Riverside City Council
March 24, 2026

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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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
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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

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-7
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-8
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-9
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-10
Final EIR
October 2025

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-11
Final EIR
October 2025

3.1 Response to Comment Letter A 1: South Coast Air Quality Management District , Dated August 7, 2025
Comment A1.1: This comment provides an introduction to the comment letter and states that the South Coast Air Quality Management District (SCAQMD) is appreciative of their opportunity to comment.

Response A1.1: The comment is introductory in nature and does not raise a specific issue with the adequacy of the Draft EIR. Because the comment does not express any specific concern or question regarding the adequacy of the EIR, no further response is required or provided.

Comment A1.2: This comment states that the Draft EIR used the “General Heavy Industry” land use type in CalEEMod for the unrefrigerated warehouse portion of the Project. The comment states that this category represents large-scale manufacturing facilities and does not reflect the Project’s characteristics. The comment states that the appropriate land use types are “Unrefrigerated Warehouse” and “Refrigerated Warehouse,” consistent with the Project’s inclusion of 20 percent cold storage. The comment states t hat use of the incorrect land use type may underestimate emissions and recommends revising the CalEEMod inputs, rerunning the model, and updating the Final EIR.

Response A1.2: The proposed Project is currently planned as a speculative industrial development, meaning no specific tenant or end user has been identified at this time. For the Air Quality, Energy, and Greenhouse Gas Analysis (Appendix B) , the California Emissions Model (CalEEMod) Land Use Subtype inputs used correspond to the Institute of Transportation Engineers (ITE) Trip Generation Hand Book (11th Edition) trip rate for the Land Use Codes used in the Project’s Traffic Analysis (Appendix K), in addition to the Project’s characteristics. This approach ensures consistency between the modeling assumptions of the traffic trips generated and the emission generated from those trips.

Additionally, the CalEEMod (Version 2022.1) User Guide identifies which ITE Land Use Codes correspond to the CalEEMod Land Use Subtypes. The CalEEMod Land Use Subtype “Unrefrigerated Warehouse-No Rail” corresponds with ITE Land Use Code 150 – Warehouse. However, to provide a conservative analysis, the Project’s Traffic Analysis utilized the ITE trip rate for Land Use Code 110 – General Light Industrial (GLI), which is 4.87 trips per 1,000 square feet (tsf) , as it is higher than the trip rate for Land Use Co de 150 Warehouse (1.71 trips/tsf). As a result, applying the GLI land use rate generates more trips (and higher mobile-source emissions) than would reasonably be expected for the Project’s proposed warehouse use.

Accordingly, the CalEEMod Land Use Subtype that correspondence with ITE Land Use Code 110 – GLI used in the Traffic Analysis would be “General Light Industry .” However, per the CalEEMod User Guide, for a project with a lot size greater than 50,000 square feet, the user must select a different land use type such as general heavy industry, industrial park, or manufacturing .1 As such , the Air Quality, Energy, and Greenhouse Gas Analysis utilized the CalEEMod Land Use Subtype of “General Heavy Industry,” as opposed to “Unrefrigerated Warehouse-No Rail,” in addition to “Refrigerated Warehouse-No Rail,” in accordance with the CalEEMod User Guide to ensure a conservative analysis and maintain consistency with the corresponding ITE trip rate used in the Project’s Traffic Analysis.

Therefore, the CalEEMod Land Use Subtype of “General Heavy Industry” is appropriate for the Project, and no changes to the land use types executed in the modeling of the Project are warranted. Therefore, no changes to the EIR are warranted.

Comment A1.3: This comment states that the Draft EIR does not evaluate potential air quality impacts associated with site cleanup and remediation activities during construction, despite the presence of VOCs

1 California Air Pollution Control Officers Association (CAPCOA). (2022, April). CalEEMod User Guide (Version 2022.1).

ICF & partners. https://www.caleemod.com/documents/user-guide/CalEEMod_User_Guide_v2022.1.pdf Massachusetts Point Project 3. Response to Comments
City of Riverside 3-12
Final EIR
October 2025
identified in the Phase I Environmental Site Assessment. The comment states that cleanup activities would likely require additional equipment and truck hauling beyond typical construction activities, potentially resulting in underestimated construction emi ssions. The comment states that use of the default 20 -mile haul distance in CalEEMod may not reflect the longer trip lengths required if contaminated soil must be transported to a permitted hazardous waste disposal facility outside Riverside County. The co mment recommends revising the CalEEMod inputs to reflect the actual disposal distance or providing substantial evidence to justify the use of the 20-mile assumption in the Final EIR.

Response A1.3: This comment has been addressed through revisions to the CalEEMod construction trip length assumptions. Specifically, the proposed Project will result in export of approximately 500 cubic yards (CY) of contaminated soil. As such, the CalEEMod default 20-mile hauling distance has been updated to 56-mile hauling distance during the site preparation phase to account for the distance to the Soil Safe Landfill in Adelanto, identified by the Riverside County Department of Waste Resources as the app ropriate disposal facility for potentially contaminated soil.

These revisions ensure that construction- related emissions associated with site cleanup and remediation activities are analyzed in the EIR analysis and technical studies. The Project’s Health Risk Assessment (HRA) (Appendix C) has been updated to reflect the correct site preparation volumes and trip lengths. The updated HRA analysis resulted in a nominal increase of particulate matter 10 exhaust (PM10E). As no significant changes were found in the updated analysis, the update did not result in a change from the previously disclosed health risk results nor a change in the HRA conclusion.

The Projects’ Air Quality, Energy, and Greenhouse Gas (GHG) Report (Appendix B) has also been updated to reflect the correct site preparation volumes and trip lengths. As shown in the updated Appendix B, the conclusions from the original Air Quality, Energy, and GHG Report remain less than significant. Therefore, recirculation of the Draft EIR is not warranted.

Draft EIR Sections 5.3, Air Quality , 5.6, Energy, and 5.8 Greenhouse Gas Emissions , have been revised to reflect the updated Appendix C and Appendix B in Section 2.0, Errata, of this Final EIR and as shown below.

This correction does not change the conclusions of the EIR, and the findings remain the same.

5.3.6 Environmental Impacts
Table 5.3-2: 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
Massachusetts Point Project 3. Response to Comments
City of Riverside 3-13
Final EIR
October 2025
Construction Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SO2 PM10 PM2.5
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)

5.3.6 Environmental Impacts
Table 5.3-3: 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 5.3-4: 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
Massachusetts Point Project 3. Response to Comments
City of Riverside 3-14
Final EIR
October 2025
Construction Activity
Maximum Daily Localized Emissions
(pounds/day)
NOx CO PM10 PM2.5
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
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)

5.6.6 Environmental Impacts
The energy analysis modeling for the proposed Project (included as Appendix B) shows that construction - related 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 5.6-5: 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).

5.8.6 Environmental Impacts
Construction
Implementation of the proposed Project would generate GHG emissions from demolition, construction activities, 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 Massachusetts Point Project 3. Response to Comments
City of Riverside 3-15
Final EIR
October 2025
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 5.8-6: 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)

5.8.6 Environmental Impacts
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 5.8-7: 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
Massachusetts Point Project 3. Response to Comments
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Final EIR
October 2025
Activity Annual GHG Emissions (MTCO2e)
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)

Comment A1.4: This comment states that the Draft EIR relies on average truck trip lengths of 15.3 miles for 2-axle, 14.2 miles for 3-axle, and 40 miles for 4-axle trucks, but states that the Draft EIR does not provide supporting evidence for these assumptions. The comme nt states that inaccurate trip length assumptions can result in underestimated emissions of Diesel Particulate Matter (DPM), NOx, and GHGs. The comment recommends that the Final EIR include documentation to support the trip length assumptions , such as fleet data or regional freight studies, or revise the assumptions to reflect realistic operational conditions. The comment further states that if the Project includes port -related truck trips, the analysis should account for distances of approximately 65–70 miles to the Ports of Los Angeles or Long Beach.

Response A1.4: As discussed in Section 3.0, Project Description , of the Draft EIR, no tenants have been identified for the proposed warehouses. Therefore, the specific type of businesses that would occupy the proposed general light industrial and refrigerated warehouse uses and their associated fleet operations are unknown.

The types of warehousing that could occur within the Project range from high -cube warehouses to light manufacturing, and goods could enter the region through multiple gateways, including the Ports of Los Angeles and Long Beach or by air through Ontario Int ernational Airport or March Inland Port . Due to the uncertainty in actual trip distances, applying SCAQMD’s recommended trip length provides an acceptable and regionally representative basis for analysis.

As acknowledged by the commenter, the trip distance of 39.9 miles per truck trip utilized for the Project is from SCAQMD Rule 2305 WAIRE Implementation Guidelines, which is the SCAQMD’s indirect source review program used to help control and minimize air quality impacts from mobile source emissions associated with trucks from warehouses. The 39.9-mile trip length is based on SC AQMD’s own studies that concluded that the average heavy duty truck trip length in the entire South Coast Air Basin was 39.9 miles. Therefore, 39.9 miles represent reasonably foreseeable average truck travel patterns associated with projects within the South Coast Air Basin, and thus are applicable and reasonably estimate the truck trip length for heavy-duty vehicles for the proposed Project.

Therefore, the Project’s truck trip length assumptions more accurately reflect the anticipated average trip lengths than the commenter’s suggested 65 –70 miles, which is not based on SCAQMD’s methodology. As such, no updates to the Draft EIR are warranted.

