HomeMy WebLinkAboutDraft Initial Study-Mitigated Negative Declaration
ROME HILL COMMERCIAL PROJECT
Planning Application No. 2021-19
General Plan Amendment No. 2022-01
Zone Change No. 2022-02
Conditional Use Permit No. 2022-17
Commercial Design Review No. 2022-12
Variance No. 2025-08
ENVIRONMENTAL REVIEW NO. 2025-02
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Prepared By:
CITY OF LAKE ELSINORE
130 South Main Street
Lake Elsinore, CA 92530
Applicant:
GEM INVESTMENTS LLC
1207 N. East Street
Anaheim, CA 92805
Environmental Consultant:
TOM DODSON & ASSOCIATES
2150 N. Arrowhead Avenue
San Bernardino, CA 92405
September 2025
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Table of Contents
Section Page
I. INTRODUCTION ................................................................................................. 1
A. Purpose ............................................................................................................. 1
B. California Environmental Quality Act ............................................................. 1
C. Intended Uses of Initial Study and Mitigated Negative Declaration ................ 2
D. Contents of Initial Study .................................................................................. 2
E. Scope of Environmental Analysis .................................................................... 3
F. Tiered Documents, Incorporation by Reference, and Technical Studies ......... 3
II. PROJECT DESCRIPTION .................................................................................... 6
III. ENVIRONMENTAL CHECKLIST .................................................................... 17
A. Background .................................................................................................... 17
B. Environmental Factors Potentially Affected .................................................. 18
C. Determination ................................................................................................. 18
IV. ENVIRONMENTAL ANALYSIS ...................................................................... 29
I. Aesthetics ........................................................................................... 29
II. Agriculture and Forestry Resources ................................................... 30
III. Air Quality ......................................................................................... 32
IV. Biological Resources .......................................................................... 43
V. Cultural Resources ............................................................................. 47
VI. Energy ................................................................................................ 52
VII. Geology and Soils .............................................................................. 57
VIII. Greenhouse Gas Emissions ................................................................ 60
IX. Hazards and Hazardous Materials ...................................................... 67
X. Hydrology and Water Quality ............................................................ 69
XI. Land Use and Planning ...................................................................... 73
XII. Mineral Resources .............................................................................. 74
XIII. Noise .................................................................................................. 74
XIV. Population and Housing ..................................................................... 81
XV. Public Services ................................................................................... 82
XVI. Recreation .......................................................................................... 84
XVII. Transportation .................................................................................... 84
XVIII. Tribal Cultural Resources ................................................................... 88
XIX. Utilities and Service Systems ............................................................. 90
XX. Wildfire .............................................................................................. 94
V. MANDATORY FINDINGS OF SIGNIFICANCE .............................................. 95
VI. PERSONS AND ORGANIZATIONS CONSULTED ........................................ 97
VII. REFERENCES ..................................................................................................... 98
LIST OF FIGURES
No. Title Page
1. Regional Location ............................................................................................... 7
2. Project Vicinity (USGS Topography) ................................................................. 8
3. Project Vicinity (Aerial Photograph) .................................................................. 9
4. Site Plan ............................................................................................................ 12
5a-b Conceptual Building Elevations .......................................................................... 13
6a-b. Conceptual Landscape Plan ................................................................................. 15
XIII-1. Noise Mitigation Requirements ........................................................................ 75
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XVII-1. VMT Part 1 ....................................................................................................... 86
XVII-2. VMT Part 2 ....................................................................................................... 87
LIST OF TABLES
No. Title Page
1. Table 1 BUILDING AREAS ........................................................................................... 10
2. Table III-1 AMBIENT AIR QUALITY STANDARDS ................................................. 32
3. Table III-2 HEALTH EFFECTS OF MAJOR CRITERIA POLLUTANTS .................. 33
4. Table III-3 LOCAL AREA AIR QUALITY LEVELS FROM THE LAKE ELSINORE
MONITORING STATIONS ........................................................................................... 35
5. Table III-4 SOUTH COAST AIR BASIN ATTAINMENT STATUS ........................... 36
6. Table III-5 REGIONAL SIGNIFICANCE – CONSTRUCTION EMISSIONS
(POUNDS PER DAY) ..................................................................................................... 39
7. Table III-6 LOCALIZED SIGNIFICANCE – CONSTRUCTION ................................. 40
8. Table III-7 REGIONAL SIGNIFICANCE – UNMITIGATED OPERATIONAL
EMISSIONS (POUNDS PER DAY) ............................................................................... 40
9. Table III-8 LOCALIZED SIGNIFICANCE – UNMITIGATED OPERATIONAL
EMISSIONS .................................................................................................................... 41
10. Table VI-1PROJECT CONSTRUCTION POWER COST AND ELECTRICITY
USAGE ............................................................................................................................ 53
11. Table VI-2 CONSTRUCTION EQUIPMENT FUEL CONSUMPTION ....................... 53
12. Table VI-3 CONSTRUCTION WORKER FUEL CONSUMPTION ESTIMATES ...... 54
13. Table VI-4 Construction Vendor Fuel Consumption Estimates (MHD Trucks) ............. 54
14. Table VI-5 CONSTRUCTION HAULING FUEL CONSUMPTION ESTIMATES
(HHD TRUCKS) ............................................................................................................. 54
15. Table VI-6 ESTIMATED VEHICLE OPERATIONS FUEL CONSUMPTION ........... 55
16. Table VI-7 PROJECT UNMITIGATED ANNUAL OPERATIONAL ENERGY
DEMAND SUMMARY .................................................................................................. 56
17. Table VIII-1 CONSTRUCTION GREENHOUSE GAS EMISSIONS .......................... 63
18. Table VIII-2 OPENING YEAR UNMITIGATED PROJECT-RELATED
GREENHOUSE GAS EMISSIONS ................................................................................ 63
19. Table VIII-3 CITY OF LAKE ELSINORE CAP GHG REDUCTION MEASURES
FOR COMMERCIAL DEVELOPMENT AND PROJECT CONSISTENCY ............... 65
20. Table XIII-1 LAKE ELSINORE EXTERIOR NOISE LIMITS ..................................... 75
21. Table XIII-2 SHORT TERM NOISE MEASUREMENT RESULTS ............................ 75
22. Table XIII-3 LONG-TERM NOSIE MEASUREMENT DATA (DBA) ........................ 75
23. Table XIII-4 WORST-CASE PREDICTED OPERATIONAL NOISE LEVELS (DBA)
......................................................................................................................................... 77
24. Table XIII-5 TYPICAL CONSTRUCTION EQUIPMENT NOISE LEVELS ............... 78
25. Table XIII-6 GUIDELINE VIBRATION DAMAGE POTENTIAL THRESHOLD
CRITERIA ....................................................................................................................... 80
26. Table XIII-7 VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT
......................................................................................................................................... 81
27. Table XVII-1 TRIP GENERATION ............................................................................... 85
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LIST OF ABBREVIATIONS AND ACROYNMS
AFY Acre-feet per year
ADT Average Daily Traffic
APE Area of Potential Effect
APN Assessor’s Parcel Number
AQMD Air Quality Management District
AQMP Air Quality Management Plan
BMPs Best Management Practices
BUOW Burrowing Owl
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
CAP Climate Action Plan
CARB California Air Resources Board
CBC California Building Code
CDR Commercial Design Review
CEQA California Environmental Quality Act
CH4 Methane
CFC Chlorofluorocarbons
C-M Commercial Manufacturing
CMU Concrete Masonry Unit
CO Carbon Monoxide
CO2 Carbon Dioxide
CP Commercial Park
CUP Conditional Use Permit
dBA A-weighted decibel
DIF Development Impact Fees
Drec Distance from Equipment to Receiver in Feet
EIR Environmental Impact Report
EPA Environmental Protection Agency
EVMWD Elsinore Valley Municipal Water District
FEMA Federal Emergency Management Agency
FGC Fish & Game Code
FIRMette Flood Insurance Rate Map
FMMP Farmland Mapping and Monitoring Program
FTA Federal Transit Association
GC General Commercial
GHG Greenhouse Gas
GPA General Plan Amendment
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GPEIR General Plan Environmental Impact Report
HDR High Density Residential
HRA Health Risk Assessment
IS/MND Initial Study and Mitigated Negative Declaration
ISTEA Intermodal Surface Transportation Efficiency Act
ITE Institute of Transportation Engineers
LDA Light Duty Autos
LEMC Lake Elsinore Municipal Code
Leq Equivalent Continuous Sound Level
Lmin Minimum time-weighted sound level recorded during a specific period
Lmax Maximum time-weighted sound level recorded during a measurement
period
LI Light Industrial
LST Localized Significance Thresholds
MBTA Migratory Bird Treaty Act
MND Mitigated Negative Declaration
MSHCP Multiple Species Habitat Conservation Plan
MSL Mean Sea Level
MTCO2e Metric Tons of Carbon Dioxide Equivalent
NBP Nesting Bird Plan
NO2 Nitrous Oxide
NOI Notice of Intent
NOx Oxides of Nitrogen
NPDES National Pollutant Discharge Elimination System
OEHHA Office of Environmental Health Hazards
PM Particulate Matter
PPV Peak Particle Velocity
RMS Root Mean Squared
ROW Rights-of-Way
RWQCB Regional Water Quality Control Board
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCH State Clearing House
SF Square Feet
SGMA Sustainable Groundwater Management Act
SO2 Sulfur Dioxide
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SRA State Responsibility Area
SWPPP Storm Water Pollution Prevention Plan
TIA Traffic Impact Analysis
USGS U.S. Geological Survey
UWMP Urban Water Management Plan
VdB Vibration-velocity decibel
VMT Vehicle miles traveled
VOC Volatile Organic Compound
WRCOG Western Riverside Council of Governments
WSA Water Supply Assessment
WQMP Water Quality Management Plan
ZC Zone Change
ROME HILL IS/ MND
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I. INTRODUCTION
A. PURPOSE
This document is an Initial Study for evaluation of environmental impacts resulting from implementation
of the Rome Hill Commercial Project. For purposes of this document, this application will be called the
“project” or “proposed project.”
B. CALIFORNIA ENVIRONMENTAL QUALITY ACT
As defined by Section 15063 of the California Environmental Quality Act (CEQA) Guidelines, an Initial
Study is prepared primarily to provide the Lead Agency with information to use as the basis for determining
whether an Environmental Impact Report (EIR), Negative Declaration, or Mitigated Negative Declaration
would be appropriate for providing the necessary environmental documentation and clearance for any
proposed project.
According to CEQA Guidelines Section 15065, an EIR is deemed appropriate for a particular proposal if
the following conditions occur:
• The project has the potential to: substantially degrade the quality of the environment; substantially
reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below
self-sustaining levels; threaten to eliminate a plant or animal community; substantially reduce the
number or restrict the range of an endangered, rare or threatened species; or eliminate important
examples of the major periods of California history or prehistory.
• The project has the potential to achieve short-term environmental goals to the disadvantage of
long- term environmental goals.
• The project has possible environmental effects that are individually limited but cumulatively
considerable.
• The environmental effects of a project will cause substantial adverse effects on human beings,
either directly or indirectly.
According to CEQA Section 21080(c)(1) and CEQA Guidelines Section 15070(a), a Negative Declaration
can be adopted if it can be determined that the project will not have a significant effect on the environment.
According to CEQA Section 21080(c)(2) and CEQA Guidelines Section 15070(b), a Mitigated Negative
Declaration can be adopted if it is determined that although the Initial Study identifies that the project
may have potentially significant effects on the environment, revisions in the project plans and/or mitigation
measures, which would avoid or mitigate the effects to below the level of significance, have been made or
agreed to by the applicant.
This Initial Study has determined that the proposed project may result in potentially significant
environmental effects but that said effects can be reduced to below the level of significance through the
implementation of mitigation measures and therefore, a Mitigated Negative Declaration is deemed the
appropriate environmental determination (document) to provide the necessary environmental evaluations
and clearance.
This Initial Study and Mitigated Negative Declaration (IS/MND) are prepared in conformance with the
California Environmental Quality Act of 1970 , as amended (Public Resources Code, Section 21000 et
seq.); the State Guidelines for Implementation of the California Environmental Quality Act (“CEQA
Guidelines”), as amended (California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15000,
et seq.); applicable requirements of the City of Lake Elsinore; and the regulations, requirements, and
procedures of other responsible public agencies or agencies with jurisdiction by law.
ROME HILL IS/ MND
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The City of Lake Elsinore is designated the Lead Agency, in accordance with Section 15050 of the CEQA
Guidelines. The Lead Agency is the public agency which has the principal responsibility for carrying out
or approving a project which may have significant effects upon the environment.
C. INTENDED USES OF INITIAL STUDY AND MITIGATED NEGATIVE DECLARATION
This Initial Study and Mitigated Negative Declaration are informational documents which are intended to
inform the City of Lake Elsinore decision-makers, other responsible or interested agencies, and the general
public of the potential environmental effects of the proposed project. The environmental review process
has been established to enable public agencies to evaluate environmental consequences and to examine and
implement methods of eliminating or reducing any potentially adverse impacts. While CEQA requires that
consideration be given to avoiding environmental damage, the Lead Agency and other responsible agencies
must balance adverse environmental effects against other public objectives, including economic and social
goals (CEQA Guidelines Section 15021).
The City of Lake Elsinore, as Lead Agency, has determined that environmental clearance for the proposed
project can be provided with an IS/MND. The Initial Study and Notice of Availability and Intent to Adopt
prepared for the Mitigated Negative Declaration will be circulated for a period of 30 days for public and
agency review. Comments received on the document will be considered by the Lead Agency before it acts
on the proposed project.
D. CONTENTS OF INITIAL STUDY
This Initial Study is organized to facilitate a basic understanding of the existing setting and
environmental implications of the proposed project. INTRODUCTION presents an introduction
to the entire report. This section identifies City of Lake Elsinore contact persons involved in the
process, scope of environmental review, environmental procedures, and incorporation by reference
documents.
I. PROJECT DESCRIPTION describes the proposed project. A description of discretionary
approvals and permits required for project implementation is also included.
II. ENVIRONMENTAL CHECKLIST contains the City’s Environmental Checklist Form. The
checklist form presents results of the environmental evaluation for the proposed project and
those areas that would have either a potentially significant impact, a less than significant
impact with mitigation incorporated, a less than significant impact, or no impact.
III. ENVIRONMENTAL ANALYSIS provides the background analysis supporting each
response provided in the environmental checklist form. Each response checked in the checklist
form is discussed and supported with sufficient data and analysis. As appropriate, each
response discussion describes and identifies specific impacts anticipated with project
implementation. In this section, mitigation measures are also set forth, as appropriate, that
would reduce potentially significant adverse impacts to levels of less than significance.
IV. MANDATORY FINDINGS presents the background analysis supporting each response
provided in the environmental checklist form for the Mandatory Findings of Significance set
forth in Section 21083(b) of CEQA and Section 15065 of the CEQA Guidelines.
V. PERSONS AND ORGANIZATIONS CONSULTED identifies those individuals consulted
and involved in the preparation of this Initial Study and Mitigated Negative Declaration.
VI. REFERENCES lists bibliographical materials used in preparation of this document.
E. SCOPE OF ENVIRONMENTAL ANALYSIS
For evaluation of environmental impacts, each question from the Environmental Checklist Form is stated
and responses are provided according to the analysis undertaken as part of the Initial Study. Responses will
consider the whole action involved, including off site as well as on site, cumulative as well as project-level,
ROME HILL IS/ MND
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indirect as well as direct, and construction as well as operational impacts. Project impacts and effects will
be evaluated and quantified, when appropriate. To each question, there are four possible responses,
including:
1. No Impact: A “No Impact” response is adequately supported if the referenced information
sources show that the impact simply does not apply to the proposed project. A “No Impact”
answer should be explained where it is based on project-specific factors as well as general
standards (e.g., the project will not expose sensitive receptors to pollutants, based on a
project-specific screening analysis).
2. Less Than Significant Impact: Development associated with project implementation will
have the potential to impact the environment. These impacts, however, will be less than the
levels of thresholds that are considered significant and no additional analysis is required.
3. Less Than Significant With Mitigation Incorporated: This applies where incorporation
of mitigation measures has reduced an effect from “Potentially Significant Impact” to a
“Less Than Significant Impact”. The Lead Agency must describe the mitigation measures
and briefly explain how they reduce the effect to a less than significant level.
4. Potentially Significant Impact: There is substantial evidence that the proposed project
may have impacts that are considered potentially significant and an EIR is required.
F. TIERED DOCUMENTS, INCORPORATION BY REFERENCE, AND TECHNICAL STUDIES
Information, findings, and conclusions contained in this document are based on the incorporation by
reference of tiered documentation and technical studies that have been prepared for the proposed project
which are discussed in the following section.
1. Tiered Documents
As permitted in CEQA Guidelines Section 15152(a), the analysis of general matters contained in a broader
EIR (such as one prepared for a general plan or policy statement) with later EIRs and negative declarations
on narrower projects; incorporating by reference the general discussions from the broader EIR; and
concentrating the later EIR or negative declaration solely on the issues specific to the later project.
Tiering is defined in CEQA Guidelines Section 15385 as follows:
“Tiering” refers to the coverage of general matters in broader EIRs (such as on general plans or policy
statements) with subsequent narrower EIRs or ultimately site-specific EIRs incorporating by reference
the general discussions and concentrating solely on the issues specific to the EIR subsequently
prepared. Tiering is appropriate when the sequence of EIRs is:
(a) From a general plan, policy, or program EIR to a program, plan, or policy EIR of lesser
scope or to a site-specific EIR;
(b) From an EIR on a specific action at an early stage to a subsequent EIR or a supplement to
an EIR at a later stage. Tiering in such cases is appropriate when it helps the Lead Agency
to focus on the issues which are ripe for decision and exclude from consideration issues
already decided or not yet ripe.
Tiering also allows this document to comply with Section 15152(b) of the CEQA Guidelines, which
discourages repetitive analyses, as follows:
“Agencies are encouraged to tier the environmental analyses which they prepare for separate but
related projects including general plans, zoning changes, and development projects. This approach
can eliminate repetitive discussions of the same issues and focus the later EIR or negative
declaration on the actual issues ripe for decision at each level of environmental review. Tiering is
appropriate when the sequence of analysis is from an EIR prepared for a general plan, policy or
program to an EIR or negative declaration for another plan, policy, or program of lesser scope, or
to a site-specific EIR or negative declaration.”
Further, Section 15152(d) of the CEQA Guidelines states:
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“Where an EIR has been prepared and certified for a program, plan, policy, or ordinance consistent
with the requirements of this section, any lead agency for a later project pursuant to or consistent
with the program, plan, policy, or ordinance should limit the EIR or negative declaration on the
later project to effects which:
(1) Were not examined as significant effects on the environment in the prior EIR; or
(2) Are susceptible to substantial reduction or avoidance by the choice of specific revisions in
the project, by the imposition of conditions or other means.”
For this document, the “City of Lake Elsinore General Plan Update Final Recirculated Program
Environmental Impact Report” certified December 13, 2011 (SCH #2005121019) serves as the broader
document, since it analyzes the entire City area, which includes the proposed project site. However, as
discussed, site-specific impacts, which the broader document (City of Lake Elsinore General Plan Update
Final Recirculated Program Environmental Impact Report) cannot adequately address, may occur for
certain issue areas. This document, therefore, evaluates each environmental issue alone and will rely upon
the analysis contained within the Lake Elsinore General Plan Final EIR with respect to remaining issue
areas.
2. Incorporation by Reference
An EIR or Negative Declaration may incorporate by reference all or portions of another document which
is a matter of public record or is generally available to the public. Where all or part of another document is
incorporated by reference, the incorporated language shall be considered to be set forth in full as part of the
text of the EIR or Negative Declaration. (CEQA Guidelines Section 15150[a])
Incorporation by reference is a procedure for reducing the size of EIRs/Negative Declaration and is most
appropriate for including long, descriptive, or technical materials that provide general background
information, but do not contribute directly to the specific analysis of the project itself. This procedure is
particularly useful when an EIR or Negative Declaration relies on a broadly-drafted EIR for its evaluation
of cumulative impacts of related projects (Las Virgenes Homeowners Federation v. County of Los Angeles
[1986, 177 Ca.3d 300]). If an EIR or Negative Declaration relies on information from a supporting study
that is available to the public, the EIR or Negative Declaration cannot be deemed unsupported by evidence
or analysis (San Francisco Ecology Center v. City and County of San Francisco [1975, 48 Ca.3d 584, 595]).
When an EIR or Negative Declaration incorporates a document by reference, the incorporation must comply
with CEQA Guidelines Section 15150 as follows:
• Where part of another document is incorporated by reference, such other document shall be made
available to the public for inspection at a public place or public building. The EIR or Negative
Declaration shall state where the incorporated documents will be available for inspection. At a
minimum, the incorporated document shall be made available to the public in an office of the Lead
Agency. (CEQA Guidelines Section 15150[b])
• The incorporated part of the referenced document shall be briefly summarized where possible or
briefly described if the data or information cannot be summarized. The relationship between the
incorporated part of the referenced document and the EIR shall be described. (CEQA Guidelines
Section 15150[c])
• This document must include the State identification number of the incorporated document (CEQA
Guidelines Section 15150[d]).
3. Documents Incorporated by Reference/Technical Studies
a. The following document(s) is/are incorporated by reference:
• City of Lake Elsinore General Plan Update Final Recirculated Program Environmental Impact
Report (“General Plan EIR”) (SCH #2005121019), certified December 13, 2011. The General
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Plan EIR, from which this document is tiered, addresses the entire City of Lake Elsinore and
provides background and inventory information and data which apply to the project site.
Incorporated information and/or data will be cited in the appropriate sections.
b. Various technical reports have been prepared to assess specific issues that may result from the
construction and operation of the proposed project. As relevant, information from these technical
reports has been incorporated into the Initial Study. The following technical reports are included as
appendices to this Initial Study:
! Appendix A: Air Quality and Greenhouse Gas Analysis Report
! Appendix B: Biological Assessment and MSHCP Consistency
! Appendix C: Bio Joint Review Findings
! Appendix D: Cultural Resources Survey Report
! Appendix E: Paleontological Resources Assessment
! Appendix F: Geotechnical Report
! Appendix G: Phase I Environmental Assessment
! Appendix H: Noise Impact Analysis
! Appendix I: Trip Generation and VMT Analysis
c. The above-listed documents and technical studies are available for review at:
City of Lake Elsinore (Main City Hall)
130 S. Main Street
Lake Elsinore, California 92530
Hours: Monday - Thursday: 8 a.m. - 5 p.m.
Friday: 8 a.m. - 4 p.m. Closed Holidays
Community Development Department (Temporary Office)
301 N. Spring Street
Lake Elsinore, California 92530
Hours: Monday - Thursday: 8 a.m. - 5 p.m.
Friday: 8 a.m. - 4 p.m. Closed Holidays
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II. PROJECT DESCRIPTION
Planning Application No. 2021-19 (Rome Hill Commercial)
Introduction
GEM Investments, LLC, is proposing to construct two commercial buildings on a 6.77-acre project site
located in southeast Lake Elsinore at Grand Avenue and Vail Street. The proposed project is envisioned to
be developed in two (2) Phases, with two approximately same same-sized structures that are designed to
function as commercial manufacturing buildings. This Initial Study (IS) has been prepared to provide the
public and City of Lake Elsinore decision-makers with an evaluation of potential physical environmental
impacts that may be caused by implementing this proposed project.
Project Location
The proposed project encompasses approximately 6.77 acres located on Grand Avenue and Kathryn Way
(APN 371-150-017) in the City of Lake Elsinore. This project site can be found on the Lake Elsinore 7.5'
Series USGS Topographic Map. It is located within the La Laguna (Stearns) Land Grant so it has no section
number, but it would be located within T6S, R4W, San Bernardino Base & Meridian. The site is located at
approximately Latitude -33.63384 and Longitude -117.3329.
Project Elements
The project is requesting the following entitlements: a General Plan Amendment (GPA 2022-01) to amend
the Land Use Designation of the project site from General Commercial (GC) and High Density Residential
(HDR) to Light Industrial (LI); Zone Change (ZC 2022-02) to change the zoning from Commercial Park
(C-P) and High Density Residential (R-3) to Commercial Manufacturing (C-M); Conditional Use Permit
(CUP 2022-17) to establish outdoor storage; Commercial Design Review (CDR 2022-12) to construct two
(2) new commercial manufacturing warehouses with office space totaling 92,760 sq. ft.; and Variance (VAR
2025-08) to reduce the required front yard setback from 15 ft. to 6 ft. due to site constraints.
The proposed Rome Hill project would develop the 6.77-acre project site with two buildings. The property
is a long rectangular lot that fronts directly on Grand Avenue and will take access from Grand Avenue.
