)
10 - ⑩
Rear Lot Layer Setback from Primary Frontage Line 20 - ⇑ Parking
Formatted: Superscript

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

Off-Street Parking 3 spaces per
1,000 sq. ft. for
Nonresidential

1.5 space per
Residential
Housing Unit

"#"in the table corresponds with the numbers on the graphic

Table 19.170.070 HE - Housing Emphasis Sub-District Development Standards

HE Development Standards Minimum Maximum #
Lot and Density
Minimum Lot Width (ft.) 25 300 ①
Maximum Floor Area Ratio (FAR) 2.0 5.0
Residential Density (Lots - Dwelling Units per Acre) 30 150 Building Form and Location
Building Height - Primary Building (Floors) 2 floors 24 floors/240- feet
②
Building Step-back - Primary Building (Floors and
approximate feet)
4th floor/+55
feet
6th floor/+75 feet
Building Height - Accessory Building (Floors) - 6 floors Build-to Lines and Setbacks (ft.)
Front (Principal Building) 0 10 ③
Front (Principal Building) Street Side (Primary Street) 0 10 ④ Street Side (Secondary) Minimum 5 10 ⑤
Interior Side 0 10 ⑥
Rear Minimum 5 10 ⑦
Front (Principal Building) Encroachment (%) 60% 80% ⑧ Storage and Loading Area (Principal Building - Front
Lot Layer)
5 - ⑨
Outdoor Storage and Loading Area (Accessory Building
- Real Lot Layer)
10 - ⑩
Rear Lot Layer Setback from Primary Frontage Line 30 - ⇑ Parking

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

Off-Street Parking 2 spaces per
1,000 sq. ft. for
Nonresidential

1.5 spaces per
Residential
Housing Unit

"#"in the table corresponds with the numbers on the graphic

Table 19.170.070 ET - Eastside Transition Sub-District Development Standards

D. ET Development Standards Minimum Maximum #
Lot and Density
Minimum Lot Width (ft.) 25 50 ①
Maximum Floor Area Ratio (FAR) 0.5 1.5
Residential Density (Lots - Dwelling Units per Acre) 15 60 Building Form and Location
Building Height - Primary Building (Floors) 1 floor 4 floors/55-feet ② Building Height - Accessory Building (Floors) 1 floor 4 floors Build-to Lines and Setbacks (in Feet)
Front (Principal Building) 5 10 ③
Front (Principal Building) Street Side (Primary Street) 0 10 ④ Street Side (Secondary) Minimum 5 10 ⑤
Interior Side 10 10 ⑥
Rear Minimum 5 15 ⑥
Front (Principal Building) Encroachment (%) 0 60 ⑦
Storage and Loading Area (Principal Building - Front
Lot Layer)
5 - ⑨
Outdoor Storage and Loading Area (Accessory Building
- Real Lot Layer)
10 - ⑩
Rear Lot Layer Setback from Primary Frontage Line 20 - ⇑ Parking
Off-Street Parking 2 spaces per
1,000 sq. ft. for
Nonresidential
2 spaces per
Residential
Housing Unit

"#"in the table corresponds with the numbers on the graphic

( Ord. 7573 § 1(Exh. A), 2021)

Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

19.170.080 Additional standards.

In addition to the requirements outlined in Section 19.240.060, the following shall apply to building placement.

The following diagram illustrates key terms used to define development areas on a lot:

A. Additional setback requirements.

1. The façade of the primary building shall be built parallel to the primary Frontage Line.

21. Façade width.
a. In the EE and HE Sub-Districts, the minimum façade width shall be 80 percent of the lot width.
b. In the IE and ET Sub-Districts, the minimum façade width shall be 60 percent of the lot width.

32. Permitted encroachments into the front setback include the following private building frontage elements: stoops (exterior stairs), forecourt terraces (at grade space), light court terraces (below grade space and stairs), recessed arcades and walkways, outdoor dining, green walls, artistic expressions, parking access screening, and planter boxes.

43. M
aximum Bbuilding setbacks.
a. Buildings shall be located no farther from frontage line than the maximum setback. a. (1) For buildings fronting on two primary streets, the front setback shall apply on both frontages.
b. (2 ) For buildings fronting on three or more streets, the front setback shall apply on at least two of the frontages.

54. Acce ssory buildings.
a. Accessory buildings in the rear setback shall be a minimum of 15 feet measured from the centerline of the rear alley easement.
b. In the absence of a rear alley, the rear setback for accessory buildings, the setback shall be a minimum of ten feet.

6. Windows and entryways.
a. All new buildings shall have windows on all perimeter walls oriented towards streets and courtyards.
b. All new buildings shall have clearly identifiable entry doorways on Front façades.

75. Exceptions.
a. Outdoor eating areas - Where an outdoor eating area is installed, a portion of the building may be set back up to 12 feet from the frontage line, if at least 80 percent of the building facade is at the frontage line.
b. Temporary mixed-use areas - A temporary use may be allowed on vacant lots in EE and/or HE Sub-Districts to activate the site if it meets the Sub-District's general intent as defined in this title.

B. Façade width.

1. In the EE and HE Sub-Districts, the minimum façade width shall be 80 percent of the lot width.

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Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

2. In the IE and ET Sub-Districts, the minimum façade width shall be 60 percent of the lot width.

C. Building heights.

1. Heights do not apply to attics, parapets, belfries, clock towers, chimney flutes, water tanks, elevator bulkheads or tower.

2. Residential building floor to finished ceiling height must be a minimum of ten feet in HE, EE, and ET Sub-Districts, except for ground or first floor live-work uses which do not have a minimum.

3. For development projects in all Sub-Districts that adjoin the ET Sub-District, the maximum building height shall be 65 feet within 20 feet of the ET Sub-district.

CD. Façade glazing and openings.

1. The ground floor façade of primary buildings with commercial and/or office uses shall be a minimum of 70 percent glazed area.

2. Ground floor openings shall have transparent glazing and provide views into work areas, display areas, sales areas, lobbies, or similar active spaces, or into window displays that are three feet deep or more.

3. Openings above the first floor shall not exceed 70 percent of the total building front wall, with each façade being calculated independently.

4. In the EE, HE and ET Sub-Districts, a continuous plane of any building façade shall not exceed 20 feet without an opening.

5. Exceptions to glazing.
a. In the ID IE Sub-District, multi-level parking facilities, where permitted, are not required to meet the ground-floor transparency requirement (refer to development standard, C1 above).
b. If buildings are in rear layer behind primary buildings, and not visible from the adjacent public street, the building ground-floor transparency requirement shall not applybe required (refer to development standard, C1 above).

DE. Windows and entryways.
a1. All new buildings shall have windows on all perimeter walls oriented towards streets and courtyards.
b2. All new buildings shall have clearly identifiable entry doorways on Front façades.

F. Loading areas.

1. Truck docks, loading, storage yards, and service areas are permitted within the rear layer on rear alley and lanes.

2. L oading , storage yards, and service areas shall be located on the side or rear of buildings and shall not face a primary street.

EG. Open space.

1. Common ground floor open space.
a. Common ground floor open space is to be used for enhanced landscaping and passive/active gathering areas. Common ground floor open space does not include land occupied by streets, driveways, parking areas, service areas, required landscape areas or required front and street side yards.

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Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

ab. Common ground floor open space may be provided in lieu of providing individual open space for each unit within the first four floors above the ground floor. bc. I n the IE, EE and HE Sub- Districts, common ground floor open space, including, but not limited to terraces, courtyards, plazas, and patios, is required and must be directly accessible from within the primary building.
d. I n the IE Sub- district, common ground floor open space adjacent to the public right- of- way shall be screened with decorative wall compliant with the development standards below (Section L.3).
e. Minimum Dimensions
i. Common ground floor open space shall be provided at a rate of 70 square feet per 1,000 square feet of building area or a minimum of 7,000 square feet, whichever is less.
ii. Each cCommon ground floor open space area shall have a minimum horizontal dimension of 20 feet in width in width and shall be a minimum of 7,000 square feet.

2. Common upper floor open space—Mixed-use buildings.
a. In the EE and HE Sub- Districts, common upper floor open space, including, but not limited to, balconies, decks, terraces, common open space, and rooftops, is required for every five floors above the first four floors and the on the rooftop. b. Common upper floor open space is required for every for every five floors above the first four floors and the on the rooftop, in addition the private open space required in this section. c. Common upper floor private open space shall have a minimum horizontal dimension of six feet in width and shall be a minimum of 2,000 square feet.

3. Private upper floor open space—Residential units.
a. Private upper floor open space shall include a balcony, deck, patio, porch that is directly accessible by a doorway from a habitable room within the residential unit. b. For each residential unit located on the fifth floor or higher, a private upper floor open space shall be a minimum 24 square feet.

FH. Outdoor retail sales and merchandise display.

1. All outdoor retail sales and merchandise displays shall be directly accessible to the primary business.

2. Outdoor retail sales and merchandise displays shall not obstruct ingress and egress to a building, hinder accessibility, obstruct fire lanes, interfere with vehicular circulation, or sight distance, or be in landscaped areas.

3. Outdoor retail sales and merchandise displays shall not exceed five percent of the total gross floor area of the business, or 200 square feet, whichever is less.

4. Display merchandise shall not exceed a height of six feet above finished grade.

5. The temporary use of a parking or undeveloped area for outdoor retail sales, merchandise displays, and entertainment is permitted with a temporary use permit as defined in this title the Zoning Code.

GI. Outdoor storage.

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Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

1. 1. For nonresidential uses, storage shall be located in the rear layer of the lot and not visible from streets.

2. Storage shall be located behind the rear most wall of the building, or 50 feet, whichever is less.

3. 2. In the EE, HE and ET Sub- Districts, storage shall be a maximum ten percent of the gross floor area of the use or 600 square feet, whichever is less.

4. 3. I n the IE Sub- District, storage shall be a maximum 40 10 percent of the gross floor area of the use or 1,000 square feet, whichever is lesslot area.

HJ. Parking.

1. Screening.
a. For lots without a primary building, parking shall be fully screened using landscaping, a decorative, opaque walls, or other rigid materials to screen any parking spaces located in the front layer.
b. Scr eening shall be a minimum 4036- inches in height. c. Screening shall be setback a minimum of two-feet from the frontage property line.

2. Off-street parking shall be set in the rear layer and set back a minimum of 25 feet from the frontage property line.
a. Parking may be setback a minimum of 10 feet from the street adjacent property line s, if a decorative wall compliant with the development standards below (Section L.3) is provided to screen the parking.

3. Exceptions to off -street parking requirement may be granted for short -term customer parking, drop-off, and public-private partnership car share spaces.

IK. Pedestrian network connectivity.

1. An internal network of pedestrian walkways shall connect: 1) all buildings on a site; 2) on -site automobile and bicycle parking areas; 3) sidewalks; and 4) any on -site common open space or amenity.

2. Private, internal walkways shall be a minimum of six feet wide, hard surfaced/paved with concrete, stone, tile, brick, or comparable material.

3. When walkways cross driveways, parking areas, or loading areas, clearly identifiable markings shall be required and may include a raised crosswalk, a different paving material, or similar method.

4. Where a walkway is parallel and immediately adjacent to a n auto access alley drive aisle, clearly identifiable markings shall be required to separate the walkway from the auto travel lane using a raised curb, bollards, or other physical barriers.

L. E
dge conditions.

1. Building pads sited along Massachusetts Avenue, between Kansas and Chicago Avenues, shall be equal to the grade of the public right-of-way.

2. All developments shall provide parkway adjacent sidewalks along Massachusetts Avenue.

3. F ences and walls facing public rights-of-way require a minimum setback of 5-feet from the property line.
a. Fences and walls are not permitted to be located between the building and the public right - of-way.

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Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment:

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bullets or numbering
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Created: 2024-01-12 10:14:43 [EST]
(Supp. No. 23, Update 1)

b. Height of fences and walls facing public rights-of-way may be a maximum of 6-feet in height.

Provided that the bottom 2/3s of the wall is solid, and the upper 1/3 of the wall is openwork. c. Fences and walls facing public rights-of-way shall be constructed of a minimum of two decorative materials.

4. Site Plan shall be designed to prevent the queuing of trucks on streets or elsewhere outside of facility.

M. Temporary mixed-use areas.

1. A temporary use may be allowed on vacant lots in EE and/or HE Sub -Districts to activate the site if it meets the Sub-District's general intent.
( Ord. 7573 § 1(Exh. A), 2021)

19.170.090 Nonconformities.

A. Land uses and structures legally established that do not conform to this chapter may continue to exist and operate as legal, conforming uses.

B. Expansion of such uses and structures shall be limited as follows:

1. The gross floor area may be expanded up to ten percent of the existing gross floor area of structures on the premises through a design review.

2. The gross floor area of previously conforming uses and structures may be expanded up to 50 percent of the existing gross floor area of structures on the premises through a minor conditional use permit.

3. Within the HE Sub-district, existing conforming nonresidential uses may be replaced with other conforming, nonresidential uses without complying with the 80 percent residential land use requirement for new development.
( Ord. 7573 § 1(Exh. A), 2021)

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SENT VIA E-MAIL: August 07, 2025
[email protected]
Candice Assadzadeh, Senior Planner
City of Riverside
Community & Economic Development Department Planning Division 3900 Main Street, 3rd Floor
Riverside, CA 92522

Draft Environmental Impact Report (EIR) for the Proposed Massachusetts Point Project (Proposed Project)
(SCH No.: 2024120391)

South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above-mentioned document. The City of Riverside is the California Environmental Quality Act (CEQA) Lead Agency for the Proposed Project. To provide context, South Coast AQMD staff has provided a brief summary of the project information and prepared the following comments, organized by topic of concern.