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-17
Final EIR
October 2025
Comment A1.5: This comment states that the Health Risk Assessment assumes 15 minutes of truck idling per day, including for trucks, but that this may underestimate actual idling behavior at a high-throughput logistics facility. The comment states that trucks may experie nce extended idling during queuing, security checks, staging, loading, and unloading, leading to higher DPM emissions than modeled. The comment notes that CARB regulations allow exemptions for “clean idle” trucks and that heavy-duty trucks can idle for significantly longer periods under certain conditions. The comment recommends that the Final EIR either revise the emissions modeling to assume at least 30 minutes of idling per truck per day or provide empirical evidence to substantiate that the 15-minute assumption is representative of expected operations.

Response A1.5: This comment does not provide substantial evidence that the 15 -minute idling assumption used in the Health Risk Assessment results in a substantial underestimation of DPM emissions or health risk impacts within the Draft EIR. As acknowledged by the comment er, statewide idling restrictions established by CARB’s Airborne Toxic Control Measure limit diesel truck idling to five minutes, with exemptions for certain “clean idle” engines. The HRA appropriately applied a conservative 15 -minute per tr uck per day idling assumption, which complies with the applicable regulatory standard and reflects a conservative approach to estimating potential emissions from truck operations.

In addition, truck idling on the Project site would be managed through site design and operational management, including designated on-site loading areas, to ensure compliance with the City’s zoning code and CARB idling restrictions minimizing potentially extended idling times. Although the City Planning Division and Engineering Department have evaluated the proposed queue length and further analysis would be prepared prior to building permit issuance, the Project Applicant is voluntarily incorporating a check-in point inside the Project Site, included as PDF AQ-4, to further reduce idling on surrounding roadways. Ultimately, all trucks accessing the Project site would be required to comply with the City’s and CARB’s 5 -minute idling limit pursuant to Riverside Municipal Code Section 19.435.030. For these reasons, the assumption used in the HRA remains conservative and consistent with regulatory requirements, and no revisions are warranted.

Comment A1.6: This comment states that the cancer risk results presented in the Draft EIR are inconsistent with those reported in its technical appendices. The comment states that while the Draft EIR and Appendix C show risks of 0.63 in one million for construction and 5.59 in one million for operation, Appendix B reports

0.54 in one million for construction and 3.55 in one million for operation. The comment recommends reconciliation of these discrepancies in order to ensure the Final EIR and all appendices present consistent cancer risk values.

Response A1.6: This comment has been addressed through revisions to Appendix B to ensure consistency across the EIR and all applicable technical studies. The Final EIR now reflects uniform cancer risk values of

0.63 in one million for construction and 5.59 in one million for operation throughout the Draft EIR, HRA (Appendix C), and the Air Quality, Energy and GHG Report (Appendix B). These revisions reconcile the discrepancies noted by the commenter and ensure that the health risk assessment results are pre sented accurately and consistently across the document and supporting appendices. Appendix B has been revised to be consistent with the cancer risk values listed in the Draft EIR and Appendix C. This correction does not change the conclusions of the EIR, and the findings remain the same.

Comment A1.7: This comment states CEQA requires that all feasible mitigation measures be utilized to reduce or minimize any significant air quality impacts and that the SCAQMD recommends certain mitigation measures and project design features be incorporated into the Final EIR.

Response A1.7: While CEQA requires that all feasible mitigation measures be utilized to minimize or eliminate any significant adverse impacts, as discussed in Section 5.3, Air Quality, of the Draft EIR, the Project would result in less than significant air quality impacts. As such, mitigation measures to mitigate air quality impacts are not required. However, the Project Applicant has agreed to incorporate some of the Massachusetts Point Project 3. Response to Comments
City of Riverside 3-18
Final EIR
October 2025
recommendations as Project Design Features (PDFs), as discussed in responses to comments A1.5, A1.13, A1.14, A1.15, A1.16, A1.17, A1.19, A1.20.

Comment A1.8: This comment suggests that the Project require zero emission or near zero emission heavy duty trucks if and when feasible. The comment further states that CARB’s clean truck rules and regulations will lead to zero emission and near zero emission trucks becoming more available for use.

Response A1.8: As discussed in Sections 5.3, 5.6, and 5.8 of the Draft EIR, the Project would not result in significant impacts to air quality, energy, or GHG. Therefore, CEQA does not require that the Project implements mitigation measures for air quality, energy, or GHG impacts. Additionally, as of 2025, the use of zero-emission heavy-duty trucks in support of uses such as those proposed by the Project remains infeasible given the extremely limited comm ercial availability of zero -emission trucks, as well as infrastructure limitations, including limited truck-accessible charging/refueling stations and electrical grid capacity.

While heavy-duty truck manufacturers have released zero-emission battery electric and hydrogen-powered trucks, these vehicles have yet to reach large scale production, and their use remains extremely limited.

Further, the availability of truck accessible v ehicle charging stations and hydrogen refueling stations in California and the United States as a whole severely limits the feasibility of zero-emission trucks.

Requiring the Project to utilize emerging technology as mandatory mitigation when the various types of technological advancements and their timeframes for commercial availability are not known with any certainty is not a feasible mitigation measure and compliance would be speculative. Lastly, the Project would not require zero emission or near zero emission heavy duty trucks as the Project’s construction and operational air quality and GHG emissions and energy consumption would not result in significant imp acts that trigger the need for mitigation measures. This comment does not warrant any changes to the Draft EIR.

Comment A1.9: This comment suggests that the Lead Agency require a phase in schedule for cleaner operating trucks to reduce any significant air quality impacts and that SCAQMD staff is available to discuss the availability of current and upcoming truck technologies.

Response A1.9: As stated in Response A1.8, implementation of this mitigation measure is unfeasible at this time as the types of technological advancements and the associated timeframes for commercial availability for zero emission and near zero emission trucks are not known with any certainty and are highly speculative.

In addition, the Project does not require mitigation measures for Air Quality, Energy, or GHG because the Project’s construction and operational air quality and GHG emissions and energy cons umption would not result in significant impacts. This comment does not warrant any changes to the Draft EIR.

Comment A1.10: This comment suggests that the Lead Agency limit the daily number of trucks to levels analyzed in the Draft EIR and if a higher number of trucks are anticipated to visit the site, the Lead Agency shall commit to reevaluating the Project through CEQA.

Response A1.10: CEQA does not require mitigation measures for Air Quality and GHG for the Project because the Project would not result in significant Air Quality or GHG Impacts, as discussed in Sections 5.3 and 5.8 of the Draft EIR
In addition, there are no mechanisms in place beyond that required for SCAQMD Rule 2305 (which the proposed buildings would be exempt from) for documenting, tracking and monitoring the number of truck trips that access any site. CEQA requires that an EIR evaluate the Project based on reasonable assumptions and foreseeable actions. The trip generation estimates uses trip generation rates listed in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11 th Edition. The comment does not present any
evidence that truck trips associated with the Project would be greater than disclosed in the Draft EIR. There is no substantial evidence presented by this comment or by any of the information in the Project’s administrative record that contradicts the reasonable assumptions made in the Draft EIR about the expected Massachusetts Point Project 3. Response to Comments
City of Riverside 3-19
Final EIR
October 2025
number of truck trips. Introducing a cap on the number of trucks that can access the proposed buildings is not required under CEQA, nor would it be reasonable or feasible for the City to monitor and enforce such a requirement. Therefore, implementation of this measure is not feasible and the measure itself is not enforceable. This comment does not warrant any changes to the Draft EIR.

Comment A1.11: This comment suggests that the Lead Agency require the provision of electric vehicle charging stations or provide electrical infrastructure and appropriately sized electric panels. The comment suggests also requiring electrical hookups for truckers to plug in any onboard auxiliary equipment.

Response A1.11: As discussed on page 5.3 -6 of the Draft EIR, the Project is required to comply with the 2022 CALGreen Code, adopted by the City of Riverside Municipal Code in Chapter 16.07: Green Code, which requires the installation of electric truck charging infrastruct ure within truck parking areas to support future installation of charging stations when electric heavy -duty trucks are available. Regarding electric hookups for truckers to plug in onboard auxiliary equipment, Title 24 requires the installa tion of conduit at truck loading docks and correct electrical room sizing to ensure that tenants are able to provide plug ins at loading docks. Therefore, no additional mitigation measures are warranted.

Comment A1.12: This comment suggests that the Project include mitigation maximizing the use of solar energy by installing solar arrays.

Response A1.12: As discussed in Section 5.6, Energy, of the Draft EIR, the Project would be designed to be solar-ready, and the Project would be designed and built in such a manner as to facilitate the installation of solar photovoltaics in the future at the time a tenant occupies each building in accordan ce with Title 24. It should be noted that as of 2022, approximately one third of the power generated by Southern California Edison is from renewable sources, and this is anticipated to continue to increase under the State’s Renewable Portfolio Standard, which requires retail sellers of electric services to increase procurement from eligible renewable resources to 44 percent of total retail sales by 2024. The amount of retail electricity provided from renewable sources is expected to further increase significantly in order to meet the state goal of carbon neutrality by 2045. Additionally, as discussed in Section 5.6 of the Draft EIR, the Project would not have unusual Project characteristics that would cause the use of construction equipment to be less energy efficient compared with other similar construction sites in other parts of the state, and would result in a less- than- significant impact related to energy usage and no mitigation would be required. Therefore, implementation of this measure at this time is not feasible and the measure itself is not required.

Comment A1.13: This comment suggests that the Project include mitigation requiring use of light -colored paving and roofing materials.

Response A1.13: The analysis determined that the Project would not result in significant impacts that would necessitate additional mitigation measures such as those suggested by the commenter. Nevertheless, the Project Applicant is voluntarily incorporating light -colored paving and roofing materials as Project Design Feature (PDF) AQ-1 to further reduce potential operational air quality impacts in response to this comment.

Draft EIR Section 5.3, Air Quality, has been revised to reflect this update in Section 2.0, Errata, of this Final EIR and shown below. This correction does not change the conclusion of the EIR, and the findings remain the same.