Refer to Figures 1 (USGS Map), Figure 2 (aerial photo), and Figure 3 (Site Plan). The project proposes to
phase the construction of the buildings in this order: Building 1 is proposed as Phase 1 which will consist
of a 46,276 square foot (SF) building with the intended use of commercial manufacturing. There will be
two 60 foot (ft.) long loading docks at the rear of the building on the east and west side of the building.
Building 2 will constitute Phase 2 and will consist of a 46,484 SF commercial warehouse. Total building
square footage is 92,760 SF.
The buildings will be two-story, unrefrigerated warehouse structures with mezzanines and offices. The
following table summarizes the building square footages and the interior operating areas. (see
attached table) The project also includes ample landscaping along Grand Avenue. This includes trees
placed at the entrance of the new development and for additional visual diversity to the street frontage. A
large number of trees are proposed throughout the site (adding diverse color and shade to the tenant parking
areas). In addition, a wide variety of drought tolerant plant materials have been selected to create a lush
outdoor environment while minimizing the amount of water consumption.
FIGURE 1
Tom Dodson & Associates
Environmental Consultants Regional Location
FIGURE 2
Tom Dodson & Associates
Environmental Consultants Project Vicinity (USGS Topography)
FIGURE 3
Tom Dodson & Associates
Environmental Consultants 3. Project Vicinity (Aerial Photograph)
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Table 1: Building Areas
The project proposes to construct a private driveway for access on the adjacent property (APN: 371-150-
017) to the rear of the property. The parking lot islands are proposed as being landscaped along with the
required trash enclosure areas throughout the site. The project includes 180 parking stalls, vehicular traffic
circulation, CMU block walls and electric vehicle gates with Knox Boxes.
The project site is located within an area that contains existing infrastructure within the adjacent right-of-
way. The proposed project would install onsite infrastructure that would connect to the existing
infrastructure that surrounds the site as described below.
Water The project would connect to and be served by the existing 12 inch water infrastructure located on
Grand Avenue.
Sewer The project would connect to and be served by the existing 15 inch sewer mainline located on site.
Drainage The project would install an onsite storm water drainage system that would route run-off to a
proposed bio detention basin located in the north end of the property.
Other Infrastructure The project would connect to existing dry utility infrastructure located in the right-
of-way in Grand Avenue.
Offsite Access Kathryn Way, the alignment of which lies within the County of Riverside, is being proposed
as a private driveway for secondary access via a separate application with the County of Riverside
Transportation Department.
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Construction
The applicant has scheduled construction of the proposed project for late 2025 or beginning of 2026. A
preliminary grading plan for the project site is provided as Figure 4 and the site is expected to balance with
no import or export of soil.
Surrounding Land Uses
North: Open Space/Lake Elsinore
East: Mixed Use: Industrial and Residential (County of Riverside)
South: Industrial, Commercial, Undeveloped land (County of Riverside)
West: Industrial, Commercial, Undeveloped land (County of Riverside)
Other Agencies Whose Approval May Be Required
Based on an evaluation of the specific project location, the proposed project will not require any permits
from other agencies to support development of the site as proposed by the applications. The amount of area
to be disturbed by the whole project will be greater than one acre; therefore, the developer will be required
to file a Notice of Intent (NOI) for a General Construction permit to comply with the National Pollutant
Discharge Elimination System (NPDES) requirements. The NOI is filed with the State Water Resources
Control Board and enforced by the Santa Ana Regional Water Quality Control Board. A Stormwater
Pollution Prevention Plan (SWPPP) must be implemented in conjunction with construction activities to
control water quality degradation. No other permits or agency requirements have been identified in
conjunction with the proposed project. The proposal to construct a private driveway within the Kathryn
Way will require review and approval from the County of Riverside.
FIGURE 4
Tom Dodson & Associates
Environmental Consultants Site Plan
FIGURE 5a
Tom Dodson & Associates
Environmental Consultants Conceptual Building Elevations (a)
FIGURE 5b
Tom Dodson & Associates
Environmental Consultants Conceptual Building Elevations (b)
FIGURE 6a
Tom Dodson & Associates
Environmental Consultants Conceptual Landscaping Plan (a)
FIGURE 6b
Tom Dodson & Associates
Environmental Consultants Conceptual Landscaping Plan (b)
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III. ENVIRONMENTAL CHECKLIST
A. BACKGROUND
1. Lead Agency Name and Address: City of Lake Elsinore, 130 South Main Street, Lake
Elsinore, CA 92530
2. Contact Person and Phone Number: Damaris Abraham, 951-848-4046; E-mail:
dabraham@lake-elsinore.org
3. Project Location: The proposed project encompasses approximately 6.77 acres located on
Grand Avenue and Vail Street (APN 371-150-017 and 371-150-016) in the City of Lake
Elsinore within Riverside County.
4. Project Sponsor’s Name and Address: GEM Investments, LLC.
5. General Plan Designation: General Commercial/Multi-Family Residential (High Density)
6. Zoning: Commercial Park (C-P)/Multi-Family Residential (R-3)
7. Description of Project: The proposed Rome Hill Commercial project would develop the 6.77-
acre project site with two commercial manufacturing buildings. Total building square footage is
92,760 SF
8. Surrounding Land Uses and Setting:
North: Open Space/Lake Elsinore
East: Mixed Use: Industrial and Residential (County of Riverside)
South: Industrial, Commercial, Undeveloped land (County of Riverside)
West: Industrial, Commercial, Undeveloped land (County of Riverside)
9. Other Public Agencies Whose Approval is Required: Refer to description above
10. Have California Native American tribes traditionally and culturally affiliated with the project
area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there
a plan for consultation that includes, for example, the determination of significance of impacts to
tribal cultural resources, procedures regarding confidentiality, etc.?
Yes. Native American tribes have been contacted, and the input is provided under the Tribal
Cultural Resources section of the Initial Study.
ROME HILL IS/ MND
Page 19
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
I. AESTHETICS. Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect
on a scenic vista?
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially degrade
the existing visual character or quality 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?
d) Create a new source of substantial light or
glare which would adversely affect day
or nighttime views in the area?
II. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural
resources are significant environmental effects, lead agencies may refer to the California Agricultural
Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation
as an optional model to use in assessing impacts on agriculture and farmland. In determining whether
impacts to forest resources, including timberland, are significant environmental effects, lead agencies
may refer to information compiled by the California Department of Forestry and Fire Protection
regarding the state’s inventory of forest land, including the Forest and Range Assessment project; and
forest carbon measurement methodology provided in Forest Protocols adopted by the California Air
Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to non-
agricultural use?
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 by
Public Resources Code section 4526), or
timberland zoned Timberland Production
(as defined by Government Code section
51104(g))?
ROME HILL IS/ MND
Page 20
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
d) Result in the loss of forest land or conversion
of forest land to non-forest uses?
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?
III. AIR QUALITY. Where available, significance criteria established by the applicable air quality
management or air pollution control district may be relied upon to make the following
determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
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?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
IV. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special
status species in local or regional plans, policies,
or regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of
Fish and Game or U.S. Fish and Wildlife
Service?
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?
ROME HILL IS/ MND
Page 21
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
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?
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?
V. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
CEQA Guidelines §15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to CEQA Guidelines §15064.5?
c) Disturb any human remains, including those
interred outside of formal cemeteries?
VI. ENERGY. Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
VII. GEOLOGY AND SOILS. Would the project:
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 Alquist-Priolo
Earthquake Fault Zoning Map, issued by the
State Geologist for the area or based on
other substantial evidence of a known fault?
Refer to Division of Mines and Geology
Special Publication 42.
ROME HILL IS/ MND
Page 22
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of
topsoil?
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?
d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life or property?
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative wastewater
disposal systems where sewers are not available
for the disposal of wastewater?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
VIII. GREENHOUSE GAS EMISSIONS. Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
IX. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) 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?
ROME HILL IS/ MND
Page 23
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
c) Emit hazardous emissions or handle hazardous
materials 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?
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 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, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
X. HYDROLOGY AND WATER QUALITY. Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater
recharge, such that the project may impede
sustainable groundwater management of the
basin?
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 offsite;
iii) Create or contribute runoff water which
ROME HILL IS/ MND
Page 24
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
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?
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?
XI. LAND USE AND PLANNING. Would the project:
a) Physically divide an established community?
b) 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?
XII. MINERAL RESOURCES. Would the project:
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?
XIII. NOISE. Would the project result in:
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 other applicable standards of other
agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
ROME HILL IS/ MND
Page 25
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project expose people residing or
working in the project area to excessive noise
levels?
XIV. POPULATION AND HOUSING. Would the project:
a) 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)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
XV. PUBLIC SERVICES. 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:
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public services/facilities?
XVI. RECREATION.
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would occur
or be accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?
ROME HILL IS/ MND
Page 26
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
XVII. TRANSPORTATION. Would the project:
a) Conflict with a program plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities?
b) Would the project conflict or be inconsistent with
CEQA Guidelines section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
XVIII. TRIBAL CULTURAL RESOURCES. Would the project cause a substantial adverse change in the
significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a
site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of
the landscape, sacred place, or object with cultural value to a California Native American tribe, and
that is:
a) 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).
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1. In applying the criteria set forth
in subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe.
XIX. UTILITIES AND SERVICE SYSTEMS. Would the project:
a) 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?
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple
dry years?
ROME HILL IS/ MND
Page 27
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
c) Result in a determination by the wastewater
treatment provider, which serves or may serve
the project that it has adequate capacity to serve
the project’s projected demand in addition to the
provider’s existing commitments?
d) 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) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
XX. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire
hazard severity zones, would the project:
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?
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the habitat of a
fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal
community, substantially reduce the number or
restrict the range of a rare or endangered plant or
animal or eliminate important examples of the
major periods of California history or prehistory?
b) Does the project have impacts that are individually
ROME HILL IS/ MND
Page 28
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
limited, but cumulatively considerable?
(“Cumulatively considerable” means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and
the effects of probable future projects)?
c) Does the project have environmental effects which
will cause substantial adverse effects on human
beings, either directly or indirectly?
ROME HILL IS/ MND
Page 29
IV. ENVIRONMENTAL ANALYSIS
This section provides an evaluation of the impact categories and questions contained in the Environmental
Checklist. A complete list of the reference sources applicable to the following source abbreviations is
contained in Section VII, References, of this document.
I. AESTHETICS
a) Have a substantial adverse effect on a scenic vista? (Less Than Significant Impact)
Grand Avenue provides excellent public views to the scenic vistas that dominate the City of Lake Elsinore,
which consist of Lake Elsinore, the surrounding foothills of Cleveland National Forest and the background
Santa Ana-Elsinore Mountains to the west. The proposed project consists of a commercial manufacturing
warehouse complex that will be developed within an area that is transitioning from undeveloped parcels to
a mix of industrial, commercial and higher density residential urban development. The proposed
development will alter the visual setting of the project site, but is not forecast to significantly impact any
public scenic vistas. This finding is consistent with the City’s General Plan Environmental Impact Report
(GPEIR) which was adopted in 2011. The GPEIR found that full development of the City in accordance
with the City policies and design guidelines would not result in any significant adverse impacts to scenic
vistas as long as important public viewing corridors are maintained. Due to its location off Grand Avenue
and the already existing surrounding urban development, visual access to the mountains and foothills are
already highly disturbed. After construction of the proposed project, the new commercial buildings and
identified landscaping will integrate the project site into this existing urban visual setting consistent with
the City’s design guidelines. Thus, the proposed project is consistent with this finding in the General Plan.
Since conformance with City design guidelines and policies is mandatory, no mitigation is required and a
finding of less than significant impact on scenic vistas is appropriate under this issue.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan Resource Protection & Preservation Element, General Plan EIR)
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway? (Less Than Significant Impact)
As indicated in the response to issue a), the proposed project will modify the visual setting of the project
site, but the proposed modification will be designed consistent with City policies and design guidelines.
The City does not have any designated scenic highways (Interstate 15 and State Route 74 are eligible for
State designation, but not designated), therefore no disturbance of any scenic resources in proximity to a
state scenic highway will occur. Further, the project site does not contain any notable trees, rock
outcroppings or historic buildings that will be adversely impacted by developing the project site as
proposed. Thus, impacts under this issue are considered less than significant.
Mitigation Measures: No mitigation measures are required.
(Sources: California State Scenic Highway System Map and General Plan Resource Protection &
Preservation Element, General Plan EIR)
c) In non-urbanized areas, substantially degrade the existing visual character or quality 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
ROME HILL IS/ MND
Page 30
other regulations governing scenic quality? (Less Than Significant Impact)
The City’s design review requirements will ensure that landscaping and architecture will be consistent with
the surrounding urban uses. The proposed implementation of the project is not forecast to cause any
significant negative alteration of any aesthetic or visual impacts when compared to these design guidelines.
The project seeks a General Plan Amendment (GPA) to allow a commercial manufacturing development,
but the existing zoning classification allows both commercial and high density residential, which would
result in comparable structures on the property. If the GPA and zone change are approved, the proposed
Rome Hill Commercial project will be fully consistent with the land use regulations and the project will
comply with City design guidelines. Thus, the potential impact under this topic is less than significant.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan and General Plan EIR)
d) Create a new source of substantial light or glare which would adversely affect day or nighttime
views in the area? (Less Than Significant Impact)
The proposed project will introduce new lighting onto the project site with a potential to adversely impact
nighttime views of the surrounding area and conflict with Mt. Palomar operations. However, the project
must comply with Section 17.112.040 and Section 17.148.110 of the Lake Elsinore Municipal Code
(LEMC) which requires that lighting shall be designed to preclude light shining into the sky above a
horizontal plane passing through the luminaire and encourage the use of low pressure sodium lighting in
non-residential development. Thus, compliance with General Plan Policy 13.2 and the LEMC will reduce
any potential impacts from light and glare to a less-than-significant level without further mitigation.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan, General Plan EIR and LEMC)
II. AGRICULTURE AND FORESTRY RESOURCES
This section describes the environmental setting for agriculture and forestry resources, as well as applicable
regulatory framework, potential impacts associated with implementation of the proposed commercial
development project at Rome Hill. The primary sources of data for the information presented below are
the local General Plan and an extensive field evaluation of the proposed project site.
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 (FMMP) of
the California Resources Agency, to non-agricultural use? (No Impact)
No Impact – In the Executive Summary to the GPEIR, agricultural resource issues were found to be less
than significant due to the limited amount of agricultural activity within the City and City’s Sphere of
Influence. The City has not designated the project site nor zoned this site for agricultural use, as the General
Plan and zoning classifications in the project vicinity are primarily industrial, commercial and high density
residential. Therefore, given that the City does not identify the project site for agricultural use, and that no
Prime Farmland, Unique Farmland or Farmland of Statewide Importance has been identified within the
project area, implementation of the proposed project and conversion of the project site to the proposed
commercial development will not pose any direct or indirect adverse impact to agricultural resources or
values. No mitigation is required.
ROME HILL IS/ MND
Page 31
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan EIR, FMMP)
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? (No Impact)
No Impact - Implementation of the proposed project will not conflict with existing zoning for agricultural
use, or a Williamson Act contract. According to the City’s GPEIR and the Project Description, the proposed
project site is not part of a Williamson Act contract. Please reference the discussion in II(a), above. Based
on this information, the proposed project will not conflict with existing zoning for agricultural use, or a
Williamson Act contract. No adverse impacts are anticipated and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan EIR, Zoning Map)
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined by Public Resources
Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section
51104(g))? (No Impact)
No Impact ‒ The project site is not located within forest land, timberland or timberland zoned for
Timberland Production. Therefore, the proposed project will not 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)). No adverse impacts to forest land or timberland are anticipated and
no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan, Zoning Map, Public Resources Code Section 12220[g])
d) Result in the loss of forest land or conversion of forest land to non-forest uses? (No Impact)
No Impact – The project site is not located within forest land and has no commercial forest or timber trees
on the property; therefore, the project will not result in the loss of forest land or conversion of forest land
to non-forest production use. No adverse impacts are anticipated and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan, Zoning Map, Public Resources Code Section 12220[g])
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? (No Impact)
No Impact – Please refer to the discussion under the preceding issues above. No agricultural activities have
been practiced on the site in recent history. Furthermore, the City has designated and zoned the site for
commercial and multi-family uses, which does not permit agricultural uses to be carried out. The uses in
the immediate vicinity surrounding the proposed project do not currently support agricultural activities, as
they consist of a mix of industrial, commercial, residential and open space uses. Ultimately, the
development of this site for the Rome Hill Commercial Project would not involve any other changes that
would result in on- or off-site agricultural land converting to a non-agricultural use.
ROME HILL IS/ MND
Page 32
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan, Zoning Map, Public Resources Code Section 12220[g])
III. AIR QUALITY
Background
The data for the following air quality evaluation is abstracted from an air quality report titled “Rome Hill
Commercial Project Air Quality, Greenhouse Gas, and Energy Impact Study, County of Riverside,” dated
1/28/2025 by MD Acoustics which is provided as Appendix A to this Initial Study. This report is used
extensively in the following analysis, and it is provided as Appendix A to this Initial Study. For a discussion
of the existing Federal and State air quality Framework and Regulatory Setting please refer to Appendix A,
Section 2. This includes local (County and City) goals and policies and California Green Building
Standards. Presented in the two tables below are the current Federal and State Ambient Air Quality
Standards and Health Impacts for specific air pollutants.
Table III-1
AMBIENT AIR QUALITY STANDARDS
1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate
matter
(PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California
ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a
year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is
equal to or less than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24-hour
average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily
concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national
policies.
ROME HILL IS/ MND
Page 33
3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature
of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference
pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
4. Any equivalent measurement method which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air
quality standard may be used.
5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.
6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of
a pollutant.
7. Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship
to the reference method” and must be approved by the U.S. EPA.
8. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing national 24-hour
PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour
PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual
mean, averaged over 3 years.
9. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site
must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per
million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this
case, the national standard of 100 ppb is identical to 0.100 ppm.
10. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain
the 1- hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not
exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010
standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to
attain or maintain the 2010 standards are approved.
Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly
compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is
identical to 0.075 ppm.
11. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects
determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these
pollutants.
12. The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly
average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the
1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
13. In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental
equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin
standards, respectively.
Table III-2
HEALTH EFFECTS OF MAJOR CRITERIA POLLUTANTS
Pollutants Sources Primary Effects
Carbon Monoxide
(CO)
• Incomplete combustion of fuels and other
carbon-containing substances, such as motor
exhaust.
• Natural events, such as decomposition of
organic matter.
• Reduced tolerance for exercise.
• Impairment of mental function.
• Impairment of fetal development.
• Death at high levels of exposure.
• Aggravation of some heart diseases (angina).
Nitrogen Dioxide
(NO2)
• Motor vehicle exhaust.
• High temperature stationary combustion.
• Atmospheric reactions.
• Aggravation of respiratory illness.
• Reduced visibility.
• Reduced plant growth.
• Formation of acid rain.
Ozone
(O3)
• Atmospheric reaction of organic gases with
nitrogen oxides in sunlight.
• Aggravation of respiratory and cardiovascular
diseases.
• Irritation of eyes.
• Impairment of cardiopulmonary function.
• Plant leaf injury.
Lead (Pb) • Contaminated soil. • Impairment of blood function and nerve construction.
• Behavioral and hearing problems in children.
Fine Particulate Matter
(PM-10)
• Stationary combustion of solid fuels.
• Construction activities.
• Industrial processes.
• Atmospheric chemical reactions.
• Reduced lung function.
• Aggravation of the effects of gaseous pollutants.
• Aggravation of respiratory and cardio respiratory
diseases.
• Increased cough and chest discomfort.
• Soiling.
• Reduced visibility.
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Pollutants Sources Primary Effects
Fine Particulate Matter
(PM-2.5)
• Fuel combustion in motor vehicles,
equipment, and industrial sources.
• Residential and agricultural burning.
• Industrial processes.
• Also, formed from photochemical reactions
of other pollutants, including NOx, sulfur
oxides, and organics.
• Increases respiratory disease.
• Lung damage.
• Cancer and premature death.
• Reduces visibility and results in surface soiling.
Sulfur Dioxide
(SO2)
• Combustion of sulfur-containing fossil fuels.
• Smelting of sulfur-bearing metal ores.
• Industrial processes.
• Aggravation of respiratory diseases (asthma,
emphysema).
• Reduced lung function.
• Irritation of eyes.
• Reduced visibility.
• Plant injury.
• Deterioration of metals, textiles, leather, finishes,
coatings, etc.
Source: California Air Resources Board, 2002.
Several pollutants listed in Table III-1 are not addressed in this analysis. Analysis of lead is not included in
this report because the project is not anticipated to emit lead. Visibility-reducing particles are not explicitly
addressed in this analysis because particulate matter is addressed. The project is not expected to generate
or be exposed to vinyl chloride because the proposed project uses do not utilize the chemical processes that
generate this pollutant and there are no such uses in the project vicinity. The proposed project is also not
expected to cause exposure to hydrogen sulfide because it would not generate hydrogen sulfide in any
substantial quantity.
The project site is located in an unincorporated portion of the County of Riverside within the sphere of
influence of the City of Lake Elsinore, which is part of the South Coast Air Basin (SCAB or Basin) that
includes all of Orange County as well as the non-desert portions of Los Angeles, Riverside, and San
Bernardino Counties. The South Coast Air Basin is located on a coastal plain with connecting broad valleys
and low hills to the east. Regionally, the South Coast Air Basin is bounded by the Pacific Ocean to the
southwest and high mountains to the east forming the inland perimeter.
Dominant airflows provide the driving mechanism for transport and dispersion of air pollution. The
mountains surrounding the region form natural horizontal barriers to the dispersion of air contaminants. Air
pollution created in the coastal areas and around the Los Angeles area is transported inland until it reaches
the mountains where the combination of mountains and inversion layers generally prevent further
dispersion. This poor ventilation results in a gradual degradation of air quality from the coastal areas to
inland areas. Air stagnation may occur during the early evening and early morning periods of transition
between day and nighttime flows. The region also experiences periods of hot, dry winds from the desert,
known as Santa Ana winds. If the Santa Ana winds are strong, they can surpass the sea breeze, which blows
from the ocean to the land, and carry the suspended dust and pollutants out to the ocean. If the winds are
weak, they are opposed by the sea breeze and cause stagnation, resulting in high pollution events.
Temperature inversions limit the vertical depth through which pollution can be mixed. Among the most
common temperature inversions in the basin are radiation inversions, which form on clear winter nights
when cold air off mountains sink to the valley floor while the air aloft over the valley remains warm. These
inversions, in conjunction with calm winds, trap pollutants near the source. Other types of temperature
inversions that affect the basin include marine, subsidence, and high-pressure inversions.
The temperature and precipitation levels for the City of Lake Elsinore show that August is typically the
warmest month and December is typically the coolest month. Rainfall in the project area varies considerably
in both time and space. Almost all the annual rainfall comes from the fringes of mid-latitude storms from
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late November to early April, with summers being almost completely dry.
The South Coast Air Quality Management District (SCAQMD) has divided the South Coast Air Basin into
38 air-monitoring areas with a designated ambient air monitoring station representative of each area. The
project site is located in the City of Lake Elsinore (Area 25). The nearest air monitoring station to the
project site is the Lake Elsinore – W Flint Street Station (Lake Elsinore Station). The Lake Elsinore Station
is located approximately 1.6 miles southeast of the project site, at 506 W Flint Street, Lake Elsinore;
however, this location does not provide all ambient weather data. Therefore, additional data was pulled
from the SCAQMD historical data for the Lake Elsinore Area (Area 25) for both sulfur dioxide and carbon
monoxide to provide the existing levels. Table III-3 presents the monitored pollutant levels within the
vicinity. However, it should be noted that due to the air monitoring station distance from the project site,
recorded air pollution levels at the air monitoring station reflect with varying degrees of accuracy, local air
quality conditions at the project site. The monitoring data presented in Table III-3 shows that ozone and
particulate matter (PM10) are the air pollutants of primary concern in the project area.
Table III-3
LOCAL AREA AIR QUALITY LEVELS FROM THE LAKE ELSINORE MONITORING STATIONS
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The Federal Environmental Protection Agency (EPA) and the California Air Resources Control Board
(CARB) designate air basins where ambient air quality standards are exceeded as “nonattainment” areas. If
standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data
to make a definitive attainment designation, they are considered “unclassified.” National nonattainment
areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation
from standards. Each standard has a different definition, or ‘form ’of what constitutes attainment, based on
specific air quality statistics. For example, the Federal 8-hour CO standard is not to be exceeded more than
once per year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air
monitoring values exceeds the threshold per year. In contrast, the federal annual PM2.5 standard is met if
the three-year average of the annual average PM2.5 concentration is less than or equal to the standard. Table
III-4 lists the attainment status for the criteria pollutants in the basin.