Summary of Project Information in the Draft EIR

Based on the Draft EIR, the Proposed Project site encompasses approximately 14.42 acres 1 and consists of demolishing the existing structures and constructing two light industrial buildings for a total of 199,850 square feet (sf) of warehouse and office uses on approximately 10. 21 acres.2 Building 1 would consist of 99,900 sf with 17 dock doors along the southern side of the building, and Building 2 would consist of 99,950 sf with 22 dock doors along the northern side of the building.3 The Proposed Project assumes 20 percent (%) of the warehouses for cold storage.4 The Proposed Project site is located at 2626 Kansas Avenue, 2069 Massachusetts Avenue, and 1989 Massachusetts Avenue. 5 Based on the review of the aerial photograph, the nearest sensitive receptor (e.g., residence) is approximately 680 feet northeast of the Proposed Project site .

Construction of the Proposed Project is anticipated to take approximately 14 months, with operations beginning in 2027.6

South Coast AQMD Comments

Incorrect Land Use Type Used in CalEEMod

According to the CalEEMod detailed report provided in Appendix B – Air Quality, Energy, and GHG Report, the land use type selected for the unrefrigerated portion of the warehouses is

1 Draft EIR. p. 3-1.
2 Ibid. p. 3-25.
3 Ibid. p. 3-25 and 3-27.
4 Ibid. p. 3-45.
5 Ibid. p. 3-1.
6 Ibid.

Candice Assadzadeh, Senior Planner August 07, 2025
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categorized as General Heavy Industry .7 However, based on the CalEEMod User Guide, the General Heavy Industry land use type is defined as: “Heavy industrial facilities usually have a high number of employees per industrial plant and are generally limited to the manufacturing of large items.”8

This classification does not accurately reflect the Proposed Project, which involves the development of two warehouse buildings with 20% of cold storage . The appropriate land use category for this project in CalEEMod should therefore be Unrefrigerated Warehouse and Refrigerated Warehouse, which more accurately represent the expected operational characteristics and associated emission factors.

Use of the incorrect land use category may lead to underestimation of construction and operational emissions in the environmental impact analysis. To ensure a more accurate assessment of air quality impacts, the Lead Agency is recommended to revise the CalEEMod inputs accordingly, rerun the model using the appropriate land use classification, and incorporate the updated results into the Final EIR.

Potentially Underestimated Construction Emissions

According to Section 5.9: Hazards and Hazardous Materials of the Draft EIR , its Phase I Environmental Site Assessment found that the Proposed Project site contains volatile organic compounds (VOCs) at concentrations that exceed their applicable regulatory screening thresholds9, specifically:
• At 2626 Kansas Avenue, elevated concentrations of trichloroethene (TCE) have been identified in shallow soil vapor in the northwest portion of the site; tetrachloroethene (PCE) and TCE have been detected in the south-central and southeastern exterior areas; and 1,1- dichloroethene (1,1 -DCE) has been detected in groundwater monitoring wells on the northwest portion of the site.
• At 2069 and 1989 Massachusetts Avenue, PCE and TCE have also been detected.

The Lead Agency has proposed Mitigation Measure HAZ-1, which requires preparation of a Soil Management Plan (SMP) and a Health and Safety Plan (HSP), both of which must be reviewed and approved by the Santa Ana Regional Water Quality Control Board prior to issuance of any grading or excavation permits.10 However, the Draft EIR does not evaluate the potential air quality impacts associated with site cleanup and remediation activities during construction.

Cleanup activities will likely involve the use of heavy -duty, diesel-fueled trucks for soil export and result in emissions from truck hauling activities and vehicle trips by workers that will be required to conduct cleanup activities. Additionally, cleanup activities will likely require the use of additional equipment that may be different from typical equipment for grading and site preparation for construction. Based on the emission calculations from the California Emissions Estimator Model ( CalEEMod) detailed report, the Lead Agency used the default one -way truck trip length of 20 miles to quantify the Proposed Project’s construction emissions from hauling

7 Appendix B – Air Quality, Energy, and GHG Report. CalEEMod Detailed Report. 8 CalEEMod User Guide. P. 23.
9 Ibid. p. 5.9-18.
10 Ibid. p. 5.9-26.

Candice Assadzadeh, Senior Planner August 07, 2025
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construction materials and importing soil. According to Section 5.19: Utilities and Service Systems of the Draft EIR, it is identified that Badlands Landfill, Lamb Canyon Landfill, the El Sobrante Landfill, and Mid-Valley Sanitary Landfill are the municipal waste landfill s that could serve the Proposed Project. 11 If cleanup activities include the removal and disposal of contaminated soil, depending on the type of contamination , these landfills may not accept the contaminated soil. In that case, contaminated soil may need to be transported to a permitted hazardous waste disposal facility located outside Riverside County, which could require a one-way trip significantly longer than 20 miles.

To ensure an accurate quantification of construction -related emissions , including the cleanup activities, particularly for regional criteria pollutants and greenhouse gases, the Lead Agency is recommended to revise the CalEEMod12 model inputs to reflect the actual distance to a known and permitted hazardous waste disposal facility expected to be used by the project . The selected trip length should be clearly disclosed and justified in the Final EIR. Should the Lead Agency elect not to revise the default 20-mile haul distance, a detailed rationale supported by substantial evidence in the administrative record must be p rovided to demonstrate the appropriateness of the default assumption in the context of the project-specific conditions.

Unsupported Truck Trip Distance Assumption Used in Emissions Modeling

Accurately estimating truck trip lengths is a key parameter when quantifying emissions from mobile sources, especially diesel particulate matter (DPM), oxides of nitrogen (NOx), and greenhouse gas (GHG). The mischaracterization of average trip length, for example, can lead to a significant underestimation of the project’s air quality impacts. According to the Draft EIR, the truck emissions are calculated with the truck trip length as the weighted average of 15.3 miles for 2-axle, 14.2 miles for 3-axle, and 40 miles for 4-axle trucks.13 However, the analysis lacks critical information regarding the supporting basis for determining the trip origins and destinations and whether the assumed distances are reflective of actual or anticipated routing patterns of the facility’s current or future truck fleet.

As such, the Final EIR should include a clear and defensible rationale for the use of the truck trip length assumption. The rationale should be supported by documentation such as empirical data from fleet operations, transportation logistics studies, regional freight movement data, or other sources that demonstrate the applicability and appropriateness of the selected distances.

Additionally, if any truck trips associated with the Proposed Project will include port -related activities, the Final EIR should explain this detail, and the modeled trip lengths should accurately reflect the mileage between the project site and the relevant port(s), such as the Ports of Los Angeles or Long Beach , located approximately 65-70 miles one-way from the Proposed Project site.

Therefore, it is recommended that the Lead Agency either revise the trip distance assumptions to more accurately reflect realistic operational conditions or provide additional evidence substantiating that the selected distances are representative of actual or reason ably foreseeable truck travel patterns associated with the Proposed Project. Failure to provide supporting evidence

11 Ibid. p. 5.19-16.
12 CalEEMod free of charge available at https://www.caleemod.com/ 13 Ibid. p. 5.3-22.

Candice Assadzadeh, Senior Planner August 07, 2025
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to validate these assumptions may compromise the accuracy of the emission estimates, conclusion, and the overall integrity of the air quality analysis presented in the Final EIR.

Truck Idling Duration and Emissions Modeling

Appendix C – Health Risk Assessment indicates that a default assumption of 15 minutes of idling per truck per day, including Transport Refrigeration Unit (TRU) trucks, was used to estimate DPM emissions for the operational health risk assessment.14 While this assumption may be consistent with regulatory idling limits, it may not accurately reflect actual operating conditions for a facility of the Proposed Project's scale. The Proposed Project is anticipated to generate approximately 342 truck trips per day, with 20% of all heavy-duty diesel trucks assumed to be equipped with a TRU,15 representing a substantial volume of heavy -duty vehicle activity. For a high -throughput logistics or distribution facility, it is reasonable to expect that individual trucks may experience extended periods of idling due to on -site queuing, security checks , staging, loading, and unloading operations, particularly during peak hours or in constrained circulation areas. As such, a 15-minute idling duration may underestimate actual on -site idling behavior and, consequently, DPM emissions, which are a key contributor to localized health risks.

Although the California Air Resources Board (CARB) limits diesel truck idling to five minutes as set forth in the Airborne Toxic Control Measure (ATCM), this regulation provides exemptions for trucks equipped with engines that meet the optional low -NOx idle emission standard , typically applicable to model year 2008 and newer trucks. These vehicles, often referred to as “clean idle” certified, are permitted to idle longer than five minutes when situated more than 100 feet from sensitive land uses such as homes and schools.16 Furthermore, CARB’s EMFAC2021 Volume III Technical Document (Table 4.4.2-5) indicates that heavy-duty trucks may idle for up to five hours at a single location under certain conditions.17

Accurate characterization of idling activity is essential to fully assess a project’s potential health risk impacts, particularly for nearby sensitive receptors. Therefore, to ensure the HRA provides a conservative and health -protective estimate of potential exposure, the Lead Agency is recommended to either: 1) revise the operational emissions modeling in the Final EIR to assume a minimum of 30 minutes of idling per truck per day, unless site -specific data or operational constraints justify a shorter duration ; or 2) provide empirical evidence , such as facility -specific queuing and processing time studies, vehicle circulation modeling, or comparable industry data , to substantiate the 15-minute assumption as representative of expected operations of the Proposed Project.

Inconsistency in Cancer Risk Results Presented in Draft EIR and Its Appendices

The health risk assessment for the Proposed Project includes evaluation of both short -term and long-term DPM emissions associated with construction and operational activities. The estimated cancer risk results are presented in the Draft EIR and its technical appendices. However, upon staff

14 Appendix C – Health Risk Assessment. p. 23.
15 Appendix C – Health Risk Assessment. p. 22.
16 CARB. Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling available at https://ww2.arb.ca.gov/our-work/programs/atcm-to-limit-vehicle-idling 17 CARB. EMFAC2021 Volume III Technical Document. Page 161. Table 4.4.2-5 available at EMFAC2021 Volume III Technical Document
Candice Assadzadeh, Senior Planner August 07, 2025
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review, inconsistencies were identified between the Draft EIR, Appendix C - Health Risk Assessment, and Appendix B - Air Quality, Energy, and Greenhouse Gas Report. Specifically, the Draft EIR and Appendix C both show cancer risks of 0.63 in one million for construction and 5.59 in one million for operation.18,19 In contrast, Appendix B shows 0.54 in one million for construction and 3.55 in one million for operation.20

To ensure transparency, accuracy, and consistency across all CEQA documents, the Lead Agency is recommended to reconcile these discrepancies and include the updates in the Final EIR to reflect the correct and consistent cancer risk values throughout the CEQA document and all supporting appendices.

Additional Recommended Air Quality and Greenhouse Gas Mitigation Measures and Project Design Features for Consideration

CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized to minimize or eliminate any significant adverse air quality impacts. To further reduce the Proposed Project’s air quality impacts, South Coast AQMD reco mmends incorporating the following mitigation measures and project design considerations into the Final EIR.

Mitigation Measures to Reduce Operational Air Quality Impacts from Mobile Sources

1. Require zero -emission (ZE) or near -zero emission (NZE) on -road haul trucks, such as heavy-duty trucks with natural gas engines that meet the CARB’s adopted optional NOx emissions standard at 0.02 grams per brake horsepower -hour (g/bhp -hr), if and when feasible.

Note: Given CARB’s clean truck rules and regulations , aiming to accelerate the utilization and market penetration of ZE and NZE trucks, such as the Advanced Clean Trucks Rule and the Heavy -duty Low NOx Omnibus Regulation, ZE and NZE trucks will become increasingly more available for use.

2. Require a phase-in schedule to incentivize the use of cleaner operating trucks to reduce any significant adverse air quality impacts.

Note: South Coast AQMD staff are available to discuss the availability of current and upcoming truck technologies and incentive programs with the Lead Agency.

3. Limit the daily number of trucks allowed at the Proposed Project to levels analyzed in the Final EIR. If higher daily truck volumes are anticipated to visit the site, the Lead Agency should commit to re-evaluating the Proposed Project through CEQA prior to allowing this higher activity level.

18 Ibid. p. 5.3-28.
19 Appendix C – Health Risk Assessment. p. 31 and 32.
20 Appendix B – Air Quality, Energy, and GHG Report. p. 27.

Candice Assadzadeh, Senior Planner August 07, 2025
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4. Provide electric vehicle (EV) charging stations or, at a minimum, provide electrical infrastructure, and electrical panels should be appropriately sized. Electrical hookups should be provided for truckers to plug in any onboard auxiliary equipment.

Mitigation Measures to Reduce Operational Air Quality Impacts from Other Area Sources

1. Maximize the use of solar energy by installing solar energy arrays.

2. Use light-colored paving and roofing materials.

3. Utilize only Energy Star heating, cooling, and lighting devices and appliances.

Design Considerations for Reducing Air Quality and Health Risk Impacts

1. Clearly mark truck routes with trailblazer signs so that trucks will not travel next to or near sensitive land uses (e.g., residences, schools, daycare centers, etc.).

2. Design the Proposed Project such that truck entrances and exits are not facing sensitive receptors, and trucks will not travel past sensitive land uses to enter or leave the Proposed Project site.

3. Design the Proposed Project such that any truck check -in point is inside the Proposed Project site to ensure no trucks are queuing outside.

4. Design the Proposed Project to ensure that truck traffic inside the Proposed Project site is as far away as feasible from sensitive receptors.

5. Restrict overnight truck parking in sensitive land uses by providing overnight truck parking inside the Proposed Project site.

