Twentynine Palms City Council
March 23, 2026

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the Solar Project will not be detrimental to the public health, safety or welfare, or materially injurious to uses, properties or improvements in the vicinity. As further described in the Environmental Impact Report, the Solar Project has been appropriately sited and conditioned to avoid or minimize impacts to air quality, noise, lighting, glare, traffic, and other potential impacts to other uses within the vicinity of the Solar Project site. Appropriate mitigation measures, conditions of approval, and compliance with Mojave Desert Air Quality Management District requirements have been incorporated into the Solar Project design to minimize potential impacts regarding Valley fever.

C. That the proposed site is adequate in size and shape to accommodate the use and integrate it with the existing and planned uses in the vicinity.

The Solar Project site encompasses approximately 184 gross acres, which exceeds the minimum acreage requirements for solar projects. As noted above, it incorporates setbacks in compliance with the adopted Renewable Energy (E) zone regulations. The Solar Project is located over 1,400 feet from the closest residence and has been relocated farther north to avoid potential impacts to more densely populated residential areas south of Two Mile Road. The Solar Project will be accessed by a private driveway from Two Mile Road and will not impact travel along other local streets.

SECTION 3. Conditional Use Permit. The Solar Project is hereby approved on the Property subject to all Conditions of Approval. The Solar Project shall not exceed 184 acres in size, and approximately 160,000 solar panels arranged into rows of approximately 720 ground-mounted solar panel racks each 104 feet wide and 252 feet long, separated by 20-foot wide service/maintenance drives. A total of approximately 170 inverters will be connected to the panels and consolidated throughout the solar field. The solar panels will be mounted on pilons, at a fixed 21 degree angle, facing south. Each module is rated at 395 WDC, with the capacity to generate approximately 51.35 to 63.2 MW, depending on the number of solar panels ultimately installed. Power generated by the solar field will be routed to on-site transformers, and then via an underground line routed to the existing Southern California Edison substation located on the south side of Two Mile Road, east of Canyon Road. The interconnection line will extend from the Solar Project’s south boundary, down a new driveway (north of the existing Easy Street) to Two Mile Road, then westerly on Two Mile Road to the substation.

SECTION 4. CEQA. The City Council has reviewed, considered, and by way of adoption of Resolution No. ____, certified the Environmental Impact Report (SCH #2024021042), adopted the Mitigation Monitoring and Reporting Program, and the related Statement of Overriding Considerations for this Project. The Environmental Impact Report (SCH# 2024021042) prepared for the Project is complete and adequate for the consideration of this Conditional Use Permit approval.

SECTION 5. Severability. If any section, subsection, sentence, clause, phrase, or portion of this Resolution, is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining

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portions of this Resolution. The City Council hereby declares that it would have adopted this Resolution, and each section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof be declared invalid or unconstitutional.

SECTION 6. Effective Date. This Resolution shall take effect thirty (30) days from the date of adoption of the last of the Project Approvals approved by City. If any of the Project Approvals are denied, not approved, or are otherwise invalidated, this Resolution shall be of no force and effect.

PASSED, APPROVED AND ADOPTED at an adjourned regular meeting of the City Council of the City of Twentynine Palms held on this 23rd day of March, 2026.

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________________________________________
________, Mayor
ATTEST:
_________________________________
Cindy Villescas, CMC, City Clerk
APPROVED AS TO FORM:
_________________________________
A. Patrick Muñoz, City Attorney
I hereby certify that the foregoing is a true copy of Resolution No. ___, duly adopted by the City Council of the City of Twentynine Palms in a meeting held on the __th day of ________, 2026, in Twentynine Palms, California by the following vote, to wit.

AYES: COUNCIL MEMBERS:

NOES:COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:
________________________________________
Cindy Villescas CMC, City Clerk

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EXHIBIT A

CONDITIONS OF APPROVAL
City of Twentynine Palms
Conditions of Approval
Project: General Plan Amendment, Rezoning, Development Code Amendment and Conditional Use Permit, DCA23-000016, REZ23-00001, GPA23-00001, CUP23-00009, REZ24-00001, E-Group PS Solar Project
Location: North of Two Mile Road and west of Noels Knoll Road (extended).

Assessor’s Parcel Nos. 0612-201-05 and 0612-201-01.

Approval Date: March 23, 2026
Deadline to Begin Construction: March 23, 2029
Applicant: Peter Bobro
E-Group PS, LLC.
40764 Winchester Road, Suite 590,
Temecula, CA 92591

CONDITIONS OF APPROVAL
Conditional approval is granted by the City Council, acting as the Approval Authority, for

1. A General Plan Amendment (GPA23-00001) to create the Renewable Energy (E) land designation, re-designating the land use designation from Rural Living (RL-5) to Renewable Energy (E).

2. A Rezoning (REZ23-00001) to redesignate the zoning on the subject site from Rural Living (RL-5) to Renewable Energy (E) and (REZ24-000001) to redesignate the zoning on the subject site from Single Family Residential – Estate (RS-E) to SingleFamily Residential (RS-1).

3. A Development Code Amendment (DCA23-000016) to create the Renewable Energy (E) zone, including development standards.

4. A Conditional Use Permit (CUP23-00009) to allow the development of the Solar Project on the Renewable Energy portion of the property.

5. A Development Agreement (DA23-000001) to establish a Community Benefit Package with a schedule of payments to the City from the Applicant for the life of the project.

The development of the project includes:

GENERAL DESCRIPTION

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E-Group PS, LLC (E-Group or the “Applicant”) is proposing the construction and operation of the 29Palms Solar Project, a 50-megawatt (MW) solar generation facility in the City of Twentynine Palms (the “Project”). The Project is proposed to be located on 184 acres of two undeveloped parcels on the western side of the City (APNs 0612- 201-05 and 0612-201-01) north of Two Mile Road (the “Site”). The Project will primarily consist of photovoltaic (PV) panels placed on fixed tilt foundation, inverters and transformers, electrical cabling and communication lines, on-site switchgear, generation-tie lines, access roads, and a security fence.

The Project will connect to the Southern California Edison (SCE) transmission network at the Carodean Substation, located approximately one-half mile away from the Site across Two Mile Road. Construction is proposed to begin in January 2026, with the Project becoming commercially operational by January 2027. The operational lifespan of the facility is estimated to be 35 years.

Part of the Project also includes the rezoning of 60 acres in the southern portion of the Property from Rural Living (RL-5) to Single Family Residential, 1 acre minimum (RS1) in order to comply with the No Net Loss provisions in Senate Bill 330.

APPROVAL DATE:

EXPIRATION OF APPROVAL, IF NO CONSTRUCTION OCCURS: (Two years after approval date).

GENERAL CONDITIONS:

G1. All conditions are continuing conditions. Failure of the applicant and/or operator to
comply with any of the said Conditions at any time may result in the revocation of the Conditional Use Permit and Site Plan and Design Review and/or citation for code violation.

G2. The applicant shall be responsible for payment of all applicable fees, including reimbursement for all city expenses in ensuing compliance with the Conditions of Approval.

G3. The applicant shall provide a signed copy of the Conditions of Approval to the Planning
Division within ten (10) days of approval.

G4. No implementing permits (i.e. grading or building permits) will be issued or processed
by the City of Twentynine Palms until all of the legislative actions associated with this

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development have been fully adopted and are effective.

G5. The applicant shall, at its sole cost and expense, indemnify, defend (with counsel
selected by the City), release, and hold harmless the City and any agency or instrumentality thereof, including any of its officers, employees, commissions, and
agents (hereinafter the “Indemnities”), from and against any and all claims, actions, or proceedings, of any type or nature, arising out of or in any way relating to the processing and/or approval of this Project. The obligations set forth in this Condition shall include, but not be limited to, suits, damages, judgments, costs, expenses, liens, levies, attorney fees or expert witness fees that may be asserted by any person or entity against the indemnitees, arising out of or relating to the processing or approval of this Project, without regard to any allegations of fault on the part of the Indemnities. In the event the obligation to defend or indemnify the Indemnitees as set forth herein should arise, upon demand by the Community Development Director the applicant shall within 10 calendar days, deposit an amount with the City which the Community Development Director reasonably deems necessary to secure such obligation.

This deposit may be used by City to pay the defense or indemnification obligations arising hereunder; and, further, should any such amounts be utilized by the City the deposit shall be replenished by the applicant within 10 calendar days of any demand by the Community Development Director to do so. The amount of the deposit required hereunder may be increased or decreased at any time by the Community Development Director, in his discretion, based upon his determination as to the funds reasonably necessary at any given time to ensure compliance with the obligations hereof, and any demand to increase the deposit shall be complied with within 10 calendar days. Any amounts deposited and ultimately not utilized shall be returned to the applicant.

G6. The Applicant shall ascertain and comply with requirements of all State, County and Local agencies as are applicable to the proposed project.

G7. The applicant is required to obtain and maintain a current City of Twentynine Palms
Business License.

G8. Approval of General Polan Amendment No. 23-000001, General Plan Amendment No. 24-000001 and Conditional Use Permit no. 23-000009 shall be contingent upon the final approval of Rezoning 23-000001, Rezoning 24-000001, Development Code Amendment No. 23-00016, and Development Agreement No. 23-000001. In the event that any of the entitlements related to this Project are either not approved, or fail to become effective, or are challenged and later invalidated for any reason, the remainder of the entitlements related to the Project shall be automatically be deemed null and void.

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PLANNING
P1. This Conditional Use Permit and Site Plan and Design Review shall be null and void if
construction has not commenced within two (2) years of the date of approval.

Extensions of time may be granted by the Planning Division, in conformance with the City of Twentynine Palms Development Code. The applicant is responsible for the initiation of an extension request.

P2. Prior to commencement of operation of the commercial solar field, the applicant shall record a lot line adjustment, lot split, or other similar instrument on the Site that, to the satisfaction of the Community Development Director, accurately defines and separates the solar project site from the remainder of the site.

P3. On-site utilities shall be underground pursuant to Chapter 19.94 (Utilities) of the City’s Development Code, or as amended by City Council.

P4. Pursuant to Section 19.73.040 of the Development Code, any areas within the front
setback not improved with drive aisles, wall, signage or similar features shall be landscaped.

P5. Prior to the issuance of any permits, the applicant shall submit Landscape Plans to the Planning Division showing size, type and location of all plants and irrigation system. Landscaping shall be installed at the quantity and quality that is presented on the plans.

P6. On-site circulation shall be provided and maintained as identified on the approved site plan. Drive aisles shall be paved or made of compacted gravel.

P7. The applicant shall install a trash enclosure sized to accommodate a trash container
in conformance with Chapter 19.92 of the City’s Development Code.

P8. The property owner/applicant shall keep the property neat, clean, and in good physical
condition including open spaces, driveways, and landscaping.

P9. All outdoor lighting shall conform to Development Code Chapter 19.78 (Lighting Standards), shall be Dark Sky approved and shall be designed to not glare or reflect onto neighboring properties or public rights-of-way. Outdoor lighting shall be shielded and limited to that required for security and safety purposes.

P10. All construction and improvements shall comply with Encroachments into Yards or

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Setbacks standards established in the Development Code for the underlying land use
district.

P11. A sign permit shall be required for all exterior signage including wall and monument
signage.

P12. During construction, the applicant or its contractor shall provide sufficient watering of excavated or graded soil to prevent excessive dust. Watering will occur at a minimum of three times daily on disturbed soil areas with active operations, unless dust is otherwise controlled by rainfall or use of a dust pallative, or other approved dust control measures.

P13. All clearing, grading, earth moving, and excavation activities will cease during periods of wind greater than 20 miles per hour (averaged over one hour), or when dust plumes of 20 percent or greater opacity impact public roads, occupied structures, or neighboring property.

P14. The applicant shall provide an adequate wind barrier to reduce potentially blowing dust in the direction of the residences east of the solar project site during construction and ongoing operation of the commercial solar field.

P15. All roads and access ways will be treated and maintained with a dust palliative or graveled or treated by another approved dust control method to prevent excessive dust.

P16. On-site vehicle speed will be limited to 15 miles per hour.

P17. On terms and in an amount acceptable to the Community Development Director, adequate surety shall be provided for reclamation of commercial solar field site should energy production cease for a continuous period of 180 days and/or if the site is abandoned. Any such reclamation is subject to the terms of the Development Agreement.

P18. The applicant shall prepare a Closure, Revegetation, and Rehabilitation Plan and submit it to the Planning Division for review and approval prior to building permit issuance. The Plan shall describe the site closure activities to meet federal, state, and local requirements for the rehabilitation and revegetation of the project site after decommissioning following the operational life of the project.

ENGINEERING CONDITIONS - GENERAL
E1. The project shall comply with all applicable City ordinances and resolutions.

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E2. All road easements required shall be offered for dedication to the public and shall continue in force until the City accepts or abandons such offers. All dedications shall be free from all encumbrances. (check alta survey).

E3. Easements, when required for roadway slopes, drainage facilities, landscaping, utilities, etc. within the areas dedicated to the City, shall be submitted and recorded as directed by the City Engineer. No structures shall be placed on any part of the easements except those directly related to the purposes of said easements.

BUILDING AND SAFETY
B1. Applicant shall provide plans and obtain the required permits that comply with applicable provisions of the 2022 California Building, Plumbing, Electrical and Mechanical Codes, the 2022 California Green Building Standards, and Title 24 Energy Code, Part 6
B2. All plans shall be stamped and wet signed by a California Licensed Engineer or Architect.

B3. Provide required ADA access plan (parking, path of travel, building access, restroom, ADA workspace, etc.) per 2022 CBC. B4.

B4. Obtain San Bernardino County Fire approval for building and site improvements.

ENGINEERING CONDITIONS – PRIOR TO GRADING PERMIT ISSUANCE

DRAINAGE
E4. Prior to issuance of a grading permit, a final drainage plan with drive aisle layouts shall be submitted for review and approval by the City Engineer showing provisions for receiving and conducting offsite and onsite tributary drainage flows around or through the site in a manner which will not adversely affect adjacent or downstream properties. This plan shall consider retaining onsite drainage flows from a 100-year design storm.

GRADING
E5. Prior to the issuance of a grading permit, the developer's engineer shall submit a comprehensive grading plan in conformance with, California Building Code and the requirements of the City.

E6. A grading permit shall be obtained from the City Engineer prior to any grading or other work done on the site.

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E7. A preliminary soils report and a current preliminary title report shall be submitted to the Engineering Department concurrently with the grading plan.

The soils report shall include stability of the site as well as the grading requirements. The Soil Engineer shall state the "R" value (soils resistance) for the site, based upon a "TI" value set by the City Engineer.

STREET IMPROVEMENTS
E8. A 30’ foot half-width street dedication along Amboy Road shall be dedicated to the City prior to Grading Permit Issuance.

E9. A 30’ foot half-width street dedication along Noels Knoll Road shall be dedicated to the City prior to Grading Permit Issuance.

E10. A 60’ full-width street dedication along Samarkand Avenue shall be dedicated to the City prior to Grading Permit Issuance.

E11. An encroachment permit separate from the grading onsite permit shall be obtained from the City of Twentynine Palms (760-367-6799), prior to any construction occurring within the public right-of-way.

E21. Final improvement plans and profiles shall indicate the location of any existing utility which would affect construction and shall provide for its relocation at no cost to the City.

E22. All proposed construction of utilities adjacent to and onsite shall be underground.

FIRE DEPARTMENT
See attached Conditions of Approval letter from San Bernardino County Fire Department.

MDAQMD
See the attached Conditions of Approval letter from Mojave Desert Air Quality Management District.

ENVIRONMENTAL – PRIOR TO GRADING PERMITS
BIO-1. For each phase of project implementation, including solar decommissioning activities, suitable habitat for special-status species (i.e., all undeveloped land or re-naturalized land within the project site) with potential to occur in the project, the project’s Applicant/Developer shall include in all construction plans and specifications detailed on the BIO-1 Mitigation Monitoring and Reporting Program.

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BIO-2. Pre-Construction Nesting Bird Survey. If construction or solar decommissioning activities must occur during the migratory bird nesting season (typically January 1through July 31), an avian nesting survey of the Project site and within 500 feet of all impact areas must be conducted to determine the presence/absence of fully protected species, protected migratory birds, and active nests. The avian nesting survey shall be performed by a qualified wildlife biologist within 72 hours prior to the start of construction in accordance with the Migratory Bird Treaty Act and California Fish and Game Code Section 3503, 3503.5, and 3513.

If an active bird nest is found, the nest shall be flagged and mapped on the construction plans along with appropriate buffer established around the nest, which shall be determined by the biologist based on the species’ sensitivity to disturbance (typically 300 feet for passerines and 500 feet for raptors and special status species). The nest area shall be avoided until the nest is vacated, and the juveniles have fledged. The nest area shall be demarcated in the field by flagging and stakes or construction fencing. On-site construction monitoring shall also be conducted when an active nest buffer is in place. No project activities may encroach into established buffers without the consent of a monitoring biologist. The buffer shall remain in place until it is determined the nestlings have fledged and the nest is no longer considered active.

BIO-3. Pre-Construction Burrowing Owl Surveys and Avoidance. One preconstruction Burrowing Owl survey shall be completed no more than 14 days before initiation of site preparation or grading or solar decommissioning activities, and a second survey shall be completed within 24 hours of the start of site preparation or grading or decommissioning activities. If grounddisturbing activities are delayed or suspended for more than 30 days after the preconstruction surveys, the Project site shall be resurveyed. Surveys for Burrowing Owls shall be conducted in accordance with protocols established in the Staff Report on Burrowing Owl Mitigation in 2012 or current version.

If Burrowing Owls are detected, and if impacts to Burrowing Owls cannot be feasibly avoided, the Project applicant will consult with CDFW and obtain appropriate take authorization from the CDFW through the CESA Incidental Take Permit (ITP) process. If requiring an ITP, mitigation for direct impacts to Burrowing Owl shall be fulfilled through compensatory mitigation at a minimum 1:1 habitat replacement of equal or better functions and values to those impacted by the Project, or as otherwise determined through the ITP process.

BIO-4. Pre Construction Survey for Desert Kit Fox and Avoidance A pre-construction survey for Desert Kit Fox shall be conducted for by a Qualified Biologist familiar with desert kit fox within 10 days before initiation of site preparation or grading activities to determine the presence/absence of Desert Kit Fox. The Qualified Biologist shall conduct a pre-project survey to

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attain 100% visual coverage within the Project area and a minimum 500-foot buffer to determine the presence or absence of desert kit fox individuals, dens, and sign. The project proponent shall provide the results of the survey to CDFW prior to start of Project activities. The
survey report should identify the status of all identified dens, include an estimate of occupancy, and detail the methodology utilized to support these conclusions.

If potential dens are located, they shall be monitored by the Qualified Biologist.

Trail cameras may be used to assist with observation but shall not be the sole basis upon which the status is determined. Permittee shall provide a determination if active dens can be avoided and buffered from Project activities to prevent take and disturbance with the survey results.

Should active Desert Kit Fox dens be present within the Project area that cannot be avoided with an adequate buffer, a Desert Kit Fox Relocation and Mitigation Plan shall be prepared by a qualified biologist in consultation with CDFW, and shall be implemented including protective measures such as the establishment of no disturbance buffer zones for active den and active natal den. No disturbance or relocation of active dens may take place when juveniles may be present and dependent on parental care.

Permittee shall block off inactive dens within the buffer zone with rocks and sticks to discourage use during Project activities and remove when construction is complete. The Qualified Biologist shall periodically check the inactive burrows remain blocked and are not reoccupied During Project activities including construction and decommissioning.

A report to evaluate the success of the relocation efforts and any subsequent re-occupation, if applicable, shall be provided at the end of the construction period. Data shall be readily available to the CDFW upon request. If an injured, sick, or dead desert kit fox is detected on any area associated with the project, the designated CDFW personnel at both the Ontario office and the Wildlife Investigation Lab shall be notified as described within the Desert Kit Fox Relocation and Mitigation Plan.

BIO-5. Prior to grading permits procedures outlined in BIO-5 Mitigation Monitoring and Report Program shall be complied with.

BIO-6. Desert Tortoise Habitat Compensatory Mitigation. The project applicant shall implement habitat mitigation for 142.1± acres of permanent impacts to occupied desert tortoise habitat. Impacts are to be compensated at a minimum 1:1 ratio either through one or a combination of the following:

Option 1: Purchase of off-site habitat mitigation lands that contain suitable habitat
for desert tortoise.

Option 2: Purchase of mitigation credits at a mitigation bank for desert tortoise.

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The applicant shall submit a document outlining the permanent impacts to desert tortoise habitat, along with a compensatory mitigation plan, to the USFWS and CDFW for review and approval. The Project applicant shall also be required to obtain an Incidental Take Permit (ITP) from the CDFW and USFWS where the ITP includes an analysis of whether Project impacts would jeopardize the continued existence of the species, provide suitable avoidance and minimization measures to reduce potential impacts, and adequately mitigate through conservation or mitigation banking. Unavoidable impacts to occupied suitable habitat shall be compensated at a minimum of 1:1, as described above, in addition to implementing all other measures and condition of the ITPs. This mitigation measure would also be applied in the event of future construction of roads subject to the future road dedications.