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 Massachusetts Point Project 3. Response to Comments
City of Riverside 3-20
Final EIR
October 2025
would reduce operational air quality impacts. No quantitative credit was taken in the air quality analysis for this design feature.

Comment A1.14: This comment suggests that the Project includes mitigation requiring use of only Energy Star heating, cooling, and lighting devices.

Response A1.14: As discussed in Section 5.6 of the Draft EIR, the Draft EIR includes an analysis of the Project’s energy demand and demonstrates that energy consumption would not result in a significant impact under CEQA. Furthermore, the Project will be required to comply with the most recent Title 24 Building Energy Efficiency Standards and CALGreen Code, which establish rigorous energy efficiency requirements for building systems, cooling, and lighting. As the Project’s energy impacts are less than significant and subject to compliance with mandatory state energy codes, the suggested mitigation measures would not be required.

In addition, as discussed in Section 5.3, Air Quality , of the Draft EIR, the Project would result in less than significant air quality impacts. As such, mitigation measures to mitigate air quality impacts are not required.

Nevertheless, the Project Applicant is voluntarily incorporating the use of Energy Star heating, cooling, lighting and appliances as PDF AQ-2 to further reduce potential operational air quality impacts in response to this comment. Draft EIR Section 5.3, Air Quality , has been revised to reflect this update in Section 2.0, Errata, of this Final EIR and shown below. This correction does not change the conclusion of the EIR, and the findings remain the same.

5.3.9 Project Design Features
None.

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.

Comment A1.15: This comment suggests that the Project clearly marks truck routes with signs so that trucks do not travel next to or near sensitive land uses.

Response A1.15: Project Design Feature (PDF AQ -3) which states that the Project would be designed to include the installation of signs at every truck exit providing directional information to the trucks’ routes, has been added to the Project and included in the updated Air Quality, Energy, and GHG Analysis (Appendix B). This PDF is meant to 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. Draft EIR Section 5.3, Air Quality, has been revised to reflect this update in Section 2.0, Errata, of this Final EIR and as shown below. This correction does not change the conclusions of the EIR, and the findings remain the same.

5.3.9 Project Design Features
None.

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 duri ng the operation of the Project. No quantitative credit was taken in the air quality analysis for this design feature.

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-21
Final EIR
October 2025
Comment A1.16: This comment recommends that the Project is designed such that truck entrances and exits are not facing sensitive receptors in order to avoid trucks traveling past sensitive land uses to enter or leave the Project.

Response A1.16: Trucks would access the site regionally via SR-91 to Spruce Street and I-215 to 3rd Street, and are expected to primarily utilize Kansas Avenue, Massachusetts Avenue, and 3 rd Street to access the site, as discussed in Section 5.17 of the Draft EIR . The Project proposes five new driveway s: Driveway 1 would located to the northeast of the Project site, along Roberta Street ; Driveway 2 would be located on the northwest of the Project site, along Roberta Street; Driveway 3 would be located along Kansas Avenue (center); Driveway 4 would be located to the southwest of the Project site, along Kansas Avenue; Driveway 5 would be located along Massachusetts Avenue, near the southeast corner of the site (refer to Section 3.0 of the Draft EIR).

Of the five proposed driveways, Driveway 5 is closest to the nearest sensitive receptor, a housing assistance shelter located at 2801 Hulen Place east of the Project site, and to the nearest residential area located south of 3
rd Street. Driveway 5 would provide both passenger vehicle and truck access, as discussed in Section 3.0 of the Draft EIR. This driveway would be located approximately 67.3 meters west of the housing assistance shelter on Hulen Place and approximately 505.7 meters north of the sensiti ve receptors on 3 rd Street. Therefore, the Project is designed such that the driveways are not adjacent to the sensitive receptors located on Hulen Place or 3rd Street. Additionally, the Project site is currently an existing industrial facility, surrounded by other existing industrial uses, and would generate a nominal amount of new truck trips as compared to the existing condition. Furthermore, the Project Applicant is voluntarily including the following measures as Project Design Features (PDFs) to furthe r reduce potential exposure of nearby sensitive receptors.

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 polluta nts 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.

Comment A1.17: This comment recommends that the Project is designed so that truck check -in points are inside the Project to avoid queuing.

Response A1.17: As discussed on page 5.17-9 of the Draft EIR, onsite truck driveways have been evaluated by the City Planning Division and Engineering Department to ensure that the necessary queue length is provided to ensure trucks accessing the business park buildings d o not back onto Chicago Avenue, Massachusetts Avenue, or 3rd Street. In addition, once tenants are known for the proposed buildings, a tenant- specific queueing analysis would be prepared and reviewed by City Engineering prior to issuance of a building permit.

In addition, as discussed in Section 5.3, Air Quality , of the Draft EIR, the Project would result in less than significant air quality impacts. As such, mitigation measures to mitigate air quality impacts are not required.

Massachusetts Point Project 3. Response to Comments
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Final EIR
October 2025
Nevertheless, although the City Planning Division and Engineering Department have evaluated the proposed queue length and further analysis would be prepared prior to building permit issuance, the Project Applicant is voluntarily incorporating a check-in point inside the Project Site as PDF AQ-4 to further reduce potential air quality impacts in response to this comment. Draft EIR Section 5.3, Air Quality, has been revised to reflect this update in Section 2.0, Errata, of this Final EIR and shown below. This correction does not change the conclusion of the Draft EIR, and the findings remain the same.

5.3.9 Project Design Features
None.

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.

Comment A1.18: This comment recommends that the Project be designed so that truck circulation is located as far away as feasible from sensitive receptors.

Response A1.18: As discussed in Response A1.16, the Project would be designed such that Project driveways are not adjacent to or directly facing sensitive receptors. The City of Riverside adopted Good Neighbor Guidelines (GNG-2020) in November 2020.

The goals of the City’s GNG-2020 are to ensure that new industrial: (1) ensure air quality and health risks are evaluated, (2) evaluate and minimize noise impacts, and (3) protect residential uses and neighborhood character of the City. The City’s GNGs are codified in the City’s Municipal Code Title 19, Zoning. Air quality and health risk GNGS include the following: (1) Minimize exposure to diesel emissions for residential neighborhoods, schools, parks, playgrounds, day care centers, nursing homes, hospita ls, and other public places (Sensitive Receptors) situated in close proximity to the industrial uses; (2) In compliance with CEQA, conduct SCAQMD URBEMIS and EMFAC computer models to identify the significance of air quality impacts on Sensitive Receptors; (3) Minimize the air quality impacts of trucks on Sensitive Receptors; (4) Promote the installation of on-site electric hook-ups to eliminate idling of main and auxiliary engines during loading and unloading of cargo and when trucks are not in use – especially where transport refrigeration units (TRUs) are proposed to be used.

The City’s Planning division has reviewed the Project plans and determined that the proposed Project is in compliance with the City’s Good Neighbor Policy. Additionally, the Project is located on site of an existing industrial facility, surrounded by other existing industrial uses, and would generate a nominal amount of new truck trips past existing sensitive/residential receptors. The Project would follow existing City truck routes and would be routed away from sensitive receptors. No changes to the design would be required and no further response is warranted.

Comment A1.19: This comment recommends that the Project restrict overnight truck parking in sensitive areas by providing overnight truck parking inside the Project site.

Response A1.19: PDF AQ -5 which states that the Project would be designed to provide overnight truck parking inside the Project Site, has been added to the Project. This PDF is meant to encourage trucks to not park overnight near sensitive receptors and prevent further exposure to criteria pollutants. No quantitative credit was taken in the air quality analysis for this design feature. Draft EIR Sections 5.3, Air Quality , has Massachusetts Point Project 3. Response to Comments
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been revised to reflect this update in Section 2.0, Errata, of this Final EIR and as shown below. This correction does not change the conclusions of the EIR, and the findings remain the same.

5.3.9 Project Design Features
None.

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.

Comment A1.20: This comment suggests that the City of Riverside conduct a review of the following references: (1) State of California – Department of Justice: Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Ac t, (2) SC AQMD 2022 Air Quality Management Plan (specifically Appendix IV-A, Appendix IV-B, and Appendix IV-C), and (3) United States Environmental Protection Agency (U.S. EPA): Mobile Source Pollution - Environmental Justice and Transportation, and to incorporate additional mitigation measures as applicable to the Project.

Response A1.20: The City considered the references provided by SCAQMD when developing the mitigation measures for the Project. In addition, SC AQMD does not specify which mitigation measures they are recommending within the references. Furthermore, CEQA does not require adoption of every potential mitigation measure and only requires adoption of feasible mitigation that will “substantially lessen ” a project’s significant impacts (CEQA Guidelines Section 15041). The Draft EIR’s mitigation measures are consistent with and support the overarching recommendations in the provided references, as further discussed below.
(1) State of California – Department of Justice: Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act
The Draft EIR’s Air Quality analysis concluded that the Project would have less than significant impacts and determined that no mitigation is required. In addition, the Project is consistent with the State of California – Department of Justice: Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.

The purpose of the Attorney General’s Warehouse Projects: Best Practices document (Best Practices document) is to help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals; while CEQA analysis is project-specific, the Attorney General’s Warehouse Projects: Best Practices document provides information on feasible best practices and mitigation measures which have been adapted from other warehouse projects in California (Department of Ju stice, 2022, page 2).