The EPA and the CARB designate air basins where ambient air quality standards are exceeded as
“nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is
inadequate or inconclusive data to make a definitive attainment designation, they are considered
“unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe,
or extreme as a function of deviation from standards. Each standard has a different definition, or ‘form’ of
what constitutes attainment, based on specific air quality statistics. For example, the Federal 8-hour CO
standard is not to be exceeded more than once per year; therefore, an area is in attainment of the CO standard
if no more than one 8-hour ambient air monitoring values exceeds the threshold per year. In contrast, the
federal annual PM2.5 standard is met if the three-year average of the annual average PM2.5 concentration
is less than or equal to the standard. Table III-4 lists the attainment status for the criteria pollutants in the
basin.
Table III-4
SOUTH COAST AIR BASIN ATTAINMENT STATUS
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Please refer to Section 4 of Appendix A for detailed information regarding Modeling Parameters and
Assumptions.
Impact Analysis
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially
substantial, adverse change in the environment.” To determine if a project would have a significant impact
on air quality, the type, level, and impact of emissions generated by the project must be evaluated. The
following air quality significance thresholds are contained in Appendix G of the CEQA Guidelines. A
significant impact would occur if the project would:
• Conflict with or obstruct implementation of the applicable air quality plan;
• Result in a cumulatively considerable net increase of any criteria pollutant for which the project region
is nonattainment under an applicable national or state ambient air quality standard;
• Expose sensitive receptors to substantial pollutant concentrations; or
• Result in other emissions (such as those leading to odors) adversely affecting a substantial number of
people.
While the final determination of whether a project is significant is within the purview of the Lead Agency
pursuant to Section 15064(b) of the CEQA Guidelines, SCAQMD recommends that its quantitative air
pollution thresholds be used to determine the significance of project emissions. If the Lead Agency finds
that the project has the potential to exceed these air pollution thresholds, the project should be considered
to have significant air quality impacts. There are daily emission thresholds for construction and operation
of a proposed project in the basin.
The following CEQA significance thresholds for construction emissions are established for the South Coast
Air Basin:
• 75 pounds per day (lbs/day) of VOC
• 100 lbs/day of NOx
• 550 lbs/day of CO
• 150 lbs/day of PM10
• 55 lbs/day of PM2.5
• 150 lbs/day of SO2
Projects in the South Coast Air Basin with construction-related emissions that exceed any of the emission
thresholds are considered to be significant under SCAQMD guidelines.
The daily operational emissions significance thresholds for the basin are as follows:
• 55 pounds per day (lbs/day) of VOC
• 55 lbs/day of NOx
• 550 lbs/day of CO
• 150 lbs/day of PM10
• 55 lbs/day of PM2.5
• 150 lbs/day of SO2
The significance of localized project impacts under CEQA depends on whether ambient CO levels in the
vicinity of the project are above or below State and federal CO standards. If ambient levels are below the
standards, a project is considered to have a significant impact if project emissions result in an exceedance
of one or more of these standards. If ambient levels already exceed a State or federal standard, project
emissions are considered significant if they increase 1-hour CO concentrations by 1.0 ppm or more or 8-
hour CO concentrations by 0.45 ppm or more. The following are applicable local emission concentration
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standards for CO:
• California State 1-hour CO standard of 20.0 ppm
• California State 8-hour CO standard of 9.0 ppm
Project-related construction air emissions may have the potential to exceed the State and Federal air quality
standards in the project vicinity, even though these pollutant emissions may not be significant enough to
create a regional impact to the South Coast Air Basin. In order to assess local air quality impacts the
SCAQMD has developed Localized Significant Thresholds (LSTs) to assess the project-related air
emissions in the project vicinity. The SCAQMD has also provided Final Localized Significant Threshold
Methodology (LST Methodology), June 2003, which details the methodology to analyze local air emission
impacts. The Localized Significant Threshold Methodology found that the primary emissions of concern
are NO2, CO, PM10, and PM2.5. The emission thresholds were calculated based on the Elsinore source
receptor area (SRA 25) and a disturbance of 2 acres per day, to be conservative, at a distance of 50 meters
(164 feet), for construction and 2 acres a day, to be conservative, for screening of localized operational
emissions.
a) Conflict with or obstruct implementation of the applicable air quality plan? (Less Than Significant
Impact)
The California Environmental Quality Act (CEQA) requires a discussion of any inconsistencies between a
proposed project and applicable General Plans and Regional Plans (CEQA Guidelines Section 15125). The
regional plan that applies to the proposed project includes the SCAQMD Air Quality Management Plan
(AQMP). Therefore, this section discusses any potential inconsistencies of the proposed project with the
AQMP.
The purpose of this discussion is to set forth the issues regarding consistency with the assumptions and
objectives of the AQMP and discuss whether the proposed project would interfere with the region’s ability
to comply with Federal and State air quality standards. If the decision-makers determine that the proposed
project is inconsistent, the lead agency may consider project modifications or inclusion of mitigation to
eliminate the inconsistency. The SCAQMD CEQA Handbook states that "New or amended General Plan
Elements (including land use zoning and density amendments), Specific Plans, and significant projects must
be analyzed for consistency with the AQMP." Strict consistency with all aspects of the plan is usually not
required A proposed project should be considered to be consistent with the AQMP if it furthers one or more
policies and does not obstruct other policies. The SCAQMD CEQA Handbook identifies two key indicators
of consistency:
(1) Whether the project will result in an increase in the frequency or severity of existing air quality
violations or cause or contribute to new violations, or delay timely attainment of air quality standards
or the interim emission reductions specified in the AQMP.
(2) Whether the project will exceed the assumptions in the AQMP in 2016 or increments based on the year
of project buildout and phase.
These criteria are evaluated in the following text.
Based on the air quality modeling analysis contained in Appendix A of this document, short-term
construction impacts will not result in significant impacts based on the SCAQMD regional and local
thresholds of significance. Appendix A also found that, long-term operations impacts will not result in
significant impacts based on the SCAQMD local and regional thresholds of significance. Refer to Table III-
5 and III-7 for the summary of emissions compared to the thresholds. Therefore, the proposed project is not
projected to contribute to the exceedance of any air pollutant concentration standards and is found to be
consistent with the AQMP for the first criterion.
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Consistency with the AQMP assumptions is determined by performing an analysis of the proposed project
with the assumptions in the AQMP. The emphasis of this criterion is to ensure that the analyses conducted
for the proposed project are based on the same forecasts as the AQMP. The 2016-2040 Regional
Transportation/Sustainable Communities Strategy, prepared by SCAG, 2016, includes chapters on: the
challenges in a changing region, creating a plan for our future, and the road to greater mobility and
sustainable growth. These chapters currently respond directly to federal and state requirements placed on
SCAG. Local governments are required to use these as the basis of their plans for purposes of consistency
with applicable regional plans under CEQA. For this project, the County of Riverside and City of Lake
Elsinore Land Use Plans define the assumptions that are represented in the AQMP.
Mitigation Measures: None required.
(Sources: Air Quality and GHG Analysis Report, Appendix A)
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? (Less Than
Significant Impact)
The latest version of CalEEMod was used to estimate the onsite and offsite construction emissions. The
emissions incorporate Rule 402 and 403. Rule 402 and 403 (fugitive dust and odors) are not considered
mitigation measures as the project by default is required to incorporate these rules during construction. The
construction emissions for the project would not exceed the SCAQMD ’s daily emission thresholds at the
regional level as demonstrated in Table III-5, and therefore would be considered less than significant.
Table III-5
REGIONAL SIGNIFICANCE - CONSTRUCTION EMISSIONS (POUNDS/DAY)
Activity
Pollutant Emissions (pounds/day)
VOC NOx CO SO2 PM10 PM2.5
SITE PREPARATION:
On-Site2 3.31 31.60 30.20 0.05 9.04 5.20
Off-Site3 0.08 0.08 1.35 0.00 0.23 0.05
Total 3.39 31.68 31.55 0.05 9.27 5.25
GRADING:
On-Site2 1.74 16.30 17.90 0.03 3.49 2.00
Off-Site3 0.14 4.85 2.33 0.03 1.41 0.45
Total 1.88 21.15 20.23 0.06 4.90 2.45
BUILDING CONSTRUCTION:
On-Site2 1.13 10.40 13.00 0.02 0.43 0.40
Off-Site3 0.24 0.95 4.15 0.00 0.85 0.22
Total 1.37 11.35 17.15 0.02 1.28 0.62
Paving
On-Site2 1.28 7.12 9.94 0.01 0.32 0.29
Off-Site3 0.06 0.22 1.13 0.00 0.25 0.06
Total 1.34 7.34 11.07 0.01 0.57 0.35
ARCHITECTURAL COATING:
On-Site2 58.82 0.86 1.13 0.00 0.02 0.02
Off-Site3 0.04 0.04 0.73 0.00 0.13 0.03
Total 58.86 0.90 1.86 0.00 0.15 0.05
Total of overlapping phases4 61.57 19.59 30.08 0.03 2.00 1.02
SCAQMD Thresholds 75 100 550 150 150 55
Exceeds Thresholds? No No No No No No
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Notes: 1 Source: CalEEMod Version 2022.1.1.29
2 On-site emissions from equipment operated on-site that is not operated on public roads.
3 Off-site emissions from equipment operated on public roads.
4 Construction, architectural coatings and paving phases may overlap.
The data provided in Table III-6 shows that none of the analyzed criteria pollutants would exceed the local
emissions thresholds at the nearest sensitive receptors. Therefore, a less than significant local air quality
impact would occur from construction of the proposed project.
Table III-6
LOCALIZED SIGNIFICANCE – CONSTRUCTION
Activity
Pollutant Emissions (pounds/day)1
NOx CO PM10 PM2.5
Site Preparation 31.60 30.20 9.04 5.20
Grading 16.30 17.90 3.49 2.00
Building Construction 10.40 13.00 0.43 0.40
Paving 7.12 9.94 0.32 0.29
Architectural Coating 0.86 1.13 0.02 0.02
Total of overlapping phases 18.38 24.07 0.77 0.71
SCAQMD Threshold for 50 meters
(164 feet) or less2 275 1,572 20 6
Exceeds Threshold? No No No No
Notes: 1 Source: Calculated from CalEEMod and SCAQMD’s Mass Rate Look-up Tables for two acres, to be conservative, in Perris
Valley Source Receptor Area
(SRA 24). Project will disturb a maximum of 4.0 acres per day (see Table 7).
2 The nearest sensitive receptor is located 56 meters southeast; therefore, the 50-meter threshold has been used.
The operations-related criteria air quality impacts created by the proposed project have also been analyzed
through the use of CalEEMod model. The operating emissions were based on year 2025, which is the
anticipated opening year for the project per the project applicant. The summer and winter emissions created
by the proposed project’s long-term operations were calculated and the highest emissions from either
summer or winter are summarized in Table III-7.
Table III-7 provides the project's unmitigated operational emissions. Table III-7 shows that the project does
not exceed the SCAQMD daily emission threshold and regional operational emissions are considered to be
less than significant.
Table III-7
REGIONAL SIGNIFICANCE – UNMITIGATED OPERATIONAL EMISSIONS (POUNDS PER DAY)
Activity
Pollutant Emissions (pounds/day)1
VOC NOx CO SO2 PM10 PM2.5
Area Sources2 3.80 0.04 5.28 0.00 0.01 0.01
Energy Usage3 0.03 0.62 0.52 0.00 0.05 0.05
Mobile Sources4 1.00 4.40 12.60 0.06 3.45 0.94
Total Emissions 4.83 5.06 18.40 0.06 3.51 1.00
SCAQMD Thresholds 55 55 550 150 150 55
Exceeds Threshold? No No No No No No
Notes: 1 Source: CalEEMod Version 2022.1.1.29
2 Area sources consist of emissions from consumer products, architectural coatings, and landscaping equipment.
3 Energy usage consists of emissions from on-site natural gas usage.
4 Mobile sources consist of emissions from vehicles and road dust.
Table III-8 shows the calculated emissions for the proposed operational activities compared with
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appropriate LSTs. The LST analysis only includes on-site sources; however, the CalEEMod software
outputs do not separate on-site and off-site emissions for mobile sources. For a worst-case scenario
assessment, the emissions shown in Table III-8 include all on-site project-related stationary sources and
10% of the project-related new mobile sources. This percentage is an estimate of the amount of project-
related new vehicle traffic that will occur on-site. Table III-8 indicates that the local operational emission
would not exceed the LST thresholds at the nearest sensitive receptors, located adjacent to the project.
Therefore, the project will not result in significant Localized Operational emissions.
Table III-8
Localized Significance – Unmitigated Operational Emissions
Activity
Pollutant Emissions (pounds/day)1
NOx CO PM10 PM2.5
Area Sources2 0.04 5.28 0.01 0.01
Energy Usage3 0.62 0.52 0.05 0.05
On-Site Vehicle Emissions4 0.44 1.26 0.35 0.09
Total Emissions 1.10 7.06 0.41 0.15
SCAQMD Threshold for 50 meters
(164 feet)5
275 1,572 5 2
Exceeds Threshold? No No No No
Notes:
1 Source: Calculated from CalEEMod and SCAQMD’s Mass Rate Look-up Tables for two acres, to be conservative, in Lake
Elsinore Source Receptor
Area (SRA 25).
2 Area sources consist of emissions from consumer products, architectural coatings, and landscaping equipment.
3 Energy usage consists of emissions from generation of electricity and on-site natural gas usage.
4 On-site vehicular emissions based on 1/10 of the gross vehicular emissions and road dust.
5 The nearest sensitive receptor is located 56 meters southeast; therefore, the 50-meter threshold has been used.
Cumulative projects include local development as well as general growth within the project area. However,
as with most development, the greatest source of emissions is from mobile sources, which travel well out
of the local area. Therefore, from an air quality standpoint, the cumulative analysis would extend beyond
any local projects and when wind patterns are considered, would cover an even larger area. Accordingly,
the cumulative analysis for the project’s air quality must be generic by nature.
The project area is out of attainment for both ozone and PM10 particulate matter. Construction and
operation of cumulative projects will further degrade the local air quality, as well as the air quality of the
South Coast Air Basin. The greatest cumulative impact on the quality of regional air cell will be the
incremental addition of pollutants mainly from increased traffic from residential, commercial, and industrial
development and the use of heavy equipment and trucks associated with the construction of these projects.
Air quality will be temporarily degraded during construction activities that occur separately or
simultaneously. However, in accordance with the SCAQMD methodology, projects that do not exceed the
SCAQMD criteria or can be mitigated to less than criteria levels are not considered significant
(cumulatively considerable) and do not add to the overall cumulative impact. The project does not exceed
any of the thresholds of significance and therefore is considered less than significant.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report, and Appendix A of this IS/MND)
c) Expose sensitive receptors to substantial pollutant concentrations? (Less Than Significant Impact)
Please refer to the analysis under issue b. which includes the findings regarding Local Significance
Thresholds (LSTs). LST impacts were determined to be less than significant based on the detailed analysis
in the Appendix A and the model results summarized in Tables III-6 and III-8 above.
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During construction the greatest potential for toxic air contaminant emissions would be related to diesel
particulate emissions associated with heavy equipment operations during construction of the proposed
project. The Office of Environmental Health Hazard Assessment (OEHHA) has issued the Air Toxic Hot
Spots Program Risk Assessment Guidelines and Guidance Manual for the Preparation of Health Risk
Assessments, February 2015 to provide a description of the algorithms, recommended exposure variates,
cancer and noncancer health values, and the air modeling protocols needed to perform a health risk
assessment (HRA) under the Air Toxics Hot Spots Information and Assessment Act of 1987. Hazard
identification includes identifying all substances that are evaluated for cancer risk and/or non-cancer acute,
8-hour, and chronic health impacts. In addition, identifying any multi-pathway substances that present a
cancer risk or chronic non-cancer hazard via non-inhalation routes of exposure.
Given the relatively limited number of heavy-duty construction equipment and construction schedule, the
proposed project would not result in a long-term substantial source of toxic air containment emissions and
corresponding individual cancer risk. Furthermore, construction-based particulate matter (PM) emissions
(including diesel exhaust emissions) do not exceed any local or regional thresholds. Therefore, no
significant short-term toxic air contaminant impacts would occur during construction of the proposed
project.
Carbon Monoxide (CO) is the pollutant of major concern along roadways because the most notable source
of CO is motor vehicles. For this reason, CO concentrations are usually indicative of the local air quality
generated by a roadway network and are used as an indicator of potential local air quality impacts. Local
air quality impacts can be assessed by comparing future without and with project CO levels to the State and
Federal CO standards which were presented in above in Section 5.0.
To determine if the proposed project could cause emission levels in excess of the CO standards discussed
above in Section 5.0, a sensitivity analysis is typically conducted to determine the potential for CO “hot
spots” at a number of intersections in the general project vicinity. Because of reduced speeds and vehicle
queuing, “hot spots” potentially can occur at high traffic volume intersections with a Level of Service E or
worse.
Micro-scale air quality emissions have traditionally been analyzed in environmental documents where the
air basin was a non-attainment area for CO. However, the SCAQMD has demonstrated in the CO attainment
redesignation request to EPA that there are no “hot spots” anywhere in the air basin, even at intersections
with much higher volumes, much worse congestion, and much higher background CO levels than anywhere
in Riverside County. If the worst-case intersections in the air basin have no “hot spot” potential, any local
impacts will be below thresholds.
The traffic impact analysis showed that the project would generate 184 trips per day. The 1992 Federal
Attainment Plan for Carbon Monoxide (1992 CO Plan) showed that an intersection which has a daily traffic
volume of approximately 100,000 vehicles per day would not violate the CO standard. The volume of traffic
at project buildout would be well below 100,000 vehicles and below the necessary volume to even get close
to causing a violation of the CO standard. Therefore, no CO “hot spot” modeling was performed and no
significant long-term air quality impact is anticipated to local air quality with the on-going use of the
proposed project.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report (Appendix A), CARB Air Quality and Land Use
Handbook [CARB 2005])
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d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number
of people? (Less Than Significant Impact)
Potential sources that may emit odors during construction activities include the application of materials
such as asphalt pavement. The objectionable odors that may be produced during the construction process
are of short-term in nature and the odor emissions are expected cease upon the drying or hardening of the
odor producing materials. Diesel exhaust and VOCs would be emitted during construction of the project,
which are objectionable to some; however, emissions would disperse rapidly from the project site and
therefore should not reach an objectionable level at the nearest sensitive receptors. Due to the short-term
nature and limited amounts of odor producing materials being utilized, no significant impact related to
odors would occur during construction of the proposed project.
The SCAQMD recommends that odor impacts be addressed in a qualitative manner. Such an analysis shall
determine whether the project would result in excessive nuisance odors, as defined under the California
Code of Regulations and Section 41700 of the California Health and Safety Code, and thus would constitute
a public nuisance related to air quality. Potential sources that may emit odors during the on-going operations
of the proposed project would include odor emissions from the trash storage areas. Due to the substantial
distance of the nearest sensitive receptors from the project site and through compliance with SCAQMD’s
Rule 402, no significant impact related to odors would occur during the on-going operations of the proposed
project.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report, CARB Air Quality and Land Use Handbook [CARB
2005])
IV. BIOLOGICAL RESOURCES
The data for the following biological resources evaluation is abstracted from a General Biological
Assessment titled “General Biological Assessment and Western Riverside County Multiple Species Habitat
Conservation Plan Consistency Analysis for Assessor’s Parcel Numbers 371-150-001 and 371-150-002,
City of Lake Elsinore-County of Riverside,” published 12/2021 by Hernandez Environmental Services.
This Assessment is used extensively in the following analysis, and it is provided as Appendix B to this
Initial Study.
A Joint Project Review (JPR) was completed by the Western Riverside County Regional Conservation
Authority (RCA) to determine consistency with the MSHCP and identify potential impacts to biological
resources associated with the development of the proposed project (Appendix B – Joint Project Review
[JPR 22-03-11 -01] for the LEAP 2022-02/Rome Hill Commercial, RCA, August 19, 2022).
The U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW)
provided comments on the JPR as they relate to the project’s consistency with MSHCP Section 6.1.4
(Guidelines Pertaining to the Urban/Wildlands Interface) (Appendix B – Review of the Joint Project Review
[JPR 22-03-11 -01] for the LEAP 2022-02/Rome Hill Commercial, provided by U.S. Fish and Wildlife
Service and California Department of Fish and Wildlife, September 14, 2022).
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? (No
Impact)
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Based on the site biological survey conducted by Hernandez Environmental Services, no evidence of any
sensitive species was identified during the site survey. Thus, the finding under this issue is that the
implementation of the proposed project will have no impact on any sensitive species and no mitigation is
required.
Mitigation Measures: No mitigation measures are required.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, regulations or by the California Department of Fish and
Game or U.S. Fish and Wildlife Service? (No Impact)
Based on the site biological survey conducted by Hernandez Environmental Services, no evidence of any
riparian habitat or any other sensitive natural community was identified during the site survey. The
development of the proposed project will impact the entire 6.77-acre project site, including approximately
6.72 acres of disturbed areas and 0.05 acre of tamarisk dominant habitat. Thus, the finding under this issue
is that the implementation of the proposed project will have no impact on any sensitive habitat or natural
community and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or
other means? (No Impact)
Based on the site biological survey conducted by Hernandez Environmental Services, no evidence of any
protected wetlands of any kind were identified during the site survey. The project site does not contain any
State or Federal drainages. Further, the project area does not contain any wetlands or vernal pools. Thus,
the finding under this issue is that the implementation of the proposed project will have no impact on any
wetland habitat and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife
species or with established native resident or migratory wildlife corridors, or impede the use of native
wildlife nursery sites? (Less Than Significant Impact)
Given the results of the biological survey, the proposed project does not appear to support wildlife
movement. The proposed project is bound by surrounding development and roadways and Lake Elsinore.
Most native bird species are protected from unlawful take by the Migratory Bird Treaty Act (MBTA). The
State of California provides protection for native bird species and their nests in the Fish and Game Code
(FGC). When development proceeds, the project site is unlikely to contain nesting birds because all trees
have been removed from the site following a nesting bird clearance survey. Thus, nesting birds are not
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likely to be adversely impacted. Given that no suitable habitat for nesting birds has been identified within
the project site, impacts thereof would be less than significant.
Thus, any effects on wildlife movement or the use of wildlife nursery sites will be less than significant
impact.
Mitigation Measures: None required.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance? (No Impact)
According to the Biological Assessment the project site contains mainly invasive species with the
possibility of a few non-native trees. Thus, based on this current study, the project site does not contain any
trees or other locally protected biological resources. Thus, based on this current study, implementation of
the proposed project will have no impact under this issue. No mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan? (Less Than
Significant With Mitigation Incorporated.)
The Western Riverside County MSHCP is a comprehensive, multi-jurisdictional effort that includes
unincorporated County of Riverside lands and multiple cities in the western portion of the County, including
the City. Rather than address sensitive species on an individual basis, the MSHCP focuses on the
conservation of 146 species, proposing a reserve system of approximately 500,000 acres and a mechanism
to fund and implement the reserve system (County 2003). The MSHCP allows participating entities to issue
take permits for listed species so that individual applicants need not seek their own permits from USFWS
and/or CDFW. The MSHCP was adopted on June 17, 2003 by the County Board of Supervisors. The
Incidental Take Permit was issued by both the USFWS and CDFW on June 22, 2004.
Pursuant to the provisions of the MSHCP, all discretionary development projects within a Criteria Area are
to be reviewed for compliance with the “Property Owner Initiated Habitat Evaluation and Acquisition
Negotiation Strategy” (LEAP) process or equivalent process. The LEAP process “ensures that an early
determination will be made of what properties are needed for the MSHCP Conservation Area, that the
owners of property needed for the MSHCP Conservation Area are compensated, and that owners of land
not needed for the MSHCP Conservation Area shall receive Take Authorization of Covered Species
Adequately Conserved through the Permits issues to the County and Cities pursuant to the MSHCP.” A
formal and complete LEAP application (LEAP 2022-02) was submitted to the City on January 12, 2022
and a JPR (22-03-11 -01) was completed by the RCA on August 19, 2022. Concurrence from CDFW and
USFWS (collectively, the Wildlife Agencies) was received on September 14, 2022.
A portion of the project impact footprint (approximately 4.28 acres) occurs within Criteria Cell 5038, which
is in the MSHCP Elsinore Area Plan, Subunit 3 (Elsinore). The project site is located within the southern
portion of Criteria Cell 5038. Conservation within this Cell is intended to contribute to the assembly of
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Proposed Extension of Existing Core 3. Conservation within this Criteria Cell 5038 focuses on grassland
habitat. Areas conserved within this Cell should be connected to grassland habitat proposed for conservation
in Criteria Cell 5036 to the east. Conservation within this Cell will range from 35 to 45 percent of the Cell
focusing on the eastern central portion of the Cell. The project site consists of disturbed habitat with
scattered ornamental trees and a small patch of tamarisk dominant habitat within the northwestern corner
of the site. The project site does not contain the grassland habitat sought for conservation in Criteria Cell
5036. Further, the site is not located within the eastern central portion of Criteria Cell 5038, which would
provide a connection to Criteria Cell 5036 to the east. Therefore, conservation of the project site would not
contribute to the conservation goals of the Criteria Cell due to the absence of grassland habitat with
connectivity to grassland habitat within Criteria Cell 5036 to the east.