BIO-7. Focused Surveys, Avoidance and Mitigation Outside of Solar BSA.

Development proposed for any portion of the site outside the Solar Project BSA shall be required to conduct the following surveys prior to issuance of grading permits: a general biological reconnaissance survey, including vegetation mapping, special-status plant survey, western Joshua Tree focused survey, desert native plant survey, desert tortoise (Gopherus agassizii) protocol-level survey, burrowing owl (Athene cunicularia) protocollevel survey, and an aquatic resources delineation.

Focused surveys shall be conducted in accordance with the methods described in Section 3.2.4, Special- Status and Regulated Resources, of the project specific Biological Resources Technical Report.

If the results of the general biological reconnaissance survey determine there are biological resources that are not evaluated in the Biological Resources Technical Report, then additional CEQA documentation would be required by the project applicant. If the general biological reconnaissance survey determines there are sensitive natural vegetation communities, and if jurisdictional aquatic resources, and/or desert native plants, desert tortoise, or burrowing owl are determined present, then the following applicable mitigation measures from Section 7 of the Project BRTR referenced below shall be implemented: Mitigation Measure BIO-2 (Construction-Related and Operational-Related Indirect Impacts to Biological Resources), Mitigation Measure BIO-3 (Desert Tortoise Avoidance and Minimization Measures), Mitigation Measure BIO-4 (Desert Tortoise Habitat Compensatory Mitigation), Mitigation Measure BIO-5 (Pre-Construction Burrowing Owl Surveys and Avoidance), Mitigation Measure BIO- 6 (Pre-Construction Survey for Desert Kit Fox and Avoidance), Mitigation Measure BIO-7 (Pre-Construction Nesting Bird Survey), Mitigation Measure BIO-8 (Sensitive Vegetation Communities and Jurisdictional Resources Mitigation), Mitigation Measure BIO-9 (Avoidance and Minimization to Potential Jurisdictional Aquatic Resources), and Mitigation Measure BIO-10 (Desert Native Plants Removal Permit).Should special-status plant species and/or western Joshua Tree be

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determined present, then the following additional mitigation measures shall be implemented:

Special-Status Plants
Impacts to special-status plant occurrences shall be avoided to the greatest extent possible and minimized where avoidance is not feasible. Where impacts to special-status plant species cannot be avoided, mitigation is required. For direct impacts to special-status plant species, one or a combination of the following strategies shall be implemented:
o Avoidance and Minimization. Impacts to special-status plant occurrences shall be avoided to the greatest extent possible and minimized where avoidance is not feasible.
o Salvage. If a qualified ecologist determines that impacts to specialstatus plants cannot be avoided and it is feasible to effectively salvage the plants, that ecologist shall develop a restoration and mitigation plan based on the life history of the species impacted, as necessary, to mitigate project impacts. The plan shall include, at minimum, (a) collection/salvage measures for plants and/or seed banks to retain intact soil conditions and maximize success likelihood; (b) details regarding storage of plants and/or seed banks; (c) location of the proposed recipient site and detailed site preparation and plant introduction techniques details for top soil storage, as applicable; (d) time of year that the salvage and replanting or seeding shall occur and the methodology of the replanting; (e) a description of the irrigation, if used; (f) success criteria; and (g) a detailed monitoring program, commensurate with the plan’s goals.

Western Joshua Tree
If impacts to western Joshua tree cannot be avoided, mitigation is required. If avoidance is not feasible, and construction will result in direct removal of western Joshua tree, a Westen Joshua Tree Conservation Act Incidental Take Permit or a Section 2081 Incidental Take Permit from CDFW shall be required prior to construction.

BIO-8. Avoidance and Minimization of Impacts to Potential Jurisdictional Aquatic Resources.

A 1602 Agreement shall be secured, if necessary, should Project designs change and affect jurisdictional waters identified in the Draft EIR. The following avoidance and minimization measures would be implemented when grounddisturbing activities occur within 25 feet of waters of the state and/or jurisdictional streambeds (i.e., jurisdictional aquatic resources):
• All jurisdictional aquatic resources within 25 feet of project activities shall be fenced or flagged as environmentally sensitive areas prior to any ground disturbance.

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• A biological monitor shall be present during construction activities within 25 feet of jurisdictional aquatic resources to ensure avoidance. • Best Management Practices shall be implemented to avoid indirect impacts to jurisdictional waters, including:
- Water containing mud, silt, or other pollutants from grading or other activities shall not be allowed to enter jurisdictional aquatic resources or be placed in locations that may be subjected to high storm flows. - Spoil sites shall not be located within jurisdictional aquatic resources or in locations that may be subject to high storm flows, where spoils might be washed into drainages.
- Raw cement/concrete or washings thereof, asphalt, paint or other coating material, oil or other petroleum products, or any other substances that could be hazardous, resulting from project-related activities, shall be prevented from entering jurisdictional aquatic resources.
- Equipment maintenance shall occur outside jurisdictional aquatic resources and in such a manner that no petroleum products or other pollutants from the equipment enters on- or off-site statejurisdictional aquatic resources either directly or indirectly.

BIO-10. Desert Native Plants Removal Permit. Prior to issuance of grading permits or solar decommissioning activities, the Project applicant shall submit an application and applicable fee paid to City of Twentynine Palms for removal of protected native desert plants under the California Desert Native Plants Act.

The applicant shall submit a detailed plan consistent with the requirements of the Act. The City shall hire, at the applicant’s expense, a qualified biologist to review the plan and provide conditions of approval for the grading permit. The Project shall comply with any conditions of approval imposed by the City upon issuance of the permit.

The permit application shall specify information outlined in the California Desert Native Plant Act Section 80114, which includes but is not limited to, the number and species of native plants to be removed, a description of the real property from which the plants are to be removed, and in the case that relocation is required, the destination of the native plants and the manner in which the plants are to be salvaged. Pursuant to the California Desert Native Plants Act, tags or seals issued by the City of Twentynine Palms must be attached to the native plants at the time of harvesting and before transporting to their permanent relocation site(s) and must remain attached to the plant until transplanted into its ultimate destination. Transport of salvaged plants will occur as prescribed by the City of Twentynine Palms.

If relocation is required by the applicable review authority, the following actions shall also be implemented to ensure successful relocation of desert native plants:

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• Salvaged plants shall be transplanted expeditiously to either their final on-site location, or to an approved off-site area. If the plants cannot be expeditiously taken to their permanent relocation area at the time of excavation, they may be transplanted in a temporary area (stockpiled) prior to being moved to their permanent relocation site(s). • Plants designated for relocation shall be marked on their north facing side prior to excavation. Transplanted plants shall be planted in the same orientation as they currently occur on the project site, with the marking on the north side of the trees facing north at the relocation site(s).
• Transplanted plants shall be watered prior to and at the time of transplantation. The schedule of watering shall be determined by the qualified desert native plant expert(s) to maintain plant health. Watering of the transplanted plants shall continue under the guidance of qualified desert native plant expert(s) until it has been determined that the transplants have become established in the permanent relocation site(s) and no longer require supplemental watering.

CUL-2. Archaeological and/or Tribal Resources Discovery and Documentation. A Cultural Resources Monitoring and Discovery Plan (Plan) shall be prepared and finalized prior to the initiation of Solar Project construction. The Plan will require that qualified archaeological monitor(s) be present and that tribal monitor(s) representing the Cahuilla Band, the Agua Caliente Band and the Yuhaaviatam be present during all ground-disturbing activities within the Project site, unless Tribe(s) provide the City with written withdrawal from their monitoring request. The applicant/developer shall allow 45 days from initial contact with the above-listed Tribes to enter into a contract with the Tribes for monitoring services. If the applicant/developer can demonstrate to the City they were unable to secure an agreement from the above-referenced Tribe, or if the contracted Tribe fails to fulfill its obligation under the contract terms, then the applicant/developer may retain an alternative qualified tribal monitor approved by the City. Monitoring requirements and locations will be defined in the Plan, along with resource discovery protocols and guidance for reducing or terminating site monitoring in the case that no artifacts are identified. Should an artifact be discovered, all construction activity within 100 feet of the discovery shall stop until a qualified archaeologist can evaluate the significance of the artifact and make a determination whether further study is necessary, and whether or when work may resume. Should the artifact be found to be significant under CEQA, an archaeological treatment plan and further data recovery may be required, as determined by the Project archaeologist and the Tribes.

CUL-3. Reburial Protocol

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Prior to issuance of grading permits: the developer/applicant shall come to an agreement with the consulting tribes indicating an area on-site which will be used, if needed, for reburial of any artifacts that have been identified during grading and cannot be avoided. This area will be protected and not disturbed in the future. This is confidential information, and the exact nature of this area will not be called out on the grading plans.

CUL-4 Monitoring and Treatment Plan
A Monitoring and Treatment Plan that is reflective of the project mitigation (“Cultural Resources” and “Tribal Cultural Resources”) shall be completed by the archaeologist and submitted to the Lead Agency for dissemination to the Yuhaaviatam of San Manuel Nation Cultural Resources Management Department (YSMN, also known as San Manuel Band of Mission Indians). The City shall approve the Plan following consultation with the Tribe Any and all findings will be subject to the protocol detailed within the Monitoring and Treatment Plan.

CUL-5 Archaeological Monitoring
Due to the heightened cultural sensitivity of the proposed project area, an archaeological monitor with at least 3 years of regional experience in archaeology shall be present for all ground-disturbing activities that occur within the proposed project area (which includes, but is not limited to, tree/shrub removal and planting, clearing/grubbing, grading, excavation, trenching, compaction, fence/gate removal and installation, drainage and irrigation removal and installation, hardscape installation [benches, signage, boulders, walls, seat walls, fountains, etc.], and archaeological work). A sufficient number of archaeological monitors shall be present each work day to ensure that simultaneously occurring ground disturbing activities receive thorough levels of monitoring coverage.

TCR-1 Treatment of Cultural Resources During Project Implementation If a pre-contact cultural resource is discovered during project implementation, ground-disturbing activities shall be suspended 60 feet around the resource(s), and an Environmentally Sensitive Area (ESA) physical demarcation/barrier constructed.

The Project Archaeologist shall develop a research design that shall include a plan to evaluate the resource for significance under CEQA criteria.

Representatives from YSMN, the Archaeologist, and the Lead Agency shall confer regarding the research design, as well as any testing efforts needed to delineate the resource boundary. Following the completion of evaluation efforts, all parties shall confer regarding the resource's archaeological significance, its potential as a Tribal Cultural Resource (TCR), and avoidance (or other appropriate treatment) of the discovered resource. Removal of any cultural resource(s) shall be conducted with the presence of a Tribal monitor representing the Tribe, unless otherwise decided by YSMN. All plans for analysis shall be reviewed and approved by the applicant and YSMN prior to implementation, and all removed material shall be temporarily curated on-site.

1608388676.1
It is the preference of YSMN that removed cultural material be reburied as close to the original find location as possible. However, should reburial within/near the original find location during project implementation not be feasible, then a reburial location for future reburial shall be decided upon by YSMN, the landowner, and the Lead Agency, and all finds shall be reburied within this location.

Additionally, in this case, reburial shall not occur until all ground-disturbing activities associated with the project have been completed, all monitoring has ceased, all cataloguing and basic recordation of cultural resources have been completed, and a final monitoring report has been issued to Lead Agency, CHRIS, and YSMN. All reburials are subject to a reburial agreement that shall be developed between the landowner and YSMN outlining the determined reburial process/location, and shall include measures and provisions to protect the reburial area from any future impacts.

Should it occur that avoidance, preservation in place, and on-site reburial are not an option for treatment, the landowner shall relinquish all ownership and rights to this material and confer with YSMN to identify an American Association of Museums (AAM)-accredited facility within the County that can accession the materials into their permanent collections and provide for the proper care of these objects in accordance with the 1993 CA Curation Guidelines. A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility. This agreement shall stipulate the payment of fees necessary for permanent curation of the collections and associated records and the obligation of the Project developer/applicant to pay for those fees.

All draft records/reports containing the significance and treatment findings and data recovery results shall be prepared by the archaeologist and submitted to the Lead Agency and YSMN for their review and comment. After approval from all parties, the final reports and site/isolate records are to be submitted to the local CHRIS Information Center, the Lead Agency, and YSMN.

TCR-2: Inadvertent Discoveries of Human Remains
If human remains or funerary objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100-foot buffer of the find) shall cease and the County Coroner shall be contacted pursuant to State Health and Safety Code §7050.5 and that code enforced for the duration of the project.

ENVIRONMENTAL – CONSTRUCTION/OPERATIONS
HAZ-1. Prior to construction, a Hazardous Material Management Plan shall be prepared by the Applicant and submitted to the City for review and approval, to specify the method for handling and disposing of hazardous material related to the construction process.

1608388676.1
HAZ-2. A toxicity characteristic leaching procedural (TCLP) test must be performed to determine the toxicity level of solar panel(s) prior to its being recycled or disposed. If the solar panel waste does not exceed the threshold to be defined as hazardous waste, no further action is required. If the solar panel’s toxicity level exceeds the threshold and is defined as hazardous waste, all federal, state, and local regulations regarding the disposal of hazardous waste will be applied to the solar panel’s disposal, including the use of a qualified hauler, and disposal in a designated landfill.

HYD-1. Spill Prevention, Control, and Countermeasure Plan (SPCCP). The Applicant shall prepare a Spill Prevention, Control, and Countermeasure Plan (SPCCP) that shall clearly state measures to stop the source of a spill, contain the spill, clean up the spill, dispose of contaminated materials, and train personnel to prevent and control future spills. The SPCCP shall identify sources of oil or hazardous wastes that may be stored or used on site. If oil or hazardous wastes would be stored on site during operations, the SPCCP shall identify the location of storage, anticipated volumes of materials to be stored, method of storage, and countermeasures to address potential spill or accidental release of materials. In addition, the SPCCP shall include step-by-step instructions for the response to spills at a facility. In addition, the spill response plan should:
• Identify individuals responsible for implementing the plan. • Define safety measures to be taken with each kind of waste. • Specify how to notify appropriate authorities, such as police and fire departments, hospitals, or municipal sewage treatment facilities for assistance.
• State procedures for containing, diverting, isolating, and cleaning up the spill.
• Describe spill response equipment to be used, including safety and cleanup equipment.
• The SPCCP shall be submitted to San Bernardino County Public Works – Environmental Management Division for review and approval prior to occupation/operations and shall be maintained over the operational life of the Project.

AES-1. Within 60 days of the completion of construction, or at the earliest possible time that is appropriate to achieve plant establishment, as determined by the City and a qualified Project biologist, native plants shall be installed on the Solar Project site as further described in the Habitat Restoration Plan included as Appendix D.3 to the EIR.

AES-2 Prior to the completion of construction, plant native vegetation along the east and south sides of the perimeter security fence to shield the Solar Project site from potential future residential viewers. Irrigation would be required to assist initial plant growth.

1608388676.1
The undersigned verifies that he/she has read the Conditions of Approval, understands each Condition, and agrees to adhere to the Conditions of Approval. ___________________________________
Applicant Signature
___________________________________
Applicant Name (Print)
___________________________________
Date

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1 RESOLUTION NO. ______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

TWENTYNINE PALMS CERTIFYING THE ENVIRONMENTAL
IMPACT REPORT (SCH # 2024021042) FOR THE CITY OF
TWENTYNINE PALMS SOLAR PROJECT; ADOPTING

ENVIRONMENTAL FINDINGS PURSUANT TO THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT; ADOPTING THE STATEMENT
OF OVERRIDING CONSIDERATIONS; AND ADOPTING A

MITIGATION MONITORING AND REPORTING PROGRAM
WHEREAS, the City of Twentynine Palms Solar Project (“Solar Project” or “Proposed Project”) encompasses 477± acres at the northwest corner of Two Mile Road and Noels Knoll Road (extended), and is comprised of two components. The Solar Project component consists of 241± acres of the 477± acre site, and would include 184± of land graded and improved with a 50 megawatt (MW) commercial solar generation facility and off-site improvements. The Residential GPA component of the Project consists of a General Plan Amendment and Rezone to change the land use and zoning designations on the 119 acres of RL-5 designated land of parcels 0612-201-01 and 0612-201-05 south of the Solar Project. The GPA and Rezone will re-designate 60 acres (half of the RL-5 designated land) as Single Family Residential, 1 unit per acre (RS-1), while the remaining 59 acres remain RL-5. Because the Solar Project will eliminate the potential for 48 residential units (the maximum density allowed in the RL-5 designation), the GPA and Rezone increase the density of the southerly 236 acres from the currently allowable 71 units to a maximum of 119 units. This change will therefore accommodate the 48 units which would be lost if the Solar Project is approved. There is no residential development proposed on this acreage as part of the Project; and
WHEREAS, pursuant to section 21067 of the California Environmental Quality Act (Pub. Res. Code §§ 21000 et seq.) (“CEQA”), and section 15367 of the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), the City of Twentynine Palms (“City”) is the Lead Agency for the Proposed Project; and WHEREAS, pursuant to CEQA and the State CEQA Guidelines, the Lead Agency determined that an Environmental Impact Report (“EIR”) should be prepared in order to analyze all potential adverse environmental impacts of the Proposed Project; and WHEREAS, the City issued a Notice of Preparation (“NOP”) of a Draft EIR for Solar Project on or about February 28, 2024, and it was transmitted to the State Clearinghouse, local and regional agencies, and posted at the San Bernardino County Clerk’s office for a 30-day comment period; and
WHEREAS, in the NOP, comments and participation were sought from the public and all interested and affected groups and agencies; and

2 WHEREAS, on or about December 9, 2025 the City initiated a 45-day public review and comment period of the Draft EIR for the Proposed Project and released the Draft EIR for public review and comment; and
WHEREAS, pursuant to State CEQA Guidelines section 15086, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and other interested parties during the 45-day public review and comment period; and
WHEREAS, the City received a total of 38 comment letters. 3 comment letters from a State agency, 1 from the regional air quality management district, 1 from a non-profit organization, 2 from Native American Tribes,1 from a union, and 30 from individuals during the 45-day public review and comment period; and WHEREAS, the City has prepared a Final EIR, consisting of the comments received during the public review and comment period on the Draft EIR, and written responses to those comments. For the purposes of this Resolution, the “EIR” shall refer to the Draft EIR together with the Final EIR; and
WHEREAS, on March 23, 2026, the City Council held a public hearing on the Project, at which all persons wishing to testify were heard; and WHEREAS, the environmental impacts identified in the EIR that the Lead Agency finds are of no impact or constitute a less than significant impact and do not require mitigation are described in Section 3 and Section 4 hereof; and WHEREAS, the environmental impacts identified in the EIR as potentially significant but which the Lead Agency finds can be mitigated to a less than significant level through the incorporation of feasible Mitigation Measures identified in the EIR and set forth herein, are described in Section 5 hereof; and WHEREAS, the environmental impacts identified in the EIR as potentially significant but which the Lead Agency finds cannot be mitigated to a less than significant level, despite the imposition of feasible Mitigation Measures identified in the EIR and set forth herein, are described in Section 6 hereof; and
WHEREAS, the cumulative impacts of the Proposed Project identified in the EIR and set forth herein, are described in Section 7 hereof; and WHEREAS, the significant and irreversible environmental changes that would result from the Proposed Project, but which would be largely mitigated, and which are identified in the EIR and set forth herein, are described in Section 8 hereof; and WHEREAS, the existence of any growth-inducing impacts resulting from the Proposed Project identified in the EIR and set forth herein, are described in Section 9 hereof; and

3 WHEREAS, alternatives to the Proposed Project that might eliminate or reduce significant environmental impacts are described in Section 10 hereof; and WHEREAS, the Mitigation Monitoring and Reporting Program setting forth the mitigation measures to which the Lead Agency shall bind itself in connection with the Proposed Project, is attached hereto as Exhibit “A”; and WHEREAS, prior to taking action, the Lead Agency has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including the EIR, and all oral and written evidence presented to it during all meetings; and
WHEREAS, the EIR reflects the independent judgment of the City Council and is deemed adequate for purposes of making decisions on the merits of the Proposed Project; and
WHEREAS, the Lead Agency has not received any comments or additional information that constituted substantial new information requiring recirculation under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and
WHEREAS, all the requirements of CEQA, and the State CEQA Guidelines, have been satisfied by the City in the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Proposed Project have been adequately evaluated; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

THE CITY COUNCIL OF THE CITY OF TWENTYNINE PALMS DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1: RECITALS
The recitals above are true and correct and are incorporated into this Resolution by reference as findings of fact.