The Best Practices document encourages jurisdictions to engage in proactive planning by adopting land use designations and zoning that channel development into appropriate areas, and setting minimum standards for logistics projects through general plan policies, local ordinances, and good neighbor policies (Department of Justice, 2022, page 3). As stated in Section 3, Project Description, of the Draft EIR, the Project site has a General Plan Land Use designation of Industrial (I) and is zoned as General Industrial. The primary intent of the Industrial land use designation is to allow for manufacturing and wholesaling, commercial uses, and warehouse and distribution facilities only at specific locations. The purpose of the Industrial zone is to provide areas appropriate for a wide variety of industrial, manufacturing, and support uses that have the potential to provide jobs and generate tax revenue in Riverside, while protecting residential neighborhoods, schools, Massachusetts Point Project 3. Response to Comments
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parks, playgrounds, day care centers, nursing homes, hospitals and other public places from nuisances or hazards associated with such activities. In addition, the City of Riverside adopted Good Neighbor Guidelines (GNG-2020) in November 2020. The goals of the City’s GNG- 2020 are to ensure that new industrial developments: (1) ensure air quality and health risks are evaluated, (2) evaluate and minimize noise impacts, and (3) protect residential uses and neighborhood character of the City. The City’s Planning division has reviewed the plans and determined that the proposed Project is in compliance with the City’s Good Neighbor Policy.

The Best Practices document also encourages robust community engagement and provides examples of best practices for community engagement for CEQA compliance (Department of Justice, 2022, page 4). The City engaged in community engagement, per CEQA Guideline s and City policies. A Notice of Preparation was published on December 12, 2024 to notify the public and other agencies about the Project, request their input/comments, and invite them to a virtual scoping meeting, which was held on Thursday, January 9, 2025.

The notice included a project description and was provided by mail to residents and posted on the City’s website. In addition, the Draft EIR was also circulated for a 45 -day public and public-agency review from Thursday, June 26
th to Monday, August11th, 2025. As set forth above, in response to public comments to the Draft EIR, the Project implemented new Project Design Features, including [add.] The Best Practices document provides warehouse siting and design considerations to reduce environmental and air quality impacts and recommends siting warehouse facilities at least 1,000 feet from property lines of the nearest sensitive receptor (Department of Justice, 2022, page 5). As discussed on page 5.3-19 of the Draft EIR, the closest sensitive receptors to the Project site is a housing assistance shelter located at 2801 Hulen Place, approximately 67.3 meters (or 221 feet) east of the Project site; however, while the 1,000 feet distance may be appropriate for larger industrial development, the Project-specific Air Quality, Energy, and GHG Report determined that the Project will not result in significant impacts to Air Quality, Energy, and GHG, nor will it result in significant health risk impacts, even to nearby sensitive receptors (Draft EIR page

5.3-22 through 5.3-21).

In addition, consistent with the warehouse siting and design considerations included in the Best Practices document, the Project’s design provides adequate amounts of on -site parking and complies with setbacks established by the City’s Code of Regulations. The truck courts are located in between the two buildings to shield trucking operations from public views (refer to Draft EIR Figure 3-8, Conceptual Site Plan). The Project would also include approximately 22,240 SF (or 0.51 acres) of ornamental landscaping around the perimeter of the site and in -between parking areas (refer to Draft EIR Figure 3 -12, Conceptual Landscape Plan).

In addition, the Project Applicant is voluntarily including PDF AQ-4, as discussed above in Response A1.17, to incorporate a truck check -in point inside of the Project site, consistent with Best Practices for siting and designing warehouse facilities, to further reduce potential air quality impacts. (2) SCAQMD 2022 Air Quality Management Plan (Appendix IV-A, Appendix IV-B, and Appendix IV-C) The Project would be consistent with the SCAQMD 2022 Air Quality Management Plan (AQMP), specifically Appendix IV-A, IV-B, and IV-C as follows:
a) Appendix IV-A – SCAQMD’s Stationary and Mobile Source Control Measures, included with the 2022 AQMP, aims to achieve the 2015 8 -hour ozone National Ambient Air Quality Standards by 2037. As the Project would not result in significant impacts for construction or operational VOC or NOx for stationary and mobile sources, the Project would therefore be consistent with the SCAQMD’s Stationary and Mobile Source Control Measures featured in Appendix IV-A of the 2022 AQMP. b) Appendix IV -B – CARB’s Strategy for South Coast, similarly to Appendix IV -A, identifies the strategies and controls to reduce ozone, specifically ground -level ozone. Ground -level ozone is Massachusetts Point Project 3. Response to Comments
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generated from NOx and VOC emissions. As the Project does not exceed SCAQMD’s thresholds of significance for NOx and VOC (refer to Section 5.3 of the Draft EIR), the Project is consistent with Appendix IV-B and would not conflict with CARB’s strategy for g round-level ozone control in the South Coast Air Basin.
c) Appendix IV -C – SCAG’s Regional Transportation Strategy and Control Measure ensures consistency within the AQMP with the Southern California Association of Government’s (SCAG’s) Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS) a nd Transportation Control Measures which addresses the 2015 8 -hour ozone standards in the South Coast Air Basin.

As discussed in Section 5.3 of the Draft EIR, the Project is consistent with SCAG’s RTP/SCS; in addition, the Project would not exceed SCAQMD’s significance thresholds of NOx or VOC emissions. As such, the Project would be consistent with SCAG’s Regional Transportation Strategy and Control Measures outlined in Appendix IV-C of the 2022 AQMP.
(3) United States Environmental Protection Agency (U.S. EPA): Mobile Source Pollution - Environmental Justice and Transportation
Regarding the United States Environmental Protection Agency (U.S. EPA): Mobile Source Pollution - Environmental Justice and Transportation, the Project’s potential environmental justice effects are social issues that are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)).

Consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include substantial discussion of environmental justice. Further, while CEQA requires that all feasible mitigation measures be utilized to minimize or eliminate any significant adverse impacts, as discussed in Section 5.3, Air Quality, of the Draft EIR, the Project would result in less than significant air quality impacts , including health risk impacts . As such, mitigation measures to mitigate air quality impacts are not required.

Comment A1.21: This comment discusses the applicability of South Coast Rule 2305 to the proposed Project and summarizes the requirements of Rule 2305 Warehouse Indirect Source Rule WAIRE Program. The comment states that project requirements, design features, and CEQA mitigation measures can be identified and implemented to help future warehouse operators meet their compliance obligations.

Response A1.21: The comment is informational in nature and does not raise a specific issue with the adequacy of the Draft EIR. South Coast Rule 2305 is applicable to buildings greater than 100,000 SF in size, as neither of the two buildings featured in the Project are greater than 100,000 SF in total building area, and are located on separate lots, Rule 2305 WAIRE Program would not be applicable. Because the comment does not express any specific concern or question regarding the adequacy of the Draft EIR, n o further response is required or provided.

Comment A1.22: This comment states that SCAQMD is a Responsible Agency since air permits are required and SCAQMD will be required to make a decision on the adequacy of the CEQA document for its own use in issuing discretionary approvals. The comment summarizes other requ irements for a Responsible Agency under CEQA. The comment states due to the requirements for Responsible Agencies, the Final EIR should be revised to include a discussion about any new stationary and portable equipment requiring SCAQMD permits and provide an evaluation of the air quality and greenhouse gas impacts.

Response A1.22: As described in Section 5.3, Air Quality, of the Draft EIR, it is anticipated that the proposed buildings would utilize two diesel-fueled fire pumps and two diesel-fueled emergency generators. To ensure a conservative analysis, the Draft EIR assumed that for the operation of the Project, the two diesel -fueled 238-horspower emergency generators would individually operate for up to 200 hours per year, which is conservative and consistent with SCAQMD’s Rule 1470, which limits stationary sources . The assumed two diesel-fueled 238-horsepower fire pumps would individually operate for up to 50 hours per year, which Massachusetts Point Project 3. Response to Comments
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would also be consistent with SCAQMD’s Rule 1470. These assumptions were incorporated into the Project’s Air Quality, Energy, GHG, and HRA analyses to provide a conservative estimate of potential operational emissions. Pages 8 through 10 of the Draft EIR Section 5.3, Air Quality, already include a summary of potentially applicable SCAQMD rules.

In response to this comment, Section 2.0, Errata , of this Final EIR has been updated to include additional SCAQMD rules identified by the commenter that were not featured in the Draft EIR, including Rules 201, 445, 461, 1110.2, 1166, 2305, and Regulation XIII, as shown below. Section 2.0 has also been updated to identify SCAQMD as a Responsible Agency, with potential subsequent approvals including issuance of permits for installation and operation of backup generators and fire pumps. The Project will remain subject to SCAQMD’s permitting authority, which ensures compliance with all applicable regulatory requirements related to air quality and toxic air contaminants. As the proposed Project is speculative industrial at this time, the applicable South Cost AQMD permits will be requested once a future tenant is identified. Accordingly, the Draft EIR provides a sufficient project description and analysis for reliance by SCAQMD in its role as a Responsible Agency under CEQA. Given these conservative assumptions and regulatory safeguards, the Draft EIR adequately addresses the comment, and no further revisions are warranted.

Draft EIR Sections 3.0, Project Description, and 5.3, Air Quality, have been revised to reflect these updates in Section 2.0, Errata, of this Final EIR and as shown below. This correction does not change the conclusions of the EIR, and the findings remain the same.

3.5 Discretionary Approvals and Permits
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.

5.3.2.3 Regional Regulations
SCAQMD Rules and Regulations
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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 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.

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• 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 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 – Volatile Organic Compound Emissions from Decontamination of Soil. 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 per 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 Massachusetts Point Project 3. Response to Comments
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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 shall be sprayed with water and/or approved vapor suppressant and adequately 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.

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.

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.

Comment A1.23: The commenter states that because SCAQMD will issue air permits, it will serve as a CEQA Responsible Agency. The comment references CEQA Guidelines Section 15096 regarding the duties of Responsible Agencies, including making findings, issuing a Statement of Overriding Considerations if necessary, and filing a Notice of Determination. The commenter further states that the Final EIR should identify SCAQMD as a Responsible Agency, evaluate all new stationary and portable equipment requiring air permits, and provide analysis of associated air quality, energy, and greenhouse gas impacts to ensure the adequacy of the CEQA document for AQMD’s approvals.