Lastly, the South Coast AQMD also suggests that the Lead Agency conduct a review of the following references and incorporate additional mitigation measures as applicable to the Proposed Project in the Final EIR:

1. State of California – Department of Justice: Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act21

2. South Coast AQMD 2022 Air Quality Management Plan,22 specifically:
a) Appendix IV -A – South Coast AQMD’s Stationary and Mobile Source Control Measures
b) Appendix IV-B – CARB’s Strategy for South Coast

21 State of California – Department of Justice, Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act available at https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf 22 South Coast AQMD, 2022 Air Quality Management Plan (AQMP) available at http://www.aqmd.gov/home/air-quality/clean- air-plans/air-quality-mgt-plan
Candice Assadzadeh, Senior Planner August 07, 2025
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c) Appendix IV-C – SCAG’s Regional Transportation Strategy and Control Measure

3. United States Environmental Protection Agency (U.S. EPA): Mobile Source Pollution - Environmental Justice and Transportation.23

Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program

Since the Proposed Project consists of developing a total of 199,850 sf warehouses, once the warehouses are occupied, the Proposed Project’s warehouse owners and operators will be required to comply with South Coast AQMD Rule 2305 – Warehouse Indirect Source Rule – WAIRE Program24 and Rule 316 – Fees for Rule 2305. 25 Rule 2305 and Rule 316 aim to reduce regional and local emissions of NOx and particulate matter (PM), including DPM, so as to reduce adverse public health impacts on communities located near warehouses. Rule 2305 applies to owners and operators of warehouses greater than or equal to 100,000 square feet. Under Rule 2305, operators are subject to an annual WAIRE Points Co mpliance Obligation that is calculated based on the annual number of truck trips to the warehouse. WAIRE Points can be earned by implementing actions in a prescribed menu in Rule 2305, implementing a site -specific custom plan, or paying a mitigation fee. Warehouse owners are only required to submit limited information reports, but they can opt to earn WAIRE Points on behalf of their tenants if they so choose, because certain actions to reduce emissions may be better achieved at the warehouse development phase, for instance, the installation of solar and charging infrastructure. Rule 316 is a companion fee rule for Rule 2305 to allow South Coast AQMD to recover costs associated with Rule 2305 compliance activities.

Therefore, the Lead Agency is recommende d to review Rule 2305 to determine the potential WAIRE Points Compliance Obligation for future operators and explore whether additional project requirements, design features/enhancements, and CEQA mitigation measures can be identified and implemented at th e Proposed Project that may help future warehouse operators meet their compliance obligation. For questions concerning Rule 2305 implementation and compliance, please call (909) 396-3140 or email [email protected]. For implementation of guidance documents and compliance and reporting tools, please visit South Coast AQMD’s WAIRE Program webpage.

South Coast AQMD Air Permits and Role as a Responsible Agency

According to the Draft EIR, t he Proposed Project would utilize two diesel fire pumps and two emergency generators,26 for which air permits from the South Coast AQMD will be required. The Final EIR should include a discussion about the South Coast AQMD rules that may be applicable to the Proposed Project. Those rules may include, for example, Rule 201 – Permit to Construct,27

23 United States Environmental Protection Agency (U.S. EPA), Mobile Source Pollution - Environmental Justice and Transportation available at https://www.epa.gov/mobile-source-pollution/environmental-justice-and-transportation 24 South Coast AQMD. Rule 2305 available at https://www.aqmd.gov/docs/default-source/rule-book/reg- xxiii/r2305.pdf
25 South Coast AQMD. Rule 316 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-iii/r316.pdf 26 Ibid. p. 5.3-22.
27 South Coast AQMD. Rule 201 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-ii/rule-201.pdf Candice Assadzadeh, Senior Planner August 07, 2025
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Rule 203 – Permit to Operate,28 Rule 401 – Visible Emissions,29 Rule 402 – Nuisance,30 Rule 403 – Fugitive Dust,31 Rule 461 – Gasoline Transfer and Dispensing,32 Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Engines,33 Rule 1113 – Architectural Coatings,34 Rule 1166 – Volatile Organic Compound Emissions From Decontamination of Soil,35 Regulation XIII – New Source Review,36 Rule 1401 – New Source Review of Toxic Air Contaminants ,37 Rule 1470 – Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines,38 etc.

In addition, it is important to note that since air permits from South Coast AQMD are required, South Coast AQMD’s role under CEQA is as a Responsible Agency. CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of the process for conducting a review of the Proposed Project and issuing discretionary approvals. Also, as set forth in CEQA Guidelines Section 15096(h), the Responsible Agency is required to make Findings in accordance with CEQA Guidelines Section 15091 for each significant effect of the project and issue a Statement of Overriding Considerations in accordance with CEQA Guidelines Section 15093 , if necessary.

Lastly, as set forth CEQA Guidelines Section 15096(i), the Responsible Agency may file a Notice of Determination.

CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of the process for conducting a review of the Proposed Project and issuing discretionary approvals. Moreover, it is important to note that if a Responsible Agency determines t hat a CEQA document is not adequate to rely upon for its discretionary approvals, the Responsible Agency must take further actions listed in CEQA Guideline Section 15096 (e), which could have the effect of delaying the implementation of the Proposed Project. In its role as CEQA Responsible Agency, the South Coast AQMD is obligated to ensure that the CEQA document prepared for this Proposed Project contains a sufficient project description and analysis to be relied upon in order to issue any discretionary approvals that may be needed for air permits.

For these reasons, the final CEQA document should be revised to include a discussion about any and all new stationary and portable equipment requiring South Coast AQMD air permits, provide the evaluation of their air quality and greenhouse gas impacts, and identify South Coast AQMD as a Responsible Agency for the Proposed Project as this information will be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385 for questions regarding what types

28 South Coast AQMD. Rule 203 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-ii/rule-203.pdf 29 South Coast AQMD. Rule 401 available at https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-401.pdf 30 South Coast AQMD. Rule 402 available at https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-402.pdf 31 South Coast AQMD. Rule 403 available at https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-403 32 South Coast AQMD. Rule 461 available at https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-461.pdf 33 South Coast AQMD. Rule 1110.2 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/r1110_2.pdf 34 South Coast AQMD. Rule 1113 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/r1113.pdf 35 South Coast AQMD. Rule 1166 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule- 1166.pdf
36 South Coast AQMD. Regulation XIII available at: https://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rule- book/regulation-xiii
37 South Coast AQMD. Rule 1401 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1401.pdf 38 South Coast AQMD. Rule 1470 available at https://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1470.pdf Candice Assadzadeh, Senior Planner August 07, 2025
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of equipment would require air permits. For more general information on permits, please visit South Coast AQMD’s webpage at https://www.aqmd.gov/home/permits.

Conclusion

As set forth in Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a- b), the Lead Agency shall evaluate comments from public agencies on the environmental issues and prepare a written response at least 10 days prior to certifying th e Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c), if the Lead Agency’s positi on is at variance with recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.

Thank you for the opportunity to provide comments . South Coast AQMD staff are available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact Danica Nguyen, Air Quality Specialist, at [email protected] should you have any questions.

Sincerely,
Sam Wang
Sam Wang
Program Supervisor, CEQA IGR
Planning, Rule Development & Implementation

SW:DN
RVC250625-03
Control Number
CAUTION: This email originated from outside the City of Riverside. It was not sent by any City official or staff. Use caution when opening attachments or links.

From: Casas, Yesenia
To: Assadzadeh, Candice
Cc: Vega, Jaqueline
Subject: [EXTERNAL] PR-2024-001666
Date: Monday, July 21, 2025 12:13:16 PM
Attachments: Outlook-pzpkutrf.png
SLAS14AD4M25072111140.pdf
ALUC application 5-13-24.pdf
Hello,
Thank you for transmitting the above referenced project to ALUC for review. Please note that the proposed project is located within zone E of March Air Reserve airport influence area, and although the city of Riverside is consistent with the compatibility plan for the March Airport Land Use Compatibility Plan, review by the ALUC is still required because the project proposes a legislative actions (Change of Zone).

Attached is an application, please contact ALUC planner Jackie Vega cc'd here for any questions regarding your application.

Best regards,
Yesenia Casas
Executive Assistant I

Confidentiality Disclaimer
This email is confidential and intended solely for the use of the individual(s) to whom it is addressed. The information contained in this message may be privileged and confidential and protected from disclosure.

If you are not the author's intended recipient, be advised that you have received this email in error and that any use, dissemination, forwarding, printing, or copying of this email is strictly prohibited. If you have received this email in error please delete all copies, both electronic and printed, and contact the author immediately.

County of Riverside California
1 Sierra Club – San Gorgonio Chapter – Box Springs Group R-NOW – Riverside Neighbors Opposing Warehouses

SENT VIA EMAIL
August 11, 2025

Candice Assadzadeh – Senior Planner
Donesia Gause – City Clerk
City of Riverside
Email: [email protected]; [email protected]

RE: Public comment for the Massachusetts Point Project, SCH# 2024120391 - DEIR

Dear City of Riverside Planning Staff,

Thank you for the opportunity to provide comments on the Draft Environmental Impact Report (DEIR) for the Massachusetts Point Project (‘The Project’), SCH # 2024120391.

The Project aims to demolish an existing building to develop two ~99,900 sq.ft. warehouses on the property adjacent to Roberta Street and Kansas Avenue in the Hunter Industrial Park neighborhood of Riverside. The community census tract 06065030502 on which the project occurs is in the 99th percentile for cumulative impact score in CalEnviroScreen4.0- it is literally a top 1% Environmental Justice (EJ) neighborhood in the state.1 The project is within an industrial zone, adjacent to a Homeless Service Campus, and is within an employment emphasis and housing emphasis overlay subdistrict. The project requires an overlay zone change to industrial emphasis subdistrict, a development agreement, design review, and an EIR.

In our review, the Sierra Club Box Springs Group and R-NOW appreciate that this project is an industrial infill project and therefore has lower potential impacts than projects that are greenfield development. However, we remain concerned that project objectives and analysis are biased towards an industrial warehouse project that is incompatible with the overlay zone goals, local and regional air quality, and perpetuate a legacy of industrial harm to this community.

1. Environmental Justice was not included as its own topic area to be analyzed as an environmental impact in the draft EIR, despite the community status as a 99th percentile community in CalEnviroScreen4.0 and similar designation in the General Plan EJ element.

Our NOP comment letter and the California Department of Justice asked for an analysis relative to the Warehouse Best Practice Document. Environmental Justice was instead

1 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40

2 treated as a piecemeal set of objectives and best practices do not appear to addressed substantively in the DEIR. Additionally, please compare the project to the Office of the Attorney General’s Warehouse Projects: Best Practices document2.

2. The Cumulative Impacts Project list omitted tens of millions of square feet of regional warehouses that are approved and under environmental review that were submitted as part of our comment letter on the project. This project’s impacts are not limited to a 2-mile radius of the project. There are over 4,000 warehouses already in the Inland Empire with over 1,000 in Riverside County. There are 13,000 acres of warehouses approved or under environmental review. The Cumulative Impacts of these projects are not limited to the local streets of the neighborhood in which they are located, as indicated by the scope of the air quality, greenhouse gas, jobs, and other analyses. Please include a more comprehensive analysis of the regional impacts of warehouses on transportation, jobs, air quality, and greenhouse gas emissions. Here is a partial list of warehouse projects that are nearby to include. a. World Logistics Center – 40.4M square feet – Approved – Moreno Valley b. Bloomington Business Park – 2.4M square feet – Approved – San Bernardino County c. West Valley Logistics Center – 2.1M - Fontana
d. Sycamore Hills Distribution Center – 600,000 sq. ft. - Riverside e. Moreno Valley Business Park Building 5 – 425,000 sq.ft. – Moreno Valley f. Harvest Landing Retail Project – 5.7M square ft. – Perris g. Beaumont Pointe – 5.0M square ft. – Beaumont
h. The District at Jurupa Valley – 1.5M sq. ft. – Jurupa Valley i. Agua Mansa Logistics Center – 1.2M sq.ft. – Colton
j. Merwin Property Project – 1.0M sq.ft. -Moreno Valley k. Crystal Windows HQ project – 400,000 sq.ft. – Moreno Valley l. All the projects along Old 215
i. Old 215 Business Park
ii. Cottonwood and Edgemont Project
iii. Bay & Day Commerce Center
iv. Old 215 Industrial Park Project
v. Moreno Valley Business Center Project
vi. First Industrial Warehouse at Day Street Project

3. The Project land-use analysis handwaves away the problems of the overlay zone. The site is within the Employment and Housing Emphasis overlay zones. The problem with ignoring this overlay zone is that adjacent land-uses in these overlay zones become less probable as the industrial zone expands and erodes the adjacent land-use compatibility. Warehouses and industrial uses beget warehouses and industrial uses; people don’t want to live next to these land uses. The project undermines the existing overlay zone and plan; it is less likely that the overlay zone will ever be implemented if the first project approved in the overlay zone is nonconforming.

4. While the City of Riverside Good Neighbor Policy does not preclude housing near industrial zones, it does preclude building warehouses within certain setbacks of residential zoning.

Current proposed guidelines would also add a cumulative impact standard that might impact

2 https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf 3 the suitability of the parcel splitting shenanigans involved in keeping the two buildings in this project just below the 100,000 square foot threshold3.

5. Table 5.14-6 indicates that the City of Riverside is jobs-rich, with more than the 1.5 jobs per dwelling unit considered housing-rich. There is no indication that the City of Riverside is on-track to add 43,000+ units. In the last 4 years, the City has added just over 600 constructed units per year4. At the current pace of construction, the City will add about 15,000 units by 2050. Thus, the 2050 projections in Connect SoCal 2024 are aspirational and not based on actual trends in unit construction of over 20,000 units. The assertion that this area needs more warehouse jobs is absurd and unsupported in the present. The City of Riverside is not jobs-poor and certainly doesn’t need more low-density warehouse jobs when that is the largest sector of employment in the region.

Summary
Thank you again for the opportunity to provide comments on the Project. Please keep the Sierra Club Box Springs Group and R-NOW notified of all documents and meetings related to the Massachusetts Point Project.

Sincerely,

Michael McCarthy, PhD
Sierra Club - Box Springs Group - Co-Conservation Chair R-NOW – Vice-Chair
Email: [email protected]

P.O. Box 1325
Moreno Valley, CA 92556-1325

3 https://riversideca.legistar.com/LegislationDetail.aspx?ID=7508406&GUID=3590D12D -A435-43D3-BB52- 8D292F48AAEB&Options=&Search=
4 https://www.hcd.ca.gov/planning-and-community-development/housing-element-implementation-and-apr- dashboard
Exhibit 13 - Draft Environmental Impact Report –

Available on the City’s Website:
https://riversideca.gov/cedd/planning/development-projects-and-ceqa-documents

Massachusetts Point Project
Final EIR
Prepared For
City of
Riverside
November 2025
Massachusetts Point Project
Final EIR
Prepared For
City of
Riverside
November 2025
Massachusetts Point Project 1. Executive Summary
City of Riverside 1-1
Final EIR
October 2025

1. Introduction
This Final Environmental Impact Report (Final EIR) has been prepared in conformance with the environmental policy guidelines for the implementation of the California Environmental Quality Act (CEQA) to evaluate the environmental effects that may result from construction and operation of the proposed Massachusetts Point Project (proposed Project).