SECTION 2: SUMMARY OF FINDINGS
Based on all of the evidence presented and the entirety of the administrative record, including but not limited to the EIR, written and oral testimony given at public hearings, and the submission of testimony from the public, organizations and regulatory agencies, the following environmental impacts associated with the Project are either: (1) less than significant and do not require mitigation; or (2) potentially significant but will be avoided or reduced to a level of insignificance through the identified Mitigation Measures;

4 or (3) significant and cannot be fully mitigated to a level of less than significant but will be lessened to the extent feasible by the identified Mitigation Measures.

SECTION 3: FINDINGS REGARDING NO IMPACT DETERMINATIONS IN THE INITIAL STUDY/NOTICE OF PREPARATION.

The City prepared an Initial Study/Notice of Preparation for the Project and circulated it for public comment from February 28, 2024 to March 29, 2024. State CEQA Guidelines section 15091 does not require specific findings to address potential environmental effects that an EIR identifies as “no impact”. Nevertheless, the City Council hereby finds that the Project would have no impact or on the following resource areas:

A. AESTHETICS
Thresholds:
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Finding: No Impact (IS/NOP page 17).

Explanation:

The IS/NOP determined that the Project would result in “No Impact” to scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway because the Project site is not located adjacent to a state scenic highway, and there are no notable rock outcroppings, trees, or other scenic resources in the immediate vicinity.

B. AGRICULTURE AND FORESTRY RESOURCES
Thresholds:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use?

5 e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
Finding: No Impact (IS/NOP page 19).

Explanation:

The Initial Study determined that the Project would result in “No Impact” to agriculture or forestry resources because no agricultural or forestry lands occur on the Project site.

Additionally, the Project is not located within an area mapped for farmland of statewide importance, is not zoned for agricultural or forestry uses, is not subject to a Williamson Act contract, and will not convert or result in the loss of existing agricultural or forestry uses.

C. AIR QUALITY
Thresholds:
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Finding: No Impact (IS/NOP page 23).

Explanation:

The Initial Study determined that the Project would result in “No Impact” with regard to objectionable odors because potential odors from construction equipment would disperse quickly, and would be temporary, and the operation of the Solar Project is not expected to generate any odors, as the solar panels will not emit any odor-causing materials.

D. BIOLOGICAL RESOURCES
Thresholds:
c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

6 Finding: No Impact (IS/NOP page 25).

Explanation:

The Initial Study determined that the Project would result in “No Impact” to federally protected wetlands and would not conflict with local policies or adopted conservation plans because there are no waters of the US in the City or on the Project site, due to the lack of connection to a navigable waterway, and adherence to mitigation measures specified in the Project-specific biological report would ensure no impact on biological overlay districts in the General Plan nor any conflict with City or county regulations and plans.

E. ENERGY
Thresholds:
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Finding: No Impact (IS/NOP page 29).

Explanation:

The Solar Project will implement the State’s Renewable Portfolio Standard and provide a new source of renewable energy for electricity providers, and future buildout under the Residential GPA would be in accordance with the building and energy codes adopted at the time of construction to assure there is no obstruction to renewable or energy efficiency plans. It will not obstruct implementation of a state or local plan for renewable energy or energy efficiency.

F. GEOLOGY AND SOILS
Thresholds:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
iii) Seismic-related ground failure, including liquefaction? d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property?

7 e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Finding: No Impact (IS/NOP page 31-32).

Explanation:

The Planning Area is not located within or adjacent to an Alquist-Priolo Earthquake Fault Zone; therefore, the Project will have no impact on risks associated with ground rupture due to an earthquake on an underlying fault.

The Project site is not located in an area identified in the General Plan as being susceptible to liquefaction, and the depth to groundwater exceeds 50 feet, therefore no liquefaction potential exists.

On-site soils are primarily sand and silts typical of alluvial fans and are not expected to contain clay or similarly expansive components that may pose a significant risk to life or property.

The Solar Project proposes no septic tanks and would not be connected to a sewer system, and future development subject to the Residential GPA would adhere to City requirements pertaining to the installation of septic tanks. There will be no impacts associated with soils capable of supporting septic systems.

The Project area primarily consists of alluvium (Qoa), which consists of late Pleistocene gravelly sands. The Project proposes shallow excavations (up to 7 feet in depth) for pilons to support the solar arrays. At these shallow depths, and in alluvium occurring on the site, potential for paleontological deposits is negligible. No significant paleontological resources are expected at the site, and no impact will occur.

G. HAZARDS AND HAZARDOUS MATERIALS
Thresholds:
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

8 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?
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
g) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
Finding: No Impact (IS/NOP page 36).

Explanation:

There are no schools within ¼ miles of the Project site, and the site does not contain any parcels included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, the proposed Project would not create a significant hazard to the public or the environment.

The Project site is not located within an airport land use plan and the nearest airfield is the Marine Corps base located 5.7 miles northeast of the site. Therefore, the proposed Project would not result in a safety hazard or excessive noise for people residing or working in the Project area.

The Project does not propose changes to surrounding roadways that would interfere with an adopted emergency response plan.

The Project site is not in or near a heavily vegetated area, and will not be impacted by wildfires.

H. HYDROLOGY
Threshold:
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Finding: No Impact (IS/NOP page 39).

9 Explanation:

The Project site is not located within the vicinity of a water body or dam, and the City is located inland and is not subject to tsunami.

The Solar Project and future development under the Residential GPA will be required to comply with all applicable water quality standards approved by the City and the Regional Water Quality Control Board for both construction activities and long-term operation of the Project. Adherence to the RWQCB and City’s standard requirements related to water quality will ensure there will be no impact to a water quality control plan.

I. LAND USE AND PLANNING
Threshold:
a) Physically divide an established community?
Finding: No Impact (IS/NOP page 40).

Explanation:

The Project site is vacant and occurs in an area of the City with large-lot residential uses scattered to the south and east. Little to no development occurs on the north or west. The Project will not divide an established community, and no impact will occur.

J. MINERAL RESOURCES
Thresholds:
a) 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?
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? Finding: No Impact (IS/NOP page 41).

Explanation:

Neither the City nor the Project site are designated by the State as having significant mineral resources. As a result, implementation of the Project would not result in the loss of availability of a mineral resource or a mineral resource recovery site.

K. NOISE
Thresholds:
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public

10 airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Finding: No Impact (IS/NOP page 43).

Explanation:

The Project site is not located within an airport land use plan and the nearest airfield is the Marine Corps base located 5.7 miles northeast of the site. Therefore, the proposed Project would not result in a safety hazard or excessive noise for people residing or working in the Project area.

L. POPULATION AND HOUSING
Thresholds:
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Finding: No Impact (IS/NOP page 44).

Explanation:

The Project site is currently vacant and will not displace any resident or housing.

M. TRANSPORTATION/TRAFFIC
c) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Finding: No Impact (IS/NOP page 49).

Explanation:

The infrequent maintenance and repair trips associated with the Solar Project are not expected to increase hazards or create a dangerous intersection because the City will condition the Project to build its access to City standards and at a 90 degree angle to Two Mile Road. No incompatible uses are proposed, and no project-related impact is anticipated.

The Project does not propose changes to surrounding roadways that would interfere with an adopted emergency response plan, and Project operation would not change any existing roads, including areas provided for emergency access. Prior to construction, both the Fire Department and Sheriff Department will review the Project site plan to ensure safety measures are addressed, including emergency access.

11 N. UTILITIES AND SERVICE SYSTEMS
Threshold:
c) Result in a determination by the wastewater treatment provider that serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Finding: No Impact (IS/NOP page 52).

Explanation:

The Solar Project will not require septic or sanitary sewer service, and any need for temporary service will be provided by portable toilets. There is no regional sanitary sewer service, and no treatment plant in the City. Future buildout of the site under the proposed Residential GPA would be subject to the same regulations and standards relating to septic or sanitary sewer service.

O. WILDFIRE
Thresholds:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
Finding: No Impact (IS/NOP page 55).

Explanation:

The Project area is not located adjacent to a state responsibility area or a very high fire hazard severity zone. Because the City, including the proposed Project, is not at high risk for wildfire, it is also not at risk for spread of wildfire, or for slope instability, flooding or landslides. Finally, there is no need for installation or maintenance of infrastructure that could exacerbate fire risk. No impacts associated with wildfire will result from development of the proposed Project.

12 SECTION 4: FINDINGS REGARDING LESS THAN SIGNIFICANT IMPACTS NOT REQUIRING MITIGATION.

Consistent with Public Resources Code Section 21002.1 and Section 15128 of the State CEQA Guidelines, the EIR focused its analysis on potentially significant impacts, and limited discussion of other impacts for which it can be seen with certainty there is no potential for significant adverse environmental impacts. State CEQA Guidelines section 15091 does not require specific findings to address potential environmental effects that an EIR identifies as “no impact” or a “less than significant” impact. Nevertheless, the City Council hereby finds that the Project would have either no impact or a less than significant impact on the following resource areas.

A. AESTHETICS

1. Scenic Vistas
Threshold:
a) Would the Project have a substantial adverse effect on a scenic vista? Finding: Less than Significant Impact. (EIR, p. 2.3-8 through 2.3-16).

Explanation:

Solar Project Impacts: Visual simulations of the Solar Project were prepared from four viewpoints located east and southeast of the site, and were chosen due to their proximity to the Project site and existing development. Due to the distance from existing development to the surrounding mountains and Project site, the low profile of the proposed solar panels, and the descending terrain north of Samarkand Drive where the Solar Project would be located, results of the visual simulation analysis determined that impacts to scenic vistas for viewers looking toward the site in all directions would be less than significant. Additional visual simulations were prepared for review by the Planning Commission and City Council, including additional views from north of the Project site looking south from Indian Trail Road and from Joshua Tree National Park. These simulations similarly show that the solar project will not be prominently visible from those viewpoints and associated impacts would be less than significant.

Residential GPA Impacts: The type and intensity of residential development that would be permitted with the approval of the Residential GPA Project would be comparable to that already occurring in the Project vicinity. Due to the distribution of homes and the resultant open space between homes on 1, 2.5 and 5 acre lots, scenic vistas would remain visible both between structures and above them, given the low profile that single story homes would generate. Future homes would adhere to the City’s development code for development density and intensity, including height restrictions, and conform to local design standards. At the time when a residential project is planned for this site, additional CEQA analysis would be conducted ensuring impacts to scenic vistas would not be significant.

13 2. Light and Glare
Threshold
d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area?
Finding: Less than Significant Impact. (EIR, pp. 2.3-19 and 2.3-21).

Explanation:

Solar Project Impacts: Glare intensity from the Solar Project was modeled and analyzed using the Federal Aviation Administration’s (FAA) Technical Guidance for Evaluating Selected Solar Technologies on Airports. In addition to the airport impacts, twenty dwelling point receptors were analyzed. The glare analyses concluded that the minimal green glare produced by the Solar Project would not affect operations at the Twentynine Palms Airport, and impacts from yellow glare on nearby dwelling units would be less than significant. The solar panel surfaces will be tempered glass with anti-reflective coating to reduce glare. The coating, in combination with the limited impact on airport and residential viewer glare, result in less than significant impacts relating to daytime glare from the Solar Project. The Solar Project site would not have any on-site lighting, therefore there would be no impacts from lighting at the Project site.

Residential GPA Impacts: The proposed Residential GPA will not, in and of itself create any new sources of light or glare. Subsequent proposals to subdivide and develop these lands will be subject to City development standards and regulations and to comprehensive CEQA review. At that time, any potential light and/or glare impacts associated with residential development will be evaluated and, if necessary, mitigated B. AIR QUALITY

1. Conflict with Air Quality Plan
Threshold:
a) Would the Project conflict with or obstruct implementation of the applicable air quality plan?
Finding: Less than Significant Impact. (EIR, pp. 2.4-15 through -18).

Explanation:

Neither the Solar Project nor the Residential GPA will conflict with or obstruct the implementation of any air quality plan, as the Project as a whole is consistent with the intent of local land use plans and regional growth forecasts. In accordance with the City’s policies, the proposed Project shall comply with the provisions of the Mojave Desert Air Quality Management District (MDAQMD) Rule Book. Project emissions would not exceed MDAQMD project-level thresholds of significance, which were designed to determine if a

14 project will have a significant impact on regional air quality. Because buildout of the site would not result in emission levels that would exceed MDAQMD thresholds, the Project will not conflict with or obstruct the implementation of any air quality plan. Air quality impacts related to said plans will be less than significant.

2. Result in Cumulatively Considerable Net Increase in Criteria Pollutants Threshold:
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Finding: Less than Significant Impact. (EIR, p. 2.4-18 through 2.4-24).

Explanation:

The Mojave Desert Air Basin (MDAB) is classified as an area of non-attainment for ozone and PM10 and a significant impact would occur if the Proposed Project resulted in a considerable increase of either of these pollutants. Both construction and operation of the Project (Solar Project and Residential GPA) will result in criteria emissions below the MDAQMD significance thresholds, and therefore would not increase the concentration of ozone precursors (NOx and ROG) or PM10. Because the Project does not propose any residential development at this time, the timeline for development of the residential portion of the Project would not overlap with the development of the Solar Project; therefore, such construction emissions are properly considered independently given their different timeframes for implementation. Given that criteria pollutant thresholds will not be exceeded, the Project would not violate any air quality standard or contribute substantially to an existing or projected air quality violation. Impacts related to construction and operation will be less than significant and are not cumulatively considerable from a nonattainment standpoint.

3. Expose Sensitive Receptors to Substantial Pollutant Concentrations Threshold:
c) Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than Significant Impact. (EIR, p. 2.4-25 through -28).

Explanation:

According to the MDAQMD CEQA Guidelines, certain project types on sites within a specified distance of a sensitive receptor must be evaluated using significance threshold criteria number 4:
(4) [A project is significant if it] Exposes sensitive receptors to substantial pollutant concentrations, including those resulting in a cancer risk greater

15 than or equal to 10 in a million and/or a Hazard Index (HI) (non-cancerous) greater than or equal to 1.

The threshold distances that specific project types must be from sensitive receptors, as specified by the MDAQMD, are as follows:
• Any industrial project within 1,000 feet;
• A distribution center (40 or more trucks per day) within 1,000 feet; • A major transportation project (50,000 or more vehicle per day) within 1,000 feet; • A dry cleaner using perchloroethylene within 500 feet; • A gasoline dispensing facility within 300 feet.

The proposed Solar Project is considered to be an industrial land use, but it would be an unmanned electric generating facility and would not emit pollutants known to cause cancer. The nearest sensitive receptor land uses are Rural Living (RL-5) residences to the east, with the nearest residence being over 1,400 feet from the east boundary of the Solar Project site. Given that the Solar Project occurs beyond the specified distance from any sensitive receptor land uses, no further evaluation per the MDAQMD significance threshold criteria number 4 described above is required.

The proposed Residential GPA density increase does not include uses that emit substantial pollutant concentrations. Thus, impacts would be less than significant.

Health Impacts
The DEIR determined impacts associated with all criteria pollutants will be less than significant, and thus health effects from exposure to criteria pollutants will also be less than significant.

Although the site will be graded for both the Solar Project and the Residential GPA, the potential for the release of the spores which result in Valley Fever is considered low, given the County-wide low incidence rates. As described in the City Council staff report of March 23, 2026, the incidence rate in San Bernardino County has come down from a high of

11.3 in 2021 to 8.2 in 2024, a 42% decrease1. Compared to the 2024 incidence rate in Riverside County (19.0), Kern County (482.2) and Inyo County (16.1), which all border San Bernardino County, the incidence rate is substantially lower, and the potential impact similarly reduced and less than significant. In addition, compliance with standard dust control measures would limit the amount of fugitive dust generated during construction, further minimizing the potential for any released spores to become airborne. Watering of a project site during construction has been determined to be an effective measure to prevent the spread of spores that can cause Valley Fever by the California Department of Public Health.2Implementation of the proposed habitat restoration plan as required 1 https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/ValleyFeverDashboard.aspx 2 Preventing Work-Related Coccidioidomycosis (Valley Fever), Fact Sheet, Hazard Evaluation System & Information Service (HESIS), California Department of Public Health, June 2013. www.cdph.ca.gov/Programs/CCDPHP/DEODC/OHB/HESIS/CDPH Document Library/CocciFact.pdf.

16 pursuant to Mitigation Measure AES-1 (Aesthetics) would further reduce the potential for dust impacts, in that replanting the site is expected to increase soil stability and reduce the long-term potential for fugitive dust. Less than significant impacts are expected.

C. CULTURAL
Threshold:
c) Disturb any human remains, including those interred outside of formal cemeteries.

Finding: Less than Significant Impact. (EIR, p. 2.6-14).

Explanation:

The records and literature search conducted for the Solar Project site cultural resource study found no evidence of past use of the Project site for human burial. During the on-site pedestrian survey of the Project site, no evidence of human remains, human burial, or cremations was identified. For both the Solar Project and Residential GPA, should any human remains be identified during Project site excavation, California Health and Safety Code, Section 7050.5 requires that all excavation activity must stop, and the County Coroner must inspect the site. If the remains are identified as those of a Native American individual by the Coroner, the NAHC is informed and required to contact the Most Likely Descendant. The descendant will recommend the appropriate next step. This requirement of California law shall ensure that the Project impacts to human remains are less than significant.

D. ENERGY

1. Energy Consumption
Threshold:
a) Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Finding: Less than Significant Impact. (EIR, p. 2.7-10 through -16).

Explanation:

The Solar Project would generate approximately 255 MWh of energy per day during the operational phase, or 93,050,290 MWh during the first year, while consuming approximately 1.61 MWh of energy annually during ongoing maintenance activities. 3 For 3 In response to comments in the Final Environmental Impact Report (FEIR) expressing concern that the Project would not achieve a 50 MW capacity, the Project applicant has provided information clarifying that the Project will install approximately 130,000 modules each rated at 395 WDC, resulting in a total approximate generating capacity of 51.35 MWDC. Therefore, the DEIR analysis of a 50 MW facility remains accurate (FEIR, Response 31.B).

17 the Residential GPA, operation of the 119 residences would consume the equivalent of 7,344.708 MWh annually. Because the overall density of the proposed residential development would be the same as the that currently allowed under the General Plan, there would be no net increase in residential energy use. The eventual development of up to 119 residences would result in an incremental increase to the County’s overall consumption of energy, however it would not be an exceedance of previously planned growth for the region and the City because the Residential GPA would maintain the site's existing development capacity of 119 residences.

Overall, impacts from the construction and operation of the Solar Project and the Residential GPA would result in a net positive impact with regard to energy due to the Solar Projects electricity generation, and would not result in wasteful, inefficient, or unnecessary consumption of energy resources. Impacts would be less than significant.

E. GEOLOGY AND SOILS

1. Strong Seismic Ground Shaking
Threshold:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
ii) Strong seismic ground shaking.

Finding: Less than Significant Impact. (EIR, p. 2.8-12 and -15).

Explanation:

The Project would be subject to strong ground shaking from seismic activity primarily from the Pinto Mountain fault. The subject site is not located within immediate proximity to an active fault zone, however it is located one mile north from Pinto Mountain fault which could result in strong ground shaking. To ensure the structural integrity of the Project, the final design plan must conform to the most recent California Building Code and CPUC requirements and local building and development standards as stated by the City Municipal Code. All Solar Project related development as well as future residential development under the Residential GPA would be required to comply with all state and local building and development standards, which are explicitly designed to reduce the effects of strong ground shaking to less than significant levels.

2. Landslides
Threshold:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
iv) Landslides.

Finding: Less than Significant Impact. (EIR, p. 2.8-15 and -16).

18 Explanation:

The Project site is not within a landslide susceptible area as identified by the City General Plan EIR Exhibit 4.6-6 (Hillside Overlay) nor is it listed in the General Plan EIR Table 4.6- 1 (Slope Instability Potential) as an area within Twentynine Palms that provides the environment for slope instability to occur. A preliminary geotechnical report was prepared for the Solar Project, and a final report will be required for both the Solar Project and future buildout of the Residential GPA site consistent with CBC Section 1803. The report would evaluate the soil composition, strength, and load bearing capacity, and make recommendations on the design of the structural foundation system. These recommendations would be implemented as part of grading and building permit review, and the Project would be required to demonstrate compliance with the report’s findings.

Under these regulatory standards, the Project would not expose life or property to landslide related damage, and impacts would be less than significant.

3. Loss of Topsoil
Threshold:
b) Result in substantial soil erosion or the loss of topsoil? Finding: Less than Significant Impact. (EIR, p. 2.8-16 and -18).

Explanation:

Development activities can accelerate erosion through vegetation removal, drainage pattern alterations, and cut/fill slopes that disrupt flows and expose soils to increased water and wind erosion. The DEIR determined that the Solar Project's strategic siting of panels, service roads, and drainage channel bridges prevents disturbance to on-site channels, ensuring that development will not substantially alter existing drainage patterns or elevate erosion risks. The preliminary geotechnical report for the Solar Project includes grading recommendations for temporary excavation activities occurring during the rainy season to prevent runoff water from entering the excavation and eroding the slope faces. A final geological technical report prepared by a qualified geologist is required for both the Solar Project and future buildout of the Residential GPA site. This report shall evaluate the property's geologic characteristics and vulnerability to hazards, including soil erosion during construction, and include final recommendations to mitigate risks during site development.