Response A1.23: As discussed, in Response A1.22, Section 2 .0, Errata, has been updated to adequately address SCAQMD as a responsible agency under CEQA, and no further revisions are warranted.

Draft EIR Section 3.0, Project Description, has been revised to reflect these updates in Section 2.0, Errata, of this Final EIR and as shown below. This correction does not change the conclusions of the EIR, and the findings remain the same.

3.5 Discretionary Approvals and Permits
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
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• 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.

Comment A1.24: This comment concludes the SCAQMD’s discussion and summarizes the standard practice for Lead Agencies when responding to Public Agencies comments. The comment also thanks the Lead Agency for giving the SC AQMD the opportunity to comment on the Draft EIR and contact information if future questions arise.

Response A1.24: The comment is conclusionary in nature and does not raise a specific issue with the adequacy of the Draft EIR. Because the comment does not express any specific concern or question regarding the adequacy of the Draft EIR, no further response is required or provided.

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Comment Letter A2: Riverside County Airport Land Use Commission, Date July 21, 2025

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3.2 Response to Comment Letter A2: Riverside County Airport Land Use Commission, Date July 21, 2025
Comment A2.1: This comment introduces the comment letter and states that the proposed Project is located within Zone E of March Air Reserve airport influence area. The comment states that due to the Project’s location and proposed legislative action (Change of Zone), t he Riverside County Airport Land Use Commission (ALUC) is required to review the Project for consistency with the March Airport Land Use Compatibility Plan. This comment included the application and contact information necessary to initiate th e required compatibility review.

Response A2.1: The proposed Project was reviewed and approved by the Riverside County Airport Land Use Commission on May 5, 2025. The ALUC Director’s Determination letter has been included as Appendix A of this Final EIR.

The following revisions have been included in Chapter 2, Errata:

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 required 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.

The Draft EIR analyzed the proposed Project buildings at a height of 46 feet. In accordance with the Conditions of Approval provided by the ALUC, incorporated as Mitigation Measures HAZ-2 through HAZ-5, the Project is consistent with the 2014 March Air Res erve Base/Inland Port Airport Land Use Compatibility Plan. Thus, this comment does not contain any information requiring further changes to the EIR. No further response is warranted.

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Comment Letter O1: Sierra Club and R-NOW, Dated August 11, 2025

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Final EIR
October 2025

3.3 Response to Comment Letter O1: Sierra Club and R-NOW, Dated August 11, 2025 Comment O1.1: This comment provides an intro duction to the comment letter and provides a summary of the proposed Project. The comment also states that the Project site is located in a census tract ranked in the 99th percentile for cumulative impacts in CalEnviroScreen4.0, making it one of the top one percent Environmental Justice neighborhoods in California.

Response O1.1: The comment is introductory in nature , provides a summary of the proposed Project, and does not raise a specific issue with the adequacy of the Draft EIR or raise any other CEQA issues. Because the comment does not express any specific concern or question regarding the adequacy of the Draft EIR, no further response is warranted.

Comment O1.2: The comment acknowledges that the Project, as an industrial infill development, would have lower potential impacts compared to greenfield projects. The comment expresses concern that the Project objectives and analysis are biased towards the Project . The comment also states that the Project is incompatible with the overlay zone goals, local and regional air quality, and perpetuates industrial harm to the community.

Response O1.2: This comment does not provide any substantial evidence that the Project would result in significant environmental impacts. The Project’s proposed Zone Change would correct the existing inconsistency between the site’s General Plan Land Use designation of Industrial (I), zoning designation of I - General Industrial, and Innovation District (ID) Overlay Zone subdistricts Employment Emphasis (EE) and Housing Emphasis (HE). As described in Section 5.3, Air Quality, of the Draft EIR, implementatio n of the proposed Project would not exceed thresholds related to air quality and impacts related to regional and localized air quality would be less than significant with implementation of existing regulations related to air quality, included as PPPs AQ -1 through AQ-4. These include compliance with SCAQMD Rules 403 (dust control), 1113 (low -volatile organic compounds paints), and 1470 (regulation of diesel -fuel internal combustion engines). The comment does not contain any information requiring changes to the EIR. No further response is warranted.

Comment O1.3: The comment states that environmental justice was not analyzed as a standalone topic in DEIR. The comment also states that warehouse best practices were not substantively addressed in the DEIR and requests that the Project be compared to Office of the Attorney General’s Warehouse Projects: Best Practices document.

Response O1.3: This comment does not provide any substantial evidence that the Project would result in a significant environmental impact. CEQA is an environmental protection statute that is concerned with physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (CEQA Guidelines Section 15360). Moreover, CEQA also requires a project to evaluate its impacts in relation to changes in an area’s population, housing needs and coverage under adequate public services. The Project’s potential environmental justice effects are social issues that are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and 15131(a)). Thus, consistent with CEQA, the Draft EIR includes an analysis of the Project’s potentially significant physical impacts on the environment and does not include substantial discussion of environmental justice.

The purpose of the Attorney General’s Warehouse Projects: Best Practices document (Best Practices document) is to help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals; while CEQA analysis is project-specific, the Attorney General’s Warehouse Projects: Best Practices document provides information on feasible best practices and mitigation measures which have been adapted from other warehouse projects in California (Department of Ju stice, 2022, page 2).

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-37
Final EIR
October 2025
The Best Practices document encourages jurisdictions to engage in proactive planning by adopting land use designations and zoning that channel development into appropriate areas, and s etting minimum standards for logistics projects through general plan policies, local ordinances, and good neighbor policies (Department of Justice, 2022, page 3). As stated in Section 3 .0, Project Description, of the Draft EIR, the Project site has a General Plan Land Use designation of Industrial (I) and is zoned as General Industrial. The primary intent of the Industrial land use designation is to allow for manufacturing and wholesaling, commercial uses, and warehouse and distribution facilities only at specific locations. The purpose of the Industrial zone is to provide areas appropriate for a wide variety of industrial, manufacturing, and support uses that have the potential to provide jobs and generate tax revenue in Riverside, while protecting residential neighborhoods, schools, parks, playgrounds, day care centers, nursin g homes, hospitals and other public places from nuisances or hazards associated with such activities. In addition, the City of Riverside adopted Good Neighbor Guidelines (GNG-2020) in November 2020. The goals of the City’s GNG -2020 are to ensure that new industrial: (1) ensure air quality and health risks are evaluated, (2) evaluate and minimize noise imp acts, and (3) protect residential uses and neighborhood character of the City. The City’s Planning division has reviewed the plans and determined that the proposed Project is in compliance with the City’s Good Neighbor Policy.

The Best Practices document also encourages robust community engagement and provides examples of best practices for community engagement for CEQA compliance (Department of Justice, 2022, page 4). The City engaged in community engagement, per CEQA Guideline s and City policies. A Notice of Preparation was published on December 12, 2024 to notify the public and other agencies about the Project, request their input/comments, and invite them to a virtual scoping meeting, which was held on Thursday, January 9, 2025.

The notice included a project description and was provided by mail to residents and posted on the city’s website. In addition, the Draft EIR was also circulated for a 45 -day public and public-agency review from Thursday, June 26th, 2025 and ending Monday, August 11th, 2025.

The Best Practices document provides warehouse siting and design considerations to reduce environmental and air quality impacts and recommends siting warehouse facilities at least 1,000 feet from property lines of the nearest sensitive receptor (Department of Justice, 2022, page 5). As discussed on page 5.3-19 of the Draft EIR, the closest sensitive receptors to the Project site is a housing assistance shelter located at 2801 Hulen Place, approximately 67.3 meters (or 221 feet) east of the Project site; however, while the 1,000 feet distance may be appropriate for larger industrial development, the Project-specific Air Quality, Energy, and GHG Report determined that the Project will not result in significant impacts to Air Quality, Energy, and GHG, nor will it result in significant health risk impacts (Draft EIR page 5.3-22 through 5.3-21).

In addition, consistent with the warehouse siting and design considerations included in the Best Practices document, the Project’s design provides adequate amounts of on -site parking and complies with setbacks established by the City’s Code of Regulations. The truck courts are located in between the two buildings to shield trucking operations from public views (refer to Draft EIR Figure 3-8, Conceptual Site Plan). The Project would also include approximately 22,240 SF (or 0.51 acres) of ornamental landscapi ng around the perimeter of the site and in -between parking areas (refer to Draft EIR Figure 3 -12, Conceptual Landscape Plan).

Lastly, the Best Practices document provides a list of suggested mitigation measures for air quality and greenhouse gas emissions, noise impacts, traffic impacts, and other significant environmental impacts (Department of Justice, 2022, page 7-13). As summarized in Table 1-1 of the Draft EIR, implementation of the proposed Project would not exceed any CEQA thresholds with implementation of the following Mitigation Measures (MM): MM BIO-1, MM CUL-1, MM GEO-1, MM HAZ-1, MM HAZ-2, MM HAZ-3, MM HAZ-4, MM HAZ-5, MM HAZ-6, MM HAZ-7, MM TCR-1, MM TCR-2, MM TCR-3, MM TCR-4. All impacts related to the following topics would be less than significant with implementation of the above -mentioned mitigation measures: Biological Resources, Cultural Resources, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, and Tribal Cultural Resources. All other environmental topics were found to have Massachusetts Point Project 3. Response to Comments
City of Riverside 3-38
Final EIR
October 2025
no impacts or less than significant impacts without mitigation in the Draft EIR. Although the Air Quality Report prepared for the Project determined that impacts to air quality would be less than significant, the Project Applicant is voluntarily including the following measures as Project Design Features (PDFs) to further reduce potential impact.

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 quantitati ve 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 polluta nts 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.