According to CEQA Guidelines Section 15132, the Final EIR shall consist of:
(a) The Draft Environmental Impact Report (Draft EIR) or a revision of the Draft EIR; (b) Comments and recommendations received on the Draft EIR, either verbatim or in summary; (c) A list of persons, organizations, and public agencies commenting on the Draft EIR; (d) The responses of the lead agency to significant environmental points raised in the review and consultation process;
(e) Any other information added by the lead agency.

This document contains responses to comments received on the Draft EIR during the public review period, which began June 26, 2025, and ended on August 11, 2025. A Notice of Availability of the Draft EIR was published concurrently with distribution of the Draft EIR. This document has been prepared in accordance with CEQA, the State CEQA Guidelines, and represents the independent judgment of the lead agency, which is the City of Riverside. This document and the circulated Draft EIR comprise the Final EIR in accordance with CEQA Guidelines, Section 15132.

1.1 FORMAT OF THE FINAL EIR
The following chapters are contained within this document:

Section 1.0, Introduction. This section describes CEQA requirements and the content of the Final EIR.

Section 2.0, Revisions to the Draft EIR. This section contains revisions made to the Draft EIR as a result of the comments received by agencies and organizations as described in Section 2.0, and/or errors and omissions discovered since release of the Draft EIR for public review.

The City of Riverside has determined that none of this material constitutes significant new information that requires recirculation of the Draft EIR for further public comment under CEQA Guidelines Section 15088.5.

The additional material clarifies existing information prepare d in the Draft EIR and does not present any new substantive information. None of this new material indicates that the Project would result in a significant new environmental impact not previously disclosed in the Draft EIR. Additionall y, none of this material indicates that there would be a substantial increase in the severity of a previously identified environmental impact that would not be mitigated, or that there would be any of the other circumstances requiring recirculation described in Section 15088.5.

Section 3.0, Response to Comments. This section provides a list of agencies and organizations who commented on the Draft EIR, as well as copies of their comment letters received during and following the public review period, and individual responses to their comments.

Section 4.0, Mitigation, Monitoring, and Reporting Program. This chapter includes the Mitigation Monitoring and Reporting Program (MMRP). CEQA requires lead agencies to “adopt a reporting and mitigation monitoring program for the changes to the project which it has adopted or made a condition of Massachusetts Point Project 1. Executive Summary
City of Riverside 1-2
Final EIR
October 2025
project approval in order to mitigate or avoid significant effects on the environment” (CEQA Section 21081.6, CEQA Guidelines Section 15097). The MMRP was prepared based on the mitigation measures included in the Draft EIR and finalized in this Final EIR.

1.2 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be “ on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible … CEQA does not require a lead agency to conduct every test or perform all resea rch, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.” CEQA Guidelines Section 15204(c) further advises, “ Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall n ot be considered significant in the absence of substantial evidence.” Section 15204(d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 15204(e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.”
In accordance with Public Resources Code (PRC) Section 21092.5, copies of the written responses to public agencies are being forwarded to those agencies at least 10 days prior to certification of the Final EIR, with copies of this Final EIR document, which conforms to the legal standards established for response to comments on the Draft EIR pursuant to CEQA.

Massachusetts Point Project 2. Errata
City of Riverside 2-1
Final EIR
October 2025

2. Errata

2.1 INTRODUCTION
As provided in Section 15088(c) of the CEQA Guidelines, responses to comments may take the form of a revision to a Draft EIR or may be a separate section in the Final EIR. This section complies with the latter option and provides changes to the Draft EIR s hown as strikethrough text (i.e., strikethrough) signifying deletions and red bold text (i.e., bold) signifying additions. These changes are meant to provide clarification, corrections, or minor revisions made to the Draft EIR initiated by the Lead Agency, City of Riverside, reviewing agencies, the public, and/or consultants based on their review. Text changes are presented in the section and page order in which they appear in the Draft EIR. None of the corrections or additions constitute significant new information or substantial project changes that, in accordance with CEQA Guidelines Section 15088.5, would trigger the need to recirculate portions of or all of the Draft EIR.

2.2 CHANGES TO THE DRAFT ENVIRONMENTAL IMPACT REPORT

2.2.1 Section 1.0 Executive Summary
Location: Page 1-22, Section 1.5, Summary of Impacts, is revised as follows:

Explanation for Change and Discussion: Revised table for consistency with threshold analysis.

Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation

5.3 Air Quality
Threshold B: Would
the Project 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?
PPP AQ -1: Rule 403.

The Project is required
to comply with the
provisions of South
Coast Air Quality
Management District
(SCAQMD) Rule 403,
which includes the
following:
• All clearing,
grading, earth -
moving, or
excavation
activities shall
cease when winds
exceed 25 mph
per SCAQMD
guidelines in order
to limit fugitive
dust emissions.
• The contractor
shall ensure that
all disturbed
unpaved roads
Less than
significant
None required Less than
significant
Massachusetts Point Project 2. Errata
City of Riverside 2-2
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October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
and disturbed
areas within the
project are
watered, with
complete
coverage of
disturbed areas,
at least 3 times
daily during dry
weather;
preferably in the
mid-morning,
afternoon, and
after work is done
for the day.
• The contractor
shall ensure that
traffic speeds on
unpaved roads
and project site
areas are reduced
to 15 miles per
hour or less.

PPP AQ-2: Rule 1113.

The Project is required
to comply with the
provisions of SCAQMD
Rule 1113. Only “Low-
Volatile Organic
Compounds” paints (no
more than 50
gram/liter of VOC)
and/or High Pressure
Low Volume (HPLV)
applications shall be
used.

Threshold C: Would
the Project expose
sensitive receptors
to substantial
pollutant
concentrations?
PPP AQ-3: Rule 1470.

The Project is required
to obtain permits from
SCAQMD for the
proposed diesel fire
pumps and emergency
generators and would
be required to comply
with Rule 1470,
regulating the use of
diesel-fueled internal
combustion engines.

PDF AQ-3: The Project
would be designed to
include the
installation of signs at
Less than
significant
None required Less than
significant
Massachusetts Point Project 2. Errata
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October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
every truck exit
providing directional
information to the
trucks’ routes. This
design feature would
prevent nearby
sensitive receptors
from further exposure
to criteria pollutants
during the operation
of the Project. No
quantitative credit
was taken in the air
quality analysis for
this design feature.

PDF AQ-4: The Project
would have a truck
check-in point inside
of the Project site,
consistent with best
practices for siting
and designing
warehouse facilities.

This design feature
would help manage
truck circulation on-
site and reduce idling
on surroundi ng
roadways, thereby
minimizing
operational exposure
of nearby sensitive
receptors to criteria
pollutants. No
quantitative credit
was taken in the air
quality analysis for
this design feature.

PDF AQ-5: The Project
would be designed to
provide overnight
truck parking inside of
the Project site. This
design feature would
encourage trucks to
not park overnight
near sensitive
receptors and prevent
further exposure to
criteria pollutants
during the operation
of the Project. No
quantitative credit
Massachusetts Point Project 2. Errata
City of Riverside 2-4
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
was taken in the air
quality analysis for
this design feature.

Threshold D:

Would the Project
result in other
emissions (such as
those leading to
odors) adversely
affecting a
substantial number
of people?
PPP AQ -4: Rule 402.

The Project is required
to comply with the
provisions of SCAQMD
Rule 402. The Project
shall not discharge
from any source
whatsoever such
quantities of air
contaminants or other
material which cause
injury, detriment,
nuisance, or annoyance
to any considerable
number of persons or
to the public, or which
endanger the comfort,
repose, health or
safety of any such
persons or the public,
or which cause, or have
a natural tendency to
cause, injury or
damage to business or
property.

PDF AQ-1: The Project
would use light -
colored paving and
roofing materials.

This design feature
would reduce heat
absorption, thereby
lowering cooling
demands and
associated energy
use, which in turn
would reduce
operational air quality
impacts. No
quantitative credit
was taken in the air
quality analysis for
this design feature.

PDF AQ-2: The Project
would use Energy Star
heating, cooling, and
lighting devices and
appliances. This
design feature would
increase energy
Less than
significant
None required Less than
significant
Massachusetts Point Project 2. Errata
City of Riverside 2-5
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
efficiency and reduce
electricity demand,
which in turn would
reduce operational air
quality impacts. No
quantitative credit
was taken in the air
quality analysis for
this design feature.

Cumulative PPP AQ -1: As listed
previously
PPP AQ -2: As listed
previously
PPP AQ-3: As listed
previously
PPP AQ-4: As listed
previously
PDF AQ -1: As listed
previously
PDF AQ -2: As listed
previously
PDF AQ -3: As listed
previously
PDF AQ -4: As listed
previously
PDF AQ -5: As listed
previously
Less than
significant
None required Less than
significant

5.5 Cultural Resources
Threshold C: Would
the Project disturb
any human remains,
including those
interred outside of
formal cemeteries?
PPP CUL -1: Human
Remains. If human
remains are found on
this site, the
developer/permit
holder or any successor
in interest shall comply
with State Health and
Safety Code Section
7050.5. Pursuant to
State Health and
Safety Code Section
7050.5, if human
remains are
encountered, no further
disturbance shall occur
until the San
Bernardino County
Coroner has made the
necessary findings as
to origin. Further,
pursuant to Public
Resources Code
Less than
significant
None required Less than
significant
Massachusetts Point Project 2. Errata
City of Riverside 2-6
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
Section 5097.98 (b),
remains shall be left in
place and free from
disturbance until a final
decision as to the
treatment and their
disposition has been
made. If the San
Bernardino County
Coroner determines the
remains to be Native
American, the Native
American Heritage
Commission shall be
contacted by the
Coroner within the
period specified by
law (24 hours).

Subsequently, the
Native American
Heritage Commission
shall identify the “Most
Likely Descendant.”
The Most Likely
Descendant shall then
make
recommendations and
engage in consultation
with the property
owner concerning the
treatment of the
remains as provided in
Public Resources Code
Section 5097.98.

Discovery of Human
Remains: In the event
that human remains
(or remains that may
be human) are
discovered at the
Project site during
grading or
earthmoving, the
construction
contractors, Project
Archaeologist, and/or
designated Native
American Monitor
shall immediately
stop all activities
within 100 feet of the
find. The Project
proponent shall then
Massachusetts Point Project 2. Errata
City of Riverside 2-7
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
inform the Riverside
County Coroner and
the City of Riverside
Community &
Economic
Development
Department
immediately, and the
coroner shall be
permitted to examine
the remains as
required by California
Health and Safety
Code Section
7050.5(b) unless
more current State law
requirements are in
effect at the time of
the discovery. Section
7050.5 requires that
excavation be
stopped in the vicinity
of discovered human
remains until the
coroner can determine
whether the remains
are those of a Native
American. If human
remains are
determined as those
of Native American
origin, the Applicant
shall comply with the
state relating to the
disposition of Native
American burials that
fall within the
jurisdiction of the
NAHC (PRC Section
5097). The coroner
shall contact the
NAHC to determine
the most likely
descendant(s). The
MLD shall complete
his or her inspection
and make
recommendations or
preferences for
treatment within 48
hours of being
granted access to the
site. The Disposition
of the remains shall
Massachusetts Point Project 2. Errata
City of Riverside 2-8
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
be overseen by the
most likely
descendant(s) to
determine the most
appropriate means of
treating the human
remains and any
associated grave
artifacts.

The specific locations
of Native American
burials and reburials
will be proprietary
and not disclosed to
the general public.

The County Coroner
will notify the Native
American Heritage
Commission in
accordance with
California Public
Resources Code
5097.98.

According to
California Health and
Safety Code, six or
more human burials
at one location
constitute a cemetery
(Section 8100), and
disturbance of Native
American cemeteries
is a felony (Section
7052) determined in
consultation between
the Project proponent
and the MLD. In the
event that the Project
proponent and the
MLD are in
disagreement
regarding the
disposition of the
remains, State law
will apply and the
median and decision
process will occur
with the NAHC (see
Public Resources
Code Section
5097.98(e) and
5097.94(k)).

Massachusetts Point Project 2. Errata
City of Riverside 2-9
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation

5.9 Hazards and Hazardous Materials
Threshold A:

Would the Project
create a significant
hazard to the public
or the environment
through the routine
transport, use, or
disposal of
hazardous
materials?
PPP HYD -1:

NPDES/SWPPP. Prior
to issuance of any
grading permits, the
applicant shall provide
the City Public Works
Department with
evidence of
compliance with the
NPDES (National
Pollutant Discharge
Elimination System)
requirement to obtain
a construction permit
from the State Water
Resource Control
Board (SWRCB). The
Project
applicant/proponent
shall comply by
submitting a Notice of
Intent (NOI) and by
developing and
implementing a
Stormwater Pollution
Prevention Plan
(SWPPP) and a
monitoring program
and reporting plan for
the construction site.

PPP HAZ-1: SCAQMD
Rule 1166. Prior to
issuance of grading or
excavation permits, the
Project applicant shall
submit verification to
the City Building and
Safety Division that it
has applied for and
obtained a SCAQMD
Rule 1166
Contaminated Soil
Mitigation Plan that
includes but is not
limited to the following,
as required by
SCAQMD: Monitor for
VOC contamination at
least once every 15
minutes commencing at
the beginning of
Potentially
significant.

Mitigation Measure HAZ-
1: SARWQCB
Concurrence. Prior to the
issuance of a grading
permit or the
commencement of any
ground-disturbing
activities, the City of
Riverside shall obtain
SARWQCB concurrence
with proposed mitigation
measures and project
design features directly
related to environmental
conditions regulated by this
agency to ensure
compliance with applicable
regulatory requirements.