In addition, both components are required to prepare a Stormwater Pollution and Prevention Plan (SWPPP), dust control plans and BMPs consistent with City Municipal Code Section 19.64.030 (Clearing and Plant Removal) at the time construction is proposed. Once operational, the Solar Project will be revegetated to mimic the current native condition, which will control erosion from storm water across the site. At buildout of the Residential GPA site, future residential projects will include soil-retaining features such as landscaping, paved driveways, roadways and sidewalks, fencing, and local stormwater management systems. The implementation of these soil erosion control features will limit the potential for wind and water erosion from causing a significant effect. Less than significant impacts are anticipated.

19 4. Unstable Soils
Threshold:
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.

Finding: Less than Significant Impact. (EIR, p. 2.8-18 and -20).

Explanation:

Landslides: see response E.2, above.

Lateral Spreading: Lateral spreading is a type of liquefaction-induced ground failure as a result of displacement atop a liquified layer. There is no associated risk for lateral spreading given that groundwater is at a depth greater than 50 feet. The failure caused by liquefaction on slopes or any area within or near the property is considered low.

Therefore, no impacts from lateral spreading are anticipated.

Subsidence: The nearest land subsidence hazard zone to the Project site is Lucerne Lake, located approximately 52 miles northwest. Disturbance related to construction and operation are not associated with inducing soil settlement and thus, implementation of the Project would have no effect on the site’s probability for subsidence. No impact would occur.

Collapse: For both the Solar Project and future buildout of the Residential GPA site, a geological technical report by a qualified geologist is required where the property’s characteristics and susceptibility for geological hazards, including soil collapse, would be evaluated. As a result, impacts related to soil collapse will be less than significant.

F. GREENHOUSE GAS EMISSIONS

1. Greenhouse Gas Emission Impacts on Environment
Threshold:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Finding: Less than Significant Impact. (EIR, p. 2.9-15 through -20).

Explanation:

Development of the proposed Solar Project reduces demand on the electrical grid by generating renewable energy onsite, thereby off-setting electricity typically sourced from the electric grid power mix. Analysis in the EIR estimated the Solar Project could offset an average of 93,050,290 kWh per year. Per the Project Air Quality and GHG Report, 93,050,290 kWh sourced from the SCE grid would result in approximately 14,697 metric tons of CO2e (MTCO2e) emissions annually, meaning the Solar Project would achieve a proportional annual reduction of 14,697 MTCO2e.

20 The annual CO2e emissions from the construction (21.6 MTCO2e/yr) and operation (0.15 MTCO2e/yr) of the Solar Project and the Solar Project’s CO2e emissions reduction would result in a net reduction of 14,675.25 MTCO2e per year and would not exceed the MDAQMD significance threshold of 100,000 short tons of CO2e (90,718 MTCO2e) per year. Buildout of the Residential GPA would similarly not exceed the MDAQMD significance threshold with estimated annual emissions of 1,813.58 MTCO2e. Overall, emission reductions of the Solar Project would offset the emissions generated by buildout of the Residential GPA, and still result in a total reduction in GHG emissions of 12,861.67 metric tons per year.

Under CEQA, the Project’s direct greenhouse gas emissions are deemed less than significant because the Project, as a whole, achieves an overall reduction in greenhouse gas emissions.

2. Conflict with Greenhouse Gas Reduction Plans and Regulations Threshold:
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Finding: Less than Significant Impact. (EIR, p. 2.9-20 through -21).

Explanation:

The Solar Project would ultimately reduce regional grid demand for electricity by 93,050,290 kWh annually, resulting in a GHG reduction of 14,675 MTCO2e annually, resulting in a net positive impact on the environment with regard to GHG emissions.

Development of Residential GPA site would not result in any increase in GHG emissions as compared to the development permissible under the City’s existing zoning and General Plan. Future residential development is subject to local, regional, and statewide building codes including California Building Standards Code, Title 24, Part 11 (CALGreen) which is aimed at increasing energy efficiency of buildings.

Overall, the Project aligns with applicable plans, policies, and regulations designed to reduce greenhouse gas (GHG) emissions. Moreover, the Project is expected to achieve a net reduction in GHG emissions, thereby contributing to state and local GHG reduction goals. As a result, its impacts are anticipated to be less than significant.

G. HYDROLOGY AND WATER QUALITY

1. Groundwater Supplies
Threshold:
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

21 Finding: Less than Significant Impact. (EIR, p. 2.11-20 through 2.11-22).

Explanation:

Buildout of the proposed Project has an estimated annual water demand of 0.45 AF from the Solar Project, and 13.8 AF from the Residential GPA. This water demand represents approximately 0.02 percent of TPWD’s total planned increases in demand of 3,660 AFY by 2045. According to the TPWD 2020 UWMP, the District maintains an existing and projected annual water supply of 6,995 AF through 2045, which is an excess supply of 3,335 AF when compared to demand. The Project’s water demand increase represents less than 1 percent of TPWD projected excess available water supply through 2045.

The Project site will maintain stormwater sheet flow where feasible, allowing for on-site soil infiltration and groundwater recharge.

Therefore, given the Project’s annual water use and minimal disruption of on-site soil water infiltration, the Project will not substantially decrease groundwater supplies or interfere substantially with groundwater recharge, and will not impede sustainable groundwater management of the basin. Impacts will be less than significant.

2. Alter Drainage Patterns: Erosion/Siltation
Threshold:
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on-or off-site; ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-or off-site;
iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv) impede or redirect flood flows?
Finding: Less than Significant Impact. (EIR, p. 2.11-22 through 2.11-25).

Explanation:

Flows generated from the 100-year 24-hour storm on the Solar Project site are conveyed to three ephemeral drainages that maintain continuous channel features. Results of the Hydrology and Hydraulics study concluded that the anticipated shifts in hydrology are minimal and no scour would occur around proposed bridge abutments, as they will be

22 located outside of the 100-year, 24-hour inundation areas. The City will require a Final Drainage Study prior to issuance of grading permits, demonstrating Project design preserves the drainages’ natural flow patterns, and minimizes scour within the project site (which would result in increased sediment transport downstream).

Implementation of City required BMPs in the SWPPP will reduce pollutants of concern that may enter nearby receiving waters and help reduce short and long-term water quality impacts caused by the construction and operation of the proposed Project. The minimal increase in impervious surfaces proposed by the Solar Project is expected to have negligible effects on runoff, erosion, and siltation, resulting in a less than significant impact on surface hydrology, including flooding.

For development of the Residential GPA site, the City requires all development projects prepare a hydrology study in conjunction with entitlements to ensure site drainage is designed to reduce potential impacts from flooding. These standard requirements assure that impacts associated with drainage patterns, siltation and erosion, and off-site flooding remain less than significant.

H. LAND USE AND PLANNING

1. Conflict with Land Use Plan, Policy or Regulation
Threshold:
b) Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Finding: Less than Significant Impact. (EIR, p. 2.12-11 through -18).

Explanation:

The proposed Project includes a Solar Project and Residential GPA. The Solar Project’s proposal for a commercial solar facility is currently not a permitted land use under the City’s 2012 General Plan, however the General Plan is a living policy document that is updated to reflect evolving needs of the City. The Residential GPA is required to assure that the Solar Project is consistent with SB 330, and that there is no net loss in residential units if the Solar Project GPA is approved.

The EIR considered four criteria for analyzing potential conflicts the Project, as a whole, may have with land use plans, policy, or regulation, including:
(1) Would the Project adversely impact the existing community (2) Is the Project consistent with the intent of the vision, goals, and policies of the General Plan as a whole
(3) Does the Project prescribe reasonable controls and standards for affected land uses to ensure compatibility and integrity of those uses with other established uses

23 (4) That the Project provides for the protection of the general health safety and/or welfare of the community.

The EIR determined that the Solar Project, in conjunction with the Residential GPA, would not result in significant adverse impacts with respect to the criteria listed above. This conclusion is based on the following factors:

1. The Project would not directly interfere with existing residential communities.

2. Development of a solar facility is consistent with the goals and policies in the City's General Plan Conservation and Open Space Element, which support incorporating renewable energy sources to power existing and future development.

3. The Project would help the City implement greenhouse gas reduction targets.

4. Adoption of the proposed Residential GPA would enable the City to remain consistent with SB 330's "no net loss" requirement.

5. The Residential GPA would expand the range of residential lot types and future housing options in the City, thereby implementing Housing Element goals related to providing a variety of densities for future development.

6. The new E zone established for the Solar Project site includes development standards, such as setbacks, glare control, night lighting restrictions, impact fees, use permits, fencing requirements, and decommissioning obligations, to ensure compatibility with established land uses in the planning area.

7. Compliance with applicable state, regional, and local standards would result in less-than-significant impacts to the general health, safety, and welfare of the community.

I. NOISE

1. Ambient Noise Levels
Threshold:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; Finding: Less than Significant Impact. (EIR, p. 2.13-10 through -16).

Explanation:

The Project will generate noise during each phase of development including construction, operation, and decommissioning for the Solar Project. Long term noise on the Solar Project site will be caused by on-site inverters and transformer. The EIR determined these sources of noise would marginally contribute to the local environmental noise and occur below detectable levels to nearby receptors. In response to noise concerns raised in connection with the Draft EIR, the Project applicant has submitted additional technical noise analysis included as Appendix B of the FEIR, further demonstrating that the nearest sensitive noise receptors (located over 1,400 feet from the property line) are not expected

24 to perceive noise from on-site inverters at any point during daytime and nighttime hours.

Therefore, noise impacts are less than significant.

As it relates to the Residential GPA, no noise impacts would occur on the southern parcel until development occurs. Currently no formal development proposal has been submitted and the southern parcel will remain undeveloped and unoccupied. When development is proposed, noise levels generated by single family homes would be analyzed under CEQA, but are not expected to significantly impact the environment. Therefore, the Residential GPA will not contribute substantially to the regional ambient noise now or in the future. Less than significant impacts will occur.

2. Groundborne Vibration and Noise Levels
Threshold:
b) Would the Project result in generation of excessive groundborne vibration or groundborne noise levels?
Finding: Less than Significant Impact. (EIR, p. 2.13-16 through -19).

Explanation:

On-site activities related to the Solar Project’s construction and decommissioning will result in groundborne vibration. However, these impacts will be temporary and occur at a substantial distance from sensitive receptors and structures. Any potential impact will be further minimized by the Project’s avoidance of sensitive nighttime hours for on-site and off-site construction and decommissioning work. No sources of vibration are expected during operation. Therefore, no adverse effects would be imposed on nearby sensitive receptors.
he Residential GPA in and of itself would not introduce a source of ground borne vibration to the southern parcel. Nor does the development propose any use of the southern parcel which could introduce a source of vibration. Impacts of the Project overall are expected to be less than significant.

J. POPULATION AND HOUSING

1. Population Growth
Threshold:
a) Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Finding: Less than Significant Impact. (EIR, p 2.14-5 through -7).

25 Explanation:

The Solar Project would not increase the number of dwelling units or population on-site.

Rather the Solar Project will eliminate the potential for 48 residential units on the northern 184 acres of the site. The Residential GPA would replace the residential units lost under the Solar Project by transferring them to the 60 acres at the southwest corner of Noels Knoll Road and Samarkand Drive. Because the units are planned under the current General Plan, the Residential GPA will have no impact on population growth, but will rather move that planned population from the north half to the south half of the property.

Overall, the Project would not induce substantial population growth.

K. PUBLIC SERVICES
Threshold:
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
• Fire Protection
• Police Projection
• Schools
• Parks
• Other public facilities
Finding: Less than Significant Impact. (EIR, p. 2.15-6 through -9).

Explanation:

Fire Protection
All developments within Twentynine Palms are subject to County and State fire codes to reduce the potential for fire to start or spread. Both the Solar Project and future residential projects under the Residential GPA would be subject to review and approval by the San Bernardino County Fire Protection District (SBCoFD) and would be required to design access throughout the site for emergency vehicles. When a residential project is planned for this site, the SBCoFD would review the plan and provide project-specific recommendations, including compliance with the Fire Code in place at the time that development is proposed. The Solar Project future residential would directly pay the SBCoFD for fire protection services. Payment/costs are commensurate with services provided, and would offset the cost of responding to an incident at the property. Impacts to fire protection services are expected to be less than significant.

26 Police Protection
Law enforcement services for the City are funded by the City’s property tax revenue.

Demand for law enforcement services to the Solar Project site would be minimal, and the property tax revenue earned from the units built as a result of the Residential GPA would contribute on-going operational funding and would offset the potential impacts to the provision of police services. Impacts to police protection resources would be less than significant.

Schools
The Solar Project would be an unmanned photovoltaic electric generating facility and would have no direct impact on the Mojave Unified School District (MUSD). Projects proposed under the Residential GPA would be subject to MUSD developer fees, which are calculated on a square-foot basis. The fee for a residential project would be calculated when a site plan is available. The school developer fees, as stipulated in Government Code §65995 would mitigate any impacts associated with the Project’s student enrollments. Impacts would be less than significant.

Parks
Recreational opportunities are funded by the General Fund. The unmanned Solar Project would result in extremely minor, if any, impacts to the City’s parks, recreation and community services. As residents populate the Residential GPA Project site, potential impacts to the City’s recreational and community services would be offset by new property tax contributions. Impacts would be less than significant.

L. RECREATIONAL RESOURCES
Threshold:
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
b) Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

Finding: Less than Significant Impact. (EIR, p. 2.16-6 through -8).

Explanation:

The Solar Project’s construction and operation are not expected to increase the City population, will not cause the physical deterioration of existing facilities, and will not require the expansion or construction of new recreational facilities. Future residential development would not increase the City’s housing inventory beyond that already planned in the General Plan. Future subdivisions to facilitate the development of these units would be subject to conditions of approval stipulating fees and/or parkland dedications and would also increase property tax revenues to the City which would allow the City to expand or construct recreational facilities incrementally as new residents’ demand increases. Impacts are expected to be less than significant.

27 M. TRAFFIC AND TRANSPORTATION

1. Conflicts with Transportation-Related Program, Plan, Ordinance or Policy Threshold:
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

Finding: Less than Significant Impact. (EIR, p. 2.17-10 through -12).

Explanation:

The Solar Project’s off-site improvements include buildout of a private driveway off Two Mile Road, routing power lines beneath the driveway and along the north side of Two Mile Road, as well as the dedication of 33 feet of right-of-way along the site’s north, south, and east boundary for future buildout of Samarkand Drive, Amboy Road, and Noels Knoll Road. The Project does not propose the development of these roadways at this time.

Roadway improvements will be constructed in conformance with the California Building Code, thus reducing potential Impacts associated with conformance to City improvement requirements to less than significant levels.

Impacts during construction activities are anticipated to be direct but temporary, and less than significant, because existing roadways operate above the General Plan’s policy of LOS C. Adverse effects to the City’s circulation system during construction of the Solar Project and future residential development on the Residential GPA site would end when construction work is complete.

Once operational, the Solar Project will be unstaffed and monitored remotely with infrequent truck trips for repair and maintenance activities. The rezoning and land use change would not inherently conflict with any traffic related policies, plans, or ordinances governing new development with respect to the City’s circulation system. Future residential development is required to prepare a stand-alone CEQA environmental assessment in compliance with Section 19.66.050 (CEQA Process) of the City Municipal Code to assess project-specific traffic impacts. Future residential projects would be required to comply with Twentynine Palms’ Circulation Plan, outlining future roadway improvements, pedestrian trails, and public transit routes within the area. Compliance with policies and standards in place at the time that development occurs will assure that impacts to these policies and programs remain less than significant.

2. Vehicle Miles Traveled
Threshold:
b) Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?

28 Finding: Less than Significant Impact. (EIR, p. 2.17-13 through -14).

Explanation:

The Project’s operational VMT analysis was based on the County of San Bernardino 2019 Transportation Impact Study Guidelines. Per the County Transportation Impact Study Guidelines, projects that generate less than 110 daily vehicle trips may be assumed to cause less than significant impacts and thus are exempt from VMT analysis. The solar facility will be monitored remotely and occasionally serviced on an as-needed basis, estimated to occur approximately three times per year. The proposed Solar Project would not cause substantial impacts related to the increase of the local or County VMT.

Future residential project(s) proposed on the Residential GPA site would be required to prepare a VMT assessment in conformance with City and County policy, as part of the review of the project(s) under CEQA. Because the Residential GPA would not change the number of units allowed in the City under existing General Plan conditions and would not change the pattern of development in this area of the City, it would not conflict with CEQA Section 15064.3 (b) and thus, impacts would be less than significant.

3. Emergency Access
Threshold:
d) Result in inadequate emergency access.

Finding: Less than significant (EIR, p. 2.17-14 through -15) Explanation:

During the Solar Project’s construction and operation, clear and unobstructed access to these evacuation routes will be provided as required by the conditions of approval for the Solar Project, which will include a construction management plan for circulation. Future residential development on the Residential GPA site would be required to prepare a separate CEQA evaluation and demonstrate compliance with local safety standards including adequate access to internal roads in the event of an emergency. Compliance with these safety standards will be evaluated by the County Sheriff and Fire Department prior to development. As such, no conflict or violations would occur relating to the Solar Project or Residential GPA’s implementation of emergency access standards in the future.

N. UTILITIES AND SERVICE SYSTEMS

1. Water, Wastewater, Storm Drainage, Electric, Natural Gas and Telecom
Thresholds:
a) Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

29 Finding: Less than significant (EIR, p. 2.19-11 through -16) Explanation:

Domestic Water
Water use during construction activities will be minimal, temporary, and supplied by water trucks. Once operational, the Solar Project site will include 160,000 solar panels and supporting infrastructure in service of the facility. No water service to the site is proposed.

The Solar Project will not generate a daily water demand because the property does not include land uses that are water dependent. The Solar Project will primarily operate without water, except in the event of a severe sandstorm, requiring each solar panel to be cleaned. An annual operational water demand of 0.45 AFY will not cause a significant reduction in TPWD’s project water supply for current and future development within the City. The Solar Project will not require the extension of TPWD’s domestic water system to service its water needs. No environmental impact related to the relocation or construction of new utility infrastructure for domestic water service would occur as a result of the Project. Therefore, no impacts are anticipated.

The Residential GPA could generate a demand for 13.80 AFY, consistent with General Plan build out in the Project area, since no increase in density would occur. The Residential GPA would not change the total planned increase in demand of 3,660 AFY by 2045 predicted by the TPWD, since it is consistent with existing General Plan growth.

Domestic water would be transmitted through existing distribution lines and extended into these projects. Impacts associated with water infrastructure will also be reviewed when projects are proposed in the future, and will be required to comply with City and Building Code water conservation requirements in place at that time. Impacts to domestic water infrastructure are expected to be less than significant.

Flood Control
According to the FEMA Flood Map, the Project site is in flood Zones X and D, as identified by FIRM panel 06071C8190J. Flood Zone X is described as outside of the 0.2% annual chance floodplain. Flood Zone D is an area of possible yet undetermined flood hazards.

The Solar Project proposes to install bridges over the ephemeral streams located on the Project site, thereby avoiding impacts to flow during significant storm conditions. Given the lack of flood control improvements in the City and the Project area, the Solar Project will not generate a need for flood control infrastructure. As such, the property’s natural drainage system will not be modified or substantially altered at any point in the Project’s construction or operation.

The Project would be required to comply with applicable standards pursuant to Chapter

19.62 (Flood Management Regulations) of the City Municipal Code. These standards include on-site control of storm flows to assure that they maintain pre-development offsite flows after construction. Future residential development on the Residential GPA site is required to prepare a hydrology study in conjunction with entitlements to ensure site drainage is designed to reduce potential impacts from flooding. The hydrology study must demonstrate that the project proposed can contain the 100 year storm on site through

30 retention, detention or other means; that it manages off-site flows through the site where necessary, and assures that these flows, when exiting the site, do so in a manner consistent with pre-development conditions. With implementation of these standard requirements, the Project would not result in a significant change in drainage patterns so as to increase flood risk.

Electricity, Natural Gas, Other Utilities
Existing electric, natural gas and telecommunications facilities currently occur in the area surrounding the Project site.

The Solar Project will generate renewable energy to be distributed and sold by Southern California Edison (SCE). At buildout, the Project is expected to produce 93 GWh of electricity. Considering the Solar Project would not require electricity in the operation phase, the likelihood for the Project to adversely affect SCE energy supply or require the extension of Edison’s existing infrastructure is negligible. The connection to the substation and the improvements required at the Carodean Substation will be installed as part of the Solar Project’s construction and will not cause the addition of other infrastructure. Buildout of the Solar Project does not include equipment fueled by natural gas. The Solar Project may require telecommunication, considering the property will include the use of CCTV cameras for security purposes and remote sensing equipment for solar panels. These facilities would not represent a significant use of telecommunication capacity and would not significantly impact telecommunication services or cell phone providers.