Regarding other MSHCP issues, the following findings were made in the General Biological Assessment:
no riparian/riverine habitat occurs within the project site; no vernal pool habitat occurs within the project
site; and no suitable habitat for the plant species of special concern were found on the project site.
MSHCP Existing Core E (Lake Elsinore) is located to the north of the project site. Therefore,
Urban/Wildlands Interface Guidelines (Section 6.14 of the MSHCP) are required to be applied to the
project. The following mitigation measures shall be incorporated into the project to reduce potentially
significant impacts to the offsite conservation area:
BIO-1 The following measures shall be implemented to reduce potential adverse impacts to adjacent
important biological resources.
Drainage
Water Quality Best Management Practices (BMPs) shall be incorporated, including the National
Pollutant Discharge Elimination Systems (NPDES) and erosion control requirements from the
Regional Water Quality Control Board to ensure that the quantity and quality of surface water
runoff discharged offsite is not altered in an adverse way when compared with existing
conditions. These BMPs will be implemented as part of the Storm Water Pollution Prevention
Plan (SWPPP) in order to ensure that water quality is not degraded.
Toxics
Measures such as those employed to address drainage issues will be implemented for toxics.
Land uses proposed in proximity to Lake Elsinore that use chemicals or generate bioproducts
that are potentially toxic or may adversely affect wildlife species, habitat or water quality must
incorporate measures to ensure that application of such chemicals does not result in discharge
to the lake.
Lighting
Night lighting shall be directed away from Lake Elsinore to protect species from direct night
lighting. Shielding shall be incorporated in Project designs to ensure ambient lighting adjacent
to the lake is not increased.
Noise
Proposed noise generating land uses affecting Lake Elsinore 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 within the
lake should not be subject to noise that would exceed residential noise standards.
Invasives
Invasive, non-native plant species must not be used as landscaping materials for development
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that is proposed adjacent to Lake Elsinore. Table 6-2 of Volume 1 of the MSHCP lists the plants
that should be avoided.
The project site is continually disturbed by the use of motor vehicles on site and the storage of large
materials. No suitable habitat for the plant species listed above is present on site. In addition, the site is not
located within the Western Riverside County MSHCP Additional survey areas for amphibians, survey areas
for mammals, or any special linkage areas; however, the site is located within the Western Riverside County
MSHCP burrowing owl survey area.
A habitat assessment conducted for this species found that the project site is continually disturbed and that
no suitable habitat is present due to the lack of small mammal burrows and manmade structures that could
be utilized as burrows, such as earthen berms; cement, asphalt, rock, or wood debris piles; or openings
beneath cement or asphalt pavement. Therefore, it has been determined that burrowing owl are not currently
present on the project site. However, due to the fact that the project site is located within the Western
Riverside County MSHCP burrowing owl survey area, a 3-day preconstruction survey is required prior to
the commencement of project activities (e.g. vegetation clearing, clearing and grubbing, tree removal, site
watering) to ensure that no owls have colonized the site in the days or weeks preceding project activities.
BIO-2 A habitat assessment has determined that the site does not provide suitable habitat for
burrowing owl.
• However, due to the fact that the project site is located within the Western Riverside County
MSHCP burrowing owl survey area, a 3-day preconstruction survey is required prior to the
commencement of ground disturbing activities (e.g. vegetation clearing, clearing and
grubbing, tree removal, site watering) to ensure that no owls have colonized the site in the
days or weeks preceding project activities.
• If Burrowing Owl are found to have colonized the project site prior to the initiation of
construction, the project proponent will immediately inform RCA and the Wildlife Agencies
and will need to prepare a Burrowing Owl Protection and Relocation Plan for approval by
RCA and the Wildlife Agencies prior to initiating ground disturbance.
• If ground-disturbing activities occur but the site is left undisturbed for more than 30 days, a
pre-construction survey will again be necessary to ensure burrowing owl has not colonized
the site since it was last disturbed. If burrow owl is found, the same coordination described
above will be necessary.
Mitigation Measures: Two mitigation measures, BIO-1 and BIO-2, will be implemented under this issue.
(Source: A general biological resources assessment has been prepared for the Rome Hill Commercial
Project site, refer to Appendix B).
V. CULTURAL RESOURCES
The data for the following cultural resources evaluation is abstracted from an updated Cultural Resources
Assessment titled “Update to Phase 1 Cultural Resources Assessment Rome Hill Commercial Development
Project (APNs 371-150-001 and -002) City of Lake Elsinore, Riverside County, California,” dated May 20,
2022 by CRM TECH. This Assessment is used extensively in the following analysis, and it is provided as
Appendix C to this Initial Study. Regarding Tribal Cultural Resources (TCR) and AB52/SB18 issues, please
refer to the discussion in this Initial Study under Section XVIII.
a) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA
Guidelines §15064.5? (Less Than Significant with Mitigation Incorporated)
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Less Than Significant With Mitigation Incorporated – The historical and archaeological resources report
provided as Appendix C summarizes the findings of a previous cultural resources and an updated field
survey that was completed for this Project. The cultural resources report concluded that there are no surface
cultural resources within the site, and as such no further cultural resources evaluation is required for this
project. However, as stated in Appendix C, contingency mitigation is recommended to allow the possibility
of salvaging subsurface resources accidentally discovered during site disturbance. As such, the following
mitigation measure shall be implemented. Refer to the discussion under Tribal Cultural Resources, Section
XVIII of this Initial Study.
CUL-1: Unanticipated Resources. The developer/permit holder or any successor in interest shall comply
with the following for the life of this permit. If during ground disturbance activities,
unanticipated cultural resources are discovered, the following procedures shall be followed:
1. All ground disturbance activities within 100 feet of the discovered cultural resource shall be
halted until a meeting is convened between the developer, the Project Archaeologist, the
Native American tribal representative(s) from consulting Tribes (or other appropriate
ethnic/cultural group representative), and the Community Development Director or their
designee to discuss the significance of the find. Consulting Tribes(s) refers to Pechanga
Band of Indians and Soboba Band of Luiseño Indians.
2. The developer shall call the Community Development Director or their designee immediately
upon discovery of the cultural resource to convene the meeting.
3. At the meeting with the aforementioned parties, the significance of the discoveries shall be
discussed and a decision is to be made, with the concurrence of the Community Development
Director or their designee, as to the appropriate mitigation (documentation, recovery,
avoidance, etc.) for the cultural resource.
4. Further ground disturbance shall not resume within the area of the discovery until a meeting
has been convened with the aforementioned parties and a decision is made, with the
concurrence of the Community Development Director or their designee, as to the appropriate
mitigation measures.
5. Treatment and avoidance of the newly discovered resources shall be consistent with the
Cultural Resources Treatment and Monitoring Agreements entered into with the appropriate
tribes. This may include avoidance of cultural resources through project design, in-place
preservation of cultural resources located in native soils, and/or re-burial on the Project
property so they are not subject to further disturbance in perpetuity as identified in Non-
Disclosure of Reburial Location measure.
6. If the find is determined to be significant and avoidance of the site has not been achieved, a
Phase III data recovery plan shall be prepared by the Project Archeologist, in consultation
with the Consulting Tribe(s), and shall be submitted to the City for their review and approval
prior to implementation of the said plan.
7. Pursuant to Calif. Pub. Res. Code § 21083.2(b) avoidance is the preferred method of
preservation for archaeological resources and cultural resources. If the Project Applicant
and the Consulting Tribe(s) cannot agree on the significance or the mitigation for the
archaeological or cultural resources, these issues will be presented to the Community
Development Director for decision. The Community Development Director shall make the
determination based on the provisions of the California Environmental Quality Act with
respect to archaeological resources, recommendations of the project archeologist and shall
take into account the cultural and religious principles and practices of the Consulting
Tribe(s). Notwithstanding any other rights available under the law, the decision of the City
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Community Development Director shall be appealable to the City Planning Commission
and/or City Council.” Evidence of compliance with this mitigation measure, if a significant
archaeological resource is found, shall be provided to City of Lake Elsinore upon the
completion of a treatment plan and final report detailing the significance and treatment
finding.
With implementation of measure CUL-1 impacts to any accidentally exposed cultural resources can be
reduced to a less than significant impact.
Mitigation Measure: see CUL-1 above.
(Sources: The preceding information was abstracted from the findings in Appendix C.)
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to
CEQA Guidelines §15064.5? (Less Than Significant With Mitigation Incorporated)
The findings above regarding historical resources also applies to archaeological resources. With
implementation of measure CUL-1 through CUL-5 potential impacts to all cultural resources will be
reduced to a less than significant impact.
CUL-2: Archaeologist/CRMP. Prior to issuance of grading permits, the applicant/developer shall
provide evidence to the Community Development Department that a Secretary of Interior
Standards qualified and certified Registered Professional Archaeologist (RPA) has been
contracted to implement a Cultural Resource Monitoring Program (CRMP) that addresses the
details of all activities that must be completed and procedures that must be followed regarding
cultural resources associated with this project. The CRMP document shall be provided to the
Community Development Director or their designee for review and approval prior to issuance
of the grading permit. The CRMP provides procedures to be followed and are to ensure that
impacts on cultural resources will not occur without procedures that would reduce the impacts
to less than significant. These measures shall include, but shall not be limited to, the following:
Archaeological Monitor - An adequate number of qualified monitors shall be present to ensure
that all earth-moving activities are observed and shall be on-site during all grading activities
for areas to be monitored including off-site improvements. Inspections will vary based on the
rate of excavation, the materials excavated, and the presence and abundance of artifacts and
features. The frequency and location of inspections will be determined by the Project
Archaeologist, in consultation with the Tribal monitor.
Cultural Sensitivity Training - The Project Archaeologist and a representative designated by
the consulting Tribe(s) shall attend the pre-grading meeting with the contractors to provide
Cultural Sensitivity Training for all Construction Personnel. Training will include a brief
review of the cultural sensitivity of the Project and the surrounding area; what resources could
potentially be identified during earthmoving activities; the requirements of the monitoring
program; the protocols that apply in the event unanticipated cultural resources are identified,
including who to contact and appropriate avoidance measures until the find(s) can be properly
evaluated; and any other appropriate protocols. This is a mandatory training and all
construction personnel must attend prior to beginning work on the project site. A sign-in sheet
for attendees of this training shall be included in the Phase IV Monitoring Report.
Unanticipated Resources - In the event that previously unidentified potentially significant
cultural resources are discovered, the Archaeological and/or Tribal Monitor(s) shall have the
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authority to divert or temporarily halt ground disturbance operations in the area of discovery
to allow evaluation of potentially significant cultural resources. The Project Archaeologist, in
consultation with the Tribal monitor(s) shall determine the significance of the discovered
resources. The Community Development Director or their designee must concur with the
evaluation before construction activities will be allowed to resume in the affected area. Before
construction activities are allowed to resume in the affected area, the artifacts shall be
recovered and features recorded using professional archaeological methods
Phase IV Report - A final archaeological report shall be prepared by the Project archaeologist
and submitted to the Community Development Director or their designee prior to grading final.
The report shall follow County of Riverside requirements and shall include at a minimum: a
discussion of the monitoring methods and techniques used; the results of the monitoring
program including any artifacts recovered; an inventory of any resources recovered; updated
DPR forms for all sites affected by the development; final disposition of the resources
including GPS data; artifact catalog and any additional recommendations. A final copy shall
be submitted to the City, Project Applicant, the Eastern Information Center (EIC), and the
Tribe.
CUL-3: Cultural Resources Disposition. In the event that Native American cultural resources are
discovered during the course of grading (inadvertent discoveries), the following procedures
shall be carried out for final disposition of the discoveries:
One or more of the following treatments, in order of preference, shall be employed with the
tribes. Evidence of such shall be provided to the Community Development Department:
1. Preservation-In-Place of the cultural resources, if feasible. Preservation in place means
avoiding the resources, leaving them in the place where they were found with no
development affecting the integrity of the resources.
2. Relocation of the resources on the Project property. The measures for relocation shall
include, at least, the following: Measures and provisions to protect the future reburial area
from any future impacts by means of a deed restriction or other form of protection (e.g.,
conservation easement) in order to demonstrate avoidance in perpetuity.
3. Relocation shall not occur until all legally required cataloging and basic recordation have
been completed, with an exception that sacred items, burial goods and Native American
human remains are excluded. Any reburial process shall be culturally appropriate. Listing
of contents and location of the reburial shall be included in the confidential Phase IV
report. The Phase IV Report shall be filed with the City under a confidential cover and not
subject to Public Records Request.
4. If preservation in place or reburial is not feasible then the resources shall be curated in the
culturally sensitive matter at a Riverside County curation facility that meets State Resources
Department of Office of Historic Preservation Guidelines for the Curation of
Archaeological Resources ensuring access and use pursuant to the Guidelines. The
collection and associated records shall be transferred, including title, and are to be
accompanied by payment of the fees necessary for permanent curation. Evidence of
curation in the form of a letter from the curation facility stating that subject archaeological
materials have been received and that all fees have been paid, shall be provided by the
landowner to the City. There shall be no destructive or invasive testing on sacred items,
burial goods and Native American human remains. Results concerning finds of any
inadvertent discoveries shall be included in the Phase IV monitoring report. Evidence of
compliance with this mitigation measure, if a significant archaeological resource is found,
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shall be provided to the City of Lake Elsinore upon completion of a treatment plan and final
report detailing the significance and treatment of finding.
CUL-4: Tribal Monitoring. Prior to the issuance of a grading permit, at least 30 days prior to the
issuance, the applicant shall contact the consulting Native American Tribe(s) that have
requested monitoring through consultation with the City during the AB 52 and/or the SB 18
process (“Monitoring Tribes”). The applicant shall coordinate with the Tribe(s) (Pechanga
Band of Indians and Soboba Band of Luiseño Indians) to develop individual Tribal Monitoring
Agreement(s). A copy of the signed agreement(s) shall be provided to the City of Lake Elsinore
Community Development Department, Planning Division prior to the issuance of a grading
permit. The Agreement shall address the treatment of any known tribal cultural resources
(TCRs) including the project’s approved mitigation measures and conditions of approval; the
designation, responsibilities, and participation of professional Tribal Monitors during grading,
excavation and ground disturbing activities; project grading and development scheduling;
terms of compensation for the monitors; and treatment and final disposition of any cultural
resources, sacred sites, and human remains/burial goods discovered on the site per the Tribe(s)
(Pechanga Band of Indians and Soboba Band of Luiseño Indians) customs and traditions and
the City’s mitigation measures/conditions of approval. The Tribal Monitor will have the
authority to stop and redirect grading in the immediate area of a find in order to evaluate the
find and determine the appropriate next steps, in consultation with the Project archaeologist.
CUL-5: Phase IV Report. Upon completion of the implementation phase, a Phase IV Cultural Resources
Monitoring Report shall be submitted that complies with the Riverside County Planning
Department's requirements for such reports for all ground disturbing activities associated with
this grading permit. The report shall follow the County of Riverside Planning Department
Cultural Resources (Archaeological) Investigations Standard Scopes of Work posted on the
County website. The report shall include results of any feature relocation as well as evidence of
the required cultural sensitivity training for the construction staff held during the required pre-
grade meeting. Once the report is determined to be adequate, two (2) copies shall be submitted
to Eastern Information Center (EIC) at the University of California Riverside (UCR) and one
(1) copy shall be submitted to the Monitoring Tribes.
Mitigation Measures: see CUL-1 through CUL-5 above.
(Sources: The preceding information was abstracted from the findings in Appendix C.)
c) Disturb any human remains, including those interred outside of formal cemeteries? (Less Than
Significant with Mitigation Incorporated )
As noted in the discussion above, no available information suggests that human remains may occur within
the project Area of Potential Effect (APE) and the potential for such an occurrence is considered very low.
In the unlikely event that unknown human remains are uncovered during project construction, CUL-6 and
CUL-7, pursuant to California Health and Safety Code Section 7050.5 and Public Resources Code Section
5097.98, would ensure that the project’s impacts would be less than significant.
CUL-6: Discovery of Human Remains. In the event that human remains (or remains that may be
human) are discovered at the project site during grading or earthmoving, the construction
contractors, project archaeologist and/or designated Native American Monitor shall
immediately stop all activities within 100 feet of the find. The project applicant shall then
inform the Riverside County Coroner and the City of Lake Elsinore Community Development
Department immediately, and the coroner shall be permitted to examine the remains as
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required by California Health and Safety Code Section 7050.5(b). Section 7050.5 requires that
excavation be stopped in the vicinity of discovered human remains and that no further
disturbance shall occur until the Riverside County Coroner has made the necessary findings
as to origin. If human remains are determined to be Native American, the applicant shall
comply with the state law relating to the disposition of Native American burials that fall within
the jurisdiction of the NAHC (PRC Section 5097). The coroner shall contact the NAHC within
24 hours and the NAHC will make the determination of most likely descendant. The most likely
descendant shall then make recommendations and engage in consultation concerning the
treatment of the remains as provided in Public Resource Code Section 5097.98.
According to the California Health and Safety Code, six or more human burial at one location
constitutes a cemetery (Section 81 00), and disturbance of Native American cemeteries is a
felony (Section 7052).
CUL-7: Non-Disclosure of Reburial Location. It is understood by all parties that unless otherwise
required by law, the site of any reburial of Native American Tribal Cultural Resources (TCR)
shall not be disclosed and shall not be governed by public disclosure requirements of the
California Public Records Act.
Mitigation Measure: see CUL-6 and CUL-7 above.
(Sources: The preceding information was abstracted from the findings in Appendix C and current California
statutes)
VI. ENERGY
The data for the following Energy evaluation is abstracted from a report titled “Rome Hill Commercial
Project Air Quality, Greenhouse Gas, and Energy Impact Study, County of Riverside,” dated 1/28/2025 by
MD Acoustics. This Study is used extensively in the following analysis, and it is provided as Appendix A
to this Initial Study.
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation? (Less Than Significant
Impact)
Construction Energy Demand
Electrical service will be provided by Southern California Edison (SCE). Based on the 2017 National
Construction Estimator, Richard Pray (2017), the typical power cost per 1,000 square feet of building
construction per month is estimated to be $2.32. The project plans to develop the site with 121,490 square
feet of new warehouse space over the course of approximately 14 months. Based on Table VI-1, the total
power cost of the on-site electricity usage during the construction of the proposed project is estimated to be
approximately $3,946. As shown in Table VI-1, the total electricity usage from Project construction related
activities is estimated to be approximately 71,745 kWh.
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Table VI-1
PROJECT CONSTRUCTION POWER COST AND ELECTRICITY USAGE
Power Cost (per 1,000 square foot of
building per month of construction)
Total Building
Size (1,000 Square
Foot)1
Construction
Duration
(months)
Total Project
Construction
Power Cost
$2.32 121.49 14 $3,946.00
Cost per kWh
Total Project Construction Electricity
Usage (kWh)
$0.06 71,745
* Assumes the project will be under the GS-1 General Service rate under SCE.
Using the CalEEMod data input, the project’s construction phase would consume electricity and fossil fuels
as a single energy demand, that is, once construction is completed their use would cease. CARB’s 2017
Emissions Factors Tables show that on average aggregate fuel consumption (gasoline and diesel fuel) would
be approximately 18.5 hp-hr-gal. As presented in Table VI-2 below, project construction activities would
consume an estimated 32,015 gallons of diesel fuel.
Table VI-2
CONSTRUCTION EQUIPMENT FUEL CONSUMPTION
Phase
Number of
Days
Offroad Equipment Type
Amount
Usage
Hours
Horse
Power
Load
Factor
HP
hrs/ day
Total Fuel
Consumption (gal
diesel fuel)1
Site Preparation 10 Rubber Tired Dozers 3 8 367 0.4 3523 1904
10 Tractors/Loaders/Backhoes 4 8 84 0.37 995 538
Grading
30 Excavators 1 8 36 0.38 109 118
30 Graders 1 8 148 0.41 485 525
30 Rubber Tired Dozers 1 8 367 0.4 1,174 1,270
30 Tractors/Loaders/Backhoes 3 8 84 0.37 746 806
Building
Construction
300 Cranes 1 7 367 0.29 745 9,262
300 Forklifts 3 8 82 0.2 394 4,893
300 Generator Sets 1 8 14 0.74 83 1,030
300 Tractors/Loaders/Backhoes 3 7 84 0.37 653 8,114
300 Welders 1 8 46 0.45 166 2,059
Paving
20 Pavers 2 8 81 0.42 544 588
20 Paving Equipment 2 8 89 0.36 513 554
20 Rollers 2 8 36 0.38 219 237
Architectural
Coating 20 Air Compressors 1 6 37 0.48 107 115
CONSTRUCTION FUEL DEMAND (gallons of diesel fuel) 32,015
Notes:1 Using Carl Moyer Guidelines Table D-21 Fuel consumption rate factors (bhp-hr/gal) for engines less than 750 hp. (Source:
https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf)
It is assumed that all construction worker trips are from light duty autos (LDA) along area roadways. With
respect to estimated VMT, the construction worker trips would generate an estimated 235,117 VMT. Vehicle
fuel efficiencies for construction workers were estimated in the air quality and greenhouse gas analysis
using information generated using CARB’s EMFAC model (see Appendix B for details). Table VI-3 shows
that an estimated 7,600 gallons of fuel would be consumed for construction worker trips.
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Table VI-3
CONSTRUCTION WORKER FUEL CONSUMPTION ESTIMATES
Phase Number of Days Worker Trips/Day Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 17.5 18.5 3237.5 30.94 105
Grading 20 15 18.5 5,550 30.94 179
Building Construction 230 51 18.5 217,005 30.94 7,015
Paving 20 15 18.5 5,550 30.94 179
Architectural Coating 20 10.2 18.5 3,774 30.94 122
Total Construction Worker Fuel Consumption 7,600
Notes:
1Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.29 defaults.
Tables V-4 and V-5 show the estimated fuel consumption for vendor and hauling during building
construction and architectural coating. With respect to estimated VMT, the vendor and hauling trips would
generate an estimated 71,685 VMT. For the architectural coatings it is assumed that the contractors would
be responsible for bringing coatings and equipment with them in their light duty vehicles. Tables V-4 and
V-5 show that an estimated 9,558 gallons of fuel would be consumed for vendor and hauling trips.
Table VI-4
CONSTRUCTION VENDOR FUEL CONSUMPTION ESTIMATES (MHD TRUCKS)1
Phase Number of
Days
Vendor
Trips/Day
Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 0 10.2 0 8.57 0
Grading 20 0 10.2 0 8.57 0
Building Construction 230 19.9 10.2 46,685 8.57 5,448
Paving 20 5 10.2 1,020 8.57 119
Architectural Coating 20 0 10.2 0 8.57 0
Total Vendor Fuel Consumption 5,567
Notes:
1Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.29 defaults.
Table VI-5
CONSTRUCTION HAULING FUEL CONSUMPTION ESTIMATES (HHD TRUCKS)1
Phase Number of
Days
Hauling
Trips/Day
Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 0 20 0 6.26 0
Grading 20 62.5 20 25,000 6.26 3,991
Building Construction 230 0 20 0 6.26 0
Paving 20 0 20 0 6.26 0
Architectural Coating 20 0 20 0 6.26 0
Total Construction Hauling Fuel Consumption 3,991
Notes:
1Assumptions for the hauling trip length and vehicle miles traveled are consistent with CalEEMod 2020.40 defaults.
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Construction equipment used over the approximately 14-month construction phase would conform to
CARB regulations and California emissions standards and is evidence of related fuel efficiencies. In
addition, the CARB Airborne Toxic Control Measure limits idling times of construction vehicles to no more
than five minutes, thereby minimizing unnecessary and wasteful consumption of fuel due to unproductive
idling of construction equipment. Furthermore, the project has been designed in compliance with
California’s Energy Efficiency Standards and 2022 CALGreen Standards.
Construction of the proposed commercial manufacturing development would require the typical use of
energy resources. There are no unusual project characteristics or construction processes that would require
the use of equipment that would be more energy intensive than is used for comparable activities; or
equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment
employed in construction of the project would therefore not result in inefficient wasteful, or unnecessary
consumption of fuel.
Operational Energy Demand
Energy consumption in support of or related to project operations would include transportation energy
demands (energy consumed by employee and patron vehicles accessing the project site) and facilities
energy demands (energy consumed by building operations and site maintenance activities).
The largest source of operational energy use would be vehicle operation of customers. The site is located
in an urbanized area just in close proximity to transit stops. Using the CalEEMod output, an average trip
length for all vehicles was assumed to be 21.774 miles. To show a worst-case analysis, as the proposed
project is an office project, it was assumed that vehicles would operate 365 days per year. Table 19 shows
the worst-case estimated annual fuel consumption for all classes of vehicles from autos to heavy-heavy
trucks. Table VI-6 shows that an estimated 106,511 gallons of fuel would be consumed per year for the
operation of the proposed project.