No grading or construction
activities shall begin until
written confirmation of
regulatory concurrence has
been received and verified
by the City.

Mitigation Measure HAZ-
2: Prior to issuance of a
grading or excavation
permit a SMP shall be
approved by the Santa
Ana Regional Water
Quality Control Board.

The SMP will describe
general methods for the
identification and
management of soils
potentially impacted by
VOCs Site-wide. In areas
where VOCs are suspected
to potentially be present in
soil (i.e., in the vicinity of
areas previously identified
on the North Parcel and
any other areas in which
potential VOC impacted
soils are otherwise
identified), earth working
activities will be conducted
by a contractor with a
current SCAQMD Rule
1166 Various Locations
Less than
significant.

Massachusetts Point Project 2. Errata
City of Riverside 2-10
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
excavation or grading
and record all VOC
concentration readings.

Handling VOC-
contaminated soil at or
from an excavation or
grading site shall
segregate VOC -
contaminated
stockpiles from non -
VOC contaminated
stockpiles such that
mixing of the stockpiles
doe
s not take place.

VOC-contaminated soil
stockpiles shall be
sprayed with water
and/or approved
vapor suppressant and
covered
with plastic
sheeting for all periods
of inactivity lasting
more than one hour. A
daily visual inspection
shall be conducted of
all covered VOC
contaminated soil
stockpiles to ensure the
integrity of the plastic
covered surfaces.

Contaminated soil shall
be treated or removed
from an excavation or
grading site within 30
days from the time of
excavation.

Plan, and the SMP will
describe the methods to
identify, manage, and
dispose of “VOC
Contaminated Soil” as
defined in Rule 1166 (i.e.,
soils emitting VOCs at
concentrations greater than
50 parts per million [ppm]
as hexane). The SMP will
also describe more
conservative monitoring
criteria and thresholds for
targeted excavation of
soils in suspected historical
VOC release areas on the
North Parcel (and
potentially other locations
in the event that a
previously unidentified
VOC or petroleum
hydrocarbon release area
is discovered during earth
working activities).

Per SCAQMD Rule 1166,
the SMP shall include
protocols for minimizing
VOC emissions into the
atmosphere during
construction, including
excavation, grading,
handling, and treatment of
VOC-impacted soils, and
shall describe associated
notification requirements,
monitoring requirements,
soil handling protocols, and
recordkeeping
requirements. In the event
that “VOC-contaminated
soil” is identified as
defined within Rule 1166,
the soil shall be handled in
accordance with the Rule
and the associated Various
Locations Plan. A project-
specific Health and Safety
Plan (HASP) shall also be
prepared in accordance
with California
Occupational Safety and
Health Administration
(OSHA) standards and
Massachusetts Point Project 2. Errata
City of Riverside 2-11
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
other applicable rules and
regulations, which will
incorporate appropriate
health and safety
precautions to be
implemented to protect
workers and the public
from exposure to
potentially hazardous
substances that may be
encountered during these
earth working activities.

Mitigation Measure HAZ-
3: Health and Safety Plan
(HSP). Prior to ground-
disturbing activities,
including grading,
trenching, excavation, or
structure demolition, a HSP
shall be approved by the
City of Riverside Fire
Department as the
Certified Unified Program
Agency (CUPA), with
responsibility for
implementing federal and
State laws and regulations
pertaining to hazardous
materials management. The
Project Applicant and/or
the construction
contractor(s) shall retain a
qualified professional to
prepare a site-specific HSP
in accordance with federal
Occupational Safety and
Health Administration
(OSHA) regulations (29
CFR 1910.120) and
California OSHA
regulations (8 CCR Section
5192). HSPs shall be a
condition of the well
abandonment, grading,
construction, and/or
demolition permit(s). The
HSP shall be implemented
by the construction
contractor to protect
construction workers, the
public, and the environment
during all ground-
Massachusetts Point Project 2. Errata
City of Riverside 2-12
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
disturbing activities from
exposure to hazardous
materials, including vapor
and soil contamination.

Mitigation Measure HAZ-
1: Soil Management Plan
(SMP) and Health and
Safety Plan (HSP). Prior to
issuance of a grading or
excavation permit a SMP
shall be approved by the
Santa Ana Regional Water
Quality Control Board.

The SMP will describe
general methods for the
identification and
management of soils
potentially impacted by
VOCs Site-wide. In areas
where VOCs are
suspected to potentially
be present in soil (i.e., in
the vicinity of areas
previously identified on
the North Parcel and any
other areas in which
potential VOC impacted
soils are otherwise
identified), earth working
activities will be
conducted by a contractor
with a current SCAQMD
Rule 1166 Various
Locations Plan, and the
SMP will describe the
methods to identify,
manage, and dispose of
“VOC Contaminated Soil”
as defined in Rule 1166
(i.e., soils emitting VOCs
at concentrations greater
than 50 parts per million
[ppm] as hexane). The
SMP will also describe
more conservative
monitoring criteria and
thresholds for targeted
excavation of soils in
suspected historical VOC
release areas on the
North Parcel (and
potentially other locations
in the event that a
Massachusetts Point Project 2. Errata
City of Riverside 2-13
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
previously unidentified
VOC or petroleum
hydrocarbon release area
is discovered during earth
working activities).

Per SCAQMD Rule 1166,
the SMP shall include
protocols for minimizing
VOC emissions into the
atmosphere during
construction, including
excavation, grading,
handling, and treatment
of VOC-impacted soils,
and shall describe
associated notification
requirements, monitoring
requirements, soil
handling protocols, and
recordkeeping
requirements. In the event
that “VOC-contaminated
soil” is identified as
defined within Rule 1166,
the soil shall be handled
in accordance with the
Rule and the associated
Various Locations Plan. A
project-specific Health
and Safety Plan (HASP)
shall also be prepared in
accordance with
California Occupational
Safety and Health
Administration (OSHA)
standards and other
applicable rules and
regulations, which will
incorporate appropriate
health and safety
precautions to be
implemented to protect
workers and the public
from exposure to
potentially hazardous
substances that may be
encountered during these
earth working activities.

As part of the SMP, the
Project Applicant and/or
the construction
contractor(s) shall retain a
qualified professional to
Massachusetts Point Project 2. Errata
City of Riverside 2-14
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
prepare a site-specific
HSP in accordance with
federal Occupational
Safety and Health
Administration (OSHA)
regulations (29 CFR
1910.120) and California
OSHA regulations (8 CCR
Section 5192). The HSP
shall be implemented by
the construction contractor
to protect construction
workers, the public, and
the environment during
all ground-disturbing
activities from exposure
to hazardous materials,
including vapor and soil
contamination.

Threshold B: Would
the Project create a
significant hazard to
the public or the
environment through
reasonably
foreseeable upset
and accident
conditions involving
the release of
hazardous materials
into the
environment?
PPP HAZ-1: As listed
previously.

PDF HAZ-1: Vapor
Intrusion Mitigation
System (VIMS). A
Vapor Intrusion
Mitigation System
(VIMS) shall be
incorporated into the
Project design to
prevent potential
vapor intrusion risks.

Less than
significant
Potentially
significant
None required
Mitigation Measure HAZ -
1: Soil Management Plan
(SMP) and Health and
Safety Plan (HSP). As
listed previously.

Less than
significant
Threshold C: Would
the Project emit
hazardous emissions
or handle
hazardous or
acutely hazardous
materials,
substances, or waste
within one -quarter
mile of an existing
or proposed school?
No impact None required No impact
Threshold D:

Would the Project
be located on a site
which is included on
a list of hazardous
materials sites
compiled pursuant
to Government
Code §65962.5
Less than
significant
None required Less than
significant
Massachusetts Point Project 2. Errata
City of Riverside 2-15
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
and, as a result,
create a significant
hazard to the public
or the environment?
Threshold E: For a
project located
within an airport
land use plan or,
where such a plan
has not been
adopted, within two
miles of a public
airport or public use
airport, would the
Project result in a
safety hazard or
excessive noise for
people residing or
working in the
Project area?
Potentially
significant
Mitigation Measure HAZ-
4 HAZ-2: Outdoor
lighting. Any new outdoor
lighting that is installed
shall be hooded or
shielded so as to prevent
either the spillage of
lumens or reflection into the
sky. Outdoor lighting shall
be downward facing.

Mitigation Measure HAZ-
5 HAZ-3: Prohibited
Uses/Activities. The
following uses/activities
are not included in the
proposed project and shall
be prohibited at this site:

1. Any use which would
direct a steady light or
flashing light of red,
white, green, or amber
colors associated with
airport operations
toward an aircraft
engaged in an initial
straight climb
following takeoff or
toward an aircraft
engaged in a straight
final approach toward
a landing at an
airport, other than an
FAA-approved
navigational signal
light or visual
approach slope
indicator.

2. Any use which would
cause sunlight to be
reflected towards an
aircraft engaged in an
initial straight climb
following takeoff or
towards an aircraft
engaged in a straight
final approach
Less than
significant
Massachusetts Point Project 2. Errata
City of Riverside 2-16
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
towards a landing at
an airport.

3. Any use which would
generate smoke or
water vapor or which
would attract large
concentrations of
birds, or which may
otherwise affect safe
air navigation within
the area. (Such uses
include landscaping
utilizing water
features, aquaculture,
outdoor production of
cereal grains,
sunflower, and row
crops, composting
operations,
wastewater
management facilities,
artificial marshes,
trash transfer stations
that are open on one
or more sides,
recycling centers
containing putrescible
wastes, construction
and demolition debris
facilities, fly ash
disposal, and
incinerators.

4. Any use which would
generate electrical
interference that may
be detrimental to the
operation of aircraft
and/or aircraft
instrumentation.

5. Highly noise-sensitive
outdoor nonresidential
uses.

6.5. Any use which results
in a hazard to flight.,
including physical (e.g., tall
objects), visual, and
electronic forms of
interference with the safety
of aircraft operations

Mitigation Measure HAZ-
6 HAZ-4: Notice of
Massachusetts Point Project 2. Errata
City of Riverside 2-17
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
Airport in Vicinity. The
“Notice of Airport in
Vicinity” shall be provided
to all prospective
purchasers and occupants
of the property.

Mitigation Measure HAZ-
7: Stormwater Basin Design
and Airport Compatibility.

Any proposed stormwater
basins or facilities shall be
designed and maintained
to provide for a maximum
48-hour detention period
following the design storm,
and remain totally dry
between rainfalls.

Vegetation in and around
the stormwater basins that
would provide food or
cover for birds is
incompatible with airport
operations and shall not be
utilized in project
landscaping. Trees shall be
spaced so as to prevent
large expanses of
contiguous canopy, when
mature. Landscaping in
and around the stormwater
basin(s) shall not include
trees or shrubs that
produce seeds, fruits, or
berries.

Landscaping in the
stormwater basin, if not
rip-rap, shall be in
accordance with the
guidance provided in
ALUC “LANDSCAPING
NEAR AIRPORTS” brochure,
and the “AIRPORTS,

WILDLIFE AND

STORMWATER
MANAGEMENT” brochure
available at RCALUC.ORG
which list acceptable plants
from Riverside County
Landscaping Guide or
other alternative
landscaping as may be
recommended by a
Massachusetts Point Project 2. Errata
City of Riverside 2-18
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
qualified wildlife hazard
biologist.

A notice sign shall be
permanently affixed to the
stormwater basin with the
following language: “There
is an airport nearby. This
stormwater basin is
designed to hold
stormwater for only 48
hours and not attract birds.

Proper maintenance is
necessary to avoid bird
strikes”. The sign shall also
include the name,
telephone number or other
contact information of the
person or entity
responsible to monitor the
stormwater basin.

Mitigation Measure HAZ-
5: Electromagnetic
Component Notification.

March Air Reserve Base
shall be notified of any
land use having
electromagnetic radiation.

Sources of
electromagnetic radiation
include radio wave
transmission in
conjunction with remote
equipment inclusive of
irrigation controllers,
access gates, etc.

Threshold F: Would
the Project impair
implementation of
or physically
interfere with an
adopted emergency
response plan or
emergency
evacuation plan?
No impact None required Less than
significant
No impact
Threshold G:

Would the Project
expose people or
structures, either
directly or
indirectly, to a
significant risk of
loss, injury, or death
No impact None required No impact
Massachusetts Point Project 2. Errata
City of Riverside 2-19
Final EIR
October 2025
Impact
Applicable Standard
Condition, Plan,
Program, or Policy
(PPP), or Project
Design Feature (PDF)
Level of
Significance
Before
Mitigation
Mitigation Measures
Level of
Significance
After
Mitigation
involving wildland
fires?
Cumulative PPP HAZ-2: As listed
previously
PPP HYD-1: As listed
previously
Potentially
significant
Mitigation Measure HAZ-
1: As listed previously.

Mitigation Measure HAZ-
2: As listed previously.

Mitigation Measure HAZ-
3: As listed previously.

Mitigation Measure HAZ-
4: As listed previously.

Mitigation Measure HAZ-
5: As listed previously.

Mitigation Measure HAZ-
6: As listed previously.

Less than
significant

5.12 Mineral Resources
Threshold A: Would
the Project result in
the loss of
availability of a
known mineral
resource that would
be of value to the
region and the
residents of the
state?
No impact
Less than
significant
None required No impact
Less than
significant

2.2.2 Section 3.0, Project Description
Location: Page 3-45, Section 3.3.8, Construction, is revised as follows:

Explanation for Change and Discussion: Revised export values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Project development is estimated to take approximately 14 months, beginning April 2026 and concluding June 2027. Construction activities for the Project would occur over one phase and include demolition and removal of existing structures, foundations, asphalt/pavement, utilities, and other subsurface improvements; site preparation, which includes clearing any remaining infrastructure, utilities, and trenching for the new utilities and services; grading and excavation; building construction; and landscape installation, paving, and application of architectural coatings. Grading work of soils is expected to result in cut of 15,065 cubic yards (CY) and fill of 24,108 CY of soils for a net import of 9,043 CY. Additionally, the site preparation phase is assumed to result in a maximum export of 500 CY of potentially contaminated soil and the demolition phase is anticipated to result in an export of 24,092 tons of debris.