The Residential GPA will generate a need for 905.6MWh or electricity and 3,723.5 MMBtu in natural gas at build out, consistent with consumption expectations under the General Plan. This usage represents 0.94% of the City’s electricity consumption and 1.73% of natural gas consumption. This increase will not significantly impact electric or natural gas infrastructure, and would represent a less than significant impact to this infrastructure.

2. Sufficient Water Supplies
Thresholds:
b) Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Finding: Less than significant (EIR, p. 2.19-17)
Explanation:

The Solar Project’s construction and operation will generate a marginal water demand.

Construction water use would occur for dust control, and may be required for native plant transplants. Operational water use would result in a recurring demand of 0.45 AF per year to rinse any sand, dust, or debris from the solar panels after a major sandstorm. The Project’s operational water demand would account for 0.01% of the total planned increases in demand of 3,660 AFY by 2045.

31 The Residential GPA would generate an annual water demand of 13.8 AFY, which accounts for approximately 0.89% of the total planned increase in demand of 3,660 AFY by 2045. The TPWD has supply nearly twice what it is projected to require in 2045.

Therefore, the Residential GPA water demand will not impact the District’s ability to provide water in normal, single dry or multiple dry years, and impacts will be less than significant.

3. Solid Waste
Threshold:
d) Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e) Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Finding: Less than significant (EIR, p. 2.19-17 and -19) Explanation:

Waste generated during the Project’s construction and future project construction would be required to comply with the City’s 50% diversion requirement, which mandates that at least half of all waste material generated from new development be diverted from landfills as detailed in City Municipal Code Section 18.14.020 (Requirements for Newly Constructed Structures). Considering most of the waste generated during construction will be recyclable material, the Project is likely to exceed the 50% requirement and thus contribute minimally to materials disposed at the Landers Landfill.

Waste generated from operation of the Solar Project would be limited to maintenance services and solar panel replacement. Solar panel replacement would be infrequent, and the waste generated by such a replacement would be conditioned by the City to be removed at the time of replacement. Therefore, replacement of solar panels is not expected to exhaust the waste capacity of Lander Landfill, and less than significant impacts would occur.

Future residential development would be required to operate in conformance with the City’s Municipal Code regarding solid waste management. At the time that development is proposed, the City will analyze new residential projects and determine their potential impacts to solid waste based on the standards in place at that time, and will require compliance with all those standards. On that basis, the Residential GPA is not expected to generate significant amounts of waste, impact local landfills, or conflict with laws and standards regarding solid waste management. Less than significant impacts will occur.

32 SECTION 5: FINDINGS REGARDING ENVIRONMENTAL IMPACTS MITIGATED TO A LESS THAN SIGNIFICANT LEVEL.

The City Council hereby finds that feasible Mitigation Measures have been identified in the EIR and this Resolution that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:

A. BIOLOGICAL RESOURCES

1. Sensitive and Special Status Species
Threshold:
a) Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.5-20 through -28).

Explanation:

As evaluated by the Project-specific Biological Resources Technical Report (BRTR), the Project site includes suitable habitat for several local and special status plants and wildlife species, as well as migratory birds. Most notably, the Mojave desert tortoise was observed in the solar project site, and the burrowing owl and desert kit fox have a moderate to high probability of occurring within the Project area. Given the occurrence or potential future occurrence of these and other biological resources within the Project area, implementation of Mitigation Measures BIO-1 through BIO-7, BIO-9 and BIO-10 are required to ensure impacts are reduced to less than significant levels.

The southern parcel may include the same or additional biological resources than those identified by the Project-specific BRTR. A site-specific field survey and protocol-surveys will be conducted as part of the project-level CEQA analysis once a formal residential development, or developments, is proposed within the area. For future development, implementation of Mitigation Measure BIO-7 as well as other mitigation measures identified below, as applicable, would reduce direct impacts to sensitive and special status wildlife and plant species to less than significant levels.

Mitigation Measure BIO-1
Construction-Related and Operational-Related Indirect Impacts to Biological Resources.

For each phase of project implementation, including solar decommissioning activities, suitable habitat for special-status species (i.e., all undeveloped land or re-naturalized land within the project site) with potential to occur in the project, the project’s Applicant/Developer shall include the following in the construction contractor’s plans and specifications to address indirect construction-related impacts to special-status species:

33 • Biological Monitoring. A qualified project biologist shall conduct monthly checks throughout the duration of project construction in order to inspect construction fencing, ensure that practicable measures are being employed to avoid incidental disturbance of habitat, species of concern, and other sensitive biological resources outside the project footprint, and ensure that all applicable requirements from the mitigation measures are being upheld.
• Worker Environmental Awareness Training. Prior to grading, a pre-construction meeting shall be required that includes a training session for project personnel by the biological monitor. The training shall include (1) a description of the species of concern and its habitats; (2) the general provisions of the applicable regulations pertaining to biological resources, including the Endangered Species Act and the Clean Water Act; (3) the need to adhere to the provisions of the Endangered Species Act, the Clean Water Act, and other applicable regulations; (4) the penalties associated with violating the provisions of the Endangered Species Act, Clean Water Act, and other applicable regulations; (5) the general measures that are being implemented to conserve the species of concern as they relate to the project; and (6) the access routes to and from disturbance area boundaries within which the project activities must be accomplished.

Additionally, the training shall include the measures and mitigation requirements for the applicable resources. Copies of the mitigation measures and any required permits from the resource agencies shall be made available to construction personnel. The video may be recorded so that multiple personnel are able to watch the material. The training shall be provided in alternate languages, as needed. In addition, operations and maintenance personnel shall be required to watch the recorded training prior to entering the Project during operations, with the only exception being emergency situations. Copies of the mitigation measures and any required permits from the resource agencies shall be made available to operations and maintenance personnel. • Delineation of Property Boundaries. Before beginning activities that would cause impacts, the contractor shall, in consultation with the biological monitor, clearly delineate the boundaries with fencing, stakes, or flags, consistent with the grading plan, within which the impacts will take place. All impacts outside the fenced, staked, or flagged areas shall be avoided, and all fencing, stakes, and flags shall be maintained until the completion of impacts in that area. In addition, any avoided environmental resources shall be clearly delineated. Prior to implementing construction activities, the biological monitor shall verify that the flagging clearly delineates the construction limits and any sensitive environmental resources to be avoided.
• Standard Dust Control Measures. Standard dust control measures as per the Mojave Desert Air Quality Management District shall be implemented to reduce dust impacts on nearby conserved lands, plants, and wildlife. Measures include controlling speed to 15 mph or less on unpaved roads, replacing ground cover in disturbed areas as quickly as possible, frequently watering active work sites, installation of shaker plates, and suspending excavation and grading operations during periods of high winds. • Stormwater Pollution Prevention Plan. Prior to issuance of a grading permit for construction, the applicant shall submit a stormwater pollution prevention plan (SWPPP) to the City of Twentynine Palms that specifies best management practices

34 to prevent all construction pollutants from contacting stormwater, with the intent of keeping sedimentation or any other pollutants from moving off site and into receiving waters. The requirements of the SWPPP shall be incorporated into design specifications and construction contracts.
• Minimize Spills of Hazardous Materials. All vehicles and equipment shall be maintained in proper condition to minimize the potential for fugitive emissions of motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials. Hazardous spills and contaminated soil shall be immediately cleaned up and the contaminated soil shall be properly handled or disposed of at a licensed facility. Servicing of construction equipment shall take place only at a designated staging area. Staging areas shall not be located within the project’s avoidance areas.
• Wildlife Hazards. The following measures shall be implemented to ensure that wildlife do not become trapped, entangled, injured, or poisoned by construction activities:
o Structures in which wildlife may become trapped (e.g., open pipes, pits, trenches, etc.) shall be tightly covered at the end of each work day. If covering the structure is not possible, an escape ramp shall be provided to allow any wildlife that falls in to safely escape.
o Debris piles, construction materials, equipment, and other items that may be used as wildlife refuge shall be inspected for wildlife at the start of each work day and prior to disturbance. If wildlife is discovered, it shall either be moved out of harm’s way by a qualified biologist or allowed to move off of the study area on its own under supervision by a qualified biologist.
o Nets and mesh shall be made of loose-weave material that is not fused at the intersections of the weave, as nets with welded weaves present an entanglement risk.
o Toxic materials and garbage shall be removed from the work site and safely stored or disposed of at the end of each work day.
• Invasive Weeds. The project applicant shall be required to replant all temporarily impacted areas with native plants and remove invasive plants. The species proposed for replanting shall not include any plants found on the most recent version of the CalIPC California Invasive Plant Inventory (http://www.calipc.org/ip/inventory/index.php). • Noise. Proposed noise-generating land uses affecting suitable habitat for specialstatus species shall incorporate setbacks, berms, or walls to minimize the effects of noise on resources pursuant to applicable rules, regulations, and guidelines related to land use noise standards. For planning purposes, wildlife are not expected to be subjected to noise that would exceed rural residential noise standards. • Fencing. The solar array site shall include a 7-foot-high perimeter fence upon completion of construction and through the duration of operation to minimize the impact on sensitive or special-status biological resources occurring adjacent to the site.
• Lighting. All construction activities shall be conducted during the daytime, and lights shall not be kept on overnight in the construction area. While night lighting is not currently proposed, if it is required for security purposes during construction activities or operational activities, all exterior lighting along undeveloped land shall be fully shielded and directed downward in a manner that will prevent light spillage or glare

35 into the adjacent avoidance areas. As applicable, emergency maintenance work on the solar arrays at night would be performed using battery or gas-powered light stands that would be directed to the active work area.

Mitigation Measure BIO-2
Pre-Construction Nesting Bird Survey.

If construction or solar decommissioning activities must occur during the migratory bird nesting season (typically January 1 through July 31), an avian nesting survey of the Project site and within 500 feet of all impact areas must be conducted to determine the presence/absence of fully protected species, protected migratory birds, and active nests.

The avian nesting survey shall be performed by a qualified wildlife biologist within 72 hours prior to the start of construction in accordance with the Migratory Bird Treaty Act and California Fish and Game Code Section 3503, 3503.5, and 3513.

If an active bird nest is found, the nest shall be flagged and mapped on the construction plans along with appropriate buffer established around the nest, which shall be determined by the biologist based on the species’ sensitivity to disturbance (typically 300 feet for passerines and 500 feet for raptors and special status species). The nest area shall be avoided until the nest is vacated, and the juveniles have fledged. The nest area shall be demarcated in the field by flagging and stakes or construction fencing. On-site construction monitoring shall also be conducted when an active nest buffer is in place.

No project activities may encroach into established buffers without the consent of a monitoring biologist. The buffer shall remain in place until it is determined the nestlings have fledged and the nest is no longer considered active.

Mitigation Measure BIO-3
Pre-Construction Burrowing Owl Surveys and Avoidance
One pre-construction Burrowing Owl survey shall be completed no more than 14 days before initiation of site preparation or grading or solar decommissioning activities and a second survey shall be completed within 24 hours of the start of site preparation or grading or decommissioning activities. If ground-disturbing activities are delayed or suspended for more than 30 days after the preconstruction surveys, the Project site shall be resurveyed. Surveys for Burrowing Owls shall be conducted in accordance with protocols established in the Staff Report on Burrowing Owl Mitigation in 2012 or current version.

If Burrowing Owls are detected, and if impacts to Burrowing Owls cannot be feasibly avoided, the Project applicant will consult with CDFW and obtain appropriate take authorization from the CDFW through the CESA Incidental Take Permit (ITP) process. If requiring an ITP, mitigation for direct impacts to Burrowing Owl shall be fulfilled through compensatory mitigation at a minimum 1:1 habitat replacement of equal or better functions and values to those impacted by the Project, or as otherwise determined through the ITP process.

36 Mitigation Measure BIO-4
Pre-Construction Survey for Desert Kit Fox and Avoidance A pre-construction survey for Desert Kit Fox shall be conducted by a Qualified Biologist familiar with desert kit fox within 10 days before initiation of site preparation or grading activities to determine the presence/absence of Desert Kit Fox. The Qualified Biologist shall conduct a pre-project survey to attain 100% visual coverage within the Project area and a minimum 500-foot buffer to determine the presence or absence of desert kit fox individuals, dens, and sign. The project proponent shall provide the results of the survey to CDFW prior to start of Project activities. The survey report should identify the status of all identified dens, include an estimate of occupancy, and detail the methodology utilized to support these conclusions.

If potential dens are located, they shall be monitored by the Qualified Biologist. Trail cameras may be used to assist with observation but shall not be the sole basis upon which the status is determined. Permittee shall provide a determination if active dens can be avoided and buffered from Project activities to prevent take and disturbance with the survey results.

Should active Desert Kit Fox dens be present within the Project area that cannot be avoided with an adequate buffer, a Desert Kit Fox Relocation and Mitigation Plan shall be prepared by a qualified biologist in consultation with CDFW, and shall be implemented including protective measures such as the establishment of no disturbance buffer zones for active den and active natal den. No disturbance or relocation of active dens may take place when juveniles may be present and dependent on parental care.

Permittee shall block off inactive dens within the buffer zone with rocks and sticks to discourage use during Project activities and remove when construction is complete. The Qualified Biologist shall periodically check the inactive burrows remain blocked and are not reoccupied During Project activities including construction and decommissioning.

A report to evaluate the success of the relocation efforts and any subsequent reoccupation, if applicable, shall be provided at the end of the construction period. Data shall be readily available to the CDFW upon request. If an injured, sick, or dead desert kit fox is detected on any area associated with the project, the designated CDFW personnel at both the Ontario office and the Wildlife Investigation Lab shall be notified as described within the Desert Kit Fox Plan.

Mitigation Measure BIO-5
Desert Tortoise Avoidance and Minimization Measures.

Relocation and/or take of a desert tortoise may not occur without consultation with the USFWS and CDFW. The phrases “authorized biologist” and “desert tortoise monitor,” as used herein, are taken from the most up to date USFWS guidance (USFWS 2009), and the definitions, roles, and responsibilities of each will be adhered to during construction.

Also, in accordance with guidance in USFWS (2019), if tortoises or fresh sign are observed during project construction, all activities that could result in take of desert tortoise shall cease immediately until an authorized biologist can confirm that no desert tortoise is present or the desert tortoise moves off the site on its own under the supervision of a qualified biologist.

37 Desert tortoise exclusion fencing shall be installed around all construction areas prior to the initiation of vegetation clearing. Once the area is fenced, desert tortoises shall be removed from the area by the authorized biologist if the appropriate state and federal permits have been obtained or be allowed to move off site on their own by creating a gap in the fence under the supervision of a qualified biologist. Note that they cannot be “harassed” or otherwise directly encouraged to move off site without obtaining a federal take permit (or as directly authorized/directed by the USFWS and CDFW, if applicable).

If the desert tortoise is allowed to move off site on its own, the gap in the exclusion fence will be closed once the tortoise has left the fenced area. After desert tortoise is no longer inside the fence, the fence shall be maintained in place until construction is completed.

The purpose of the fence is to preclude all desert tortoises from the construction impact zone, including desert tortoises that may try to get back to their on-site burrow(s). A minimum of two tortoise-free pre-construction clearance survey passes conducted by the authorized biologist or desert tortoise monitor, after exclusion fencing has been installed, are required to ensure that desert tortoises are no longer on the site and construction may commence. If the fence fails or is subject to gaps then two more tortoise-free survey passes must occur before work can resume.

The fence shall be constructed of 0.5-inch mesh hardware cloth and extend 18 inches above ground and 12 inches below ground. Where burial of the fence is not possible, the lower 12 inches shall be folded outward against the ground and fastened to the ground so as to prevent desert tortoise entry. The fence shall be supported sufficiently to maintain its integrity, be checked at least weekly during construction by the authorized biologist or desert tortoise monitor, and maintained when necessary, by the project proponent to ensure its integrity. Access points will be protected by installing the latest specification entrance gates/grates/etc. In all cases, the protection system will not include gaps sufficient for even the smallest hatchling to pass through. Common raven perching deterrents shall be installed as part of the fence construction. If unsupervised gaps are detected, then pre-construction clearance surveys will be required after remediation and prior to resumption of work.

All project-related facilities and construction-related areas, such as staging areas and personnel parking areas, other than the access road and Two Mile Road discussed below, shall occur within the fenced area. All related infrastructure shall also remain within the fenced area.

As part of the Worker Environmental Awareness Program (WEAP) training, all workers shall be informed to check beneath any parked vehicle immediately prior to moving the vehicle while in desert tortoise habitat outside fenced impact areas. After the desert tortoise-exclusion fence has been installed, all personal vehicles and construction equipment shall be parked inside the fenced area. Vehicular travel outside of established roads (including Samarkand Road, Sunrise Road, and private roads (once constructed) prior to removal of desert tortoises shall be prohibited. If a desert tortoise is found beneath a vehicle, the authorized biologist shall be contacted to move it from harm’s way, if the appropriate state and federal permits have been obtained. Alternatively, the vehicle shall not be moved until the desert tortoise has left of its own accord under supervision of a

38 qualified biologist. The authorized biologist shall be responsible for taking appropriate precautions to ensure that any desert tortoise moved in this manner is not exposed to temperature extremes that could be harmful to the animal.

The desert tortoise exclusion fence during construction shall have as part of its design either a desert-tortoise-proof cattle guard, desert tortoise exclusion gate, exclusion grate, or a breakaway portion of fence that can be opened and closed to allow vehicle access.

The gate or modified fence shall remain closed at all times during construction except to allow vehicles to enter or leave the site. This measure may be modified if the desert tortoise monitor, based on surveys of surrounding areas, determines that there is little or no likelihood of desert tortoises entering the site through the opening. If the authorized biologist determines that the gate may be left open and subsequently finds that a desert tortoise has entered the construction area through that opening, a gate or modified fence shall be installed and kept closed after desert tortoise has left the site.

Prior to installing the fence, the authorized biologist shall survey the area along which the fence will be installed, with the goal of establishing a fenced area that allows for as many desert tortoise burrows to remain outside the fenced area while still accommodating project construction. The authorized biologist shall consider the direction of the burrow and know that burrows may be 30 to 40 feet long. So, not only the burrow opening, but also the burrow's end, shall be considered and excluded if the fence line is to be altered.

Any desert tortoise burrows found within the proposed fence line that cannot be avoided shall be hand excavated by the authorized biologist prior to clearing of the fence line or installation of the fence. Burrow excavation procedures are discussed in Desert Tortoise Council (1999). The authorized biologist or desert tortoise monitors shall remain on-site to monitor the installation of the fence.

After installing the fence, and before any other activities occur within the fenced area, the authorized biologist shall survey the site for desert tortoises. If possible, the surveys shall occur immediately after installation of the fence and several days prior to brushing or grading activities. The site shall be searched at least two consecutive times with a negative survey result, meaning if the site is searched and desert tortoise are found, two additional surveys must be completed until the result is negative. Burrows shall either be excavated as they are found or flagged for excavation later. Each burrow shall also be carefully checked for viable desert tortoise eggs. If found, the authorized biologist shall have a plan for disposition of these eggs outside the impact zone but within the adjacent area and move the eggs in such a way that the viability of the eggs is not adversely affected by their movement (Desert Tortoise Council 1999). Handling of desert tortoise eggs would require consultation with CDFW and the USFWS. Security fencing shall be placed inside of the desert tortoise exclusion fencing, which shall remain in place for the duration of project operations (e.g., excluding all wildlife from entering the Project), as recommended by USFWS and CDFW (Lalumiere, pers. comm. 2025).

Prior to conducting vegetation clearing or grading activities in desert tortoise habitat outside permanently fenced areas of the project site (i.e., off-site access road, gen-tie alignment, and substation), the authorized biologist or desert tortoise monitor under the

39 supervision of an authorized biologist will survey the access road impact area immediately prior to conducting these activities to ensure that no desert tortoises are present. Because of the linear nature of the access road, the applicant may conduct surveys at any time of year but shall avoid impacts to potential and known desert tortoise burrows, in addition to avoiding impacts to desert tortoises. Potential burrows will be buffered by 30 feet unless they can be shown to be unoccupied, or the authorized biologist believes a smaller buffer is appropriate in order to protect underground burrows. Examples of situations where smaller buffers may be appropriate may include the following: burrow entrances are obviously oriented away from the impact area; the type of activity near the burrow is not likely to impact desert tortoise (e.g., the activity will not have the potential to crush a burrow); the burrow is adjacent to an existing thoroughfare that receives vehicle use already and the proposed activity is similar in nature; etc. Temporary desert tortoise exclusion fencing will be installed along the access road. Once construction along the access road is completed, the desert tortoise exclusion fencing shall be removed. No vehicle or equipment parked outside any of the fenced areas will be moved prior to inspecting the ground beneath the vehicle or equipment for the presence of desert tortoise. If present, the desert tortoise will be left to move on its own under supervision by a qualified biologist.