Table VI-6
ESTIMATED VEHICLE OPERATIONS FUEL CONSUMPTION
Vehicle Type Vehicle Mix Number
of Vehicles
Average
Trip
(miles)1
Daily
VMT
Average
Fuel
Economy
(mpg)
Total
Gallons
per Day
Total Annual
Fuel
Consumption
(gallons)
Light Auto Automobile 75.5 21.774 1,644 30.94 53.15 19,401
Light Truck Automobile 13.2 21.774 287 25.55 11.24 4,104
Light Truck Automobile 39.7 21.774 864 25.60 33.75 12,318
Medium Truck Automobile 27.7 21.774 602 20.47 29.42 10,739
Light Heavy Truck 2-Axle Truck 5.1 21.774 111 16.63 6.69 2,442
Light Heavy Truck 10,000 lbs + 2-Axle Truck 1.4 21.774 30 15.79 1.90 695
Medium Heavy Truck 3-Axle Truck 2.6 21.774 56 8.57 6.52 2,379
Heavy Heavy Truck 4-Axle Truck 42.9 21.774 934 6.26 149.13 54,433
Total 208 -- 4,529 -- 291.81 --
Total Annual Fuel Consumption 106,511
Notes:
1 The trip generation assessment, the project is to generate 208 total net new trips after reduction of existing uses. Default CalEEMod vehicle fleet
mix utilized.
1Based on the size of the site and relative location, trips were assumed to be local rather than regional.
Trip generation generated by the proposed project are consistent with other similar industrial uses of similar
scale and configuration as reflected in the Trip Generation Assessment (TJW Engineering, 2025). That is,
the proposed project does not propose uses or operations that would inherently result in excessive and
wasteful vehicle trips, nor associated excess and wasteful vehicle energy consumption. Therefore, project
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transportation energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary.
The annual natural gas and electricity demands were provided per the CalEEMod output and are provided
in Table VI-7.
Table VI-7
PROJECT UNMITIGATED ANNUAL OPERATIONAL ENERGY DEMAND SUMMARY
Natural Gas Demand kBTU/year
Unrefrigerated Warehouse 2,319,509
Total 2,319,509
Electricity Demand kWh/year
Unrefrigerated Warehouse 559,140
Parking Lot 152,253
Total 711,393
Notes:
1Taken from the CalEEMod 2022.1.1.29 annual output.
As shown in Table VI-7, the estimated electricity demand for the proposed project is approximately 711,393
kWh per year. In 2022, the non-residential sector of the County of Riverside consumed approximately 8,720
million kWh of electricity. In addition, the estimated natural gas consumption for the proposed project is
approximately 2,319,509 kBTU per year. In 2022, the non-residential sector of the County of Riverside
consumed approximately 146.9 million therms of gas, or 14.69 billion kBTU. Therefore, the increase in
both electricity and natural gas demand from the proposed project is insignificant compared to the County’s
2022 demand.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report Appendix A and Title 24 and Green Building Standards)
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? (Less
Than Significant Impact)
Regarding federal transportation regulations, the project site is located in an already developed area. Access
to/from the project site is from existing roads. These roads are already in place so the project would not
interfere with, nor otherwise obstruct intermodal transportation plans or projects that may be proposed
pursuant to the ISTEA because SCAG is not planning for intermodal facilities in the project area.
Regarding the State’s Energy Plan and compliance with Title 24 CCR energy efficiency standards, the
applicant is required to comply with the California Green Building Standard Code requirements for energy
efficient buildings and appliances as well as utility energy efficiency programs implemented by the SCE
and Southern California Gas Company.
Regarding the State’s Renewable Energy Portfolio Standards, the project would be required to meet or
exceed the energy standards established in the California Green Building Standards Code, Title 24, Part 11
(CALGreen). CalGreen Standards require that new buildings reduce water consumption, employ building
commissioning to increase building system efficiencies, divert construction waste from landfills, and install
low pollutant-emitting finish materials. As shown above, the project would not conflict with any of the
state or local energy plans. Therefore, the proposed project would have a less than significant potential to
conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Mitigation Measures: No mitigation measures are required.
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(Sources: Referenced energy programs, Air Quality and GHG Analysis Report Appendix A and Title
24/Green Building Standards)
VII. GEOLOGY AND SOILS
The data for the following geology and soils evaluation is abstracted from an updated report titled
“Geotechnical Update Builder’s Max APNs 371-150-001 and -002) Grand Avenue at Kathryn Way Lake
Elsinore, California,” dated February 22, 2022 by Geocon West, Inc., 2/22/22 This document is used
extensively in the following analysis, and it is provided as Appendix E to this Initial Study.
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 Alquist-Priolo
Earthquake Fault Zoning Map, issued by the State Geologist for the area or based on
other substantial evidence of a known fault? Refer to Division of Mines and Geology
Special Publication 42. (Less Than Significant Impact)
The Willard strand of the Elsinore fault zone is mapped in the eastern portion of the site. The entire site is
within a Riverside County Fault Hazard Zone. Mitigation has been incorporated to address this active fault
trace across the property by including a setback as shown on Figure VI-1. The setback shown on Figure VI-
1 provides 50 feet on each side of the fault zone to minimize potential for ground rupture impacts to the
future project. Thus, implementation of the proposed project will be possible without causing a significant
adverse impact due to onsite fault rupture. Based on the current Geotechnical Report, this finding remains
valid for the proposed project. No additional mitigation is required.
Mitigation Measures: None required
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
ii. Strong seismic ground shaking? (Less Than Significant With Mitigation Incorporated.)
Several fault traces run through the City, and as with much of Southern California, the proposed structures
are likely to be subject to strong seismic ground shaking impacts should any major earthquakes occur in
the future, particularly because the site is in close proximity to the Willard strand of the Elsinore Fault Zone,
which, at this location is classified as an Alquist-Priolo Earthquake Zone. Additionally, several Active Fault
Zones as defined by Riverside County travel throughout the City as shown in Figure 3.11-2 of the City’s
General Plan Map of the City’s Earthquake Fault Zones. As a result, and like all other development projects
in the City and throughout much of the Southern California Region, the proposed Project will be required
to comply with all applicable seismic design standards contained in the current California Building Code
(CBC), including Section 1613 Earthquake Loads, and in the Geotechnical Investigation (Appendix E).
Compliance with the CBC and project specific Geotechnical study will ensure that structural integrity of
the occupied buildings will be maintained in the event of earthquake related seismic ground shaking. The
seismic design parameters outlined in the Geotechnical Report shall be enforced through the
implementation of mitigation measure GEO-1 below.
Mitigation Measure:
GEO-1 The Project shall comply with the recommendations to address geology and soils impacts within
the Geotechnical Update prepared by GEOCON WEST, INC. Appendix e), including, but not
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limited to: seismic ground shaking, subsidence, liquefaction, expansive soils, and corrosive soils,
for all structures on site.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
iii. Seismic-related ground failure, including liquefaction? (Less Than Significant With
Mitigation Incorporated)
The GPEIR Figure 3.11-3 indicates that liquefaction potential at the site is Very High. This is substantiated
in the Geotechnical Report which indicates measures in GEO-1 shall be implemented to minimize potential
for seismic-related ground failure. With implementation of measure GEO-1 the impacts under this issue
are considered less than significant.
Mitigation Measures: GEO-1.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
iv. Landslides? (Less Than Significant Impact)
The project site is located on a shallow sloped alluvial fan that has no identified landslides. According to
the site geotechnical report, the nearest geology formation with a potential for landsliding is about one mile
distant. Thus, based on the data in Appendix E, the potential for landslide hazard is less than significant.
Mitigation Measures: No mitigation measures are required.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
b) Result in substantial soil erosion or the loss of topsoil? (Less Than Significant With Mitigation
Incorporated)
The potential for soil erosion, loss of topsoil, and/or placing structures on unstable soils is anticipated to be
marginally possible at the site during ground disturbance associated with construction. The project site is
vacant with some limited non-native vegetation coverage. City grading standards, best management
practices and the Storm Water Pollution Prevention Plan (SWPPP) and Water Quality Management Plan
(WQMP) are required to control the potential onsite significant erosion hazards. The topography of the site
generally slopes from the highest point to the south towards Grand Avenue. The elevation change is minimal
on the property. The onsite soils have a moderate infiltration capability that will minimize surface runoff
and natural erosion onsite.
However, during project construction when soils are exposed, temporary soil erosion could occur, which
could be exacerbated by rainfall. Project clearing and grading would be managed through the preparation
and implementation of a SWPPP, and will be required to implement best management practices to achieve
concurrent water quality controls after construction is completed and the Rome Hill commercial buildings
are occupied. The following mitigation measures or equivalent best management practices (BMPs) shall be
implemented to address these issues:
GEO-2 Stored backfill material shall be covered with water resistant material during periods of heavy
precipitation to reduce the potential for rainfall erosion of stored backfill material. If covering
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is not feasible, then measures such as the use of straw bales or sandbags shall be used to capture
and hold eroded material on the Project site for future cleanup.
GEO-3 All exposed, disturbed soil (trenches, stored backfill, etc.) shall be sprayed with water or soil
binders twice a day, or more frequently if fugitive dust is observed migrating from the site within
which the Rome Hill project site being constructed.
With implementation of the above mitigation measures, implementation of the SWPPP, WQMP, and
associated BMPs, any impacts under this issue are considered less than significant.
Mitigation Measures: Mitigation measures GEO-2 and GEO-3 are required.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of
the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or
collapse? (Less Than Significant With Mitigation Incorporated)
The project site was determined by the Geotechnical Study to be a stable alluvial deposit with some
unverified fill locations on the surface. The site will be prepared (graded and compacted) in accordance
with the guidelines in mitigation measure GEO-1 to ensure a stable building foundation that will minimize
lateral spreading, subsidence or collapse. With implementation of GEO-1, potential impacts to the site soils
and alluvial deposit can be controlled to a less than significant impact level.
Mitigation Measures: GEO-1
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property? (No Impact)
The onsite soils have been identified in Appendix E as having non-expansive soils or fill materials. Thus,
the proposed project will not be located on an expansive soil type. No adverse impact will occur under this
issue.
Mitigation Measures: No mitigation measures are required.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater
disposal systems where sewers are not available for the disposal of wastewater? (No Impact)
The Project does not propose any septic tanks or alternative wastewater disposal systems as it will connect
to the regional wastewater collection system on Grand Avenue. Therefore, determining if the project site
soils are capable of adequately supporting the use of septic tanks or alternative wastewater disposal systems
where sewers are not available for the disposal of wastewater does not apply. No adverse impacts are
anticipated.
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Mitigation Measures: No mitigation measures are required.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
(Less Than Significant With Mitigation Incorporated)
The potential for discovering paleontological resources during development of the Project is considered
high based on the data compiled in the Appendix E. Also, because paleontological resources are often
located beneath the ground surface and can only be discovered as a result of ground disturbance activities
associated with clearing and grading, the following mitigation measure shall be implemented:
GEO-4
• All Earth-moving operations in the project area should be monitored for potential
paleontological remains by a qualified paleontological monitor. The monitor should be
prepared to quickly salvage fossils, if they are unearthed, to avoid construction delays, but
must have the power to temporarily halt or divert construction equipment to allow for
removal of abundant or large specimens.
• Collected samples of sediment should be processed to recover small fossils, and all recovered
specimens should be identified and curated at a repository with permanent retrievable
storage.
• A report of findings, including an itemized inventory of recovered specimens, should be
prepared upon completion of the procedures outlined above. The report should include a
discussion of the significance of the paleontological findings, if any. The report and the
inventory, when approved by the City of Lake Elsinore, would signify completion of the
program to mitigate potential impacts on paleontological resources. Under these conditions,
the proposed project may be cleared to proceed in compliance with CEQA provisions on
paleontological resources.
With incorporation of this mitigation measure, the potential for impact to paleontological resources will be
reduced to a less than significant level. No additional mitigation is required.
Mitigation Measures: Mitigation measure GEO-4 is required.
(Source: A geology and soils report has been prepared for the Rome Hill Commercial Project site, refer to
Appendix E)
VIII. GREENHOUSE GAS EMISSIONS
The data for the following Greenhouse Gas Emissions evaluation is abstracted from a report titled “Rome
Hill Commercial Project Air Quality, Greenhouse Gas, and Energy Impact Study, County of Riverside,”
dated 1/28/2025 by MD Acoustics. This Study is used extensively in the following analysis, and it is
provided as Appendix A to this Initial Study. Section 2.2 0f the Greenhouse Gas (GHG) Study provides the
background information regarding the international, national, state and local GHG Regulatory Setting. The
City’s program is summarized below.
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact
on the environment? (Less Than Significant Impact)
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City of Lake Elsinore Climate Action Plan
In compliance with State Assembly Bill AB32 and Executive Order S-3-05, the City of Lake Elsinore
adopted a Climate Action Plan (CAP) on December 13, 2011. The City’s CAP is a long range plan designed
to reduce community-wide greenhouse gas (GHG) emissions from activities within the City limits.
Specifically, the CAP is designed to:
• Benchmark Lake Elsinore’s existing (2008) GHG emissions and projected emissions relative to state-
wide emissions targets;
• Establish GHG emissions reduction strategies and measures to reduce the City’s proportionate share of
emissions to meet the state-wide targets identified in Assembly Bill 32 (AB32), and Executive Order
S-3-05;
• Set forth procedures to monitor and verify the effectiveness of the CAP and require amendment if the
CAP is not achieving targeted levels of emissions;
• Mitigate Lake Elsinore’s GHG emissions impacts (by reducing GHG emissions consistent with the
State of California via the California Environmental Quality Act (CEQA) Guidelines, AB32, and
Executive Order S-3-05). The CEQA Guidelines encourage the adoption of plans or mitigation
programs as a means of comprehensively addressing the cumulative impacts of projects (see CEQA
Guidelines, Sections 15064(h)(3) and 15130(c); and,
• Serve as the programmatic tiering document for the purposes of CEQA within the City of Lake Elsinore
for GHG emissions, and what applicable projects will be reviewed. If a proposed development project
can demonstrate it is consistent with the applicable emissions reduction measures included in the CAP,
the programs and standards that would be implemented as a result of the CAP, and the General Plan
Update growth projections, the project’s environmental review pertaining to GHG impacts may be
streamlined as allowed by CEQA Guidelines Sections 15152 and 15183.5.
The CAP is not intended to limit future development or economic growth within Lake Elsinore; rather, by
adopting a CAP, the City has established the compliance and performance standards that a project is to
meet in order to satisfy State mandates. Discussions of the Project’s consistency with the CAP’s
Greenhouse Gas Reduction Measures are discussed in Section 7.3.
The City of Lake Elsinore’s CAP has a GHG emissions target that is specifically intended for use in
evaluating the significance of GHG emissions from community-wide emissions. The City selected
efficiency-based targets for the years governed by the General Plan to reduce community-wide emissions
to 6.6 MT CO2e per service population per year by 2020 (a 22.3% reduction from the 2008 rate of 8.5 MT
CO2e/SP) and to 4.4 MT CO2e per service population per year by 2030 (a 48.2% reduction from the 2008
rate of 8.5 MT CO2e/SP). These efficiency-based targets represent the AB 32 and Executive Order S-3-05
targeted emissions levels for 2020 and 2030 on a per service population basis and they were derived by
dividing the state-wide AB 32 targeted emissions level for 2020 and statewide Executive Order S-3-05
targeted emissions level for 2030 by the 2020 and 2030 state-wide service population respectively.
Therefore, these targets represent the maximum quantity of emissions each resident and employee in the
State of California could emit in 2020 and 2030 based on emissions levels necessary to achieve the state-
wide AB 32 and Executive Order S-3- 05 GHG emissions reduction goals.
In order to meet the state-wide efficiency metric targets, the CAP must demonstrate that it can reduce
community-wide emissions to 6.6 MT CO2e/SP (or 944,737 MT CO2e total based on an estimated 2020
service population of 143,142) by 2020 and 4.4 MT CO2e/SP (or 1,334,243 MT CO2e based on an
estimated 2030 service population of 303,237) by 2030.
Therefore, to determine whether the project's GHG emissions are significant, this analysis uses the County
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of Riverside CAP Update and SCAQMD draft local agency tier 3 screening threshold of 3,000 MTCO2e.
The project will be subject to the latest requirements of the California Green Building and Title 24 Energy
Efficiency Standards (currently 2022) which would reduce project-related greenhouse gas emissions.
Constituent gases of the Earth’s atmosphere, called atmospheric greenhouse gases (GHG), play a critical
role in the Earth’s radiation amount by trapping infrared radiation emitted from the Earth’s surface, which
otherwise would have escaped to space. Prominent greenhouse gases contributing to this process include
carbon dioxide (CO2), methane (CH4), ozone, water vapor, nitrous oxide (N2O), and chlorofluorocarbons
(CFCs). This phenomenon, known as the Greenhouse Effect, is responsible for maintaining a habitable
climate. Anthropogenic (caused or produced by humans) emissions of these greenhouse gases in excess of
natural ambient concentrations are responsible for the enhancement of the Greenhouse Effect and have led
to a trend of unnatural warming of the Earth’s natural climate, known as global warming or climate change.
Emissions of gases that induce global warming are attributable to human activities associated with
industrial/manufacturing, agriculture, utilities, transportation, and residential land uses. Transportation is
responsible for 41 percent of the State’s greenhouse gas emissions, followed by electricity generation.
Emissions of CO2 and nitrous oxide (NO2) are byproducts of fossil fuel combustion. Methane, a potent
greenhouse gas, results from off-gassing associated with agricultural practices and landfills. Sinks of CO2,
where CO2 is stored outside of the atmosphere, include uptake by vegetation and dissolution into the ocean.
Refer to Table 6 of Appendix A which provides a description of each of the greenhouse gases and their
global warming potential.
CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial,
adverse change in the environment.” To determine if a project would have a significant impact on
greenhouse gases, the type, level, and impact of emissions generated by the project must be evaluated.
The following greenhouse gas significance thresholds are contained in Appendix G of the CEQA
Guidelines, which were amendments adopted into the Guidelines on March 18, 2010, pursuant to SB 97. A
significant impact would occur if the project would:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment; or
b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of
reducing the emissions of greenhouse gases.
However, despite this, currently neither the CEQA statutes, OPR guidelines, nor the draft proposed changes
to the CEQA Guidelines prescribe thresholds of significance or a particular methodology for performing
an impact analysis; as with most environmental topics, significance criteria are left to the judgment and
discretion of the Lead Agency. As previously discussed, SCAQMD has drafted interim thresholds. The
screening threshold of 3,000 MTCO2e per year for all land uses was used in this analysis.
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact
on the environment? (Less Than Significant Impact)
The greenhouse gas emissions from project construction equipment and worker vehicles are shown in Table
VIII-1. The emissions are from all phases of construction. The total construction emissions amortized over
a period of 30 years are estimated at 16.75 metric tons of CO2e per year. Annual CalEEMod output
calculations are provided in Appendix A.
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Table VIII-1
CONSTRUCTION GREENHOUSE GAS EMISSIONS
Activity Emissions (MTCO2e)1
Onsite Offsite Total
Site Preparation 24.10 1.06 25.16
Grading 26.90 42.81 69.71
Building Construction 252.00 136.30 388.30
Paving 13.80 3.20 17.00
Coating 1.22 1.20 2.42
Total 318.02 184.57 502.59
Averaged over 30 years2 10.60 6.15 16.75
Notes:
1. MTCO2e=metric tons of carbon dioxide equivalents (includes carbon dioxide, methane and nitrous oxide).
2. The emissions are averaged over 30 years because the average is added to the operational emissions, pursuant to SCAQMD.
* CalEEMod output (Appendix A)
Operational emissions occur over the life of the project. The operational emissions for the project are
1,441.32 metric tons of CO2e per year as shown in Table VIII-2. These emissions do not exceed the County
of Riverside CAP Update and SCAQMD screening threshold of 3,000 metric tons of CO2e per year.
Therefore, the project's GHG operational emissions are considered to be less than significant.
Table VIII-2
OPENING YEAR UNMITIGATED PROJECT-RELATED GREENHOUSE GAS EMISSIONS
Category
Greenhouse Gas Emissions (Metric Tons/Year)1
Bio-CO2 NonBio-CO2 CO2 CH4 N2O CO2e
Area Sources2 0.00 2.46 2.46 0.00 0.00 2.47
Energy Usage3 0.00 295.00 295.00 0.02 0.00 296.00
Mobile Sources4 0.00 973.00 973.00 0.03 0.10 1,004.00
Solid Waste5 10.20 0.00 10.20 1.02 0.00 35.70
Water6 8.91 48.00 56.90 0.92 0.02 86.40
Construction7 0.00 16.53 16.53 0.00 0.00 16.75
Total Emissions 19.11 1,334.99 1,354.09 1.99 0.12 1,441.32
County of Riverside CAP and SCAQMD Draft Screening Threshold 3,000
Exceeds Threshold? No
Notes:
1 Source: CalEEMod Version 2022.1.1.29
2 Area sources consist of GHG emissions from consumer products, architectural coatings, and landscape equipment.
3 Energy usage consist of GHG emissions from electricity and natural gas usage.
4 Mobile sources consist of GHG emissions from vehicles.
5 Solid waste includes the CO2 and CH4 emissions created from the solid waste placed in landfills.
6 Water includes GHG emissions from electricity used for transport of water and processing of wastewater.
7 Construction GHG emissions based on a 30-year amortization rate.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report, Appendix A)
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the
emissions of greenhouse gases? (Less Than Significant Impact)
The proposed project would have the potential to conflict with any applicable plan, policy or regulation of
an agency adopted for the purpose of reducing the emissions of GHGs. As stated previously, both the
County of Riverside and the City of Lake Elsinore have adopted Climate Action Plans; therefore, the project
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and its GHG emissions have been compared to the goals of both the County of Riverside CAP Update as
well as the City of Lake Elsinore CAP.
Consistency with the County of Riverside CAP Update
Per the County’s CAP Update, the County adopted its first CAP in 2015 which set a target to reduce
emissions back to 1990 levels by the year 2020 as recommended in the AB 32 Scoping Plan. Furthermore,
the goals and supporting measures within the County’s CAP Update are proposed to reflect and ensure
compliance with changes in the local and State policies and regulations such as SB 32 and California’s
2017 Climate Change Scoping Plan. Therefore, compliance with the County’s CAP in turn reflects
consistency with the goals of the CARB Scoping Plan, Assembly Bill (AB) 32 and Senate Bill (SB) 32.
Appendix D of the Riverside County CAP Update also states that project's that do not exceed the CAP's
screening threshold of 3,000 MTCO2e per year are considered to have less than significant GHG emissions
and are in compliance with the County's CAP Update. According to the County's CAP Update, projects that
do not exceed emissions of 3,000 MTCO2e per year are also required to include the following efficiency
measures:
• Energy efficiency matching or exceeding the Title 24 requirements in effect as of January 2017, and
• Water conservation measures that match the California Green Building Code in effect as of January
2017.
As stated above, the GHG emissions generated by the proposed project would not exceed the County of
Riverside CAP Update screening threshold of 3,000 metric tons per year of CO2e.
Consistency with the City of Lake Elsinore CAP
The City of Lake Elsinore adopted the City of Lake Elsinore CAP, on December 13, 2011. The Climate
Action Plan provides specific measures to be implemented in new developments to reduce GHG emissions
as well as a GHG emissions reduction target based on a community-wide emissions reduction to 6.6
MTCO2e per service population per year by 2020 and 4.4 MTCO2e per service population per year by
2030.
Appendix D of the CAP contains a project level worksheet that an applicant may use to demonstrate
consistency with the General Plan growth potential and CAP. The following are the criteria for determining
consistency with the CAP:
Is the project consistent with the General Plan land use designation?
The proposed project site is currently designated in the General Plan for General Commercial and High
Density Residential land uses and zoned as C-P, Commercial Park and R-3, High Density Residential. The
project is seeking a General Plan Amendment to Light Industrial and a zone change to C-M, Commercial-
Manufacturing in the City of Lake Elsinore.
The proposed project is to develop the site with multiple commercial manufacturing buildings and uses.
Therefore, the proposed project is anticipated to be consistent with the updated zoning and land uses
specified in the City of Lake Elsinore's General Plan. Therefore, the project meets this criterion.
Is the project consistent with the General Plan population and employment projections for the site, upon
which the CAP modeling is based?
The City of Lake Elsinore General Plan's build-out of population, housing and employment have anticipated
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the development of the Project site as a commercial area with a current land use of General Commercial
over a portion of the site . Therefore, this buildout projection was used in the preparation of the CAP.
Therefore, the project meets this criterion.
Does the project incorporate the following CAP measures as binding and enforceable components of the
project?
Until these measures have been formally adopted by the City and incorporated into applicable codes, the
requirements must be incorporated as mitigation measures applicable to the project (CEQA Guidelines,
Section 15183.5(b)(2)).