Draft EIR Section 5.3, Air Quality, has been revised to reflect these updates in Section 2.0, Errata, of this Final EIR and shown in the following Responses above: A1.13, A1.14, A1.15, A1.17, and A1.19 . This correction does not change the conclusion of the EIR, and the findings remain the same No further response is warranted.

Comment O1.4: The comment states that the cumulative project list omitted tens of millions of square feet of regional warehouse development. The comment states that Project impacts are not limited to a two- mile radius of the Project site and that there are over 4,000 w arehouses in the Inland Empire, including over 1,000 warehouses in Riverside county, as well as 13,000 acres of warehouse projects approved or under review. The comment requests a more comprehensive analysis of regional impacts of warehouses on transportation, jobs, air quality, and greenhouse gas emissions and provides a list of warehouse projects to be included.

Response O1.4: CEQA Guidelines Section 15130(b)(1) states that the information utilized in an analysis of cumulative impacts should come from one of the following, or a reasonable combination of the two:
• A list of past, present, and probable future projects producing related or cumulative impacts, including those projects outside the control of the lead agency; or • A summary of projections contained in an adopted local, regional, or statewide plan or related planning document that describes or evaluates conditions contributing to the cumulative effect.

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-39
Final EIR
October 2025
Pursuant to CEQA Guidelines Section 15355(b) cumulative impacts must be assessed by taking into account “the project when added to other closely related past, present, and reasonably foreseeable probably future projects.” In deciding which Related Projects must be analyzed, CEQA Guidelines Section 15130(b)(3) instructs the lead agency to “define the geographic scope of the area affected by the cumulative effect and provide a reasonable explanation for the geographic limitation used.” When assessing Related Projects lists specifically, courts ask “whether it was reasonable and practical to include the projects and whether, without their inclusion, the severity and significance of the cumulative impacts were reflected adequately.” ( City of Long Beach v. Los Angeles Unified School Dist. (2009) 176 Cal.App.4th 889, 906 (“ Long Beach”), quoting Environmental Protection & Information Center v. California Dept. of Forestry & Fire Protection (2008) 44 Cal.4th 459, 525.) But the selection of the assessment area for cumulative impacts is “left to the agencies’ expertise,” and “[a]bsent a showing of arbitrary action, [courts] assume that the agencies have exercised this discretion appropriately.” (Long Beach at 908, quoting in part Ebbetts Pass Forest Watch v. Department of Forestry & Fire Protection (2004) 123 Cal.App.4th 1331, 1351.) The City’s 2025 Traffic Impact Analysis Guidelines (TIA Guidelines) were utilized to determine the cumulative projects listed in Draft EIR Table 5 -1, Cumulative Projects List (Draft EIR Section 5.0, Environmental Impact Analysis). As discussed on page 14 of the TIA Guidelines, the City requires a ll projects within a one-mile radius from any project boundary to be included in the cumulative project’s list. For a conservative analysis (and as standard practice) the City’s Traffic Division requires a radius measuring one mile plus half of the longest side of the project. For this Project, following City’s guidance and standard practices, the radius for cumulative projects was determined to be 5,655 feet.

As such, the Project has adequately analyzed cumulative project impacts, including impacts on transportation, jobs, air quality, and greenhouse gas emissions. The comment does not identify substantial evidence showing that a cumulative impact would occur from its list of other projects located at a significant distance beyond the 5,655-foot radius from the Project, and does not contain any information requiring changes to the EIR.

No further response is warranted.

Comment O1.5: This comment states that the Project’s land-use analysis dismisse s the Employment and Housing Emphasis overlay zones. The comment also states that the approval of the Project could impact the implementation of the overlay zoning plan and compatibility of adjacent land uses.

Response O1.5: This comment does not provide any substantial evidence that the Project would result in a significant environmental impact. The Zone Change Amendment was discussed in the Draft EIR on pages 3 - 1, 3 -25, 3 -46, 5.11 -10, 5.11 -26, 5.14 -8, 5.14 -9. As discussed i n Section 3.0, Project Description , the proposed Project has a General Plan Land Use designation of Industrial (I) and is zoned I - General Industrial.

The site is also located within the Innovation District (ID) Overlay Zone, specifically within the Emplo yment Emphasis (EE) and Housing Emphasis (HE) subdistricts. The proposed Zone Change is still in alignment with the existing General Plan Land Use Designation. The proposed Zone Change would not affect the zoning designations or existing land uses of the neighboring parcels. The comment does not contain any information requiring changes to the EIR. No further response is warranted.

Comment O1.6: This comment states that the City of Riverside’s Good Neighbor Policy restricts the development of warehouses within certain setbacks of residential zoning . The comment also states that the City is proposing new guidelines that would introduce a cumulative impact standard that may affect the Project’s proposed parcel split and building sizes.

Response O1.6: Compliance with the City’s Good Neighbor Policy is to be verified by the City’s Planning division during the Design Review process. The City’s Planning division has reviewed the plans and determined that the proposed Project is in compliance with the City’s Good Neighbor Policy. The proposed Massachusetts Point Project 3. Response to Comments
City of Riverside 3-40
Final EIR
October 2025
site design does not identify potential significant environmental impacts. Thus, potential impacts related to compliance with the City’s Good Neighbor Policy would not occur.

The comment also references the Riverside City Council Meeting Agenda for August 19, 2025. The referenced guideline is a Planning Commission recommendation for revisions to industrial development standards that has not yet been adopted. As such, it is not applicable to the proposed Project. The comment does not present new information requiring changes to the Draft EIR. No further response is warranted.

Comment O1.7: This comment states that Draft EIR Table 5.14-6 indicated that the City of Riverside is job rich. The comment states that the City is not on track to add 43,000 plus units and that the 2050 projections in Connect SoCal 2024 are not based on actual trends. The comment states that the City is not job poor and does not need more warehousing jobs.

Response O1.7: This comment does not provide any substantial evidence that the Project would result in a significant environmental impact. As seen in Table 5.14-6 of the Draft EIR, the City of Riverside had a jobs to housing ratio of 1.68 in 2019, which would be considered job-rich. Based on SCAG’s 2024-2050 RTP/SCS population and growth forecast, the job to housing ratio is projected to decrease to 1.49 by 2050 , which would be considered housing-rich. The proposed Project would contribute to achieving a more balanced job to housing ratio by additional employment opportunities the community.

The comment expresses disagreement with SCAG’s long -range projections, stating they are not based on “actual trends.” The RTP/SCS is the region’s official growth forecast, developed through an extensive process, and has been adopted by SCAG for use by local agencies. Reliance on these adopted forecasts is consistent with CEQA practice and ensures consistency with regional planning assumptions. The comment does not present substantial evidence that SCAG’s projections are invalid, nor does it provide an alternative data source that would be more appropriate for the cumulative analysis.

The comment does not identify any new significant impact or deficiency in the Draft EIR analysis, and no further response or revision is required.

Comment O1.8: This comment concludes the letter by requesting that the Sierra Club Box Springs Group and R-NOW be notified of all documents and meetings related to the Project.

Response O1.8: The comment is conclusory in nature and does not raise a specific issue with the adequacy of the Draft EIR evaluation. As substantiated by the responses above, none of the conditions arise which would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5. No new significant environmental impact would result from the Project or from a new mitigation measure proposed to be implemented; there is no substantial increase in the severity of an environmental impact; no feasible project alternative or mitigation measure considerably different from others previously analyzed that would lessen the environmental impacts of the proposed Project; and the Draft EIR is not fundamentally inadequate or conclusory in nature.

Sierra Club Box Springs Group and R -NOW will be added to the notification list for the Project and no further response is warranted.

Massachusetts Point Project 3. Response to Comments
City of Riverside 3-41
Final EIR
October 2025
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Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-1
Final EIR
October 2025

4. Mitigation Monitoring and Reporting Summary

4.1 INTRODUCTION
The California Environmental Quality Act (CEQA) requires a lead or public agency that approves or carries out a project for which an Environmental Impact Report (EIR) has been certified, which identifies one or more significant adverse environmental effect s and where findings with respect to changes or alterations in the project have been made, to adopt a “…reporting or monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment” (Public Resources Code Sections 21081, 21081.6).

A Mitigation Monitoring and Reporting Program (MMRP) is required to ensure that adopted mitigation measures are successfully implemented. The City of Riverside is the Lead Agency for the Project and is responsible for implementation of the MMRP. This report describes the MMRP for the Project and identifies the parties that will be responsible for monitoring implementation of the individual mitigation measures in the MMRP.

4.2 MITIGATION MONITORING AND REPORTING PROGRAM
The MMRP for the Project will be active through all phases of the Project, including design, construction, and operation. The attached table identifies the mitigation program required to be implemented by the City of Riverside for the Project. The table identifies mitigation measures required by the City of Riverside to mitigate or avoid significant impacts associated with the implementation of the Project, the timing of implementation, and the responsible party or parties for monitoring compliance.

The MMRP also includes a column that will be used by the compliance monitor (individual responsible for monitoring compliance) to document when implementation of the measure is completed. As individual Plans, Programs, and Policies, Project Design Features (PDF), and mitigation measures are completed , the compliance monitor will sign and date the MMRP, indicating that the required actions have been completed.

Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-2
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Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-3
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Table 4-1: Mitigation Monitoring and Reporting Program
Mitigation Measure Implementation
Timing
Responsible
Party
Verification
Method
Date Completed
and Initials

AESTHETICS
PPP AES-1: Light and Glare. All lights shall be directed and/or shielded to prevent the light from adversely affecting adjacent properties. No structure or lighting feature shall be permitted which creates adverse glare. A photometric plan shall be provided that indicates the amount of light emanating from the proposed/existing light fixtures to comply with City of Riverside Municipal Code Chapter 19.556, Outdoor Lighting.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
PDF AES-1: Lighting Design. The Project’s lighting would be designed to adhere to the recommended lighting practices in the Attorney General's Warehouse Projects Best Practices. All Project lighting would be designed to be directed into the interior of the site. Additionally, all Project lighting would include use of full cut-off light shields and/or anti- glare lighting.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______

AIR QUALITY
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 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.