The WEAP required under Mitigation Measure BIO-1 shall also include the following information and requirements specific to protection of desert tortoise:
- A description of the desert tortoise, including adults and juveniles - Color photographs of desert tortoise
- Protections to the desert tortoise under the ESA and CESA and potential penalties for violating the ESA and CESA
- Measures implemented under the project to protect desert tortoises and to conserve their habitat
- The requirement that all workers shall check beneath any parked vehicle immediately prior to moving the vehicle while in desert tortoise habitat outside fenced impact areas and what to do if a desert tortoise is found
- Information for contacting the authorized biologist or desert tortoise monitor in case personnel observe one or more desert tortoises on the project site - All trash that may attract desert tortoise predators (e.g., ravens, domestic dogs) shall be removed from the work site at the end of each day.
- If desert tortoises occur in a work area and will not leave of their own accord, then it will be necessary to coordinate with the USFWS and CDFW. Physical relocation of a desert tortoise may not occur unless approved by the wildlife agencies, and this may require authorizations pursuant to Incidental Take Permits from the USFWS and CDFW.
- The biological monitors shall have the authority to stop work at all times, if proper avoidance measures are not in place or project activities may potentially result in impacts to desert tortoises.
- A speed limit of 15 mph shall be maintained at all times except on county/state roads. - Work shall be restricted to daylight hours at all times when working within or adjacent to desert tortoise habitat, except in an emergency, to avoid vehicle traffic when tortoise may be on access roads at times of poor visibility.

40 This mitigation measure would also be applied in the event of future construction of roads subject to the future road dedications.

Mitigation Measure BIO-6
Desert Tortoise Habitat Compensatory Mitigation.

The project applicant shall implement habitat mitigation for 142.1± acres of permanent impacts to occupied desert tortoise habitat. Impacts are to be compensated at a minimum 1:1 ratio either through one or a combination of the following:

Option 1: Purchase of off-site habitat mitigation lands that contain suitable habitat for desert tortoise.

Option 2: Purchase of mitigation credits at a mitigation bank for desert tortoise.

The applicant shall submit a document outlining the permanent impacts to desert tortoise habitat, along with a compensatory mitigation plan, to the USFWS and CDFW for review and approval. The Project applicant shall also be required to obtain an Incidental Take Permit (ITP) from the CDFW and USFWS where the ITP includes an analysis of whether Project impacts would jeopardize the continued existence of the species, provide suitable avoidance and minimization measures to reduce potential impacts, and adequately mitigate through conservation or mitigation banking. Unavoidable impacts to occupied suitable habitat shall be compensated at a minimum of 1:1, as described above, in addition to implementing all other measures and condition of the ITPs. This mitigation measure would also be applied in the event of future construction of roads subject to the future road dedications.

Mitigation Measure BIO-7
Focused Surveys, Avoidance and Mitigation Outside of Solar BSA Development proposed for any portion of the site outside the Solar Project BSA shall be required to conduct the following surveys prior to issuance of grading permits: a general biological reconnaissance survey, including vegetation mapping, special-status plant survey, western Joshua Tree focused survey, desert native plant survey, desert tortoise (Gopherus agassizii) protocol-level survey, burrowing owl (Athene cunicularia) protocollevel survey, and an aquatic resources delineation. Focused surveys shall be conducted in accordance with the methods described in Section 3.2.4, Special-Status and Regulated Resources, of the project-specific Biological Resources Technical Report.

If the results of the general biological reconnaissance survey determine there are biological resources that are not evaluated in the Biological Resources Technical Report, then additional CEQA documentation would be required by the project applicant. If the general biological reconnaissance survey determines there are sensitive natural vegetation communities, and if jurisdictional aquatic resources, and/or desert native plants, desert tortoise, or burrowing owl are determined present, then the following applicable mitigation measures from Section 7 of the Project BRTR referenced below shall be implemented: Mitigation Measure BIO-2 (Construction-Related and OperationalPage 797 of 1008 41 Related Indirect Impacts to Biological Resources), Mitigation Measure BIO-3 (Desert Tortoise Avoidance and Minimization Measures), Mitigation Measure BIO-4 (Desert Tortoise Habitat Compensatory Mitigation), Mitigation Measure BIO-5 (Pre-Construction Burrowing Owl Surveys and Avoidance), Mitigation Measure BIO-6 (Pre-Construction Survey for Desert Kit Fox and Avoidance), Mitigation Measure BIO-7 (Pre-Construction Nesting Bird Survey), Mitigation Measure BIO-8 (Sensitive Vegetation Communities and Jurisdictional Resources Mitigation), Mitigation Measure BIO-9 (Avoidance and Minimization to Potential Jurisdictional Aquatic Resources), and Mitigation Measure BIO10 (Desert Native Plants Removal Permit).

Should special-status plant species and/or western Joshua Tree be determined present, then the following additional mitigation measures shall be implemented:

Special-Status Plants
Impacts to special-status plant occurrences shall be avoided to the greatest extent possible and minimized where avoidance is not feasible. Where impacts to special-status plant species cannot be avoided, mitigation is required. For direct impacts to specialstatus plant species, one or a combination of the following strategies shall be implemented:
- Avoidance and Minimization. Impacts to special-status plant occurrences shall be avoided to the greatest extent possible and minimized where avoidance is not feasible.
- Salvage. If a qualified ecologist determines that impacts to special-status plants cannot be avoided and it is feasible to effectively salvage the plants, that ecologist shall develop a restoration and mitigation plan based on the life history of the species impacted, as necessary, to mitigate project impacts. The plan shall include, at minimum, (a) collection/salvage measures for plants and/or seed banks to retain intact soil conditions and maximize success likelihood; (b) details regarding storage of plants and/or seed banks; (c) location of the proposed recipient site and detailed site preparation and plant introduction techniques details for top soil storage, as applicable; (d) time of year that the salvage and replanting or seeding shall occur and the methodology of the replanting; (e) a description of the irrigation, if used; (f) success criteria; and (g) a detailed monitoring program, commensurate with the plan’s goals.

Western Joshua Tree
If impacts to western Joshua tree cannot be avoided, mitigation is required. If avoidance is not feasible, and construction will result in direct removal of western Joshua tree, a Westen Joshua Tree Conservation Act Incidental Take Permit or a Section 2081 Incidental Take Permit from CDFW shall be required prior to construction.

Mitigation Measure BIO-9
Sensitive Vegetation Communities and Jurisdictional Resources Mitigation Outside of Solar BSA
If the Residential GPA site and future road dedications are constructed, prior to issuance of a grading permit, permanent impacts to the sensitive vegetation community (e.g.,

42 desert willow–smoketree wash woodland), will be mitigated at not less than a 1:1 ratio through preservation of the same vegetation community either on site, off site, or through a CDFW approved mitigation bank. Areas outside the solar BSA shall also mitigate to ensure no-net-loss of jurisdictional aquatic resources at a minimum of 1:1 with purchase of credits at an approved mitigation bank including Regional Water Quality Control Board/California Department of Fish and Wildlife jurisdiction. Mitigation shall be completed through use of a mitigation bank (e.g., Black Mountain Conservation Bank) or other applicant-sponsored mitigation either on site or off site. Final mitigation ratios and credits shall be determined in consultation with the resource agencies but will be no less than a 1:1 mitigation ratio. Should applicant-sponsored mitigation be implemented, a Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared. The HMMP shall include a conceptual planting plan including planting zones, grading, and irrigation, as applicable; a conceptual planting plant palette; a long-term maintenance and monitoring plan; annual reporting requirements; and proposed success criteria. Any applicantsponsored mitigation shall be conserved and managed in perpetuity.

Best management practices shall be implemented to avoid any indirect impacts on jurisdictional waters and sensitive vegetation communities as described in Mitigation Measure BIO-8 (Avoidance and Minimization of Impacts to Potential Jurisdictional Aquatic Resources).

Mitigation Measure BIO-10
Desert Native Plants Removal Permit
Prior to issuance of grading permits or solar decommissioning activities, the Project applicant shall submit an application and applicable fee paid to City of Twentynine Palms for removal of protected native desert plants under the California Desert Native Plants Act. The applicant shall submit a detailed plan consistent with the requirements of the Act. The City shall hire, at the applicant’s expense, a qualified biologist to review the plan and provide conditions of approval for the grading permit. The Project shall comply with any conditions of approval imposed by the City upon issuance of the permit.

The permit application shall specify information outlined in the California Desert Native Plant Act Section 80114, which includes but is not limited to, the number and species of native plants to be removed, a description of the real property from which the plants are to be removed, and in the case that relocation is required, the destination of the native plants and the manner in which the plants are to be salvaged. Pursuant to the California Desert Native Plants Act, tags or seals issued by the City of Twentynine Palms must be attached to the native plants at the time of harvesting and before transporting to their permanent relocation site(s) and must remain attached to the plant until transplanted into its ultimate destination. Transport of salvaged plants will occur as prescribed by the City of Twentynine Palms.

If relocation is required by the applicable review authority, the following actions shall also be implemented to ensure successful relocation of desert native plants:

43 • Salvaged plants shall be transplanted expeditiously to either their final on-site location, or to an approved off-site area. If the plants cannot be expeditiously taken to their permanent relocation area at the time of excavation, they may be transplanted in a temporary area (stockpiled) prior to being moved to their permanent relocation site(s). • Plants designated for relocation shall be marked on their north facing side prior to excavation. Transplanted plants shall be planted in the same orientation as they currently occur on the project site, with the marking on the north side of the trees facing north at the relocation site(s).
• Transplanted plants shall be watered prior to and at the time of transplantation. The schedule of watering shall be determined by the qualified desert native plant expert(s) to maintain plant health. Watering of the transplanted plants shall continue under the guidance of qualified desert native plant expert(s) until it has been determined that the transplants have become established in the permanent relocation site(s) and no longer require supplemental watering.

Overall, impacts to sensitive and special status species will be mitigated to less than significant levels through implementation of Mitigation Measures BIO-1 through -7, and BIO-9 and -10.

2. Riparian Habitat and Sensitive Natural Communities
Threshold:
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.5-28 through -32).

Explanation:

The BRTR identified one CDFW designated sensitive natural community on-site, Desert Willow-Smoketree Wash Woodland, and 7.39 acres of non-wetland waters of the state subject to the jurisdiction of the RWQCB and streambed or riparian habitat subject to CDFW jurisdiction. The Solar Project shall implement Mitigation Measure BIO-8 (Avoidance and Minimization of Impacts to Potential Jurisdictional Aquatic Resources) which would require avoidance and minimization measures when ground-disturbing activities occur within 25 feet of waters of the state and/or jurisdictional streambeds.

Potential short-term or temporary indirect impacts, as well as potential long-term operationally related indirect impacts to sensitive vegetation communities would be mitigated with implementation of Mitigation Measure BIO-1.

The proposed Residential GPA of the southern parcel would not result in direct impacts to riparian habitats or other jurisdictional aquatic resources. For future development, implementation of Mitigation Measure BIO-7 and Mitigation Measure BIO-9 would reduce

44 direct impacts to sensitive vegetation communities, including riparian habitats, if present on the Residential GPA site, to less than significant levels. (See Mitigation Measures BIO- 1, -7, and -9, above)
Mitigation Measure BIO-8
Avoidance and Minimization of Impacts to Potential Jurisdictional Aquatic Resources.

A 1602 Agreement shall be secured, if necessary, should Project designs change and affect jurisdictional waters identified in the Draft EIR. The following avoidance and minimization measures would be implemented when ground-disturbing activities occur within 25 feet of waters of the state and/or jurisdictional streambeds (i.e., jurisdictional aquatic resources):
• All jurisdictional aquatic resources within 25 feet of project activities shall be fenced or flagged as environmentally sensitive areas prior to any ground disturbance. • A biological monitor shall be present during construction activities within 25 feet of jurisdictional aquatic resources to ensure avoidance.
• Best Management Practices shall be implemented to avoid indirect impacts to jurisdictional waters, including:
- Water containing mud, silt, or other pollutants from grading or other activities shall not be allowed to enter jurisdictional aquatic resources or be placed in locations that may be subjected to high storm flows.
- Spoil sites shall not be located within jurisdictional aquatic resources or in locations that may be subject to high storm flows, where spoils might be washed into drainages.
- Raw cement/concrete or washings thereof, asphalt, paint or other coating material, oil or other petroleum products, or any other substances that could be hazardous, resulting from project-related activities, shall be prevented from entering jurisdictional aquatic resources.
- Equipment maintenance shall occur outside jurisdictional aquatic resources and in such a manner that no petroleum products or other pollutants from the equipment enters on- or off-site state-jurisdictional aquatic resources either directly or indirectly.

Overall, impacts to riparian habitat and sensitive natural communities will be mitigated to less than significant levels through implementation of Mitigation Measures BIO-1, -7, -8, and -9.

3. Migratory Wildlife
Threshold:
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

45 Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.5-32 through -44).

Explanation:

The Project site was identified as being located within the established habitat linkage area defined by the General Plan, including areas for desert tortoise and burrowing owl. The site is a region used by common and special status species, which currently access the site without any obstructions. The BRTR determined restrictions by the Project’s buildout to existing migratory patterns would be less than significant. The Project is required to avoid impacts to specific wildlife species with implementation of Mitigation Measure BIO3 through BIO-5, and Mitigation Measure BIO-6. Indirect impacts resulting from construction or on-going operation of the Solar Project would be mitigated to less than significant levels with implementation of Mitigation Measure BIO-1. As such, the Project would result in less than significant impacts with mitigation incorporated.

No changes to the physical composition of the southern parcel are proposed immediately, but development at a higher intensity could occur in the future. These changes could alter or reduce the southern parcel’s value or use as a wildlife corridor. Future impacts will be analyzed once a formal residential project is proposed, as required per Mitigation Measure BIO-7. No immediate direct impacts will occur as a result of the Residential GPA. (See Mitigation Measures BIO-1, -3, -4, -5, -6, and -7, above) Overall, impacts to migratory wildlife will be mitigated to less than significant levels through implementation of Mitigation Measures BIO-1, -3, -5, -6, and -7.

C. CULTURAL RESOURCES

1. Historical Resources
Threshold:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5.

Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.6-12 and -13).

Explanation:

The cultural resources evaluation of the Solar Project site found a previously recorded historic resources (a paved portion of Two Mile Road) and a newly identified cultural resource comprised of 20th century scattered trash. Both resources failed to meet any of the four CRHR criteria for determination of cultural/historical significance and therefore are not significant under CEQA. Sixteen newly identified isolates were also identified as being from the prehistoric and historic eras. However, the recording and evaluation of the sixteen isolates determined that these resources do not meet the criteria for either cultural or historical significance, and no impacts to historical resources pursuant to Section 15064.5 would occur.

46 The cultural resources inventory and evaluation did not include the Residential GPA site because no development was planned at the time. However, although no historically significant resources were identified on the Solar Project site, based on the findings from the Solar Project site survey as described above, there is potential for historic resources to occur on the Residential GPA site. Future construction of residences on the land could result in potentially significant impacts to historic resources. Mitigation Measure CUL-1 requires that a cultural resource survey and evaluation be prepared when development is proposed on the Residential GPA site to ensure impacts would be less than significant.

Mitigation Measure CUL-1
Cultural Resource Survey – Residential GPA Site
In order to assure that impacts to cultural resources are reduced to less than significant levels, a cultural resource survey, including an analysis of both historic and archaeological resources, shall be conducted prior to the approval of a tentative subdivision map or any other entitlement to allow development on the Residential GPA site. The survey shall include records searches, literature review and field investigations, and shall include mitigation measures as necessary to protect any resources identified on the site.

Overall, impacts to historical resources pursuant to Section 15064.5 will be mitigated to less than significant levels through implementation of Mitigation Measures CUL-1.

2. Archaeological Resources
Threshold:
b) Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.6-13 and -14).

Explanation:

The presence of historic and prehistoric resources in the region, coupled with the alluvial soil on the Project site provide evidence suggesting that archaeologically significant resources may potentially occur under the surface of the site. Development of the Solar Project site poses a potentially significant impact on archaeological resources. In order to mitigate this potentially significant impact, Mitigation Measure CUL-2 requires that a Cultural Resources Monitoring and Discovery Plan be prepared to facilitate site monitoring by a qualified archaeologist during all ground-disturbing activities. In response to comments made by the Yuhaaviatam of San Manuel Nation and Agua Caliente Band of Cahuilla Indians in connection with the Draft EIR, Mitigation Measures CUL-3, -4 and - 5 were added
The incorporation of the Cultural Resources Monitoring and Discovery Plan, monitoring of Project grading activities, and addition of Mitigation Measures CUL-3 through CUL-5 would reduce potential impacts to archaeological resources to a less than significant level.

47 For the Residential GPA site, both Mitigation Measures CUL-1 through CUL-5 would apply, requiring both a cultural resources survey and a Cultural Resources Monitoring and Discovery Plan prior to and during ground disturbing activities. With these mitigation measures in place, potential impacts to archaeological artifacts would be reduced to less than significant levels.
(See Mitigation Measures CUL- 1 above)
Mitigation Measure CUL-2
Archaeological and/or Tribal Resource Discovery and Documentation A Cultural Resources Monitoring and Discovery Plan (Plan) shall be prepared and finalized prior to the initiation of Solar Project construction. The Plan will require that qualified archaeological monitor(s) be present and that tribal monitor(s) representing the Cahuilla Band, the Agua Caliente Band and the Yuhaaviatam be present during all ground-disturbing activities within the Project site, unless Tribe(s) provide the City with written withdrawal from their monitoring request. The applicant/developer shall allow 45 days from initial contact with the above-listed Tribes to enter into a contract with the Tribes for monitoring services. If the applicant/developer can demonstrate to the City they were unable to secure an agreement from the above-referenced Tribe, or if the contracted Tribe fails to fulfill its obligation under the contract terms, then the applicant/developer may retain an alternative qualified tribal monitor approved by the City. Monitoring requirements and locations will be defined in the Plan, along with resource discovery protocols and guidance for reducing or terminating site monitoring in the case that no artifacts are identified. Should an artifact be discovered, all construction activity within 100 feet of the discovery shall stop until a qualified archaeologist in collaboration with Tribal Cultural Monitor(s) can evaluate the significance of the artifact and make a determination whether further study is necessary, and whether or when work may resume. Should the artifact be found to be significant under CEQA, an archaeological treatment plan and further data recovery may be required, as determined by the Project archaeologist and the Tribes.

Mitigation Measure CUL-3 Reburial Protocol
Prior to issuance of grading permits: the developer/applicant shall come to an agreement with the consulting tribes indicating an area on-site which will be used, if needed, for reburial of any artifacts that have been identified during grading and cannot be avoided.

This area will be protected and not disturbed in the future. This is confidential information, and the exact nature of this area will not be called out on the grading plans.

Mitigation Measure CUL-4 Monitoring and Treatment Plan
A Monitoring and Treatment Plan that is reflective of the project mitigation (“Cultural Resources” and “Tribal Cultural Resources”) shall be completed by the archaeologist and submitted to the Lead Agency for dissemination to the Yuhaaviatam of San Manuel Nation Cultural Resources Management Department (YSMN, also known as San Manuel Band of Mission Indians). The City shall approve the Plan following consultation with the Tribe Any and all findings will be subject to the protocol detailed within the Monitoring and Treatment Plan.

48 CUL-5 Archaeological Monitoring
Due to the heightened cultural sensitivity of the proposed project area, an archaeological monitor with at least 3 years of regional experience in archaeology shall be present for all ground-disturbing activities that occur within the proposed project area (which includes, but is not limited to, tree/shrub removal and planting, clearing/grubbing, grading, excavation, trenching, compaction, fence/gate removal and installation, drainage and irrigation removal and installation, hardscape installation [benches, signage, boulders, walls, seat walls, fountains, etc.], and archaeological work). A sufficient number of archaeological monitors shall be present each work day to ensure that simultaneously occurring ground disturbing activities receive thorough levels of monitoring coverage.

Overall, impacts to archaeological resources pursuant to Section 15064.5 will be mitigated to less than significant levels through implementation of Mitigation Measures CUL-1 through CUL-5.

D. HAZARDS AND HAZARDOUS MATERIALS

1. Hazardous Materials Transport, Use, and Disposal
Threshold:
a) Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.10-10 through -16).

Explanation:

According to the information sourced during the Phase I investigation, as well as the visual and physical observations recorded during the site field survey, there are no existing hazardous conditions at or near the site.

The Project’s on-site construction and operation will involve the use of hazardous material. The Project’s construction (on- and off-site) will involve the transport, use, storage, and/or disposal of hazardous material including gasoline, diesel fuel, oil, lubricants, grease, welding gases, solvents, and paints. These substances will be subject to strict regulation as described above and as required in Mitigation Measure HAZ-1.

Compliance with these measures will reduce the probability for hazardous impacts to less than significant levels.