Table VIII-3 provides a list of the reduction measures for new non-residential developments included in
CAP Appendix D. Table VIII-3 also provides a project consistency analysis of each measure. Per Table
VIII-3, the Project meets this criterion.
Table VIII-3
CITY OF LAKE ELSINORE CAP GHG REDUCTION MEASURES FOR COMMERCIAL DEVELOPMENT AND
PROJECT CONSISTENCY
Local Measure Measure Description Project Consistency
T-1.2
Pedestrian
Infrastructure
Through the development review process, require the
installation of sidewalks along new and reconstructed streets.
Also require new subdivisions and large developments to
provide sidewalks or paths to internally link all uses where
applicable and provide connections to neighborhood activity
centers, major destinations, and transit facilities contiguous
with the project site; implement through conditions of
approval.
Consistent. The proposed project does not
currently contain any sidewalks/pathways and
the project does not include any new or
reconstructed streets. Sidewalks/pathways are
provided within the project site.
T-1.4 Bicycle
Infrastructure
Through the development review process, require new
development, as applicable, to implement and connect to the
network of Class I, II and III bikeways, trails and safety
features identified in the General Plan, Bike Lane Master
Plan, Trails Master Plan and Western Riverside County Non-
Motorized Transportation plan; implement through
conditions of approval. The City will also continue to pursue
and utilize funding when needed to implement portions of
these plans.
Not Applicable. Per the Lake Elsinore General
Plan Circulation Element, Figure
2.5 Bikeway Plan there are no bikeways or
trails located adjacent to the proposed project
site.
T-1.5 Bicycle
Parking
Through the development review process, enforce the
following short-term and long-term bicycle parking standards
for new non-residential development (consistent with 2010
California Green Building Code [CalGreen], Section
5.106.4), and implement through conditions of approval:
Short-Term Bicycle Parking: If the project is anticipated to
generate visitor traffic, provide permanently anchored
bicycle racks within 200
feet of the visitor entrance, readily visible to passers- by, for
5% of visitor motorized vehicle parking capacity, with a
minimum of one two-bike capacity rack.
Long-Term Bicycle Parking: For buildings with over 10
tenant occupants, provide secure bicycle parking for 5% of
tenant-occupied motorized vehicle parking
capacity, with a minimum of one space.
Not Applicable. The project is not anticipated
to generate visitor traffic and the project is not
forecast to have more than 10 tenants.
T-2.1
Designated
Parking for Fuel-
Efficient Vehicles
Amend the Municipal Code to require that new non-
residential development designate 10% of total parking
spaces for any combination of low-emitting, fuel-efficient
and carpool/vanpool vehicles (consistent with CalGreen Tier
1, Sections A5.106.5.1 and A5.106.5.3), and implement
Consistent. As shown on the project site plan,
the project is consistent with Section 17.18.045
of the County of Riverside Municipal Code and
Table 5.106.5.3.3 of CalGreen in regards to the
number of electric vehicle/vanpool parking
spaces required. The site includes a total of 180
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Local Measure Measure Description Project Consistency
through conditions of approval. Parking stalls shall be
marked ―Clean Air Vehicle.
parking spaces and nine of those parking
spaces are to be electric vehicle charging
stations.
E-1.1 Tree
Planting
Through the development review process, require new
development to plant at minimum one 15-gallon non-
deciduous, umbrella-form tree per 30 linear feet of boundary
length near buildings, per the Municipal Code. Trees shall be
planted in strategic locations around buildings or to shade
pavement in parking lots and streets.
Consistent. This measure is implemented by
the Departments of Planning, Public Works,
and Parks and Recreation through City
ordinance, development review process, and
conditions of approval. The landscape design
proposed for this new commercial development
aims to meet the City of Lake Elsinore
requirements by providing plant material that is
not only diverse in color and texture, but is also
drought tolerant. Refer to the landscaping
description in the Project Description and the
copy of the Landscape Plan. The proposed
project elements would be required to comply
with the City ordinances and conditions of
approval, if applicable.
E-1.2 Cool Roof
Requirements
Amend the City Municipal Code to require new non-
residential development to use roofing materials having solar
reflectance, thermal emittance or Solar Reflectance Index
(SRI) 3 consistent with CalGreen Tier 1 values (Table
A5.106.11.2.1), and implement through conditions of
approval.
Consistent. This measure is implemented by
the Departments of Planning and Building
through City ordinance, development review
process, and conditions of approval. The
proposed Project elements would be required to
comply with the City ordinances and
conditions of approval, if applicable.
E-1.3 Energy
Efficient Building
Standards
Adopt an ordinance requiring that all new construction
exceed the California Energy Code requirements, based on
the 2008 Energy Efficiency Standards by 15% (consistent
with CalGreen Tier 1), through either the performance based
or prescriptive approach described in the California Green
Building Code; implement through conditions of approval.
Alternately, a solar photovoltaic system and/or solar water
heating may be used to assist in meeting all or a portion of
the 15% requirement.
Consistent. The California Green Building
Standards Code (proposed Part 11, Title 24)
was adopted as part of the California Building
Standards Code in the CCR. Part 11 establishes
voluntary standards, that are mandatory in the
2022 edition of the Code, on planning and
design for sustainable site development, energy
efficiency (in excess of the California Energy
Code requirements), water conservation,
material conservation, and internal air
contaminants. The proposed project will be
subject to these mandatory standards.
E-4.1
Landscaping
Through the development review process, enforce the City’s
Assembly Bill 1881 Landscaping Ordinance; implement
through conditions of approval.
Consistent. AB 1881 Landscaping Ordinance
requires that landscaping be water efficient,
thereby consuming less energy and reducing
emissions. The proposed project elements
would be required to comply with these
landscape requirements.
E-4.2 Indoor
Water
Conservation
Requirements
Amend the City's Uniform Building Code to require
development projects to reduce indoor water consumption by
30% (consistent with CalGreen Tier 1, Section
A5.303.2.3.1), and implement through conditions of
approval.
Consistent. The proposed project will utilize
water fixtures that are sold in California that
are required to meet CCR Title 20, Sections
1601 – 1608 that require all water fixtures to be
low flow and provide an average water use
reduction of 30%.
S-1.4
Construction and
Demolition Waste
Diversion
Amend the Municipal Code to require development projects
to divert, recycle or salvage at least 65% of nonhazardous
construction and demolition debris generated at the site by
2020 (consistent with CalGreen Tier 1, Section A5.408.3.1).
Require all construction and demolition projects to be
accompanied by a waste management plan for the project and
a copy of the completed waste management report shall be
provided upon completion.
Consistent. The California Green Building
Standards Code (proposed Part 11, Title 24)
was adopted as part of the California Building
Standards Code in the CCR. Part 11 establishes
voluntary standards, that are mandatory in the
2022 edition of the Code. Section 5.408
requires the recycling and/or salvaging for
reuse of a minimum of 65 percent of the
nonhazardous construction and demolition
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Local Measure Measure Description Project Consistency
waste. The proposed project will be subject to
these mandatory standards.
Notes:
1 Source: City of Lake Elsinore Climate Action Plan
Based on the forecast GHG emissions and this preceding consistency analysis, the proposed project can be
developed with a less than significant impact on GHG emissions.
Mitigation Measures: No mitigation measures are required.
(Sources: Air Quality and GHG Analysis Report, Appendix A)
IX. HAZARDS AND HAZARDOUS MATERIALS
a) Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials? (Less Than Significant With Mitigation Incorporated)
b) 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? (Less Than
Significant With Mitigation Incorporated)
a&b) The Project may create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials; or may 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. During construction there is a potential for accidental release of
petroleum products (fuel and hydraulic fluids) in sufficient quantity to pose a significant hazard to people
and/or the environment. Also, the future tenants will utilize cleaning materials, pesticides and other
chemicals in small quantities in support of storage operations. The following mitigation measure will be
incorporated into the Storm Water Pollution Prevent Plan (SWPPP) prepared for the Project and
implementation of this measure can reduce this potential short-term construction hazard to a less than
significant level.
HAZ-1 All spills or leakage of petroleum products during construction activities will be remediated in
compliance with applicable state and local regulations regarding cleanup and disposal of the
contaminant released. The contaminated waste will be collected and disposed of at an
appropriately licensed disposal or treatment facility. This measure will be incorporated into the
SWPPP and the WQMP prepared for the Project development.
Implementation of measure HAZ-1 and compliance with all Federal, State, and local regulations governing
the storage and use of hazardous materials which is required, will ensure that the Project operates in a
manner that poses no substantial hazards (during both construction and occupancy) to the public or the
environment from such activities. No further mitigation is required.
Mitigation Measures: Mitigation measure HAZ-1 is required.
(Sources: GPEIR, Chapter 3.10, Hazards and Hazardous Materials.)
c) Emit hazardous emissions or handle hazardous materials or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school? (Less Than Significant
Impact)
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The project site is located more than one-quarter mile from a school. The proposed project will not utilize
any acutely hazardous materials on the project site, either to support construction or future operations.
Since implementation of the Project will not emit acute hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste, and implementation of the site for commercial manufacturing
uses would not normally involve any acutely hazardous materials, the potential for exposing a school and
its students to a significant hazard is considered to be less than significant impact. No additional mitigation
is required.
Mitigation Measures: No mitigation required.
(Sources: GPEIR, Chapter 3.10, Hazards and Hazardous Materials.)
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? (No Impact)
The provisions in Government Code Section 65962.5 are commonly referred to as the "Cortese List" (after
the Legislator who authored the legislation that enacted it). The list, or a site's presence on the list, has
bearing on the local permitting process as well as on compliance with CEQA.
According to the California State Waterboards GEOTRACKER site1 which provides information regarding
Leaking Underground Storage Tanks, the Project site is not 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
not create a significant hazard to the public or the environment. There are two permitted underground
storage tanks within one mile of the Project site. Refer to Figure IX-1, Geotracker Site.
The Department of Toxic Substances Control's Hazardous Waste and Substances Site List (Cortese List)
site2 does not show any Hazardous Waste and Substances Sites currently located on the Project sites. Refer
to Figure IX-2, Envirostor Site. Based upon the available data, there is no evidence to support that hazardous
wastes or contamination would be present on the site. No additional mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: Geotracker; GPEIR, Chapter 3.10, Hazards and Hazardous Materials. )
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 for
people residing or working in the project area? (No Impact)
The Project site is located approximately 1.6 miles from an operating private airport, Skylark Airport,
which is located at the southeast corner of Lake Elsinore. As shown on Figure IX-3 Zone D (which
encompasses the project site) has minimal conflicts with the airport operations. The proposed use of two
commercial manufacturing buildings at the project site will have no conflict with the airport operations at
this small private airport. No adverse impacts are anticipated and no mitigation is required.
1 http://geotracker.waterboards.ca.gov/
2 http://www.envirostor.dtsc.ca.gov/public/mapfull.asp?global_id=&x=-
119&y=37&zl=18&ms=640,480&mt=m&findaddress=True&city=32397%20Riverside%20Dr,%20Lake%20
Elsinore,%20CA%2092530&zip=&county=&federal_superfund=true&state_response=true&voluntary_clean
up=true&school_cleanup=true&ca_site=true&tiered_permit=true&evaluation=true&military_evaluation=tru
e&school_investigation=true&operating=true&post_closure=true&non_operating=true
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Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore GPEIR and Land Use map)
f) Impair implementation of or physically interfere with an adopted emergency response plan or
emergency evacuation plan? (Less Than Significant Impact)
According to the City’s General Plan, no evacuation routes have been identified, though effectively I-15,
SR74/Riverside Drive and Grand Avenue could be considered evacuation routes within the City. The
proposed Project will be limited to the project site and is not anticipated to impact any surrounding potential
evacuation route functions on Grand Avenue during construction. The project site is located just north of
Grand Avenue. It is not anticipated that development of the project site would impair implementation of or
physically interfere with an adopted emergency response plan or emergency evacuation plan because the
site activities will be confined within the proposed project site. The proposed onsite parking and circulation
plans will be reviewed by the local Fire Department and City Engineering Department to ensure that the
Project’s ingress/egress are adequate for accommodating emergency vehicles. Therefore, there is a less than
significant potential for the development of the Project to physically interfere with any adopted emergency
response plans, or evacuation plans. No significant impacts are anticipated and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore GPEIR and Circulation Element)
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death
involving wildland fires? (Less Than Significant Impact)
According to the City of Lake Elsinore General Plan, the proposed Project is not located in a high wild fire
hazard zone and is served by the Riverside County Fire Department’s urban fire protection services.
Therefore, Project implementation would not result in a potential to expose people or structures to wildland
fire hazards. Potential Project-related impacts are less than significant; no mitigation measures are required.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan EIR, Public Services)
X. HYDROLOGY AND WATER QUALITY
The data for the following Hydrology and Water Quality evaluation is abstracted from a report titled
“Project Specific Water Quality Management Plan Rome Hill Commerce Park,” dated 1/16/2023 by W.H.
Civil. This Study is used extensively in the following analysis, and it is provided as Appendix E to this
Initial Study. Section 2.2 of the Water Quality Management study provides the background information
regarding the Federal, State and local Regulatory Setting.
a) Violate any water quality standards or waste discharge requirements or otherwise substantially
degrade surface or ground water quality? (Less Than Significant With Mitigation Incorporated)
The proposed project is located within the Santa Ana River Region (Region No. 8), which is governed by
the Santa Ana Regional Water Quality Control Board (RWQCB or Regional Board). The project would be
supplied with water by Elsinore Valley Municipal Water District that uses a mix of groundwater and
imported surface water to meet customer demand. For a developed area, the only three sources of potential
violation of water quality standards or waste discharge requirements are from generation of municipal
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wastewater, stormwater runoff, and potential discharges of pollutants, such as accidental spills. Municipal
wastewater is delivered to the Elsinore Valley Municipal Water District ’s (EVMWD) treatment plant
located in Lake Elsinore. The EVMWD is responsible for the collection, transmission, treatment, and
disposal of wastewater from its member agencies. The Santa Ana Regional Board is responsible for
ensuring the District ’s Water Reclamation Facility complies with waste discharge requirements and in so
doing ensures that future wastewater generated by the proposed project will not degrade downstream water
quality.
To address stormwater and accidental spills within this environment, any new project must ensure that site
development implements a Stormwater Pollution Prevention Plan (SWPPP) (National Pollutant Discharge
Elimination System, (NPDES) requirement) to control potential sources of water pollution that could
violate any standards or discharge requirements during construction, and a Water Quality Management Plan
(Preliminary WQMP, Appendix E) to ensure that project-related stormwater and accidental discharges after
development meets discharge requirements from the property over the long-term. The Preliminary WQMP
specifies stormwater runoff permit Best Management Practices (BMPs) requirements for capturing,
retaining, and treating on-site stormwater once the units have been installed and occupied. The whole lot
will drain to the infiltration basin proposed at the rear of the lot. The proposed will be sized to handle total
water volume generated on-site. Because the project site will consist of a mix of impervious and pervious
surfaces, the project has identified onsite drainage system components (a biofiltration swale and an
underground infiltration system and treatment unit) that will generally be installed as part of the project to
control water quality degradation and to control the volume of stormwater discharges from the developed
site to a level comparable or below the existing condition. Refer to Appendix E. The SWPPP will specify
the specific BMPs that the Project would be required to implement during construction activities to ensure
that all potential water pollutants of concern generated during construction are prevented, minimized, and/or
otherwise appropriately treated prior to being discharged from the subject property in surface runoff. With
implementation of these mandatory Plans (SWPPP and WQMP) and their BMPs, as well as mitigation
measure HAZ-1 above, the development of the Rome Hill Commercial Development is not forecast to
cause a violation of any water quality standards or waste discharge requirements.
Mitigation Measures: Implementation of the SWPPP and WQMP are mandatory and do not require project
specific mitigation. Measure HAZ-1 will be implemented in support of the SWPPP and WQMP.
(Sources: Appendix G and Site Plan)
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge,
such that the project may impede sustainable groundwater management of the basin? (Less Than
Significant Impact)
Implementation of the proposed Project is not forecast to deplete groundwater supplies that would
substantially affect the water availability for existing or planned land uses or biological resources. It is
anticipated that, based on previous studies at the project site, the depth to groundwater is anticipated to be
approximately greater than 36 feet below the ground surface (bgs). Therefore, given that the project does
not require extensive excavation, the potential to intercept the local groundwater table during grading of
the project site is considered to be less than significant. The regional groundwater aquifer would not be
physically altered or impacted as a result of the proposed project. The design of the drainage and retention
facilities of the proposed project (refer to Appendix G) would encourage groundwater recharge.
The Rome Hill Commercial Development Project would be supplied with water by the Elsinore Valley
Municipal Water District (EVMWD) that uses imported surface water and local groundwater to meet
primary customer potable water demand. Using imported surface water helps prevent overdraft of local
groundwater basins. Assuming two Commercial buildings totaling 92,760 SF and associated landscaping,
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the project would require about 15 acre-feet per year. The City General Plan EIR forecasts adequate water
supplies through 2030 as evidenced by the summary provided on Table 3.16-7 of the GPEIR. The total
supply for the District through 2030 is 79,181 acre-feet per year (AFY), while the demand for 2030 is
forecast to be 68,169 AFY. Thus, the anticipated available water supply within EVMWD ’s retail service
area is forecast to be greater than the demand for water in the future, which indicates that the District has
available capacity to serve the proposed project without significant adverse impacts on area groundwater
basins.
While the development of the Project may result in a slight reduction in the amount of surface runoff
recharge associated with future site runoff, this reduction is expected to be off-set/replaced by infiltration
from the onsite infiltration basins, as well as the required onsite landscaping allowing percolation of onsite
rainfall. The development of the project will, therefore, not substantially interrupt the existing percolation
of the site, or any flow of groundwater under the project site. No significant adverse impacts to groundwater
resources are forecast to occur from implementing the proposed Project. No mitigation is required.
Mitigation Measures: No additional mitigation measures are required.
(Sources: Appendix G, Site Plan and the City GPEIR, Chapter 3.16)
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? (Less Than Significant Impact)
The Preliminary WQMP Study (Appendix E) addresses the onsite flows and comparable runoff for post-
developed condition of the Commercial Development project. The site design envisions that sheet flow will
be discharged from the developed portion of the project site to a bio-infiltration swale west of the developed
site. This swale will convey the flows from the developed site to the Underground Infiltration Basin to be
installed at the north end of the project site. Table D.3 of the Study (Appendix G) indicates that the Design
Capture volume of runoff is 13,789 cubic feet and the Basin’s design will accommodate 14,257 cubic feet.
Based on this information, the proposed Rome Hill Commercial Development Project is not forecast to
cause significant downstream erosion or siltation on- or off-site as downstream flows will not be increased.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix G and Site Plan)
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in
flooding on- or offsite? (Less Than Significant Impact)
Refer to the evaluation in Section X.c.i. and Appendix G for an analysis of the project’s impacts on
downstream runoff.
Based on this information, the proposed project is not forecast to result in flooding on- or offsite.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix G and Site Plan)
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; (Less
Than Significant Impact)
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Refer to the evaluation in Section X.c.i. and Appendix G for an analysis of the project’s impacts on
downstream runoff.
Based on this information, the proposed project is not forecast to result in exceeding the capacity of existing
or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix E and Site Plan)
iv. Impede or redirect flood flows? (Less Than Significant Impact)
Refer to the evaluation in Section X.c.i. and Appendix E for an analysis of the project’s impacts on
downstream runoff.
Based on this information, the proposed project is not forecast to result in impeding or redirecting flood
flows.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix G and Site Plan)
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? (No
Impact)
Implementation of the Project has no potential to expose people or structures to a significant risk of
inundation by seiche, tsunami, or other flood hazards. According to the FEMA FIRMette map in Appendix
G, the proposed Project is located outside of any flood hazard area. Furthermore, the Project is located
about 25 miles from the Pacific Ocean, and is separated by the Peninsular Mountain Range from the Ocean.
Therefore, the potential to expose people or structures to a significant risk of flood hazard due to tsunami
would be minimal. Lake Elsinore is located approximately 1,600 feet north of the site and has a water
surface elevation of approximately 1,238 feet Mean Sea Level (MSL). Lake water surface elevations are
1,244 feet MSL and outflow channel elevations are 1,255 feet MSL. The hill located just northwest of the
proposed development acts as a barrier between the site and the lake, with a peak of approximately 1,283
feet above MSL. Further, the proposed development elevations will be approximately 1,268 feet above
MSL. Thus, the potential for a seiche on Lake Elsinore to impact the project site is considered less than
significant. No mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix D, Appendix G, Appendix F, and Site Plan)
e) Conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan? (Less Than Significant Impact)
In 2014, Governor Brown signed into law the Sustainable Groundwater Management Act, also known as
SGMA. The Act took effect in 2015. It requires for the first time in state history that groundwater resources
be sustainably managed by local agencies through the formation of Groundwater Sustainability Agencies
(GSAs) in basins that are deemed high-priority or medium-priority by the State Department of Water
Resources. In such basins, GSAs are required to develop and implement Groundwater Sustainability Plans.”
The groundwater basin underlying the Project is not considered to be a basin that requires immediate
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management under the Sustainable Groundwater Management Act. As such, the Project would not conflict
with a sustainable groundwater management plan. Water consumption and effects in the basin indicate that
the proposed Project’s water demand is considered to be minimal relative to the overall water resources
required to meet the City’s and EVMWD’s overall potable water demands. By controlling water quality
during construction and operations through implementation of both short- (SWPPP) and long- (WQMP)
term best management practices at the site, no potential for conflict or obstruction of the Regional Board’s
Water Quality Control Plan has been identified.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendix G, Site Plan and EVMWD 2020 Urban Water Management Plan )
XI. LAND USE AND PLANNING
a) Physically divide an established community? (No Impact)
Refer to the aerial photo provided as Figure 2, which shows the Project’s site-specific location. The project
site is presently designated on the General Plan as a mix of General Commercial (GC) and High Density
Residential (HDR), with broadly consistent zoning with High Density Residential and Commercial Park
classifications. The project will require a change in land use from the City of Lake Elsinore to Light
Industrial (GP) and Commercial Manufacturing (Zoning). The Project is located within a currently vacant
site. The project site has varying levels of development on three sides: mixed use (industrial and residential)
on the east; industrial and commercial on the south; and industrial, open space and residential on the west.
North of the site is open space transitioning to the southern edge of Lake Elsinore. Either the Commercial
or High Density Residential uses will allow large buildings on the project site (up to three stories) so the
proposed structures that would be built under the proposed land use designation will not substantially
increase building mass on the site. The development of the two buildings at this location would not conflict
with surrounding land uses and the surrounding land use designations and zoning classifications. As noted,
the proposed development will not physically divide an established community. Consequently, the
development of the project site with the proposed uses will not divide any established community in any
manner. Therefore, no significant impacts under this issue are anticipated and no mitigation is necessary.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and GPEIR)
b) 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? (Less Than
Significant Impact)
Based on the project’s entitlements, consistency with the General Plan land use designation and zoning
classification (land use plans) will be achieved if the proposed project is approved. Consistency of the
project design with specific policies or regulations related to avoidance or mitigation of environmental
effects is documented by this IS/MND, which has determined that no significant effects will result from
implementing the proposed project. Finally, it is assumed that through City planning staff acceptance of the
applications for the proposed project and then working with the developer to ensure that the project meets
the City’s design guidelines, the project will be found consistent with City requirements. Based on these
findings, the project implementation will have a less than significant potential to conflict with Plan
elements, policies or regulations adopted to avoid or mitigate an environment effect.
Mitigation Measures: No mitigation measures are required.
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(Sources: City of Lake Elsinore General Plan, the GPEIR, and the LEMC)
XII. MINERAL RESOURCES
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? (No Impact)
The proposed site for the Rome Hill Commercial Development Project is moderately disturbed as it
currently consists of graded and maintained open space land. The site is in an urbanizing area surrounded
by existing and prospective development to the east, south, and west within the City of Lake Elsinore and
adjacent County areas. According to the map prepared for the Lake Elsinore General Plan depicting Mineral
Resources, provided as Figure 3.12-1 of the GPEIR, the Project is not located on a site that contains known
mineral resources of any type. Therefore, the development of the proposed Project is not forecast to cause
any loss of mineral resource values to the region or residents of the state, nor would it result in the loss of
any locally important mineral resources identified on the City’s General Plan. No impacts would occur
under this issue. No mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
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? (No Impact)
Based on the data in the General Plan and GPEIR, no mineral resource recovery site is identified for the
project location; thus, no adverse impact to mineral resources or recovery of such resources will be caused
by project implementation.
Mitigation Measures: No mitigation measures are required.
(Sources: General Plan EIR)
XIII. NOISE
The data for the following Noise impact evaluation is abstracted from a report titled “Rome Hill
Commercial Project Noise Impact Study City of Lake Elsinore, CA,” dated 12/10/2021 by MD Acoustics.