Location: Page 3-46, Section 3.5, Discretionary Approvals and Permits, is revised as follows:

Explanation for Change and Discussion: Added applicable responsible agencies for reference.

Massachusetts Point Project 2. Errata
City of Riverside 2-20
Final EIR
October 2025
The City of Riverside is expected to use the information contained in this EIR for consideration of approvals related to and involved in the implementation of this Project. These include, but may not be limited to, the permits and approvals described below.
• Zoning Code (Map/Text) Amendment
• Development Agreement
• Tentative Parcel Map
• Design Review
• Certification of the Environmental Impact Report
• Approvals and permits necessary to execute the proposed Project, including but not limited to grading permit, building permit, etc.
• In addition, the Project is subject to review and approval by the Riverside Airport Land Use Commission (ALUC) for the Zoning Code Map and text amendments.

The Following approvals are anticipated from responsible agencies:
• Riverside Airport Land Use Commission (ALUC) approval of Project’s proposed Zoning Code Map and text amendments.
• SCAQMD approval and issuance of permits for installation and operation of backup generators and fire pumps as well as compliance with all applicable regulatory requirements related to air quality and toxic air contaminates.

2.2.3 Section 5.3, Air Quality
Location: Page 5.3-8, Section 5.3.2.3, Regional Regulations, is revised as follows:

Explanation for Change and Discussion: Revised to include additional SCAQMD Rules and Regulations included per response to comment letter A1.

SCAQMD Rules and Regulations
All projects are subject to SCAQMD rules and regulations. Specific rules applicable to the Project include the following:

Rule 201- Permit to Construct. A person shall not construct, alter, or operate equipment that may cause the issuance of air contaminants without first obtaining a permit from SCAQMD. This permitting requirement ensures review of potential air quality impacts prior to equipment installation or operation.

Rule 203 – Permit to Operate. A person shall not operate or use any equipment or agricultural permit unit, the use of which may cause the issuance of air contaminants, or the use of which may reduce or control the issuance of air contaminants, without first obtaining a written permit to operate from the Executive Officer or except as provided in Rule 202. The equipment or agricultural permit unit shall not be operated contrary to the conditions specified in the permit to operate.

Rule 401 – Visible Emissions. A person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any 1 hour that is as dark or darker in shade as that designated No. 1 on the Ringelmann Chart, as published by the United States Bureau of Mines.

Rule 402 – Nuisance. A person shall not discharge from any source whatsoever such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any such Massachusetts Point Project 2. Errata
City of Riverside 2-21
Final EIR
October 2025
persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. The provisions of this rule do not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals.

Rule 403 – Fugitive Dust. SCAQMD Rule 403 governs emissions of fugitive dust during and after construction. Compliance with this rule is achieved through application of standard Best Management Practices (BMP), such as application of water or chemical stabilizers to disturbed soils, covering haul vehicles, restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping loose dirt from paved site access roadways, cessation of construction activity when winds exceed 25 mph, and establishing a perma nent ground cover on finished sites.

Rule 403 requires project applicants to control fugitive dust using the best available control measures such that dust does not remain visible in the atmosphere beyond the property line of the emission source. In addition, Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from creating an off-site nuisance. Applicable Rule 403 dust suppression (and PM10 generation) techniques to reduce impacts on nearby sensitive receptors may include, but are not limited to, the following:
• Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for 10 days or more). • Water active sites at least three times daily. Locations where grading is to occur shall be thoroughly watered prior to earthmoving.
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 0.6 meters (2 feet) of freeboard (vertical space between the top of the load and top of the trailer) in accordance with the requirements of California Vehicle Code Section 23114.
• Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less. • Suspend all grading activities when wind speeds (including instantaneous wind gusts) exceed 25 mph. • Provide bumper strips or similar best management practices where vehicles enter and exit the construction site onto paved roads or wash off trucks and any equipment leaving the site each trip. • Replant disturbed areas as soon as practical.
• Sweep on-site streets (and off-site streets if silt is carried to adjacent public thoroughfares) to reduce the amount of particulate matter on public streets. All sweepers shall be compliant with SCAQMD Rule 1186.1, Less Polluting Sweepers.

Rule 445 – Wood Burning Devices. This rule prohibits the installation of wood -burning devices in any new development and is intended to reduce particulate matter emissions from such devices. Therefore, all new development must comply with SCAQMD Rule 445.

Rule 461 – Gasoline Transfer. This rule governs the transfer of gasoline into and out of stationary storage tanks and vehicle fuel tanks within the SCAQMD. The rule requires the use of CARB certified enhanced vapor recovery systems to control VOCs emissions during gasoline transfer operations. The rule establishes equipment, operation, maintenance, testing, and recordkeeping requirements for both storage tanks and dispensing systems to ensure they are vapor- and liquid-tight.

Rule 481 – Spray Coating. This rule applies to all spray painting and spray coating operations and equipment and states that a person shall not use or operate any spray painting or spray coating equipment unless one of the following conditions is met:
• The spray coating equipment is operated inside a control enclosure, which is approved by the Executive Officer. Any control enclosure for which an application for permit for new construction, alteration, or change of ownership or location is submitted after the date of adoption of this rule shall be exhausted only through filters at a design face velocity not less than 100 feet per minute nor greater than 300 Massachusetts Point Project 2. Errata
City of Riverside 2-22
Final EIR
October 2025
feet per minute, or through a water wash system designed to be equally effective for the purpose of air pollution control.
• Coatings are applied with high-volume low-pressure, electrostatic and/or airless spray equipment. • An alternative method of coating application or control is used which has effectiveness equal to or greater than the equipment specified in the rule.

Rule 1108 - Volatile Organic Compounds. This rule governs the sale, use, and manufacturing of asphalt and limits the volatile organic compound (VOC) content in asphalt used in the Basin. This rule also regulates the VOC content of asphalt used during construction. Therefore, all asphalt used during construction of the Project must comply with SCAQMD Rule 1108.

Rule 1110.1 – Stationary Combustion Emissions. This rule governs emissions from stationary internal combustion engines and establishes emission limits for NOx, VOCs, and CO. This rule requires monitoring and testing to demonstrate compliance.

Rule 1113 – Architectural Coatings. No person shall apply or solicit the application of any architectural coating within the SCAQMD with VOC content in excess of the values specified in a table incorporated in the Rule.

Rule 1143 – Paint Thinners and Solvents. This rule governs the manufacture, sale, and use of paint thinners and solvents used in thinning of coating materials, cleaning of coating application equipment, and other solvent cleaning operations by limiting their VOC content. This rule regulates the VOC content of solvents used during construction. Solvents used during the construction phase must comply with this rule.

Rule 1166 – VOC Emissions from Soil Excavation and Handling. This rule sets requirements to control the emission of VOCs from excavating, grading, handling, and treating VOC -contaminated soil as a result of leakage from storage or transfer operations, accidental spillage, or other deposition. Pursuant to SCAQMD Rule 1166, excavating or grading soil containing VOC materials shall:
• Apply for, obtain, and operate pursuant to a mitigation plan pursuant to the requirements of SCAQMD Rule 1166. Monitor for VOC contamination at least once every 15 minutes commencing at the beginning of excavation or grading and record all VOC concentration readings. Handling VOC-contaminated soil at or from an excavation or grading site shall segregate VOC-contaminated stockpiles from non-VOC contaminated stockpiles such that mixing of the stockpiles does not take place. VOC contaminated soil stockpiles sh all be sprayed with water and/or approved vapor suppressant and adequately cover them with plastic sheeting for all periods of inactivity lasting more than one hour. A daily visual inspection shall be conducted of all covered VOC contaminated soil stockpiles to ensure the integrity of the plastic covered surfaces. Contaminated soil shall be treated or removed from an excavation or grading site within 30 days from the time of excavation.

Rule 1470 – Requirements for Stationary Diesel -fueled Internal Combustion and Other Compression Ignition Engines. This rule applies to any person who owns or operates a stationary compression ignition engine in the SCAQMD with a rated brake horsepower greater than 50. This rule sets operational hour requirement stating that new stationary emergency diesel engines sha ll not operate more than 50 hours a year for maintenance and testing. Additionally, under this rule, emergency generators shall operate for a maximum of 200 hours a year.

Rule 2305 – Warehouse Associated Mobile Sources. This rule outlines the reduction of local and regional emissions of nitrogen oxides and particulate matter, and to facilitate local and regional emission reductions with warehouses and associated mobiles sources. As the Project proposes one 99,850- SF building and one 99,950-SF building, it would thus be exempt from this rule as it applies to warehouses with greater than or equal to 100,000 SF of indoor floor space in any single building.

Massachusetts Point Project 2. Errata
City of Riverside 2-23
Final EIR
October 2025
Regulation XIII – New Source Review. This regulation governs New Source Review (NSR) for new, relocated, or modified facilities that emit air contaminants. This regulation requires the application of Best Available Control Technology (BACT), analysis of potential emission increases, and the use of emission reduction credits to offset increases in nonattainment pollutants.

Location: Page 5.3-23, Section 5.3.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised export values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Construction of the Project would occur over an approximately 14 -month period. Construction activities associated with the Project would result in emissions of CO, ROG, NOx, SOx, PM10, and PM2.5. Pollutant emissions associated with construction would be generated from the following construction activities: (1) demolition, (2) site preparation, (3) grading, (4) building construction, (5) paving, and (6) architectural coatings. These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants. In addition, emissions would result from the import of 9,043 CY of soil during the grading phase and from export of 24,092 tons of debris during the demolition of the existing building , a maximum export of 500 CY of potentially contaminated soil during the site preparation phase , and export of 24,092 tons of debris during the demolition phase.

Location: Page 5.3-24, Section 5.3.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion : Revised emissions values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Table 5.3-1: Regional Project Construction Emissions
Construction Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SO2 PM10 PM2.5
2026
Demolition 2.7 44.9 25.6 0.2 24.1 5.4
Site Preparation 3.9 34.7

35.9 32.0

32.2 0.1 7.7

8.0 4.4

4.5 Grading 3.5 33.0 30.5 0.1 5.0 2.6
Building Construction 1.5 12.1 20.4 <0.1 1.8 0.7
Maximum Daily Emissions 2026 3.9 44.9 32.0

32.2 0.2 24.1 5.4
2027
Building Construction 1.4 11.6 18.6 <0.1 1.8 0.7
Paving 1.4 7.0 10.7 <0.1 0.5 0.3
Architectural Coating 54.7 1.2 2.3 <0.1 0.2 0.1
Maximum Daily Emissions 2027 54.7 11.6 18.6 <0.1 1.8 0.7 Maximum Daily Emission 2026-2027 54.7 44.9 32.0

32.2 0.2 24.1 5.4
SCAQMD Significance Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: ROGs = reactive organic gases, CO = carbon monoxide, SO2 = sulfur dioxide, NOx = nitrogen oxides, PM10 = particulate matter (10 microns), PM2.5 = particulate matter (2.5 microns) Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B) Massachusetts Point Project 2. Errata
City of Riverside 2-24
Final EIR
October 2025
Location: Page 5.3-25, Section 5.3.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised emissions values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Table 5.3-2: Regional Project Operational Emissions
Operational Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SO2 PM10 PM2.5
Mobile 3.3 28.1 42.1 0.3 16.8 4.7
Area 6.2 0.1 8.7 <0.1
<0.1

0.0 <0.1

0.0 Energy 0.1 2.1 1.8 <0.1 0.2 0.2
Off-Road <0.1 17.7 176.2 <0.1 <0.1 <0.1
Stationary 1.6 4.4 4.0 <0.1 0.2 0.2
Total Project Operational
Emissions 11.3 52.4 232.7 0.3 17.2 5.1
Existing Use Operational Emissions 1.9 31.6 61.0

65.3 0.4 23.1 6.3
Net New Emissions 9.3 20.8 171.8
167.4 <0.1 -6.0 -1.3
SCAQMD Significance Thresholds 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: ROGs = reactive organic gases, CO = carbon monoxide, SO2 = sulfur dioxide, NOx = nitrogen oxides, PM10 = particulate matter (10 microns), PM2.5 = particulate matter (2.5 microns) Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Table 5.3-3: Localized Project Construction Emissions
Construction Activity
Maximum Daily Localized Emissions
(pounds/day)
NOx CO PM10 PM2.5
2026
Demolition 20.7 19.0 17.9 3.4
Site Preparation 34.6 31.0 7.4 4.3
Grading 30.0 28.7 4.1 2.3
Building Construction 10.7 28.1 0.8 0.8
Maximum Daily Emissions 2026 34.6 31.0 17.9 4.3
2027
Building Construction 10.2 14.0 0.4 0.3
Paving 6.9 10.0 0.3 0.3
Architectural Coating 1.1 1.5 <0.1 <0.1
Maximum Daily Emissions 2027 10.2 14.0 0.4 0.3
Maximum Daily Emission 2026-2027 34.6 31.0 17.9 4.3
SCAQMD Localized Significance Thresholds 45.17
268
6,285.3
1,827.7
89 33.3

28.3 8.7
I
I
- -
-
-
Massachusetts Point Project 2. Errata
City of Riverside 2-25
Final EIR
October 2025
Construction Activity
Maximum Daily Localized Emissions
(pounds/day)
NOx CO PM10 PM2.5
Threshold Exceeded? No No No No
Notes: NOx = nitrogen oxides, CO = carbon monoxide, PM10 = particulate matter (10 microns), PM2.5 = particulate matter (2.5 microns).

Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B) Location: Page 5.3-32, Section 5.3.9, Project Design Features, is revised as follows:

Explanation for Change and Discussion : Revised to include Project Design Features the Project Applicant is voluntarily including to further reduce potential Air Quality impacts.