During operation, the site will generate hazardous waste in the form of biodegradable dielectric fluid and mineral oil used to operate the transformer at the site. No hazardous material will be stored on-site during operation. Additionally, any on-site generated waste during construction and operation will be collected and disposed of in compliance with City standards and State law.

Future residential projects will reviewed by the City for conformance with CEQA at the time the project(s) are proposed. Compliance with state and local standards as stated in

49 Twentynine Palms Municipal Code and CalOSHA will ensure potential impacts related to the transport, use, storage, and disposal of hazardous waste are adequately contained to lessen the probability for direct or indirect impact to less than significant levels.

Mitigation Measure HAZ-1
Prior to construction, a Hazardous Material Management Plan shall be prepared by the Applicant and submitted to the City for review and approval, to specify the method for handling and disposing of hazardous material related to the construction process.

Overall, impacts resulting from the routine transport, use, or disposal of hazardous materials will be mitigated to less than significant levels through implementation of Mitigation Measures HAZ-1.

2. Release of Hazardous Materials
Threshold:
b) Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.10-16 and -17).

Explanation:

Construction and operation of the Solar Project would not result in a significant foreseeable upset in regard to release of hazardous materials with proper construction management and design. Cleaners, solvents, and other chemicals may be used on-site for routine maintenance, and will be regulated by Cal OSHA and the County Department of Environmental Health Services and the City Fire Department. These materials, if used, must be properly stored, handled and treated according to the regulations issued by the State of California (See Chapter 30, Title 22 of the CCR). All federal, state, and local policies, programs, and municipal codes regarding the transportation, use, storage, and disposal of hazardous products will be adhered to by the Project. The application of BMPs set forth in mitigation measures HYD-1, HAZ-1 and HAZ-2 will further ensure that potential impacts relating to the handling of hazardous material will be reduced to less than significant levels.

Future residential project(s) resulting from the Residential GPA would be analyzed for adequacy in managing on-site sources of pollution by the City under its CEQA process.

The review would also analyze potential sources of impacts related to the use of hazardous material during construction and operation. Future residential project(s) would be subject to the most current state and local standards controlling the transport, use, storage, and disposal of hazardous material. Under these regulatory practices, the probability for adverse effects to the environment or public health associated with the release of hazardous material in connection to the future residential development is limited, and is expected to result in a less than significant impact.

50 (See Mitigation Measures HAZ-1 above)
Mitigation Measure HAZ-2
A toxicity characteristic leaching procedural (TCLP) test must be performed to determine the toxicity level of solar panel(s) prior to its being recycled or disposed. If the solar panel waste does not exceed the threshold to be defined as hazardous waste, no further action is required. If the solar panel’s toxicity level exceeds the threshold and is defined as hazardous waste, all federal, state, and local regulations regarding the disposal of hazardous waste will be applied to the solar panel’s disposal, including the use of a qualified hauler, and disposal in a designated landfill.

Overall, impacts resulting from the accidental release of hazardous materials will be mitigated to less than significant levels through implementation of Mitigation Measures HAZ-1 and HAZ-2.

E. HYDROLOGY AND WATER QUALITY

1. Surface and Groundwater Quality
Threshold:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.11-17 and -19).

Explanation:

The City and Regional Water Quality Control Board review would ensure that construction and operational best management practices (BMPs) satisfy local, state, and federal standards. The required Storm Water Pollution Prevention Plan (SWPPP) must comply with California’s General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (2022 CGP), State Water Resources Control Board (State Water Board) Order No. 2022-0057-DWQ (NPDES No. CAS000002) for traditional construction projects.

For the Solar Project, any on-site pollutants will be properly contained and stored in compliance with local regulations. Additionally, a Spill Prevention Control and Countermeasure Plan (Mitigation Measure HYD-1) will be implemented to ensure proper containment and inspections to prevent oil and fuel spills.

Future development of the Residential GPA would require individual septic tanks or onsite package treatment plant(s). Effluent from future water treatment systems will be contained in closed systems and regulated by RWQCB permits, and is not expected to degrade groundwater quality. Future development plans will also be required to comply with TPWD and NPDES regulations to minimize the pollutant load associated with construction. Meeting those standards requires the preparation and approval of a sitePage 807 of 1008 51 specific SWPPP, which must be approved by the City prior to the initiation of construction activities. The SWPPP will include BMPs that will protect surface waters from pollutants in storm flows during construction of the site. Disposal of domestic products, including grease and oil would be required to comply with County and RWQCB regulations.

Adherence to local, state and federal requirements will assure that impacts associated with water quality standards for future development of the Residential GPA are less than significant.

Mitigation Measure HYD-1
Spill Prevention, Control, and Countermeasure Plan (SPCCP) The Applicant shall prepare a Spill Prevention, Control, and Countermeasure Plan (SPCCP) that shall clearly state measures to stop the source of a spill, contain the spill, clean up the spill, dispose of contaminated materials, and train personnel to prevent and control future spills. The SPCCP shall identify sources of oil or hazardous wastes that may be stored or used on site. If oil or hazardous wastes would be stored on site during operations, the SPCCP shall identify the location of storage, anticipated volumes of materials to be stored, method of storage, and countermeasures to address potential spill or accidental release of materials. In addition, the SPCCP shall include step-by-step instructions for the response to spills at a facility. In addition, the spill response plan should:
• Identify individuals responsible for implementing the plan • Define safety measures to be taken with each kind of waste • Specify how to notify appropriate authorities, such as police and fire departments, hospitals, or municipal sewage treatment facilities for assistance • State procedures for containing, diverting, isolating, and cleaning up the spill • Describe spill response equipment to be used, including safety and cleanup equipment
The SPCCP shall be submitted to San Bernardino County Public Works – Environmental Management Division for review and approval prior to occupation/operations and shall be maintained over the operational life of the Project.

Overall, impacts surface and groundwater quality will be mitigated to less than significant levels through implementation of Mitigation Measures HYD-1.

F. TRIBAL CULTURAL RESOURCES
Threshold:
a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

52 i)Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
ii)A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe
Finding: Less than Significant with Mitigation Incorporated. (EIR, p. 2.18-9 through -11).

Explanation:

AB 52 and SB 18 require the City to initiate a formal consultation process with relevant tribes prior to releasing an environmental impact report, negative declaration, or mitigated negative declaration. Written notices about the proposed Project were sent to 28 individuals representing fourteen Native American tribes, and responses from five Tribes were received. The consultation process was completed and is described in Section

2.18.5 and 2.18.6.

There is a potential for development of the Solar Project to impact tribal cultural resources if they occur on a Project site. Grading, excavation, and other ground disturbing activities could uncover previously unknown resource. Mitigation Measures CUL-2 described in Section 2.6.7, Cultural Resources, of the EIR would reduce potential impacts to less than significant levels.

Future development on the Residential GPA lands would be subject to CEQA, and since no on-site cultural resource evaluation has been conducted for this land, Mitigation Measure CUL-1 is included in Section 2.6 to assure that cultural resource survey(s) are completed when development is proposed. In addition, and also as required by CEQA, the City will be required to conduct Tribal Consultation under the requirements of AB 52 when these lands are proposed for development.

In response to comments made by the Yuhaaviatam of San Manuel Nation and Aqua Caliente Band of Cahuilla Indians in connection with the Draft EIR, Mitigation Measures CUL-3 through CUL-5, and TCR-1 and TCR-2 were added. With implementation of CUL1 through CUL-5, and TCR-1 and TCR-2, and the requirements of State law, impacts to Tribal Cultural Resources associated with the Residential GPA will be less than significant.
(See Mitigation Measures CUL- 1 through CUL-5 under Cultural Resources)

53 Mitigation Measure TCR-1
Treatment of Cultural Resources During Project Implementation If a pre-contact cultural resource is discovered during project implementation, grounddisturbing activities shall be suspended 60 feet around the resource(s), and an Environmentally Sensitive Area (ESA) physical demarcation/barrier constructed.

The Project Archaeologist shall develop a research design that shall include a plan to evaluate the resource for significance under CEQA criteria. Representatives from YSMN, the Archaeologist, and the Lead Agency shall confer regarding the research design, as well as any testing efforts needed to delineate the resource boundary. Following the completion of evaluation efforts, all parties shall confer regarding the resource's archaeological significance, its potential as a Tribal Cultural Resource (TCR), and avoidance (or other appropriate treatment) of the discovered resource. Removal of any cultural resource(s) shall be conducted with the presence of a Tribal monitor representing the Tribe, unless otherwise decided by YSMN. All plans for analysis shall be reviewed and approved by the applicant and YSMN prior to implementation, and all removed material shall be temporarily curated on-site.

It is the preference of YSMN that removed cultural material be reburied as close to the original find location as possible. However, should reburial within/near the original find location during project implementation not be feasible, then a reburial location for future reburial shall be decided upon by YSMN, the landowner, and the Lead Agency, and all finds shall be reburied within this location.

Additionally, in this case, reburial shall not occur until all ground-disturbing activities associated with the project have been completed, all monitoring has ceased, all cataloguing and basic recordation of cultural resources have been completed, and a final monitoring report has been issued to Lead Agency, CHRIS, and YSMN. All reburials are subject to a reburial agreement that shall be developed between the landowner and YSMN outlining the determined reburial process/location, and shall include measures and provisions to protect the reburial area from any future impacts.

Should it occur that avoidance, preservation in place, and on-site reburial are not an option for treatment, the landowner shall relinquish all ownership and rights to this material and confer with YSMN to identify an American Association of Museums (AAM)- accredited facility within the County that can accession the materials into their permanent collections and provide for the proper care of these objects in accordance with the 1993 CA Curation Guidelines. A curation agreement with an appropriate qualified repository shall be developed between the landowner and museum that legally and physically transfers the collections and associated records to the facility. This agreement shall stipulate the payment of fees necessary for permanent curation of the collections and associated records and the obligation of the Project developer/applicant to pay for those fees.

All draft records/reports containing the significance and treatment findings and data recovery results shall be prepared by the archaeologist and submitted to the Lead Agency

54 and YSMN for their review and comment. After approval from all parties, the final reports and site/isolate records are to be submitted to the local CHRIS Information Center, the Lead Agency, and YSMN.

Mitigation Measure TCR-2: Inadvertent Discoveries of Human Remains If human remains or funerary objects are encountered during any activities associated with the project, work in the immediate vicinity (within a 100-foot buffer of the find) shall cease and the County Coroner shall be contacted pursuant to State Health and Safety Code §7050.5 and that code enforced for the duration of the project.

Overall, impacts to tribal cultural resources will be mitigated to less than significant levels through implementation of Mitigation Measures CUL-1 through CUL-5, and TCR-1 and - TCR-2.

55 SECTION 6: FINDINGS REGARDING ENVIRONMENTAL IMPACTS NOT FULLY

MITIGATED TO A LEVEL OF LESS THAN SIGNIFICANT
The City Council hereby finds that, despite the incorporation of Mitigation Measures outlined in the EIR and in this Resolution, the following impacts from the Twentynine Palms Solar Project and related approvals cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein:

A. AESTHEICS

1. Existing Visual Character
Threshold:
c) In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Finding: Significant and Unavoidable with Mitigation Incorporated. (EIR, pp. 2.3-16 through -19).

Explanation:

The Project occurs in a non-urbanized area and is surrounded by vacant desert lands. The EIR determined that the solid expanse of dark, uniformly placed solar arrays placed atop graded and compacted soil would starkly contrast with the surrounding landscape of natural contours, light beiges, tans, browns and greens. The Solar Project would not be consistent with any other land uses currently allowed under the General Plan, or with the prevailing visual character in the surrounding vicinity due to its mass, scale, shape, and color.

In order to reduce the severity of these impacts, mitigation measures AES-1 and AES-2 were developed, which would allow for the restoration of the native plant environment surrounding the solar panels to the extent possible. However, given the broad expanse of land whose scenic character will be impacted, and its location surrounding the panels, and that the Solar Project would still be visible after replanting of native vegetation, impacts would remain significant and unavoidable due to the mass, scale, and form of the Solar Project.

The Residential GPA would increase the density of single-family housing from 1 unit per 5 acres (RL-5) to 1 unit per 1 acre (RS-1) on the 60 acres located at the southwest corner of Samarkand Drive (extended) and Noels Knoll Road (extended). While additional residential structures on this land would alter the existing visual character of public views, the Residential GPA would conform with similar RS-1 land uses occurring within 0.25 miles of the Project site and would not introduce a contrasting visual impediment to the area. The EIR determined that the impacts of the proposed Residential GPA to the visual character of the Project site would be less than significant with the imposition of the City’s Development Code standards and requirements.

56 Mitigation Measure AES-1
Within 60 days of the completion of construction, or at the earliest possible time that is appropriate to achieve plant establishment, as determined by the City and a qualified Project biologist, native plants shall be installed on the Solar Project site as further described in the Habitat Restoration Plan included as Appendix D.3.

Mitigation Measure AES-2
Prior to the completion of construction, plant native vegetation along the east and south sides of the perimeter security fence to shield the Solar Project site from potential future residential viewers. Irrigation would be required to assist initial plant growth.

57 SECTION 7: FINDINGS REGARDING CUMULATIVE ENVIRONMENTAL IMPACTS The State CEQA Guidelines (14 CCR 15130) require a reasonable analysis of the significant cumulative impacts of a Proposed Project. Cumulative impacts are defined by CEQA as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts” (State CEQA Guidelines, Section 15355).

Consistent with CEQA’s requirements, the EIR for the Twentynine Palms Solar Project includes an analysis of cumulative impacts, which include the impacts of Proposed Project plus all other pending or approved projects within the affected area for each resource. The geographic scope of the analysis is the jurisdictions of the City of Twentynine Palms, unless specifically identified below. Cumulative impacts have been assessed using the summary of projections method set forth in State CEQA Guidelines Section 15130(b)(1)(B). The primary documents used to determine cumulative impacts were the City of Twentynine Palms General Plan (2012) and its EIR.

The City Council hereby finds as follows:

A. AESTHETICS
Solar Project Cumulative Impacts
Cumulative impacts include the impacts of this proposed Solar Project as well as the impacts of other similar projects in the nearby vicinity. No large-scale solar projects currently exist within City boundaries. However, other comparably sized solar farms operate in the surrounding region on unincorporated County lands: the 150-acre Cascade Solar Farm in Joshua Tree, the 120-acre SEPV2 and SEPV8 Solar Farm on Lear Avenue, and the 80-acre SEPV9 on Indian Trail4. Together, these four solar fields impact a total of 350 acres. The proposed Solar Project, in combination with the existing solar fields, would not contribute to a cumulatively significant impact to scenic vistas because all incorporate low-profile panels that avoid substantial interference or blockage.

Cumulative impacts to scenic vistas from additional potential projects within the City, as with the proposed Solar Project, would be less than significant, insofar as the height and scope of such projects would need to meet the criteria and standards provided in the City’s proposed renewable energy ordinance and would be unlikely to significantly block surrounding mountain views. Impacts associated with scenic vistas would also likely be less cumulatively significant.

While the Project does not propose to change the land use designation for any site other than the Project site, the City’s creation of a new Energy zone could conceivably increase the potential for similar future solar projects within Twentynine Palms, insofar as other projects could request re-zoning to this new use. It is possible that some of those projects could be located in undeveloped rural areas of the City. Any such proposals would require 4 County of San Bernardino, Land Use Services/Planning Division Renewable Energy Projects as of February 1, 2025

58 a discretionary zone change and would need to meet the standards provided within the City’s proposed Energy zone. The impacts associated with any additional requests for the use of the Energy designation and zone would be assessed on a case-by-case basis as each of these projects was proposed. However, depending on the location of future projects, if any, their impacts to visual character could be significant and unavoidable, and when added to the impacts of the Solar Project, could be cumulatively significant.

When considering the existing solar fields within the sphere of influence and the region, the number of acres that would be affected with the addition of this Solar Project, and the potential impacts of additional solar projects which could be allowed by the creation of the new Energy General Plan and Zoning designation, the cumulative impacts to the visual character and aesthetic resources of this rural high desert section of Twentynine Palms are considered significant and unavoidable.

Cumulative light and glare impacts generated by additional solar projects would be similar to those identified for the Solar Project, and be dependent on the location of each project.

Compliance with the City’s proposed renewable energy ordinance, which requires that any proposed solar project not impact Marine Corps Air Ground Combat Center (MCAGCC) operations, and compliance with Federal Aviation Administration requirements for light and glare from solar projects, would ensure that future solar projects do not contribute to glare impacts at MCAGCC or the Airport. Lighting impacts would also not be cumulatively significant, because additional solar projects would not be expected to provide lighting.

Residential GPA Cumulative Impacts
The cumulative impacts associated with the Residential GPA would be limited, insofar as no other lands within the City are proposed for increases in density, and residentially designated lands will be required to meet the same Development Code lighting standards as those required for projects within the Residential GPA. These standards limit residential outdoor lighting, and provide for shielding to limit off-site impacts. When considered across all residential lands in the City, cumulative impacts would be expected to be less than significant.
(EIR, p. 2.3-21 through -23).

B. AIR QUALITY
Impacts to air quality are assessed on a cumulative, regional scale due to the dispersing nature of pollutant emissions and the aggregate impacts from surrounding jurisdictions.

The Mojave Desert Air Basin is non-attainment for PM10 and ozone. Any activity resulting in the emissions of PM10, ozone, or ozone precursors will contribute, to some extent, to the regional non-attainment designation for these criteria pollutants. However, the level of cumulative impacts on regional air quality resulting from a single project are difficult to measure.

59 The Project will contribute to incremental increases in criteria air pollutant emissions. As discussed in Section 2.4.6 (b) of the EIR, the Project is not expected to exceed the MDAQMD thresholds for any criteria pollutant during its construction of operations and is therefore determined to have a less than significant impact. Given that the Project would not contribute significant impacts to pollutants for which the region is in non-attainment, impacts to regional ozone and PM10 levels would not be cumulatively considerable. (EIR, p. 2.4-28).

C. BIOLOGICAL RESOURCES
The proposed Project, along with other projects developed under the General plan’s land use designations, will result in potential impacts to plants and wildlife, natural communities, waters of the State, riparian habitats and other biological resources. As is the case with the proposed Project, other future projects will be required to comply with the regional and local ordinances designed to protect biological resources and will be required to conduct site-specific biological resource assessments and surveys. These surveys will include mitigation measures designed to reduce each project’s impacts, and will effectively mitigate any incremental impact on biological resources. Future preservation of open space lands, purchases of mitigation bank land, and similar measures will be imposed as impacts are identified. For this reason, Project impacts would not be cumulatively considerable. (EIR, p. 2.5-50).

D. CULTURAL RESOURCES
In its General Plan, the City of Twentynine Palms commits to identifying and preserving historically and culturally significant resources during development projects where ground disturbance activities could potentially impact these resources. The City’s Conservation and Open Space Goal CO-2 and associated Policies CO-2.1 through 2.10 provide a checklist of actions regarding research and preservation of artifacts.

Geographically, cumulative impacts to cultural and historical resources include the Solar Project site, the Residential GPA site, and the immediate surrounding vicinity, which are all within the traditional use areas of the Serrano and Cahuilla people. The Project area and surrounding lands would contribute to cumulative impacts if the Project and future projects were to adversely impact significant cultural resources not only on the Project site, but also throughout the community.

To guide the discovery, identification and preservation of potential resources and reduce potential cumulative impacts, the City requires the preparation of cultural resources inventory and evaluation reports utilizing a wide range of historical data including archaeological reports, historic accounts, and tribal resources. This requirement will be applied to the Residential GPA area and other lands in the City as development occurs in the area. Mitigation, including consultation, monitoring, recording, and translocation (as needed) will be applied to future projects in the City, as they have been to the Solar Project and Residential GPA. With implementation of similar mitigation measures, the potential cumulative impacts would not be significant. (EIR, p. 2.6-16).

60 E. ENERGY
The assessment of potential cumulative impacts on energy resources involves the consideration of energy consumption for the proposed Project in addition to impacts stemming from past, present, and future projects, and whether the combined energy uses from all project results in wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

The Project consists of a commercial solar field and a residential GPA but does not propose the development of residential units at this time. Overall, the Project will result in net positive electricity generation. Future residential development on site, and all other new projects in the City, will be subject to the Building Code energy conservation standards in place when development occurs. These standards, now enforced through the Calgreen Code, require the installation of rooftop solar, and aim to have new development be net-zero producing in the future. As the energy code is updated, future cumulative projects in the City will be required to comply with the more stringent requirements, which will reduce residents’ and businesses’ use of energy in buildings.

Similarly, as vehicle fuel consumption standards increase because of State mandates, gasoline consumption will also decrease in the future. As a result of State mandates, therefore, cumulative impacts associated with the wasteful consumption of energy will remain less than significant. (EIR, p 2.7-16 and -17).