This Study is used extensively in the following analysis, and it is provided as Appendix I to this Initial
Study. Section 2.0 of the Noise Study provides the background information regarding noise fundamentals,
while the national, and state Regulatory Setting is also provided by the Noise Study. The City’s noise
guidelines are summarized below.
City of Lake Elsinore Noise Regulations
The project falls within the City of Lake Elsinore. The City outlines their noise regulations and standards
within the Noise Element from the General Plan and the Noise Ordinance from the Municipal Code. For
purposes of this analysis, the performance standards contained in LEMC Section 17.176 (Noise Control)
are used to evaluate the stationary noise impacts from the proposed project. The project impacts were
compared to the City’s commercial and residential noise standards.
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LEMC Section 17.176 (Noise Control)
Lake Elsinore lays out daytime and nighttime noise limits for an individual operation for residential,
commercial, and industrial zones. These limits must not be exceeded for 30 minutes or more within an hour.
These limits plus 5 dB must not be exceeded for 15 minutes or more within an hour. These limits plus 10
dB must not be exceeded for 5 minutes or more within an hour. These limits plus 15 dB must not be
exceeded for 1 minutes or more within an hour. These limits plus 20 dB must not be exceeded at any time.
If the ambient exceeds these levels, each category must be raised 5 dB.
Table XIII-1
LAKE ELSINORE EXTERIOR NOISE LIMITS
Receiving Land Use Category Time Period Noise Level (dBA)
Single-Family Residential 10:00 p.m. – 7:00 a.m. 40
7:00 a.m. – 10:00 p.m. 50
Multiple Dwelling Residential 10:00 p.m. – 7:00 a.m. 45
7:00 a.m. – 10:00 p.m. 50
Public Space
Limited Commercial and Office 10:00 p.m. – 7:00 a.m. 55
7:00 a.m. – 10:00 p.m. 60
General Commercial 10:00 p.m. – 7:00 a.m. 60
7:00 a.m. – 10:00 p.m. 65
Light Industrial Anytime 70
Heavy Industrial Anytime 75
Construction Noise Regulations
Construction must not occur between the hours of 7 PM and 7 AM or on weekends or holidays. Mobile
equipment operating short-time (10 days or less) and intermittently has a maximum noise level restriction
of 75 dBA at single-family residential areas. Stationary equipment with long-term operation and repetitive
use has a maximum noise level of 60 dBA at single-family residential areas. At commercial properties,
mobile equipment must be 85 dBA or less and stationary equipment must be 75 dBA or less. Construction
vibration must be imperceptible beyond the property line.
Please refer to Section 5 of Appendix I for a discussion of the methods used to measure the existing
background noise environment in the project area.
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 other
applicable standards of other agencies? (Less Than Significant With Mitigation Incorporated)
Existing Noise Environment
One (1) 10-minute ambient noise measurement and one (1) hour and a half measurement were conducted
at the project on 12/3/2021. These noise monitoring locations are illustrated in Figure XIII-1. The
measurement measured the Leq, Lmin, Lmax and other statistical data (e.g. L2, L8) and is presented in
Table s XIII-2 and XIII-3. The noise measurements were taken to determine the existing baseline noise
conditions.
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Table XIII-2
SHORT TERM NOISE MEASUREMENT RESULTS
1. Short-term noise monitoring ST1 is illustrated in Figure XIII-1.
Table XIII-3
LONG-TERM NOISE MEASUREMENT DATA (DBA)1
1. Long-term noise monitoring LT1 is illustrated in Figure XIII-1.
Figure XIII-1: NOISE MEASUREMENT LOCATIONS
The results of the short-term noise data gathering at the site (shown on Figure XIII-1, site “S”) “a” re-
presented in Tables XIII-2. Noise data indicates that ambient noise level was 52.5 dBA Leq at the ST1 site.
Additional field notes and photographs are provided in Appendix A of Appendix I. The L50 limit of 50
dBA was exceeded. The project must therefore not exceed the ambient level.
The results of the long-term noise data are presented on Table XIII-3. The noise data indicates that the
ambient noise level was 68.4 at site ”L” on Figure XIII-1. The L50 limit of 50 dBA, the L25 limit of 55
dBA, the L8 limit of 60 dBA, the L2 limit of 65 dBA, and the Lmax level of 70 dBA are exceeded.
Operational Noise Impacts and Mitigation
This assessment analyzes future noise impacts to and from the project and compares the results to the City’s
Noise Standards. The analysis details the estimated exterior noise levels associated with traffic from
adjacent roadways and from future on-site stationary noise sources.
Due to the location of the proposed loading dock facilities, receptors that may be affected by project
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operational noise include the existing residences to the southeast. The worst-case stationary noise was
modeled using SoundPLAN acoustical modeling software. The model utilizes SoundPLAN’s sound level
data for the loading docks and parking specified within Section 5.4 of this report. Loading activity
constitutes the project’s maximum operational noise levels.
A total of four (4) receptor locations were modeled to evaluate the proposed project’s operational noise
impact to adjacent existing or future noise sensitive land uses. Table XIII-4 demonstrates the project plus
ambient noise levels. Project plus ambient noise level projections are anticipated to range between 53 to 68
dBA Leq at the receptors R1 – R4. In addition, Table XIII-4 provides the anticipated change in noise level
as a result of the proposed project during daytime operating conditions. The levels are not anticipated to
increase as a result of the project; however, the Noise study recommends implementation of mitigation
measure NOI-1. The impact is therefore less than significant with implementation of NOI-1 .
Table XIII-4
WORST-CASE PREDICTED OPERATIONAL NOISE LEVELS (DBA)
Notes:
1. Receptor locations in Exhibit F. R1 to R3 are industrial.
2. The measured ambient Leq .
3. Residential uses are acceptable up to 50 dBA Leq during the day.
Noise Impacts to On/Off-Site Receptors Due to Project Generated Traffic
The project would generate 184 daily passenger car equivalent trips of which an estimated 18 would occur
in the AM peak hour and 19 would occur in the PM peak hour. Per the memo provided by TJW Engineering,
Inc., 12/2/2021 (Rome Hill Commercial Trip Generation Analysis and VMT Screening), see Appendix B.
This equates to approximately one passenger car equivalent trip every three minutes in the PM peak hour
and would not result in a substantial increase in traffic noise.
Traffic along the subject roadways would need to double in average daily traffic volumes to generate a 3
dBA increase in noise level. Since the project generates a nominal amount of traffic relative to the existing
ADTs, the project’s traffic noise level increase would be nominal and therefore less than significant.
Mitigation Measures:
NOI-1 The following noise reduction measures have been implemented into the plan:
• All roof-top exterior equipment will be shielded from view with solid parapets that are taller
than the equipment constructed with a surface weight of at least 4.2 lb/ft2.
• A 6 foot wall with a surface weight of at least 4.2 lb/ft2 will surround the site.
(Sources: Appendix G)
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Construction Noise Impacts
The degree of construction noise may vary for different areas of the project site and also vary depending
on the construction activities. Noise levels associated with the construction will vary with the different
phases of construction. The Federal Environmental Protection Agency (EPA) has compiled data regarding
the noise generated characteristics of typical construction activities. The data is presented in Table XIII-5.
Table XIII-5
TYPICAL CONSTRUCTION EQUIPMENT NOISE LEVELS
Equipment Powered by Internal Combustion Engines
Construction is considered a short-term impact and would be considered significant if construction activities
are taken outside the allowable times as described in the LEMC Section 7.34.060. Project construction is
anticipated to occur during the permissible hours according to the LEMC. Construction noise will have a
temporary or periodic increase in the ambient noise level above the existing within the project vicinity.
Furthermore, noise reduction measures are provided to further reduce construction noise. Typical operating
cycles for these types of construction equipment may involve one or two minutes of full power operation
followed by three to four minutes at lower power settings. The loudest piece of mobile equipment (a
bulldozer) is anticipated to be 85 dBA at 50 ft from the source. At 70 ft, which is the distance from the
nearest proposed building to 10 ft within the residential property line, the Lmax level would be 82 dBA.
An 8’ temporary barrier is required along the residential property line to bring the level to 73 dBA, which
is below the mobile equipment construction noise limit of 75 dBA.
The loudest piece of stationary equipment (a generator) is anticipated to be 82 dBA at 50 feet from the
source. At 225 feet with the 8 foot temporary barrier, a generator is anticipated to be 60 dBA. In order to
meet the stationary noise limit of 60 dBA, stationary equipment must be staged as far away from the existing
residential properties as possible. To meet the construction noise limits, construction will operate between
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the hours of 7 AM and 7 PM on weekdays. Stationary equipment will be staged as far away from the
existing residential properties as possible, and there will be an 8-foot wall surrounding the existing
residential property lines. By implementing the two mitigation measures, NOI-2 and NOI-3, as identified
below, construction noise levels can be controlled to a less tan significant impact.
Mitigation Measures:
NOI-2 During construction an 8-foot high temporary noise barrier shall be installed along the
residential property line.
NOI-3 During construction noisy stationary equipment, such as generators, shall be staged as far away
from the existing residential properties as possible.
(Sources: Appendix I)
b) Generation of excessive ground-borne vibration or ground-borne noise levels? (Less Than
Significant Impact)
Ground-Bourne Vibration Fundamentals: Vibration Descriptors
Ground-borne vibrations consist of rapidly fluctuating motions within the ground that have an average
motion of zero. The effects of ground-borne vibrations typically only cause a nuisance to people, but at
extreme vibration levels, damage to buildings may occur. Although ground-borne vibration can be felt
outdoors, it is typically only an annoyance to people indoors where the associated effects of the shaking of
a building can be notable. Ground-borne noise is an effect of ground-borne vibration and only exists indoors
since it is produced from noise radiated from the motion of the walls and floors of a room and may also
consist of the rattling of windows or dishes on shelves.
Several different methods are used to quantify vibration amplitude:
PPV – Known as the peak particle velocity (PPV) which is the maximum instantaneous peak in vibration
velocity, typically given in inches per second.
RMS – Known as root mean squared (RMS) can be used to denote vibration amplitude
VdB – A commonly used abbreviation to describe the vibration level
Vibration Perception
Typically, developed areas are continuously affected by vibration velocities of 50 VdB or lower. These
continuous vibrations are not noticeable to humans whose threshold of perception is around 65 VdB.
Outdoor sources that may produce perceptible vibrations are usually caused by construction equipment,
steel-wheeled trains, and traffic on rough roads, while smooth roads rarely produce perceptible ground-
borne noise or vibration. To counter the effects of ground-borne vibration, the Federal Transit
Administration (FTA) has published guidance relative to vibration impacts. According to the FTA, fragile
buildings can be exposed to ground-borne vibration levels of 0.3 inches per second without experiencing
structural damage.
Vibration Propagation
There are three main types of vibration propagation: surface, compression, and shear waves. Surface waves,
or Rayleigh waves, travel along the ground’s surface. These waves carry most of their energy along an
expanding circular wavefront, similar to ripples produced by throwing a rock into a pool of water. P-waves,
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or compression waves, are body waves that carry their energy along an expanding spherical wavefront. The
particle motion in these waves is longitudinal (i.e., in a “push-pull” fashion). P-waves are analogous to
airborne sound waves. S-waves, or shear waves, are also body waves that carry energy along an expanding
spherical wavefront. However, unlike P-waves, the particle motion is transverse, or side-to-side and
perpendicular to the direction of propagation.
As vibration waves propagate from a source, the vibration energy decreases in a logarithmic nature and the
vibration levels typically decrease by 6 VdB per doubling of the distance from the vibration source. As
stated above, this drop-off rate can vary greatly depending on the soil but has been shown to be effective
enough for screening purposes, in order to identify potential vibration impacts that may need to be studied
through actual field tests.
Construction Vibration
Construction activities can produce vibration that may be felt by adjacent land uses. The construction of
the proposed project would not require the use of equipment such as pile drivers, which are known to
generate substantial construction vibration levels. The primary vibration source during construction may be
from a bulldozer. A large bulldozer has a vibration impact of 0.089 inches per second peak particle velocity
(PPV) at 25 feet which is likely perceptible but below any risk to architectural damage.
The fundamental equation used to calculate vibration propagation through average soil conditions and
distance is as follows:
PPVequipment = PPV ref(25/Drec)n
Where PPVref – reference PPV at 25 feet
Drec = distance from equipment to receiver in feet
n = 1.5 (the value related to the attenuation rate through ground)
The thresholds from the Caltrans Transportation and Construction Induced Vibration Guidance Manual in
Table XIII-6 provides general thresholds and guidelines as to the vibration damage potential from vibratory
impacts.
Table XIII-6
GUIDELINE VIBRATION DAMAGE POTENTIAL THRESHOLD CRITERIA
Source: Table 19, Transportation and Construction Vibration Guidance Manual, Caltrans, Sept. 2013.
Note: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include
impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory compaction equipment.
Table XIII-7 gives the approximate vibration levels for particular construction activities. These data
provide a reasonable estimate for a wide range of soil conditions.
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Table XIII-7
VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT1
At a distance of 70 feet, a large bulldozer would yield a worst-case 0.019 PPV (in/sec) which is below any
risk of damage and likely imperceptible. Thus, the potential vibration impact is less than significant, and
no mitigation is required.
Mitigation Measures: No mitigation measures are required
(Sources: Appendix G )
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where
such a plan has not been adopted, within two miles of a public airport or public use airport, would the
project expose people residing or working in the project area to excessive noise levels? (No Impact)
According to the City General Plan, the only airport within the City is the Skylark Airport (private) located
on the southeast side of the Lake, less than one mile southeast of the project site. Based on the City General
Plan Update EIR, the Airport does not have any noise contours extending off of the Airport itself. Based
on the limited operations at this private airport, future employees at the project site will not be exposed to
excessive airport noise levels. No mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
XIV. POPULATION AND HOUSING
a) 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)? (Less Than Significant Impact)
The proposed Rome Hill Commercial Project would convert vacant land located within the City of Lake
Elsinore that is currently designated for commercial and high density residential land uses. The project
requires a GPA to Light Industrial and a zone change to C-P, Commercial Manufacturing in order to allow
the proposed development. The proposed building square footage totals approximately 92,000 SF.
Assuming two (2) employees per 5,000 SF, a maximum of 18 to 20 persons could be employed at the project
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site. It is not known whether these employees will be new to the City or whether they will live within the
City. The Southern California Association of Government (SCAG) 2019 Local Profile for the City of Lake
Elsinore indicates that the 2019 population was estimated at 69,800. The SCAG Demographic and Growth
Forecast projects an estimated City population of 90,740 by the year 2035. Thus, the forecast growth
through 2035 would readily accommodate the forecast number of potential employees generated by the
proposed project. Further, the proposed project will not provide or expand housing resources in the City
and no extensions of public infrastructure will be caused by the proposed project. Therefore, the project is
not forecast to induce any substantial population growth in the City or surrounding area. No significant
impact would occur under this issue and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR; and Connect SoCal 2024, Demographics and
Growth Forecast Technical Report)
b) Displace substantial numbers of existing people or housing, necessitating the construction of
replacement housing elsewhere? (No Impact)
No occupied residences/homes are located on the vacant project site; therefore, implementation of the
proposed project will not displace substantial numbers of existing housing, necessitating the construction
of replacement housing elsewhere. No impacts will occur; therefore, no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR; site visits)
XV. PUBLIC SERVICES
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:
a) Fire protection? (Less Than Significant Impact)
The proposed project site is served by Riverside County Fire Department and California Department of
Forestry. Fire protection and emergency response services are provided from Station No. 85, which is
located at 29405 Grand Avenue. According to the GPEIR, the goals and policies and implementation
programs identified in the General Plan are sufficient to ensure adequate fire protection services as
development under the GP continues. However, it is primarily through the payment of Development Impact
Fees (DIF fees) as a standard condition of approval, the proposed project’s incremental impacts to
Fire/Emergency response would be less than significant. Further, the City Fire Department has reviewed
this project (3/18/25) to ensure that adequate access for emergency vehicles and adequate fire flow will
occur at the project site. The project will connect to the existing 12 inch water line in Grand Avenue which
will provide adequate fire flow to the future development.
The proposed project will incrementally add to the existing demand for fire protection services. Cumulative
fire protection impacts are mitigated through the payment of the Development Impact Fee (DIF), which
contains a Fire Facilities component. There is no identified near term need to expand facilities in a manner
that could have adverse impacts on the environment, but implementation of the GP policies and programs
ensure that impacts from expanding facilities as needed are sufficient to control new facility impacts to a
less than significant impact level. The City’s General Fund covers operational expenses for fire protection,
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and the proposed project will contribute property taxes to the general fund to offset its incremental demand
for fire protection services. Any impacts are considered less than significant and no additional mitigation
is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
b) Police protection? (Less Than Significant Impact)
Police protection services are provided by the Riverside County Sheriff’s Department from its station in
Lake Elsinore. According to the City General Plan EIR, law enforcement protection for the City at buildout
should be feasible based on incremental expansion of the number of officers, with perhaps some additional
office space at the police station at 333 W. Limited Avenue. The project site is located within existing patrol
routes and future calls can be responded to within the identified priority call target response times.
The proposed project will incrementally add to the existing demand for police protection services.
According to the City General Plan EIR, these incremental impacts are mitigated through the
implementation of State laws and local ordinances; Policy 1.6 of the Community Form chapter, Land Use
section; Policies 8.1 through 8.4 under Goal 8 of the Community Facilities and Protection Services section
of the Public Safety and Welfare chapter; and Goals 9 through 11 and associated policies of the same
Community Facilities section. As part of the City’s review process of the proposed project, each of these
significance criteria are evaluated and determinations made regarding compliance with these policies
verified. The City’s General Fund covers operational expenses. The Project will contribute new property
taxes to the General Fund to offset this incremental demand for police protection services. Any impacts are
considered less than significant and no additional mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
c) Schools? (No Impact)
The proposed Project would develop a commercial manufacturing project, and would not generate any
direct, new student demand for education services. The Lake Elsinore Unified School District (District)
requires a mitigation payment per square foot of commercial and industrial development. The development
impact fee mitigation program of the District is presumed by State law to adequately provide for mitigating
the impacts of the proposed Project. Since this is a mandatory requirement, no additional mitigation
measures are required achieve a no impact finding.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
d) Parks? (Less Than Significant Impact)
Park services are provided by the City and when a project increases demand for park and recreation services,
it is required to pay the applicable Park Capital Improvement Fund Fees. The nearest park to the project
site appears to be located east of Ontario Way about ½ mile east of the project site. The General Plan
concluded that through payment of this fee as a standard condition of approval, the proposed project’s
incremental impacts to park services would be less than significant. Thus, impacts will remain less than
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significant with no mitigation.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR, Chapter 3.15)
e) Other public services/facilities? (No Impact)
According to the City General Plan, the City also supports library and animal control services. The proposed
project will not create any direct demand on these services. Regardless, any incremental impacts are
mitigated through the payment of the DIF. Payment of DIF is deemed adequate mitigation for the proposed
project as it will offset potential future demand generated by potential new employees that choose to locate
within the City. Any impacts are considered less than significant and no additional mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
XVI. RECREATION:
a) Would the project increase the use of existing neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated? (No
Impact)
b) Does the project include recreational facilities or require the construction or expansion of recreational
facilities which might have an adverse physical effect on the environment? (No Impact)
The proposed Project will develop a commercial manufacturing project that is not forecast to significantly
increase the local population or related demand for recreational resources. Therefore, no adverse impact to
existing recreational resources will occur nor will there be a requirement to expand such resources. No
adverse impact is forecast and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
XVII. TRANSPORTATION
The data for the following Transportation/Traffic impact evaluation is abstracted from two reports titled
“Exhibit B Scoping Agreement For Traffic Impact Study” and “Rome Hill Commercial VMT Screening,
City of Lake Elsinore,” dated 1/2/2024 by TJW Engineering, Inc. These Studies are used extensively in the
following analysis, and they are provided as Appendices H1 and H2 to this Initial Study.
a) Conflict with a program plan, ordinance or policy addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities? (Less Than Significant Impact)
The Project proposes to develop a 92,760 two-building commercial manufacturing facility on the project
site. The Project will take access via Grand Avenue and a private driveway along the east side of the
property. It is anticipated that the Project will be developed in two phases with an anticipated Opening Year
of 2026. The preliminary Project site plan is presented at Figure 3. In order to develop traffic estimates for
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the proposed Project, trip-generation statistics published by the Institute of Transportation Engineers (ITE)
in their Trip Generation Manual (11th Edition, 2021) for the warehouse category (ITE Land Use Code 150)
land use category have been used. The Project is estimated to generate 184 two-way trips per day with a
maximum of 18 AM peak hour trips and 19 PM peak hour trips. Refer to Table XVII-1 for this information.
Table XVII-1
TRIP GENERATION
Notes: ITE Trip Generation (11th Edition, 2021); TSF=Thousand Square Feet
Based on the City of Lake Elsinore Traffic Impact Analysis Guidelines (June 2020 and amended May 2022),
the proposed project generates less than 50 peak hour trips and does not require a Traffic Impact Analysis
(TIA) that includes a Level of Service Analysis. Consistent with the City Guidelines, the proposed project
does not require additional traffic analysis and will not result in a conflict with a program, plan, ordinance
or policy addressing the roadway circulation system. The project will install appropriate circulation system
improvements for bicycle and pedestrian facilities and will not conflict with any transit operations.
Potential impacts under this issue are less than significant with no mitigation.
Mitigation Measures: No mitigation measures are required.
(Sources: Appendices H1 and H2)
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision
(b)? (Less Than Significant Impact)
Senate Bill 743 (Section 15064.3 (b))mandates that California Environmental Quality Act (CEQA)
guidelines be amended to provide an alternative to Level of Service for evaluating transportation impacts.
The amended CEQA guidelines, specifically Section 15064.3, recommend the use of Vehicle Miles
Traveled (VMT) for transportation impact evaluation. For the purposes of this analysis the recommended
VMT analysis methodology and thresholds identified within the Technical Advisory and the City’s new
analysis methodology have been used.
The City’s Guidelines indicate residential and office projects located within a low VMT-generating area
may be presumed to have a less than significant impact. In addition, other employment-related land use
projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per
service population that is similar to the existing land uses in the low VMT area. For this screening, the
WRCOG screening tool was used to determine low VMT-generating areas. The proposed project is located
within a low VMT-generating area (see attached). In addition, the proposed project can be reasonably
expected to generate VMT per service population similar to the existing land uses within the low VMT area
such as the manufacturing/warehousing/industrial buildings along Grand Avenue and the surrounding area.
As such, the proposed project can be presumed to have a less than significant impact on VMT and can be
screened from VMT analysis. Consistent with the City guidelines, the proposed project does not require
additional VMT analysis. Refer to Figure XVII-1 for the analysis. Based on this information, the proposed
Project does not require additional traffic or VMT analysis and is screened out. Thus, the proposed Project
will not have a significant impact on regional VMT.
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Figure XVII-1: VMT Part 1
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Figure XVII-1: VMT Part 2
Mitigation Measures: No mitigation measures are required.
(Sources: Appendices H1 and H2)
Design of driveways, internal roadways, and intersections will be based on City Code, which sets the
standard for such design. As such the Project will construct the project access driveways in accordance with
designs shown in Figure XVII-1. Based on these direct project design improvements in the circulation
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system, it is not anticipated that traffic hazards will increase. As such, the Project development would have
a less than significant potential to increase hazards due to geometric design features or incompatible uses.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment)? (No Impact)
All proposed new roads are consistent with the City’s General Plan Circulation Element. Thus, the proposed
project has no potential to increase hazards due to a geometric design feature or an incompatible use at this
location. No mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City General Plan and Site Plan Figure 3)
d) Result in inadequate emergency access? (Less Than Significant Impact)
The proposed project will have minor effects on the circulation system during construction, but any
encroachment into the roadways will be required to implement traffic controls to protect adequate access.
Project access will be designed in accordance with all applicable design and safety standards required by
adopted fire codes, safety codes, and building codes established by the City’s Engineering and Fire
Departments. During construction, only adjacent roadways will be impacted and the adjacent roadway does
not provide essential access to any areas at present. The parking lots and site layouts will be designed to
meet requirements to allow emergency vehicles adequate access. The design of the proposed project will
be reviewed by the Fire Department to ensure that adequate emergency access is provided. Therefore, the
proposed Project will have a less than significant potential to result in inadequate emergency access.
Mitigation Measures: No mitigation measures are required.
(Sources: City General Plan and Site Plan Figure 3)
XVIII. TRIBAL CULTURAL RESOURCES
a) 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). (Less Than Significant With
Mitigation Incorporated)
b) A resource determined by the lead agency, in its discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In
applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency
shall consider the significance of the resource to a California Native American tribe. (Less Than Significant
With Mitigation Incorporated)
Changes in the California Environmental Quality Act, effective July 2015, require that the City address a
new category of cultural resources – tribal cultural resources – not previously included within the law’s
purview. Tribal Cultural Resources are those resources with inherent tribal values that are difficult to
identify through the same means as historical or archaeological resources. These resources can be identified
and understood only through direct consultation with the tribes who attach tribal value to the resource.