Prior to demolition,
grading, and
construction permits.

City of Riverside
Engineering
Division and
Building & Safety
Division.

City approval of
Final plans.

Initials: ______

Date: ______
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.

Prior to demolition
and construction
permits.

City of Riverside
Building & Safety
Division.

City approval of
Final plans.

Initials: ______

Date: ______
PPP AQ-3: Rule 1470. The Project is required to obtain permits from SCAQMD for the proposed diesel fire pumps and emergency generators Prior to issuance of
certificate of
occupancy.

City of Riverside
Building & Safety
Division.

City approval of
Final plans.

Initials:
______
I
I
I
Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-4
Final EIR
October 2025
Mitigation Measure Implementation
Timing
Responsible
Party
Verification
Method
Date Completed
and Initials
and would be required to comply with Rule 1470, regulating the use of diesel-fueled internal combustion engines.

Date: ______
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.

Prior to demolition
and construction
permits.

City of Riverside
Building & Safety
Division.

City approval of
Final plans.

Initials: ______

Date: ______
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.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
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.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
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.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
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 roadway s, 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.

Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
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 Prior to Project
Approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
I
Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-5
Final EIR
October 2025
Mitigation Measure Implementation
Timing
Responsible
Party
Verification
Method
Date Completed
and Initials
quantitative credit was taken in the air quality analysis for this design feature.

BIOLOGICAL RESOURCES
Mitigation Measure BIO -1: Nesting Birds. Vegetation within and surrounding the Project site has the potential to provide refuge cover from predators, perching sites and favorable conditions for avian nesting that could be impacted by construction activities associated with the Project. Nesting bi rds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (Sections 3503, 3503.3, 3511, and 3513 of the California Fish and Game Code prohibit the take, possession, or destruction of birds, their nests or eggs). In order to protect migratory bird species, a nesting bird clearance survey should be conducted prior to any ground disturbance or vegetation removal activities that may disrupt the birds during the nesting season.

Consequently, if avian nesting behaviors a re disrupted, such as nest abandonment and/or loss of reproductive effort, it is considered “take” and is potentially punishable by fines and/or imprisonment.

If construction occurs between February 1st and August 31st, a pre - construction clearance survey for nesting birds should be conducted within three (3) days of the start of any vegetation removal or ground disturbing activities to ensure that no nesting bi rds will be disturbed during construction. The biologist conducting the clearance survey should document a negative survey with a brief letter report indicating that no impacts to active avian nests will occur. If an active avian nest is discovered during the pre -construction clearance survey, construction activities should stay outside of a no- disturbance buffer. The size of the no-disturbance buffer will be determined by the wildlife biologist and will depend on the level of noise and/or surrounding anthr opogenic disturbances, line of sight between the nest and the construction activity, type and duration of construction activity, ambient noise, species habituation, and topographical barriers. These factors will be evaluated on a case -by-case basis when de veloping buffer distances. Limits of construction to avoid an active nest will be established in the field with flagging, fencing, or other appropriate barriers; and construction personnel will be instructed on the sensitivity of nest areas. A biological monitor should be present to delineate the boundaries of the buffer area and to monitor the active nest to ensure that nesting behavior is not adversely affected by the construction activity. Once the young have Prior to issuance of
grading permits.

City of Riverside
Engineering
Division and
Building & Safety
Division.

Submittal of Pre-
construction
Clearance Survey
report to City by
Qualified
Biologist.

Initials: ______

Date: ______
I I
Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-6
Final EIR
October 2025
Mitigation Measure Implementation
Timing
Responsible
Party
Verification
Method
Date Completed
and Initials
fledged and left the nest, or the nest otherwise becomes inactive under natural conditions, construction activities within the buffer area can occur.

CULTURAL RESOURCES
PPP CUL-1: 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 He alth 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. T he 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 proponen t 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)).

During ground-
disturbing activities.

City of Riverside
Community &
Economic
Development
Department and
Building & Safety
Division.

Provide evidence
to the City that
developer/permit
holder has
complied with
State Health and
Safety Code
Section 7050.5.

Provide evidence
to the City that
the San
Bernardino County
Coroner has
contacted the
Native American
Heritage
Commission within
24 hours of
discovery.

Initials: ______

Date: ______
I I
Massachusetts Point Project 4. Mitigation Monitoring and Reporting Program City of Riverside 4-7
Final EIR
October 2025
Mitigation Measure Implementation
Timing
Responsible
Party
Verification
Method
Date Completed
and Initials
Mitigation Measure CUL -1: Inadvertent Discovery of Archaeological Resource. During implementation of the project, in the event that archaeological materials are encountered during ground -disturbing activities, work must be halted within 50 feet of the find until it can be evaluated by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior’s Standa rds for Professional Archaeology (United States Department of the Interior, 1983).

Construction activities may continue in other areas. If the find is considered a “resource” the archaeologist shall pursue either protection in place or recovery, salvage and treatment of the deposits. Recovery, salvage and treatment protocols shall be developed in accordance with applicable provisions of Public Resource Code Section 21083.2 and CEQA Guidelines 15064.5 and 15126.4 in consultation with the City.

Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if unique archaeological resources cannot be preserved in place or left in an undisturbed state, recovery, salvage, and treatment shall be required at the developer/applicant’s expense.

During ground-
disturbing activities.

City of Riverside
Community &
Economic
Development
Department and
Building & Safety
Division.

Provide evidence
to the City that a
qualified
Archeological has
been retained.

Submittal of
report that
documents the
finding to the City.

Initials: ______

Date: ______

GEOLOGY AND SOILS
PPP GEO-1: CBC Compliance. The Project is required to comply with the California Building Standards Code (CBC) as included in Chapter 16.08 of the Riverside Municipal Code to preclude significant adverse effects associated with seismic and soils hazards. CBC -related and geologist an
d/or civil engineer specifications for the proposed Project are required to be incorporated into grading plans and building specifications as a condition of construction permit approval.

Prior to grading and
construction permits.

City of Riverside
Engineering
Division and
Building & Safety
Division.

City approval of
construction plans.

Initials: ______

Date: ______
Mitigation Measure GEO -1: Paleontological Resources. Construction plans and specifications shall state that in the event that potential paleontological resources are discovered during excavation, grading, or construction activities, work shall cease within 50 feet of the find until a qualified paleontologist (who meets the
Society of Vertebrate
Paleontology’s (SVP, 2010) definition for qualified profession paleontologist) has evaluated the find. If a fossil is determined to be significant, the qualified paleontologist shall implement a paleontological salvage program to remove the resources from their location, following the guidelines of the SVP (2010). Any fossils encountered and recovered shall be prepared to the point of identification, catalogued, and curated at a public, non -profit institution During ground-
disturbing activities.

City of Riverside
Community &
Economic
Development
Department and
Building & Safety
Division.

City approval of
construction plans.

Halt any work in
the event of
paleontological
resource
discovery.

Provide evidence
to the City that a

Initials: ______

Date: ______
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with a research interest in the material and with retrievable storage, such as the Western Science Center in Riverside County, if such an institution agrees to accept the fossils. If no institution accepts the fossil collection, they shall be donated to a local school in the area for educational purposes. Accompanying notes, maps, and photographs shall also be filed at the repository and/or school.

If any fossil remains are discovered, the qualified paleontologist shall make a recommendation whether monitoring shall be required for the continuance of earth moving activities. Prior to commencement of grading activities, the City of Riverside Public Works Department, shall verify that all project grading and construction plans specify the requirements herein related to the unanticipated discovery of paleontological resources.

After completion of the salvage and curation of any resources, the qualified paleontologist shall prepare a report summarizing the results of the monitoring and salvage efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall be submitted to the City Director of the City Community Development Department, or designee, and the Western Science Center in Riverside County.
qualified
paleontologist has
been retained.

Submittal of
report that
documents the
finding to the City.

HAZARDS AND 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 coverage under the construction genera l 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.

Prior to issuance of
any grading
permits.

City of Riverside
Public Works
Department.

Provide evidence
of compliance with
the NPDES
requirement to the
City Public Works
Department.

Submit a NOI,
develop and
submit a SWPPP,
and submit a
MMRP for the
construction site.

Initials: ______

Date: ______ 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 the planned excavation contractor possesses a current SCAQMD Rule 1166 Various Locations Mitigation Plan. The excavation contractor’s Rule 1166 plan would provide for Prior to issuance of
grading or
excavation permits.

City of Riverside
Building and
Safety Division.

Submit verification
to the City
Building and
Safety Division
that the planned

Initials: ______

Date: ______
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compliance with these requirements provided the plan remains valid and is approved by SCAQMD: Monitor for VOC contamination at least once every 15 minutes commencing at the beginning of excavation or grading in areas where VOCs are suspected to potentially be present 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 shall be sprayed with water and/or approved vapor suppressant and 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. excavation
contractor
possesses a
current SCAQMD
Rule 1166 Various
Locations
Mitigation Plan.

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.

Prior to Project
approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials: ______

Date: ______
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 iden tify, 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 fo r 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).

Prior to issuance of
a grading or
excavation permit.

Santa Ana
Regional Water
Quality Control
Board.

Santa Ana
Regional Water
Quality Control
Board approval
of SMP and HSP.

Initials: ______

Date: ______
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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 requirement s, 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 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.

Mitigation Measure 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.

Prior to Project
approval.

City of Riverside
Planning Division.

City approval of
Final plans.

Initials:
______

Date: ______
Mitigation Measure 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 Prior to Project
approval.

City of Riverside
Planning Division.