5.3.9 Project Design Features
None.

PDF AQ-1: The Project would use light-colored paving and roofing materials. This design feature would reduce heat absorption, thereby lowering cooling demands and associated energy use, which in turn would reduce operational air quality impacts. No quantitative credit was taken in the air quality analysis for this design feature.

PDF AQ-2: The Project would use Energy Star heating, cooling, and lighting devices and appliances.

This design feature would increase energy efficiency and reduce electricity demand, which in turn would reduce operational air quality impacts. No quantitative credit was taken in the air quality analysis for this design feature.

PDF AQ -3: The Project would be designed to include the installation of signs at every truck exit providing directional information to the trucks’ routes. This design feature would prevent nearby sensitive receptors from further exposure to criteria pollutants during the operation of the Project. No quantitative credit was taken in the air quality analysis for this design feature.

PDF AQ-4: The Project would have a truck check-in point inside of the Project site, consistent with best practices for siting and designing warehouse facilities. This design feature would help manage truck circulation on -site and reduce idling on surrounding roadways, thereby minimizing operational exposure of nearby sensitive receptors to criteria pollutants. No quantitative credit was taken in the air quality analysis for this design feature.

PDF AQ-5: The Project would be designed to provide overnight truck parking inside of the Project site.

This design feature would encourage trucks to not park overnight near sensitive receptors and prevent further exposure to criteria pollutants during the operation of the Project. No quantitative credit was taken in the air quality analysis for this design feature.

2.2.4 Section 5.5, Cultural Resources
Location: Page 5.5-13, Section 5.5.8, Existing Regulations and Plans, Programs, or Policies , is revised as follows:

Explanation of Change and Discussion: Revised PPP CUL-1 per City’s standard language.

Massachusetts Point Project 2. Errata
City of Riverside 2-26
Final EIR
October 2025

5.5.8 Existing Regulations and Plans, Programs, or Policies Existing Regulations
• California Health and Safety Code Section 7050.5
• Public Resources Code Section 5097.98
Plans, Programs, or Policies
The following Plans, Programs, and Policies (PPPs) that are listed below would reduce impacts related to cultural resources. These actions will be included in the Project’s Mitigation Monitoring and Reporting Program:

PPP CUL-1: Human Remains. If human remains are found on this site, the developer/permit holder or any successor in interest shall comply with State Health and Safety Code Section 7050.5. Pursuant to State Health and Safety Code Section 7050.5, if human remains are encountered, no further disturbance shall occur until the San Bernardino County Coroner has made the necessary findings as to origin. Further, pursuant to Public Resources Code Section 5097.98 (b), remains shall be left in place and free from disturbance until a final decision as to the treatment and their disposition has been made. If the San Bernardino County Coroner determines the remains to be Native American, the Native American Heritage Commission shall be contacted by the Coroner within the period specified by law (24 hours). Subsequently, the Native American Heritage Commission shall identify the “Most Likely Descendant.” The Most Likely Descendant shall then make recommendations and engage in consultation with the property owner concerning the treatment of the remains as provided in Public Resources Code Section 5097.98. Discovery of Human Remains: In the event that human remains (or remains that may be human) are discovered at the Project site during grading or earthmoving, the construction contractors, Project Archaeologist, and/or designated Native American Monitor shall immediately stop all activities within 100 feet of the find. The Project proponent shall then inform the Riverside County Coroner and the City of Riverside Community & Economic Development Department immediately, and the coroner shall be permitted to examine the remains as required by California Health and Safety Code Section 7050.5(b) unless more current State law requirements are in effect at the time of the discovery. Section 7050.5 requires that excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If human remains are determined as those of Native American origin, the Applica nt shall comply with the state relating to the disposition of Native American burials that fall within the jurisdiction of the NAHC (PRC Section 5097). The coroner shall contact the NAHC to determine the most likely descendant(s). The MLD shall complete his or her inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. The Disposition of the remains shall be overseen by the most likely descendant(s) to determine the most appropriate means of treating the human remains and any associated grave artifacts.

The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. The County Coroner will notify the Native American Heritage Commission in accordance with California Public Resources Code 5097.98.

According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052) determined in consultation between the Project proponent and the MLD. In the event that the Project proponent and the MLD are in disagreement regarding the disposition of the remains, State law will apply and the median and decision process will occur with the NAHC (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

Massachusetts Point Project 2. Errata
City of Riverside 2-27
Final EIR
October 2025

2.2.5 Section 5.6, Energy
Location: Page 5.6-6, Section 5.6.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised fuel construction values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

The energy analysis modeling for the proposed Project (included as Appendix B) shows that construction - r
elated use of construction vehicles and off-road equipment would utilize approximately 59,818 75,047 gallons of diesel fuel and 15,304 22,470 gallons of gasoline, as detailed in Table 5.6-1 below.

Table 5.6-4: Construction Fuel Consumption
Construction Source Gallons of Diesel Fuel Gallons of Gasoline Fuel Construction Vehicles 21,839
37,068
15,304
22,470
Off-Road Construction Equipment 37,979 0
Total 59,818
75,047
15,304
22,470
Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B).

2.2.6 Section 5.8, Greenhouse Gas Emissions
Location: Page 5.8-11 to 5.8-12, Section 5.8.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised emissions values for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Construction
Implementation of the proposed Project would generate GHG emissions from demolition, construction a
ctivities, haul trips, vendor trips, and construction worker vehicle trips. For construction emissions, the SCAQMD recommends amortizing emissions over 30 years by calculating the total GHG emissions for the construction activities, dividing it by a 30-year project life, then adding that number to the annual operational phase GHG emissions, which is done within this analysis. Table 5.8 -1 provides the estimated construction emissions from the Project. As shown, the Project would emit a total of 844 850 Annual MTCO2e over the duration of construction, with 2026 having the highest emission level ( 821 826 MTCO2e). Amortized over 30 years, the Project’s construction emissions would be approximately 28 MTCO2e per year.

Table 5 .8 -5: Project Construction Greenhouse Emissions Activity Annual GHG Emissions (MTCO2e)
2026 821
826
2027 23
Total Emissions 844
850
Total Emissions Amortized Over 30 Years 28
Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B) I
- -
- -
I
Massachusetts Point Project 2. Errata
City of Riverside 2-28
Final EIR
October 2025
Operation
The proposed Project would construct two warehouse buildings with a combined total building square footage of 199,850 square feet (SF) that would accommodate approximately 194 employees. Operation of the proposed Project would generate GHG emissions from v ehicle trips, electricity and natural gas consumption, water and wastewater transport (the energy used to pump water), and solid waste generation.

GHG emissions from electricity consumed by the proposed Project would be generated off site by fuel combustion at the electricity provider. GHG emissions from water transport are also indirect emissions resulting from the energy required to transport water from its source. GHG emissions from solid waste disposal are associated with the anaerobic breakdown of material.

The Air Quality, Energy, and GHG Impact Analysis prepared for the proposed Project (Appendix B) describes that the GHG emissions generated from the proposed Project at buildout are primarily associated with non-construction related mobile sources, such as vehicle and truck trips. The annual GHG emissions associated with the proposed Project are summarized in Table 5.8- 2. As shown, operation of the Project, including amortized construction emissions, would generate a net total of approximately 7,272 7,269 MTCO2e per year, which would not exceed the screening threshold of 10,000 MTCO2e per year. The existing operational GHG emissions from the existing buildings were estimated to be 1,785 MTCO2e. As such, the net new emissions (proposed Project minus existing) from the proposed Project are 5,457 5,484 MTCO2e per year. The proposed Project’s net and total GHG emission results are both below the SCAQMD significance threshold of 10,000 MTCO2e per year. Therefore, impacts would be less than significant.

Table 5.8-6: Project Greenhouse Gas Emissions
Activity Annual GHG Emissions (MTCO2e)
Project Operational Emissions
Mobile 5,426
Area 4
Energy 921
Water 127
Waste 74
Refrigeration 183
Off-Road 461
Stationary 18
45 Total Project Gross Operational Emissions 7,214
Amortized Construction Emissions 28
Total Project Emissions 7,242
7,269
Existing Emissions 1,785
Net New Emissions (Gross - Existing) 5,457
5,484
Significance Threshold 10,000
Threshold Exceeded? No
Source: Air Quality, Energy, and GHG Impact Analysis (Appendix B) Massachusetts Point Project 2. Errata
City of Riverside 2-29
Final EIR
October 2025
Location: Page 5.8-13 to 5.8-16, Section 5.8.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised typo for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Table 5.8-7: Project Consistency with the CARB 2022 Scoping Plan Action Consistency
GHG Emissions Reductions Relative to the SB 32 Target
40% Below 1990 levels by 2030. Consistent. The Project would comply with the 2022 Title 24, Part 6 energy requirements, as well as Title 24, Part 11 building standards, along with other local and State
initiatives that aim to achieve the 40% below 1990 levels by 2030 goal.

Smart Growth/Vehicle Miles Traveled (VMT)
VMT per capita reduced 25% below 2019 levels by
2030, and 30% below 2019 levels by 2045.

Consistent. The proposed Project would provide bicycle
racks and bicycle parking spaces to encourage alternative modes of transportation. The Project is consistent with the growth and land use assumptions in the Southern California Association of Government’s 2022 Connect SoCal Regional Transportation Plan/Sustainable Communities Strategy
(which was utilized for growth estimates in the CARB Scoping Plan) including reductions in VMT per capita. The plan aims to reduce VMT per capita by 25% below 2019 levels by
2030 and 30% by 2045, which aligns with targets set in the CARB Scoping Plan. Thus, the Project would not interfere with VMT reduction targets and measures.

Light-Duty Vehicle (LDV) Zero-Emission Vehicles (ZEVs)
100% of LDV sales are ZEV by 2035. Consistent. The proposed Project is a speculative industrial building that could potentially involve the manufacturing and storage of LDV ZEVs. The future tenant would be required to comply with the CARB’s Advanced Clean Truck Regulation that requires truck manufactur ers to transition from diesel trucks to zero emission trucks, and would be designed and constructed in accordance with the 2022 Title 24 Part 6 and Part 11 requirements, which include constructing
infrastructure to allow for electric vehicle charging.

Truck ZEVs
100% of medium - and heavy -duty vehicle (MHDV)
sales are ZEV by 2040 (AB 74 University of
California Institute of Transportation Studies [ITS]
report).

Consistent. The proposed Project is a speculative industrial building that could potentially involve the manufacturing and storage of MHDV ZEVs. The future tenant would be required to comply with the CARB’s Advanced Clean Truck Regulation that would require truck manu
facturers to transition from
diesel trucks to zero emission trucks, and would be designed and constructed in accordance with the 2022 Title 24 Part 6 and Part 11 requirements, which include constructing
infrastructure to allow for electric vehicle charging.

Aviation
20% of aviation fuel demand is met by electricity
(batteries) or hydrogen (fuel cells) in 2045.

Sustainable aviation fuel meets most or the rest of the aviation fuel demand that has not already
transitioned to hydrogen or batteries.

Not Applicable. The proposed Project would not utilize aviation fuel.

Massachusetts Point Project 2. Errata
City of Riverside 2-30
Final EIR
October 2025
Action Consistency
Ocean-going Vessels (OGV)
2020 OGV At -Berth regulation fully implemented,
with most OGVs utilizing shore power by 2027.
25% of OGVs utilize hydrogen fuel cell electric
technology by 2045.

Not Applicable. The proposed Project would not utilize any OGVs.

Port Operations
100% of cargo handling equipment is zero -emission
by 2037. 100% of drayage trucks are zero emission
by 2035.

Not Applicable. The proposed Project would not impact any operations at any ports.

Freight and Passenger Rail
100% of passenger and other locomotive sales are
ZEV by 2030. 100% of line haul locomotive sales are
ZEV by 2035. Line haul and passenger rail rely
primarily on hydrogen fuel cell technology, and
others primarily utilize electricity.

Not Applicable. The proposed Project would not involve any rail operations.

Oil and Gas Extraction
Not Applicable. The proposed Project would not
involve oil and gas extraction operations.

Reduce oil and gas extraction operations in line
with petroleum demand by 2045.

Not Applicable. The proposed Project would not involve oil and gas extraction operations.

Petroleum Refining
Carbon capture and sequestration (CCS) on majority
of operations by 2030, beginning in 2028.

Production reduced in line with petroleum demand.

Not Applicable. The proposed Project would not involve any petroleum refining.

Electricity Generation
Sector GHG target of 38 million metric tons of carbon
dioxide equivalent (MTCO 2e) in 2030 and 30
MTCO2e in 2035. Retail sales load coverage134 20
gigawatts (GW) of offshore wind by 2045. Meet
increased demand for electrification without new
fossil gas-fired resources.

Consistent. The Project would not generate electricity. The Project would comply with the 2022 Title 24, Part 6 building energy including efficiency and renewable energy
requirements.

New Residential and Commercial Buildings
All electric appliances beginning 2026 (residential)
and 2029 (commercial), contributing to 6 million heat
pumps installed statewide by 2030.

Consistent. The Project would comply with the 2022 Title 24, Part 6 building energy requirements, including installing electrical wiring for all built in appliances.

Existing Residential Buildings
80% of appliance sales are electric by 2030 and
100% of appliance sales are electric by 2035.

Appliances are replaced at end of life such that by
2030 there are 3 million all -electric and electric -
ready homes —and by 2035, 7 million homes—as
well as contributing to 6 million heat pumps installed
statewide by 2030.

Not Applicable. The proposed Project would not involve the operation any existing residential buildings.

Existing Commercial Buildings
80% of appliance sales are electric by 2030, and
100% of appliance sales are electric by 2045.

Appliances are replaced at end of life, contributing
to 6 million heat pumps installed statewide by 2030.

Consistent. The Project would be consistent and comply with Title 24 Section 6 requirements for commercial buildings, including complying with 100% electric appliances
beginning in 2029, replacing an existing building that was not constructed to be consistent with the current 2022 Title 24 Building Code requirements.

Massachusetts Point Project 2. Errata
City of Riverside 2-31
Final EIR
October 2025
Action Consistency
Food Products

7.5% of energy demand electrified directly and/or
indirectly by 2030; 75% by 2045.