Tribal cultural resources may include Native American archaeological sites, but they may also include other
types of resources such as cultural landscapes or sacred places. The appropriate treatment of tribal cultural
resources is determined through consultation with tribes.
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Changes in the California Environmental Quality Act, effective July 2015, require that the City address a
new category of cultural resources – tribal cultural resources – not previously included within the law’s
purview. Tribal Cultural Resources are those resources with inherent tribal values that are difficult to
identify through the same means as historical or archaeological resources. These resources can be identified
and understood only through direct consultation with the tribes that attach tribal value to the resource.
Tribal cultural resources may include Native American archaeological sites, but they may also include other
types of resources such as cultural landscapes or sacred places. The appropriate treatment of tribal cultural
resources is determined through consultation with tribes.
Assembly Bill 52 (AB52), signed into law in 2014, amended CEQA and established new requirements for
tribal notification and consultation. AB 52 applies to all projects for which a notice of preparation or notice
of intent to adopt a negative declaration/mitigated negative declaration is issued after July 1, 2015. AB 52
also broadly defines a new resource category of tribal cultural resources and establishes a more robust
process for meaningful consultation that includes:
• Prescribed notification and response timelines;
• Consultation on alternatives, resource identification, significance determinations, impact
evaluation, and mitigation measures; and
• Documentation of all consultation efforts to support CEQA findings.
A tribe must submit a written request to the relevant lead agency if it wishes to be notified of projects within
its traditionally and culturally affiliated area. The lead agency must provide written, formal notification to
the tribes that have requested it within 14 days of determining that a project application is complete or
deciding to undertake a project. The tribe must respond to the lead agency within 30 days of receipt of the
notification if it wishes to engage in consultation on the project, and the lead agency must begin the
consultation process within 30 days of receiving the request for consultation. Consultation concludes when
either (1) the parties agree to mitigation measures to avoid a significant effect, if one exists, on a tribal
cultural resource, or (2) a party, acting in good faith and after reasonable effort, concludes that mutual
agreement cannot be reached. AB 52 also addresses confidentiality during tribal consultation per Public
Resources Code Section 21082.3(c).
On March 8, 2024, the City provided written notification of the project in accordance with AB 52 to six (6)
Native American tribes that requested to receive such notification from the City. Of the tribes notified, the
Rincon Band of Luiseño Indians, Pechanga Band of Indians, and Soboba Band of Luiseño Indians requested
formal government-to-government consultation under AB 52. As a result, the following consultations
occurred:
• Rincon Band of Luiseño Indians: The City held consultation meetings with the Rincon Band of
Luiseño Indians on May 9, 2024 and July 23, 2025. As part of the consultation, the Rincon of
Luiseño Indians did not identify potential TCRs within the project’s potential impact limits.
However, the Rincon Band of Luiseño Indians did indicate a concern over the potential for
uncovering TCRs or other tribal-affiliated resources during construction of the project. In response,
City Planning staff provided the Rincon Band of Luiseño Indians with recommended mitigation
measures for review to address the potential for subsurface TCRs on the project site. The mitigation
measures agreed to by the various tribes that were consulted are provided in CUL-1 through CUL-
7 in Item V. The Rincon Band of Luiseño Indians indicated that they were in agreement with the
identified mitigation measures and acknowledged that the Pechanga Band of Indians and Soboba
Band of Luiseño Indians would be the monitoring tribes for the project, and the AB 52 consultation
process was concluded on July 31, 2025.
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• Soboba Band of Luiseño Indians: The City held consultation meetings with the Soboba Band of
Luiseño Indians on June 24, 2024, December 19, 2024, April 17, 2025, July 2, 2025, August 14,
2025, and August 21, 2025. As part of the consultation, the Soboba Band of Luiseño Indians did
not identify potential TCRs within the project’s potential impact limits. However, the Soboba Band
of Luiseño Indians did indicate a concern over the potential for uncovering TCRs or other tribal-
affiliated resources during construction of the project. In response, City Planning staff provided the
Soboba Band of Luiseño Indians with recommended mitigation measures for review to address the
potential for subsurface TCRs on the project site. The mitigation measures agreed to by the various
tribes that were consulted are provided in CUL-1 through CUL-7 in Item V. The Soboba Band of
Luiseño Indians indicated that they were in agreement with the identified mitigation measures, and
the AB 52 consultation process was concluded on August 29, 2025.
• Pechanga Band of Indians: The City held consultation meetings with the Pechanga Band of Indians
on May 8, 2024, November 15, 2024, December 19, 2024, April 22, 2025, August 14, 2025, and
August 21, 2025. As part of the consultation, the Pechanga Band of Luiseño Indians did not identify
potential TCRs within the project’s potential impact limits. However, the Pechanga Band of Indians
did indicate a concern over the potential for uncovering TCRs or other tribal affiliated resources
during construction of the project. In response, City Planning staff provided the Pechanga Band of
Indians with recommended mitigation measures for review to address the potential for subsurface
TCRs on the project site. The mitigation measures agreed to by the various tribes that were
consulted are provided in CUL-1 through MM CUL-7 in Item V. The AB 52 consultation process
was concluded on August 29, 2025.
Although no specific Tribal Cultural Resources were identified, the consulting tribes expressed concerns
that the project has the potential for unknown TCRs to be discovered during grading and other ground-
disturbing activities. Therefore, MM CUL-1 through MM CUL-7 identified in Items V(b) and V(c), above,
would be implemented to ensure that potential impacts to TCRs pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section 5024.1 would be less than significant.
Mitigation Measures: see CUL-1 through CUL-7 in Item V above.
(Sources: Tribal Consultation)
XIX. UTILITIES AND SERVICE SYSTEMS
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment
or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or
relocation of which could cause significant environmental effects? (Less Than Significant Impact)
Water
Less Than Significant Impact – Water will be provided by the Elsinore Valley Municipal Water District
(EVMWD). Water service is available through a connection to a 12 inch water main located adjacent to
the project site on Grand Avenue. The project would be supplied with water by EVMWD that uses imported
water from the Metropolitan Water District of Southern California (MWD), local groundwater, and recycled
water to meet customer demand. Using imported surface water helps prevent overdraft of local groundwater
basins. As previously stated under Section X, Hydrology and Water Quality, the City’s GPEIR (2011)
identifies sufficient water resources to meet demand in its service area through 2030. The available water
supply within the District’s retail service area is anticipated to be greater than the demand for water in the
future, which indicates that EVMWD has available capacity to serve the proposed commercial project
without requiring the construction of new water facilities beyond those that would be developed within the
project site to serve residences within the project site. Because the proposed project encompasses less than
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100,000 SF of commercial development, the preparation of a Water Supply Assessment (WSA) by is not
required. Therefore, development of the Rome Hill Commercial Development Project would not result in
a significant environmental effect related to the relocation or construction of new or expanded water
facilities. Impacts are less than significant.
Wastewater
Less Than Significant Impact – Wastewater collection will be provided by Elsinore Valley Municipal Water
District (EMWD or District) and the project will connect to the 15 inch sewer main located on the project
site. Municipal wastewater is delivered to one of EVMWD’s four regional water reclamation facilities
which treat wastewater generated for the project site and surrounding area. The District is responsible for
the collection, transmission, treatment, and disposal of wastewater within its service area, which includes
portions of the City of Lake Elsinore and surrounding communities. As such, the project would connect to
the District’s existing wastewater collection system within the property itself. Wastewater management
agencies must ensure that adequate treatment capacity is available for its service area well before the excess
demand is generated, and adequate capacity is maintained at its Regional Water Reclamation Facilities to
ensure treatment and collection capacity are in place before development occurs. Therefore, development
of the proposed project would not result in a significant environmental impact related to the relocation or
construction of new or expanded wastewater facilities. Impacts are less than significant.
Stormwater
Less Than Significant Impact – The surface runoff from the site, nonpoint source storm water runoff, will
be managed in accordance with the SWPPP prepared for site construction and the WQMP over the long-
term, as discussed in the Hydrology and Water Quality Section (Section X) of this Initial Study. Onsite
flows will be collected at the northeast corner of the project site within a large underground infiltration
basin. This system will be designed to capture the increment of additional flow over the natural peak 100-
year flow runoff from the project site. This extra flow will be detained on site and the historic volume will
be discharged to Lake Elsinore in conformance with City of Lake Elsinore and Riverside County MS4
requirements. Therefore, surface water will be adequately managed on site and as such, development of the
Project would not result in a significant environmental effect related to the relocation or construction of
new or expanded stormwater facilities. Impacts are less than significant.
Electric Power
Less Than Significant Impact – Southern California Edison (SCE) will provide electricity to the site and the
power distribution system located adjacent to the site along Grand Avenue will be able to supply sufficient
electricity. The effort to connect to the existing electrical system, and to install electricity connections within
the project site to serve future residents of the proposed Project with electricity is not anticipated to result
in significant impacts, as evidenced by the discussions in preceding sections. The proposed project will
install solar electric systems at the project site in accordance with the current building code requirements.
Therefore, development of the Project would not result in a significant environmental effect related to the
relocation or construction of new or expanded electric power facilities. Impacts are less than significant.
Natural Gas
Less Than Significant Impact – Natural gas will be supplied by Southern California Gas. The site will
connect to the existing natural gas line adjacent to the project site in Grand Avenue. The effort to connect
to the existing gas line within the adjacent roadway, and to install natural gas lines within the project site to
serve future tenants of the proposed Project with natural gas is not anticipated to result in significant
impacts, as evidenced by the discussions in preceding sections. Therefore, development of the Project
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would not result in a significant environmental effect related to the relocation or construction of new or
expanded natural gas facilities. Impacts are less than significant.
Telecommunications
Less Than Significant Impact – Development of the Rome Hill Commercial Development Project would
require a connection to telecommunication services, such as wireless internet service and phone service.
The local service provider is Verizon. This can be accomplished through connection to existing services
that are available to the developer at the project site. Therefore, development of the project would not result
in a significant environmental effect related to the relocation or construction of new or expanded
telecommunications facilities. Impacts are less than significant.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR and Utility Will Serve letters)
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry and multiple dry years? (Less Than Significant Impact)
Please refer to the discussion under Hydrology, Section X(b) above. The Rome Hill Commercial
Development Project is two structure commercial site with approximately 92,700 SF of area. It is
anticipated to demand about 15 AFY of water from EVMWD. The available water supply within the
District’s retail service area is anticipated to be greater than the demand for water in the future, which
indicates that EVMWD has available capacity to serve the proposed project. As such, given that EVMWD’s
evaluation in the City GPEIR and the District’s Urban Water Management Plan (UWMP) indicates that the
water district anticipates ample water supply will be available to serve the project’s daily/annual demand,
including during normal, dry and multiple dry years. Therefore, the project would have sufficient water
supplies available to serve it and reasonably foreseeable future development during normal, dry and
multiple dry years. Impacts under this issue are considered less than significant.
Mitigation Measures: Other than implementing current water management requirements of the District,
no mitigation measures are required.
(Sources: City of Lake Elsinore General Plan, the GPEIR, EVMWD’s UWMP for 2020)
c) Result in a determination by the wastewater treatment provider, which serves or may serve the
project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s
existing commitments? (Less Than Significant Impact)
Municipal wastewater is delivered to the one of EVMWD’s four regional water reclamation facilities which
treat an estimated 20 million gallons of wastewater per day. The District is responsible for the collection,
transmission, treatment, and disposal of wastewater within its service area, which includes portions of the
City of Lake Elsinore, California. Given the available capacities at District wastewater treatment plants, it
is anticipated that the District has available capacity to accommodate the anticipated wastewater generated
from the new commercial development, as discussed under the Hydrology section above, and as such would
generate an estimated 100 gallons of wastewater per employee per day. No new major system upgrades or
expansion will be required for the wastewater system with a 15 inch sewer line available in Grand Avenue
to receive wastewater. Accessing the adjacent wastewater utility system will not result in a significant
impact to the environment from providing wastewater services to the proposed project site and the District
has adequate treatment capacity at its Regional Plants to meet this new demand. Impacts under this issue
are less than significant.
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Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
c) 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? (Less Than Significant
Impact)
d) Comply with federal, state, and local management and reduction statutes and regulations related to
solid waste? (No Impact)
The proposed Project will generate demand for solid waste service system capacity and has a potential to
contribute to potentially significant cumulative demand impacts on the solid waste system. Solid waste
generation at the proposed Project is estimated to be two 10-yard bins per week. Solid waste capacity has
been expanded to provide adequate disposal capacity for cumulative demand over at least the next five
years. Combined with the City’s mandatory source reduction and recycling program, the proposed Project
is not forecast to cause a significant adverse impact to the waste disposal system due to the available
capacities at nearby landfills.
According to the Integrated Waste Management Board Jurisdiction Diversion and Disposal Profile for City
of Lake Elsinore, the following disposal facilities were used by the City most recently (the most recent year
for which data was found): Badlands Disposal Site (Riverside), El Sobrante Sanitary Landfill (Riverside),
Lamb Canyon Disposal Site (Riverside). More than 50% of waste produced within Riverside County is
also disposed of within the County. Descriptions of the primary disposal facilities and their capacity are
summarized below.
El Sobrante Sanitary Landfill is located at 10910 Dawson Canyon Road east of Interstate 15 in the Gavilan
Hills. According to the State of California’s Solid Waste Information System, the landfill is active and
permitted with a projected closure date of January 1, 2051. The site is currently permitted to a capacity of
209,910,000 cubic yards with a remaining capacity of 143,977,170 cubic yards and permitted throughput
of 16,054 tons per day.
Badlands disposal site is located at 31125 Ironwood Ave, Moreno Valley 92373. According to the State of
California’s Solid Waste Information System, the landfill is active and permitted with a projected closure
date of January 1, 2022. The site is currently permitted to a capacity of 34,400,000 cubic yards with a
remaining capacity of 15,748,799 cubic yards and permitted throughput of 4,800 tons per day.
Lamb Canyon disposal site is located on Lamb Canyon Road three miles south of Beaumont 92223.
According to the State of California’s Solid Waste Information System, the landfill is active and permitted
with a projected closure date of April 1, 2029. The site is currently permitted to a capacity of 38,935,653
cubic yards with a remaining capacity of 19,242,950 cubic yards and permitted throughput of 5,000 tons
per day.
Several of the referenced landfills will be permitted to contain greater volumes of waste in the near future.
Any hazardous materials collected on the project site during either construction or operation of the Project
will be transported and disposed of by a permitted and licensed hazardous materials service provider.
Therefore, the Project is expected to comply with all regulations related to solid waste under federal, state,
and local statutes and be served by a landfill(s) with sufficient permitted capacity to accommodate the
Project's solid waste disposal needs. No further mitigation is necessary.
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XX. WILDFIRE
a) Substantially impair an adopted emergency response plan or emergency evacuation plan? (Less
Than Significant Impact)
The project site is located within an area that has mixed designations for wildfire hazards that range from
Moderate to Very High as the area contains a rapid transition from Moderate to Very High wildfire hazards.
The project site exhibits a low to dense fuel load with some trees on the property and non-native grasses
and shrubs. Two fire stations are located near the project site: Stations 11 (Lakeland Village Station) and
51 (El Cariso Station), refer to Figure 3-1, Wildfire Susceptibility in the General Plan. The proposed
development will be limited to the project site and immediately adjacent areas of roadway improvements
on Grand Avenue. The limited roadway adjacent to the project site and the potential for impairing an
emergency response or evacuation plan is minimal. Grand Avenue is the local emergency roadway and the
project construction and ongoing use of this roadway will not be affected by the proposed project. Impacts
are less than significant under this issue and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
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?
(Less Than Significant Impact)
The proposed project site is located on a relatively flat parcel of land; is not subject to significant prevailing
winds that could exacerbate wildfire risks; and has no other special circumstances that would concentrate
pollutant concentrations from a wildfire or to uncontrolled spread of wildfire. In fact, proximity to the Lake
reduces the potential for the uncontrolled spread of wildfire in the area. The land to the south and east has
been developed and the remaining vacant land has a modest to high fuel load. The impact under this issue
is less than significant and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
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? (No Impact)
The proposed project will not install or extend any infrastructure that could exacerbate fire hazards within
the project area or the adjacent wildfire hazard area. No impact is forecast and no mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan, the GPEIR and Figure 2, Aerial Photo)
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? (No Impact)
The proposed project will not create new significant risks, such as downslope or downstream flooding or
landslides, due to drainage system modifications or post-fire slope instability. No impact is forecast and no
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mitigation is required.
Mitigation Measures: No mitigation measures are required.
(Sources: City of Lake Elsinore General Plan and the GPEIR)
V. MANDATORY FINDINGS OF SIGNIFICANCE
The following are Mandatory Findings of Significance in accordance with Section 21083 of CEQA and
Section 15065 of the CEQA Guidelines. The analysis in this Initial Study and the findings reached indicate
that the proposed project can be implemented without causing any new project specific or cumulatively
considerable unavoidable significant adverse environmental impacts. Mitigation is required to control
potential environmental impacts of the proposed project to a less than significant impact level. The
following findings are based on the detailed analysis of the Initial Study of all environmental topics and the
implementation of the mitigation measures identified in the previous text and summarized following this
section.
a) Does the project have the potential to substantially degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop
below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the
number or restrict the range of a rare or endangered plant or animal or eliminate important examples of
the major periods of California history or prehistory? (Less Than Significant With Mitigation Incorporated)
The Project has no potential to cause a significant impact to any biological or cultural resources, with
implementation of mitigation measures. The Project has been identified as having a less than significant
potential to degrade the quality of the natural environment, substantially reduce habitat of a fish or wildlife
species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant
or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal.
The Project requires mitigation to prevent significant biological resource impacts from occurring as a result
of implementation of the Project. Based on the historic disturbance of the site, and its current disturbed
condition, the potential for impacting cultural resources is low. The Cultural Resources Report determined
that no significant archaeological or historical resources of importance were found at the project site, so it
is not anticipated that any resources could be affected by the Project because no significant cultural
resources exist. However, because it is not known what could be unearthed upon any excavation activities,
contingency mitigation measures are provided to ensure that, in the unlikely event that any resources are
found are discovered, they are protected by proper management from any potential significant impacts.
Please see biological and cultural sections of this Initial Study.
b) Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed
in connection with the effects of past projects, the effects of other current projects, and the effects of
probable future projects)? (Less Than Significant With Mitigation Incorporated)
The Project has 18 potential impact categories that are individually limited, but may be cumulatively
considerable. These are: Aesthetics, Agricultural Resources, Air Quality, Biological Resources, Cultural
Resources, Energy, Greenhouse Gases, Hydrology & Water Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing, Public Services, Recreation, Transportation, Tribal Cultural
Resources, Utilities and Service Systems, and Wildfire. Cumulative traffic, air quality, greenhouse gas, etc.
impacts are considered as part of the analysis contained under the related impact category. Only four of the
above issues (Biology, Cultural Resources, Hazards and Noise) require the implementation of mitigation
measures to reduce potential adverse cumulative environmental impacts to a less than significant level and
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ensure that cumulative effects do not become cumulatively considerable. All other environmental issues
were found to have no significant impacts without implementation of mitigation. The potential cumulative
environmental effects of implementing the proposed Project have been determined to be less than
cumulatively considerable and thus, less than significant impacts.
c) Does the project have environmental effects which will cause substantial adverse effects on human
beings, either directly or indirectly? (Less Than Significant With Mitigation Incorporated)
The proposed Project includes activities that have a potential to cause direct substantial adverse effects on
humans. The issues of Air Quality, Geology and Soils, Hazards & Hazardous Materials, Hydrology and
Water Quality, Noise and Wildfire can all have direct impacts on humans, but only Geology and Soils,
Hazards and Noise require the implementation of mitigation measures to reduce potential human impacts
to a less than significant level. All other direct human impact environmental issues were found to have no
significant impacts on humans without implementation of mitigation. The potential for direct human effects
from implementing the proposed Project have been determined to be less than significant.
Conclusion
This document evaluated all CEQA issues contained in the latest Initial Study Checklist form. The
evaluation determined that either no impact or less than significant impacts would be associated with the
issues of Aesthetics, Agriculture and Forestry Resources, Air Quality, Energy, Greenhouse Gases,
Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Population and Housing, Public
Services, Recreation, Transportation, Utilities & Service Systems, and Wildfire. The issues of Biological
Resources, Cultural Resources, Geology & Soils, Hazards & Hazardous Materials, Noise, and Tribal
Cultural Resources, require the implementation of mitigation measures to reduce Project specific and
cumulative impacts to a less than significant level. The required mitigation has been established in this
Initial Study to reduce impacts for these issues to achieve a less than significant impact level.
Based on the evidence and findings in this Initial Study, the City of Lake Elsinore proposes to adopt a
Mitigated Negative Declaration (MND) for the Rome Hill Commercial Development Project. A Notice of
Intent to Adopt a Mitigated Negative Declaration (NOI) will be issued for this project by the City. The
Initial Study and NOI will be circulated for 30 days of public comment. At the end of the 30-day review
period, a final MND package will be prepared and it will be reviewed by the City for possible adoption at
a future public hearing(s), the date for which has yet to be determined. If you or your agency comments on
the MND/NOI for this Project, you will be notified about the meeting date in accordance with the
requirements in Section 21092.5 of CEQA (statute).
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VI. PERSONS AND ORGANIZATIONS CONSULTED
This section identifies those persons who prepared or contributed to the preparation of this
document. This section is prepared in accordance with Section 15129 of the CEQA Guidelines.
City of Lake Elsinore
Damaris Abraham, Director of Community Development
Nancy Huynh, Principal Planner
Tom Dodson & Associates
Tom Dodson, President
Kaitlyn Dodson-Hamilton, Vice President
Applicant’s Legal Counsel
Kelly Alhadeff-Black, Legal
CRM TECH
Nina Gallardo
Tom Tang
Michael Hogan
Ben Kerridge
Geocon West Inc.
Lisa A Battiato, CEG 2316
Joseph J. Vettel, GE 2401
Petrina Zen, PE 87489
Hernandez Environmental Services
Juan Jose Hernandez, Principal Biologist
L & L Environmental
Leslie Nay Irish, CEO
MD Acoustics, LLC
Tyler Klassen, EIT
Rachel Edelman, INCE-USA Sarah Ostergaard, INCE-USA
South Short Testing & Environmental
John P. Frey, EP
TJW Engineering, Inc.
Thomas Wheat, PE, TE, President
David Chew, PTP, Transportation Planner
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VII. REFERENCES
The following documents were used as information sources during preparation of this document.
California Department of Conservation, 2025. California Important Farmland Finder.
https://maps.conservation.ca.gov/dlrp/ciff/ (Accessed 06/21/25)
California State Water Resources Control Board, 2024. GeoTracker.
https://geotracker.waterboards.ca.gov/ (Accessed 06/04/25)
California Department of Forestry and Fire Protection, 2025. Fire Hazard Severity Zone Viewer.
https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/ (Accessed
06/21/25)
California Department of Transportation, 2025. California scenic highways.
https://www.arcgis.com/apps/mapviewer/index.html?layers=f0259b1ad0fe4093a5604c9b838a486
a (Accessed 06/21/25)
CRM TECH, 2022. Update to Phase I Cultural Resource Assessment Rome Hill Commercial Development
Project (APNs 371-150-001 and -002) City of Lake Elsinore, Riverside County, California
(Appendix D)
CRM TECH, 2022. Paleontological Resources Assessment Report Rome Hill Commercial Development
Project Assessor’s Parcel Numbers 371-150-001 and -002 City of Lake Elsinore, Riverside County,
California (Appendix E)
FEMA, 2025. FEMA Flood Map Service Center: Welcome! https://msc.fema.gov/portal/home (Accessed
06/21/25)
Geocon West Inc., 2022. Geotechnical Update Builder’s Max APNs 371-150-001 & 371-150-002 Grand
Avenue at Kathryn Way Lake Elsinore, California (Appendix F)
Hernandez Environmental Services, 2022. General Biological Assessment and Western Riverside County
Multiple Species Habitat Conservation Plan Consistency Analysis for Assessor’s Parcel Numbers
371-150-001 & 371-150-002 (Appendix B)
City of Lake Elsinore, 2025. City of Lake Elsinore Zoning Map [PDF]. https://davis.lake-
elsinore.org/portal/apps/webappviewer/index.html?id=d78b8d4d4fd24df1b864fd0538e83019
(Accessed 06/21/25)
City of Lake Elsinore, 2025. Municipal Code. https://www.codepublishing.com/CA/LakeElsinore/
(Accessed 06/21/25)
City of Lake Elsinore, 2011. City of Lake Elsinore General Plan https://www.lake-elsinore.org/465/Lake-
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MD Acoustics, LLC, 2025. Rome Hill Commercial Project Air Quality, Greenhouse Gas, and Energy
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California, 92530 (Appendix G)
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I)