City approval of
Final plans and
Conditions of
Approval.

Initials: ______

Date: ______
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towards an aircraft engaged in a straight final approach 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 product ion 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 demol ition 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. Any use which results in a hazard to flight.

Mitigation Measure HAZ -4: Notice of Airport in Vicinity. The “Notice of Airport in Vicinity” shall be provided to all prospective purchasers and occupants of the property.

Prior to Occupancy. Project Applicant. Provide evidence to RCALUC that
the “Notice of
Airport in Vicinity”
has been
provided to
prospective
purchasers and
occupants of the
property.

Initials: ______

Date: ______
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.

Prior to Occupancy. Project Applicant. Provide
notification of any
land use having
electromagnetic
radiation to
RCALUC.

Initials: ______

Date: ______

HYDROLOGY AND WATER QUALITY
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) Prior to issuance of
any grading
permits.

City of Riverside
Public Works
Department.

Provide evidence
of compliance with
the NPDES
requirement to the
City Public Works
Department.

Initials: ______

Date: ______
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and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site.

Submit a NOI,
develop and
submit a SWPPP,
and submit a
MMRP for the
construction site.

PPP HYD -2: WQMP . Prior to the issuance of any grading permits, a completed Water Quality Management Plan (WQMP) shall be submitted to and approved by the City’s Public Works Department. The WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development Project in order to minimize the adverse effects on receiving waters.

Prior to issuance of
any grading
permits.

City of Riverside
Public Works
Department.

City’s Public
Works
Department
approval of
WQMP.

Initials: ______

Date: ______

PUBLIC SERVICES
PPP PS-1: The Project is required to pay school impact fees in accordance with SB 50 at the time of building permit issuance. The school impact fee for commercial/industrial developments within the RUSD boundary is $0.84 per SF, which would equal approximately $167, 874 for the Project.

At the time of
building permit
issuance.

Riverside Unified
School District.

Provide evidence
to City that the
school impact fees
have been paid.

Initials: ______

Date: ______

RECREATION
PPP R-1: Park and Recreation Development Fees. Pursuant to Municipal Code Chapters 16.44, 16.60, and 16.76, park development fees are imposed on the construction or placement of applicable nonresidential construction in accordance with the schedule of fees adopted by the City Council.

Prior to the issuance
of a building permit.

City of Riverside
Parks and
Recreation
Department.

Provide evidence
to City that the
park development
fees have been
paid.

Initials:
______

Date: ______

TRANSPORTATION
PDF TRA -1: Chicago Avenue/Massachusetts Avenue Intersection Improvements: The Project would change the intersection control on Chicago Avenue/Massachusetts Avenue intersection to all -way stop (AWSC) control.

Prior to the issuance
of Certificate of
Occupancy.

City of Riverside
Public Works
Department –
Traffic Division.

City approval of
Final Plans.

Initials:
______

Date: ______
PDF TRA -2: Chicago Avenue/3rd Street Intersection Improvements:

The Project would implement protected -permissive left-turn phasing for the northbound and southbound left -turn approaches by installing flashing yellow signal head and “Left Turn Yield On Flashing” sign on Chicago Avenue/3rd Street intersection.

Prior to the issuance
of Certificate of
Occupancy.

City of Riverside
Public Works
Department –
Traffic Division.

City approval of
Final Plans.

Initials: ______

Date: ______
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TRIBAL CULTURAL RESOURCES
Mitigation Measure CUL -1: Inadvertent Discovery of Archaeological Resource. As listed in Section 5.5, Cultural Resources.

During ground-
disturbing activities.

City of Riverside
Community &
Economic
Development
Department and
Building & Safety
Division.

Halt any work in
the event of
inadvertent
discoveries of
archeological
resources.

Provide evidence
to the City that a
qualified
Archeological has
been retained.

Submittal of
report that
documents the
finding to the City.

Initials: ______

Date: ______
MM-TCR-1: Prior to grading permit issuance, if there are any changes to project site design and/or proposed grades, the Applicant and the City shall contact consulting tribes to provide an electronic copy of the revised plans for review. Additional consultation shal l occur between the City, developer/applicant, and consulting tribes to discuss any proposed changes and review any new impacts and/or potential
avoidance/preservation of the cultural resources on the project site. The City and the developer/applicant shal
l make all attempts to avoid
and/or preserve in place as many cultural and paleontological resources as possible that are located on the project site if the site design and/or proposed grades should be revised. In the event of inadvertent discoveries of archaeological resources, work shall temporarily halt until agreements are executed with consulting tribe, to provide tribal monitoring for ground disturbing activities.

Prior to grading
permit issuance.

City of Riverside
Engineering
Division and
Building & Safety
Division.

Provide copy of
consultation logs
showing
Applicant’s effort
to contact
interested tribes
and the outcome
of any such
consultation Halt
any work in the
event of
inadvertent
discoveries of
archeological
resources.

Initials: ______

Date: ______
MM-TCR-2: Project Archaeologist: Prior to the issuance of a grading permit, the Property Owner/Developer shall provide a letter from a County certified Archaeologist and Paleontologist stating that the Property Owner/Developer has retained these individuals, and that the Prior to the issuance
of a grading permit.

City of Riverside
Building & Safety
Division.

Provide a letter to
the City from a
certified
Archaeologist and
Paleontologist

Initials: ______

Date: ______
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Archaeologist and Paleontologist shall be on site during all grading and other significant ground-disturbing activities.

MM-TCR-3: Treatment and Disposition of Cultural Resources: In the event that Native American cultural resources are inadvertently discovered during the course of grading for this project, the following procedures will be carried out for treatment and disposition of the discoveries:

1. Consulting Tribes Notified: Within 24 hours of discovery, the consulting tribe(s) shall be notified via email and phone. The developer shall provide the city evidence of notification to consulting tribes. Consulting tribe(s) will be allowed access to the discovery, in order to assist with the significance evaluation.

2. Temporary Curation and Storage: During the course of construction, all discovered resources shall be temporarily curated in a secure location on site or at the offices of the project archaeologist. The removal of any artifacts from the project site will need approval of the consulting tribe(s); and

3. Treatment and Final Disposition: The landowner(s) shall relinquish ownership of all cultural resources, including sacred items, burial goods, and all archaeological artifacts and non -human remains as part of the required mitigation for impacts to cultural resources to the consulting tribe (s). The Applicant shall relinquish the artifacts through one or more of the following methods and provide the City of Riverside Community and Economic Development Department with evidence of same:
a. Accommodate the process for on-site reburial of the discovered items with the consulting Native American tribes or bands. This shall include measures and provisions to protect the future reburial area from any future impacts. Reburial shall not occur until
all cataloguing and basic recordation have been
completed;
b. Upon consultation with the tribe(s) and if parties agree that reburial on project site is not feasible, a curation agreement with an appropriate qualified repository within Riverside County that meets federal standards per 36 CFR Part 79, if agreed upon by the tribe(s), and therefore will be
professionally curated. The collections and associated records shall be transferred, including title, to an appropriate curation During ground-
disturbing activities.

City of Riverside
Community &
Economic
Development
Department and
Building & Safety
Division.

Provide the City
that with evidence
of notification to
consulting tribes in
the event of
inadvertent
discoveries; a
copy of the
completed Phase
IV Monitoring
Report.

Initials: ______

Date: ______
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facility within Riverside County, to be accompanied by payment of the fees necessary for permanent curation;
c. If more than one Native American tribe or band is involved with the project and cannot come to a consensus as to the disposition of cultural materials, they shall be curated at the Western Science Center or Museum of Riverside by default; and
d. At the completion of grading, excavation, and ground - disturbing activities on the site, a Phase IV Monitoring Report shall be submitted to the City documenting monitoring activities conducted by the project archaeologist and Native Tribal Monitors within 6 0 days of completion of grading. This report shall document the impacts to the known resources on the property; describe how each mitigation measure was fulfilled; document the type of cultural resources recovered and the disposition of such resources; pro vide evidence of the required cultural sensitivity training for the construction staff held during the required pre -
grade meeting; and, in a confidential
appendix, include the daily/weekly monitoring notes from the archaeologist. All reports produced will be submitted to the City of Riverside, Eastern Information Center, and consulting tribes.

MM-TCR-4: Cultural Sensitivity Training: The Secretary of Interior Standards County certified archaeologist and Native American monitors shall attend the pre-grading meeting with the developer/permit holder’s contractors to provide Cultural Sensitivity Training for all construction personnel. This shall include the procedures to be followed during ground disturbance in sensitive areas and protocols that apply in the event that unanticipated resources are discovered. Only construction personnel who have rece
ived this training can conduct construction and disturbance activities in sensitive areas. A sign -in sheet for attendees of this training shall be included in the Phase IV Monitoring Report.

Prior to start of
grading.

City of Riverside
Planning Division.

Provide City with
sign-in sheet from
Cultural Sensitivity
Training for all
construction
personnel and
included in the
Phase IV
Monitoring Report.

Initials: ______

Date: ______

UTILITIES AND SERVICE SYSTEMS
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 coverage under the construction genera l 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 Prior to issuance of
any grading
permits.

City of Riverside
Public Works
Department.

Provide evidence
of compliance with
the NPDES
requirement to the
City Public Works
Department.

Initials:
______

Date: ______
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a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site.

Submit a NOI,
develop and
submit a SWPPP,
and submit a
MMRP for the
construction site.

PPP HYD -2: WQMP . Prior to the issuance of any grading permits, a completed Water Quality Management Plan (WQMP) shall be submitted to and approved by the City’s Public Works Department. The WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development Project in order to minimize the adverse effects on receiving waters.

Prior to issuance of
any grading
permits.

City of Riverside
Public Works
Department.

City’s Public
Works
Department
approval of
WQMP.

Initials: ______

Date: ______

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