Consistent. The Project would include up to 20% of the total building area for cold storage, which has the potential to store food products. The proposed Project would comply
with the 2022 Title 24 Building Codes in Section 6 and would be required to meet increasing standards set by the State.

Therefore, the Project would be consistent with meeting current and future policies concerning the storage of food products as speculative cold storage warehouses.

Construction Equipment
25% of energy demand electrified by 2030 and
75% electrified by 2045.

Consistent. The proposed Project would be required to use construction equipment that is registered by CARB and meet CARB’s standards. CARB sets its standards to be in line with the goal of reducing energy demand by 25% in 2030 and
75% in 2045.

Chemicals and Allied Products; Pulp and Paper
Electrify 0% of boilers by 2030 and 100% of boilers
by 2045. Hydrogen for 25% of process heat by
2035 and 100% by 2045. Electrify 100% of other
energy demand by 2045.

Consistent. As the Project proposes speculative industrial buildings, there is a potential for the Project to involve the production and/or storage of chemicals and allied products like pulp and paper. The Project would comply with the
energy demands of the 2022 Title 24 Section 6 Building
Codes and would comply with the electricity and hydrogen requirement by 2045 for the production of chemicals and allied products.

Stone, Clay, Glass, and Cement
CCS on 40% of operations by 2035 and on all
facilities by 2045. Process emissions reduced through
alternative materials and CCS.

Consistent. As the Project proposes speculative industrial buildings, there is a potential for the Project to involve the production and/or storage of stone, clay, glass and/or
cement. The Project would comply with the energy demands of the 2022 Title 24 Section 6 Bui lding Codes and would promote the implementation and use of CCS for operations by 2035 and on all operations and facilities by 2045.

Other Industrial Manufacturing
0% energy demand electrified by 2030 and 50%
by 2045.

Consistent. The proposed Project is a speculative industrial building that could allow for manufacturing. A future
manufacturing tenant would be required to meet the energy demand goals of 50% by 2045, and the proposed Project
would be constructed to comply with Title 24, Part 6 Building energy requirements, including increases in onsite energy generation requirements and improved insulation reducing energy consumption in industrial manufacturing operations.

Combined Heat and Power
Facilities retire by 2040. Not Applicable. The proposed Project would not involve any existing combined heat and power facilities.

Agriculture Energy Use
25% energy demand electrified by 2030 and 75%
by 2045.

Not Applicable. The proposed Project would not involve any agricultural uses.

Low Carbon Fuels for Transportation
Biomass supply is used to produce conventional and
advanced biofuels, as well as hydrogen.

Not Applicable. The proposed Project would not involve any production of biofuels.

Massachusetts Point Project 2. Errata
City of Riverside 2-32
Final EIR
October 2025
Action Consistency
Low Carbon Fuels for Buildings and Industry
In 2030s, biomethane135 blended in pipeline .

Renewable hydrogen blended in fossil gas pipeline
at 7% energy (~20% by volume), ramping up
between 2030 and 2040. In 2030s, dedicated
hydrogen pipelines constructed to serve certain
industrial clusters.

Not Applicable. The proposed Project would not involve any production of fuels for buildings and industry.

Non-Combustion Methane Emissions
Increase landfill and dairy digester methane capture.

Some alternative manure management deployed for
smaller dairies.

Moderate adoption of enteric strategies by 2030.

Divert 75% of organic waste from landfills by 2025.

Oil and gas fugitive methane emissions reduced 50%
by 2030 and further reductions as infrastructure
components retire in line with reduced fossil gas
demand.

Not Applicable. The proposed Project would not involve any production of non-combustion methane emissions or organic waste.

High Global Warming Potential (GWP) Emissions
Low GWP refrigerants introduced as building
electrification increases, mitigating
hydrofluorocarbon (HFC) emissions.

Consistent. The proposed Project includes refrigeration and would be consistent with the 2022 Title 24 Section 6 Building Codes for 2022 and would be required to meet increasing standards set by the State. Therefore, the Project would be consistent with meeting current and future policies concerning the use of low GWP refrigerants.

Location: Page 5.8-17, Section 5.8.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised to include an additional Policy for consistency with updated Air Quality, Energy, and GHG Impact Analysis (Appendix B).

Table 5.8-8: Project Consistency with the City General Plan Policies Related to GHGs General Plan Goal or Policy Consistency
Policy AQ -1.10: Encourage job creation in job -poor
areas as a means of reducing vehicle miles traveled.

Consistent. As discussed in Section 5.14, Population and Housing, the City of Riverside is housing -rich, meaning that more housing is provided than employment
opportunities in the area. I mplementation of the
proposed Project would create up to an additional 194
jobs. Therefore, the proposed Project would create jobs in a job-poor area, consistent with this policy.

Policy AQ-1.15: Establish land use patterns that reduce the number and length of motor vehicle trips and promote alternative modes of travel.

Consistent. As discussed in Section 5.17, Transportation, existing bus services near the Project site would allow Project site residents convenient access to transit.

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

Consistent. The Project would comply with the 2022 Title 24, Part 6 building energy including efficiency and
renewable energy requirements.

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

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

Massachusetts Point Project 2. Errata
City of Riverside 2-33
Final EIR
October 2025
General Plan Goal or Policy Consistency
Policy AQ -5.7: Require residential building
construction to meet or exceed energy use guidelines
in Title 24 of the California Administrative Code.

Not Applicable. The proposed Project does not
propose residential buildings.

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

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

2.2.7 Section 5.9, Hazards and Hazardous Materials
Location: Page 5.9-22, Section 5.9.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised nearest runway based on more detailed information provided in the May 5, 2025, RCALUC director’s determination letter for accuracy and consistency.

The Project site is located approximately 2.9 miles east of the Flabob Airport, a small public-use airport in the City of Jurupa Valley. The nearest runway at Flabob Airport, Runway 6-24, has an easterly runway elevation of 768 approximately 750 feet above mean sea level (AMSL). In June 11, 2024, an Application for Major Land Use Action Review was submitted to the Riverside County Airport Land Use Commission (ALUC) for the proposed Project pursuant to ALUC Review Procedures. On May 5, 2025, ALUC determined that FAA review is require d for structures exceeding 1,039 feet AMSL at the project’s distance from the Flabob Airport runway, however, the proposed building’s top elevation is 935 feet AMSL, so FAA Obstruction Evaluation Service review is not warranted.

Location: Page 5.9-24, Section 5.9.7, Cumulative Impacts, is revised as follows:

Explanation for Change and Discussion: Revised reference to closest cumulative projects for accuracy and consistency.

The severity of potential hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. As shown in Figure 5 -1, Cumulative Projects, in Section 5.0, Environmental Impact Analysis, of this Draft EIR, the re are two closest cumulative projects, both is located at 2610 Durahart Street, approximately 0.25 miles east of the Project site.

The commencement of construction of the adjacent cumulative project is unknown; however, it is possible that construction activities involving hazardous materials from both the proposed Project and the adjacent cumulative project or other nearby cumulative projects would occur simultaneously that could have the potential to cumulatively contribute to an impact. However, all hazardous materials users and transporters, as well as hazardous waste generators and disposers are subject to regulations that require proper transport, handling, use, storage, and disposal of such materials to ensure public safety, which are verified by the City during the construction and development permitting process.

Thus, if hazardous materials are found to be present on any of the cumulative or future project sites, appropriate remediation activities would be required pursuant to standard federal, State, and regional regulations that would reduce potential impacts, such as the activities which would be done by the proposed Project. In addition, regulatory compliance and implementation of Mitigation Measure HAZ -1, the SMP and HSP would be implemented for the proposed Project to ensure that hazardous soil from the site would be handled and disposed of in a manner which would reduce the potential of the proposed Project to result in a hazard to the public or environment that could cumulatively combine. As such, the potential impacts from the proposed Project would be less than significant and not cumulatively considerable.

Massachusetts Point Project 2. Errata
City of Riverside 2-34
Final EIR
October 2025
In regard to potential cumulative impacts associated with the Project’s proximity to Flabob Airport and March Air Reserve Base/Inland Port Airport, future development projects in the area, like the proposed Project, would be subject to consistency review by ALUC. As part of this process, ALUC would provide conditions to ensure that future projects are designed and operated in a manner that avoids significant impacts related to airport safety and land use compatibility. With implementation of Mitigation Measures HAZ-2 through HAZ-5, the proposed Project would not result in significant impacts, and its contribution to cumulative impacts related to airport proximity would not be cumulatively considerable.

2.2.8 Section 5.17, Transportation
Location: Page 5.17-7, Section 5.17.6, Environmental Impacts, is revised as follows:

Explanation for Change and Discussion: Revised to include consistency with transportation related General Plan policies.

City of Riverside General Plan
The proposed Project is also consistent with the General Plan designations of the site. The Project site has a General Plan land use designation Industrial (I). The City of Riverside General Plan states that the primary intent of the Industrial land use designation is to allow for manufacturing and wholesaling; support commercial uses; and warehouse and distribution facilities only at specific locations. Once approved by the Development Agreement, the Project site would be within one of these specific locations. The Project proposes to construct two new industrial buildings on a 10.21-acre portion of the site (2626 Kansas Avenue and 2069 Massachusetts Avenue) that would support warehouse and office uses. No development is proposed on 1989 Massachusetts Avenue. As described in Section 3.0, Project Description, a warehouse is used for the storage, receiving, shipping or wholesaling of goods and merchandise, and any incidental or accessory activities. The proposed light industrial warehouses are consistent with the intended uses of the Industrial land use designation. In addition, the Project would be consistent with the following applicable City of Riverside 2025 General Plan Circulation and Community Mobility Element Policies: CCM-2.2, CCM-2.3, CCM-2.4, CCM-2.7, CCM-5.2, CCM-6.2, CCM-9.10, CCM-10.12, CCM-12.1, CCM-12.2, CCM-13.1, CCM-13.3. As such, the proposed Project would not conflict with the City of Riverside General Plan, and no impact would occur.

2.2.9 Section 5.19, Utilities
Location: Page 5.19-13, Section 5.19.4. 5, Stormwater Drainage Environmental Impacts , is revised as follows:

Explanation for Change and Discussion: Revised the number and location description of the Project’s proposed on-site underground detention/infiltration systems to correct discrepancies and ensure document consistency.

As stated above, the northern portion of the Project site is developed with two buildings and asphalt concrete while the southern portion of the site is undeveloped and pervious. In the existing condition, stormwater on the northern portion of the site is directed to existing on-site v-gutters and is conveyed to Roberta Street and Kansas Avenue. Stormwater flow for the southern portion of the site is overland flow that is generally conveyed in the southeast-to-northwest direction to Kansas Avenue. Off-site flows are directed to an existing gutters that runs along Kansas Avenue. The proposed Project would collect drainage via proposed grate inlets and catch basins, which would convey storm water to an on- site underground storm drain system. The storm drain system would discharge to one two proposed on-site underground detention/infiltration systems.

This d Detention/infiltration sSystem A would be located under the passenger drive aisle in the southnorthwest portion of the site adjacent to Building 2 and would direct overflow to Kansas Avenue Massachusetts Point Project 2. Errata
City of Riverside 2-35
Final EIR
October 2025
Roberta Steet. Detention/Infiltration System B would be located beneath the truck court of Building 1 and would direct overflow to Kansas Avenue. In the current condition, the existing 100-year, 3-hour flow is 4.56 cubic square feet (cfs) on Roberta Street and 12.41 cfs on Kansas Avenue. Upon completion of the proposed Project, the 100-year, 3-hour flow would be 2.78 cfs on Roberta Street and 7.67 cfs on Kansas Avenue, lower than the existing on-site flows (Appendix I, Page 5). Therefore, the proposed stormwater system would provide improved infiltration compared to existing conditions.

Massachusetts Point Project 2. Errata
City of Riverside 2-36
Final EIR
October 2025
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Massachusetts Point Project 3. Response to Comments
City of Riverside 3-1
Final EIR
October 2025

3. Response to Comments
This section of the Final Environmental Impact Report (FEIR; Final EIR) for the Massachusetts Point Project (Project) includes a copy of all comment letters that were submitted during the public review period for the Draft Environmental Impact Report (DEIR), along with responses to comments in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15088. The 45-day review period for the DEIR began on June 26, 2025, and ended on August 11, 2025. A total of three comment letters were received in response to the DEIR during the 45 -day public review period. Responses to all three comment letters are provided below.

The responses amplify or clarify information provided in the DEIR and/or refer the reader to the appropriate place in the document where the requested information can be found. Comments that are not directly related to environmental issues (e.g., opinions on the merits of the Project unrelated to its environmental impacts) are noted for the record. Where text changes in the DEIR are warranted based on comments received, updated Project information, or other information provided by City staff, those changes are noted in the response to comment and the reader is directed to Section 2.0, Errata, of this FEIR.

These changes to the analysis contained in the DEIR represent only minor clarifications/amplifications and do not constitute significant new information. In accordance with CEQA Guidelines Section 15088.5, recirculation of the DEIR is not required.

All written comments received on the DEIR are listed in Table 3-1. All comment letters received on the DEIR have been coded with a number to facilitate identification and tracking. The comment letters were reviewed and divided into individual comments, with each comment containing a si ngle theme, issue, or concern.

Individual comments and the responses to them were assigned corresponding numbers. To aid readers and commenters, electronically bracketed comment letters have been reproduced in this document wi th the corresponding responses provided immediately following each comment letter.

Table 3-1: Comments Received on the DEIR
Comment Letter Agency/Organization/Commenter Date
Agencies
A1 South Coast Air Quality Management District (SCAQMD) August 7, 2025 A2 Riverside County Airport Land Use Commission (ALUC) July 21, 2025 Organizations
O1 Sierra Club and R-NOW August 11, 2025

To finalize the EIR for the Project, the following responses were prepared to address these comments.

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-2
Final EIR
October 2025
Comment Letter A1: South Coast Air Quality Management District, Dated August 7, 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-3
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-4
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-5
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-6
Final EIR
October 2025