F. GEOLOGY AND SOILS
According to CEQA, a cumulative impact is based on whether the project’s incremental effects, when combined with impacts related to past, present, and reasonably foreseeable future projects in the area could result in a combined significant impact. The Project is not considered to have an incremental effect given that the Solar Project will be built in accordance with the most current state and local building codes and development standards pursuant to City Municipal Code. Similarly, future residential development on the southern parcel will adhere to the California Building Code and policies, standards, and programs consistent with the City General Plan and Municipal Code. These standards also apply to any new development project in the City, as permitted by the General Plan. Individual projects will be required to implement the City’s and State’s seismic standards, and to address on-site soils as they are proposed. The uniform application of these standards throughout the City will assure than no significant cumulative geologic or soil impacts will occur. (EIR, p. 2.8-20 and -21).

G. GREENHOUSE GAS EMISSIONS
Due to their dispersing nature and aggregate regional impacts, greenhouse gases are analyzed in terms of their cumulative impacts. The above analysis considers the potential cumulative impacts of the overall Project on greenhouse gas emissions in the Mojave Desert Air Basin using significance criteria from the MDAQMD. The analysis also considers emissions in relation to local and state greenhouse gas reduction plans and targets.

61 Although the proposed GPA would redistribute residential density by concentrating it on the southern half of the site rather than the northern half, the overall Project would maintain the site's existing development capacity of 119 residences and would not introduce any new GHG-related impacts beyond those already evaluated in the City's 2012 General Plan. Buildout of the Solar Project would achieve a net reduction in GHG emissions by generating onsite solar energy in sufficient amounts to fully offset all direct and indirect emissions associated with the site’s buildout, including those from electricity consumption, stationary equipment, and mobile emissions. Consequently, the Project would result in a cumulatively beneficial impact on GHG emissions. (EIR, p. 2.9-21 and - 22).

H. HAZARDS AND HAZARDOUS MATERIALS
The Project site is currently vacant. Future residential development may occur on the southern parcel, at which point the residential project would be subject to the most current state and local standards pertaining to the transport, use, storage, and disposal of hazardous materials and thus, potential cumulative impacts would be limited to below significance.

Similarly, future development projects in the City will be subject to the same local, regional and State laws governing hazardous materials. The standards applied to each project, based on its specific characteristics, will reduce cumulative impacts associated with hazardous materials to less than significant levels. (EIR, p. 2.10-18).

I. HYDROLOGY AND WATER QUALITY
Project cumulative impacts are expected to be limited. The Project will not contribute to water quality degradation and will result in a minimal net water demand compared to current conditions. The Project will have no effect on local or area-wide drainage facilities and will not require capacity from any existing or future off-site drainage facility. The Project will not have a cumulatively considerable impact on area drainage or local or regional water quality or supplies. (EIR, p. 2.11-26).

J. LAND USE
The probability for cumulative considerable impacts would occur if the Project, in combination with existing or future development, were to conflict with the General Plan or local standards and thus collectively cause significant environmental impacts. The creation of the Renewable Energy land use and zoning designation will result in less than significant project impacts on land use and planning. Should the land use and zoning designation be applied to other parcels in the City, the impact to land use and planning would be assessed on a site-specific basis, and would be mitigated on a case-by-case basis.

As it relates to the Residential GPA, the proposal to increase density on 60 acres of the southern parcel will result in the eventual development of single family homes which will be developed to City standards. These standards are designed to allow for limited height, building setbacks and other standards that are consistent with single family development

62 throughout the community. As a result, the Residential GPA, when considered in the context of other residential development allowed and expected in the General Plan, will not result in cumulative land use impacts. (EIR, p. 2.12-18).

K. NOISE
Both the solar facility and the future residential development would generate noise and thus marginally increase the ambient noise environment. The levels of noise generated by the Project will not exceed City standards, and will be subject to General Plan and Municipal Code requirements. There are no existing or currently proposed projects that are likely to cumulatively contribute to noise in the project area. Future development in the City under the General Plan will increase the noise levels in the City at build out, and affect the ambient noise environment. However, the General Plan’s land use map concentrates noisier uses, such as commercial and industrial uses, to major streets, and isolated sensitive receptors, such as residences, from these noise sources by creating neighborhoods away from major roadways. Future development in the City will be analyzed to determine whether it meets City standards, and will be required to mitigate noise impacts if it does not. These standards and requirements assure that noise levels at General Plan build out will not exceed the established CNEL levels, and that the City’s noise environment remains compatible with its land uses. Cumulative impacts are expected to be less than significant. (EIR, p. 2.13-19).

L. POPULATION & HOUSING
The proposed Project will replace 48 units lost on the Solar Project property by increasing density on 60 acres of land at the southwest corner of Noels Knoll Road and Samarkand Drive. It will also generate temporary construction jobs. It is expected that Project-related employment opportunities will be filled by current residents of the City and region, and therefore will not significantly increase the local population or increase demand for housing.

The housing, jobs, and infrastructure proposed by the Project, in combination with other future developments in the City, would all contribute incrementally to population growth.

Given that the Project would not increase the number of residential units projected in the General Plan, cumulative impacts associated with population are also not expected. As discussed above, population growth in the area since 2012 has been significantly slower than anticipated, and General Plan growth projections were much more aggressive than has actually occurred. Therefore, while the Project will contribute to cumulative population growth, impacts related to unplanned population growth would not be cumulatively considerable. (EIR, p. 2.14-7 and -8).

M. PUBLIC SERVICES
The Solar Project would not directly increase the population of the City. The need for police and fire protection services to the Project site would increase marginally as the site would be unmanned and surrounded by security chain link fencing. The Solar Project would not result in a cumulatively considerable impact to public facilities.

63 The Project does not propose to build homes on the Residential GPA site at this time.

Future build out of the Project site would result in a population increase and an increase for fire, police, educational, and recreational services consistent with the impacts analyzed in the General Plan, since no change in the overall total of residential units would occur. Similarly, other residential projects in the City will also increase the demand for public services. Impacts would not be cumulatively considerable because fees and property tax revenues for those services would be paid from new property tax revenue, paid directly to the SBCoFD by new property owners who need the service, or paid to MUSD at the time of development. (EIR, p. 2.15-9).

N. RECREATIONAL RESOURCES
The proposed Solar Project would operate as an unstaffed solar facility which would not generate a demand for local recreational resources and, in turn, would not result in the substantial or accelerated physical deterioration of parkland or recreational facilities. The proposed Solar Project would not directly or indirectly warrant the construction or expansion of recreational facilities.

Future development of the Residential GPA would result in the same anticipated population growth as in the General Plan, 294 residents, but potential adverse effects to recreational resources would be less than significant with the implementation of conditions of approval, the increase in property tax, and the implementation of the City Parks and Recreation Master Plan and the Trail Master Plan. Access to recreational resources as required by these Plans would apply to all future residential projects and residents in Twentynine Palms, including residents in the Project site southern parcel.

Therefore, no substantial or accelerated physical deterioration of parkland or recreational facilities would occur in connection with future residential build out in the City. Additionally, no environmental impacts from the expansion or construction of recreational facilities beyond the City’s scope for future development is anticipated to occur. Overall, cumulative impacts associated with recreational facilities will be less than significant. (EIR, p. 2.16-8).

O. TRAFFIC AND TRANSPORTATION
Programs, Plan, Ordinance or Policy
Under current and future conditions, the Project would not cause cumulative impacts because the Project on-site and off-site improvements are in compliance with applicable state and local standards. Buildout of the residential parcel located south of the Solar Project site would be consistent with General Plan build out, and subject to City policies and standards, as well as the Municipal Code. These same policies and standards are applied to all projects as they are proposed in the City, and would assure compliance with LOS policies, construction standards and emergency access. Impacts associated with City policies and programs would not be cumulatively considerable.

Vehicle Miles Traveled
As discussed in question (b) for Section 2.17.6, the Solar Project’s operations as a solar facility generate limited VMTs which are consistent with both the City’s definition of a

64 “small project” and the City’s daily per trip VMT at General Plan build out. In connection with the Residential GPA, VMT impacts will be consistent with the General Plan, since the same number of units would be built as are allowed under the General Plan currently.

Other projects proposed under the General Plan will be evaluated using the same VMT policy as that considered for the proposed Project, and will be mitigated based on that policy, if required. Projects that are consistent with the City’s General Plan build out daily VMT per trip would not result in cumulative VMT impacts, and the Project would not significantly impact VMT at General Plan build out.

Emergency Access
No obstructions to the City’s traffic corridors would occur as a result of the Project. The same safety standards would be applicable to future development projects in the area and throughout the City as they are proposed for development. Therefore, the proposed Project would not contribute to cumulative emergency access impacts. (EIR, p. 2.17-15 and -16).

P. TRIBAL CULTURAL RESOURCES
Geographically, cumulative impacts to cultural and historical resources include the Solar Project site, the Residential GPA site, the immediate surrounding vicinity, which are located within the traditional use areas of the Serrano and Cahuilla people. The entire Project area includes approximately 477 acres of land, and it would contribute to cumulative impacts if the Project were to adversely impact significant tribal cultural resources. As described above, the City and its General Plan protect tribal resources, and all projects are reviewed under CEQA for potential impacts to these resources. Future projects developed in the City will be required to undergo Tribal Consultation, and the recommendations of the consulting tribes will be included in mitigation measures and/or conditions of approval for all projects. As a result, cumulative impacts associated with Tribal Cultural Resources are not expected to be cumulatively considerable. (EIR, p. 2.18-11 and -12).

Q. UTILITIES AND SERVICE SYSTEMS
The possibility for cumulatively considerable impact by the Project is generally in connection to the southern parcel’s buildout for single-family residential use (RS-1) consistent with the proposed Residential GPA. Both components of the Project were analyzed in tandem throughout this section to determine their individual environmental impact. The Solar Project was evaluated and determined to cause no adverse effects to the environment in regard to the construction of utility connections and compliance with solid waste reduction policies. Future residential development was assessed based on assumptions and available information and determined to cause less than significant impact in connection to the construction of new utility connection, and compliance with solid waste reduction policies. Both components were determined to increase current local water demand, but to have less than significant impacts on water supplies through 2045. Future projects in the area surrounding the Project, and the City as a whole, will be required to comply with the same standards and requirements as the proposed Project,

65 and would implement the same water and waste reduction measures currently required of the proposed Project. As a result of these requirements, the cumulative impacts associated with implementation of the Project and all future projects would be less than significant. (EIR, p. 2.19-20).

66 SECTION 8: FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE

ENVIRONMENTAL CHANGES
As required by CEQA Section 15126.2(c), this section of the EIR addresses the potentially significant irreversible environmental changes to or loss of non-renewable resources that could occur from implementation of the proposed Project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified. (also see Public Resources Code section 21100.1 and Title 14, California Code of Regulations, Section 15127). In general, non-renewable resources imply fossilbased energy resources, but may also pertain to the permanent loss of agricultural, biological, mineral and other natural resources. The use of non-renewable resources during construction and operation of future projects allowed by the proposed Project, and long-term impacts associated with the build out of the Project area may be irreversible and irretrievable.

Buildout of the proposed Project will result in the irretrievable and irreversible commitment of non-renewable natural resources, including energy resources such as petroleum, and mineral resources used for construction materials, such as concrete and steel. Future development facilitated by the proposed Project would increase the demand for sand and gravel resources for roadways, infrastructure, and building construction. These resources could be derived from the regional market, but the demand for sand and gravel resources would not be considered significant when compared to available regional resources.

The annual demand for electricity (in kWh), from the residential units within the Project site would be significantly reduced by the Solar Project’s generation of electricity. Future residential development facilitated by the proposed Residential GPA will not increase General Plan build out housing units, and would be evaluated on a project-by-project basis to assure each project is designed, built, and operated in accordance with all applicable energy-related regulations, including energy efficiency and conservation standards. Energy related impacts are considered less than significant because the proposed Solar Project will result in significant new solar energy production.

The proposed Project would facilitate continued urban development that could disturb or permanently affect sensitive species and/or their habitats. As discussed in Section 2.5, a number of mitigation measures are proposed to offset the impacts of the Solar Project on biological resources at the site caused by grading the 140± acres, and the revegetation of portions of the site after construction will allow for the re-colonization of native species to some extent. Mitigation measures have been found in Section 2.5 to reduce the Project’s impacts on biological resources to less than significant levels.

In summary, although the proposed Project will result in the irreversible loss of finite resources, the loss will not be significant, and is consistent with planned development goals of the City and the objectives of the proposed Project. (EIR, p. 5-1 and -2).

67 SECTION 9: FINDINGS REGARDING GROWTH-INDUCING IMPACTS Section 15126.2 of the CEQA Guidelines requires that an EIR consider and analyze a project’s potential to induce growth. Growth inducement can be directly generated by a project, such as the extension of a roadway into a previously undeveloped area, or may indirectly impact growth and cause changes in the environment that could lead to growth. The degree to which the proposed Project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment is evaluated below. This section is based on the project description provided in Section 1 of this EIR, and the analysis of the various impact areas conducted in Section 2. As noted in CEQA (15126.2(e), it should not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.

The proposed Project will not overtly, incidentally or significantly induce growth or change the physical conditions in this area of the City, or in the City as a whole. The Residential GPA results in the same number of residential units at General Plan build out as would occur under current General Plan designations, since it simply relocates the units lost on the Solar Project site to lands adjacent and to the south within the Project site. The Solar Project will increase the availability of electric power within Southern California Edison’s (SCE) service area, but will not, in and of itself induce growth, since SCE’s service area is projected to grow regardless of the availability of power, according to the City’s General Plan, Southern California Association of Governments, San Bernardino Associated Governments and other agencies charged with predicting growth in the region. Therefore, growth that is facilitated by the proposed Project is not of a type or extent that is inadvertently induced in the sense meant by CEQA. Growth in the City will be highly coordinated both locally and regionally, and the City and its public service providers will continue to coordinate land use and transportation, as well as public services and utilities.

Cumulative Impacts
Impacts associated with the implementation of the Project must be considered along with the effects of other development, which may also occur outside the proposed Project and jurisdiction. CEQA identifies these as cumulative impacts (Section 21083 (b), CEQA Statutes and Section 15355 of the CEQA Guidelines). In this EIR, cumulative impacts have been addressed categorically for the proposed Project in Section 2.0 and for project alternatives in Section 3.0. As found in those Sections, cumulative impacts associated with implementation of the Project are expected to be less than significant. (EIR, p. 6-1 and -2).

68 SECTION 10: FINDINGS REGARDING ALTERNATIVES
A. PROJECT OBJECTIVES
As required by CEQA, the City has identified the following list of criteria as the objectives for the Project.

A. Maintain a range of potential housing units consistent with the City’s General Plan.

B. Expand the amount of utility-scale renewable energy available to the City and region and reduce local and state dependence on fossil fuels which will support the State of California’s renewable energy objectives.

C. Provide the City with a community benefits package which increases City revenue.

D. Assist the City in achieving its General Plan goals of reducing its carbon footprint and supporting sustainable sources of electricity.

E. Develop a project which limits the impact on the land by allowing renaturalization of the property once the project’s operations have ended.

B. SIGNIFICANT AND UNAVOIDABLE IMPACTS
Based upon the Final Project EIR and the CEQA Findings of Fact contained herein, as well as the evidentiary materials supporting these documents, the City Council finds that implementing the Proposed Project could result in the following list of significant and unavoidable impacts to the environment:

Aesthetics: Visual Character or Quality of Public Views of the Site and its Surroundings
The Solar Project occurs in a non-urbanized area, and is surrounded by vacant desert lands. The visual character of the Solar Project has been evaluated on this basis. A key characteristic of the Project site is the natural topography created by sheet flow and the drainage system that starts south of Two Mile Road and fans out across the middle of the Project site. The natural state of the Project site and surrounding landscape have remained largely intact in this region of Twentynine Palms due to the distance from State Highway 62 and the few paved roads around the Project site. Apart from the electric transmission lines along Two Mile Road and Sunrise Road and Carodean Substation located approximately 0.5 miles west of the Solar Project along Two Mile Road, the Project site and the surrounding landscape to the west present a high level of native highdesert visual unity.

69 The solid expanse of dark, uniformly placed solar arrays placed atop graded and compacted soil would starkly contrast with the surrounding landscape of natural contours, light beiges, tans, browns and greens. The Solar Project would not be consistent with any other land uses currently allowed under the General Plan, or with the prevailing visual character in the surrounding vicinity due to its mass, scale, shape, and color. Views of the expansive desert from surrounding public vantage points, particularly from the east side of the site along Noels Knoll (extended) and Sunrise Road, and also along Amboy Road (extended) and the planned multi-purpose trail would be impacted by the Solar Project because of the large scale and highly contrasting color and form. From the northern property boundary looking southerly, users of both Amboy Road (extended) and the planned multi-purpose trail would experience a significant change in the native desert, with homes located on lots of 5 acres or more, to the proposed intensity of solar panels occurring in a solid pattern across more than 100 acres of land. The Solar Project would substantially change the visual character along both Amboy Road and the planned multipurpose trail. Because the Solar Project proposes a broad expanse of development, there are no feasible mitigation measures available to reduce these impacts. As a result, impacts to the visual character of the area as seen from the northwest, north and northeast will remain significant and unavoidable.

From Noels Knoll Road (extended), immediately adjacent to the Solar Project; and from Sunrise Road, 1,400 feet east of the Solar Project, and from Samarkand Drive (once extended) along the south boundary of the Project, the Solar Project would be in full view and would substantially degrade the existing visual character or quality of public views of the site and its surroundings. A chain link fence along the perimeter would also impede westerly views and degrade the visual character of the landscape. Impacts to views from Noels Knoll, Sunrise Road and Samarkand Drive would be significant and unavoidable.

In order to reduce the severity of these impacts, mitigation measures AES-1 and AES-2 are included in Section 2.3 of the EIR, which would allow for the restoration of the native plant environment surrounding the solar panels to the extent feasible. However, given the broad expanse of land whose scenic character will be impacted, and its location surrounding the panels, and that the Solar Project would still be visible after replanting of native vegetation, impacts would remain significant and unavoidable due to the mass, scale, and form of the Solar Project. (EIR, p. 4-1 through-3).

C. ALTERNATIVES CONSIDERED AND REJECTED
In addition to the three alternatives studied in the EIR, the City also considered an Alternative Site alternative, but no alternative site was available for sale or lease or met the Project objectives. The distance to existing substations and site topography made these sites infeasible, and would have resulted in substantially more site disturbance and grading through the extension of much longer gen-tie lines to connect to a substation.

Furthermore, the sites were not operationally feasible as they were shaded by surrounding topography and therefore did not provide sufficient irradiation required for utility-scale solar facilities; and the sites would not significantly lessen the visual and aesthetic impacts of the Project. As a result, the alternative was rejected. (EIR, p. 3-4)

70 D. ALTERNATIVES SELECTED FOR ANALYSIS IN THE EIR
Three alternatives were selected for consideration, based on the potential of each alternative to reduce the significant and unavoidable impacts of the proposed Project, and the ability to meet the stated project objectives. Each alternative is summarized below.

Alternative 1 – “No Project/No Construction” Alternative This Alternative assumes that the Project site (477 acres) would remain vacant desert land. None of the Project objectives would be achieved.

Alternative 2 – “No Project/Existing General Plan” Alternative Under Alternative 2, the site would develop as currently designated in the General Plan.

The result of this Alternative would be the construction of 72 single family homes on the 360± acres of RL-5 designated land, and 47 single family homes on the 117± acres of RS-E land within the Project limits. Under this alternative, the Project area would build out as a standard large-lot subdivision, with improvements to public roadways on all sides, as well as a new internal street system. Although no configuration of lots has been developed, it would be expected that these 119 housing units would develop to City standards in the RL-5 and RS-E zones.

Alternative 2 would maintain a range of potential housing units consistent with the City’s General Plan (Project Objective A). However, the City Council hereby rejects Alternative 2 because it fails to meet the majority of the Project objectives. It does not expand the amount of utility-scale renewable energy available to the City and region, which would otherwise reduce local and state dependence on fossil fuels (Objective B). It also fails to provide the City with a community benefits package that increases City revenue (Objective C), does not assist the City in achieving its General Plan goals of reducing its carbon footprint and supporting sustainable sources of electricity (Objective D), and would not enable renaturalization of the property once the project’s operations have ended (Objective E).

Alternative 3 – “Reduced Project Intensity” Alternative Alternative 3 would result in 80± acres of commercial solar development on the north half of the eastern parcel, between the City’s north boundary and Samarkand Drive. Under this alternative, the solar component would reduce the City’s residential capacity under SB 330, requiring a General Plan and Zoning map amendment on 20 acres of the southern half of the eastern parcel to Single Family Residential (RS-1), which would generate up to 20 single family homes (see Exhibit 3-1). The western 317± acre parcel would be developed under the current residential designations and would generate up to 52 single family homes on 259 acres of RL-5 land and 47 homes on 117 acres of RS-E land. Although no lot configuration is known, this alternative would be expected to pave